HomeMy WebLinkAboutReso 035-00 GPA/EDSP FGHRESOLUTION NO. 35 - 00
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
APPROVING A GENERAL PLAN AMENDMENT AND AN AMENDMENT TO
THE EASTERN DUBLIN SPECIFIC PLAN FOR DUBLIN RANCH 'AREA F' (PA 98-068),
'AREA G' (PA 98-069) AND 'AREA H' (PA 98-070)
WHEREAS, Martin Inderbitzen, representing property owner Jennifer Lin et. al, has requested
approval to amend portions of the General Plan and the Eastern Dublin Specific Plan, which would:
Relocate various land uses and acreages within Areas F, G and H of Dublin Ranch on land
generally located east of Tassajara Road and North ofi-580 within the Eastern Dublin Specific
Plan area (APN: 985-0005-001,985-0005-002) as shown on Exhibits A and B: General Plan and
Eagtern Dublin Specific Plan Land Use Map and Eastern Dublin Specific Plan Planning Subareas
Map. Land use changes include relocating all of the Medium High Density Residential, High
Density Residential, and Neighborhood Commercial uses within Area F to Area G. These three
land uses would be replaced with Medium Density Residential uses within Area F. The
Neighborhood Commercial uses which are currently shown along both sides of Central Parkway
(previously the "Transit Spine") would be relocated to Area G and reoriented in a north-south
direction between Dublin Boulevard and Central Parkway along Main Street.
.
Amend text in the Land Use element of the General Plan and Eastern Dublin Specific Plan to
delete references to the '°transit Spine" and replace it with either "Central Parkway" or "Main
Street" as appropriate, in accordance with Resolution No. 77-97. This Resolution was approved
by the City Council on June 17, 1997 to amend the circulation element of the General Plan and
Eastern Dublin Specific Plan. This Amendment reclassified the "Transit Spine" from a transit-
oriented corridor to an east-west arterial and renamed it "Central Parkway" (Exhibit C: EDSP
Text Amendments).
Amend text in the General Plan and Eastern Dublin Specific Plan, to allow Campus Office uses be
developed on 10.5 acres of land designated for General Commercial uses within the south-west
quadrant of Area H, pursuant to a Stage 2 Planned Development (PD) Rezone (Exhibits C and D:
EDSP and GP Text Amendments).
4. Update Appendix 4 "Eastern Dublin Specific Plan Land Use Summary By Land Owner", #19
Pao-Lin (also know as Areas F, G and H, now owned by Jennifer Lin et al) (Exhibit E).
WHEREAS, a complete application for this project is on file with the Dublin Planning Department;
and
WHEREAS, the potential environmental effects of the proposed project have been previously
addressed in the Eastern Dublin Specific Plan EIR (SCH No. 91-103064); and
WltERES, individUal Initial Studies have been prepared for each of the three Dublin Ranch Areas
(Area F - SCH No.99112040, Area G - SCH No.99112041 and Area H - SCH No.99112042) to evaluate
site-specific impacts of the project (to a greater level of detail than in the Program EIR) pursuant to CEQA
guidelines Section 15168. Based on the three Initial Studies, a Mitigated Negative Declaration and
Mitigated Monitoring Program has been prepared for each area with the finding that with the
implementation of Mitigation Measures previously adopted for the Program EIR and with site specific
Mitigation Measures contained in the Initial Studies, as further clarified by the Response to Comments, the
potential site-specific impacts of the projects would be reduced to a level of insignificance. The Program
EIR and Initial Studies adequately describe the impacts of the project, and there have been no substantial
changes or new information that would be outside the scope of the Program EIR; and
WItEREAS, the Planning Commission did hold a properly noticed public hearing on said
application on December 14, 1999, January 11, 2000 and January 25, 2000 and did adopt a Resolution
recommending that the City Council approve a General Plan Amendment and an Amendment to the
Eastern Dublin Specific Plan for Area F (PA 98-068), Area G (PA 98-069) and Area H (PA 98-070);.
and
WItEREAS, a properly noticed public hearing was held by the City Council on February 15, 2000;
and
WltEREAS, a StaffReport was submitted recommending that the City Council approve the
proposed General Plan Amendment and Amendment to the Eastern Dublin Specific Plan; and
WItEREAS, the City Council did hear and use their independent judgment and considered all said
reports, recommendations and testimony hereinabove set forth.
NOW, THEREFORE, BE IT RESOLVED TltAT the Dublin City Council does hereby find that:
1. The proposed Amendments are consistent with the goals, general provisions and purpose of the
Dublin General Plan and the Eastern Dublin Specific Plan as proposed to be amended herein; and
.
The relocation of land uses and acreages within Areas F, G and H of Dublin Ranch are
appropriate for the subject property in terms of land use compatibility and configuration and will
provide a comprehensive plan for the development of Areas F, G and H; and
o
The amended land uses and text would allow the development of Main Street, a pedestrian
orientated retail and service center within walking distance of high and medium high density
residences as reflected on the Development Plan included as a part of Exhibit B to the Staff
Report. These changes are appropriate based on analysis in the staff report, will provide a
development pattern consistent with the Specific Plan goals, and will help implement policies of
the General Plan and EDSP regarding development in Eastern Dublin; and
.
The amended text would allow Campus Office uses be developed on 10.5 acres of land
designated for General Commercial uses within the south-west quadrant of Area H, pursuant to a
Stage 2 Planned Development (PD) Rezone. The change to this land use is appropriate based
upon analysis in the staff report, will result in more efficient use of land in line with market
conditions, will provide a development pattern consistent with the Specific Plan goals, and will
help implement policies of the General Plan and EDSP regarding development in Eastern Dublin;
and
o
The revised Appendix 4 "Eastern Dublin Specific Plan Land Use Summary By Land Owner", #19
Pao-Lin represents updated information regarding land uses and acreages within the Pao-Lin
property (also know as Areas F, G and H, now owned by Jennifer Lin et al) of the Eastern Dublin
Specific Plan area.
BE IT FURTHER RESOLVED TItAT THE Dublin City Council does hereby approve a
General Plan Amendment and an Amendment to the Eastern Dublin Specific Plan, as shown on Exhibits
A, B, C, D, E and F to the StaffReport for the February 15, 2000 City Council meeting for PA 98-068,
PA 98-069 and PA 98-070.
PASSED, APPROVED AND ADOPTED this 7th day of March, 2000.
AYES:
Councilmembers Howard, McCormick, Zika, Vice Mayor Lockhart and
Mayor Houston
NOES: None
ABSENT None
ABSTAIN: None
ATTEST:
[,__C~ Clerk x.~ -
Mayor Pro Tempore
K2/G/3-7-00/reso-gpa-dblnranch.doc (Item 6.3)
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Dublin Ranch
Planning Areas F, G & H
Response to Mitigated Negative
Declaration Comments
January 2000
EXHIBIT B OF ATTACHMENT 1
Introduction
This report compiles all letters received by the City of Dublin during the 3D-day Mitigated
Negative Declaration public review period and includes responses to each of the comments.
Clarifications to Initial Studies Project Descriptions
The following clarifications are made in the Project Description section for the Initial Studies for
Planning Areas F, G and H. The following text should be deleted from each ofthe Initial Study
documents:
.
Planniflg .'\.rea F: The applieant has also requested approval of a lot line
adjustment to separ:ate Planning .'\.rea F from the remainder of thc Dl:lblin
Ranca property.
.
Plarming .'\.rea G: The applicant has also requested approval of a master
tentati~/e tract map to subdi'/ide the Pla:rming .'\.rea into smaller parcels of land
for sale to future builders. .A~fter the master tentati'/e tract map is finalized and
recorded, it is anticipated that tentati~/e subdivision maps would be filed to
create individual buildin; lots for residential construction. The master
tentative tract map is beiflg revie'.ved concurrently '.vith the 8pecific
Plan/GCi'l.eral Plan .'\mendmeRt application and PD rezone, hO'tvever, the
master teITtative map may not be acted apon until other applications ha'/c been
acted upon.
Plannin; .'\.rea H: The applicant -has also requested approval of a lot line
adjustment to separate Planning .Alien H from the remainder of the Dublin
Ranch property.
The following text shall replace the above language in each of the Initial Studies:
.
