A - SS-1-Apple Campus 2 Project EIR Response to Comments Document, September 2013
September 2013
FINAL
APPLE CAMPUS 2 PROJECT EIR
RESPONSE TO COMMENTS DOCUMENT
STATE CLEARINGHOUSE NO. 2011082055
ATTACHMENT SS-1
THIS EIR IS SUBJECT TO, AND THE APPLICANT HAS ELECTED TO PROCEED UNDER,
CHAPTER 6.5 (COMMENCING WITH SECTION 21178) OF THE PUBLIC RESOURCES CODE,
WHICH PROVIDES, AMONG OTHER THINGS, THAT ANY JUDICIAL ACTION
CHALLENGING THE CERTIFICATION OF THE EIR OR THE APPROVAL OF THE PROJECT
DESCRIBED IN THE EIR IS SUBJECT TO THE PROCEDURES SET FORTH IN SECTION
21185* TO 21186, INCLUSIVE, OF THE PUBLIC RESOURCES CODE.** A COPY OF
CHAPTER 6.5 (COMMENCING WITH SECTION 21178) OF THE PUBLIC RESOURCES CODE
WAS INCLUDED AS APPENDIX I TO THE DRAFT EIR.
* THIS LANGUAGE IS PROVIDED IN ACCORDANCE WITH SECTION 21187 OF
THE PUBLIC RESOURCES CODE. PLEASE NOTE THAT, AS OF SEPTEMBER 16,
2013, SECTION 21187 REFERS TO “THE PROCEDURES SET FORTH IN SECTION
21178.2 OF THE PUBLIC RESOURCES CODE.” HOWEVER, THERE IS NO
SECTION 21178.2. INSTEAD, THE RELEVANT PROCEDURES ARE SET FORTH
IN SECTION 21185 OF THE PUBLIC RESOURCES CODE.
** PLEASE NOTE THAT, AS OF SEPTEMBER 16, 2013, PUBLIC RESOURCES CODE
SECTION 21185 STATES IN PART THAT “THE ACTION OR PROCEEDING
SHALL BE FILED IN THE COURT OF APPEAL WITH GEOGRAPHIC
JURISDICTION OVER THE PROJECT.” THAT CODE SECTION WAS THE
SUBJECT OF LITIGATION COMMENCED IN THE SUPERIOR COURT OF
ALAMEDA COUNTY (PLANNING & CONSERVATION LEAGUE V. STATE OF
CALIFORNIA, CASE NO. RG12626904). ON JUNE 3, 2013, THE COURT ISSUED
ITS JUDGMENT THAT PUBLIC RESOURCES CODE SECTION 21185,
SUBDIVISION (a)(1) IS FACIALLY UNCONSTITUTIONAL AND VOID BECAUSE
IT RESTRICTS THE ORIGINAL JURISDICTION OF THE SUPREME COURT AND
SUPERIOR COURTS, AS CONFERRED BY ARTICLE VI, SECTION 10 OF THE
CALIFORNIA CONSTITUTION. AT THE TIME OF PUBLICATION OF THIS
RESPONSE TO COMMENTS DOCUMENT, SENATE BILL 743 (PROPOSING
AMENDMENTS TO CHAPTER 6.5 OF THE PUBLIC RESOURCES CODE) HAD
BEEN APPROVED BY BOTH THE STATE SENATE AND THE STATE
ASSEMBLY. THE DEADLINE FOR THE GOVERNOR OF CALIFORNIA TO
APPROVE THE BILL IS OCTOBER 13, 2013. FOR THE MOST CURRENT
VERSION OF CHAPTER 6.5, PLEASE REFER TO http://leginfo.legislature.ca.gov/.
THE STATUS OF SECTION 21185(a)(1) MAY OR MAY NOT CHANGE AFTER
THE PRINTING OF THIS DOCUMENT. INTERESTED PARTIES SHOULD
DETERMINE FOR THEMSELVES THE STATUS OF SECTION 21185(a)(1) WHEN
CONTEMPLATING ANY ACTION INVOLVING CHAPTER 6.5 OF THE PUBLIC
RESOURCES CODE. THE CITY OF CUPERTINO MAKES NO
REPRESENTATIONS ABOUT THE EFFECT OF THIS LITIGATION ON THE
PROVISIONS OF CHAPTER 6.5 OF THE PUBLIC RESOURCES CODE.
September 2013
FINAL
APPLE CAMPUS 2 PROJECT EIR
RESPONSE TO COMMENTS DOCUMENT
STATE CLEARINGHOUSE NO. 2011082055
Submitted to:
City of Cupertino
Community Development Department
10300 Torre Avenue
Cupertino, California 95014
Prepared by:
LSA Associates, Inc.
2215 Fifth Street
Berkeley, California 94710
510.540.7331
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Final\00-Cover-TOC.doc (09/23/13) FINAL i
TABLE OF CONTENTS
I. INTRODUCTION ....................................................................................................................... 1
A. PURPOSE OF THE RESPONSE TO COMMENTS DOCUMENT .................................. 1
B. ENVIRONMENTAL REVIEW PROCESS ....................................................................... 1
C. DOCUMENT ORGANIZATION ...................................................................................... 2
II. LIST OF COMMENTING AGENCIES, ORGANIZATIONS, AND INDIVIDUALS ............. 3
A. ORGANIZATION OF COMMENT LETTERS AND RESPONSES ................................ 3
B. LIST OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS COMMENTING
ON THE DRAFT EIR ........................................................................................................ 3
III. COMMENTS AND RESPONSES ............................................................................................ 11
A. STATE, REGIONAL, AND LOCAL AGENCIES .......................................................... 23
B. ORGANIZATIONS .......................................................................................................... 60
C. INDIVIDUALS ................................................................................................................ 78
D. PUBLIC MEETING COMMENTS ................................................................................ 127
E. COMMENTS FROM INDIVIDUALS ON THE MERITS OF THE PROJECT ........... 132
IV. TEXT REVISIONS ................................................................................................................. 135
APPENDICES
Appendix A: Comment Letters
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRTABLE OF CONTENTS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Final\00-Cover-TOC.doc (09/23/13) FINAL ii
FIGURES AND TABLES
FIGURES
Figure III-4 (Revised): Conceptual Site Plan – August 2013 .......................................................... 25
Figure RTC-1: Visual Simulation: Looking South between Nightingale Avenue
and Peacock Avenue on East Homestead Road ......................................... 27
Figure V.I-3 (Revised): Existing and Proposed Bicycle Facilities ................................................... 32
Figure III-4 (Revised): Conceptual Site Plan – August 2013 ........................................................ 136
Figure III-17a (Revised): Off-Site Street Changes ........................................................................... 145
Figure IV-2 (Revised): Zoning Designations ................................................................................ 148
Figure IV-3 (Revised): Mitigation Measure PLAN-3 ................................................................... 149
Figure V.I-3 (Revised): Existing and Proposed Bicycle Facilities ................................................. 151
TABLES
Table RTC-1: Trips Generated by Select Residences North of East Homestead Road ................. 19
Table RTC-2: Distribution of Trips on Pruneridge Avenue ........................................................... 20
Table RTC-3: Levels of Service for Requested Intersections ........................................................ 29
Table RTC-4: Background AM Off-Ramp Queuing (in feet) ........................................................ 40
Table RTC-5: Caltrain AM Peak Hour Capacity ........................................................................... 48
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service .................................... 51
Table RTC-6: Pruneridge Avenue Peak Hour Roadway Volumes ................................................ 96
Table II-1: Summary of Impacts and Mitigation Measures from the EIR .............................. 137
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service .................................. 152
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Final\1-Introduction.doc (09/23/13) FINAL 1
I. INTRODUCTION
A. PURPOSE OF THE RESPONSE TO COMMENTS DOCUMENT
This document has been prepared to respond to comments received on the Draft Environmental
Impact Report (EIR) prepared for the Apple Campus 2 Project (project). The project is proposed for
an approximately 176-acre site in the City of Cupertino (City). The Draft EIR identifies the potential
environmental consequences associated with implementation of the project. This Response to
Comments (RTC) Document provides responses to comments on the Draft EIR and makes revisions
to the Draft EIR in response to those comments or to clarify, amplify, or make insignificant modifica-
tions to the Draft EIR. This document, together with the Draft EIR, constitutes the Final EIR for the
proposed project.
B. ENVIRONMENTAL REVIEW PROCESS
According to the California Environmental Quality Act (CEQA), lead agencies are required to consult
with public agencies having jurisdiction over a proposed project and to provide the general public
with an opportunity to comment on the Draft EIR.
The City of Cupertino circulated a Notice of Preparation (NOP) on August 19, 2011, notifying
responsible agencies and interested parties that an EIR would be prepared for the project and indicat-
ing the environmental topics anticipated to be addressed. The scoping period, initially planned to end
on September 19, 2011, was extended to October 5, 2011 to allow for further public comment. In
addition, a public scoping session was held on September 8, 2011. Public notices for the scoping
session were mailed to approximately 20,000 households in Cupertino, advertisements were placed in
local newspapers, and the City posted the NOP and scoping session notice on the City’s website.
Notices were also sent to households in Santa Clara and Sunnyvale that are within 1,000 feet of the
project site. Comments received by the City on the NOP and at the public scoping meeting were taken
into account during the preparation of the Draft EIR.
The Draft EIR was made available for public review on June 6, 2013, and distributed to applicable
local, regional, State, and federal agencies. Paper and CD copies of the Draft EIR were available at
the City of Cupertino Community Development Department and a digital version of the document
was available on the City’s website for the project (http://www.cupertino.org/index.aspx?page=1107).
Notice of availability of the Draft EIR was made in several ways. The City sent postcards announcing
the availability of the Draft EIR to all mailing addresses within Cupertino, and to mailing addresses
within 1,000 feet of the project site outside of Cupertino. In addition, in accordance with CEQA, the
City mailed the Notice of Availability to all properties adjacent to the project site, and on-site notices
were also posted on each parcel constituting the project site and at City Hall. The Notice of Availability
was also posted on the City’s main website and the project website. The City also sent emails announc-
ing the availability of the Draft EIR to all persons who had indicated an interest in the project. A press
release was also sent out at the same time.
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRI. INTRODUCTION
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Final\1-Introduction.doc (09/23/13) FINAL 2
The CEQA-mandated 45-day public comment period ended on July 22, 2013. Comments on the Draft
EIR could be submitted in writing to the Community Development Department or posted on the
City’s website for the project. The City also held a public meeting during the comment period, on
June 26, 2013, at which the public was encouraged to make comments. At the meeting, the City
provided: cards for hand-written comments; access to computers, laptops, or other devices for
comments to be posted directly to the City-sponsored website for public comments; and facilities for
oral comments. The City made available more than 200 digital versions of the Draft EIR to attendees
on USB storage devices. The City also handed out, and made available at City Hall, public comment
cards with a “QR” (Quick Response) Code directing interested parties to the City-sponsored website
for public comments. Written comments received on the Draft EIR during the 45-day public comment
period are contained in this RTC Document.
C. DOCUMENT ORGANIZATION
This RTC Document consists of the following chapters:
Chapter I: Introduction. This chapter discusses the purpose and organization of this RTC
Document and how the RTC Document fits into the Final EIR, and summarizes the
environmental review process for the project.
Chapter II: List of Commenting Agencies, Organizations and Individuals. This chapter
contains a list of agencies, organizations, and individuals who submitted written comments
on the Draft EIR during the public review period.
Chapter III: Comments and Responses. This chapter contains a written response for each
comment on environmental issues received during the public review period. Each response
is keyed to the associated comment letter and comment number. Reproductions of all
comment letters received on the Draft EIR are provided in Appendix A.
Chapter IV: Draft EIR Revisions. This chapter contains text revisions to the Draft EIR in
response to comments received and responses provided, or in order to clarify, amplify or
make insignificant modifications to the Draft EIR. Underlined text represents language that
has been added to the Draft EIR; text with strikeout has been deleted from the Draft EIR.
Revisions to figures are also provided, where appropriate.
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Final\2-ListofCommenters.doc (09/23/13) FINAL 3
II. LIST OF COMMENTING AGENCIES, ORGANIZATIONS,
AND INDIVIDUALS
This chapter presents a list of comment letters1 received during the public review period and describes
the organization of the letters and comments that are provided in Chapter III, Comments and
Responses, of this document.
A. ORGANIZATION OF COMMENT LETTERS AND RESPONSES
Comment letters received on the Draft EIR are grouped and coded by the affiliation of the commenter,
as follows: State, regional, and local agencies (A); organizations (B); individuals (C); public meeting
comments (D); and comments from individuals solely on the merits of the project that do not raise
environmental issues (E). Appendix A includes a reproduction of each comment letter received on the
Draft EIR.
The comment letters are numbered consecutively following the A, B, C, D and E designations. The
letters are annotated according to the following code:
A#-# State, Regional, and Local Agencies
B#-# Organizations
C#-# Individuals
D#-# Public Meeting Comments
E#-# Comments from Individuals on the Merits of the Project
The letters are numbered and comments within each letter are numbered consecutively after the
hyphen. For instance, comment A1-3 is the third discrete comment in the first letter submitted by a
State, Regional, or Local Agency. Chapter III includes a written response for each comment on
environmental issues received during the public review period.
B. LIST OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS
COMMENTING ON THE DRAFT EIR
Comments submitted to the City during the public review period are listed on the following pages.
1 “Letters” include paper letters submitted by mail, fax, or email attachment; emails; discrete postings about the Draft
EIR or project on the City’s website; and comment cards submitted during the public meeting on the Draft EIR.
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LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRII. LIST OF COMMENTING AGENCIES, ORGANIZATIONS, AND INDIVIDUALS
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This page intentionally left blank.
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III. COMMENTS AND RESPONSES
Written responses to each comment letter received on the Draft EIR are provided in this chapter.
Letters received during and after the public review period on the Draft EIR are provided in their
entirety. Each letter is immediately followed by responses keyed to the specific comments. The letters
are grouped by the affiliation of the commenter as follows: State, regional, and local agencies (A);
organizations (B); individuals (C); public meeting comments (D); and comments from individuals
solely on the merits of the project that do not raise environmental issues (E).
Please note that some text within the comment letters has not been numbered because it does not raise
environmental issues or relate to the adequacy of the information or analysis within the Draft EIR,
and therefore no response is required.
Text revisions to the Draft EIR made in response to comments received and responses provided, or to
clarify, amplify or make insignificant modifications to the Draft EIR, are included in the responses.
Underlined text represents language that has been added to the Draft EIR; text with strikeout has been
deleted from the Draft EIR. All text revisions are listed in the order in which they would appear in the
Draft EIR (by page number) in Chapter IV, Text Revisions, of this RTC Document.
Many of the comments received on the Draft EIR involve variations of several key issues. In order to
consolidate responses to questions and comments related to these topics, and to address concerns
comprehensively, master responses have been prepared. Master Responses are included for the
following topics and are referenced in subsequent responses, as appropriate.
1. Significant and Unavoidable Impacts
2. Project Merits
3. Mitigation Nexus
4. Nitrogen Deposition
5. Public Access Through Project Site
6. Project Trip Distribution
7. Cut-Through Traffic
8. Adequacy of Transportation Demand Management (TDM) Penalties
9. Monitoring TDM Program
10. Median on East Homestead Road
11. Diverted Trips Due to Pruneridge Avenue Closure
12. Trip Cap
13. Calabazas Creek Trail
14. New Freeway Ramps
15. School Busing Program
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIII. COMMENTS AND RESPONSES
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\3-Responses.doc (09/16/13) FINAL 12
Master Response #1: Significant and Unavoidable Impacts
Certain traffic-related impacts are identified in the Draft EIR as significant and unavoidable even
though feasible mitigation measures are identified that would reduce the impacts to a less-than-
significant level. Several commenters suggest that these significant and unavoidable findings are not
appropriate. Pursuant to CEQA Section 21081(a)(2), the significant and unavoidable conclusion is
appropriate in these cases because implementation of the identified mitigation measures is not within
the responsibility and jurisdiction of the CEQA lead agency, which is the City of Cupertino. For
instance, implementation of Mitigation Measure TRANS-1 (construction of an additional westbound
lane at the intersection of Wolfe Road/I-280 Northbound Ramps) would reduce Impact TRANS-1
(unacceptable operations at the intersection of Wolfe Road/I-280 Northbound Ramps resulting from
project traffic) to a less-than-significant level. Because the I-280 Northbound Ramps are a State
transportation facility under the jurisdiction of the State of California Department of Transportation
(Caltrans), neither the project sponsor nor the City of Cupertino can ensure implementation of
Mitigation Measure TRANS-1. Thus, lacking any assurance that Mitigation Measure TRANS-1 can
and will be implemented by Caltrans, the Draft EIR concludes that Impact TRANS-1 is significant and
unavoidable notwithstanding the City’s and Apple’s commitment to continue to work with the
agencies that have jurisdiction over implementation of Mitigation Measure TRANS-1 and other,
similar measures outside the City’s control.
Pursuant to CEQA Guidelines Section 15126.4, “[m]itigation measures must be fully enforceable
through permit conditions, agreements, or other legally-binding instruments.” (See also CEQA Section
21081.6(b).) Because the City lacks such legally-binding instruments to ensure that Mitigation
Measure TRANS-1 and other mitigation measures outside its responsibility and jurisdiction are fully
enforceable, the City cannot guarantee implementation of such mitigation measures. Therefore,
identifying Impact TRANS-1 (and other impacts for which the identified mitigation measures outside
the jurisdiction of Cupertino) as significant and unavoidable is appropriate.
The identification of these impacts requiring extra-jurisdictional mitigation as significant and unavoid-
able is also consistent with the findings required to be made by lead agencies for each of the signifi-
cant environmental effects identified in an EIR pursuant to CEQA Guidelines Section 15091 and
Public Resources Code Section 21081(a). One of these findings (“Such changes or alterations are
within the responsibility and jurisdiction of another public agency and not the agency making the
finding. Such changes have been adopted by such other agency or can and should be adopted by such
other agency.”) would be made by the City for each of the significant unavoidable impacts for which a
mitigation measure would reduce the impact to a less-than-significant level, but the mitigation measure
is not under the control of the City. The mitigation measures outside the responsibility and jurisdiction
of the City require that Apple fund, help fund, or construct the physical improvements, if and when the
responsible jurisdictions grant necessary approvals for the mitigations. This requirement is incorpo-
rated into the Mitigation Monitoring and Reporting Program for the project.
Some commenters have stated that because certain traffic impacts have been identified as significant
and unavoidable, the City would have no obligation to mitigate these impacts. Such statements are
incorrect. Lead agencies must identify feasible mitigation measures for all significant impacts per
CEQA Sections 21002, 21002.1(a), 21081(a); and CEQA Sections 15091(a), 15021(a)(2), 15126.4(a).
As required by CEQA Sections 21080(a) and (a)(1), “with respect to each significant effect,” the lead
agency must identify “[c]hanges or alterations [that] have been required in, or incorporated into, the
project which will mitigate or avoid” the impact. The lead agency may then explain, if applicable, that
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIII. COMMENTS AND RESPONSES
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\3-Responses.doc (09/16/13) FINAL 13
implementation of the measures is not within its responsibility and jurisdiction and the measures “have
been, or can and should be, adopted by that other agency” (CEQA Section 21081(a)(2)) and/or that the
measures are infeasible (CEQA Section 20181(a)(3)). The lead agency may find that certain impacts
remain significant despite mitigation, but conclude that overriding benefits outweigh these effects
(CEQA Section 20181(b)); however, this finding does not relieve the lead agency of its obligations to
identify feasible mitigation measures under CEQA Section 20181(a).
If the proposed project is approved, the City will require that Apple: (i) work in good faith with the
applicable jurisdictions to permit the identified physical improvements and (ii) fund the estimated
cost identified in the Mitigation Monitoring and Reporting Program for each of the extra-jurisdic-
tional mitigation measures identified in the Draft EIR. These funds will be submitted to the agency
with jurisdiction over each improvement for use in constructing the improvement or an alternate
improvement in the project vicinity that can be demonstrated, to the satisfaction of the City of
Cupertino Director of Public Works, to reduce the identified traffic-related impacts. In addition,
Apple has agreed to collaborate and coordinate with these other jurisdictions to construct and/or fund
the identified mitigations when the jurisdictions approve the measures. Where physical mitigation
measures are feasible but outside of the City’s jurisdiction, the City will continue to monitor the
progress of implementing the mitigation measures and will continue to work with Apple and the other
agencies. In this way, the mitigation measures identified in the Draft EIR are designed to comply with
the requirement of CEQA to mitigate significant impacts to the extent feasible.
Master Response #2: Project Merits
Pursuant to CEQA Guidelines Section 15088, a lead agency is required to evaluate “comments on
environmental issues” received on a Draft EIR. Similarly, pursuant to CEQA Guidelines Section
15132, a Final EIR must provide responses only to “significant environmental points raised in the
review and consultation process.” Accordingly, detailed responses are provided only for comments
received on the Draft EIR that raise issues concerning the “environment.” As defined in CEQA
Section 21060.5, “environment means the physical conditions which exist within the area which will
be affected by a proposed project, including land, air, water, minerals, flora, fauna, noise, objects of
historic or aesthetic significance.”
Economic costs and benefits are outside the scope of environmental issues as defined by CEQA and
need not be evaluated in an EIR. CEQA Guidelines Section 15131 states: “Economic or social effects
of a project shall not be treated as significant effects on the environment. An EIR may trace a chain of
cause and effect from a proposed decision on a project through anticipated economic or social
changes resulting from the project to physical changes caused in turn by the economic or social
changes. The intermediate economic or social changes need not be analyzed in any detail greater than
necessary to trace the chain of cause and effect. The focus of the analysis shall be on the physical
changes.”
Pursuant to CEQA, the Draft EIR is a disclosure document that identifies the significant impacts of
the project, but does not contain conclusions about the merits of the project, including whether the
project is “too big,” whether the project is right for the community, or whether the project should be
approved. Those decisions are made by the City of Cupertino City Council, following consideration
of the recommendations of the Planning Commission. Rather, the Draft EIR evaluates the size of the
project in the context of applicable significance thresholds identified by the City. This evaluation
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includes an assessment of whether the size of the project would create a significant adverse effect on
the physical environment. For instance, if a project building is sufficiently tall that it would block a
public view of a scenic vista, that would be considered a significant impact pursuant to the City’s
significance thresholds, as explained on pages 207 to 211 of the Draft EIR.
Comments conveying support of or opposition to the project, or comments pertaining solely to
economic or social effects of the project, without reference to environmental issues, are included in
this Response to Comments Document, but detailed responses are not provided. However, decision-
makers will take these comments into account when considering project approval even if they do not
relate to environmental issues or the adequacy of the EIR.
Master Response #3: Mitigation Nexus
Pursuant to CEQA Guidelines Section 15126.4, a mitigation measure must be “roughly proportional”
to the impacts of the project, which means that the proposed project is required to pay its fair share of
the cost to mitigate an impact that is caused by other projects in addition to the proposed project.
Several comments suggest mitigation measures that are not directly related to and would not mitigate
a significant project impact. For example, a homeless transition facility would not be warranted as a
mitigation measure because the project would not result in impacts that would be reduced by the
homeless transition facility. Similarly, mitigation targeting a specific population (e.g., students and
seniors) that is not significantly adversely affected by project impacts is not warranted.
Master Response #4: Nitrogen Deposition
According to the Santa Clara Valley Habitat Plan, atmospheric nitrogen, including atmospheric
nitrogen generated by motor vehicle emissions, is thought to function as an effective fertilizer in
nutrient-poor soils, such as serpentine soils in the Bay Area. The buildup of nitrogen over time is
thought to facilitate the invasion and persistence of non-native species that may out-compete native
species in nutrient-poor plant communities. Several comments suggest that the vehicle trips generated
by the proposed project would make a significant contribution to the cumulative impact of nitrogen
deposition in the Bay Area on nutrient-poor soil communities, including serpentine soil communities
(which harbor protected species such as the Bay checkerspot butterfly). In addition, several comments
suggest that Apple should be required to pay a Nitrogen Deposition Fee, as required by member
agencies of the Santa Clara Valley Habitat Plan.
No Significant Impact Due to Nitrogen Deposition. The project would not make a significant
contribution to the cumulative impact of nitrogen deposition on serpentine habitat or the Bay
checkerspot butterfly for two key reasons.
Although the project would increase the number of regional vehicle trips, these trips would occur at a
distance far removed from the locations of serpentine soils. The project site is located in the midst of
an urbanized area, far from established clusters of serpentine grasslands (e.g., in the Coast Range or
habitat south of San Jose). In Appendix E of the Santa Clara Valley Habitat Plan (Estimation of
Contributions to Deposition of Nitrogen in Santa Clara County for the Santa Clara Valley Habitat
Plan), the simulations for nitrogen deposition in serpentine habitats for the Bay checkerspot butterfly
indicate that almost one-third (30 percent) of the nitrogen deposition derives from mobile emission
sources in the vicinity of the habitat areas, 13 percent of the nitrogen deposition comes from other
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sources within about 12 miles of the habitat areas, and 17 percent of the deposition comes from the
remainder of Santa Clara County. The complete breakdown of simulated nitrogen deposition sources
is shown in Figure E-27 of Appendix E of the Habitat Plan. The project site is located over 20 miles
from the center of serpentine and Bay checkerspot habitat areas in the Bay Area. In addition, as
shown in Table V.C-5, Projected Housing Demand by City Based on Residential Location of Current
Apple Employees, on page 227 of the Draft EIR, the vast majority of Apple employees would live in
places at a distance from serpentine habitat. Therefore, the project would not make a significant
contribution to the cumulative impact of nitrogen deposition in serpentine areas, including those
within the Habitat Plan boundaries.
In addition, as explained on page 134 of the Draft EIR, as part of the project Apple would voluntarily
pay $126,381, an amount equivalent to the Nitrogen Deposition Fee that a project generating 35,106
net new daily trips would pay if it would result in significant impacts related to nitrogen deposition.
In that case, the payment would constitute full mitigation of the impact. However, because the
proposed project is not located within the boundaries of the Santa Clara Valley Habitat Plan, which
established such a fee for its member agencies, and would not create a significant impact due to
nitrogen deposition, the payment by Apple would be voluntary. This amount would be paid to the
Implementing Entity of the Habitat Plan, and is expected to be used to protect and enhance sensitive
habitat in the region that is subject to degradation due to nitrogen deposition. Thus, even if the
contribution of nitrogen from project vehicle trips were considered cumulatively considerable, the
payment of this amount would ensure that such an impact would be less than significant.
Santa Clara Valley Habitat Plan Applicability. As stated in the Habitat Plan, “The purpose of this
Plan is to protect and enhance ecological diversity and function in the greater portion of Santa Clara
County, while allowing appropriate and compatible growth and development in accordance with
applicable laws.” The Habitat Plan, therefore, is designed not only to protect and enhance sensitive
habitats and species within the Habitat Plan area, but also to facilitate development (roads, urban
growth, and other infrastructure) identified by the Habitat Plan participants. The City of Cupertino is
not a Habitat Plan participant and does not receive any of the benefits that come with participation,
including take authorization for listed species associated with covered activities and projects, or
streamlining of permitting processes. Because the project site is located outside the Habitat Plan
boundaries and is not covered by the Habitat Plan, as described above, the project applicant is not
required to pay Habitat Plan development fees, including the Nitrogen Deposition Fee. However, as
discussed above, Apple has voluntarily agreed to pay, in full, an amount equivalent to the Nitrogen
Deposition Fee that the project would have had to pay had there been significant impacts due to
nitrogen deposition.
Master Response #5: Public Access Through Project Site
Retaining Pruneridge Avenue as a public right-of-way was incorporated into a project alternative (the
Pruneridge Avenue alternative), which is analyzed on pages 605 to 612 of the Draft EIR. As
discussed on page 626 of the Draft EIR, two additional alternatives allowing for public access across
the site (a Pruneridge Avenue Tunnel alternative and a Mobility and Park alternative) were rejected
for detailed analysis because they would interfere with major utility lines, would infringe on private
property, result in adverse visual impacts, incur significant costs and/or would still pose significant
security concerns to Apple (thus conflicting with a key project objective).
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Apple maintains that any public access provided within the project site would compromise its privacy
and security objectives. One of Apple’s fundamental project objectives in developing the project is to
consolidate Apple employees in a single secure location to ensure privacy and to promote shared
creativity and collaboration and spur invention. The project’s landscaped area, ancillary spaces, and
buildings would also serve to promote interaction among colleagues. The only way that the outside
and ancillary spaces can play this role is if they are as secure as the main building. Providing
building-by-building security in place of maintaining a secured perimeter would not provide the level
of security Apple desires and thus would conflict with a primary project objective.
Master Response #6: Project Trip Distribution
Some commenters suggested that the anticipated distribution of project trips on the roadway network
should have been determined using alternative methods, including methods that would have distributed
more trips in the immediate vicinity of the project site and on surrounding local and County roadway
facilities.
The trip distribution pattern for the new vehicle trips added to the roadway system by the project is
based on the residence locations of current Apple employees at other Cupertino sites. The assumption
is that employees at the project site would have similar characteristics and therefore similar residence
location preferences. This is a reasonable assumption because: (i) many of the employees at the project
site would be current Apple employees and (ii) the close proximity of the project to current Apple
facilities in Cupertino makes it reasonable to assume that new employees would make similar choices
about where they live. This method of using more localized and specific data (i.e., employee
addresses) to evaluate trip distribution provides a more precise means of analysis than is typical in
transportation impact analyses, which typically rely on general land use/travel patterns.
Relying on general land use/travel patterns and models may be the approach more conventionally
taken in transportation analyses because it is unusual to have fine-grained employee location data of
the kind provided by Apple. However, the use of such data for existing and likely future employees
allows for a more precise transportation analysis that better accounts for the expected commute trips of
employees. This employee location data allows for a more precise analysis, because unlike the general
land use/travel pattern data produced by organizations such as the Association of Bay Area
Governments (ABAG) and Metropolitan Transportation Commission (MTC), the employee location
data in this case is derived from actual Apple employees who are likely to have travel habits similar to
future Apple employees working on the project site.
The impact analysis in the Draft EIR employs a cautious approach in other ways. The transportation
analysis in the Draft EIR assumes that all project traffic would be new traffic added to the roadway
system. However, some of the traffic generated by the project would originate from existing homes in
the area. It is also likely that some future employees currently reside in the area but work elsewhere
and therefore – as part of the project – would modify a portion of their commute trips and would not
generate completely new trips on the roadway system. In addition, employees may purchase or rent
existing homes in the area, in which case they would replace trips generated by current residents of
those homes. Traffic from approved and pending residential developments were added to the
Background and Cumulative scenario traffic projections. Traffic generated by employees residing in
those developments is therefore accounted for twice in the analysis. This approach of using actual
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employee location data ensures that the traffic analysis is as accurate as possible, while not under-
estimating potential impacts on the roadway network.
Master Response #7: Cut-Through Traffic
Several residential streets in the cities of Santa Clara and Sunnyvale are situated near the project site.
The Draft EIR evaluates potential impacts on some of the most direct cut-through streets in the
residential neighborhoods adjacent to the project site, including Quail Avenue, Marion Way, and
Inverness Way in Sunnyvale and Hillsdale Avenue and De Soto Avenue in Santa Clara. Several
comments submitted on the Draft EIR expressed concern about the use of additional residential
streets as cut-through routes. Streets cited in the comments are Dunford Way (known as Marion Way
west of Oriole Avenue), Lochinvar Avenue, Swallow Drive, Peacock Avenue, Nightingale Avenue,
Teal Drive, Lillick Drive, Halford Avenue, Henderson Avenue, and Norman Drive, all of which are
within the City of Sunnyvale. The cut-through analysis conducted for the Draft EIR focuses on
potential cut-through traffic during the AM peak hour, when the volume of project trips would be the
highest. The analysis concluded that (i) given the small number of project trips coming from El
Camino Real (drivers most likely to use cut-through routes in Sunnyvale would come from El
Camino Real) and (ii) the inferiority of many potential cut-through routes to the main arterials and
collectors (in terms of speed of travel or convenience), the impact due to project-related cut-through
traffic would be less than significant. This finding would apply to all residential streets in the vicinity
of the project site, not just the most likely cut-through routes considered in the Draft EIR analysis.
Please refer to pages 430 to 432 of the Draft EIR for additional discussion. The cut-through traffic
evaluation in the Draft EIR focuses on the addition of potential cut-through traffic from the project
and not the diversion of non-project related traffic in the area due to increased congestion. However,
the intersection level of service analysis indicates that the intersections around the project site would
operate at acceptable standards and therefore it is not anticipated that traffic would divert into the
neighborhood to bypass congestion. See page 431 of the Draft EIR for further details.
Although the analysis in the Draft EIR shows that there will not be a significant impact due to cut-
through traffic, the City acknowledges that cut-through traffic is of concern to local residents.
Therefore, as a Condition of Approval, the City would require Apple to set aside funds ($500,000 for
the City of Sunnyvale and $250,000 for the City of Santa Clara) to monitor cut-through traffic and
potentially install traffic calming measures should cut-through traffic-related problems arise due to
implementation of the proposed project. The City of Cupertino would work with the appropriate
jurisdictions to determine the extent of the neighborhood cut-through traffic and to ensure that
neighborhood concerns are addressed. Therefore, impacts related to cut-through traffic (including on
the additional residential streets identified in comments on the Draft EIR) would be less-than-
significant.
Master Response #8: Adequacy of Transportation Demand Management (TDM) Penalties
The City has established TDM penalties that would be assessed if the project exceeds the trip count of
4,270 AM peak-hour vehicle trips and 4,400 PM peak-hour vehicle trips. The TDM penalties are
discussed on pages 445 to 446 of the Draft EIR. The penalties would be assessed every day until trip
count conformance is achieved, and are intended to ensure compliance with Mitigation Measure
TRANS-9b. The fee would be $5/day/trip if Apple does not implement additional TDM measures
determined in consultation with City staff (see page 443 of the Draft EIR for these additional
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measures) and $3/day/trip if additional TDM measures are implemented. (These penalties would be
adjusted based on the Consumer Price Index.)
As an example, if the trip counts are exceeded by 200 vehicles in the AM peak hour and 200 vehicles
in the PM peak hour, and Apple does not agree to implement City-approved TDM measures, the
penalty would be $2,000 per day. Due to the monitoring schedule described on pages 444 to 447 of
the Draft EIR, it would likely take 6 months before conformance could be measured and confirmed.
Therefore, the total penalty would be $260,000 (26 weeks x 5 working days a week x $2,000 a day)
for 6 months of this hypothetical exceedance scenario. Such penalties are robust compared to other
similar TDM-related penalties assessed throughout the Bay Area and are considered sufficient to
ensure compliance with the peak trip counts goal established in Mitigation Measure TRANS-9b.
Master Response #9: Monitoring TDM Program
Ultimate authority for monitoring Apple’s TDM Program would reside with the City. As discussed on
pages 444 through 447 of the Draft EIR, Apple would be responsible for the collection of initial
TDM-related data (identification and description of the specific TDM measures being implemented,
and estimates of AM and PM peak hour vehicle trips and vehicle trips per employee) in accordance
with measurement guidance and monitoring guidelines created by Apple and the City. However, the
effectiveness of Apple’s TDM Program would ultimately be verified with the collection of additional
data (including daily, hourly, and 15-minute traffic counts taken at project driveways and/or parking
facilities over specified 2-week periods) to be undertaken by an independent City-approved planning/
engineering firm. This firm, under the direction of the City, could request additional data from Apple,
or reject the initial data collected by Apple (and substitute a different data set). Therefore, primary
responsibility for monitoring the efficacy of Apple’s TDM program would reside with the City. No
conflict would exist between the TDM Monitoring Report (prepared by an independent firm) and the
initial data collected by Apple because the Apple-collected data could be used at the discretion of the
independent firm preparing the TDM Monitoring Report. Apple would pay for the cost to conduct
monitoring and City staff time to review the annual monitoring reports.
The appropriate entity for the oversight of the monitoring program and making findings of compli-
ance or non-compliance is the City of Cupertino. Because the City is the CEQA lead agency and has
jurisdiction over land use decisions within its borders, it is the correct entity to administer this
program and to ensure that this mitigation measure is implemented and made enforceable. Oversight
by another entity, such as the Santa Clara Valley Transportation Authority (VTA), is not appropriate
or required.
Master Response #10: Median on East Homestead Road
As described on page 102 of the Draft EIR, the proposed project includes the option of a landscaped
median on East Homestead Road between North Wolfe Road and North Tantau Avenue. The purpose
of the median is to provide additional landscaping along the northern edge of the project site as both a
beautification measure and to act as a visual buffer to adjacent residences. The median is not a
requirement nor is it a mitigation measure for the project. Both the cities of Cupertino and Sunnyvale
share jurisdiction of this segment of East Homestead Road. Given the shared jurisdiction, both
agencies would need to approve the final design of the median; therefore Apple would continue to
work with both cities to finalize the design of the median.
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The final design would continue to provide local access (ingress and/or egress) to Nightingale
Avenue and Peacock Avenue. However, if the landscaped median is approved, direct eastbound
access to/from homes on the north side of East Homestead Road would be limited and residents of the
area would be required to make U-turns at designated gaps within the median (at Nightingale Avenue,
Peacock Avenue, and other streets if provided). The limitations on eastbound access would primarily
affect the 22 homes between Nightingale Avenue and Peacock Avenue, and six homes between
Peacock Avenue and Quail Avenue. These homes would generate the following AM and PM peak
hour trips:
Table RTC-1: Trips Generated by Select Residences North of East Homestead Road
Between Nightingale Avenue
and Peacock Avenue
Between Peacock Avenue
and Quail Avenue
Number of homes 22 6
AM peak hour trips (total) 26 14
Inbound (AM peak hour trips) 7 4
Outbound (AM peak hour trips) 19 (highest) 10
PM peak hour trips (total) 27 9
Inbound (PM peak hour trips) 17 6
Outbound (PM peak hour trips) 10 3
Source: Fehr & Peers, 2013.
Thus the greatest number of U-turns that would occur at a given median gap is 19 vehicles for the
AM peak hour for outbound trips west of Peacock Avenue, which would not substantially degrade the
operations of East Homestead Road.
In Sunnyvale’s and Cupertino’s review of the proposed median, design considerations such as the
ability to make U-turns, provision of eastbound left-turn pockets, eastbound refuge lanes, and other
design elements would be evaluated to minimize the accessibility impacts to residents on the north
side of East Homestead Road. As noted above, ultimately both local agencies would need to approve
the final design of the median project.
Master Response #11: Diverted Trips Due to Pruneridge Avenue Closure
With the closure of Pruneridge Avenue, vehicles currently traveling on this roadway between North
Wolfe Road and North Tantau Avenue would detour around the project site. The maximum detour
path along North Wolfe Road, East Homestead Road and North Tantau Avenue is approximately 1.1
miles in length and represents a 0.6-mile detour (1.1 mile new path minus 0.5 mile existing path).
There are generally three types of trips that would be affected by the proposed closure:
1. Through trips with no destination on Pruneridge Avenue between North Wolfe Road and
North Tantau Avenue that would be diverted around the project site;
2. Vehicles currently accessing the project site that would be diverted to the new driveways
on North Wolfe Road and North Tantau Avenue; and
3. Trips associated with The Hamptons apartment community. As discussed on page 430 of
the Draft EIR, travelers to/from The Hamptons that would be significantly affected by the
project are only those that currently travel to/from the east on Pruneridge Avenue.
