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Mayor Pulido and Members of the City Council April 2, 2018 Page 2 reason, we are requesting a one-month delay to (i) allow Mr. Bisno, the Xerox Building owner, and State Fund the opportunity to reach agreement on the use of State Fund Drive as the exit path for the new parking structure and (ii) provide time for design modifications to provide for an appropriate primary loading zone and the addition of a move-in/move-out loading area for the tenants of the proposed residences. Our specific objections are as follows: s The Morning Peak Hour Cross -Traffic. This project impact was not addressed in the traffic study, which focused on Cabrillo Park Drive at Xerox Centre, but not upon the proposed project's interface with the existing circulation on Xerox Centre Drive. In fact, the traffic study does not even state how many cars will be entering or exiting the Xerox Building parking structure at peak hours or, for that matter, at any time. As of now, the City, the public, and the owner and tenants of the Xerox Building have no idea to what degree this conflict will impact tenants and visitors to the Xerox Building or traffic on Cabrillo Park Drive. Curiously, Table 5-1 of the traffic study cites the number of cars that would enter and exit the Madison parking structure if the Madison site was built out as a 210,000 square foot office tower. (Note that the project site is the Phase II of the Xerox Centre identified by Table 5-1, whereas the existing Xerox building is Phase 1 and has a square footage of 321,833.) This is curious because CEQA is not concerned with comparing a proposed project to what theoretically could have been built under existing or prior zoning, but rather what the potential impacts of the proposed project are when compared to existing conditions. Here, it is indisputable that existing conditions do not include cross -traffic from a second parking structure. It is equally indisputable that the project will result in traffic leaving the new parking structure and crossing the incoming traffic lane for the existing Xerox Building parking structure. The potential conflicts must be analyzed. Instead, the traffic study concludes on Page 14 that "the traffic impact potential associated with the proposed Project would likely be less than that of the entitled land use." That may be interesting information, but it is not a CEQA analysis. Even if the correct square footage is applied to the analysis and the number of morning peak hour entry trips are extracted from the ITE manual, the ITE manual is not intended to and cannot judge the potential morning peak hour conflicts on Xerox Centre Drive because those potential conflicts are uniquely defined by existing characteristics and conditions.