"The applicant is also requesting approval of a Lot Line Adjustment and Vesting
Master Tentative Map to encompass all three of the Planning Areas. The Lot Line
Adjustment would modify a portion of the northerly boundary of Planning Area F
to encompass a portion of Planning Area E within Planning Area F. The .19.4
acres of land to be added has been designated as a school site within Planning
Area E and environmental review for this portion of the site was conducted by the
City of Dublin in 1997. The Lot Line Adjustment would also modify the east-west
boundary lines between Planning Areas G and H to be co-terminus with submitted
Planning Area Plans.
The Vesting Master Tentative Map proposes to establish smaller parcels within
Planning Area G for sale to future builders. The smaller parcels to be create are
consistent with related Stage 1 and Stage 2 development plan proposals. After the
vesting master tentative map is finalized and recorded, it is anticipated that future
tentative subdivision maps would be filed within Planning Area G to create
individual building sites for residential and non-residential construction. The
Vesting Master Tentative Map does not propose to subdivide property within
Planning Areas For H. It is anticipated that future tentative subdivision maps
would be filed in conjunction with or subsequent to Stage 2 Development Plans to
divide Planning Areas F and H into small lots for building purposes. "
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 2
January 2000
Summary of Comment Letters
Comment letters were received by the City of Dublin from the following agencies and
organizations.
· Comment Letter 1: Alameda County Flood Control District Zone 7
· Comment Letter 2: Alameda County Public Works Agency
· Comment Letter 3: Martin Inderbitzen
· Comment Letter 4: Lin Planning Team
· Comment Letter 5: East Bay Regional Parks District
· Comment Letter 6: California Department of Fish and Game
· Comment Letter 7: U.S. Fish and Wildlife Service
· Comment Letter 8: California Regional Water Quality Control Board, San
Francisco Bay Region
· Comment Letter 9: California Department of Transportation
· Comment Letter 10: Bruce Webb, Dublin San Ramon Services District
Responses to Comments
This is a summary of each of the comments and the response of the City of Dublin. Each
letter has been reviewed and divided into smaller comments as noted by annotations in the
margin in each of the letters. Each comment is then summarized and responded to below. The
full teArt of each letter with annotations follows this section. Since many of the comments
relate to potential biological impacts of the projects, a master response has been formulated
for this topic.
Master Response to Comments Regarding Biological Resources
The teArt of the three Initial Studies summarize information presented in the H.T. Harvey &
Associates report for Dublin Ranch Planning Areas F, G and H (Pao Yeh Lin Property),
Ecological Impacts and Mitigation (10/25/99) ("Report"). This report presents information on
the status of sensitive species on the property, the amount of survey work that was conducted
to determine their status, the level of impact H. T. Harvey & Associates identified regarding
each species that would occur as a result of proposed development and proposed mitigation
measures that would reduce the anticipated impacts to-Iess-than-significant levels. This report
was used as the background for the Initial Studies and was also appended to each of the three
Initial Study documents. City staff and the consulting biologist carefully reviewed the report
during the Initial Study preparation process. City staff and the biological consultant also
reviewed the Biological Resources analysis contained in the Eastern Dublin Specific
Plan/General Plan EIR ("EIR"). Based on these reviews staff and the biological consultant
believe that any potential for significant impacts to biological resources will be avoided or
reduced to a level of insignificance, in compliance with CEQA. This mitigation will occur
through compliance with applicable mitigation mea,sures adopted in the EIR and identified in
the Initial Studies for the projects,a,sJurther-clarified in this m(ister response.
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 3
January 2000
During the public review period, the City of Dublin received letters from the State
Department of Fish and Game, United States Fish and Wildlife Service and other agencies.
These agencies stated their opinion that biological impacts had not been adequately analyzed
or mitigated under CEQA. The City of Dublin respectfully disagrees. Through this master
response and later individual responses, the City will describe the areas of disagreement and
the evidence supporting the City's position.
Red-Legged Frog
Biological surveys of Planning Areas F, G and H conducted in 1998 and 1999 and described
in the Harvey report, resulted in the observation of a single adult female red-legged frog in
the Planning Area F stockpond during a July 1, 1999 site visit. Initial Studies for Planning
Areas F, G and H conclude only limited use of the Planning Area F stockpond, upland
grasslands and the seasonal wetlands by red-legged frogs occurs based on their low detection
rate on the property. The Planning Area F Initial Study notes that red-legged frogs could
breed in the stockpond. However, the appearance of a single individual after a year and a half
of survey work suggest overland movement to this pond from another inhabited site. This
species has been recorded from the drainage to the north (3!4 mile) and from the Fallon Road
vicinity to the east (112 mile).
As discussed in the Harvey report, red-legged frogs dispersing from off-site locations or the
Planning Area F pond currently are able to make unrestricted movement to other suitable
aquatic habitat to the north and east as described above. There is no suitable aquatic habitat
between the stockpond and Interstate 580; and Interstate 580 forms a barrier to further
movement to or from the south. Development along Tassajara Road blocks movement to and
from the west where red-legged frogs are present in Tassajara Creek.
The U.S. Fish and Wildlife Service (Service) notes that red-legged frogs use upland areas to
forage or to move between areas of suitable aquatic habitat, The Project Impacts section of
each Initial (Section IV "a") are hereby revised by reference to include the following text to
clarify that the impact area includes not only the stockpond in Planning Area F, but may _alsQ
include upland areas around the stockpond.
"Clearing and grading could result in the loss of individual red-legged frogs and
would result in the loss of any upland foraging and dispersal habitat."
The Planning Area F Initial Study contains Mitigation Measure 2(iii) for red-legged frog
impacts. This mitigation measure will be also revised to include the additional clarifying
language and incorporated into the Initial Study by reference to read as follows:
Mitigation Measure 2: Prior to the issuance of a grading permit, the project
builders! developers shall:
(iii) Implement measures to minimize direct impacts to California red-
legged frogs (initiation of construction during the dry season, May-
October; seining of the impacted pond in April and May and transportation
of any red-legged frogs or larvae to the Northern Drainage;
preconstruction surveys; in suitable habitat, removal of vegetation by hand
prior to construction; and, in suitable habitat, monitoring of construction
by a herpetologist), in consultation with CDFG and the V.S, Fish &
Wildlife Service (VSFWS). Enhance, restore, and preserve 4.5 acres of7riparian habitat along a 3500-foot reach of the Northern Drainage.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 4
January 2000
Removal of cattle and urinatural debris, replanting of riparian vegetation,
installation of instream weirs, and creation of an in-stream or slightly off-
channel pond will significantly improve conditions along this degraded
stream for the red-legged frogs currently occupying the drainage and will
mitigate the loss of the Planning Area F stock pond and adjoining
drainages. A minimum buffer of 300 feet along the stream in the Northern
Drainage will be preserved.
(new text to be added): Mitigation work at the proposed 0.1 O-acre pond in
the northern drainalle shall consist of removinll sediments from the bed of
the former pond which existed at this site and re-establishinll the original
stream channel confilluration to flow adiacent to the pond site. The pond
shall provide open water and wetland habitat suitable for use bv red-
legged frolls and shall be buffered bv 300-foot wide setbacks of preserved
habitat. "
Vernal Pool Invertebrates
The Service comments on the presence of suitable habitatfor the conservancy fairy shrimp,
the longhorn fairy shrimp, and the vernal pool tadpole shrimp in Planning Area H seasonal
wetlands. The Planning Area H Initial Study summarizes the results of sampling for vernal
pool invertebrates on and in the vicinity of Planning Area H, and the Harvey report provides
additional information. No special status vernal pool invertebrates have been found on the
project site or in the project vicinity. In the absence of any occurrences of these species on or
in the vicinity of the site, no impacts to them m,:e expected and no mitigation measures are
required. .. ;
California Tiger Salamander .
The Planning Area F Initial Study notes that tiger salamanders breed in the on-site stock pond
and estivate in mammal burrows or other retreats in the upland portions of the site. The Initial
Studies for Planning Areas G and H report on the lack of breeding habitat within their - -
respective areas and conclude that upland habitat use is minimal based on a history of
agricultural operations in these areas, but does recognize the possibility that the species could
move across or estivate on them.
The Project Impacts section (IV "a") of the Planning Area F Initial Study identifies the loss of
the stockpond and surrounding upland habitat as a project impact. It does not specify the
amount of impact. Section IV "a" of the Initial Study for Planning Area F is hereby revised
by reference to note that all tiger salamander habitat on the site would be lost should the
project be implemented. The estimated extent of this impact is shown on the attached Figure.