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For the second type – vehicles currently accessing the project site – it is assumed that their destination
would remain the same and, therefore, they are not considered “diverted” trips. To estimate the
number of affected vehicles for each of the three trip types, Fehr & Peers conducted origin and
destination (OD) surveys1 in August 2011 at the intersections of North Wolfe Road/Pruneridge
Avenue and North Tantau Avenue/Pruneridge Avenue. Fehr & Peers also collected trip counts at The
Hamptons driveway in November 2011 to determine the trip generation and distribution characteris-
tics of the apartment complex so that the number of apartment trips to/from the east could be
measured. The OD survey results (see RTC Table 2) were used to determine the percentage of
vehicles that travel on Pruneridge Avenue as through traffic versus those that access the existing
office uses on Pruneridge Avenue, and therefore would not be diverted.
Table RTC-2: Distribution of Trips on Pruneridge Avenue
Destination
AM Peak Period
% (Number of Vehicles)
PM Peak Period
% (Number of Vehicles)
Pruneridge Through Traffic 65% (1,050) 50% (700)
Project Site 27% (425) 43% (600)
The Hamptons 8% (140) 7% (100)
Total 100% (1,615) 100% (1,400)
Source: Fehr & Peers, 2013.
The through trips on Pruneridge Avenue were assumed to divert to both East Homestead Road and
Vallco Parkway to/from North Wolfe Road and North Tantau Avenue to travel to their ultimate
destination. Existing intersection turning movement distributions (i.e., the percent of vehicles that
turn left/right or travel straight) were used to make assumptions about the number of vehicles diverted
to East Homestead Road or Vallco Parkway and their ultimate path of travel to/from North Wolfe
Road and North Tantau Avenue. The Hamptons trips coming from/traveling to the east were assumed
to divert to East Homestead Road and North Wolfe Road via the Wolfe Road/Pruneridge Avenue
intersection. Based on the numbers of vehicle trips expected to be diverted due to the closure of
Pruneridge Avenue and the relatively short diversion distance (0.6 mile), the closure of Pruneridge
Avenue would not result in significant effects on vehicular travel behavior (although significant
impacts would occur to bicyclists and pedestrians, as discussed in the Draft EIR).
Master Response #12: Trip Cap
As described on page 441 of the Draft EIR, the City evaluated the feasibility of a mitigation measure
requiring a “trip cap.” Under a trip cap, once development of the project site generates trip volumes
that exceed AM and PM peak-hour values for triggering impacts to the transportation system,
continued development and growth at the project site would be halted. A trip cap was rejected as
infeasible because it would conflict with a key project objective of consolidating Apple’s engineering
and support personnel in one location. In addition, such a trip cap would limit employment growth on
the site, which would be undesirable to Apple and the City for economic reasons and would conflict
with a key project objective of developing a campus that can accommodate 14,200 employees.
1 Origin-Destination surveys can be used to estimate the amount of through traffic in a particular area. They involve
recording the license plates of vehicles at the entrances and exits and matching the plates to determine the number and
percentage of vehicles traversing the area.
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Instead, “peak trip counts” are established as goals for full implementation of the TDM measures for
the project (used to reduce physical impacts on the transportation system), as such counts would
reduce project traffic while also allowing for planned growth within the site. “Peak trip counts” avoid
the negative consequences of “trip caps,” such as limiting the ability of Apple to achieve its
objectives of consolidating research and development teams into one location at the site, while also
providing an effective mechanism for ensuring that Apple effectively implements the TDM Program.
Master Response #13: Calabazas Creek Trail
Several comments suggest that a trail should be developed through the project site, along Calabazas
Creek. Such a trail is shown in General Plan Figure 2-I and would promote walkability and the use of
alternative modes of transport in the vicinity of the project site.
As discussed on pages 152 to 155 of the Draft EIR, the project would not fully implement this
proposed trail segment and Strategies 2 and 3 of Policy 2-73 of the Land Use/Community Design
Element, which encourage the implementation of trail projects (and require dedications or easements
for trails, where appropriate). However, as discussed on page 152 of the Draft EIR, the General Plan
allows flexibility in the implementation of trail projects, including the balancing of safety, privacy,
and security concerns in identifying a specific trail alignment.
Requiring Apple to construct a Calabazas Creek trail through the project site as mitigation for Impact
PLAN-2 was determined to be infeasible because Apple has indicated that the fundamental objective
of a secure campus would be compromised with the provision of a public trail immediately adjacent
to or through the project site. Even with security and design measures such as fencing, Apple
maintains that such a trail through a portion of the site would pose security risks because Apple has
been the target of intense scrutiny regarding its future projects. Given that Apple’s research and
development facility is to be located at this site, perimeter security that will afford privacy is a
fundamental objective. Please refer to Master Response #5: Public Access Through Project Site for
additional discussion of these security considerations, including the relationship of these security
concerns with key project objectives.
In addition, development of a trail along Calabazas Creek through the project site would be physically
constrained. The riparian corridor within the site terminates at a culvert under I-280. If a trail through
the site were provided, it would either terminate at the I-280 culvert or would require a crossing over
or under I-280. A connection under I-280 would be a potentially costly engineering solution or would
only be operable during the dry season. The cost of a connection over I-280 would be significantly
higher and would be disproportionate to the impact of the project on planned trail facilities, making it
an infeasible measure.
Because a public trail through the project site would be infeasible due to security reasons and physical
planning constraints, the Draft EIR identifies an alternate, feasible mitigation measure to further the
implementation of the City’s trail-related planning policies. Mitigation Measure PLAN-3, described
on pages 154 to 155 of the Draft EIR, would require aesthetic and functional improvements along an
alternate creek trail, part of which would be adjacent to the boundaries of the project site. This
alternate creek trail would extend from the intersection of North Tantau Avenue and Pruneridge
Avenue, south to the intersection of Vallco Parkway and the creek. The required improvements would
include signage, plantings that reference Calabazas Creek, pedestrian-scaled lighting, rest areas or
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picnic tables, pavement features that reference the creek and/or water, and decorative fencing and
guard rails. In addition, Mitigation Measure PLAN-3 would require that Apple fund a study of a Class
I trail along the drainage channel and Calabazas Creek channel south of the project site. The City
could then pursue development of that trail, based on the findings of the study.
While Mitigation Measure PLAN-3 would partially mitigate the loss of the segment of the planned
Calabazas Creek trail, the measure would provide substitute trail facilities and alignments that would
be less desirable to trail users. Therefore, the impact would remain significant and unavoidable, as
discussed in the Draft EIR.
A project alternative, the Mobility and Park alternative, was initially considered as part of the project
alternatives analysis, as discussed on page 626 of the Draft EIR. This alternative would include a trail
that would extend along Calabazas Creek through the project site, and would ultimately connect
North Wolfe Road and North Tantau Avenue. However, this alternative was rejected because it would
pose significant security concerns to Apple and would conflict with a key project objective.
Master Response #14: New Freeway Ramps
Several comments suggest that the project include the creation of new I-280 ramps that would allow
direct access to and exit from the project site. The creation of new I-280 ramps serving the project site
was not proposed as part of the project and was rejected as a mitigation measure because: 1) new
ramps on the freeway would not significantly reduce the impacts of the project; 2) such a change is
not under the jurisdiction of the City of Cupertino; 3) new ramps could exacerbate congestion on I-
280 and compromise the key security objective of the project; 4) new ramps would violate Caltrans
regulations related to the proximity of freeway interchanges (including Highway Design Manual,
Chapter 500, Section 501.3, which requires interchanges to be at least 1 mile apart in urban areas) and
5) a new ramp directly to the site would violate Caltrans regulations prohibiting direct access to
private property from freeways (Highway Design Manual Topic 104.1).
Master Response #15: School Busing Program
Several comments suggest that the City require Apple to implement a new school busing program to
reduce traffic impacts associated with the project. Requiring Apple to bus children to school as
mitigation for project-related traffic impacts was rejected from detailed consideration in the Draft EIR
for the following reasons:
School trips in the area are generally understood to have a distribution pattern that differs
from those associated with the project. Thus the reduction of school trips may not
substantially reduce the impacts of the project on the roadway network.
The implementation of a school busing program would not only be difficult and costly to
develop and administer, but there also would not be a nexus between the project’s impact
on the roadway network and the benefit that would be achieved by implementing a school
busing system. See also Master Response #3: Mitigation Nexus.
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A. STATE, REGIONAL, AND LOCAL AGENCIES
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COMMENTER A1
City of Sunnyvale
Kent Steffens, Director of Public Works
July 22, 2013
Response A1-1: This comment comprises the transmittal conveying the comment letter from
the City of Sunnyvale, along with an introduction to the content of the letter.
This comment is noted.
Response A1-2: This comment introduces the subsequent comments and notes previous
collaboration with the City of Cupertino on project-related planning issues.
Response A1-3: The information in Table III-2, including the identified building heights of
the Phase 2 development, is correct. Figure III-4 on page 67 of the Draft EIR
is revised as shown on the following page.
Response A1-4: As described on page 125 of the Draft EIR, the Corporate Fitness Center
would be adjacent to a 25-space parking lot. Parking in this lot would not be
restricted to Corporate Fitness Center employees or service vehicles. On a
daily basis, Apple employees would be directed to park in the Main Building
Parking Garage, Main Parking Structure, North Tantau Parking Structure, and
Phase 2 parking areas. Therefore, no change to the text of the Draft EIR is
warranted.
Response A1-5: As described on page 59 of the Draft EIR, under existing conditions, the
perimeter of the project site is patrolled by Apple personnel on a 24-hour
basis. Security personnel also monitor other parts of the project site. This
security protocol would continue with implementation of the proposed project
and would ensure that the landscaping along the perimeter of the site would
not harbor criminal activity. In addition, as part of the project, Apple would
utilize camera surveillance along the perimeter fence that would be monitored
at a centrally-located campus operations center.
Response A1-6: The Corporate Fitness Center would primarily be used by employees within
the project site, and other, off-site fitness centers would remain available to
employees at off-site Apple facilities. Because the Corporate Fitness Center
would be an easy walk (approximately 5 minutes, via internal pathways) from
the Main Building, the vast majority of employees would not be expected to
use transit to access the facility. However, transit access to the Corporate
Fitness Center would be available on an on-demand basis for those employees
who prefer not to walk to the facility. The shuttles serving the Corporate
Fitness Center would be the 15-seat Sprinter vans that Apple currently uses to
shuttle employees between buildings at existing Apple facilities. These vans
would pick-up and drop-off passengers at the parking lot adjacent to the
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Apple Campus 2 Project EIR
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Corporate Fitness Center. Because the on-demand vans would not offer a
significant travel time savings (and in many cases would be less convenient
than walking), the use of these vans to access the Corporate Fitness Center is
expected to be negligible, and the vans would not add a substantial amount of
traffic to East Homestead Road.
Response A1-7: Please see Response to Comment A1-4.
Response A1-8: As described on page 208 of the Draft EIR, the viewpoint locations selected
for preparation of project visual simulations “were selected based on project
site visibility and the locations that provide the most representative views of
the project site.” These viewpoint locations are not intended to be exhaustive
of all the views surrounding the project site that could be altered with
implementation of the proposed project. Rather, the locations are intended to
illustrate the ways in which viewsheds may change due to the project.
Similarly, the preparation of a visual simulation for every viewpoint that may
be subject to change with implementation of the proposed project is not
required to evaluate the impacts of the project on views. Viewpoints 4, 5, and
6, as shown on Figure V.B-1, are representative of viewpoints to the north of
the project site. The corresponding visual simulations on Figures V.B-5
through V.B-7 show that the buildings on the project site would be largely
obscured by proposed perimeter landscaping.
Although the visual simulations in the Draft EIR are adequate to meet
CEQA’s information disclosure requirement, an additional simulation (from
the intersection of East Homestead Road and Peacock Avenue) has been
prepared in response to this comment, as shown in Figure RTC-1. Similar to
the existing visual simulations, this additional simulation indicates that the
buildings on the project site would be largely obscured by proposed
perimeter landscaping.
Response A1-9: The Lighting Technical Report1 was prepared for the project and was used to
evaluate project impacts on light and glare in the Draft EIR. The model used
in the Lighting Technical Report to evaluate project-related light and glare did
not include trees or other landscape features that could obscure light, in order
to analyze a worst-case light/glare scenario. As described on page 215 of the
Draft EIR, even using this worst-case modeling scenario, the project would
not exceed the light spillover thresholds established by the Illuminating
Engineering Society of North America. At three of the eight identified
1 Arup, 2012. Apple Campus 2 Project Environmental Impact Report Lighting Technical Report. October 29.
Visual simulation of the proposed project
Existing view of the project site
FIGURE RTC-1
Apple Campus 2 Project EIR
Visual Simulation:
Looking South between Nightingale Avenue and
Peacock Avenue on East Homestead RoadSOURCE: APPLE,2013.
I:\COC1101 Apple Campus 2\RTC\Figures\Fig_RTC-1.indd (9/10/13)
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receptor locations light spillover would be reduced with implementation of
the project (due to the substitution of widely-dispersed lighting in surface
parking lots with updated, focused lighting, and other factors). The lighting
values reported for the project on Table V.B-1 on page 215 of the Draft EIR
would likely be reduced further if proposed vegetation and landscape
features are taken into account. Therefore, additional measures to reduce
light spillover, including the planting of larger trees, would not be warranted.
Response A1-10: This comment requests potential transportation improvements that exceed
those required by project impacts. The transportation analysis in the Draft
EIR does not identify project impacts on the Homestead Road corridor nor at
the De Anza Boulevard/Homestead Road/I-280 interchange complex.
Because the project would result in less-than-significant impacts at the
locations identified above, the improvements identified in the comment are
not required. TRAFFIX is the approved LOS transportation software adopted
by all local jurisdictions within Santa Clara County, including Cupertino and
Sunnyvale. TRAFFIX was used to identify impacts to local streets.
Response A1-11: As part of the project, bike lanes would be extended/enhanced on North Wolfe
Road from East Homestead Road to Vallco Parkway. There is an existing bike
lane gap on North Wolfe Road for approximately 350 feet north of East
Homestead Road. This is an existing condition in the City of Sunnyvale and
the City of Sunnyvale is best positioned to implement improvements to its
bicycle facility network.
Response A1-12: A significant impact related to project effects on the bicycle network bicycle
was not identified at this location, so mitigation is not required. The defi-
ciency in bike facilities described in the comment is an existing condition in
the City of Sunnyvale and the City of Sunnyvale is best positioned to
implement improvements to its bicycle facility network. The City of
Cupertino would support such improvements.
Response A1-13: The transportation impact analysis used to prepare Section V.I, Transportation
and Circulation, of the Draft EIR was conducted in conformance with CEQA
requirements by using the appropriate analysis scenarios, locations, and
methods and by applying appropriate significance criteria to identify impacts
and mitigation measures. The study was conducted according to the
requirements of the City of Cupertino, the Santa Clara VTA, and CEQA.
Response A1-14: VTA’s Transportation Impact Analysis Guidelines (March 2009) indicate
that intersections where the project adds more than 10 trips per lane should
be considered for evaluation; however, it is ultimately the decision of the
lead agency to select intersections for evaluation. The five suggested
intersections were not originally selected for evaluation, since they: 1)
marginally meet the 10 trip per lane rule and 2) are signalized minor street
intersections that provide local access/circulation, located along a corridor
that does not have existing operational deficiencies.
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Intersection turning movement counts are not available for all five
intersections for which additional studies were requested. Data were
available for the the Sunnyvale-Saratoga Avenue intersections at Cheyenne
Drive-Connemara Way and Alberta Avenue-Harwick Way (both City of
Sunnyvale intersections) and the Lawrence Expressway/Benton Avenue
intersection (County of Santa Clara). Analysis has been completed for these
intersections and is presented below. The latest available intersection turning
movement volume data for the two City of Sunnyvale intersections are from
October 2012.
The City of Santa Clara provided counts for the Lawrence Expressway/
Benton Avenue intersection from May 2012, which were used to analyze
operations. The LOS results for the two additional City of Sunnyvale
intersections and one additional City/County of Santa Clara intersection
using TRAFFIX analysis software under the Existing, Background, and
Cumulative plus Project scenarios are summarized in Table RTC-3. The
results show that all three intersections would operate at acceptable service
levels and no mitigation measures are required.
Table RTC-3: Levels of Service for Requested Intersections
Intersection
Peak
Hour1 Jurisdiction
Plus Project Conditions
Existing Background Cumulative
DelayLOS Delay LOS DelayLOS
Sunnyvale-Saratoga
Ave/Cheyenne Dr-
Connemara Wy
AM
PM Sunnyvale 9.5
7.6
A
A
9.7
8.1
A
A
10.2
8.4
B
A
Sunnyvale-Saratoga
Ave/Alberta Ave-
Harwick Wy
AM
PM Sunnyvale 16.5
17.6
B
B
17.5
19.2
B
B-
18.4
20.3
B-
C+
Lawrence Expressway/
Benton Ave
AM
PM
County of
Santa Clara
40.9
35.9
D
D+
53.8
43.8
D-
D
56.1
46.0
E+
D
Notes: 1 AM = morning peak hour, PM = afternoon peak hour.
Delay = Whole intersection weighted average control delay expressed in seconds per vehicle.
LOS = Level of Service
Bold indicates unacceptable intersection operations. Bold and highlighted indicates significant impacts.
Source: Fehr & Peers, August 2013.
Intersection turning movement volume counts were not available for the
intersections of East Homestead Road/Blue Jay Drive and East Homestead
Road/Heron Avenue. These intersections are within the jurisdiction of the
City of Cupertino and are signalized minor intersections that intersect with
local streets that have a limited amount of neighborhood traffic. In response to
this comment, Fehr & Peers conducted physical observations of these two
intersections on September 10, 2013, since intersection turning movement
volumes were not available, and determined that in their professional
judgment the intersections currently operate at acceptable levels. Further, the
addition of through traffic on East Homestead Road due to the project is not
anticipated to substantially deteriorate operations. In addition, the level of
service analysis at the intersections of East Homestead Road/North Wolfe
Road, East Homestead Road/Blaney Avenue and East Homestead Road/
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Sunnyvale-Saratoga Road do not show any impacts in the east-west direction,
further indicating that the level of service for the minor intersections at Blue
Jay Drive and Heron Avenue along this corridor would not degrade to
unacceptable levels. For these reasons, the City of Cupertino determined that a
more detailed study would not yield meaningful information or different
conclusions, and thus it elected not to further evaluate these intersections.
Therefore, the project’s impacts to the East Homestead Road/Blue Jay Drive
and East Homestead Road/Heron Avenue intersections would be less than
significant.
Response A1-15: Please see Master Response #6: Project Trip Distribution. As shown on
Figure C-2 in the Appendix to the Transportation Impact Analysis, the
analysis included project traffic added to Wolfe Road north of Fremont
Avenue. It was assumed that employees living in the City of Sunnyvale at
closer proximity to the site would either move into existing homes and
replace trips generated by the current residents (and not add new traffic) or
move into new homes included in Background and Cumulative projections.
Response A1-16: VTA’s Transportation Impact Analysis Guidelines (March 2009) includes
guidance on the appropriate data sources for existing conditions, but does not
require that existing conditions represent conditions present at the time of the
most recent CMP monitoring. Existing conditions were established in May
2011 when the majority of the data collection and intersection counts were
conducted for the analysis. These May 2011 data approximate conditions that
existed when the Notice of Preparation (NOP) for the Draft EIR was
published in August 2011. This approach is also consistent with recent
CEQA case law, which has confirmed that the baseline normally constitutes
physical conditions as they exist on the date the Notice of Preparation is
published.
Response A1-17: The intersections of Sunnyvale-Saratoga Road/Homestead Road and
Sunnyvale-Saratoga Road/Homestead Avenue were correctly evaluated as
having six through lanes on Sunnyvale-Saratoga Road.
Response A1-18: The impact to pedestrian access at the I-280/Wolfe Road interchange is
identified as Impact TRANS-29. Mitigation Measure TRANS-29 requires the
provision of enhanced crosswalks at that location. Additional pedestrian
traffic generated by the project would not create a project impact that would
require mitigation at other freeway ramps in the area.
Response A1-19: Page 359 of the Draft EIR is modified as follows:
Near the project site, bicycle lanes (Class II) are provided on
Pruneridge Avenue, Homestead Road, Wolfe Road, Tantau Avenue,
Vallco Parkway, and Stevens Creek Boulevard. There is a disconti-
nuity in the Class II facility along Wolfe Road at the I-280 over-
crossing. A Class III bike route exists on Tantau Avenue south of
Stevens Creek Boulevard to Barnhart Avenue. There is a discontinu-
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ity in the Miller Avenue bike lane between Stevens Creek Boulevard
and Calle De Barcelona. Additionally, bicycle facilities do not exist
on Stevens Creek Boulevard east of Cronin Drive. Furthermore, the
bike lanes on Homestead Road are shared with parking lanes at the
following locations: 1) westbound between Nightingale Avenue and
Nighthawk Terrace and 2) westbound from the intersection with
Tantau Avenue for approximately 350 feet. At these locations,
parking is prohibited Monday through Friday from 8:00 a.m. to 5:00
p.m., during which time the lanes are used for bikes and right-turn
vehicles. The remainder of the time the lanes primarily function as
parking lanes, although bicyclists can continue to use them when
cars are not parked in them.
Bicycle facilities comprising bicycle lanes (Class II) and bicycle routes
(Class III) connect the Apple Campus 2 site to the Lawrence Caltrain station.
Continuous bicycle lanes connect the Apple Campus 2 site to Apple’s
Infinite Loop campus via Homestead Road and De Anza Boulevard, both of
which have high traffic volumes and speeds, which generally discourage
bicyclists.
Response A1-20: Figure V.I-3 on page 361 of the Draft EIR is updated as shown on the
following page.
Response A1-21: This comment is noted. Each intersection is numbered and correlated back to
the index map included on the same figure. No change is proposed as adding
intersection locations would add clutter to an already busy graphic.
Response A1-22: Per VTA Transportation Impact Analysis Guidelines, transit facilities,
including bus stops, within approximately 2,500 feet of the project site are
shown in Figure V.I-5 of the Draft EIR. The intersection of El Camino
Real/Wolfe Road, while a major transfer point, is outside of this zone and
therefore is not shown on the figure.
Homestead Rd
Wol
f
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El Camino Real
Stevens Creek Blvd
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Prospect Rd
Fremont Ave
Benton St
Monroe St
Pruneridge Ave
Bollinger Rd
Williams Rd
Ho
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A
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Moorpark AveMcClellan Rd
Remington Dr
Qu
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Hamilton Ave
Bu
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Payne Ave
Po
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A
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Bow
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Campbell Ave
Doyle Rd
Pie rce R d
Reed Ave
John
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McCoy Ave
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LEGEND
City of Cupertino
Project Site
Existing Bicycle Facilities
Class I Bike Path
Class II Bike Lane
Class III Bike Route
Planned Bicycle Facitlities
Class II Bike Lane J
not to scale Apple Campus 2 Project EIR
Existing and Proposed Bicycle FacilitiesSOURCE: FEHR & PEERS, AUGUST 2013.
I:\COC1101 Apple Campus 2\RTC\Figures\Fig_VI3 [Revised].ai (8/15/2013)
FIGURE V.I-3
[Revised]
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Response A1-23: Page 368 of the Draft EIR is revised as follows:
Most commuting bicyclists travel at a rate of about nine to 10 miles
per hour, meaning the Lawrence, Sunnyvale, and Santa Clara
Caltrain stations are located about an 18, 23, and 28-minute bicycle
ride away from Apple Campus 2, respectively. Only the Lawrence
Caltrain station has continuous bicycle infrastructure that connects it
to Apple Campus 2 in the form of Class II lanes along Wolfe Road
(on all segments except between old San Francisco Road and
Fremont Avenue), Reed Avenue, and Aster Avenue.
Response A1-24: The City of Cupertino does not have a City-wide traffic-forecasting model.
Discussions were held with VTA staff when the analysis for the Draft EIR
was initiated to determine whether the VTA model was the appropriate tool
to develop traffic projections for Cumulative Conditions. VTA staff noted
that the project is relatively small when compared to overall employment in
the region, and would fall under the category of “short-term” development
as defined within the VTA Traffic Impact Analysis Guidelines because the
project would be built and occupied within 5 years. The use of a
transportation model is not typically recommended by VTA for projects of
this scale. Therefore, in consultation with VTA, the City confirmed that
adding traffic projections from approved and pending development would be
the recommended approach to developing cumulative traffic projections.
Response A1-25: Please see Response to Comment A1-24. The City of Cupertino is essentially
built out according to its adopted General Plan (2005-2020). While the City
is currently contemplating updates to its General Plan, that process is in the
earliest stages and it would be speculative to estimate the amount of growth
that could occur prior to adoption of the updated plan. As a result, the
cumulative scenario used in the Draft EIR is appropriate and no revisions are
necessary. Additionally, it is anticipated that the project would be
constructed within a 48-month time period starting early 2014. Therefore,
construction is expected to be complete well before the cumulative horizon
year (2020) studied in the Draft EIR. As explained on page 376 of the Draft
EIR, the cumulative analysis was based on a list of projects anticipated to be
constructed in the neighboring jurisdictions by the cumulative horizon year
(2020). Furthermore, the project falls under the category of “short-term”
development as defined within the VTA Traffic Impact Analysis Guidelines
because the project would be built and occupied within 5 years. Pursuant to
the Guidelines the appropriate projection methods for cumulative conditions
have been applied.
Response A1-26: The comment indicates that the project conflicts with Sunnyvale’s Bike
Capital Improvement Program regarding bike lanes at North Wolfe
Road/East Homestead Road. The comment does not specify the conflict,
although it is noted that the Bike Capital Improvement Program sets forth a
final layout for each arterial and collector street in Sunnyvale and identifies
improvements needed to implement the desired layout. Because the project
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would not preclude the construction of bike lanes at the intersection of North
Wolfe Road and East Homestead Road, the project would not conflict with
this element of the City of Sunnyvale Bike Capital Improvement Program.
Response A1-27: The City agrees that policies and plans in adjacent cities should be taken into
consideration in developing pedestrian and bicycle impact criteria. However,
CEQA does not require an analysis of a project’s consistency with all studies
conducted by neighboring jurisdictions, as is suggested by the comment. To
the contrary, CEQA Guidelines Section 15125(d) requires an analysis of
inconsistencies with “applicable” plans, including, among others, the air
quality attainment or maintenance plan or State Implementation Plan, area-
wide waste treatment and water quality control plans, regional transportation
plans, regional housing allocation plans, and habitat conservation plans. For
that reason, it is not necessary to assess whether the project is inconsistent
with the City of Sunnyvale’s Pedestrian Safety and Opportunities Study and
the Comprehensive School Traffic Study. Nonetheless, the noted studies and
plans were reviewed and it is noted that the project would construct and
enhance pedestrian and bicycle facilities in the vicinity of the project site and
would not preclude construction of any planned facilities in adjacent cities,
including those identified in the studies. Therefore, the project would not
conflict with specific pedestrian and bicycle projects in adjacent cities and
further evaluation is not warranted.
Response A1-28: Please see Response to Comment A1-27.
Response A1-29: The transit impact criteria used in the Draft EIR were reviewed by VTA. The
consistency of the project with VTA’s Comprehensive Operations Analysis
Criteria is addressed on pages 426 and 427 of the Draft EIR; see in particular
Impact TRANS-30 and its associated mitigation measure. The project would
provide enhancements and amenities to transit stops on roadways in the
project site vicinity and would be generally consistent with the Comprehen-
sive Operations Analysis Criteria.
Response A1-30: Traffic turning left into the project site from the north on North Wolfe Road
comprises traffic approaching the site from the north on North Wolfe Road
and from the east and west on East Homestead Road. The projected left-turn
volume during the AM peak hour is greater than 350 vehicles, thus requiring
two left-turn lanes.
Response A1-31: The northbound right-turn volume is projected to be over 1,100 vehicles
during the AM peak hour, thus requiring two right-turn lanes. A bike lane
would be provided for cyclists. The impact of the dual right-turn lanes on
pedestrian conditions was identified as Impact TRANS-28 in the Draft EIR.
The mitigation measure includes installation of a “Yield to Peds” sign that is
activated by a pedestrian push button and a high visibility crosswalk (i.e.,
with ladder striping) at the east leg of the Wolfe Road/Project Access
intersection to help make the crosswalk more prominent. It is also recom-
mended in the Draft EIR that the City consider the provision of a leading
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bicycle and pedestrian interval (although this is not part of a mitigation
measure).
Response A1-32: Please see Master Response #10: Median on East Homestead Road.
Response A1-33: The public bus stops to be enhanced by the project sponsor would be designed
to the appropriate VTA standards, as directed by the VTA.
Response A1-34: The list on page 386 of the Draft EIR includes the transportation
infrastructure improvements that are proposed as part of the project. This is
an existing condition in the City of Sunnyvale and the City of Sunnyvale is
best positioned to implement improvements to its bicycle facility network.
The project applicant is not proposing to provide colored bike lanes on Wolfe
Road at the parking transitions between El Camino Real, Homestead Road,
or complete the bike lane gap on Wolfe Road/Homestead Road, so these
items are appropriately not included on the list of proposed transportation
improvements. All enhanced bike lanes within the City of Cupertino’s
jurisdiction will be maintained by the City.
Response A1-35: Please see Master Response #10: Median on East Homestead Road.
Response A1-36: Please see Master Response #11: Diverted Trips Due to Pruneridge Avenue
Closure.
Response A1-37: This comment requests potential transportation improvements that exceed
those required by project impacts. The transportation analysis in the Draft
EIR does not identify project impacts at the De Anza Boulevard/I-280
interchange complex. Because the project would result in less-than-
significant impacts at the locations identified above, the improvements
identified in the comment are not required. Please also see Master Response
#3: Mitigation Nexus.
Response A1-38: Table V.I-14 in the Draft EIR shows that travel time for vehicles traveling
south on North Wolfe Road would be 97 hours of total vehicle delay with a
two left-turn lane project exit configuration, compared to 141 hours for a
three left-turn lane configuration. This translates into 101 seconds of delay
per vehicle with a two-lane project exit and 146 seconds of delay per vehicle
for a three-lane project exit, a difference of 45 seconds of delay per vehicle.
These results are based on a VISSIM analysis conducted for the North Wolfe
Road corridor, which reflects the movement of individual vehicles on the
roadway system and the effects of vehicles weaving, merging, and queuing
between intersections. The City is confident this analysis reflects the best
available means of understanding the impacts of the various project
entrance/exit configurations on traffic along the North Wolfe Road corridor.
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Response A1-39: The discussion for Impact TRANS-34 refers to the closure of Pruneridge
Avenue and impacts on residents at The Hamptons; however, the comment
refers to the evaluation of potential traffic added to neighborhood streets. The
general assessment in the Draft EIR is that the neighborhood cut-through
routes are inferior to the main travel routes because they are less direct, have
multiple stop signs, and lower posted speed limits. Please see Master
Response: Neighborhood cut-through traffic for additional discussion on this
topic.
Response A1-40: Development of the project would occur in accordance with all elements of
the project description as defined in Chapter III of the Draft EIR (Project
Description). As described on pages 128 to 129 on the Draft EIR, Apple
anticipates that three to four special events would held per year, with a
maximum of approximately 1,000 guests (including approximately 350 non-
Apple employee guests). The event management plan described is sufficient
to evaluate associated impacts, and City staff retains the ability to monitor
activities, as needed, subject to cost recovery. The Conditional Use Permit
for the auditorium use would restrict events for invited guests, but would not
restrict events for current Apple employees.
Response A1-41: As discussed on pages 432 to 437 of the Draft EIR, the proposed project
would provide adequate on-site parking (with implementation of Mitigation
Measure TRANS-35), thus limiting the demand for off-site parking. The
measures to address any spillover parking include implementation of
additional TDM measures and, if required, the provision of additional
parking. As part of the conditions of approval (and as specified in the
Mitigation Monitoring and Reporting Program), the project sponsor would
fund monitoring to assess whether spillover parking occurs. The implementa-
tion of permit parking is one of the possible measures listed on pages 435 to
436 of the Draft EIR that could be pursued if spillover parking occurs. This
measure would be subject to the responsibility and jurisdiction of the City of
Sunnyvale, but Apple has agreed to coordinate and collaborate with
Sunnyvale and to contribute funding that could be used to implement the
measure.
Response A1-42: Please see Master Response #10: Median on East Homestead Road. The City
of Cupertino would work with the City of Sunnyvale to determine the
ultimate design of the median, including the length and design of the
westbound left-turn lane from East Homestead Road to southbound North
Wolfe Road. The final design would seek to extend the left-turn lanes as far
as possible, without eliminating parking on the north side of East Homestead
Road. Therefore, care would be taken to ensure that parking would not be
eliminated along this section of East Homestead Road.
Response A1-43: Please see Master Response #9: Monitoring TDM Program.
Response A1-44: Noise from all on-site mechanical equipment, including that associated with
the air intake equipment proposed in the northern quadrant of the project site
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(and other heating-ventilation-cooling-and air conditioning (HVAC)
equipment), has been analyzed and discussed on pages 465 and 466 of the
Draft EIR. As described in that analysis, due to the distance of the proposed
facilities from off-site sensitive receptors, noise from the operation of air
intake mechanical equipment that would be located in the northern quadrant
of the project site would attenuate to below background ambient noise levels
(which are dominated, in the location of the air intake equipment referenced
in the comment, by traffic noise on East Homestead Road) as measured at
receiving sensitive land uses. Therefore, as project-related mechanical
equipment stationary noise sources would not exceed existing ambient noise
levels at receiving sensitive land uses (66.5 A-weighted decibels (dBA)
CNEL associated with existing traffic on East Homestead Road, as measured
at 50 feet from the outermost travel lane), impacts of mechanical equipment
on the noise environment would be considered less than significant, and no
mitigation would be required.
Response A1-45: This concluding comment is noted. Please see the previous responses on the
analyses requested by the City of Sunnyvale.
COMMENTER A2
Santa Clara Valley Habitat Agency
Kenneth R. Schreiber, Interim Executive Officer
July 9, 2013
Response A2-1: This introductory comment is noted.
Response A2-2: The City agrees with the statement that “even relatively small amounts of
nitrogen could contribute to a cumulatively significant impact by diminishing
the population sizes of serpentine species and possibly the chances of
survival of the threatened [Bay checkerspot] butterfly and the serpentine-
specific plant species.” This concept is described more extensively in the
attachment to Letter A2 (California Department of Fish and Game, 2012.
Streamlining Mitigation for Impacts to Biological Resources. November 13.).
However, as described in Master Response #4: Nitrogen Deposition, the
contribution of the vehicle trips generated by the project to this cumulative
impact would not be considerable. Furthermore, Apple would voluntarily pay
$126,381, an amount equivalent to the Nitrogen Deposition Fee, had nitrogen
deposition been identified as a significant impact in the Draft EIR (no such
impact was identified). Thus, even if the contribution of nitrogen from
project vehicle trips were considered cumulatively considerable, the payment
of this amount would ensure that such an impact would be less-than-
significant. Refer to Master Response #4: Nitrogen Deposition for additional
detail.
Response A2-3: This comment, which indicates that payment of an amount equivalent to the
Nitrogen Deposition Fee by Apple to the Santa Clara Valley Habitat Agency
would be appreciated, is noted. However, the City rejects the request that the
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payment of this amount be identified as mitigation for a “cumulatively
significant environmental impact.” As described in Master Response #4:
Nitrogen Deposition, the project would not make a significant contribution to
the cumulative impact because: 1) the project location and most project trips
would be located at a distance from nutrient-poor soils most affected by
nitrogen deposition and 2) Apple, as part of the project, would voluntarily
pay an amount, equivalent to the Nitrogen Deposition Fee adopted in the
Habitat Plan, expected to be used to protect and enhance sensitive habitat in
the region that is subject to degradation due to nitrogen deposition. However,
the City agrees that if a significant impact were identified, payment of the
Nitrogen Deposition Fee would be appropriate mitigation.
Response A2-4: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted. The City will consider the need to evaluate the effects of nitrogen
deposition due to development projects within its jurisdiction based on the
size, location, trip distribution, and other pertinent characteristics of proposed
projects in Cupertino.
Response A2-5: This concluding comment is noted.
COMMENTER A3
County of Santa Clara, Roads and Airports Department
Michael Murdter, Director
July 22, 2013
Response A3-1: This comment, which conveys an attached letter, is noted.
Response A3-2: This introductory comment is noted.
Response A3-3: Please see Master Response #1: Significant and Unavoidable Impacts.
Response A3-4: The left-turn queue on the northbound approach of the intersection of
Saratoga Avenue and Lawrence Expressway currently extends the length of
the left-turn pocket during the AM peak hour under existing conditions.
Because the project would add traffic to this movement, Santa Clara County
requests that the project add a second left-turn lane or extend the left-turn
pocket. Significant project impacts were not identified at this intersection
because it is projected to operate at acceptable LOS E+ under Background
plus Project conditions during the AM peak period. However, Apple and
Cupertino have agreed to coordinate and collaborate with Santa Clara
County on operational issues, where feasible. Although the addition of
project traffic to the left-turn queue would not be considered a physical
environmental impact, the City of Cupertino would require a fair share
contribution to this existing operational issue as a Condition of Approval, in
order to improve existing operations.
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COMMENTER A4
State of California Department of Transportation (Caltrans)
Erik Alm, District Branch Chief
July 22, 2013
Response A4-1: This comment, which conveys an attached letter, is noted.
Response A4-2: This introductory comment is noted.
Response A4-3: Please see Master Response #6: Project Trip Distribution. Project traffic
using SR 85 north of I-280 would come from/go to areas along SR 85 and
along US 101 north of the US 101/SR 85 interchange, such as Mountain
View and Palo Alto. The route comprising Lawrence Expressway and US
101 is not a faster alternative for those destinations and would not be
attractive to project traffic. Therefore, the trip distribution pattern and trip
assignment is correct and no change is warranted.
Response A4-4: Queuing is generally not considered a physical environmental impact in and
of itself, based on the City’s criteria of significance. The one exception to
this is when excessive off-ramp queuing extends onto the freeway mainline
and causes a hazardous condition. Such conditions would not occur with
implementation of the project at the northbound I-280/Lawrence
Expressway/Stevens Creek off-ramp or at the southbound I-280/Stevens
Creek Boulevard off-ramp. Nevertheless, at the request of the commenter,
additional analysis was conducted to respond to the comment and evaluate
considerations related to queuing at the two off-ramps.
The proposed project would add the greatest amount of traffic to the ramps
during the AM peak hour. Therefore, supplemental operational analysis of
the off-ramps was conducted and focuses on the Background Plus Project
AM peak hour scenario. Table RTC-4 summarizes the results, which are
discussed in detail below.
