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Mayor Pulido and Members of the City Council April 2, 2018 Page 3 Those existing conditions include the distance of the driveway from Cabrillo Park Drive to the entrance to •the Xerox Building parking structure, the length of time it.takes for the gate arm to rise to allow a car to enter, the number of cars that can enter in a given period of time, and the actual number of cars that, under existing conditions, queue on Xerox Centre Drive while awaiting entrance to the parking structure at peak times of the morning. That information must then be supplemented with estimates of the number of cars that would be leaving the new parking structure at the same time, how long the wait would be for each car to have the gate rise, and how deep the backup would be within the new structure. The purpose would be not to evaluate the impacts of the existing traffic conditions on residents of the new projects (which is not a CEQA task), but to determine potential impacts, if any, arising from the addition of cross -traffic to the existing conditions. Questions to be addressed would include whether the cross -traffic would unacceptably slow down entrance to the Xerox parking structure, whether a slow -down would add to unacceptable queuing on Cabrillo Park Drive, and whether delays in exiting the new structure would be long enough to cause impatient drivers to take unsafe risks to cross the incoming cars. The fact that the traffic modeling does not address on-site traffic implications that could impact persons on private property does not excuse the EIR from evaluating these inevitable traffic conflicts any more than it would excuse the evaluation of a project's noise impacts on neighboring residents. The point here is that the project's injection of cross - traffic into an existing congested condition must be evaluated. Simply saying "it won't happen" does not comply with CEQA. Because the project will create for the first time traffic that must cross through existing traffic at the morning peak hour, there most certainly is a "fair argument" that the potential for an impact should be evaluated. Absent that analysis, the project's EIR is not adequate. This analysis must be prepared and circulated for public review so that the public, including the owner and tenants of the Xerox Building, has the opportunity to review and comment upon the analysis. Alternatively, the City Council could add a condition that the project's parking structure would be entered only from Xerox Centre Drive and exited only by way of State Fund Drive. This would avoid the potential for morning peak hour cross -traffic, avoid evening peak hour cross -traffic on State Fund Drive, and eliminate the need for a revision of the project's EIR to address the cross -traffic conflicts.