ATTACHMENT A SUMMARY OF COMMENTS AND RESPONSES

ATTACHMENT A SUMMARY OF COMMENTS AND RESPONSES Attachment A: Summary of Comments and Responses on Renaissance Square Environmental Assessment and Section 4(f) Evaluation, December 2008 A. INTRODUCTION This document summarizes and responds to comments on the Renaissance Square Environmental Assessment and Section 4(f) Evaluation, December 2008 (the EA). The EA was prepared by the Rochester Genesee Regional Transportation Authority (RGRTA) in compliance with the National Environmental Policy Act (NEPA) for the Federal Transit Administration (FTA) as lead federal agency. Public review for the EA began with publication and distribution of the document on December 17, 2008. A Notice of Availability for the Renaissance Square Environmental Assessment and Section 4(f) Evaluation was published in the Democrat and Chronicle on December 17, 2008. Copies of the EA were available for public review at the offices of RGRTA in Rochester, New York, and FTA’s Region 2 office in New York, New York. Copies were also available at the following locations: Rundel Library, City of Rochester Department of City Planning, Monroe County Department of Planning and Economic Development, Monroe Community College, Rochester Downtown Development Corporation, and Andrews Terrace. In addition, the EA was available on the Project web site: www.renaissancesquare.net and at www.rgrta.com. RGRTA convened a public hearing for the Project on January 8, 2009 from 6:30 PM to 8:30 PM at the Hyatt Regency Hotel, 125 East Main Street, Rochester, New York, which is located across the street from the Project Site. At the hearing, a total of 19 speakers provided comments on the Project. Comments on the EA were accepted via mail, e-mail, and on the Project’s web site through January 16, 2009. (There were no requests that the comment period be extended.) In addition to the oral testimony at the public hearing, 29 written submissions were received on the EA. Copies of the transcript from the public hearing and the written submissions are provided at the end of this document in Attachment A.1. This document is organized as follows: Section B lists all resource agencies, elected officials, and individuals and organizations that commented on the EA. This list is organized alphabetically. Following each commenter’s name is a list of the comments made, referenced by comment number. A total of 42 stakeholders submitted written or oral comments on the EA. Section C contains a summary of all comments made and a response to each of those comments. Where similar comments on the same subject matter were made by more than one person, a single entry summarizes all comments on that issue. Following each comment is a list in parentheses of the people or organizations that made the comment. A-1 Attachment A: Summary of Comments and Responses Please note that a number of commenters referred incorrectly to the EA as an Environmental Impact Statement (EIS). These incorrect references were corrected in the summary of comments provided below. The comments are organized into 11 general subject areas, and provided in the same order as the organization of the EA: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. General Comments on the Project Project Alternatives Land Use, Zoning, and Public Policy Socioeconomic Conditions Visual and Aesthetic Conditions Historic Resources Transportation Air Quality Noise and Vibration Construction Impacts Process, Agency Coordination and Public Participation In addition, the following attachments are provided at the end of this Summary of Comments and Responses: Attachment A.1: Attachment A.2: Attachment A.3: Attachment A.4: Attachment A.5: Copies of public hearing transcript and written comments. Information about Project revisions made in 2008 (see Comment 12 below). Correspondence from Landmark Society of Western New York, dated August 26, 2008 (see Comment 31 below). Supplemental information on analysis of bus operations (see Comments 40, 41, 42, and 43 below). Supplemental information on traffic impact assessment (see Comments 34 and 35 below). B. LIST OF COMMENTERS RESOURCE AGENCIES 1. Monroe County Department of Transportation (MCDOT), Terrence J. Rice, Director of Transportation, written submissions dated December 3, 2008 and January 27, 2009 (Comments 32, 33, 34, 36, 37, 28, 39, and 40). ELECTED OFFICIALS 2. Paul E. Haney, Legislator—District 23, Monroe County Legislature, comments made at public hearing, January 8, 2009; and written submission dated January 12, 2009 (Comments 5, 6, 41, 43, 44, 45, 53). ORGANIZATIONS AND INDIVIDUALS 3. Tracy Armstrong, Director, Communitywide Convention Marketing, comments made at public hearing, January 8, 2009 (Comment 2). 4. William Brown, written submission dated January 6, 2009 (Comment 10). A-2 Attachment A: Summary of Comments and Responses 5. John Buckland, written submission dated January 9, 2009 (Comments 10, 19). 6. Paul Christopher, comments made at public hearing, January 8, 2009 (Comment 1). 7. Nick DeRosa, written submission dated January 13, 2009 (Comments 9, 10, 11, 14, 18, 31). 8. Rebecca DeRosa, written submission dated January 13, 2009 (Comments 9, 10, 11, 14, 18, 31). 9. Patricia Donoghue, Vice President of Communication and Community Affiliations, Visit Rochester, comments made at public hearing, January 8, 2009 (Comments 1, 2, 3). 10. Dan Dwyer, comments made at public hearing, January 8, 2009 (Comment 1). 11. Raymond K. Gust, written submission dated January 7, 2009 (Comments 1, 2). 12. Ed Hall, President/CEO, VisitRochester, written submission dated January 8, 2009 (Comments 1, 2, 3). 13. Mark Hollenbeck, comments made at public hearing, January 8, 2009 (Comments 1, 2). 14. Dave Houser, Local 25, Stagehands, comments made at public hearing, January 8, 2009 (Comments 1, 2). 15. Bob James, written submission dated December 12, 2007 (Comment 33). 16. James L. Kemp, written submission provided at public hearing, January 8, 2009 (Comments 17, 46, 47). 17. Landmark Society of Western New York, Joanne Arany, Executive Director, written submission dated January 15, 2009 (Comments 26, 27, 28, 29, 30). 18. Landmark Society of Western New York, Katie Comeau, comments made at public hearing, January 8, 2009 (Comments 26, 27, 28, 29, 30). 19. Donna Leary, written submission dated January 6, 2008 (Comments 1, 56). 20. John Lonneville, written submission dated December 18, 2009 (Comment 20). 21. Karen Mason, written submission dated January 8, 2009 (Comments 1, 2). 22. Jonathan Maurer, comments made at public hearing, January 8, 2009 (Comments 16, 41, 53). 23. David A. Parker, written submission dated January 14, 2009 (Comment 7). 24. Bernet Parkins, written submission dated January 7, 2009 (Comment 2). 25. Victoria Posner, written submission dated December 17, 2008 (Comments 10, 25). 26. Alice Roberson, comments made at public hearing, January 8, 2009; and written submission dated January 10, 2009 (Comments 1, 4, 15, 17, 22, 45, 53, 55). 27. Arnie Rothchild, Chairman of the Board, Rochester Broadway Theatre League, comments made at public hearing, January 8, 2009 (Comments 1, 2). 28. Al Serenati, written submission dated January 7, 2009 (Comment 1). 29. Sally Shannon, comments made at public hearing, January 8, 2009 (Comment 2). 30. Van L. Smith, written submission dated December 24, 2008 (Comment 2) A-3 Attachment A: Summary of Comments and Responses 31. Wayne Smith, House Manager, Rochester Broadway Theatre League, written submission, dated January 7, 2009 (Comment 2). 32. Andrew Stainton, comments made at public hearing, January 8, 2009 and written submission dated January 16, 2009 (Comments 17, 23, 24, 31, 43, 44, 45, 48, 49, 57). 33. Joyce Szatkowski, written submission dated January 7, 2009 (Comments 1, 2). 34. Joe Triolo, written submission dated January 12, 2009 (Comment 10). 35. Ed Vesneski, comments made at public hearing, January 8, 2009 (Comments 1, 8). 36. Patrick Waser, written submission dated January 15, 2009 (Comments 6, 10). 37. Eric Welch, comments made at public hearing, January 8, 2009 (Comment 1). 38. Carlene Woodward, comments made at public hearing, January 8, 2009; and written submission dated January 16, 2009 (Comments 42, 44, 54). 39. Ed Wurtz, comments made at public hearing, January 8, 2009 (Comment 1). 40. Kevin Yost, comments made at public hearing, January 8, 2009 (Comments 13, 48). 41. Gary Zaccaria, Stage Manager, Auditorium Theatre, comments made at public hearing, January 8, 2009; and undated written submission (Comment 2). 42. Heidi N. Zimmer-Meyer, President, Rochester Downtown Development Corporation, written submission dated January 15, 2009 (Comments 1, 2, 12, 35, 50, 51, 52). C. COMMENTS RECEIVED GENERAL COMMENTS IN SUPPORT OF PROJECT A number of commenters made comments in support of the Renaissance Square Project. The supporters made the following general points. Comment 1: Many speakers indicated general support for the Renaissance Square Project: • The Project will bring a feeling of safety back to Downtown Rochester. It will enliven the area, especially after dark. (Donoghue, Hall, Gust, Hollenbeck, Mason) The Project will help create jobs and revitalize the economy and Downtown Rochester. (Christopher, Dwyer, Gust, Hollenbeck, Houser, Leary, Serenati, Szatkowski, Welch, Wurtz, Zimmer-Meyer) We support the Project’s multi-use nature. (Roberson, Rothchild, Vesneski) The Project will strengthen the surrounding area, encouraging investment in neighboring properties. The promise of the Project has already led to residential conversion projects (Cox Building and Warner Place) and has affected other investment decisions (Hyatt Regency, Clarion Riverside, and PAETEC’s decision to locate on the Midtown block). (Zimmer-Meyer) • • • A-4 Attachment A: Summary of Comments and Responses Comment 2: Many speakers noted their support for the new Performing Arts Center: • We support the Project’s creation of a new performing arts center in Downtown Rochester. (Armstrong, Houser, Parkins, Rothchild, V. Smith, Zaccaria) The Performing Arts Center will provide a tremendous economic benefit to Downtown Rochester. (Houser, Rothchild) A new Performing Arts Center will allow the City to attract more shows. (Gust, Houser, Zaccaria) Rochester has a great need for a new performing arts venue. The existing Auditorium Theatre is outdated and no longer suitable. It is not large enough and does not have adequate loading, storage, or backstage facilities. It is also inadequate for patrons, with difficult access for patrons in wheelchairs and inadequate restrooms, among other things. (Gust, Houser, Parkins, Shannon, W. Smith, Szatkowski, Zaccaria) A new theater will help Rochester to attract visitors and additional conventions. (Armstrong, Donoghue, Gust, Hall, Hollenbeck, Mason, Zimmer-Meyer) • • • • OTHER GENERAL COMMENTS ON THE PROJECT Comment 3: To reach its full potential, the Renaissance Square Project must be linked to the existing Skywalk System to allow easy pedestrian flow between the new theater and the existing hotels and convention center. (Donoghue, Hall) The Project will be linked to the Skywalk System through the Mortimer Street Garage. As described in the EA in Chapter 2, “Project Alternatives,” the Project will be connected to the Mortimer Street Garage (see page 2-5). The Mortimer Street Garage is connected to the Skywalk System via the connection between the garage and the Sibley Building across North Clinton Avenue. Figure 2-2 in Chapter 2, “Project Alternatives,” of the EA illustrates the location of the existing connection to the Skywalk System; the discussion of the Project’s connection to the Skywalk System is provided on page 2-3 of the EA. After several delays, in fact almost 10 years, the present plan for a Performing