“The second part is I certainly would be in agreement with adding, as part of the Final EIR, to an analysis that would allow the types of things that were suggested by Mr. Elberling, which sounds like a win‐win situation, the widening of the sidewalks, signaled crosswalks in various parts.
Even though weʹre building the bridges over Howard Street, we still need to allow for some additional pedestrian crossings in various places along Howard and other streets to not force everyone to cross at the intersections as they now have to.” (San Francisco Planning Commissioner Michael J. Antonini; transcript, June 5, 2014)
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“And I thought itʹs very wise, no turns on red. And the other thing that has to be part of the analysis is we have a lot of intersections downtown which are signaled in a way that pedestrians all go at one time, and then traffic moves at different intervals. And thatʹs much safer because the frustration of drivers waiting to make a right turn is not there because, when they have the arrow to go right or they have the ability to turn right, there are no pedestrians.
And an area like this is very similar to our densest downtown areas. And we certainly should implement that sort of signal controls. And again I think this can be done fairly easily, to make sure the EIR includes impacts from that ‐‐ those sorts of changes to allow those to be part of the project when itʹs finished.” (San Francisco Planning Commissioner Michael J. Antonini;
transcript, June 5, 2014)
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“4. The DEIR’s Few Identified Pedestrian Impact Mitigations Are Hopelessly Inadequate To Deal With Even Today’s Moscone Center Impacts, Let Alone The Expansion Project’s.
Only one block of Fourth Street sidewalk, adjacent to the Metreon, is identified for possible ‐ but not committed ‐ widening as a Project Mitigation Measure to create any necessary additional pedestrian capacity for the Project’s Impacts. The even narrower sidewalk on the next block north adjacent to the Marriott Hotel/Ross Store which is a continuation of the very same route to Market Street and the Union Square hotels– an obvious bottleneck – is ignored because the authors assert with no supporting rationale whatsoever that it is somehow too far away from the Project (about 600 ft)! This Pedestrian Impact Mitigation discussion of the DEIR can only be described as utterly, pathetically, and shamefully inadequate.” (TODCO Group/Yerba Buena Neighborhood Consortium; letter, undated, received June 6, 2014)
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“5. A Genuinely Effective Pedestrian Capacity/Safety Mitigation Program Must Be Identified by the Project EIR and Required To Be Implemented As Part of the Project Itself, Not Just For the Sake of Legal Compliance With CEQA But Most Of All To Protect the Lives and Physical and Emotional Well‐Being of Our Yerba Buena Neighborhood’s Residents, Especially Its 2000+
Elders and Persons With Disabilities.
Attached is a diagram showing the needed street and sidewalk Significant Pedestrian Impact Mitigation Measures that need to funded and implemented by the City as part of the Expansion Project itself, not deferred for later uncertain funding or subject to further study.
Failure to identify and implement as part of the Project such Mitigation Measures will violate CEQA and is litigable. It includes:
• Widening sidewalks on the east side of Fourth Street from Howard Street to Market Street.
• Adding several signalized crosswalks at key locations to increase pedestrian capacity and/or provide pedestrian safety at dangerous locations.
• Adding “red arrows” to the traffic lights at the intersections where “No Turns On Red”
are allowed to improve pedestrian safety at those dangerous locations.
• Implementing a Sidewalk Management Plan (to be drafted by DCP/DPW in the coming year) that will optimize the location of all sidewalk street furniture, cafe tables, advertising signs, etc. to maximize Neighborhood sidewalks’ pedestrian capacity and safety while also satisfying urban design and amenity goals.” (TODCO Group/Yerba Buena Neighborhood Consortium; letter, undated, received June 6, 2014)
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“What we want and what weʹve been trying to get for 30 years is the conclusive mitigation of improvements to the sidewalks and neighborhood streets that will solve the problem today. We have been unsuccessful, largely, over these three decades to get that done in this city.
Our mitigations we are seeking are on the diagram map on the very last page of the comments.