City of Dublin
Dublfn Ranch PA's F, G & H
Response to .comments
Page 5
January 2000
'. --------
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II " "I
if 0 rS~'~:'nta R'
,- 1 0,=11 d, I
-:--L ':-":o"'h_,,=-,:~I Reha billt
'.. . --" ",. - >---- __H_ p-- a.".' Jl."~~;" Annex
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- - - - - I Property Boundary
Approximate area of Estivation Habitat = 20.4 acres
2,000 0
~~~
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.~
approximate scale in feet
H. THARVEY & ASSOCIATES
ECOLOGICAL CONSULTANTS
Pao Yeh Lin:
Estimated California Tiger Salamander Estivation Habitat
File No. 555-26
Date 1/14/00 '''- Figure 1
Initial Studies for Planning Areas G and H state that tiger salamanders are unlikely to estivate
in these planning areas and would rarely move across or otherwise occur on them due to the
regular disking and other agricultural operations which occur on them. However, recognizing
the possibility that salamanders could exist within these two areas, the Project Impact
discussion of the Biological Resources section Initial Studies for Planning Areas G and H are
hereby revised by reference to state that all potential upland tiger salamander habitat would
be lost should the project be constructed
The Planning Area F Initial Study contains Mitigation Measure 2 (ii), for impacts to tiger
salamanders. This mitigation measure is hereby revised and incorporated by reference into
the Planning Area F Initial Study to read as follows:
Mitigation Measure 2: Prior to the issuance of a grading permit, the project
builders/developers shall:
(ii) Create a new California tiger salamander breeding pond in the Northern
Drainage in the fall months, prior to Q:rading or other construction
activities the followinQ: spring or summer, and translocate individual tiger
salamanders from the impacted pond to the new pond. The new pond will
be approximately 0.7 acres in size, thereby mitigating the loss of the Area
F pond at a ratio of approximately 1: 1.
(new text) The acreaQ:e of estivation habitat oreserved around the created
pond in the northern drainage shall be a minimum of 63 acres. The amount
of estivation habitat preserved around the existinQ: off-site breedinQ: pond
to be preserved shall be a minimum of 20 acres. The opportunity for
interchanQ:e with other off-site breedinQ: locations shall be maintained on.
both sites.
A qualified herpetologist will conduct nocturnal surveys at the pond for
emerging adult salamanders during significant rain events from December
through February and transport individuals to the new pond. The impacted
pond will then be thoroughly seined for any salamander larvae present in
April and May; any larvae captured will be transported to the new pond.
The new pond and adjacent estivation habitat will be preserved. In
addition, existing, occupied breeding and estivation habitat off-site, :Ehe
acreage to be commenSU1Q-tc '.'/ith impacted habitat, will be preserved. +he
acreage of estivation .
. habitat preserved LH'olHld both the created pond and the m~istin;; breeding
pond to be set aside will be commensumte with the extent of impacted
estivation habitat on .^..reo. F, ':lhich \vill be determined based on sffi"veys
durin;; '"inter 1999/2000, or based on an a;;reemcJll-t with CDFG regLH'din;;
the likely extent of suitable estivation habitat.
This revised mitigation measure is adequate to reduce impacts to tiger salamanders to a less-
than-significant level within Planning Areas F, G and H.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 7
January 2000
Kit Fox
The Service does not concur with the findings of the Initial Studies that kit fox are absent
from the project site. The Harvey report contains a description ofthe results of kit fox
surveys conducted in the project vicinity since 1989 and an analysis of their results. They
conclude that kit fox are not present in the Dublin area and are absent from the Pao Yeh Lin
site. The information reviewed is the best available scientific information and it indicates that
kit fox ate not present and the project site is outside the species' range. The surveys were
conducted by professional biologists and reviewed by the City's consulting biologist. The
City consultant's professional opinion and the previous report conclude that there is no
potential for kit fox within the three Planning Areas.
Burrowing Owl
All three of the Initial Studies identify the loss of individual burrowing owls, their occupied
burrows and occupied owl habitat as a potentially significant impact. Mitigation measures
contained in each of the Initial Studies provide mitigation for these impacts. The mitigation
measures are consistent with the requirements contained in the California Department ofFish
and Game's Staff Report on Burrowing Owl mitigation dated October 17, 1995, and are
considered sufficient to reduce any project impacts to this species to a less-than-significant
level.
Other Species
The project area contains one eucalyptus tree located on the border between Planning Areas F
and G, which could be used by tree nesting raptors and loggerhead shrike. The tree is
proposed for removal. CDFG recommends preserving the tree for use by these species in the
future. However, with development of the proposed project, the tree would no longer be a
suitable nest site for these species due to the loss of surrOlll1ding foraging habitat and the
greatly increased level of disturbance introduced to the area by the proposed project.
Therefore, the Initial Studies for Planning Areas F and G incorporates the mitigation
proposed by the CDFG in their comment letter by planting riparian-associated trees in the
. northern drainage in an area proposed to be dedicated for open space. This tree planting js _
proposed for mitigating impacts to
CDFG jurisdiction and would also mitigate for the loss of the eucalyptus tree. A mitigation
and monitoring plan is proposed to be prepared for this work by the applicant's consulting
biologist.
The information in the Harvey report notes the likely presence of homed lark on the site.
Loss of homed lark habitat was not identified as a significant impact in the Initial Studies due
. to the large amount of similar habitat in the region and their fairly wide distribution in this
area. The homed lake information in the Harvey report is evidence that there is no potential
for significant impact. The Initial Studies contain mitigation measures for other grassland-
associated species, including the California tiger salamander and burrowing owl.
San Joaquin spearscale and Congdon's tarplant are included on the California Native Plan~
Society (CNPS) List IB. This list contains plants considered by the CNPS to be rare,
threatened or endangered in California and elsewhere. They have no federal or state special
status. The Initial Studies, in the absence of the ability to conduct thorough field surveys due
to disking of the site, presume presence if suitable habitat is present and offers mitigation
standards for their removal.
The CDFG believes pursuant to Section 153_80(d) of the CEQA_Guidelines, that these species
should be treated as if they were formally listed species. ThissectioI! of the CEQA
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 8
January 2000
Guidelines provides criteria by which a lead agency can determine whether a species which is
not formally listed should nevertheless be treated as such for purposes of CEQA review. The
criteria in the CEQA Guidelines contain qualitative definitions of "rare" and "endangered"
species. City staff and the City's biological consultant reviewed the criteria for these two
plants. Two plant species referred to here, while not common in the region, are known to be
present at several locations in the Livermore-Amador Valley area and this were determined
not to meet the criteria established by 15380(d) ofthe Guidelines.
As noted in the comment from CDFG, the recreated stream channel proposed for Planning
Area F surrounded by development is not expected to fully compensate for the fill of on-site
drainages. The on-site channel is part of a mitigation proposal that includes an off-site
component along the northern drainage that has larger buffers and greater protection from
development activities. The on-site component responds to concerns over the complete
elimination of natural drainages on the site. Stream improvements provided in Mitigation
Measure 3(ii) would compensate for loss of additional channel length.
The Initial Studies list the need for the project developer to obtain a Streambed Alteration
Permit from the Department ofFish and Game under the section titled "Other Public Agency
Required Approvals."
Letter 1: Alameda County Zone 7
.
Comment 1: On page 3 7, item c: "substantially alter drainage patterns, including
streambed courses such that substantial siltation or erosion would occur," the Initial
Study states that storm drain runoff would eventually flow into the Zone 7 G-3
facility immediately north of the 1-580 freeway. This is a planned facility that
currently does not exist. If constructed, the G- 3 facility must meet Zone 7 standards.
Response: The G-3 channel has been in operationfor some time by Zone 7. As noted
in preliminary engineering studies for the G-3 and Arroyo Las Positas channels and
Dublin Ranch Master drainage area (prepared by Schaaf and Wheeler dated 12/3/98)
and Dublin Ranch Master Drainage Study (5/99) document the peak flows, hydraulics
and hydraulic grade lines for the new and existingflows on the surrounding streams
and improved channels. The studies document that the peak flows from Planning
Areas F, G and H development would occur significantly sooner than the peak of the
Arroyo Las Positas channel drainage basin. Therefore, the existing channel could
accommodate this small amount of stormwater runoff from the proposed project and
facilities have been adequately sized The drainage patterns and streambed courses
of the development area would not be significantly changed and therefore, no further
erosion would result to streambed or channel courses. Most of the increased flows
would be in improved channels, pipes or structures so that streambed erosion would
be kept to a minimum and would be improved from existing conditions. Proper
erosion control measures will be undertaken in accordance with Zone 7 and Regional
Water Quality Control Board criteria and policies.