Arts Center, Monroe Community College Campus, and a Rochester transit center lacks a complete design for execution. Why has it taken so long? (Roberson) The Renaissance Square Project does not lack a complete design; its preliminary design is described in Chapter 2 of the EA, “Project Alternatives.” Over the past 10 years, there has been a considerable evolution in the concept of the Renaissance Square Project. This is described in the EA (see page S-2 in the Executive Summary, section B, “Background” and the longer discussion provided on page 5 of Appendix A, “Planning and Evaluation of Project Alternatives,” of the EA). RGRTA initially proposed an above-ground transit A-5 Response: Comment 4: Response: Attachment A: Summary of Comments and Responses center on Main Street, but this project was opposed by the City of Rochester and others, and the project was revised to move the transit center below ground. RGRTA and FTA prepared a Draft Environmental Impact Statement (EIS) for the revised project, which was known as Rochester Central Station. A public hearing was held to solicit public input on the Rochester Central Station Draft EIS in November 2003. Subsequently, in fall 2003 and early 2004, RGRTA in cooperation with the City, identified Monroe County and Monroe Community College (MCC) as potential development partners for the transit center project. After conducting feasibility studies, RTRTA determined that incorporating MCC and a performing arts center into the transit center project would be physically feasible, would benefit RGRTA and its riders, would serve the cultural and educational needs of Rochester, and would fulfill the City’s economic revitalization goals for Center City. At that point, the Rochester Central Station Draft EIS was withdrawn, and the project was changed to include the community college campus and Performing Arts Center as well as the transit center. An initial design was developed for the new project, now known as the Renaissance Square Project. Consistent with the requirements of NEPA, RGRTA began preparation of an Environmental Assessment for the Renaissance Square Project. The design was revised in spring and summer 2008 to reduce the Project’s cost and to reflect the decision to keep the Mortimer Street Garage (see response to Comment 12 below). Those adjustments resulted in the Project as currently proposed. Comment 5: Chapter 16 of the EA comments on resource commitments, but does not mention money. Certainly the alternative uses that the money could be used for warrant some discussion. (Haney) The federal funds that would be granted by FTA for the Project are earmarked for Renaissance Square. Chapter 16 of the EA (“Commitment of Resources”) mentions and addresses funding (i.e., money). This chapter describes the funding commitment that is required for the Project. Page 16-1 of that chapter states, “The construction of the Preferred Alternative would require an expenditure of public and private funds, which is not retrievable. The total commitment of funds required for the Preferred Alternative is estimated at $230 million.” In addition, funding required for the Project is also described in Chapter 2, “Project Alternatives,” of the EA, on page 2-5 under the heading, “Project Cost.” The EA also identifies and analyzes the “No Action” Alternative, in which no money would be spent on the Renaissance Square Project. NEPA does not require any further analysis of alternative uses of funds. If it weren’t for the myopic fixation of some community leaders on the construction of the bus station, the new MCC campus would be up and open, the Response: Comment 6: A-6 Attachment A: Summary of Comments and Responses reconstruction of East Ridge Road and Mt. Hope Avenue (from which federal transportation funds were pulled and put into the bus station) would be under way; and any number of other meritorious projects would be under way using the funds that have been set aside for this project, including the construction of the satellite stations that are needed to break the outmoded hub and spoke system that we have and that are called for in RGRTA’s long range planning documents. (Haney, Waser) Response: The Renaissance Square Project will meet the transportation needs in the region, as set forth in Chapter 1 of the EA (“Purpose and Need”), and is consistent with RGRTA’s transportation plans and overall route structure. The federal funds that would be granted by FTA for the Project are earmarked for Renaissance Square, and NEPA does not require analysis of alternative uses of funds. There are plenty of uses for the money other than another place to gather when we have housing needs. Investment should be made in downtown and performing arts is not the way to go. (Parker) See the response to Comments 5 and 6 regarding alternative uses for funding. One of the purposes of the Project is to revitalize Downtown Rochester, not only through the addition of a Performing Arts Center, but also through improved transit and a new Downtown campus for Monroe Community College. As described in Chapter 1, “Purpose and Need,” of the EA (see page 1-4), the Renaissance Square Project has multiple purposes. In addition to meeting a transportation need by providing a new transit center, the Project is also intended to promote the Center City area of Downtown Rochester by acting as a catalyst for new construction and spurring economic development. An analysis of economic benefits was conducted during preparation of the EA, which is included in Appendix B of the EA and summarized in Chapter 4, “Socioeconomic Conditions.” That analysis concludes that the Renaissance Square Project would result in an ongoing economic benefit to the region, including on-site jobs and contributions to the economic vitality of Downtown Rochester (see pages 4-6 through 4-8 of the EA). Following completion of that study, an additional more specialized study was prepared that evaluated the economic impact of the Performing Arts Center component of the project in detail. That report, the Renaissance Square Performing Arts Center Operation Plan and Economic Impact Analysis, prepared in October 2008 by Strategic Advisory Group, similarly concluded that the Performing Arts Center component of the Project would result in ongoing economic benefits. If Downtown Rochester and Main Street were in high demand, and people were coming in from out of town, would we be putting MCC and the bus station on Main Street? What’s lacking to revitalize Downtown Rochester is an aggressive effort to attract businesses to downtown. (Vesneski) Comment 7: Response: Comment 8: A-7 Attachment A: Summary of Comments and Responses Response: See the response to the previous comment. Please note that MCC is currently located and the bus transfer functions currently occur on Main Street today; with the proposed Project, both these components will be housed in new, modern facilities but they will not be new to the Project area. Moreover, as described in the EA (see page 1-2), transportation planning documents have identified Downtown Rochester as an appropriate location for a new transit center for several decades. The purpose and need for the Renaissance Square Project are described in the EA in Chapter 1, “Purpose and Need.” As noted there, and in the response to the previous comment, one of the purposes for the Renaissance Square Project is to promote the Center City area of Downtown Rochester by acting as a catalyst for new construction and spurring economic development. Allow private development to reinvigorate Main Street, and the City in general, with loft apartments and ground-floor retail, like most cities do, and the area will start to recover naturally, free of government aid. (N. DeRosa, R. DeRosa) The purpose and need for the Renaissance Square Project are described in the EA in Chapter 1, “Purpose and Need.” As described there (see page 1-4), the Project is intended to meet multiple needs, which include, in addition to economic revitalization, the transportation needs of RGRTA’s Regional Transit Service (RTS) bus system and MCC’s need for a new home for its Damon City campus. Allowing private development to reinvigorate Main Street would not meet the transportation needs of the Project described in Chapter 1. Please note that the Renaissance Square Project will include ground-floor retail uses facing Main Street. Comment 9: Response: Comment 10: This project is a waste of taxpayer dollars at a time when the federal, state, and county governments cannot afford it. (Brown, Buckland, N. DeRosa, R. DeRosa, Posner, Triolo, Waser) Response: The Project is not a waste of taxpayer dollars. As noted above in the response to the previous comments, the Project is proposed to meet the transportation needs of the RTS system, to revitalize the Downtown area of Rochester, and to provide new space for MCC, among other needs. Comment 11: Rochester already has several small theaters, and private developers would have already come along and built a Broadway scale theater if it were deemed profitable in a city the size of Rochester. In this economy it is doubtful anyone could afford a Broadway-style production when all their money is being spent on frivolous taxes that seem to spawn nothing more than failed government projects. (N. DeRosa, R. DeRosa) Response: As described in the EA in Chapter 1 (see page 1-3), there is a need for a new theater in Downtown Rochester. Rochester’s performing arts community has advocated for a new theater that can address the limitations of existing theaters A-8 Attachment A: Summary of Comments and Responses in Rochester; provide modern, updated space with improved support functions; and attract more traveling, large-scale productions that cannot be accommodated in Rochester’s existing venues. As discussed in response to Comment 26, below, the EA also describes the possibility of the Performing Arts Center not being included in the Project. ALTERNATIVES Comment 12: The design revisions made in summer 2008, including the decision to release the Edwards Building from the Project, the externalization of the Project’s retail spaces so that they front directly on Main Street, and the addition of a major entrance to the Performing Arts Center at Main and Clinton, all effectively correct major flaws in the early project design. (Zimmer-Meyer) Response: As noted in the comment, the Renaissance Square Project underwent a design revision in spring and summer 2008. The primary reasons for the design revision were the need to reduce the Project’s cost (including the decision not to use the Granite and Edwards Building for the Project) and the decision to retain the Mortimer Street Garage. During this process, community input was sought at public workshops in April and June 2008. As a result of the design modifications, the Project no longer proposes to use the Edwards or Granite Buildings as part of the Project. Other modifications include changes to the design of the Performing Arts Center, including reorientation of its entrance; and the retention of the existing Mortimer Street Garage. Copies of drawings showing the alternatives evaluated during the redesign process are provided in Attachment A.2. The EA analyzes the revised Project. Comment 13: I am concerned about the annual operating costs of the Project’s three components. Rather than build the Project, are there other alternatives, such as renovating the Auditorium Theatre, renovating the Sibley Building for MCC, and putting the transit center elsewhere? (Yost) Response: A number of alternatives were considered but were found not to meet the needs of the Project. These are described in the EA in Appendix A. As described there, the Project was developed based on a number of planning studies that identified the need