Technical Memorandum
Date: December 21, 2023
To: Ms. Karly Kaufman, Rincon Consultants, Inc.
From: At van den Hout
Subject: Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel
Introduction
Hexagon Transportation Consultants, Inc. has completed an analysis to evaluate the transportation impact of the Palo Alto Housing Element Update on intersection level of service (LOS) and on transit-, bicycle-, and pedestrian travel. The proposed Housing Element would amend the City of Palo Alto’s 2030 Comprehensive Plan by replacing the current Housing Element with the proposed 2023-2031 Housing Element. In addition to evaluating these metrics for the Housing Element, these measurements for Scenario 6 of the City’s Comprehensive Plan were also analyzed.
Intersection Level of Service
The same intersections included in the transportation section of the Comprehensive Plan were studied. The intersections were evaluated by generating turning movement volumes with the updated Palo Alto Travel Forecasting Model (Palo Alto model) and then using those volumes in the TRAFFIX software to determine the intersection’s LOS under each scenario. Intersection LOS was analyzed for the following scenarios:
• Existing Conditions: This scenario presents the same existing traffic conditions reported in the Palo Alto Comprehensive Plan Update: Analysis of Additional Scenarios, dated January 23, 2017. • Comprehensive Plan (2030) Conditions: This scenario includes the proposed land uses assumed for Scenario 6 reported in Palo Alto Comprehensive Plan Update: Analysis of Additional Scenarios, dated January 23, 2017. The traffic volumes were developed with the old Palo Alto Model created in 2013. Scenario 6 contains 6,000 additional housing units and 8,868 new jobs. • Comprehensive Plan (2031) Conditions: This scenario also includes the proposed land uses assumed for Scenario 6 of Palo Alto’s Comprehensive Plan. The traffic volumes were developed with the updated Palo Alto Model created in 2023. Scenario 6 contains the same 6,000 additional housing units and 8,868 new jobs.
• Housing Element (2031) Conditions: This scenario includes the proposed land uses assumed in the 2023-2031 Housing Element. The Housing Element has 6,860 additional housing units. The housing opportunity sites include approximately 500,000 square feet of existing commercial development that would be demolished and replaced with new housing. The 500,000 square feet of commercial development, which is equivalent to about 1,643 jobs, were removed from the land use database, resulting in a net increase of 7,225 new jobs.
Study Intersections
The 18 intersections included in the analysis are listed below and shown on Figure 1. These intersections were selected by City staff as a reasonable representation of Palo Alto’s road network by incorporating major streets in different parts of the city.
Alma St
Bryant St
Cowper St
El Camino Real
Page Mill Rd
Park Blvd
Oregon Expy
Foothill Expy
Middlefield Rd
Stanford Ave
San Antonio Rd
University Ave
Junipero Serra Blvd
E Bayshore Rd
Ramona St
Loma Verde Ave
E Charleston Rd
Embarcadero Rd
Palm Dr
Hanover St
E Meadow Dr
Colorado Ave
Arastradero Rd
Sand Hill Rd
S California Ave
Channing Ave
Los Robles Ave
Mountain View
Palo
Alto
Menlo Park
18 17
12 10
9 1
8 7
4 3
2 6
16 5
15 13
11 14
280
101
82 X = Study Intersection
LEGEND
Palo Alto Housing Element
Figure 1
Study Intersections
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 3
1. I-280 Northbound Off-Ramp and Sand Hill Road (Menlo Park)
2. Middlefield Road and Charleston Road
3. Middlefield Road and San Antonio Road (CMP)
4. Alma Street and Charleston Road
5. El Camino Real (SR 82) and Embarcadero Road/Galvez Road (CMP)
6. El Camino Real (SR 82) and Page Mill Road/Oregon Expressway (CMP)
7. El Camino Real (SR 82) and Arastradero Road/Charleston Road (CMP)
8. El Camino Real (SR 82) and San Antonio Road (CMP; Mountain View)
9. Foothill Expressway/Junipero Serra Boulevard and Page Mill Road (CMP)
10. Foothill Expressway and Arastradero Road (CMP)
11. El Camino Real (SR 82) and Sand Hill Road/Alma Street (CMP)
12. Charleston Road and San Antonio Avenue (CMP)
13. University Avenue & El Camino Real, northbound ramps (CMP)
14. University Avenue/Palm Drive & El Camino Real, southbound ramps (CMP)
15. Middlefield Road and University Avenue
16. Middlefield Road and Embarcadero Road
17. Middlefield Road and Oregon Expressway (CMP)
18. Embarcadero Road and East Bayshore Road
Traffic conditions at the study intersections were analyzed for the weekday AM and PM peak hours of traffic. The AM peak hour of traffic is generally between 7:00 and 9:00 AM, and the PM peak hour is typically between 4:00 and 6:00 PM. It is during these periods that the most congested traffic conditions occur on an average day.