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 9
January 2000
Letter 2: Alameda County Public Works Department
· Comment 2.1: Drainage impacts from the proposed development on downstream
facilities should be addressed. In particular, the Arroyo de la Laguna has been
experiencing numerous erosion impacts and the effect ofproject runoff on the Arroyo
should be addressed.
Response: The drainage basin that contributes storm water runoff to this section of
the Arroyo is approximately 425 square miles in size. The proposed project area
constitutes approximately one tenth of one percent (0.10) of the drainage area. Based
on this, any contribution to current or future Arroyo erosion would be considered
less than significant.
· Comment 2.2: The applicant should be required to designate haul routes to and from
the site and repair any damage to County roads.
Response: Comment acknowledged. This comment has beenforwarded to the Dublin
Public Works Department for appropriate action during the grading and excavation
phase of the project. Preliminarily, it is not believed that County roadways would be
usedfor construction vehiclesfor the proposed project.
· Comment 2.3: It is unclear about the WIdening and improvement of Tassajara Road,
specifically within County-maintained roadway portions.
Response: Comment acknowledged. The project is not anticipated to require
widening or improvements to the unincorporated portions of TassajarG Road. .
· Comment 2.4: All roadway and storm drain facilities in County right-of-way must
conform to Alameda County Subdivision Design Guidelines and hydrology criteria
and standards. Any rights-of-way dedication, road improvements, relocations, etc.
shall be at no cost to the CoUnty.
Response: Comment acknowledged. No improvements are proposed within County
rights-of-way for the proposedproject.
Letter 3: Martin Inderbitzen
· Comment 3.1: Concerns raised regarding the presence of certain species within the
planning area that are not present on site. Replacement language is suggested in lieu
of a required 300-foot wide buffer along the stream in the northern drainage area.
Please clarify that if a preconstruction survey of the site finds no burrowing owls no
further mitigation would be required.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 10
January 2000
Response: See Master Response Regarding Biological Resources regarding the
amount of land to be dedicated for off-site mitigation in the northern drainage area
for loss of on-site habitat for the red-legged frog and California tiger salamander.
Regarding burrowing owl mitigation, if the preconstruction surveys identify no
burrowing owl on the site, no further mitigation would be required.
· Comment 3.2: Conditions and recommendations contained in the H.T. Harvey Report
dated 10/25/99 should be used as part of the three Initial Studies. Concerns are raised
regarding the type and location of mitigation required.
Response: Information gathered and analyzed by H T. Harvey & Associates was
used as the basis of the biological impacts and mitigation measures section of all
three Initial Studies. The full text of the Harvey report was included in the Appendix
of each Initial Study. A peer review of this report was conducted by LSA Associates,
the City's consulting biologist. Through the Master Response to Comments Regarding
Biological Resources and other individual responses, some of the Harvey report
mitigation measures have been augmentedfor clarification. City staff and the City's
consulting biologist feel the mitigation measures contained in the Initial Studies, as
modified in this Response to Comment document, are generally consistent with the
Harvey report.
· Comment 3.3: Mitigation Measure 5 requires the project to make a fair share
coritribution to downstream drainage improvements. Zone 7 currently requires
payment of a fee to the District and payment of the fee to the District would satisfy a
fair share contribution. Therefore, the mitigation measure should be removed.
Response: Payment of afee by the project sponsors to Zone 7 would likely satisfy the
Mitigation Measure. However, the City prefers to maintain the mitigation measure in
the event there are drainage improvements requiredfor the project over and above
that which would be covered by the fee.
.
Comment 3.4: The Mitigation Measure dealing with flood protection should read:
"Applicant shall remove habitable portion of the project site from the I DO-year FEMA
floodplain prior to occupancy permits being issued."
Response: The Initial Study is hereby corrected by reference to replace appropriate
Mitigation Measures in the Initial Studiesfor Planning Areas G and H to the
following language: "The project developer(s) shall remove habitable portions of the
project from the IOO-year FEMA flood plain prior to building permits being issued. "
· Comment 3.5: Much of the teA'! of the Initial Studies appear to be written generally so
as to cover all tl:rree Planning Areas, Because of this, clarifications are needed to
prevent inaccuracies, such as cultural resources and the lack of Tiger Salamander
outside of Planning Area F, .. -
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 11
January 2000
Response: Based on the Harvey report, the California Tiger Salamander has been
identified in Planning Area F. Based upon an amplification of the Initial Study
information contained in the Master Response Regarding Biological Resources, the
movement and estivation of tiger salamander species is noted within Planning Areas
G and H However, the presence of these species is anticipated to be minimal, due to
regular disking and agricultural operations on these two Planning Areas.
To ensure that fUll protection is provided in the unlikely event that unidentified
archeological or paleontological resources are discovered anywhere in the three
planning areas, the City prefers to maintain the language of these mitigation
measures. These mitigation measures respond to Impact 3.9 B set forth in the Eastern
Dublin EIR and are consistent with the mitigation measures outlined in this previous
EIR.
· Comment 3.6: The Initial Studies include numerous traffic mitigation measures that
are specific and that have been taken from the project traffic report. The mitigation
measures assume that a long list of development projects and related traffic
improvements would occur. The listing of projects is highly speculative and may not
be accurate, Instead, the mitigation measure for the three planning area projects
should require that an acceptable level of service is maintained that may include the
list attached. Traffic mitigation measures apply to all three planning areas, not each
individual area. -.
Response: Cumulative traffic impacts and mitigation measures have been developed
using the "list" method of known and probable projects. It is believed that these
projects will be developed before or simultaneously with the three Dublin Ranch. _
Planning Areas (F-H), although this cannot be assured. The City of Dublin prefers to
list specific mitigation measure elements rather than a broad mitigation measure, as
suggested by the commenter. This will assist the City in fulfilling its legal
responsibility of mitigation monitoring and reporting. Changes to specific mitigation
measures may be allowed by the City of Dublin at the time of subdivision approval
based on further traffic analysis at some point in the future.
The traffic sections of each of the three Initial Studies are, in fact, identical, given the
close interconnectivity of the three planning areas in terms of traffic and
transportation impacts.
· Comment 3.7: The population figures and associated park requirements for Planning
Areas F and H have been miscalculated. The numbers in the Initial Study represent
dwelling units rather than population. Additionally, the park acreage requirement per
capita has been miscalculated. City requirement includes 1.5 acres for local parks and
3.5 acres for community parks, whereas the Initial Studies use a 5-acre park
requirement all for local parks,
Response: Estimates of park requirements for the project included in the Initial Study
are in error. For the three Planning Areas, the City uses. (J.neighborhood park
dedication requirementof 1:5 acres per 1000 residents. The amount of parkland
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 12
January 2000
proposed in Planning Areas F and G exceed this standard. The requirement for
community parks is calculated separately and accounts for the remainder portion of
Dublin Ranch. The impact remains less-than-significant with regard to the provision
of parkland.
· Comment 3.8: Regarding noise exposure, no residential development is proposed in
Planning Area H, so it is inappropriate to apply exterior residential noise standards to
non-residential land uses. Also, only a portion of Planning Area G is proposed for
residential land uses, so the imposition of residential noise exposure standards is
inappropriate here too.
Response: The Initial Study for Planning Area H identifies the existing noise
environment for all three adjacent Planning Areas and indicates the range of existing
noise mitigation measures adopted as part of the Eastern Dublin Specific Plan. No
new noise mitigation measures are required for this project. The commenter is
correct that no residential development is proposedfor Planning Area H, which is
confirmed by the Initial Study project description.
Acoustic mitigation measures for Planning Area H would only apply to residential
development occurring within the Planning Area.
· Comment 3.9: No residential development is proposed within Planhing Area H, so all
references to inclusionary housing requirements and residential zoning should be
removed.
Response: The commenter is correct, and the paragraph in the Project Description _
dealing with inclusionary housing requirements is hereby removed by reference from
the Planning Area H Initial Study. .
