HomeMy WebLinkAboutPC Reso 13-32 Dublin Crossing Cert of FEIR Dublin Crossing rec to CC RESOLUTION NO. 13- 32
A RESOLUTION OF THE PLANNING COMMISSION
OF THE CITY OF DUBLIN
RECOMMENDING CITY COUNCIL CERTIFICATION OF A FINAL ENVIRONMENTAL
IMPACT REPORT AND ADOPTION OF ENVIRONMENTAL FINDINGS UNDER CEQA FOR
THE DUBLIN CROSSING SPECIFIC PLAN
PA 08-049
WHEREAS, the Applicant, Dublin Crossing LLC (SunCal Companies) has submitted a
Planning Application to enable private development on approximately 189 acres of property that
is currently part of the Camp Parks Reserve Forces Training Area. The proposal includes the
approval of the Dublin Crossing Specific Plan, General Plan Amendments, Zoning Ordinance
Amendments, Rezoning properties to a new Dublin Crossing Zoning District, and consideration
of a Development Agreement and certification of an Environmental Impact Report, among other
related actions. These planning and implementing actions are collectively known as the "Dublin
Crossing Specific Plan Project" or the "Project"; and
WHEREAS, the Dublin Crossing Specific Plan (DCSP) project area is approximately
189 acres in size and is generally bound by 5th Street to the north, Scarlett Drive to the
west, Dublin Boulevard to the south, and Arnold Road to the east. The Project Area
includes properties identified by Assessor Parcel Numbers 986-0001-001-15 (partial), 986-
0034-002-00, and 986-0034-006-00; and
WHEREAS, the California Environmental Quality Act (CEQA), together with the State
guidelines and City environmental regulations require that certain projects be reviewed for
environmental impacts and that environmental documents be prepared. It was determined that
an Environmental Impact Report (EIR) be prepared to analyze the Dublin Crossing Specific Plan
Project; and
WHEREAS, the City circulated a Notice of Preparation, dated June 4, 2012, to public
agencies and interested parties for consultation on the scope of the EIR. The City also
conducted a public scoping meeting on June 20, 2012; and
WHEREAS, the City prepared a Draft Environmental Impact Report (EIR) dated June
2013 for the proposed Project that reflected the City's independent judgment and analysis of the
potential environmental impacts of the Project. The Draft EIR is incorporated herein by
reference; and
WHEREAS, the Draft EIR was circulated for public review from June 24, 2013 to August
8, 2013 (45 days); and
WHEREAS, the City received comment letters from State, regional, and local agencies
as well as interested individuals and organizations during the public review period. In
accordance with the requirements of CEQA, the City prepared written responses to all the
comments received during the public comment period. The City prepared a Final EIR (that
includes the Responses to Comments), dated October 2013, for the proposed Project, which
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included an annotated copy of each comment letter identifying specific comments, responses to
each specific comment, and clarifications and minor corrections to information presented in the
Draft EIR. The Final EIR is attached as Exhibit A to this Resolution and is incorporated herein
by reference (Exhibit A also contains the complete EIR — Draft EIR, Appendices, and Final EIR
combined — on a CD within the document). The complete Dublin Crossing Specific Plan EIR
incorporates the Draft EIR and the Final EIR together. The responses to comments provide the
City's good faith, reasoned analysis of the environmental issues raised by the comments; and
WHEREAS, the City carefully reviewed the comments and written responses and
determined that the Final EIR, including the clarifications and minor corrections to the Draft EIR,
do not constitute significant new information requiring recirculation of the Draft EIR under the
standards in CEQA Guidelines section 15088.5; and
WHEREAS, a Staff Report, dated October 22, 2013 and incorporated herein by
reference, described and analyzed the Project for the Planning Commission and contained
information on the Final EIR; and
WHEREAS, the Planning Commission reviewed the Staff Report, the Final EIR, including
comments and responses, at a noticed public hearing on October 22, 2013 at which time all
interested parties had the opportunity to be heard; and
WHEREAS, the Final EIR, including comments and responses, reflects the City's
independent judgment and analysis on the potential for environmental impacts from the Project;
and
WHEREAS, the Final EIR identified several potentially significant impacts that will be
reduced to a less than significant level with specified mitigation measures. Approval of the
project by the City Council will therefore require adoption of findings on impacts and mitigations
and a Mitigation Monitoring and Reporting Program; and
WHEREAS, the Final EIR/EIS identified significant and unavoidable environmental
impacts of the project and approval of the project by the City Council will therefore require
adoption of Findings and a Statement of Overriding Considerations: and
WHEREAS, the Final EIR and all of the documents relating to the Project are available
for review in the City Planning Division at the Dublin City Hall, file PA 08-049, during normal
business hours. The location and custodian of the Final EIR and other documents that
constitute the record of proceedings for the Project is the City of Dublin Community
Development Department, 100 Civic Plaza, Dublin, CA 94568, file PA 08-049.
NOW, THEREFORE, BE IT RESOLVED THAT, the Dublin Planning Commission hereby
makes the following findings and recommendations to the City Council on the Final EIR and the
environmental review of the Project under CEQA:
A. The foregoing recitals are true and correct and made a part of this resolution.
B. The Final EIR has been completed in compliance with CEQA, the CEQA Guidelines and
the City of Dublin Environmental Guidelines.
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C. The Planning Commission has independently reviewed and considered the information
contained in the Final EIR, including the written comments received during the Draft EIR
review period and the oral and written comments received at the public hearing, prior to
making its recommendation on the proposed Project.
D. The Final EIR reflects the City's independent judgment and analysis on the potential
environmental impacts of the proposed Project. The Final EIR provides information to
the decision-makers and the public on the environmental consequences of the proposed
Project.
E. The Final EIR adequately describes the proposed Project, its significant environmental
impacts, mitigation measures and a reasonable range of alternatives to the proposed
Project.
BE IT FURTHER RESOLVED the Dublin Planning Commission hereby recommends
that, prior to the approval of the Project, the City Council certify the Final Environmental Impact
Report as complete, adequate and in compliance with CEQA, the CEQA Guidelines, and the
City of Dublin Environmental Guidelines. The Planning Commission further recommends that
the City Council make all required, mitigation and alternatives findings, adopt a Statement of
Overriding Considerations, and adopt a Mitigation Monitoring and Reporting Program, all in
compliance with the requirements of CEQA.
PASSED, APPROVED, AND ADOPTED this 22nd day of October, 2013 by the following
vote:
AYES: O'Keefe, Bhuthimethee, Do, Goel, Kohli
NOES:
ABSENT:
ABSTAIN:
`Ria ing Commission Chair
ATTEST:
Assistan Co nity Development Director
G:1PA#120081PA 08-049 Camp Parks Dublin Crossing12011 RestartlPC Mtg 10.22.20131PC Att 8-Reso FEIR.docx
2185663.1
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DUBLIN
CROSSING
SPECIFIC PLAN
FINAL
ENVIRONMENTAL
IMPACT REPORT
OCTOBER 2013
Dublin Crossing Specific Plan
Final Environmental Impact Report SCH # 2012062009 Prepared for
City of Dublin Prepared by
October 2013
Dublin Crossing Specific Plan Final EIR
Page 1
Introduction The Draft Program Environmental Impact Report was circulated for a 45-day public review period from Monday, July 24, 2013 through Thursday, August 8, 2013, as assigned by the State of California Governor’s Office of Planning and Research State Clearinghouse and consistent with CEQA regulations. Copies of the document were distributed to state, regional, and local agencies, as well as organizations and individuals, for their review and comment. This document has been prepared in accordance with CEQA and state and local CEQA Guidelines and represents the independent judgment of the Lead Agency. This Response to Comments volume, together with the DEIR, technical appendices, and other written documentation prepared during the EIR process, as those documents may be modified by the City Council at the time of certification, will constitute the Final EIR, as defined in the State CEQA Guidelines, Section 15132, and the City of Dublin’s environmental document reporting procedures.
Document Organization and Framework This Response to Comments package is organized as follows: Section 1 provides a brief introduction to this report. Section 2 provides a list of agencies and interested persons commenting on the DEIR. This section also contains individual comments followed thereafter by responses. To facilitate review of the responses, an index number (e.g., 1-1, 1-2, 2-1) has been assigned to each comment and to its corresponding responses. Section 3 contains revisions to the Draft EIR as a result of the comments by agencies and interested persons. The responses to comments contained in this section contain material and revisions which will be added or made to the text of the Final EIR. City Staff has reviewed this material and determined that none of this material constitutes the type of significant new information that requires a recirculation period for further public comment under CEQA Guideline Section 15088.5. None of this new material indicates that the project will result in a significant new environmental impact not previously disclosed in the DEIR. Additionally, none of this material indicates that there would be a substantial increase in the severity
Dublin Crossing Specific Plan Final EIR
Page 2
of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation as described in Section 15088.5.
CEQA Requirements Regarding Comments and Responses CEQA Guidelines Section 15204 (a) outlines parameters for submitting comments, and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be, “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated.” Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible… CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by those submitting comments. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.”
Dublin Crossing Specific Plan Final EIR
Page 1
List of Commenters on the Draft Program EIR This section includes all written responses received on the DEIR and the City’s responses to each comment. Comment letters and specific comments are given letters and numbers for reference purposes. Where sections of the DEIR are excerpted in this document, the sections are shown indented. Changes to the DEIR text are shown in underline for additions and strikeout for deletions. The following is a list of agencies and persons that submitted comments on the Recirculated Draft EIR during the public review period:
Table 2-1: List of Written Comments Received on the Draft EIR
Comment
Letter No.
Commenting Person/Agency Date of Comment 1 CA Department of Transportation (Caltrans) August 7, 2013 2 Alameda County Community Development Agency – Planning Department August 7, 2013 3 Alameda County Community Development Agency –Surplus Property Authority August 8, 2013 4 Alameda County Fire Department July 12, 2013 5 Alameda County Transportation Commission August 1, 2013 6 Alameda County Flood Control and Water Conservation District, Zone 7 August 8, 2013 7 Dublin San Ramon Services District August 7, 2013 8 Dublin Unified School District August 7, 2013 9 California Clean Energy Committee August 2, 2013 10 William M. (Tim) Neilson June 27, 2013 11 Jasmeet July 10, 2013 12 Thomas McKinney July 24, 2013 13 Thomas McKinney July 29, 2013 14 Dublin Crossing, LLC July 22, 2013
Dublin Crossing Specific Plan Final EIR
Page 1
Response to Comment Letter #1 from Mr. Erik Alm, CA Department of
Transportation, dated August 7, 2013
Response to Comment 1-1 – Trip Generation For calculating the project trip generation rates, the project land uses were added to the baseline land uses and then the model was run to evaluate the traffic impacts. In the absence of layering approach, it is not feasible to create project only trips at intersections. Please see detailed explanation on this approach on page 3-228 of the DEIR (June 2013). Turning traffic diagrams, including distribution per study intersection for all scenarios, is provided in Appendix I of the Draft EIR and is available through the City of Dublin website at: http://dublinca.gov/index.aspx?NID=202.
Response to Comment 1-2 – Highway Operations
Intersection Delays The decrease in delay of intersections under future conditions would be reduced due to existing roadway improvements that are planned by the City of Dublin and funded by transportation impact fees. The model results reflect not only changes in the land uses, but also changes to the street network over time. The reason some of the impacts are lower in future year of 2035 is due to the fact that some of the improvements to the street network are expected to come on-line between 2020 and 2035. Therefore the model shows redistribution of traffic due to these anticipated changes. Please refer to pages 3-225 to 3-234 of the Draft EIR (June 2013) for detailed description of street network changes.
Freeway Volumes The traffic volumes for the study freeway segments were developed using the Alameda County Travel Demand Forecast (TDF) model for forecast years 2020 and 2035. Because the Alameda County TDF model does not include a 2012 land use data set, the City of Dublin TDF model was used for the 2012 forecast year. For each horizon year (2012, 2020, and 2035), the proposed project was coded into the appropriate model and the output traffic volumes were reported directly from the model. There are several reasons why the study scenarios show no increase in traffic volumes on some study freeway segments. First, the proposed project would be an “infill” development, which would change the origin/destination trip pairs in the project vicinity. For example, the proposed project would include a retail component. Some of these trips are currently made from residents of Dublin to retail destinations outside of Dublin. With more local retail options, residents of Dublin are now more likely to stay in Dublin (on local streets) as opposed to using the freeway to access retail establishments outside of the area. In addition, the project includes a large residential component and is located (1) directly west of an existing industrial park in Dublin and (2) north of a large industrial park in Pleasanton. In some cases, project trips would replace
Dublin Crossing Specific Plan Final EIR
Page 2
longer home-based work trips that currently commute to/from these industrial parks from outside the area. Second, the TDF models consider the travel time of each route between origin/destination pairs, and the models will divert ambient traffic in accordance with the quickest path between origin/destination trip pairs. For example, when the project adds traffic to a freeway segment, this creates an increase in delay for existing users. As a result, some existing freeway users will change their routes because using a local street may result in a shorter net travel time. Thus, the proposed project could add traffic to a freeway segment, but the diversion of ambient traffic may result in little or no increase in the overall peak hour traffic volume. Third, the TDF models consider the lengthening of the peak commute period (commonly referred to as “peak hour spreading”). In areas that are congested (such as I-580 and I-680), TDF models will spread trips throughout the commute period, rather than just assigning them during the peak hour. This behavior is common among motorists. For example, if traffic around the project site is heavily congested during the 5:00 PM to 6:00 PM period, the model will consider the travel time for each origin/destination trip pair and move a small number of trips outside of the peak hour (to 4:50 PM instead of 5:05 PM). When all of these aspects of the TDF models are considered, the unadjusted (raw) model output showed small decreases in traffic volumes on some study roadway segments with the addition of the proposed project. In an effort to disclose the impacts of the project as conservatively as possible, decreases in baseline traffic were not permitted as part of the TDF model adjustment process. For example, if the unadjusted TDF model output showed a “no project” traffic volume on a study segment as 5,000 vehicles per hour (vph) and a “with project” traffic volume of 4,985 vph, the “with project” traffic volume was reported as 5,000 vph.
Response to Comment 1-3 – Signal Operations Copies of the Syncho files utilized in the Traffic Impact Analysis are provided in Appendix I of the Draft EIR and are available through the City of Dublin website at http://dublinca.gov/index.aspx?NID=202.
Dublin Crossing Specific Plan Final EIR
Page 3
Response to Comment Letter #2 from Mr. Albert Lopez, Alameda County
Community Development Agency – Planning Department, dated August 7, 2013
Response to Comment 2-1 – Air Quality Comment noted.
Response to Comment 2-2 – Traffic and Transportation Comment noted.
Response to Comment 2-3 – Alternatives As described in Section 15126.6(f) of the CEQA Guidelines, the range of alternatives required in an EIR is governed by the “Rule of Reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. As part of the project approval process, the City will prepare written findings (as defined by Section 15091 of the CEQA Guidelines). Possible findings include: (1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. The findings will provide the basis for selection of the proposed project or one of the alternatives, based on direction as determined by the City of Dublin City Council.
Response to Comment 2-4 – Air Quality / Greenhouse Gas Emissions Comment noted. The City will consider whether photovoltaic structures or solar water heaters are feasible mitigations to reduce air quality impacts as part of its findings in considering approval of the project. The Specific Plan land use designations for those portions of the project area that are closest to Dublin Boulevard and the BART station permit residential density up to 60 units/net acre and allow for a combination of residential and commercial uses, so the ability to construct high density residential development, as suggested by the commenter, is already being accommodated.
Chris Bazar I
Agency Directar
Stuart Cook
Dircclar
224
West Winton Ave
Room 110
Hayward
California
94544-1215
phone
510.670.5333
fax
510.670.6374
WWW.
acgov,org/cda
ALAMEDA COUNTY COMMUNITY DEVELOPMENT AGENCY
SURPLUS PROPERTY AUTHORITY
August 8,2013
Kristi Bascom, Principal Planner
City of Dublin
100 Civic Plaza
Dublin. CA 94568
RE: Dublin Crossing Specific Plan DEIR
Dear Ms. Bascom:
Thank you for the opportunity to comment on the Draft Environmental Impact Report
(DEIR) for the Dublin Crossing Specific Plan project. As you are aware, the
Alameda County Surplus Property Authority is the master developer of both the
Dublin Transit Center just to the south and the former Santa Rita property just to the
east ofthis project.
The Authority has four development sites directly across Dublin Boulevard from the
Dublin Crossing area, including two that are currently under contract with developers.
One of these sites (Site 164) is under contract with Regency Centers for a shopping
center development (the Village @ Dublin), for which a DEIR has just been released
by the City, approximately five weeks after the Dublin Crossing DEIR was published.
We are therefore concemed that the Dublin Crossing EIR accurately describe
potential impacts and adequately mitigate those impacts, and that the analysis and
proposed mitigation measures for the Dublin Crossing EIR be consistent with the
analysis and proposed mitigation measures in the Village @ Dublin EIR, especially
since the Dublin Crossing project is very similarly situated and includes a 150,000
square foot shopping center at the northwest corner of Arnold Road and Dublin
Boulevard, kitty-comer to the proposed 153,000 square foot Village @ Dublin
project, located at the southeast comer of Arnold Road and Dublin Boulevard.
Trip Generation Rates:
The Dublin Crossings DEIR (page 3-224) uses ITE's 2008 Eighth Edition of Trip
Generation for trip generation rates, including a daily trip rate of 42.94 for "shopping
centers". In addition, all trip generation rates (including the shopping center rate) are
reduced by 5o/o "since the project area is located near the Dublin/Pleasanton BART
station". In contrast, the Village @ Dublin DEIR (page 44) uses ITE's 2012 Ninth
Edition of Trip Generation with a "shopping center" daily trip rate of 56.73 (for the
non-Whole Foods porlion of the project), and no reduction for proximity to BART,
even though the two projects are essentially the same distance from the BART
station.
Kristi Bascom
August 8,2013
Page 2
Both project areas are also considered to be within the BART station's "walkshed", as
documented in the City of Dublin's 2010 Eastern Dublin Traffic Impact Fee Update report.
Given the very similar characteristics of the "shopping center" component of these two projects,
the City should be consistent in its analysis by using the same trip generation rates and
reductions due to BART.
Project Timing and "Cumulative" Traffic:
The DEIR states (page 2-16) that anticipated build-out of the i 80 acre Dublin Crossing project
is assumed to occur "over a period of approximately eight to twelve years", which seems
reasonable, given the scale of the project. What's not clear is when the "period" might begin,
given the complexity of the Army's phasing plan, the need to negotiate extensive biological and
wetland impacts with Federal and State agencies, and the need to build significant amounts of
infrastructure, both on and off-site. It's most likely that construction of the project will not begin
until 2015, at the earliest, making "build-out" ln 2025 or even later.
Because the identified traffic impacts associated with the Dublin Crossing project are largely
related to the timing of the project relative to other projects in the vicinity, please clarifu when
build-out of the project can reasonably be assumed. For instance, the Village @ Dublin DEIR
assumes that the Dublin Crossing project is built-out tn2020, and that the Village project traffic
will then be added to this cumulative condition. In fact, given the relative scales and complexity
of the two projects, the opposite is more likely, with the Village @ Dublin project being
completed prior to the majority of the Dublin Crossing project being constructed. The traffic
analysis should reflect this.
Eastern Dublin TIF:
The Dublin Crossings project is literally surrounded on three sides by roadways and intersections
that have been, or will be, improved through the Eastern Dublin Traffic Impact Fee program,
including Dublin Boulevard, Dougherty Road and Arnold Road. The TlF-funded extension of
Scarlett Drive from Dublin Boulevard to Dougherty Road and the TlF-funded widening of
Arnold Road to four lanes north of Dublin Boulevard are almost entirely within the Dublin
Crossing Specific Plan area, and Dublin Crossing traftc would necessarily utihze many other
TlF-funded improvements. Yet the DEIR and the draft Specific Plan are unclear as to how the
Dublin Crossings project will (or will not) participate in the Eastern Dublin TIF program, or
otherwise provide mitigation. For instance, on page 3-223, the DEIR states that "presently, the
proposed Dublin Crossing project is not part of the most recent update of the TIF program".
Similarly, it's unclear whether the project will be responsible for constructing the Amold Road
widening and Scarlett Drive extension as part of the project - or if it is being assumed that these
improvements - estimated to cost over $18 million- will continue to be funded through the TIF.
Kristi Bascom
August 8,2073
Page 3
Given the Dublin Crossing project's location and dependence on existing and planned TIF
improvements, and the fact that several planned TIF improvements are within the boundary of
the project, it seems most logical for the project to be directly incorporated into the Eastern
Dublin TIF program. This would create a clear method fbr the project's large volume of "new"
traffic to help fund TIF improvements that would otherwise be funded by others for the benefit
of this project. The Final EIR should clarifz what relationship the Dublin Crossing project will
have to the E,astern Dublin TIF and the responsibility of the project to construct the Scarlett
Drive and Arnold Road improvements.
Traffic Mitigation:
The DEIR states that the project would degrade the Iron Horse Parkway and Dublin Boulevard
intersection from LOS C to LOS F under 2035 cumulative conditions, and states that the project
applicant would be responsible for mitigating this condition (page 3-267). However, the
proposed mitigation of adding a second northbound left turn lane on Iron Horse Parkway by
widening the roadway 12 feet along approximately 400 feet the east side of Iron Horse Parkway
appears to be infeasible without the loss of most (or all) of the existingiplanned sidewalk and
street parking. This would be contrary to the adopted Dublin Transit Center street design
standards and could impact the existing and planned residential projects along Iron Horse
through the loss of pedestrian access andlor on-street parking spaces.
The Final EIR should assess the practicality of this mitigation measure and the impacts the
mitigation measure may create on its own.
Biological Impacts
The DEIR states (page 3-82) that the "Eastern Alameda Conservation Strategy (EACS) is sti11 in
the developing process and has not been approved or adopted. Therefore, the proposed project
would not have a conflict with the provisions of an adopted Habitat Conservation Plan....
Therefore the proposed project would have no impact".
The Final East Alameda County Conservation Strategy (EACCS) was released in 2010, and was
subsequently adopted by the City of Dublin. The Final EIR should therefore assess the proposed
project's biological impacts against the Conservation Strategy's policy prior to determining
whether or not there is an impact.
As noted above, the Village @ Dublin DEIR was recently released by the City of Dublin for the
development of a shopping center on a 74.2 acre site located directly across the street from the
Dublin Crossing project. The Village project is located on similar terrain (relatively flat, highly
disturbed grassland) as the 180 acre Dublin Crossing project, and has similar habitat
characteristics as the grassland portions of the Dublin Crossing DEIR. While similar potential
biological impacts have been identified for the two projects (impacts to special-status plants,
Ikisti Bascom
August 8,2013
Page 4
impacts to burrowing owls and impacts to nesting birds) - the proposed mitigation measures in
the Dublin Crossing DEIR for these potential impacts tend to be much less stringent than the
proposed mitigation measures for the Village @ Dublin project.
For instance, even though Congdon's tarplant populations have been documented within the
Dublin Crossing project area,the proposed mitigation measure (MM 3.3-2b because Congdon's
tarplant is not a federal or state-listed plant) is to notify CDFW and prepare a mitigation plan that
"shall include such measures such as transplanting plants, collecting seed or clippings and
replanting species in an on-site location, if feasible or other location approved by Department of
Fish and Game".
In contrast, in the Village DEIR (where neither Congdon's tarplant nor any other special-status
plant species has ever been identified), the special-status plant mitigation measure requires that,
if populations/stands of a special-status species are identified and impacts are unavoidable,
compensatory mitigation be provided, such as acquisition of off-site mitigation areas or credits at
a mitigation bank, and such "mitigation shall be acquired at a minimum acreage ratio of 1:1
(acquired:impacted). For either ofisite mitigation option, measures shall be implemented
(including contingency measures) providing for the long-term protection of the species".
Another example is proposed mitigation for burrowing owls. While the Village DEIR requires
that pre-construction surveys and (if owls are found on the site) mitigation conform to both the
CDFW 2012 StaffReport on Burrowing Owl Mitigation and the EACCS, the Dublin Crossing
DEIR burrowing owl mitigation measures omit any mention of the more stringent standards of
the EACCS.
Similarly, while both projects identifz potential impacts to nesting birds during construction, the
Village DEIR has a much more stringent mitigation measure. The Dublin Crossing mitigation
measure (MM 3.3.-6) states that, between March 1 and September 15, the project applicant shall
have a qualified biologist conduct nest surveys no more than 30 days prior to any
demolition/construction or ground-disturbing activities within 300 feet of "potential nest tress"
for non-raptor species and 500 feet ofpotential nest trees for raptor species. In contrast, the
Village DEIR mitigation measure requires that, for any construction between February 1 through
August 37, at least three surveys of the site, spaced over several months, with the last to be
conducted no more than 14 days prior to the start of work. Furthermore, the proposed mitigation
measure requires that all trees, shrubs and other suitable nesting habitat within 250 feet of the
project site "shall be searched for nests" (even this is offthe property).
The City of Dublin needs to consistently apply mitigation measures to projects with similar
biological impacts. Based on a comparison with the Village @ Dublin DEIR, the Dublin
Crossing DEIR does not meet this standard. The Dublin Crossing FEIR should address this
issue by modiffing the proposed biological mitigation measures so that they are consistent with
other City of Dublin EIRs.
Kristi Bascom
August 8,2013
Page 5
Thank you for this opportunity to comment on the Dublin Crossing Draft Environmental Impact
Report. We look forward to reviewing the Final EIR and commenting on the draft Dublin
Crossing Specific Plan in the future.
Sincerely,ffid-V--St-uart Cook
Director
CC: Pete Knoedler, Regency Centers
Dublin Crossing Specific Plan Final EIR
Page 4
Response to Comment Letter #3 from Mr. Stuart Cook, Alameda County
Community Development Agency – Surplus Property Authority, dated August 8,
2013
Response to Comment 3-1 – Trip Generation Rates In determining the trip generation rates for any transportation analysis, the City uses the standards in place at the time the Notice of Preparation (NOP) is published for the EIR. In the case of the Dublin Crossing analysis, the NOP was published on June 4, 2012. At that time, the traffic analysis commenced and the trip generation rates used were those from the ITE manual in place at the time. The NOP for The Village @ Dublin, another Draft EIR that was recently prepared by the City of Dublin, was published on January 7, 2013. The ITE manual reference is updated regularly and it is a normal practice to use the most current version. A change in the trip generation to the 2012 ITE (Ninth Edition) rates is not anticipated to change the impact conclusions in the Draft EIR. With regards to the question on the five percent overall trip reduction and its application to the Dublin Crossing project, but not to The Village @ Dublin project, it is important to recognize that the two proposed land uses scenarios are different. It is a normal practice to apply the trip credits based upon the land use categories and other factors including proximity to a key traffic generator. Additionally, The Village @ Dublin has been allocated a 30 percent pass by trip credit as compared to 20 percent for commercial uses at Dublin Crossing. This difference is due to the different land use scenarios, proximity to the freeway, and overall differences between two projects.
Response to Comment 3-2 – Project Timing and Cumulative Traffic The citywide traffic model, which was used for both the Dublin Crossing and The Village @ Dublin traffic analyses, assumed that approximately twenty percent of the residential units in the Dublin Crossing project would be fully occupied in Year 2020. However, in the project-level traffic analysis for 2020 for both the Crossing project and Regency project the City took a more conservative approach, and changed the assumptions to assume that the entire Dublin Crossing project would be built out and occupied by Year 2020. This approach examined the highest Project trip generation for Year 2020 and minimized the need for conducting additional interim model runs.
Response to Comment 3-3 – Eastern Dublin TIF There are several transportation improvements needed for the implementation of the Dublin Crossing project. Construction or financial contributions toward some of the improvements have been identified as mitigation measures in the Draft EIR, and some improvements are required project commitments for the safe circulation of multimodal traffic. As a means of contributing its fair share toward improvements that are identified in the EIR, the developer will be required to pay a transportation
Dublin Crossing Specific Plan Final EIR
Page 5
fee at each building permit based on the amount such development would be subject to under the Eastern Dublin TIF, if the development were in the EDTIF. The Draft Development Agreement between the developer and the City contains language requiring the developer to complete specific transportation improvements by specific deadlines. These improvements are both EDTIF and non-EDTIF projects, and include the extension and widening of Scarlett Drive and the widening of Arnold Road from two lanes to four lanes between Dublin Boulevard and Central Parkway. The developer will receive a credit against their transportation fee obligation for EDTIF projects constructed by it above its fair share of project expense based on the traffic mitigation measures in the EIR.
Response to Comment 3-4 – Traffic Mitigation Based on comments received during the Draft EIR comment period, the City is reconsidering proposed Mitigation Measure 3.12-4, which would require the addition of a northbound left-turn lane on Iron Horse Parkway at the intersection of Iron Horse Parkway and Dublin Boulevard. In an effort to conserve as much of the on-street parking and sidewalk area as possible in the Transit Center, the proposed alternative mitigation is proposed that will achieve the same mitigation result, but a more compact design will have fewer impacts on the surrounding streetscape and pedestrian mobility. MM 3.12-4 on pages ES-55 and ES-56 and pages 3-281 and 3-282 in the Draft EIR have been changed as follows: “To mitigate the impact at the intersection of Iron Horse Parkway and Dublin Boulevard would require an additional northbound left turn lane on Iron Horse Parkway. Based on the 2035 cumulative plus project conditions, the two northbound left turn lanes would need to be 400 feet each. This improvement would require the removal of parking on the east side of Iron Horse Parkway, traffic signal modifications, and changing the travel lane configuration and alignment to create:
One 16-foot wide southbound receiving lane on Iron Horse Parkway;
Two 10-foot wide northbound left turn lanes on Iron Horse Parkway; and
One 14-foot wide northbound shared through-right turn lane. Because the proposed project causes the change in operation from LOS C to LOS F, the proposed project is responsible for constructing these improvements. The timing of these improvements will be determined in the project’s mitigation monitoring program.” Under this configuration, parking would be removed on the east side of Iron Horse and the southeast corner of the intersection would need to be reconstructed, but little (if any) landscaping would be removed and no sidewalks would be removed
Dublin Crossing Specific Plan Final EIR
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from the proposed intersection. Operationally, this would allow for normal eight-phase signal operation and crosswalks on all four legs of the intersection.
Response to Comment 3-5 – Biological Resources Comment noted and the respective change has been made to page 3-89 in the Draft EIR. The East Alameda County Conservation Strategy (EACCS) was released in December 2010. On August 21, 2012, the City of Dublin City Council adopted a resolution accepting the East Alameda County Conservation Strategy as guidance for environmental permitting for public projects affecting habitat and endangered species in Eastern Alameda County. The City recognizes that compliance with the EACCS by local jurisdictions, individual landowners, and developers who need regulatory permits is strictly voluntary. There is no requirement on behalf of the City, or private developers, to comply with the Conservation Strategy, rather the City acknowledges the EACCS as a guidance tool that could enable a more straightforward review and permitting process for projects with impacts to biological resources. Therefore, the project’s compliance with the EACCS is not a regulatory standard for determining biological impacts under CEQA.
Response to Comment 3-6 – Biological Resources The mitigation measures relating to Congdon’s tarplant, Burrowing owls, and nesting birds in the Dublin Crossing Specific Plan Final EIR have been modified to be consistent with the mitigation measures identified in the Village @ Dublin Draft EIR. See Response to Comment 3-7, 3-8, 3-9, and 3-10 below.
Response to Comment 3-7 – Biological Resources: Congdon’s tarplant See response to Comment 3-6. The respective changes to mitigation measures MM 3.3-2a and MM 3.3-2b on pages ES-16 to ES-18 and pages 3-74 to 3-75 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 3-8 – Biological Resources: Burrowing owls See response to Comment 3-6. The respective changes to mitigation measure MM 3.3-3a on pages ES-18 to ES-21 and pages 3-76 to 3-77 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 3-9 – Biological Resources: Nesting birds See response to Comment 3-6. The respective changes to mitigation measure MM 3.3-6 on pages ES-27 through ES-29 and pages 3-84 to 3-85 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Dublin Crossing Specific Plan Final EIR
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Response to Comment 3-10 – Biological Resources See response to Comment 3-6. As described above, the respective changes to the mitigation measures MM 3.3-2a, MM 3.3-2b, MM 3.3-3a, and MM 3.3-6 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
G:\PA#\2008\PA 08-049 Camp Parks_Dublin Crossing\2011 Restart\CEQA-EIR docs\DEIR\DEIR comment letters\Fire Dept.doc
Alameda County Fire Department
Fire Prevention Bureau
City of Dublin
100 Civic Plaza, Dublin, California 94568 Phone: 925-833-6606 Fax: 925-829-9248
APPLICATION REFERRAL LETTER COMMENTS
DATE: 07/12/2013
TO: Kristi Bascom, Contract Planner
FROM: Bonnie S. Terra, Division Chief/Fire Marshal
SUBJECT/PERMIT #: Draft EIR and Specific Plan
ADDRESS: Dublin Crossings
Comments:
1. Street widths provided may not be adequate given the proposed heights of buildings. In
those locations where buildings over 30 feet in height are to be built, the road width will
need to be 26 feet. The 26 feet must be free and clear of any obstructions parking or
medians.
2. In areas where there are fire hydrants the street widths shall be 26 feet.
3. Given that the site plan and unit configuration provided is illustrative and not definitive
at this time. It is not possible to determine if there are enough ingress and egress points.
Please note that multiple-family residential areas having more than 200 units, commercial
projects greater than 30 feet in height and/or more than 124,000 square feet shall be
provided with at least two points of access.
Dublin Crossing Specific Plan Final EIR
Page 8
Response to Comment Letter #4 from Ms. Bonnie Terra, Alameda County Fire
Department, dated July 12, 2013
Response to Comment 4-1 – Internal Circulation Comment noted. The recommended changes have been incorporated into the Dublin Crossing Specific Plan.
Dublin Crossing Specific Plan Final EIR
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Response to Comment Letter #5 from Ms. Beth Walukas, Alameda County
Transportation Commission, dated August 1, 2013
Response to Comment 5-1 – Agency Name Reference Comment noted and the respective changes have been made to pages 3-267 to 3-269 of the Draft EIR.
Response to Comment 5-2 – Level of Service (LOS) Standard Comment noted and the respective change has been made to page 3-269 of the Draft EIR.
Response to Comment 5-3 – Definition of “Unacceptable” LOS Comment noted and the respective change has been made to page 3-269 of the Draft EIR.
Response to Comment 5-4 – Figure 3.12-7 Correction Figure 3.12-7 presents the trip distribution for the proposed project. The title of the figure has been revised on page 3-241 in the Draft EIR in the figures at the end of Chapter 3.12 of the Draft EIR. The trip generation for the proposed project is described in Table 3.12-7: Dublin Crossing Trip Generation.
Response to Comment 5-5–Multimodal/Complete Street Design
Considerations The Alameda CTC has requested that additional Transportation Demand Management (TDM) measures should be considered instead of physical improvements like addition of lanes. Following this general discussion, the letter asks for analyzing secondary impacts to other modes due to the proposed mitigations. Then three specific mitigations are recommended for additional analysis to evaluate secondary impacts. The impacts to transit, bicycle and pedestrian modes of transportation are evaluated in the EIR. Pages 3-234 to 3-236 of the Draft EIR (June 2013) provide a description of impacts on bicycle and pedestrian modes. Furthermore, on page 3-272 of the Draft EIR, Mitigation Measure 3.12-10 provides a specific mitigation to address bicycle and pedestrian circulation impacts. Additionally, the Specific Plan would incorporate the following measures from the City’s Bikeways Master Plan:
• Develop a bicycle commuter route system that connects residential neighborhoods to employment areas, multi-modal terminals, and schools.
• Encourage employers to provide secure bicycle parking, showers and changing rooms for bicycle commuters.
• As a condition of project approval, require major development projects with major transportation impacts to construct adjacent bicycle facilities included in the proposed bicycle system.
Dublin Crossing Specific Plan Final EIR
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• Install bicycle stencils and bicycle-sensitive loop detectors (or other detector type) on bikeways as part of new signals, signal upgrades, and resurfacing/restriping projects. With regards to the specific mitigation measures, the following responses are provided: MM 3.12-3: The City is pursuing multiple sources of funding to conduct a feasibility analysis of the Iron Horse Trail connectivity from Dougherty Road to the (East) Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in this location could significantly enhance bike and pedestrian access to and from the project area and beyond. To support this project, the developer of the Dublin Crossing project is contributing $50,000 towards the feasibility analysis, and the City is seeking additional funding from ACTC’s own Sustainable Communities Technical Assistance Program. It is the City’s full intent to pursue a grade-separated crossing at this location, and at this time the alternative mitigation measure of removing a portion of the crosswalk across Dublin Boulevard will remain in the EIR.
MM 3.12-4: See response to comment 3-4 (above). MM 3.12-6: Design of the intersection improvements will be reviewed for consistency with the City’s Bikeways Master Plan and reviewed for consistency with the City’s Complete Streets Policy (adopted by the City Council in December 2012).
ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT, ZONE 7
100 NORTH CANYONS PARKWAY LIVERMORE, CA 94551 PHONE (925) 454-5000 FAX (925) 454-5727
August 8, 2013
Ms. Kristi Bascom
City of Dublin Community Development Department
100 Civic Plaza
Dublin, CA 94568
Re: Dublin Crossing Specific Plan & Draft EIR
Kristi:
Zone 7 Water Agency (Zone 7) has reviewed the referenced CEQA document in the context of Zone 7’s
mission to provide drinking water, non-potable water for agriculture/irrigated turf, flood protection, and
groundwater and stream management within the Livermore-Amador Valley. We have the following
comments for your consideration:
1. Section 2, Project Description, and Section 3.11, Public Services and Utilities: Zone 7’s 24-
inch Santa Rita/Dougherty Pipeline runs just outside of the western boundary of this study area.
A portion of Zone 7’s 18-inch Hopyard Pipeline is located within the project area along with our
DSRSD Turnout No. 3. Please see the attached figure. Per Figure 5-5, it shows a relocated
drainage ditch along with two underground storage ponds which may interfere with our pipeline.
Any work which may interfere with Zone 7’s use of its waterline and/or turnout or full enjoyment
of its easement rights requires an encroachment permit to be obtained from Zone 7. It appears
that the turnout is located in what is planned to be a park/recreation area located westerly of A
Street and southerly of G Street. We request that the developer provide more detailed
information on the plans for that portion of the project located adjacent to our Hopyard Pipeline
and DSRSD Turnout No. 3. Zone 7 does not generally allow permanent structures or trees to be
planted within our easements. Any work within our easement will require an encroachment
permit. Please contact John Koltz at 925-454-5067 for obtaining an encroachment permit.
2. On page 3-149 in Section 3.8.3: the DEIR mentions that the onsite recycled water demands will
be 131 ac-ft/yr to 144 ac-ft/yr, but we don’t find any reference to its associated salt loading or
potential effect on groundwater TDS. The RWQCB’s Basin Plan objective for this part of the
groundwater basin is 1,000 mg/l TDS, but the current TDS conditions are not mentioned despite
the project area having several groundwater monitoring wells located on it; some were installed
for this EIR effort.
3. On page 3-142, under Groundwater Basin: While there is mention of Zone 7 serving as the
groundwater Basin Manager (page 3-142), our salt management plan (SMP), as well as a
groundwater demineralization plant to manage and mitigate salt buildup in the Main Basin (pages
3-143), the document lacks discussion of the State’s recent Recycled Water Policy which now
requires salt management plans to provide for management of “nutrient loading” and “monitoring
of contaminants of emerging concern (CEC)” by 2014. Zone 7 is working with DSRSD and
other local water purveyors on an update of its SMP to meet these State’s requirements, which
should be noted. Furthermore, we request Dublin’s support of these efforts to ensure a safe and
reliable water source for future generations.
4. In Section 3.8: The numerous wells located on the site could lead to a groundwater
contamination conduit issue if abandoned or buried during the construction of the project. Please
incorporate a discussion as well as a mitigation measure that requires any existing or discovered
well that is not needed for the project or groundwater basin management to be properly sealed or
destroyed under a Zone 7 permit.
5. On p.2-13, under 2.8 Infrastructure Improvements: typo in last word in 2nd paragraph –
change “are” to “area” Also, it is not clear what “existing trapezoidal channel across the
southeastern portion of the project area” the author is referring to, as none of the Figures on
stormwater drainage identify it by this name.
6. On p.2-14, 1st paragraph: there is a reference to Figure 2-11 which presents the Conceptual
Stormwater Drainage and Detention System, yet Figure 3.8-3 presents the Proposed Drainage for
Dublin Crossing Specific Plan. It is unclear which is the most current plan, as there are major
differences associated with the use of underground storage basins.
7. On p.3-144, 2nd paragraph: Gleason is misspelled as “Gleeson.”
8. On p. 3-149, under On-site Surface Water Runoff: a reference to Figure 3.8-3 is called out.
The two underground HMP storage basins proposed have a storage capacity of 3.3 acre-feet and
1.6 acre-feet; however, Figure 2-11 indicates 3.0 acre-feet and 1.5 acre-feet, respectively. Please
clarify as to which is correct. Also, it is not clear how a basin size of 150’x75’x8’, as shown in
Figure 3.8-3, can contain 3.3 acre-feet of storage; nor is it plausible how a 60’x40’x10.5’ basin
can contain 1.6 acre-feet. This requires discussion, or possibly revision.
9. On p.3-150, 2nd paragraph should refer to the use of DUAL 96-inch diameter storm drain pipes.
It is unclear how the proposed underground dual 96” storm drain pipes would act as detention
basins as there is no description of how it would function or operate. Further review of the
Hydrologic model is required.
10. On p.3-150, under Off-site Surface Water Runoff Management, third paragraph: “n” value
is referred as “water flow velocity rate” instead of the typical designation, Manning’s coefficient.
The proposed “n” value of 0.5 appears to be extremely high. Please review and correct as
needed.
11. On p.3-157, Mitigation Measure 3.8-4a: it is unclear how the proposed detention basin will be
operated and maintained, and by whom.
12. Hydraulic Model: Staff is still reviewing the Hydrologic Model associated with the proposed
project and will not be able to provide comment before August 16. Zone 7 requests an extension
of time to provide comments on the model.
We appreciate the opportunity to comment on this Draft EIR. If you have any questions, please feel free
to contact me at (925) 454-5005 or via email at erank@zone7water.com.
Sincerely,
Elke Rank
cc: Carol Mahoney, Rhett Alzona, Joe Seto
ZONE 7 WATER AGENCY DRAWN:
100 North Canyons Parkway
Livermore, CA
File:
REVIEWED:LOCATION OFHOPYARD PIPELINE &DSRSD TO #3
SCALE: AS SHOWN
DATE:07/23/2013
FIGURE #
.
PROJECT AREA
ZONE 7'S
HOPYARD PIPELINE
AND DSRSD TO-#3
Dublin Crossing Specific Plan Final EIR
Page 11
Response to Comment Letter #6 from Ms. Elke Rank, Alameda County Flood
Control and Water Conservation District, Zone 7, dated August 8, 2013
Response to Comment 6-1 – Public Services and Utilities The existing DSRSD turnout and Zone 7 pipelines are located within the future City of Dublin Community Park parcel. The future planning and design of the park (which has not yet begun) will take into consideration the location of the turnout and pipeline and Zone 7 and DSRSD will be consulted on any issues relating to these facilities in the park design, including obtaining encroachment permit(s) if required.
Response to Comment 6-2 – Salt Loading Effects on Groundwater Recycled water is planned for use at the project site. Potential impacts of recycled water delivered to the local groundwater basin — the Livermore-Amador Valley Groundwater Basin — was addressed in the Final Environmental Impact Report for the San Ramon Valley Recycled Water Program (Report), adopted in December 1996 by the DSRSD/EBMUD Recycled Water Authority which is incorporated herein by reference. Potential impacts to groundwater quality were discussed in Section 3.1 of the EIR; the impacts and mitigation summary for groundwater was outlined in Table 3-2. The project site is located over the Fringe Basin, groundwater basin that is not used for domestic water supply. Impacts to the Fringe Basin from the San Ramon Valley Recycled Water Program were found to be potentially significant. Potential increase in salt loading to the main basin, which is used for domestic water supply, is less than significant. Potential rise in shallow groundwater levels is possible, though unlikely; therefore the impact is also less than significant. As the Livermore-Amador Valley Groundwater Basin manager, Zone 7 developed a Salt Management Plan (SMP) in 2004 to address the increasing concentrations of salt in the groundwater basin, and to protect the long-term water quality of the Main Basin into the future. The adoption and implementation of an approved SMP was required under Provision D.1.c.ii of the San Francisco Bay Regional Water Quality Control Board’s “Master Water Recycling Permit,” Order No. 93-159. Zone 7’s Mocho Groundwater Demineralization Plant, which was completed in 2009, was one of the salt management strategies that were selected in the SMP. In 2005, Zone 7 prepared and adopted a Groundwater Management Plan (GWMP). It consisted mostly of a compilation of all of Zone 7’s then-current groundwater management policies, programs, and practices but also provided basin management objectives and included stakeholders and the public during its adoption process. The SMP was incorporated into the GWMP since it dealt with managing the sustainability of the groundwater basin’s water quality. In 2009, the State Water Resources Control Board adopted a new Recycled Water Policy (SWRCB Res No. 2009-0011). It mandated that a Salt and Nutrient Management Plan (SNMP) be prepared for basins where recycled water was to be used, and required it include plans for Constituents of Emerging Concern (CEC)
Dublin Crossing Specific Plan Final EIR
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monitoring. The plans are to be completed by May 2014, and include collaboration from local water, wastewater, and contributing stakeholders. Zone 7’s current SMP does not address either nutrient management or the CEC monitoring requirements. Starting in 2011, Zone 7 began working on the update of its SMP to incorporate the recent regulatory requirements. The key goals and objectives of the update effort include: 1) verifying strategies for reducing salt loading in the Main Basin, 2) addressing nutrient and CEC monitoring requirements, 3) assessing the potential salinity impacts of the water supply “portfolios” outlined in Zone 7’s 2011 Water Supply Evaluation, including increased recycled water use in the region, and 4) updating future salt and nutrient management plans. The update to the SMP is in progress. Based on compliance with these regulatory requirements and plans, the project’s impact to groundwater due to salt loading and total dissolved solids would be less than significant.