Vehicle Level of Service (LOS) is a qualitative description of operating conditions ranging from LOS A, or free-flow conditions with little or no delay, to LOS F, or jammed conditions with excessive delays. The VTA CMP guidelines dictate using the 2000 Highway Capacity Manual (HCM) methodology to analyze intersections. Palo Alto uses the same process for its intersections. The 2000 HCM operations method evaluates signalized intersection operations on the basis of average control delay time for all vehicles at the intersection. This method is applied using the TRAFFIX software. Since TRAFFIX is also the CMP-designated intersection level of service evaluation software, the City of Palo Alto employs the CMP default values for the analysis parameters.
The City of Palo Alto’s LOS standard for signalized non-CMP intersections is LOS D or better. For CMP intersections, the City’s standard is LOS E or better. The LOS definitions for signalized intersections are shown in Table 1. Levels of Service D and E are typical at intersections in many urban areas where a high volume of vehicles pass through an intersection physically constrained by adjacent existing structures.
City of Palo Alto Definition of Adverse Intersection Operational Effects Adverse operational effects on signalized intersections are based on the City of Palo Alto and CMP level of service standards. According to the City of Palo Alto and CMP level of service standards, a development is said to create an adverse operational effect on traffic conditions at a signalized intersection if for either peak hour, one of the following conditions occurs:
1. The level of service at the intersection drops below its respective level of service standard (LOS D or better for local intersections and LOS E or better for CMP intersections) when project traffic is added, or
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 4
2. An intersection that operates below its level of service standard under no-project conditions experiences an increase in critical-movement delay of four (4) or more seconds, and an increase in critical volume-to-capacity ratio (v/c) of one percent (0.01) or more when project traffic is added.
The exception to this threshold is when the addition of project traffic reduces the amount of average control delay for critical movements. In this case, the threshold is when the project increases the critical v/c value by 0.01 or more.
City of Menlo Park Definition of Adverse Intersection Operational Effects The intersection of I-280 Northbound Off-Ramp and Sand Hill Road (#1) is located in Menlo Park.
The following thresholds are from the City of Menlo Park’s TIA Guidelines, and compliance with local policies was evaluated based on these thresholds.
1. A project is considered potentially noncompliant with local policies if the addition of project traffic causes an intersection on a collector street operating at LOS “A” through “C” to operate at an unacceptable level (LOS “D,” “E” or “F”) or have an increase of 23 seconds or greater in average vehicle delay, whichever comes first. Potential noncompliance shall also include a project that causes an intersection on arterial streets or local approaches to State controlled signalized intersections operating at LOS “A” through “D” to operate at an unacceptable level (LOS “E” or “F”) or have an increase of 23 seconds or greater in average vehicle delay, whichever comes first.
2. A project is also considered potentially non-compliant if the addition of project traffic causes an increase of more than 0.8 seconds of average delay to vehicles on all critical movements for intersections operating at a near-term LOS “D” through “F” for collector streets and at a near-term LOS “E” or “F” for arterial streets. For local approaches to State controlled signalized intersections, a project is considered to be potentially non-compliant if the addition of project traffic causes an increase of more than 0.8 seconds of delay to vehicles on the most critical movements for intersections operating at a near-term LOS “E” or “F.”