· Comment 3.10: The t~rminology "intermittent creeks," "creek" and/or "streams"
should be removed since none of these exist on the property. Instead, the terms
"defined drainages" or "swales" should be used.
Response: The Eastern Dublin Specific Plan identifies two "intermittent streams"
within Planning Area F (Figure ], 7B). For all other natural drainage features south
of the stock pond in Area F the terms "defined drainage areas" are hereby
incorporated by reference.
Comment 4: Lin Planning Team
· Comment 4.1: Much of the text is written generally to cover all three project areas
which makes information confusing and not appropriate to the specific planning area.
Response: In many instances, the background and impact information for all three
Planning Areas are gemfrall)lthe .same, since a high degree of interconnectivity exists
City of Dublin Page 13
Dublin Ranch PA's F, G & H January 2000
Response to Comments
between the three areas. Examples of this include noise, drainage and traffic. Other
topics have been specifically tailored for each planning area, for example, biological
impacts and population and housing impacts.
. Comment 4.2: Area H, page 3, second line, the use of the word vacant is wrong, since
agricultural and cattle grazing occur on the site.
Response: The term "vacant" was intended to convey that the site is devoid of
buildings or structures, The Initial Study is hereby corrected by reference to reflect
the historical and on-going grazing and agricultural uses of the property. The
property is therefore not considered vacant.
. Comment 4.3: Area H, page 3, project description, first paragraph, does not mention
that a master tentative tract map is also proposed which should be included in the
Initial Study,
Response: See the Clarification to Initial Studies Project Descriptions discussion
contained in the Response to Comments.
.
Comment 4.4: Figure number should be;: 2 not 3.
.
Response: The commenter is correct that the exhibit is mislabeled. This correction is
hereby included by reference into the Area H Initial Study.
Comment 4.5: Area H, Project Description, it is not necessarily true that a Stage 2 PD
rezone application will be filed at the same time as the tentative tract map and Site -
Development Review. This application could be submitted prior to or with a
Tentative Tract Map.and/or Site Development Review application.
Response: The commenter is correct, the filing of such applications would not need to
be done simultaneously. The project description is thereby corrected by reference to
include the updated information.
Comment 4.6: Area H, Internal collector roads are only one instance of providing a
roadway system. The final system may include a collector loop or other system. The
final system will be determined prior to submittal of individual tentative tract maps.
The Initial Study implies this is the only solution and the term "collector" should be
deleted.
Response: The project description contained in the Initial Study was not meant to
imply that collector roads would be the only interior means of circulation. It was
meant to differentiate local facilities, such as local and collector roads which would
be constructed by individual subdividers, from other major roadways which would be
constructed with assessment district financing. Therefore, there is no need to delete
the word (Icollector. "
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 14
January 2000
· Comment 4.7: Area H, page 5, second paragraph, no housing is proposed for Planning
Area H so language describing City indusionary housing requirements should be
deleted from the Initial Study.
Response: The commenter is correct and all discussion related to inclusionary
housing requirements in Planning Area H is hereby deleted by reference.
· Comment 4.8: Area H, page 5, second paragraph under Assessment Districts should
be corrected to read "assessment districts ,t rather than "initial study."
Response: The commenter is correct and the Initial Study is hereby corrected by
reference as noted.
· Comment 4.9: Area H, page 5, project description, first paragraph, although a lot line
adjustment has been requested a master tentative tract map is also requested as part of
the application and should be noted in the project description section of the Initial
Study.
Response: Refer to comment and response 4.3.
· Comment 4.10: Area H, page 10, references to "permits" should be changed to
"authorization" or "401 Certification."
Response: The Initial Study is hereby corrected by reference to note that
"authorizations" are requiredfrom the Regional Water Quality Control Board _
"Permits" would still be required to be issued by the Corps of Engineers and
California Department of Fish and Game for streambed alteration.
· Comment 4.11: Area H, page 10, reference is not made regarding a master tentative
tract map as part of the project.
Response: Refer to Response 4.3.
.
Comment 4.12: Area H, page 11, the section heading on this page identifies a
category of "potentially significant impacts" which is not shown in the checklist
which follows. Many of the impacts are listed as "less than significant with mitigation
measures." The Initial Study should state that impacts are potentially significant
unless mitigation is incorporated.
Response: The changes identified above are correct and are incorporated by
reference into this Initial Study and the Initial Studies for Planning Areas F and G as
well. The "The Less Than Significant with Mitigation 1/ checklist heading corresponds
to No.4 under Evaluation ofEnvironmentai Impacts. As reflected in the comment,
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 15
January 2000
mitigation measures would reduce these impacts from "potentially significant" to
"less than significant. "
· Comment 4.13: Area H, page 13, refer to Item 27.
Response: See response to Comment 4.28.
· Comment 4.14: Area H, checklist, question the box checked off: shouldn't the Ii less
than significant impact" or "no impact" box be checked instead of "less than
significant after mitigation" for the Public Services section?
Response: The box in question was checked offin error. It should not have been
checked since this box is a topic heading and checkmarks have been provided for
individual components within the Public Services section (i.e., fire, police, schools,
etc.). This correction to the Initial Study is hereby made by reference.
· Comment 4.15: Area H, checklist, question the "no impact" box checked off
regarding the Mandatory Finding of Significance "all and "b." Shouldn't these be
changed to "less than significant?"
Response: The original response was based onfull implementation'ofmitigation
measures,. Upon further consideration, it may be more appropriate to check off the
"less than significant" boxes for subsections "a" and "b" in the Mandatory Findings
of Significance section. These changes are hereby made and incorporated by
reference into the text of the Initial Study. These revisions also assume full
implementation of mitigation measures.
· Comment 4 .16: Area H, page 23, the reference to Planning Area F should be revised
to. Planning Area H.
Response: This change is hereby made and incorporated by reference into the text of
the Initial Study.
· Comment 4.17: Refer to Comment 1 regarding the term "vacant."
Response: Refer to Comment and Response 4.2.
· Comment 4.18: Area H, page 24, Aesthetics, the use ofthe word "former" is
inaccurate as the site is still being used for agriculture.
Response: This change, to delete the word "former," is hereby made and incOlporated
by reference into the tex(ofthe Initial Study.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 16
January 2000
· Comment 4.19: Area H, page 24, Aesthetics, when a Statement of Overriding
Considerations has been adopted, the impact remains potentially significant and
unavoidable, it is not reduced to a level of less than significant.
Response: The comment is correct, The intent of the referenced statement is to
indicate that since the impact was previously addressed in a Statement of Overriding
Considerations for the Eastern Dublin SPIGP EIR, no additional analysis is required
In regard to the last line in subparagraph "a" on page 24, the referenced statement is
hereby revised and incorporated by reference to delete the words" less than
significant impacts would result for this project and" This project would have no
impact beyond that previously addressed in the Statement of Overriding
Considerations, "
· Comment 4.20: Area H, page 24, Aesthetics, when a Statement of Overriding
Considerations has been adopted, the impact remains potentially significant and
unavoidable, it is not reduced to a level of less than significant.
Response: See above response. Accordingly, the last full line of the referenced text is
hereby amended and incorporated by reference into the Initial Study to delete
reference to reduction of the impact to less than significance.
· Comment 4.21: Area H, page 25, Agricultural Resources, when a Statement of
Overriding Considerations has been adopted, the impact remains potentially
significant and unavoidable, it is not reduced to a level of less than significance.
Response: Refer to above responses to Comments 4.19 and 4.20. Although the
comment is correct, impacts to Agricultural Resources were previously addressed in
the Statement o.fOverriding Considerations adoptedfor the Eastern Dublin SPIGP
EIR and no further analysis is needed for this Initial Study. However, the reference to
"less than significant" impacts are hereby deleted and incorporated by reference into
the Initial Study.
· Comment 4.22: Area H, page 25, refer to Item 19 (Comment 4.20).
Response: See response to Comment 4.19 and 4.20. References to "less than
significant" impacts are hereby deleted and incOlporated by reference into the Initial
Study.
· Comment 4.23: Area H, page 26, Biological Resources, Environmental Setting, the
word "one" should be replaced with "at least once."
Response: The Initial Study is hereby corrected by reference to make the above
change. .
City of Dublin.
