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i Chairman and Members or the Commission San Joaquin County Planning Commission October 5, 2000 Page 3 showed far more housing and housing related traffic generation than jobs creation contrary to what is assumed in the Negative Declaration. The Negative Declaration is inconsistent with the prior ETRs, attempting to understate the severity of local and regional transportation impacts; • The traffic analyses for Neighborhood"F" are erroneously premised on the theory that a remote job location in Alameda, Santa Clara, Contra Costa or San Mateo County is responsible for a return trip back to a Mountain House residence, thus skewing the traffic data and the so-called"fair share"concept for allocating trafficj burdens caused by the Project; The Neighborhood"F" Negative Declaration improperly defers development and II • implementation of traffic and transportation mitigation measures in violation of CEQA. Mitigation measures for I-580, Grant Line Road and Altamont Pass Road are improperly deferred, and based on the "mitigation offset"program,will likely never be implemented. The Mountain House CSD's adoption of a"technical report"and traffic impact fee on August 22,2000 violated CEQA in that the CSD failed to prepare an initial study to evaluate the effects of the proposed adoption, and failed to evaluate the fee structure and purported mitigation package which artificially limits the mitigation required for transportation and roadway impacts in connection with your consideration of the Neighborhood"F" Project and the Mountain House development as a whole; • The CSD's action in adopting a technical report for transportation impact fees improperly segmented the discussion of impacts directly attributable to the Project from the alleged factual basis for the technical report and the establishment of a Mountain House traffic impact fee, in violation of CLQA's rule against project-splitting and segmenting analysis of project components.The CS adoption of a technical report and traffic impact fee erroneously found that no additional environmental review is required, in violation of CEQA; I • The"technical report"and impact fee"mitigation and offset"program violates j CEQA in that this scheme allows the Project proponent to completely avoid funding and improving most of the local and regional roadways adversely affect ec by the Project, and results in unmitigated impacts to regional roadways and the 1- 580 corridor.Aside from further violating CEQA by splitting off the technical report and impact fee from your Board's consideration of the neighborhood"F" Project, the failure of the Initial Study for the Project to identify that many roads will not be constructed or upgraded and that such projects will not even be partially funded is a fundamental, fatal flaw in the Project's purported CEQA j analysis; i I