The northbound I-280/Lawrence Expressway/Stevens Creek off-ramp has a
storage capacity of approximately 430 feet on three lanes between the
Stevens Creek Boulevard intersection and the junction with the northbound
off-ramp, with an additional 1,300 feet of storage on the off-ramp itself. This
results in a total storage capacity of 2,590 feet (430 feet x 3 lanes + 1,300
feet). Based on TRAFFIX, the average queue for the northbound approach at
the Stevens Creek Boulevard/I-280-Lawrence Expressway intersection is 30
vehicles under Background No Project Conditions, which would increase to
55 vehicles under the plus project scenario. The northbound approach is
assumed to have three lanes and TRAFFIX calculates the queue per lane;
thus under the Background No Project scenario the queue would be 2,250
feet (30 vehicles x 25 feet/vehicle x 3 lanes) and 4,125 feet (55 vehicles x 25
feet/vehicle x 3 lanes) under the plus project scenario. The project is
expected to increase the queue by 1,875 feet. With Mitigation Measure
TRANS-10, which would add an additional northbound lane (increasing
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storage to 3,020 feet (2,590 feet + 430 feet lane)), intersection operation
would improve and reduce queuing to 31 vehicles per lane or 3,100 feet (31
vehicles/lane x 25 feet/vehicles x 4 lanes). While queuing would slightly
exceed the 3,020 feet of available storage, the ramp is fed from an auxiliary
lane, meaning that the small amount of queuing beyond storage capacity (80
feet) would occur in the auxiliary lane. This amount of queuing that only
minimally exceeds storage capacity would not directly block mainline lanes
and would not create a hazardous condition. The expected AM peak hour
queue length can be accommodated at the southbound I-280 off ramp at
Lawrence Expressway/Stevens Creek Boulevard and no further evaluation
was conducted.
The southbound I-280/Stevens Creek Boulevard off-ramp has a storage
capacity of approximately 400 feet in three lanes, plus 280 feet over two
lanes, and 350 feet in a single lane. This results in a total storage capacity of
2,110 feet (400 feet x 3 lanes + 280 feet x 2 lanes + 350 feet x 1 lane). Based
on TRAFFIX, the average queue for the southbound approach at the Stevens
Creek Boulevard/I-280 Southbound Ramps is 13 vehicles under Background
No Project Conditions, which would increase to 16 vehicles under the plus
project scenario. TRAFFIX calculates the queue per lane; thus under the No
Project scenario the queue would be 975 feet (13 vehicles x 25 feet/vehicle x
3 lanes) and 1,200 feet (16 vehicles x 25 feet/vehicle x 3 lanes) under the
plus project scenario. The project is expected to increase the queue by 275
feet. The expected AM peak hour queue length can be accommodated at the
southbound I-280 off ramp at Stevens Creek Boulevard and no further
evaluation was conducted.
Table RTC-4: Background AM Off-Ramp Queuing (in feet)
Off-Ramp
Available
Storage
No
Project
Plus
Project
Northbound I-280/Lawrence Expressway/
Stevens Creek (without Mitigation Measure
TRANS-10)
2,590 2,250 4,125
Northbound I-280/Lawrence Expressway/Stevens
Creek (with Mitigation Measure TRANS-10) 3,020 2,200 3,100
Southbound I-280/Stevens Creek Boulevard 2,110 975 1,200
Source: Fehr & Peers, September 2013.
Response A4-5: The list of Transportation Demand Management (TDM) measures referenced
in this comment and found in the Transportation Impact Analysis (TIA) were
adapted for inclusion in the Draft EIR (see pages 121 to 122). The comment
that electric vehicle charging spaces would not reduce vehicle trips is noted,
but no additional clarification is needed. The Draft EIR notes at the bottom of
page 122 that, although “electrical vehicles would not necessarily reduce
project vehicle trips, they would achieve other environmental benefits related
to air quality, noise, and greenhouse gas emissions.”
To the extent that bike sharing within the project site could facilitate travel to
the employee amenities on-site (including dining facilities and the Corporate
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Fitness Center), and reduce travel to similar facilities off-site, bike sharing
could benefit off-site traffic levels. The bike sharing program would be
complementary to the shuttle program, allowing Apple employees to travel to
and from work without a car, while retaining the ability to travel short
distances during the day, such as to other nearby Apple facilities or neighbor-
ing retail establishments. Expanding the bike sharing program would
promote alternative means of commuting and is appropriately described as a
TDM measure.
As noted in the “Campus Walking/Cycling Commutes” on page 121 of the
Draft EIR, this measure includes: 1) provision of more convenient bicycle
and pedestrian access to the Main Building; 2) provision of bike lockers near
the entrance to the Main Building; and 3) increasing the distance between
work space and parking areas, to make parking less convenient. These
features would encourage the use of alternate modes of transportation.
As discussed on pages 440 through 447 of the Draft EIR, Mitigation Measure
TRANS-9b would require Apple to achieve a 34 percent alternative mode
participation rate, as verified with peak trip counts at the buildout capacity of
14,200 employees. The mitigation measure does not prescribe the use of the
“Additional TDM Measures” described on page 443 of the Draft EIR unless
the peak trip count goal is not met. At that point, Apple would be required to
implement some or all of the “Additional TDM Measures” until the peak trip
count goal is met. The mitigation measure is thus structured to ensure Apple
meets its peak trip count goal with the most efficient configuration of TDM
measures (and is not contingent on the City selecting specific TDM measures
for Apple to implement). Reducing the project parking supply may cause
parking in adjacent neighborhoods (a significant concern expressed by
residents who live near the project site) and therefore is not being considered
for this project.
Response A4-6: Ramp meters are used to manage freeway operations, by controlling the traffic
demand at freeway entry ramps. The freeway operations analysis conducted as
part of the Draft EIR is based on freeway density and assumes that the project
on-ramp demand would be accommodated on the freeway system. The
resulting freeway impacts and mitigation measure are discussed in TRANS-
22. In addition, most of the ramp intersections requested for additional
analysis were evaluated in the Draft EIR. The ramp intersections at Wolfe
Road/I-280 northbound ramps, Wolfe Road/I-280 southbound ramps,
Lawrence Expressway/Southbound I-280 Ramps, De Anza Boulevard/SR 85
northbound ramps, and De Anza Boulevard/SR 85 southbound ramps were
included in the analysis. Most of these intersections were projected to operate
at acceptable service levels or appropriate intersection LOS mitigation
measures were identified.
Queuing is generally not considered a physical environmental impact per the
City’s criteria of significance, but rather an operational consideration. The
one exception is when queuing at off-ramps extends onto the freeway
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mainline and causes a hazardous condition. The comment references on-
ramps, and so only relates to operational issues and not environmental
impacts. However, the requested six metered freeway on-ramps were
reviewed to determine if further operational analysis should be conducted.
The proposed project would add the greatest amount of traffic to the on-
ramps during the PM peak hour, when project traffic leaves the site to access
the surrounding freeway network. The review focused on the on-ramps for
the Background plus Project PM peak hour.
Apple and the City would continue to work with Caltrans to determine the
operational queuing considerations for the southbound I-280 on-ramps at
Wolfe Road (loop) and Lawrence Expressway. In the PM peak hour, the
existing queues due to ramp-metering at the southbound Lawrence
Expressway on-ramp extend the length of the on-ramp. Because the project
would add a considerable amount of traffic to this movement, Caltrans
requests that the applicant provide additional storage for this freeway on-
ramp by adding an HOV preferential lane. Although not a physical
environmental impact, the City of Cupertino would require a fair share
contribution to this existing operational issue as a Condition of Approval,
since the addition of project traffic would increase ramp queues.
Neither the northbound I-280 on-ramps at Wolfe Road (diagonal) nor De
Anza Boulevard (diagonal) have ramp-metering during the PM peak hour,
when the project would add the greatest amount of traffic; therefore, no
additional operational analysis was considered for these two locations. The
project would add 22 and 45 PM peak hour trips to the northbound SR 85/
Homestead Road loop on-ramp and southbound SR 85/De Anza Boulevard
on-ramp, respectively. This is not considered a substantial amount of traffic,
and therefore these two on-ramps on SR 85 were not considered for further
evaluation.
Response A4-7: Any construction within the Caltrans right-of-way associated with the project
would be conducted with the appropriate Caltrans permits and oversight. All
Traffic Operations Systems and ramp metering equipment would be main-
tained and would remain operational, as required by Caltrans or other
agencies.
Response A4-8: Apple would continue to work with Caltrans and the City of Cupertino to
develop the final design of the two off-ramps at the I-280/Wolfe Road
interchange, with the goal of extending the off-ramps to contain the expected
queues. The final design could include the suggestions identified in the
comment. However, there are right-of-way constraints (especially in the
southbound direction) that limit the length of the off-ramps. Because of these
constraints, and due to jurisdictional issues, the impacts to the northbound
and southbound ramps (TRANS-25 and TRANS-26) were identified as
significant and unavoidable.
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Response A4-9: Identified freeway impacts and mitigation measures are addressed under
Impact TRANS-22, and discussed in Response A8-8. Proposed mitigation
measures to freeway impacts include fair share contributions to: (1) the State
Route 85 Express Lane Project (converting the existing HOV lane to a toll
lane to allow single occupant vehicles to drive in the HOV lane for a fee); (2)
improvements identified by Caltrans to eliminate an existing bottleneck on
southbound I-280 between El Monte Road and Magdalena Avenue; and (3)
either the Bus Rapid Transit (BRT) stations proposed within Cupertino, or an
alternate improvement or study towards the improvement of the I-280
corridor. The fair share contribution amount was calculated in consultation
with VTA staff based on the project’s contribution to project growth on the
affected freeway segment. Improvements on southbound I-280 between El
Monte Road and Magdalena Avenue were developed by the City in
collaboration with VTA and Caltrans.
Response A4-10: City of Cupertino staff have discussed the fair-share formula with Caltrans
and have provided Caltrans with the corresponding calculations. Caltrans has
expressed that they are satisfied with the fair-share contributions and the
projects identified to receive the funding.
Response A4-11: Please see Master Response #1: Significant and Unavoidable Impacts. The
City would ensure that Apple pay the estimated cost of all mitigation
measures identified in the Draft EIR, including those associated with impacts
that remain significant and unavoidable. As described in the Master Response,
Apple would be required to pursue the mitigation measures requiring action
by other jurisdictions to the maximum extent feasible. The significant and
unavoidable finding does not allow the lead agency to avoid identifying
feasible mitigation, but recognizes that Caltrans and other agencies have not
yet granted the necessary approvals to implement these measures and the City
of Cupertino cannot, at this time, guarantee that such approvals would be
granted. Apple has agreed to coordinate and collaborate with the extra-
jurisdictional agencies to construct each mitigation measure, or to provide
funding to the agencies to design and construct either: (1) the identified
mitigation measure or (2) an alternate improvement which mitigates the
impact to the satisfaction of the City of Cupertino. Therefore, the City fully
expects that the physical improvements identified in the noted mitigation
measures would be successfully constructed and implemented and would
require that Apple pursue these physical improvements or fund the estimated
cost of the identified improvements, as noted in the Mitigation Monitoring and
Reporting Program. The only circumstance in which the mitigation would not
be implemented would be if Caltrans, or another responsible agency, does not
approve the improvements.
Response A4-12: Please refer to Section V.B, Aesthetics, of the Draft EIR, for a complete
disclosure of the aesthetics impacts of the proposed project, including visual
simulations of the project from eight representative viewpoints in the vicinity
of the project site. As described in detail in Section V.B, the project would
result in no significant aesthetics impacts.
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Response A4-13: All sound walls proposed as part of the project, as described on page 136 of
the Draft EIR, would be built along – but within – the boundaries of the
project site. However, in the unlikely event that sound walls would need to
be built within a State right-of-way, an environmental assessment would be
prepared.
Response A4-14: This comment, which pertains to the disposition of right-of-way for the
construction of mitigation measures, does not pertain to the adequacy of the
Draft EIR and is noted.
Response A4-15: This comment, which pertains to the protocols governing work within a State
right-of-way, does not pertain to the adequacy of the Draft EIR and is noted.
COMMENTER A5
City of San José, Department of Community Development
Andrew Crabtree, Division Manager, Planning Division
July 22, 2013
Response A5-1: This introductory comment is noted.
Response A5-2: According to the VTA Congestion Management Program Requirements for
Deficiency Plans, adopted November 18, 1992, a Deficiency Plan is needed
when a Congestion Management Program (CMP) intersection exceeds its
CMP threshold (LOS E) during CMP monitoring, or when the intersection is
projected to exceed its threshold as the result of a land use impact analysis,
and there are no feasible improvements or mitigation measures that would
allow it to operate at or better than its threshold. The comment letter
identifies five CMP intersections with significant and unavoidable impacts
(four under Background plus Project conditions and one under Cumulative
plus Project conditions) and concludes that a Deficiency Plan is needed.
Physical improvements have been identified for the four CMP intersections
with impacts under Background Plus Project Conditions that would mitigate
the impacts to a less-than-significant level. Since these intersections are in
neighboring jurisdictions and the City of Cupertino cannot guarantee that
those jurisdictions would implement the mitigation measures, the impacts are
correctly identified as significant and unavoidable. However, the project
applicant would be required to provide funding to those jurisdictions of
amounts that would allow for the design and construction of the improve-
ments so that those jurisdictions can implement them and mitigate the project
impacts. Furthermore, Apple has agreed to coordinate and collaborate with
the extra-jurisdictional agencies to construct each mitigation measure, or to
provide funding to the agencies to design and construct either: (1) the
identified mitigation measure or (2) an alternate improvement which
mitigates the impact to the satisfaction of the City of Cupertino. Since these
are feasible improvements, a deficiency plan is not warranted for these
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locations. See also Master Response #1: Significant and Unavoidable
Impacts.
The intersection of De Anza Boulevard and Stevens Creek Boulevard is
projected to operate at LOS E under Cumulative plus Project Conditions. The
City of Cupertino’s LOS threshold for this intersection is LOS E+, so a
significant impact was identified. The CMP LOS threshold for this intersec-
tion is LOS E. Therefore it would not exceed the CMP LOS threshold and a
Deficiency Plan is not warranted. However, Apple would be required to pay
a fair-share contribution towards implementation of an adaptive traffic signal
system along De Anza Boulevard, to partially mitigate the impact that was
identified in the Cumulative scenario.
The City of Cupertino is committed to working collaboratively with the City
of San Jose and other adjacent jurisdictions to address regional transportation
improvements.
Pages 411 and 412 of the Draft EIR are revised as follows:
Impact TRANS-13: Under Cumulative plus Project Conditions,
completion of the proposed project would cause intersection #8
De Anza Boulevard/Stevens Creek Boulevard to operate at an
unacceptable level (change from LOS E+ to LOS E) during the
PM peak hour based on City of Cupertino LOS impact
thresholds. (S)
Mitigation Measure TRANS-13a: At intersection #8 De Anza
Boulevard/Stevens Creek Boulevard, the provision of an exclusive
southbound right-turn lane (for a total of two left-turn lanes, four
through lanes, and one right-turn lane) and adjusting the signal
timings to accommodate the added turn lane would improve
intersection operations to acceptable levels at LOS E+ with 58.9
seconds of average delay. However, this improvement is physically
not feasible, since the widening of the roadway to accommodate the
southbound right-turn lane would impact an underground garage
belonging to the office development on the northwest corner of the De
Anza Boulevard/Stevens Creek Boulevard intersection; therefore the
impact at the De Anza Boulevard/Stevens Creek Boulevard
intersection is considered significant and unavoidable.
Mitigation Measure TRANS-13b: The project sponsor shall expand
the TDM program to reduce the severity of the impact. Increasing the
TDM participation and associated alternative mode share from 28
percent to 34 percent would improve operations to LOS E (62.1
seconds); however the increase in TDM participation would not
reduce the impact to a less-than-significant level.
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Mitigation Measure TRANS-13c: The project sponsor shall provide a
$50,000 fair-share contribution towards the implementation of an
adaptive traffic signal system along De Anza Boulevard between
Homestead Road and Rainbow Drive. Implementation of an adaptive
traffic signal system would improve intersection operations; however
it would not reduce the impact to a less-than-significant level. (SU)
Response A5-3: Please see Master Response #9: Monitoring TDM Program and Master
Response #8: Adequacy of TDM Penalties. The shuttles referenced in the
comment are private shuttles for use only by Apple employees. The shuttle
routes and stops are designed based on locations with concentrations of
employee residences and major transit hubs. Apple would continue to modify
its routes and stops in response to its employee needs. Maintaining shuttle
planning as an in-house activity allows Apple to be more responsive than if it
were conducted in collaboration with VTA.
Response A5-4: Please see Master Response #9: Monitoring TDM Program and Master
Response #8: Adequacy of TDM Penalties.
Response A5-5: The existing sidewalk on the south side of Steven Creek Boulevard west of
Calvert Drive is currently 5 feet wide. The proposed mitigation would reduce
the buffer between the vehicle travel lane and the sidewalk from approxi-
mately 5 feet to 1 foot and maintain the existing 5-foot sidewalk. Because the
width of the sidewalk would not diminish, no significant impact would result
and no mitigation would be required.
Response A5-6: Please see Master Response #4: Nitrogen Deposition. As noted in that
response, Apple would voluntarily pay $126,381, an amount equivalent to the
Nitrogen Deposition Fee that would be assessed had there been a significant
impact from the development of the project, based on the assumption that the
project would generate 35,106 net new daily trips. The payment would be
voluntary because the proposed project is not located within the boundaries of
the Santa Clara Valley Habitat Plan, which established such a fee for its
member agencies. This payment does not constitute “mitigation” for a
significant impact related to nitrogen deposition because: 1) the project’s
contribution to such an impact is not cumulatively considerable and 2) the
payment of this amount is part of the project and thus does not constitute
mitigation.
Response A5-7: The themes of reducing dependency on single-occupancy vehicles and the
reduction of greenhouse gas emissions run through numerous City documents,
including those related to land use planning. The most prominent of these is
the City of Cupertino General Plan, which encourages compact, transit-
oriented growth, multi-modal transportation infrastructure, and the provision
of housing for a range of income groups. Please refer to the discussions, in
particular, of the Land Use/Community Design Element, which promotes
walkable neighborhoods (see page 142 of the Draft EIR); Housing Element,
which promotes housing production in a job-rich area to reduce commutes
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(see pages 146 to 147 of the Draft EIR); Circulation Element, which promotes
connectivity and mobility in Cupertino with an emphasis on non-automotive
transportation (see page 147 of the Draft EIR); and Environmental Resources/
Sustainability Element (see pages 147 to 148 of the Draft EIR). In addition, as
discussed on page 134 of the Draft EIR, the City’s Green Building Ordinance
(Section 16.58 of the Municipal Code), which took effect on July 1, 2013,
would reduce greenhouse gas emissions in the City through its support of the
use of healthy building materials and construction methods and the promotion
of resource efficiency and conservation through the design, construction,
retrofit, operation and demolition of new buildings and existing buildings
undergoing renovations. A complete copy of the General Plan may be
accessed at: http://www.cupertino.org/index.aspx?page=709. The Green
Building Ordinance may be accessed at: http://www.cupertino.org/
index.aspx?page=1007.
Response A5-8: This concluding comment is noted.
COMMENTER A6
City of Santa Clara
Kevin Riley, Director of Planning
July 19, 2013
Response A6-1: This introductory comment, which notes the efforts by City of Cupertino
staff to meet with City of Santa Clara staff to discuss the Draft EIR, is noted.
Response A6-2: This comment, which references the City of Santa Clara’s support of
Condition of Approval CA-TRANS-3 described on pages 435 to 436 of the
Draft EIR, is noted. This Condition of Approval is designed to reduce the
less-than-significant effects of the project on parking supply outside the
boundaries of the project site.
Response A6-3: The mitigation funds referenced in this comment would be submitted to the
VTA. If the Stevens Creek BRT project does not move forward , the VTA
would be able to use the funds for an alternative improvement or study
towards the improvement of Stevens Creek Boulevard or the impacted I-280
corridor.
Response A6-4: Please see Master Response #1: Significant and Unavoidable Impacts.
Response A6-5: Please see Master Response #11: Diverted Trips Due to Pruneridge Avenue
Closure.
Response A6-6: Project construction vehicles would be required to adhere to all roadway
weight limit prohibitions (as well as other local, State, and federal require-
ments).
Response A6-7: This concluding comment is noted.
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COMMENTER A7
Peninsula Corridor Joint Powers Board (Caltrain)
Hilda Lafebre, Manager, Capital Project & Environmental Planning
July 22, 2013
Response A7-1: This comment, which conveys an attached letter, is noted.
Response A7-2: Apple’s existing Infinite Loop site has approximately 100 Caltrain riders,
which represents approximately 2.4 percent of the 4,200 employees at that
facility. Assuming a similar level of Caltrain ridership, the proposed project
would result in 340 new Caltrain riders. Assuming that 40 percent of these
would ride the trains during the peak hour, the proposed project would
increase Caltrain peak-hour ridership by approximately 140 riders (340 x 40
percent). Based on Apple’s trip distribution assumptions shown in Figure
V.I-7 and accessibility to Caltrain stations, approximately 70 percent of these
riders would travel southbound and 30 percent would travel northbound in
the AM peak hour (98 southbound and 42 northbound riders). Table RTC-5
lists the AM peak hour Caltrain train capacities and expected Apple demand
by service type and direction of travel.
Table RTC-5: Caltrain AM Peak Hour Capacity
Service Type
Load
Factor
Seats
Available
per
Train1
Number of
Trains Per
Peak Hour2
Seats
Available
Per Peak
Hour
Estimated
Apple
Caltrain
Riders
Southbound
Limited Trains 0.50 325 2 650 98 Express Trains (Baby Bullet) 0.77 150 0 0
Northbound
Limited Trains 0.68 208 4 832 42 Express Trains (Baby Bullet) 0.93 45 1 45
Notes:
1. Assuming total capacity of 650 seats per train.
2. Number of trains serving Sunnyvale and Lawrence stations based on August 2013 train schedule.
Source: Fehr & Peers, September 2013.
In the southbound direction, the Limited Trains have an available capacity of
325 seats (650 seats x (1-0.5 load factor)) and the Express Trains have an
available capacity of approximately 150 seats (650 seats x (1-0.77 load
factor)). Between 8:00 a.m. and 9:00 a.m. two Limited Trains serve the
Sunnyvale and/or Lawrence stations (no Express Train service is provided to
the two stations in Sunnyvale in the southbound direction in the AM peak
hour); thus in the AM peak hour Caltrain has a total capacity of 650 seats
(325 Limited Train capacity x 2 trains) in the southbound direction, which
would be sufficient to meet the expected demand of 98 new southbound
Caltrain riders from the proposed project.
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Similarly, in the northbound direction, the Limited Trains have an available
capacity of 208 seats (650 x (1-0.68 load factor)) and the Express Trains
have an available capacity of approximately 45 seats (650 seats x (1-0.93
load factor)). Between 8:00 a.m. and 9:00 a.m. four Limited Trains and one
Express Train service the Sunnyvale and/or Lawrence stations; thus in the
AM peak hour Caltrain has a total capacity of 877 seats (208 Limited Train
capacity x 4 trains plus 45 Express Train capacity x 1 train) in the north-
bound direction, which is sufficient to meet the expected demand of 42
southbound Caltrain riders. The difference in travel times between the
Limited and Express northbound trains is minimal; thus project employees
would be expected to ride either service equally.
COMMENTER A8
Santa Clara Valley Transportation Authority
Roy Molseed, Senior Environmental Planner
Michael T. Burns, General Manager
July 22, 2013
Response A8-1: This introductory comment, which states that many of the Santa Clara Valley
Transportation Authority’s (VTA’s) preliminary concerns about the project
were addressed in the Draft EIR and Transportation Impact Analysis (TIA),
is noted.
Response A8-2: This comment, which requests that bus stops proposed adjacent to the project
site be designed such that VTA buses are unimpeded by Apple-related buses
and shuttles, is noted. The new VTA bus stops that would be developed as
part of the project on North Wolfe Road and North Tantau Avenue, as
described on page 111 of the Draft EIR, would be exclusively for VTA
vehicles.
Response A8-3: The proposed intersection modifications generally include minor widening
such as the addition of one lane on an approach. Due to the combination of the
modifications requiring only minor widening and the low transit, bicycle, and
pedestrian volumes in the vicinity of the affected intersections, secondary
impacts to non-auto modes would be less than significant and thus would not
require mitigation. It should be noted, however, that the designs for the
modifications would incorporate pedestrian-friendly treatments such as narrow
lane widths and tight corner radii, where appropriate. For example, at the
Homestead Road/Tantau Avenue (#27) and Stevens Creek Boulevard/Tantau
Avenue (#32) intersections, the proposed mitigation measures, which involve
adding right-turn lanes, also include eliminating existing “pork-chop” islands
to improve the pedestrian environment. In addition, mitigation measures that
include roadway widening would generally only occur at locations where the
project is anticipated to add a substantial amount of vehicle traffic, thus
resulting in poor LOS.
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Response A8-4: This comment encourages the City to consider alternatives to widening
intersections when Level of Service (LOS) thresholds are exceeded. The
Draft EIR utilizes the significance criteria currently used by the City.
Response A8-5: As discussed on pages 111 to 120 of the Draft EIR, the project would include
enhancements to bicycle and pedestrian facilities throughout the streets
surrounding the project site. In addition, Mitigation Measure PLAN-2 and
Mitigation Measure PLAN-3 would require Apple to implement additional
bike and pedestrian facility improvements, including a coordinated
wayfinding scheme around the project site perimeter, enhanced bike lanes and
pedestrian paths along the North Wolfe Road bridge over I-280, other bicycle
and pedestrian amenities, ADA improvements, and an alternate Calabazas
Creek pathway. Also, Mitigation Measures TRANS-23, TRANS-28, TRANS-
29 would require enhancements to the pedestrian environment at the North
Wolfe Road/Project Access intersection and at the I-280 ramps with Wolfe
Road. The City has identified all feasible mitigation to reduce the impacts of
roadway widening on the pedestrian and bike environment in the vicinity of
the project site.
Response A8-6: The apparent discrepancy identified in the TIA is that Intersection #21,
Wolfe Road/I-280 Northbound Ramps is indicated as having a significant
project impact in Table ES-1 under Background plus Project and Cumulative
plus Project Conditions but is not included in Tables 15 and 16. The infor-
mation in Table ES-1 of the TIA is correct. The intersection LOS for Wolfe
Road/I-280 Northbound Ramp intersection (#21) was inadvertently omitted
from Tables 15 and 16; although impacts were correctly identified in Impacts
TRANS-5 and TRANS-14 in the Draft EIR for Background and Cumulative
plus Project conditions, respectively.
Response A8-7: This comment, which concurs with Mitigation Measure TRANS-22, is noted.
Response A8-8: An expanded freeway segment analysis was conducted to provide more
information regarding Impact TRANS-22. This expanded analysis conducted
in response to this comment identifies impacts to additional freeway
segments. Page 398 of the Draft EIR will be revised to reflect this analysis
(see Chapter IV, Text Revisions, and discussion below). These changes are
not considered “significant new information” pursuant to CEQA Guidelines
Section 15088.5 because they do not represent a new significant impact or a
substantial increase in the severity of an impact. The newly identified
segments include segments that are more distant from the project site than the
ones initially identified in the Draft EIR. In addition, the amount of project
traffic that would be contributed to the newly identified segments would be
less than the amount of project traffic identified in the previously identified
segments. While the number of affected segments has increased, the intensity
of the impact has not increased, since the volume of project traffic diminishes
as distance from the project site increases. Therefore, the changes to this
impact represent refinements to the impact statement in the Draft EIR and do
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not represent a new significant impact or a substantial increase in the severity
of the impact.
Table V.I-10 (Existing Plus Project Freeway Levels of Service) and page 398
of the Draft EIR are revised as follows. The changes to Table V.I-10 are not
shown using underline and strikeout text to enhance readability.
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
Mixed-Flow Lanes
SR 17 - Summit Road
to Bear Creek Road
NB AM
PM 4400 88
24
F
C
29
11
89
24
F
C
0.66%
0.25%
SB AM
PM 4400 19
45
C
D
5
10
19
45
C
D
0.11%
0.23%
SR 17 - Bear Creek
Road to Saratoga-Los
Gatos Road
NB AM
PM 4400 92
20
F
C
39
15
93
20
F
C
0.89%
0.34%
SB AM
PM 4400 17
36
B
D
7
15
17
36
B
D
0.16%
0.34%
SR 17 - Saratoga-Los
Gatos Road to Lark
Avenue
NB AM
PM 4400 54
28
E
D
110
30
56
28
E
D
2.50%
0.68%
SB AM
PM 4400 29
70
D
F
13
40
29
71
D
F
0.30%
0.91%
SR 17 - Lark Avenue
to SR 85
NB AM
PM 4400 35
23
D
C
147
40
36
23
D
C
3.34%
0.91%
SB AM
PM 4400 14
50
B
E
17
100
14
51
B
E
0.39%
2.27%
SR 17 - SR 85 to San
Tomas Expressway/
Camden Avenue
NB AM
PM 6900 53
19
E
C
20
8
53
19
E
C
0.29%
0.12%
SB AM
PM 6900 13
21
B
C
3
20
13
21
B
C
0.04%
0.29%
SR 17 - San Tomas
Expressway/Camden
Avenue to Hamilton
Avenue
NB AM
PM 6900 72
20
F
C
39
16
73
20
F
C
0.57%
0.23%
SB AM
PM 7820 18
27
B
D
6
39
18
27
B
D
0.08%
0.50%
SR 17 - Hamilton
Avenue to I-280
NB AM
PM 7820 71
36
F
D
77
31
64
32
F
D
0.98%
0.40%
SB AM
PM 6900 26
41
C
D
12
77
26
42
C
D
0.17%
1.12%
SR 85 - SR 87 to
Almaden
Expressway
NB AM
PM 4600 119
25
F
C
23
6
121
25
F
C
0.50%
0.13%
SB AM
PM 4600 22
27
C
D
3
19
22
27
C
D
0.07%
0.41%
SR 85 - Almaden
Expressway to
Camden Avenue
NB AM
PM 4600 85
36
F
D
45
12
86
36
F
D
0.98%
0.26%
SB AM
PM 4600 24
41
C
D
5
37
24
41
C
D
0.11%
0.80%
SR 85 - Camden
Avenue to Union
Avenue
NB AM
PM 4600 70
27
F
D
60
16
71
27
F
D
1.30%
0.35%
SB AM
PM 4600 31
52
D
E
7
48
31
53
D
E
0.15%
1.04%
SR 85 - Union
Avenue to S. Bascom
Avenue
NB AM
PM 4600 60
27
F
D
81
21
61
27
F
D
1.76%
0.46%
SB AM
PM 4600 20
81
C
F
10
65
20
83
C
F
0.22%
1.41%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 85 - S. Bascom
Avenue to SR 17
NB AM
PM 4600 105
14
F
B
108
28
109
14
F
B
2.35%
0.61%
SB AM
PM 4600 16
68
B
F
12
86
16
70
B
F
0.26%
1.87%
SR 85 - SR 17 to
Winchester Blvd
NB AM
PM 4600 85
18
F
B
216
55
91
18
F
B
4.70%
1.20%
SB AM
PM 4600 14
27
B
D
24
171
14
28
B
D
0.52%
3.72%
SR 85 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 4600 69
27
F
D
240
62
74
27
F
D
5.22%
1.35%
SB AM
PM 4600 30
54
D
E
29
190
30
57
D
E
0.63%
4.13%
SR 85 - Saratoga
Avenue to Saratoga-
Sunnyvale Road
NB AM
PM 4600 32
21
D
C
48
12
32
21
D
C
1.04%
0.26%
SB AM
PM 4600 23
65
C
F
5
38
23
66
C
F
0.11%
0.83%
SR 85 - Saratoga-
Sunnyvale Road to
Stevens Creek Blvd
NB AM
PM 5290 54
21
E
C
0
0
47
18
E
B
0.00%
0.00%
SB AM
PM 4600 19
94
C
F
0
0
19
94
C
F
0.00%
0.00%
SR 85 - Stevens
Creek Blvd to I-280
NB AM
PM 4600 109
19
F
C
28
7
110
19
F
C
0.61%
0.15%
SB AM
PM 6900 15
85
B
F
3
22
12
68
B
F
0.04%
0.32%
SR 85 - I-280 to W.
Homestead Road
NB AM
PM 4600 94
15
F
B
31
223
114
20
F
C
0.67%
4.85%
SB AM
PM 4600 14
25
B
C
282
72
16
26
B
C
6.13%
1.57%
SR 85 - W.
Homestead Road to
W. Fremont Avenue
NB AM
PM 4600 89
26
F
C
26
202
90
28
F
D
0.57%
4.39%
SB AM
PM 4600 25
53
C
E
240
61
27
54
D
E
5.22%
1.33%
SR 85 - W. Fremont
Avenue to El Camino
Real
NB AM
PM 4600 65
28
F
D
20
143
65
29
F
D
0.43%
3.11%
SB AM
PM 4600 25
72
C
F
186
45
26
73
C
F
4.04%
0.98%
SR 85 - El Camino
Real to SR 237
NB AM
PM 4600 52
28
E
D
12
88
52
29
E
D
0.26%
1.91%
SB AM
PM 4600 25
106
C
F
111
27
32
134
D
F
2.41%
0.59%
SR 85 - SR 237 to
Central Expressway
NB AM
PM 4600 26
20
C
C
6
44
26
20
C
C
0.13%
0.96%
SB AM
PM 4600 12
90
B
F
54
14
12
90
B
F
1.17%
0.30%
SR 85 - Central
Expressway to US
101
NB AM
PM 4600 36
14
D
B
6
42
36
14
D
B
0.13%
0.91%
SB AM
PM 4600 16
28
B
D
57
14
16
28
B
D
1.24%
0.30%
I-280 - US 101 to
McLaughlin Avenue
NB AM
PM 9200 95
21
F
C
88
31
96
21
F
C
0.96%
0.34%
SB AM
PM 9200 18
31
B
D
7
47
18
31
B
D
0.08%
0.51%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-280 - McLaughlin
Avenue to 10th
Street
NB AM
PM 9200 75
34
F
D
117
39
76
34
F
D
1.27%
0.42%
SB AM
PM 9200 22
52
C
E
14
94
22
53
C
E
0.15%
1.02%
I-280 - 10th Street to
SR 87
NB AM
PM 9200 76
29
F
D
130
43
78
29
F
D
1.41%
0.47%
SB AM
PM 9200 20
66
C
F
16
104
20
67
C
F
0.17%
1.13%
I-280 - SR 87 to Bird
Avenue
NB AM
PM 9200 88
72
F
F
260
85
92
73
F
F
2.83%
0.92%
SB AM
PM 9200 19
67
C
F
32
207
19
69
C
F
0.35%
2.25%
I-280 - Bird Avenue
to Meridian Avenue
NB AM
PM 9200 88
44
F
D
289
94
92
44
F
D
3.14%
1.02%
SB AM
PM 9200 30
60
D
F
35
230
30
62
D
F
0.38%
2.50%
I-280 - Meridian
Avenue to I-880
NB AM
PM 8510 113
25
F
C
327
116
112
23
F
C
3.84%
1.36%
SB AM
PM 9200 25
85
C
F
40
260
19
67
C
F
0.43%
2.83%
I-280 - I-880 to
Winchester Blvd
NB AM
PM 6900 84
34
F
D
654
212
96
35
F
D
9.48%
3.07%
SB AM
PM 6900 23
103
C
F
80
520
23
116
C
F
1.16%
7.54%
I-280 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 6900 76
34
F
D
728
247
87
35
F
D
10.55%
3.58%
SB AM
PM 6900 36
51
D
E
94
578
37
56
D
E
1.36%
8.38%
I-280 - Saratoga
Avenue to Lawrence
Expressway
NB AM
PM 6900 67
29
F
D
785
225
76
30
F
D
11.38%
3.26%
SB AM
PM 6900 28
77
D
F
100
623
29
86
D
F
1.45%
9.03%
I-280 - Lawrence
Expressway to Wolfe
Road
NB AM
PM 6900 62
32
F
D
382
106
66
33
F
D
5.54%
1.54%
SB AM
PM 6900 25
63
C
F
67
411
25
67
C
F
0.97%
5.96%
I-280 - Wolfe Road to
De Anza Blvd
NB AM
PM 6900 57
31
E
D
135
705
58
35
E
D
1.96%
10.22%
SB AM
PM 6900 29
97
D
F
850
269
33
103
D
F
12.32%
3.90%
I-280 - De Anza Blvd
to SR 85
NB AM
PM 6900 57
29
E
D
136
672
58
32
E
D
1.97%
9.74%
SB AM
PM 6900 24
81
C
F
831
245
28
85
D
F
12.04%
3.55%
I-280 - SR 85 to
Foothill Expressway
NB AM
PM 6900 62
24
F
C
107
439
63
26
F
C
1.55%
6.36%
SB AM
PM 6900 26
70
C
F
534
178
29
72
D
F
7.74%
2.58%
I-280 - Foothill
Expressway to
Magdalena Avenue
NB AM
PM 6900 41
23
D
C
86
368
42
25
D
C
1.25%
5.33%
SB AM
PM 6900 30
51
D
E
436
146
32
52
D
E
6.32%
2.12%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-280 - Magdalena
Avenue to El Monte
Road
NB AM
PM 8050 36
22
D
C
81
326
42
27
D
D
1.01%
4.05%
SB AM
PM 9200 27
70
D
F
402
134
29
71
D
F
4.37%
1.46%
I-280 - El Monte
Road to La Barranca
Road
NB AM
PM 9200 31
21
D
C
65
261
31
22
D
C
0.71%
2.84%
SB AM
PM 9200 20
63
C
F
322
87
21
64
C
F
3.50%
0.95%
I-280 - La Barranca
Road to Page Mill
Road
NB AM
PM 8970 29
24
D
C
65
261
30
26
D
C
0.72%
2.91%
SB AM
PM 9200 20
58
C
E
322
87
21
59
C
F
3.50%
0.95%
I-280 - Page Mill
Road to Alpine Road
NB AM
PM 9200 23
45
C
D
39
157
23
46
C
D
0.42%
1.71%
SB AM
PM 9200 24
23
C
C
193
52
25
23
C
C
2.10%
0.57%
I-880 - I-280 to
Stevens Creek
Boulevard
NB AM
PM 6900 84
18
F
B
35
229
85
19
F
C
0.51%
3.32%
SB AM
PM 6900 20
29
C
D
308
93
22
30
C
D
4.46%
1.35%
I-880 - Stevens Creek
Boulevard to N.
Bascom Avenue
NB AM
PM 6900 81
25
F
C
32
206
82
26
F
C
0.46%
2.99%
SB AM
PM 6900 61
52
F
E
277
84
64
53
F
E
4.01%
1.22%
I-880 - N. Bascom
Avenue to The
Alameda
NB AM
PM 6900 76
29
F
D
24
155
76
30
F
D
0.35%
2.25%
SB AM
PM 6900 26
56
C
E
208
63
27
57
D
E
3.01%
0.91%
I-880 - The Alameda
to Coleman Avenue
NB AM
PM 6900 84
29
F
D
18
116
84
30
F
D
0.26%
1.68%
SB AM
PM 6900 31
74
D
F
156
47
32
75
D
F
2.26%
0.68%
I-880 - Coleman
Avenue to SR 87
NB AM
PM 6900 54
33
E
D
14
87
54
33
E
D
0.20%
1.26%
SB AM
PM 6900 31
64
D
F
117
35
32
64
D
F
1.70%
0.51%
I-880 - SR 87 to N.
1st Street
NB AM
PM 6900 55
40
E
D
14
87
55
41
E
D
0.20%
1.26%
SB AM
PM 6900 35
73
D
F
117
35
36
74
D
F
1.70%
0.51%
I-880 - N. 1st Street
to US 101
NB AM
PM 6900 72
44
F
D
13
78
72
45
F
D
0.19%
1.13%
SB AM
PM 6900 25
85
C
F
105
32
26
86
C
F
1.52%
0.46%
I-880 - US 101 to E.