Dublin Ranch P A's F, G & H
Response to Comments
Page 17
January 2000
· Comment 4.24: Area H, page 28, Wetlands, this sentence is not accurate. CDFG
jurisdictional habitat does not exist in Area H. This occurs in a ditch paralleling the
frontage road which extends from the elevated farm road to the G- 3 channel.
Response: The Initial Study is hereby corrected to note that Us. Army Corps of
Engineers wetlands exist within Planning Area H
· Comment 4.25: Area H, page 28, Project Impacts, section implies that that certain
plant arid animal species are present on the site when evidence has been presented to
the contrary. Refer to the H.T. Harvey report.
Response: Refer to Master Response to Biological Resources.
· Comment 4.26: Exhibit 5 title should be changed to "jurisdictional area" and not
"wetlands." The exhibit shows all water subject to Corps jurisdiction, not just
wetlands.
Response: The title of Exhibit 5 is hereby changed by reference to read
"Jurisdictional Waters of the us. Including Wetlands."
.
Comment 4.27: Area H, Project Impacts and Mitigation Measures "a," there are no
tiger salamanders within Area G based on on-site surveys. The reference needs to be
removed. Also, there is confusion regarding the burrowing owl. If owls are not found
on the site, then a habitat set-aside is not required.
Response: See Master Response to Biological Resources regarding the potential
presence of tiger salamander habitat within Planning Area H Regarding burrowing
owl within the Planning Areas, if required preconstruction surveys fail to find
burrowing owl, no additional mitigation. would be required
.
Comment 4.28: Area H, page 30, Cultural Resources, Based on the Final EIR, no
significant resources have been identified in Area H, only Area F. Therefore, the
Initial Study is inaccurate in indicating the possibility of resources within this
Planning Area.
Response: To ensure that full protection is provided in the unlikely event that
unidentified archeological or paleontological resources are discovered anywhere in
the three planning areas, the City prefers to maintain the language of these mitigation
measures. These mitigation measures respond to Impact 3.9B set forth in the Eastern
Dublin EIR and are consistent with the mitigation measures outlined in this previous
EIR.
· Comment 4.29: Area H,page)O, Biological- Resources, believe it is inappropriate to
specify a biological resoUrces mitigation site in North Livermore. The location of any
City of Dublin Page 18
Dublin Ranch PA's F, G & H January 2000
Response to Comments
mitigation area will be dependent on discussions with the Corps of Engineers and the
Initial Study text should be revised to "23 acres."
Response: The reference to the North Livermore site has been taken from the Harvey
report, which has been used as the basis for biological impacts and mitigation
measures. A site in North Livermore. was identified in the report as a potential off-
site mitigation for biological resource impacts.
· Comment 4.30: Area H, page 31 and throughout, why are Planning Areas F and G
discussed here? This is the initial stucj.y only for Area H.
Response: The topic in question is hydrology and drainage, although this is not
specified in the comment, Adjacent Planning Areas have been included to discuss
how the drainage of Planning Area H is linked to adjacent areas. Similarly, other
references to adjacent Planning Areas have been provided where a logical linkage to
the adjacent areas exist, such as traffic and transportation.
.
Comment 4.31: Area H, page 32, first full paragraph, delete the phrase "minimizing
grading on steep slopes."
Response: The phrase has been included since it describes one of n:zany mitigation
measures included in the Eastern Dublin Specific Plan which apply to this and all
other development proposals in the eastern Dublin area. Only those mitigation
measures with applicability would be enforced - .
for Planning Area H On page 31 of the Planning Area H Initial Study, under the
discussion of Landform and Topography, notes that the site is relatively flat with-an -
approximate grade change of approximately 4 feet over the Planning Area site.
.
Comment 4.32: Area H, page 33, hydrology, the following sentence is not accurate:
"The project site is hilly with several intermittent creeks flowing through it." There
are no hills or intermittent creeks in Planning Area H, only defined drainages.
Response: The Initial Study is hereby corrected by reference to delete the reference to
intermittent streams and replace this language with the term "defined drainages. "
.
Comment 4.33: Area H, page 33, mitigation measure, text regarding NPDES permits
needs to be revised to say "file a notice of intent with the state" rather than "obtain a
notice of intent from the state."
Response: The Initial Study is hereby corrected by reference.
· Comment 4.34: Area H, page 35, Mitigation Measure 6, this measure would require
the developer to pay a fair share contribution for downstream drainage improvements.
ACFC Zone 7 has an existing-drainage program for this PurPose and the project will
pay these fees. Therefore, the need for further study is not needed.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 19
January 2000
Response: Payment of afee by the project sponsors to Zone 7 would likely satisfy the
Mitigation Measure. However, the City prefers to maintain the mitigation measure in
the event there are drainage improvements required of the project over and above
that which would be covered by the fee.
· Comment 4.35: Area H, page 35, "g," "h" and "i," the project developer has already
obtained a conditional letter of map revision from FEMA where FEMA has agreed to
take the portions of the site out of the flood plain. The mitigation measure should be
re-written as follows: "The applicant shall remove habitable portions of the project
from the 1 aD-year FEMA flood plain prior to occupancy permits being issued."
Response: The Initial Study is hereby corrected by reference to replace Mitigation
. Measure 7 with substantially the above wording, Mitigation
Measure 7 now reads:" The project developer(s) shall remove habitable portions of
the project from the 100-year FEMA flood plain prior to building permits being
issued. "
· Comment 4.36 Area H, page 35 "h" and "i," the Initial Study notes that there would
be no hazards due to dam or levee break because the existing stock pond in Planning
Area F would be removed. A comment.,should probably be added that in the event the
pond is not removed, embankments will be reinforced to eliminate dam failure as a
potential hazard.
Response: The Initial Study has been prepared based on the assumption that the stock
pond existing within Planning Area F would be removed to accommodate proposed -
land uses shown in the applicant's request for development within Planning Area F .if
the stock pond were to remain, a revised application would need to be filed with the
City and additional environmental documentation performed.
· Comment 4.37: Area H, page 37, noise, Environmental Setting, The paragraph in the
Initial Study regarding noise should be re-written to reflect that no residential
development is proposed in Planning Area H. Secondly, use of soundwalls along 1-
580 are excluded (sic) from occurring pursuantto the Eastern Dublin Scenic Corridor
Policies and Standards.
Response: The environmental setting portion of the Planning Area H Initial Study
describes existing noise conditions in general terms for all three of the adjacent
Planning Areas, based on the noise section contained in the Eastern Dublin Specific
Plan. Although a brief reference to residential noise standards is made in the Noise
section of the Checklist explanation, the Project Description for the Initial Study
clearly states that no residential development is proposed within Planning Area H
There is no requirement or mitigation measure contained in the Initial Study to
require noise barrier walls to be con~tructed adjacent tOJhis Planning Area.
City of Dublin
Dublin Ranch PAIs F, G & H
Response to Comments
Page 20
January 2000
· Comment 4.38: Area H, page 38, project impacts and mitigation measures "a," the
Initial Study lists fire sprinklers as an element of the project. There may be portions
of the project that may not require sprinklers so that this comment should be removed.
Response: The discussion contained in the Initial Study is intended as a general
listing of.fire prevention measures which may be required by the Alameda County
Fire Department as part of the review of individual development projects. Inclusion
of fire sprinklers is not listed as a specific mitigation measure. There is no need to
remove this comment since sprinklers could be requiredfor portions of the project.
· Comment 4.39: Area H, page 43, there is no Table 2 on Page 43, Comparison of Trip
Generation. Why has this table not been included in the document?
Response: Table 2 may have been inadvertedly left out and is attached to this
memorandum. It is hereby incorporated by reference into the Initial Study for
Planning Area H The purpose of including this table is to show that the combined
peak hour traffic generation from the three Planning Areas is not significantly higher
than and generally consistent with the approved Eastern Dublin Specific Plan and
associated EIR.
.