For signalized intersections involving two state routes, the proposed project is considered potentially non- compliant with local policies if for any peak hour:
1. The level of service degrades from an acceptable LOS D or better under existing conditions to an unacceptable LOS E or F under existing plus project conditions, and the average delay per vehicle increases by four seconds or more, or
2. The level of service is an unacceptable LOS E or F under existing conditions, and the addition of project trips causes an increase in the average control delay at the intersection by four seconds or more.
City of Mountain View Definition of Adverse Intersection Operational Effects The intersection of El Camino Real (SR 82) and San Antonio Road is located in Mountain View (#8). Adverse operational effects at signalized intersections are based on the City of Mountain View’s level of service standards. A development is said to create an adverse operational effect on traffic conditions at a signalized intersection if for either peak hour, one of the following conditions occurs:
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 5
1. The level of service at the intersection drops below its respective level of service standard (LOS D or better for all local intersections and LOS E or better for CMP and expressway intersections) when project traffic is added, or
2. An intersection that operates below its level of service standard under no-project conditions experiences an increase in critical-movement delay of four (4) or more seconds, and an increase in critical volume-to-capacity ratio (v/c) of one percent (0.01) or more when project traffic is added.
The exception to this threshold is when the addition of project traffic reduces the amount of average control delay for critical movements, i.e., the change in average control delay for critical movements is negative. In this case, the threshold is when the project increases the critical v/c value by 0.01 or more.
Table 1
Signalized Intersection Level of Service Definitions Based on Average Control Delay
Source: Transportation Research Board, 2000 Highway Capacity Manual (Washington, D.C., 2000), p.10-16.
Level of
Service Description
Average Control
Delay Per
Vehicle (sec.)
Signal progression is extremely favorable. Most vehicles arrive during the green phase and do not stop at all. Short cycle lengths may also contribute to the very low vehicle delay.
10.0 or lessA
B
Operations characterized by good signal progression and/or short cycle lengths. More vehicles stop than with LOS A, causing higher levels of average vehicle delay.
10.1 to 20.0
Higher delays may result from fair signal progression and/or longer cycle lengths. Individual cycle failures may begin to appear at this level. The number of vehicles stopping is significant, though some vehicles may still pass through the intersection without stopping.
20.1 to 35.0C
This level of delay is considered unacceptable by most drivers. This condition often occurs with oversaturation, that is, when arrival flow rates exceed the capacity of the intersection. Poor progression and long cycle lengths may also be major contributing causes of such delay levels. greater than 80.0F
The influence of congestion becomes more noticeable. Longer delays may result from some combination of unfavorable signal progression, long cycle lengths, or high volume-to-capacity (V/C) ratios. Many vehicles stop and individual cycle failures are noticeable.
35.1 to 55.0D
This is considered to be the limit of acceptable delay. These high delay values generally indicate poor signal progression, long cycle lengths, and high volume-to-capacity (V/C) ratios. Individual cycle failures occur frequently.
55.1 to 80.0E
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 6
Intersection Level of Service Results
The results of the LOS analysis are summarized in Table 2. The Table shows the LOS results for the Existing, 2030 Comprehensive Plan (CP), 2031 Comprehensive Plan (CP), and the 2031 Housing Element Update (HEU). The level of service analysis under existing conditions shows that, relative to the city of Palo Alto and Santa Clara County Congestion Management Program (CMP) level of service standards, all intersections except the intersection of I-280 northbound ramps and Sand Hill Road (#1) are operating at acceptable levels of service. The intersection of I-280 NB Ramps/Sand Hill Road operates at LOS F, which is below the LOS standard, with 114.5 seconds of average delay during the AM peak hour. The intersection of Foothill Expressway and Page Mill Road (#9), which is a CMP intersection, operates at LOS F with 189.7 seconds of average delay during the PM peak period. This LOS F is below the Palo Alto and CMP standard.
Table 2
AM and PM Peak Hour Level of Service Results at Study Intersections
Avg. Avg. Avg. Avg.
Peak Delay Crit. Delay Crit. Delay Crit. Delay Crit.