for the Project components and after consideration of various alternatives for the Project’s design and location. As noted in Appendix A (see page 4), a subcommittee of the Greater Rochester Arts and Cultural Council, composed of representatives from various performing arts organizations in Rochester, identified the need for a large theater to be used largely for Broadway-style shows and musical performances. The expanding future needs of this type of show cannot continue to be accommodated in the existing Auditorium Theatre. A-9 Attachment A: Summary of Comments and Responses MCC has identified a need to relocate its Damon City Campus from the Sibley Building because its design is not conducive to MCC’s space needs (see pages 3 and 4 of Appendix A of the EA). Relocating MCC to the Renaissance Square Project will allow MCC to upgrade and expand its facility and allow for technological advances in its facilities and programs. Alternative locations for the transit center have also been evaluated (see page 9 of Appendix A of the EA). However, no other sites were identified that would 1) be large enough to house the number of buses needed at the transit center; and 2) be close enough to the existing RTS hub, which is currently along Main Street at Clinton Avenue, so as to allow buses to maintain their current routes to the maximum extent possible. Locating the transit center on a site that maintains current routes to the extent possible will allow RTS to optimize its bus operations, which will minimize annual operating costs. Comment 14: MCC should either make do with the building it currently has or relocate elsewhere in the city, possibly to the site Midtown currently occupies. (N. DeRosa, R. DeRosa) Response: MCC has indicated that its current location does not meet the College’s needs. As described in the EA in Chapter 1, “Purpose and Need,” on page 1-3, MCC’s space in the Sibley Building is costly to operate and maintain and its design is not conducive to the College’s needs for classrooms. Relocating MCC to another site in the city would not provide the advantages provided by having MCC co-located with the transit center. Co-locating MCC with the transit center is an effective means to encourage transit ridership and will allow the two components to share building services, such as retail space and utilities. In addition, a different project is currently being planned for the site that Midtown Plaza occupies. This project is described in the EA (for example, see page 3-6 in Chapter 3, “Land Use, Zoning, and Public Policy”). As described there, Midtown Plaza is planned for redevelopment as the new corporate headquarters for PAETEC and a mix of other uses. Comment 15: The bus terminal component of the Project should be combined with the Amtrak station to form a Transportation Zone. The train station already has ticketing facilities and restrooms and would be a better location for a bus terminal. The vacant lot north of the station could house city buses until departure time as in the Renaissance Square Plan. The bus terminal should remain at its present location on East Main Street. This combination of train and bus terminal, like Syracuse, would be convenient for the city and provide ready access for travelers. (Roberson) Response: The Project Sponsors analyzed an alternative that included locating the transit center at the Amtrak station. This alternative was not carried forward because it would not meet the purpose and need for the Project and would require major A-10 Attachment A: Summary of Comments and Responses restructuring of the existing RTS bus routes. Locating the transit center at the Amtrak station was studied in the Rochester Amtrak Station Revitalization Study, as well as in the alternatives analysis conducted for the Renaissance Square Project that is included in Appendix A of the EA (see page 9 of Appendix A). Those studies concluded that locating the bus transit center at the Amtrak station would not meet the needs identified in the EA or the needs of RTS riders, since a substantial percentage of the bus riders have origins or destinations near the intersection of Main Street and Clinton Avenue. Moreover, the hub of the RTS system is at the Main Street and Clinton Avenue location. The Amtrak station is one-half mile from the Main Street and Clinton Avenue location , and is not within the central area of Downtown Rochester. Therefore, this location would not be practical or reasonable for passengers bound to and from Downtown location. The studies also concluded that an Amtrak station location for the transit center would be disruptive to RTS’s existing “hub and spoke” system of operation, and would therefore increase operational costs by increasing mileage, and could adversely disrupt the scheduling of bus operations. For these reasons, the EA did not study in detail locating bus transit center at the Amtrak station. Comment 16: We have to stop thinking of people that ride buses as being something that we want to put off in some other neighborhood. We should get them downtown and workers should be transported to the heart of the city. The suggestion to combine the bus terminal component with the Amtrak station makes absolutely no sense. (Maurer) Response: Renaissance Square will bring bus riders to the heart of Downtown Rochester. As noted above in the response to the previous comment, an alternative that locates the transit center at the Amtrak station would not meet the transportation needs identified in the EA, or the needs of RTS riders, since a substantial percentage of the riders have origins or destinations near the intersection of Main Street and Clinton Avenue. The Project as proposed will provide access to the center of the city for RTS commuters. Comment 17: The bus terminal component of the Project detracts from the other components. The fumes, pollution, and traffic should not be located Downtown. The turning buses and their exhaust would not be attractive for pedestrians. (Kemp, Roberson, Stainton) Response: The bus terminal component of the Project does not detract from the other components. The Preferred Alternative’s multi-use building is being designed and constructed to meet the needs of its tenants, so that the operations of buses at the transit center can be accommodated without disrupting Monroe Community College and the Performing Arts Center. The EA evaluates the Project’s effects on traffic, air quality, and noise in Chapters 8, 9, and 10, and A-11 Attachment A: Summary of Comments and Responses concludes that the Project will not result in significant adverse traffic, air quality, or noise impacts. Moreover, providing a bus terminal Downtown would be consistent with RGRTA’s existing RTS bus system, which already uses Main Street in the vicinity of Clinton Avenue as its hub. Approximately 20 RTS bus routes converge at this intersection. During the peak commuter periods, when RTS buses operate frequently, nearly 100 buses per hour pull over on Main Street near Clinton Avenue to unload and pick up passengers. The Renaissance Square Project will not bring additional buses to this location, and will move bus transfer operations off the street. Locating a new transit center close to this intersection, but off Main Street, will also allow RGRTA to maintain existing RTS routes but free up traffic lanes on Main Street for other traffic. As noted in response to Comment 13 above, alternative locations that meet the purpose and need for the transit center are not available. Comment 18: Main Street is not the only available location for the bus station, nor would its location on Main Street serve any good for the flow of traffic along Downtown’s busiest street. (N. DeRosa, R. DeRosa) Response: The Renaissance Square project is not simply a bus station. It will serve as a bus transfer facility and hub for the RTS bus operations that occur in Downtown Rochester, and to serve this purpose it must be located in close proximity to the existing hub of RTS operations. The Project Site is the only site identified that would meet the purpose and need for the Project, and it will not adversely affect the flow of traffic on Main Street. As noted in the response to Comment 13 above, alternative locations were considered during Project development. However, no other sites were identified that would 1) be large enough to house the number of buses needed at the transit center; and 2) be close enough to the existing RTS hub, which is currently along Main Street at Clinton Avenue, so as to allow buses to maintain their current routes to the maximum extent possible. As such, these alternative locations would not meet the project needs identified in Chapter 1 of the EA, and therefore were not studied in detail in the EA. In addition, this location on Main Street will not adversely affect the flow of traffic along Downtown’s busiest street. In the existing condition, Main Street in the vicinity of Clinton Avenue serves as the hub of RGRTA’s RTS bus system, and approximately 20 RTS bus routes converge at this intersection. During the peak commuter periods, when RTS buses operate frequently, nearly 100 buses per hour pull over on Main Street near Clinton Avenue to unload and pick up passengers. Locating a new transit center close to this intersection, but off Main Street, will allow RGRTA to maintain existing routes but free up traffic lanes on Main Street for other traffic. The EA includes a detailed analysis of traffic impacts in Chapter 8, “Transportation,” which concludes that the Project willd not result in significant adverse impacts on traffic. A-12 Attachment A: Summary of Comments and Responses Comment 19: A drive-in movie theater should be built instead of a theater and might actually be used. (Buckland) Response: A drive-in movie theater would not meet the purpose and need for the Project as identified in Chapter 1, “Purpose and Need.” The Project will be used: it will serve the thousands of riders each day who use RTS buses to travel to or from Downtown Rochester, the 2,000 students who currently attend MCC’s Damon City Campus, and the thousands of patrons expected to attend performances at the new Performing Arts Center each year. Comment 20: Rochester needs light rail service, not buses. The Project should include the first light rail station for the City of Rochester. (Lonneville) Response: Introducing light rail service to Rochester is not among RGRTA’s goals, is not a goal of the Renaissance Square Project, and would not meet the needs of the RTS bus system. The EA describes the purpose and need for the Project in Chapter 1, “Purpose and Need.” As described there, the Project is intended to meet the needs of the existing RTS service, which is well established and well used. Comment 21: The best way to improve bus service is to lessen the wait time by putting more buses on the road, rather than making the waiting area more comfortable. (Wasder) Response: Improving bus service by increasing the number of buses is not proposed as part of the Project. The EA describes the purpose and need for the Project in Chapter 1, “Purpose and Need.” As noted later in this document, on average 55 buses per hour will use the new transit center. This service frequency is appropriate for the existing ridership. RGRTA routinely adjusts service frequency as needed, in response to changes in ridership as well as budget constraints. Comment 22: The waterfront should be included as well. (Roberson) Response: The Project site is not on the waterfront. As noted earlier in the response to Comment 13, alternative sites for the Project were evaluated during development of the Renaissance Square Project, but none were identified that met the purpose and need for the Project. LAND USE, ZONING, AND PUBLIC POLICY Comment 23: With the