Response to Comment 6-3 – Salt Loading Effects on Groundwater See Response to Comment 6-2.
Response to Comment 6-4 – On-site Wells It is the City’s standard practice to include a condition of approval with any site improvement/grading plan or approval of a tentative map as follows: “Any groundwater wells found on the project site that are not needed for the project or groundwater basin management shall be properly sealed and/or destroyed under a Zone 7 permit.”
Response to Comment 6-5 – Infrastructure Improvements Comment noted and the respective change has been made to page 2-15 of the EIR. The location of the existing “open” trapezoidal channel is shown in Figure 3.8-2: Existing Drainage.
Response to Comment 6-6 – Clarification to Figures 2-11 and 3.8-3 Figure 2-11: Conceptual Stormwater Drainage and Detention System represents the conceptual storm water drainage and detention system. Figure 3.8-3: Proposed Drainage represents the proposed Q100 project flows and the title of the figure has been revised on pages v, 3-159, and 3-220 of the EIR to read accordingly.
Response to Comment 6-7 – Misspelling “Gleeson” Comment noted and the respective change has been made to page 3-153 of the EIR.
Dublin Crossing Specific Plan Final EIR
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Response to Comment 6-8 – Onsite Surface Water Runoff The correct volumes are 3.3 acre-feet and 1.6 acre-feet and Figure 2-11: Conceptual Stormwater Drainage and Detention System will be revised accordingly. The corresponding basin sizes reflect the bottom dimensions of the proposed basins. With 3:1 side slopes, the basins as shown will carry the proposed volumes. Page 2-15 of the EIR has been revised to clarify the dimensions are of the bottom of the basin.
Response to Comment 6-9 – Storm Drain Pipes In order to address the C.3 requirements, developed runoff must be mitigated to existing flow conditions. To accomplish this in drainage basins XX-1 and XX-2 of Dublin Crossing, flow will be routed to, and detained, in dual 96” diameter underground storage pipes. The storage pipes will be placed in a public storm drain easement. The runoff from drainage basins XX-1 and XX-2 will be conveyed to the dual 96” diameter underground storage pipes via public storm drain systems in the streets. Detailed design for the proposed dual 96” pipes will part of the construction documents approved at a later date, but the general concept is that the dual pipe systems will be connected at each end with vaults/manholes. At the downstream end of the system, the vault/manhole will have pipes or slots to meter runoff back into the City’s public storm drain system. The pipes/slots will be designed per the BAHM software to match the proposed runoff to the existing hydrograph. This storage system will be designed during the improvement plan process and will include construction details for the dual pipes and the vault/manhole structures.
Response to Comment 6-10 – Off-site Surface Water Runoff Management (“n”
value) The value noted (0.5) was a typographic error and has been corrected on page 3-160 of the EIR. Calculations shown in Appendix F were done based on 0.05 n-value.
Response to Comment 6-11 – Mitigation Measure 3.8-4a (Detention Basin) The underground detention basins are proposed to be owned, operated, and maintained by a future Homeowners Association (HOA) or by a public agency (if an agency exists that is interested in serving in this capacity). A maintenance agreement will be executed between the City and the HOA (or agency) to ensure that the detention basins, and the Chabot Creek Channel, will be maintained properly and operated in a manner that does not impede the use of the Community Park (in which these facilities are proposed to be located).
Response to Comment 6-12 – Hydraulic Model Comment noted. Additional comments were not provided by Zone 7 on the hydraulic model.
Dublin Crossing Specific Plan Final EIR
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Response to Comment Letter #7 from Ms. Rhodora Biagtan, Dublin San Ramon
Services District, dated August 7, 2013
Response to Comment 7-1 – General Comment noted.
Dublin Crossing Specific Plan Final EIR
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Response to Comment Letter #8 from Ms. Kim McNeely, Dublin Unified School
District, dated August 7, 2013
Response to Comment 8-1 – School Acreage Comment noted and the respective change has been made to page 2-8 of the EIR.
Response to Comment 8-2 – School Site Description Comment noted and the respective change has been made to page 2-12 of the EIR.
Response to Comment 8-3 – Internal Circulation Comment noted and the respective change has been made to page 2-13 of the EIR.
Response to Comment 8-4 – Pedestrian and Bicycle Circulation The narrative description of the pedestrian and bicycle circulation is conceptual at this stage. Should the Dublin Unified School District (DUSD) develop an elementary school within the project area, the City of Dublin will work collaboratively with the DUSD to accommodate school-related pedestrian and bicycle circulation requirements into the final circulation plan.
Response to Comment 8-5 – Soil Remediation As described on page 3-136 of the Draft EIR (June 2013), the U.S. Army and NASA are responsible for environmental remediation of existing hazardous materials within the project area and have agreed to remediate the project area to state and federal requirements. There will be no Department of Toxic Substance Control (DTSC) land use controls on the site, which means that site uses are unrestricted. Contamination that remains after the U.S. Army and NASA transfer the property to the project applicant and/or that needs to be remediated to a higher standard will either be remediated by the project applicant or by the U.S. Army or NASA prior to and during site grading and demolition activities associated with future development. Therefore, the proposed school site would be remediated and cleared to a level suitable for construction of an elementary school site.
Response to Comment 8-6 – Project Phasing Comment noted. The DUSD will be consulted regarding project phasing in coordination with District needs and the availability of various parcels of land for development.
Response to Comment 8-7 – Hazardous Materials Comment noted. The City acknowledges that a School Level Phase 1 clearance would be required in order for the site to be approved by the California Department of Education.
Dublin Crossing Specific Plan Final EIR
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Response to Comment 8-8 – Clarifications to Table 3.11-1 Comment noted and the respective change has been made to page 3-200 of the EIR.
Response to Comment 8-9 – Text Clarifications to Page 3-187, 2nd Paragraph Comment noted and the respective change has been made to page 3-200 of the EIR.
Response to Comment 8-10 – School Facility Act of 1998 Comment noted and the respective change has been made to page 3-205 of the EIR.
Response to Comment 8-11 – Clarification to Impact 3.11-3 Comment noted and the respective change has been made to pages 3-212 and 3-213 of the EIR.
Response to Comment 8-12 – Clarification to Table 3.11-3 Comment noted. The City has confirmed with DUSD that the existing data in the table is the most current data available.
Response to Comment 8-13 Acres and Capacity References Comment noted. The clarifications are reflected on pages 3-212 and 3-213 of the EIR.
Response to Comment 8-14 – Clarification regarding Seismic Faults Identified
in Figure 3.5-1 Comment noted. A detailed discussion regarding potential fault rupture impacts and seismic ground shaking is discussed starting on page 3-105 of the Draft EIR (June 2013) and Appendix D to the Draft EIR contains both a Preliminary Geotechnical Investigation that was conducted in March 2012 and a Fault Ground-Rupture Investigation that was conducted in March 2013, which should be consulted for more information.
Dublin Crossing Specific Plan
Final EIR
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Response to Comment Letter #9 from Mr. Eugene Wilson, California Clean Energy
Committee, dated August 2, 2013
Response to Comment 9-1 – Introduction
This comment provides background and introductory information about the
California Clean Energy Committee. The comment does not raise any issue with
respect to the contents of the Draft EIR, or any environmental issue regarding the
proposed project. Because the comment does not specifically reference the Draft
EIR or raise any other CEQA issue, no further response is necessary. The general
summary of environmental issues raised in the letter are addressed in the responses
to the specific comments on these issues below.
Response to Comment 9-2 – Global Warming
The comment provides background about global climate change, including
providing general predictions of future global greenhouse gas (GHG) emissions and
the potential effects. This comment does not specifically reference the Draft EIR or
raise any other CEQA issue.
Response to Comment 9-3 – GHG Emissions
As described on page 3-118 of the Draft EIR, “Business as Usual” emissions refer to
the emissions that would be expected to occur in the absence of GHG emission
reductions. The baseline “Business as Usual” emissions for the project were
calculated with the California Emissions Estimator Model (CalEEMod), as
recommended by the Bay Area Air Quality Management District (BAAQMD) and the
other air districts throughout California. CalEEMod utilizes emission factors
provided by the various California air districts to account for local requirements and
conditions.
The emissions provided in the Draft EIR are based on a variety of inputs, including
but not limited to, the land uses proposed for the project (1,995 residential dwelling
units, 50,000 square feet of office uses, 150,000 square feet of shopping center uses,
a 900-student elementary school, and 31.7 acres of park space), construction
information (phases, lengths, and equipment used), and operational mobile trip
generation (additional 22,047 gross daily vehicle trips). CalEEMod utilized the
project information, as described above, to generate GHG emissions for the
proposed project. CalEEMod contains several land use categories that are mainly
based on data for land use categories published by the Institute of Transportation
Engineers (ITE).
The Draft EIR described that emissions would result directly from mobile and area
sources, and indirectly from energy consumption, water demand, and waste
generation. Emissions were calculated based on consumption rates and emissions
factors from CARB, EPA, the California Air Pollution Control Officers Association
(CAPCOA), CEC, California Climate Action Registry (CCAR), and the Pacific Institute.
Dublin Crossing Specific Plan
Final EIR
Page 18
The proposed project’s GHG emission outputs are categorized by pollutant/GHG,
land use, and source; refer to Appendix B, Air Quality and Greenhouse Gas Emissions
Data, of the Draft EIR for detailed model input/output data.
The most common GHGs emitted in association with land use developments include
carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). Carbon dioxide
equivalent (CO2eq) values are also reported. In order to obtain the CO2eq, an
individual GHG is multiplied by its global warming potential (GWP). The GWP
designates on a pound for pound basis the potency of the GHG compared to CO2.
CalEEMod calculates the emissions associated with on-road mobile sources. These
are associated with residents, workers, customers, and delivery vehicles visiting the
land use types in the project. The emissions associated with on-road mobile sources
includes running and starting exhaust emissions, evaporative emissions, brake and
tire wear, and fugitive dust from paved and unpaved roads. Starting and
evaporative emissions are associated with the number of starts or time between
vehicle uses are also included. The emissions from mobile sources were calculated
with the trip rates, trip lengths, and emission factors for running from the CARB’s
Emissions Factors 2011 (EMFAC2011), which is the recommended by CARB and the
BAAQMD.
Area sources include emissions calculated from hearths, consumer product use,
architectural coatings, and landscape maintenance equipment. Landscape
maintenance includes fuel combustion emissions from equipment such as lawn
mowers, roto-tillers, shredders/grinders, blowers, trimmers, chain saws, and hedge
trimmers, as well as air compressors, generators, and pumps. The emissions
associated from landscape equipment use were processed using OFFROAD 2011
and CARB’s Technical Memo: Change in Population and Activity Factors for Lawn and
Garden Equipment (June 13, 2003).1
Prepared by the CEC, the California Commercial End Use Survey (CEUS)2 database
was used to develop energy intensity values (electricity or natural gas usage per
square feet per year) for non-residential buildings. The energy use from residential
land uses is calculated based on the Residential Appliance Saturation Survey
(RASS)3.
The project’s emissions inventory also included emissions from natural gas
consumption. The emission factors for natural gas combustion are based on the
1 California Air Resources Board, Technical Memo: Change in Population and Activity Factors for Lawn and Garden
Equipment, June 13, 2003. Available at : http://www.arb.ca.gov/msei/offroad/techmemo/Lawn_and_Garden_Activity.doc
2 California Energy Commission, California Commercial End-Use Survey Results, 2006.
3 California Energy Commission, Residential Appliance Saturation Study, 2009.
Dublin Crossing Specific Plan
Final EIR
Page 19
EPA’s AP-42, Compilation of Air Pollutant Emission Factor (AP-42) compilation of air
pollutant emission factors and data from CCAR. The emissions from electricity were
calculated by multiplying the energy use times the carbon intensity and other GHGs
of the utility district per kilowatt hour.
The amount of water used and wastewater generated by a project has indirect GHG
emissions associated with it. These emissions are a result of the energy used to
supply, distribute, and treat the water and wastewater. Emissions from residential
water use are based on data from the Pacific Institute Waste Not Want Not report4.
These values were divided by the total number of occupied households in California
to give water demand per dwelling unit. Data for most commercial and industrial
land uses was also obtained from the Pacific Institute’s Waste Not Want Not report.5
Total gallons of water used per day per metric were reported, where the metric is
employee, student, room, acre, or square foot, depending on the land use. Indoor
water end-use intensities were also obtained from the Pacific Institute report.6
Emissions from wastewater treatment are based on the CARB’s Local Government
Operations Protocol (LGOP)7, which are in turn based on EPA methodologies.8
The Project’s BAU emissions do not include the reductions in GHG emissions from
Specific Plan measures. Those reduction measures are described in the Draft EIR
(June 2013) on pages 3-123 – 3-126, in particular Table 3.6-4. The quantification
methods and reduction factors associated with the Specific Plan GHG reduction
measures identified in the Draft EIR were developed and calculated using the
CalEEMod model (see Appendix B to Draft EIR). CalEEMod uses the methodology
prescribed by the California Air Pollution Control Officers Association (CAPCOA).9
The CAPCOA methodology presents the emissions reductions in terms of percentage
reductions. For mitigation measures where the source metric is reduced, reductions
are generally assessed based on a ratio comparison of a common “denominator”
source metric for each source category in order to assist in the quantification of
strategy impacts. For mitigation measures involving emission factor reductions, a
ratio comparing the mitigated and baseline emissions factor is utilized to quantify
the emission reductions. The CAPCOA source data that is used in the CalEEMod
model is derived from CAPCOA’s Quantifying GHG Mitigation Measures
documentation.10 The CalEEMod model allows GHG reductions to be taken for
neighborhood enhancements; transit improvements; and reducing commute trips,
4 Pacific Institute, Waste Not, Want Not: The Potential for Urban Water Conservation in California, 2003.
5 Ibid.
6 Ibid.
7 California Air Resources Board, Local Government Operations Protocol. Chapter 10: Wastewater Treatment Facilities, 2008.
8 United States Environmental Protection Agency, Inventory of US Greenhouse Gas Emissions and Sinks: 1990-2006.
Chapter 8: Waste, 2008.
9 Environ International Corporation, California Emissions Estimator Mode Users Guide, page 9, February 2011.
10 CAPCOA, Quantifying GHG Mitigation Measures, August 2010.
Dublin Crossing Specific Plan
Final EIR
Page 20
water usage, energy consumption, and solid waste generation. Specific categories
that were utilized in the analysis for which a GHG reduction was quantified were for
increasing density, improving walkability, improving transit accessibility, providing
traffic calming measures, limiting parking supply, and implementing a trip reduction
program. With the reduction measures that are part of the project, the Project GHG
emissions would be 18,686.60 which results in an efficiency level of 3.08
MTCO2eq/SP/year.
As indicated in Section 3.6 of the Draft EIR, the City of Dublin decided to rely on the
thresholds within the CEQA Thresholds of Significance Revised Draft Operations and
Justification Report (dated October 2009) prepared by the BAAQMD. The BAAQMD
CEQA Thresholds of Significance Revised Draft Operations and Justification Report
established thresholds based on substantial evidence11 and are consistent with the
thresholds outlined in the BAAQMD’s 2010 CEQA Air Quality Guidelines. City staff
believes that these thresholds represent the best available science on the subject of
what constitutes significant air quality and/or GHG effects under CEQA.
Furthermore, pursuant to CEQA Guidelines Section 15064.7(c), “…a lead agency may
consider thresholds of significance previously adopted or recommended by other
public agencies or recommended by experts, provided the decision of the lead
agency to adopt such thresholds is supported by substantial evidence.” Therefore,
the City is permitted to use BAAQMD’s thresholds to analyze the project’s GHG
impacts on climate change, per CEQA Guidelines Section 15064.7(c). Note that
BAAQMD’s adoption of its CEQA Guidance, including its recommended thresholds of
significance, has been upheld in court. The First District Court of Appeal, reversing a
trial court’s decision, upheld BAAQMD’s adoption of the thresholds finding that the
adoption was not a project subject to CEQA review. The court reasoned that the
State CEQA Guidelines establish a procedure for adopting significance thresholds,
and CEQA review of the thresholds themselves is not part of that procedure.
Moreover, in adopting the thresholds, BAAQMD had undertaken a public review
process and considered substantial evidence in compliance with the State CEQA
Guidelines, so that requiring a specific CEQA analysis and document (ex. Negative
Declaration or Environmental Impact Report) would be duplicative.
The GHG analysis in the Draft EIR uses the BAAQMD’s efficiency approach, which
considers efficiency in terms of the GHG emissions compared to the sum of the
number of jobs and the number of residents at a point in time, which is referred to
as the service population (project jobs plus project residents) (SP). The efficiency
metrics is intended to avoid penalizing well-planned communities that propose a
large amount of development. GHG efficiency metrics act to encourage the types of
11 “Substantial evidence” includes facts, reasonable assumptions predicated upon facts, or expert opinions supported by
facts, but does not include argument, speculation, unsubstantiated opinion or narrative, evidence that is clearly inaccurate or
erroneous, or evidence of social or economic impacts that do not contribute to, or are not caused by, physical impacts on the
environment. Cal. Pub. Res. C. §21080(c); see also CEQA Guidelines §15384.
Dublin Crossing Specific Plan
Final EIR
Page 21
development that BAAQMD and California Governor’s Office of Planning and
Research (OPR) support (i.e., infill and transit-oriented development) because these
types of development result in a lower amount of GHG emissions per service
population than greenfield development or development outside urban areas. 12
Additionally, it should be noted that the BAAQMD bright line threshold would not be
appropriate to apply to the proposed specific plan project which is not an individual
development project. The BAAQMD CEQA Guidance states that the CEQA threshold
of significance for Plan-level entitlements, such as Specific Plans, should use the
threshold of 4.6 CO2e/SP/yr or compliance with a locally-adopted Qualified GHG
Reduction Strategy or Climate Action Plan (CAP).13 The Draft EIR applies both of
these thresholds in analyzing the level of significance for the Project’s GHG
emissions. The analysis in the Draft EIR shows that the Project emissions are below
the threshold of 4.6 CO2e/SP/yr and the Project complies with the City adopted
CAP. (See analysis of Impacts 3.6-1 and 3.6-2 in Draft EIR, pp. 3-118 – 3-126.) In
addition, the BAAQMD states that the bright line threshold applies to “…areas where
a qualified Climate Action Plan has not been adopted….”; the Dublin Climate Action
Plan was adopted by the City in October, 2010. Therefore, the bright line threshold
would not apply to the proposed project in this regard.
Response to Comment 9-4 – BAAQMD Guidelines/AB 32
The BAAQMD developed their California Environmental Quality Act (CEQA)
Guidelines for the purpose of assisting lead agencies in evaluating air quality impacts
of projects and plans proposed in the San Francisco Bay Area Basin (SFBAAB). The
Guidelines provide BAAQMD-recommended procedures for evaluating potential air
quality impacts during the environmental review process consistent with CEQA
requirements.
The purpose of California‘s legislative mandate (AB 32) is to reduce total projected
2020 GHG emissions to 1990 levels. The BAAQMD and CARB analysis relied on the
initial estimate of this reduction to equal approximately 30 percent.14 However, this
is likely an overestimate of the amount of the reduction needed based on recent
data. In 2011 ARB revised its “business as usual” GHG emission estimate for 2020,
in order to account for the recent economic downturn in its emission projections.
The estimate presented in the scoping plan (596 MMTCO2eq) was based on pre-
recession, 2007 data from the Integrated Energy Policy Report. In 2011 the CARB
adopted the Final Supplement to the AB 32 Scoping Plan Functional Equivalent
12 BAAQMD, CEQA Thresholds of Significance Revised Draft Options and Justification Report, October 2009.
13 BAAQMD, California Environmental Quality Act (CEQA) Guidelines, May 2010, pp. 2-7 – 2-8., .
14 BAAQMD, California Environmental Quality Act (CEQA) Guidelines, 2012 and California Air Resources Board, Assembly Bill
32 Scoping Plan, 2009.
Dublin Crossing Specific Plan
Final EIR
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Document (2011). In the Final Supplement, CARB updated the 2020 BAU based on
revised growth projections and considering the influence of the recent recession
and reduction measures that are already in place. Based upon revised growth
projections only, statewide emissions would need to be reduced approximately 20%
from the Updated 2020 BAU of approximately 545 MMTCO2eq to meet 1990 levels.
So, to the extent the BAAQMD’s CEQA Guidelines (2011 and 2012) and the CEQA
Thresholds of Significance Revised Draft Operations and Justification Report (2009)
rely on the GHG emission reduction goals established by AB 32, it overestimates the
reduction needed by using the 30% reduction goal.
In addition, courts have upheld the use of a CEQA significance threshold for GHG
emissions based on a percentage reduction from BAU derived from AB 32. The use
of a significance threshold based on an adopted plan or law to determine whether a
project’s impact is cumulatively considerable is also specifically authorized by CEQA
Guidelines Section 15064(h)(3)
Unlike the 2020 target under AB 32 and the Scoping Plan, the 2050 target is only a
goal set forth in Executive Order S-3-05. The Executive Order is not an adopted plan
or regulation that provides specific requirements for the reduction of greenhouse
gas emissions as defined under CEQA Guidelines 15064(h)(3). In addition, BAAQMD
(or any other agency) does not provide methodology or emissions factors to
determine 2050 emissions. It is beyond the scope of the analysis tools available at
this time to examine emission levels and reasonable emissions reductions in the
year 2050 in a CEQA analysis.
The quantitative GHG efficiency metric threshold was used based on the BAAQMD
CEQA Thresholds of Significance Revised Draft Operations and Justification Report.
The BAAQMD provides several threshold options for significance of GHG emissions,
including an efficiency threshold. Normalizing projected emissions from land use-
related emissions sectors by utilizing a demographic unit (e.g., population and
employment) provides evaluation of the GHG efficiency of a project and the
opportunity to evaluate the project’s consistency with AB 32 targets.
The BAAQMD established the efficiency metric threshold to avoid penalizing well-
planned communities that accommodate projected growth. Instead, GHG efficiency
metrics act to encourage the types of development that BAAQMD and the OPR
support (i.e., infill and transit-oriented development) because they tend to reduce
GHG and other air pollutant emissions on a per capita basis.
Response to Comment 9-5 – Existing Uses
The existing uses on-site include the Camp Parks U.S. Army Reserve Training Area,
the NASA parcel, and the Alameda County Surplus Property Authority parcel. In
2002, the US Army formally requested an amendment to the General Plan to change
the land use designation from “Public Lands” to a combination of commercial retail,
office space, residential, and open space uses.
Dublin Crossing Specific Plan
Final EIR
Page 23
The project description indicates that there are 934 residents and employees
throughout the entire Camp Parks base. It should be noted that these residents and
employees are not located on the project site. The buildings on the project site are
currently vacant. Pursuant to CEQA Guidelines Section 15125 the baseline
conditions for the analysis consist of the uses that exist at the time that the notice of
preparation is published. Therefore, the on-site buildings were not included in the
existing conditions for the project site. As a result, all emissions from the proposed
project were considered new emissions and were not reduced to reflect emissions
from any prior or existing uses on the project site.
Response to Comment 9-6 – GHG Emissions
As described in the Draft EIR, total build-out under the Specific Plan would result in
a service population increase of approximately 6,070 people. The significance
threshold used in the Draft EIR is not solely based on the amount of emissions for
the project. It is based on the amount of emissions per service population per year
(See Responses to Comments 9-3 and 9-4). The project emissions with GHG
reductions that will result from Specific Plan measures will be 18, 686.60 MTCO2eq.
This equates to a emission level of 3.08 MTCO2eq/sp/yr which is 33% below the
significance threshold of 4.6 MTCO2eq/sp/yr. The overall project emissions are
also 28.5% below the 2020 BAU projection for the proposed project.
Response to Comment 9-7 – GHG Emissions Growth
Refer to Response to Comment 9-6, above.
Response to Comment 9-8 – City CAP
This comment addresses the City of Dublin Climate Action Plan (dated October
2010). The Draft EIR analyzes the project’s consistency with the Climate Action Plan
(CAP) (Draft EIR Impact 3.6-2) in response to the second CEQA Appendix G checklist
item (Consistency with applicable GHG plans, policies, or regulations). The Draft
EIR analyzes the compliance of the proposed Project with applicable measures in
the Climate Action Plan (Table 3.6-3). The Draft EIR also analyzes whether the
proposed project BAU emissions will be consistent with the goal of the CAP to
reduce GHG emissions to 20% below projected Year 2020 BAU emissions by 2020
which will result in an overall level of emissions of 4.2 MTCO2eq/sp/yr. The
proposed project will reduce Year 2020 BAU emissions by 28.5% which exceeds the
CAP’s reduction target and will result in an overall level of 3.08 MTCO2eq/sp/yr
which is below the CAP level of 4.2 MTCO2eq/sp/yr. The Draft EIR does not rely on
the CAP for the GHG cumulative impacts analysis or quantification of reduction
measures for the proposed project under the streamlining provisions of CEQA
Guidelines section 15183.5(a) &(b)(2)
This comment has detailed objections to the content and adoption of the City CAP.
Since the Draft EIR does not use the CAP to calculate project emissions or reductions
or rely on the CAP for the impacts analysis under CEQA Guidelines section
Dublin Crossing Specific Plan
Final EIR
Page 24
15183.5(a) &(b)(2), these objections to the CAP are not relevant to the proposed
project. Since the objections to the methodology, assumptions and reduction
measures under the CAP are not relevant to the proposed project analyzed in the
Draft EIR, no response is necessary. Furthermore, the CAP and the Negative
Declaration for the CAP were adopted by the City in November 2011 and are no
longer subject to challenge. Since the specific comments on the CAP do not raise any
issue with respect to the contents of the Draft EIR, or any environmental issue
regarding the proposed project, no further response is necessary.
Response to Comment 9-9 – Energy Conservation
The energy analysis was prepared pursuant to Public Resources Code Section
21100(b)(3) and Appendix F of the CEQA Guidelines, which require a description
(where relevant) of the “wasteful, inefficient, and unnecessary consumption of
energy caused by a project”. The design guidelines in the proposed Specific Plan
encourage sustainable design solutions that reduce energy consumption and create
simple building designs through the efficient use of space, materials, and resources
while maintaining a level of design integrity and authentic architectural style (see
pages 3-2 to 3-3, 3-5 to 3-8, 3-32 to 3-33, and 4-12 to 4-14 of the Specific Plan).
Title 24, Part 6 of the California Code of Regulations was established to ensure
energy efficiency in new developments. Therefore, project compliance with Title 24
would ensure the project’s efficient use of energy. Cases have held that a project’s
compliance with Title 24 energy efficiency measures supports a finding that a
project will not result in a wasteful, inefficient or unnecessary consumption of
energy.
Response to Comment 9-10 – Energy Conservation
The reduction of emissions from off-road equipment would occur from efficient fuel
consumption. The use of cleaner off-road equipment would reduce energy
consumption through the reduction of fuel use. According to page 3-7 of the Draft
EIR, there would not be any inefficient, wasteful, or unnecessary energy usage in
comparison to similar development projects of this nature regarding construction-
related fuel consumption. The proposed project would adhere to, and exceed, all
Federal, State, and local requirements for energy efficiency, including Title 24 of the
California Code of Regulations regarding building energy efficiency standards.
Therefore, the proposed project would not result in the inefficient, wasteful, or
unnecessary consumption of building energy. See Response to Comment 9-9 on
building energy efficiency.
Response to Comment 9-11 – Energy Conservation
Refer to Response to Comment 9-9, above. The energy analysis was prepared in
accordance with Appendix F of the CEQA Guidelines. The energy requirements of the
proposed project were calculated with CalEEMod and are provided in Appendix B
(Air Quality and Greenhouse Gas Emission Data) of the Draft EIR. Appendix B
Dublin Crossing Specific Plan
Final EIR
Page 25
provides the projected unmitigated/mitigated operational energy consumption
emissions for criteria pollutants and GHGs for the Specific Plan using CalEEMod.
Energy consumption reduction measures used in the CalEEMod run include the
installation of high efficiency lighting, and energy efficient appliances for all land
uses proposed in the Specific Plan. The outputs in Appendix B also provide natural
gas usage by land use. Please note that that the items listed in Appendix F relating
to energy impacts of the project are not mandatory and not required to be
addressed in the EIR for every project. Appendix F states that the items should only
be discussed “to the extent relevant and applicable to the project” and “in many
instances specific items may not apply”. Given the nature of the project as an infill,
mixed use residential and commercial project, the project does not present any
special or unusual circumstances regarding energy use that would result in
wasteful, inefficient or unnecessary energy consumption. Therefore, many of the
specific items of information requested in the comment letter are not required to be
discussed or disclosed under CEQA. In addition, the project includes measures to
reduce energy use as described below.
The proposed project includes numerous measures and design features that would
reduce energy consumption. The Specific Plan design guidelines promote or require
energy efficient windows on exterior walls; rooftop gardens and green roofs; energy
effective roof materials to meet or exceed Energy Star requirements for solar
reflectance; rooftop solar panels; small-scale wind turbines; energy efficient
appliances and mechanical equipment; strategic location of mechanical equipment;
energy efficient, low voltage lighting; and energy efficient street lighting, among
others. Furthermore, the Specific Plan requires builders to implement energy
conservation measures and construction practices per Title 24 of the California
Code of Regulations. The applicable Project design features mentioned above were
inputted into CalEEMod as measures to reduce energy consumption from the
proposed project; please refer to Table 3.6-5 of the Draft EIR. CalEEMod quantified
the project’s reductions in energy consumption from the use of high efficiency
lighting and energy efficient appliances. These design features would result in a
reduction of 2,116 megawatt hours (MWh) per year to 11,066 MWh; a reduction of
approximately 16 percent (refer to Appendix B, Air Quality and Greenhouse Gas
Emissions Data, of the Draft EIR).
The Specific Plan also promotes green building concepts to improve the health,
welfare, and public safety by encouraging innovative and sustainable design and
construction techniques through the use of green building practices. Green Street
Design Project and cumulative level energy consumption and the effect on energy
supplies are discussed in Section 3.11 of the Draft EIR. As described in the Draft EIR,
the proposed project would not result in the need for new energy infrastructure to
support the site. Since the project will not result in wasteful, inefficient or
unnecessary consumption of energy, the project will not result in a significant
impact. Therefore, there is no legal basis for requiring mitigation measures to
increase energy-efficiency under CEQA.
Dublin Crossing Specific Plan
Final EIR
Page 26
Response to Comment 9-12 – Energy Conservation
The siting, orientation, and design of the project are measures that reduce energy
consumption, including transportation energy. As described in Section 4.6,
Streetscape Design, of the Specific Plan, the proposed project would incorporate
green streets and sustainable landscape design to minimize the detrimental
environmental effects of streets, and further reduce vehicle trips and fossil fuel
emissions from the proposed project. The Specific Plan area is located
approximately 0.3 miles from the Dublin/Pleasanton BART Station. The proposed
mixed-use development is within close proximity to transit and would encourage
residents and employees within the Specific Plan area to utilize transit. In addition,
the Specific Plan Design Guidelines and proposed circulation improvements also
provide innovative design elements/provisions to further reduce vehicle miles
traveled (VMT) from the proposed project. Namely, the Specific Plan includes
Transit Oriented Development (TOD), mixed-use development, and multi-modal
circulation to reduce vehicular use and encourage alternative transportation
choices. Plan-level design elements such as a “park once and walk” environment,
multi-purpose trails (combined bicycle and pedestrian routes), improved bike lanes
and routes, bulbouts, textured crosswalks, pedestrian linkages (to parks, schools,
BART, mixed-use, transit stops, residential to commercial areas), and adequate
bicycle facilities would reduce the project’s transportation energy consumption. As
described in Section 3.11 of the Draft EIR, Pacific Gas and Electric (PG&E) (the
electric service provider to the project area) has indicated that sufficient
infrastructure exists to support the proposed project. Renewable energy makes up
19.04 percent of PG&E’s energy portfolio.15 Additionally, refer to Response to
Comment 9-11.
Response to Comment 9-13 – Energy Conservation
As described above, the energy analysis was prepared in accordance with Appendix
F of the CEQA Guidelines. Appendix F does not require or recommend an analysis of
the economic viability of renewable energy strategies and energy efficient tools.
Additionally, the analysis in the Draft EIR determined that the project will not result
in a wasteful, inefficient or unnecessary consumption of energy. In addition, GHG
emissions would be less than significant. Mitigation measures require an essential
nexus with project impact and must also be roughly proportional to the impacts.
Therefore, mitigation that requires 100 percent or some lesser percentage of
renewable energy would not meet the nexus and rough proportionality standards
pursuant to CEQA Guidelines Section 15126.4 because the mitigation would not
relate to a significant environmental impact of the proposed project. Therefore,
they were properly not included in the Draft EIR. It should be noted, however, that
15 California Public Utilities Commission, California Renewables Portfolio Standard (RPS), Accessed September 3, 2013.
http://www.cpuc.ca.gov/PUC/energy/Renewables/index.htm
Dublin Crossing Specific Plan
Final EIR
Page 27
the Specific Plan promotes the use of renewable sources of energy (such as solar
panels and small-scale wind turbines) in the Plan area (pages 3-6 and 3-7 of the
Specific Plan).
Response to Comment 9-14 – Energy Conservation
Refer to Response to Comment 9-12 and 9-13, above. As discussed in the Draft EIR,
the electric service provider to the project area has stated that sufficient
infrastructure exists to support the proposed project and that additional generation
facilities would not be required. The Draft EIR analyzes the various transportation
and energy efficiency design features of the proposed project. The project’s close
proximity to the BART station would reduce vehicle trips (i.e., improve
transportation energy efficiency), and the project’s various energy efficiency design
features, as described in Response to Comment 9-11 above, would reduce electricity
and natural gas consumption.
Response to Comment 9-15 – Energy Conservation
Refer to Response to Comment 9-11, 9-12 and 9-13, above. As discussed in the Draft
EIR, the proposed project and design features will not result in a wasteful, inefficient
or unnecessary consumption of energy. In addition, GHG emissions would be less
than significant. Furthermore, the Specific Plan promotes the design and
implementation of rooftop solar panels, and the strategic location of solar panels to
effectively capture solar energy. Although rooftop solar may be included in the
proposed project, it would not be required per CEQA standards because impacts are
less than significant (See Response to Comment 9-13).
The discussion in the comment of the costs of various types of energy sources and
utility rates are economic issues which are not the proper subject of analysis under
CEQA (CEQA Guidelines section 15131 (economic effects shall not be treated as
environmental effects under CEQA)). Additionally, most of the information
provided in the comment is opinion or speculation which is not supported by
substantiated facts.
The comment also provides information about various topics including utility rates,
rooftop solar, and solar water heating. To the extent the comments are proposing
solar power, solar water heating and LED lighting as mitigation measures, the
measures could not be required as mitigations per CEQA standards because energy
impacts of the project are less than significant (See Response to Comment 9-13).
The other components of the comments do not raise any issue with respect to the
contents of the Draft EIR, or any environmental issue regarding the proposed
project. Because the comment does not specifically reference the Draft EIR or raise
any other CEQA issue, no further response is necessary.
Dublin Crossing Specific Plan
Final EIR
Page 28
Response to Comment 9-16 – Air Quality and Transportation Mitigation
The Draft EIR identifies certain air quality impacts as significant and unavoidable
(Draft EIR, Chapter 3.2). The Draft EIR identifies one significant and unavoidable
traffic impact – Impact 3.12-7 – impact to certain freeway onramps. If the City
decides to approve the proposed Project with these significant and unavoidable
impacts, it will have to make findings that potential mitigation measures or
alternatives to reduce these impacts to less than significant are infeasible and adopt
a Statement of Overriding Considerations. As part of these findings the City will
consider whether proposed mitigation measures would substantially reduce these
significant and unavoidable impacts and whether the proposed mitigation measures
are feasible. The City will consider the mitigation measures proposed in the
comment as part of its findings. However, note that some of the mitigation
measures proposed in the comment will not substantially reduce the significant
unavoidable impacts of the proposed Project. The Dublin Crossing Specific Plan
includes project design features that would reduce potential vehicle trips and
transportation (mobile source) emissions. These features include increased density
and diversity, improved walkability design, increased destination and transit
accessibility, improved pedestrian network, limited parking supply, traffic calming
measures, and trip reduction, ride sharing, and employee vanpool programs. It
should be noted that the BAAQMD thresholds for criteria pollutants were primarily
developed for analyzing individual development projects, not plan level (e.g.,
specific plan) or multiple development projects.
Response to Comment 9-17 – Air Quality and Transportation Mitigation
The Draft EIR analyzes bicycle facilities in the vicinity of the proposed project. For
example, the proposed project is adjacent to and would be connected with the Iron
Horse Regional Trail. The Iron Horse Regional Trail would be reconfigured with the
new project frontage and Scarlett Drive, and a secondary trail pathway could be
integrated along the southwestern edge of the Central Park, depending on the
eventual park design. According to the Bikeways Master Plan, The Iron Horse Trail
continues to the Bart station and in the future would go under Interstate 580 and
travel along the alignment of Owens Drive.
Associated uses along the secondary trail pathway through the park could include a
café/concession, bicycle racks, wayfinding signage, lighting, restrooms, and
landscaped gardens. The proposed project would also include a pedestrian trail
adjacent to Dublin Boulevard that would connect to the existing trail corridor, as
well as sidewalks and bicycle paths throughout the project area.
The internal circulation of the proposed project would be designed in a grid pattern
of different street types. The internal “backbone” street system is designed to
establish connections to the existing exterior roadway network as well as internally
between residential neighborhoods, parks, open spaces, an optional elementary
school site, and business/commercial areas. With sidewalks on all streets, and
Dublin Crossing Specific Plan
Final EIR
Page 29
bikeways on many, the streets will become the framework for the pedestrian and
bicycle network as they connect to uses both internally and beyond the project area.
Pedestrian and Bicycle Mobility impacts were analyzed in the Section 3.12 of the
Draft EIR and were determined to be less than significant. Consistency of the
proposed project with the Bikeways Master Plan was evaluated on pages 3-234 to 3-
236 of the Draft EIR (June 2013). Additionally, the Specific Plan would incorporate
the following measures from the City’s Bikeways Master Plan:
Develop a bicycle commuter route system that connects residential
neighborhoods to employment areas, multi-modal terminals, and schools.
Encourage employers to provide secure bicycle parking, showers and
changing rooms for bicycle commuters.
As a condition of project approval, require major development projects with
major transportation impacts to construct adjacent bicycle facilities included
in the proposed bicycle system.
Install bicycle stencils and bicycle-sensitive loop detectors (or other detector
type) on bikeways as part of new signals, signal upgrades, and
resurfacing/restriping projects.
Response to Comment 9-18 – Air Quality and Transportation Mitigation
Refer to Response to Comment 9-16 and 9-17, above. As noted above, the project’s
internal circulation would be designed in a grid pattern of different street types,
which enhance and enable non-vehicular connectivity. Additionally, the project
proposes a mix of commercial and residential uses that would reduce vehicle trips
in the area. It should be noted that the Specific Plan identifies the proposed land
uses within the project area, but does not specify actual end users. Therefore, while
end users such as grocery stores are not specifically identified in the project
description, they are also not precluded from the project. As described above, the
project’s mix of uses as well as pedestrian and transit friendly design would reduce
vehicle trips, thereby reducing emissions.
Response to Comment 9-19 – Air Quality and Transportation Mitigation
The comment suggests the use of zero-emission electric vehicles, commuter benefits
programs, and shared parking in the Specific Plan. Although the project does not
specifically mention zero-emission vehicles (ZEVs) or plug-in hybrid electric
vehicles (PHEVs), the project design includes internal circulation and amenities that
would support these vehicles, such as opportunities for electric vehicles charging
stations.
The circulation network would accommodate a wide variety of vehicles and
alternative modes of transportation. Sidewalks, multi-use trails, bicycle parking,
transit stops with shelters, and traffic calming measures all encourage the more
environmentally sustainable modes of travel. This approach is often referred to as
green streets.
Dublin Crossing Specific Plan
Final EIR
Page 30
The project site would be connected by a network of on- and off-street walking and
bike trails and sidewalks, to encourage safe pedestrian and bicycle access and
interconnectivity. The proposed project is a mixed use development that is located
approximately 0.3 miles from the Dublin/Pleasanton BART station. The mixed-use
development within close proximity to transit would encourage residents and
employees within the Specific Plan area to utilize transit. As described in the Draft
EIR, existing transit service in the project vicinity is provided by the Livermore
Amador Valley Transit Authority (LAVTA), Bay Area Rapid Transit (BART), and the
Altamont Commuter Express (ACE).
The Specific Plan includes various methods to reduce parking including utilizing
shared parking. A major direct benefit of transit-oriented development is the
reduced need for motor vehicles and vehicle parking. Mixed-use developments have
differing peak parking times and may allow for shared parking between various
uses. The Specific Plan encourages the reduction in off-street parking, shared
parking, and time limits on on-street parking to encourage the use of alternative
transportation. As described above, the Specific Plan incorporates several of the
features identified in the comment. Additionally, several measures noted in the
comment, including commuter benefits programs, transportation management
associations, and parking cash-out programs are not specifically identified in the
proposed specific plan. However, the benefits of such measures are inherent to
mixed-use/transit oriented projects and are encouraged in Specific Plan policy CIR
4.22.
Response to Comment 9-20 – Transportation/Plan Bay Area
The comment states that the proposed project is inconsistent with Plan Bay Area.
Plan Bay Area does not establish development standards or criteria for projects in
Dublin or other local jurisdictions. Plan Bay Area contains a Sustainable
Communities Strategy (SCS) as part of the Regional Transportation Plan (RTP) that
meets greenhouse gas reduction targets adopted by the California Air Resources
Board pursuant to SB 375. Local development is not required to be consistent with
Plan Bay Area. Cities are not required to revise their land use policies and plans
(including General Plan and Specific Plans) to be consistent with Plan Bay Area
(Government Code section 65080(b)(2)(J)). Nonetheless, the Crossing Project site is
part of a Priority Development Area (PDA) for Dublin identified in the Plan which is
called the Transit Center. The Transit Center includes the Dublin Crossing area and
other adjacent development areas, such as the Dublin Transit Center adjacent to the
Dublin/Pleasanton BART Station. Therefore, the employment, population and
vehicle miles traveled projections for the Transit Center PDA in Plan Bay Area
include significant development outside the Dublin Crossing project. The final
projections for growth in the Plan Bay Area are not completely consistent with the
information on projected growth envisioned by the City. However, the Dublin
Crossing Project is consistent with the type of development envisioned for PDA
areas – mixed use, higher density, infill, transit-oriented development that promotes
Dublin Crossing Specific Plan
Final EIR
Page 31
the use of alternative modes of transportation and results in lower greenhouse gas
emissions from development.
Response to Comment 9-21 – Transportation/Impacts to Bicycles
The impacts to transit, bicycle and pedestrian modes of transportation are evaluated
in the EIR. Pages 3-234 to 3-236 of the Draft EIR (June 2013) provide an analysis of
the project impacts on bicycle and pedestrian modes. Furthermore, on page 3-272
of the Draft EIR, Mitigation Measure 3.12-10 provides a specific mitigation to
address bicycle and pedestrian circulation impacts.
Consistency of the proposed project with the Bikeways Master Plan was evaluated
on page 3-236 of the Draft EIR. Additionally, the Specific Plan would incorporate the
following measures from the City’s Bikeways Master Plan:
Develop a bicycle commuter route system that connects residential
neighborhoods to employment areas, multi-modal terminals, and schools.
Encourage employers to provide secure bicycle parking, showers and
changing rooms for bicycle commuters.
As a condition of project approval, require major development projects with
major transportation impacts to construct adjacent bicycle facilities included
in the proposed bicycle system.
Install bicycle stencils and bicycle-sensitive loop detectors (or other detector
type) on bikeways as part of new signals, signal upgrades, and
resurfacing/restriping projects.
The proposed project is adjacent to and would be connected with the Iron Horse
Regional Trail. The Iron Horse Regional Trail would be reconfigured with the new
project frontage and Scarlett Drive, and a secondary trail pathway could be
integrated along the southwestern edge of the Central Park, depending on the
eventual park design. According to the Bikeways Master Plan, The Iron Horse Trail
continues to the Bart station and in the future would go under Interstate 580 and
travel along the alignment of Owens Drive.
Response to Comment 9-22 – Transportation/Impacts to Bicycles
The Iron Horse Regional Trail will continue to operate as a Class 1 facility and the
development of the project will not change the function or the general location of
the trail. A grade-separated crossing is the preferred mitigation measure to ensure
that bicycle and pedestrian mobility across Dublin Boulevard is maintained. To this
end, the City is pursuing multiple sources of funding to conduct a feasibility analysis
of the Iron Horse Trail connectivity from Dougherty Road to the (East)
Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in
this location could significantly enhance bike and pedestrian access to and from the
project area and beyond. To support this project, the developer of the Dublin
Crossing project is contributing $50,000 towards the feasibility analysis, and the
City is seeking additional funding from the Alameda County Transportation
Dublin Crossing Specific Plan
Final EIR
Page 32
Commission (ACTC) Sustainable Communities Technical Assistance Program. It is
the City’s full intent to pursue a grade-separated crossing at this location, although
the City is also including the alternative mitigation measure of removing a portion of
the crosswalk across Dublin Boulevard in the EIR. Under the alternative mitigation,
bicyclists will continue to be able to cross Dublin Boulevard.