# Intersection Hour (sec) LOS V/C (sec) LOS V/C (sec) LOS V/C (sec) LOS V/C 1 AM 114.5 F 1.269 162.4 F 1.454 141.1 F 1.376 142.0 F 1.379 PM 27.0 C 0.939 54.5 D 1.078 44.4 D 1.028 44.6 D 1.029
2 AM 47.6 D 0.660 49.0 D 0.701 52.7 D 0.848 51.8 D 0.844 PM 39.8 D 0.695 53.9 D 0.932 45.2 D 0.864 45.5 D 0.876
3 AM 48.9 D 0.668 49.1 D 0.727 52.4 D 0.808 52.8 D 0.814 PM 39.0 D 0.789 42.6 D 0.879 46.2 D 0.884 46.8 D 0.883
4 AM
PM
5 AM 46.1 D 0.729 57.7 E 0.908 52.0 D 0.849 52.8 D 0.871 PM 42.5 D 0.824 70.9 E 1.055 54.4 D 0.962 54.2 D 0.963
6 AM 62.7 E 0.819 67.6 E 0.880 72.8 E 0.956 71.7 E 0.948 PM 52.4 D 0.910 77.8 E 1.078 71.5 E 1.036 69.2 E 1.029
7 AM 35.3 D 0.663 37.5 D 0.756 43.3 D 0.880 43.7 D 0.888 PM 47.7 D 0.841 63.3 E 0.993 62.8 E 0.994 65.4 E 1.007
8 AM 40.5 D 0.768 48.9 D 0.905 49.8 D 0.933 50.8 D 0.942 PM 54.0 D 0.816 94.2 F 1.077 63.9 E 0.928 64.8 E 0.931
9 AM 55.7 E 0.909 69.7 E 0.993 69.6 E 0.994 69.6 E 0.995 PM 189.7 F 1.064 306.4 F 1.182 287.6 F 0.918 285.2 F 1.151 10 AM 48.7 D 0.276 51.1 D 0.481 50.8 D 0.463 50.7 D 0.463 PM 57.0 E 0.849 133.5 F 1.280 90.8 F 1.105 93.6 F 1.118 11 AM 22.7 C 0.452 23.0 C 0.534 23.2 C 0.509 23.5 C 0.510 PM 36.5 D 0.651 38.3 D 0.836 37.1 D 0.720 36.9 D 0.717
12 AM 48.4 D 0.729 51.3 D 0.814 55.4 E 0.843 55.9 E 0.857 PM 42.0 D 0.844 44.0 D 0.859 58.3 E 1.006 62.6 E 1.030
13 AM 22.5 C 0.666 34.0 C 0.887 24.5 C 0.755 23.7 C 0.732 PM 32.4 C 0.619 33.6 C 0.815 33.1 C 0.645 33.3 C 0.637
14 AM 20.9 C 0.424 19.2 B 0.534 21.7 C 0.483 22.1 C 0.483 PM 24.9 C 0.487 22.3 C 0.566 26.8 C 0.549 27.3 C 0.554
15 AM 27.0 C 0.609 29.5 C 0.746 34.0 C 0.767 33.9 C 0.763 PM 27.5 C 0.512 28.2 C 0.670 30.0 C 0.617 30.4 C 0.635
16 AM 50.3 D 0.583 62.9 E 0.828 67.5 E 0.852 65.5 E 0.835 PM 36.6 D 0.607 40.0 D 0.758 43.8 D 0.775 44.0 D 0.783
17 AM 42.8 D 0.754 57.9 E 0.899 74.3 E 1.054 78.4 E 1.075 PM 42.9 D 0.688 64.5 E 0.907 67.2 E 0.928 68.8 E 0.947
18 AM 31.6 C 0.682 56.4 E 0.929 31.0 C 0.739 31.4 C 0.767 PM 40.3 D 0.702 52.3 D 0.892 51.8 D 0.878 52.3 D 0.879
Notes:
* Denotes CMP intersection
BOLD indicates substandard level of service
BOLD indicates noncompliance based on thresholds in the City of Menlo Park's TIA Guidelines, or adverse operational effects according to Cities of Mountain View and Palo Alto level of service standards.