proposed plan, the community college will be surrounded by excessively heavy bus traffic. (Stainton) Response: The community college will not be surrounded by excessively heavy bus traffic with the Project. Under the existing condition and with the Project, MCC is close to the transit hub, which benefits the significant number of students who A-13 Attachment A: Summary of Comments and Responses use transit. With the Project, MCC will be located adjacent to the RTS Downtown hub, which is the same as the current condition. Monroe Community College’s Damon City Campus is currently located in the Sibley Building, which is adjacent to the RTS system’s hub on East Main Street. In the current condition, approximately 20 RTS bus routes converge at this location and during the peak commuter periods, when RTS buses operate frequently, nearly 100 buses per hour pull over on Main Street near Clinton Avenue to unload and pick up passengers. As described in response to Comment 41 below, the number of buses using this hub will not increase as a result of the Project. With the Renaissance Square Project, the buses will be relocated off Main Street to a transit structure specifically designed for them. The Preferred Alternative’s multi-use building is being designed and constructed to meet the needs of its tenants, so that the operations of buses at the transit center can be accommodated without disrupting Monroe Community College and the Performing Arts Center. Moreover, co-locating the transit center with the community college provides the most convenient transit access for students who commute by bus to class. SOCIOECONOMIC CONDITIONS Comment 24: The Project would take properties off the tax rolls and replace them with facilities that are going to cost millions of dollars each year to support. This would drain public coffers for decades. (Stainton) Response: The Project would take 18 privately owned tax parcels off the tax rolls, but it would also include two large publicly owned parcels (the former site of the older Mortimer Street Garage, which is owned by the City of Rochester, and the site of the Gateway and Atrium Buildings, which is owned by Monroe County). The property ownership for the Project Site is described in the EA (see pages 21 and 2-2 and Figure 2-3 in Chapter 2, “Project Alternatives;” pages 3-1 and 3-2 and Figure 3-3 in Chapter 3, “Land Use, Zoning, and Public Policy;” and pages 4-6 and 4-7 in Chapter 4, “Socioeconomic Conditions”), and the need for acquisition of private property is also described in those chapters. The Project will not drain public coffers for decades. The EA includes a detailed Economic and Fiscal Impact Evaluation in Appendix B. This is referenced and summarized in Chapter 4 of the EA, “Socioeconomic Conditions.” As noted in the EA (see pages 4-6 through 4-8), the Project is projected to result in an ongoing economic benefit to the region, including on-site jobs and contributions to the economic vitality of Downtown Rochester. Comment 25: I notice that the full environmental study is on the web site but the study that shows how profitable the Project will be is not. I suppose this is because the Project will only be a financial drain on the taxpayers. (Posner) A-14 Attachment A: Summary of Comments and Responses Response: This comment is not correct. The EA includes a detailed Economic and Fiscal Impact Evaluation in Appendix B, which is available on the Project’s web site. This is referenced and summarized in Chapter 4 of the EA, “Socioeconomic Conditions,” which, as noted in the comment, is also available on the web site. VISUAL AND AESTHETIC CONDITIONS Comment 26: As the economic climate continues to change, it looks increasingly likely that we could see demolition on the Site without concrete plans to rebuild. Destruction of viable buildings without plans to rebuild has proven time and time again to be a serious mistake. Yet that is what the EA presents as the scenario if funding for the theater component is not achieved. This possibility is mentioned only twice in the EA on page S-8 and pages 2-5 to 2-6, where the EA states that if funding for the Performing Arts Center is not achieved, the space allocated to the Performing Arts Center would be used for staging during construction, and then would be developed as a landscaped public plaza. Casual readers of the EA could easily miss this intention and could erroneously assume the buildings might be mothballed for future use. (Landmark Society) Response: The Project that is proposed and evaluated in the EA includes three components, the transit center, MCC, and the Performing Arts Center. The Project Sponsors fully intend to build the Performing Arts Center and are actively pursuing funding opportunities for it, and therefore have not prepared a design for the Project that does not include the PAC. If funding for the PAC is not identified, any necessary design changes at the Project will be developed subject to review by FTA and any additional environmental reviews that may be required by applicable law. The Project Sponsors will also solicit and consider the thoughts and suggestions of interested parties in developing a revised design for the Project, through public design workshops similar to those held for the Project to date. To be conservative, as noted in the comment, the EA recognizes the possibility that funding might not be found for the PAC and that therefore the PAC might not be incorporated into the Project. The EA describes (on pages S-8 and 2-5 through 2-6, as noted in the comment) what might occur in that event, including the potential appearance of the Project without the PAC and other changes in the Project’s effects if the PAC is not included. As described in the EA on those pages, if funding is not available for the PAC at the time that property acquisition and demolition for the transit center and MCC begins, demolition of all the buildings on the Project Site would occur in any case, to allow the PAC site to be used for a construction staging site (see page 2-5 of the EA and the response to Comment 28 below). If full PAC funding is never achieved, as described in the EA (see page 2-5), a landscaped public plaza would be developed on the PAC site. In addition, minor design changes would be required for the Project, because the eastern façade of the MCC building would be an A-15 Attachment A: Summary of Comments and Responses exterior façade rather than an interior wall. The EA also describes on the referenced pages the changes in the Project’s effects that would occur if the PAC is not included in the Project. Comment 27: The visual impacts of the Project scenario without the PAC are not adequately assessed in the EA. The only reference to an altered visual impact versus the Preferred Alternative is a brief mention of the fact that the Mortimer Street Garage would be more visible from the east and south—a vista that would be significantly detrimental to the appearance of this critical site. The appearance of the “landscaped public plaza” that would replace the row of 19th century buildings on the Project Site if the Performing Arts Center is not built is not described or even hinted at anywhere in the document. Replacing a row of 19th century buildings with a “landscaped public plaza” presents a huge problem in terms of the continuity of the streetscape. The result would be a streetscape that is very different from what is depicted in the illustrations in the EA. The block of East Main Street from St. Paul to Clinton would consist of the Granite Building and the one component of Renaissance Square fronting Main Street, with large open spaces on either side of the one new building—resulting in more voids than solids. This is an unacceptable outcome for this block, which has always featured a continuous streetwall in keeping with the character of a traditional downtown Main Street setting. The vision for Main Street in the existing city zoning code is consistent with strong urban planning principles: the zoning for Main Street states that “consistent setbacks create strong edges and promote spatial definition along the streetscape” and indicates that that setback should be zero feet, creating a strong, consistent edge at the front lot line. (Landmark Society) Response: Please see the responses to Comments 26 above and 28 below. Comment 28: If funding for the theater does not materialize before the Project begins, we strongly encourage the project planners to invest some funds into enhancing, rather than demolishing, the existing buildings. Historically appropriate façade improvements can transform these types of buildings into unique assets to the community. (Landmark Society) Response: If funding for the theater does not materialize before the Project begins, the Project Sponsors nonetheless intend to demolish the existing buildings in order to use the site for construction staging. This is described in the EA on pages 2-5 and 2-6. The affected properties are the tax parcels at the corner of Main Street and North Clinton Avenue that are occupied by eight small buildings extending from 190-194 East Main Street to the corner of North Clinton Avenue, as well as the two small buildings facing onto North Clinton Avenue north of Main Street. If funding for the PAC is not identified or construction of the transit center and MCC is ready to commence before such funding is identified, this A-16 Attachment A: Summary of Comments and Responses site will be used as a construction staging site for the rest of the Renaissance Square Project. Using the corner property as a construction staging site would provide substantial advantages during the Project’s construction, including the following: Without using the PAC site for staging, the Mortimer Street parcels (the future site of the transit center) would have to be used for staging and location of the construction crane for the MCC component of the Project. If the PAC site is available for staging and placement of the crane, this would greatly simplify the construction logistics by providing additional access to the construction site. Using the PAC site for staging would allow the transit center to be constructed nine months earlier, which would allow it to begin operation more quickly and would also result in significant cost savings related to escalation and delays. • Without using the PAC site for staging, the future location of the public plaza in front of the Edwards Building would be used for steel erection and contractor trailers and other construction staging activities. However, the plaza site is too small to also accommodate large deliveries, which would be made from Main Street. If the PAC site is available for staging, large material deliveries and steel erection can occur from there, reducing potential risks to the Granite and Edwards Buildings during construction. • Without using the PAC site for staging, the use of the curbside lane on Main Street for deliveries and laydown areas would adversely affect bus operations there. If the PAC site is available for staging, these lane closures would not be necessary. Please see the response to the previous comment regarding the use of the site following completion of construction. HISTORIC RESOURCES Comment 29: We are disappointed that the Project no longer includes the interior rehabilitation and reuse of the Edwards and Granite Buildings, but we are pleased with the commitment to the exterior renovation of these significant buildings. (Landmark Society) Response: Comment noted. The Project described and analyzed in the EA reflects the current plans for the Project, which no longer includes interior rehabilitation and reuse of the Edwards and Granite Buildings. As noted in the response to Comment 12 above, the design revision undertaken