Comment 4.40: Area H, page 44, traffic Mitigation Measures 7 an~ 8, the Initial
Study includes numerous traffic mitigation measures that are very specific and are
assumed to be taken directly from the project traffic report. Mitigation measures
contained in the traffic report are based on a number of other projects that" may not
occur. Instead, the project should be conditioned to maintain acceptable levels of
service and the list of recommended improvements may include the list attached:
. Response: Cumulative traffic impacts and mitigation measures have been developed
using the "list" method of known and probable projects. It is believed that these
projects will be developed before or simultaneously with the three Dublin Ranch
Planning Areas (F-H), although this cannot be assured. The City of Dublin prefers to
list specific mitigation measure elements rather than a broad mitigation measures, as
suggested by the commenter. This will assist the City in fulfilling its legal
responsibility of mitigation monitoring and reporting. Changes to specific mitigation
measures may be allowed by the City of Dublin at the time of subdivision approval
based onjUrther traffic analysis at some point in the future.
.
Comment 4.41: Area H, page 46, "d" and "g," substitute Planning Area H for
Planning Area F.
Response: The Initial Study is hereby corrected by reference to replace references to
Planning Area Fwith Planning Area H .
· Comment 4.42: Area H, page 46~ "e," no new residences are planned in Area H.
City of Dublin Page 21
Dublin Ranch PA's F, G & H January 2000
Response to Comments
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Response: The Initial Study is hereby corrected by reference to delete references to any
new residential development in Planning Area H
· Comment 4.43: Area G, refer to comments on Area H.
Response: The comment is unclear. Not all of the comments regarding Planning Area
H also pertain to Planning Area G. To the extent that they do, however, refer to the
appropriate responses to Planning Area H
· Comment 4.44: Area G, page 2, second line, Refer to Area H concerning use of the
word "vacant."
Response: Refer to Response to Comment 4.2.
· Comment 4.45: Area G, page 3, Specific Plan/General Plan Amendment description,
this paragraph is incorrect, since there are no Medium High Density Residential,
Open Space, Middle School or Elementary School designations shown for Area G in
the current Specific Plan.
Response: The Initial Study is hereby corrected to delete references to these land uses
in Planning Area G. Land uses included in the existing Specific Plan includes
Medium Density Residential, High Density Residential, Public/Semi-Public,
Neighborhood Commercial/Village Center, Neighborhood Park and Neighborhood
Square.
· Comment 4.46: Area G, page 4, sixth paragraph, first sentence, the sentence is not
clear and it appears something is missing.
Response: The Initial Study is hereby corrected by reference to complete the
incomplete sentence as follows: " Grading activities would occur within Planning
Area G to accommodate planned land uses, roads and utilities, although the amount
of grading is not known at this time. "
· Comment 4.47: Area G, Exhibit 4, it is unclear which area is Area G.
Response: The commenter is correct, the exhibit is Area H The corrected exhibit is
attached.
.
Comment 4.48: Area G, page 10, zoning, this appears to be the zoning for Area F and
not Area G.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 24
January 2000
Response: Existing zoning for Planning Area G is hereby corrected to include: PD-
Neighborhood Commercial, High Density Residential and Medium Density
Residential. The Initial Study for Planning Area G is hereby corrected by reference to
include this information.
· Comment 4.49: Area G, page 11, no "potentially significant impacts" exists on the
Initial Study checklist, even though this is referenced in the text of the Initial Study.
The checklist should note that impacts are potentially significant unless mitigation is
incorporated.
Response: The changes identified above are correct and are incorporated by
reference into this Initial Study.
· Comment 4.50: Area G, page 24, where a Statement of Overriding Concerns has been
adopted, the impact remains potentially significant and unavoidable. The impact isn't
reduced to "less than significant" in succeeding environmental documents.
Response: Refer to Responses to Comments 4.19 and 4.20.
· Comment 4.51: Area G, page 26 "e," refer to above regarding Statement of
Overriding Considerations.
Response: See response to above comment.
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 25
January 2000
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· Comment 4.52: Area G, page 26, Biological Resources, Environmental Setting, the
term "fallow" implies abandonment and it should be made clear that the land is disked
for weed control and grazed, etc. Exchange the word "one" for "at lease once."
Response: The Initial Study is hereby corrected by reference to incorporate the fact
that the site has been diskedon an annual basis.
· Comment 4.53: Area G, page 26, Biological Resources, Environmental Setting,
second paragraph, delete the word "draft."
Response: The Initial Study is hereby corrected by reference to incorporate the above
change.
· Comment 4.54: Area G, page 27, second paragraph, first line, add "ponded areas and"
in front of "wetlands."
Response: The Initial Study for Planning Area G is hereby corrected by reference to
incorporate the above change. The corrected sentence would therefore read:
"Because Planning Area G lacks long-term ponded areas or wetlands ef an)' ld",d, no
suitable habitat for western pond turtles and nesting Tricolored Blackbirds is present
on Planning Area G. ""
· Comment 4.55: Area G, page 27, first paragraph, 'second line, after the second "Area
G" add "contained small isolated areas of short term :{londing along the access road,
bisecting Area G (and Area H) and these ponded areas." -
Response: The Initial Study is hereby corrected by reference to incorporate the above
change and to read as follows: "Portions of Planning Area G contain small, isolated
areas of short-term lJonding along the access road bisecting Planing Area G and
Planning Area Hand these vonded areas were sampledfor special-status vernal pool
invertebrates, but none were detected.
Comment 4.56: Area G, page 31, Drainage, first paragraph, first and second lines,
there are no intermittent streams on the property. These are gentle swales. Streams are
considered to be jurisdictional.
Response: The Initial Study is hereby corrected by reference to incorporate the above
change.
.
Comment 4.57: Area G, page 32, Hydrology and Water Quality, Environmental
Setting, first line, refer to above comment above concerning the word "stream."
Response: See response to abbvef:omment.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 27
January 2000
· Comment 4.58: Area G, page 33, project impacts and mitigation measures, "b," the
text is difficult to understand, since there is little, if any, recharge of groundwater. The
dense clay layer near the surface prevents downward mov~ment of water.
Response: The Initial Study references back to the previous EIR. Based on the type of
soil present on the site, groundwater recharge would be minimal. No change to the
Initial Study is therefore required
· Comment 4.59: Area G, page 33, project impacts and mitigation measures, "e," refer
to earlier comment regarding the absence of streams on the site.
Response: See earlier response regarding corrections to the Initial Study to
incorporate this change. References to intermittent streams within Planning Area G
are hereby replaced with the term "defined drainages. "
· Comment 4.60: Area G, page 34, item "e," fifth line, refer to previous comment
concerning streams.
Response: See Response to Comment 4.59.
· Comment 4.61: Area G, page 35, "h" and "i'" the discussion does not answer the
question. .
Response: The checklist question is "would the proposed project place housing within-
an area that would impede or redirect floodwaters, including flood water caused by a
dam or levee failure. " The response is that a small portion of Planning Area G
currently lies within a 1 OO-year flood plain, however, project developers must adhere
to Mitigation Measure 6 which would ensure that all habitable portions of the site be
raised outside of the 100- year flood plain. It is assumed that the City of Dublin
and/or FEMA would not approve grading plans that would redirect storm water in
such a manner as to place other structures within a flood hazard area. It has also
been assumed, based on submitted plans and written descriptions submitted by the
applicant, that the stock pond within Planning Area F would be removed as part of
the project, so that there would be no flooding hazardfrom a dam or levee break.
· Comment 4.62: Area G, page 35, Land Use and Planning, last line, 240 dwellings
should be revised to reflect 275 dwellings.
Response: The Initial Study is hereby corrected by reference to note that approval of
the proposed Planning Area G SPAlGPA would result in an increase of275 dwelling
units over the existing Eastern Dublin Specific Plan, not 240 dwelling units as
identified in the Initial Study. Based on successful mitigation of all potential impacts
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 28
January 2000
to levels of less than significance, an increase of up to 275 dwelling units is not
believed to result in any significant impacts.
· Comment 4.63: Area G, page 36, Noise, Environmental Setting, second paragraph,
refer to Area H, item 36 (Comment 4.37) concerning non-residential noise standards.
Response: See response to Comment 4.37.
· Comment 4.64: Area G, page 36, Noise, Environmental Setting, third paragraph, this
statement is inaccurate and should be revised. The sentence does not separate noise
exposure levels by land use type and infers that that the projected noise level within
all of Area G has an overlay of 65 dB with the rest of the Area having less than 65
dB. Additionally, does not add the disclaimer included in Area H, being that
foreground buildings, walls, etc. will attenuate and reduce much of the noise before it
reached Area G. This statement has more bearing on this Area as it has a greater
distance from the freeway. Finally, the text needs to be revised to c1arifythat Areas G
and F are not impacted by noise generated by Tassajara Road.