Existing
2030
Comprehensive
Plan (CP)
2031
Comprehensive
Plan (CP)
2031 Housing
Element Update
(HEU)
Embarcadero Rd & E. Bayshore Rd
San Antonio Rd & Charleston Rd *
El Camino Real NB Ramps & University Ave *
Middlefield Rd & Charleston Rd
Middlefield Rd & San Antonio Rd *
Alma St & Charleston Rd
El Camino Real & Embarcadero Rd/Galvez St *
El Camino Real & Page Mill Rd/Oregon Expy *
El Camino Real & Arastradero Rd/Charleston Rd *
This intersection is the subject of a separate study
El Camino Real & San Antonio Rd (Mtn View)*
Foothill Expy/Junipero Serra Blvd & Page Mill Rd *
Foothill Expy & Arastradero Rd *
El Camino Real & Alma St/Sand Hill Rd *
I-280 NB Off-Ramp & Sand Hill Rd (Menlo Park)
El Camino Real SB Ramp & University Ave/Palm Dr *
Middlefield Rd & University Ave
Middlefield Rd & Embarcadero Rd
Middlefield Rd & Oregon Expressway *
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 7
As shown in Table 2, most intersections are projected to have longer average delays under future conditions than under Existing Conditions. Intersection traffic operations between the 2031 CP and the 2031 HEU are projected to be very similar, which was expected since the future development assumptions are similar. While the 2031 HEU includes 686 more housing units, it also assumes 500,000 square feet less commercial development. The 500,000 square feet of commercial development would be demolished and replaced with housing. Therefore, the 2031 HEU would generate more housing trips but fewer commercial trips. The following summarizes the number of intersections that would have a substandard LOS in at least one of the peak hours:
• Existing: 2 intersections
• 2030 Comp Plan: 6 intersections
• 2031 Comp Plan: 4 intersections
• 2031 HEU Plan: 4 intersections
Compared to the traffic analysis conducted for the 2030 Comprehensive Plan, based on the new forecasts, the El Camino Real (SR 82) and San Antonio Road (#8) and the intersection of Embarcadero Road and East Bayshore Road (#18) would no longer cause an adverse operational effect on traffic conditions under the 2031 Comprehensive Plan and 2031 HEU scenario. These intersections would continue to operate at acceptable conditions. The following Intersections would have an adverse operational effect on traffic conditions in all future scenarios during at least one peak hour.
• I-280 Northbound Off-Ramp and Sand Hill Road (#1)
• Foothill Expressway/Junipero Serra Boulevard and Page Mill Road (CMP) (#9) • Foothill Expressway and Arastradero Road (CMP) (#10)
• Middlefield Road and Embarcadero Road (#16)
The City of Palo Alto’s 2030 Comprehensive Plan identified mitigation measures to improve traffic operations at these intersections. These transportation improvements were found to be unfeasible, and the impacts were determined to be significant and unavoidable. However, some mitigation measures included in the Comprehensive Plan Update that could not be addressed with the Palo Alto model would help in reducing the traffic impact for the identified intersections.
Impact on Transit Ridership
The Palo Alto model was used to forecast transit trips under existing conditions and under each future scenario. Table 3 presents the number of boardings made on different transit service providers and the number of transit trips that begin and/or end in Palo Alto, i.e., trips entirely within Palo Alto, trips that start in Palo Alto and end in another jurisdiction, and trips that begin in another jurisdiction and end in Palo Alto.
The table shows that the total transit boardings for the 2031 Comprehensive Plan and the 2031 HEU are projected to be 8,690 and 9,126 fewer than the boardings forecasted for the 2030 Comprehensive Plan, respectively. These changes in future transit ridership are attributable to several factors, primarily the updates made to the Palo Alto model and also revisions to the regional land use and demographic forecasts made by ABAG, resulting in different travel patterns and changes in the mode of travel.
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 8
Table 3
Existing (2015) and Future Daily Transit Boardings, Trips To, From, and Within Palo Alto
The 2030 Comprehensive Plan concluded that none of the future scenarios would increase demand beyond the current or planned capacity of the transit network. Since transit ridership for the 2031 HEU and for the 2031 Comprehensive Plan is less than for the 2030 Comprehensive Plan, the 2031 HEU would not cause a potential impact related to the transit system.