in spring and summer 2008, was undertaken to reduce Project cost and maintain the Mortimer Street Garage, removed the Granite and Edwards Buildings from the Project. As described in the EA (see pages 2-4 and 2-5), after the Atrium Building on Main Street is demolished for Renaissance Square, the Project will repair the east facade of the Granite Building, which served as a party wall between the building and adjacent Atrium Building. For the Edwards Building, the south façade will be restored where the existing pedestrian bridge will be removed. Once the Project A-17 • Attachment A: Summary of Comments and Responses is complete, the Edwards Building is expected to become more attractive for future reuse. Comment 30: What will happen to the Sibley Building and the Auditorium Theatre building if they lose their primary tenants? Potential abandonment of those two landmark buildings is a negative impact that should be addressed in the EA. (Landmark Society) Response: Potential abandonment of the Sibley Building and Auditorium Theatre is not anticipated. The Auditorium Theatre building is owned by the Rochester Broadway Theatre League, which will continue to own the building once the new Performing Arts Center at Renaissance Square is complete. The relocation of large, Broadway-style shows from the Auditorium Theatre to the new PAC will allow the Auditorium Theatre to be used for smaller events, such as community performances, for which it is not currently available when it is booked with large shows. Decisions regarding future plans for the privately owned Sibley Building will be made by the building’s owner. However, as described in the EA (see page 1-3 in Chapter 1 of the EA, and pages 3 and 4 of Appendix A of the EA), prior to and independent of planning for the Renaissance Square Project, MCC has been seeking modern, efficient space for its Downtown campus because the Sibley Building’s design is not conducive to MCC’s space needs. Therefore, MCC intended to relocate even without the Project. Comment 31: The EA states that there will be “no impact on historic resources.” It refers to the buildings that will be demolished as “late 19th century.” In fact, the corner buildings were constructed prior to 1850, which means they are roughly 50 years older than the EA states. The definition of “historic” is older than 50 years—clearly buildings that are 150 years are technically “historic,” making this statement inaccurate (if not fraudulent). Note that a nearly exact replica of their façade can be found in the Strong Museum atrium. How can we be celebrating this architectural history there and tearing down the original two blocks away and still pretend that there is “no impact on historic resources?” (N. DeRosa, R. DeRosa, Stainton) Response: The EA does not state that there will be no impact on historic resources. As stated on page 7-14 of the EA, FTA has determined and the State Historic Preservation Office (SHPO) has concurred that the Project would have no adverse effect on historic resources, consistent with the requirements and terminology of Section 106 of the National Historic Preservation Act. This determination was based on an analysis that was conducted of the Project’s effects on historic resources in accordance with the requirements of NEPA and Section 106 of the National Historic Preservation Act, as well as the State Environmental Quality Review Act, State Historic Preservation Act, and Section A-18 Attachment A: Summary of Comments and Responses 4(f) of the Department of Transportation Act. The analysis conducted and the conclusions made are summarized in Chapter 7, of the EA, “Historic Resources.” As described in that chapter (see pages 7-1 and 7-2), as defined by the regulations, the definition of “historic resource” is not based on age alone, and therefore a property that is 50 years old or older is not necessarily a historic resource that would be subject to protections under Federal and State law. Rather, historic resources are defined as properties that are National Historic Landmarks, properties that are listed on the State and National Registers of Historic Places, properties that have been determined to be eligible for listing on the State and National Registers, and City of Rochester preservation districts and individual landmarks. In addition, sites and properties that appear to meet the criteria for listing on the State and National Registers of Historic Places were also evaluated, in consultation with the New York State Office of Parks, Recreation and Historic Preservation, which is New York’s State Historic Preservation Officer (SHPO) for review of federally sponsored projects, to determine if those properties meet the criteria for listing on the State and National Registers of Historic Places. As described in the EA (see page 7-5), none of the buildings on the Project Site have been listed on or determined eligible for listing on the State and National Registers and none meet the eligibility criteria, and therefore none of the buildings on the Project Site are historic resources. Although these buildings range in date from the late 19th through mid-20th century, many have been altered, removing historic architectural details, and others are not architecturally distinguished. During consultation under the Section 106 review process, in a letter dated August 26, 2008, the Landmark Society of Western New York expressed concern about the small buildings on the Project Site and whether they might meet the eligibility criteria for the State and National Registers of Historic Places (a copy of that letter is attached in Attachment A.3). To respond to that concern, the Project Sponsors prepared a supplemental report, dated November 17, 2008, providing information on the architecture and history of all buildings on the Project Site and concluding that none of the properties on the Project Site were listed on or meet the eligibility criteria for the State and National Registers of Historic Places. The supplemental report was transmitted by James B. Durfee, AIA, Project Architect at The Associates, by e mail to Robert Englert, who is responsible for Monroe County at the SHPO, for review on November 26, 2008. A copy of that report is provided in Appendix C to the EA. Following review of that supplemental report, the SHPO concluded that the Renaissance Square Project will have no adverse effect on historic resources. The research materials provided in the supplemental report, including building documentation prepared by the Landmark Society of Western New York in a 1981 survey of Downtown Rochester, concluded that the small buildings facing Main Street have construction dates ranging from approximately 1860 to 1900; A-19 Attachment A: Summary of Comments and Responses those on North Clinton Avenue have construction dates ranging from 1870 to 1935. TRANSPORTATION TRAFFIC AND TRANSIT Comment 32: The Monroe County Department of Transportation (MCDOT), which is the Traffic Engineer for the City of Rochester, provided a comment letter, dated December 3, 2008, identifying concerns related to the Project’s traffic analysis and requested that Project Sponsors coordinate with MCDOT during final design to develop and refine traffic features. Response: MCDOT’s December 3, 2008 comment letter was based on a review of a July 2008 preliminary draft of the EA. Comments on that document included a request for a full set of figures and appendices (which had not been provided in July 2008), editorial comments on the text, and specific comments on the assumptions and results of the analysis. After further discussions between the Project Sponsors, consultant team, and MCDOT, including a meeting/ conference call on January 12, 2009, and MCDOT’s review of the December 2008 EA, MCDOT indicated in a follow-up letter dated January 27, 2009 that it was satisfied with the traffic analysis for the Renaissance Square Project and with the responses to its comments that were discussed. The comments of the December 3, 2008 letter are summarized and the responses discussed with MCDOT are provided in this section (see Comments 33, 34, 36, 37, 28, 39, and 40 below). The Project Sponsors will continue to coordinate with MCDOT as the Renaissance Square Project advances regarding the traffic improvement measures recommended on pages 8-9 and 8-10 of the EA and the potential for signal timing modifications to improve traffic operations. As requested by MCDOT, the Project sponsors will coordinate with MCDOT as design progresses to determine if any refinements are needed to improve traffic conditions. Comment 33: Does the analysis consider Broad Street to be in place? We’ve been made aware that the City is considering the removal of Broad Street, particularly the section between South Avenue and Exchange Street, as part of the “re-watering” project. An assessment should be made to see if this would impact the Renaissance Square Project. (James, MCDOT) Response: The traffic analysis in the EA considers Broad Street to be in place. Chapter 8 of the EA, “Transportation,” provides information on the street network used in the traffic analysis. Page 8-2 and Figure 8-1 in the EA provide information on existing conditions; pages 8-5 and 8-6 describe the assumptions that were made A-20 Attachment A: Summary of Comments and Responses about future baseline conditions; and Tables 8-4 and 8-6 present traffic conditions in the future baseline condition and in the future condition with the Preferred Alternative, including information on the two study area intersections at Broad Street. As noted in the comment, the City of Rochester is currently in the planning stages for a “re-watering project,” in which the bridge that carries traffic on Broad Street across the Genesee River may be removed. The Renaissance Square Project team developed the assumptions of future conditions to be used in the Renaissance Square EA in coordination with the City of Rochester in April 2008. At that time, the City did not identify the rewatering project; therefore, the traffic analysis for the Renaissance Square EA assumes Broad Street to be in place. Please also note that the Draft Generic Environmental Impact Statement published for the Midtown Plaza project also assumes Broad Street to be in place in its analysis of future background conditions. An assessment of the impact of the re-watering project that takes into account the Renaissance Square Project will be conducted by the rewatering project if it progresses. Because the re-watering project would be undertaken with City, State, and federal funds; prior to its approval, environmental studies would be prepared to evaluate the environmental effects of the re-watering project in accordance with the requirements of NEPA and SEQRA. The City has confirmed that Renaissance Square would be considered as a background project in those environmental studies; therefore, any cumulative impacts of the Broad Street project and Renaissance Square would be addressed by measures recommended in the environmental documentation prepared to evaluate the re-watering project. Comment 34: Of the intersections that were analyzed, signal timing changes should be able to address many of the deficiencies identified but not at all intersections. The St. Paul Street/Westbound Cumberland Street and St. Paul Street/Eastbound Cumberland Street/Bittner Street intersections cannot be addressed as such and mitigation should be analyzed/explored further in the final design phase. (MCDOT) Response: The traffic analysis in the EA describes the signal timing changes that are proposed as part of the Project to address deficiencies. As noted in Appendix D to the EA (in Appendix D-1, see the memorandum dated July 31, 2008 that follows Figure 24), these include signal timing changes