Theyʹre very straightforward: wider sidewalks on two blocks of Fourth Street at the obvious places where needed; new mid‐block signalized crossings in three locations that are particularly crucial or hazardous in the surrounding neighborhood; the mere installation of red light arrows on the ‐‐ at the intentions where in fact no turns are permitted on red so that auto drivers can actually see them; and finally, implementing a sidewalk management plan that organizes all the stuff on the sidewalks ‐‐ all kinds, restaurant tables, advertising signs, whatever, you name it – logically so that the open throughway for pedestrians is optimized, unlike today, which is a mess.
Thatʹs what we want. And we want that to be done as a mitigation prior to the Moscone Expansion Project and built at the same that expansion project is built.” (John Elberling, TODCO Group/Yerba Buena Neighborhood Consortium; transcript, June 5, 2014)
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Response TR‐6
The comments raise concerns that too few pedestrian mitigation measures are included in the EIR, propose mitigation measures for incorporation into the EIR, and request additional analysis of the proposed mitigation measures.
Because pedestrian impacts were determined to be less than significant (as discussed in response to Comment TR‐3), mitigation measures provided in the comments, including the widening of the east sidewalk of Fourth Street between Market and Howard streets, adding new signalized crosswalks, adding red arrows to traffic signals where vehicles have a “No Turn on Red” restriction, and development and implementation of a Sidewalk Management Plan listed in the comments, are not required. The EIR thus does streets is included in the Central SoMa Plan. The City has indicated its intent to widen sidewalks on the east side of Fourth Street between Market and Howard streets, consistent with Improvement Measure IM‐TR‐4A, and is currently considering the design of sidewalk widening in this location. Also, separate from the proposed project, DPW is considering sidewalk widening on the west side of Fourth Street between Jessie and Mission streets, to meet the Central SoMa Plan and Better Streets Plan recommendations in time for implementation of these improvements upon certification of the Central SoMa Plan and coincident with the proposed Moscone Center Expansion project. DPW has indicated their intent to fund installation of red arrows at the intersections of Fourth/Howard and Fourth/Folsom, consistent with Improvement Measure IM‐TR‐4C.
The SFMTA and DPW already have standards for placement of landscaping and street furniture (documented within the Better Streets Plan), as well as permitting requirements for placing restaurant tables and chairs within the sidewalk right‐of‐way to ensure that adequate walkway area is available for pedestrians. Minimum sidewalk widths are currently required to be maintained. Pursuant to the Americans with Disabilities Act (ADA) requirements, the minimum width for ADA‐compliant sidewalk is 36 inches (3 feet).10 As noted in Response TR‐4, the effective widths of the sidewalk locations were used in the pedestrian analysis, thereby accounting for any sidewalk obstructions.
Therefore, an additional mitigation measure to develop and implement a Sidewalk Management Plan is not required.
The project sponsor has also indicated its intent to develop and implement measures to further reduce the proposed project’s less‐than‐significant transportation‐related
10 Ibid.
construction impacts, including a traffic control plan for project construction activities.
These measures are identified in the EIR as Improvement Measure IM‐TR‐8.
CEQA does not require or authorize “improvement measures” where impacts are not determined to be significant. Nevertheless, the Planning Department identified some proposals that could improve the pedestrian experience in the area. The City, various users and property owners in the area, or the project sponsor could elect to implement these improvement measures, but they are not required to do so under CEQA. The EIR identified some transportation improvement measures that could be implemented, including:
Improvement Measure IM‐TR‐1A: Transportation Demand Management on EIR page IV.A‐58.
Improvement Measure IM‐TR‐1B: Improved Fifth & Mission/Yerba Buena Center Garage Signage on EIR page IV.A‐59.
Improvement Measure IM‐TR‐4A: Fund the Design and Construction of Sidewalk Widening along Sidewalks Adjacent to Moscone Center on EIR page IV.A‐69.