Impact on Bicycle and Pedestrian Travel
Mode share refers to the percentage of trips made by each of the primary modes of transportation: Driving Alone, Shared Ride, Taking Transit, Bicycling, and Walking. The Palo Alto model calculates the mode split based on input factors taken from survey data or other sources that have been validated. Table 4 presents the total number of daily person trips made in Palo Alto under existing conditions and under each of the planning scenarios. The table includes all trips beginning and/or ending in Palo Alto, i.e., trips that start and end in Palo Alto, trips that begin in Palo Alto and end in another jurisdiction, and trips that start in another jurisdiction and end in Palo Alto.
Table 4
Mode Share for Palo Alto Daily Person Trips
Transit Service 2015
Existing
2030
Comprehensive
Plan
2031
Comprehensive
Plan
2031
Housing
Element
CalTrain 12,767 24,061 22,928 23,066
VTA Bus 6,700 17,151 13,056 13,645
VTA LRT 610 1,958 1,733 1,875
SamTrans 2,056 5,188 3,736 3,525
Stanford Shuttles 7,418 10,628 13,686 13,298
CalTrain Shuttles 3,477 7,231 8,027 8,142
Palo Alto Shuttles 1 1,937 3,519 - -
BART, Muni and Other 5,199 9,900 7,344 7,395
Total 40,164 79,636 70,510 70,946
Transit Trips 25,478 50,560 42,851 42,339
Boardings/Trip 1.58 1.58 1.65 1.68
1 Palo Alto shuttle service was discontinued in 2020.
Mode Trips % Share Trips % Share Trips % Share Trips % Share Drive Alone 324,513 58.7% 379,739 58.5% 357,039 56.1% 360,774 56.3% Shared Ride 130,437 23.6% 142,710 22.0% 148,056 23.3% 151,628 23.6% Transit 25,478 4.6% 50,560 7.8% 42,851 6.7% 42,339 6.6% Bike 26,717 4.8% 20,927 3.2% 33,278 5.2% 32,876 5.1%
Walk 45,535 8.2% 55,537 8.6% 55,288 8.7% 53,655 8.4%
TOTAL 552,680 100.0% 649,474 100.0% 636,512 100.0% 641,273 100.0% 2031 HEU2031 CompExisting 2030 Comp
Palo Alto Housing Element: Impact on Level of Service, Transit, Bike, and Pedestrian Travel December 21, 2023 P a g e | 9
The table shows slightly lower drive-alone and transit mode shares, but higher shared-ride shares for the 2031 Comprehensive Plan and the 2031 HEU compared to the 2030 Comprehensive Plan. The model estimated a significant increase in bike mode shares compared to the 2030 Comprehensive Plan. This increase is primarily caused by the updates made to the Palo Alto model, which was recalibrated against more recent data that showed higher bicycle travel within the City of Palo Alto. Note that the walk and bike mode shares for the 2031 HEU are slightly lower than for the 2031 Comprehensive Plan because most of the residential growth of the Comprehensive Plan is planned in the downtown area and along El Camino Real, while most of the HEU development is located near US-101, which is further away from complementary land uses such as shopping, dining, and socializing, and that area has poorer access to transit service and bike facilities.
The Comprehensive Plan concluded that none of the scenarios would impede the development or function of planned pedestrian or bicycle facilities and that it assumed the implementation of all improvements included in the City’s Bicycle + Pedestrian Transportation Plan. Although the model showed that the 2031 HEU would increase the number of bicycle trips by about 11,950 (or 57 percent) compared to the 2030 Comprehensive Plan, the HEU would not create more demand than could be met by existing or planned facilities. Planned infrastructure improvements such as upgrades to existing grade-separated Caltrain crossings at California Avenue and University Avenue to improve pedestrian and bicycle facilities, as well as a new pedestrian/bicycle, grade-separated Caltrain crossing in South Palo Alto and grade separation of all Caltrain crossings, would improve the quality and safety of bicycle and pedestrian travel significantly. In addition, the City would continue to implement its adopted Bicycle + Pedestrian Transportation Plan, and concept area plans in the California Avenue area would guide new bicycle and pedestrian improvements.
Bicycle and pedestrian facilities will continue to be upgraded to current accessibility and design standards in accordance with policies in the Bicycle + Pedestrian Transportation Plan and in the Comprehensive Plan Update.