Brokaw Road
EB AM
PM 6900 55
60
E
F
10
62
55
61
E
F
0.14%
0.90%
WB AM
PM 6900 24
67
C
F
84
26
24
67
C
F
1.22%
0.38%
I-880 - E. Brokaw
Road to Montague
Expwy
EB AM
PM 6900 30
36
D
D
6
37
30
36
D
D
0.09%
0.54%
WB AM
PM 6900 30
79
D
F
50
16
30
79
D
F
0.72%
0.23%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-880 - Montague
Expwy to Great Mall
Pkwy
EB AM
PM 6900 27
65
D
F
3
19
27
65
D
F
0.04%
0.28%
WB AM
PM 6900 41
75
D
F
25
8
41
75
D
F
0.36%
0.12%
SR 237 - SR 85 to
Central Expressway
EB AM
PM 4400 82
23
F
C
7
50
82
23
F
C
0.16%
1.14%
WB AM
PM 4400 24
56
C
E
63
16
24
56
C
E
1.43%
0.36%
SR 237 - Central
Expressway to Maude
Avenue
EB AM
PM 4400 31
13
D
B
4
25
31
13
D
B
0.09%
0.57%
WB AM
PM 4400 13
62
B
F
32
8
13
62
B
F
0.73%
0.18%
SR 237 - Maude
Avenue to US 101
EB AM
PM 4400 60
25
F
C
2
13
60
25
F
C
0.05%
0.30%
WB AM
PM 4400 31
60
D
F
24
6
31
60
D
F
0.55%
0.14%
High-Occupancy Vehicle (HOV) Lanes
SR 85 - SR 87 to
Almaden Expressway
NB AM
PM 1650 61
12
F
B
4
1
61
12
F
B
0.24%
0.06%
SB AM
PM 1650 4
20
A
C
0
3
4
20
A
C
0.00%
0.18%
SR 85 - Almaden
Expressway to
Camden Avenue
NB AM
PM 1650 45
9
D
A
8
2
45
9
D
A
0.48%
0.12%
SB AM
PM 1650 10
24
A
C
1
6
10
24
A
C
0.06%
0.36%
SR 85 - Camden
Avenue to Union
Avenue
NB AM
PM 1650 42
10
D
A
11
3
42
10
D
A
0.67%
0.18%
SB AM
PM 1650 8
30
A
D
1
9
8
30
A
D
0.06%
0.55%
SR 85 - Union
Avenue to S. Bascom
Avenue
NB AM
PM 1650 37
11
D
A
14
4
37
11
D
A
0.85%
0.24%
SB AM
PM 1650 5
37
A
D
1
11
5
37
A
D
0.06%
0.67%
SR 85 - S. Bascom
Avenue to SR 17
NB AM
PM 1650 77
18
F
B
19
5
78
18
F
B
1.15%
0.30%
SB AM
PM 1650 14
25
B
C
2
15
14
25
B
C
0.12%
0.91%
SR 85 - SR 17 to
Winchester Blvd
NB AM
PM 1650 90
8
F
A
38
10
92
8
F
A
2.30%
0.61%
SB AM
PM 1650 6
24
A
C
4
30
6
24
A
C
0.24%
1.82%
SR 85 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 1650 46
8
D
A
42
10
47
8
E
A
2.55%
0.61%
SB AM
PM 1650 4
29
A
D
2
33
4
29
A
D
0.12%
2.00%
SR 85 - Saratoga
Avenue to Saratoga-
Sunnyvale Road
NB AM
PM 1650 31
7
D
A
8
2
31
7
D
A
0.48%
0.12%
SB AM
PM 1650 6
26
A
C
1
7
6
26
A
C
0.06%
0.42%
SR 85 - Saratoga-
Sunnyvale Road to
Stevens Creek Blvd
NB AM
PM 1650 21
8
C
A
0
0
21
8
C
A
0.00%
0.00%
SB AM
PM 1650 6
31
A
D
0
0
6
31
A
D
0.00%
0.00%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 85 - Stevens
Creek Blvd to I-280
NB AM
PM 1650 21
8
C
A
0
0
21
8
C
A
0.00%
0.00%
SB AM
PM 1650 9
29
A
D
0
0
9
29
A
D
0.00%
0.00%
SR 85 - I-280 to W.
Homestead Road
NB AM
PM 1650 60
9
F
A
0
0
60
9
F
A
0.00%
0.00%
SB AM
PM 1650 7
29
A
D
0
0
7
29
A
D
0.00%
0.00%
SR 85 - W.
Homestead Road to
W. Fremont Avenue
NB AM
PM 1650 41
5
D
A
5
21
41
5
D
A
0.30%
1.27%
SB AM
PM 1650 9
21
A
C
42
11
10
21
A
C
2.55%
0.67%
SR 85 - W. Fremont
Avenue to El Camino
Real
NB AM
PM 1650 47
9
E
A
3
24
47
9
E
A
0.18%
1.45%
SB AM
PM 1650 7
25
A
C
26
8
7
25
A
C
1.58%
0.48%
SR 85 - El Camino
Real to SR 237
NB AM
PM 1650 39
7
D
A
2
12
39
7
D
A
0.12%
0.73%
SB AM
PM 1650 9
29
A
D
16
5
9
29
A
D
0.97%
0.30%
SR 85 - SR 237 to
Central Expressway
NB AM
PM 1650 24
5
C
A
1
6
24
5
C
A
0.06%
0.36%
SB AM
PM 1650 7
18
A
B
10
2
7
18
A
B
0.61%
0.12%
SR 85 - Central
Expressway to US
101
NB AM
PM 1650 15
7
B
A
1
8
15
7
B
A
0.06%
0.48%
SB AM
PM 1650 4
7
A
A
7
2
4
7
A
A
0.42%
0.12%
I-280 - Meridian
Avenue to I-880
NB AM
PM 1650 32
6
D
A
58
9
33
6
D
A
3.52%
0.55%
SB AM
PM 1650 13
82
B
F
7
46
13
84
B
F
0.42%
2.79%
I-280 - I-880 to
Winchester Blvd
NB AM
PM 1650 50
18
E
B
116
37
53
19
E
C
7.03%
2.24%
SB AM
PM 1650 12
92
B
F
14
92
12
97
B
F
0.85%
5.58%
I-280 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 1650 43
11
D
A
128
30
46
11
D
A
7.76%
1.82%
SB AM
PM 1650 10
29
A
D
10
102
10
30
A
D
0.61%
6.18%
I-280 - Saratoga
Avenue to Lawrence
Expressway
NB AM
PM 1650 58
7
E
A
139
20
62
7
F
A
8.42%
1.21%
SB AM
PM 1650 9
32
A
D
11
110
9
34
A
D
0.67%
6.67%
I-280 - Lawrence
Expressway to Wolfe
Road
NB AM
PM 1650 56
10
E
A
0
0
56
10
E
A
0.00%
0.00%
SB AM
PM 1650 12
39
B
D
0
0
12
39
B
D
0.00%
0.00%
I-280 - Wolfe Road to
De Anza Blvd
NB AM
PM 1650 50
9
E
A
0
0
50
9
E
A
0.00%
0.00%
SB AM
PM 1650 18
33
B
D
0
0
18
33
B
D
0.00%
0.00%
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-280 - De Anza Blvd
to SR 85
NB AM
PM 1650 32
10
D
A
24
83
32
11
D
A
1.45%
5.03%
SB AM
PM 1650 9
25
A
C
106
43
11
26
A
C
6.42%
2.61%
I-280 - SR 85 to
Foothill Expressway
NB AM
PM 1650 42
11
D
A
19
71
42
12
D
B
1.15%
4.30%
SB AM
PM 1650 15
18
B
B
94
31
16
18
B
B
5.70%
1.88%
I-280 - Foothill
Expressway to
Magdalena Avenue
NB AM
PM 1650 40
7
D
A
15
40
40
8
D
A
0.91%
2.42%
SB AM
PM 1650 13
13
B
B
66
21
14
13
B
B
4.00%
1.27%
Notes:
Bold font indicates unacceptable operations based on VTA’s LOS E Standard. Bold and highlighted indicates significant
impacts. 1 NB = Northbound, SB = Southbound. 2 AM = morning peak hour, PM = afternoon peak hour. 3 vph = vehicles per hour 4 Measured in passenger cars per mile per lane. 5 LOS = level of service. 6 Project trips added to individual freeway segments 7 Percent Contribution determined by dividing the number of project trips by the freeway segment’s capacity.
Source: 2011 Monitoring and Conformance Report, VTA, May 2012.
Impact TRANS-22: Completion of the proposed project would
add substantial amounts of traffic to the following ten mixed flow
segments and one HOV freeway segments operating at LOS F:
I-280, Southbound, El Monte Road to Magdalena Avenue
I-280, Northbound, SR 85 to Foothill Expressway
I-280, Southbound, Foothill Expressway to SR 85
I-280, Southbound, SR 85 to De Anza Boulevard
I-280, Southbound, De Anza Boulevard to Wolfe Road
I-280, Northbound, Lawrence Expressway to Wolfe Road
I-280, Southbound, Wolfe Road to Lawrence Expressway/
Stevens Creek Boulevard
I-280, Northbound, Saratoga Avenue to Lawrence Expressway/
Stevens Creek Boulevard
I-280, Southbound, Lawrence Expressway/Stevens Creek
Boulevard to Saratoga Avenue
I-280, Northbound, Winchester Boulevard to Saratoga Avenue
I-280, Northbound, Winchester Boulevard to I-880
I-280, Southbound, Winchester Boulevard to I-880
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I-280, Northbound, I-880 to Meridian Avenue
I-280, Southbound, I-880 to Meridian Avenue
I-280, Northbound, Meridian Avenue to Bird Avenue
I-280, Southbound, Meridian Avenue to Bird Avenue
I-280, Northbound, Bird Avenue to SR 87
I-280, Southbound, Bird Avenue to SR 87
I-280, Northbound, SR 87 to 10th Street
I-280, Southbound, SR 87 to 10th Street
I-280, Northbound, 10th Street to McLaughlin Avenue
I-280, HOV, Northbound, Saratoga Avenue to Lawrence
Expressway
I-280, HOV, Southbound, Winchester Boulevard to I-880
I-280, HOV, Southbound, I-880 to Meridian Avenue
SR 85, Northbound, Winchester Boulevard to SR 17 + HOVto
Camden Avenue
SR 85, Northbound, Saratoga Avenue to Winchester
Boulevard
SR 85, Southbound, SR 17 to Bascom Avenue
SR 85, Northbound, SR 17 to Bascom Avenue + HOV
SR 85, Southbound, Bascom Avenue to Union Avenue
SR 85, Northbound, Bascom Avenue to Union Avenue
SR 85, Northbound, Union Avenue to Camden Avenue
I-880, Southbound, Bascom Avenue to Stevens Creek
Boulevard
These freeway segments would be impacted under the Existing
Plus Project Conditions based on CMP guidelines. (S)
Mitigation Measure TRANS-22: The project sponsor shall pay a
$536,0001,292,215 fair share contribution towards two planned
transportation projects identified in VTA’s Valley Transportation
Plan 2035 (VTP 2035)2 that would improve traffic operations of the
impacted freeway segments and provide added transportation
2 The Valley Transportation Plan is a long-range vision for transportation in Santa Clara County. The VTA is
responsible for preparing and updating the VTP. The VTP 2035 identifies the programs, projects, and policies VTA would
like to pursue over the lifetime of the plan. It connects projects with anticipated funds and lays out a framework for the
development and maintenance of the transportation system over the next 25 years.
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capacity on parallel facilities: (1) SR 85 Express Lane project
(converting the existing HOV lane to a toll lane to allow single
occupant vehicles to drive in the HOV lane for a fee) between
Mountain View and San Jose; (2) eliminating the existing bottleneck
on southbound I-280 between El Monte Road and Magdalena
Avenue; and (23) either the Bus Rapid Transit (BRT) stations
proposed within Cupertino on Stevens Creek Boulevard at Wolfe
Road and De Anza Boulevard, or an alternative improvement or
study towards the improvement of the impacted I-280 corridor or a
parallel corridor that would provide capacity. The fair share
contribution amount was calculated in consultation with VTA staff
based on the project’s contribution to project growth on the impacted
freeway segment.
It is unlikely that the Express Lane or BRT project would be imple-
mented prior to project completion and that these improvements
would reduce the impact to a less-than-significant level. In addition,
the City has no control over the implementation of these mitigation
measures; therefore the impact to the freeway segments would
remain significant and unavoidable. (SU)
Response A8-9: This comment references Mitigation Measures TRANS-1, TRANS-5,
TRANS-14, TRANS-25, TRANS-26, and TRANS-29, which relate to
changes to the I-280/Wolfe Road freeway ramps. As explained in the Draft
EIR, these changes would be under the jurisdiction of Caltrans. The comment
that these changes remain within the Caltrans right-of-way is noted.
Response A8-10: Please see Response to Comment A4-4.
Response A8-11: This concluding comment is noted.
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B. ORGANIZATIONS
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COMMENTER B1
Silicon Valley Bicycle Coalition
Corinne Winter
July 22, 2013
Response B1-1: This introductory comment, which states that “Apple has done an exemplary
job of incorporating [the Silicon Valley Bicycle Coalition’s] suggestions to
make this part of Cupertino more bike-friendly,” is noted.
Response B1-2: This comment, which discusses the improvements to bike infrastructure and
facilities around the project site that Apple would implement as part of the
project, is noted. These improvements are discussed on pages 111 to 112 of
the Draft EIR and are graphically depicted in Figures III-20a through III-20f
of the Draft EIR.
The TDM measures proposed as part of the project and referenced in the
comment are described on pages 121 to 122 of the Draft EIR.
Response B1-3: The operations of southbound North Tantau Avenue were comprehensively
evaluated from a multi-modal perspective. Evaluation of the VISSIM model
results during the PM peak hour showed that the vehicular volumes traveling
south from the project site and turning right onto Vallco Parkway would
warrant the provision of a second southbound through lane at the I-280
overcrossing. The provision of a single through lane on the I-280 overcross-
ing would result in a bottleneck with significant queues on southbound North
Tantau Avenue. It should be noted that excessive queuing can lead to impa-
tient driving behavior, which could adversely affect bicycle and pedestrian
travel on southbound North Tantau Avenue.
Response B1-4: Reverse angle parking is safer for bicyclists. However, it is currently not
being proposed for Vallco Parkway as it is not yet an established vehicle
parking configuration and therefore is not familiar to most motorists.
Although the provision of 6-foot bike lanes would further improve the
bicycling environment, the provision of 5-foot bike lanes is adequate and
meets Caltrans engineering standards.
Response B1-5: This concluding comment is noted.
COMMENTER B2
SEIU-United Service Workers West
July 19, 2013
Response B2-1: This comment does not pertain to the adequacy of the Draft EIR and is noted.
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COMMENTER B3
Concerned Citizens of Cupertino
July 17, 2013
Response B3-1: This comment, which conveys a table of contents for the remainder of the
letter, is noted.
Response B3-2: This comment provides information from the City of Menlo Park on the
Facebook Campus Project and a quote from the Cupertino Courier on the
Apple Campus 2 project, and is noted.
Response B3-3: This comment provides suggestions for the City to consider in addressing
traffic congestion and parking. See also Master Response: Traffic
Congestion. In response to the comment, “What is the baseline number of
peak hour trips,” as noted on page 388 of the Draft EIR, the baseline number
of daily trips in the AM Peak Hour is 1,270 and the number of PM Peak
Hour trips is 1,587.
Response B3-4: As described in Chapter III, Project Description, a total of 14,200 employees
are proposed to be located at the Apple Campus 2 project at build-out. The
terms of Apple leases at other locations is not part of the project evaluated in
the Draft EIR.
Response B3-5: Please see Chapter V., Setting, Impacts and Mitigation Measures, page 182
in the Draft EIR for a discussion of the baseline environmental setting used
in the Draft EIR. The estimated amount of vehicle traffic to be added by the
project is as stated in the Transportation Impact Analysis page iii, Appendix
B of the Draft EIR and on pages 387 and 388 of the Draft EIR.
Response B3-6: This comment provides information on parking ratios and spaces, and states
that the number of parking spaces provided is less than the number of spaces
required by the City’s Parking Ordinance. See the evaluation of parking in
the Draft EIR on pages 432-437, which explains that in Planned
Development zones, in which the project is located, the parking ratios set out
in the City’s Parking Ordinance may be used as a guideline and that it is
appropriate to consider site- and project-specific parking needs. The Draft
EIR analyzes the anticipated parking needs and concludes that the amount of
parking provided would be adequate for the project with implementation of
Mitigation Measure TRANS-35. The City has balanced the need to provide
adequate parking to ensure that neighboring areas are not impacted and the
concept of using limited parking as a tool to manage the number of people
that drive to the project site, and has concluded that the provision of 10,980
parking spaces is adequate, based in part on the parking study conducted at
the Infinite Loop and Mariani Avenue campuses. The Draft EIR confirms
that the proposed parking would be adequate to meet on-site demand, while
also recommending Condition of Approval CA-TRANS-3 to ensure the
ongoing management of parking issues, if any arise.
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Response B3-7: The existing level of service at the intersection of Blaney Avenue/Homestead
Road (Intersection #13) and Wolfe Road/Stevens Creek Boulevard (Intersec-
tion #24) is shown in Figure V.I-6 on page 371 of the Draft EIR. The level of
service at these intersections with the project is shown on Figure V.I-8 on
page 392 of the Draft EIR.
The intersections of Blaney Avenue/Stevens Creek Boulevard and Stevens
Creek Boulevard/Perimeter Road were not included as study intersections,
and thus associated level of service is not reported in the Draft EIR. The side
streets at these intersections have comparatively low traffic volumes and they
operate at good levels of service. The project would add traffic to the Stevens
Creek Boulevard approaches at these intersections, which have excess
capacity. Therefore it was determined that the project would not have an
impact at these locations and no further analysis was required.
Wolfe Road and Perimeter Road do not intersect. The comment is likely
referring to the right-turn-only ramp connectors between Wolfe Road and
Perimeter Road. These connectors are right-turn-only locations to and from
the Vallco Shopping Mall, with few conflicting movements and, therefore,
were not analyzed. Perimeter Road was designed to accommodate traffic
with full occupancy of the shopping center. Any traffic added by the project
to Perimeter Road would comprise people shopping at the center and would
not exceed the capacity of the roadway. Therefore no analysis of project
impacts along Perimeter Road was conducted.
Response B3-8: The project sponsor would be required to work with the City of Cupertino,
VTA, and Caltrans to construct interchange improvements, including ramp
widening, at the Wolfe Road/I-280 interchange, to mitigate project impacts.
The sponsor would also be required to pay a fair share contribution to the
planned Express Lanes on SR 85 and make either a contribution to the BRT
planned on Stevens Creek Boulevard or an alternative improvement or study
towards the improvement of the I-280 corridor to offset freeway impacts.
While the Express Lane project does not add lanes, it allows single occupant
vehicles (SOVs) to use the carpool lane, thus allowing more SOVs to use the
other lanes, therefore improving freeway operations. Both the VTA and
Caltrans support this approach.
Response B3-9: Unused traffic mitigation funds would be returned to Apple.
Response B3-10: This comment provides information from a City Council report on the Clyde
Avenue (Samsung) project and is noted.
Response B3-11: Please see Master Response #12: Trip Cap and Master Response: Adequacy
of TDM Penalties.
Response B3-12: Trip count monitoring would commence within 6 months of project
occupancy, even partial occupancy of Phase 1. If AM or PM peak hour trip
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counts are not met, then Apple would be required to meet with the City within
60 days of not meeting the trip count to develop a plan and identify new TDM
measures. Please see Master Response: Adequacy of TDM Penalties.
Response B3-13: This comment provides information from a City Council report on the Clyde
Avenue (Samsung) project and is noted. Similar to the agreement between
Samsung and the City of Mountain View, the TDM monitoring program, as
described on pages 443 to 448 of the Draft EIR, would institute substantial
penalties if Apple does not meet the established peak trip counts goal.
Furthermore, such penalties would be assessed for every day during the
established monitoring period that the peak trip counts exceed the goal.
Please see Master Response #12: Trip Cap and Master Response: Adequacy
of TDM Penalties. As discussed in Master Response: Adequacy of TDM
Penalties, even a modest exceedance of 200 trips during the AM peak period
and 200 trips during the PM peak period (approximately 4.7 percent of the
AM peak trip counts goal and 4.5 percent of the PM peak trip counts goal)
would incur a penalty of $260,000 over a 6-month monitoring period. These
penalties are comparable to those established by the City of Mountain View
for Samsung.
Response B3-14: This comment provides information on establishing a transportation
management association and TDMs from the City of Mountain View, Palo
Alto, and Emeryville, and is noted.
Response B3-15: This comment provides information on measures required of employment
uses associated with the provision of housing and is noted.
Response B3-16: This comment provides recommendations and suggestions for the provision
of park space in reference to Mitigation Measure PLAN-1 and support for
Apple’s participation in the design of the Calabazas Creek Trail. See also
Master Response #13: Calabazas Creek Trail.
Response B3-17: This comment suggests that an independent fiscal impact analysis be
prepared and considered in the Draft EIR and additional information on tax
revenues and the Development Agreement be provided. In response, please
see Master Response #2: Project Merits, clarifying that detailed responses to
comments that raise only economic or social issues, rather than environ-
mental issues, are not required. In regards to a discussion of school service
boundaries and project effects on schools, see pages 563-567 and 581-584 in
the Draft EIR. This comment also provides information on local sales tax
revenue, tax sharing, construction taxes and fees, and fees and required
funding of transportation improvements as stated in Mitigation Measures
contained in the Draft EIR. These comments are noted, but to the extent that
they focus on fiscal and economic considerations, no further response is
required.
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Response B3-18: This comment provides additional information to support comment B3-17
and is noted.
Response B3-19: This comment provides additional information to support comment B3-17
and is noted.
Response B3-20: This comment provides information and suggestions regarding public access
to the Apple property, design and construction of the Calabazas Creek Trail,
and the closure of Pruneridge Avenue (per Mitigation Measures PLAN-1,
PLAN-2, PLAN-3 and TRANS-31). The comment provides information
from other projects and planning documents, and support for construction of
the Calabazas Creek Trail and a public park on Tantau Avenue. Please see
Master Response #13: Calabazas Creek Trail, Master Response #5: Public
Access Through Project Site.
Response B3-21: This comment provides additional information to support comment B3-20
and is noted.
Response B3-22: This comment supports an alternative that would retain Pruneridge Avenue,
and have the Apple Campus project extended and built over the road. As
stated on page 597 of the Draft EIR, CEQA requires the analysis of a
reasonable range of alternatives to the proposed project, or to the location of
the proposed project, which would feasibly attain most of the proposed
project’s basic objectives and avoid or substantially lessen any of the
significant effects of the proposed project. The range of alternatives required
in an EIR is governed by a “rule of reason” that requires the EIR to set forth
only those alternatives necessary to permit a reasoned choice. The alternative
suggested in this comment is similar to three alternatives considered in the
Draft EIR. The retention of Pruneridge Avenue as a public right-of-way was
incorporated into a project alternative (the Pruneridge Avenue alternative),
which is discussed on pages 605 to 612 of the Draft EIR. As discussed on
page 626 of the Draft EIR, two additional alternatives allowing for public
access across the site (a Pruneridge Avenue Tunnel alternative and a Mobility
and Park alternative) were rejected from detailed analysis because they would
interfere with major utility lines, would infringe on private property, result in
adverse visual impacts, would incur significant costs, and/or would still pose
significant security concerns. The alternative proposed in this comment would
have similar effects to those alternatives already evaluated in the Draft EIR.
This comment also repeats comments made in B3-16 and B3-20 in regards to
support for constructing the Calabazas Creek Trail as publically accessible
open space. See Master Response #13: Calabazas Creek Trail.
As discussed on page 626 of the Draft EIR, a Pruneridge Avenue Tunnel
alternative was preliminarily evaluated. Such an alternative would maintain
the current east/west thoroughfare through the project site. However, the
evaluation concluded that construction of the tunnel would interfere with a
major sanitary sewer line, infringe on private property, result in adverse
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visual impacts, and incur significant costs. The increased excavation would
also require additional off-haul of soil and would increase greenhouse gas
emissions at the project site. Similarly, the construction of a “land bridge”
over Pruneridge Avenue could require the import of more material (and
associated air pollutant and greenhouse gas emissions).
The development of a bridge across the project site, connecting North Wolfe
Road to North Tantau Avenue, would result in significant visual and other
environmental impacts, such as noise impacts, to the adjacent neighbors,
especially sensitive receptors at The Hamptons. The foundation for such a
large structure would interfere with utility and road systems serving both the
project and The Hamptons and could require the acquisition of right-of-way
to accommodate the structural system. A bridge would also conflict with a
key project objective related to the provision of a single, secure campus, as
(depending on its design) the bridge could allow for views directly into
campus buildings.
Response B3-23: This comment provides additional information to support comment B3-22
and is noted.
Response B3-24: The comment provides information on development agreements and
community benefits related to other projects, and states that “mitigation
measures should not be considered direct community benefits.” The
mitigation measures identified in the Draft EIR are required to lessen or
avoid the significant environmental effects of the project, as required by
CEQA.
Response B3-25: See Response B3-22.
Response B3-26: This comment provides additional information to support comment B3-25
and is noted.
COMMENTER B4
Cupertino Chamber of Commerce
Mark Matsumoto, Government Affairs Specialist
July 10, 2013
Response B4-1: This comment, which conveys an attached letter, is noted.
Response B4-2: Please see Master Response #2: Project Merits.
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COMMENTER B5
Erik’s Deli Café
Sam Ashknaz, Owner
July 8, 2013
Response B5-1: Please see Master Response #2: Project Merits.
COMMENTER B6
Cypress Hotel and Park Place Restaurant
Maria Streeby, Director of Operations
June 24, 2013
Response B6-1: Please see Master Response #2: Project Merits.
COMMENTER B7
Santa Clara & San Benito Counties Building & Construction Trades Council
Neil Struthers, CEO
June 7, 2013
Response B7-1: This comment, which conveys an attached letter, is noted.
Response B7-2: Please see Master Response #2: Project Merits.
COMMENTER B8
Los Gatos Chamber of Commerce
Dianne Anderson, President
June 20, 2013
Response B8-1: Please see Master Response #2: Project Merits. The comment about the
project’s “environmental and sustainable ideas” is noted. The environmental
implications of these sustainability features are explored throughout the Draft
EIR, but specifically in Section V.K, Greenhouse Gas Emissions and
Sustainability.
COMMENTER B9
Cupertino Historical Society
Donna Austin, President
June 19, 2013
Response B9-1: This comment, which expresses support for the relocation of Glendenning
Barn, is noted. The proposed relocation of the barn is described on pages 133
to 134 of the Draft EIR. The environmental implications of this proposed
relocation are described on pages 279 to 283 of the Draft EIR.
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COMMENTER B10
Erik’s Deli Café
Sam Ashknaz, Owner
June 12, 2013
Response B10-1: Please see Master Response #2: Project Merits.
COMMENTER B11
VJONES Salon
Barry Jones, CEO
June 12, 2013
Response B11-1: Please see Master Response #2: Project Merits.
COMMENTER B12
Cupertino Chamber of Commerce
June 12, 2013
Response B12-1: Please see Master Response #2: Project Merits.
COMMENTER B13
Silicon Valley Leadership Group
Carl Guardino, President/CEO
June 11, 2013
Response B13-1: This comment, which conveys an attached letter, is noted.
Response B13-2: Please see Master Response #2: Project Merits. This comment references
some of the sustainability features which are incorporated into the project
and are discussed in the Draft EIR, including the TDM Program, the
provision of open space, and the use of alternative forms of energy. No
further response is required.
COMMENTER B14
City of Cupertino
Orrin Mahoney, Mayor
June 26, 2013
Response B14-1: This comment comprises a transcribed interview with City of Cupertino
Mayor Orrin Mahoney on KMTV Community Television, which serves
Cupertino, Los Altos, and Mountain View. This transcript contains no
comments on the adequacy of the Draft EIR. The City generally agrees with
the characterization of an EIR that is conveyed in the comment – specifically,
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that the EIR is a disclosure document that identifies the significant
environmental impacts of the project, but does not prescribe a specific
outcome regarding project approval.
COMMENTER B15
Kimco Realty
David Jamieson, Vice President Asset Management
May 16, 2013
Response B15-1: This comment, which conveys an attached letter, is noted.
Response B15-2: Please see Master Response #2: Project Merits. The roadway changes
proposed as part of the project, including those in the vicinity of Cupertino
Village, are discussed on pages 100 to 120 of the Draft EIR.
COMMENTER B16
Bitter + Sweet
Janice Chua, Owner
June 7, 2013
Response B16-1: Please see Master Response #2: Project Merits.
COMMENTER B17
Los Altos Patch
L.A. Chung, Editor
June 6, 2013
Response B17-1: This comment comprises an email exchange between a Patch.com editor and
City of Cupertino Mayor, in which the editor asks for the Mayor’s thoughts
on the Draft EIR. The specific environmental topics listed in the comment
are all discussed in detail in the Draft EIR, as follows:
Closure of Pruneridge Avenue: discussed throughout Draft EIR, but see
in particular pages 150-152; 156-159; and 427-430.
Hazardous materials from building demolition: see pages 344-345 of
Draft EIR.
Relocation of Glendenning Barn: see pages 279-283 of Draft EIR.
Protection of trees along North Wolfe Road and East Homestead
Avenue: see Figure III-3 (Existing and Proposed Trees) on page 57 of
Draft EIR.
Noise abatement: discussed throughout Section V.J, Noise, but see in
particular pages 464-480.
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Jobs, housing availability, and schools: see pages 225-233 for a
discussion of the interrelationship between jobs and housing demand; see
pages 581-584 for a discussion of the project’s anticipated less-than-
significant impacts on schools.
COMMENTER B18
San Jose Silicon Valley Chamber of Commerce
Matthew R. Mahood, CEO and President
May 31, 2013
Response B18-1: This comment, which conveys an attached letter, is noted.
Response B18-2: Please see Master Response #2: Project Merits.
COMMENTER B19
Sand Hill Property Company
Peter Pau
May 29, 2013
Response B19-1: Please see Master Response #2: Project Merits.
COMMENTER B20
Silicon Valley Leadership Group
Shiloh Ballard
June 26, 2013
Response B20-1: Please see Master Response #2: Project Merits.
COMMENTER B21
Santa Clara Chamber of Commerce
Steve Van Dorn
June 26, 2013
Response B21-1: Please see Master Response #2: Project Merits.
COMMENTER B22
Sierra Club Loma Prieta Chapter
Megan Fluke Medeiros, Conservation and Development Manager
July 22, 2013
Response B22-1: This comment, which conveys an attached letter, is noted.
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Response B22-2: This introductory comment, which summarizes the Sierra Club Loma Prieta
Chapter’s guidelines for evaluating development projects, is noted.
Response B22-3: This comment lists components of the project that the commenter supports.
Please see Master Response #4: Nitrogen Deposition for an explanation of
the finding in the Draft EIR that the project would not make a significant
contribution to cumulative impacts associated with nitrogen deposition.
Response B22-4: This comment introduces the next several comments, which focus on the
transportation impacts of the project.
Response B22-5: The mode-share split target of 34 percent identified for the project in
Mitigation Measure TRANS-9b is reasonable given the project’s suburban
location and distance from rail stations, which pose an impediment to a large
scale adoption of mass transit services. Some Caltrain stations are reasonably
close (i.e., Lawrence and Sunnyvale), but lack the express service offered at
the Mountain View station, for example. Apple would addresses the relative
scarcity of public transit services by adding TDM strategies. Apple’s current
TDM Program includes a variety of measures to reduce travel by single
occupancy vehicles, including the use of commuter coach bus services, mass
transit shuttle links, ride share matching, bike facilities, transit initiatives,
shared bicycles, short-term car rentals, among others. Refer to pages 59 to
60 of the Draft EIR for a complete list of current TDM measures. While a
higher non-single occupant vehicle (SOV) mode share would be supported
by the City of Cupertino, the measures needed to achieve such a higher mode
share could yield unacceptable consequences (including increased parking
demand in residential neighborhoods adjacent to the project site). Thus the
diversion rate achieved at Facebook or Stanford may not be desirable at the
project site, when weighing competing interests. The City weighed these
competing concerns in requiring achievement of the 34 percent goal. As part
of the project, Apple would continue to implement, and further expand, its
TDM Program, with a mandatory target to increase the alternative mode
share from 28 percent to 34 percent (i.e., a reduction in peak hour trips of 6
percentage points). Counting the total number of “peak hour vehicle trip
counts” at each of the project driveways would help determine whether
Apple is meeting the required 34 percent target mode share set by the City.
Apple would provide supplemental information about the TDM Program
being implemented and rate of use of the TDM measures.
The project’s TDM goal of 34 percent at full buildout has been identified as a
reasonable target because it is considered relatively aggressive but achievable
for office developments in suburban locations greater than ½ mile from a rail
station. To ensure that Apple achieves and maintains its targeted TDM
participation rate, the City would require implementation of the monitoring
program, described in the TDM Program Expansion subsection of the Draft
EIR (see pages 441-444) and in Master Response #9: Monitoring TDM
Program. Any failure to achieve 34 percent participation would result in
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financial fines and penalties. The City would continue to work with Apple to
identify opportunities to minimize commutes by single occupancy vehicles,
but believes the mitigation requirement is appropriate as a minimum
threshold.
Response B22-6: The City of Cupertino supports using TDM measures to reduce vehicle
traffic in lieu of constructing intersection vehicle capacity improvements, in
accordance with a TDM First strategy. To this end, the City has worked
closely with Apple to identify a relatively aggressive but achievable TDM
participation rate of 34 percent. However, a TDM First strategy may be
impractical or undesirable. For example, the comment suggests expanding
parking capacity only once all TDM measures have been exhausted. Because
all parking would be provided either underground or in structures, it would
be infeasible to retrofit the site design to add parking if TDM measures prove
to be insufficient. For that reason, the City has analyzed the parking proposed
by Apple to ensure that it accommodates demand without incentivizing the
use of single occupancy motor vehicles. As discussed on pages 434 to 436 of
the Draft EIR, the parking proposed for the site is based on a 34 percent
TDM participation rate. Further, once the project is built and if the TDM
measures do not achieve the needed vehicle trip reduction, it may be
infeasible for the City to require the project sponsor to construct the
intersection improvements to reduce the impacts associated with lower-than-
expected TDM participation. In this case, the significant roadway impacts
would remain unmitigated. For several significantly affected intersections,
the level of TDM participation needed to achieve an acceptable level of
operation was determined to be infeasible – in most circumstances, requiring
participation far in excess of 65 percent. The City has balanced the need to
ensure acceptable transportation conditions against identifying an aggressive
but achievable TDM participation rate. The TDM program does not preclude
the ability of Apple to increase its implementation to higher levels in the
future if deemed feasible.
Response B22-7: This comment suggests that the trees proposed for removal as part of the
project be relocated. As discussed on page 95 of the Draft EIR, of the 4,506
existing trees on the site at least 90 trees would be transplanted. In addition,
3,620 trees would be removed. The identification of trees appropriate for
transplantation was the result of several arborist studies conducted on the
project site, culminating in A Review of the Consolidated Arborist Report for
the Apple Campus 2 Project.1 That document indicated general agreement on
the trees proposed for transplant versus removal. Trees were rejected as
candidates for transplant due to several reasons, including 1) poor health; 2)
diminished potential to survive a transplant; 3) conflicts with existing
utilities; or 4) constraints associated with steep slopes and other existing site
conditions. Furthermore, of the existing trees on the site, approximately 75
1 Bench, Michael L., 2013. A Review of the Consolidated Arborist Report for the Apple Campus 2 Project. May 29.
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percent are non-native species. Of these non-native species, many individual
trees are not suited to the climate or location of the area, and have water
needs that exceed those desired in the area. Therefore, the transplantation of
additional trees would not reduce the environmental impacts that would
result from the project and would not be desirable from an environmental
perspective.
Response B22-8: As discussed on pages 130 to 133 of the Draft EIR, while the use of recycled
water is not required as part of the project, Apple has designed into the
project the ability to use recycled water in the cooling systems and for
limited indoor uses. Apple is also evaluating the use of recycled water for
irrigation. The likelihood of extending a recycled water line to the project site
was speculative when the Draft EIR was being prepared, but such an
extension is supported by Apple and the City.2 In addition, the extension of a
recycled water line into the project site would require approval of other
jurisdictions in addition to the City of Cupertino.
Response B22-9: As discussed on page 257, impacts related to the encroachment of develop-
ment into the Calabazas Creek corridor would be less than significant, as the
buffer around the creek that would be provided as part of the project would
adequately protect the creek and its adjacent banks. In addition, as described
on page 196 of the Draft EIR, the 50-foot buffer would comply with the basic
creek setback requirement established in the Santa Clara Valley Water
Resources Protection Collaborative’s Guidelines and Standards for Land Use
Near Streams. In the absence of City of Cupertino regulations for creek
buffers on private land, the expansion of the buffer around the creek to 100
feet would not reduce any of the significant effects of the project, including
those less-than-significant impacts on jurisdictional waters and wildlife
corridors, because the creek surroundings are currently highly urbanized.
Furthermore, the project would increase the amount of pervious surfaces on-
site, from approximately 43 acres to 102 acres, which may provide
stormwater quality benefits, including to Calabazas Creek.
Response B22-10: This comment, which suggests that Apple add a store or museum to the
project, is noted. This comment does not pertain to environmental issues
surrounding the project and no further response is required.
Response B22-11: The types of public amenities identified in this comment (fencing, pedestrian
seating, and public art) are already incorporated into three mitigation
measures in the Draft EIR. Mitigation Measure PLAN-2 would require the
installation of “publicly accessible amenities (e.g., bicycle racks, benches,
2 On August 13, 2013 the Sunnyvale City Council approved the extension of a recycled water line that would reach
the project site. This extension is described on pages 130 to 133 of the Draft EIR. The approval of this recycled water line,
which underwent independent environmental review, does not change the impact findings in the Draft EIR related to water
supply and demand.
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attractive pedestrian-oriented lighting, and landscaping) along the project site
perimeter,” in addition to a coordinated wayfinding scheme and landscaping
along the North Wolfe Road bridge over I-280 that could enhance the
aesthetic character of the project site perimeter. Mitigation Measure PLAN-3
would require aesthetic and functional improvements along an alternate creek
trail, part of which would be adjacent to the boundaries of the project site.
These improvements would include signage, plantings that reference
Calabazas Creek, pedestrian-scaled lighting, rest areas or picnic tables,
pavement features that reference the creek and/or water, and decorative
fencing and guard rails.
Response B22-12: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted.
Response B22-13: The comment suggests that the City ask or require that Apple not increase
vehicle trips over existing or “baseline” conditions. This suggestion would be
inconsistent with the objective of accommodating 14,200 employees. While
the actual employee capacity of the site today is 9,800, for CEQA baseline
purposes, the number of employees was assumed to be 4,844, which was the
estimated number of employees working at the project site in August 2011,
the date the Notice of Preparation was issued (existing employment on the
site has diminished further since August 2011). At that point, Hewlett-
Packard was departing the site, and Apple was occupying only a portion of
the site, in preparation for the project. In addition, most of those 4,844
employees are existing Apple employees, meaning that they already have a
comparatively low trip generation due to the existing TDM Program.
Achieving an increase of 9,356 employees without increasing vehicle trips
would not be feasible and would constrain employment growth at the project
site. Please also refer to Master Response #12: Trip Cap.
Response B22-14: The City does not have a traffic impact fee. In lieu of imposing such a fee,
the City requires major development projects to undergo CEQA review, and
requires development project sponsors to fund improvements identified as
mitigation measures in CEQA review documents. In this way, the City
ensures that there is a nexus between project impacts and transportation
improvement measures.