Improvement Measure IM‐TR‐4B: Fund the Design and Implementation of Upgraded Crosswalks at Intersections Adjacent to Moscone Center on EIR page IV.A‐70.
Improvement Measure IM‐TR‐4C: Fund the Design and Implementation of Red Turn Arrow Signals at the Intersections of Fourth/Howard and Fourth/Folsom streets.
Improvement Measure IM‐TR‐8: Construction Measures on EIR page IV.A‐79.
In response to the comments, additional improvement measures have been identified for the neighborhood, and the text on EIR pages IV.A‐69 and IV.A‐70 is revised as follows (new text is underlined, deleted text is shown as strikethrough):
Improvement Measure IM‐TR‐4A: Fund the Design and Construction of Sidewalk Widening along Sidewalks Adjacent to Moscone Center
Consistent with the requirements of the Better Streets Plan and Planning Code Section 138.1, the project sponsor could fund the widening of the following sidewalk segments could be widened adjacent to the Moscone Center, consistent with ongoing planning efforts. Once the relevant planning effort has concluded and the relevant EIR has been certified and the project is approved, the project sponsor, or other users or the City could fund the design and implementation of the sidewalk widening projects listed below, if approved, totaling three four block faces:
Fourth Street east sidewalk between Mission Market and Howard streets to 15 by five to seven feet, resulting in sidewalk widths of between 15 and 25 feet (upon certification of the Central SoMa Plan EIR and if the Plan is approved): one block face two block faces.
Third Street west sidewalk between Mission and Howard streets to 15 feet (upon certification of the Central SoMa Plan EIR and if the Plan is approved):
one block face.
Mission Street south sidewalk between Third and Fourth streets to 15 feet (upon certification of the Better Market Street EIR and if the project is approved): one block face.
Improvement Measure IM‐TR‐4A would further reduce the proposed project’s less‐than‐significant impacts related to pedestrians, and would not result in any secondary transportation‐related impacts.
The City has indicated its intent to fund the design and implementation of widening of the east sidewalk of Fourth Street between Market and Howard streets, consistent with this improvement measure.
Improvement Measure IM‐TR‐4B: Fund the Design and Implementation of Upgraded Crosswalks at Intersections Adjacent to Moscone Center
Crosswalks could be widened and should be restriped to the Continental design, consistent with the Better Streets Plan. The project sponsor or other users or the City
It should be noted that the project already includes an enhanced midblock crosswalk across Howard Street between Fourth and Third streets.
Improvement Measure IM‐TR‐4B would further reduce the proposed project’s less‐than‐significant impacts related to pedestrians, and would not result in any secondary transportation‐related impacts.
DPW has indicated their intent to fund the design and implementation of upgraded crosswalks, consistent with this improvement measure.
Improvement Measure IM‐TR‐4C: Fund the Design and Implementation of Red Turn Arrow Signals at the Intersections of Fourth/Howard and Fourth/Folsom.
At the intersection of Fourth Street/Howard Street, red arrow traffic signal aspects could be installed for both the southbound Fourth Street approach to Howard Street, and also for the westbound Howard Street approach to Fourth Street, which both currently have No Right/Left Turn on Red restrictions. At the intersection of Fourth Street/Folsom Street, red arrow traffic signal aspects could be installed for both the southbound Fourth Street approach to Folsom Street and for the eastbound Folsom Street approach to Fourth Street, which both currently have No Right/Left Turn on Red restrictions. The project sponsor, other users, or the City could reimburse SFMTA for costs associated with the design and implementation of the additional signal.
Improvement Measure IM‐TR‐4C would further reduce the proposed project’s less‐than‐significant impacts related to pedestrians, and would not result in any secondary transportation‐related impacts.
DPW has indicated their intent to reimburse SFMTA for costs associated with the design and implementation of the additional signals, consistent with this improvement measure.
These revisions would not change the conclusions presented in the EIR.