Loading...
HomeMy WebLinkAbout6.2 Attachment 2 - Exhibit A of Attachment 1 - CEQA AddendumSemi-Public Sites General Plan Amendment, Eastern Dublin Specific Plan Amendment and Rezoning CEQA Addendum May 25, 2021 Planning Application Number: PLPA-2020-00054 Attachment 2 - Exhibit A of Planning Commission Resolution 40 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Addendum | Page 1 Semi-Public Sites GPA CEQA Addendum May 25, 2021 Project Overview The City initiated a General Plan Amendment (GPA), Eastern Dublin Specific Plan Amendment (SPA) and a Rezoning (RZ) for 2.5 acres on the GH PacVest property and 2.0 acres on the East Ranch property in Eastern Dublin from Semi-Public to Public/Semi-Public to allow a broader range of public and semi-public uses, including the potential for future development of affordable housing by a non-profit entity. The GPA, SPA and RZ are also referred to in this document as the proposed project. Both sites are located within the Eastern Dublin Specific Plan (EDSP) area and the Fallon Village project area. Prior CEQA Analysis Prior CEQA analysis includes: 1) the Eastern Dublin General Plan and Specific Plan EIR (1993); 2) the East Dublin Properties Stage I Development Plan and Annexation Supplemental EIR (2002); and 3) the Fallon Village Supplemental EIR (2005). Collectively, these three environmental review documents are referred to as the “EDSP EIRs” or “previous CEQA findings,” and are described below. East Dublin General Plan and Specific Plan EIR (1993) The East Dublin General Plan and Specific Plan Environmental Impact Report (EIR) and an Addendum (1993 GPA/SP EIR) were certified by the City Council on August 22, 1994. This EIR analyzed GPAs affecting a 6,920-acre area and the adoption of the EDSP, which encompassed a 3,328-acre area and provides a comprehensive planning framework for future development in Eastern Dublin. The area considered in this EIR included the two project sites under consideration in the proposed GPA, SPA and RZ. The 1993 GPA/SP EIR identified the following significant and unavoidable impacts: cumulative loss of agriculture and open space land, cumulative traffic, extension of natural gas, electric, and telephone service communications facilities, consumption of non-renewable natural resources, increases in energy uses through increased water treatment and disposal and through operation of the water distribution system, inducement of substantial growth and concentration of population, earthquake ground shaking, loss/degradation of botanically sensitive habitat, regional air quality, noise, and aesthetics. Pursuant to City Council Resolution No. 53-93, the City adopted Mitigation Measures and a Monitoring Program, which continue to apply to development in the Eastern Dublin Specific 41 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Addendum | Page 2 Plan area. The City Council also adopted a number of Statement of Overriding Considerations in connection with their certification of the 1993 GPA/SP EIR. Fallon Village Initial Study and East Dublin Properties Stage I Development Plan and Annexation Supplemental EIR (2002) In 2002, the City approved an Annexation, Pre-Zoning, and related Planned Development District Stage I Development Plan for the Fallon Village project. The Fallon Village project site consists of 1,132 acres within the EDSP area. An Initial Study (IS) was prepared to determine if the Fallon Village project required additional environmental review beyond that analyzed in the 1993 GPA/SP EIR. The IS found that many of the anticipated impacts of the Fallon Village project were adequately addressed in the 1993 GPA/SP EIR given: 1) the comprehensive planning for the development area; 2) the 1993 GPA/SP EIR‘s analysis of buildout under the EDSP land use designations and policies; 3) the long term 20-30 year focus of the EDSP and the 1993 GPA/SP EIR; 4) the fact that the Fallon Village project was specifically contemplated in the 1993 GPA/SP EIR; and 5) the fact that the Fallon Village project consisted of the same land uses analyzed in the 1993 GPA/SP EIR. Although the IS concluded that the 1993 GPA/SP EIR adequately analyzed most of the potential environmental impacts of the Fallon Village project, it also identified the potential for some new significant impacts or substantially intensified impacts beyond those previously analyzed. As a result, the 1993 GPA/SP EIR was updated and supplemented by the Programmatic East Dublin Properties Stage I Development Plan and Annexation Supplemental EIR (2002 Supplemental EIR), which updated the analyses of agricultural resources, biology, air quality, noise, traffic and circulation, schools, and utilities. The area considered in this EIR included the two project sites under consideration in the proposed GPA, SPA and RZ. In certifying the 2002 Supplemental EIR, the City adopted Mitigation Measures, a Monitoring Program and a Statement of Overriding Considerations for cumulative air quality and traffic impacts that continues to apply to development in Eastern Dublin, including the two project sites. Fallon Village Supplemental EIR (2005) In 2005, the City considered additional approvals for the 1,132-acre Fallon Village area. These requested approvals had three components: 1. Amendments to the General Plan and EDSP to include the entire 1,132-acre Fallon Village area into the EDSP and to reflect changes to the land use designations on the site; 2. Revisions to the 2002 approval of the Planned Development District Stage I Development Plan to increase the number of dwellings units by 582 to a total of 3,108 units and increase non-residential uses from 1,081,725 square feet to 2,503,175 square feet of commercial and office uses; and 42 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Addendum | Page 3 3. A Stage 2 Development Plan, Vesting Tentative Map, Development Agreement, and Lot Line Adjustment for the development of the northernly 488 acres of the Fallon Village area to allow 1,078 dwelling units, a school, parks, and associated use. The City Council approved all three components of the Fallon Village project request. On December 6, 2005, the City Council certified the Final Supplemental Fallon Village Project Environmental Impact Report (2005 Supplemental EIR) that analyzed the new uses and revisions to the previous approvals for the Fallon Village project. The 2005 Supplemental EIR identified potentially significant environmental impacts and related mitigation measures. The City adopted Mitigation Measures and a Monitoring Program for this approval that continues to apply to development in the Fallon Village area, including the two project sites. In addition, as part of Resolution No. 222-05, the City adopted a Statement of Overriding Considerations for the following significant and unavoidable impacts: traffic impact to the Dublin Boulevard/Dougherty Road intersection; cumulative impacts to local roadways, consistent with the Alameda County Congestion Management Plan; demolition of the Fallon Ranch House; and an increase in regional emissions beyond Bay Area Air Quality Management District (BAAQMD) thresholds. For the East Ranch site, the 2005 Supplemental EIR analyzed 573 dwelling units, 11.5 acres of neighborhood park, 6.8 acres of open space, and 2.0 acres of Semi-Public uses. For the GH PacVest site, the 2005 Supplemental EIR analyzed development of 130 units, per the Medium High Density Residential land use designation and 2.5 acres of Semi-Public uses. The City intended the 2005 Supplemental EIR to be used by state or regional agencies in their review of permits required for development in the Fallon Village area (e.g., California Department of Fish and Wildlife Streambed Alteration Agreements, California Endangered Species Act permits, Water Quality Certification or waiver by the Regional Water Quality Control Board under the Clean Water Act). Proposed CEQA Analysis in this Document The City determined that an Addendum to the EDSP EIRs is the appropriate CEQA review for the proposed project. This City prepared this Addendum pursuant to CEQA Guidelines Section 15164 for the project. The City prepared a CEQA analysis using the City’s Initial Study Checklist, dated May 25, 2021, incorporated herein by reference, to assess whether any further environmental review is required for the proposed project. Through this Initial Study, the City determined that no subsequent EIR or Negative Declaration is required per the following: 43 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Addendum | Page 4 No Subsequent Review is Required per CEOA Guidelines Section 15162 CEQA Guidelines Section 15162 identifies the conditions requiring subsequent environmental review. After a review of these conditions, the City determined that no subsequent EIR or Negative Declaration is required for this project. This is based on the following analysis: a) Are there substantial changes to the project involving new or more severe significant impacts? There are no substantial changes to the project as analyzed in the EDSP EIRs. The project proposes a broader set of allowed uses, including the possibility to construct affordable housing. Such uses would be similar to other existing and planned development in the Eastern Dublin Specific Plan area. . As demonstrated in the Initial Study, the project does not constitute a substantial change to the EDSP EIR analysis, will not result in additional significant impacts, and no additional or different mitigation measures are required. b) Are there substantial changes in the conditions which the project is undertaken involving new or more severe significant impacts? There are no substantial changes in the conditions assumed in the EDSP EIRs, as amended. The project proposes a broader set of allowed uses, including the possibility to construct affordable housing. Such uses would be similar to other existing and planned development in the Eastern Dublin Specific Plan area. This is documented in the attached Initial Study. c) Is there new information of substantial importance, which was not known and could not have been known at the time of the previous EIR that shows the project will have a significant effect not addressed in the previous EIR; or previous effects are more severe; or, previously infeasible mitigation measures are now feasible but the applicant declined to adopt them; or mitigation measures considerably different from those in the previous EIR would substantially reduce significant effects but the applicant declines to adopt them? As documented in the attached Initial Study, there is no new information showing a new or more severe significant effect beyond those identified in the prior CEQA documents. Similarly, the Initial Study documents that no new or different mitigation measures are required for the project. All previously adopted mitigations continue to apply to the project. The CEQA documents adequately describe the impacts and mitigations associated with the proposed development on portions of the Eastern Dublin Specific Plan area. d) If no subsequent EIR-level review is required, should a subsequent negative declaration be prepared? No subsequent EIR or Negative Declaration is required because there are no significant impacts of the project beyond those identified in the EDSP EIRs, as documented in the attached Initial Study. 44 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Addendum | Page 5 Conclusion This Addendum is prepared pursuant to CEQA Guidelines Section 15164 based on the attached Initial Study. The Addendum and Initial Study review the proposed GPA, SPA and RZ as discussed above. Through the adoption of this Addendum and related Initial Study, the City determines that the proposed project does not require a subsequent or supplemental EIR or Negative Declaration under CEQA Section 21166 or CEQA Guidelines Sections 15162 and 15163. The City further determines that the EDSP EIRs adequately address the potential environmental impacts of the Semi-Public Sites GPA, SPA and RZ. As provided in Section 15164 of the CEQA Guidelines, this Addendum need not be circulated for public review, but shall be considered with the prior environmental documents before making a decision on this project. The Initial Study and the EDSP EIRs are incorporated herein by reference and are available for public review during normal business hours, Monday through Friday, from 8:00 a.m. to 12:00 p.m. and 1:00 p.m. to 5:00 p.m., in the Community Development Department, Dublin City Hall, 100 Civic Plaza, Dublin CA. 45 Semi-Public Sites General Plan Amendment, Eastern Dublin Specific Plan Amendment and Rezoning Environmental Checklist / Initial Study May 25, 2021 Planning Application Number: PLPA-2020-00054 46 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study| Page i 5/18/21 Table of Contents Project Background 1 Project Purpose 2 Project Description 2 CEQA Analysis 5 Determination 6 Aesthetics ..................................................................................................................................... 7 Agricultural and Forestry Resources .......................................................................................... 10 Air Quality .................................................................................................................................. 11 Biological Resources ................................................................................................................... 14 Cultural Resources ..................................................................................................................... 17 Energy ........................................................................................................................................ 19 Geology and Soils ....................................................................................................................... 20 Greenhouse Gas Emissions ........................................................................................................ 23 Hazards and Hazardous Materials ............................................................................................. 25 Hydrology and Water Quality .................................................................................................... 27 Land Use and Planning ............................................................................................................... 30 Mineral Resources ..................................................................................................................... 31 Noise .......................................................................................................................................... 