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Board of Supervisors January 28, 2013 Page 10 The Applicant also believes that the Board has ample bases for rejecting the Reduced Project Size Alternative, as the Planning Commission did. Under Alternative 2, the size of the Project's footprint would be reduced to half of the 11.6-acre site. The Board may properly and lawfully find that this alternative is infeasible for failing to meet key project objectives regarding the construction and operation of a truck stop serving. regional travelers. (DEIR, p. 7-9.) Specifically, the alternative conflicts with the project objectives of developing a property of sufficient size to accommodate a heavy-track and auto fuel dispensing area and emergency tire repair and replacement services, and providing a facility of sufficient size to capture overflow overnight track parking. (EPS Technical Memo,p. 4.) In Love's experience in developing similar truck stops, the size of the Project cannot be reduced and still result in an economically viable project. The scale of the reduced number of pumps,in addition to the smaller convenience store and fast-food restaurant, would not result in a requisite return on investment. (EPS Technical Memo,p. 4.) Additionally, as the EPS Technical Memorandum explains, a large portion of the Project is being developed to accommodate the needs of trucking customers, with their very large and cumbersome vehicles. Providing overnight parking spaces for large numbers of trucks will consume substantial amounts of land; and site must be configured to address operational and safety considerations such as the need for sufficient space for trucks to maneuver safely around the site. For these reasons,the Project will result in fairly low-intensity usage of a majority of the 11.6-acre site. Compared with what would occur with full site build-out under Alternative 2, this low-intensity usage translates into lower overall traffic impacts for the Project than for Alternative 2 as properly and realistically understood. Although, on its face, Alternative 2 would allow only half of the Project site to be developed, the Board should assume that the landowner would someday seek development approvals for the remaining acreage (approximately 5.8 acres). The existing General Plan and zoning designations would allow for the development of commercial-freeway services, which are typically high-intensity uses. Such uses, tacked onto those of a truck stop complex half the size of the Project, would likely cause environmental impacts greater than those of the Project. In addition to greater levels of traffic, there would be greater amounts of air pollution and greenhouse gas emissions. (EPS Technical Memo, pp. 4-5.) In short, because Alternative 2 does not account for the full development of the entire 11.6-acre site, Alternative 2, together with the foreseeable development of the remainder of the site, would actually lead to more,rather than fewer, environmental impacts than the Project. Based on these considerations, the Board may(and we respectfully submit, should)reject Alternative 2 as being both infeasible and environmentally more damaging than the Project. Alternative 3: Combination Gasoline Station As with Alternatives I and 2, the Applicant believes that the Board has ample basis for rejecting the Combination Gasoline Station Alternative, under which a gas station and convenience market would be developed with the capacity to serve only passenger cars and lighter trucks. The Board may find that the alternative is infeasible for failing to meet key project