Response to Comment 9-23 – Transportation/New road construction
Chapter 4 of the Dublin Crossing Specific Plan describes the pedestrian and bicycle
circulation network in the project area, including sections on pedestrian circulation
(Section 4.2.1), bicycle circulation (Section 4.2.2), and public transit (Section 4.2.3).
These provide alternative means of transportation to automobile use. Chapter 4
also contains a multitude of figures and exhibits that illustrate roadway cross
sections and generous provisions for sidewalks and dedicated bike lanes (both Class
1 and Class 2) throughout the project area. Section 4.3.5 describes the intersections
that connect to the street network outside of the project area and notes that these
connections shall be enhanced to support the safe crossing of existing perimeter
streets. So, overall, the Project development does not focus on creating additional
roadway facilities and capacity. The comments on the economic costs of roadway
development and automobile use are not required to be analyzed under CEQA
because they are not environmental impacts. (CEQA Guidelines section 15131
(economic effects shall not be treated as environmental effects under CEQA)).
1
Wiseman, Bill
From:AlamedaTim@aol.com
Sent:Thursday, June 27, 2013 10:37 PM
To:Kristi Bascom
Subject:Dublin Crossing Comment
Kristi, I and my family own a condo in the Elan project facing DeMarcus Blvd. I am thrilled that mixed use development
will take place across Dublin boulevard from us. If done well, it can only benefit us, both economically (our home
value) and for our convenience (with nearby retail). My one big concern is traffic mitigation on DeMarcus with so many
residential units looking to BART as a primary transit provider. It appears that DeMarcus cannot be widened (with
residential projects on both sides) and I'm not sure how it can take more traffic - we're already a little anxious to see what
impact the current construction of added residential units on the old BART parking lot will have on DeMarcus. We enjoy
our proximity to BART, one of the main reasons we bought there, but don't want it to become a drawback that would drive
us away. I hope this will be considered, and look forward to hearing details on this aspect of the plan.
Sincerely,
William M. (Tim) Neilson
Dublin Crossing Specific Plan Final EIR
Page 33
Response to Comment Letter (via email) #10 from Mr. William Neilson, dated June
27, 2013
Response to Comment 10-1 – Traffic Mitigation on DeMarcus Boulevard The transportation and circulation analysis prepared for the EIR analyzed 37 intersections, including Demarcus Boulevard and Dublin Boulevard (study intersection No. 14). The existing Level of Service at this intersection in the AM peak hour is LOS C and in the PM peak hour is LOS B (see EIR Table 3.12-5). With the Dublin Crossing project and full buildout of the General Plan (“2035 Cumulative Plus Project”), the Levels of Service will measure LOS B in the AM peak hour and LOS C in the PM Peak hour (see EIR Table 3.12-10). The traffic impacts at this intersection with the proposed project are less than significant.
1
Wiseman, Bill
From:jasnew99@yahoo.com
Sent:Wednesday, July 10, 2013 5:52 PM
To:Kristi Bascom
Subject:Camp Parks Exchange / Dublin Crossing comments
Hi,
I strongly disagree with having more dense housing build in Dublin. I have lived in Dublin for a long time and have
seen congestion and other issues including crime come up. I think dense housing is great for builders but just those
is not good for the city. Our schools are now congested along with the other infrastructure like hospitals, roads,
parks. Dublin lacks office spaces. As a small business owner there is hardly decent choices for office space in
Dublin. Compare this with San Ramon and Pleasanton the city needs to think long term rather than short term gain.
regards
Jasmeet
Dublin Crossing Specific Plan Final EIR
Page 34
Response to Comment Letter (via email) #11 from Jasmeet, dated July 10, 2013
Response to Comment 11-1 – Proposed Project Land Uses Comment noted. Since the comment relates to the merits of the project and not environmental impacts, no further response is necessary.
1
Wiseman, Bill
From:Thomas McKinney <tfmckinney@gmail.com>
Sent:Wednesday, July 24, 2013 5:18 PM
To:Kristi Bascom
Subject:Comments on the DEIR for Dublin Crossing Project
By e-mail and US mail
Ms Bascom:
I am a retired geologist living in Dublin and provide the following comments on Appendix D - Geology and
Soils.
I have additional concerns about Hazardous Material raised by the Phase 1 site assessment but have not
completed a review of that section.
APPENDIX D - Preliminary Geotechnical Analysis - Geological Hazards Page 7 - Potential For Surface
Rupture
This paragraph is inappropriate and misleading, and does not adequately summarize the findings of the Fault to
Ground-rupture investigation discussed at length later in Appendix D. It should be updated to better reflect
these studies and related comments on the DEIR.
Page 8 - Liquefaction - bottom paragraph indicates that the thickness of potentially liquefiable sandy layers
used in the analysis of liquefaction was 1/2 to 2 feet. However, on p.5 it is indicated that the sandy soil layers
were generally encountered below depths of 15 ft, with thicknesses ranging to 6 feet, What was the thickness of
sandy layers that was used in the analysis and did it include layers up to 6 ft and if not why not?
Fault To Ground-Rupture Investigation - Page 3 - Faulting
Reference is made to Plate 5 - Fault Activity Map with no discussion in the text or a reference in the text to its
source. Full disclosure would indicate that the reference is CGS (2010) and should include a discussion of the
fact that Plate 5 shows that site is in the southern part of the Pleasanton Fault Zone and is mapped at the site as -
"Holocene fault displacement (during the past 11,700 years) without historical record" (orange color). The site
is in the southern portion of this zone and is shown as a solid line while areas of the fault to the north of the site
are shown as the same classification (orange) but as a dashed line. The southern part of the Pleasanton Fault
Zone south of Highway 580 is designated as "Quaternary Fault (age undifferentiated)" (Purple).
Page 3 - 2nd paragraph - last sentence. "The Pleasanton Fault Zone at the site is depicted by short dashed lines
on the Pleasanton Fault Zone Map, which indicates that the CGS considers this trace to be an inferred location."
This is true but again full disclosure would require that it should be pointed out that study maps of the site area
(CGS FER 109 - 1/30/81 and Division of Mines and Geology Open File Report - 81-9 (1981) which apparently
formed the basis for CGS FER 109 10/31/81, show both solid and dashed lines for the fault traces within the
site boundary. The map legend indicates " Solid lines indicate well defined features; dashed lines indicate less-
well defined features." All of the trenches examined in this site investigation were located in the southern part
of the site where CGS indicates that the races are less-well defined and did not include any in the northern
portion where CGS indicates that they are well-defined.
TRENCH STRATIGRAPHY
2
Page 10 first paragraph indicates that Log Unit D, the inferred base of the modern soil profile (Holocene)
which occurs in trenches across the site is an uninterrupted layer without distortion. This does not appear to be
the case. The northeastern portion of T-1 at about 0 + 70 ft Log Unit D as well as six other Log Units is
interrupted along a straight steep line and is indicated on the trench profile with question marks along its length.
Page 10 - last Paragraph indicates that this feature in T-1 and other segments of T-2 and T-3 trenches are
channel features which have channel deposits which have channel deposits which do not extend up into the
modern soil (Log Units A thru D) and are inferred to be older than about 3,000 years. Again this is not true for
for the feature in T-1 where Unit D is interrupted. In addition this questioned feature is distinctly different from
the other channel features and deposits elsewhere in the trenches (T-2 and T-3). The feature in T-1 is much
steeper and deeper that the other inferred channels. The T-1 feature is about 14 ft deep while the inferred
channels in T-2 and T-3 are 4 to 5 ft deep, comparable to the current drainage culvert. In addition, the log
comment on T-! "Failure Slicks" is not addressed in the text and lends additional support for a structural and not
a channel origin for this feature in T-1.
CONCLUSION
Thus, the siting of trenches away from the northern portion of the site where the fault traces are well defined,
the interruption of portion of the modern soil profile, Log Unit D in T-1, the steep and deeper nature of the
questioned feature in T-1 compared to other areas which show channel deposits and the notation of "Failure
Slicks" in the T-1 log, do not support the conclusion that ".. it is unlikely that surface rupture due to fault
displacement will occur at the site."
Thomas F. McKinney, PhD
Dublin Crossing Specific Plan Final EIR
Page 35
Response to Comment Letter (via email) #12 from Mr. Thomas McKinney, dated
July 24, 2013
Note: All comments are in reference to Appendix D – Preliminary Geotechnical
Analysis
Response to Comment 12-1 – Potential For Surface Rupture The paragraph the commenter refers to is in Appendix D, the Preliminary Geotechnical Investigation, Dublin Crossing Project at Camp Parks, Dublin California that was completed in March 2012. Additional analysis related to potential fault rupture (Fault Ground-Rupture Investigation Proposed Dublin Crossing Mixed Use Development, Camp Parks Reserve Forces Training Area, Dublin CA) was later completed in March 2013, which is also included in Appendix D. The paragraph in the March 2012 document is superceded by the 2013 analysis. The Draft EIR reflects the conclusions of the more detailed fault rupture study that was completed in March 2013.
Response to Comment 12-2 – Liquefaction The only dimensions in the bottom paragraph on page 8 of the Preliminary Geotechnical Investigation are to half an inch to two inches of differential settlement and there are no comments on the thickness of potentially liquefiable sand layers. Pages 8-9 of the Preliminary Geotechnical Investigation states: “Settlement calculations due to liquefaction indicate that the potential for liquefaction-induced settlement can range from half an inch to two inches with differential settlement on the order of 1 inch.” For liquefaction-induced settlement calculations, the engineers used sandy layers with a thickness up to six feet, which was indicative of the site-soil conditions as presented by the boring logs.
Response to Comment 12-3 – Plate 5 – Fault Activity Map Source of the Fault Activity Map is shown on Plate 5. The map was included in the report to show the most recently published and generalized fault setting with respect to the San Francisco Bay Area. As stated in the report immediately preceding the citing of Plate 5 – “The project site and the San Francisco Bay Area are located in an area characterized by moderate to high seismic activity”. The detail suggested by the commenter is presented on the Fault Activity Map and is not needed in the report text because it would have no impact on the interpretation or findings presented in the report.
Response to Comment 12-4 – Pleasanton Fault Zone The California Geologic Survey (CGS) Revised Official Special Studies Zones (SSZ) Map of the Dublin quadrangle (effective January 1, 1982) was published after both CGS FER 109 - 1/30/81 and Division of Mines and Geology Open File Report - 81-9 (1981). The 1982 CGS SSZ map provides CGS’ most up-to-date and official best estimate of where faults may be located. The map shows all three fault traces
Dublin Crossing Specific Plan Final EIR
Page 36
through the entire SSZ as short dashes (inferred) and shows the two longer traces as queried (additional uncertainty). The authors of the Preliminary Geotechnical Investigation conclude, and the EIR supports the conclusion, that the locations of the exploratory trenches with respect to project-site coverage are adequate, reasonable, and comply with the intent of the Alquist-Priolo Act.
Response to Comment 12-5 – Trench Stratigraphy The “straight steep line” noted by the commenter is the west margin of “clayey sand/sandy clay (CL), light to medium brown, wet, loose to medium dense, channel deposit”. The contact is queried to indicate an indistinct boundary between the channel deposit and soil stratigraphic layers. No sharp contact, slickensides, gouge, distorted beds adjacent to the contact, or other features that would be associated with fault offset are present along the contact. The contact conforms to an erosional feature and not a structural feature.
Response to Comment 12-6 – T-1, T-2, and T-3 Trench Features Because of the presence of caving and an erosion channel at the location of Trench T-1, Trench T-6 was later excavated and logged between Trenches T-1 and T-2. Trench T-6 was located to fill in information that was obscured in Trench T-1 and provided an overlapping profile of the soil layers observed in Trenches T-1 and T-2. The overlapping configuration of Trenches T-1, -2, and -3 shows that Log Unit D, and other soil layers, are continuous and uninterrupted across that part of the project site. The depth of the channel deposit logged in Trench T-1 is based on exposure in the trench and would be expected to be deeper or shallower at other locations. Channel deposits can be of differing depths depending on relief of base level, energy and volume of the water flow, localized erodability of the soil, and other factors. Evidence observed in Trench T-1 including continuity of soil layers across the project site indicates that the feature east of about Station 0+70 is an erosional channel cut into the soil layers. The “Failure Slicks” notation on trench log T-1 is included in the shaded area of the log representing caving and refers to slickensides in the clay soil that failed during caving of the trench. The most recent and official SSZ map shows the inferred fault traces as similarly uncertain across the project site and throughout the SSZ. The possible fault traces in northern portion of the site are no more certain than in the southern portion. The location of the BSA trenches adequately covers the project site. The soil profile in Trench T-1 is locally eroded by a clayey sand / sandy clay channel deposit that has an indistinct (queried) contact with adjoining older soil layers. The contact is without features that would be associated with fault offset. An additional Trench (T-6) was excavated and logged between and overlapping T-1 and T-2 that
Dublin Crossing Specific Plan Final EIR
Page 37
showed that Log Unit D is continuous and uninterrupted by faulting. The steep and deep nature of the channel deposit appears to be a consequence of several local factors causing erosion, none of which are associated with fault displacement. Based on geologic interpretation of the six exploratory trenches and other evidence presented in the March 2013 Fault Ground-Rupture Investigation report, it was concluded that an active trace of the inferred Pleasanton fault does not cross the Dublin Crossing project site. The conclusion in the report that "it is unlikely that surface rupture due to fault displacement will occur at the site" is an apt and appropriate interpretation of the observed evidence and complies with the intent of the Alquist-Priolo Act. The report and findings have been peer reviewed and approved by a consulting geologist for the City of Dublin as required by the State of California Alquist-Priolo Earthquake Fault Zoning Act of 1972 and represents accurate information and analysis for the purposes of this EIR.
1
Wiseman, Bill
From:Thomas McKinney <tfmckinney@gmail.com>
Sent:Monday, July 29, 2013 3:10 PM
To:Kristi Bascom
Subject:Comments on Appendix E on the DEIR for Dublin Crossing Project
By E-mail and US Mail
Ms Bascom:
Appendix E - Impact 3.7-4 Results in the Disturbance of Contaminated Soil and Groundwater
Page 3-135 Indicates based on the Phase I ESA that 3 sites are identified which have potentially significant
impact but indicates that the US Army has committed to remediating them to regulatory approval.
There is only one paragraph which addresses groundwater contamination and indicates that an upgradient
property has affected the underlying groundwater with petroleum hydrocarbons and concludes without
providing any information that based on the distance of this site, it is unlikely that the property could have
affected the project area.
Is this property mentioned the Federal Correction Institute located a few blocks away on 8th Street? This
dismissal of potential affects at the project area cannot be accepted without location and time of
occurrence information, and a groundwater analysis evaluating contaminant and groundwater travel times and
distances. Provide these further details.
What are the plans, if any, for a Phase II ESA and when would it occur, it's focus and its relationship to the EIR
process?
Trench Contamination - There is no mention of the petroleum odor contamination observed in Fault Rupture
Study Trench T-3 which was found at and below the water table. What soil and groundwater investigations, if
any, have been conducted for this contamination. Provide their results.
Secondary Impacts - The proposed action includes the removal of Army facilities and activities from the
project area. What, if any, of these activities will be relocated and/or developed in adjacent areas and what will
be their short- and long-term impacts and the cumulative impacts from these relocation actions and the project
area impacts?
Thanks for your consideration.
Thomas F. McKinney, PhD
Dublin Crossing Specific Plan Final EIR
Page 38
Response to Comment Letter (via email) #13 from Mr. Thomas McKinney, dated
July 29, 2013
Response to Comment 13-1 – Potential Effects from the Federal Correction
Institute The Federal Correction Institute is located at 5701 8th Street approximately 0.298 miles northwest of and up-gradient of the project area. On April 25, 2008, a 3,000-gallon diesel aboveground storage tank overflowed at the property, releasing approximately 100 gallons of diesel. Excavation of the diesel-impacted soil and asphalt within the spilled area was conducted from April through May 2008. A soil and groundwater investigation was performed in September 2008 to initially characterize the impact of the spill. Results of the investigation indicated elevated concentrations of diesel in the soil samples and detectable concentrations of diesel in the groundwater samples. A supplementary investigation was conducted in August and September 2009. As part of the investigation, three monitoring wells were installed. Soil and groundwater analytical data from the investigation indicated elevated diesel concentrations within the spilled area. A closure report prepared by the U.S. Department of Justice Federal Bureau of Prisons was submitted to Alameda County Environmental Health for their review in October 2010. The report concluded that the impacted area was limited to the immediate vicinity of the spilled area and that the residual contaminants present in the soil and groundwater should naturally attenuate over time. Based on the localized impacted area and distance from the project area (approximately one-quarter mile or greater), it is unlikely that the property could have impacted the project area. Response to Comment 13-2 – Preparation of a Phase II ESA There are currently no plans for a Phase II ESA. As described on page 3-136, the U.S. Army and NASA are responsible for environmental remediation of existing hazardous materials within the project area and have agreed to remediate the project area to state and federal requirements. Contamination that remains after the U.S. Army and NASA transfer the property to the project applicant and/or that needs to be remediated to a higher standard (e.g. residential) will either be remediated prior to and during site grading and demolition activities associated with future development within the project area.
Response to Comment 13-3 – Trench Contamination Remedial activities to remove the impacted material that was observed in Trench T-3 is being conducted by the U.S. Army in conjunction with the local regulatory agencies. The remedial activities are still ongoing.
Response to Comment 13-4 – Secondary Impacts from Relocation of Existing
Army Facilities
Dublin Crossing Specific Plan Final EIR
Page 39
The existing Army facilities located within the project area would be demolished and new facilities constructed within the remaining portion of Camp Parks outside the proposed project area. An analysis of impacts associated with redevelopment of Camp Parks was analyzed previously in the U.S. Army Draft and Final EIR on Master
Planned Redevelopment at Camp Parks (2009).
Comments on Draft EIR from SunCal Page 1 July 22, 2013
ES-2
proposed project includes up to 1,995 residential units (not including secondary
units);
Need to delete reference to secondary units being above the cap
ES-10
MM 3.2-5: Locate Sensitive Receptors Away from Existing Toxic Air Contaminants and
Implement HVAC systems for Sensitive Receptors in the vicinity of BAAQMD permitted Toxic Air
Contaminant sources. Prior to building permit issuance, the project applicant shall demonstrate to
the City of Dublin Community Development Director that the following mitigation measures will be
implemented in order to reduce the potential impact from TAC exposure due to the potential siting
of residential or other sensitive receptor development within 1,000 feet of a BAAQMD identified
stationary TAC source:
This gets into more detail later, but it is very unclear if this is claiming that there are any instances
of land use controls which need to exist on the project site due to any sort of TAC.
ES-12
All new commercial development projects that have the potential to emit TACs shall be located
1,000 feet away from existing and proposed development used by sensitive receptors, unless a
project-specific evaluation of human health risks is conducted and the results of the evaluation
determine that no significant impact would occur.
Same as above
ES-13
prepare a wetland mitigation plan that ensures no-net-loss of wetland and waters
habitat and is approved by the City and applicable resource agencies.
Approval by City?
Page ES-15
MM 3.3-2a ….If no special-status plants are located during the surveys, no further
mitigation measures would be required. If any federal or state plant ESA listed species
are found during the rare plant surveys, the project applicant shall consult with the
CDFW and USFWS to obtain incidental take permits under Section 2081 of the CESA
and either Section 7 or 10 of the FESA.
Request clarity that this mitigation measure applies to plants listed under the State or
Federal ESA, and that MM 3.3-2b applies to other special status plant species
Page ES-21
The project applicant shall could preserve additional upland habitat within a USFWS
approved conservation area as determined in consultation with the USFWS. The Project
proponent shall coordinate or consult”
This measure would be determined in consultation with the USFWS, if required.
Impact 3.3-5: Protocol level surveys for vernal pool invertebrates were conducted
throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as during the
Comments on Draft EIR from SunCal Page 2 July 22, 2013
summer of 2012 (dry season) and 2013 wet season by Cardno Entrix. No vernal pool
fairy shrimp, vernal pool tadpole shrimp or longhorn fairy shrimp were found during
these surveys. California linderiella was found during the 2002-2003 surveys, but not
within the project area. New surveys are currently being conducted by Cardno ENTRIX.
Since the new surveys have not been completed at this time, the presence of this species
within the project area is assumed in the analysis of project impacts.
They list the surveys and say that there are no shrimp, but then they contradict themselves
and say that new surveys are being conducted and that presence is assumed. I am fine
with the mitigation measures, as we don’t have concurrence on the survey results from
the USFWS yet, but it needs to be clear that the 2012-2013 surveys were conducted as
MM 3.3-5, not in addition to it.
MM 3.3-5: Consult with the USFWS and Reduce Impacts on Vernal Pool Invertebrates
and Their Habitat.
The project applicant shall prepare a habitat assessment for the vernal pool
invertebrates. If vernal pool invertebrates are found within the project area during the
habitat assessment, the project applicant shall comply with the following steps to ensure
protection of vernal pool invertebrates and their habitat and that impacts are reduced to
a less than significant level.
a. The project applicant shall retain a qualified biologist to conduct habitat
assessments for protected vernal pool invertebrates and based on the results of
the habitat assessments, determine in consultation with the USFWS if protocol
level vernal pool invertebrate surveys will be required within the project area.
b. If suitable habitat is present, the project applicant, in consultation with the
USFWS and CDFW, shall either (1) conduct a protocol-level survey for federally
listed vernal pool crustaceans, which will identify other protected vernal pool
invertebrates (curvefooted Hygrotus beetle and San Francisco fork-tailed
damselfly), or (2) assume presence of federally-listed vernal pool crustaceans and
curve footed Hygrotus beetle and San Francisco fork-tailed damselfly in areas of
suitable habitat. Surveys shall be conducted by qualified biologists in accordance
with the most recent USFWS guidelines or protocols to determine the time of year
and survey methodology (survey timing for these species is dependent on yearly
rainfall patterns and seasonal occurrences, and is determined on a case-by-case
basis). The USFWS protocol level surveys shall be conducted as part of the
Section 404 permit process within 2-years of the application. If surveys reveal no
occurrences of federally listed vernal pool crustaceans or other protected vernal
pool invertebrates, no further mitigation would be required.
c. If surveys determine that one or more special-status vernal pool invertebrate
species occurs within the project area, or if the project applicant, in consultation
with the USFWS and/or CDFW, assumes presence of federally-listed vernal pool
invertebrates in all affected habitats, the project applicant shall provide
information to the USACE to support Section 7 consultation with the USFWS and
the project applicant shall ensure no net loss of habitat shall be achieved through
avoidance, preservation, creation and/or purchase of credits as a part of the
Section 7 Consultation process. The selected measures may be part of the
permitting process.
Comments on Draft EIR from SunCal Page 3 July 22, 2013
USFWS and CDFG have no published protocol for curvefooted Hygrotus beetle and San
Francisco fork-tailed damselfly. It is likely best to exclude all reference to the
2012-2013 Branchiopod surveys to avoid confusion. By including referencing to
them, but omitting the negative findings, it may obligate the project to additional
surveys that would not be necessary otherwise.
Pg. ES -37 MM 3.8-4b .Discuss with City the intent of the proposed rerouting of the Basin #2 outfall .
ES-38
MM 3.8-4b: Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the
grading permit associated with the construction of the proposed community park, the project
applicant shall submit to the City a revised stormwater drainage plan that realigns the stormwater
outflow associated with the proposed North Basin #2 from the 1.7 acre Chabot Creek riparian
channel (as is currently proposed) to a separate underground pipe that connects directly with the
existing box culvert located at proposed Scarlett Court Extension and Dublin Boulevard, and
thereby avoids stormwater discharge into the 1.7 acre Chabot Creek riparian channel.
This is a new proposal. It is unclear why it is necessary.
ES-48
IHT.
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_c_r_o_s_s_i_n_g_ _p_r_o_j_e_c_t_ _c_a_n_n_o_t_ _b_e_ _c_o_n_s_t_r_u_c_t_e_d_ _b_y_
_y_e_a_r_ _2_0_3_5_,_ _a_n_ _a_l_t_e_r_n_a_t_i_v_e_ _m_i_t_i_g_a_t_i_o_n_ _w_o_u_l_d_
_b_e_ _t_o_ _e_l_i_m_i_n_a_t_e_ _t_h_e_ _c_r_o_s_s_w_a_l_k_ _o_n_ _t_h_e_ _e_a_s_t_
_l_e_g_ _o_f_ _t_h_e_ _S_c_a_r_l_e_t_t_ _D_r_i_v_e_ _a_n_d_ _D_u_b_l_i_n_
_B_o_u_l_e_v_a_r_d_ _i_n_t_e_r_s_e_c_t_i_o_n_._ _T_h_i_s_ _w_o_u_l_d_ _r_e_q_u_i_r_e_
_p_e_d_e_s_t_r_i_a_n_s_ _a_n_d_ _b_i_k_e_s_ _f_r_o_m_ _t_h_e_ _I_r_o_n_ _H_o_r_s_e_
_T_r_a_i_l_ _t_o_ _c_r_o_s_s_ _t_h_r_e_e_ _c_r_o_s_s_w_a_l_k_s_ _r_a_t_h_e_r_ _t_h_a_n_
_o_n_e_._ _B_e_c_a_u_s_e_ _o_f_ _t_h_e_ _e_f_f_e_c_t_s_ _o_f_ _t_h_e_
_a_l_t_e_r_n_a_t_i_v_e_ _m_i_t_i_g_a_t_i_o_n_ _o_n_ _p_e_d_e_s_t_r_i_a_n_ _a_n_d_
_b_i_k_e_ _m_o_b_i_l_i_t_y_,_ _t_h_e_ _g_r_a_d_e_ _s_e_p_a_r_a_t_e_d_
_c_r_o_s_s_i_n_g_ _i_s_ _t_h_e_ _C_i_t_y_’s_ _p_r_e_f_e_r_r_e_d_ _m_i_t_i_g_a_t_i_o_n_
_a_t_ _t_h_i_s_ _l_o_c_a_t_i_o_n_._ _
Pragmatically this seems to be a nonfunctional solution. Should we reference
changing the timing of pedestrian triggered light sequencing?
ES-51
The project impacts to freeway ramps could be mitigated by changing the ramp metering rates so
that more vehicles could access the freeway. However, the freeway ramps are operated by
Caltrans, which sets metering rates based on overall operations in the freeway corridor. In the
future, major improvements are planned for I-580 in the project vicinity, including the addition of
High Occupancy Vehicle and auxiliary lanes. In addition, as the Cities surrounding the I-580
corridor continue to build out and additional parallel east/west connectors such as the Stoneridge
Drive and Dublin Boulevard extensions are completed, it is likely that the ramp meter rates would
change over time to accommodate the demand on both the freeway ramps and freeway
segments.
If “major improvements are planned” then should we have language that if these
improvements were to occur that our significant unavoidable impact could be
mitigated? If impact is same in no project scenario is it still a significant impact of
project?
Comments on Draft EIR from SunCal Page 4 July 22, 2013
Pg. 2-7 2.6 Proposed Land Use & Development Plan - Should reference Figure 2-7, not 2-9. Pg. 2-7 Table 2-1 - Header should read "net" acreage instead of "total" acreage Pg. 2-10 Central Park and Iron House Trail Realignment - 3rd paragraph should read "two underground onsite storm drainage detention basins…"
2-13
T_h_e_ _C_a_m_p_ _P_a_r_k_’s_ _e_n_t_i_r_e_ _1_,_8_0_0_+_ _a_c_r_e_
_w_a_t_e_r_s_h_e_d_ _d_r_a_i_n_s_ _t_h_r_o_u_g_h_ _t_h_e_ _p_r_o_j_e_c_t_
_a_r_e_a_._ _
Pg. 2-14 Storm Drain Infrastructure - Last paragraph should read "two underground onsite storm drainage detention basins…"
2-15
Former Building 109/Parks Reserve Forces Training Area (PRFTA) 2 - Former
Building 109/PRFTA 2 located at the southwestern portion of the project area
containing concentrations of dioxin and lead within the surficial soil above the
acceptable risk-based screening levels for closure. The U.S. Army is awaiting
confirmation from the regulatory agencies regarding the remediation of this site
(Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army,
Camp Parks on May 21, 2013).
This site is fully remediated. The only remaining activity is monitoring wells.
Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of the
project area and requires land use controls by the CRWQCB to obtain an NFA
status. The CRWQCB issued a Pre-NFA determination on May 28, 2008. This
determination acknowledged that groundwater cleanup objectives have been met.
However, a deed restriction (land use control) is required to achieve a full NFA
designation due to the presence of soil which contains diesel concentrations greater
than acceptable levels. The Department of Toxic Substances Control (DTSC)
concurred with these findings in January 20, 2012.
Page 2-15 (twice), Page 3-128 (twice), Page 3-135 (twice), Page 3-145
Reference to Central Valley Flood Board or CRWQCB is inapplicable to this project. All
instances should reference the San Francisco RWQCB, which had jurisdiction in this
area.
Comments on Draft EIR from SunCal Page 5 July 22, 2013
Pg. 2-17 Table 2-2 Phasing Plan – Footnote #1 missing.
3-11
Building heights associated with the proposed project would range from a maximum
height of 40 feet and three stories for the DC Lower Density Residential (DC LDR)
and DC Medium Density (DC MDR) land use districts to 75 feet and six stories for
the General Commercial/DC Medium Density Residential (GC/DC MDR) and
General Commercial/DC High Density Residential (GC/DC HDR) land use districts.
We need to identify methodology of measuring. What start and end point?
3-34 under total emissions:
Due to the scale of the proposed project, which would generate 19,641 new trips per
day, emissions would exceed the BAAQMD thresholds
This total trip number is different than the one in traffic section (22,047).
3-36
There are no mobile TAC sources located within 1,000 feet of the project area as
Interstates 580 and 680 are located 1,500 feet to the south and 5,000 feet to the
west of the project area, respectively. However, there are several stationary TAC
and PM2.5 sources located within 1,000 feet of the project area (BAAQMD 2013).
Including several diesel generators associated with the commercial area
approximately 300 feet east of the project area, and three diesel engines located
within Camp Parks, adjacent to the northern site boundary. Based on the screening
level data provided by the BAAQMD, these stationary TAC sources have the
potential to exceed the BAAQMD cancer risk thresholds of 10 in one million
(BAAQMD 2012).
Again this is unclear if there are controls being suggested?
Page 3-45
Cardno Entrix prepared a biological resource technical report on behalf of the project
applicant in May June 2013, which updates previous biological technical studies that
were prepared by the U.S. Army for the Final Environmental Impact Statement on Master
Planned Redevelopment at Camp Parks (U.S. Army 2009). This technical report was peer
reviewed by RBF Consulting for technical accuracy and is included as Appendix C.
May should be June
In addition to approximately 77 acres of developed and semi-developed land within the
project area, wetlands and non-native grasslands are also located within the project
area. The acreage of these vegetation communities is shown below in Table 3.3-1:
Habitats and Vegetation Communities within the Project Area and on Figure 3.3-1:
Existing Biological Habitats.
The table and figure do not represent the Project Area as defined in the document. No
data/references for the Alameda County Surplus Property (ACSP). Overall, section
Comments on Draft EIR from SunCal Page 6 July 22, 2013
provides insufficient data to reach conclusion for this area, as the biological resources
technical report Study Area is not synonymous with the Project Area.
Table 3.3-1. Habitats and Vegetation Communities within the Project Area
Appears to include acreages for other waters (as included in the Cardno biological
resources technical report Study Area) located outside the Project Area as defined in the
DEIR.
Page 3-47
Wetlands and Drainage Ditches
This section only addressed the drainage ditches (linear features) within the project that
qualify as wetlands per the USACE protocol, that is, wetland drainage ditches. Other
wetlands are included on page 3-48.
Other waters of the U.S. include Chabot Canal (Canal 01), and an unnamed canal
(Canal 02).
A portion of Canal 02 addressed in the Cardno biological resources technical report falls
outside the Project Area as defined in the DEIR.
Page 3-50
According to the CNDDB, USFWS, and CNPS queries, a total of 68 special-status
species and three rare natural communities and USFWS-designated critical habitat for
California tiger salamander (Ambystoma californiense), California red-legged frog
(Rana draytonii), Alameda whipsnake (Masticophis lateralis euryxanthus), and vernal
pool fairy shrimp (Branchinecta lynchi) are known to occur in the project area within the
Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical quadrangle.
Produce reference for statement regarding SSP occurrence in project area (as defined in
the DEIR): According to biological resources technical report these species are known to
occur within the Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical
quadrangles, not the Study Area or Project Area.
Cardno Entrix performed queries of the California Department of Fish and Game,
Natural Diversity Database (CNDDB), California Native Plant Society (CNPS) Online
Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPSEI)
and the United States Fish and Wildlife (USFWS) Online Species List of Federal
Endangered and Threatened Species to identify known biological resources within the
greater project vicinity project area.
This is incorrect; the Cardno report identified known biological resources within the
overall project vicinity, extending greater than 5 miles from the Project Area as defined
in the DEIR.
Page 3-51
Previous Biological Surveys
Inconsistent with mitigation measures and text; update to include 2012-2013
Branchiopods surveys or remove references to 2012-2013 in other locations in the DEIR.
Surveys should consistently be applied to analysis, and referenced as such throughout the
document. One option is to say that updated surveys are in progress, as results have not
yet been accepted by the USFWS
Comments on Draft EIR from SunCal Page 7 July 22, 2013
Life histories of special-status plant and animal species identified by the CNDDB,
USFWS, and the California Native Plant Society (CNPS) lists that have a moderate or
higher likelihood of occurring in the project area are described below:
Inconsistent with species included below, many are listed as having a low likelihood of
occurrence: conservancy fairy shrimp, Longhorn fairy shrimp, Vernal pool fairy shrimp,
curved-foot hygrotus diving beetle, San Francisco forktail damselfly, California
linderiella, Western pond turtle, California tiger salamander, California red-legged frog,
tricolored blackbird, ferruginous hawk, Swainson’s hawk, Prairie falcon, San Joaquin kit
fox, Palmate-bracted bird’s-beak, and Northern California black walnut.
There are no known occurrences in Alameda County. Although not a target species, this
species was not detected in focused surveys between 2002 and 2003 and during wet and
dry surveys conducted by Cardno Entrix in 2012 and 2013.
Same as above comment regarding 2012-2013 Branchiopod surveys. If including survey
results they should be consistently incorporated into text and Mitigation Measures.
Page 3-53
Separate paragraph for Western pond turtle (FYI: this was a typo in the Cardno report as
well).
Page 3-54
There are several known CNDDB occurrences for this species within two miles of the
project area. The nearest occurrences are 1.4 miles to the north and 1.2 miles to the
northeast of the project area. USFWS protocol requires that occurrences be evaluated
within one mile of a proposed project. The first occurrence is located within Camp Parks
training area. The second during the March 2012 field survey occurrence is located
within Tassajara Creek
Clarify that no occurrences are located in the project area. No CRLF were observed
during the March 2012 field survey.
Page 3-55
CRLF were not observed during any of these surveys. No suitable aquatic habitat was
observed within the project area during the March 2012 survey conducted by Cardno
Entrix Therefore, the likelihood of California Tiger Salamander California Red-legged
frog occurring within the project area is considered low.
Should reference CRLF not California Tiger Salamander
Page 3-61
As the CNDDB contains recorded occurrences of this species within the project area and
it was observed during the plant surveys, the likelihood of Congdons tarplant to occur
within the project area is considered moderate high.
Given that this species is known to occur within the Project area, and conditions have not
changed significantly since those occurrences, the likelihood of this species occurring is
high.
Page 3-62
Hairless popcorn-flower (Plagiobothrys glaber)
This species is believed to have been extirpated in California. CNNDB occurrence is
from 2002, but identification is uncertain and has been disputed. All other occurrences
are from pre-1954. This species is an annual herb ascending to erect with cauline leave
Comments on Draft EIR from SunCal Page 8 July 22, 2013
that occurs in meadows and alkaline seeps, as well as coastal salt marshes and swamps.
During floristic surveys, this species was not found within the project area. Hairless
popcorn-flower (Plagiobothrys glaber) has a low likelihood of occurrence.
Does not state likelihood of occurrence consistent with other species analysis, suggest
additional text.
Page 3-64
The California Endangered Species Act (CESA, Fish and Game Code of California,
Chapter 1.5, Sections 2050-2116) prohibits the take of any plant or animal listed or
proposed for listing as rare (plants only), threatened, or endangered.
CESA does not afford protection to rare species, plants or otherwise. Rare plant
protection is granted by the NPPA. 1977. This statement is confusing and inaccurate.
Page 3-65
California Department of Fish and Game Wildlife (CDFW) Code
The California Fish and Game Wildlife Code includes regulations governing the use of,
or impacts on, many of the state’s fish, wildlife, and sensitive habitats.
While California Department of Fish and Game (CDFG) and the new name of the
department, California Fish and Wildlife (CDFW), is used inconsistently throughout the
document, the regulatory code name has not changed and should be referenced as the
California Fish and Game Code in all cases.
Page 3-68
1.4 acres of other waters of the U.S.
A portion of this acreage appears to be outside Project area. No analysis of ACSP is
included.
Page 3-70
If any federal or state ESA listed plant species are found during the rare plant surveys,
the project applicant shall consult with the CDFW and USFWS to obtain incidental take
permits under Section 2081 of the CESA and either Section 7 or 10 of the FESA.
Need to clarify that this consultation only applies to ESA listed species.
Special Status Wildlife Species – Mammals
Page 3-72
Although no surveys specific for Western Pond Turtle have been conducted, Western
Pond Turtle was observed within the project area greater Camp Parks Training Area
during surveys for California Red Legged Frog.
Inaccurate, Western Pond Turtle was observed within the Camp Parks Training area but
outside the Project area. Please provide reference for observations within project area.
Page 3-73
The Cantonment Area of - Camp Parks
Recommend specifying project area for consistency.
Page 3-76
ES-21
Comments on Draft EIR from SunCal Page 9 July 22, 2013
The project applicant shall could preserve additional upland habitat within a USFWS
approved conservation area as determined in consultation. The Project proponent shall
coordinate or consult”
This measure would be determined in consultation with the USFWS, if required.
Protocol level surveys for vernal pool invertebrates were conducted throughout Camp
Parks in 2002 and 2003 by the U.S. Army, as well as during the summer of 2012 (dry
season) and 2013 wet season (in progress) by Cardno Entrix.
Since the new surveys have not been completed at this time, the presence of this species
within the project area is assumed in the analysis of project impacts.
References new surveys with negative findings and then contradicts survey findings,
needs consistency.
Removal of these wetlands could result in the potential take of protected vernal pool
branchiopods and other protected invertebrates, if they were to occur, and their habitat.
This would be considered a potentially significant impact.
Surveys have previously been conducted for curve-footed Hygrotus beetle and San
Francisco fork-tailed damselfly been conducted with negative findings. Since there is no
published survey protocol, and these species would be identified as part of the
branchiopod survey protocol, recommend striking, or specifying that they would be
identified during branchiopod surveys.
MM 3.3-5
See comments regarding consistency on how in-progress branchiopod surveys are
applied.
Page 3-51 (3 times), Page 3-55 (three times), Page 3-60, Page 3-61, Page 3-74, and
Page 4-10.
Recommend that they either define or change the “Cantonment Area.” This area is not
defined or otherwise identified in the DEIS and it is unclear to a reader that is not familiar
with the project background that the project is located within the former Camp Parks
Cantonment Area.
Page 3-151 and Page 3-208
Order No. 99-08-DWQ is a previously expired regulation (expired in 2004, and extended
to 2009) and does not apply to this project. This project is expected to fall under 2009-
0009-DWQ as amended by 2010-0014-DWQ. However, as 2009-0009-DWQ is set to
expire September 2, 2014 alternative text may be that the project shall comply with
requirements of the NPDES General Permit for Storm Water Discharges Associated with
Construction and Land Disturbance Activities. (Construction General Permit). Pg.3-165 School shown under impact 3.9-3 as 11 acres .
3-166 table
Consistent. The Specific Plan includes a maximum of 1,995 residential units; 200,000 square feet
of commercial uses, a 30 net-acre community park; five acres of neighborhood park and an 11
acre elementary school site.
Comments on Draft EIR from SunCal Page 10 July 22, 2013
Change school to 12 acres.
3-187
A_c_c_o_r_d_i_n_g_ _t_o_ _t_h_e_ _D_u_b_l_i_n_ _U_n_i_f_i_e_d_
_S_c_h_o_o_l_ _D_i_s_t_r_i_c_t_’s_ _D_e_m_o_g_r_a_p_h_i_c_ _S_t_u_d_y_
_a_n_d_ _F_a_c_i_l_i_t_i_e_s_ _P_l_a_n_,_ _2_0_1_1_-_2_0_1_2_,_ _e_a_c_h_
_n_e_w_ _s_i_n_g_l_e_-_f_a_m_i_l_y_ _h_o_m_e_ _(_l_a_r_g_e_ _a_n_d_
_m_e_d_i_u_m_ _l_o_t_ _s_i_n_g_l_e_ _f_a_m_i_l_y_ _h_o_m_e_)_
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_0_._5_2_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _h_o_m_e_;_
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_h_o_u_s_i_n_g_ _(_o_t_h_e_r_w_i_s_e_ _k_n_o_w_n_ _a_s_
_“t_o_w_n_h_o_m_e_s_”)_ _g_e_n_e_r_a_t_e_ _a_n_ _a_v_e_r_a_g_e_
_0_._2_9_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _h_o_m_e_;_ _a_n_d_ _a_
_n_e_w_ _h_i_g_h_ _d_e_n_s_i_t_y_ _r_e_s_i_d_e_n_t_i_a_l_
_(_m_u_l_t_i_f_a_m_i_l_y_ _h_o_u_s_i_n_g_ _d_e_v_e_l_o_p_m_e_n_t_)_
_g_e_n_e_r_a_t_e_s_ _a_n_ _a_v_e_r_a_g_e_ _o_f_ _0_._1_2_5_ _K_-_1_2_
_s_t_u_d_e_n_t_s_ _p_e_r_ _u_n_i_t_ _(_D_U_S_D_ _2_0_1_2_)_._ _
Pg. 3-199 School shown under impact 3.11-3 as 11 acres.
3-200
The project applicant would build both the community park and neighborhood parks,
as well as provide a $2.5 million dollar park maintenance endowment to the City.
You sure about that?
4-23 under no project alt
Hydrology and Water Quality (less). Surface water runoff under this alternative would
be less in comparison to the proposed project since additional development would
not occur under the Specific Plan and the project are is anticipated to remain in its
current condition. Therefore, the No Project Alternative would result in less impacts
in comparison to the proposed project.
Not true due to mitigations. The project alternative will have superior water quality
impacts. Pg.3-265 MM 3.12-1 left turn Dougherty road- Clarify with City intent of fair share monetary contribution. Pg.3-266 MM 3.12-2- Clarify with City intent of fair share monetary contribution.
Comments on Draft EIR from SunCal Page 11 July 22, 2013
Pg. 3-266,67 MM 3.12-3 – Clarify with City intent of fair share monetary contribution. Pg.3-267 MM 3.12-4 - Clarify with City intent of fair share monetary contribution. Pg.3-268,69 MM 3.12-6- Clarify with City intent of fair share monetary contribution.
4-26 under Alt 2
Land Use and Planning (greater). Similar to the proposed project, the Reduced
Development Alternative would not physically divide an established community
and/or conflict with applicable land use plan, policies or regulations. Therefore, the
No Project Alternative would result in similar impacts as compared to the proposed
project.
Says greater but concludes similar Figure 2-10 FEMA Flood Zones - Project boundary is missing. Figure 2-11 Conceptual Stormwater Drainage & Detention System – legend incorrectly identifies "ponds" instead of "underground detention basin." Figure 2-15 Phasing Map – adjust phase boundaries 2, 4 & 5 to follow street.
General
Please note that Phasing map is being updated to correct two typos.
ACSPA parcel sometimes in sometimes out – no references to Transit Village EIR
Dublin Crossing Specific Plan Final EIR
Page 40
Response to Comment Letter #14 from Dublin Crossing LLC, received July 22, 2013
Response to Comment 14-1 – Secondary Units Comment noted and the respective change has been made to page ES-2 of the Draft EIR.
Response to Comment 14-2 – Toxic Air Contaminants The air toxics analysis in the Draft EIR is based on the BAAQMD’s list of permitted toxic air contaminant (TAC) sources located within 1,000 feet of the project boundary (including diesel generators). The BAAQMD has identified emission rates and associated health risks for these sources. For residential uses, the BAAQMD requires that either a 1,000 foot buffer from air toxic sources be incorporated or other mitigation measures as identified in Mitigation Measure MM 3.2-5 of the Draft EIR. The closest TAC source is the Camp Parks generator, which is located 200 feet north of the project area. However, most of the sources in the project vicinity are 500 to 1,000 feet from the boundary of the project area.