at the following intersections: St. Paul Street and Eastbound Cumberland Street (AM and PM peak hours); St. Paul Street and Westbound Cumberland Street (AM and PM peak hours); St. Paul Street and Mortimer Street (AM and PM peak hours); and East Main Street and North Clinton Avenue (AM peak hour). The analysis presented in the EA (see page 8-12 and Table 8-6) concludes that the Project will improve operations in the PM peak hour at the northwestbound approach to the intersection of St. Paul Street and Eastbound Cumberland Street and for the intersection overall. As noted in the comment, the EA analysis concludes that A-21 Attachment A: Summary of Comments and Responses even with the signal timing changes, the St. Paul Street/Westbound Cumberland Street intersection will operate with unacceptable levels of service in the AM peak hour (see pages 8-12 and 8-16 in the EA) because of the increase in traffic resulting from future background conditions (i.e., conditions that would exist if the Project were not built). Please note that in response to the December 3, 3008 comment letter from MCDOT, the Project’s traffic consultants re-examined the results of the traffic analysis to seek to optimize signal timings throughout the study area. As a result of that re-examination, additional improvements in signal timings were identified that would improve intersection operations for the Project. This reexamination is provided in Attachment A.5. As discussed in Attachment A.5, with the modifications made, the Project will improve operations at the South Avenue and Broad Street intersection in the PM peak hour, so that the eastbound approach improves from LOS F to LOS C, and the overall intersection improves from LOS D to LOS C. As requested by MCDOT, the Project sponsors will coordinate with MCDOT as design progresses to determine if any refinements are needed to improve traffic conditions. Comment 35: The EA asserts that the Preferred Alternative would not result in significant adverse impacts on traffic operations in the 2014 analysis year scenario (page 8-16). However, there is concern about the PM peak hour LOS ratings at South Avenue and Broad Street, as well as St. Paul Street and Cumberland South. The South/Broad intersection already experiences problems during the weekday evening commute. (Zimmer-Meyer) Response: The traffic analysis in Chapter 8 of the EA identifies the locations noted in the comment as intersections that will operate at unacceptable levels of service in the future background conditions, but notes that the Renaissance Square Project will not cause significant adverse impacts there (see pages 8-12 and 8-16 of the EA). Subsequent to publication of the EA, the Project Sponsors explored further signal timing modifications to alleviate congestion at the intersection of South Avenue and Broad Street to improve its LOS. The results of this analysis, which are shown in Table A.5-1 of Attachment A.5, reveal that with further modification, this intersection would operate at LOS C. The intersection of St. Paul Street and Eastbound Cumberland Street would also be improved with further signal modification (see Table A.5-1 of Attachment A.5); however, the intersection of St. Paul Street and Westbound Cumberland Street would have LOS E or F conditions with or without completion of the Preferred Alternative. . Comment 36: For the approach from westbound Main Street to northbound Clinton Avenue, MCDOT believes that converting the curb lane (now used as a bus lane) to a through lane with a right-turn pocket will improve intersection operations. (MCDOT) A-22 Attachment A: Summary of Comments and Responses Response: Comment noted. This modification was not assumed in the traffic analysis in the EA. . Comment 37: Not all turn restrictions need to be removed within the Project area, for example, northbound turns onto North Clinton Avenue can still be restricted at Main Street without affecting Renaissance Square operations. This should be investigated in the final design phase. (MCDOT) Response: Comment noted. As noted above, the Project sponsors will work with MCDOT to explore potential improvements at affected intersections during final design for the Project. Comment 38: It is unclear from the EA what the geometric impacts are for street sections “off site.” How are lane use changes being transitioned to and from the Project Site? It is also unclear from the EA what the geometric plans are for Mortimer Street, Division Street, the bus terminal entrances/exits, as well as alignments to other connecting streets. Access details with the bus terminal entrances and exits need to be worked out. The St. Paul Street access needs a signal, due to Mortimer Street being right there, but the North Clinton Avenue access could be unsignalized. These details need to be developed further in the final design phase. (MCDOT) Response: Pages 8-9 and 8-10 of the EA describe the traffic improvements associated with the Preferred Alternative, which include changes to turn restrictions, installation of new signals, and signal timing modifications. Specific information on the geometry of the Project’s driveways will be provided to MCDOT for review during final design for the Project. As also noted in the EA (see pages 8-9 and 8-10), Division Street will be closed as part of the Project but a portion of existing Division Street would remain to allow access to the Granite and Edwards Buildings. Mortimer Street will be closed for through traffic but will serve as a delivery entrance for the Preferred Alternative and for access to the Cox and Edwards Buildings. As described on pages 8-9 and 8-10 of the EA, a new traffic signal is proposed at both bus terminal entrance/exit points—i.e., where St. Paul Street and North Clinton Avenue intersect with the driveways of the new transit center. The Project sponsors will coordinate with MCDOT and the City of Rochester to design and implement these changes. Comment 39: Overall, MCDOT believes that the Renaissance Square Project could work in conjunction with maintaining St. Paul Street and North Clinton Avenue as oneway streets and with some geometric improvements in the area that we understand will be done by the Project. We look forward to working with the Project engineers to develop and refine the traffic features further during the final design phase. (MCDOT) A-23 Attachment A: Summary of Comments and Responses Response: Comment noted. The design set forth and evaluated in the EA assumes that St. Paul Street and North Clinton Avenue are maintained as one-way streets, with geometric improvements as noted in the comment. . Comment 40: It is unclear from the EA what the impact will be for buses that will be re-routed to access the terminal facility. We recall discussion related to redistributing eastbound left turns at Main Street/North Clinton Avenue to southbound State Street to Andrews Street. The report proposes allowing westbound left turns at Main Street/State Street, which is an illegal move. All of this needs to be analyzed to assess what the impacts are. (MCDOT) Response: The potential route change mentioned in the comment was not analyzed, because it is not being considered by RGRTA. However, the route change is an example of the types of modifications that RGRTA could make to some bus routes to reduce the number of buses arriving at the transit center from Main Street. The traffic analysis in Chapter 8 of the EA describes the effect on traffic conditions related to bus reroutings. The EA analyzes traffic conditions based on reasonable assumptions for the routing of existing bus routes to the new transit center, and therefore the conclusions about the Project’s impacts presented in Chapter 8 incorporate the bus reroutings. This chapter concludes that the Preferred Alternative, including the bus reroutings, will not result in significant adverse traffic impacts. Assumptions about buses are discussed on page 8-10 of the EA. Attachment A.4 provides further explanation on assumptions made regarding the rerouting of buses with implementation of the Preferred Alternative. As noted on pages 8-9 and 8-10 of the EA, it is proposed that leftturn turn restrictions to and from Main Street at the intersections of St. Paul Street and North Clinton Avenue be lifted to accommodate the relocation of buses to the new bus transit center. The EA does not recommend modifications at the intersection of Main Street and State Street. Please also note that RGRTA regularly makes adjustments to bus routes and schedules to reflect changes in ridership, changes in land use, and other factors, and will continue to do so in the future. RGRTA will continue to evaluate the routing of buses as the design for Renaissance Square progresses and may make route changes to result in more efficient operations once the Project is completed. . Comment 41: The EA fails to address the traffic flow problems associated with the bus station. The EA states that 40 Greyhound/Trailways buses a day will use the station but has no data regarding the RGRTA buses or how they will access the bus station. According to the Sear Brown Report dated January 11, 1998, a total of 1,197 RGRTA buses will use the Project every day. This coupled with the 40 Greyhound/Trailways buses a day makes for 1,237 buses per day that will use the Project. Yet, the EA does not update this data or discuss how they will enter A-24 Attachment A: Summary of Comments and Responses or leave the station. How do we safely and efficiently move 1,237 buses through the Main Street intersections? This is a glaring weakness that also has pedestrian safety implications. (Haney, Maurer) Response: The EA does not fail to address the traffic flow problems associated with the traffic center; it includes a detailed level-of-service analysis of traffic conditions, presented in the EA in Chapter 8, “Transportation,” that evaluates the effects of the new transit center, including the rerouting of buses from Main Street and nearby streets into the transit center (see page 8-10). That analysis concludes that no significant adverse traffic impact will result from the Preferred Alternative, including bus reroutings. As described in the EA (see page 2-3 in Chapter 2), the bus transit center will include 36 bus bays, of which 30 will be used by RTS and 6 by intercity (Greyhound and Trailways) buses. Attachment A.4 provides further explanation on assumptions made regarding the rerouting of buses with implementation of the Preferred Alternative. The purpose of the Project (see pages 1-4 and 1-5 in Chapter 1 of the EA) is to serve the existing RTS system. As noted on page 8-10 of the EA, “The transit center would relocate RTS, Greyhound, and Trailways buses from existing layover positions within Downtown Rochester. . . These buses would be rerouted from the existing layover positions to the new transit center; however, the transit center component of the Preferred Alternative itself is not expected to generate new bus trips during peak hours.” The transit center will therefore serve the existing RTS buses that currently use the hub in Downtown Rochester, which is a total of 1,213 RTS buses daily (over a 24-hour period). The 1998 numbers cited in the comment do not reflect current RTS operations. During the peak period of operations (weekdays from 3 PM to 6 PM), approximately 105 RTS buses per hour will enter and leave the bus transit center. RGRTA is designing the facility to meet this peak demand. The new facility will improve congestion along East Main Street, St. Paul Street, and North Clinton Avenue, because the curb lanes will no longer be used for buses to pull over to discharge and pick up passengers. Currently, buses arriving and departing from the curb lanes must weave into and out of the moving lanes for