Response B22-15: As discussed on page 156 of the Draft EIR, the City imposes a Housing
Mitigation Fee on office, industrial, hotel, retail, and research and develop-
ment uses that funds the development of affordable housing throughout the
City. As part of the project, Apple would pay double the rate applicable to
office and research and development projects in Planned Industrial, (P(MP),
zoned areas.
Response B22-16: This concluding comment is noted.
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COMMENTER B23
Apple Inc.
James C. Fowler, Associate General Counsel-Real Estate
Dan Whisenhunt, Senior Director
July 22, 2013
Response B23-1: This introductory comment is noted.
Response B23-2: This comment introduces a mitigation measure that is suggested to substitute
for Mitigation Measure TRANS-23, which would require Apple to reduce the
number of left-turn lanes at the Main Project Driveway on North Wolfe Road
from three to two.
Response B23-3: This comment states that the Apple’s proposal for three left-turn lanes exiting
the project site on to North Wolfe Road can be implemented without creating
the weaving impact identified in Impact TRANS-23, and without implement-
ing Mitigation Measure TRANS-23, which would require reducing the
number of left-turn lanes from three to two. The Draft EIR fully analyzes the
impacts of three left-turn lanes exiting the project site on to North Wolf Road
(see pages 414 to 418 of the Draft EIR), and concludes that the impacts on
traffic operations would be less than significant but that a three-lane
driveway exit design would have a significant impact on safety due to
“weaving.” Mitigation Measure TRANS-23, which requires the number of
driveway left-turn lanes to be reduced from three to two, would reduce this
impact to a less-than-significant level (see pages 416 to 418 of the Draft
EIR).
The commenter states that the weaving impact is unlikely to occur for the
reasons stated in the comment, and that the following measures also would
reduce the weaving impact to a less-than-significant level without requiring a
reduction to two lanes: (i) installing clear signage at the exit approach,
including overhead signs, painted directions on lanes and appropriate lane
striping; (ii) internal employee education; and (iii) traffic monitors.
The commenter proposes that these measures be implemented for a nine-
month period during which the driveway exit would be monitored by an
independent observer at the expense of the project sponsor. If the weaving
behavior predicted in the Draft EIR is observed, the third lane would be
closed.
In response to this comment, City staff and City consultants evaluated the
commenter’s proposal, and the City has concluded that the following
alternative mitigation measure would reduce the impact to a less-than-
significant level in lieu of reducing the proposed driveway exit to two lanes.
In order to fully evaluate the effectiveness of the measure and to consider any
additional design refinements that might be warranted, the measure would be
implemented on a nine-month trial basis.
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Page 418 of the Draft EIR is revised as follows:
Impact TRANS-23: Based on City of Cupertino standards, the
design of the project with three left-turn lanes on the Wolfe Road
driveway approach would cause a substantial increase in
conflicts due to vehicles weaving on Wolfe Road between the
driveway and the I-280 ramps in order to merge and align into
the correct lanes to enter the freeway upon exiting the campus.
(S)
Implementation of one of the following two mitigation measures
would reduce this impact to a less-than-significant level:
Mitigation Measure TRANS-23: At the main project driveway on
Wolfe Road, the project sponsor shall reduce the number of left turn
lanes from three to two. This would reduce the weaving on
southbound Wolfe Road between the driveway and the I-280
northbound on-ramp since there would be, at most, a one-lane lane
change in order for drivers to align themselves to the correct lane.
(LTS)
OR
Mitigation Measure TRANS-23 (Alternate): The project sponsor
shall be permitted to construct three left-turn exit lanes from the
project site to Wolfe Road if all of the following measures are
implemented:
• Clear signage, including but not limited to overhead signs, shall
be installed to indicate the destination of each of the three exit
lanes in order to discourage unsafe lane changes.
• Each lane on Wolfe Road, between the driveway and Pruneridge
Avenue, shall be clearly marked by painted stripes, directional
arrows, and destination legends to indicate the destination of
each lane and to indicate by double lines or other appropriate
markings that changing lanes is a violation of law.
• The project sponsor shall fund the following measures for a trial
period of nine months from issuance of the first certificate of
occupancy for the Main Building and shall install closed-circuit
video cameras linked to the City’s Traffic Operations Center to
continuously record vehicle movements at the project driveway
and along southbound Wolfe Road. Trained personnel, who are
independent from the project sponsor, shall periodically review
the video footage at the direction of the City, and provide a
report at the end of each month to the Public Works Department.
This report shall document any unsafe or illegal lane changes
(violations) observed, noting accidents caused by violations and
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noting whether, in the professional judgment of the independent
observer, the observed violations constitute a safety problem that
should be addressed and, if so, recommending measures to
address them.
• If, at any time following the nine-month trial period
implementation of the measures listed above do not substantially
prevent violations, in the professional opinion of the independent
observer and the City, the City shall determine whether additional
measures are required, or whether the number of lanes must be
reduced to two exit lanes. Monitoring shall continue until nine
months following full occupancy of the project.
• A penalty of $500 per violation during the PM 2-hour peak
period per day shall be paid by the project sponsor to the City.
The number of violations shall be determined by the independent
observer based upon review of the video footage and
extrapolated to account for daily activity during the PM 2-hour
peak period should daily video footage not be reviewed.
• The project sponsor shall develop employee education materials,
to the satisfaction of the City, explaining the proper use of the
driveway exit lanes without weaving among lanes. (LTS)
Response B23-4: This comment, which states support for the finding in the Draft EIR that the
provision of three left-turn lanes would not result in significant vehicle
delays on North Wolfe Road, is noted. See Response B23-3.
Response B23-5: This concluding comment is noted.
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C. INDIVIDUALS
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COMMENTER C1
Tappan (Tap) Merrick
June 21, 2013
Response C1-1: This comment does not pertain to the environmental analysis in the Draft
EIR. It has been forwarded to the City of Cupertino planner assigned to the
Cupertino Village project.
COMMENTER C2
Ronald Joseph Moore, Sr.
July 21, 2013
Response C2-1: This comment generally pertains to the merits of the project. Please see
Master Response #2: Project Merits. The commenter notes that “It is
reasonable to assume that Apple will consolidate the scattered employees
into the new Campus, and some Traffic will only change places and not
increase.” This concept is discussed in Chapter III, Project Description, and
throughout the Draft EIR. As discussed on page 92 of the Draft EIR, “The
net increase of new employees assumed for the purpose of this EIR (9,356)
may over-estimate the number of net new employees in the project area
because it is not certain how many new employees would be existing Apple
employees currently working outside the project site or new employees that
do not currently work for Apple in the vicinity of the project site. The
proposed project is intended to consolidate current and new Apple
employees. Therefore, it is likely that the net increase of employees that
would result from the project would be less than 9,356. However, the full
potential net increase is used in this EIR to allow for a cautious environmen-
tal analysis that does not under-estimate potential impacts of the project.”
COMMENTER C3
Keithddl527@aol.com
July 18, 2013
Response C3-1: This comment does not pertain to the adequacy of the Draft EIR for the
proposed project and is noted. The comment pertains to the approval of a
temporary structure, a project distinct from the proposed Apple Campus 2
Project, which was approved administratively with a Temporary Use Permit,
as allowed by the City’s Municipal Code. No special exceptions were
granted. The Santa Clara Valley Water District contact for the temporary
structure was Usha Chatwani and the Temporary Use Permit application
number is TUP-2013-03.
Response C3-2: This comment consists of photographs of the temporary structure approved
on the site, is not related to the adequacy of the Draft EIR, and is noted. As
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noted above, the project is being undertaken in accordance with the City of
Cupertino Municipal Code.
COMMENTER C4
Gary Beaupre
July 15, 2013
Response C4-1: Please see Master Response #2: Project Merits regarding the size of the
project, and its evaluation in the context of significance criteria established
by the City. As described in Section V.I, Transportation and Circulation, the
project would result in significant unavoidable impacts to the operations of
the intersection of I-280/Wolfe Road. Please refer to Impacts TRANS-1,
TRANS-5, TRANS-14, TRANS-25, TRANS-26, and TRANS-29 in Section
V.I of the Draft EIR.
Response C4-2: The specific freeway ramps identified in this comment were evaluated to
determine if they would be substantially affected by project traffic. Please
refer to Figure V.I-8, Existing Plus Project Intersection Level of Service
(LOS) Results, on page 392 of the Draft EIR, which indicates the amount of
delay expected on these freeway ramps due to the introduction of traffic
associated with the proposed project.
Response C4-3: Please see Response to Comments C4-1 and C4-2.
Response C4-4: Please see Response to Comments C4-1. As discussed on pages 211 to 212
of the Draft EIR, the project is not expected to result in significant adverse
effects on community character (including the community character of
Sunnyvale) due to the amount of open space on the project site; the clustering
of most buildings away from the periphery of the site; the preservation of
trees and the extension of berms along the site perimeter; and the provision
of an inconspicuous and visually permeable fence along the edge of the site.
As shown in Figures V.B-5 and V.B-7 of the Draft EIR, visual simulations
from locations north of East Homestead Road indicate that project buildings
would be almost wholly obscured by vegetation and landscape features.
Response C4-5: Please see the previous responses to this letter, above.
COMMENTER C5
Stan (Last name not provided)
July 11, 2013
Response C5-1: Please see Master Response #2: Project Merits regarding the size of the
project, and its evaluation in the context of significance criteria established
by the City. As discussed on pages 440 to 441 of the Draft EIR, project
construction traffic would use only designated truck routes within the
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vicinity of the project site, and most construction truck traffic would occur
during off-peak hours. With the exception of the segment of Pruneridge
Avenue between The Hamptons and North Tantau Avenue (which would be
closed as part of the project) no road closures would occur during the
construction period. However, temporary traffic diversion may be needed to
facilitate relocation of utilities on North Wolfe Road and East Homestead
Road, and street widening on North Wolfe Road during construction of the
project.
Response C5-2: Please see Master Response #2: Project Merits regarding the size of the
project, and its evaluation in the context of significance criteria established
by the City.
Response C5-3: This comment about preserving and reusing the existing buildings on the site
does not pertain to the adequacy of the Draft EIR and is noted. That option
was explored as part of the No Project alternative, discussed on pages 599 to
605 of the Draft EIR.
Response C5-4: Impacts related to tree removal are discussed on pages 210 to 211 of the
Draft EIR (Aesthetics section) and 261 of the Draft EIR (Biological
Resources section). Although the removal of the former HP Campus
redwood grove would change the visual character of the site, this change
would not be considered significant and adverse because: those trees are
located within the interior of the site and are not very visible from public
viewpoints; tree coverage around the perimeter of the project site would be
largely maintained; and trees removed from the site would be replaced with
at least 6,200 trees intended to reference the site’s native vegetation and
agricultural past (a net increase of 2,494 trees). These new trees would
enhance the visual quality of the site.
Response C5-5: The only road that would be closed during the project would be the segment
of Pruneridge Avenue between The Hamptons and North Tantau Avenue.
However, temporary traffic diversion may be needed to facilitate relocation
of utilities on North Wolfe Road and East Homestead Road, and street
widening on North Wolfe Road during construction of the project.
Response C5-6: The closure of Pruneridge Avenue is discussed throughout the Draft EIR, but
see in particular pages 150 to 152; 156 to 159; and 427 to 430.
Response C5-7: Please see Master Response #2: Project Merits regarding the size of the
project, and its evaluation in the context of significance criteria established
by the City.
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COMMENTER C6
Sandra and Don Boren
July 8, 2013
Response C6-1: This comment, which discusses the merits of potential additional bicyclists in
the area and the use of shuttles for transit, but does not pertain to the
adequacy of the Draft EIR, is noted. Please see Master Response #2: Project
Merits.
COMMENTER C7
Russ Robinson
July 8, 2013
Response C7-1: This comment, which pertains to the merits of the project and not the
adequacy of the Draft EIR, is noted. Please see Master Response #2: Project
Merits.
COMMENTER C8
Ann (Last name not provided)
July 2, 2013
Response C8-1: This comment notes generally that the project would increase traffic in the
area and increase occupancy of the site beyond existing levels. This comment
is consistent with the analysis in Section V.I, Transportation and Circulation,
of the Draft EIR.
Response C8-2: Please note that the retention of Pruneridge Avenue as a public right-of-way
was analyzed as a project alternative (the Pruneridge Avenue alternative),
which is discussed on pages 605 to 612 of the Draft EIR. The closure of
Pruneridge Avenue is discussed throughout the Draft EIR, but see in
particular pages 150 to 152; 156 to 159; and 427 to 430.
Response C8-3: As discussed on pages 552 to 559 of the Draft EIR, site-specific construction
and operational health risk modeling was performed for the project and
results indicate that a significant risk would not occur to nearby residents or
other sensitive receptors around the project site (including students at local
schools). Wind patterns indicate that dispersion of emissions would occur to
the east and southeast of the project site, away from Cupertino High School
and Lawson Middle School.
Response C8-4: See Master Response #15: School Busing Program.
As a clarification, oral comments on the Draft EIR were accepted at the
public meeting for the project on June 26, 2013.
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Response C8-5: This comment, which states that the City of Sunnyvale will hold a study
session on the Draft EIR, is noted.
Response C8-6: This comment on the merits of the project is noted. As discussed on pages
581 to 584 of the Draft EIR, the project would result in less-than-significant
impacts related to school enrollment (and the need for new capital school
facilities). Therefore, no mitigation would be required to reduce impacts on
schools.
COMMENTER C9
Rich Altmaier
July 1, 2013
Response C9-1: This comment, which generally pertains to the merits of the project, and not
the adequacy of the Draft EIR, is noted. The Draft EIR identifies extensive
mitigation measures for the transportation-related effects of the project,
including a robust TDM Program, which would require the diversion of 34
percent of project trips into non-single-occupant vehicles. Existing and
proposed TDM measures, as discussed on pages 441 to 443 of the Draft EIR,
would incentivize and encourage the use of public transit and bicycles by
Apple employees.
COMMENTER C10
Rick Haffner
July 1, 2013
Response C10-1: The Draft EIR identifies several freeway/expressway access expansions or
changes that would be required as mitigation measures. See in particular
Mitigation Measures TRANS-1, TRANS-3, TRANS-5, TRANS-9a, TRANS-
10, TRANS-11, TRANS-14, TRANS-19a, TRANS-20, TRANS-21,
TRANS-22, TRANS-25, and TRANS-26. The transportation analysis is a
major component of the Draft EIR, and careful consideration was given to all
feasible mitigation measures to reduce the impacts of the project on the
roadway system. Please refer to Section V.I, Transportation and Circulation
for a discussion of the impacts of the project on all modes of transportation,
and recommended mitigation measures. As part of the environmental
documentation prepared for the Main Street Project, mitigation measures to
reduce significant impacts were identified. In addition, the Main Street
Project was incorporated into the Background scenario for the Apple Campus
2 Project, which was analyzed in Section V.I, Transportation and Circulation,
of the Draft EIR.
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COMMENTER C11
William F. Bailey
Tap Merrick
June 30, 2013
Response C11-1: Please see Master Response #2: Project Merits.
Response C11-2: This comment, which expresses support for the closure of Pruneridge
Avenue within the project site, is noted. The retention of Pruneridge Avenue
as a public right-of-way was analyzed as a project alternative (the Pruneridge
Avenue alternative), which is discussed on pages 605 to 612 of the Draft
EIR.
Response C11-3: This comment provides the commenter’s summary of the public meeting
held on the Draft EIR on June 26, 2013 and identified the ways in which
comments on the Draft EIR could be submitted for consideration. Please also
see Master Response #2: Project Merits.
Response C11-4: This comment is noted. While the Draft EIR used background information
provided by Apple (e.g., site plans and technical reports, which were peer
reviewed by the EIR consultant), the City is the lead agency for this EIR and
has reviewed and exercised its independent judgment over all materials
submitted to the City in preparing the EIR. See CEQA Section 21082.1(b).
The fiscal impact analysis prepared for the project primarily focuses on
revenue that would be generated by the project, and costs to the City
associated with the project. The Draft EIR is the correct document to review
for information on the potential physical impacts of the project, including
impacts to neighborhoods around the project site.
Response C11-5: Please see Master Response #7: Cut-Through Traffic.
Response C11-6: Surrounding local jurisdictions were contacted for an updated list of
approved and pending projects to be included in the transportation analysis.
Several of the projects noted in the comment were not included in the lists
provided by the respective agencies and therefore were not included in the
analysis. The transportation evaluation is required to include reasonably
foreseeable projects as known at the time of publication of the Notice or
Preparation (August 2011). It is assumed that these projects were not
reasonably foreseeable at that time. The projects identified in the comment
that were not included in the analysis in the Draft EIR are located further
away from the project study area and would add a negligible amount of
traffic to the study intersections.
Response C11-7: This comment, which encourages project site neighbors to submit comments
on the Draft EIR, is noted.
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COMMENTER C12
Keith Murphy
June 28, 2013
Response C12-1: This comment requests information on how data on major development
projects in the City are made available to the public. The City establishes
stand-alone webpages for larger development projects, including the Main
Street Project and the Apple Campus 2 Project. While the City uses its
discretion in determining which projects warrant an independent webpage, it
strives to make the planning process transparent to the public. All approval
documents on smaller projects are placed online within two days of
approval at: www.cupertino.org/records in the Planning Department folder.
Information regarding the Apple Campus 2 Project is made available online
at: www.cupertino.org/applecampus2.
In addition, because the Apple Campus 2 Project has been designated an
Environmental Leadership Development Project pursuant to AB 900 under
Section 21178 et. seq. of the Public Resources Code, the City has made the
administrative record for the project available at the website noted above.
The rest of the comment does not pertain to the adequacy of the Draft EIR
and a response is not required.
COMMENTER C13
Yolanda Reynolds
June 26, 2013
Response C13-1: This comment states that the project would exacerbate traffic congestion and
air pollution in the area. These issues are discussed in detail in Sections V.I,
Transportation and Circulation, and V.L, Air Quality, of the Draft EIR.
Response C13-2: East Homestead Road, which is located immediately to the north of the
project site, would remain open with implementation of the proposed project.
As indicated on page 400 of the Draft EIR, two study intersections along
Homestead Road would be substantially adversely affected with implementa-
tion of the proposed project: Intersection #5 (De Anza Boulevard and
Homestead Road) and Intersection #27 (Tantau Avenue and Homestead
Road). These intersections would also be substantially adversely affected
under cumulative plus project conditions, as indicated on page 410 of the
Draft EIR. Under cumulative conditions, the average increase in delay
caused by the project at these two intersections would range from 4 seconds
at Intersection #5 to approximately 38 seconds at Intersection #27. Even
though delay would increase at these intersections, Homestead Road would
continue to be accessible to drivers, and a potential alternate route for certain
segments of I-280.
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Response C13-3: Please refer to Response 13-2 and Master Response #2: Project Merits. In
addition, the closure of Pruneridge Avenue is discussed throughout the Draft
EIR, but see in particular pages 150 to 152; 156 to 159; and 427 to 430.
COMMENTER C14
Jia and Linda
June 21, 2013
Response C14-1: Implementation of the project would result in the removal of a maximum of
3,620 trees from the project site. As discussed on page 95 of the Draft EIR,
with implementation of the project, a minimum of 800 trees would be
retained in place on the project site (including the majority of the site
perimeter trees and trees along the Calabazas Creek riparian corridor), and a
minimum of 90 mature trees would be transplanted from the interior of the
site to either the perimeter or to specific locations in the interior of the site. In
order to mitigate the tree removals in accordance with the City’s Protected
Tree Ordinance and to increase vegetation at the site, Apple proposes to plant
a minimum of 6,200 new trees on the project site, resulting in a net increase
of 2,494 trees.
COMMENTER C15
Gina Wang
June 20, 2013
Response C15-1: Please see Master Response #2: Project Merits.
Response C15-2: This comment, which references historic levels of congestion on I-280 and
states support for Apple’s “plans to improve local roadways and alternative
options for employee transit,” is noted.
Response C15-3: Please see Master Response #2: Project Merits.
COMMENTER C16
Donna Austin
June 19, 2013
Response C16-1: This comment generally pertains to the merits of the project and is noted.
Please see Master Response #2: Project Merits. The statement about the
commenter’s confidence that Apple will mitigate the traffic impacts of the
project is also noted.
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COMMENTER C17
Bernard Wood
June 18, 2013
Response C17-1: The retention of Pruneridge Avenue as a public right-of-way was analyzed as
a project alternative (the Pruneridge Avenue alternative), which is discussed
on pages 605 to 612 of the Draft EIR. As discussed on page 626 of the Draft
EIR, two additional alternatives allowing for public access across the site (a
Pruneridge Avenue Tunnel alternative and a Mobility and Park alternative)
were rejected from detailed analysis because they would interfere with major
utility lines, would infringe on private property, result in adverse visual
impacts, would incur significant costs, and/or would still pose significant
security concerns. See also Response to Comment B3-22.
COMMENTER C18
Earl Sharkey
June 17, 2013
Response C18-1: This comment references Apple’s existing TDM program, which is discussed
on pages 59 to 60 of the Draft EIR.
Response C18-2: Please see Master Response #2: Project Merits.
COMMENTER C19
Judy Gaffney
June 17, 2013
Response C19-1: Please see Master Response #2: Project Merits. The comment regarding
environmental issues associated with the use of the project site for the former
HP campus is noted.
COMMENTER C20
Shaunak
June 15, 2013
Response C20-1: This comment generally pertains to the merits of the project. Please see
Master Response #2: Project Merits. The water feature suggested in the
comment is noted. As part of the project, a water feature would be developed
in the courtyard of the Main Building that would also serve as a rain water
capture device.
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COMMENTER C21
Dolly Sandoval
June 14, 2013
Response C21-1: This comment, which expresses general support for the project, is noted.
Please see Master Response #2: Project Merits.
Response C21-2: Please see Master Response #2: Project Merits for a discussion of the
treatment of project socioeconomic effects under CEQA. The comment
expressing support for the design of the project and the project’s
environmental features is noted.
Response C21-3: Traffic impacts associated with the project, and identified mitigation
measures to reduce these impacts, are discussed in Section V.I, Transporta-
tion and Circulation, of the Draft EIR.
Response C21-4: Please see Master Response #2: Project Merits.
COMMENTER C22
Henry and Sally Zoellner
June 13, 2013
Response C22-1: The retention of Pruneridge Avenue as a public right-of-way was analyzed as
a project alternative (the Pruneridge Avenue alternative), which is discussed
on pages 605 to 612 of the Draft EIR. As discussed on page 626 of the Draft
EIR, two additional alternatives allowing for public access across the site (a
Pruneridge Avenue Tunnel alternative and a Mobility and Park alternative)
were rejected from detailed analysis because they would interfere with major
utility lines, would infringe on private property, result in adverse visual
impacts, would incur significant costs, and/or would still pose significant
security concerns. See also Response to Comment B3-22.
Response C22-2: The request to annex the Westwood Oaks neighborhood into Cupertino is
noted. This comment does not pertain to the adequacy of the Draft EIR and
no further response is required.
COMMENTER C23
Vanya Matzek
June 13, 2013
Response C23-1: The project would not include access through the project site connecting
North Wolfe Road and North Tantau Avenue. However, as discussed on
pages 111 to 120 of the Draft EIR, the project includes extensive changes to
the bike and pedestrian environment surrounding the project site (including
along Vallco Parkway) that would allow continuous bike and pedestrian
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access (via sidewalks and bike lanes) along East Homestead Road, North
Tantau Avenue, Vallco Parkway, and North Wolfe Road in the vicinity of the
project site. These facilities would complete the “loop” referenced in the
comment, but over a greater length compared to the “loop” under existing
conditions. In addition, mitigation measures in the Draft EIR would also
enhance bike and pedestrian facilities in the area. Mitigation Measure PLAN-
2 and Mitigation Measure PLAN-3 would require Apple to implement
additional bike and pedestrian facility improvements, including a coordinated
wayfinding scheme around the project site perimeter, enhanced bike lanes
and pedestrian paths along the North Wolfe Road bridge over I-280, other
bicycle and pedestrian amenities, ADA improvements, and an alternate
Calabazas Creek trail segment. Also, Mitigation Measures TRANS-23,
TRANS-28, TRANS-29 would require enhancements to the pedestrian
environment at the North Wolfe Road/Project Access intersection and at the
I-280 ramps with Wolfe Road.
COMMENTER C24
Darcy Paul
June 12, 2013
Response C24-1: This comment generally focuses on the “many positive impacts” of the
project, but also supports “appropriate measures taken to ensure that
congestion and the impacts of traffic are minimized and even eliminated.”
Careful consideration was given to all feasible mitigation measures to reduce
the impacts of the project on the roadway system. Please refer to Section V.I,
Transportation and Circulation for a discussion of the impacts of the project
on all modes of transportation, and recommended mitigation measures.
COMMENTER C25
Keith Warner
June 12, 2013
Response C25-1: Please see Master Response #2: Project Merits, including the discussion of
the treatment of socioeconomic effects in CEQA documents.
COMMENTER C26
James Forsythe
June 11, 2013
Response C26-1: This comment generally pertains to the merits of the project. Please see
Master Response #2: Project Merits. The comment also notes that shifting
the work hours of Apple employees away from peak periods could reduce
project traffic impacts. This concept is employed in the list of “Additional
TDM Measures” discussed on page 443. These measures, which include the
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implementation of a flexible work schedule and the encouragement of
telecommuting, would be implemented if the TDM measures identified as
part of the project fail to meet the peak hour counts goal established in
Mitigation Measure TRANS-9b.
COMMENTER C27
Glenn Grigg
June 10, 2013
Response C27-1: This comment notes that the intersection of North Tantau Avenue/Pruneridge
Avenue would be a good candidate for a roundabout. However, it is not part
of the project, is not included in any City plans, and is not required to reduce
the significant effects of the project. Therefore, a roundabout is not being
considered at this location.
Response C27-2: The Main Parking Structure adjacent to I-280 is designed to have direct
access to both North Wolfe Road and Tantau Avenue.
COMMENTER C28
Yaeko Hirotsuka
June 8, 2013
Response C28-1: Please see Master Response #2: Project Merits.
Response C28-2: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted. Please see Master Response #11: Diverted Trips Due to Pruneridge
Avenue Closure for additional information about the effect of the Pruneridge
Avenue closure on local roadway traffic volumes.
Response C28-3: As discussed on page 626 of the Draft EIR, two alternatives allowing for
public access across the site (a Pruneridge Avenue Tunnel alternative and a
Mobility and Park alternative) were rejected from detailed analysis because
they would interfere with major utility lines, would infringe on private
property, result in adverse visual impacts, would incur significant costs,
and/or would still pose significant security concerns. However, the No
Project alternative and the Pruneridge Avenue alternative, discussed in
Chapter VI, Alternatives, would retain public access across the project site.
See also Response to Comment B3-22.
Response C28-4: This comment, which pertains to the merits of the project and not the
adequacy of the Draft EIR, is noted.
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COMMENTER C29
Yaeko Hirotsuka
June 8, 2013
Response C29-1: Please see Responses to Comments C28-1 through C28-4.
COMMENTER C30
Eddie Kuo
June 6, 2013
Response C30-1: Please see Master Response #2: Project Merits. The environmental
implications of the sustainability features referenced in the comment are
explored throughout the Draft EIR, but specifically in Section V.K,
Greenhouse Gas Emissions and Sustainability.
COMMENTER C31
Eno Schmidt
June 6, 2013
Response C31-1: Please see Master Response #2: Project Merits. The comment about the
“advance consideration” of issues “involving congestion and concentrations
of such large number of employees in one location” is noted, but no
additional response is required. This comment does not pertain to the
adequacy of the Draft EIR.
COMMENTER C32
Margaret Reilly
June 5, 2013
Response C32-1: This comment, which pertains to the provision of City-wide WiFi as part of
the project and not to the adequacy of the Draft EIR, is noted.
COMMENTER C33
Chandramohan Mathu
June 6, 2013
Response C33-1: Please see Master Response #2: Project Merits.
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COMMENTER C34
Best/Yash (Full name not provided)
June 6, 2013
Response C34-1: Please see Master Response #2: Project Merits.
COMMENTER C35
Geoff Paulsen
July 22, 2013
Response C35-1: The analysis in the Draft EIR evaluates environmental conditions far into the
future, where applicable (in the case of the demographic analysis in Section
V.G, Population, Employment, and Housing, housing and employment
growth in the City and County are evaluated out to 2035). In addition,
although the focus of the analysis is on the environs of the project, impacts
are examined for areas outside the boundaries of Cupertino, including
regional roadways. The comment regarding the desire for a taller project is
noted. Such a design was not considered as part of a project alternative
because it would not reduce the impacts of the project, as required by CEQA,
and could exacerbate the potential impacts of the project if a taller building
would degrade viewsheds in the area.
Response C35-2: This comment, which suggests that Apple add a store, museum, or visitor
center to the project, is noted. This comment does not pertain to environmen-
tal issues surrounding the project or the adequacy of the Draft EIR and no
further response is required.
Response C35-3: Mitigation Measure PLAN-3 includes a requirement that Apple fund a study
of a Class I trail along the drainage channel and Calabazas Creek channel
south of the project site (instead of constructing such a trail). The high cost of
developing such a trail would make it infeasible for a single project to
support. In addition, no trail exists today, so the project would not have a
significant impact on the existing environment with respect to trails. Please
see Master Response #13: Calabazas Creek Trail.
Response C35-4: This comment is noted and will be considered in the implementation of
Mitigation Measure BIO-3.
Response C35-5: The stormwater control methods mentioned in the comment would be required
as part of the project, pursuant to the provisions of the San Francisco Bay
Region Municipal Stormwater National Pollutant Discharge Elimination
System Permit, as described on pages 307 to 308 of the Draft EIR. It should
also be noted that the project would benefit stormwater quality because the
amount of pervious surfaces on the site would increase from approximately 43
acres to 102 acres.
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Response C35-6: This comment, which generally expresses an opposition to road widening, is
noted. As a general response, the Draft EIR includes mitigation measures that
seek to reduce the transportation impacts of the project without widening
roads. For instance, Mitigation Measure TRANS-9b would require Apple to
divert 34 percent of its peak hour trips using a range of TDM measures,
including increased transit usage and incentivizing biking and walking
commutes.
Response C35-7: Occupied project buildings would average approximately 240 square feet per
employee, which is a fairly typical employee density for technology-related
office uses.
Response C35-8: As described on page 626 of the Draft EIR, a Mobility and Park alternative
(which would include a 1.1-acre on-site park) was rejected from detailed
analysis in the Draft EIR because it would pose significant security concerns
to Apple and would conflict with a key project objective.
COMMENTER C36
Neighbor
July 22, 2013
Response C36-1: Please see Master Response: Diverted Trips Due to Pruneridge Closure. The
segment of Pruneridge Avenue east of North Tantau Avenue is not expected
to experience high traffic volumes such that closure of the street would be
warranted.
COMMENTER C37
Dean Fujiwara
July 22, 2013
Response C37-1: Please refer to Response to Comment A1-14. The intersection at Homestead
Road/Heron Avenue is a signalized intersection that provides protected left-
turn access to and from the Serra Gardens neighborhood (thus facilitating
access onto Homestead Road after project implementation). The Homestead
Road/Linnet Lane intersection is a side-street stop controlled intersection,
where traffic to/from Linnet Lane needs to yield to traffic on Homestead
Road (thus increased traffic on Homestead Road could increase the difficulty
of turns from Linnet Lane). The proposed development projects, including
the Apple Campus 2 Project as well as the shopping centers at Cupertino
Village and Homestead Square, would increase traffic volumes on
Homestead Road. However, as discussed in Response to Comment A1-14,
the intersections would continue to operate acceptably.
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COMMENTER C38
Ken Nishimura
July 22, 2013
Response C38-1: This introductory comment is noted.
Response C38-2: Please see Master Response #2: Project Merits.
Response C38-3: The comment is correct that the closure of Pruneridge Avenue would have
significant effects on bicycling and pedestrian infrastructure in the area and
that the project would generate significant traffic congestion. These impacts
are identified as significant and unavoidable in the Draft EIR. See the
summary of significant and unavoidable project impacts on pages 6 to 7 of
the Draft EIR.
Response C38-4: The shuttle service suggested by the commenter was not identified as a
mitigation measure due to: 1) the relatively low numbers of pedestrians and
cyclists that use the segment of Pruneridge Avenue within the project site
that would be vacated; 2) the relatively short length of the pedestrian detour
that would be required due to the closure of Pruneridge Avenue; 3) the
relatively high cost of running such a shuttle service at a frequency that
would be convenient to pedestrians; and 4) the adverse effects on air
pollution and traffic congestion associated with such a shuttle service.
Response C38-5: The project would include substantial transportation improvements, as
described on pages 381 to 384 of the Draft EIR, which would add roadway
capacity to reduce the amount of traffic congestion that could occur. In
addition, Apple would expand its TDM Program (including its dedicated
shuttle bus service) and (per Mitigation Measure TRANS-9b) increase the
percentage of employees who use transit, walking, bicycling, and shared ride
modes of transport to and from work from 28 percent to 34 percent to reduce
the amount of added traffic congestion.
The transportation impact analysis evaluated project impacts to freeway
interchanges. Specifically I-280/Wolfe Road freeway ramp operations were
evaluated and off-ramp widenings were identified as mitigation measures.
Mitigation measures were also identified for the intersection of the I-280
northbound off-ramp at Stevens Creek Boulevard.
Response C38-6: Please see Master Response #1: Significant and Unavoidable Impacts.
Response C38-7: The exit intersection of the campus transit station would be signalized to
facilitate effective operations at this location, and to ensure safety of
bicyclists. With signalization this intersection is projected to operate at LOS
A and LOS B during the AM and PM peak periods, respectively.
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Response C38-8: The existing alternative mode use of 28 percent was measured on days with
good weather. Therefore the goal of 34 percent should also be measured on
days with good weather to provide a consistent comparison. On days with
inclement weather some employees who typically use alternative modes may
elect to drive to work. This would not represent “normal” travel patterns and
would potentially skew the results.
Response C38-9: Please see Master Response: Adequacy of TDM Penalties.
Response C38-10: Please see Master Response #12: Trip Cap.
Response C38-11: The project driveways would be controlled with traffic signals that are
operated by the City of Cupertino Public Works Department. The signals
would be operated in conjunction with other traffic signals on North Wolfe
Road and North Tantau Avenue so that traffic flows on the arterials are
maintained. This would require longer wait times for vehicles on the side
streets, including the project driveways. Therefore traffic exiting the site
would effectively be metered.
Response C38-12: Apple shuttles are owned and operated by third party operators who fuel all
vehicles off-site.
Response C38-13: This comment, which expresses support for the Reduced Density alternative
evaluated in Chapter VI, Alternatives, of the Draft EIR is noted.
COMMENTER C39
Patricia Melcic
July 22, 2013
Response C39-1: This comment references Impacts AIR-1 and AIR-2, which relate to the
violation of air quality standards. These impacts pertain to exceedances of
established thresholds of air pollutants in the air basin and would not
disproportionately affect persons within 1 mile of the project site. As
calculated in the air quality technical study prepared for the Draft EIR,
emissions of toxic air contaminants from construction would be less than
significant for nearby residents.
Response C39-2: Although level of service delays in the Draft EIR are calculated in seconds of
delay (and not miles), this comment likely overstates the project’s contribu-
tion to freeway congestion. Under cumulative conditions, the project would
add approximately 1 minute and 23 seconds of delay to operations at the
Wolfe Road/I-280 Northbound Ramps and 1 minute and 8 seconds of delay
to the Lawrence Expressway/I-280 Southbound Ramps.
Response C39-3: The intersection of Pruneridge Avenue/North Tantau Avenue was analyzed
in Section V.I, Transportation and Circulation, of the Draft EIR. This
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intersection is not listed in Table II-1, Summary of Impacts and Mitigation
Measures, from the EIR, because its operations would not be substantially
adversely affected by the project.
Response C39-4: The Main Parking Structure entrance would have direct access both to North
Tantau Avenue and North Wolfe Road, and associated traffic would be
distributed to the two streets.
Response C39-5: Table RTC-6 summarizes the peak hour roadway volumes for Pruneridge
Avenue between Lawrence Expressway and Tantau Avenue for Existing,
Background No Project, and Background Plus Project conditions and their
corresponding levels of service.
Pruneridge Avenue is classified as a minor arterial per the City of Santa
Clara 2010-2035 General Plan. Based on the General Plan, an arterial can
accommodate up to 885 vehicles per lane and maintain LOS D operations.
Pruneridge Avenue has two lanes between Lawrence Expressway and Tantau
Avenue and a total capacity of 1,770 peak hour vehicles (885 x 2 lanes).
Based on the data presented in Table RTC-6, Pruneridge Avenue has
sufficient capacity to accommodate the expected growth in traffic on the
roadway.
Table RTC-6: Pruneridge Avenue Peak Hour Roadway Volumes
Scenario Peak Hour1
Two-Way
Roadway Volume LOS2
Existing AM
PM
707
883
C
C
Background No Project AM
PM
733
931
C
C
Background Plus Project AM
PM
939
1,135
C
D
Notes: 1 AM = morning peak hour, PM = afternoon peak hour. 2 Based on Roadway Segment Daily LOS Definitions presented in Santa Clara’s General
Plan. Peak hour capacities were assumed to be ten percent of the daily capacity.
Source: Fehr & Peers, August 2013.
Response C39-6: The modest additional traffic volumes for the project that would occur on
Pruneridge Avenue, as shown in Response to Comment C39-5, would not be
expected to create hazardous conditions for bicyclists and pedestrians.
COMMENTER C40
Jennifer Hodor
July 22, 2013
Response C40-1: This introductory comment stating objections to the proposed project is
noted. As discussed in Section V.I, Transportation and Circulation, of the
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Draft EIR, operations at the intersection of North Wolfe Road and East
Homestead Road would not be significantly affected by the project.
Response C40-2: Employees who use the Corporate Fitness Center would be directed to park
in the parking facilities elsewhere within the project site. As part of Condi-
tion of Approval CA-TRANS-3, if parking spillover is identified as a
problem as part of annual parking monitoring, a detailed parking manage-
ment plan would be provided and additional measures would be taken
(including the provision of additional parking on the project site). A
crosswalk has not been proposed at the intersection of Nightingale Avenue
and East Homestead Road.
Response C40-3: As proposed, the project would provide a shuttle stop pullout on the south
side of East Homestead Road just east of the North Wolfe Road intersection.
The stop would only be used by Apple’s 15-seat employee Sprinter vans. Use
of the Sprinter vans that would use the stop on East Homestead Road would
be limited to employees who are traveling to or leaving the Corporate Fitness
Center. The relatively small number of vans accessing the Corporate Fitness
Center would not substantially increase traffic on East Homestead Road.
Most project employees would use the Transit Center on North Tantau
Avenue.
Response C40-4: As discussed on pages 432 to 437 of the Draft EIR, the proposed project
would provide adequate parking on-site (with implementation of Mitigation
Measure TRANS-35), thus limiting the demand for off-site parking. As part
of the conditions of approval, the project sponsor would fund monitoring to
assess whether intrusion occurs and measures to ameliorate parking intru-
sion. The measure would be subject to City of Sunnyvale approval.
Response C40-5: Please see Master Response #7: Cut-Through Traffic and Master Response
#11: Diverted Trips Due to Pruneridge Avenue Closure.
Response C40-6: Please refer to Master Response #14: New Freeway Ramps.
Response C40-7: This concluding comment is noted.