32 Population and Housing ............................................................................................................. 34 Public Services ............................................................................................................................ 35 Recreation .................................................................................................................................. 38 Transportation ........................................................................................................................... 40 Tribal Cultural Resources ........................................................................................................... 43 Utilities and Service Systems ..................................................................................................... 44 Wildfires ..................................................................................................................................... 47 47 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study| Page ii 5/18/21 Appendices A Traffic Generation Evaluation Memorandum List of Figures Figure 1: Project Location Note: All figures are included at the end of the document. List of Tables Table 1: General Plan Comparison of Semi-Public and Public/Semi-Public Uses Table 2: Trip Generation Comparison Summary 48 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 1 5/18/21 Semi-Public Sites General Plan Amendment, Eastern Dublin Specific Plan Amendment and Rezoning CEQA Initial Study Project Background Project Title Semi-Public Sites General Plan Amendment, Eastern Dublin Specific Plan Amendment and Rezoning PLPA-2020-00054 Lead Agency City of Dublin Community Development Department 100 Civic Plaza Dublin, CA 94568 Contact Michael P. Cass Principal Planner Phone: 925-833-6610 michael.cass@dublin.ca.gov Project Location & Setting The proposed project involves two vacant sites (collectively the project site) with an existing General Plan land use designation of Semi-Public, namely, 2.5 acres on the GH PacVest property (formerly known as the “Chen” property) and 2.0 acres on the East Ranch property (formerly known as the “Croak” property). As shown in Figure 1: Project Location, both sites are located in Eastern Dublin. Both properties are surrounded by residential uses to the north and west, by undeveloped land to the south, and by the City Limits and Urban Limit Line to the east with undeveloped land beyond. The two sites are located in the Planned Development (PD) zoning district and have an approved Stage 1 Development Plan. The specific location of the Semi-Public sites on each property would be determined at the time of Stage 2 Development Plan approval. Project Applicant City of Dublin 49 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 2 5/18/21 100 Civic Plaza Dublin, CA 94568 General Plan Designation Semi-Public Zoning PD Planned Development Project Purpose On October 6, 2020, the City Council received a report and status update on the Housing Element Update and Regional Housing Needs Allocation (RHNA). The Housing Element must include an inventory of specific sites or parcels that may be available to accommodate the RHNA. At the meeting, Staff presented an initial review of sites that may be able to accommodate the potential RHNA. The City Council provided unanimous direction for City Staff to prioritize the conversion of the existing vacant Semi-Public sites to a designation that could accommodate affordable housing. The project is consistent with the City’s Two-Year Strategic Plan July 2020-June 2022, in particular: Strategy 3: Create More Affordable Housing Opportunities. Objective E: Update the City’s General Plan Housing Element in accordance with state law and to ensure an adequate supply of sites to accommodate the City’s Regional Housing Needs Allocation for the period 2023-31. The proposed project would allow a broader range of uses, including the potential for future development of affordable housing by a non-profit entity. Project Description The City initiated a General Plan Amendment (GPA), Eastern Dublin Specific Plan Amendment (SPA) and Rezoning (RZ) for 2.5 acres on the GH PacVest property and 2.0 acres on the East Ranch property in Eastern Dublin from Semi-Public to Public/Semi-Public to allow a broader range of uses, including the potential for future development of affordable housing by a non- profit entity. As shown in Figure 1: Project Location, collectively, these two properties constitute the project site. The proposed project would also amend the land use designations in the Eastern Dublin Specific Plan and the Planned Development zoning designation for consistency with the General Plan Amendment. 50 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 3 5/18/21 The proposed project does not propose any specific development project. Any such development would occur subsequently as part of a Stage 2 Development Plan application. As such, the analysis in this Initial Study is considered programmatic as it relates to a change in land use designation as a matter of policy and regulation. According to the City’s General Plan, the Semi-Public land use designation allows quasi-public uses such as child care centers, youth centers, senior centers, special needs program facilities, religious institutions, clubhouses, community centers, community theatres, hospitals, private schools, and other facilities that provide cultural, educational, or other similar services and benefit the community. As shown in the Table 1: General Plan Comparison of Semi-Public and Public/Semi-Public Allowed Land Uses, the Public/Semi-Public land use designation allows a combination of public facilities land uses and semi-public facilities land uses. In particular, development of housing on a site designated on the General Plan Land Use Map as Public/Semi-Public shall be considered consistent with the General Plan when it is developed by a non-profit entity and serves to meet affordable housing needs or the housing needs of an underserved economic segment of the community. Both sites are located within the Eastern Dublin Specific Plan (EDSP) area and the Fallon Village project area. 51 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 4 5/18/21 Table 1: General Plan Comparison of Semi-Public and Public/Semi-Public Uses Land Use Semi-Public Public/Semi- Public Public schools X Libraries X City office buildings X State, County, and other public agency facilities X Post offices X Fire stations X Utilities X Dublin Civic Center X Childcare centers X X Youth centers X X Senior centers X X Special needs program facilities X X Religious institutions X X Clubhouses X X Community centers X X Community theatres X X Hospitals X X Private schools X X Other facilities that provide cultural, educational, or other similar services and benefit the community X X Housing developed by a non-profit entity and serves to meet affordable housing needs or the housing needs of an underserved economic segment of the community X Other Public Agencies Whose Approval Is Required None. 52 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 5 5/18/21 CEQA Analysis The discussion below analyzes the potential environmental impacts of the project per the criteria as described in Public Resources Code Section 21166 and CEQA Guidelines Section 15162. For convenience, this analysis uses the Appendix G of the CEQA Guidelines as a framework. Different from the standard CEQA checklist included in Appendix G of the CEQA Guidelines are the impact options included in this analysis. Prior CEQA analysis includes: 1) the Eastern Dublin General Plan and Specific Plan EIR (1993); 2) the East Dublin Properties Stage I Development Plan and Annexation Supplemental EIR (2002); and 3) the Fallon Village Supplemental EIR (2005). Collectively, these three environmental review documents are referred to as the “EDSP EIRs” or “previous CEQA findings,” and are described below. The impact check-boxes indicate that the project would not result in a new impact, a substantial increase in the severity of an impact, or an equal to or less severe impact, than those identified in previous CEQA findings. As such, no new environmental review is required because none of the standards under Public Resources Code Section 21166 and CEQA Guidelines Section 15162 are met which would trigger the need for additional CEQA documentation. There are no significant project changes, new information, or change in circumstances that result in a new or substantial increase in severity of a significant impact from those identified in the EDSP EIRs. Therefore, no standards for requiring supplemental environmental review or documentation under CEQA are met and none are required for the project. 53 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 6 5/18/21 Determination On the basis of this initial evaluation: I find that the project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I find that although the project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. I find that the project MAY have a significant effect on the environment and an ENVIRONMENTAL IMPACT REPORT is required. I find that the project MAY have a potentially significant or a potentially significant unless mitigated impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. I find that although the project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the project, nothing further is required. X CITY OF DUBLIN _____________________ _____________________________ Michael P. Cass, Principal Planner Date May 25, 2021 54 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 7 5/18/21 Aesthetics ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 1. AESTHETICS. Would the project: a) Have a substantial adverse effect on a scenic vista? X b) Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway? X c) Substantially degrade the existing visual character or quality of the site and its surroundings? X d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? X Previous CEQA Documents The previous EDSP EIRs identified the following impacts and mitigations for visual resources:  Impact 3.8/A: Standardized "Tract" Development within the project area which did not respond to natural site conditions could cause a significant impact. Adherence to Mitigation Measure 3.8/1.0, which requires consistency with EDSP Goal 6.3.4, reduces this impact to an insignificant level.  Impact 3.8/B: Alteration of Rural/Open Space Visual Character was identified as a significant and unavoidable impact even with adherence to Mitigation Measure 3.8/ 2, which would implement the EDSP plan with retention of predominant natural features and encourages a sense of place in Eastern Dublin.  Impact 3.8/C: Obscuring Distinctive Natural Features identifies the potential of EDSP buildings and related improvements to obscure or alter existing features and reduce the visual uniqueness of the Eastern Dublin area. Implementation of Mitigation Measure 3.8/3.0, which would implement EDSP Policy 6-28, reduces this impact to an insignificant level.  Impact 3.8/D: Alteration of Visual Quality of Hillsides notes that grading and excavation of building sites in hillside areas would compromise the visual quality of the EDSP area. Mitigation Measures 3.8/4.0 through 3.8/4.5 are included in the EDSP EIR to reduce Impact 3.8/D to an insignificant level. These mitigation measures require implementation of EDSP Policies 6-32 through 6-38.  Impact 3.8/E: Alteration of Visual Quality of Ridges states that structures built in proximity to ridges may obscure or fragment the profile of visually sensitive ridgelines. Implementation of Mitigation measures 3.8/5.0 through 3.8/5.2 would reduce this 55 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 8 5/18/21 impact to a less-than-significant level. These measures require the implementation of EDSP Policies 6-29 and 5-30 and General Plan Amendment Guiding Policy E.  Impact 3.8/F: Alteration of Visual Character of Flatlands is identified as a significant and unavoidable impact. No mitigation measure has been identified which can either fully or partially reduce this impact.  Impact 3.8/G: Alteration of the Visual Character of Watercourses which involves the potential for elimination of the visibility and function of watercourses would be mitigated to an insignificant level by adherence to Mitigation Measure 3.8/ 6.0, which required future development to implement EDSP Policy 6-39.  Impact 3.8/H: Alteration of Dublin's Visual Identity as a Freestanding City is mitigated to a level of insignificance by implementation of the EDSP land use plan (Mitigation Measure 3.8/5.0).  Impact 3.8/I: Scenic Vistas includes the alteration of the character of existing scenic vistas and important sightlines. With implementation of Mitigation Measures 3.8/7.0 and 3.8/7.1 this impact would be reduced to an insignificant level. Mitigation Measure 3.8/7.0 requires adherence to EDSP Policy 6-5 and Mitigation Measure 3.8/7.1 requires the City to conduct a visual survey of the EDSP site and to identify and map viewsheds of scenic vistas.  Impact 3.8/J: Scenic Routes identifies that the urban development of the EDSP will significantly alter the visual experience of travelers on scenic routes in Eastern Dublin. Implementation of Mitigation Measures 3.8 / 8.8 and 8.1 will reduce this impact to an insignificant level. These two measures require implementation of EDSP Action Programs 6Q and 6R. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Scenic vistas, views The project site is vacant and classified by the EDSP EIR as “dry-farming rotational cropland.” The EDSP does identify certain ridgelands and ridgelines as visually sensitive and the City pursuant to Specific Plan Policy 6-5 and Action Program 6Q adopted the Eastern Dublin Scenic Corridor, Policies and Standards as means to preserve scenic vistas. Previous CEQA findings found potentially significant impacts to scenic vistas and views. The impact was addressed with implemental of Mitigation Measures 3.8/3.0, 3.8/4.0-4.5, 3.8/5.0- 5.2, 3.8/6.0, 3.8/7.0 and 3.8/7.1 EDSP Policies 6-29 through 6-38 which provide guidelines for grading and building design as a means to preserve scenic vistas and view corridors apply to the project and EDSP area. 56 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 9 5/18/21 (b) Scenic resources The EDSP EIRs found potentially significant impacts to scenic resources. The impact was addressed with implemental of Mitigation Measures 3.8/8.0 and 3.8/8 and EDSP Policies 6-30 through 6-31. These mitigation measures are implemented at a project level as means to preserve scenic vistas and view corridors. No scenic resources exist on the project site, including but not limited to significant stands of trees, rock outcroppings, or bodies of water, so there would be no impact. (c) Substantially degrade the visual character of the site or surrounding area The EDSP EIRs found that development within the EDSP area would alter the existing visual characters of the upland grasses and fields. No mitigation measure could be identified to fully or partially reduce this impact to a less than significant level. The City adopted a Statement of Overriding Consideration for this impact; thus, no additional analysis was found necessary. (d) Create a new source of substantial light or glare Previous CEQA findings found less than significant impacts at both the program and development level. Future development associated with the project would not increase the amount of light and glare that was not previously anticipated in the EDSP and would be required to comply with adopted City regulations for lighting. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified aesthetic/visual impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to aesthetic resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 57 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 10 5/18/21 Agricultural and Forestry Resources ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 2. AGRICULTURE RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? X b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? X c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))? X d) Result in the loss of forest land or conversion of forest land to non-forest use? X e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? X Previous CEQA Documents The previous EDSP EIRs identified the following impacts and mitigations for agricultural resources:  Impact 3.1/C Discontinuation of Agricultural Uses states that agricultural uses within the area would be decreased as a result of the implementation of the EDSP. However, since most land owners at the time the ESDP EIR was written had filed non-renewal notices for their Williamson Act contracts it was assumed that agricultural uses would decline independent of the implementation of the EDSP so the impact was insignificant and no mitigation was required.  Impact 3.1/D Loss of Farmland of Local Importance states that agricultural lands of local importance would be lost as a result of the EDSP. Since these agricultural lands of local 58 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 11 5/18/21 importance were not classified as prime farmland, however, the impact was insignificant and no mitigation was required. The previous EDSP EIRs evaluated if the soils were considered as “prime agricultural soils” through the adopted criteria established by the Cortese-Knox-Hertzberg Local Government Reorganization Act (Government Code Section 56064, referred to as Assembly Bill 2838). It was determined that no additional prime or agricultural lands beyond those identified in previous EIRs were found. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a-e) Convert farmland or conflict with zoning Previous CEQA findings found there were no significant impacts with respect to agricultural resources. No new conditions have been identified for the project with respect to conversion of prime farmland to a non-agricultural use. No new or more severe significant impacts would result from the project than were previously analyzed. No agricultural zoning or Williamson Act contracts presently exist on the project site nor are any agricultural operations on-going. There is no forest land within the project site. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified agricultural impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to agricultural resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Air Quality ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs a) Conflict with or obstruct implementation of the applicable air quality plan? X b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non- X 59 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 12 5/18/21 Previous CEQA Documents The EDSP EIRS identified the following impacts and mitigation measures for air quality:  Impact 3.11/A: Dust Deposition from Construction Activity states that project construction will generate respirable particulate matter that could potentially impact nearby areas significantly. Mitigation Measure 3.11/1.0 mitigates this impact to an insignificant level but dust emissions remain a potentially significant cumulative impact.  Impact 3.11/B: Construction Equipment/Vehicle Emissions acknowledges that operating construction equipment will generate exhaust pollutants. Since the build out of the EDSP is long-term the impact of these emissions is potentially significant. Mitigation Measures 3.11/2.0 through 3.11/4.0 do not sufficiently reduce the anticipated ozone precursor emission to within Bay Area Air Quality Management District (BAAQMD) standards so air quality impacts remain potentially significant and contribute to a potentially significant cumulative impact.  Impact 3.11/C: Mobile Source Emissions: ROG or NOx states that as a result of vehicle trips generated by the full build out of the EDSP ROG and NOx emissions will exceed the BAAQMD threshold causing a significant impact. Mitigation Measures 3.11/5.0 through 3.11/11.0 reduce this impact but not sufficiently to reduce it to an insignificant level.  Impact 3.11/D: Mobile Source Emissions CO2 notes that the EDSP will not cause any new CO2 emission standard violations and, therefore, has an insignificant impact.  Impact 3.11/E: Stationary Source Emissions notes that project related NOx emissions from fuel consumption for energy demand exceeds BAAQMD’s significance threshold causing a significant impact. Mitigation Measures 3.11/12.0 and 3.11/13.0 reduce this impact but not sufficiently to reduce it an insignificant level. This impact also contributes to a potentially significant cumulative impact for the area. The EDSP EIRs found a significant and unavoidable impact (AQ-2) associated with regional emissions. The EIR analysis determined that project would exceed BAAQMD’s thresholds of significance for reactive organic gases and nitrogen and, thus, the project would have a significant effect on regional ozone air quality. The lowered national eight-hour standard for ozone would result in a significant and unavoidable impact. Mitigation Measures 3.11/5.0-11.0 attainment under an applicable federal or state ambient air quality standard? c) Expose sensitive receptors to substantial pollutant concentrations? X e) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? X 60 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 13 5/18/21 include bicycle/pedestrian paths as well as extension of transit service, which are being implemented as part of the project. The EDSP EIRs found a significant and unavoidable cumulative impact (AQ-2) associated with project contributions to regional air quality. The City adopted a Statement of Overriding Considerations for this impact, which includes the project. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Consistent with air quality plans The project would not conflict with the Clean Air Plan adopted by BAAQMD since the project site has been included in Dublin's planned growth, which is the basis of the Clean Air Plan. (b) Violate air quality standards or cause cumulatively considerable air pollutants The project is located in the Livermore-Amador Valley where, per BAAQMD, air pollution is high. High temperatures increase the potential for ozone and there is a transport of pollutants that occur between Livermore Valley and the San Joaquin Valley to the east. Since certification of the EDSP EIRs, the thresholds with respect to air quality have been revised. The U.S. Environmental Protection Agency (EPA) also lowered the national eight-hour standard for ozone from 0.075 ppm to 0.070 ppm in 2015. The BAAQMD also lowered the state one-hour standard for nitrogen dioxide to 0.18 ppm and retained the national average standard of 0.030 ppm. The new thresholds do not represent “new information” as specifically defined under CEQA as the information used to develop these new thresholds was known, or could have been known, when the EDSP EIRs were prepared. The previous CEQA findings found that proposed development would result in a significant and unavoidable emission of air pollutants exceeding the applicable BAAQMD standards. Mitigation Measures 3.11/2.0 through 3.11/4.0, 3.11/5.0 through 3.11/11.0, 3.11/12.0, and 3.11/13.0 were recommended to reduce impacts to a less than significant level but were insufficient to reduce impacts to a less than significant level. The City adopted a Statement of Overriding Considerations for these significant and unavoidable impacts that applies to the project. (c-d) Expose sensitive receptors to pollutant concentrations or create objectionable odors The health risk of diesel exhaust from roadway traffic was previously analyzed. The 1999 BAAQMD CBQA Guidelines (1999 Guidelines) identified diesel engine particulate matter as a toxic air contaminant based on California Air Resources Board (CARB) findings. There were several studies published prior to 2002 that demonstrated potential health impacts to residences living close to freeways. (See studies cited in CARB's 2005 “Air Quality and Land Use Handbook".) The 1999 Guidelines encourage lead agencies to address impacts to sensitive receptors (such as residences) to exposure of high levels of diesel exhaust from sources such as 61 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 14 5/18/21 a high-volume freeway (1999 BAAQMD CBQA Guidelines, p. 47). The project site is located more than a mile from the closest freeway and, therefore, not subject to potential impacts. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified air quality impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to air quality resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Biological Resources ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 4. BIOLOGICAL RESOURCES. Would the project: a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? X b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? X c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? X d) Interfere substantially 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? X 62 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 15 5/18/21 ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? X f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for biological resources:  Impact 3.7/A: Direct Habitat Loss found that the implementation of the EDSP would result in substantial reduction of habitat and range, a potentially significant impact. Mitigation Measures 3.7/1.0 through 3.7/4.0 reduce this impact to an insignificant level though the project does still contribute to a potentially significant cumulative impact and does result in a significant irreversible change.  Impact 3.7/B: Indirect Impacts of Vegetation Removal recognizes that dust generation from construction, increased erosion, sedimentation, and potential for slope failure, and alteration of drainage patterns could cause a potentially significant impact. Mitigation Measures 3.7/5.0, 3.6/ 18.0, 3.6/22.0, 3.6/23.0, and 3.11/8 reduce this impact to an insignificant level.  Impact 3.7/C: Loss or Degradation of Botanically Sensitive Habitat recognizes that habitat could be lost directly or indirectly as a result of the implementation of the EDSP resulting in potentially significant impacts. Mitigation Measures 3.7/6.0 through 3.7/17.0 reduce this impact to a level of insignificance.  Impacts 3.7/D and 3.7/E pertain to threatened and endangered species. Mitigation Measures 3.7/18.0 and 3.7/19.0 reduce these impacts to an insignificant level.  Impacts 3.7/F through 3.7/I pertain to species who are federal candidates for listing as endangered or threatened. Mitigation Measures 3.7/20.0 through 3.7/22.0 reduce these impacts to an insignificant level.  Impacts 3.7/J through 3.7/R pertain to California species of special concern. Mitigation Measures 3.7/23.0 through 3.7/28.0, 3.4/42.0, 3.7/6.0 through 3.7/17, and 3.7/21.0 reduce all impacts to less than significant. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. 63 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 16 5/18/21 Project Impacts and Mitigation Measures (a) Substantial adverse effect on candidate, sensitive, or special status species No changes have occurred to the project site since certification of the EDSP EIRs. The project site is located within the Eastern Alameda County Conservation Strategy (EACCS) planning area which was adopted as a guidance document for analyzing impacts to listed species within eastern Alameda County in 2010. The EACCS embodies a regional approach to permitting and mitigation for wildlife habitat impacts associated with land development, infrastructure, and other activities. The EACCS guidelines provide more protection for biological resources than the guidelines at the time of the EDSP EIRs. However, EACCS guidelines only apply to public projects and are not a requirement for private development projects. Furthermore, mitigation measures contained in the EDSP EIRs, especially those related to the San Joaquin Kit Fox and Western Burrowing Owl, would also continue to apply to public and private development projects. (b, c) Substantial adverse effect on any riparian habitat, natural community, or wetlands Given the programmatic nature of the proposed project, any future development would be required to comply with the above referenced mitigation measures and, for public development, the EACCS. Therefore, impacts would be equal or less severe than those identified in the EDSP EIRs, and no further mitigation is required. (d) Interfere or impede the movement of migratory fish or wildlife The existing vegetation within the East Ranch portion of the project site consists of mostly grasses with some non-native trees that were planted by the Croak family as ornamental landscape trees which is not native habitat for migratory species. The GH PacVest portion of the project site consists of grasses only. There are no creeks or streams on the project site that would allow for migration of fish species. Impacts to migratory fish or wildlife would be insignificant. (e) Conflict with local policies or ordinance include tree preservation or any adopted habitat conservation or natural community conservation plans. The only trees on the project site are ornamental non-native trees which are not protected per Chapter 5.6 Heritage Trees of the Dublin Municipal Code and, therefore, there would be no impact. The EACCS is neither a Habitat Conservation Plan nor a Natural Community Conservation Plan, but is a document intended to provide guidance during the project planning and permitting process to ensure that impacts are offset in a biologically effective manner. Future development would be required to implement the EACCS guidelines. 