traffic. This reduces the throughput of these streets, since passing vehicles must reduce speeds or otherwise yield to buses as they maneuver. For a discussion of pedestrian safety, see the response to Comment 44. Comment 42: The EA does not reflect the true volume of buses (approximately 1,600) between the prime hours of 7 AM and 7 PM that will be entering and exiting the station. (Woodward) Response: The traffic impact assessment in the EA fully accounts for existing and future bus operations in Downtown Rochester and correctly reflects the volume of buses. As described on page 8-3 of the EA, the traffic analysis considers conditions in three peak hours: a morning peak hour, an evening peak hour, and A-25 Attachment A: Summary of Comments and Responses a theater peak hour. For each peak hour analyzed, the analysis considers the true volume of buses on the streets and entering the transit center. As noted in the response to Comment 41, the bus transit center will serve a total of 1,213 RTS buses daily (over a 24-hour period). This is the same number of buses that currently are present on East Main Street, St. Paul Street, and Clinton Avenue. No increase in the number of buses is planned; the only change that will result with the Project is the small changes to bus routes that will be required to shift the buses one block north of Main Street into the transit center. Attachment A.4 provides more information about the number of existing RTS buses that use the Main Street hub. As shown in Attachment A.4, a total of 978 RTS buses currently use the hub between 7 AM and 7 PM, and this number will not change with the Project. Comment 43: The location of the bus station, between two one-way streets, means that there simply is no practical way for buses coming from the west to navigate this path without travelling circuitous routes through several key intersections, twice, using left turns that are not allowed today. Keeping Clinton Avenue and St. Paul Street as one-way streets raises serious concerns about how buses will circulate on the streets: (1) hundreds of buses will have to make left turns at the two Main Street intersections, causing traffic delays and pedestrian danger; (2) the 351 eastbound buses that will have to completely circle the block, each passing east on Main Street between St. Paul Street and Clinton Avenue twice; and (3) all 1,237 buses will have to use Clinton Avenue and St. Paul Street between Main Street and Mortimer Street. Instead of addressing this issue in the EA, it simply states that there will be “no traffic impact.” (Haney, Stainton) Response: The transit center’s location between two one-way streets will require some buses to have routes that are more circuitous, while other buses’ routes will not be more circuitous. Maintaining one-way streets would not result in significant adverse traffic impacts, however. The EA does not simply state that there will be no traffic impact. It presents a detailed traffic analysis, included in Chapter 8 of the EA, that was conducted in coordination with the Monroe County Department of Transportation, which is the Traffic Engineer for the City of Rochester. That analysis evaluated traffic conditions with the Project in place, including retention of the one-way street network and rerouting of buses, and concluded that no significant adverse traffic impacts would occur. Chapter 8 of the EA provides a brief discussion of the methodology used to account for bus reroutings on page 8-10 (see “Changes in Bus Operations”). As described in the EA (see page 8-10), assumptions regarding future bus routings were developed based on information provided by RGRTA for the proposed operation of the bus terminal, modifications to the bus routes within the vicinity of the Renaissance Square study area due to the removal of turn restrictions, and the desire to reduce bus travel along Main Street between St. Paul Street and North Clinton Avenue. The traffic analysis accounted for the re-routing of buses from the A-26 Attachment A: Summary of Comments and Responses current layover positions on East Main Street, St. Paul Street, and North Clinton Avenue to the new bus transit center at Renaissance Square. As noted in the response to the previous comment, the traffic analysis included in Chapter 8 of the EA considers traffic conditions in three peak hours: a morning peak hour, an evening peak hour, and a theater peak hour. For each peak hour analyzed, the analysis considers the volume of buses on the streets and entering the transit center, as well as the other traffic anticipated to be at study area intersections in the future analysis year. The methodology used for this analysis is described in more detail in Attachment A.4 of this FONSI. As is described in Attachment A.4, the maximum number of buses in any of the peak hours analyzed is 114 buses per hour, during the AM peak hour (7 AM to 8 AM), not 351 buses or 1,237 buses as cited in the comment. With the rerouting, some bus routes will be more circuitous than they are currently, others will be less circuitous, and yet others will be relatively unchanged (see Attachment A.4). RGRTA regularly makes adjustments to bus routes and schedules to reflect changes in ridership, changes in land use, and other factors, and will continue to do so in the future. RGRTA will continue to evaluate the routing of buses as the design for Renaissance Square progresses and may make route changes to result in more efficient operations once the Project is completed. The traffic analysis (provided in Chapter 8 of the EA) concluded that the Preferred Alternative will not result in significant adverse impacts on traffic circulation. Comment 44: There is serious concern about the hundreds of buses that will have to make left turns at the two Main Street intersections and the traffic delays and pedestrian dangers that will create. Doing away with no left hand turns will not only bring traffic to a halt, but the ability of pedestrians to cross safely is seriously compromised. Instead of a more walkable and user friendly area, it will be like an obstacle course, especially for people with young children, the handicapped, and the elderly. (Haney, Stainton, Woodward) Response: To address the Preferred Alternative’s potential impact on traffic operations, the EA includes a detailed assessment of the intersections of East Main Street and St. Paul Street and East Main Street and North Clinton Avenue to determine whether the rerouting of buses would adversely impact traffic operations. The analysis, provided in Chapter 8 of the EA, concludes that removing the left-turn prohibitions on Main Street will not adversely affect traffic conditions or pedestrian conditions. As discussed in the EA (see page 8-16 in Chapter 8, “Transportation”), the left-turn provisions present today on Main Street have two purposes: 1) to serve as a pedestrian safety measure; and 2) to maintain capacity on Main Street at the signalized intersections. Large numbers of pedestrians are present in this area, due to nearby land uses and because of the bus transfer function that occurs there; the turn restrictions protect these pedestrians from vehicle conflicts as they cross streets. In addition, the presence A-27 Attachment A: Summary of Comments and Responses of many buses pulling toward and away from the curb and laying over in the curb lane reduces the capacity of Main Street for through traffic, resulting in the need to keep the center lane flowing by prohibiting left-hand turns. The bus transit center will improve pedestrian circulation on East Main Street, since pedestrians will no longer have to cross Main Street to transfer between buses because transfers will occur inside the new facility. Removing the buses from curbside positions will also improve sight lines for motorists traveling through the area. In addition, without buses using the curb lane to pick up and discharge passengers and without buses pulling into and out of the moving lanes, there will be additional through capacity on Main Street. The traffic analysis in Chapter 8 of the EA included a future conditions assessment that accounted for the rerouting of buses from the current layover positions on East Main Street, St. Paul Street, and North Clinton Avenue to the new bus transit center at Renaissance Square and the lifting of the left turn prohibitions on Main Street. The EA concluded that the Project will not adversely impact the level of service of traffic on East Main Street and North Clinton Avenue and East Main Street and St. Paul Street (see page 8-16). The EA also recommended a campaign that promotes safe pedestrian and driver behavior to minimize effects on pedestrian circulation and noted that pedestrian signals at Downtown intersections could be improved to provide for a pedestrian phase, which would reduce the potential for pedestrian-vehicle conflicts in the vicinity of the Project Site (refer to page 8-16 of the EA). . Comment 45: The press has reported that part of the solution of dealing with the 1,237 buses per day that will use the Project will be to make St. Paul Street (and its extension, South Avenue) and Clinton Avenue two-way streets. This, however, has a set of very serious problems attached to it which are not addressed or even mentioned in the EA. Making St. Paul Street and Clinton Avenue two way (the maps in the EA show the streets as one-way, but the design of the bus station almost requires them to be two-way, as an equal number of bus slips face east and west) has several problems that are not addressed or even mentioned in the EA. Since the public hearing, it has been suggested to me that the plan to turn Clinton Avenue and St. Paul Street into two-way streets has been abandoned, which would solve the problems I noted but raise different problems (noted in Comments 41 and 43 above). (Haney, Roberson, Stainton) Response: The Renaissance Square Project does not include converting St. Paul Street and North Clinton Avenue to two-way operation. The analysis presented in the EA reflects a continued one-way operation for these streets. The commenter is correct that the maps in the EA illustrate one-way streets (see Figures 8-2, 8-3, and 8-4 in Chapter 8), since the Project as proposed will not change the street directions. The design of the transit center, with slips facing both east and west, will allow buses headed southbound on St. Paul Street to enter the facility from A-28 Attachment A: Summary of Comments and Responses that street and buses headed northbound on Clinton Avenue to enter from that street. Comment 46: Traffic control and the lack of interference have not been adequately explained to the public. (Kemp) Response: The EA explains in detail the issues of traffic control and the lack of interference. The EA includes a detailed assessment of traffic circulation for 16 intersections within Downtown Rochester in Chapter 8, “Transportation,” and concludes that the Preferred Alternative will not result in significant adverse impacts on traffic. Chapter 8 also describes the traffic improvements that are proposed as part of the Project (see pages 8-9 and 8-10 of the EA). Comment 47: Please explain the 1-Lake route going north from East Avenue through downtown to Kodak. (Kemp) Response: With the Preferred Alternative, RTS’s 1-Lake bus route will use the new bus transit center, but no other changes in its routing are proposed. Comment 48: The statement made in the EA that there will be “no negative environmental impact” caused by the Project is directly contradicted by the reality of the bus station’s impact on the bus system. The Project would slow the already slow bus system by lengthening bus routes and requiring buses to spend time backing up. How much longer would commutes be? This would also increase