COMMENTER C41
Martin Landszaat
July 21, 2013
Response C41-1: Please refer to the discussion of Mitigation Measure TRANS-1 on page 394
of the Draft EIR and Mitigation Measure TRANS-25 on page 420 of the
Draft EIR. If agreement is reached with Caltrans to construct these mitigation
measures (which are outside the control of the City of Cupertino), project
impacts at I-280/Wolfe Road would be reduced to a less-than-significant
level.
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COMMENTER C42
Ronald Moore
July 21, 2013
Response C42-1: This comment is similar to and from the same commenter as Comment C2.
Please see Master Response #2: Project Merits. The comment about the
consolidation of Apple employees on the site is noted and is reflected in the
discussion of proposed project employment on pages 91 to 92 of the Draft
EIR.
Response C42-2: Please see Response to Comment C44-1.
Response C42-3: Please see Master Response #2: Project Merits.
Response C42-4: This comment, which suggests that Apple open a store in Cupertino, is noted.
This comment does not pertain to environmental issues surrounding the
project and no further response is required.
COMMENTER C43
Patrick Robbins
July 21, 2013
Response C43-1: As discussed on page 215, project effects due to light and glare would be
less-than-significant at all locations, including near Receptor 4, which is near
the location described by the commenter. As shown in Table V.B-1,
Illuminance Assessment of Receptor Locations, the illuminance value at
Receptor 4 would increase by only 0.130 footcandle with implementation of
the proposed project (far below the threshold of 0.8 footcandle).
Response C43-2: This intersection was not included in the analysis because, as the comment
notes, it is a minor all-way stop controlled intersection (and thus would not
be subject to substantial project traffic). Fehr & Peers conducted follow-up
observations at this intersection in September 2013. The observations
indicate that the intersection operates at approximately LOS C in both the
AM and PM peak periods, which is an acceptable level of service. Although
queuing of up to six cars was observed on Pruneridge Avenue, no excessive
queuing or unsafe driving behavior was observed.
Response C43-3: As shown in Figure V.I-7, Project Trip Distribution, the intersection of
Pruneridge Avenue and North Tantau Avenue is not projected to experience
substantial increases in vehicle trips. Thus the relatively minor change in
operation at this intersection is not surprising.
Response C43-4: Please refer to pages 128 to 129 and pages 434 to 435 of the Draft EIR for a
discussion of special event parking. As discussed on page 128, on special
event days employees who typically park in the Auditorium and Valet Parking
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facility would be directed to park elsewhere (including at off-site locations
requiring shuttle transport, if necessary). These employees would be given
advance notice of the parking restrictions, and provision would be made for
parking at other locations within the project site or other Apple facilities in the
area. Special events would occur approximately three to four times a year, and
on these occasions – due to the parking protocols established by Apple – no
significant spillover parking is expected to occur off-site.
Response C43-5: As shown on page 453 of Section V.J, Noise, of the Draft EIR, the purpose
of the short-term noise monitoring was to establish the existing ambient noise
environment at sensitive land uses in the vicinity of the project site. These
noise measurements were not used in the analysis of significant impacts.
Modeled traffic noise levels that would be experienced under project condi-
tions were compared to modeled traffic noise levels under conditions without
the project and were not compared to existing measured noise levels. Using
modeled noise levels, rather than measured noise levels, is standard practice
and is considered to produce more accurate results since measured noise
during a single day or a small number of days may not be representative of
project conditions.
In regard to potential project-related noise increases for residences on
Pruneridge Avenue, based on the anticipated trip distribution pattern of the
proposed project, the segment of Pruneridge Avenue between North Tantau
Avenue and Lawrence Expressway would experience less than 1 percent of
total project trips. Therefore, similar to all other roadway segments with
higher project trip volumes that were modeled and analyzed in the noise
analysis, project-related traffic noise impacts along Pruneridge Avenue
would be less than significant.
COMMENTER C44
Mary Brunkhorst
July 21, 2013
Response C44-1: This comment, which summarizes some of the key conclusions of the Draft
EIR regarding traffic impacts, is noted.
Response C44-2: This comment, which describes existing traffic conditions observed by the
commenter, is noted.
Response C44-3: As discussed in Section V.I, Transportation and Circulation, of the Draft
EIR, operations at the intersection of North Wolfe Road and East Homestead
Road would not be significantly affected by the project.
Response C44-4: Please see Master Response #7: Cut-Through Traffic.
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Response C44-5: Pedestrian crossings were considered when conducting the traffic analysis.
The existing traffic signal timing, with slight modifications, could
accommodate added pedestrians without increasing the delays to vehicles.
Response C44-6: Please see Master Response #11: Diverted Trips Due to Pruneridge Avenue
Closure.
Response C44-7: As discussed on page 35 of the Draft EIR, the cumulative analysis of traffic
in the Draft EIR takes into account traffic from pending developments in the
area, along with reasonably foreseeable roadway improvements. In general,
mitigation occurs on a project-by-project basis, and individual project
applicants would be required to mitigate the effects of their projects on the
transportation system to a less-than-significant level, where feasible.
Response C44-8: Please see Master Response #1: Significant and Unavoidable Impacts. Apple
would work with the City of Cupertino, the VTA, and Caltrans to obtain the
necessary permits to construct improvements in the Caltrans right-of-way.
The City and Caltrans anticipate having the improvements within Caltrans’
right-of-way completed prior to final occupancy of the project. Secondary
impacts associated with the mitigation measures have been considered in the
Draft EIR.
Response C44-9: Apple would be required to implement all mitigation measures that are
within the responsibility and jurisdiction of the City of Cupertino. Regarding
mitigation measures that are within the responsibility and jurisdiction of
other agencies, Apple has agreed to coordinate and collaborate with the
extra-jurisdictional agencies to construct each mitigation measure, or to
provide funding to the agencies to design and construct either: (1) the
identified mitigation measure or (2) an alternate improvement which
mitigates the impact to the satisfaction of the City of Cupertino. Please see
Master Response #1: Significant and Unavoidable Impacts.
Response C44-10: This comment, which expresses support for the closure of Pruneridge
Avenue within the project site and does not pertain to the adequacy of the
Draft EIR, is noted.
Response C44-11: This comment, which summarizes previous comments, is noted.
Response C44-12: Please see Master Response #2: Project Merits.
COMMENTER C45
Nancy Wagner
July 21, 2013
Response C45-1: This introductory comment is noted.
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Response C45-2: Both the type and number of project-related vehicles using roadways in the
vicinity of the site were taken into account as part of the noise analysis for the
project described in Section V.J, Noise, of the Draft EIR. The number of
vehicles using Pruneridge Avenue east of the project site is not expected to
increase substantially with implementation of the proposed project. Less than
1 percent of project trips would use the segment of Pruneridge Avenue
between North Tantau Avenue and Lawrence Expressway, resulting in a
negligible increase in traffic-related noise. The impacts of the project on noise
levels along Pruneridge Avenue east of the project site would thus be less than
significant.
Response C45-3: This general comment about expected increases in traffic along North Tantau
Avenue is noted.
Response C45-4: Please see Response to Comment C45-2.
Response C45-5: This comment about building height preference is noted. As shown in Figure
V.B-4, Visual Simulations, Viewpoint 3, East Pruneridge Avenue, project
buildings from this location would be completely obscured by vegetation.
Response C45-6: This general concluding comment is noted.
COMMENTER C46
Sally Everett-Beaupre
July 21, 2013
Response C46-1: This introductory comment is noted.
Response C46-2: Please refer to pages 212 to 215 of the Draft EIR, which discuss the less-
than-significant impacts of the project on light and glare.
Response C46-3: Please refer to the visual simulations of the project on page 194 to 204 of the
Draft EIR.
COMMENTER C47
Patrick Waddell
July 21, 2013
Response C47-1: Santa Clara residents could continue to access the I-280/Wolfe Road
interchange via Homestead Road or Vallco Parkway. The detour is estimated
to be just over 0.5 mile, which would add a negligible amount of travel time.
Access to I-280 northbound would not be restricted to the interchange at
Stevens Creek Boulevard.
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Response C47-2: Please see Master Response #11: Diverted Trips Due to Pruneridge Avenue
Closure, as well as Master Response #5: Public Access Through Project Site.
Response C47-3: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted.
Response C47-4: Chapter VI, Alternatives, of the Draft EIR, includes analysis of four project
alternatives, including the No Project alternative, Pruneridge Avenue
alternative, Reduced Construction alternative, and Reduced Density alterna-
tive. These alternatives are analyzed for each of the topics evaluated in detail
in the Draft EIR. In addition, as described on pages 625 and 626 of the Draft
EIR, seven additional alternatives were considered but rejected for further
analysis because they would conflict with project objectives or would not
substantially reduce the environmental impacts of the project.
Response C47-5: As discussed on page 626, the Pruneridge Avenue Tunnel alternative was not
rejected from analysis solely due to conflicts with the existing sanitary sewer
line. It was also rejected because it would infringe on private property and
could result in adverse visual impacts and incur significant costs.
Response C47-6: Apple considers any public access on the site to compromise its primary
security objective. Please refer to Master Response #5: Public Access
Through Project Site.
Response C47-7: Please refer to Response to Comment B3-22 and Master Response #5: Public
Access Through Project Site.
COMMENTER C48
Dale Porter
July 21, 2013
Response C48-1: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted. See Master Response #3: Mitigation Nexus. Also, the retention of
Pruneridge Avenue in its existing condition is evaluated as part of the No
Project alternative discussed in Chapter VI, Alternatives.
COMMENTER C49
Anonymous
July 21, 2013
Response C49-1: This comment, which expresses opposition to the closure of Pruneridge
Avenue as part of the project, is noted. The evaluation of impacts of the
closure on the transportation patterns of The Hamptons residents is discussed
on pages 429 to 430 of the Draft EIR.
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Response C49-2: The proposed Apple Campus would not be open to the public.
COMMENTER C50
A Local
July 20, 2013
Response C50-1: As noted on page 134 of the Draft EIR, the proposed project would be
required to meet Leadership in Energy and Environmental Design (LEED)
Silver certification or an equivalent, as identified in the City of Cupertino
Green Building Ordinance. Apple has committed to incorporating into the
project the sustainability features discussed on pages 134 to 136 of the Draft
EIR.
Response C50-2: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted.
COMMENTER C51
Ruth Moore
July 20, 2013
Response C51-1: Please refer to Master Response #2: Project Merits.
COMMENTER C52
Harvey Checkman
July 19, 2013
Response C52-1: The segment of Pruneridge Avenue within the site that would be closed as
part of the project is not a designated emergency access route. With the
addition of project traffic, there would be added delays on Homestead Road
during the peak commute periods; however, the delays would not be severe.
For example, in the evening when commute congestion is greater, the delay
on eastbound Homestead Road (towards Kaiser Hospital) at Wolfe Road is
estimated to increase by 10 seconds. Similarly, the delay on southbound
Wolfe Road towards Kaiser Hospital is estimated to increase by 15 seconds.
Emergency vehicles would continue to be able to navigate the corridors with
emergency signal pre-emption that give priority signals to emergency
response vehicles (as required by Mitigation Measure PSU-1).
Response C52-2: This proposal for the rerouting of Pruneridge Avenue resembles that
described for the Mobility and Park alternative described on page 626 of the
Draft EIR. That alternative was rejected because it would pose significant
security concerns to Apple, thus compromising one of Apple’s key objectives
for the project.
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Response C52-3: Please see Master Response #12: Trip Cap.
Response C52-4: Please see Master Response #3: Mitigation Nexus.
Response C52-5: Please see Master Response #3: Mitigation Nexus. Such a local hiring
program would be difficult to administer/enforce and may do little to reduce
the effects of the project on the local and regional roadway system (if, for
instance, local residents drive to work). Since Apple has historically found
success in reducing vehicle traffic through its TDM Program, the City has
determined that a more robust TDM Program (as required by Mitigation
Measure TRANS-9b) would be the most effective way to further reduce
traffic generated by the proposed project.
Response C52-6: Please see response to comment C52-2.
COMMENTER C53
Ann (Last name not provided)
July 19, 2013
Response C53-1: Impact AIR-1 and Impact AIR-2 identify impacts to regional air quality
attainment standards from exceedances in criteria pollutant thresholds (see
Table V.L-5 and Table V.L-7 of the Draft EIR). As shown in Table V.L-5,
construction emissions of ozone precursors (ROG and NOx) would exceed
the Bay Area Air Quality Management District (BAAQMD) threshold for
average daily construction emissions. As shown in Table V.L-7, operational
analysis results indicate the net new project emissions would exceed the
BAAQMD’s threshold for ROG, NOx, PM2.5 and PM10.
The primary source of construction emission exceedances is construction
truck trips, while the primary source of project operation emissions is mobile
source emissions generated by employee, visitor, and vendor vehicle trips to
and from the project site. These emissions associated with the project are
regional in nature, meaning that air pollutants are rapidly dispersed or, in the
case of vehicle emissions associated with the project, emissions are released
in other areas of the air basin. Because the resulting emissions are dispersed
rapidly and contribute only a small fraction of the region’s air pollution, air
quality in the immediate vicinity of the project site (including the Kaiser
Hospital) would not substantially change compared to existing conditions as
the air quality monitoring data reported in Table V.L-2.
Site-specific construction and operational health risk modeling was per-
formed (see pages 552 to 559 of the Draft EIR), taking into account predomi-
nant winds, and results indicate that the project air emissions would not
create a significant risk would not occur to nearby residents or other sensitive
receptors (including the hospital).
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Response C53-2: With the addition of project traffic, there would be added delays on Homestead
Road during the peak commute periods; however, the delays would not be
severe. For example, in the evening when commute congestion is greater, the
delay on eastbound Homestead Road (towards Kaiser Hospital) at Wolfe Road
is estimated to increase by 10 seconds. Similarly, the delay on southbound
Wolfe Road towards Kaiser Hospital is estimated to increase by 15 seconds.
Emergency vehicles would continue to be able to navigate the corridors with
emergency signal pre-emption that give priority signals to emergency response
vehicles (as required by Mitigation Measure PSU-1).
Response C53-3: Please see Master Response #11: Diverted Trips Due to Pruneridge Avenue
Closure.
COMMENTER C54
Ann (Last name not provided)
July 19, 2013
Response C54-1: This comment is noted. The inconsistency of the proposed closure of
Pruneridge Avenue with General Plan policies is discussed under Impacts
PLAN-2, PLAN-5, and PLAN-6 in the Draft EIR.
Response C54-2: Impacts related to the closure of Pruneridge Avenue would be significant and
unavoidable because the provision of public access through the project site
would conflict with the primary security objective identified by Apple for the
project, thus compromising the viability of the project. The term
“unmitigable” is not used to describe these impacts.
Response C54-3: Similar to the Pruneridge Avenue Tunnel alternative discussed on page 626
of the Draft EIR, a pedestrian/bicycle bridge crossing the project site would
require acquisition of right-of-way, result in adverse visual impacts, would
incur significant costs, and may still pose significant security concerns.
Therefore, such an alternative would not be environmentally superior to other
project alternatives evaluated in detail in the Draft EIR (including the
Pruneridge Avenue alternative, which would preserve Pruneridge Avenue in
place) and will not be analyzed further.
COMMENTER C55
Pingang and Wen Wang
July 19, 2013
Response C55-1: As discussed in Section V.I, Transportation and Circulation, the project
would not result in a significant impact on Intersection #35 (Lawrence
Expressway/Pruneridge Avenue). Therefore, no improvement measures are
identified in the Draft EIR at this intersection.
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COMMENTER C56
Jeremy Hubble
July 19, 2013
Response C56-1: Please see Master Response #10: Median on East Homestead Road and
Response to Comment A1-18. The roadway/bike facility constraints
referenced in the comment represent an existing condition in the City of
Sunnyvale for which the City of Sunnyvale has the responsibility for and
jurisdiction over the implementation of the improvements.
Response C56-2: Increases in traffic on East Homestead Road would not result in bike/
pedestrian conflicts because as part of the project adequate bike/pedestrian
facilities would be provided along East Homestead Road. Please refer to
page 112 of the Draft EIR for a description of these facilities.
Response C56-3: Please refer to Master Response #5: Public Access Through Project Site.
COMMENTER C57
Vincent Grande
July 17, 2013
Response C57-1: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted.
Response C57-2: Please refer to Master Response #14: New Freeway Ramps.
COMMENTER C58
Anonymous
July 17, 2013
Response C58-1: Refer to Section V.I, Transportation and Circulation, which analyzes the
effect of the project on the operation of North Wolfe Road and East
Homestead Road.
COMMENTER C59
David Mooso
July 14, 2013
Response C59-1: In regard to potential project-related noise increases for residences on
Pruneridge Avenue, based on the anticipated trip distribution pattern of the
proposed project, the segment of Pruneridge Avenue between North Tantau
Avenue and Lawrence Expressway would experience less than 1 percent of
total project trips. Therefore, project-related traffic noise impacts along
Pruneridge Avenue would be less than significant.
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COMMENTER C60
Art Cohen
July 14, 2013
Response C60-1: Please see Master Response #3: Mitigation Nexus. Security concerns
surrounding the project have not been identified as a significant impact that
would require mitigation.
COMMENTER C61
Denia Phillips
July 12, 2013
Response C61-1: Please see Master Response #2: Project Merits.
COMMENTER C62
James (Last name not provided)
July 12, 2013
Response C62-1: Impacts to migratory birds are discussed on pages 258 to 260 of the Draft
EIR. It is unclear why the commenter believes the circular design of the
Main Building would appear as a water body from the perspective of flying
migratory birds. Apart from its circular design in plan view, the Main
Building would have no other characteristics of a water body (see Figure III-
4 and III-5a for representative plan views of the Main Building). The interior
courtyard of the Main Building would be landscaped and would contain
numerous built features, including a central garden, food stations, mainte-
nance access, dining terrace, and pathways, none of which are characteristic
of the aquatic portion of a lake or pond. The interior courtyard would have no
major elements with reflective qualities, other than a small water feature.
Therefore, it is unlikely the circular layout of the Main Building would be
“extremely confusing to migratory flying animals.”
COMMENTER C63
John Kilmer
July 11, 2013
Response C63-1: The comment appears to be referring to the closure of Pruneridge Avenue
(not North Tantau Avenue) within the project site. Please see Master
Response: Diverted Trips Due to Pruneridge Closure and the discussion on
pages 427 to 428 of the Draft EIR. Please refer to pages 590 to 592 of the
Draft EIR for a discussion of the project’s potential effects on emergency
response times.
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COMMENTER C64
Elaine Manley
July 11, 2013
Response C64-1: This introductory comment is noted.
Response C64-2: Additional parking on the site is not desirable from an environmental
perspective because: 1) as explained on pages 432 to 437 of the Draft EIR,
the parking proposed for the site would be adequate to meet demand with
implementation of a TDM Program; 2) too much parking on the site could
reduce the desirability of alternate transportation modes and generate
additional traffic; and 3) the construction of new or larger buildings on the
site to accommodate parking would result in adverse impacts related to air
pollutant and greenhouse gas emissions. In addition, the project site would
not be open to the public. Thus, long-term parking demand for visitors is
expected to be modest and could be accommodated within proposed visitor
parking facilities. However, as part of Condition of Approval CA-TRANS-3,
if parking spillover is identified as a problem as part of annual parking
monitoring, a detailed parking management plan would be provided and
additional measures would be taken (including the provision of additional
parking on the project site).
Response C64-3: Please see Master Response #10: Median on East Homestead Road.
Response C64-4: This comment about the merits of the project design is noted. Please see
Master Response #2: Project Merits.
Response C64-5: This concluding comment is noted.
COMMENTER C65
Andy Frazer
Carol Absalom
Kevin Klenk
Yair Barniv
Pearl Wang
July 10, 2013
Response C65-1: Please see Master Response #7: Cut-Through Traffic.
Response C65-2: Please see Master Response #2: Project Merits.
Response C65-3: Please see Master Response #2: Project Merits.
Response C65-4: Please see Master Response #7: Cut-Through Traffic. The 34 percent
diversion rate would be achieved through enforcement and regular
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monitoring of the TDM Program required as part of Mitigation Measure
TRANS-9b.
Response C65-5: It is not anticipated that the mitigation measures identified in the Draft EIR to
reduce impacts at the I-280/Wolfe Road and Lawrence Expressway/I-280
interchanges would be inadequate, based on the transportation analysis
conducted as part of the project.
Response C65-6: Please see Master Response #7: Cut-Through Traffic. The Condition of
Approval that would require Apple to set aside $500,000 for the City of
Sunnyvale and $250,000 for the City of Santa Clara is intended to allow for
the monitoring of cut-through traffic and the potential installation of traffic
calming measures should cut-through traffic-related problems arise due to
implementation of the proposed project. These funds are not intended to be
used for “helping traffic to/from/through the main arteries of 280, Wolfe, and
Lawrence.”
Response C65-7: Please see Response to Comment C65-5.
COMMENTER C66
Indranil Das
July 4, 2013
Response C66-1: This introductory comment is noted.
Response C66-2: Please see Master Response #2: Project Merits. Also, refer to Section V.I,
Transportation and Circulation, which analyzes the effect of the project on
the operation of North Wolfe Road and East Homestead Road.
Response C66-3: Please see Master Response #7: Cut-Through Traffic. As discussed on pages
432 to 437 of the Draft EIR, adequate parking would be provided within the
project site (and parking off-site would not be convenient). Therefore,
spillover parking off-site is not expected.
Response C66-4: Please refer to the mitigation measures identified in Sections V.I,
Transportation and Circulation; V.J, Noise; and V.L, Air Quality. These
measures would be required to be implemented by the City.
Response C66-5: The entrance on East Homestead Road would primarily be for bicyclists and
pedestrians. Please refer to Response to Comment C66-3 regarding the
expectation that spillover parking outside the site is not expected.
Response C66-6: Although the I-280/Wolfe Road interchange would be busy at peak hours,
there would be capacity for additional vehicles generated by the project.
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Response C66-7: Such a parking control measure could be implemented if, as a result of
implementation of Condition of Approval CA-TRANS-3 (see pages 435 to
437 of the Draft EIR), spillover parking occurs in adjacent neighborhoods.
Response C66-8: This concluding comment is noted.
COMMENTER C67
Michelle Philips
July 10, 2013
Response C67-1: Please see Master Response #7: Cut-Through Traffic.
COMMENTER C68
Ann (Last name not provided)
July 3, 2013
Response C68-1: This introductory comment is noted.
Response C68-2: See Master Response #15: School Busing Program.
COMMENTER C69
David Mooso
June 30, 2013
Response C69-1: Please see Master Response #2: Project Merits. Mitigation Measure PLAN-2
would include the construction of an alternate creek trail, and partial funding
of a trail study for the drainage channel and segment of Calabazas Creek
south of the project site. See also Master Response #13: Calabazas Creek
Trail.
COMMENTER C70
U P
June 30, 2013
Response C70-1: Please see Master Response #1: Significant and Unavoidable Impacts and
Master Response #2: Project Merits. Please also refer to Section V.I,
Transportation and Circulation, of the Draft EIR, which analyzes the effects
of the project on the transportation links listed in the comment.
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COMMENTER C71
David Mooso
June 30, 2013
Response C71-1: The provision of a northbound right-turn overlap phase with the westbound
left-turn vehicle phase is a feasible signal control measure. The traffic
phasings/timings for the North Tantau Avenue/Pruneridge Avenue intersec-
tion would be refined during the project entitlement process. This suggestion
will be considered at that time.
COMMENTER C72
Loran Stringer
June 30, 2013
Response C72-1: Please see Master Response #12: Trip Cap.
COMMENTER C73
Michelle Connelly
June 30, 2013
Response C73-1: Please see Master Response #2: Project Merits. Please also refer to the
discussion of the Reduced Density alternative, on pages 619 to 625 of the
Draft EIR. That alternative would reduce the size of the project to reduce
traffic impacts and other related impacts. See also Master Response #5:
Public Access Through Project Site.
Response C73-2: The potential intermittent use of outdoor areas around the perimeter of the
project site by smokers would not result in a significant health risk as public
exposure to such smoke would be sporadic.
Response C73-3: This concluding comment is noted.
COMMENTER C74
Sally Everett-Beaupre
June 29, 2013
Response C74-1: This introductory comment is noted.
Response C74-2: The analysis of the environmental effects of the project in the Draft EIR was
not confined to the geographic confines of Cupertino and extends to all
bordering jurisdictions.
Response C74-3: Please refer to Master Response #14: New Freeway Ramps. Also, it should be
noted that Apple’s existing TDM program has been successful in diverting
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approximately 28 percent of Apple employees from the use of single-occupant
vehicles. Mitigation Measure TRANS-9b would increase this diversion rate to
34 percent, with stringent monitoring requirements to ensure compliance.
Response C74-4: This concluding comment is noted.
COMMENTER C75
Jon Ramos
June 26, 2013
Response C75-1: The Draft EIR is most easily accessible via the City’s website for the project:
http://www.cupertino.org/index.aspx?page=1107. The existing buildings on
the site would be demolished as part of the project. Refer to page 61 of the
Draft EIR for a description of the zoning designations on the project site.
COMMENTER C76
Ann Peterson
June 26, 2013
Response C76-1: Due to the robust market for office space in Cupertino and in surrounding
communities, any buildings vacated by Apple are expected to be occupied by
different tenants. Long-term building vacancies due to the project (and
associated adverse environmental impacts such as urban blight) are not
anticipated.
COMMENTER C77
Jeff Greef
June 26, 2013
Response C77-1: The greenhouse gas emissions that would be generated by the proposed
project have been quantified and are shown in the Draft EIR in Table V.K-2
(Project Construction Emissions) on page 504 and Table V.K-3 on page 510.
This comment also requests the quantification of carbon emissions from the
off-site production of construction materials. The term “total carbon footprint”
is subject to a wide variety of interpretations. The Draft EIR contains an
extensive analysis of the greenhouse gas emissions expected to result from
construction and operation of the project. For the construction analysis,
transportation of construction materials to the site and onsite construction
activities have been estimated and evaluated. To the extent the commenter is
inquiring about manufacturing processes off-site, there is extensive publicly
available information on the estimated emissions associated with processes
such as cement production, steel production, and glass manufacturing. At this
stage in the planning process, due to variations in construction suppliers and
vendors, it is not possible to develop an accurate estimate of construction
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lifecycle emissions. Off-site production of greenhouse gas emissions is
typically monitored and inventoried for compliance with State greenhouse gas
reduction goals independently from the end product user. Additionally, an
analysis of total construction lifecycle emissions is not required by the
California Air Resources Board or the Bay Area Air Quality Management
District for CEQA documents, and specific methodologies for calculating
such emissions have not been mandated.
The attribution of such emissions is also typically assigned in the first instance
to the producer, not the end product user. For example, the World Resources
Institute has observed that “[t]he significant quantities of energy and GHG
[greenhouse gas] emissions that are embodied in these products are, under
prevailing GHG accounting systems, attributed to the country of production,
not consumption.”1
As for the consideration of emissions that would not have occurred had the
project not occurred, the Draft EIR has analyzed and considered the
greenhouse gas emissions for this project, as compared to the baseline
conditions (as required by CEQA), to determine the emissions attributable to
the project. Please refer to the extensive sustainability features that would be
designed into the project, described on pages 134 to 136 of the Draft EIR,
which were taken into account in conducting this analysis.
Response C77-2: Please see Response to Comment C77-1.
COMMENTER C78
Mahesh Nihalani
June 26, 2013
Response C78-1: Please see Master Response #2: Project Merits.
COMMENTER C79
Anonymous
June 25, 2013
Response C79-1: Please see Master Response #2: Project Merits.
1 World Resources Institute, 205. Navigating the Numbers: Greenhouse Gas Data and International Climate Policy,
Executive Summary. Website: http://pdf.wri.org/navigating_numbers.pdf.
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COMMENTER C80
John Nelson
June 26, 2013
Response C80-1: Please see Master Response #2: Project Merits. Please also refer to the
discussion of the Reduced Density alternative, on pages 619 to 625 of the
Draft EIR. That alternative would reduce the size of the project to reduce
traffic impacts and other related impacts.
COMMENTER C81
Charles Hanson
June 25, 2013
Response C81-1: As discussed on page 137 of the Draft EIR, as part of the project, a minimum
of 75 percent of construction and demolition waste would be diverted from
landfills and recycled or reused.
COMMENTER C82
Anonymous
June 25, 2013
Response C82-1: Please see Master Response #2: Project Merits.
COMMENTER C83
Walter Li
June 25, 2013
Response C83-1: As discussed on page 182 of the Draft EIR, CEQA Guidelines Section 15125
requires an EIR to evaluate the impacts of the project compared to “baseline
conditions” that are defined as the conditions that “exist at the time the notice
of preparation is published, or if no notice of preparation is published, at the
time environmental analysis is commenced, from both a local and regional
perspective.” Accordingly, the baseline condition used to evaluate the impacts
of the project includes a site occupancy of approximately 4,844 employees
(the number of employees that occupied the project site in August 2011, when
the Notice of Preparation was released). However, Chapter VI, Alternatives,
includes an analysis of the impacts of a project that would allow for full
occupancy (i.e., 9,800 employees) of the existing buildings on the project site.
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COMMENTER C84
Marc Aronson
June 21, 2013
Response C84-1: Please see Master Response #2: Project Merits.
COMMENTER C85
Jennifer Martin
June 18, 2013
Response C85-1: Please see Master Response: Analysis of Neighborhood Cut-Through Traffic.
Response C85-2: Mitigation Measure NOI-1 in the Draft EIR would ensure that construction
activities are in compliance with the Municipal Code and all applicable noise
regulations.
COMMENTER C86
Mike Hammes
June 17, 2013
Response C86-1: In the transportation analysis conducted as part of the Draft EIR, a small
percentage of project traffic was assumed to access the project site via the I-
280/De Anza Boulevard interchange; thus the analysis captures the scenario
identified in this comment.
Response C86-2: As part of Condition of Approval CA-TRANS-3, if parking spillover is
identified as a problem as part of annual parking monitoring (which could
include monitoring of the nearby Kaiser facilities), a detailed parking
management plan would be provided and additional measures would be
taken (including the provision of additional parking on the project site).
COMMENTER C87
Aleksandr Movshovich
June 17, 2013
Response C87-1: Please see Master Response #2: Project Merits and Master Response #5:
Public Access Through Project Site.
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COMMENTER C88
Edward Hirshfield
June 17, 2013
Response C88-1: Please see Master Response #2: Project Merits. The comment also notes that
shifting the work hours of Apple employees away from peak periods could
reduce project traffic impacts. This concept is employed in the list of
“Additional TDM Measures” discussed on page 443 of the Draft EIR. These
measures, which include the implementation of a flexible work schedule and
the encouragement of telecommuting, would be implemented if the TDM
measures identified as part of the project fail to meet the peak hour counts
goal established in Mitigation Measure TRANS-9b.
COMMENTER C89
Linda Vanderhule
June 17, 2013
Response C89-1: This comment, which does not pertain to the adequacy of the Draft EIR, is
noted.
COMMENTER C90
Gary Jones
June 15, 2013
Response C90-1: Please see Master Response #2: Project Merits.
COMMENTER C91
Jun Xu
June 14, 2013
Response C91-1: Please see Master Response #2: Project Merits.
COMMENTER C92
Sue and Joel Rosado
June 14, 2013
Response C92-1: Please see Master Response #2: Project Merits and Responses to Comments
A1-13 and C1-1.
Response C92-2: Please see Master Response #2: Project Merits.
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COMMENTER C93
Frank Bryan
June 14, 2013
Response C93-1: Please see Master Response #2: Project Merits and Master Response #11:
Diverted Trips Due to Pruneridge Avenue Closure.
COMMENTER C94
Sharon (Last name not provided)
June 14, 2013
Response C94-1: Please see Master Response #2: Project Merits and Master Response #11:
Diverted Trips Due to Pruneridge Avenue Closure..
COMMENTER C95
Ying Xia
June 12, 2013
Response C95-1: Please see Master Response #2: Project Merits.
COMMENTER C96
Richard Altmaier
June 12, 2013
Response C96-1: This comment, which generally pertains to the merits of the project, and
supports the mitigation measures identified in the Draft EIR, is noted.
COMMENTER C97
David Cookson
June 7, 2013
Response C97-1: As discussed on pages 344 to 345 of the Draft EIR, Mitigation Measure
HAZ-3 would require the project sponsor to conduct hazardous materials
surveys of all buildings on the site that have not been previously inspected or
abated. Buildings identified as containing hazardous building materials
would be abated in accordance with all applicable local, State, and federal
regulations. Hazardous building materials would thus be monitored on the
site until abated, thus reducing the potential for emissions of hazardous
building materials in the air to a less-than-significant level. Mitigation
Measures HAZ-2a and HAZ-2b, discussed on page 344 of the Draft EIR,
would require the preparation of an Environmental Site Management Plan
(which could itself require ongoing monitoring) and a vapor intrusion
assessment to ensure that residual hazardous materials in groundwater and
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soil on the project site are not released into the air such that they would result
in a significant health risk to the public.
COMMENTER C98
Kevin Klenk
June 7, 2013
Response C98-1: This comment generally pertains to the impacts of the project on freeway
interchanges. Please refer to Mitigation Measures TRANS-1, TRANS-3,
TRANS-5, TRANS-9a, TRANS-10, TRANS-11, TRANS-14, TRANS-19a,
TRANS-20, TRANS-21, TRANS-22, TRANS-25, and TRANS-26 in the
Draft EIR. These measures represent feasible improvements to freeways to
reduce the impacts of the project on congestion levels. In addition, Mitigation
Measure TRANS-9b would require that 34 percent of project trips be
diverted from single-occupancy vehicles, thus reducing the project’s impact
on the roadway system, including freeways.
COMMENTER C99
Willie LU
June 6, 2013
Response C99-1: The traffic data referenced in the comment is noted, but it is unclear how this
relates to the impact analysis in the Draft EIR. Please also refer to Master
Response #2: Project Merits. While there may be merits to locating a
corporate campus at a distance from population centers, the benefits of this
approach include: proximity between jobs/housing (and the potential for
reduced commutes) and proximity to transit services (which can benefit
levels of traffic congestion, air pollutant emissions, and greenhouse gas
emissions).
Response C99-2: Please note that while attorneys were involved in the preparation of the Draft
EIR, the report was primarily authored by a team of technical experts under
the direction and supervision of City of Cupertino Department of Community
Development staff (See Draft EIR Chapter VIII, Report Preparation). The
mitigation measures in the report would be enforced and monitored by means
of a Mitigation Monitoring and Reporting Program that would be made
available to the public. Please also refer to Master Response #1: Significant
and Unavoidable Impacts.
Response C99-3: This comment is noted, although it does not pertain to specific environmental
issues related to the project and no further response is required.
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COMMENTER C100
Giselle Ballou
June 6, 2013
Response C100-1: Please see Master Response #2: Project Merits. This comment also suggests
that the project would increase traffic in the area. This comment is consistent
with the analysis in Section V.I, Transportation and Circulation, of the Draft
EIR.
COMMENTER C101
Cynthia Smyth
June 6, 2013
Response C101-1: Please see Master Response #2: Project Merits.
COMMENTER C102
Milt Kostner
June 6, 2013
Response C102-1: Please refer to Section V.I, Transportation and Circulation, for a discussion
of questions relating to impacts associated with the removal of Pruneridge
Avenue on arterials and freeway interchanges in the vicinity of the project
site and associated with bus traffic.
Response C102-2: Please refer to Mitigation Measure NOI-1, which addresses the hours during
which construction activities could occur. Exterior project noise-generating
construction activities within 750 feet of residentially zoned property would
be permitted only between the weekday hours of 7:00 a.m. and 8:00 p.m.
Response C102-3: Please see Master Response #2: Project Merits. The open space within the
site, while not physically accessible to the public, would be visible through a
metal, powder-coated, picket-style fence surrounding most of the site.
COMMENTER C103
Heidi Johnson
June 6, 2013
Response C103-1: While it is often suggested that Douglas Fir (Pseudotsuga menziesii) will not
grow in the Santa Clara Valley and other areas adjacent to the San Francisco
Bay, in fact, Douglas Fir have been shown to thrive in the area around the
project site. For instance, a healthy Douglas Fir can be found growing on the
southbound I-280 off-ramp at De Anza Boulevard, adjacent to Apple’s
current Infinite Loop Campus. Additionally, a prominent Douglas Fir in the
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area has grown immediately adjacent to Stanford's northernmost entrance
arch at Palm Drive for at least 125 years.
COMMENTER C104
Richard and Beverly Olsen
July 18, 2013
Response C104-1: Please see Master Response #2: Project Merits. To sign up for notifications
about the proposed project, please use the City’s eNotification Signup form:
http://www.cupertino.org/index.aspx?page=480.
COMMENTER C105
Todd Beirdo
June 30, 2013
Response C105-1: Please see Master Response #2: Project Merits.
COMMENTER C106
Keith Murphy
July 22, 2013
Response C106-1: This introductory comment is noted.
Response C106-2: It is unclear why the commenter believes the project has been “fast-tracked,”
as the environmental review process for the project was initiated over 2 years
ago (summer of 2011). As discussed on page 494 of the Draft EIR, the
project was certified as an Environmental Leadership Project pursuant to
State Assembly Bill 900 in April 2013. Under this certification, the project
was required to undergo normal environmental review required under
CEQA, including all requirements regarding the mitigation of significant
impacts. Apple’s AB 900, Jobs and Economic Improvement Through
Environmental Leadership Act of 2011 Application is available here:
http://www.opr.ca.gov/s_californiajobs.php. This link was also placed on the
City’s website for the project.
Response C106-3: This comment is noted. As described in pages 225 to 230 of the Draft EIR,
the project would not result in significant impacts related to housing and thus
no mitigation would be required.
Response C106-4: Please see Responses to Comments C106-2 and C106-3.
Response C106-5: Impacts associated with the closure of Pruneridge Avenue are discussed
throughout Draft EIR, but see in particular pages 150-152; 156-159; and 427-
430. Please also refer to Master Response #5: Public Access Through Project
Site.
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Response C106-6: Please refer to Impacts PLAN-1, PLAN-3, PLAN-5, and PLAN-6 in the
Draft EIR, which relate to General Plan provisions concerning the provision
of trails and park space within the project site. Please refer to Response to
Comment C3-1 regarding the referenced construction project on the site. This
temporary structure would not infringe on the riparian buffer around
Calabazas Creek or Santa Clara Valley Water District access to the creek.
Response C106-7: Please refer to Response to Comment C106-2 regarding the project’s certifica-
tion as an Environmental Leadership Project. Please refer to Response to
Comment C3-1 regarding the referenced construction project on the site.
Relevant information about the project is consolidated on one web page:
Apple Campus 2 Project: http://www.cupertino.org/index.aspx?page=1107.
Response C106-8: Please refer to Response to Comment C3-1. The accompanying photographs
depict the site of the RC-1A Mockup.
Response C106-9: This concluding comment is noted.
COMMENTER C107
Stephen Rohde
July 22, 2013
Response C107-1: This comment, which expresses support for the project, is noted.
Response C107-2: Please see Master Response #10: Median on East Homestead Road.
Response C107-3: If designed in accordance with City standards, using appropriate trees
species, long-term maintenance of the East Homestead Road median would
be manageable.
Response C107-4: Please refer to Master Response #14: New Freeway Ramps.
Response C107-4: This concluding comment, which pertains to the merits of the proposed
median along East Homestead Road, is noted.