Response to Comment 14-3 – Approval of a Wetland Mitigation Plan Comment noted and the respective changes have been made to pagesES-15, 3-72, and 3-73 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-4 – Plants Listed under the State and/or Federal
Endangered Species Act Comment noted and the respective changes have been made to pages ES-16 to ES-18 and pages 3-74 and 3-75 of the Draft EIR. Revisions to the Draft EIR do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-5 – Preservation of Upland Habitat and Protocol
Level Surveys for Vernal Pool Invertebrates Comment noted and the respective changes have been made to page ES-25 to ES-26 and page 3-81 of the Draft EIR. Revisions to the Draft EIR do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-6 – Vernal Pool Invertebrates Comment noted and the respective changes have been made to pages ES-25 to ES-26 and pages 3-82 to 3-83of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Dublin Crossing Specific Plan Final EIR
Page 41
Response to Comment 14-7 – Stormwater Basin #2 Outfall Mitigation Measure 3.8-4b on pages ES-43, 3-168, and 3-169 of the Draft EIR has been revised to more clearly correlate directly to the project impact, as follows: MM 3.8-4b: Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the first grading/sitework permit associated with the construction of the proposed community park, the project applicant shall submit to the City for review and approval, plans, details, and calculations for the proposed underground stormwater detention structure(s) and associated storm drain system within the park parcel to ensure that adequate capacity will be provided; that the resultant discharge flow rates meet the requirements of the Regional Water Quality Control Board; and that the placement of the underground facilities in the park will not impact the park design and construction of recreational facilities. The location and layout of the underground detention structures and the connection of these facilities to the proposed Chabot Creek riparian channel, box culvert or downstream facilities shall be agreed upon by both the project applicant and the City. The method and location of stormwater discharge of the underground facilities shall be reviewed and approved by all appropriate regulatory and/or permitting agencies. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-8 – Stormwater Outfall from Proposed North Basin
#2 See Response to Comment 14-7.
Response to Comment 14-9 – Grade Separated Crossing Project The City is pursuing multiple sources of funding to conduct a feasibility analysis of the Iron Horse Trail connectivity from Dougherty Road to the (East) Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in this location could significantly enhance bike and pedestrian access to and from the project area and beyond. To support this project, Sun Cal is contributing $50,000 towards the feasibility analysis, and the City is seeking additional funding from ACTC’s own Sustainable Communities Technical Assistance Program. It is the City’s full intent to pursue a grade-separated crossing at this location, and at this time the alternative mitigation measure of removing a portion of the crosswalk across Dublin Boulevard will remain in the EIR.
Response to Comment 14-10 – Significant and Unavoidable Impact at
Southbound Hacienda Drive to I-580 Eastbound On-Ramp and Southbound
Tassajara Road to I-580 Westbound On-Ramp Comment noted. Even if the freeway ramps could be mitigated by changing the ramp metering rates so that more vehicles could access the freeway, the proposed project would exacerbate a significant impact until the ramps are metered. Therefore, this would be considered a significant and unavoidable impact.
Dublin Crossing Specific Plan Final EIR
Page 42
Response to Comment 14-11 – Land Use and Development Plan Figures Comment noted. In Section 2.6, Land Uses and Development Plan, Figure 2-7 Conceptual Land Use Plan was referenced to show the land use diagram of the proposed project and Figure 2-8: Illustrative Site Plan was referenced to show a conceptual plan for the proposed project. Figure 2-9: Proposed Street Network as noted by the commenter is not referenced within Section 2.6.
Response to Comment 14-12 – Table 2-1 Comment noted and the respective changes have been made to page 2-8 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-13 – Central Park and Iron Horse Regional Trail
Alignment Comment noted and the respective changes have been made to page 2-11 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-14 – Camp Parks Watershed Commenter provides text from the Draft EIR that the 1,800+ acre watershed drains through the project area. The text on pages 2-14 and 3-153 of the Draft EIR has been revised to state that the majority of the Camp Parks watershed drains through the project area. The off-site watershed area and amount of watershed drainage that flows through the project area in the Draft EIR analysis was based on the correct information.
Response to Comment 14-15 – Storm Drain Infrastructure Comment noted and the respective changes have been made to page 2-14 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-16 – Former Building 109/Parks Reserve Forces
Training Area (PRFTA) 2 Comment noted. According to Mark Hall, Environmental Coordinator at U.S. Army, Camp Parks, the contamination at the Former Building 109/PRFTA 2 was remediated by the U.S. Army and cleaned to industrial standards. There are currently groundwater monitoring wells at the site and the U.S. Army has completed three quarters of sampling in coordination with the Department of Toxic Substances and Control (DTSC). The respective changes have been made to page 2-17 and page 3-138 and 3-139 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Dublin Crossing Specific Plan Final EIR
Page 43
Response to Comment 14-17 – Reference to the San Francisco Regional Water
Quality Control Board Comment noted and the respective changes have been made to pages 2-17, 3-137, 3-146, 3-154 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-18 – Footnote to Table 2-2: Phasing Plan Comment noted. The project applicant has been noted in the footnote of Table 2-2: Phasing Plan on page 2-18 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-19 – Building Heights Comment noted. Method of building height measurement has been added to the Specific Plan.
Response to Comment 14-20 – Number of Trips per Day Analyzed in the Air
Quality Modeling The air quality modeling modeled 22,047 trips per day (See Appendix B of the Draft EIR). Page 3-35 in the Draft EIR has been revised to reflect the correct value. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-21 – Toxic Air Contaminants Comment noted. See Response Comment 14-2.
Response to Comment 14-22 – Date of Technical Report and Alameda County
Surplus Property Comment noted and the respective changes have been made to pages 3-47 and 3-48 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. A Draft EIR was prepared for the Dublin Transit Center included the Alameda County Surplus Property. The EIR was certified by the City Council on November 19, 2002. Based on the analysis completed in the Dublin Transit Center EIR, the Alameda County Surplus Property was not found to contain any special status species or significant biological features (e.g. wetlands), etc. However, the mitigation measures included in the Draft EIR for the proposed project would apply to future development on the Alameda County Surplus Property site as well, which would ensure that the proposed project would have a less than significant impact on biological resources.
Dublin Crossing Specific Plan Final EIR
Page 44
Response to Comment 14-23 – Table 3.3-1: Habitats and Vegetation
Communities within the Project Area Comment noted and the respective changes have been made to page 3-47 and 3-48 of the Draft EIR. See Response to Comment 14-22. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-24 – Wetlands and Drainage Ditches Comment noted and respective changes have been made to page 3-49 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-25 - Other Waters of the U.S. and an Unnamed Canal
(Canal 02) Comment noted and respective changes have been made to pages 3-50 and 3-51 of the Draft EIR. Revisions do not change the analysis in the Draft EIR.
Response to Comment 14-26 – Reference for Special Status Species Occurrence
in the Project Area Comment noted and the respective changes have been made to page 3-53 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-27 – Identification of the Project Area Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-28 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-29 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-30 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Dublin Crossing Specific Plan Final EIR
Page 45
Response to Comment 14-31 – Western Pond Turtle Comment noted and the respective changes have been made to page 3-56 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-32 - California Red Legged Frog Comment noted and the respective changes have been made to page 3-58 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-33 –California Red Legged Frog Comment noted and the respective changes have been made to page 3-58 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-34 – Congdon’s Tarplant Comment noted and the respective changes have been made to page 3-64 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-35 – Hairless popcorn-flower Comment noted and the respective changes have been made to page 3-64 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-36 – Regulatory Framework, California Endangered
Species Act Comment noted and the respective changes have been made to page 3-68 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-37 – California Fish and Game Code Comment noted and the respective changes have been made to page 3-69 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-38 – Other Waters of the U.S. and the Alameda
County Surplus Property Comment noted and the respective changes have been made to page 3-72 to 3-73 of the Draft EIR. The Alameda County Surplus Property is addressed in Response to Comment 14-22
Dublin Crossing Specific Plan Final EIR
Page 46
Response to Comment 14-39 – Endangered Species Act Comment noted and the respective changes have been made to pages 3-74 and 3-75 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-40 – Western Pond Turtle Comment noted and the respective changes have been made to page 3-77 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-41 – Reference to Cantonment Area of Camp Parks Comment noted and the respective changes have been made to page 3-79 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-42 – California Red Legged Frog Comment noted and the respective changes have been made to page 3-79 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-43 – Vernal Pool Invertebrates Comment noted and the respective changes have been made to page 3-82 and 3-83 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-44 – Mitigation Measure 3.3-5 Comment noted and the respective changes have been made to page 3-83 the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-45 - Reference to Cantonment Area of Camp Parks Comment noted and the respective changes have been made to pages 2-2, 3-53, 3-54, 3-79, and 4-11 the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-46 – Stormwater Pollution Prevention Plans
(SWPPs) Comment noted and the respective changes have been made to page 3-161 of the Draft EIR.
Dublin Crossing Specific Plan Final EIR
Page 47
Response to Comment 14-47 – Acreage of the School Site Comment noted and the respective changes have been made to page 3-177 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-48 – Acreage of the School Site Comment noted and the respective changes have been made to pages 3-178 and 3-179 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-49 – Student Generation Commenter does not provide a specific comment on the student generation rates. Therefore, no response is necessary.
Response to Comment 14-50 - Acreage of the School Site Comment noted and the respective changes have been made to page 3-212 and 3-213 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-51 – Funding for the Community Park and
Neighborhood Parks The project will provide the funds for and the City will design and construct both the Community Park and the two neighborhood parks.
Response to Comment 14-52 – No Project Alternative Comment noted. The No Project Alternative would result in a reduction of impacts to hydrology and water quality in comparison to the proposed project as the alternative would not result in a significant increase in impervious surfaces compared to existing conditions.
Dublin Crossing Specific Plan Final EIR
Page 48
Response to Comment 14-53– Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips.
Response to Comment 14-54– Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips.
Response to Comment 14-55– Fair Share Monetary Contribution Comment noted. The project contributes to the cumulative impact at this location. The fair share monetary contribution mitigates the impact of the projects additional trips.
Response to Comment 14-56– Fair Share Monetary Contribution Comment noted. The mitigation measure requires the project to complete this improvement. There is no provision for fair share contribution.
Response to Comment 14-57 – Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips.
Response to Comment 14-58 – Alternative #2 Comment noted and the respective changes have been made to page 4-27 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-59 – Figure 2-10 Comment noted and the respective changes have been made to Figure 2-10 in the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-60 – Figure 2-11 Comment noted and the respective changes have been made to Figure 2-11 in the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-61 – Figure 2-15 Comment noted and the respective changes have been made to the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR.
Dublin Crossing Specific Plan Final EIR
Page 49
Response to Comment 14-62 – Phasing Map Comment noted. An updated Phasing Map (to correct minor typographical errors) is included in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR.
Response to Comment 14-63 – Alameda County Surplus Property Comment noted. See Response to Comment 14-22.
Dublin Crossing Specific Plan Final EIR
Page 50
Changes to the Draft EIR Changes to the Draft EIR are shown on the following pages.
Dublin Crossing Specific Plan Final EIR
Table of Contents
Page v
Figure 3.7-1: Sound Levels and Human Response
Figure 3.8-1: Hydrologic Features
Figure 3.8-2: Existing Drainage
Figure 3.8-3: Proposed DrainageProposed Q100 Project Flows
Figure 3.10-1: Sound Levels and Human Response
Figure 3.12-1: Site Location and Off-Site Study Intersections
Figure 3.12-2: Future Project Study Intersections
Figure 3.12-3: Existing Bicycle Facilities
Figure 3.12-4: Existing Transit Routes
Figure 3.12-5a and 3.12-5b: Existing Lane Configurations
Figure 3.12-6a and 3.12-6b: Existing Peak Hour Intersection Volumes
Figure 3.12-7: Project Trip Distribution
Figure 3.12-8a and 3.12-8b: Existing Plus Project Peak Hour Intersection Volumes
Figure 3.12-9a and 3.12-9b: 2020 Background No Project Peak Hour Intersection
Volumes
Figure 3.12-10a and 3.12-10b: 2020 Background No Project Lane Configurations
Figure 3.12-11: 2020 Background No Project Roadway Configurations
Figure 3.12-12a and 3.12-12b: 2020 Background Plus Project Peak Hour
Intersection Volumes
Figure 3.12-13a and 3.12-13b: 2035 Cumulative No Project Peak Hour Intersection
Volumes
Figure 3.12-14a and 3.12-14b: 2035 Cumulative No Project Lane Configurations
Figure 3.12-15: 2035 Cumulative No Project Roadway Improvements
Figure 3.12-16a and 3.12-16b: 2035 Cumulative Plus Project Peak Hour Intersection
Volumes
Figure 3.12-17: 2035 Cumulative Plus Project Lane Configurations
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-2
In 2004, the US Army developed a master plan summary report describing the
proposed future development and revitalization of the portion of the project area
within Camp Parks. The Final Environmental Impact Statement (FEIS) on Master
Planned Redevelopment at Camp Parks (U.S. Army Garrison Camp Parks 2009) was
the federal environmental document prepared to analyze the environmental
consequences of implementation of the master plan for redevelopment of Camp
Parks. The FEIS included consideration of the proposed project.
In December 2007 the Army prepared a “Notice of Availability” to solicit a master
developer for the Camp Parks Real Property Exchange Area. The Exchange
Agreement provides the Army with an opportunity to modernize facilities through
the provision of 180-acres of Army owned property (including the NASA parcel but
excluding the 8.7-acre Alameda County Surplus Property Authority parcel), to a
developer in exchange for Camp Parks facilities improvements. The Exchange
Agreement is not a part of the Specific Plan but was necessary to facilitate
acquisition of the property by the project developer.
In October 2008, the Army announced the selection of the master developer for the
Project. In April 2011, the developer and the U.S. Army officially finalized the
Exchange Agreement, authorizing the developer to commence the Specific Plan
process.
Project Description
The Specific Plan addresses the future development of the project area, which is
comprised of residential, commercial, parks and open space, and an elementary
school. Specifically, the proposed project includes up to 1,995 residential units (not
including secondary units); up to 200,000 square feet of commercial uses, 30 net-
acre community park; five acres of neighborhood parks; and provisional space for a
12-acre elementary school site.
Summary of Environmental Impacts
All impacts identified in the subsequent environmental analysis are summarized in
Table S-1: Executive Summary of Project Impacts, which identifies impacts by each
technical section.
Summary of Cumulative Considerable Effects
The proposed project would result in a significant cumulative impact from short-
term construction air quality emissions and long-term operational air quality
emissions, as well as a significant cumulative impact to the Southbound Hacienda
Drive to I-580 Eastbound On-Ramp and the Southbound Tassajara Road to I-580
Westbound On-Ramp.
Summary of Alternatives
CEQA Guidelines require that an EIR describe and evaluate alternatives to the
project that could eliminate significant adverse project impacts or reduce them to a
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-15
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
Impact 3.2-7: The proposed
project would allow some uses
which generate airborne odors,
which could be considered
offensive. However, limited
exposure and compliance with
applicable regulatory
requirements will ensure that
any impact is less than
significant.
Less than Significant No mitigation measures are necessary. Less than Significant
Impact 3.2-8: The proposed
project is consistent with
population growth assumptions
in the 2010 Bay Area Clean Air
Plan, is anticipated to result in
reduced Vehicle Miles Travelled
(VMT) compared to population
growth, and is consistent with
several of the Clean Air Plan’s
Control Measures.
Less than Significant No mitigation measures are necessary. Less than Significant
Biological Resources
Impact 3.3-1: Based on a
preliminary wetland delineation
of the project area, the proposed
project could result in the fill of
wetlands.
Potentially Significant MM 3.3-1: Prepare and Implement a Wetland
Mitigation Plan. Prior to commencing any
activities that would impact wetlands or waters
habitat, the project applicant shall obtain all
required public agency permits and shall prepare
Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-16
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
a wetland mitigation plan that ensures no-net-
loss of wetland and waters habitat and is
approved by the City andthat is approved by the
applicable resource agencies and submitted to
the City. The wetland mitigation plan shall
include measures for avoidance, minimization,
and compensation for wetland impacts.
Avoidance and minimization measures may
include the designation of buffers around
wetland features to be avoided, or project design
measures, such as free-span bridges.
Compensation measures shall include the
preservation and/or creation of wetland or
waters. The final mitigation ratios (the amount of
wetlands and waters created or preserved
compared to the amount impacted) shall be
determined by the applicable resource agencies
and the City. The wetland mitigation and
monitoring plan shall include the following:
Descriptions of the wetland types, and
their expected functions and values;
Performance standards and monitoring
protocol to ensure the success of the
mitigation wetlands over a period to be
determined by the resource agencies;
Engineering plans showing the location,
size and configuration of wetlands to be
created or restored;
An implementation schedule showing
that construction or preservation of
mitigation areas shall commence prior to
or concurrently with the initiation of
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-17
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
construction; and
A description of legal protection
measures for the preserved wetlands
(i.e., dedication of fee title, conservation
easement, and/or an endowment held by
an approved conservation organization,
government agency or mitigation bank).
Impact 3.3-2: A query of the
CNPS lists 34 plant species that
occur within the project vicinity.
Based on habitats within the
project area during the March
2012 survey by Cardno Entrix,
the list was reduced to four
special status plant species that
have the potential to be located
within the project area including:
Congdon’s tarplant (Centromadia
parryi ssp. Congdonii), Palmate-
bracted bird’s-beak
(Cordylanthus palmatus),
Northern California Black
Walnut (Juglans hindsii), and
Hairless popcorn-flower
(Plagiobothrys glaber). Out of
these four special status plant
species, the only special status
plant species that has the
potential to be located within the
project area is the Congdon’s
tarplant, which was documented
as occurring within the project
area based on floristic surveys
Potentially Significant .MM 3.3-2a: Conduct a Floristic Survey and
Consult with CDFG CDFW and USFWS if State or
Federally Listed ESA Plants are Found and
Comply with Incidental Take Permits. The
project applicant shall retain a qualified botanist
to conduct rare plant surveys within the
construction zone for Congdon’s tarplant or other
state or federally species with potential habitat
within the project area during the appropriate
time of yearblooming period of those species for
which suitable habitat is present in accordance
with agency protocols. These plant surveys shall
be conducted in accordance with the 2009
California Department of Fish and GameCDFW
and United States Fish and Wildlife
ServiceUSFWS rare plant survey protocols. Two
or three separate surveys may be required to
cover the blooming periods of species where
suitable habitat is present. The results of the
surveys shall be summarized in a report and
submitted to CDFW and USFWS, and would be
valid for two years. If no special-status plants are
located during the surveys, no further mitigation
measures would be required. If any federal or
state ESA plant species are found during the rare
plant surveys, the project applicant shall consult
Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-18
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
conducted between 1995 and
2000.
with the CDFW and USFWS to obtain incidental
take permits under Section 2081 of the CESA and
either Section 7 or 10 of the FESA. Consultation
with USFWS under Section 7 of the FESA could
occur as part of the CWA Section 404 permit
process as part of the wetland mitigation,
described under Mitigation Measure MM 3.3-1.
MM 3.3-2b: Develop and Implement Mitigation
in Consultation with CDFW if Other Special
Status Plant Species Are Found. If populations
or stands of Congdon’s tarplant or other special-
status plant species (excluding federal or state
listed plants) are found during the rare plant
surveys and impacts are unavoidable, the project
applicant shall notify the CDFW. A compensatory
mitigation plan shall be developed in consultation
with and approved by the CDFW and the City
prior to the commencement of any activities that
would impact any special status plants, such as
the acquisition of off-site mitigation areas
presently supporting the species in question or
purchase of credits in a mitigation bank that is
approved to sell credits for the affected species.
The location of mitigation sites shall be
determined in consultation with, and subject to
approval of USFWS and/or CDFW. Off-site
compensatory mitigation shall be acquired at a
minimum acreage of 1:1 (acquired: impacted).
For either off-site mitigation option, measures
shall be implemented providing for the long-term
protection of the species. The mitigation plan
shall include measures such as transplanting
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-19
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
plants, collecting seed or clippings and replanting
species in an on-site location, if feasible or other
location approved by Department of Fish and
Game.
Impact 3.3-3: Several California
burrowing owl pairs have been
documented within the project
area, including during the winter
and breeding season. Due to the
security fencing that surrounds
Camp Parks, low human use, and
maintenance activities, the
project area provides suitable
breeding, foraging and wintering
habitat for the California
burrowing owl. Implementation
of the proposed project could
result in the displacement of
burrowing owls during
construction activities, and once
completed the proposed project
could result in the removal of
suitable burrowing owl
(breeding and wintering)
habitat. Permanent loss of
occupied burrow(s) and habitat.
Potentially Significant MM 3.3-3a: Conduct a Burrowing Owl Survey
and Impact Assessment. The project applicant
shall retain a qualified biologist to conduct a
California burrowing owl take avoidance surveys
14 days prior to ground disturbing activities and
impact assessment following the 2012 California
Department of Fish and Game Staff Report on
Burrowing Owl Mitigation (CDFW 2012) or as
updated at the time of the implementation of the
proposed project. If no owls are found during
this first survey, a final survey shall be conducted
within 48-hours prior to ground disturbance to
confirm that burrowing owls are still absent. If
ground disturbing activities are delayed or
suspended for more than 14 days after the initial
take avoidance survey, the project area shall be
resurveyed including the final survey within 48-
hours of disturbance. The report(s) shall be
submitted to California Department of Fish and
GameCDFW as indicated in the CDFW 2012 Staff
Report.
If it is determined that project activities may
result in impacts to nesting, occupied, and
satellite burrows and/or burrowing owl habitat,
the project applicant shall consult with the
CDFW. More specifically, if the surveys identify
breeding or wintering burrowing owls on or
adjacent to the project area, occupied burrows
Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-20
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
cannot be disturbed and shall be provided with
protective buffers. Where avoidance is not
feasible during the non-breeding season, a site
specific exclusion plan (i.e. a plan that considers
the type and extent of the proposed activity, the
duration and timing of the activity, the sensitivity
and habituation of the owls, and the dissimilarity
of the proposed activity with background
activities) shall be implemented to encourage the
owls to move away from the work area prior to
construction and to minimize the potential to
affect the reproductive success of the owls. The
exclusion plan shall be subject to the CDFW
approval and monitoring requirements.
Compensatory mitigation could also be required
by the CDFW as part of the approval of an
exclusion plan. Mitigation may include the
permanent protection of habitat at a nearby off-
site location acceptable to the CDFW. and develop
a detailed mitigation plan such that the habitat
acreage, number of burrows, and burrowing owl
impacted are replaced. The mitigation plan shall
be based on the requirements set forth in
Appendix A of the CDFW 2012 Staff Report on
Burrowing Owl Mitigation.
MM 3.3-3b: Implement Avoidance Measures. If
California burrowing owl are located within the
project area and direct impacts can be avoided,
the project applicant shall implement the
following avoidance measures during all phases
of construction to reduce or eliminate potential
impacts to California burrowing owls.
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-21
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
Avoid disturbing occupied burrows
during the nesting period, from 1
February through 31 August.
Avoid impacting burrows occupied
during the non-breeding season by
migratory or non-migratory resident
burrowing owls.
Avoid direct destruction of burrows
through chaining (dragging a heavy chain
over an area to remove shrubs), disking,
cultivation, and urban, industrial, or
agricultural development.
Develop and implement a worker
awareness program to increase the on-
site worker’s recognition of and
commitment to burrowing owl
protection.
Place visible markers near burrows to
ensure that farm equipment and other
machinery does not collapse burrows.
Do not fumigate, use treated bait or other
means of poisoning nuisance animals in
areas where burrowing owls are known
or suspected to occur (e.g., sites observed
with nesting owls, designated use areas).
Restrict the use of treated grain to poison
mammals to the months of January and
February.
MM 3.3-3c: Conduct Burrow Exclusion. In the
event that California burrowing owls are located
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-22
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
within the project area, the project applicant shall
conduct a Burrowing Owl Relocation Plan. If
avoidance of burrowing owl or their burrows is
not possible, the project applicant in consultation
with the California Department of Fish and
Wildlife shall prepare a Burrowing Owl
Relocation Plan as indicated and following the
CDFW 2012 Staff Report. Monitoring of the
excluded owls shall be carried out as per the
California Department of Fish and Game 2012
Staff Report. Mitigation for permanent impacts to
nesting, occupied, and satellite burrow and/or
burrowing owls shall be developed based on the
CDFW 2012 Staff Report on Burrowing Owl
Mitigation.
Impact 3.3-4: Habitat
assessments or surveys for
special-status amphibians and
reptiles were performed within
the project area by the U.S. Army
in 2006, including California Red
Legged Frog and California Tiger
Salamander. Although no
surveys specific for Western
Pond Turtle have been
conducted, Western Pond Turtle
was observed within the project
areagreater Camp Parks Training
Area during surveys for
California Red Legged Frog.
During the field surveys
conducted by in March 2012, the
Potentially Significant MM 3.3-4a: Conduct Pre-Construction Surveys
for Western Pond Turtle (WPT) The project
applicant shall retain a qualified biologist to
conduct pre-construction surveys for Western
Pond Turtle no more than 30 days prior to work
in or adjacent to any habitat suitable for WPT
within the project area. If no Western Pond
Turtles are found, no further mitigation is
required. If Western Pond Turtles are found, the
consulting biologist shall consult with the
California Department of Fish and Game for
authorization to relocate the species to suitable
habitat away from the construction zone. The
turtle shall be relocated to either a pond within
the Training Area (if authorization from the US
Army is granted) or downstream from the
construction zone to similar or better habitat.
Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-23
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
project area was not found to
provide suitable breeding habitat
for these species. However, the
proposed project includes re-
alignment of the ephemeral
drainage, which could result in
the potential “take” of Western
Pond Turtle and/or California
Red Legged Frog if found within
the project area.
MM 3.3-4b: Consult with United States Fish and
Wildlife Service and Reduce Impacts on
California Red-Legged Frog. The project
applicant shall comply with the following
requirements:
a. The project applicant shall retain a
qualified herpetologist to conduct
habitat assessments for CRLF and based
on the results of the habitat assessments,
determine in consultation with the
USFWS if protocol-level CRLF surveys
will be required within the project area.
The project area consists of multiple
phase areas within which separate CRLF
habitat assessments may be conducted.
It shall then be determined on a phase-
by-phase basis, if further surveys will be
required. The project applicant can forgo
the habitat assessments and conduct
protocol-level surveys. If required, the
focused surveys shall follow the Revised
Guidance on Site Assessment and Field
Surveys for the California Red-legged
Frog (USFWS 2005). A CRLF survey
report prepared to meet the protocol
guidelines shall be submitted to the
USFWS. If no CRLF are found then no
further mitigation is required.
b. If CRLF are found then the project
applicant shall provide information to
the USACE to support Section 7
consultation with the USFWS and the
project applicant shall ensure no net loss
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of habitat that shall be achieved through
avoidance, preservation, creation and/or
purchase of credits. The final selected
measures may be part of the Section 7
permitting process.
c. The project applicant shall obtain a
biological opinion from the U.S Fish and
Wildlife Service and comply with the
conditions and mitigation requirements
of those agencies to ensure that no net
loss of habitat occurs. Mitigation may
include, but would not be limited to,
onsite and offsite preservation and
creation of CRLF habitat, purchase of
credits at mitigation banks, payment of
in lieu fees approved by the agencies, or
other agency approved and required
mitigation measures.
d. Avoidance measures may include the
following or equivalent protective
measures:
To minimize disturbance of breeding and
dispersing CRLF, construction activity
within CRLF upland habitat shall be
conducted during the dry season
between April15 and October 15 or
before the onset of the rainy season,
whichever occurs first. If construction
activities are necessary in CRLF upland
habitat between October 15 and April 15,
the project applicant would contact the
USFWS for approval to extend the work
period.
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To minimize disturbance and mortality of
adult and juvenile CRLF in aquatic habitat
and underground burrows, the project
applicant could minimize the extent of
ground-disturbing activities within these
habitats by requiring the contractor to
limit the work area to the minimum
necessary for construction. In addition,
the project applicant could ensure that
the contractor would install temporary
exclusion fence between the construction
work area and potential aquatic habitat
for all construction within grasslands
near aquatic habitat.
The project applicant could ensure that a
qualified wildlife biologist monitors all
construction activities within CRLF
upland habitat. This would ensure no
take of individual CRLF occurs during
project construction. If a CRLF is found,
then the monitor would immediately stop
construction in that area and contact
USFWS for advice.
The project applicant shall could
preserve additional upland habitat
within a USFWS approved conservation
area. This measure shall be determined
in consultation with the USFWS, if
required.The Project proponent shall
coordinate or consult
Impact 3.3-5: Protocol level
surveys for vernal pool
Potentially Significant MM 3.3-5: Consult with the USFWS and Reduce
Impacts on Vernal Pool Invertebrates and
Less than Significant
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invertebrates were conducted
throughout Camp Parks in 2002
and 2003 by the U.S. Army, as
well as during the summer of
2012 (dry season) and 2013
(wet season) by Cardno Entrix.
No vernal pool fairy shrimp,
vernal pool tadpole shrimp or
longhorn fairy shrimp were
found during these surveys.
California linderiella was found,
during the 2002 and 2003
surveys, but not within the
project area. New The surveys
are currently being conducted by
Cardno Entrix have not been
accepted by the USFWS. Since
the new surveys have not been
completed at this timeTherefore,
the presence of this species
within the project area is
assumed in the analysis of
project impacts.
Surveys for curve-footed
Hygrotus beetle and San
Francisco fork-tailed damselfly
were also conducted within
Camp Parks in 2002 and 2003
and neither of these species were
observed. Site conditions have
not changed significantly and
these species are not expected to
occur. Potentially suitable
habitat was observed within the
Their Habitat. The project applicant shall
prepare a habitat assessment for the vernal pool
invertebrates. If vernal pool invertebrates are
found within the project area during the habitat
assessment, the project applicant shall comply
with the following steps to ensure protection of
vernal pool invertebrates and their habitat and
that impacts are reduced to a less than significant
level.
a. The project applicant shall retain a
qualified biologist to conduct habitat
assessments for protected vernal pool
invertebrates and based on the results of
the habitat assessments, determine in
consultation with the USFWS if protocol-
level vernal pool invertebrate surveys
will be required within the project area.
b. If suitable habitat is present, the
project applicant, in consultation with
the USFWS and CDFW, shall either (1)
conduct a protocol-level survey for
federally listed vernal pool crustaceans,
which will identify and other protected
vernal pool invertebrates (curve-footed
Hygrotus beetle and San Francisco fork-
tailed damselfly), or (2) assume presence
of federally-listed vernal pool
crustaceans and curve footed Hygrotus
beetle and San Francisco fork-tailed
damselfly in areas of suitable habitat.
Surveys shall be conducted by qualified
biologists in accordance with the most
recent USFWS guidelines or protocols to
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survey area for vernal pool
invertebrates and these areas
would be removed during
proposed construction activities.
Removal of these wetlands could
result in the potential take of
protected vernal pool
branchiopods and other
protected invertebrates, if they
were to occur, and their habitat.
determine the time of year and survey
methodology (survey timing for these
species is dependent on yearly rainfall
patterns and seasonal occurrences, and
is determined on a case-by-case basis).
The USFWS protocol level surveys shall
be conducted as part of the Section 404
permit process within two years of the
application. If surveys reveal no
occurrences of federally listed vernal
pool crustaceans or other protected
vernal pool invertebrates, no further
mitigation would be required.
c. If surveys determine that one or more
special-status vernal pool invertebrate
species occurs within the project area, or
if the project applicant, in consultation
with the USFWS and/or CDFW, assumes
presence of federally-listed vernal pool
invertebrates in all affected habitats, the
project applicant shall provide
information to the USACE to support
Section 7 consultation with the USFWS
and the project applicant shall ensure no
net loss of habitat shall be achieved
through avoidance, preservation,
creation and/or purchase of credits as a
part of the Section 7 Consultation
process. The selected measures may be
part of the permitting process.
d. Where feasible, all vernal pool
invertebrate habitat shall be avoided. If
habitat that can be avoided during
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construction activities is identified at a
distance determined in consultation with
USFWS, a USFWS-approved biologist
(monitor) shall inspect any construction-
related activities to ensure that no
unnecessary take of listed species or
destruction of their habitat occurs. The
Project proponent will establish
monitoring and reporting protocols to
reduce impacts to vernal pool
invertebrate species and habitat.
e. The project applicant shall ensure that
an appropriate number of acres, as
approved by USFWS during consultation,
are preserved to mitigate for direct or
indirect impacts on vernal pool
crustacean habitat.
f. Water quality in the avoided wetlands
shall be protected using erosion control
techniques, such as silt fencing or straw
wattles during construction in the
watershed.
Impact 3.3-6: A variety of
special-status birds are expected
to be located within the project
area. Some of these species are
resident species and some are
migratory species that breed
within the project area. The
special-status birds known to
nest in the Livermore Valley area
include the Golden eagle, white-
tailed kite, tricolored blackbird,
Potentially Significant MM 3.3-6: Protect Birds Covered by the
Migratory Bird Treaty Act (Including, but not
limited to White-Tailed Kite, golden eagle,
Cooper’s hawk, Loggerhead Shrike, and Other
Special-Status Species). Project contractors
shall avoid construction activities during the bird
nesting season (February 1 through August 31).
If Between March 1 and September
15construction activities are conducted during
the bird nesting season, the project applicant
shall have a qualified biologist conduct at least
Less than Significant
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Significance
northern harrier, California
horned, prairie falcon, Cooper’s
hawk and loggerhead shrike.
Trees, fresh emergent wetland
vegetation and grassland could
provide potentially suitable
nesting habitat for these species,
which are protected under the
Migrant Bird Treaty Act and the
Fish and Game Code. The
proposed project would require
grading and possible removal of
existing trees and vegetation.
three nest surveys of the project area to develop
a baseline of nesting activity on and adjacent to
the project area. Depending on the construction
schedule, pre-construction surveys shall be
initiated prior to planned construction activity to
allow for multiple site visits (e.g. for construction
activities planned for mid-May, the first survey
shall be conducted no more than 14 days prior to
the start of work). no more than 30 days prior to
any demolition/construction or ground-
disturbing activities that are within 300 feet of
potential nest trees for non-raptor species (i.e.
trees, cattails, or grassland) and 500 feet of
potential nest trees for raptor species or suitable
nesting habitat (i.e., trees, cattails, grassland).
Where access to property adjacent to the
construction activities is prohibited by the
owner/operator, the survey shall be conducted
using binoculars or spotting scope. A pre-
construction survey report shall be submitted to
the California Department of Fish and Game that
includes, at a minimum: (1) a description of the
methodology including dates of field visits, the
names of survey personnel with resumes, and a
list of references cited and persons contacted;
and (2) a map showing the location(s) of any bird
nests observed on the project area. If no active
nests of Migratory Bird Treaty Act covered
species are identified, then no further mitigation
is required.
If active nests of protected bird species are
identified in the focused nest surveys, the project
applicant will shall consult with the appropriate
regulatory agencies to identify project-level
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Significance
mitigation requirements, based on the agencies’
standards and policies as then in effect.
Performance measures may include the
following, based on current agency standards and
policies.
a. The project applicant, in consultation
with California Department of Fish and
Game, would delay construction in the
vicinity of active nest sites during the
breeding season (February 1 through
September 15) while the nest is occupied
with adults and/or young. A qualified
biologist would shall monitor any
occupied nest to determine when the
nest is no longer used. If the construction
cannot be delayed, avoidance measures
would shall include the establishment of
protective buffer zones around the nests
as follows: for raptor nests, the size of
the buffer zone shall be a minimum 250
foot radius centered on the nest; for
other birds, the size of the buffer zone
shall be a 50-foot radius centered on the
nest. In some cases, these buffers may be
increased or decreased depending on the
bird species and the level of disturbance
that will occur near the nest. Changes to
the buffer should be made by the project
biologist in consultation with the CDFW.
of a non-disturbance buffer zone around
the nest site. The size of the buffer zone
would be determined in consultation
with the CDFW and may vary depending
on the species, but will be a minimum of
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250 feet. The buffer zone would be
delineated with highly visible temporary
construction fencing.
b. No intensive disturbance (e.g., heavy
equipment operation associated with
construction, or use of cranes) or other
project-related activities that could cause
nest abandonment or forced fledging
would be initiated within the established
buffer zone of an active nest between
February 1 and September 15August 31.
c. If construction activities are
unavoidable within the buffer zone, the
project applicant shall retain a qualified
biologist to monitor the nest site to
determine if construction activities are
disturbing the adult or young birds.
d. If fully protected species (white-tailed
kites, golden eagles) are found to be
nesting near the proposed construction
area, their nests would be completely
avoided until the birds fledge. Avoidance
would include the establishment of a
non-disturbance buffer zone of 500 feet,
or as determined in consultation with
the CDFW.
Impact 3.3-7: Removal of trees
and/or buildings or structures
from the project area could
impact roosting sites for pallid
bat and Yuma myotis.
Potentially Significant MM 3.3-7a: Conduct Bat and Bat Roosting Site
Surveys. Prior to construction activities, the
project applicant shall retain a qualified biologist
to conduct a focused survey for bats and potential
roosting sites within the project area. The
Less than Significant
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and/or lead based paint (LBPs).
Impact 3.7-4: The project area is
not located on a hazardous
material site pursuant to
Government Code Section
65962.5. However, based on the
Phase I ESA there are three sites
currently being evaluated by the
U.S. Army. Hazardous materials
may be encountered during
construction.
Potentially Significant MM 3.7-4: Remediation of Hazardous
Materials. Future development within the
vicinity of Former Building 109/PRFTA, Area
761/PRFTA 13, and the Potential Construction
Debris Dump Sites shall not proceed until a NFA
status is granted and the project area has been
cleaned to the appropriate land use standard to
the satisfaction of Department of Toxic
Substances and Control (DTSC). The NFA status
paperwork shall be submitted to the City in
conjunction with the Building and Grading/Site
work permit and shall be found acceptable by the
City prior to ground disturbance.
Less than Significant
Impact 3.7-5: There are no
schools located within a quarter
mile of the project area.
However, the proposed project
includes construction of an 11 12
net usable acre school site that
would be located adjacent to
proposed residential uses. In
addition, commercial businesses
proposed within the project area
would be required to comply
with federal, state and local
regulations regarding hazardous
substances.
Less than Significant No mitigation measures are necessary. Less than Significant
Hydrology and Water Quality
Impact 3.8-1: Portions of the
proposed project and lower
Less than Significant No mitigation measures are necessary. Less than Significant.
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Without Mitigation
Mitigation Measures Resulting Level of
Significance
portion of the Base watershed
are within the FEMA mapped
floodplain. Future development
would be required to comply
with the existing floodplain
regulations to ensure that
structures do not impede or
redirect flows.
Impact 3.8-2: Construction-
related activities resulting from
implementation of the proposed
project may result in the
degradation of surface water
quality.
Less than Significant No mitigation measures are necessary. Less than Significant.
Impact 3.8-3: The proposed
project would not result in
adverse impacts to the amount of
available groundwater available,
degrade groundwater quality, or
decrease groundwater recharge
in the project area.
Less than Significant No mitigation measures are necessary. Less than Significant.
Impact 3.8-4: Implementation of
the proposed project would
substantially increase the
impervious surface area on the
project site, thereby altering the
existing drainage pattern and
amount of surface runoff
resulting in a potential increase
Potentially Significant MM 3.8-4a: Construction of a new Off-site
Detention Basin North of the Project SiteArea.
Prior to the issuance of grading permits for Phase
2 of the proposed project, the project applicant
shall work in coordination with the U. S. Army
(Camp Parks) to design and construct a new off-
site detention basin designed to ensure that flow
rates to Line G-1 do not exceed the maximum
Less than Significant
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Executive Summary
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Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
in peak storm water flows (i.e.,
10- and 100-year storm events).
Q100 discharge flow rate of 950 cfs as required
by Zone 7. The design plans for this new off-site
detention basin will be reviewed by the City, in
coordination with Zone 7, for verification of
compliance with all applicable regulations and
consistency with on-site drainage requirements,
prior to construction.
MM 3.8-4b: Re-align Stormwater Outflow from
Proposed North Basin #2. Prior to issuance of
the first grading/sitework permit associated with
the construction of the proposed community
park, the project applicant shall submit to the
City for review and approval, plans, details, and
calculations for the proposed underground
stormwater detention structure(s) and
associated storm drain system within the park
parcel to ensure that adequate capacity will be
provided; that the resultant discharge flow rates
meet the requirements of the Regional Water
Quality Control Board; and that the placement of
the underground facilities in the park will not
impact the park design and construction of
recreational facilities. The location and layout of
the underground detention structures and the
connection of these facilities to the proposed
Chabot Creek riparian channel, box culvert or
downstream facilities shall be agreed upon by
both the project applicant and the City. The
method and location of stormwater discharge of
the underground facilities shall be reviewed and
approved by all appropriate regulatory and/or
permitting agencies. a revised stormwater
drainage plan that realigns the stormwater
outflow associated with the proposed North
Dublin Crossing Specific Plan Final EIR
Executive Summary
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Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
Basin #2 from the 1.7 acre Chabot Creek riparian
channel (as is currently proposed) to a separate
underground pipe that connects directly with the
existing box culvert located at proposed Scarlett
Court Extension and Dublin Boulevard, and
thereby avoids stormwater discharge into the 1.7
acre Chabot Creek riparian channel.
Impact 3.8-5: The proposed
project would not expose people
or structures to a significant risk
of loss, injury, or death involving
flooding, including flooding as a
result of the failure of a levee or
dam. Structures and personnel
would not be subject to greater
risk with implementation of the
proposed project as compared to
existing conditions.
Less than Significant No mitigation measures are necessary. Less than Significant.
Land Use and Planning
Impact 3.9-1: The proposed
project would result in the
construction of 200,000 square
feet of commercial uses, which
would contribute to the
economic vitality of the City, as
well as result in the creation of
indirect or induced jobs. Based
on the City’s existing vacancy
rate, the amount of taxable sales,
and the population growth in the
City, the additional commercial
Less than Significant No mitigation measures are necessary. Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
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Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
would result in the need for or
the construction of new or
physically altered facilities to
meet the City’s response times or
other standards for fire
protection services.
Impact 3.11-2: The proposed
project would not significantly
increase the need for law
enforcement services, which
would result in the need for the
construction of new or physically
altered facilities in order to meet
the City’s response times.
Less than Significant No mitigation measures are necessary. Less than Significant
Impact 3.11-3: Implementation
of the proposed project would
increase the number of students
in the Dublin Unified School
District (DUSD) with the
construction of a maximum of
1,995 residential units, which
would increase the capacity of
the schools, which are operating
above optimum capacity. The
proposed project includes an 11
12 net usable acre school site
and future development would
be required to pay school impact
fees as required under State law
to the DUSD.
Less than Significant No mitigation measures are necessary. Less than Significant
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Executive Summary
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Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
stormwater infrastructure, this
would be considered a less than
significant impact.
Impact 3.11-9: Implementation
of the proposed project would
increase the generation of solid
waste, but would be served by
landfills with adequate capacity
to accommodate the increase.
Less than Significant No mitigation measures are necessary. Less than Significant
Impact 3.11-10: The proposed
project may result in the
expansion of electricity, gas, and
telecommunications on-site;
however, the project site area is
already served by these utilities
and there is adequate
infrastructure in place both on
and adjacent to the project area
to serve the proposed project.
Less than Significant No mitigation measures are necessary. Less than Significant
Transportation and Circulation
Impact 3.12-1: During the PM
peak hour, the study intersection
of Dougherty Road and Amador
Valley Boulevard would operate
at an unacceptable LOS E under
both 2020 background no
project conditions and 2020
background plus project
conditions.
Potentially Significant MM 3.12-1: Addition of Northbound Left-Turn
Lane on Dougherty Road. The proposed project
shall add an additional northbound left-turn lane
on Dougherty Road at the Dougherty Road and
Amador Valley Boulevard intersection. Based on
the 2020 background plus project conditions, the
two northbound left turn lanes would need to be
325 feet each. This improvement would require
widening Dougherty Road by approximately 12
Less than Significant
Dublin Crossing Specific Plan Final EIR
Executive Summary
Page ES-56
Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
Because the impact is caused by future land use
growth in the region as well as this proposed
project, the mitigation for this impact is for the
project to make a fair share monetary
contribution toward these improvements. The
timing of these improvements will be determined
in the Mitigation Monitoring and Reporting
Program and developer obligations will be
outlined in the Developer Agreement. In the
event that the grade separated crossing project
cannot be constructed by year 2035, an
alternative mitigation would be to eliminate the
crosswalk on the east leg of the Scarlett Drive and
Dublin Boulevard intersection. This would
require pedestrians and bikes from the Iron
Horse Trail to cross three crosswalks rather than
one. Because of the effects of the alternative
mitigation on pedestrian and bike mobility, the
grade separated crossing is the City’s preferred
mitigation at this location.
Impact 3.12-4: During the PM
peak hour, the study intersection
of Iron Horse Parkway and
Dublin Boulevard would degrade
from LOS C under 2035
cumulative no project conditions
to an unacceptable LOS F under
2035 cumulative plus project
conditions. The City of Dublin
level of service standard for this
intersection is LOS D.
Potentially Significant MM 3.12-4: Addition of a Northbound Left-turn
lane on Iron Horse Parkway at the Intersection
of Iron Horse Parkway and Dublin Boulevard.
To mitigate the impact at the intersection of Iron
Horse Parkway and Dublin Boulevard would
require an additional northbound left turn lane
on Iron Horse Parkway. Based on the 2035
cumulative plus project conditions, the two
northbound left turn lanes would need to be 400
feet each. This improvement would require
widening Iron Horse Parkway by approximately
12 feet along the east side in advance of the
Less than Significant
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Executive Summary
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Project Impacts Level of Significance
Without Mitigation
Mitigation Measures Resulting Level of
Significance
intersection. It may also require removal of
parking, realignment of travel lanes through the
intersection, relocation of sidewalks, and traffic
signal modifications. the removal of parking on
the east side of Iron Horse Parkway, traffic signal
modifications, and changing the travel lane
configuration and alignment to create:
One 16-foot wide southbound receiving
lane on Iron Horse Parkway;
Two 10-foot wide northbound left turn
lanes on Iron Horse Parkway; and
One 14-foot wide northbound shared
through-right turn lane.