64 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 17 5/18/21 Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified biological resources impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to biological resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Cultural Resources ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 5. CULTURAL RESOURCES. Would the project: a) Cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines section 15064.5? X b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5? X c) Disturb any human remains, including those interred outside of dedicated cemeteries? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for cultural resources:  Impact 3.9/A: Disruption or Destruction of Identified Prehistoric Resources recognized impacts associated with the disruption or destruction of identified prehistoric resources which would be reduced to an insignificant level by adherence to Mitigation Measures 3.9/1.0-4.0, which require a program of mechanical or hand subsurface testing for midden deposits, recordation of identified cultural resources on State of California site survey forms, preparing a plan testing of each resource and, if required, having the City retain the services of a qualified archeologist to develop a cultural resource protection program.  Impact 3.9/B: Disruption or Destruction of Unidentified Pre-Historic Resources identified an impact related to the disruption or destruction of unidentified pre-historic resources. Mitigation Measures 3.9/5.0 and 6.0 would reduce this impact to an insignificant level 65 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 18 5/18/21 by requiring a halt to development activities that could impact unidentified cultural resources and completion of follow-on site surveys within Eastern Dublin.  Impact 3.9/C: Disruption or Destruction of Identified Historic Resources would be mitigated to an insignificant level by adherence to Mitigation Measures 3.9/7.0 through 3.9/12.0 that requires in-depth analysis of properties with cultural resources, encouragement of adaptive reuse of historic structures to the extent feasible, review of potential historic resources by an architectural historian and development of a preservation program for historic sites and disruption or destruction of unidentified historic resources.  Impact 3.9/D: Disruption or Destruction of Unidentified Historic Resources would be reduced to an insignificant level by adherence to Mitigation Measures M 3.9 / 5.0, 6.0, 7.0, 9.0, 10.0, and 12.0. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Historic resources Both project sites are vacant and, therefore, there would be no impact to historic resources. (b) Archaeological resources Previous CEQA findings require adherence to Mitigation Measures 3.9/5.0 and 6.0, which would reduce this impact to an insignificant level by requiring a halt to future development activities that could impact unidentified cultural resources and completion of follow-on site surveys. (d) Human remains The project is subject to existing cultural resource mitigation measures contained in the previous EDSP EIRs as well as state and local regulations regarding potential impacts to human remains. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified cultural resources impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to cultural resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 66 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 19 5/18/21 Energy ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 6. Energy. Would the project: a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?? X b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? X Previous CEQA Documents The EDSP EIRs did not specifically analyze impacts to energy as it was not a separate topic for analysis when the EDSP EIRs were completed. Utilities and service systems impacts and mitigation measures, some of which are related to the demand for energy of additional service systems, were identified and can be found in the utilities and service systems section of this document. Additional impacts and mitigations for energy from the EDSP EIRs include:  Impact 3.4/Q: Demand for Utilities Extensions notes that the build out of the GP/EDSP will significantly increase demand for gas, electric and telephone services. To supply adequate electrical service to the project, PG&E estimates that a new distribution system will have to be constructed. Extension of utility lines are necessary if the GP/EDSP is approved and built. There is no mitigation to this impact and it remained a significant and unavoidable impact.  Impact 3.4/S: Consumption of Non-Renewable Natural Resources noted that the provision of adequate natural gas and electrical service will require the consumption of non-renewable natural resources. This impact is considered significant and unavoidable. Mitigation Measures 3.4/45.0 and 3.4/46.0 would reduce the impact as much as possible. The City adopted a Statement of Overriding Considerations for the significant and unavoidable impacts of the GP/EDSP, which includes the project. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. 67 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 20 5/18/21 Project Impacts and Mitigation Measures (a) Consumption of energy The EDSP EIRs identified that development of the Eastern Dublin area would result in a significant and unavoidable impact due to the consumption of non-renewable natural resources, including energy consumption. Mitigation measures are identified in the EDSP EIRs that would help mitigate this impact. Furthermore, since preparation of the EDSP EIRs, the California Building Energy Efficiency Standards contained in 24 Cal Code Regs pt. 6 have been revised and updated and include more stringent requirements to prevent the unnecessary consumption of energy. The project would be required to comply with these standards. In addition, Dublin Municipal Code Chapter 7.94 (Green Building) encourages sustainable construction practices in planning, design, energy and water efficiency and conservation, material conservation, resource efficiency and environmental quality. (b) State or local plan for renewable energy or energy efficiency The project does not contain any features that would conflict with or obstruct a state or local plan for renewable energy or energy efficiency and is required to comply with state and local energy regulations, as described above. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified energy impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to energy beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Geology and Soils ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 7. GEOLOGY AND SOILS. Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: X 68 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 21 5/18/21 ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? X ii) Strong seismic ground shaking? X iii) Seismic-related ground failure, including liquefaction? X iv) Landslides? X b) Result in substantial soil erosion or the loss of topsoil? X c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse? X d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? X e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? X f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for geology and soils:  Impact 3.6/A: Fault Ground Rupture was found to have insignificant impact since no known active or potentially active faults traverse the EDSP area and Alquist-Priolo Special Studies Zones are not located within the EDSP area.  Impact 3.6/B: Earthquake Ground Shaking: Primary Effects identified potentially significant and unavoidable impacts from primary effects of seismic ground shaking that were insufficiently mitigated by Mitigation Measure 3.6/1.0. 69 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 22 5/18/21  Impacts 3.6/C through 3.6/L were identified as potentially significant but mitigatable by Mitigation Measures 3.6 / 2.0 through 3.6/28.0 to a level of insignificance. The City adopted a Statement of Overriding Considerations for the significant and unavoidable impacts of the GP/EDSP, which includes the proposed project. The project would be required to adhere to applicable mitigation measures as set forth in EDSP EIRs. Project Impacts and Mitigation Measures (a) Seismic hazards As described in the previous EDSP EIRs, the project site is located in the Coast Range geomorphic province of California. The project site is not located within an Alquist-Priolo Earthquake Fault Zoning Map. No faults and/or their traces have been mapped at the site. The previous EDSP EIRs used applicable building code data which included Peak Ground Accelerations of 0.6g. The 2019 California Building Code (CBC) increased Peak Ground Acceleration, a seismic design parameter used in the previous CEQA analysis, to 0.77g. The EDSP EIRs analyzed and found potentially significant and unavoidable impacts associated with primary effects of seismic ground shaking (Impact 3.6/B; MM 3.6/1.0); potentially significant but mitigable secondary effects of seismic ground shaking including seismically induced settlement, land sliding, and compaction (Impact 3.5/c; MM 3.6/2.0- 8.0); alterations of site landforms (Impact 3.6/D; MM 3.6/9-10), groundwater (Impacts 3.6/F and 3.6/G; MM 3.6/11-13), expansive soils (Impact 3.6/H; MM 3.6/14-16), natural slope stability (Impact 3.6/I; MM 3.6/17-19), cut-and-fill slope stability (Impact 3.6/J; MM 3.6/20-26), erosion and sedimentation (Impacts 3.6/K and L; MM 3.6/27-28). The EDSP EIRs analyzed and found potentially significant and unavoidable impacts associated with primary effects of seismic ground shaking. The project would over excavate potentially liquefiable soils and replace them with engineered fill. Previous geotechnical field explorations have determined there are no mapped landslides on the project site. (b) Erosion/topsoil loss Construction of the project would modify the existing ground surface and alter patterns of surface runoff and infiltration and could result in a short-term increase in erosion and sedimentation caused by grading activities. The project would be required to implement Regional Water Quality Control Board (RWQCB) erosion control measures as enforced by the City in addition to any mitigation measures included in the EDSP EIRs. The City's requirement to implement site-specific erosion and other controls would reduce erosion impacts from the project site. The project would also implement erosion control measures such as soil covering vegetation and landscaping after completion of construction. 70 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 23 5/18/21 (c-d) Soil stability Previous geotechnical investigations described in the EDSP EIRs did not identify any unstable geologic or soil units or those that would be unstable after the project site is developed. Previous geotechnical investigations did identify expansive soils within the project site. Per the requirements in the EDSP EIRs, future development projects would require remedial grading, including over-excavation, keyways, subdrains and engineering fill per geotechnical engineer direction. (e) Soil capability to support waste water disposal, including septic Future development would not use a septic tank or alternative wastewater disposal systems and, therefore, there would be no impact. (f) Unique paleontological resource or site or unique geologic feature The EDSP EIRs analyzed and found that no potential of buried prehistoric sites with undisturbed or partially disturbed sources cultural deposits are associated with the project site. Conclusion The project does not propose changes beyond what was previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified geology and soil impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to geology and soil beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Greenhouse Gas Emissions ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 8. GREENHOUSE GAS EMISSIONS. Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? X b) Conflict with applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? X 71 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 24 5/18/21 Previous CEQA Documents Since certification of the EDSP EIRs, the issue of the contribution of greenhouse gases to climate change has become a more prominent issue of concern as evidenced by passage of AB 32 in 2006. Because the EDSP EIRs were previously certified, the determination of whether greenhouse gases and climate change need to be analyzed for this project is governed by the law on supplemental or subsequent EIRs (Public Resources Code section 21166 and CEQA Guidelines, Sections 15162 and 15163). Greenhouse gas and climate change is not required to be analyzed under those standards unless it constitutes "new information of substantial importance, which was not known and could not have been known at the time the previous EIRs were certified as complete” (CEQA Guidelines Sec. 15162 (a) (3)). Greenhouse gas and climate change impacts were not analyzed in the prior EIRs; however, these impacts are not new information that was not known or could not have been known at the time these previous EIRs were certified. The issue of climate change and greenhouse gases was widely known prior to the certification of these EIRs. The United Nations Framework Convention on Climate Change was established in 1992. The regulation of greenhouse gas emissions to reduce climate change impacts was extensively debated and analyzed throughout the early 1990s. The studies and analyses of this issue resulted in the adoption of the Kyoto Protocol in 1997. Therefore, the impact of greenhouse gases on climate change was known at the time of the certification of the EDSP EIRs. Under CEQA standards, it is not new information that requires analysis in a supplemental EIR or Negative Declaration. No supplemental environmental analysis of the project's impacts on this issue is required under CEQA. Project Impacts and Mitigation Measures (a, b) Generate greenhouse gas (GHG) emissions or conflict with GHG plans or regulations As discussed above, no additional environmental analysis is required under CEQA Section 21166 and CEQA Guidelines Section 15162. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of GHG emission impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to GHG emissions, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 72 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 25 5/18/21 Hazards and Hazardous Materials ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 9. HAZARDS AND HAZARDOUS MATERIALS. Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? X b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? X c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within ¼ mile of an existing or proposed school? X d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? X e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? X f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? X g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? X Previous CEQA Documents The EDSP EIRs did not include an analysis of impacts resulting from hazards and hazardous materials. 73 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 26 5/18/21 Project Impacts and Mitigation Measures (a) Transport, use or disposal of hazardous materials No development project is proposed, only a change in allowable uses with the intent of providing affordable housing, which does not involve the use of hazardous materials. To the extent there are potentially hazardous materials used in construction, the impacts would be less than significant due to compliance with regulatory requirements. (b) Potential release of hazardous materials into the environment The proposed change in land use would not create a significant hazard to the pubic or environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. (c) Emit hazardous materials within one-quarter mile of an existing or proposed school The proposed land use change would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within on-quarter mile of an existing or proposed school since the expansion of uses would not involve the handling of hazardous materials. (d) Listed as a hazardous materials site No development project is proposed, only a change in allowable uses with the intent of providing affordable housing, which does not involve the use of hazardous materials. (e) Proximity to a public or private airport The project would not result in a safety hazard or excessive noise for people working in the project area. The project site is not located within the Airport Protection Area (APA) of the Livermore Airport (Livermore Executive Airport, Airport Land Use Compatibility Plan, 2012). The project is located within the Airport Influence Area (AIA) of the Livermore Airport, but the proposed expansion of uses are allowed in the AIA and would not cause a significant safety hazard. (f) Impair implementation of an emergency response plan or emergency evacuation plan No emergency evacuation plan would be affected since no roadways would be blocked or otherwise altered. (h) Expose people or structures to wildland fires As further discussed in the Wildfire section below, the project would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based 74 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 27 5/18/21 on the information in this environmental analysis, the project would result in less than significant impacts relating to hazards and hazardous materials. With adherence to applicable regulatory requirements, the project would result in less than significant impacts relating to hazards and hazardous materials s, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Hydrology and Water Quality ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 10. HYDROLOGY AND WATER QUALITY. Would the project: a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality? X b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?? X c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river through the addition of impervious surfaces, in a manner which would: X i) Result in substantial erosion or siltation on- or off- site? X ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite? X iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? X iv) Impede or redirect flood flows? X d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? X 75 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 28 5/18/21 ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for hydrology and water quality:  Impact 3.5/P identified significant impacts related to the supply of water to the Eastern Dublin area. Mitigation Measures 3.5/24.0-3.5/40.0 were adopted to prevent overdraft of ground water resources by requiring or encouraging annexation and connection to DSRSD, minimize the effect of additional demand for water by encouraging water recycling and conservation and by encouraging the development of new facilities and supplies, and to ensure the development of a water distribution system by generally preventing development until such facilities are constructed by developers.  Impact 3.5/Q noted that the EDSP would increase demand to serve development at build-out under the then-applicable General Plan and required an additional 25,000 acre-feet annually. Mitigation Measures 3.5/26.0 through 3.5/31.0 reduced the impact to an insignificant level.  Impact 3.5/V identified an impact due to flooding as a result of water storage reservoir failure but would be mitigated to an insignificant level by Mitigation Measure 3.5/41.0.  Impact 3.5/Y: Potential Flooding was found to be potentially significant but was reduced to an insignificant level by Mitigation Measures 3.5/44.0 through 3.5/48.0.  Impact 3.5/Z: Reduced Groundwater Recharge was a potentially significant impact but Mitigation Measures 3.5/49.0 and 3.5/50.0 reduced the impact to an insignificant level.  Impact 3.5/AA: Non-Point Sources of Pollution was found to be a potentially significant impact but was reduced to an insignificant level by Mitigation Measures 3.5/51.0 and 3.5/52.0. The 2005 Supplemental EIR identified potential impacts related to “cumulative stormwater generation/capacity of local channels” and “changes in non-point source water quality regulations.” Supplemental Mitigation Measures SM-SD-1 and SM-SD-2 were adopted to reduce these potential supplemental impacts to less than significant. SM-SD-1 required water quality and hydrologic design recommendations requiring implementation of bio- retention/filtration facilities with all subsequent individual development projects in the Fallon Village project area. SM-SD-2 required future individual development projects within the project area to comply with the storm water quality and hydromodification management 76 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 29 5/18/21 provisions of the Alameda Countywide Clean Water Program as administered by the City of Dublin. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Violate water quality or waste discharge requirements Any future development project will be required to be designed to treat all of its storm water runoff for water quality and hydromodification management to meet current Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, Provision C.3 requirements as prescribed in the Municipal Regional NPDES Permit issued by the San Francisco Bay Regional Water Quality Control Board. As a result, the project would meet the requirements of current RWQCB C.3 requirements, which are more stringent than those considered in the EDSP EIRs. (b) Substantially deplete or interfere with groundwater supplies Future water sources would rely on surface water supplies from the Dublin San Ramon Services District (DSRSD) and not local groundwater supplies. The project is required to support Zone 7’s groundwater recharge program to only pump groundwater it artificially recharges using its imported surface water or locally-stored runoff from Arroyo del Valley. Compliance with this would maintain groundwater at a no net loss for the Livermore Valley Groundwater Basin. As a result, the project would not result in a net increase in groundwater extraction from Livermore Valley Groundwater Basin. (c) Substantially alter existing drainage patterns Future development would not significantly change drainage patterns and proposed storm drain facilities would be adequately sized for project runoff. The project would incorporate and comply with the drainage system master planned improvements as they were designed and approved in the Dublin Ranch Drainage Master Plan with appropriate sizing and construction of downstream facilities such as the G3 Culvert Regional Conveyance facility constructed with the Dublin Ranch project, extended by the Fallon Village project. Future development would also be required to pay fees to the Dublin Ranch East Side Storm Drain Benefit District for construction of the downstream regional facilities. Per SM-SD-2, future development would also pay required Zone 7 Special Drainage fees (SDA-7-1) for regional storm drain facilities. (g) Inundation by seiche, tsunami, or mudflow The project site is not located near a major body of water that could result in a seiche. The risk of potential mudflow is considered low since no historic landslides or mudflows have been identified on the project site. There would be no impact with implementation of the project. 77 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 30 5/18/21 (h) Conflict with water quality control or groundwater management plan Future development would be required to incorporate and comply with the drainage system master planned improvements as they were designed and approved in the Dublin Ranch Drainage Master Plan. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified hydrology and water quality impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to hydrology and water quality beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Land Use and Planning ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 11. LAND USE AND PLANNING. Would the project: a) Physically divide an established community? X b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? X Previous CEQA Documents The EDSP EIRs identified the following impact for land use and planning:  Impact 3.1/A found that there were significant and unavoidable impacts from the EDSP as a result of the loss of agricultural and open space lands. No mitigation measures were identified for those impacts. The City adopted a Statement of Overriding Considerations for this significant and unavoidable impact, which includes the project. 78 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 31 5/18/21 Project Impacts and Mitigation Measures (a) Physically divide an established community Any future development would be a continuation of development in adjacent land uses. Allowed future uses would be compatible with the existing land uses and would not divide an established community. (b) Conflict with general plan The project site is located in the EDSP project boundary and would be consistent with environmental goals and policies contained in the City’s General Plan. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified land use and planning impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to land use and planning beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Mineral Resources ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 12. MINERAL RESOURCES. Would the project: a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? X b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? X Previous CEQA Documents The EDSP EIRs did not include an analysis of impacts to mineral resources. 79 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 32 5/18/21 Project Impacts and Mitigation Measures (a-b) Loss of known or identified mineral resource The City does not have any mineral extraction areas so there would be no new or substantially more severe significant impacts to mineral resources, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Conclusion Because the City does not have any mineral extraction areas, there would be no impact, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Noise ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 13. NOISE. Would the project result in: a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? X b) Generation of excessive groundborne vibration or groundborne noise levels? X c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for noise:  Impact 3.10/A: Exposure of Proposed Housing to Future Roadway Noise identified future vehicular traffic associated with development proposed in Eastern Dublin as potentially significant to future residents. This impact would be mitigated to an insignificant level through adherence to Mitigation Measure 3.10 / 1.0 that requires acoustic studies for all future residential development in the Eastern Dublin area. 80 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 33 5/18/21  Impact 3.10/B: Exposure of Existing Residences to Future Roadway Noise would be a potentially significant impact to existing residents in the Eastern Dublin area as development occurs in accord with the Eastern Dublin General Plan Amendment and Specific Plan. This impact would be reduced through adherence to Mitigation Measure 3.10 I 2.0, which requires future development projects to provide noise protection to existing residential uses in Eastern Dublin; however, noise impacts to existing residents along Fallon Road would remain significant and unavoidable.  Impact 3.10/ C: Exposure of Existing and Proposed Development to Airport Noise was considered an insignificance impact and no mitigation was required.  Impact 3.10/D: Exposure of Proposed Residential Development to Noise from Future Military Training Activities at Parks Reserve Forces Training Area (RFTA) and the County Jail identified potentially significant noise for future residents within 6,000 feet of Parks RFTA. This impact would be reduced through adherence to Mitigation Measure 3.10/3.0 that requires acoustic studies for development near Parks RFTA and the County Jail; however, reduction of noise from Parks RFTA may not be feasible, so this impact would be significant and unavoidable.  Impact 3.10/E: Exposure of Existing and Proposed Residences to Construction Noise would be a potentially significant impact related to noise associated with construction of the EDSP, including but not limited to buildings, roads, and utilities. Adherence to Mitigation Measures 3.10/4.0 and 3.10/5.0 would reduce construction noise impacts to a level of insignificance through preparation and submittal of Construction Noise Management Plans and compliance with local noise standards.  