RGRTA’s annual operating costs. (Stainton, Yost) Response: Implementation of the Preferred Alternative will require some buses to travel an additional two blocks to enter and exit the transit center, but this rerouting will not substantially change the length of bus routes or commute times. RGRTA proposed this Project to meet the critical transportation needs identified in Chapter 1, “Purpose and Need,” of the EA. The Project will result in an overall benefit to the RTS bus system, not an adverse impact as cited in the comment. The Project has been designed for the RTS bus system with the needs of that system in mind. Comment 49: The entire bus system will be made vulnerable to any tie-ups as buses make their way along the maze through the station. Any blockage along this central route will literally bring half or potentially all of the bus system to a halt as it waits to be cleared. No mention of this vulnerability is made in the EA. (Stainton) Response: As noted in the response to the previous comment, RGRTA proposed this Project to meet the critical transportation needs identified in Chapter 1, “Purpose and Need,” of the EA. As with any bus system, contingency plans will be in A-29 Attachment A: Summary of Comments and Responses place that will be used if a bus break-down impedes circulation through the transit center. PARKING Comment 50: The parking analysis did not assume a large enough growth percentage for future parking demand in the area. It does not recognize the demand to be created, given the activity levels projected for the Renaissance Square uses, and new redevelopment potential being generated by adjacent development for the Sibley Complex. In addition, should the convention and hotel business increase as a result of better economic conditions and the draw of Renaissance Square and its Performing Arts Center, additional parking needs should be estimated and accounted for in the analysis. (Zimmer-Meyer) Response: The assumptions for the parking analysis were developed in consultation with the Monroe County Department of Transportation. As described in the EA in Chapter 8, “Transportation,” in section C, “Parking,” the parking analysis assumes a growth rate in parking demand of ½ percent per year, from the existing analysis year of 2008 through the future analysis year of 2014 (see page 8-17 in Chapter 8). In addition to this background growth rate, the parking demand of future development projects was also included. The specific development projects incorporated are listed in Chapter 3 of the EA (see page 8-18 in Chapter 8). This list was developed in coordination with the City of Rochester and other interested parties, including the commentor. As discussed on pages 8-17 and 8-18, the combination of existing parking demand, increased by ½ percent per year, with additional demand from future development projects, was considered the future baseline condition. This is outlined in Table 8-8 of Chapter 8 of the EA (see page 8-18). To analyze the effect of the Renaissance Square Project on parking conditions, the additional visitors anticipated to be drawn to the Project Site as a result of the Project were added to the analysis. These included new students, faculty, and staff at MCC beyond those present at MCC today, new employees and visitors to the transit center, and patrons attending performances at the PAC. The increase in parking demand and effects on parking utilization are summarized in Table 8-9 of the EA (see page 8-19). The analysis concludes that 225 parking spaces will remain available during the weekday peak period upon completion of the Preferred Alternative. The demand for parking in the study area is highest during the weekday peak period and is substantially lower in the evening, meaning that even more spaces will be available in the study area during performances at the Performing Arts Center. Comment 51: The owners of the Alliance Building, Chase Tower, and Clinton Square have reported that their efforts to fill vacant office space are stymied by the current lack of proximate parking in the Main and Clinton area. (Zimmer-Meyer) A-30 Attachment A: Summary of Comments and Responses Response: The parking analysis presented in the EA was based on surveys of existing facilities and projected future development in Downtown Rochester, and the conclusions of the parking assessment do not support this assertion. As described in response to the previous comment, the analysis presented in the EA concluded that in the future with completion of the Preferred Alternative, 225 off-street parking spaces will remain available during the weekday peak period within the parking study area. Comment 52: Moving the RTS bus transfer function into the new transit center will permit much needed changes, which might include the addition of on-street parking (as many as 300 new on-street spaces on Main Street alone). (Zimmer-Meyer) Response: Comment noted. As noted in Chapter 8 of the EA (see page 8-19), the removal of bus layover positions from East Main Street, St. Paul Street, and North Clinton Avenue could facilitate changes in parking restrictions on those roadways. MCDOT and the City of Rochester could allow for on-street parking on these roadways once the Preferred Alternative is operational. However, to be conservative, these new parking spaces were not included in the quantitative analysis of parking that was conducted for the EA. Even without these additional spaces, the analysis in the EA concludes that no significant adverse impact to parking conditions would result from the Project and that an estimated 225 off-street parking spaces will remain available during the weekday peak period within the parking study area. AIR QUALITY Comment 53: The EA’s failure to include data on the actual number of buses that will use the bus station or how they will access the bus station has air pollution implications. The enormous fumes from the buses will pollute the air, which presents a health problem. (Haney, Maurer, Roberson) Response: The traffic and air quality impact assessments in the EA fully accounts for existing and future bus operations in Downtown Rochester., and conclude that the Project will not result in significant adverse traffic or air quality impacts. As described in response to Comment 41 above, the bus transit center will serve a total of 1,213 RTS buses daily (over a 24-hour period), with a maximum of 114 buses in the AM peak hour. No increase to the number of buses in Downtown Rochester is proposed: this is the same number of buses that currently uses the curb lanes of Main Street, Clinton Avenue, and St. Paul Street as their hub (see also page 9-3 in Chapter 9 of the EA, “Air Quality”). The only change that will result with the Project is the small changes to bus routes that will be required to shift the buses one block north of Main Street into the transit center. The EA includes an air quality analysis in Chapter 9, “Air Quality.” That analysis reflects the traffic conditions anticipated once the buses have been rerouted to A-31 Attachment A: Summary of Comments and Responses enter and exit the transit center, rather than laying over on East Main Street. The air quality analysis was prepared in accordance with procedures set forth in the New York State Department of Transportation’s (NYSDOT) Environmental Procedures Manual. Based on NYSDOT’s criteria, a detailed analysis of mobile source air quality was not required for the EA (refer to pages 9-2 and 9-3 of the EA), indicating that no potential for significant adverse air quality impacts will result because of the Project. The analysis also notes that the Project will reduce the concentrations of particulate matter on the sidewalks near the Project Site, since buses will no longer idle along the curbside adjacent to the sidewalks (see page 9-3), and it notes that RGRTA’s ongoing procurement program will result in the continued replacement of the existing diesel bus fleet with ultra-low sulfur diesel fuel-powered buses (see page 9-3). Overall, the analysis concludes that no significant adverse impact on air quality will result from the Project. Comment 54: The constant dieseling of buses will bring on a level of particulate pollution that has never been tested. Why would a theatergoer or a student want to be breathing in fumes? There is no air treatment in the plans for the bus station, and there is no provision to remedy or reduce the level of the pollutants for the air quality in the adjacent buildings. (Woodward) Response: As noted in response to Comment 53, the Preferred Alternative will not increase bus operations within Downtown, but rather will relocate bus layover positions from the curbside lanes of Main Street, St. Paul Street, and North Clinton Avenue to the new bus transit center nearby. The theater, MCC, and the waiting areas within the transit center will be fully enclosed. Within the busway, doors will separate the waiting area from the bus layover spaces. The busway itself will not be fully enclosed and bus emissions will be naturally ventilated, much like the ventilation of buses in the current curbside layover operations of RTS. Furthermore, RTS continues to modernize its fleet with low emissions, clean fuel buses. NOISE AND VIBRATION Comment 55: The buses’ honking horns will be a problem. (Roberson) Response: Noise from the buses will not be a problem. As noted in response to Comment 53, the Preferred Alternative will not increase bus operations within Downtown, but rather will relocate bus layover positions from the curbside to the new bus transit center nearby. The Preferred Alternative’s multi-use building is being designed and constructed to meet the needs of its tenants, so that the operations of buses at the transit center can be accommodated without disrupting Monroe Community College and the Performing Arts Center. A-32 Attachment A: Summary of Comments and Responses CONSTRUCTION IMPACTS Comment 56: Construction of the Renaissance Square Project will create over 3,700 construction-related jobs. (Leary) Response: Comment noted. The construction-related economic benefits of the Project are described in the EA in Chapter 14, “Construction Impacts.” As described there (see pages 14-2 and 14-3), the construction of the Project is projected to result in a total of 907 jobs on the Project Site and another 801 off-site jobs. PROCESS, AGENCY COORDINATION, AND PUBLIC PARTICIPATION Comment 57: A new EA should be prepared that directly addresses the true costs of the Project to the taxpayer, to the bus system’s uses, to downtown pedestrians, and to the community college (which will be surrounded by excessively heavy bus traffic). To continue to proceed without adequately addressing these and many other concerns raised at the January 8 public meeting, after fully informing the public as to what the true costs and impact of the project are, is to continue in an essentially fraudulent manner. (Stainton) Response: A new EA is not necessary. The published EA was prepared in compliance with requirements of NEPA and the New York State Environmental Quality Review Act (SEQRA) and fully discloses the potential environmental effects of the Preferred Alternative in accordance with federal, state, and local criteria. It includes an assessment of the Project’s economic and fiscal impacts (see pages 4-6 through 4-8 of the EA), effects on bus operations and pedestrian conditions (see Chapter 8, “Transportation”), and noise impacts on sensitive land uses including Monroe Community College (see pages 10-2 and 10-4). The public comments have been responded to in this document and have been considered by the Federal Transit Administration and RGRTA as part of their statement of findings, which is consistent with the requirements of NEPA and SEQRA. A-33