Because the proposed project causes the change
in operation from LOS C to LOS F, the proposed
project is responsible for constructing these
improvements. The timing of these
improvements will be determined in the project’s
mitigation monitoring program.
Impact 3.12-5: During the PM
peak hour, the study intersection
of Hacienda Drive and Dublin
Boulevard would operate at an
unacceptable LOS E under both
2035 cumulative no project
conditions and 2035 cumulative
plus project conditions. The City
of Dublin level of service
standard for this intersection is
LOS D.
Potentially Significant MM 3.12-5: Convert one of the through lanes to
a second right turn lane at the Hacienda Drive
and Dublin Boulevard Intersection. As part of
the City of Dublin’s Traffic Impact Fee program,
the intersection of Hacienda Drive and Dublin
Boulevard has a planned northbound approach
geometry of three left turn lanes, three through
lanes, and one right turn lane. To mitigate the
impact at the intersection of Hacienda Drive and
Dublin Boulevard would require converting one
of the through lanes to a second right turn lane,
which is the existing northbound geometry at the
Less than Significant
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-2
consequences of implementation of the master plan for redevelopment of Camp
Parks. The FEIS included consideration of the proposed project.
In December 2007 the Army prepared a “Notice of Availability” to solicit a master
developer for the Camp Parks Real Property Exchange Area. The Exchange
Agreement provides the Army with an opportunity to modernize facilities through
the provision of 180-acres of Army owned property (including the NASA parcel but
excluding the 8.7-acre Alameda County Surplus Property Authority parcel), to a
developer in exchange for Camp Parks facilities improvements. The Exchange
Agreement is not a part of the Specific Plan but was necessary to facilitate
acquisition of the property by the project developer.
In October 2008, the Army announced the selection of the master developer for the
Project. In April 2011, the project applicant and the U.S. Army officially finalized the
Exchange Agreement, authorizing the project applicant to commence the Specific
Plan process.
2.2 Regional Location
The project area is located in the City of Dublin in northern Alameda County, near
the center of the Tri Valley region. Regional access to the City is from Interstate 580,
Interstate 680, and the Dublin/Pleasanton line of Bay Area Rapid Transit (BART).
Cities that border Dublin include San Ramon to the north (in Contra Costa County),
Pleasanton to the south and Livermore to the east. The regional location is shown in
Figure 2-1: Regional Location.
2.3 Project Location
The project area is centrally located in the City of Dublin, between the major urban
areas of West and East Dublin. The project area is bound by a network of streets;
5th and 6th street to the north, Arnold Road to the east, Dublin Boulevard to the
south and Scarlett Drive (with future extension) and the Iron Horse Regional Trail to
the west. The project area would connect with the Iron Horse Regional Trail, which
provides access to the Dublin/Pleasanton BART station, approximately one-third
mile to the south. The project vicinity map is shown in Figure 2-2: Project Vicinity.
The project area is generally flat and a significant portion is undeveloped. Two
seasonal drainages traverse the project area, one north to south generally through
the middle of the project area and another along the eastern border, parallel to
Arnold Road.
Existing Setting/Baseline Conditions
The project area was historically used as grazing land prior to the installation of
Camp Parks in the 1940s. The portion of the project area within Camp Parks is
known as the “Cantonment” area. The project area contains former and/or existing
supply buildings and warehouses, infrastructure maintenance facilities, vehicle
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-6
the Environmental Impact Report. The City of Dublin and the project applicant have
provided the following project objectives for the proposed project:
Ensure a long-term financially viable infill project that provides for the
creation of new jobs, recreational opportunities, and expanded housing
opportunities.
Create a community that is compatible in scale and design with surrounding
land uses.
Create a project that has a fiscally-neutral impact on the City’s financial and
services resources.
Create a community with a strong sense of place and a range of recreation
and mobility amenities by designing a unique streetscape that will serve to
tie the neighborhoods together with an integrated design theme.
Establish a cohesive community feel in the project area through the
development and implementation of design guidelines that ensure
consistency between individual neighborhoods while allowing unique
architectural expression.
Provide sufficient land for the Dublin Unified School District (DUSD) to
construct an elementary school within the project site.
Provide a new community park that will be the centerpiece of Dublin
Crossing and serve as the focus for major social, cultural, and recreational
events for the project, residents of Dublin, and the Tri-Valley region.
If the City of Dublin, the Dublin Crossing project developer and the County of
Alameda come to an agreement on the transfer of the Alameda County
Surplus Property Authority (ACSPA) property to either the City of Dublin or
the Dublin Crossing project developer, include the 8.7-acre ACSPA parcel in
the project area and plan for its full integration into the project design while
maintaining the park acreage at some location within the project area.
Create a distinctive Dublin Boulevard with amenities and facilities that are
consistent with the City of Dublin Streetscape Master Plan, Bikeways Master
Plan, and the City of Dublin General Plan.
Provide a range of transportation choices; including walking, bicycling, and
access to transit (BART and bus service), ridesharing, and vanpooling to
reduce traffic congestion and greenhouse gas emissions.
Provide enhanced transportation amenities that encourage non-vehicular
access to and on the Iron Horse Regional Trail, the Dublin/Pleasanton BART
station, and to both on-site and adjacent commercial services.
Provide an east-west roadway through the project site area to enhance
circulation between the points east and points west of the area.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-7
Construct one or more neighborhood parks that are conveniently located and
serve as a focal point of recreation and neighborhood events.
Provide flexibility in land use regulations to allow for site constraints,
variations in housing styles, and changing market conditions.
Provide a mixture of residential unit types appropriate to the projected
housing needs as identified in the City of Dublin General Plan Housing
Element.
Mitigate the unusual phasing impacts of the proposed project by ensuring
that each phase (or combination of phases) can stand alone as a well-
designed neighborhood with an adequate circulation network and an
alternative transition between the proposed project and the remaining Camp
Parks base.
Promote environmental stewardship through the inclusion of progressive
energy programs and standards in construction and ongoing operation of
residential and commercial buildings.
2.6 Proposed Land Uses and Development Plan
The proposed project will redevelop the project area into a new, mixed-use
community with residential, commercial, retail, and parks and open space land uses.
Figure 2-9: Land Use Diagram shows the proposed land use designations at the
project area. Development within the project area would be constructed according
to the Dublin Crossing Specific Plan (Specific Plan). The Specific Plan is a planning
document for the proposed project identifies the ultimate land use plan, circulation,
infrastructure, and fiscal impacts on public services. The Specific Plan also includes
a set of development regulations and design guidelines that will be referenced as
part of all subsequent development reviews and approvals.
The proposed project includes up to 1,995 residential units; 200,000 square feet of
commercial uses, a 30-net acre community park (exclusive of the creek corridor);
five acres of neighborhood parks; and provisional space for a 12 net usable acre
elementary school site. The land use breakdown is included in Table 2-1: Dublin
Crossing Specific Plan Land Use Breakdown. The land use diagram for the proposed
project is shown in Figure 2-7: Conceptual Land Use Plan. An illustrative site plan,
which is a conceptual plan for the proposed project is shown in Figure 2-8:
Illustrative Site Plan.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-8
Table 2-1: Dublin Crossing Specific Plan Land Use Breakdown
Land Use
Total
Acreage1
Permitted
Density
Total Development
Potential
Dublin Crossing Lower Medium
Density Residential (DC
LDRMDR)
41.9 6.0 – 14.0
units/net acre Up to 1,995 dwelling
units.5 Dublin Crossing Medium-High
Density Residential (DC M-HDR) 46.5 14.1 – 20 25
units/net acre
Mixed Use (MU)2
13.2
20.1 – 60 units/net
acre
0.25 to 1.0 FAR
75,000 to 200,000
gross square feet
General Commercial/DC Medium
Density Residential (GC/DC M-
HDR)3
9.1
14.1 - 20 25
units/net acre
0.25 to 1.0 FAR
General Commercial/DC High
Density Residential (GC/DC
HDR)3
9.9
20.1 - 60 units/net
acre
0.25 to 1.0 FAR
Park (P)4 30 n/a n/a
Open Space (OS) 2.6 n/a n/a
School (S)5 12 n/a n/a
Roadways, Utilities, and other
Infrastructure 23.8 n/a n/a
Total Net Project Area Acreage 189
Notes:
(1) Acreages are rounded to the nearest whole number. Net acreage is defined as the gross acreage less
backbone street, public street, and right-of-way area.
(2) The Mixed Use land use district shall contain a minimum of 75,000 gross square feet of commercial uses
(with a maximum floor area ratio (FAR) of 1.0) and a 5 acre neighborhood park. In conjunction with an
application that meets the commercial and park requirements above, residential uses are permitted with a
density of up to 60 units/net acre. FAR applies only to commercial uses.
(3) Can have commercial only, mixed-use, or residential-only uses. FAR applies only to commercial uses.
(4) Park acreage is net usable acres. In the case of the 30 net-acre Community Park, the park is exclusive of
Chabot Creek, the north-south drainage in the western portion of the project area.
(5) Net usable acreage. The school site can be developed at the Dublin Crossing Lower Density Residential (DC
LDR) use and density if the site is not utilized by the Dublin Unified School District and if the Specific Plan
maximum of 1,995 residential units is not exceeded.
The proposed project will be connected by a hierarchy of streets, trails, linked open
spaces, and interconnected neighborhoods. Land uses will also visually and
physically connected by circulation infrastructure, continuity of streetscapes,
complementary design features, and by the nature of their compatibility.
Land uses in the project area reflect the optimal type and mix necessary to achieve
the vision of a livable and sustainable, transit-oriented urban village. The types of
uses and transportation network proposed support transit-oriented development
(TOD) for the Dublin/Pleasanton BART station, local transit service. It will also link
to the Iron Horse Regional Trail and reinforce a stronger connection between West
and East Dublin.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-9
Residential Neighborhoods
The proposed project will contain 88.4 acres of residential neighborhoods
accommodating up to 1,995 residential units with densities ranging from 6 to 20 25
dwelling units per net acre.
Dublin Crossing Lower Medium Density Residential (DC LDRMDR) has a
density of 6 to 14 units per net acre;
Dublin Crossing Medium-High Density Residential (DC M-HDR) has a density
of 14.1 to 20 25 units per net acre; and
Three other non-residential land use districts and the school site also allow the
potential for residential uses, some up to a maximum of 60 units per acre depending
on the district. However, the maximum number of residential units allowed within
the project area is 1,995 units, which includes any units in these non-residential
land use districts.
There will be a variety of housing types throughout the project area including
single-family detached, single-family attached and multi-family units. They will be
located to provide a logical transition from the existing high density residential
development adjacent to the BART station and from the existing medium-density
residential neighborhood east across Scarlett Drive.
Residential density ranges within each residential neighborhood are allowed to
provide flexibility of subdivision design and to adapt to changing future housing
market conditions.
Commercial
Mixed Use
The Mixed Use (MU) land use district is proposed for 13.2 acres at the northwest
corner of Arnold Road and Dublin Boulevard. The Mixed Use land use district will
contain a minimum of 75,000 and a maximum of 200,000 gross square feet of
commercial uses (with a maximum floor area ratio (FAR) of 1.0) and a 5 acre
neighborhood park. In conjunction with an application that meets the commercial
and park requirements above, residential uses are permitted with a density of up to
60 units/net acre that is not included in the commercial FAR calculations.
Residential-only uses are not permitted.
Mixed-use can take the form of vertical mixed-use, horizontal mixed-use, or a
combination of both. Vertical mixed-use is characterized by residential use above
and adjacent to the base commercial. Horizontal mixed-use is characterized by
residential use adjacent to the base commercial, as either attached or detached
units, but the project is designed so that the residential and commercial uses are
integrated and built simultaneously to function as a single project.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-10
Typical permitted commercial uses include a variety of eating and drinking
establishments, hotel, entertainment, retail stores, bank branches, bookstores,
markets, personal and professional services, and office uses.
A five acre Neighborhood Park will be located north of the commercial uses and will
be designed in concert with the surrounding development.
A gateway plaza located at the northwest corner of Dublin Boulevard and Arnold
Road will create a public focal point along Dublin Boulevard. This gateway plaza
will include generous landscape and hardscape treatment around a water feature
with trellises and seating areas to encourage activation of the space.
A second plaza is envisioned in an internal courtyard between the commercial
and/or mixed-use buildings. This plaza will feature a smaller water feature, and
possibly an outdoor eating area for restaurants. Accent planting in pots and
planters will be located throughout the interior plaza to provide color. These plazas
will be constructed concurrent with the commercial and/or mixed-use
development.
General Commercial/Dublin High Density Residential (GC/DC M-HDR)
General Commercial/Dublin Crossing Medium-High Density Residential (GC/DC M-
HDR) is proposed for 9.9 acres on the periphery of the project area along Dublin
Boulevard, as shown in Figure 2-7, Conceptual Land Use Plan. Uses allowed in this
district are commercial, mixed use (as described in the MU land use district above),
and residential. In combination with the Mixed Use land use district (which will
contain a minimum of 75,000 square feet of commercial uses), the GC/DC M-HDR
land use district can contain an additional 125,000 of commercial uses, up to a
Specific Plan area total of 200,000 square feet. The maximum floor area ratio (FAR)
of commercial uses in the district is 1.0 and the maximum density for residential
development in the land use district is 60 25 units/net acre. Residential uses do not
count toward the commercial FAR limits.
General Commercial/Dublin Medium Density Residential (GC/DC MDR)
To provide flexibility to accommodate future market conditions and City housing
needs, a combination land use district is proposed for areas along Arnold Road –
north of the Mixed Use land use district.
General Commercial/Dublin Crossing Medium Density Residential (GC/DC MDR) is
proposed for 9.1 acres on the periphery of the project area along Arnold Road, as
shown in Figure 2-7, Conceptual Land Use Plan. Uses allowed in this district are
commercial, mixed use (as described in the MU land use district above), and
residential. In combination with the Mixed Use land use district (which will contain
a minimum of 75,000 square feet of commercial uses), the GC/DC MDR land use
district can contain an additional 125,000 of commercial uses, up to a Specific Plan
area total of 200,000 square feet. The maximum floor area ratio (FAR) of
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-11
commercial uses in the district is 1.0 and the maximum density for residential
development in the land use district is 20 units/net acre. Residential uses do not
count toward the commercial FAR limits.
Parks, Open Space, and Public Facilities
The project area contains a total of 73.4 acres of land designed for public use which
includes parks/open space (including the five acre neighborhood park within the
Mixed Use land use district), an elementary school site, and public roadways.
Central Park and Iron Horse Regional Trail Realignment
Located at the crossroads of Dublin Boulevard, Scarlett Drive and the Iron Horse
Regional Trail is the proposed 30 net usable acre Dublin Crossing Central Park
(Central Park). The Central Park is envisioned as an innovative and uniquely
designed community gathering place for the residents of Dublin Crossing and the
broader community of Dublin.
The Central Park will provide high-quality recreational amenities for both passive
and active recreation and civic events (e.g., festivals, farmer’s market, art shows,
etc.). Amenities could include an amphitheater, organized and informal sports
fields, sport courts, restrooms, walking paths, parking, a community garden,
demonstration vineyards, play areas, picnic grounds, a carousel, a rose garden, and
possibly a museum.
Chabot Creek extends north to south along the eastern side of the proposed Central
Park. This channel has intermittent seasonal flows and provides regional drainage
from Camp Parks (to the north) and eventually flows under I-580 and into the
Chabot channel. This channel will be relocated and grade contoured as a natural
riparian corridor and could include a multi-use trail with staggered observation
lookouts and interpretive signage and will be located adjacent to the eastern border
of the Central Park. The daylit section of the riparian corridor is not included in the
net usable park acreage total. Two underground onsite storm drainage detention
basins (sized at 1.5 and 3.0 acre-feet) will be constructed within the Central Park.
A gateway plaza at the southeast corner of Central Park at the visually prominent
corner of Dublin Boulevard and the future extended Scarlett Drive will serve as the
primary entrance into the park. The Dublin Boulevard frontage will create an
opportunity for a strong visual civic statement at a key central location within the
City. The gateway plaza will include a large signage treatment and significant
landscaping, seating and other street furniture and a sculptural element(s).
The Iron Horse Regional Trail will be reconfigured with the new project frontage
and Scarlett Drive, and a secondary trail pathway will be integrated along the
southwestern edge of the Central Park. Associated uses adjacent to the secondary
trail pathway through the park could include a café/concession, bicycle racks,
wayfinding signage, lighting, restrooms, and landscaped gardens.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-12
Neighborhood Parks
The five net-acre Neighborhood Park will be located within the Mixed Use land use
district. The amenities and facilities within the park will depend to a great deal on
the land use adjacencies, so therefore design details in the Specific Plan have been
limited. The intent is to create a Park Master Plan that is highly responsive to the
surrounding uses, land use pattern, and neighborhood needs.
School
The proposed project provides an opportunity for the Dublin Unified School District
(DUSD) to acquire 12 net usable acres of land for a public elementary school site
which is designated as School (S) on Figure 2-7: Conceptual Land Use Plan. This
elementary school will be designed to accommodate up toapproximately 900
children and will may include classrooms, a gymnasiummulti-purpose room,
administrative offices, a multi-use sports field, sport courts, a playground, and
parking.
The school site will have an overlay designation of Dublin Crossing Lower Medium
Density Residential (DC LDRMDR). In the event that DUSD does not acquire the site,
residential uses will be allowed in accordance with the DC LDR MDR land use
district, development standards, and design guidelines contained in the Specific
Plan.
2.7 Site Access and Circulation
Vehicular Circulation
Regional and Local Circulation
Interstate Highways – Interstate Highway access to the Specific Plan area is
provided by I-580 and I-680. I-580 runs south of the Specific Plan area and
connects to I-680 and I-880 to the west and I-5 to the east. I-680 runs west of
the Specific Plan area and connects to the northerly cities of San Ramon,
Danville, Walnut Creek and Concord and the southerly cities of Fremont,
Milpitas, San Jose, and Silicon Valley.
Dublin Boulevard – Dublin Boulevard is the main east-west arterial that runs
through the city and is the southern boundary of the Specific Plan area.
Dublin Boulevard provides access to the Dublin/Pleasanton and West
Dublin/Pleasanton BART stations and commercial, office, and residential
areas in the downtown and West and East Dublin. Dublin Boulevard has an
existing bikeway network consisting of Class I bike paths and Class II bike
lanes. Livermore-Amador Valley Transit Authority (Wheels) bus transit
service and a bus rapid transit (BRT) line run along Dublin Boulevard.
Arnold Road – Arnold Road is a local roadway extending north from Dublin
Boulevard into Camp Parks. Existing office buildings are located on the east
side of the roadway. The City of Dublin has future plans for a Class I bike path
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-13
along one side of the road at the Dublin Boulevard and Arnold Road
intersection, which will connect to an existing Class II bike lane on both sides
of the street.
Scarlett Drive – Scarlett Drive is a local roadway located along the west side
of the Specific Plan area. The current alignment terminates at Houston Place
and picks up again at Dublin Boulevard. To implement the City’s existing
approved Capital Improvement Plan street network it is anticipated that the
Specific Plan development will provide for construction of the planned
extension of Scarlett Drive from Houston Place to Dublin Boulevard, adjacent
to the Iron Horse Regional Trail.
Internal Circulation
A grid pattern of streets, each with different character and function, will serve the
transportation needs of the proposed project. The internal “backbone” street
system is designed to establish connections to the existing exterior roadway
network as well as internally between residential neighborhoods, parks, open
spaces, a potential elementary school site, and business/commercial areas. With
sidewalks on all public streets, and bikeways on many, these backbone streets will
become the framework for the pedestrian and bicycle network that connect to uses
both internally and beyond the project area. This internal circulation network will
also allow for adequate and safe pedestrian, bicycle, and vehicle access and drop off
to the school site. Internal roadway classifications include Collector Streets, Local
Streets, and Private Streets, each of which is described below. The proposed
backbone street network is shown in Figure 2-9: Proposed Backbone Street
Network.
Collector Streets
Collector Streets will serve as the primary conduits for interior neighborhood traffic
and provide access to and from neighborhood residential streets and perimeter
streets outside of the project area. These streets are not intended to support
regional traffic, but they may provide direct access to schools and parks. Collector
Streets include B Street, Central Parkway, and G Street, as well as the future
extension of Scarlett Drive.
Local Streets
Local Streets will provide direct multi-modal access to neighborhoods by residents
and visitors while discouraging through traffic and high speeds. Local Streets are
intended to provide low-speed access between and within neighborhoods,
promoting a multi-modal network with an emphasis on comfort, safety, and
amenities for pedestrians and bicyclists.
Private Streets
Private Streets will be privately owned and maintained streets that provide access
to common interest subdivisions (future development subdivisions) and
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-14
commercial and mixed-use developments. Private Streets will be designed for a low
volume of traffic with limited vehicular access. Private Streets may be narrower
than public residential streets and may or may not include sidewalks, on-street
parking, or other street features.
Pedestrian and Bicycle Circulation
The project area is adjacent to and will be connected with the Iron Horse Trail
which is the longest trail system in Alameda and Contra Costa counties. The Iron
Horse Trail provides a direct link with the Dublin/Pleasanton BART station, located
one-quarter of a mile south of the project area. The proposed project would also
include a pedestrian trail adjacent to Dublin Boulevard that would connect to the
existing trail corridor, as well as sidewalks and bicycle paths throughout the project
area.
Public Transportation
The proposed project would be served by the Bay Area Rapid Transit (BART) and
the Livermore-Amador Valley Transit Authority (Wheels).
BART – BART is the regional rail service in the San Francisco Bay Area, with
stations and stops throughout the greater Bay Area, including the
Dublin/Pleasanton and West Dublin/Pleasanton stations. The
Dublin/Pleasanton BART station is located approximately a quarter mile
south of the Specific Plan area.
Livermore-Amador Valley Transit Authority (Wheels) – The Livermore-
Amador Valley Transit Authority provides services in Dublin and the Tri-
Valley area via Wheels, which provides local, regional, and paratransit bus
service. Nearby stops are located along Dublin Boulevard and at the
Dublin/Pleasanton BART station. The project proposes to provide new bus
shelters along Dublin Boulevard.
2.8 Infrastructure Improvements
Storm Drain Infrastructure
The Camp Park’s entire 1,800+ acreA majority of the Camp Parks watershed drains
through the project area. The majority of the runoff from this watershed is conveyed
through Camp Parks in natural and man-made swales. These swales cross the
project area and are intercepted along the north side of Dublin Boulevard and
conveyed to various existing Zone 7 drainage facilities. The main drainage channel
for runoff from Camp Parks crosses the project area and is currently a mapped
FEMA 100-year floodplain as shown in Figure 2-10: FEMA Flood Zone.
To the northeast and east of Camp Parks, runoff is collected in an existing channel
and conveyed south along Arnold Road. Near Arnold Road and Central Parkway, a
flow “splitter” divides flow between two existing Zone 7 drainage facilities. A
portion of this flow continues down Arnold Road, while the remainder is conveyed
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-15
in an existing trapezoidal channel across the southeastern portion of the project
area.
Two underground onsite storm drainage detention basins (sized at 1.5 6 and 3.0 3
acre-feet) will be constructed within the Central Park to accommodate a range of 10
percent of the 2 year storm flows to the 10 year storm flows. The basin size reflects
the bottom dimensions of the proposed basins with 3:1 slopes. An offsite basin
(sized at 76 acre-feet) to meet the 950 cfs maximum requirement is proposed north
of the Specific Plan area along the existing drainage channel. Additionally, best
management practices (BMPs) shall be implemented in new developments within
the project area to ensure that runoff in storm drains does not lower water quality
within or outside of the project area. Refer to Figure 2-11: Conceptual Stormwater
Drainage and Detention System.
Wastewater
The wastewater collection, treatment, and disposal services provider for the project
area will be provided by the Dublin San Ramon Services District (DSRSD). DSRSD
provides wastewater collection and treatment at the Regional Wastewater
Treatment Facility located in the City of Pleasanton.
Several existing sanitary sewer mains currently convey wastewater through and
around the project area. These sewer mains will be rerouted through the project
area as required to accommodate phased development (see Figure 2-12: Conceptual
Sanitary Sewer System). Wastewater generated from the proposed project would be
collected and conveyed through a conventional gravity system of pipes located
within the new street network. The onsite wastewater system will connect to the
existing DSRSD sewer conveyance facilities surrounding the site.
Potable Water Supply Infrastructure
The DSRSD owns and operates potable water system within the boundaries of Camp
Parks including the project area. They also maintain potable water facilities in the
streets adjacent to Camp Parks, including Dougherty Road, Scarlett Drive, Dublin
Blvd. and Arnold Road.
Several existing water mains currently traverse the project area providing service to
existing buildings through a looped water system. As shown in Figure 2-13:
Conceptual Potable Water System, these water mains will be rerouted through the
project area as required to accommodate phased development.
Recycled Water
The DSRSD produces and distributes recycled water for landscape irrigation in
Dublin as part of its Potable Water Conservation and Water Recycling Program.
Except for certain isolated locations, all new irrigation systems serving parks,
streetscapes, and common area landscaping for multi-family or commercial
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-17
Former Building 109/Parks Reserve Forces Training Area (PRFTA) 2 -
Former Building 109/PRFTA 2 located at the southwestern portion of the
project area containing concentrations of dioxin and lead within the surficial
soil above the acceptable risk-based screening levels for closure. The
contamination was remediated by the U.S. Army and cleaned to industrial
standards. There are currently groundwater monitoring wells at this site and
the U.S. Army has completed three quarters of sampling in coordination with
the Department of Toxic Substances and Control (DTSC). The U.S. Army is
awaiting confirmation from the regulatory agencies regarding the
remediation of this site (Personal Communication with Mark Hall,
Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013 and
September 17, 2013).
Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of
the project area and requires land use controls by the San Francisco
CRWQCB to obtain an NFA status. The CRWQCB San Francisco RWQCB
issued a Pre-NFA determination on May 28, 2008. This determination
acknowledged that groundwater cleanup objectives have been met. However,
a deed restriction (land use control) is required to achieve a full NFA
designation due to the presence of soil which contains diesel concentrations
greater than acceptable levels. The Department of Toxic Substances Control
(DTSC) concurred with these findings in January 20, 2012.
Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern
portion of the potential construction debris dump sites consists of large
mounds of soil and debris north of Dublin Boulevard and east of the
installation entrance road. Construction and demolition debris, asbestos
containing material (ACM), waste asphalt, drill cuttings, and grass clippings
were observed in the mounds during site visits conducted from 1990
through 2002. DTSC stated that the area may need further investigation
prior to receiving an NFA. Soil samples revealed that there were high
hydrocarbons in the soil. The soil has been removed and re-sampled with
negative results and have been subsequently submitted to DTSC for review
(Personal Communication with Mark Hall, Environmental Coordinator, U.S.
Army, Camp Parks on May 21, 2013).
In addition, many of the existing structures located within the project area that
would be demolished contain Asbestos Containing Material (ACM) and Lead Based
Paints (LBPs).
Contamination that remains after the U.S. Army or NASA transfers the property to
the project applicant will either be remediated by the project applicant or by the U.S.
Army or NASA, prior to and during site grading and demolition activities with future
development activities.
Dublin Crossing Specific Plan Final EIR
Project Description
Page 2-18
2.10 Project Phasing
Phasing Plan
Development of the project area will include five development phases, with
anticipated build-out occurring over a period of approximately eight to twelve
years. Ultimate development timing will depend on market demands, U.S. Army
contracts, and according to an orderly extension of roadways, infrastructure, public
services, and utilities, and the provision of parks, recreational facilities, school, and
other public amenities. Figure 2-15: Conceptual Phasing Plan and Table 2-2:
Phasing Plan identifies the proposed phasing plan for development within the
project area.
The development phases shall occur sequentially, although portions of phases may
occur concurrently. Development of each phase shall include all infrastructure,
services, facilities and amenities, both public and private, needed to serve the uses
and structures within that phase in accordance with the Specific Plan. Development
of each phase will result in a project that could “stand alone” if future phases were
not constructed. It is anticipated that each phase may include sub-phases which may
result in multiple Final Maps.
Table 2-2: Phasing Plan
Project Phase Gross Area 1
Maximum Number
of Residential Units
Maximum Amount
of Commercial
Square Footage
1 33 570 -
2 54 421 75,000
3 48 435 50,000
4 26 156 75,000
5 28 413 -
Total 189 acres Up to 1,995
residential units
Up to 200,000
Commercial SF
Source: Dublin Crossing, LLC
2.11 Requested Actions, Entitlements, and Required Approvals
Initial entitlements required for future development in the Specific Plan area
include the following actions to be taken by the Dublin City Council:
EIR Certification: Certification of the Dublin Crossing Specific Plan
Environmental Impact Report (EIR), including findings that identify
significant environmental impacts of the Project and mitigation measures
that must be implemented as part of the Project, which will be reflected in
the Mitigation Monitoring and Reporting Program (MMRP) and imposed as
conditions of approval on subsequent discretionary approvals. This action
will be adopted by resolution.
Dublin Crossing Specific Plan Final EIR
Aesthetics and Visual Resources
Page 3-11
Degradation of the Visual Character of the Project Area and Surrounding Area
Impact 3.1-2: Implementation of the proposed project would alter the existing
aesthetic character of the project area by redeveloping the project
area with residential, commercial and mixed-use development.
However, the project area has been partially disturbed as part of its
use as the Camp Parks Reserve Forces Training Area. In addition, the
proposed Specific Plan includes development standards and design
guidelines that are designed to create a more visually appealing
environment within the project area. Therefore, the proposed project
is not anticipated to degrade the visual character of the project area
and surrounding uses and is therefore considered a less than
significant impact.
The project area contains approximately 62 acres of developed land, which is
primarily located in the western portion of the project area and includes 18
buildings, which are currently used for installation operations, academic activities,
administration, equipment storage and maintenance for Camp Parks. Buildings are
interspersed with open areas, which consist of primarily non-native grasslands.
The proposed project would result in the conversion of the project area from
partially developed land to urban uses, which would change the existing views to
and from surrounding properties and roadways. As shown in the Figure 2-7:
Conceptual Land Use Plan and Figure 2-8: Illustrative Site Plan, the proposed project
includes development of up to 1,995 residential units; 200,000 square feet of
commercial uses, a 30 net-acre community park, five acres of neighborhood park,
and a 12 net usable acre elementary school site, which would be developed within
five phases over ten years. Figures 3.1-1a, 3.1-1b and 3.1-1c: Visual Simulations
illustrate future development of the project area from Dublin Boulevard, Scarlett
Drive and the Iron Horse Regional Trail, and Arnold Road including the construction
of buildings and the installation of new landscaping (e.g. trees) within the project
area1. As shown in the visual simulations, development of the proposed project
would further urbanize the project area and would slightly detract the viewer from
these distant views of the hills along these roadways. However, the project area is
partially degraded and the views have already been compromised because portions
of the project area were previously developed associated with the Camp Parks.
The proposed Specific Plan includes both development standards and design
guidelines to guide site design, architecture, circulation, parking, lighting, and other
distinguishing features. The design guidelines will address overall building design
1 The visual simulations are for illustrative purposes and building heights could be higher than what is shown in the
simulations.
Dublin Crossing Specific Plan Final EIR
Aesthetics and Visual Resources
Page 3-12
(e.g. siting, architectural details), building articulation, building massing, indoor-
outdoor relationship, building materials, colors, and finishes, base and top
treatments, entry designs, windows and doors, roofs, mechanical equipment and
utilities, service, storage and loading areas, perimeter walls and fences, onsite public
art, and exterior lighting. These development standards and design guidelines will
also be used during the design review process to guide future development.
Building heights associated with the proposed project would range from a
maximum height of 40 feet and three stories for the DC Lower Medium Density
Residential (DC LDRMDR) and DC Medium Density (DC M-HDR) land use districts to
75 feet and six stories for the General Commercial/DC Medium-High Density
Residential (GC/DC M-HDR) and General Commercial/DC High Density Residential
(GC/DC HDR) land use districts.
The overall change in the visual character of the project area from a partially
developed area to more urban and suburban land uses would result in a permanent
change in the character of the project area. However, the project area is surrounded
by primarily by urban uses and would be of high quality design, which would
complement the surrounding uses. Therefore, implementation of the proposed
Specific Plan would help ensure that properties and buildings contribute to visually
appealing neighborhoods, commercial areas, parks and environments and would
not result in the degradation of the visual character of the project area and
surroundings. Therefore, the proposed project would be considered a less than
significant impact, and no mitigation is required.
Light and Glare
Impact 3.1-3: The project area and its surroundings are currently developed with
some buildings and site improvements that were part of the Camp
Parks facility, which generate daytime and night-time light and glare.
Additional sources of daytime glare and nighttime lighting would be
introduced through build-out of the Specific Plan. The proposed
Specific Plan includes development standards and design guidelines
to reduce light and glare. This is considered a less than significant
impact.
Implementation of the proposed project would introduce new development within
the Specific Plan area, increasing the potential for daytime and nighttime light and
glare. The main sources of daytime glare would be from sunlight reflecting from
structures with reflective surfaces, such as windows. The main sources of nighttime
light and glare would be from additional lighting, including, but not limited to,
internal and external building lights, parking lot lights, street lighting, site lighting,
lights associated with vehicular travel (i.e., vehicle headlights), and any new security
lighting associated with future development.
The proposed Specific Plan includes design guidelines that address lighting in the
project area, including, but not limited to the following:
Dublin Crossing Specific Plan Final EIR
Air Quality
Page 3-35
Threshold Exceeded ? Yes Yes Yes No
Notes:
1. Emissions estimates calculated using CalEEMod.
2. Area source mitigation includes the use of low VOC paints and only natural gas hearths, which are proposed for the project.
Refer to Appendix B, Air Quality and Greenhouse Gas Data, for detailed model input/output data.
Energy Source Emissions
Energy source emissions would be generated as a result of electricity and natural
gas (non-hearth) usage including space heating and cooling, water heating,
ventilation, lighting, appliances, and electronics.
Mobile Source Emissions
Mobile sources are emissions from motor vehicles, including tailpipe and
evaporative emissions. According to the Traffic Impact Analysis prepared by
Hexagon in 20122013, the proposed project would generate 19,64122,047 net new
daily vehicle trips. Project-generated vehicle emissions were calculated using the
CalEEMod model and are shown in Appendix B. This model was utilized to predict
ROG, NOX, and PM10 emissions from motor vehicle traffic associated with the
proposed project based on the trip generation in the iTraffic Impact Analysis. As
shown in Table 3.2-6: Proposed Project Long-Term Operational Emissions,
unmitigated mobile source emissions generated by vehicle traffic associated with
the proposed project would not exceed established BAAQMD thresholds for PM2.5,
but would exceed thresholds for ROG, NOX, and PM10.
The proposed project includes project design features that would reduce potential
mobile source emissions. Section 3.0 (Design Guidelines) of the Dublin Crossing
Specific Plan provide the basis for development that includes increased density and
diversity, improved walkability design, increased destination and transit
accessibility, improved pedestrian network, limited parking supply, traffic calming
measures, and trip reduction, ride sharing, and employee vanpool programs, which
were applied in CalEEMod air quality model; refer to Appendix B, Air Quality and
Greenhouse Gas Data for a description of model inputs and design
features/mitigation measures.
Total Emissions
As shown in Table 3.2-6: Proposed Project Long-Term Operational Emissions, the
total unmitigated operational emissions associated with build-out of the proposed
project would exceed BAAQMD thresholds for ROG, NOX, PM10, and PM2.5. Stationary
source emissions would be reduced with compliance with BAAQMD Regulation 6,
Rule 3 (Wood-Burning Devices), which restricts wood burning and places limits on
excessive smoke. However, as indicated in Table 3.2-6: Proposed Project Long-
Term Operational Emissions, mobile source emissions are the largest contributor to
the estimated air pollutant levels. Due to the scale of the proposed project, which
would generate 19,64122,047 new trips per day, emissions would exceed the
BAAQMD thresholds. As described above, the proposed project is a mixed use
project in proximity to the Dublin/Pleasanton BART station and associated transit
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Biological Resources
Page 3-47
3.3 Biological Resources
Several sensitive biological resources are known to occur or have the potential to
occur within and adjacent to the project area as identified during biological studies
and surveys that were conducted as part of the Master Planned Development at the
Camp Parks Reserve Forces Training Area between 1995 and 2003. Several of these
sensitive biological resources have the potential to be affected by the proposed
project. Therefore, this section describes the existing biological resources within
and adjacent to the project area; assesses the potential impacts to these biological
resources associated with the proposed project; and recommends mitigation
measures for impacts that are considered significant under Federal, State and Local
policies and regulations, including, but not limited to, the Clean Water Act (CWA),
the Federal Endangered Species Act (ESA), the California Endangered Species Act
(CESA), the California Environmental Quality Act (CEQA), and City of Dublin
Ordinances.
Cardno Entrix prepared a biological resource technical report on behalf of the
project applicant in May June 2013, which updates previous biological technical
studies that were prepared by the U.S. Army for the Final Environmental Impact
Statement on Master Planned Redevelopment at Camp Parks (U.S. Army 2009). This
technical report was peer reviewed by RBF Consulting for technical accuracy and is
included as Appendix C.
Environmental Setting
In addition to approximately 77 acres of the developed and semi-developed land
withinportions of the project area surveyed by Cardno Entrix, two other vegetation
communities are located within the project area: wetlands and non-native
grasslands are also located within the project area. The acreage of these vegetation
communities is shown below in Table 3.3-1: Habitats and Vegetation Communities
within the Project Area and on Figure 3.3-1: Existing Biological Habitats.
Table 3.3-1. Habitats and Vegetation Communities within the Project Area
Habitat Vegetation Community
Acreage
Wetlands and Other Waters 2 1.61 Acres
Non-native grassland 105 104.32 Acres2
Developed, or semi-developed 77 73.66 Acres1
Total 183 179.59 acres
Notes:
1. Includes buildings, roadways, and landscaped areas. Approximately 62 acres are
impervious.
Source: Cardno Entrix 2013
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The Alameda County Surplus Property portion of the project area was surveyed as
part of the Dublin Transit EIR and is comprised of non-native grassland. The EIR
was certified by the City Council on November 19, 2002. Based on the analysis
completed in the Dublin Transit Center EIR, the Alameda County Surplus Property
was not found to contain any special status species or significant biological features
(e.g. wetlands), etc.
Wetlands and Other Waters
Drainage Ditches
There are seven drainage ditches within the project area as shown in Figure 3.3-2:
Preliminary Wetlands and Other Waters. All are manmade features created to
channel runoff away from various parts of the project area. These drainage ditches
were either dry or were saturated due to recent rains at the time of the survey
conducted by Cardno Entrix in March 2012, but did not contain standing water and
did not appear to be subject to high-velocity flows as there was no scour or distinct
bed and bank.
Based on the vegetation present, these features function as intermittent drainages
to channel runoff during rain events. Individual descriptions of the ditches are
provided below.
Ditch 01 is a shallow roadside drainage ditch designed to carry flows from an
asphalt pad and adjacent paved roads in a southern direction along Keppler Avenue,
before entering a culvert under the road, and flowing north of 5th Street into a
culvert east of Hutchins Avenue to Chabot Canal (Canal 01). The majority of the
ditch is dominated by annual grassland vegetation including brome species, yellow
star thistle, and stinkwort, and lacked evidence of hydrology or an ordinary high
water mark. A portion of the drainage ditch has begun to fill in with sediment along
Keppler Avenue near 5th Street; this portion is discussed as Wetland Drainage Ditch
01 in Wetland Drainage Ditches below.
Ditch 02 is a drainage ditch designed to flow in a southern direction from 6th Street,
becoming progressively deeper before tying into Chabot Canal (Canal 01) at
approximately the ordinary high water mark. The majority of the ditch is dominated
by annual grassland vegetation and lacks an ordinary high water mark. An existing
culvert allows for vehicle access over the ditch into an industrial yard approximately
155 feet south of 6th Street. This drainage appears to receive sheet flow from the
adjacent roadway, and developed areas, as well as seasonal irrigation runoff from
landscaping to the west and lacks an OHW, scour, or evidence of high flows.
Ditch 03 begins north of 4th Street near Hutchinson Avenue, and flows west
towards Chabot Canal, becoming progressively deeper before tying into the Canal at
approximately the ordinary high water mark. This drainage ditch is dominated by
annual grassland vegetation and lacks an ordinary high water mark, scour, or
evidence of high flows. The drainage is encased in existing culverts, each
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Page 3-49
approximately 100-feet long, in two areas. This drainage appears to receive sheet
flow from Hutchison Road, 4th Street, and the adjacent annual grasslands.
Ditch 04 consists of a very shallow, poorly drained portion south of 4th Street, a
maintained ditch flowing north to south that intersects with an east to west flowing
segment that eventually discharges into Ephemeral Drainage 01. This ditch exhibits
variable vegetation and hydrology.
In three locations (Wetland Drainage Ditch 02, 03 and 04) the ditch is shallow and
poorly drained and has developed wetland indicators that are discussed in more
detail below. The north to south flowing portion near 4th Street is maintained
through dredging of sediment, vegetation removal, and grading to maintain flows
and prevent stormwater from ponding on 4th Street. Further south the ditch was
used to direct water away from temporary facilities on an adjacent concrete pad,
and existing drainage pipes from the pads to the ditch were observed. The southern
portion of the ditch no longer appears to receive maintenance and does not have
positive flow towards Chabot Canal during low flow events resulting in stormwater
ponding in Wetland Drainage Ditch 04 (discussed below).
Ditch 05 is a shallow roadside ditch that may have originally overtopped into Canal
02, but does not appear to receive sufficient flows to exhibit wetland characteristics
or evidence of an ordinary high water mark. No surface water connection to Canal
01 or Canal 02 was observed. Ditch 06 is an incised feature south of a industrial yard
that flows to Chabot Canal that exhibits evidence of intermittent flow, and is
dominated by non-native grassland species and canary grass (Phalaris minor). Ditch
07, is a section of open ditch that transfers water from storm drain pipe draining
road runoff from Dublin Boulevard into Chabot Canal.
Wetlands and Drainage Ditches
In four locations, the above described drainage ditches pond water for a sufficient
period of time to develop hydric soils, a dominance of hydrophytic vegetation, and
exhibit primary or secondary hydrology indicators for wetlands. These areas are
indicated as Wetland Drainage Ditch 01, 02, 03, and 04 as shown in Figure 3.3-2:
Preliminary Wetlands and Other Waters.
Soil samples SP6 and SP8 that were conducted by Cardno Entrix exhibit typical
wetland indicators observed within the wetland drainage ditches. These samples
were taken in depressions and/or poorly drained locations within the manmade
drainage ditches. These areas were dominated by a variety of facultative wetland or
obligate wetland plants species, such as tall flatsedge (Cyperus eragrostis), Baltic
rush (Juncus balticus), western dock (Rumex occidentalis), and common spikerush
(Eleocharis macrostachya) and exhibited depleted or gleyed soils. Hydrology
indicators included ponding water, saturation, or surface soil cracks. Wetland
Drainage Ditch 01 appears to have formed due to a blocked culvert in roadside
drainage ditch, while Wetland Drainage Ditch 02, 03, and 04 are the result of poor
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Page 3-50
flow due to low initial grade or sediment buildup in manmade drainage ditches. All
associated drainage ditches flow to Chabot Canal.
Ephemeral Drainage
A portion of drainage ditch between Camp Parks Boulevard and Chabot Canal
displays evidence of an ordinary high water mark with minor shelving and rilling
and receives intermittent flows. The ditch is dominated by upland grasses, but was
observed ponding at a higher frequency then adjacent drainage ditches. This
drainage connects Drainage Ditch 04 to Chabot Canal and is approximately 905 feet
(0.288 29 acres).
Canal
Other waters of the U.S. include Chabot Canal (Canal 01), and an unnamed canal
(Canal 02). Both canals are Canal 01 is an ephemeral features with water
marks/staining and drift deposits indicating the ordinary high water mark. This
ordinary high water mark was used to delineate the edge of the feature. Margins of
Canal 01 were dominated by Harding grass (Phalaris aquatica) and canary grass.
Canal 02 is a maintained concrete lined channel with evidence of flow, but
dominated by ruderal vegetation and mowed/maintained annual grasses. These
features appear to be improved flood control channels, designed to convey high
flows during rain events and have steep sides that extend well past the ordinary
high water mark.
Chabot Canal (Canal 01), exhibited minor scouring in areas that appear to be from
frequent low flows, and shelving in the southern section due to higher flows.
Indicators of hydrology range from ponding and saturation to water stained leaves
and drainage patterns. Vegetation with Chabot Canal ranges from emergent
vegetation such as cattails, rushes and sedge in the southern section, to a small area
of riparian vegetation in the central portion, to mowed or cleared vegetation with a
shallow low-flow channel and annual grassland margins in the northern section.
Chabot Canal is primarily a vegetated canal, but is concrete lined at the southern
perimeter of the project area and has rip-rap and/or concrete at culverts and where
existing storm drain systems outfall into the Canal. The Canal receives nuisance
flows from existing storm drain systems and manmade drainage ditches throughout
the project area, and conveys off-site flows from north of the project area through
the area into the City of Dublin storm drain system.
Canal 02 consists of a concrete and riprap-lined low-flow channel, and margins are
dominated by immature annual grasslands and ruderal vegetation. Canal 02 appears
to conveyed flows from a historic creek in the Tassajara Regional Park as well as
stormwater flows from developed areas to the northeast of the project area.
Through the project area a portion of this feature has been previously incased and
consists of underground drainage facilities. The majority of flows appear to be
diverted into an encased storm drain system at the southeastern edge of the project
area.