Impact 3.10/F: Noise Conflicts due to the Adjacency of Diverse Land Uses Permitted by Plan Policies Supporting Mixed-Use Development would result from close proximity of different land use types that may result in potentially significant impacts. Mitigation Measure 3.10 /6.0 requires the preparation of noise management plans for all mixed- use developments within the Eastern Dublin area. This measure would reduce noise generated by mixed-use development to a level of insignificance. The City adopted a Statement of Overriding Considerations for the significant unavoidable impacts described above, which includes the project. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Exposure to or generate noise exceeding standards The EDSP EIRs identified the sources of major noise affecting the EDSP area to be vehicular traffic stemming from Interstate 580, aircraft flyovers from the Livermore Municipal Airport, Parks RFTA, and County Jail. The short-term noise measurement results noted that other than site grading associated with the construction of the development the roadway noise and aircraft flyovers would dominate any noise levels generated by the project. 81 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 34 5/18/21 (b) Exposure to ground borne vibration or ground borne noise The EDSP EIRs identified a potentially significant impact for future roadway noise as well as construction noise as a result of the build out of the EDSP, which includes the project site. Implementation of mitigation measures within the EDSP EIRs reduces this impact to an insignificant level. (c) Excessive noise level near a public or private airport The project would not result in safety hazard or excessive noise for people working or living in the project area. A portion of the project site is located within the Airport Influence Area of Livermore Municipal Airport, but is not located within the Airport Protection Area (APA) of the airport (Livermore Executive Airport, Airport Land Use Compatibility Plan, 2012). Therefore, the project site would not be subjected to substantial aircraft noise from this airport different from that previously analyzed. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified noise impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to noise beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Population and Housing ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 14. POPULATION AND HOUSING. Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? X b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? X 82 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 35 5/18/21 Previous CEQA Documents The EDSP EIRs did not identify any significant impacts or mitigation measures for population and housing. Project Impacts and Mitigation Measures (a) Population growth While the broadening of allow uses could result in an increase of residential development, it is only a total of 4.5 acres and as such, would not induce substantial additional population growth in the Eastern Dublin area which has long been envisioned in the Dublin General Plan and the EDSP. (b) Housing and resident displacement Since the project site is vacant, no housing units or people would be displaced as a result of the project. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified population and housing impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to population and housing beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Public Services ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 15. PUBLIC SERVICES. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities or need for new or physical altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services: a) Fire protection? X b) Police protection? X c) Schools? X 83 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 36 5/18/21 ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs d) Parks? X e) Other public facilities? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for public services:  Impacts 3.4/A and 3.4/B are related to the provision of police services. One notes that there would be a demand for increased police services with implementation of the Eastern Dublin General Plan Amendment and Specific Plan and the other identifies an impact related to the hilly topography of the Eastern Dublin area that could present accessibility and crime-prevention issues. Adherence to Mitigation Measures 3.4/1.0 through 3.4/ 5.0 would reduce impacts to the Dublin Police Department to an insignificant level.  Impacts 3.4/C through 3.4/E are related to the provision of fire services. The build out of the GP/EDSP would increase the demand for fire services and the outlying areas of the GP/EDSP were beyond the fire response area at the time resulting in extended fire response times. The build out of the GP/EDSP would also result in the settlement of population and construction of new communities in proximity to high fire hazard open space areas. This would pose an increasing wildfire hazard to people and property if open space areas are not maintained for fire safety. Mitigation Measures 3.4/6.0 through 3.4/13.0 reduce these impacts to an insignificant level.  Impacts 3.4/F through 3.4/J are related to schools. The buildout of the GP/EDSP will increase the demand for new classroom space and school facilities in proportion to the number of residential units constructed, far exceeding the current available capacity of either school district at the time. Overcrowding at existing schools could occur if insufficient new classroom space is provided. Development of eastern Dublin under existing jurisdictional boundaries would result in the area's being served by two different school districts. The division of the project site by two different school districts would adversely affect financing of schools in eastern Dublin and complicate provision of education to planning area students. The cost of providing new school facilities proposed in the General Plan Amendment and Specific Plan could adversely impact local school districts by creating an unwieldy financial burden unless some form of financing is identified. Mitigation Measures 3.4/13.0 through 3.4/19.0 reduce these impacts to an insignificant level.  Impacts 3.4/K through 3.4/N are related to parks and public facilities. Without the addition of new parks and facilities, the increased demand for new park and recreation facilities resulting from buildout of the GP/EDSP would create potentially significant impacts. Acquisition and improvement of new park and recreation facilities may place a 84 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 37 5/18/21 financial strain on existing City revenue sources causing a potentially significant impact. Development of residential and commercial areas in eastern Dublin without adequate provision of trail easements may thwart efforts to develop a regional trail system. Urban development along project stream corridors and ridgelines would adversely impact outdoor recreational opportunities for future Dublin residents and obstruct the formation of an interconnected open space system. Mitigation Measures 3.4/20.0 through 3.4/36.0 would reduce this impact to an insignificant level. The 2005 Supplemental EIR analyzed the adequacy of park acreage within the Fallon Village project area and found it to be consistent with the number, size and locations of parks within the program level Stage 1 PD and with the City of Dublin Parks and Recreation Master Plan. The project would be required to adhere to applicable mitigation measures as set forth in the EDSP EIRs. Project Impacts and Mitigation Measures (a) Fire Future development would increase demand for fire and emergency services by increasing the amount of permanent daytime population on the project site. Features would be incorporated into the project as part of existing City ordinances and development requirements which assist in reducing impacts. These features include installation of on-site fire protection measures such as fire sprinklers and installation of new fire hydrants that meet the minimum fire flow requirements contained in the Uniform Building Code and Uniform Fire Code. As part of the City’s Development Fee Program, any future development project would be required to pay an impact fee for fire facilities to serve new development in the City. This impact fee relates to funding new fire facilities in Eastern Dublin, ensuring adequate water supplies and pressure for fire suppression, and minimizing wildland fire hazards. (b) Police Incremental increases in the demand for police service could be expected associated with a future development project. This increase in calls for service would be off-set through adherence to City of Dublin safety requirements from the Dublin Police Services. (c) Schools No new impacts to school service are anticipated since payment of mandated statutory impact fees at the time of issuance of building permits would provide mitigation of educational impacts of the project pursuant to State law. (d, e) Parks and other public facilities Future development would be required to comply with all prior mitigation measures and, if applicable, would pay the required Park Fee as part of the Public Facility fees. 85 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 38 5/18/21 Construction associated with future development would incrementally increase the long-term maintenance demand for roads and other public facilities. However, such additional maintenance demands would be off-set by additional City fees and property tax revenues accruing to the City and, therefore, impacts would be less-than-significant. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified public services impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to public services beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Recreation ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 16. RECREATION. Would the project: a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? X b) Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for recreation:  Impact 3.4/K indicated that increased demand for parks as a result of buildout of the GP/EDSP would represent a significant impact on the ability of the City to provide park service for future residents. It would also be a potentially significant cumulative impact for the community due to lack of sufficient city-wide park facilities that would not meet a standard of five acres of parkland per 1,000 population. Mitigation Measures 3.4/20.0- 28 were included in the Eastern Dublin EIR to reduce this impact to an insignificant level.  Impact 3.4/L identified a park facility fiscal impact on the City of Dublin. The fiscal strain of providing new park facilities would be a potentially significant impact. Mitigation 86 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 39 5/18/21 Measures 3.4/ 29.0-31.0 would require that each new development in Eastern Dublin provide a fair share of parks and open space facilities. Development of a parks implementation plan was also called for. Finally, adoption of a park in-lieu fee program was required. These mitigation measures reduce this impact to an insignificant level.  Impacts 3.4/ M and N dealt with the regional trail system and open space connections. Development of residential and commercial areas in Eastern Dublin was anticipated to have a potentially significant impact to the construction of a regional trail system. Adherence to Mitigation Measure 3.4/ 32.0 would require the establishment of a trail system with connections to planned regional and sub-regional trails, which would reduce this impact to an insignificant level.  Impact 3.4/N notes that urban development along stream corridors and ridgelines would adversely impact outdoor recreational opportunities for future Dublin residents and potentially obstruct the formation of an interconnected open space system. Mitigation Measures 3.4 / 33.0-36.0 would reduce this impact to an insignificant level. The project would be required to adhere to applicable mitigation measures as set forth in EDSP EIRs. Project Impacts and Mitigation Measures (a, b) Increase the use of existing recreation facilities causing deterioration or require new recreation facilities The City’s park and recreational facilities are composed of neighborhood facilities, community facilities, community parks and community center. The EDSP identified 46.8 acres of parkland for the Fallon Ranch project area which is consistent with the City of Dublin 2015 Parks and Recreation Master Plan ratio of 5.0 acres of parkland per 1,000 residents. Because sufficient park land has been constructed and it being planned, future development associated with the project site would not increase the use of existing neighborhood and/or regional parks such that a substantial physical deterioration of the facility would occur or be accelerated; nor would it require the construction/expansion of a recreational facility elsewhere which would have an adverse physical effect on the environment. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified recreation impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to recreation beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 87 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 40 5/18/21 Transportation ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 17. TRANSPORTATION. Would the project: a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? X b) Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?? X c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? X d) Result in inadequate emergency access? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for transportation and traffic:  Impacts 3.3/A through 3.3/E identified significant, significant cumulative, and significant and unavoidable adverse impacts related to daily traffic volumes on I-580 for Year 2010 with and without build-out of the GP/EDSP and under a Year 2010 cumulative build-out scenario. Mitigation Measures 3.3/1.0 through 3.3/5.0 reduced these impacts but not sufficiently to avoid significant cumulative impacts.  Impacts 3.3/F through 3.3/N identified impacts to levels of service and PM peak hour traffic volumes at 18 intersections and at I-580 ramps. Mitigation Measures 3.3/6.0 through 3.3/8.0 and 3.3/10.0 through 3.3/14.0 were adopted to reduce these impacts. Impacts 3.3/I, 3.3/M and 3.3/N were unable to be reduced to an insignificant level.  