COMMENTER C108
Ria Lo
July 22, 2013
Response C108-1: Please see Master Response #5: Public Access Through Project Site.
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COMMENTER C109
Mette Christensen
July 22, 2013
Response C109-1: The City coordinates transportation improvements among major develop-
ment projects in the City, along with requiring each project sponsor to fund
transportation improvements needed to reduce the impacts of the project.
Additionally, the City works directly with the residents, businesses, and
schools in the Rancho Rinconada area to address traffic and parking concerns
on an on-going basis, and will continue to do so as projects in the area move
forward.
Response C109-2: Please refer to: Muffly, Dave, 2011. Apple Arborist. Apple Campus 2,
Consolidated Arborist Report. August 1 (and all arborist reports referenced
therein). These reports are available for review as part of the Administrative
Record for the project (accessible at: http://www.cupertino.org/index.aspx
?page=1107). These reports are also available for review at the City of
Cupertino Community Development Department.
Response C109-3: The City provides a convenient way to send questions, requests, comments
and complaints directly to City staff through the “Access Cupertino” link on
its home page. The link can be accessed on the top bar of the City’s home
page. The website is: www.cupertino.org/access/ .
Response C109-4: This comment introduces excerpts from the Draft EIR that relate to the
previous comments. No further response is required.
Response C109-5: This comment comprises excerpts from the Draft EIR. No further response is
required.
COMMENTER C110
Ria Lo
July 22, 2013
Response C110-1: This introductory comment is noted.
Response C110-2: This comment, which is noted, pertains generally to the merits of the project
design and not the adequacy of the Draft EIR. The analysis in Section V.I,
Transportation and Circulation, takes into account expected visitors to the
project site. With the exception of special events, visitation to the site is
expected to be modest. Furthermore, most visitors would arrive at and depart
the campus during the midday, when traffic volumes on the surrounding
roadway network are lower.
Response C110-3: Please see Response to Comment C110-2. The “superblock” layout of the
campus is discussed in regard to pedestrian and bicyclist accessibility, and
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land use patterns in general, on pages 149 to 152 and 188 to 190 of the Draft
EIR.
Response C110-4: This comment is noted. In establishing the parking supply for the project
(and crafting related mitigation), the key objective was to balance the
probable demand for parking at the site with the understanding that too much
parking may incentivize driving. As discussed in pages 432 to 437 of the
Draft EIR, the parking supply takes into account visitor parking spaces, and
carpooling, and thus does not correlate directly with the desired 34 percent
single occupancy vehicle diversion rate required as part of Mitigation
Measure TRANS-9b.
Response C110-5: The 34 percent trip diversion requirement in Mitigation Measure TRANS-9b
is appropriate given Apple’s location in a suburban setting. This requirement
does not suggest that Apple cannot achieve a higher alternative mode share.
The two examples cited in the comment are not completely analogous to
Apple. Stanford has faculty housing near campus which supports higher
bicycle use. Unlike the project site, both Stanford and Genentech are adjacent
to high-frequency Caltrain stations and located closer to regional
transportation hubs.
Response C110-6: The proposed roadway modifications generally include minor widening such
as the addition of one lane on an approach. Due to the combination of the
modifications requiring only minor widening and the low transit, bicycle, and
pedestrian volumes in the vicinity of the affected intersections, secondary
impacts to non-auto modes would be less than significant. It should be noted,
however, that the designs for the modifications would incorporate pedestrian-
friendly treatments such as narrow lane widths and tight corner radii, where
appropriate. In addition, mitigation measures that include roadway widening
would generally only occur at locations where the project is anticipated to
add a substantial amount of vehicle traffic. In general, the preference of the
City is to avoid roadway widening where possible. Therefore, a fundamental
mitigation measure in the Draft EIR is Mitigation Measure TRANS-34,
which would require a 34 percent trip diversion rate (through implementation
of a TDM Program) that is robust considering the relatively suburban setting
of the project.
Response C110-7: The comment about the City’s minimum parking requirements is noted. As
discussed on page 443 of the Draft EIR, if Apple is unsuccessful at meeting
the trip diversion goal required in Mitigation Measure TRANS-9b, it would
be required to implement additional TDM measures. One such measure could
include a parking cash-out program, or similar incentive to reduce parking
demand.
Response C110-8: The closure of the Cupertino Village south entrance represents the closure of
one of three driveways on North Wolfe Road. In addition, Cupertino Village
is accessible via the North Wolfe Road/Pruneridge Avenue intersection.
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Given the multiple alternative access points onto North Wolfe Road, the
closure of the southern Cupertino Village driveway is expected to result in a
negligible increase in traffic on East Homestead Road and would not
compromise the viability of businesses in the shopping center.
Response C110-9: The closure of Pruneridge Avenue is identified as significant and unavoidable
for several impact areas in the Draft EIR (see Impacts PLAN-2, PLAN-5,
PLAN-6, TRANS-31, TRANS-32, TRANS-33, and TRANS-34.
Response C110-10: These reference materials, used to support the previous comments, are noted.
COMMENTER C111
Sylvia Gallegos
July 22, 2013
Response C111-1: CEQA requires the lead agency make all adopted mitigation measures
enforceable and to adopt a mitigation monitoring and reporting program that
meets the requirements of CEQA Sections 21081.6(a)(1) and (b), which
requires the City, as lead agency, to be responsible for monitoring
implementation of all adopted mitigation measures that are within its
responsibility and jurisdiction. The comment suggesting formation of a citizen
committee to oversee mitigation monitoring is noted.
Response C111-2: The transportation analysis of the Reduced Density alternative in Chapter VI,
Alternatives, was conducted at a lesser level of detail than the proposed
project, consistent with Section 15126.6(d) of the CEQA Guidelines.
However, the analysis was sufficiently detailed to compare the specific
impacts of the project on the transportation system to those that would result
from the Reduced Density alternative – to “allow meaningful evaluation,
analysis, and comparison with the proposed project.”
Response C111-3: This comment, which relates to existing bicycle facility conditions that
would not be affected by the project, is noted. No further response is
required.
Response C111-4: As discussed on page 443 of the Draft EIR, if Apple is unsuccessful at
meeting the trip diversion goal required in Mitigation Measure TRANS-9b, it
would be required to implement additional TDM measures. One such
measure could include a parking cash-out program, which is included in the
list of TDM measures for future consideration.
Response C111-5: One of the additional TDM measures identified on page 443 of the Draft EIR
(which could be employed if Apple does not meet its required trip diversion
goal) is an expansion of the campus car-sharing fleet, which, as suggested,
makes use of the Apple shuttle more attractive. As for the acquisition or use
of park-and-ride lots, as described in the Draft EIR, if 34 percent TDM
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participation is not achieved, the City would work with Apple to identify
additional measures. One option that may be considered by the City and
Apple as another potentially viable TDM measure is the acquisition or use of
park-and-ride lots, although the need, location, and approval of such off-site
facilities is speculative and may require additional environmental and
discretionary review. At this point, it is not anticipated that park-and-ride lots
would be needed to achieve the 34 percent TDM participation because other
measures are expected to be successful in diverting trips, so they are not
included as a specific measure in the Draft EIR.
Response C111-6: As discussed on pages 148 to 149 of the Draft EIR, the 1.1-acre requirement
for Mitigation Measure PLAN-1 is based on the 1.1-acre portion of the
project site that would be re-designated from Parks and Open Space to
Industrial/Residential as part of the project. Replacement park space need not
be developed in close proximity to the project site (because the park
designation was part of a residential project that was never built, and the park
was never constructed). However, the City would consider local allocations
of park space as a factor in pursuing development of the park space
elsewhere in the City.
COMMENTER C112
Wahila Wilkie
July 22, 2013
Response C112-1: Regarding the comment about the closure of Pruneridge Avenue, this issue is
discussed throughout the Draft EIR, and in particular pages 150 to 152; 156
to 159; and 427 to 430. Traffic in the vicinity of the project site is discussed
throughout Section V.I, Transportation and Circulation, of the Draft EIR.
Requiring Apple to bus children to school as mitigation for project-related
traffic impacts was rejected from detailed consideration in the Draft EIR for
the reasons discussed in Master Response #15: School Busing Program.
Mitigation Measure PLAN-1 would require Apple to provide sufficient funds
for the acquisition of 1.1 acres of property for the future development of a
park, or agree to purchase, designate, and dedicate to the City 1.1 acres of the
land elsewhere in the City as Parks and Open Space.
COMMENTER C113
Marialis Seehorn
July 22, 2013
Response C113-1: As discussed in Section V.I, Transportation and Circulation, although the
project would worsen congestion at certain locations, all intersections and
roadway networks (with the exception of the segment of Pruneridge Avenue
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within the project site) would remain functional and usable by the public,
including residents of Sunnyvale.
COMMENTER C114
Robert Neff
July 22, 2013
Response C114-1: This general comment about bicycling conditions is noted. No further
response is required.
Response C114-2: The project includes numerous transportation network modifications/
improvements around the project site, including continuous bike lanes on
North Tantau Avenue between East Homestead Road and Stevens Creek
Boulevard, as discussed on pages 111 to 112 of the Draft EIR.
Response C114-3: As part of Mitigation Measure TRANS-6, Apple would be required to
modify the East Homestead Road/North Tantau Avenue intersection to
provide an exclusive eastbound right-turn lane. With this modification, as
shown in Appendix H of the Transportation Impact Analysis (Appendix B of
the Draft EIR), the pork-chop island on the south-west corner would be
removed.
COMMENTER C115
Tammy Mongelli
July 22, 2013
Response C115-1: Please see Master Response #2: Project Merits and Master Response #3:
Mitigation Nexus.
COMMENTER C116
Ray Crump
July 22, 2013
Response C116-1: This comment, which generally pertains to the merits of the project, is noted.
Please also refer to Section V.I, Transportation and Circulation, of the Draft
EIR, which identifies measures to reduce the traffic generated by the project.
See Master Response #1: Significant and Unavoidable Impacts regarding the
City’s commitment to implementing mitigation measures that are outside the
jurisdiction of Cupertino.
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D. PUBLIC MEETING COMMENTS
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PUBLIC MEETING
June 26, 2013
COMMENTER D1
Randy Smith
Response D1-1: This comment, which references the beneficial impacts of the project and
does not discuss the adequacy of the Draft EIR, is noted.
COMMENTER D2
Dennis Garringon
Response D2-1: This comment, which does not address the adequacy of the Draft EIR, is
noted.
COMMENTER D3
Arturo Sainz
Response D3-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D4
David Jamieson
Response D4-1: Please see Master Response #2: Project Merits.
COMMENTER D5
Al Sousa
Response D5-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D6
R. T. Parmley
Response D6-1: Please see Master Response #5: Public Access Through Project Site.
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COMMENTER D7
D. Radisic
Response D7-1: An Environmental Impact Report was prepared for the Infinite Loop campus
that included a Transportation Impact Analysis (TIA). That TIA followed
methodologies in developing trip generation estimates and evaluating the
effects of the traffic on the surrounding roadway system that are similar to
those used in the Draft EIR. Analyses using microsimulation were not
typically conducted when the Infinite Loop campus was being planned.
Therefore the Apple Campus 2 TIA includes elements of a more technically
sophisticated analysis to better understand the impacts of the project on the
roadway network.
COMMENTER D8
Tappan (Tap) Merrick
Response D8-1: This comment, which references a meeting that the commenter had with an
Apple representative, is noted.
Response D8-2: Please see Master Response #7: Cut-Through Traffic.
COMMENTER D9
E. Castro
Response D9-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D10
Jim Reed
Response D10-1: This comment, which references beneficial socioeconomic and
environmental impacts of the project and not the adequacy of the Draft EIR,
is noted.
COMMENTER D11
Mark Van Den Huevel
Response D11-1: This comment, which also addresses the adequacy of the Draft EIR and not
the adequacy of the Draft EIR, is noted.
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COMMENTER D12
Josué Garcia
Response D12-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D13
Jose Espinosa
Response D13-1: Please see Master Response #2: Project Merits.
COMMENTER D14
Larry Watson
Response D14-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D15
Anonymous
Response D15-1: This comment expresses concern about the impacts of the project (identified
in the Draft EIR) on the I-280/Wolfe Road interchange. Mitigation Measures
TRANS-1, TRANS-5, TRANS-14, TRANS-25, TRANS-26, and TRANS-29
would reduce impacts to this interchange.
COMMENTER D16
Anonymous
Response D16-1: This comment references the closure of Pruneridge Avenue and the impacts
on travel times to nearby services. The closure of Pruneridge Avenue is
discussed throughout the Draft EIR, but refer particularly to pages 150-152;
156-159; and 427-430. With the addition of project traffic, there would be
added delays on Homestead Road during the peak commute periods;
however, the delays would not be severe. For example, in the evening when
commute congestion is greater, the delay on eastbound Homestead Road
(towards Kaiser Hospital) at Wolfe Road is estimated to increase by 10
seconds. Similarly, the delay on southbound Wolfe Road towards Kaiser
Hospital is estimated to increase by 15 seconds. Emergency vehicles would
continue to be able to navigate the corridors with emergency signal pre-
emption that give priority signals to emergency response vehicles (as
required by Mitigation Measure PSU-1).
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COMMENTER D17
Thorisa Yap
Response D17-1: Please see Master Response #2: Project Merits.
COMMENTER D18
Jim Riley
Response D18-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
COMMENTER D19
Lidia Blair
Response D19-1: This comment, which references beneficial socioeconomic impacts of the
project and not the adequacy of the Draft EIR, is noted.
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIII. COMMENTS AND RESPONSES
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\3-Responses.doc (09/16/13) FINAL 132
E. COMMENTS FROM INDIVIDUALS ON THE MERITS OF THE PROJECT
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIII. COMMENTS AND RESPONSES
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\3-Responses.doc (09/16/13) FINAL 133
The letters with a prefix “E” are letters received from individuals via the mail, email, or City’s
website in support of the project that pertain solely to the merits of the project and do not raise
questions or concerns about project environmental issues or the adequacy of the Draft EIR. Therefore,
pursuant to Sections 15088 and 15132 of the CEQA Guidelines, no formal response is required.
However, these comments will be considered by the City decision-makers when project approval is
contemplated. See also Master Response #2: Project Merits.
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIII. COMMENTS AND RESPONSES
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\3-Responses.doc (09/16/13) FINAL 134
This page intentionally left blank.
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 135
IV. TEXT REVISIONS
Chapter IV presents specific changes to the text of the Draft EIR that are being made to clarify
materials in the Draft EIR, in response to comments received during the public review period or at the
request of City staff. In no case do these revisions introduce “significant new information” as defined
in CEQA Guidelines Section 15088.5, including new or more severe environmental impacts, new
mitigation measures or alternatives, or information indicating that the Draft EIR is fundamentally or
basically inadequate. All revisions contained herein are minor in nature.
Where revisions to the main text are called for, the page and paragraph are set forth, followed by the
appropriate revision. Added text is indicated with underlined text. Text deleted is shown in strikeout.
Page numbers correspond to the page numbers of the Draft EIR.
Page 2 of the Draft EIR is revised as follows:
The City of Cupertino circulated a Notice of Preparation (NOP) for the proposed project, which
notified responsible agencies and interested parties that an EIR would be prepared for the project
and indicated the environmental topics anticipated to be addressed in the EIR. The NOP was
published on August 19, 2011, and was mailed to public agencies, organizations, and individuals
likely to be interested in the potential impacts of the project. The scoping period, initially planned
to end on September 19, 2011, was extended to October 5, 2011 to allow for further public
comment. Comments on the NOP were received by the City and considered during preparation
of the EIR. A scoping session for the EIR was held as a public meeting on September 8, 2011.
Public notices for the scoping session were mailed to approximately 20,000 households in the
City, advertisements were placed in local newspapers, and the City posted the Notice of
Preparation (NOP) and hearing notice on the City’s website. Notices were also sent to
households in Santa Clara and Sunnyvale within 1,000500 feet of the project site. A copy of the
NOP and comments submitted during the EIR scoping period are included in Appendix A of this
EIR.
Table II-1, starting on page 9 of the Draft EIR, is revised as shown starting on page 137 of this
chapter.
Page 61 of the Draft EIR is revised as follows:
The Park and Recreation Public Park/Recreation (PR) zone corresponds to the approximately 1.1-
acre portion of the site designated Parks and Open Space in the General Plan. This area currently
contains a parking lot. The PR zone allows for the development of parks, playgrounds, and
recreational facilities, including agricultural uses such as crop and tree farming. As with the
General Plan Parks and Open Space designation described above, the site was zoned PR at the
time a development project was proposed for a portion of the Ridgeview Campus area.
Figure III-4 on page 67 of the Draft EIR is revised as shown on the following page.
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RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 144
The numbering of one subheading on page 102 is revised as follows:
(3) North Tantau Avenue. Apple also proposes …
Figure III-17a on page 105 of the Draft EIR is revised as shown on page 145 of this chapter.
Page 111 of the Draft EIR is revised as follows:
Currently, Route 81 accesses Pruneridge Avenue only in the eastbound direction from
northbound North Wolfe Road, where it then turns left onto North Tantau Avenue, and then
right onto East Homestead Road towards the City of Santa Clara. With the closure of
Pruneridge Avenue, Route 81 would continue to travel north on North Wolfe Road, turn right
onto Vallco Parkway, and left onto North Tantau Avenue, where it would connect with its
current route. Figure III-18 shows the existing and proposed route of Route 81. As part of the
proposed project, a new bus stop would be established at the northeast quadrant of the
intersection of North Wolfe Road and Stevens Creek Boulevard. Other adjustments to bus stops
and signage may be required to accommodate the rerouting.
Page 136 of the Draft EIR is revised as follows:
14. Construction and Phasing
The project would be developed in two phases. Phase 1 would involve the demolition of all
buildings on the site and construction of the approximately 2,820,000-square-foot Main
Building, and an additional 245,000 square feet of auditorium, fitness center, and Valet Parking
Reception uses. In addition, the Main Parking Structure, North Tantau Parking Structure,
Central Plant, Security Receptions, Landscape Maintenance Buildings, and associated
transportation and utility infrastructure would also be developed as part of Phase 1. As part of
Phase 1, the median of North Wolfe Road south of East Homestead Road would be temporarily
removed, along with its trees, while utility infrastructure is being installed. Some or all of the
trees from the median may be stored off-site while the utility lines are installed. Following
completion of the utility project, the median would be reconstructed according to its current
configuration and some or all of the trees would be transplanted back to the median in their
original location or replaced with equivalent trees (as some of the trees are not suitable for
transplant). Also Aas part of Phase 1, an approximately 15-foot temporary sound wall would be
installed around the Phase 1 portion of the project site (except along the southern boundary of
the project site, adjacent to I-280) to reduce construction-related noise levels in the vicinity of
adjacent residential uses. Phase 1 sound walls would be placed 30 feet from the sidewalk
(where site boundaries face a public right-of-way) or at the property line. Sound walls would be
installed along the west bank of Calabazas Creek. In addition, an 8- to 12- foot galvanized
fence/sound wall composed of concrete with structural steel with a privacy screen would be
located along the southern boundary of the project site, adjacent to I-280.
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Apple Campus 2 Project EIR Off-Site Street Changes
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 146
Phase 2 would involve the development of 600,000 square feet of office, research, and
development space east and west of North Tantau Avenue, along with the Satellite Plant North
and South, parking, and associated transportation and utility infrastructure. As part of Phase 2,
temporary sound walls would be placed 20 feet west of the shared property line with the
residential uses and Jenny Strand Park to the east of the project site.1
No roads in the vicinity of the site would be closed for the duration of the project construction
period. However, temporary traffic diversion may occur to facilitate relocation of utilities on
North Wolfe Road and East Homestead Road, and street widening on North Wolfe Road. In
addition, detours may occur around Pruneridge Avenue early in the construction period (before
physical vacation of the street segment occurs) to allow for utility relocation.
A temporary concrete batch plant would be located in the northwestern portion of the project
site, with entries on the north and west sides of the plant. The plant would be used to formulate
concrete for use in the construction of the proposed project, and would reduce the need for the
transport of mixed concrete to the project site by truck.
Page 139 of the Draft EIR is revised as follows:
o Table 2-A, Development Allocation, would be amended to reflect the future anticipated
commercial square footage in Vallco Park North, which encompasses the project site.
Similar adjustments would be made to the discussion of Vallco Park North on pages 2-
30 and 2-31 of the Land Use/Community Design Element.
o Other General Plan figures would be adjusted to reflect the removal of Pruneridge
Avenue, the removal of the Parks and Open Space designation from the site, and the
relocation of Glendenning Barn.
o Amendments related to a change in the setback ratio for North Tantau Avenue from
1.5:1 to 1:1 due to a required mitigation measure to add a southbound right-turn lane on
North Tantau Avenue to Stevens Creek Boulevard.
Zoning Map Amendment. The PR zone, which corresponds to the approximately 1.1-acre
portion of the site designated Parks and Open Space in the General Plan, would be rezoned
to P(MP).
Development Agreement. If parties mutually agree, a Development Agreement that would
cover the entire project site would vest the project approvals.
Subdivision Maps. Re-subdivision of the existing parcelization by a vesting tentative
subdivision map from 19 parcels to five parcels. The conforming Final Map would ,
includeing the recordation of appropriate Covenants, Codes and Restrictions that would
govern the use of the five parcels.
Conditional Use Permit. The Conditional Use Permit would allow certain uses and
facilities to be permitted on the site (including auditorium uses and wireless antennae) if
Apple meets certain conditions established by the City.
1 Skansa and DPR, 2012. Apple Campus 2 Construction Equipment Summary. December 11.
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 147
Development Permit. The Development Permit would be granted concurrent with approval
of a conceptual development plan that includes a general description of proposed uses and
the circulation system, a topographical map of the site and neighboring properties, a
landscape plan, and other information required by the City. Phase 2 development would
require an independent Development Permit.
Page 154 of the Draft EIR is revised as follows:
Mitigation Measure PLAN-3: The project sponsor shall implement the following measures to
the satisfaction of the City, as illustrated in Figure IV-3:
a. Fund and construct to the satisfaction of the City a pedestrian/bike alternate creek trail
extending from the intersection of North Tantau Avenue and Pruneridge AvenueCalabazas
Creek, south to Vallco Parkway, on both sides of North Tantau Avenue, and then west
along the north side of Vallco Parkway to the intersection of Calabazas Creek. This funding
shall account for planning, design, collaboration with other agencies, and construction and
maintenance of the alternate trail route. The trail shall include a combination of the
following features that reference Calabazas Creek:
Figure IV-2 on page 161 of the Draft EIR is updated as shown on page 148 of this chapter.
Figure IV-3 on page 162 of the Draft EIR is updated as shown on page 149 of this chapter.
Page 163 of the Draft EIR is revised as follows:
The Park and RecreationPublic Park/Recreation (PR) zone corresponds to the portion of the site
designated Parks and Open Space in the General Plan. The PR zone allows for the development
of parks, playgrounds, and recreational facilities, including agricultural uses such as crop and
tree farming. According to Section 19.92 of the Zoning Ordinance, “The purpose of the park
and recreation zone is to regulate the land uses and recreational activity permitted within
publicly owned parks within the City, to ensure the safety and enjoyment of the persons
utilizing the park facilities, as well as to protect the rights of adjoining property owners.”
Footnote 24 on page 229 of the Draft EIR is revised as follows:
24 Prior to 2005, this portion of the site was zoned Planned Industrial (P(MP)). In November 2005, the area
was approved for a townhouse development consisting of 130 townhomes and a 1.1-acre public park. At that time,
the area was rezoned as Planned Residential (P(Res)) and Park and RecreationPublic Park/Recreation (PR). Apple
purchased the area in 2006 and in 2009 Apple applied for a rezoning of the P(Res) zoned parcels to allow for the
development of planned industrial uses in addition to residential uses. The City granted the rezoning to P(MP, Res).
As part of the Apple Campus 2 Project, Apple does not propose to remove the residential zoning designation on the
site.
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feetfeet
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Apple Campus 2 Project EIR
Zoning DesignationsSOURCE: GOOGLE EARTH; LSA ASSOCIATES, INC., JUNE 2011.
I:\COC1101 Apple Campus 2\figures\RTC\Figures\Fig_IV2_[Revised].ai (9/20/13)
FIGURE IV-2
[Revised]
Homestead Rd
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Apple Campus 2 Project EIR Mitigation Measure PLAN-3
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 150
Page 358 of the Draft EIR is revised as follows:
Vallco Parkway is a short (less than 0.5 mile) six-lane, east-west roadway that provides a
connection between Wolfe Road and Tantau Avenue. Vallco Parkway has an approximate
ADT of 4,000 vehicles. Entitled development projects, including JC Penney, Rose Bowl,
and Main Street, are located along Vallco Parkway. The lane configuration of Vallco
Parkway will be modified in conjunction with these development projects to four travel
lanes with some on-street parking. The road currently has one signalized intersection at
Perimeter Road. Between Perimeter Road and Wolfe Road, Vallco Parkway is currently
under construction to provide two lanes in each direction as a result of approvals associated
with the JC Penny and Rose Bowl projects. Between Perimeter Road and Tantau Avenue,
the Main Street Project has been approved to construct one lane plus angled parking in the
eastbound direction, while the westbound direction will remain three lanes. Additionally,
wWith the Main Street new development projects, two additional a new traffic lights will
be added : one at Finch Avenue (Main Street) and the other at the new entrance to the Main
Street garage between Finch and Tantau Avenues. Parallel on-street parking is currently
under construction approved along the frontage of the Rose Bowl Project (currently under
construction) and the JC Penney parking garage between Wolfe Road and Perimeter Road.
Angled parking has also been approved along the frontage of the Main Street project
between Perimeter Road and Tantau Avenue on the south side of Vallco Parkway.
However, no on-street parking exists along the north side of Vallco Parkway between
Tantau Avenue and Perimeter Road.
Page 359 of the Draft EIR is modified as follows:
Near the project site, bicycle lanes (Class II) are provided on Pruneridge Avenue, Homestead
Road, Wolfe Road, Tantau Avenue, Vallco Parkway, and Stevens Creek Boulevard. There is a
discontinuity in the Class II facility along Wolfe Road at the I-280 overcrossing. A Class III
bike route exists on Tantau Avenue south of Stevens Creek Boulevard to Barnhart Avenue.
There is a discontinuity in the Miller Avenue bike lane between Stevens Creek Boulevard and
Calle De Barcelona. Additionally, bicycle facilities do not exist on Stevens Creek Boulevard
east of Cronin Drive. Furthermore, the bike lanes on Homestead Road are shared with parking
lanes at the following locations: 1) westbound between Nightingale Avenue and Nighthawk
Terrace and 2) westbound from the intersection with Tantau Avenue for approximately 350
feet. At these locations, parking is prohibited Monday through Friday from 8:00 a.m. to 5:00
p.m., during which time the lanes are used for bikes and right-turn vehicles. The remainder of
the time the lanes primarily function as parking lanes, although bicyclists can continue to use
them when cars are not parked in them.
Figure V.I-3 on page 361 of the Draft EIR is updated as shown on the following page.
Homestead Rd
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LEGEND
City of Cupertino
Project Site
Existing Bicycle Facilities
Class I Bike Path
Class II Bike Lane
Class III Bike Route
Planned Bicycle Facitlities
Class II Bike Lane J
not to scale Apple Campus 2 Project EIR
Existing and Proposed Bicycle FacilitiesSOURCE: FEHR & PEERS, AUGUST 2013.
I:\COC1101 Apple Campus 2\RTC\Figures\Fig_VI3 [Revised].ai (8/15/2013)
FIGURE V.I-3
[Revised]
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 152
Page 368 of the Draft EIR is revised as follows:
Most commuting bicyclists travel at a rate of about nine to 10 miles per hour, meaning the
Lawrence, Sunnyvale, and Santa Clara Caltrain stations are located about an 18, 23, and 28-
minute bicycle ride away from Apple Campus 2, respectively. Only the Lawrence Caltrain
station has continuous bicycle infrastructure that connects it to Apple Campus 2 in the form of
Class II lanes along Wolfe Road (on all segments except between old San Francisco Road and
Fremont Avenue), Reed Avenue, and Aster Avenue.
Page 394 of the Draft EIR is revised as follows:
Impact TRANS-1: Under Existing plus Project Conditions, completion of the proposed
project would cause intersection #21 Wolfe Road/I-280 Northbound Ramps to operate at
an unacceptable level (change from LOS B to LOS E) during the AM peak hour based on
City of Cupertino LOS standards. (S)
Mitigation Measure TRANS-1: As part of the project, the project sponsor shallwould
construct an additional westbound lane at intersection #21 Wolfe Road/I-280 Northbound
Ramps to provide for dual left-turn and dual right-turn lanes. With the additional lane, the
intersection would operate at acceptable LOS B (17.1 seconds) during the AM peak hour.
However, the off-ramp intersection is under Caltrans jurisdiction. Therefore, neither the
project sponsor nor the City of Cupertino can ensure the implementation of the proposed
mitigation measure; thus the impact is considered significant and unavoidable. (SU)
Pages 396 through 398 of the Draft EIR, including the addition of Table V.I-10 (Existing Plus Project
Freeway Levels of Service), are revised as follows. The changes to Table V.I-10 are not shown using
underline and strikeout text to enhance readability.
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
Mixed-Flow Lanes
SR 17 - Summit Road
to Bear Creek Road
NB AM
PM 4400 88
24
F
C
29
11
89
24
F
C
0.66%
0.25%
SB AM
PM 4400 19
45
C
D
5
10
19
45
C
D
0.11%
0.23%
SR 17 - Bear Creek
Road to Saratoga-Los
Gatos Road
NB AM
PM 4400 92
20
F
C
39
15
93
20
F
C
0.89%
0.34%
SB AM
PM 4400 17
36
B
D
7
15
17
36
B
D
0.16%
0.34%
SR 17 - Saratoga-Los
Gatos Road to Lark
Avenue
NB AM
PM 4400 54
28
E
D
110
30
56
28
E
D
2.50%
0.68%
SB AM
PM 4400 29
70
D
F
13
40
29
71
D
F
0.30%
0.91%
SR 17 - Lark Avenue
to SR 85
NB AM
PM 4400 35
23
D
C
147
40
36
23
D
C
3.34%
0.91%
SB AM
PM 4400 14
50
B
E
17
100
14
51
B
E
0.39%
2.27%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 153
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 17 - SR 85 to San
Tomas Expressway/
Camden Avenue
NB AM
PM 6900 53
19
E
C
20
8
53
19
E
C
0.29%
0.12%
SB AM
PM 6900 13
21
B
C
3
20
13
21
B
C
0.04%
0.29%
SR 17 - San Tomas
Expressway/Camden
Avenue to Hamilton
Avenue
NB AM
PM 6900 72
20
F
C
39
16
73
20
F
C
0.57%
0.23%
SB AM
PM 7820 18
27
B
D
6
39
18
27
B
D
0.08%
0.50%
SR 17 - Hamilton
Avenue to I-280
NB AM
PM 7820 71
36
F
D
77
31
64
32
F
D
0.98%
0.40%
SB AM
PM 6900 26
41
C
D
12
77
26
42
C
D
0.17%
1.12%
SR 85 - SR 87 to
Almaden
Expressway
NB AM
PM 4600 119
25
F
C
23
6
121
25
F
C
0.50%
0.13%
SB AM
PM 4600 22
27
C
D
3
19
22
27
C
D
0.07%
0.41%
SR 85 - Almaden
Expressway to
Camden Avenue
NB AM
PM 4600 85
36
F
D
45
12
86
36
F
D
0.98%
0.26%
SB AM
PM 4600 24
41
C
D
5
37
24
41
C
D
0.11%
0.80%
SR 85 - Camden
Avenue to Union
Avenue
NB AM
PM 4600 70
27
F
D
60
16
71
27
F
D
1.30%
0.35%
SB AM
PM 4600 31
52
D
E
7
48
31
53
D
E
0.15%
1.04%
SR 85 - Union
Avenue to S. Bascom
Avenue
NB AM
PM 4600 60
27
F
D
81
21
61
27
F
D
1.76%
0.46%
SB AM
PM 4600 20
81
C
F
10
65
20
83
C
F
0.22%
1.41%
SR 85 - S. Bascom
Avenue to SR 17
NB AM
PM 4600 105
14
F
B
108
28
109
14
F
B
2.35%
0.61%
SB AM
PM 4600 16
68
B
F
12
86
16
70
B
F
0.26%
1.87%
SR 85 - SR 17 to
Winchester Blvd
NB AM
PM 4600 85
18
F
B
216
55
91
18
F
B
4.70%
1.20%
SB AM
PM 4600 14
27
B
D
24
171
14
28
B
D
0.52%
3.72%
SR 85 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 4600 69
27
F
D
240
62
74
27
F
D
5.22%
1.35%
SB AM
PM 4600 30
54
D
E
29
190
30
57
D
E
0.63%
4.13%
SR 85 - Saratoga
Avenue to Saratoga-
Sunnyvale Road
NB AM
PM 4600 32
21
D
C
48
12
32
21
D
C
1.04%
0.26%
SB AM
PM 4600 23
65
C
F
5
38
23
66
C
F
0.11%
0.83%
SR 85 - Saratoga-
Sunnyvale Road to
Stevens Creek Blvd
NB AM
PM 5290 54
21
E
C
0
0
47
18
E
B
0.00%
0.00%
SB AM
PM 4600 19
94
C
F
0
0
19
94
C
F
0.00%
0.00%
SR 85 - Stevens
Creek Blvd to I-280
NB AM
PM 4600 109
19
F
C
28
7
110
19
F
C
0.61%
0.15%
SB AM
PM 6900 15
85
B
F
3
22
12
68
B
F
0.04%
0.32%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 154
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 85 - I-280 to W.
Homestead Road
NB AM
PM 4600 94
15
F
B
31
223
114
20
F
C
0.67%
4.85%
SB AM
PM 4600 14
25
B
C
282
72
16
26
B
C
6.13%
1.57%
SR 85 - W.
Homestead Road to
W. Fremont Avenue
NB AM
PM 4600 89
26
F
C
26
202
90
28
F
D
0.57%
4.39%
SB AM
PM 4600 25
53
C
E
240
61
27
54
D
E
5.22%
1.33%
SR 85 - W. Fremont
Avenue to El Camino
Real
NB AM
PM 4600 65
28
F
D
20
143
65
29
F
D
0.43%
3.11%
SB AM
PM 4600 25
72
C
F
186
45
26
73
C
F
4.04%
0.98%
SR 85 - El Camino
Real to SR 237
NB AM
PM 4600 52
28
E
D
12
88
52
29
E
D
0.26%
1.91%
SB AM
PM 4600 25
106
C
F
111
27
32
134
D
F
2.41%
0.59%
SR 85 - SR 237 to
Central Expressway
NB AM
PM 4600 26
20
C
C
6
44
26
20
C
C
0.13%
0.96%
SB AM
PM 4600 12
90
B
F
54
14
12
90
B
F
1.17%
0.30%
SR 85 - Central
Expressway to US
101
NB AM
PM 4600 36
14
D
B
6
42
36
14
D
B
0.13%
0.91%
SB AM
PM 4600 16
28
B
D
57
14
16
28
B
D
1.24%
0.30%
I-280 - US 101 to
McLaughlin Avenue
NB AM
PM 9200 95
21
F
C
88
31
96
21
F
C
0.96%
0.34%
SB AM
PM 9200 18
31
B
D
7
47
18
31
B
D
0.08%
0.51%
I-280 - McLaughlin
Avenue to 10th
Street
NB AM
PM 9200 75
34
F
D
117
39
76
34
F
D
1.27%
0.42%
SB AM
PM 9200 22
52
C
E
14
94
22
53
C
E
0.15%
1.02%
I-280 - 10th Street to
SR 87
NB AM
PM 9200 76
29
F
D
130
43
78
29
F
D
1.41%
0.47%
SB AM
PM 9200 20
66
C
F
16
104
20
67
C
F
0.17%
1.13%
I-280 - SR 87 to Bird
Avenue
NB AM
PM 9200 88
72
F
F
260
85
92
73
F
F
2.83%
0.92%
SB AM
PM 9200 19
67
C
F
32
207
19
69
C
F
0.35%
2.25%
I-280 - Bird Avenue
to Meridian Avenue
NB AM
PM 9200 88
44
F
D
289
94
92
44
F
D
3.14%
1.02%
SB AM
PM 9200 30
60
D
F
35
230
30
62
D
F
0.38%
2.50%
I-280 - Meridian
Avenue to I-880
NB AM
PM 8510 113
25
F
C
327
116
112
23
F
C
3.84%
1.36%
SB AM
PM 9200 25
85
C
F
40
260
19
67
C
F
0.43%
2.83%
I-280 - I-880 to
Winchester Blvd
NB AM
PM 6900 84
34
F
D
654
212
96
35
F
D
9.48%
3.07%
SB AM
PM 6900 23
103
C
F
80
520
23
116
C
F
1.16%
7.54%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 155
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-280 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 6900 76
34
F
D
728
247
87
35
F
D
10.55%
3.58%
SB AM
PM 6900 36
51
D
E
94
578
37
56
D
E
1.36%
8.38%
I-280 - Saratoga
Avenue to Lawrence
Expressway
NB AM
PM 6900 67
29
F
D
785
225
76
30
F
D
11.38%
3.26%
SB AM
PM 6900 28
77
D
F
100
623
29
86
D
F
1.45%
9.03%
I-280 - Lawrence
Expressway to Wolfe
Road
NB AM
PM 6900 62
32
F
D
382
106
66
33
F
D
5.54%
1.54%
SB AM
PM 6900 25
63
C
F
67
411
25
67
C
F
0.97%
5.96%
I-280 - Wolfe Road to
De Anza Blvd
NB AM
PM 6900 57
31
E
D
135
705
58
35
E
D
1.96%
10.22%
SB AM
PM 6900 29
97
D
F
850
269
33
103
D
F
12.32%
3.90%
I-280 - De Anza Blvd
to SR 85
NB AM
PM 6900 57
29
E
D
136
672
58
32
E
D
1.97%
9.74%
SB AM
PM 6900 24
81
C
F
831
245
28
85
D
F
12.04%
3.55%
I-280 - SR 85 to
Foothill Expressway
NB AM
PM 6900 62
24
F
C
107
439
63
26
F
C
1.55%
6.36%
SB AM
PM 6900 26
70
C
F
534
178
29
72
D
F
7.74%
2.58%
I-280 - Foothill
Expressway to
Magdalena Avenue
NB AM
PM 6900 41
23
D
C
86
368
42
25
D
C
1.25%
5.33%
SB AM
PM 6900 30
51
D
E
436
146
32
52
D
E
6.32%
2.12%
I-280 - Magdalena
Avenue to El Monte
Road
NB AM
PM 8050 36
22
D
C
81
326
42
27
D
D
1.01%
4.05%
SB AM
PM 9200 27
70
D
F
402
134
29
71
D
F
4.37%
1.46%
I-280 - El Monte
Road to La Barranca
Road
NB AM
PM 9200 31
21
D
C
65
261
31
22
D
C
0.71%
2.84%
SB AM
PM 9200 20
63
C
F
322
87
21
64
C
F
3.50%
0.95%
I-280 - La Barranca
Road to Page Mill
Road
NB AM
PM 8970 29
24
D
C
65
261
30
26
D
C
0.72%
2.91%
SB AM
PM 9200 20
58
C
E
322
87
21
59
C
F
3.50%
0.95%
I-280 - Page Mill
Road to Alpine Road
NB AM
PM 9200 23
45
C
D
39
157
23
46
C
D
0.42%
1.71%
SB AM
PM 9200 24
23
C
C
193
52
25
23
C
C
2.10%
0.57%
I-880 - I-280 to
Stevens Creek
Boulevard
NB AM
PM 6900 84
18
F
B
35
229
85
19
F
C
0.51%
3.32%
SB AM
PM 6900 20
29
C
D
308
93
22
30
C
D
4.46%
1.35%
I-880 - Stevens Creek
Boulevard to N.