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Emergent Wetland
Two emergent wetlands (Emergent Wetland 01, Emergent Wetland 02) located
west of Chabot Canal, were dominated by cattails, stinkwort, curly dock, and
canarygrass, and exhibited gleyed sandy clay soils. Both features exhibited primary
hydrology indicators including saturation, surface water, water marks and/or
water-stained leaves. These features are a direct result of a leaking potable water
pipeline containing chlorinated and fluoridated water, and owned by the Dublin San
Ramon Services District, and as such would not typically be considered jurisdiction
wetlands by the USACE.
Seasonal Wetland
A 0.092 024 acre marginal seasonal wetland feature is located north of 3rd Street
and east of Fernandez Boulevard, which is dominated by non-native facilitative
wetland plants consisting primarily of common plantain (Plantago lanceolata) and
seaside barley (Hordium Marinum). This feature lacked hydrology and was dry
during two of three wet season site visits.
Soils are fill material and lack strong hydric indicators. The feature is adjacent to
intermittent Drainage Ditch 01.
Potential Section 404 Jurisdictional Wetland and Other Waters
Based on the area delineated, approximately 1.605 61 acres of potentially
jurisdictional wetlands and Other Waters were identified within the project area,
including 0.103 11 acres of wetland drainage ditch, 0.092 24 acres of seasonal
wetland, and 1.409 27 acres of other waters of the U.S.
These features appear to be subject to the United States Army Corps of Engineers’
(USACE) jurisdiction pursuant to the Clean Water Act for the following reasons:
1.409 27 Acres of Other Waters: Chabot Canal (Canal 01) and Canal 02 areis
an ephemeral surface tributaries to Alamo Creek, which is a relatively
permanent water. Ephemeral Drainage 01 is a tributary to Chabot Canal that
displays and ordinary high water mark(OHW).
0.196 24 Acres of Wetlands: The seasonal wetland and wetland drainage
ditches meet the USACE’s three-parameter wetland criteria (hydrophytic
vegetation, hydric soils, and wetland hydrology); and are hydrologically
linked to Chabot Canal, thus, the wetlands has a significant nexus to a non-
relatively permanent water that flows directly to a Traditional Navigable
Water.
Drainage ditches (Drainage Ditch 01, 02, 03, 04, 05, 06, and 07) within the project
area are man-made drainage features designed to drain adjacent upland areas
toward Chabot Canal and did not exhibit a dominance of wetland vegetation, hydric
soils, or hydrology. Additionally, they lacked indicators of an ordinary high water
mark and appear to be only sporadically inundated.
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Manmade ditches created in upland habitats to direct runoff from upland habitats
are typically not classified as jurisdiction wetlands by the USACE. Emergent
wetlands (0.022 acres) were found to be a direct result of a leaky potable water pipe
and are not typically considered jurisdictional.
Waters of the State
Using the USACE guidance, all wetlands and other waters of the U.S mapped within
the project area using would likely be considered jurisdictional by the Regional
Water Quality Control Board (RWQCB) under the Porter-Cologne Act. Additionally,
0.494 acres of drainage ditch (Drainage Ditch 01, 02, 03, 04, 05, 06 and 07) that
were created in uplands to drain uplands may be considered jurisdictional by the
RWQCB
Non-native grasslands
Non-native grassland is composed of annual grasses, with cover ranging from sparse
to dense, and associated species of native and non-native flowering forbs. Most of
the plants are dead in the summer and fall seasons. Non-native grassland usually
occurs on fine-textured soils that are moist or very wet during the winter rainy
season and very dry during the summer. It is distributed throughout the valleys and
foothills of most of California, and generally ranges from sea level up to about 3,000
feet elevation.
Non-native grasslands within the project area contain both native and non-native
species. The plant composition within the project area has not changed since the
previous surveys (2003 to 2004) were conducted. Dominant species include
slender wild oat (Avena barbata), wild oat (Avena fatua), Bermuda grass (Cynodon
dactylon), slender wild oat (Avena barbata), ryegrasses (Lolium spp.) and several
barley species (Hordeum spp.) and canarygrass (Phalaris ssp.). Associated annual
forbs include primarily non-native plants such as black mustard (Brassica nigra),
short pod mustard (Hirschfeldia incana), bristly ox-tongue (Picris echioides), alkali
mallow (Malvella leprosa), stinkwort (Dittrichia graveolens), annual fireweed
(Epilobium brachycarpum), and yellow star-thistle (Centaurea solstitialis). The
ruderal grassland habitat covers approximately 104.69 acres and occurs in
previously disturbed areas, evident by concrete footings, asphalt, rebar, and pipes
from demolished buildings. Some of these ruderal grassland areas are mowed or
disked for fuel control.
Developed Areas
The project area includes approximately 77 acres of developed areas that include
hardscape and landscape areas. Developed areas include buildings, parking areas,
storage areas and roads. The developed areas within the project area are
concentrated towards the west. However, the eastern portion also includes a few
buildings, storage yards and associated parking lots.
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Special Status Species
According to the CNDDB, USFWS, and CNPS queries, a total of 68 special-status
species and three rare natural communities and USFWS-designated critical habitat
for California tiger salamander (Ambystoma californiense), California red-legged frog
(Rana draytonii), Alameda whipsnake (Masticophis lateralis euryxanthus), and
vernal pool fairy shrimp (Branchinecta lynchi) are known to occur in the project
areawithin the Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical
quadrangle. Information gathered during the site visits and data on range, habitat
requirements, and known localities was used to refine the species list and determine
which species were likely to occur based on the plant communities (i.e. habitat
types) within the project area. Based on the database queries and biological surveys,
nine wildlife species and one plant species have a moderate or higher likelihood of
occurrence in the project area. No rare natural communities occur within the
project area. Similarly, there is no-USFWS designated critical habitat within the
project area.
Survey Methods
Cardno Entrix performed queries of the California Department of Fish and Game,
Natural Diversity Database (CNDDB), California Native Plant Society (CNPS) Online
Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPSEI)
and the United States Fish and Wildlife (USFWS) Online Species List of Federal
Endangered and Threatened Species to identify known biological resources within
the project areagreater project vicinity. Results of those queries are shown in the
technical appendices in Appendix C.
A reconnaissance-level survey was conducted by Cardno Entrix biologist on March
6, 2012. The survey consisted of walking meandering transects through accessible
representative vegetation or plant communities that occur within the project area to
assess their suitability for native plant and animal species. Particular attention was
given to areas that appeared to provide the most suitable habitat for special-status
species expected to occur in the region.
Previous Biological Surveys
A special-status plant species survey was completed at Camp Parks in 1995 by Jones
& Stokes (as cited in US Army 2006), followed by a field reconnaissance in 1997 by
the U.S. Army Corps of Engineers-Louisville District 2003 (as cited in US Army
2006). An extensive two-year floristic survey, which included three performance of
surveys coinciding with the progression of flowering, was conducted between
spring 2001 and spring 2003. In 2003, a sensitive plant survey was conducted in
appropriate habitat within Camp Parks with special focus on the Cantonment
Areaon the project area, and southwest portion of the Training Area. No federal or
state-listed or candidate plant species were detected during any survey, site
conditions have not changed significantly since the surveys were conducted and
none are believed to occur within the project area.
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An installation-wide faunal survey focusing on rare species was completed in 1995
by Jones & Stokes (as cited in U.S. Army, 2006). In addition, surveys were performed
in 2003 for vernal pool invertebrates, California red-legged frog, burrowing owls,
San Joaquin kit foxes, and other sensitive species including raptors and loggerhead
shrikes. Most of the latter surveys focused on the project area (Cantonment Area)
and adjacent portions of the southwest Training Area at Camp Parks. However, the
vernal pool surveys were done in appropriate habitat throughout Camp Parks and
the San Joaquin kit fox surveys addressed appropriate habitat in the project area
Cantonment and southern training area. Site conditions have not changed
significantly since these surveys were conducted as confirmed by Cardno Entrix in
the March 2012 reconnaissance survey.
A United States Fish and Wildlife Service protocol dry season branchiopod survey
was conducted April 17, 2012 by Cardno Entrix. Wet season vernal pool
invertebrate surveys were conducted winter through spring of 2012-2013.
However, results of these surveys shall be considered preliminary until accepted by
the USFWS.
Species Accounts
Life histories of special-status plant and animal species identified by the CNDDB,
USFWS, and the California Native Plant Society (CNPS) lists that have a moderate or
higher likelihood of occurringthe potential to occur in the project area are described
below:
Conservancy fairy shrimp (Branchinecta conservation)
The conservancy fairy shrimp is endemic to California’s Central Valley, with one
outlying population in Ventura County, southwest of the Valley. Within the Central
Valley, records for this species come from Tehama, Butte, Glenn, Solano and Yolo
County. There are no known occurrences in Alameda County. Although not a target
species, this species was not detected in focused surveys between 2002 and 2003.
This species was also not detected and during wet and dry surveys conducted by
Cardno Entrix in 2012 and 2013. However, these surveys are considered
preliminary until accepted by the USFWS. Suitable large playa pools that this
species typically occurs in are not present in the project area. Therefore, the
likelihood of Conservancy fairy shrimp occurring within the project area is
considered low.
Longhorn fairy shrimp (Branchinecta longiantenna)
Typical habitats for Longhorn fairy shrimp include vernal pools, seasonally ponded
areas within vernal swales, and ephemeral freshwater habitats. There are only eight
known populations of the longhorn fairy shrimp. The nearest occurrence of this
species is within the Altamont Pass and these occurrences occur within clear
depression pools in sandstone outcrops. Vernal pools in other parts of California
that support these fairy shrimp consist of either loam and sandy loam or shallow,
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alkaline pools. The seasonal pool habitat is subject to seasonal variations, and
longhorn fairy shrimp are dependent on the ecological characteristics of such
variations. These characteristics include duration of inundation and presence or
absence of water at specific times of the year. The longhorn fairy shrimp is capable
of living in vernal pools of relatively short duration (pond 6 to 7 weeks in winter
and 3 weeks in spring). This species was not found during USFWS protocol level
surveys conducted from 2002 to 2003 of by the surveys conducted in 2012 and
2013 by Cardno Entrix. Therefore, the likelihood of Longhorn fairy shrimp
occurring within the project area is considered low.
Vernal pool fairy shrimp (Branchinecta lynchi)
Vernal pool fairy shrimp are federally listed as threatened. Vernal pool fairy shrimp
occur in vernal pools and seasonal wetlands that fill during winter and spring rains
and then dry up fall until rains return. Cysts lie in the soil through dry periods,
hatching with the next season’s rains, or may even remain dormant for decades
before hatching. There are known occurrences of this species within Springtown in
northeast Livermore, approximately eight miles east of the project area. This
species was not detected during focused biological surveys from 2002 to 2003 or
the 2012 and 2013 surveys conducted by Cardno Entrix. The results of the 2012
and 2013 surveys are considered preliminary until accepted by the USFWS.
Therefore, the likelihood of Vernal pool fairy shrimp occurring within the project
area is considered low.
Curved-foot hygrotus diving beetle (Hygrotus curvipes)
The curved-foot hygrotus diving beetle is not state or federally listed or a species of
concern, but is included on the CDFG CDFW Special Animals list. This aquatic beetle
occurs in small seasonal pools and wetlands and small pools left in dry creek beds,
and is typically associated with alkaline tolerant vegetation. Occurrences of this
species are known from the northeast portion of Livermore and Altamont Pass.
Suitable habitat within the project area exists along the drainage canals. This species
was not detected during focused biological surveys from 2002 to 2003 and site
conditions have not changed significantly since that time. Therefore, the likelihood
of Curved-foot hygrotus diving beetle occurring within the project area is
considered low.
San Francisco forktail damselfly (Ischnura gemina)
The San Francisco forktail damselfly is found from Tomales Bay in Marin County,
south to the north side of Monterey Bay in Santa Cruz County. This species is known
to occur in and around seeps, ponds, small creeks and canals. Males and females are
extremely sexually dimorphic, showing a great range of color. Females deposits eggs
in plant stems, generally without being guarded by a male. This species is believe to
be restricted to the San Francisco Bay region and may have disappeared from
locations in the southern part of its former range, perhaps from hybridization with
black-fronted damselflies. Suitable habitat within the project area exists along the
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drainage canals. This species was not detected during focused biological surveys
conducted from 2002 to 2003 and site conditions have not changed significantly
since that time. Therefore, the likelihood of San Francisco forktail damselfly
occurring within the project area is considered low.
California linderiella (Linderiella occidentalis)
California linderiella is not state or federally listed or a Species of Special Concern,
but is included on the CDFW Special Animals list. This small fairy shrimp occurs in
vernal pools and other seasonal wetlands. Their life history is very similar to that of
the vernal pool fairy shrimp, but this species is more widespread. California
linderiella commonly occur in Alameda County, the nearest CNDDB occurrence is
approximately 1.17 miles to the northeast just south of the Air Force
Communication Annex. This species was not detected during focused biological
surveys between 2002 and 2003 or during the surveys conducted by Cardno Entrix
in 2012 and 2013. Therefore, the likelihood of California linderiella occurring
within the project area is considered low. Western pond turtle (Actinemys
marmorata)
Western Pond Turtle
The western pond turtle (WPT) is a California Species of Special Concern. This
aquatic turtle ranges throughout much of the state, from the Sierra Nevada foothills
to the coast, and in coastal drainages from the Oregon border to the Mexican border.
They typically inhabit ponds, slow-moving streams and rivers, irrigation ditches,
and reservoirs with abundant emergent and/or riparian vegetation. The turtle
requires adjacent (i.e., within 200 to 400 meters of water) uplands for nesting and
egg laying, typically in soils with high clay or silt component on unshaded, south-
facing slopes. In colder climates, they may spend the winters hibernating in these
upland habitats. There are known CNDDB occurrences for this species within one-
half mile of the project area within ponds and perennial drainages that provide
potential habitat for this species. This species was not detected during focused
biological surveys from 2002 to 2003. Therefore, the likelihood of Western pond
turtle occurring within the project area is considered low.
California tiger salamander (Ambystoma californiense)
The California tiger salamander (CTS) is federally listed as threatened and a
California threatened species. CTS is most commonly found in annual grassland
habitat, but also occurs in grassy understory of open valley foothill hardwood
habitats. The species occurs from near Petaluma, Sonoma County, east through the
Central Valley to Yolo and Sacramento counties and south to Tulare County, and
from the vicinity of San Francisco Bay south into Santa Barbara County. Adults
spend most of the year in subterranean refugia, especially burrows of California
ground squirrels, and occasionally man-made structures. The primary cause of
decline of CTS populations is the loss and fragmentation of habitat from human
activities and the encroachment of nonnative predators.
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There are several known CNDDB occurrences for this species within two miles of
the project area. The nearest occurrences are 1.4 miles to the north and 1.2 miles to
the northeast of the project area. USFWS protocol requires that occurrences be
evaluated within one mile of a proposed project. The first occurrence is located
within Camp Parks training area. The second during the March 2012 field
surveyoccurrence is located within Tassajara Creek. No suitable habitat for the
CRLF was observed during the March 2012 field survey. The ephemeral
drainage/storm drainage canal in the center of the project area does not support
deep pools where this species may breed. Similarly, the drainage canal along the
eastern border of the project area is channelized and concrete lined. In both of these
canals, cattails were present. Booz Allen Hamilton and GANDA surveyed the project
area and additional sections of the Cantonment Area of Camp Parks in 2003. The
survey concentrated on sixteen wetlands within or immediately north of the
Cantonment Area. Of sixteen sites visited, two areas within the Cantonment Area
contained standing water. The first wetland (ephemeral drainage/ storm drainage
canal) is located just southwest of the intersection of 8th Street and Hutchins
Avenue. The second wetland is grassy ditch located just west of the intersection
between 8th Street and Davis Ave. The Booz Allen Hamilton (2004) report state that
it was abnormal for this grassy ditch, to contain water during the summer months
and it was believed that this water was due to runoff from landscaping; this ditch is
nearly surrounded by developed areas with several landscaped areas. Although
these areas did not contain sufficient water for breeding, additional surveys were
conducted. CRLF were not observed during any of these surveys. No suitable aquatic
habitat was observed within the project area during the March 2012 survey
conducted by Cardno Entrix. Therefore, the likelihood of California Tiger
SalamanderCRLF occurring within the project area is considered low.
Cooper’s hawk (Accipiter cooperii)
This hawk is found throughout California, except in the high altitudes of the Sierra
Nevada. The Cooper’s hawk is protected under the Migratory Bird Treaty Act
(MBTA). Cooper’s hawks typically breed in forest, or in groves of trees along rivers,
but also in low scrub of treeless areas. The wooded area is often near the edge of a
field or a water-opening. The nesting season for this hawk begins late February,
however, lost clutches are replaced. The Audubon eBird database contains
observations of Cooper’s hawks in the Dublin and Livermore area. Based on the
survey conducted in March 2012 by Cardno Entrix there is limited nesting habitat in
the project area, Cooper’s hawk is a year round resident of the project vicinity.
Therefore, the likelihood of Cooper’s hawk occurring within the project area is
considered moderate.
Golden eagle (Aquila chrysaetos)
Golden eagle is a California fully protected species and is protected under the Bald
and Golden Eagle Protection Act. One of North America’s largest predatory birds, the
golden eagle is more common in southern California than in northern California.
Ranging from sea level up to 11,500 feet, the golden eagle’s habitat typically consists
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The 2003 San Joaquin Kit Fox survey identified potentially suitable habitat, but no
kit foxes were observed. Site conditions have not changed significantly since the
2003 surveys. Therefore, the likelihood of San Joaquin kit fox to occur within the
project area is considered low.
Plant Species
A query of the California Native Plant Society (CNPS) lists 34 plant species that
occur within the project vicinity. Based on habitats within the project area during
the March 2012 survey by Cardno Entrix, the list was reduced to four species
including: Congdon’s tarplant Centromadia parryi ssp. congdonii), Palmate-bracted
Bird’s-beak (Chloropyron palmatum), Northern California Black Walnut (Juglans
hindsii), and Hairless popcorn-flower (Plagiobothrys glaber).
Congdon’s tarplant (Centromadia parryi ssp. congdonii)
The Congdon’s tarplant is listed as a Rare Plant Rank (RPR) 1B.2 by the CNPS.
Congdon’s tarplant is a prostrate to erect, yellow flowered annual herb in the
Sunflower Family (Asteraceae). It generally occurs in annual grasslands with poorly-
drained, somewhat alkaline, clay or sandy-loam soils, at elevations between sea
level and 230 meters (754 feet). It has historic occurrences in Alameda, Contra
Costa, Monterey, Santa Clara, Santa Cruz, San Luis Obispo and Solano Counties, but
is thought to be extirpated from Santa Cruz and Solano Counties (Tibor 2001 as
cited in Booz Allen Hamilton 2004). Congdon’s tarplant is described as severely
threatened by development (Tibor 2001 as cited in Booz Allen Hamilton 2004),
although it is evidently tolerant of mowing and some other physical disturbances
within the ruderal grasslands within the project area.
Jones & Stokes Associates, Inc. surveyed for nine of the potential special-status plant
species at Camp Parks in 1995 and 1997. Congdon’s tarplant populations were first
observed during the 1997 survey. Before its discovery at Camp Parks, this species
had not been recorded in the Amador Valley, which includes Camp Parks, for more
than 30 years. Subsequent surveys in August 1999 and July 2000 confirmed that
known populations occur in 107 acres in the Training and Cantonment Areas. In
addition, the potential habitat for this species covers more than 1,200 acres.
According to the CNDDB, over 10,000 plants were estimated for this area in 1997.
Additionally, a small patch of approximately 26 plants was identified in 2000 just
south of Camp Parks, across Dublin Boulevard in the vicinity of a BART facility. The
majority of the populations are found in highly disturbed or mowed areas (i.e., along
the edge of parking lots and abandoned roads) and along the edges of annual
grasslands at PRFTA. The soil in these locations is heavy alkaline clay in the Clear
Lake and Diablo series. As the CNDDB contains recorded occurrences of this species
within the project area and it was observed during the plant surveys, the likelihood
of Congdon’s tarplant to occur within the project area is considered moderatehigh.
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Palmate-bracted Bird’s-beak (Chloropyron palmatum).
Palmate-bracted bird’s-beak is known to occur in seven meta-populations with the
closest in the Springtown alkali sink in the Livermore Valley, approximately six
miles east of Project area. It was federally designated as endangered in 1986 (FR
51:23767 as cited in US Army 2006) and state designated as endangered in 1984
due to agricultural conversion; it is threatened by agriculture, urbanization,
vehicles, altered hydrology, grazing, and development.26 This species occurs on
saline-alkaline soils and is a component of alkali sink scrub vegetation (CDFW 1998
as cited in Booz Allen Hamilton 2004). During floristic surveys, this species was not
found within the project area. Therefore, the likelihood of Palmate-bracted Bird’s-
beak to occur within the project area is considered low.
Northern California Black Walnut (Juglans hindsii)
Northern California black walnut is designated RPR 1B.1, rare and endangered in
California and elsewhere, in the CNPS inventory. It is a deciduous tree in the Walnut
Family (Juglandaceae) that is approximately 50 to 80 feet tall with dark, narrowly
furrowed bark. Its male flowers are arranged in greenish-yellow catkins and its
small green female flowers are borne singly or in small clusters near the ends of the
new twigs. Its habitat is riparian scrub and woodland. Northern California walnut
grows in deep, alluvial soils associated with rivers and creeks, in riparian forest or
riparian woodland (Hickman 1993, CNPS 2001 – as cited in Booz Allen Hamilton
2004). The original range of Northern California black walnut appears to have been
limited to Contra Costa, Napa, Sacramento, Solano, and Yolo Counties. This species
was reported to occur along the Sacramento River prior to 1949, but is now
extirpated in Sacramento, Solano, and Yolo Counties (Smith 1949 in CNDDB 2001 as
cited in Booz Allen Hamilton 2004). Currently, only two native occurrences are
known: one stand in Napa County and one stand in Contra Costa County (Tibor
2001; CNDDB 2002; CNPS 2001 as cited in Booz Allen Hamilton 2004). Native
stands of Northern California black walnut are threatened by hybridization with
orchard trees, conversion to agriculture and development. Although specimens
have been observed within Camp Parks none have been observed within the project
area. Therefore, the likelihood of Northern California Black Walnut to occur within
the project area is considered low.
Hairless popcorn-flower (Plagiobothrys glaber)
This species is believed to have been extirpated in California. CNNDB occurrence is
from 2002, but identification is uncertain and has been disputed. All other
occurrences are from pre-1954. This species is an annual herb ascending to erect
with cauline leave that occurs in meadows and alkaline seeps, as well as coastal salt
marshes and swamps. During floristic surveys, this species was not found within the
project area. Therefore, hairless popcorn-flower has a low likelihood of occurrence.
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California Endangered Species Act
The California Endangered Species Act (CESA, Fish and Game Code of California,
Chapter 1.5, Sections 2050-2116) prohibits the take of any plant or animal listed or
proposed for listing as rare (plants only), threatened, or endangered. In accordance
with the California Endangered Species Act (CESA), the CDFG CDFW has jurisdiction
over state-listed species. The CDFG CDFW regulates activities that may result in
“take” of individuals listed under the Act (i.e., “hunt, pursue, catch, capture, or kill, or
attempt to hunt, pursue, catch, capture, or kill”). Habitat degradation or
modification is not expressly included in the definition of “take” under the Fish and
Game Code. The CDFGCDFW, however, has interpreted “take” to include the “killing
of a member of a species which is the proximate result of habitat modification.”
California Environmental Quality Act
The California Environmental Quality Act (CEQA) is a state law that requires state
and local agencies, such as the City, to document and consider the environmental
implications of their actions and to refrain from approving projects with significant
environmental effects if there are feasible alternatives or mitigation measures that
can substantially lessen or avoid those effects. CEQA requires the full disclosure of
the environmental effects of agency actions, such as approval of a general plan
update or the projects covered by that plan, on resources such as air quality, water
quality, cultural resources, and biological resources. The State Resources Agency
promulgated guidelines for implementing CEQA known as the State CEQA
Guidelines.
Section 15380(b) of the State CEQA Guidelines provides that a species not listed on
the federal or state lists of protected species may be considered rare if the species
can be shown to meet certain specified criteria. These criteria have been modeled
after the definitions in FESA and CESA and the section of the California Fish and
Game Code dealing with rare or endangered plants or animals. This section was
included in the guidelines primarily to deal with situations in which a public agency
is reviewing a project that may have a significant effect on a species that has not yet
been listed by either the USFWS or CDFG CDFW or species that are locally or
regionally rare.
The CDFG CDFW has produced three lists (amphibians and reptiles, birds, and
mammals) of “species of special concern” that serve as “watch lists.” Species on
these lists are of limited distribution or the extent of their habitats has been reduced
substantially, such that threat to their populations may be imminent. Thus, their
populations should be monitored. They may receive special attention during
environmental review as potential rare species, but do not have specific statutory
protection. All potentially rare or sensitive species, or habitats capable of
supporting rare species, are considered for environmental review per the CEQA
Guidelines Section 15380(b).
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The CNPS, a non-governmental conservation organization, has ranked plant species
of concern in California. Vascular plants included on these lists are ranked as
follows:
Rank 1A Plants considered extinct.
Rank 1B Plants rare, threatened, or endangered in California and elsewhere.
Rank 2 Plants rare, threatened, or endangered in California but more
common elsewhere.
Rank 3 Plants about which more information is needed - review list.
Rank 4 Plants of limited distribution-watch list.
These CNPS listings are further described by the following threat code extensions:
1. Seriously endangered in California
2. Fairly endangered in California
3. Not very endangered in California.
Although the CNPS is not a regulatory agency and plants in these ranks have no
formal regulatory protection, plants appearing in Rank 1B or Rank 2 are, in general,
considered to meet CEQA’s Section 15380 criteria, and adverse effects to these
species may be considered significant. Impacts on plants that are listed by the CNPS
as Rank 3 or 4 are also considered during CEQA review, although because these
species are typically not as rare as those in Rank 1B or 2, impacts on them are less
frequently considered significant.
California Department of Fish and Wildlife (CDFW) Code
The California Fish and Wildlife Game Code includes regulations governing the use
of, or impacts on, many of the state’s fish, wildlife, and sensitive habitats. The CDFW
exerts jurisdiction over the bed and banks of rivers, lakes, and streams according to
provisions of Sections 1601–1603 of the Fish and Game Code. The Fish and Game
Code requires a Streambed Alteration Agreement for the fill or removal of material
within the bed and banks of a watercourse or water body and for the removal of
riparian vegetation.
Certain sections of the Fish and Game Code describe regulations pertaining to
certain wildlife species. For example, Fish and Game Code Sections 3503, 2513, and
3800 (and other sections and subsections) protect native birds, including their nests
and eggs, from all forms of take. Disturbance that causes nest abandonment and/or
loss of reproductive effort is considered “take” by the CDFW. Raptors (i.e., eagles,
falcons, hawks, and owls) and their nests are specifically protected in California
under Fish and Game Code Section 3503.5. Section 3503.5 states that it is “unlawful
to take, possess, or destroy any birds in the order of Falconiformes or Strigiformes
(birds of prey) or to take, possess, or destroy the nest or eggs of any such bird
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Impacts and Mitigation Measures
Standards of Significance
A proposed project would result in a significant impact to biological resources if it
were to result in a:
Substantial effect, either directly or through habitat modifications, on any
candidate, sensitive, or special-status species;
Substantial effect on any riparian habitat or other sensitive natural
community;
Substantial effect on protected wetlands;
Substantial interference with the movement of any native resident or
migratory fish or wildlife species or with established native resident or
migratory wildlife corridors, or impede the use of native wildlife nursery
sites; or
Conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state
habitat conservation plan.
Jurisdictional Wetlands, Other Waters of the U.S. and Waters of the State
Impact 3.3-1: Based on a preliminary wetland delineation of the project area, the
proposed project could result in the fill of wetlands, which would
result in a potentially significant impact.
Based on the preliminary wetland delineation of the project area by Cardno Entrix,
approximately 0.09 24 acres of seasonal wetlands; 0.11 acres of wetland drainage
ditch; and 1.4 27 acres of other waters of the U.S. were mapped within the
boundaries of the project area. Additionally, 0.5 49 acres of drainage ditch, created
in uplands to drain uplands may be considered jurisdictional by the Regional Water
Quality Control Board (RWQCB). Based on the conceptual land use plan for the
proposed project, the ephemeral drainage canals would be partially avoided and a
small section (approximately 900 linear feet) will be re-routed due to construction.
All other wetlands within the project area would be permanently filled due to
construction activities. Since fill of wetlands and “other waters of the U.S.” are
prohibited under state and federal regulations described above, without first
obtaining permits and approvals from the federal and state agencies, fill of wetlands,
waters of the U.S., and waters of the State would result in a potentially significant
impact.
Mitigation Measure
MM 3.3-1 Prepare and Implement a Wetland Mitigation Plan. Prior to
commencing any activities that would impact wetlands or waters
habitat, the project applicant shall obtain all required public agency
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permits and shall prepare a wetland mitigation plan that ensures no-
net-loss of wetland and waters habitat and is approved by the City
andthat is approved by the applicable resource agencies and
submitted to the City. The wetland mitigation plan shall include
measures for avoidance, minimization, and compensation for wetland
impacts. Avoidance and minimization measures may include the
designation of buffers around wetland features to be avoided, or
project design measures, such as free-span bridges. Compensation
measures shall include the preservation and/or creation of wetland or
waters. The final mitigation ratios (the amount of wetlands and
waters created or preserved compared to the amount impacted) shall
be determined by the applicable resource agencies and the City. The
wetland mitigation and monitoring plan shall include the following:
Descriptions of the wetland types, and their expected functions
and values;
Performance standards and monitoring protocol to ensure the
success of the mitigation wetlands over a period to be determined
by the resource agencies;
Engineering plans showing the location, size and configuration of
wetlands to be created or restored;
An implementation schedule showing that construction or
preservation of mitigation areas shall commence prior to or
concurrently with the initiation of construction; and
A description of legal protection measures for the preserved
wetlands (i.e., dedication of fee title, conservation easement,
and/or an endowment held by an approved conservation
organization, government agency or mitigation bank).
Special-Status Plant Species
Impact 3.3-2: A query of the CNPS lists 34 plant species that occur within the project
vicinity. Based on habitats within the project area during the March
2012 survey by Cardno Entrix, the list was reduced to four special
status plant species that have the potential to be located within the
project area including: Congdon’s tarplant (Centromadia parryi ssp.
Congdonii), Palmate-bracted bird’s-beak (Cordylanthus palmatus),
Northern California Black Walnut (Juglans hindsii), and Hairless
popcorn-flower (Plagiobothrys glaber). Out of these four special
status plant species, the only special status plant species that has the
potential to be located within the project area is the Congdon’s
tarplant, which was documented as occurring within the project area
based on floristic surveys conducted between 1995 and 2000. The
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potential loss of Congdon’s tarplant within the project area would be
considered a potentially significant impact.
The majority of the Congdon’s tarplant populations within the project area are
found in highly disturbed or mowed areas (i.e., along the edge of parking lots and
abandoned roads) and along the edges of ruderal grasslands at Camp Parks.
Disturbance or removal of grassland and wetland habitat could potentially result in
the loss of this special status species, which would be considered a potentially
significant impact.
The following mitigation measures would reduce this potentially significant impact
to special status species to a less than significant level by identifying the presence
or absence of this plant species through a floristic survey for special-status plant
species and if any special-status plant species are found, avoiding, transplanting,
and monitoring plants that would be affected by the proposed project.
Mitigation Measures
MM 3.3-2a Conduct a Floristic Survey and Consult with CDFG CDFW and
USFWS if State or Federally ESA Listed Plants are Found and
Comply with Incidental Take Permits. The project applicant shall
retain a qualified botanist to conduct rare plant surveys within the
construction zone for Congdon’s tarplant or other state or federally
listed plant species with potential habitat within the project area
during the blooming period of those species for which suitable habitat
is present appropriate time of year in accordance with agency
protocols. These plant surveys shall be conducted in accordance with
the 2009 California Department of Fish and Game CDFW and United
States Fish and Wildlife ServiceUSFWS rare plant survey protocols.
Two or three separate surveys may be required to cover the blooming
periods of species where suitable habitat is present. The results of the
surveys shall be summarized in a report and submitted to CDFW and
USFWS, and would be valid for two years. If no special-status plants
are located during the surveys, no further mitigation measures would
be required. If any federal or state ESA plant species are found during
the rare plant surveys, the project applicant shall consult with the
CDFW and USFWS to obtain incidental take permits under Section
2081 of the CESA and either Section 7 or 10 of the FESA. Consultation
with USFWS under Section 7 of the FESA could occur as part of the
CWA Section 404 permit process as part of the wetland mitigation,
described under Mitigation Measure MM 3.3-1.
MM 3.3-2b Develop and Implement Mitigation in Consultation with CDFW if
Other Special Status Plant Species Are Found. If populations or
stands of Congdon’s tarplant or other special-status plant species
(excluding federal or state listed plants) are found during the rare
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plant surveys, the project applicant shall notify the CDFW. A
mitigation plan shall be developed in consultation with and approved
by the CDFW and the City prior to the commencement of any activities
that would impact any special status plants, such as the acquisition of
off-site mitigation areas presently supporting the species in question
or purchase of credits in a mitigation bank that is approved to sell
credits for the affected species. The location of mitigation sites shall
be determined in consultation with, and subject to approval of USFWS
and/or CDFW. Off-site compensatory mitigation shall be acquired at a
minimum acreage ratio of 1:1 (acquired: impacted). For either off-site
mitigation option, measures shall be implemented (including
contingency measures) providing for the long-term protection of the
species. The mitigation plan shall include measures such as
transplanting plants, collecting seed or clippings and replanting
species in an on-site location, if feasible or other location approved by
Department of Fish and Game.
Special Status Wildlife Species - Mammals
Impact 3.3-3: Several California burrowing owl pairs have been documented within
the project area, including during the winter and breeding season.
Due to the security fencing that surrounds Camp Parks, low human
use, and maintenance activities, the project area provides suitable
breeding, foraging and wintering habitat for the California burrowing
owl. Implementation of the proposed project could result in the
displacement of burrowing owls during construction activities, and
once completed, the proposed project could result in the removal of
suitable burrowing owl (breeding and wintering) habitat. Permanent
loss of occupied burrow(s) and habitat would be considered a
potentially significant impact.
The following mitigation measure would reduce impacts to the California burrowing
owl to a less than significant level by documenting information on burrowing owls
in the project area and by conducting a California burrowing owl survey and if any
burrowing owls are found, avoiding, or excluding the owls outside the breeding
season, and mitigating for the loss of habitat that would be affected by the proposed
project. Because California burrowing owls have been observed within the project
area, the following mitigation measures would reduce this potentially significant
impact to a less than significant level.
Mitigation Measures
MM 3.3-3a Conduct a Burrowing Owl Survey and Impact Assessment. The
project applicant shall retain a qualified biologist to conduct a
California burrowing owls take avoidance surveys 14 days prior to
ground disturbing activities and impact assessment following the
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2012 California Department of Fish and Game Staff Report on
Burrowing Owl Mitigation (CDFW 2012) or as updated at the time of
the implementation of the proposed project. If no owls are found
during this first survey, a final survey shall be conducted within 48-
hours prior to ground disturbance to confirm that burrowing owls are
still absent. If ground disturbing activities are delayed or suspended
for more than 14 days after the initial take avoidance survey, the
project area shall be resurveyed including the final survey within 48-
hours of disturbance. The report(s) shall be submitted to California
Department of Fish and Game CDFW as indicated in the CDFW 2012
Staff Report.
If it is determined that project activities may result in impacts to
nesting, occupied, and satellite burrows and/or burrowing owl
habitat, the project applicant shall consult with the CDFW. More
specifically, if the surveys identify breeding or wintering burrowing
owls on or adjacent to the project area, occupied burrows cannot be
disturbed and shall be provided with protective buffers. Where
avoidance is not feasible during the non-breeding season, a site
specific exclusion plan (i.e. a plan that considers the type and extent of
the proposed activity, the duration and timing of the activity, the
sensitivity and habituation of the owls, and the dissimilarity of the
proposed activity with background activities) shall be implemented to
encourage the owls to move away from the work area prior to
construction and to minimize the potential to affect the reproductive
success of the owls. The exclusion plan shall be subject to the CDFW
approval and monitoring requirements. Compensatory mitigation
could also be required by the CDFW as part of the approval of an
exclusion plan. Mitigation may include the permanent protection of
habitat at a nearby off-site location acceptable to the CDFW. and
develop a detailed mitigation plan such that the habitat acreage,
number of burrows, and burrowing owl impacted are replaced. The
mitigation plan shall be based on the requirements set forth in
Appendix A of the CDFW 2012 Staff Report on Burrowing Owl
Mitigation.
MM 3.3-3b Implement Avoidance Measures. If California
burrowing owl are located within the project area and direct impacts
can be avoided, the project applicant shall implement the following
avoidance measures during all phases of construction to reduce or
eliminate potential impacts to California burrowing owls.
Avoid disturbing occupied burrows during the nesting period,
from 1 February through 31 August.
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Avoid impacting burrows occupied during the non-breeding
season by migratory or non-migratory resident burrowing owls.
Avoid direct destruction of burrows through chaining
(dragging a heavy chain over an area to remove shrubs), disking,
cultivation, and urban, industrial, or agricultural development.
Develop and implement a worker awareness program to
increase the on-site worker’s recognition of and commitment to
burrowing owl protection.
Place visible markers near burrows to ensure that farm
equipment and other machinery does not collapse burrows.
Do not fumigate, use treated bait or other means of poisoning
nuisance animals in areas where burrowing owls are known or
suspected to occur (e.g., sites observed with nesting owls, designated
use areas).
Restrict the use of treated grain to poison mammals to the
months of January and February.
MM 3.3-3c Conduct Burrow Exclusion. In the event that California
burrowing owls are located within the project area, the project
applicant shall conduct a Burrowing Owl Relocation Plan. If avoidance
of burrowing owl or their burrows is not possible, the project
applicant in consultation with the California Department of Fish and
Wildlife shall prepare a Burrowing Owl Relocation Plan as indicated
and following the CDFW 2012 Staff Report. Monitoring of the
excluded owls shall be carried out as per the California Department of
Fish and Game 2012 Staff Report. Mitigation for permanent impacts to
nesting, occupied, and satellite burrow and/or burrowing owls shall
be developed based on the CDFW 2012 Staff Report on Burrowing
Owl Mitigation.
Special-Status Species - Amphibians and Reptiles
Impact 3.3-4: Habitat assessments or surveys for special-status amphibians and
reptiles were performed within the project area by the U.S. Army in
2006, including California Red Legged Frog and California Tiger
Salamander. Although no surveys specific for Western Pond Turtle
have been conducted, Western Pond Turtle was observed within the
project areagreater Camp Parks Training Area during surveys for
California Red Legged Frog. During the field surveys conducted by in
March 2012, the project area was not found to provide suitable
breeding habitat for these species. However, the proposed project
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includes re-alignment of the ephemeral drainage, which could result
in the potential “take” of Western Pond Turtle and/or California Red
Legged Frog if found within the project area. Therefore, this would be
considered a potentially significant impact.
During the 2012 field surveys conducted by Cardno Entrix, the ephemeral drainage
located within the project area did not contained deep pools that could provide
suitable breeding habitat for California Red Legged Frog. In addition, none of the
seasonal wetlands retain water long enough to provide suitable breeding habitat for
the California Tiger Salamander. Similarly, the ephemeral drainage does not provide
suitable habitat for the Western Pond Turtle since it dries during the summer
months and does not appear to provide suitable nesting or refuge habitat for this
species.
California Tiger Salamander
During installation wide surveys conducted at Camp Parks in 2005, California Tiger
Salamander breeding locations were identified within the Camp Parks Training
Area, however no breeding habitat was identified within the project area. The
project area is approximately 1.4 miles away from the nearest known breeding
location and approximately 0.90 miles south of an upland observation during the
2005 surveys.
Existing development (i.e. buildings, roads and parking areas) between the project
area and the Camp Parks Reserve Forces Training Area would likely hinder
dispersal and reduce the survival potential of dispersing California Tiger
Salamander (CTS). Potential of CTS occurring within the project area decreases with
distance from known breeding habitat, potential breeding habitat, and suitability of
habitat. Based on existing conditions and the lack of habitat, it is unlikely that CTS
would occur within the project area. Additionally, implementation of the proposed
project is not expected to result in habitat modification or degradation because
potential dispersal habitat within the project area lacks suitable aquatic
components, thus breeding, sheltering, and feeding of CTS would not be significantly
impaired. Therefore, implementation of the proposed project would have no impact
on this species and no mitigation is required.
Western Pond Turtle
Although a survey specific for Western Pond Turtle has not been conducted within
the project area or the Camp Parks Forces Training Area, WPT have been observed
within the installationwithin the greater Camp Parks Training Area during surveys
for CTS and CRLF by the U.S. Army in 2006. All of the observations have been made
within man-made ponds in the Training Area. No observations of WPT have been
made within the project area (US Army 2006). The habitat within the project area
does not provide suitable breeding or aestivating habitat for the WPT.
Implementation of the proposed project calls for the re-alignment of the ephemeral
drainage. It is expected that this realignment would occur during the dry season
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and thus it would be unlikely that a Western Pond Turtle would be present.
Nevertheless, re-alignment of the stream could result in the “take” of Western Pond
Turtle. This would be considered a potentially significant impact.
Implementation of the following mitigation measure would reduce impacts to
Western Pond Turtle to less than significant level by identifying the presence or
absence of WPT by conducting a pre-construction survey for Western Pond Turtle
and if any Western Pond Turtles are found, avoiding, excluding and/or relocating
the Western Pond Turtle to a more suitable habitat within the immediate vicinity of
the project area but away from the construction zone.
Mitigation Measure
MM 3.3-4a Conduct Pre-Construction Surveys for Western Pond Turtle (WPT)
Prior to Re-Alignment of the Ephemeral Drainage. The project
applicant shall retain a qualified biologist to conduct pre-construction
surveys for Western Pond Turtle no more than 30 days prior to work
in or adjacent to any habitat suitable for WPT within the project area.
If no Western Pond Turtles are found, no further mitigation is
required. If Western Pond Turtles are found, the consulting biologist
shall consult with the California Department of Fish and Game for
authorization to relocate the species to suitable habitat away from the
construction zone. The turtle shall be relocated to either a pond
within the Training Area (if authorization from the US Army is
granted) or downstream from the construction zone to similar or
better habitat.
California Red-Legged Frog
The Cantonment Area of - Camp Parks -–The project area was previously surveyed
in August 2003. The survey followed the measures prescribed in the USFWS
Guidance on Site Assessment and Field Surveys for California Red-Legged Frog
(Rana aurora draytonii). None of the six potential wetlands within the project area
were found to provide suitable habitat for the California Red Legged Frog based on a
habitat assessment prepared in 2003. Based on the surveys conducted by Cardno
Entrix in March 2012, conditions within the project area have not changed since
2003 and thus the habitat within these areas is primarily unchanged. However,
since the surveys were conducted in 2003, new focused field surveys may be
warranted.
The habitat within the project area does not provide breeding habitat for the CRLF,
and the nearest known CRLF breeding site is 1.32 miles north of the project area
within Camp Parks. Existing development (i.e. buildings, roads and parking areas)
between the project area and the Camp Parks Training Area likely hinders dispersal
and reduces the survival potential of dispersing CRLF. Nevertheless, there is a
possibility that CRLF could disperse within the project area and therefore could be
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-81
not be limited to, onsite and offsite preservation and creation
of CRLF habitat, purchase of credits at mitigation banks,
payment of in lieu fees approved by the agencies, or other
agency approved and required mitigation measures.
d. Avoidance measures may include the following or equivalent
protective measures:
To minimize disturbance of breeding and dispersing CRLF,
construction activity within CRLF upland habitat shall be
conducted during the dry season between April15 and
October 15 or before the onset of the rainy season,
whichever occurs first. If construction activities are
necessary in CRLF upland habitat between October 15 and
April 15, the project applicant would contact the USFWS for
approval to extend the work period.
To minimize disturbance and mortality of adult and
juvenile CRLF in aquatic habitat and underground burrows,
the project applicant could minimize the extent of ground-
disturbing activities within these habitats by requiring the
contractor to limit the work area to the minimum necessary
for construction. In addition, the project applicant could
ensure that the contractor would install temporary
exclusion fence between the construction work area and
potential aquatic habitat for all construction within
grasslands near aquatic habitat.
The project applicant could ensure that a qualified wildlife
biologist monitors all construction activities within CRLF
upland habitat. This would ensure no take of individual
CRLF occurs during project construction. If a CRLF is found,
then the monitor would immediately stop construction in
that area and contact USFWS for advice.
The project applicant shall could preserve additional
upland habitat within a USFWS approved conservation
area. The Project proponent shall coordinate or consultThis
measure shall be determined in consultation with the
USFWS, if required.
Vernal Pool Invertebrates
Impact 3.3-5: Protocol level surveys for vernal pool invertebrates were conducted
throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as
during the summer of 2012 (dry season) and 2013 (wet season) by
Dublin Crossing Specific Plan Final EIR
Biological Resources
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Cardno Entrix. No vernal pool fairy shrimp, vernal pool tadpole
shrimp or longhorn fairy shrimp were found during these surveyss.
California linderiella was found during the 2002 and 2003 surveys,
but not within the project area. The New surveys are currently being
conducted by Cardno Entrix have not been accepted by USFWS. Since
the new surveys have not been completed at this timeTherefore, the
presence of this species within the project area is assumed in the
analysis of project impacts.