Impacts 3.3/O and 3.3/P identified significant impacts related to transit service extensions and the provision of safe street crossings for pedestrians and bicycles. Mitigation Measures 3.3/15.0-15.3 and 3.3/16.0-16.1 were adopted which reduced these impacts to a level of insignificance. The City adopted a Statement of Overriding Considerations for the remaining significant and unavoidable cumulative impacts of Impacts 3.3/B, 3.3/E, 3.3/I, 3.3/M and 3.3/N, which apply to the project. 88 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 41 5/18/21 The project would be required to adhere to applicable mitigation measures as set forth in EDSP EIRs. Project Impacts and Mitigation Measures (a) Conflict with applicable transportation circulations plans/standards As described in Appendix A: Traffic Generation Evaluation Memorandum (Kimley-Horn, April 9, 2021), a trip generation evaluation was prepared to determine if the proposed change in land uses would potentially result in a transportation impact. The evaluation compared vehicle trips generated by the highest intensity land use under the Semi-Public land use designation (a day care center and a recreational community center) to the likely use of the Public/Semi-Public land use (an affordable housing project). As shown in Table 2: Trip Generation Comparison Summary, the new Public/Semi-Public use would not exceed the existing highest trip generating land uses and, therefore, the proposed GPA, SPA and Rezoning would not result in any significant transportation impacts. Table 2: Trip Generation Comparison Summary GPA/SPA Use ITE Land Use Code Land Use Size Units AM Peak Hour PM Peak Hour Semi-Public 565 Day Care Center 10 KSF 110 111 495 Recreational Community Center 88.01 KSF 155 203 - Subtotal 98.01 KSF 265 314 Public/Semi-Public 223 Affordable Housing (Income Limits) 135 Dwelling Units 138 84 Difference (Public/Semi-Public – Semi-Public) -127 -230 It should also be noted that a residential density of 40 units per acre was also considered as the upper range in density for this site. At this density, 40 residential units per acre for 4.5 acres would result in a total of 180 residential units. This number of units would generate an estimated 184 AM peak hour trips and 112 PM peak hour trips. At this density, affordable housing would still result in fewer AM and PM peak hour trips than the Semi-Public scenario. (b) Conflict with CEQA Guidelines Section 15064.3 Since certification of the EDSP EIRs, the issue of vehicle miles traveled (VMT) has become a more prominent issue of concern as evidenced by passage of SB 743 in 2013. Previously, CEQA analysis was conducted using a level of service (LOS) measurement that evaluated traffic delay. As specified under SB 743, and implemented under Section 15064.3 of the State CEQA Guidelines (effective December 28, 2018), VMT is the required metric to be used for identifying CEQA impacts and mitigation. In December 2018, OPR published a Technical Advisory on Evaluating Transportation Impacts, including guidance for VMT analysis. The Office of 89 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 42 5/18/21 Administrative Law approved the updated CEQA Guidelines and lead agencies were given until July 1, 2020, to implement the updated guidelines for VMT analysis. Because EDSP EIRs have been certified, the determination of whether VMT needs to be analyzed for this project is governed by the law on supplemental or subsequent EIRs (Public Resources Code section 21166 and CEQA Guidelines, Sections 15162 and 15163). VMT is not required to be analyzed under those standards unless it constitutes "new information of substantial importance, which was not known and could not have been known at the time the previous EIRs were certified as complete” (CEQA Guidelines Sec. 15162 (a) (3)). VMT impacts were not analyzed in the prior EIRs; however, these impacts are not new information that was not known or could not have been known at the time these previous EIRs were certified. The issue of VMT as a metric for analyzing traffic was widely known prior to the certification of these EIRs. Therefore, the impact of VMT was known at the time of the certification of the EDSP EIRs. Under CEQA standards, it is not new information that requires analysis in a supplemental EIR or Negative Declaration. No supplemental environmental analysis of the project's impacts on this issue is required under CEQA. (c) Substantially increase hazards due to a design feature Future development of the project site would add sidewalks and other vehicular and pedestrian travel ways where none currently exist and would be required to comply with current City engineering design standards and other safety standards to ensure that no safety hazards would be created or exacerbated. (d) Result in inadequate emergency access Future development of the project site would be required to go through Stage 2 Planned Development application, which would ensure that all roadways would be designed consistent with City roadway design standards. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified transportation impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to transportation beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 90 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 43 5/18/21 Tribal Cultural Resources ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 18. TRIBAL CULTURAL RESOURCES. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or X b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. X Previous CEQA Documents The EDSP EIRs did not specifically analyze impacts to tribal cultural resources as it was not a separate topic for analysis when the EIRs were completed. Cultural resource impacts and mitigation measures, some of which could pertain to tribal resources, were identified and can be found in the cultural resources section of this document. Project Impacts and Mitigation Measures (a) Listed or eligible for listing in the California Register of Historical Resources Both project sites are vacant and, therefore, there would be no impact to historic resources. (b) Significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1 The project is subject to existing cultural resource mitigation measures, as described above in Cultural Resources section. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on this environmental analysis, the project would not result in new significant impacts to tribal cultural resources. 91 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 44 5/18/21 With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts to tribal cultural resources beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Utilities and Service Systems ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 19. UTILITIES AND SERVICE SYSTEMS. Would the project: a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? X b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? X c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project projected demand in addition to the provider’s existing commitments? X d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? X e) Comply with federal, state, and local statutes and regulations related to solid waste? X Previous CEQA Documents The EDSP EIRs identified the following impacts and mitigation measures for utilities and service systems:  Impact 3.5/B identified the lack of a collection system as a significant impact. Mitigation Measures 3.5/1.0-3.5/5.0, generally preventing development until such facilities are constructed by developers, were adopted to mitigate this impact to an insignificant level. 92 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 45 5/18/21  Impact 3.5/C noted potential growth-inducing impacts of pipeline construction. These impacts were mitigated by Mitigation Measure 3.5/6.0, preventing the construction of facilities greater than those required for the GPA/EDSP, to an insignificant level.  Impacts 3.5/D, 3.5/E and 3.5/G identified current and future inadequate treatment plant capacity in DSRSD's treatment plan and inadequate disposal capacity as significant impacts. All were mitigated to an insignificant level by Mitigation Measures 3.5/7.0 through 3.5/9.0 and 3.5/11.0 through 3.5/14.  Impacts 3.5/F and 3.5/H relate to the increased energy usage as a result of Impacts 3.5/D, E, and G. Both were mitigated by Mitigation Measures 3.5/10.0, 3.5/15.0 and 3.5/16.0 but remained significant and unavoidable impacts  Impact 3.5/I noted that a failure of the export disposal system could have a potentially significant impact but Mitigation Measure 3.5/17.0 reduce this impact to an insignificant level.  Impact 3.5/L noted that the proposed recycled water system must be constructed and operated properly in order to prevent any potential contamination of or cross- connection with potable water supply systems. Mitigation Measure 3.5/20.0 reduced this impact to an insignificant level.  Impact 3.5/P identified significant impacts related to the supply of water to the Eastern Dublin area. Mitigation Measures 3.5/24.0-3.5/40.0 were adopted to prevent overdraft of ground water resources by requiring or encouraging annexation and connection to DSRSD, minimize the effect of additional demand for water by encouraging water recycling and conservation and by encouraging the development of new facilities and supplies, and to ensure the development of a water distribution system by generally preventing development until such facilities are constructed by developers.  Impact 3.5/Q noted that buildout of the GP/EDSP will increase water demand. Mitigation Measures 3.5/26.0 through 3.5/31.0 reduced this impact to an insignificant level.  Impact 3.5/R noted that there would be a significant impact since the increase in water demands through development of the GP/EDSP will require an expansion of existing water treatment facilities in order to deliver safe and potable water. Mitigation Measures 3.5/32.0 and 33.0 reduced this impact to an insignificant level.  Impact 3.5/S noted that at the time there was no water service in the area, with the exception of a Zone 7 water supply connection to Alameda County for the old Santa Rita Jail. With the development of the GP/EDSP, a water distribution system and storage system would be required. If a water distribution system was not constructed, this would be a significant impact. Mitigation Measures 3.5/34.0 through 3.5/38.0 reduced this impact to an insignificant level.  Impact 3.5/U accounted for the increased energy requirement as a result of increased water demands requiring a water distribution system. Mitigation Measure 3.5/40.0 mitigated this impact but was insufficient to reduce the impact to a less than potentially significant level. 93 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 46 5/18/21  Impact 3.5/Z: Reduced Groundwater Recharge was a potentially significant impact but Mitigation Measures 3.5/49.0 and 3.5/50.0 reduced the impact to an insignificant level. The City of Dublin adopted a Statement of Overriding Considerations for Impacts 3.3/F and H, which includes the project. The 2005 Supplemental EIR analyzed supplemental impacts of wastewater collection and disposal capacity as changed conditions since the 2002 Supplemental EIR. There were found to be no supplemental impacts to wastewater collection based on the latest 2005 Wastewater Collection System Master Plan Update by the Dublin San Ramon Services District (DSRSD) using the latest sewer generation rates and long-term wastewater planning. Wastewater disposal capacity was found to be adequate based on completion of a 2005 Livermore-Amador Valley Water Management Agency export pipeline expansion project and no supplemental impacts were found with regard to wastewater disposal. The project would be required to adhere to applicable mitigation measures as set forth in Eastern Dublin General Plan and Specific Plan EIR. Project Impacts and Mitigation Measures (a, c) Wastewater treatment requirements and facilities DSRSD is the water and sewer provider for the project site. DSRSD has master planned the wastewater collection system, treatment capacity and disposal capacity in accordance with the General Plan and EDSP demand levels as documented in the latest 2017 Wastewater Collection System and Treatment Facilities Master Plans. The project is included within the build out of the GP/EDSP and, therefore, accounted for. Connection fees are based on these master plans and also account for the proposed level of development on the project site. Previous potential impacts due to growth inducing system expansion no longer apply as the project is located at the far eastern edge of DSRSD’s service area and would not require expansion of the system. Therefore, no supplemental impacts have been identified. (b) Sufficient water supplies DSRSD has master planned their water supply capacity, water distribution system, reservoirs and pumping in the project area in accordance with the General Plan and EDSP demand levels as documented in the current Urban Water Management Plan (2016). Connection fees are based on these master plans and account for the proposed level of development on the project site. Therefore, no supplemental impacts have been identified. Per SB221, the project would be required to obtain written verification from DSRSD that sufficient water supply is available for the project. Previous potential impacts due to growth inducing system expansion no longer apply as the project site is located within DSRSD’s service area. 94 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 47 5/18/21 (d, e) Solid waste disposal and regulatory compliance Approval of the project would incrementally increase the generation of solid waste. Over the long term, the amount of solid waste reaching the landfill would decrease as statewide regulations mandating increased recycling take effect. The EDSP EIRs found that there would be adequate capacity within the local landfill to accommodate increases in the amount of solid waste. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified utilities and service system impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements and mitigation measures, there would be no new or substantially more severe significant impacts to utilities and service systems beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. Wildfires ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 20. Wildfires. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project: a) Substantially impair an adopted emergency response plan or emergency evacuation plan?? X b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? X c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment X d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? X 95 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 48 5/18/21 Previous CEQA Documents The EDSP EIRs did not specifically analyze impacts of wildfires as it was not a separate topic for analysis when the EDSP EIRs were completed. Public services impacts and mitigation measures, some of which related to the provision of fire services pertain to wildfires, were identified and are discussed in the Public Services section. The project would be required to adhere to applicable mitigation measures as set forth in EDSP EIRs. Project Impacts and Mitigation Measures (a) Impair emergency response plan In accordance with the City’s Wildfire Management Plan and Chapter 7.32 of the Dublin Municipal Code, all residential lots adjacent to open space shall be constructed with special materials and have a 20-foot-wide emergency access road behind them in the buffer zone. (b) Pollutants or uncontrolled spread Future development would be required to comply with Stage 2 Planned Development application requirements which would minimize the risk that any pollutant concentrations or wildfire risk as a result of slope, prevailing winds, or other factors that exacerbate wildfire risks could occur beyond what was analyzed in the EDSP EIRs. (c) Infrastructure Future development would be required to comply with Stage 2 Planned Development application requirements which would ensure that all infrastructure is constructed according to the latest City and State fire code requirements. (d) Slope instability resulting in post-fire slope instability As discussed in the Hydrology and Water Quality section, the project includes an erosion control plan that implements slope erosion control measures during and post-construction and does not change historic drainage patterns outside of the project site. The project would not result in changes to drainage or slopes beyond what was previously analyzed in the EDSP EIRs. Conclusion The project does not propose substantial changes to the land uses for the project sites than were previously analyzed in the EDSP EIRs that would require major changes to the EIRs. Based on the information in EDSP EIRs and this environmental analysis, the project would not substantially increase the severity of the previously identified wildfire impacts, nor result in new significant impacts. With adherence to applicable regulatory requirements, there would be no new or substantially more severe significant impacts from wildfires beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 96 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 49 5/18/21 Mandatory Findings of Significance ENVIRONMENTAL IMPACTS Issues New Significant Impact Substantial Increase in the Severity of an Impact Identified in the EDSP EIRs Equal or Less Severe Impact than Identified in the EDSP EIRs 21 MANDATORY FINDINGS OF SIGNIFICANCE. Does the project: a) Have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? X b) Have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of the past projects, the effects of other current projects, and the effects of probable future projects.) X c) Have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? X a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? No New Impact. As discussed and analyzed in this document, the proposed project would not degrade the quality of the environment. Additionally, for the reasons discussed in Biological Resources, the proposed project, with mitigation, would not substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, or reduce the number or restrict the range of a rare or endangered plant or animal. Further, for the reasons identified in Cultural Resources, the project site does not contain any significant cultural resources, and no impacts to such resources would occur. Therefore, implementation of the proposed project would not result in any new impacts or increase the severity of a previously identified significant impact as 97 City of Dublin Semi-Public Sites GPA/SPA/RZ CEQA Initial Study | Page 50 5/18/21 previously analyzed, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required for this impact area. b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? No New Impact. The proposed project has the potential to result in incremental environmental impacts that are part of a series of approvals that were anticipated under the Eastern Dublin EIR. The Eastern Dublin EIR considered the project’s cumulatively considerable impacts where effects had the potential to degrade the quality of the environment as a result of build-out of the Eastern Dublin Specific Plan. The implementation of the proposed project, with mitigation, would not result in any new cumulative impacts or increase the severity of a previously identified significant cumulative impact as previously analyzed, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required for this impact area. c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? No New Impact. The proposed project would not create adverse environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly. The proposed project would allow for the conversion an existing vacant site to an urban use, specifically the construction of two low to mid-rise (3-story and 5-story) R&D buildings, a parking structure, surface parking, and related improvements, including landscaping. None of these uses or activities would result in any substantial adverse effects on human beings, either directly or indirectly, as discussed throughout this document. Therefore, implementation of the proposed project would not result in any new impacts or increase the severity of a previously identified significant impact as previously analyzed, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required for this impact area. 98 kimley-horn.com 824 Bay Avenue, Suite 10, Capitola, CA 95010 831 316 1430 MEMORANDUM May 25, 2021 TO: Michael P. Cass, Principal Planner, City of Dublin Pratyush Bhatia, Transportation and Operations Manager, City of Dublin FROM: Bill Wiseman and Ben Huie, Kimley-Horn & Associates, Inc. RE: Trip Generation Evaluation for the Semi-Public Sites GPA – CEQA Analysis Kimley-Horn is preparing the California Environmental Quality Act (CEQA) analysis for a City- initiated General Plan Amendment (GPA) and Eastern Dublin Specific Plan Amendment (SPA) and Rezoning (RZ) for 2.5 acres on the GH PacVest property and 2.0 acres on the East Ranch property in eastern Dublin, CA. This study evaluates the potential transportation impacts associated with changing the existing General Plan land use designation for the two sites from Semi-Public to Public/Semi-Public to allow a broader range of uses, including the potential for affordable housing developed by a non-profit entity. The purpose of this memorandum is to determine if the change in land use designation would result in additional vehicles trips generated and, consequently, a potential transportation impact. Project Description The proposed GPA, SPA, and RZ would occur on 2.5 acres on the GH PacVest property and 2.0 acres on the East Ranch property in Eastern Dublin, CA. Both sites are located within the Eastern Dublin Specific Plan (EDSP) area. Prior CEQA analysis includes: 1) the East Dublin General Plan and Specific Plan EIR (1993), 2) the Fallon Village Supplemental EIR (2002), and 3) the Fallon Village Supplemental EIR (2005). Collectively, these three environmental review documents are referred to as the “EDSP EIRs.” This project tiers off of these previous EDSP EIRs which, at that time, significant impacts related to transportation were based on level of service (LOS) and not vehicle miles traveled (VMT). Therefore, this transportation evaluation focuses on vehicle trips generated, and not VMT. Appendix A 99 Michael Cass City of Dublin Page 2 According to the City’s General Plan, the Semi-Public land use designation and the Public/Semi-Public land use designation allows multiple land uses at a maximum floor-area ratio (FAR) of 0.50 and an employee density of 590 square feet per employee. Table 1: General Plan Comparison of Semi-Public and Public/Semi-Public Uses shows a comparison of the allowed uses between the two land use designations. Table 1: General Plan Comparison of Semi-Public and Public/Semi-Public Allowed Land Uses Land Use Semi-Public Public/Semi- Public Public schools X Libraries X City office buildings X State, County, and other public agency facilities X Post offices X Fire stations X Utilities X Dublin Civic Center X Childcare centers X X Youth centers X X Senior centers X X Special needs program facilities X X Religious institutions X X Clubhouses X X Community centers X X Community theatres X X Hospitals X X Private schools X X Other facilities that provide cultural, educational, or other similar services and benefit the community X X Housing developed by a non-profit entity and serves to meet affordable housing needs or the housing needs of an underserved economic segment of the community X In particular, development of affordable housing on a site designated on the General Plan Land Use Map as Public/Semi-Public Facilities shall be considered consistent with the General Plan when it is developed by a non-profit entity and serves to meet affordable housing needs or the housing needs of an underserved economic segment of the community. Trip Generation Evaluation 100 Michael Cass City of Dublin Page 3 To determine if the change in land uses would potentially result in a transportation impact, the vehicle trips generated by the highest intensity land use under the Semi-Public land uses was compared to the likely use of the Public/Semi-Public land use. To estimate the number of trips generated by each land use, Kimley-Horn utilized the appropriate trip generation rates published in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 10th Edition (2017). To estimate the land use sizes, it was assumed that the sum of the two parcels (i.e., 4.5 acres) would be developed at the maximum floor area ratio (FAR) of 0.5. This results in a building area of 98.01 thousand square feet (KSF). For the school uses, it was assumed that each parcel could construct a school of up to 300 students each. The daily, AM peak hour, and PM peak hour trip generation for each of the Semi-Public land uses is shown in Table 1: Estimated Trip Generation for Semi-Public Uses. Table 1: Estimated Trip Generation for Semi-Public Uses ITE Land Use Code Land Use Size Units Daily Trips AM Peak PM Peak Total In Out Total In Out 495 Recreational Community Center 98.01 KSF 2,826 172 114 58 226 106 120 534 Private School (K-8) 600 Students 2,466 546 300 246 156 72 84 536 Private School (K-12) 600 Students 1,488 480 293 187 102 44 58 560 Church 98.01 KSF 682 32 19 13 48 22 26 565 Day Care Center 98.01 KSF 4,668 1,078 561 517 1,090 512 578 610 Hospital 98.01 KSF 1,052 87 59 28 95 30 65 620 Nursing Home 98.01 KSF 652 54 42 12 58 24 34 Maximum Trip Generator = Day Care Center 4,668 1,078 561 517 1,090 512 578 As shown, a day care center results in the highest number of daily, AM peak hour, and PM peak hour trips with 4,668 daily trips, 1,078 AM peak hour trips, and 1,090 PM peak hour trips. However, since the maximum size of the day care centers that were surveyed for the ITE Trip Generation Manual was approximately 10 KSF, it was unrealistic to assume a 98.01 KSF day care center for this evaluation. Therefore, the size of the day care center was limited to 10 KSF and the remaining 88.01 KSF was assumed to be a recreational community center. It should be noted that the average size of the recreational community centers surveyed in the ITE Trip Generation Manual was approximately 78 KSF square feet and therefore this is a realistic evaluation. The trip generation for this scenario is shown in Table 2: Estimated Trip Generation for Day Care Center and Recreational Community Center. This scenario would result in 265 AM peak hour trips and 314 PM peak hour trips. 101 Michael Cass City of Dublin Page 4 Table 2: Estimated Trip Generation for Day Care Center and Recreational Community Center ITE Land Use Code Land Use Size Units Daily Trips AM Peak PM Peak Total In Out Total In Out 495 Recreational Community Center 88.01 KSF 2,538 155 102 53 203 95 108 565 Day Care Center 10 KSF 478 110 57 53 111 52 59 Maximum Trip Generator = Day Care Center 3,220 265 159 106 314 147 167 For the proposed Public/Semi-Public land uses, it was assumed that the land use would be affordable housing. To estimate the size of the affordable housing for both parcels combined, a density of 30 residential units per acre for 4.5 acres was assumed, resulting in a total of 135 residential units. Using ITE Trip Generation Manual, 10th Edition, land use code 223 for Affordable Housing (Income Limits) was assumed. This land use is estimated to generate 138 AM peak hour trips and 84 PM peak hour trips. No daily trip information for this land use is provided in the Trip Generation Manual, 10th Edition. Table 3: Trip Generation Comparison Summary shows a peak hour trip comparison for the allowed Semi-Public use versus the likely land use for the Public/Semi-Public. The new Public/Semi-Public use would not exceed the existing highest trip generating land use and, therefore, the proposed GPA, SPA and Rezoning would not result in any significant transportation impacts. Table 3: Trip Generation Comparison Summary GPA/SPA Use ITE Land Use Code Land Use Size Units AM Peak Hour PM Peak Hour Semi-Public 565 Day Care Center 10 KSF 110 111 495 Recreational Community Center 88.01 KSF 155 203 - Subtotal 98.01 KSF 265 314 Public/Semi-Public 223 Affordable Housing (Income Limits) 135 Dwelling Units 138 84 Difference (Public/Semi-Public – Semi-Public) -127 -230 It should also be noted that a residential density of 40 units per acre was also considered as the upper range in density for this site. At this density, 40 residential units per acre for 4.5 acres would result in a total of 180 residential units. Using ITE Trip Generation Manual, 10th Edition, land use code 223 for Affordable Housing (Income Limits) was assumed. This land use is estimated to generate 184 AM peak hour trips and 112 PM peak hour trips. At this 102 Michael Cass City of Dublin Page 5 density, affordable housing would still result in fewer AM and PM peak hour trips than the Semi-Public scenario. Conclusion The proposed GPA, SPA, and RZ of parcels from Semi-Public to Public/Semi-Public would not result in any new or substantially more severe significant impacts to transportation beyond what has been analyzed in the previous EDSP EIRs, and no other CEQA standards for supplemental review are met. Therefore, no further environmental review is required. 103