Bascom Avenue
NB AM
PM 6900 81
25
F
C
32
206
82
26
F
C
0.46%
2.99%
SB AM
PM 6900 61
52
F
E
277
84
64
53
F
E
4.01%
1.22%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 156
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
I-880 - N. Bascom
Avenue to The
Alameda
NB AM
PM 6900 76
29
F
D
24
155
76
30
F
D
0.35%
2.25%
SB AM
PM 6900 26
56
C
E
208
63
27
57
D
E
3.01%
0.91%
I-880 - The Alameda
to Coleman Avenue
NB AM
PM 6900 84
29
F
D
18
116
84
30
F
D
0.26%
1.68%
SB AM
PM 6900 31
74
D
F
156
47
32
75
D
F
2.26%
0.68%
I-880 - Coleman
Avenue to SR 87
NB AM
PM 6900 54
33
E
D
14
87
54
33
E
D
0.20%
1.26%
SB AM
PM 6900 31
64
D
F
117
35
32
64
D
F
1.70%
0.51%
I-880 - SR 87 to N.
1st Street
NB AM
PM 6900 55
40
E
D
14
87
55
41
E
D
0.20%
1.26%
SB AM
PM 6900 35
73
D
F
117
35
36
74
D
F
1.70%
0.51%
I-880 - N. 1st Street
to US 101
NB AM
PM 6900 72
44
F
D
13
78
72
45
F
D
0.19%
1.13%
SB AM
PM 6900 25
85
C
F
105
32
26
86
C
F
1.52%
0.46%
I-880 - US 101 to E.
Brokaw Road
EB AM
PM 6900 55
60
E
F
10
62
55
61
E
F
0.14%
0.90%
WB AM
PM 6900 24
67
C
F
84
26
24
67
C
F
1.22%
0.38%
I-880 - E. Brokaw
Road to Montague
Expwy
EB AM
PM 6900 30
36
D
D
6
37
30
36
D
D
0.09%
0.54%
WB AM
PM 6900 30
79
D
F
50
16
30
79
D
F
0.72%
0.23%
I-880 - Montague
Expwy to Great Mall
Pkwy
EB AM
PM 6900 27
65
D
F
3
19
27
65
D
F
0.04%
0.28%
WB AM
PM 6900 41
75
D
F
25
8
41
75
D
F
0.36%
0.12%
SR 237 - SR 85 to
Central Expressway
EB AM
PM 4400 82
23
F
C
7
50
82
23
F
C
0.16%
1.14%
WB AM
PM 4400 24
56
C
E
63
16
24
56
C
E
1.43%
0.36%
SR 237 - Central
Expressway to Maude
Avenue
EB AM
PM 4400 31
13
D
B
4
25
31
13
D
B
0.09%
0.57%
WB AM
PM 4400 13
62
B
F
32
8
13
62
B
F
0.73%
0.18%
SR 237 - Maude
Avenue to US 101
EB AM
PM 4400 60
25
F
C
2
13
60
25
F
C
0.05%
0.30%
WB AM
PM 4400 31
60
D
F
24
6
31
60
D
F
0.55%
0.14%
High-Occupancy Vehicle (HOV) Lanes
SR 85 - SR 87 to
Almaden Expressway
NB AM
PM 1650 61
12
F
B
4
1
61
12
F
B
0.24%
0.06%
SB AM
PM 1650 4
20
A
C
0
3
4
20
A
C
0.00%
0.18%
SR 85 - Almaden
Expressway to
Camden Avenue
NB AM
PM 1650 45
9
D
A
8
2
45
9
D
A
0.48%
0.12%
SB AM
PM 1650 10
24
A
C
1
6
10
24
A
C
0.06%
0.36%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
APPLE CAMPUS 2 PROJECT EIRIV. TEXT REVISIONS
P:\COC1101 Apple 2 Campus\PRODUCTS\RTC\Screen\4-TextRevisions.doc (09/16/13) FINAL 157
Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 85 - Camden
Avenue to Union
Avenue
NB AM
PM 1650 42
10
D
A
11
3
42
10
D
A
0.67%
0.18%
SB AM
PM 1650 8
30
A
D
1
9
8
30
A
D
0.06%
0.55%
SR 85 - Union
Avenue to S. Bascom
Avenue
NB AM
PM 1650 37
11
D
A
14
4
37
11
D
A
0.85%
0.24%
SB AM
PM 1650 5
37
A
D
1
11
5
37
A
D
0.06%
0.67%
SR 85 - S. Bascom
Avenue to SR 17
NB AM
PM 1650 77
18
F
B
19
5
78
18
F
B
1.15%
0.30%
SB AM
PM 1650 14
25
B
C
2
15
14
25
B
C
0.12%
0.91%
SR 85 - SR 17 to
Winchester Blvd
NB AM
PM 1650 90
8
F
A
38
10
92
8
F
A
2.30%
0.61%
SB AM
PM 1650 6
24
A
C
4
30
6
24
A
C
0.24%
1.82%
SR 85 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 1650 46
8
D
A
42
10
47
8
E
A
2.55%
0.61%
SB AM
PM 1650 4
29
A
D
2
33
4
29
A
D
0.12%
2.00%
SR 85 - Saratoga
Avenue to Saratoga-
Sunnyvale Road
NB AM
PM 1650 31
7
D
A
8
2
31
7
D
A
0.48%
0.12%
SB AM
PM 1650 6
26
A
C
1
7
6
26
A
C
0.06%
0.42%
SR 85 - Saratoga-
Sunnyvale Road to
Stevens Creek Blvd
NB AM
PM 1650 21
8
C
A
0
0
21
8
C
A
0.00%
0.00%
SB AM
PM 1650 6
31
A
D
0
0
6
31
A
D
0.00%
0.00%
SR 85 - Stevens
Creek Blvd to I-280
NB AM
PM 1650 21
8
C
A
0
0
21
8
C
A
0.00%
0.00%
SB AM
PM 1650 9
29
A
D
0
0
9
29
A
D
0.00%
0.00%
SR 85 - I-280 to W.
Homestead Road
NB AM
PM 1650 60
9
F
A
0
0
60
9
F
A
0.00%
0.00%
SB AM
PM 1650 7
29
A
D
0
0
7
29
A
D
0.00%
0.00%
SR 85 - W.
Homestead Road to
W. Fremont Avenue
NB AM
PM 1650 41
5
D
A
5
21
41
5
D
A
0.30%
1.27%
SB AM
PM 1650 9
21
A
C
42
11
10
21
A
C
2.55%
0.67%
SR 85 - W. Fremont
Avenue to El Camino
Real
NB AM
PM 1650 47
9
E
A
3
24
47
9
E
A
0.18%
1.45%
SB AM
PM 1650 7
25
A
C
26
8
7
25
A
C
1.58%
0.48%
SR 85 - El Camino
Real to SR 237
NB AM
PM 1650 39
7
D
A
2
12
39
7
D
A
0.12%
0.73%
SB AM
PM 1650 9
29
A
D
16
5
9
29
A
D
0.97%
0.30%
SR 85 - SR 237 to
Central Expressway
NB AM
PM 1650 24
5
C
A
1
6
24
5
C
A
0.06%
0.36%
SB AM
PM 1650 7
18
A
B
10
2
7
18
A
B
0.61%
0.12%
LSA ASSOCIATES, INC.
SEPTEMBER 2013
RESPONSE TO COMMENTS DOCUMENT
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Table V.I-10: Existing Plus Project Freeway Segment Levels of Service
Freeway Segment Direction1
Peak
Hour2
Capacity
(vph)3
Existing ConditionsExisting plus Project Conditions
Density4 LOS5 Trips6 Density LOS
%
Impact7
SR 85 - Central
Expressway to US
101
NB AM
PM 1650 15
7
B
A
1
8
15
7
B
A
0.06%
0.48%
SB AM
PM 1650 4
7
A
A
7
2
4
7
A
A
0.42%
0.12%
I-280 - Meridian
Avenue to I-880
NB AM
PM 1650 32
6
D
A
58
9
33
6
D
A
3.52%
0.55%
SB AM
PM 1650 13
82
B
F
7
46
13
84
B
F
0.42%
2.79%
I-280 - I-880 to
Winchester Blvd
NB AM
PM 1650 50
18
E
B
116
37
53
19
E
C
7.03%
2.24%
SB AM
PM 1650 12
92
B
F
14
92
12
97
B
F
0.85%
5.58%
I-280 - Winchester
Blvd to Saratoga
Avenue
NB AM
PM 1650 43
11
D
A
128
30
46
11
D
A
7.76%
1.82%
SB AM
PM 1650 10
29
A
D
10
102
10
30
A
D
0.61%
6.18%
I-280 - Saratoga
Avenue to Lawrence
Expressway
NB AM
PM 1650 58
7
E
A
139
20
62
7
F
A
8.42%
1.21%
SB AM
PM 1650 9
32
A
D
11
110
9
34
A
D
0.67%
6.67%
I-280 - Lawrence
Expressway to Wolfe
Road
NB AM
PM 1650 56
10
E
A
0
0
56
10
E
A
0.00%
0.00%
SB AM
PM 1650 12
39
B
D
0
0
12
39
B
D
0.00%
0.00%
I-280 - Wolfe Road to
De Anza Blvd
NB AM
PM 1650 50
9
E
A
0
0
50
9
E
A
0.00%
0.00%
SB AM
PM 1650 18
33
B
D
0
0
18
33
B
D
0.00%
0.00%
I-280 - De Anza Blvd
to SR 85
NB AM
PM 1650 32
10
D
A
24
83
32
11
D
A
1.45%
5.03%
SB AM
PM 1650 9
25
A
C
106
43
11
26
A
C
6.42%
2.61%
I-280 - SR 85 to
Foothill Expressway
NB AM
PM 1650 42
11
D
A
19
71
42
12
D
B
1.15%
4.30%
SB AM
PM 1650 15
18
B
B
94
31
16
18
B
B
5.70%
1.88%
I-280 - Foothill
Expressway to
Magdalena Avenue
NB AM
PM 1650 40
7
D
A
15
40
40
8
D
A
0.91%
2.42%
SB AM
PM 1650 13
13
B
B
66
21
14
13
B
B
4.00%
1.27%
Notes:
Bold font indicates unacceptable operations based on VTA’s LOS E Standard. Bold and highlighted indicates significant
impacts. 1 NB = Northbound, SB = Southbound. 2 AM = morning peak hour, PM = afternoon peak hour. 3 vph = vehicles per hour 4 Measured in passenger cars per mile per lane. 5 LOS = level of service. 6 Project trips added to individual freeway segments 7 Percent Contribution determined by dividing the number of project trips by the freeway segment’s capacity.
Source: 2011 Monitoring and Conformance Report, VTA, May 2012.
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Impact TRANS-22: Completion of the proposed project would add substantial amounts of
traffic to the following ten mixed flow segments and one HOV freeway segments
operating at LOS F:
I-280, Southbound, El Monte Road to Magdalena Avenue
I-280, Northbound, SR 85 to Foothill Expressway
I-280, Southbound, Foothill Expressway to SR 85
I-280, Southbound, SR 85 to De Anza Boulevard
I-280, Southbound, De Anza Boulevard to Wolfe Road
I-280, Northbound, Lawrence Expressway to Wolfe Road
I-280, Southbound, Wolfe Road to Lawrence Expressway/Stevens Creek Boulevard
I-280, Northbound, Saratoga Avenue to Lawrence Expressway/Stevens Creek
Boulevard
I-280, Southbound, Lawrence Expressway/Stevens Creek Boulevard to Saratoga
Avenue
I-280, Northbound, Winchester Boulevard to Saratoga Avenue
I-280, Northbound, Winchester Boulevard to I-880
I-280, Southbound, Winchester Boulevard to I-880
I-280, Northbound, I-880 to Meridian Avenue
I-280, Southbound, I-880 to Meridian Avenue
I-280, Northbound, Meridian Avenue to Bird Avenue
I-280, Southbound, Meridian Avenue to Bird Avenue
I-280, Northbound, Bird Avenue to SR 87
I-280, Southbound, Bird Avenue to SR 87
I-280, Northbound, SR 87 to 10th Street
I-280, Southbound, SR 87 to 10th Street
I-280, Northbound, 10th Street to McLaughlin Avenue
I-280, HOV, Northbound, Saratoga Avenue to Lawrence Expressway
I-280, HOV, Southbound, Winchester Boulevard to I-880
I-280, HOV, Southbound, I-880 to Meridian Avenue
SR 85, Northbound, Winchester Boulevard to SR 17 + HOVto Camden Avenue
SR 85, Northbound, Saratoga Avenue to Winchester Boulevard
SR 85, Southbound, SR 17 to Bascom Avenue
SR 85, Northbound, SR 17 to Bascom Avenue + HOV
SR 85, Southbound, Bascom Avenue to Union Avenue
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SR 85, Northbound, Bascom Avenue to Union Avenue
SR 85, Northbound, Union Avenue to Camden Avenue
I-880, Southbound, Bascom Avenue to Stevens Creek Boulevard
These freeway segments would be impacted under the Existing Plus Project Conditions
based on CMP guidelines. (S)
Mitigation Measure TRANS-22: The project sponsor shall pay a $536,0001,292,215 fair
share contribution towards two planned transportation projects identified in VTA’s
Valley Transportation Plan 2035 (VTP 2035)2 that would improve traffic operations of
the impacted freeway segments and provide added transportation capacity on parallel
facilities: (1) SR 85 Express Lane project (converting the existing HOV lane to a toll lane
to allow single occupant vehicles to drive in the HOV lane for a fee) between Mountain
View and San Jose; (2) eliminating the existing bottleneck on southbound I-280 between
El Monte Road and Magdalena Avenue; and (23) either the Bus Rapid Transit (BRT)
stations proposed within Cupertino on Stevens Creek Boulevard at Wolfe Road and De
Anza Boulevard, or an alternative improvement or study towards the improvement of the
impacted I-280 corridor or a parallel corridor that would provide capacity. The fair share
contribution amount was calculated in consultation with VTA staff based on the project’s
contribution to project growth on the impacted freeway segment.
It is unlikely that the Express Lane or BRT project would be implemented prior to project
completion and that these improvements would reduce the impact to a less-than-
significant level. In addition, the City has no control over the implementation of these
mitigation measures; therefore the impact to the freeway segments would remain
significant and unavoidable. (SU)
Page 405 of the Draft EIR is revised as follows:
Impact TRANS-9: Under Background plus Project Conditions, completion of the
proposed project would exacerbate unacceptable operations of intersection #36 Stevens
Creek Boulevard/Calvert Drive/I-280 Ramps (west) during the PM peak hour based on
CMP guidelines. (S)
Mitigation Measure TRANS-9a: At intersection #36 Stevens Creek Boulevard/Calvert
Drive/I-280 Ramps (west), the project sponsor shall implement Mitigation Measure
TRANS-3 (add exclusive eastbound right-turn lane), which would improve intersection
operations to 112.2 seconds (LOS F). However, the Stevens Creek Boulevard/Calvert
Drive/I-280 Ramps (west) intersection would continue to operate unacceptably.
2 The Valley Transportation Plan is a long-range vision for transportation in Santa Clara County. The
VTA is responsible for preparing and updating the VTP. The VTP 2035 identifies the programs,
projects, and policies VTA would like to pursue over the lifetime of the plan. It connects projects with
anticipated funds and lays out a framework for the development and maintenance of the
transportation system over the next 25 years.
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Providing a second channelized free right-turn lane with a third eastbound receiving lane
on the connector link between Stevens Creek Boulevard and Lawrence Expressway, for a
distance of approximately 1,250 feet, including a pedestrian-activated traffic signal to
allow for protected pedestrian crossings to the pedestrian refuge island, would improve
intersection operations to LOS E D+ with 63.0 38.6 seconds of delay. However, there are
right-of-way constraints that render a second right-turn lane infeasible, since there would
be less than 7 feet of right-of-way available between the fence and curb on the south side
of Steven Creek after implementation of Mitigation Measure TRANS-3. At minimum, 11
feet of right-of-way are needed to accommodate a second right-turn lane.
This improvement would reduce the impact to a less-than-significant level. However, this
intersection is a CMP intersection and is located within the City of Santa Clara. It is also
under Caltrans jurisdiction. The project sponsor would be required to coordinate with the
City of Santa Clara and Caltrans to construct the identified physical improvement at the
Stevens Creek Boulevard/Calvert Drive/I-280 Ramp (west) intersection. Since this
intersection is outside of the City of Cupertino’s jurisdiction, the City cannot guarantee
that the improvement would be constructed. For this reason the impact would remain
significant and unavoidable.
Mitigation Measure TRANS-9b: The project sponsor shall expand the TDM program to
reduce the severity of the impact. Increasing the TDM participation and associated
alternative mode share from 28 percent to 34 percent would improve operations to LOS F
(142.8 seconds) without implementation of TRANS-3; however it would not reduce the
impact to a less-than-significant level. A robust monitoring program would be required to
ensure that this TDM program mitigation measure is implemented and that the required
trip reduction is achieved. Details of the TDM program are discussed under the
Evaluation of TDM Program Expansion section. (SU)
Pages 411 and 412 of the Draft EIR are revised as follows:
Impact TRANS-13: Under Cumulative plus Project Conditions, completion of the
proposed project would cause intersection #8 De Anza Boulevard/Stevens Creek Boulevard
to operate at an unacceptable level (change from LOS E+ to LOS E) during the PM peak
hour based on City of Cupertino LOS impact thresholds. (S)
Mitigation Measure TRANS-13a: At intersection #8 De Anza Boulevard/Stevens Creek
Boulevard, the provision of an exclusive southbound right-turn lane (for a total of two left-
turn lanes, four through lanes, and one right-turn lane) and adjusting the signal timings to
accommodate the added turn lane would improve intersection operations to acceptable
levels at LOS E+ with 58.9 seconds of average delay. However, this improvement is
physically not feasible, since the widening of the roadway to accommodate the south-
bound right-turn lane would impact an underground garage belonging to the office
development on the northwest corner of the De Anza Boulevard/Stevens Creek Boulevard
intersection; therefore the impact at the De Anza Boulevard/Stevens Creek Boulevard
intersection is considered significant and unavoidable.
Mitigation Measure TRANS-13b: The project sponsor shall expand the TDM program to
reduce the severity of the impact. Increasing the TDM participation and associated
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alternative mode share from 28 percent to 34 percent would improve operations to LOS E
(62.1 seconds); however the increase in TDM participation would not reduce the impact
to a less-than-significant level.
Mitigation Measure TRANS-13c: The project sponsor shall provide a $50,000 fair-share
contribution towards the implementation of an adaptive traffic signal system along De
Anza Boulevard between Homestead Road and Rainbow Drive. Implementation of an
adaptive traffic signal system would improve intersection operations; however it would
not reduce the impact to a less-than-significant level. (SU)
Page 413 of the Draft EIR is revised as follows:
Impact TRANS-19: Under Cumulative plus Project Conditions, completion of the
proposed project would exacerbate unacceptable operations of intersection #36 Stevens
Creek Boulevard/Calvert Drive/I-280 Ramps (west) during the PM peak hour based on
CMP guidelines. (S)
Mitigation Measure TRANS-19a: Potential physical improvements as mitigation
measures for intersection #36 Stevens Creek Boulevard/Calvert Drive/I-280 Ramps are
discussed under Mitigation Measure TRANS-9. (add two exclusive eastbound right-turn
lanes). However, there are right-of-way constraints that render this mitigation measure
infeasible. Additionally, this intersection is within the City of Santa Clara, and the City
has no control over the implementation of the mitigation measure; therefore the impact is
considered significant and unavoidable. The project sponsor shall implement Mitigation
Measure TRANS-9a (add free eastbound right-turn lane), which would improve
intersection operations to LOS D (41.5 seconds). This improvement would reduce the
impact to a less-than-significant level. However, because this intersection is under City of
Santa Clara and Caltrans jurisdiction, the City cannot guarantee that the improvement
would be constructed. For this reason, the impact would remain significant and
unavoidable.
Mitigation Measure TRANS-19b: The project sponsor shall expand the TDM program to
reduce the severity of the impact. Increasing the TDM participation and associated
alternative mode share from 28 percent to 34 percent would improve operations to LOS F
(145.8 seconds) without implementation of mitigation measure TRANS-9; however the
increase in TDM participation would not reduce the impact to a less-than-significant
level. (SU)
Page 418 of the Draft EIR is revised as follows:
Impact TRANS-23: Based on City of Cupertino standards, the design of the project with
three left-turn lanes on the Wolfe Road driveway approach would cause a substantial
increase in conflicts due to vehicles weaving on Wolfe Road between the driveway and the
I-280 ramps in order to merge and align into the correct lanes to enter the freeway upon
exiting the campus. (S)
Implementation of one of the following two mitigation measures would reduce this
impact to a less-than-significant level:
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Mitigation Measure TRANS-23: At the main project driveway on Wolfe Road, the
project sponsor shall reduce the number of left turn lanes from three to two. This would
reduce the weaving on southbound Wolfe Road between the driveway and the I-280
northbound on-ramp since there would be, at most, a one-lane lane change in order for
drivers to align themselves to the correct lane. (LTS)
OR
Mitigation Measure TRANS-23 (Alternate): The project sponsor shall be permitted to
construct three left-turn exit lanes from the project site to Wolfe Road if all of the
following measures are implemented:
• Clear signage, including but not limited to overhead signs, shall be installed to
indicate the destination of each of the three exit lanes in order to discourage unsafe
lane changes.
• Each lane on Wolfe Road, between the driveway and Pruneridge Avenue, shall be
clearly marked by painted stripes, directional arrows, and destination legends to
indicate the destination of each lane and to indicate by double lines or other
appropriate markings that changing lanes is a violation of law.
• The project sponsor shall fund the following measures for a trial period of nine months
from issuance of the first certificate of occupancy for the Main Building and shall
install closed-circuit video cameras linked to the City’s Traffic Operations Center to
continuously record vehicle movements at the project driveway and along southbound
Wolfe Road. Trained personnel, who are independent from the project sponsor, shall
periodically review the video footage at the direction of the City, and provide a report
at the end of each month to the Public Works Department. This report shall document
any unsafe or illegal lane changes (violations) observed, noting accidents caused by
violations and noting whether, in the professional judgment of the independent
observer, the observed violations constitute a safety problem that should be addressed
and, if so, recommending measures to address them.
• If, at any time following the nine-month trial period implementation of the measures
listed above do not substantially prevent violations, in the professional opinion of the
independent observer and the City, the City shall determine whether additional
measures are required, or whether the number of lanes must be reduced to two exit
lanes. Monitoring shall continue until nine months following full occupancy of the
project.
• A penalty of $500 per violation during the PM 2-hour peak period per day shall be
paid by the project sponsor to the City. The number of violations shall be determined
by the independent observer based upon review of the video footage and extrapolated
to account for daily activity during the PM 2-hour peak period should daily video
footage not be reviewed.
• The project sponsor shall develop employee education materials, to the satisfaction of
the City, explaining the proper use of the driveway exit lanes without weaving among
lanes. (LTS)
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Page 420 of the Draft EIR is revised as follows:
Condition of Approval CA-TRANS-1: Apple shall extend the northbound right-turn pocket at
#28 Tantau Avenue/Pruneridge Avenue to the #29 Tantau Avenue/Project Access intersection
(approximately 600 feet) to provide for improved operations along the Tantau Avenue corridor.
Vallco Parkway Evaluation. With proposed development projects (JC Penney, Rose Bowl, and
Main Street), Vallco Parkway would be reconfigured to have two lanes in each direction
between Wolfe Road and Perimeter Road (currently under construction), and one eastbound
lane and three westbound lanes between Perimeter Road and Tantau Avenue. During the AM
and PM peak hours, the model shows that with one eastbound through lane there would be
excessive queuing in the eastbound direction during the peak hours. As a condition of approval
it is recommended that Vallco Parkway between Perimeter Road and Tantau Avenue be
reconfigured to have two lanes in each direction (ultimately providing for two through lanes in
each direction along the entire length of Vallco Parkway). With the added traffic volumes from
the proposed project and the provision of a second eastbound through lane, it is recommended
that a new signal be provided at the Main Street parking garage driveway between Finch Road
and Tantau Avenue to provide for controlled access at the parking garage. Testing of the model
with the two-lane configuration in both directions of travel showed that the westbound direction
would operate without excessive queuing, even though the travel lanes would be reduced from
three to two lanes.
Condition of Approval CA-TRANS 2: Apple shall reconfigure Vallco Parkway between
Perimeter Road and Tantau Avenue to two vehicle lanes and one bike lane in each direction,
plus diagonal parking on the south side, including any associated improvements such as, but not
limited to, median relocation. In addition, Apple shall design and install a traffic signal at the
Main Street Project garage entrance onto Vallco Parkway.
(Please note that subsequent references to Conditions of Approval in Section V.I,
Transportation and Circulation, would be renumbered accordingly.)
Evaluation of Freeway Ramps. The VISSIM simulation analysis was also conducted to evaluate
impacts of the project on the operations of I-280/Wolfe Road on and off-ramps. The addition of
project traffic would cause excessive queuing on the Wolfe Road/I-280 off-ramps that would extend
onto the freeway mainline.
Page 421 of the Draft EIR is revised as follows. This minor change is made to allow the City Council
to adopt the measure that would have the least impact on the operation of Cupertino Village.
Evaluation of Adjacent Driveway Conditions. The Cupertino Village has a driveway
on Wolfe Road that is directly north of/adjacent to the new project driveway intersection.
Vehicles exiting the driveway might try to maneuver across the three southbound through lanes
to access the left-turn lanes to turn into the project site or make a U-turn, resulting in hazardous
conditions for vehicles. Additionally, during the peak commute periods, the southbound traffic
volumes are high and may create queues that effectively block driveway access, which could
potentially lead to impatient drivers merging into traffic when there are insufficient gaps. This
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driveway should be restricted to right turns in only or closed due to its proximity to the new
signalized intersection.
Impact TRANS-27: The proposed location of the project driveway intersection on Wolfe
Road and the associated congestion would result in hazards for vehicles exiting the
southernmost Wolfe Road driveway to the Cupertino Village shopping center (City of
Cupertino and CEQA). (S)
Implementation of one of the following two mitigation measures would reduce this impact to a
less-than-significant level:
Mitigation Measure TRANS-27: The southernmost driveway to the Cupertino Village
shall should be closedor restricted to right-turns in only. With this mitigation the impact
would be less-than-significant. (LTS)
OR
Mitigation Measure TRANS-27 (Alternate): The southernmost driveway to the Cupertino
Village shall be restricted to right-turns in only. With this mitigation the impact would be
less-than-significant. (LTS)
Page 427 of the Draft EIR is revised as follows:
Impact TRANS-30: The added traffic on Wolfe Road and around the project site would
result in increased congestion and could induce transit demand and increase transit
ridership in the area, which currently has minimal transit stop amenities (VTA). (S)
Mitigation Measure TRANS-30: The project sponsor shall upgrade transit stops along
Wolfe Road between Stevens Creek Boulevard and Homestead Road, on Vallco Parkway
between Wolfe Road and Tantau Avenue, and on Tantau Avenue between Stevens Creek
Boulevard and Homestead Road, and on Homestead Road between Tantau Avenue and
Wolfe Road. (LTS)
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APPENDIX A
COMMENT LETTERS
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cont.
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LeƩ er
B3
cont.
15
LeƩ er
B3
cont.
15
cont.
LeƩ er
B3
cont.
15
cont.
LeƩ er
B3
cont.
15
cont.
LeƩ er
B3
cont.
16
LeƩ er
B3
cont.
16
cont.
LeƩ er
B3
cont.
16
cont.
LeƩ er
B3
cont.
16
cont.
LeƩ er
B3
cont.
16
cont.
LeƩ er
B3
cont.
17
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
17
cont.
LeƩ er
B3
cont.
18
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
18
cont.
LeƩ er
B3
cont.
19
LeƩ er
B3
cont.
19
cont.
LeƩ er
B3
cont.
20
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
20
cont.
LeƩ er
B3
cont.
21
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
21
cont.
LeƩ er
B3
cont.
22
LeƩ er
B3
cont.
22
cont.
LeƩ er
B3
cont.
23
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
23
cont.
LeƩ er
B3
cont.
24
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
24
cont.
LeƩ er
B3
cont.
25
LeƩ er
B3
cont.
25
cont.
LeƩ er
B3
cont.
25
cont.
LeƩ er
B3
cont.
25
cont.
LeƩ er
B3
cont.
25
cont.
LeƩ er
B3
cont.
26
LeƩ er
B3
cont.
26
cont.
LeƩ er
B3
cont.
26
cont.
LeƩ er
B3
cont.
26
cont.
LeƩ er
B3
cont.
LeƩ er
B4
1
LeƩ er
B4
cont.
2
LeƩ er
B5
1
LeƩ er
B6
1
LeƩ er
B7
1
LeƩ er
B7
cont.
2
LeƩ er
B8
1
LeƩ er
B9
1
LeƩ er
B10
1
LeƩ er
B11
1
LeƩ er
B12
1
1
cont.
LeƩ er
B12
cont.
LeƩ er
B13
1
LeƩ er
B13
cont.
2
LeƩ er
B14
1
1
cont.
LeƩ er
B14
cont.
LeƩ er
B15
1
LeƩ er
B15
cont.
2
LeƩ er
B16
1
LeƩ er
B17
1
LeƩ er
B18
1
LeƩ er
B18
cont.
2
LeƩ er
B19
1
LeƩ er
B20
1
LeƩ er
B21
1
LeƩ er
B22
1
LeƩ er
B22
cont.
2
3
3
cont.
4
5
LeƩ er
B22
cont.
6
6
cont.
7
8
LeƩ er
B22
cont.
9
10
10
cont.
11
12
14
15
16
LeƩ er
B22
cont.
13
LeƩ er
B23
1
LeƩ er
B23
cont.
1
cont.
2
3
4
LeƩ er
B23
cont.
5
4
cont.
LeƩ er
B23
cont.
LeƩ er
C1
1
LeƩ er
C2
1
LeƩ er
C2
cont.
1
cont.
LeƩ er
C3
1
LeƩ er
C3
cont.
2
LeƩ er
C4
1
2
3
4
5
LeƩ er
C5
1
2
3
4
7
6
5
LeƩ er
C6
1
1
LeƩ er
C7
LeƩ er
C8
1
2
3
4
5
6
LeƩ er
C9
1
LeƩ er
C10
1
LeƩ er
C11
1
2
LeƩ er
C11
cont.
2
cont.
3
4
LeƩ er
C11
cont.
4
cont.
5
6
7
LeƩ er
C12
1
LeƩ er
C13
1
2
3
LeƩ er
C14
1
LeƩ er
C15
1
2
3
LeƩ er
C16
1
LeƩ er
C17
1
LeƩ er
C18
1
2
LeƩ er
C19
1
1
LeƩ er
C20
LeƩ er
C21
1
LeƩ er
C21
cont.
2
3
4
LeƩ er
C22
1
2
LeƩ er
C23
1
LeƩ er
C24
1
LeƩ er
C25
1
LeƩ er
C26
1
LeƩ er
C27
1
2
LeƩ er
C28
1
2
3
4
LeƩ er
C29
1
LeƩ er
C30
1
LeƩ er
C31
1
LeƩ er
C32
1
LeƩ er
C33
1
LeƩ er
C34
1
LeƩ er
C35
1
2
3
4
5
6
7
8
LeƩ er
C36
1
LeƩ er
C37
1
LeƩ er
C38
1
2
3
4
5
6
LeƩ er
C38
cont.
7
8
9
10
11
12
13
LeƩ er
C39
1
2
3
4
6
5
LeƩ er
C40
1
2
3
4
5
LeƩ er
C40
cont.
5
cont.
6
7
LeƩ er
C41
1
LeƩ er
C42
1
2
3
LeƩ er
C42
cont.
4
LeƩ er
C42
cont.
4
cont.
LeƩ er
C43
1
2
4
5
3
LeƩ er
C44
1
2
3
4
5
6
7
LeƩ er
C44
cont.
7
cont.
8
9
10
11
12
LeƩ er
C45
1
2
4
5
3
6
LeƩ er
C46
1
2
3
LeƩ er
C47
1
2
3
4
5
6
7
LeƩ er
C48
1
1
2
LeƩ er
C49
LeƩ er
C50
1
2
LeƩ er
C51
1
LeƩ er
C52
1
2
3
4
5
6
LeƩ er
C53
1
2
3
LeƩ er
C54
1
2
3
LeƩ er
C55
1
2
3
LeƩ er
C56
1
LeƩ er
C57
1
LeƩ er
C58
1
2
LeƩ er
C59
1
LeƩ er
C60
1
LeƩ er
C61
1
LeƩ er
C62
1
LeƩ er
C63
1
LeƩ er
C64
1
2
3
4
5
LeƩ er
C65
1
2
LeƩ er
C65
cont.
3
4
5
6
7
LeƩ er
C66
1
2
3
4
5
6
7
8
LeƩ er
C67
1
LeƩ er
C68
1
LeƩ er
C69
2
1
LeƩ er
C70
1
LeƩ er
C71
1
LeƩ er
C72
1
LeƩ er
C73
1
2
3
LeƩ er
C74
1
LeƩ er
C75
1
2
3
4
LeƩ er
C76
1
1
LeƩ er
C77
2
LeƩ er
C78
1
1
LeƩ er
C79
LeƩ er
C80
1
1
LeƩ er
C81
LeƩ er
C82
1
1
LeƩ er
C83
LeƩ er
C84
1
1
LeƩ er
C85
2
LeƩ er
C86
1
LeƩ er
C87
1
2
LeƩ er
C88
1
LeƩ er
C89
1
LeƩ er
C90
1
LeƩ er
C91
1
LeƩ er
C92
1
LeƩ er
C93
1
2
LeƩ er
C94
1
LeƩ er
C95
1
LeƩ er
C96
1
LeƩ er
C97
1
LeƩ er
C98
1
LeƩ er
C99
1
2
3
LeƩ er
C100
1
LeƩ er
C101
1
LeƩ er
C102
1
2
3
LeƩ er
C103
1
LeƩ er
C104
1
LeƩ er
C105
1
LeƩ er
C106
1
2
2
cont.
3
LeƩ er
C106
cont.
4
5
6
7
LeƩ er
C106
cont.
7
cont.
8
LeƩ er
C106
cont.
8
cont.
LeƩ er
C106
cont.
8
cont.
LeƩ er
C106
cont.
9
LeƩ er
C107
1
LeƩ er
C108
1
2
3
4
5
LeƩ er
C109
1
2
3
4
LeƩ er
C109
cont.
5
LeƩ er
C109
cont.
5
cont.
5
cont.
LeƩ er
C109
cont.
5
cont.
LeƩ er
C109
cont.
5
cont.
LeƩ er
C109
cont.
5
cont.
LeƩ er
C109
cont.
LeƩ er
C110
1
2
3
4
5
6
LeƩ er
C110
cont.
6
cont.
7
8
9
LeƩ er
C110
cont.
9
cont.
10
LeƩ er
C111
1
2
3
4
5
6
LeƩ er
C112
1
LeƩ er
C113
1
LeƩ er
C114
1
2
3
LeƩ er
C115
1
LeƩ er
C116
1
LeƩ er
D1
1
1
LeƩ er
D2
LeƩ er
D3
1
1
LeƩ er
D4
LeƩ er
D5
1
1
LeƩ er
D6
LeƩ er
D7
1
1
LeƩ er
D8
2
LeƩ er
D9
1
1
LeƩ er
D10
LeƩ er
D11
1
1
LeƩ er
D12
LeƩ er
D13
1
1
LeƩ er
D14
LeƩ er
D15
1
1
LeƩ er
D16
LeƩ er
D17
1
1
LeƩ er
D18
LeƩ er
D19
1
1
LeƩ er
D20
LeƩ er
E1
LeƩ er
E2
LeƩ er
E3
LeƩ er
E4
LeƩ er
E6
LeƩ er
E7
LeƩ er
E8
LeƩ er
E5
LeƩ er
E10
LeƩ er
E11
LeƩ er
E9
LeƩ er
E12
LeƩ er
E13
LeƩ er
E14
LeƩ er
E15
LeƩ er
E16
LeƩ er
E17
LeƩ er
E18
LeƩ er
E19
LeƩ er
E20
LeƩ er
E21
LeƩ er
E22
LeƩ er
E23
LeƩ er
E24
LeƩ er
E25
LeƩ er
E26
LeƩ er
E27
LeƩ er
E28
LeƩ er
E29
LeƩ er
E30
LeƩ er
E31
LeƩ er
E32
LeƩ er
E33
LeƩ er
E34
LeƩ er
E35
LeƩ er
E36
LeƩ er
E37
LeƩ er
E38
LeƩ er
E39
LeƩ er
E40
LeƩ er
E42
LeƩ er
E41
LeƩ er
E43
LeƩ er
E44
LeƩ er
E45
LeƩ er
E46
LeƩ er
E47
LeƩ er
E49
LeƩ er
E48
LeƩ er
E50
LeƩ er
E51
LeƩ er
E53
LeƩ er
E52
LeƩ er
E54
LeƩ er
E56
LeƩ er
E55
LeƩ er
E57
LeƩ er
E58
LeƩ er
E60
LeƩ er
E59
LeƩ er
E61
LeƩ er
E62
LeƩ er
E64
LeƩ er
E63
LeƩ er
E65
LeƩ er
E66
LeƩ er
E68
LeƩ er
E67
LeƩ er
E69
LeƩ er
E70
LeƩ er
E72
LeƩ er
E71
LeƩ er
E73
LeƩ er
E74
LeƩ er
E75
LeƩ er
E77
LeƩ er
E76
LeƩ er
E78
LeƩ er
E80
LeƩ er
E79
LeƩ er
E81
LeƩ er
E82
LeƩ er
E83
LeƩ er
E84
LeƩ er
E86
LeƩ er
E85
LeƩ er
E87
LeƩ er
E88
LeƩ er
E90
LeƩ er
E89
LeƩ er
E93
LeƩ er
E92
LeƩ er
E94
LeƩ er
E91
LeƩ er
E95
LeƩ er
E97
LeƩ er
E96
LeƩ er
E98
LeƩ er
E99
LeƩ er
E100
LeƩ er
E102
LeƩ er
E101
LeƩ er
E103
LeƩ er
E104
LeƩ er
E105
LeƩ er
E107
LeƩ er
E106
LeƩ er
E108
LeƩ er
E109
LeƩ er
E110
LeƩ er
E112
LeƩ er
E111
LeƩ er
E113
LeƩ er
E114
LeƩ er
E115
LeƩ er
E117
LeƩ er
E116
LeƩ er
E118
LeƩ er
E119
LeƩ er
E120
LeƩ er
E122
LeƩ er
E121
LeƩ er
E123
LeƩ er
E124
LeƩ er
E126
LeƩ er
E125
LeƩ er
E127
[ TranslaƟ on: “This is cool!!!!!” ]
LeƩ er
E128
LeƩ er
E130
LeƩ er
E129
LeƩ er
E131
LeƩ er
E132
LeƩ er
E134
LeƩ er
E133
LeƩ er
E135
LeƩ er
E137
LeƩ er
E136
LeƩ er
E138
LeƩ er
E139