Surveys for curve-footed Hygrotus beetle and San Francisco fork-
tailed damselfly were also conducted within Camp Parks in 2002 and
2003 and neither of these species were observed. Site conditions
have not changed significantly and these species are not expected to
occur. Potentially suitable habitat was observed within the survey
area for vernal pool invertebrates and these areas would be removed
during proposed construction activities. Removal of these wetlands
could result in the potential take of protected vernal pool
branchiopods and other protected invertebrates, if they were to occur,
and their habitat. This would be considered a potentially significant
impact.
Implementation of the following mitigation measures would reduce potential
impacts to vernal pool invertebrates to a less than significant level by preparing a
habitat assessment for vernal pool invertebrates. If the habitat assessment
concludes that vernal pool invertebrates could be located within the project area,
the project applicant could either conduct protocol-level surveys or assume
presence. If any federally-protected vernal pool invertebrates are found within the
project area or if the project applicant assumes presence, then the project applicant
shall ensure no net loss of habitat occurs and shall be achieve through avoidance,
reservation, creation and/or purchase of mitigation credits. Implementation of the
following mitigation measure would reduce this impact to a less than significant
level.
Mitigation Measure
MM 3.3-5 Consult with the USFWS and Reduce Impacts on Vernal Pool
Invertebrates and Their Habitat. The project applicant shall prepare
a habitat assessment for the vernal pool invertebrates. If vernal pool
invertebrates are found within the project area during the habitat
assessment, the project applicant shall comply with the following
steps to ensure protection of vernal pool invertebrates and their
habitat and that impacts are reduced to a less than significant level.
a. The project applicant shall retain a qualified biologist to
conduct habitat assessments for protected vernal pool
invertebrates and based on the results of the habitat
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-83
assessments, determine in consultation with the USFWS if
protocol-level vernal pool invertebrate surveys will be
required within the project area.
b. If suitable habitat is present, the project applicant, in
consultation with the USFWS and CDFW, shall either (1)
conduct a protocol-level survey for federally listed vernal pool
crustaceans, which will identify and other protected vernal
pool invertebrates (curve-footed Hygrotus beetle and San
Francisco fork-tailed damselfly), or (2) assume presence of
federally-listed vernal pool crustaceans and curve footed
Hygrotus beetle and San Francisco fork-tailed damselfly in
areas of suitable habitat. Surveys shall be conducted by
qualified biologists in accordance with the most recent USFWS
guidelines or protocols to determine the time of year and
survey methodology (survey timing for these species is
dependent on yearly rainfall patterns and seasonal
occurrences, and is determined on a case-by-case basis). The
USFWS protocol level surveys shall be conducted as part of the
Section 404 permit process within two years of the application.
If surveys reveal no occurrences of federally listed vernal pool
crustaceans or other protected vernal pool invertebrates, no
further mitigation would be required.
c. If surveys determine that one or more special-status vernal
pool invertebrate species occurs within the project area, or if
the project applicant, in consultation with the USFWS and/or
CDFW, assumes presence of federally-listed vernal pool
invertebrates in all affected habitats, the project applicant shall
provide information to the USACE to support Section 7
consultation with the USFWS and the project applicant shall
ensure no net loss of habitat shall be achieved through
avoidance, preservation, creation and/or purchase of credits as
a part of the Section 7 Consultation process. The selected
measures may be part of the permitting process.
d. Where feasible, all vernal pool invertebrate habitat shall be
avoided. If habitat that can be avoided during construction
activities is identified at a distance determined in consultation
with USFWS, a USFWS-approved biologist (monitor) shall
inspect any construction-related activities to ensure that no
unnecessary take of listed species or destruction of their
habitat occurs. The Project proponent will establish
monitoring and reporting protocols to reduce impacts to
vernal pool invertebrate species and habitat.
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-84
e. The project applicant shall ensure that an appropriate number
of acres, as approved by USFWS during consultation, are
preserved to mitigate for direct or indirect impacts on vernal
pool crustacean habitat.
f. Water quality in the avoided wetlands shall be protected using
erosion control techniques, such as silt fencing or straw
wattles during construction in the watershed.
Migrant Bird Treaty Act (MBTA) – Nesting Birds
Impact 3.3-6: A variety of special-status birds are expected to be located within the
project area. Some of these species are resident species and some are
migratory species that breed within the project area. The special-
status birds known to nest in the Livermore Valley area include the
Golden eagle, white-tailed kite, tricolored blackbird, northern harrier,
California horned, prairie falcon, Cooper’s hawk and loggerhead
shrike. Trees, fresh emergent wetland vegetation and grassland could
provide potentially suitable nesting habitat for these species, which
are protected under the Migrant Bird Treaty Act and the Fish and
Game Code. The proposed project would require grading and possible
removal of existing trees and vegetation. Therefore, implementation
of the proposed project could result in the loss of active nests, which
would be considered a potentially significant impact on special-
status bird species and birds protected under the MBTA.
The proposed project includes creation of an open space area along the ephemeral
drainage canal, which would provide potentially suitable nesting habitat for some of
these species following construction. However, implementation of the following
mitigation measure would reduce impacts to nesting birds to less than significant
level by requiring that pre-construction bird surveys are conducted and that the
project applicant avoid any nests if found.
Mitigation Measure
MM 3.3-6 Protect Birds Covered by the Migratory Bird Treaty Act (Including,
but not limited to White-Tailed Kite, golden eagle, Cooper’s hawk,
Loggerhead Shrike, and Other Special-Status Species). Project
contractors shall avoid construction activities during the bird nesting
season (February 1 through August 31). If Between March 1 and
September 15construction activities are conducted during the nesting
season, the project applicant shall have a qualified biologist conduct at
least three nest surveys of the project area to develop a baseline of
nesting activity on and adjacent to the project area. Depending on the
construction schedule, preconstruction surveys shall be initiated prior
to the planned construction activity to allow adequate time for
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-85
multiple site visits (e.g. for construction activities planned for mid-
May, the first survey shall be conducted no more than 14 days prior to
the start of work). no more than 30 days prior to any
demolition/construction or ground-disturbing activities that are
within 300 feet of potential nest trees for non-raptor species (i.e.
trees, cattails, or grassland) and 500 feet of potential nest trees for
raptor species or suitable nesting habitat (i.e., trees, cattails,
grassland). Where access to property adjacent to the construction
activities is prohibited by the owner/operator, the survey shall be
conducted using binoculars or spotting scope. A pre-construction
survey report shall be submitted to the California Department of Fish
and Game that includes, at a minimum: (1) a description of the
methodology including dates of field visits, the names of survey
personnel with resumes, and a list of references cited and persons
contacted; and (2) a map showing the location(s) of any bird nests
observed on the project area. If no active nests of Migratory Bird
Treaty Act covered species are identified, then no further mitigation is
required.
If active nests of protected bird species are identified in the focused
nest surveys, the project applicant will shall consult with the
appropriate regulatory agencies to identify project-level mitigation
requirements, based on the agencies’ standards and policies as then in
effect. Performance measures may include the following, based on
current agency standards and policies.
a. The project applicant, in consultation with California
Department of Fish and Game, would shall delay
construction in the vicinity of active nest sites during
the breeding season (February 1 through September
15August 31) while the nest is occupied with adults
and/or young. A qualified biologist would monitor any
occupied nest to determine when the nest is no longer
used. If the construction cannot be delayed, avoidance
measures would shall include the establishment of
protective buffer zones around the nests as follows: for
raptor nests, the size of the buffer zone shall be a
minimum 250 foot radius centered on the nest; for
other birds, the size of the buffer zone shall be a 50-foot
radius centered on the nest. In some cases, these buffers
may be increased or decreased depending on the bird
species and the level of disturbance that will occur near
the nest. Changes to the buffer should be made by the
project biologist in consultation with the CDFW.of a
non-disturbance buffer zone around the nest site. The
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-86
size of the buffer zone would be determined in
consultation with the CDFW and may vary depending
on the species, but will be a minimum of 250 feet. The
buffer zone would be delineated with highly visible
temporary construction fencing.
b. No intensive disturbance (e.g., heavy equipment
operation associated with construction, or use of
cranes) or other project-related activities that could
cause nest abandonment or forced fledging would be
initiated within the established buffer zone of an active
nest between February 1 and September 15August 31.
c. If construction activities are unavoidable within the
buffer zone, the project applicant shall retain a qualified
biologist to monitor the nest site to determine if
construction activities are disturbing the adult or young
birds.
d. If fully protected species (white-tailed kites, golden
eagles) are found to be nesting near the proposed
construction area, their nests would be completely
avoided until the birds fledge. Avoidance would include
the establishment of a non-disturbance buffer zone of
500 feet, or as determined in consultation with the
CDFW.
Special Status Bat Species
Impact 3.3-7: Removal of trees and/or buildings or structures from the project area
could impact roosting sites for pallid bat and Yuma myotis.
Disturbance of roosting sites during the maternity season (May 1st-
Oct1st) could result in a potentially significant impact.
No bat surveys have been conducted within the project area. However, trees and
existing old buildings or structures may represent potentially suitable roosting
habitat for a variety of regionally occurring bat species. The two bat species with a
likelihood of occurrence include the pallid bat and Yuma myotis. These species have
been documented as roosting approximately 2.06 miles southwest of the project
area. Removal of trees and/or buildings or structures from: the project area could
impact roosting sites for these species. These roosting sites can also be used as
maternity roosts. Disturbance of roosting sites during the maternity season (May
1st-Oct1st) could result in a potentially significant impact. Implementation of the
following measure would reduce the potentially significant impact on special-status
bats and their roost sites to less than significant level.
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-88
Preservation of Heritage Trees and Tree Preservation
Impact 3.3-8: Trees are located within the project area and a detailed tree survey
has not been conducted for the proposed project. Nevertheless, trees
within the project area could fall under the definition of heritage trees
per Section 5.60 of the City of Dublin Municipal Code. Removal of
protected trees, due to construction activities within the project area
would be considered a potentially significant impact.
If the proposed project were to remove and/or damage trees that are considered
heritage trees per Section 5.60 of the City of Dublin Municipal Code, this would be
considered a potentially significant impact. Implementation of the following
mitigation measure would reduce this impact to a less than significant level by
requiring that the project applicant survey all the trees within the project area and
identify those that shall be removed with implementation of the proposed project
Mitigation Measure
MM 3.3-8 Conduct Tree Survey and Replace Trees at Suitable Ratios. The
project applicant shall retain a certified arborist to survey all trees
located within the project area in order to identify and evaluate those
trees that shall be removed with implementation of the proposed
project. An arborist report shall be prepared consistent with the
certified arborist to survey trees within the project area and identify
and evaluate trees that shall be removed. The arborist report shall be
prepared and submitted to the City of Dublin to document the trees
that are to be removed. If any of the trees fall under the jurisdiction
Section 5.60 of the City’s Municipal Code, the project applicant shall
then mitigate impacts to trees based on the following or equivalent
protective measures depending on the size and health of trees to be
removed.
a. Prior to the start of construction, the project applicant shall install
exclusion fencing at the dripline of any tree that will not be
affected by the construction and prohibit any parking or storage of
construction materials or other materials inside the fence.
b. Mitigation, at an inch-by-inch ratio, shall be provided for native
trees larger than 24inches in circumference measured at four (4)
feet six (6) inches above natural grade.
Potential Conflicts with a Habitat Conservation Plan
There is no habitat conservation plan within Alameda County or the City of Dublin
that the proposed project would be able to participate in. The Eastern Alameda
Conservation Strategy (EACS) is still in the developing process and has not been
approved or adoptedwas released in December 2010 and the City of Dublin adopted
Dublin Crossing Specific Plan Final EIR
Biological Resources
Page 3-89
a resolution accepting the EACS as guidance for environmental permitting for public
projects affecting habitat and endangered species in Eastern Alameda County. The
City acknowledges the EACS as a guidance tool. Therefore the proposed project
would not have a conflict with the provisions of an adopted Habitat Conservation
Plan, Natural Community Conservation, or other approved local, regional, or state
habitat conservation plan. Therefore, the proposed project would have no impact.
Dublin Crossing Specific Plan Final EIR
Geology and Soils
Page 3-116
expose people or structures to potential substantial adverse effects, including the
risk of loss, injury, or death involving strong seismic ground shaking which would
reduce this potentially significant impact to a less than significant level.
Mitigation Measure
MM 3.5-3 Preparation of Design-Level Geotechnical Report. Future
development within the project area shall consult with a registered
geotechnical engineer to prepare a design level geotechnical report
that incorporates the recommendations in the preliminary
geotechnical investigation by Berlogar, Stevens and Associates (March
2012). The design level geotechnical report shall address site
preparation and grading (including measures to address potential
liquefaction and expansive soils), building foundations, CBC seismic
design parameters, and preliminary pavement sections. This report
shall be submitted in conjunction with Building Permit application(s)
and reviewed and approved by the City. The Report’s
recommendations shall be incorporated into the project design and
construction documents.
Liquefaction
Impact 3.5-4: Future development associated with the proposed project could
expose people or structures to potential substantial adverse effects of
liquefaction. This is considered a potentially significant impact.
Generally, when liquefaction occurs because of earthquakes, the conditions of
cohesionless surface material accompanied with relatively shallow water tables
underlying the area were the factor. In such cases, ground vibration increases the
pore pressure resulting in water moving upward whereby turning the sand or silt
into a quicksand like condition. The surface characteristics include the development
of sand boils, surface cracks, ground settlement and differential compaction.
Without proper soil engineering, foundation design, and construction, the project
area could expose people and/or structures to hazards associated with seismic-
related ground failure.
The project area is located within a CGS Seismic Hazard Zone where liquefaction
may occur during a strong earthquake. Based on the geotechnical investigation
there is the potential for liquefaction to occur within the occasional interbedded
layers of loose to medium dense sandy soils that exist below the groundwater table.
These potentially liquefiable layers generally range from approximately half a foot
to two feet thick and are overlain by at least ten feet of non-liquefiable cover. As
part of The results of the settlement calculations performed for the liquefaction
analysis, the results indicate that the potential liquefaction-induced settlement would
likely range from approximately half an inch to two inches. Differential settlement is
estimated to be on the order of one inch. Surface manifestation of liquefaction (e.g. sand
Dublin Crossing Specific Plan Final EIR
Geology and Soils
Page 3-117
boils, ground fissures) are is not anticipated due to the presence of at least ten feet of
non-liquefiable cover.
Future development within the project area would be required to comply with the
City’s Building Code, liquefaction regulations of the CBC, and the City’s standard
engineering practices and design criteria. In addition, Mitigation Measure MM 3.5-3
would require that the project applicant prepare a design-level geotechnical report,
which would address liquefaction and reduce this potentially significant impact to a
less than significant level.
Soil Erosion
Impact 3.3-5: Implementation of the proposed project may result in soil erosion or
the loss of topsoil during short-term construction activities within the
project area. This is considered a less than significant impact.
A portion of the project area is covered by roads, buildings, parking lots, and
sidewalks from the Camp Parks Reserve Forces Training Area. However, earth-
disturbing activities associated with future construction activities within the project
area have the potential to increase erosion if proper sedimentation and erosion
control methods are not in place. According to the Natural Resources Conservation
(NRCS) service, the Clear Lake soil is characterized as having slow to very slow
erosion potential and the Diablo Clay soils has a moderate erosion potential.
The City of Dublin Public Works Department Policy No. 95-11 requires that all plans
specify both long-term and short-term erosion control measures that will be
implemented during construction activities to control runoff, erosion, and sediment
movement prior to issuance of a building permit. In addition, in order to comply
with the National Pollution Discharge Elimination System (NPDES) permit process
for storm drainage and construction site discharge, projects involving construction
that are greater than one acre in size within the project area is required to prepare
and implement a Storm Water Pollution Prevention Plan (SWPPP) which would be
submitted for review by the City of Dublin Public Works Department during the
Grading/Site Work and Building Permit process, The SWPP describes the
stormwater BMPs (structural and operational measures) that would control the
quality (and quantity) of stormwater runoff. In addition, the NPDES permit requires
implementation of non-point source control of runoff through the application of a
number of Best Management Practices (BMPs). These BMPs are meant to reduce
the amount of constituents, including eroded sediment, that enter streams and other
water bodies. Examples of BMPs typically used in the City of Dublin include
vegetated swales in parking areas.
Compliance with the City of Dublin Public Works Department Policy No. 95-11: the
NPDES permit process; and the City’s Building Code requirements the proposed
project would result in a less than significant impact from erosion during
construction activities.
Dublin Crossing Specific Plan Final EIR
Hazards and Hazardous Materials
Page 3-138
Livermore Municipal Airport Master Plan, the project area is not located within the
airport influence area and is not located within an unacceptable noise contour.
North of the project area, is a heliport, which is used infrequently at
approximately18 days a year.
Wildland Fire Hazards
Due to the urban nature of the project area, the proposed project is not located
within an area that would be subject to the requirements of the City’s Wildfire
Management Plan (City of Dublin 2002).
Project Setting
The project area was historically used as grazing land prior to the installation of
Camp Parks in the 1940s. The project area contains former and/or existing supply
buildings and warehouses, infrastructure maintenance facilities, vehicle repair
facilities, fueling points, hazardous waste accumulation sites, office and
administration buildings, a buried construction debris deposition area, several
railroad spurs, former lumber yards, and soil stockpiles. The majority of the existing
buildings are located within the western portion of the project area on
approximately 77 acres. Approximately 112 acres in the eastern portion of the
project area is generally undeveloped.
There are approximately 16 existing buildings/structures warehouses that are
interspersed amongst fields of non-native grasslands where other buildings once
stood. Most of the buildings/warehouses were constructed as World War II
temporary buildings and consist of rectangular structures that are primarily
comprised of horizontal wood siding and a flat built-up roof.
Hazardous Materials
A total of 41areas with environmental conditions of concern were identified at the
project area. Environmental remediation activities been conducted at the 38 of the
41 areas and have received or are in the process of receiving a no further action
(NFA)/case closure from the regulatory agencies. The following sites, which may
require additional remedial action in order to obtain a NFA status include:
Former Building 109/ Parks Reserve Forces Training Area (PRFTA) 2 - Former
Building 109/PRFTA 2 located at the southwestern portion of the project
area containing contained concentrations of dioxin and lead within the
surficial soil above the acceptable risk-based screening levels for closure.
The contamination was remediated by the U.S. Army and cleaned to
industrial standards. There are currently groundwater monitoring wells at
this site and the U.S. Army has completed three quarters of sampling in
coordination with the Department of Toxic Substances and Control (DTSC).
The U.S. Army is awaiting confirmation from the regulatory agencies
regarding the remediation of this site (Personal Communication with Mark
Dublin Crossing Specific Plan Final EIR
Hazards and Hazardous Materials
Page 3-139
Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013and
September 17, 2013).
Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of
the project area and requires land use controls by the San Francisco
CRWQCB to obtain an NFA status. The San Francisco CRWQCB issued a Pre-
NFA determination on May 28, 2008. This determination acknowledged that
groundwater cleanup objectives have been met. However, a deed restriction
(land use control) is required to achieve a full NFA designation due to the
presence of soil which contains diesel concentrations greater than acceptable
levels. The Department of Toxic Substances Control (DTSC) concurred with
these findings in January 20, 2012.
Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern
portion of the potential construction debris dump sites consists of large
mounds of soil and debris north of Dublin Boulevard and east of the
installation entrance road. Construction and demolition debris, asbestos
containing material (ACM), waste asphalt, drill cuttings, and grass clippings
were observed in the mounds during site visits conducted from 1990
through 2002. DTSC stated that the area may need further investigation
prior to receiving an NFA. Soil samples revealed that there were high
hydrocarbons in the soil. The soil has been removed and re-sampled with
negative results and have been subsequently submitted to DTSC for review
(Personal Communication with Mark Hall, Environmental Coordinator, U.S.
Army, Camp Parks on May 21, 2013).
Asbestos containing materials (ACM) and Lead Based Paints (LBPs) in existing
structures - Asbestos is a strong, incombustible, and corrosion resistant
material, which was used in many commercial products between the 1940s
and the early 1970s. If inhaled, asbestos fibers can result in serious health
problems. Asbestos Containing Materials (ACMs) are building materials
containing more than one percent asbestos (some state and regional
regulators impose a one-tenth of one percent (0.1 percent) threshold).
Until 1978, when the U.S. Consumer Product Safety Commission (CPSC)
phased out the sale and distribution of residential paint containing lead,
many homes were treated with paint containing some amount of lead. It is
estimated that over 80 percent of all housing built prior to 1978 contains
some Lead-Based Paints (LBP). The mere presence of lead in paint may not
constitute a material to be considered hazardous. In fact, if in good condition
(no flaking or peeling), most intact LBP is not considered to be a hazardous
material. LBPs can create a potential health hazard for building occupants,
especially children when in poor condition. ACMs and LBPs are associated
the structures located within the project area that were constructed more
than 40 years ago.
Dublin Crossing Specific Plan Final EIR
Hazards and Hazardous Materials
Page 3-146
Result in the Disturbance of Contaminated Soil or Groundwater
Impact 3.7-4: The project area is not located on a hazardous material site pursuant
to Government Code Section 65962.5. However, based on the Phase I
ESA there are three sites currently being evaluated by the U.S. Army.
Hazardous materials may be encountered during construction. This
would be considered a potentially significant impact.
There are approximately three sites where remedial action activities are still
required to attain a commercial/industrial NFA status, which is the standard used
by the U.S. Army. These sites include: Building 109/PRFTA 2; Area 761/PRFTA 13;
and the eastern portion of the potential construction debris dump sites (ECP 36, 37,
and 39) as described below.
Former Building 109/PRFTA - Former Building 109/PRFTA 2 located at the
southwestern portion of the project area containing contained
concentrations of dioxin and lead within the surficial soil above the
acceptable risk-based screening levels for closure. The contamination was
remediated by the U.S. Army and cleaned to industrial standards. There are
currently groundwater monitoring wells at this site and the U.S. Army has
completed three quarters of sampling in coordination with the Department
of Toxic Substances and Control (DTSC). The U.S. Army is awaiting
confirmation from the regulatory agencies regarding the remediation of this
site (Personal Communication with Mark Hall, Environmental Coordinator,
U.S. Army, Camp Parks on May 21, 2013 and September 17, 2013).
Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of
the project area and requires land use controls by the San Francisco
CRWQCB to obtain an NFA status. The San Francisco CRWQCB issued a Pre-
NFA determination on May 28, 2008. This determination acknowledged that
groundwater cleanup objectives have been met. However, a deed restriction
(land use control) is required to achieve a full NFA designation due to the
presence of soil which contains diesel concentrations greater than acceptable
levels. The Department of Toxic Substances Control (DTSC) concurred with
these findings in January 20, 2012.
Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern
portion of the potential construction debris dump sites consists of large
mounds of soil and debris north of Dublin Boulevard and east of the
installation entrance road. Construction and demolition debris, asbestos
containing material (ACM), waste asphalt, drill cuttings, and grass clippings
were observed in the mounds during site visits conducted from 1990
through 2002. DTSC stated that the area may need further investigation
prior to receiving an NFA. Soil samples revealed that there were high
hydrocarbons in the soil. The soil has been removed and re-sampled with
negative results and have been subsequently submitted to DTSC for review
Dublin Crossing Specific Plan Final EIR
Hazards and Hazardous Materials
Page 3-147
(Personal Communication with Mark Hall, Environmental Coordinator, U.S.
Army, Camp Parks on May 21, 2013).
In addition, a property located up-gradient of the project area has affected the
underlying groundwater with petroleum hydrocarbons. However, based on the
distance of this site from the project area, it is unlikely that the property could have
affected the project area.
The U.S. Army and NASA are responsible for environmental remediation of existing
hazardous materials within the project area and have agreed to remediate the
project area to state and federal requirements (Personal Communication with Mark
Hall, Environmental Coordinator, U.S. Army Camp Parks on June 17, 2013).
Contamination that remains after the U.S. Army or NASA transfers the property to
the project applicant and/or that needs to be remediated to a higher standard (e.g.
residential) will either be remediated by the project applicant or by the U.S. Army or
NASA, prior to and during site grading and demolition activities with future
development activities.
Construction activities would be restricted within these portions of the project area
until an NFA status has been achieved. If contamination is discovered during
construction activities in the vicinity of these sites, this would be considered a
potentially significant impact. The following mitigation measure would reduce this
impact to a less than significant level.
Mitigation Measure
MM 3.7-4 Remediation of Hazardous Materials. Future development within
the vicinity of Former Building 109/PRFTA, Area 761/PRFTA 13, and
the Potential Construction Debris Dump Sites shall not proceed until a
NFA status is granted and the project area has been cleaned to the
appropriate land use standard to the satisfaction of Department of
Toxic Substances and Control (DTSC). The NFA status paperwork shall
be submitted to the City in conjunction with the Building and
Grading/Site work permit and shall be found acceptable by the City
prior to ground disturbance.
Implementation of mitigation measure MM 3.7-4 would reduce potential impacts
associated with contaminated soils within the project area to a less than significant
level.
Emit Hazardous Materials in the Vicinity of a School
Impact 3.7-5: There are no schools located within a quarter mile of the project area.
However, the proposed project includes construction of an 11 12 net
usable acre school site that would be located adjacent to proposed
residential uses. In addition, commercial businesses proposed within
the project area would be required to comply with federal, state and
Dublin Crossing Specific Plan Final EIR
Hazards and Hazardous Materials
Page 3-148
local regulations regarding hazardous substances. Therefore, the
proposed project would result in a less than significant impact to
the school proposed within the project area.
There are no schools located within a quarter mile of the project area. However, the
proposed project includes a 12 net usable acre school site and the project area is
located within two miles of several existing schools: Dublin High School (8151
Village Parkway, Dublin), Valley High School and Wells Middle School (6800 Penn
Drive, Dublin), Fallon Middle School (3601 Kohnen Way, Dublin), Murray
Elementary School (8435 Davona Drive, Dublin), Green Elementary School (3300
Antone Way, Dublin) Dougherty Elementary School (5301 Hibernia Drive, Dublin)
and Frederikson Elementary School (7243 Tamarack Drive, Dublin).
New businesses that locate near residential areas or within a quarter mile from a
school may expose these sensitive land uses to greater risk of exposure to
hazardous materials, wastes, or emissions. While the risk of exposure to hazardous
materials cannot be eliminated, measures can be implemented to maintain risk to
acceptable levels. As noted in the project description, future new development will
include residential, commercial, office and retail uses, as well as a community park.
Hazardous materials would be typical for these types of uses with no high-risk
materials such as those that are expected with industrial uses. Under these
circumstances, required compliance with regulations established by federal, State
and local regulatory agencies is considered adequate to avoid the negative effects
related to the use, storage, emission and the transport of hazardous materials at
future development/redevelopment sites within the project area. In addition, the
proposed school site would be surrounded by proposed residential uses and
therefore would not be in the vicinity of future commercial uses proposed within
the project area. Therefore, the proposed project would have a less than
significant impact on the proposed elementary school and schools in the vicinity of
the project area with compliance of applicable federal, State, and local regulations.
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-150
In developed portions of the City of Dublin, storm drainage is conveyed in
underground pipes, channels, and to a lesser extent, swales. New development is
required to install adequately-sized storm drains, connected to the City’s system, to
accommodate increased runoff volumes. Stormwater drainage is managed by the
City of Dublin Public Works Department and all runoff in the vicinity is directed to
regional storm drain facilities owned and maintained by Zone 7 of the Alameda
County Flood Control and Water Conservation District (Zone 7).
Flooding
As shown in Figure 3.8-1: Hydrologic Features, a portion of the project site area is
located within Zone X and Zone AE floodplains as mapped on the Flood Insurance
Rate Maps prepared by FEMA (Panel 309). Zone X is defined as “areas of 0.2 percent
annual chance flood; areas of 1 percent annual chance flood with average depths of
less than one foot or within drainage areas less than one square mile; and areas
protected by levees from one percent annual flood.” The areas adjacent to the
Chabot Channel are mapped by FEMA as Zone AE, which are designated as special
flood hazard areas subject to inundation by the one percent annual flood with Base
Flood Elevations determined as shown in the Flood Insurance Rate Map, Plate 5.
Reservoirs/Dams
There are 29 reservoirs/dams in Alameda County. The following reservoirs are
located within 12 miles of the proposed project:
Don Castro Reservoir is located approximately 9 miles to the east of the
proposed project in Hayward. It is maintained by the Alameda County Flood
Control and Water Conservation District for flood control, and by the East
Bay Regional Park District as a recreational facility.
Lake Chabot Reservoir is located approximately nine miles west of the
project area. It was completed in 1875 by damming San Lorenzo creek and
served as the primary water source for the East Bay Area.
The Upper San Leandro Reservoir is located approximately 13 miles
northwest of the project area. It was built by the East Bay Water Company in
1926 and is maintained by the East Bay Municipal Utility District.
The San Antonio Reservoir is located approximately 13 miles south-
southeast of the project area. Built in 1964 by the City and County of San
Francisco, it is managed by the San Francisco Public Utilities Commission
(SFPUC). The reservoir captures local rain and runoff from the Alameda
Watershed and contributes surface water supplies to the SFPUC Water
System.
Lake de Valle is located approximately 14 miles southeast of the project area.
De Valle Dam and Lake de Valle were built in 1968 as part of the State Water
Project. It provides storage for the South Bay Aqueduct and flood control for
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-153
export of concentrated minerals or salts from the Main Basin and the delivery of
treated water with reduced TDS and hardness levels to Zone 7’s customers.
Water Quality
The quality of surface and groundwater at the proposed project area is affected by
land uses within the entire watershed. Drainage from the project area affects the
quality of water in larger creeks and drainages downstream, including Arroyo de la
Laguna, Alameda Creek, and San Francisco Bay. Water quality in surface and
groundwater bodies is regulated primarily by the State and Regional Water Quality
Control Boards (discussed below).
Project Site Setting
Watershed Characteristics
As shown in Figure 3.8-2: Existing Drainage, the Camp Park’s entire 1,800+ acrea
majority of the Camp Parks watershed drains through the project area. The
majority of the runoff from this watershed is conveyed through natural and man-
made swales. These swales cross the project area and are intercepted along the
north side of Dublin Boulevard and conveyed to various existing Zone 7 drainage
facilities. The largest portion of the watershed is located north of Camp Parks and
drains south within the main channel, concentrating near the intersection of the
proposed Scarlett Drive extension and Dublin Boulevard in Line G-1, which is
currently a mapped FEMA 100-year floodplain.
The smaller portion of the upstream watershed to the northeast of Camp Parks
collects runoff in an existing concrete trapezoidal channel (G-5) and conveys it to
the intersection of Arnold Road and Broder Boulevard. Just north of this
intersection, there is a headwall with two to 48-inch pipes. These pipes currently
“split” the channel flow, diverting a portion towards Camp Parks and Line G-1. The
remaining flow is conveyed south under the Arnold Drive/Broder Boulevard
intersection, through a small basin between Gleaeson Drive and Broader Boulevard
and into an open channel along the west side of Arnold Drive. Per Zone 7, the
maximum flow of 950 cubic feet per second (cfs) at Line G-1 assumes that this
splitter has been removed. Based on the offsite detention basin proposed in the
“Hydrologic and Hydraulic Analysis for the Proposed Camp Parks Detention Basin
Study” (RJA 2013), the splitter will remain in place.
A second flow splitter was installed at the Arnold Road open channel, near Central
Parkway dividing flow between Drainages G-5 and G-2. A seven foot and four foot
box culvert down Arnold Road to Line G-2, while a trapezoidal channel conveys
runoff into the project area to Line G-5. Per the Santa Rita Drainage Master Plan, a
maximum of 350 cfs can be “split” and directed to Line G-5.
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-154
Underground Drainage Facilities
Underground drainage facilities include the Line G-1 channel that runs along the
west side of Hutchins Avenue and across the project area towards the future Scarlett
Avenue extension at Dublin Boulevard. A 48-inch corrugated metal pipe (CMP)
intercepting an existing open channel is located just north of the 8th Street and west
of Davis Avenue. The pipe assumed to flow south to 5th Street (RJA 2013).
An approximately 30-inch re-enforced concrete pipe (RCP) exiting a curb inlet at the
northwest corner of 5th Street and Davis Avenue connects to another inlet just to the
west on 5th Street. This inlet is assumed to intercept the northerly 48-inch CMP.
The outlet pipe from this inlet flow flows in a southeasterly direction.
A box culvert discharging to Line G-1 is located in the middle of the project site. A
surface investigation of the project by RJA engineers found that the size of the box
culvert was indeterminable due to the amount of silt and vegetation at the outfall to
the channel. It was assumed that this is the discharge point for the above mentioned
drainage facilities (RJA 2013).
Regulatory Setting
Federal
Clean Water Act
The principal law governing pollution of the nation’s surface waters is the Federal
Water Pollution Control Act (Clean Water Act [CWA]). Originally enacted in 1948, it
was amended in 1972 and has remained substantially the same since. The CWA
consists of two major parts: provisions that authorize federal financial assistance for
municipal sewage treatment plant construction and regulatory requirements that
apply to industrial and municipal dischargers. The CWA authorizes the
establishment of effluent standards on an industry basis. The CWA also requires
states to adopt water quality standards that “consist of the designated uses of the
navigable waters involved and the water quality criteria for such waters based upon
such uses”.
National Pollutant Discharge Elimination System
To achieve its objectives, the CWA is based on the concept that all discharges into
the nation’s waters are unlawful, unless specifically authorized by a permit. The
NPDES is the permitting program for discharge of pollutants into surface waters of
the United States under Section 402 of the CWA. Thus, industrial and municipal
dischargers (point source discharges) must obtain NPDES permits from the
appropriate RWQCB (i.e., the Central Valley region). The existing NPDES (Phase I)
stormwater program requires municipalities serving more than 1,000,000 persons
to obtain a NPDES stormwater permit for any construction project larger than five
acres. Proposed NPDES stormwater regulations (Phase II) expand this existing
national program to smaller municipalities with populations of 10,000 persons or
more and construction sites that disturb more than one acre. For other dischargers,
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-159
Alameda Countywide Clean Water Program
The City of Dublin is a co-permittee of the Alameda Countywide Clean Water
Program which was started in 1991. This local government and community
Program educates the public on how to keep businesses and homes from
contributing to stormwater pollution, and also coordinates its activities with other
pollution prevention programs, such as wastewater treatment plants, hazardous
waste disposal, and water recycling.
3.8.3 Relevant Project Characteristics
Water Demand
According to the Water Supply Assessment prepared by DSRSD, the proposed
project would require additional water demand for residential and commercial uses.
Water demand for the proposed uses would be approximately 371 acre feet per year
for the proposed project with the proposed elementary school and 365 acre feet per
year without the elementary school. Recycled water demand for the proposed
project would be 144 acre feet per year for the proposed project with the
elementary school and 131 acre feet per year without the elementary school (West
Yost Associates 2013).
Surface Water Management
Surface water management consists of both on-site runoff and the management of
off-site runoff extending through or around the site.
On-site Surface Water Runoff
As shown in Figure 3.8-3: Proposed DrainageProposed Q100 Project Flows, surface
waters within the project area would be divided into four drainage sheds. Drainage
sheds A9-A (63.3 acres) and A9-B (81.7 acres) would ultimately flow into the Line G-
1 drainage channel. Two underground detention basins, located within the
proposed community park, would be constructed. Preliminary estimates by Ruggeri
Jensen Azar (RJA) call for the construction of two underground basins (RJA 2013).
Park Basin #1, which captures drainage from A9-B, would have a storage capacity of
3.3 acre feet and an outflow rate of 80 cfs. Park Basin #2, which captures drainage
from A9-A, would have a storage capacity of 1.6 acre feet and an outflow of 71 cfs.7
Based on project plans, drainage from both of these underground basins would be
conveyed via an underground pipe to the proposed Chabot Creek riparian channel
that would be realigned through the proposed community park.
7 This analysis assumed two open-air basins and that the bottom 2 ½ feet of each basin was inundated with runoff from the
previous storm event. Given the fact that these two basins are now proposed to be underground, the ultimate storage
capacities would be determined as part of detailed engineering design. However, the basins would be designed so that there is
sufficient capacity to ensure that runoff capacities to not exceed pre-condition flow conditions.
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-160
Drainage sheds XX-1 (23.1 acres) and XX-2 (20.9 acres), which are located in the
southeast corner of the site, would ultimately flow into the Line G-5 drainage
channel. Two underground detention basins consisting of 96 inch diameter storm
drain pipes would be constructed along the proposed Central Parkway, or other
suitable public roadway. Basin 3-1 would be capable of storing 1.6 acre feet and
Basin 3-2 would be capable of storing 1.7 acre feet.
Off-site Surface Water Runoff Management
There are two main sources of existing offsite runoff that would have to be
conveyed around or through the proposed project to accommodate development.
The first off-site flow is a portion of the main 1,800 acre watershed located north of
the project area. The majority of this flow currently drains from the north to via the
existing Line G-1 channel, discharging at the intersection of proposed Scarlett Drive
extension and Dublin Boulevard. Based on discussions with the City and the project
applicant, a new offsite detention basin will be constructed on currently Army-
owned property, north of the project site. This new off-site basin will be designed to
reduce Q100 (storm event that occurs every 100 years) runoff flows from currently
924 cfs to 604 cfs.
Water flowing out from this new off-site basin would then flow into the 1.7 acre
Chabot Creek riparian channel through the proposed community park. Preliminary
plans call for this drainage channel to be constructed with a four and a half foot wide
channel base, 3:1 side slopes and an “n” value (water flow velocity rate, or
Manning’s coefficient) of 0.050.
The second offsite flow is from the area east and north of Arnold Road. This
includes the watershed north of Broder Boulevard, and the separate developed area
east of Arnold Drive. Improvements would include undergrounding the existing
open channel along Arnold Drive via a new double 4 foot by 8 foot re-enforced
concrete box culvert. The existing second flow “splitter” near the proposed Central
Parkway would be removed and a new “splitter” structure would be new
underground flows south on Arnold Road and the required flow split between Lines
G-2 and G-5. A new dual 60 inch re-enforced concrete pipe would be constructed
along Central Parkway, or other suitable public roadway, intercepting Basin’s 3 -1
and 3-2, and ultimately flowing into Line G-5 south of Dublin Boulevard.
Hydromodification and Water Quality Management
Hydromodification (stormwater management) for the proposed project as a whole
would be addressed the construction of the four basins, described above. These
facilities would be constructed prior to, or in concert with any “upstream” site
development.
Backbone roadway infrastructure would be constructed in phases consistent with
the development of adjacent parcels. Each portion of the roadway will incorporate
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-161
roadside bioretention area to treat stormwater runoff from the roadways (see
Figure 2-11: Conceptual Stormwater Drainage and Detention System, above, and
roadway cross-sections in the Draft Dublin Crossing Specific Plan). These
bioretention areas will be connected to the roadway stormwater systems which
would then discharge into one of the four basins.
In accordance with the Alameda County Clear Water Program, low impact design
(LID) site design measures for water quality protection will be implemented as
individual parcels are developed, to adequately address the impacts of their
proposed development and to show compliance with the post-construction, long-
term requirements of Provision C.3. Water quality features include bioretention
areas, flow-through planters, tree well filters, median filters and “treatment trains.”
Trash capture facilities would also be incorporated into the system. These on-site
facilities would be connected to the stormwater drain system in the backbone
roadways.
Stormwater Pollution Previsions Prevention Plans (SWPPPs) would also be
prepared, as a separate document, to control short-term construction-related
discharge pollutants as required by the NPDES General Permit for Storm Water
Discharges Associated with Construction and Land Disturbance Activities. the CA
State Water Resources Control Board Order No. 99-08-DWQ, .
Impacts and Mitigation Measures
Criteria for Determining Significance
In accordance with the CEQA, State CEQA Guidelines, and agency and professional
standards, a project impact would be considered significant if the project would:
Violate any water quality standards or waste discharge requirements;
Substantially deplete groundwater supplies or interfere substantially with
groundwater recharge such that there would be a net deficit in aquifer
volume or a lowering of the local groundwater table level (e.g., the
production rate of pre-existing nearby wells would drop to a level which
would not support existing land uses or planned uses for which permits have
been granted;
Substantially alter the existing drainage pattern of the site or area, including
the alteration of the course of a stream or river, in a manner which would
result in substantial erosion or siltation on- or off-site;
Substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river, or substantially
increase the rate or amount of surface runoff in a manner which would result
in flooding on- or off-site;
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-168
Additionally, drainage from the proposed Park Basin #2 (the northerly basin) is
shown by RJA to discharge directly into the proposed 1.7 acre Chabot Creek riparian
channel, which would be realigned and extend through the proposed community
park. At this point, it is unclear what entity will own the Chabot Creek riparian
channel, and what measures will be put in place to ensure it is adequately managed
and maintained. This could result in a potential significant environmental impact
with the long-term viability of the stormwater management system as is currently
proposed.
Implementation of the following mitigation measures will reduce these impacts to
less than significant.
Mitigation Measure
MM 3.8-4a Construction of a new Off-site Detention Basin North of the Project
Site. Prior to the issuance of grading permits for Phase 2 of the
proposed project, the project applicant shall work in coordination
with the U. S. Army (Camp Parks) to design and construct a new off-
site detention basin designed to ensure that flow rates to Line G-1 do
not exceed the maximum Q100 discharge flow rate of 950 cfs as
required by Zone 7. The design plans for this new off-site detention
basin will be reviewed by the City, in coordination with Zone 7, for
verification of compliance with all applicable regulations and
consistency with on-site drainage requirements, prior to construction.
MM 3.8-4b Re-align Stormwater Outflow from Proposed North Basin #2. Prior
to issuance of the first grading/sitework permit associated with the
construction of the proposed community park, the project applicant
shall submit to the City for review and approval, plans, details, and
calculations for the proposed underground stormwater detention
structure(s) and associated storm drain system within the park parcel
to ensure that adequate capacity will be provided; that the resultant
discharge flow rates meet the requirements of the Regional Water
Quality Control Board; and that the placement of the underground
facilities in the park will not impact the park design and construction
of recreational facilities. The location and layout of the underground
detention structures and the connection of these facilities to the
proposed Chabot Creek riparian channel, box culvert or downstream
facilities shall be agreed upon by both the project applicant and the
City. The method and location of stormwater discharge of the
underground facilities shall be reviewed and approved by all
appropriate regulatory and/or permitting agencies. a revised
stormwater drainage plan that realigns the stormwater outflow
associated with the proposed North Basin #2 from the 1.7 acre Chabot
Creek riparian channel (as is currently proposed) to a separate
underground pipe that connects directly with the existing box culvert
Dublin Crossing Specific Plan Final EIR
Hydrology and Water Quality
Page 3-169
located at proposed Scarlett Court Extension and Dublin Boulevard,
and thereby avoids stormwater discharge into the 1.7 acre Chabot
Creek riparian channel.
Flooding Exposure / Risk, Including the Failure of a Levee or Dam
Impact 3.8-5: The proposed project would not expose people or structures to a
significant risk of loss, injury, or death involving flooding, including
flooding as a result of the failure of a levee or dam. Structures and
personnel would not be subject to greater risk with implementation of
the proposed project as compared to existing conditions. This is
considered a less than significant impact.
According to the Association of Bay Area Governments (ABAG) Dam Failure
Inundation Maps, a very small portion of the southwestern portion of the project
area is located within the limits of potential inundation zone from a catastrophic
failure of the dam at Lake del Valle, which is located approximately 10.5 miles
southeast of the project area (ABAG 2013). However, the State Division of Safety of
Dams under the authority of the Department of Water Resources inspects this and
other dams under its jurisdiction on an annual basis to confirm if each dam is safe,
performing as intended and is not developing problems. Roughly a third of these
inspections each year include in-depth instrumentation reviews of the dam
surveillance network data.
The Division also periodically reviews the stability of dams and their major
appurtenances in light of improved design approaches and requirements, as well as
new findings regarding earthquake hazards and hydrologic estimates in California.
Based on the continued dam-safety compliance inspection conducted by the
Division of Safety of Dams, the risk of flooding from catastrophic dam failure is
considered low.
Therefore, this would be considered a less than significant impact, and no
mitigation is required.
Dublin Crossing Specific Plan Final EIR
Land Use and Planning
Page 3-177
uses and would not physically divide an established community. Therefore, this
would be considered a less than significant impact, and no mitigation is required.
Conflict with Applicable Land Use Plans, Policies, or Regulations
Impact 3.9-3: Implementation of the proposed project would not conflict with goals
and policy of the City of Dublin General Plan, nor the City of Dublin
Zoning Code. This is considered a less-than-significant impact.
As described in the project description, residential, commercial, mixed-use and
public uses could be developed within the project area under the proposed Dublin
Crossing Specific Plan. The Specific Plan includes a maximum of 1,995 residential
units; 200,000 square feet of commercial uses, a 30 net-acre community park; five
acres of neighborhood park and a 12 an 11 net usable acre elementary school site.
The proposed residential uses would be consistent with the existing surrounding
residential uses, which are of similar density and design. Currently the majority of
the project area is designated Public Facilities in the City of Dublin General Plan and
is zoned Agriculture.
The City of Dublin General Plan, including the General Plan Land Use Map, will be
amended concurrent with the adoption of the Dublin Crossing Specific Plan to
include the proposed land use designations to replace the existing General Plan land
use designations for the area as shown in Figure 2-7: Conceptual Land Use Plan.
The Zoning Map for the project area would be amended concurrent with the
adoption of the Dublin Crossing Specific Plan to rezone the project area to Specific
Plan Planned Development (PD-DX). Where land use regulations and/or
development standards in the Dublin Zoning Ordinance are inconsistent with the
Dublin Crossing Specific Plan, the standards and regulations of the Specific Plan
prevail. Any issue not specifically addressed in the Dublin Crossing Specific Plan
shall be subject to the Dublin Zoning Ordinance and/or Municipal Code.
