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Chairman and Members or the Commission San Joaquin County Planning Commission October 5,2000 Page 7 development pay its "fair share"of the cost of roadway improvements, including those required in Alameda County.The fair share scheme created by the CSD and the Project approvals makes the mitigation of off-site road impacts illusory, in violation of CEQA. In addition, significant unmitigated cumulative impacts of the Project remain, in violation of CEQA. Subsequent to San Joaquin County's original consideration of the Mountain House project, the City of Tracy approved Tracy Hills and South Schulte projects, which will have significant long term impacts to public services, infrastructure needs and transportation systems, including the same regional roads affected by the Mountain House project. The City of"i'racy's Urban Management Plan describes extensive additional development in the form of urban townships in the Tracy area,all of which will result in significant cumulative impacts in association with the Tri-Mark Project currently under review. In order to partially address regional transportation impacts attributable to the Tracy Hills and South Schulte projects, the County of Alameda,the City of Livermore and the City of Tracy entered into a Joint Powers Authority to administer transportation impact fees levied on the new development in Tracy Hills and South Schulte, to fund essential trip reduction and alternative transportation programs, as well as much needed roadway maintenance and improvements.The impact fees assessed in these developments are expended both in San Joaquin and Alameda Counties on these trip reduction and roadway improvement projects cooperatively pursuant to the Joint Powers Agreement between the City of Tracy and the County of Alameda. We think that the direct impact to Alameda County Roads and the regional transportation impacts of the Tri-Mark Projcct must be addressed within the scope of the current environmental review for the Tri-Mark Project, and believe that a joint powers authority between our counties should administer a fee to address the regional impacts of the Project. The model has worked elsewhere and can work here to alleviate congestion and do something positive for the environment. The Deficiencies Require Pre ar tion of an EIR to Address Significant Transportation ImRMAIN- The deficiencies outlined above require preparation of a revised environmental review fo the Project,which we believe should be in the form of an EIR to afford maximum public review of the Project proposals and even more importantly the nature and extent of traffic and transportation mitigation measures required for the Project. Thank you for your consideration of these matters. We respectfully request that your Commission carefully consider these comments, and agree to revise the environmental analysis of the Project to develop a mitigation program that actually evaluates and mitigates impacts.