Interpretations may be made by the Community Development Director if not
specifically covered in the City’s existing regulations. Proposed land use
designations would include Dublin Crossing Lower Density Residential (DC LDR)
with a density of 6 to 14 units per net acre; Dublin Crossing Medium Density
Residential (DC MDR) with a density of 14.1 to 20 units per acre; Mixed Use with a
density of 20.1 to 60 units per net acre; General Commercial/DC Medium Density
Residential (GC/DC MDR) with a maximum floor to area ratio (FAR) of 1.0 and a
maximum density for residential development within this district of 20 units per
acre; General Commercial/DC High Density Residential (GC/DC HDR) with a
maximum floor to area ratio (FAR) of 1.0 and a maximum density for residential
development within this district of 55 units per acre; Parks/Open Space (P); Open
Space (OS), and School (S). With the adoption of the General Plan amendments, the
proposed uses would be allowed within the project area.
Dublin Crossing Specific Plan Final EIR
Land Use and Planning
Page 3-178
The proposed project’s consistency with the City of Dublin General Plan discussed in
Table 3.9-1: City of Dublin General Plan Consistency Analysis. Consistency with
policies related to environmental effects are addressed in each technical section of
the EIR. As demonstrated, the proposed project would not be in conflict with the
applicable land use policies of the General Plan. Therefore, this would be
considered a less than significant, and no mitigation is required.
Table 3.9-1: City of Dublin General Plan Consistency Analysis
City of Dublin General Plan Consistency Analysis
Land Use Element
2.1.1 Housing Availability
Implementing Policy B – Designate site available
for residential development in the primary
planning area for medium to medium high
density where site capability and access are
suitable and where the higher density would be
compatible with existing residential
development nearby.
Consistent. The Specific Plan includes a
maximum of 1,995 residential units; 200,000
square feet of commercial uses, a 30 net-acre
community park; five acres of neighborhood
park and an 11a 12 net usable acre elementary
school site. The proposed residential uses would
be consistent with the surrounding residential
uses to the south and west of the project area.
Parks and Open Space Element
3.1 Open Space for Preservation of Natural
Resources and For Public Health and Safety
Implementing Policy C - Acquire and improve
parklands in conformance with the standards
and policies recommended in the City’s General
Plan.
Consistent. The proposed project includes a 30
net-acre community park and five acres of
neighborhood park within the project area.
Implementing Policy D – Encourage an efficient
and high intensity of use of the flat and gently
sloping portions of the planning area as a means
of minimizing grading requirements and
potential impacts to environmental and
aesthetic resources.
Consistent. The project area is generally flat
and higher-density urban development with
residential and commercial uses would be
facilitated by the proposed project.
Implementing Policy I - Require land dedication
and improvements for the parks designated in
the General Plan for the Eastern Extended
Planning Area and based on a standard of 5 net
acres per 1,000 residents. Collect in-lieu park
fees as required by City policies
Consistent. Based on a population estimate of
2.73 persons per household and a maximum of
1,995 residential units, the proposed project
would increase the population by approximately
5,446 persons. Based on 30 net acres of park
space within the project area, the proposed
project exceeds the City standards, which would
require approximately 27 acres of parks space.
Schools, Public Lands and Utilities Element
4.1 Public Schools
Dublin Crossing Specific Plan Final EIR
Land Use and Planning
Page 3-179
City of Dublin General Plan Consistency Analysis
Implementing Policy C. Initiate preparation of
site plans or specific plans jointly with the
Dublin Unified School District prior to sale.
Consistent. The proposed project includes an
12 net usable acre site for development of a
future elementary school. The project applicant
has been working with the Dublin Unified School
District to coordinate future dedication of this
school site to the District.
Circulation and Scenic Highways Element
5.1.1 Roadway Standards
Guiding Policy A – Design non-residential streets
to (1) accommodate forecasted average daily
traffic demand on segments between
intersections, and (2) minimize congested
conditions during peak hours of operation at
intersections and serve a balance of vehicles,
bicycles, pedestrian, and transit.
Consistent. The Specific Plan includes a
circulation network to accommodate additional
traffic associated with future development. The
Transportation section of this Draft EIR
analyzed the transportation circulation impacts
associated with the proposed project and
includes mitigation measures to help reduce
traffic congestion at affected intersections.
Dublin Crossing Specific Plan Final EIR
Noise
Page 3-193
Exposure to Long-Term Stationary Noise
Impact 3.10-3: Compliance with design guidelines and development standards
contained within the Specific Plan will ensure that potential future
development within the project does not exceed established noise
standards. This is considered a less than significant impact.
The proposed project could result in long-term stationary noise impacts on sensitive
receptors in the project vicinity, which consist of residential uses adjacent to and
within the project area. Examples of stationary noise sources that could be located
within the project area include commercial operations, generators, air conditioning
facilities, and stationary noise sources at the proposed community park including an
amphitheater, carousel, etc. As shown in Figure 2-7: Conceptual Land Use Plan, the
proposed commercial uses would be located in the eastern portion of the project
area along Arnold Road and Dublin Boulevard. The proposed 11 12 net usable acre
school site would be located within the center of the project area and the proposed
community park would be located at the corner of Scarlett Drive and Dublin
Boulevard. Conceptual plans for the community park show the amphitheater and
carousel located within the central portion of the park and would not be
immediately adjacent to residential uses. Uses at parks and schools are generally
compatible with residential uses as the generation of stationary noise sources
typically occur during the daytime hours.
The purpose of the Specific Plan is to guide development and design within the
project area. This will be accomplished by a set of regulations, design principles,
and related implementing actions designed to foster quality development and
prevent excessive noise. For example, to reduce noise from service, storage, and
loading areas, the Specific Plan recommends that the location and hours of loading
and unloading areas should be designed to minimize noise impacts on the
surrounding residential neighborhood (Specific Plan Design Guidelines Section
3.1.11). For drive-through and drive-up uses, the Design Guidelines specify that
outdoor ordering systems are to be located to direct sound away from residential
uses and common areas, or otherwise minimize noise impacts to these uses.
Entertainment uses should be separated from residential and other uses that may
conflict with the higher levels of light, noise, and pedestrian traffic.
The Specific Plan proposes development that is consistent with existing land uses in
the vicinity of the project area and is anticipated to generate similar noise levels.
Where new development would abut noise sensitive uses (within the project area,
as well as between the project area and existing offsite uses), the Specific Plan
includes design guidelines and development standards that are aimed at reducing
noise levels, including building orientation, setbacks, and buffers. By providing the
necessary regulatory and design guidance, the proposed project ensures that future
development within project area implements the policies of the Noise Element in
the City of Dublin General Plan as well as the Municipal Code noise regulations.
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-200
police also enforce city ordinances and state laws within the limits of the City of
Dublin.
Schools
The Dublin Unified School District (DUSD) provides public education in the City of
Dublin and the surrounding area (including the proposed project area). The DUSD
includes five elementary schools, one K-8 school, one middle school, a
comprehensive high school, a continuation high school, and a K-3 parent
participation program. The elementary schools all feature before and after school
child care. Primary and secondary school facilities, 2011-2012 student enrollment,
and the school’s optimum capacity are identified in Table 3.11-1: Optimum Capacity
of Schools Serving the Project Area
Table 3.11-1: Optimum Capacity of Schools Serving the Project Area
Grade Level and School Name Student Enrollment in
2011-2012 Optimum Capacity
Elementary
Dougherty 758 749
Dublin 621 755
Green 781 749
Frederiksen 641 705
Murray 393 457
Kolb 760 820
Fallon (based on 6-8 grade only) 824 1,212
Middle School
Fallon (based on 6-8 grade only) 824 1,212
Wells 718 1,063
High School
Dublin HS 1,747 2,500
Valley Continuation HS 80 160
Source: Dublin Unified School District, 2012.
The proposed project is located within the service areacurrent attendance
boundaries of Frederiksen Elementary School, Wells Middle School, and Dublin High
School. Depending on space availability, students may be overflowed to another
campus with available capacity.
For planning purposes, a school district’s projected student generation rates are
based on dwelling units. Student generation rates are the average number of
students residing in a home. It is also an indicator of the number of students that
will come from new housing developments. According to the Dublin Unified School
District’s Demographic Study and Facilities Plan, 2011-2012, each new single-family
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-202
The project area is generally flat with elevations ranging from 357 feet at the
northeast corner of the project area to a low of approximately 336 feet at the
southwest corner of the project area near the intersection of Dublin Boulevard and
the Iron Horse Regional Trail. The entire 1,800 acre watershed within Camp Parks
majority of the Camp Parks drains through the project area. The majority of the
runoff from this watershed is conveyed through Camp Parks in natural and
engineered swales which cross the project area and are intercepted along the north
side of Dublin Boulevard and the project area and are intercepted along the north
side of Dublin Boulevard and conveyed to various existing Zone 7 drainage facilities.
The main drainage channel for runoff from Camp Parks crosses the project area and
is currently mapped as a FEMA 100-year floodplain. Zone 7 has indicated that the
peak 100-year storm runoff within this main channel concentrated at Dublin
Boulevard shall not exceed 950 cubic feet per second (cfs). To the northeast and
east of Camp Parks, runoff is collected in an existing channel and conveyed south
along Arnold Road to a flow “splitter” near Central Parkways, which divides flow
between two existing Zone 7 drainage facilities. A portion of this flow continues
down Arnold Road, while the remainder is conveyed in an existing trapezoidal
channel across the southeastern portion of the project area.
Water
The Dublin San Ramon Services District (DSRSD) is the purveyor of potable water in
the City of Dublin. DSRSD has provided drinking water to more than 60,000 people
in Dublin since March 1961 and in Dougherty Valley since May 2000. In addition to
potable water, DSRSD also provides recycled (reclaimed) water for irrigation and
other non-potable uses. DSRSD Ordinance No. 301 requires recycled water use for
approved customer categories for all new land uses, including commercial, multi-
family residential, and institutional irrigation uses with the DSRSD potable water
service area. The City of Dublin also has Water-Efficient Landscaping Regulations
that reduce water use for irrigation (refer to the Dublin Municipal Code, Chapter
8.88).
DSRSD’s Urban Water Management Plan (June 2011) (hereinafter “DSRSD UWMP”)
includes a projection of future potable and reclaimed water use through the year
2030. This projection is shown in Table 3.11-2: DSRSD Current and Projected Water
Meter Connections by Customer Type (Potable and Reclaimed).
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-205
jurisdictions. The City of Dublin currently contracts with Amador Valley Industries
(AVI), a private company for residential and commercial garbage collection within
the City limits. The City of Dublin also has an aggressive and comprehensive
recycling program and collects both recycling and organics. All single-family
residences are provided with recycling containers. In addition, free recycling
service is available to all commercial customers that subscribe to garbage service.
In regards to construction and demolition debris, the City requires all construction
and demolition projects to recycle at least 50-percent of waste generated on a job
site.
Solid waste generated within the project area would be deposited at the Altamont
Landfill. The Altamont Landfill has a total estimated permitted capacity of
62,000,000 cubic yards. The total estimated capacity used is 16,280,000 cubic yards
(or 26.3 percent), and the remaining estimated capacity is at 45,720,000 cubic yards
(or 73.7 percent). The estimated closure date of this landfill is January 2029.
Electricity and Natural Gas
Pacific Gas and Electric Company (PG&E) provides electricity to all or part of 47
counties in California, and provides natural gas to all or part of 39 counties in
California, constituting most of the northern and central portions of the state. PG&E
provides electricity and natural gas service to the City of Dublin. PG&E charges
connection and user fees for all new development, in addition to sliding rates for
electrical and natural gas service based on use. Electricity and gas services are
currently offered in the project vicinity.
Title 24, Part 6, of the California Code of Regulations, entitled “Energy Efficiency
Standards for Residential and Nonresidential Buildings,” specifies requirements to
achieve the State’s minimum energy efficiency standards. The standards apply to
new construction of both residential and nonresidential buildings, and regulate
energy consumed for heating, cooling, ventilation, water heating and lighting.
Compliance with these standards is verified and enforced through the local building
permit process. Projects that apply for a building permit on or after January 1, 2010,
must comply with the 2008 Energy Efficiency Standards. In addition, the California
Energy Commissions’ Energy Aware Planning Guide is available as a reference tool to
assist in project planning.
Regulatory Setting
State
Schools
School Facilities Act of 1998
The School Facilities Act of 1998 (also known as Senate Bill [SB] 50), provides state
funding for a portion of the funding needed for new school construction projects
that can satisfy certain criteria for such funding, including eligibility due to growth,
Division of State Architect plan approval. However, the Act also dramatically limits
the maximum amount of impact fees, which can be charged by school districts as
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-212
that there is a five-minute response time to all emergency calls. The City of Dublin
has 51 sworn personnel with a population of 46,572, for a ratio of 1.09 sworn
personnel per 1,000 residents (Personal Communication with Lieutenant Nate
Schmidt, Alameda County Sherriff; Department/City of Dublin Police Department,
June 5, 2013).
Although the addition of new residents to the project area would slightly increase
the demand for police services, implementation of the proposed project is not
anticipated to have an adverse effect on response times for police services and
would not affect the Department’s ability to serve the proposed project (Personal
Communication with Lieutenant Nate Schmidt, Alameda County Sherriff;
Department/City of Dublin Police Department, June 5, 2013).
Future development within the project area would be required to comply with
Chapter 7.32.300 (Building Security) and Chapter 7.32.310 (Nonresidential building
security) of the City’s Building Code, which includes building standards aimed at
reducing law enforcement calls within the City. In addition, the City would collect
public facilities fees (Chapter 7.78 of the City of Dublin Municipal Code) from future
development to help off-set police service capital improvements and on-going
maintenance expenses incurred by the new development prior to issuance of a
Building Permit to ensure that the proposed project will not cause impacts on law
enforcement services that would result in significant environmental impacts.
Therefore, the proposed project would have a less than significant impact on law
enforcement services, and no mitigation is required.
Increased Demand for Educational Facilities
Impact 3.11-3: Implementation of the proposed project would increase the
number of students in the Dublin Unified School District
(DUSD) with the construction of a maximum of 1,995
residential units, which would increase the capacity of the
schools, which are operating above optimum capacity. The
proposed project includes an 11a 12 net usable acre school site
and future development would be required to pay school
impact fees as required under State law to the DUSD. This is
considered a less than significant impact.
The proposed project would allow for a future net new development potential with
a maximum of 1,995 residential units within the project area. Children from the
proposed residential dwelling units would likely attend DUSD schools including:
Frederiksen Elementary School; Wells Middle School; and Dublin High School.
Based on the DUSD’s student generation rate for medium density housing (single
family residential with lots less than 4,000 square feet) of 0.525 K-12 students per
home and a maximum of 1,995 homes within the project area the proposed project
would generate approximately 1,047 students. As shown in Table 3.11-3:
Enrollment Capacity of Schools Serving the Project Area, the DUSD has an excess of
capacity of 990 students.
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-213
Table 3.11-3: Enrollment Capacity of Schools Serving the Project Area
Grade Level and
School Name
Student Enrollment in
2011-2012 Optimum Capacity Excess Capacity
Elementary
Frederiksen 641 705 64
Middle School
Wells 718 1,063 345
High School
Dublin HS 1,474 2,500 581
Source: Dublin Unified School District, 2012.
The proposed project includes a 12 net usable acre site for a future elementary
school, which would be dedicated to the DUSD for a proposed school that would
serve the proposed project and surrounding uses. This elementary school will be
designed to accommodate up toapproximately 900 children and will include
classrooms, a gymnasium, administrative offices, a multi-use sports field, sport
courts, a playground, and parking. In addition, future development within the
project area would be required by law to pay school impact fees at the time of the
building permit issuance. The DUSD currently charges development fees in the
amount of $2.97 per square foot of residential development and $0.47 per square
foot for commercial and industrial uses. These fees are used by the DUSD to
mitigate impacts associated with long-term operation and maintenance of school
facilities.
A project applicant’s fees would be determined at the time of the building permit
issuance and would reflect the most current fee amount established by the DUSD.
School fees exacted from residential and commercial uses would help fund
necessary school service and facilities improvements to accommodate anticipated
population and school enrollment growth within the DUSD service area, and would
allow for the DUSD to allocate these funds as deemed necessary. Therefore, the
increased demand on the DUSD is considered a less than significant impact on
school services, and no mitigation is required.
Increased Demand for Parks and Recreation Facilities
Impact 3.11-4: The proposed project would increase the demand for park and
recreational uses within the project area. However,
development projects within the project area would be
required to pay the City’s Public Facilities Fee prior to Building
Permit issuance. This is considered a less than significant
impact.
Implementation of the proposed project would increase the demand for
neighborhood and community parks due to the projected increase in the residential
population generated by future development within the project area. The proposed
Dublin Crossing Specific Plan Final EIR
Public Services and Utilities
Page 3-220
project Infrastructure Master Plan, which the City will be reviewing and approving in
accordance with the requirement of the Specific Plan. The Infrastructure Master
Plan should identify the development trigger for the future tank. The future tank
should be installed prior to approval of the Final Map for the trigger point.
With implementation of these measures, this would be considered a less than
significant impact, and no mitigation is required.
Stormwater Runoff
Impact 3.11-8: Implementation of the proposed project may result in
increased off-site stormwater flows and future development
within the project area would be required to install proposed
drainage improvements and pay applicable impact fees at the
time of issuance of the building permits. This is considered a
less than significant impact.
As previously mentioned, the City of Dublin Public Works Department maintains the
City’s storm drain pipelines that are located within public streets. Zone 7 owns and
operates regional storm drain facilities that collect runoff from the City.
Surface water management consists of both on-site runoff and the management of
off-site runoff extending through or around the site.
On-site Surface Water Runoff
As shown in Figure 3.8-3: Proposed DrainageQ100 Project Flows, surface waters
within the project area would be divided into four drainage sheds. Drainage sheds
A9-A (63.3 acres) and A9-B (81.7 acres) would ultimately flow into the Line G-1
drainage channel. Two underground detention basins, located within the proposed
community park, would be constructed. Preliminary estimates by Ruggeri Jensen
Azar (RJA) call for the construction of two underground basins (RJA 2013). Park
Basin #1, which captures drainage from A9-B, would have a storage capacity of 3.3
acre feet and an outflow rate of 80 cfs. Park Basin #2, which captures drainage from
A9-A, would have a storage capacity of 1.6 acre feet and an outflow of 71 cfs.9
Based on project plans, drainage from both of these underground basins would be
conveyed via an underground pipe to the proposed Chabot Creek riparian channel
that would be realigned through the proposed community park.
Drainage sheds XX-1 (23.1 acres) and XX-2 (20.9 acres), which are located in the
southeast corner of the site, would ultimately flow into the Line G-5 drainage
9 This analysis assumed two open-air basins and that the bottom 2 ½ feet of each basin was inundated with runoff from the
previous storm event. Given the fact that these two basins are now proposed to be underground, the ultimate storage
capacities would be determined as part of detailed engineering design. However, the basins would be designed so that there i s
sufficient capacity to ensure that runoff capacities to not exceed pre-condition flow conditions.
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-240
(ITE code 220), elementary school use (ITE code 520), office use (ITE code 710),
shopping centers (ITE code 820), and City Park (SANDAG), the project would
generate 24,563 gross daily vehicle trips, with 1,924 gross trips occurring during
the AM peak hour (7:00 to 9:00) and 2,695 gross trips occurring during the PM peak
hour (4:00 to 6:00).
Since the proposed development would relocate the existing Camp Parks entrance
on Dublin Boulevard, the trips generated by the existing use were redistributed
from the current base entrance to the proposed new entrance at Dougherty Road
and Amador Valley Boulevard.
A retail pass-by trip reduction of 20 percent (based on prior analysis in the City of
Dublin) was applied to the PM peak hour trip generation. Pass-by-trips are trips that
would already be on the adjacent roadways (and are therefore already counted in
the existing traffic) but would turn into the site while passing by. Justification for
applying the pass-by-trip reduction is founded on the observation that such retail
traffic is not actually generated by the retail development, but is already part of the
ambient traffic levels. Pass-by-trips are therefore excluded from the PM peak hour
traffic projections at most offsite intersections, but were assigned to the site’s
planned driveways and the intersection of Arnold Road/Dublin Boulevard.
Since the project area is located near the Dublin/Pleasanton BART station, a transit
reduction of five percent was applied to the overall project trip generation based on
results from the City of Dublin travel demand forecasting model.
After applying the appropriate trip reductions, the project would generate 22,047
net new daily trips, with 1,828 net new trips occurring during the AM peak hour and
2,393 net new trips occurring during the PM peak hour. The project trip generation
estimates are presented below in Table 3.12-7: Dublin Crossing Trip Generation. It
should be noted that some of the trips generated by the project would be internal to
the site. For example, some of the project’s residential trips would occur to and from
the proposed school. While these internal trips would represent new trips on the
on-site roadway network, they would not result in new trips to the off-site roadway
network. The internal capture of these trips is accounted for in the Travel Demand
Forecast Model assignment process.
Project Trip Distribution and Assignment
As part of the project trip distribution, an estimate is made of the directions to and
from which the project trips would travel. In the project trip assignment, the project
trips are assigned to specific streets and intersections. The directional distribution
of site-generated traffic to and from the project area was developed based on a
select zone analysis from the City of Dublin Travel Demand Forecast model and
shown in Figure 3.12-7: Proposed Project Trip Generation RatesDistribution. The
peak hour trips generated by the proposed uses were assigned to the roadway
system by the model at each study location.
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-267
Table 3.12-13: 2035 Cumulative Plus Project Freeway Ramp Capacity Analysis
2035 No Project 2035 Plus Project
Freeway Ramps
Peak
Hour
Capacity
(vph)1 Volumes2
V/C
Ratio3 Volumes2
V/C
Ratio3
I-580 at Dougherty Road/Hopyard
Road
SB Hopyard to WB I-580 On Ramp AM 900 627 0.70 672 0.75
PM 1800 326 0.18 399 0.22
SB Hopyard to EB I-580 On Ramp AM 1800 777 0.43 777 0.43
PM 360 213 0.59 213 0.59
I-580 at Hacienda Drive
SB Hacienda to WB I-580 On Ramp AM 720 513 0.71 564 0.78
PM 1800 588 0.33 588 0.33
SB Hacienda to EB I-580 On Ramp AM 1800 337 0.19 410 0.23
PM 300 443 1.48 457 1.52
I-580 at Tassajara Road/Santa Rita
Road
SB Tassajara to WB I-580 On Ramp AM 720 698 0.97 755 1.05
PM 1800 676 0.38 676 0.38
SB Tassajara to EB I-580 On Ramp AM 1800 324 0.18 324 0.18
PM 300 342 1.14 343 1.14
Note: Bold and shaded V/C ratio indicates a significant impact.
1 Capacities obtained from observations at existing ramp meters.
2 Volumes obtained from Dublin TDF Model.
3 Volume-to-capacity ratio.
Source: Hexagon 2012
CMACTC/MTS System Analysis Results
The 2011 Alameda County Congestion Management Program (CMP) includes a Land
Use Analysis component to determine the impacts of land use decisions made by
local jurisdictions on the regional transportation system. The intent of this program
is to:
better tie together local land use and regional transportation facilities
decisions;
better assess the impacts of developments in one community on another
community;
promote information sharing between local governments when decisions
made by one jurisdiction will have an impact on another.
Local jurisdictions have responsibilities regarding the analysis of transportation
impacts of land use decisions. Among those is an analysis of project impacts on the
Metropolitan Transportation System (MTS) for the 2020 and 2035 horizon years.
For projects that generate more than 100 peak-hour vehicle trips, a CMP traffic
analysis is required using the Alameda Countywide Transportation Demand Model
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-268
(ACTDM). In accordance with the Technical and Policy Guidelines of the Congestion
Management Program, the CMP analysis requires evaluation of the traffic impacts of
the project on the MTS.
The Consulting firm Fehr & Peers developed a travel demand model for the City of
Dublin based on the August 2011 ACTDM. Refinements were made to the
Countywide model within the City of Dublin and surrounding areas to provide more
detail in terms of local land uses, and the roadway and transit transportation
systems. The City of Dublin Travel Demand Model (CDTDM) was developed (a) to
provide daily and peak-hour traffic flow projections on freeways, arterial and
collector roadways for the General Plan update, and (b) to provide a tool to analyze
future land use development proposals and transportation network changes within
the City. Documentation of the Dublin Citywide model, including model validation is
provided in the City of Dublin Final Model Development Report, dated April 2012.
Traffic impact analyses for relatively small projects typically add project traffic on
top of the existing (or future no-project) volumes. This "layering" method is
reasonable when the addition of project traffic is unlikely to change the travel
patterns of existing traffic on the roadway system. As a result, the traffic volumes on
roadway segments are by definition always higher than without the project. With
large scale developments, such as the Dublin Crossing project, layering project
traffic on top of existing traffic is not realistic, especially when the project is located
in an area where roadways are already projected to be congested and new
roadways are proposed as part of the project. There are two main reasons for this:
(1) drivers may alter their route to avoid the areas where the additional project
traffic is added to the roadway system because an alternate route would be faster
and (2) the project would result in a change of travel patterns in the area. Two
examples of this include:
Some residents of Dublin that now shop at retail uses in Pleasanton would
shop at the retail center of the Dublin Crossing instead. Thus, their shopping
trip would have a different destination and they would use different roads to
get there. This would result in an increase in traffic on some facilities and a
decrease of traffic on other facilities.
Without the project, I-580 operates at congested conditions during commute
hours. Because some project traffic from the Dublin Crossing development
would add to the traffic congestion on this freeway, ambient traffic would
start using other facilities instead. Thus, some traffic that uses the I-580/I-
680 interchange would shift to alternate routes such as Dougherty Road,
Dublin Boulevard, and Bollinger Canyon Road. Because I-580 and I-680
already operate at or near capacity, there is not much room left to add more
vehicles to these facilities.
Travel demand models, such as the CDTDM and the ACTDM, account for these
changes in traffic patterns resulting from large development projects. For that
reason, these models were used to forecast the impacts on the freeways and MTS
system in the vicinity of the project. The CMA Alameda County Transportation
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-269
Commission (Alameda CTC) requires project’s to conduct the roadway segment and
freeway analysis for the years 2020 and 2035 using the ACTDM. The most recent
version of the ACTDM was obtained from the ACCMA Alameda CTC and future peak-
hour forecasts were developed, with and without the project. Since the ACTDM set
does not include a 2012 forecast year, the freeway analysis for existing and existing
plus project conditions were based on forecasts developed with the CDTDM.
It should be noted that, although the project would add a substantial amount of
peak-hour trips to the adjacent segment of Dublin Boulevard, this does not
necessarily result in the same substantial increase of vehicles on that roadway
segment. Some of the ambient traffic on Dublin Boulevard would change their route
and use other facilities to get to their destination (including diversion to the new
proposed parallel route on G Street). Thus, the increase in traffic volumes on the
freeway segments and the MTS system forecasted by the model would result in a
smaller increase in traffic when compared to the layering of project trips method.
The level of service standard for the CMP analysis is LOS E. The Alameda County
CMACTC does not have a policy for determining a threshold of significance for CMP
requirements and expects that professional judgment will be used to determine
project impacts. The City Engineer, in his expert professional judgment has
determined that the level of service for the CMP Land Use analysis is LOS E.
Therefore, for the purpose of this traffic analysis, if a segment operates at an
unacceptable LOS (per professional judgment) without the project, the impact of the
project is considered significant if the contribution of project traffic results in an
increase in the volume-to-capacity ratio of at least 0.02. This threshold is consistent
with prior traffic impact analyses for development in the City of Dublin.
In order to determine the impact of the project, peak-hour traffic volumes on the 16
directional MTS roadway segments (for 2020 and 2035) and 16 directional freeway
segments (for 2012, 2020, and 2035) in the vicinity of the project were analyzed.
During the AM peak hour, the 2012 existing no project and plus project data at the
freeway segments is shown on Table 3.12-14: 2012 No Project and Plus Project AM
Peak Hour Freeway Level of Service. During the PM peak hour, the 2012 existing no
project and plus project data at the freeways is shown on Table 3.12-15: 2012 No
Project and Plus Project PM Peak Hour Freeway Level of Service. During the AM
peak hour, the 2020 background no project and plus project data at the freeways
and roadway segments is shown on Table 3.12-16: 2020 No Project and Plus
Project AM Peak Hour Freeway and Roadway Segment Level of Service. During the
PM peak hour, the 2020 background no project and plus project data at these
facilities is shown on Table 3.12-17: 2020 No Project and Plus Project PM Peak
Hour Freeway and Roadway Segment Level of Service. During the AM peak hour, the
2035 cumulative no project and plus project data at these segments is shown on
Table 3.12-18: 2035 No Project and Plus Project AM Peak Hour Freeway and
Roadway Segment Level of Service. During the PM peak hour, the 2035 cumulative
no project and plus project data at these facilities is shown on Table 3.12-19: 2035
No Project and Plus Project PM Peak Hour Freeway and Roadway Segment Level of
Service.
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-284
crossing should be utilized. The grade separated crossing would eliminate
the need for at-grade pedestrian actuations at the traffic signal, which would
allow more green time to be allocated to through traffic on Dublin Boulevard.
Although this project has not been environmentally cleared, nor has
engineering or right of way analysis been completed with regards to the
feasibility of this improvement, the City is aggressively pursuing this project
to improve pedestrian and bicycle mobility along the Iron Horse Trail. The
City also plans to include a grade separated crossing at this location in its
update to the TIF program to secure project funding.
Because the impact is caused by future land use growth in the region as well
as this proposed project, the mitigation for this impact is for the project to
make a fair share monetary contribution toward these improvements. The
timing of these improvements will be determined in the Mitigation
Monitoring and Reporting Program and developer obligations will be
outlined in the Developer Agreement. In the event that the grade separated
crossing project cannot be constructed by year 2035, an alternative
mitigation would be to eliminate the crosswalk on the east leg of the Scarlett
Drive and Dublin Boulevard intersection. This would require pedestrians and
bikes from the Iron Horse Trail to cross three crosswalks rather than one.
Because of the effects of the alternative mitigation on pedestrian and bike
mobility, the grade separated crossing is the City’s preferred mitigation at
this location.
Iron Horse Parkway and Dublin Boulevard Intersection
Impact 3.12-4: During the PM peak hour, the study intersection of Iron Horse
Parkway and Dublin Boulevard would degrade from LOS C under
2035 cumulative no project conditions to an unacceptable LOS F
under 2035 cumulative plus project conditions. This is considered a
potentially significant impact.
To mitigate this impact, the project applicant would be required to construct an additional
northbound left turn lane on Iron Horse Parkway. With implementation of the following
mitigation measure, the intersection would operate at LOS D during the PM peak hour.
Therefore, this mitigation measure would reduce this impact to a less than significant
level.
Mitigation Measure:
MM 3.12-4: Addition of a Northbound Left-Turn Lane on Iron Horse Parkway at the
Intersection of Iron Horse Parkway and Dublin Boulevard. To mitigate the
impact at the intersection of Iron Horse Parkway and Dublin Boulevard
would require an additional northbound left turn lane on Iron Horse
Parkway. Based on the 2035 cumulative plus project conditions, the two
northbound left turn lanes would need to be 400 feet each. This
improvement would require widening Iron Horse Parkway by approximately
Dublin Crossing Specific Plan Final EIR
Transportation & Circulation
Page 3-285
12 feet along the east side in advance of the intersection. It may also require
removal of parking, realignment of travel lanes through the intersection,
relocation of sidewalks, and traffic signal modifications. the removal of
parking on the east side of Iron Horse Parkway, traffic signal modifications,
and changing the travel lane configuration and alignment to create:
One 16-foot wide southbound receiving lane on Iron Horse
Parkway;
Two 10-foot wide northbound left turn lanes on Iron Horse
Parkway; and
One 14-foot wide northbound shared through-right turn lane.
Because the proposed project causes the change in operation from LOS C to
LOS F, the proposed project is responsible for constructing these
improvements. The timing of these improvements will be determined in the
project’s mitigation monitoring program.
Hacienda Drive and Dublin Boulevard
Impact 3.12-5: During the PM peak hour, the study intersection of Hacienda Drive
and Dublin Boulevard would operate at an unacceptable LOS E under
both 2035 cumulative no project conditions and 2035 cumulative plus
project conditions. The City of Dublin level of service standard for this
intersection is LOS D. Because the intersection would operate at an
unacceptable level of service under no project conditions, the addition
of project trips would result in a potentially significant impact to
the intersection based on the City of Dublin impact criteria.
With implementation of the following mitigation measure, the Hacienda Drive and Dublin
Boulevard intersection would operate at LOS D during the PM peak hour. Therefore, this
mitigation measure would reduce this impact to a less than significant level.
Mitigation Measure:
MM 3.12-5: Convert One of the Through Lanes to a Second Right-Turn Lane at the
Hacienda Drive and Dublin Boulevard Intersection. As part of the City of
Dublin’s Traffic Impact Fee program, the intersection of Hacienda Drive and
Dublin Boulevard has a planned northbound approach geometry of three left
turn lanes, three through lanes, and one right turn lane. To mitigate the
impact at the intersection of Hacienda Drive and Dublin Boulevard would
require converting one of the through lanes to a second right turn lane,
which is the existing northbound geometry at the intersection. Because no
improvements relative to the existing geometry are necessary, the City of
Dublin should modify its planned improvement at the northbound approach
of the intersection back to the existing configuration. With this mitigation,
the intersection would operate at LOS D during the PM peak hour.
Dublin Crossing Specific Plan Final EIR
Transportation and Circulation
Page 3-290
Mitigation Measure:
MM 3.12-9: Coordination with LAVTA. As the plan area develops, the project applicant
shall coordinate with the City of Dublin and LAVTA to determine if route
changes and/or increased service is required in the project area. In addition,
the project shall provide additional bus duckouts and transit shelters to
support project trips, where appropriate.
Pedestrian/Bicycle Mobility Impacts
Impact 3.12-10: The proposed project does not include detailed information such as
intersection layouts, crosswalk locations, wheelchair ramp locations,
and driveway locations. For this reason, impacts to bicycle and
pedestrian safety cannot be evaluated at this time, which is
considered a potentially significant impact.
As more detail becomes available, a detailed analysis of pedestrian and bicycle mobility
should shall be completed. With implementation of the following mitigation measures, the
impact would be reduced to a less than significant level.
Mitigation Measure:
MM 3.12-10: Review of Intersection Layouts and Driveway Locations. As each
individual site develops within the Specific Plan and more details are
available, additional review by the City of Dublin will be necessary to insure
that individual elements of the project do not conflict with the
pedestrian/bike accessibility and are consistent with the policies and
guidelines in the Dublin Bikeways Master Plan. The following mitigation
measures shall be implemented:
Marked crosswalks shall be provided at all onsite intersections, where
appropriate, based on the layout of the local streets. Prior to final design
of the streets and pathways, the intersection designs should be reviewed
by City staff to insure that the pathway crossings are clearly marked and
include Americans with Disabilities Act (ADA) compliant wheelchair
ramps. Bollards may also be considered so that vehicles are restricted
from driving on the 10-foot wide paths.
The layout of private and minor streets within the site shall minimize, to
the greatest extent possible, the number of crossings with the proposed
onsite 10-foot pedestrian paths. This includes potentially realigning the
Iron Horse Trail onto the Central Park site so that the driveway access to
the park at Scarlett Drive does not conflict with trail operations.
Bike parking, showers, and changing rooms shall be considered at the
park, office and shopping center uses, where appropriate.
During construction along Scarlett Drive, Dublin Boulevard, and Arnold
Road, temporary traffic control plans shall be prepared to minimize the
Dublin Crossing Specific Plan Final EIR
CEQA Considerations
Page 4-2
cannot be predicted with certainty, the project impacts to freeway ramps
would be considered a significant and unavoidable impact.
4.2 Significant Irreversible Changes
Section 15126.2(c) of the State CEQA Guidelines requires an EIR to discuss the
significant irreversible environmental changes that would be involved if the
proposed project would be implemented. Examples include the following: uses of
nonrenewable resources during the initial and continued phases of the project, since
a large commitment of such resources makes removal or nonuse thereafter unlikely;
primary and secondary impacts of a project that would generally commit future
generations to similar uses (e.g., highway improvements that provide access to a
previously inaccessible area); and/or irreversible damage that could result from any
potential environmental accidents associated with the proposed project.
Analysis
The proposed project would allow for the future development of residential,
commercial, parks and open space, and an elementary school. Specifically, the
proposed project includes a maximum of up to 1,995 residential units; 200,000
square feet of commercial uses, 35 acres of parks; and a 12 net usable acre
elementary school site.
A variety of nonrenewable and limited resources would be irretrievably committed
for construction and operation, including but not limited to: oil, natural gas,
gasoline, lumber, sand and gravel, asphalt, steel, water, land, energy, and
construction materials. With respect to operational activities, compliance with all
applicable building codes, as well as project mitigation measures or project
requirements, would ensure that all natural resources are conserved or recycled to
the maximum extent feasible.
The proposed project would result in an increase in demand on public services and
utilities. For example, an increase in the intensity of land uses within the project
area would result in an increase in regional electric energy consumption to satisfy
additional electricity demands from the proposed project. These energy resource
demands relate to initial project construction, transport of goods and people, and
lighting, heating, and cooling of buildings. However, the proposed project would not
involve a wasteful or unjustifiable use of energy or other resources, and energy
conservation efforts would occur with new construction. In addition, new
development associated with the proposed project would be constructed and
operated in accordance with specifications contained in Title 24 of the California
Code of Regulations. Therefore, the use of energy on-site would occur in an efficient
manner.
Although portions of the Camp Parks property have already been developed,
increased development within the project area to support urban uses may be
regarded as a permanent and irreversible change. The proposed project would
Dublin Crossing Specific Plan Final EIR
CEQA Consideration
Page 4-11
Cumulative Impacts Analysis and Assumptions
Impacts associated with cumulative development were analyzed based on the
proposed project’s effects in combination with a summary of projections in the
adopted City of Dublin General Plan (February 11, 1985, Updated May 2013), the
City’s Capital Improvement Program (CIP); and implementation of the Camp Parks
Master Plan.
Implementation of the Camp Parks Master Plan would involve redevelopment of the
what is known as the “Cantonment Area” of Camp Parks to provide more modern
and better-organized facilities. Beneficial features of the Master Plan include:
peripherally located family housing, minimal impact on range training, aggregation
of similar land uses, a campus-style training center, and controlled access at a main
entry gate. The Camp Parks Master Plan anticipates a population increase at build-
out of 11 percent for daily personnel (from 920 to 1,020 people) , the average daily
use of the installation from Army stationing and full-time units/staff, and 85 percent
for total of assigned personnel (from 2,297 to 4,242 people). The total of assigned
personnel is projected to increase by 1,945 people between 2002 and 2012, due to
increases in enlisted personnel and warrant officers.
Aesthetics and Visual Resources
The proposed project is located within an already urbanized area of the City; neither
the project area nor surrounding area has any scenic resources. Although
implementation of the proposed project would allow redevelopment of the project
area from its former use as the Camp Parks Reserve Forces Training Area, the
proposed project includes both development standards and design guidelines to
guide the design of future development within the area. The design guidelines
would also ensure that the proposed project does not introduce substantial light
and glare which would pose a hazard or nuisance. The proposed project would also
be required to comply with a number of other City policy documents that address
urban design and aesthetics. These include: Streetscape Master Plan, Community
Design and Sustainability Element of the General Plan and the Bikeways Master
Plan. In addition, future development would be required to undergo Site
Development Review to ensure that the Specific Plan guidelines are implemented.
The above considerations ensure that cumulative development would result in a
less than significant cumulative impact.
Conclusion: The proposed project would be required to comply with the
design guidelines in the Specific Plan as well as other City policy documents,
which would ensure that the proposed project does not contribute to
cumulative light and glare in the City and surrounding areas, and would
ensure that the proposed project is of quality design. The existing setting
together with the design features of the Specific Plan would ensure the
project’s cumulative contribution to aesthetics and visual quality, would
Dublin Crossing Specific Plan Final EIR
CEQA Consideration
Page 4-27
impacts to several special status and animal species and there would be similar
impacts to protected trees. Assuming the same biological mitigation measures under
this alternative, impacts would be similar in comparison to the proposed project.
Cultural Resources (similar). The Reduced Density Alternative would not eliminate
potential damage to any unknown cultural resources, including historic,
archaeological, or paleontological resources, and/or human remains that could
result with construction of the proposed project. Similar to the proposed project, the
Reduced Density Alternative would result in a less than significant impact to
cultural resources with mitigation measures incorporated herein and therefore,
would have similar impacts in comparison to the proposed project.
Geology and Soils (similar). Impacts under the Reduced Density Alternative would
be similar to the proposed project in that the project area would still be exposed to
seismic ground shaking, liquefaction, soil erosion, and expansive soils with
development within the project area. Because this alternative would be required to
comply with the City’s Building Code, and the California Building Code, the Reduced
Density Alternative would result in similar impacts to the proposed project.
Greenhouse Gas Emissions and Climate Change (greater). An increase in direct and
indirect sources of greenhouse gas emissions associated with the proposed project
would also occur under the Reduced Density Alternative. The reduction in
development and density is anticipated to increase the per capita GHG emissions
since the service population would decrease. The Reduced Density Alternative
would locate fewer people near transit and other commercial uses and therefore
vehicle trips are not anticipated to decrease proportionally. Therefore, the Reduced
Development Alternative is anticipated to result in greater greenhouse gas
emissions in comparison to the proposed project.
Hazards and Hazardous Materials (slightly less). The Reduced Density Alternative
would result in similar impacts with respect to hazards and hazardous materials
due to the types of uses proposed under this alternative (e.g. residential and
commercial uses). Therefore, the Reduced Development Alternative would also
result in a less than significant impact.
Hydrology and Water Quality (similar). Surface water runoff under this alternative
would be slightly less in comparison to the proposed project due to development at
lower densities, which would result in a reduction of impervious surfaces.
Mitigation measures would also be required under this alternative to reduce
potentially significant impacts to short and long-term surface water hydrology.
Therefore, the Reduced Density Alternative would result in similar impacts in
comparison to the proposed project.
Land Use and Planning (greatersimilar). Similar to the proposed project, the
Reduced Development Alternative would not physically divide an established
community and/or conflict with applicable land use plan, policies or regulations.
Dublin Crossing Specific Plan Final EIR
References
Page 5-2
Cardno Entrix. Biological Technical Report for Dublin Crossing. June 2013.
Cal Engineering and Geology. Second Geotechnical and Geologic Review, Preliminary
Geotechnical Report and Fault Ground Rupture Investigation, Dublin Crossing Project
at Camp Parks, Dublin, California. April 2013.
City of Dublin. Dublin Crossing Specific Plan. June 2013.
City of Dublin. City of Dublin General Plan, adopted February 11, 1985, updated
January 19, 2010.
City of Dublin. City of Dublin Municipal Code.
City of Dublin. City of Dublin Final Model Development Report. April 2012.
City of Dublin. Wildfire Management Plan. Adopted July1996. Revised November
2010.
City of Dublin. Dublin Transit Center General Plan Amendment. 2002.
City of Dublin. Dublin Transit Center EIR. 2002.
City of Dublin. Village @ Dublin Retail Project Supplemental EIR. 2013.
City of Dublin. City of Dublin Climate Action Plan. 2010.
Cyril M. Harris. Handbook of Noise Control. 1979.
Dublin San Ramon Community Services District (DSRSD). 2010 Urban Water
Management Plan. June 2011.
Dublin Unified School District. CalPADS Enrollment. October 2012.
Dublin Unified School District. Demographics Update, Board of Trustees Meeting.
March 2012.
Economic and Planning Systems (EPS). City of Dublin Economic Development
Strategy. November 2012.
ECORP Consulting, Inc. Supplemental Cultural Resources Assessment for the Dublin
Crossing Specific Plan Environmental Impact Report Alameda County, California. April
2012.
Federal Transit Administration. Transit Noise and Vibration Impact Assessment
Guidelines, May 2006.
Hall, Mark, Environmental Coordinator, U.S. Army, Camp Parks. Personal
Communication with Erika Spencer, RBF Consulting on May 21, 2013 and
September 17, 2013.
ICF International (ICF). East Alameda County Conservation Strategy. October 2010.
Intergovernmental Panel on Climate Change. Climate Change, The Science of Climate
Change – Contribution of Working Group I to the Second Assessment Report of the
IPCC. 1996.
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Dublin Crossing Specific Plan EIRExisting Biological Habitats
Figure 3.3-1Date: 10-9-13 JN: 70-100382
Source: Cardno Entrix (2013)
Dublin Crossing Specific Plan EIRPreliminary Wetlands and Other Waters
Figure 3.3-2Date: 12/05/2012 JN: 70-100382
Source: Cardno Entrix (2012)
Per 1995 Santa Rita Drainage Master Plan (pgs 10 & 19), a maximum flow of 350 would be diverted to Line G-5
Per 1995 Santa Rita Drainage Master Plan (pg 19) & 1194 letter from Alameda Co. Public Workds Agency, Option C at “U/S 580”, Q100 = 950 cfs max.
Existing detention basin per “Hydrologic and Hydraulic Analysis for the Proposed Camp Parks Dentention Basin” study dated March 8, 2013.
1
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Date: 09/17/2013 JN: 70-100382
Dublin Crossing Specific Plan EIR
Figure 3.8-3
Proposed Q100 Project Flows
Source: Ruggeri-Jensen-Azar (2013)