Response: The Environmental Setting section summarizes existing andfuture noise
levels on the site based on information contained in the EDSP EIR. It clearly
references other source documents that should be consulted for a full discussion of
noise impacts by land use type. The Environmental section also clearly notes that
noise exposure within the Planning Aret;[ is expected to be reducedto a level
consistent with City standards in the future based on distances from roads and the
planned construction of intervening structures. This includes Tassajara Road. There
is nothing in the text that needs to be corrected or modified.
· Comment 4.65: Area G, page 37, Population and Housing, Project Impacts and
Mitigation Measures, the total population number should be 2,808, not 1,404 as
listed. Two lines later afigure of2,084 is listed for the approved Planning Area G
Plan. If this is the Eastern Dublin Specific Plan, this number is in error. The EDSP
permits818 dwelling units, which works out to 1,636 residents. Ifthis 2,084 figure is
not the EDSP population for.Area G, is additional explanation needed? Area F
population should be included in this discussion, as land uses and densities have been
re-allocated between the two areas.
Response: The Initial Study incorrectly reported the ultimate, expected total
population of Planning Area G. Based on information supplied by the applicant, the
Planning Area is currently approvedfor an estimated population of 1,636 people
(818 dwellings x 2. 0 persons per dwelling, based on persons-per-unit figures
contained in the EDSP). The proposed amendment would allow approximately 2,808
persons (1,404 dwellings x 2.0 persons-per unit). All other impacts, such as traffic,
utilities and services, have been based on the number of dwelling units included in
this response and no additional analysis is warranted.
As noted in the Project Descriptions in the Initial Studies for Planning Areas F and
G, the applicant desires to relocate residential and commercial land uses between
these two Planning Areas, so any net increase inpopulationfor the two Planning
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
. Page 29
January 2000
Areas over the existing Eastern Dublin Specific Plan/General Plan would be small
and less than significant.
· Comment 4.66: Area G, page 40, "b," third line, the number of residents for Area G
should be revised to 2,808 residents. The estimates for park dedications are also
incorrect. The Initial Study uses the incorrect population and secondly it uses the
standard of5 acres of park for 1,000 residents. Per City standard, local parks are only
1.5 acres of the total, with community parks making up the remaining 3.5 acres per
1,000. Hence, the 7.02 acre figure should be revised for local parks. This will also
affect the overall Area F and G park acreage, which should be revised Environmental
Setting, second paragraph, Refer to Area H, item 36 (Comment 37) concerning non-
residential noise standards.
Response: The commenter is correct. See response to Comment 4.65 regarding the
future estimated population for Planning Area G. Based on the corrected anticipated
corrected population for Planning Area G, an anticipated 4.2 acres of neighborhood
parks would be required based on a ratio of 1.5 acres of neighborhood parks per
1000 residents.
· Comment 4.67: Area G, page 45 and throughout, revise the four references to Area F
to Area G.
Response: The Initial Study is hereby corrected by reference to incorporate the above
change.
· Comment 4.68: Area F, refer to comments on Areas G and H.
Response: Refer to responses for Planning Areas F and H
· Comment 4.69: Area F, page 3, second line, refer to Area H regarding the word
"creek. "
Response: The Eastern Dublin Specific Plan EIR notes the presence of "intermittent
creeks" north of the existing stock pond in Planning Area F. South of the stock pond
the Initial Study for Planning Area F is hereby changed to refer to such features as
"defined drainage areas. " Also refer to Comment 3.10.
.
Comment 4.70: Area F, page 3, Project Description, Specific Plan/General Plan
Amendment, second paragraph, the first line should be revised to read all of Medium
High Density, not a portion, as noted,
Response: The Initial Study is hereby corrected by reference to incorporate the above
change regarding the description of Medium Density Residential land uses.
City of Dublin
Dublin Ranch P A's F,G & H
Response to Comments
Page 30
January 2000
· Comment 4.71: Area F, page 4, Table 1, land use acreages are not the most current,
specifically regarding the Medium Density Residential (68.9), Public/Semi-Public
(3.9) and Open Space (2.8) and the units of Medium Density Residential (689).
Response: The Initial Study is hereby corrected by reference to incorporate the above
change.
· Comment 4.72: Area F, page 4, first paragraph, this paragraph is not really true; only
the north-south arterial street has been adjusted by the proposed application. These
streets (sic) do not go through Area H as stated.
Response: The Initial Study is hereby corrected by reference to incorporate the above
change.
· Comment 4.73: Area F, page 5, Assessment District discussion, first paragraph, need
to add Area F in addition to or instead of the Area G.
Response: The Initial Study is hereby corrected by reference that Phase 1 Assessment
District improvements are encompassed within Planning Area G with the exception of
the southerly side of Dublin Boulevard (within Planning Area H) and the northerly
side of Central Parkway (Planning Area F). Phase 2 of the Assessment District
proposes the construction of Gleason Road across the site within Planning Area F
· Comment 4.74: Area F, page 6, second paragraph, there is no discussion of a Master
Tentative Tract Map being included in this Initial Study. In addition, the lot line
adjustment noted in the document does not include Parcel 0 (within Planning Area E
of the Dublin Ranch) by reference.
Response: See the Clarifications to Initial Studies Project Descriptions regarding
proposed subdivisions of the three Planning Areas. -
.
Comment 4.75: Area F, Project Description, see previous comment.
Response: See the Clarifications to Initial Studies Project Descriptions regarding
proposed subdivisions of the three Planning Areas.
.
Comment 4.76: Area F, page 11, General Plan designations, Middle School,
Elementary School, Neighborhood Park, Neighborhood Square, Public and Semi-
Public uses are not zoning districts. If this remains, the Middle School should be
revised to be a High School.
Response: Existing zoning districts for Planning Area Finc/ude PD-Single Family
Residential, PD- Medium Density Residential, PD- Medium High Density
Residential, PD-High Density Residential, PD-High Density Residential and PD-
Neighborhood Commercial.
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 31
January 2000
· Comment 4.77: Area F, page 12, first paragraph, no "potentially significant impacts"
exists on the Initial Study checklist, even though this is referenced in the text of the
Initial Study. The checklist should note that impacts are potentially significant unless
mitigation is incorporated.
Response: Refer to the responses to Comments 4.12.
· Comment 4,78: Area F, page 25, first paragraph, where a Statement of Overriding
Concerns has been adopted, the impact remains potentially significant and
unavoidable. The impact isn't reduced to "less than significant" in succeeding
environmental documents.
Response: See responses to Comments 4.19 and 4.20.
.
Comment 4.79: Area F, page 27, "b," second paragraph, see above comment
regarding Statement of Overriding. Consideration.
Response: See response to Comment 4. 78.
· Comment 4.80: Area F, page 27, "d and e," second paragraph, see above comment
regarding Statement of Overriding Consideration.
Response: See response to Comment 4. 78.
· Comment 4.81: Area F, page 27, Biological Impacts, Environmental Setting, first
paragraph, exchange the word "one" for "at least once."
Response: The changes identified above are incorporated by reference into this Initial
Study.
· Comment 4.82: Area F, page 31, Biological Impacts "iii," the reference to a minimum
300-foot buffer along the stream to the northern drainage should be replaced with
"appropriate buffers along the drainage will be preserved." This is because the
specific dimension will be dependent on outcomes of discussions with other
regulatory agencies. The term "stream" should be replaced with the term "tributary
drainage. "
Response: See Master Response to Biological Impacts. Mitigation Measure 2 (iii)
has been modified as outlined in the Master Response.
City of Dublin
Dublin Ranch P A's F l G & H
Response to Comments
Page 32
January 2000
· Comment 4.83: Area F;page 32, Biological Impacts, mitigation measure, this section
described the proposed mitigation configuration, yet says, .. "will be filled and later
recreated." This implies that the proposed mitigation is the existing condition to be
filled and recreated. "Filled and later recreated near its former location" should be
changed to "created" to clarify that these are the measurements for the constructed
feature and not the jurisdictional area. Additionally, the third line refers to "in-kind"
mitigation. "In-kind" mitigation is not proposed, but mitigation has been proposed in
terms of seasonally ponded wetlands.
Response: The Initial Study is hereby corrected by reference to reflect that the
channel to be constructed will be "created" rather than "recreated " The original text
was taken from the H T. Harvey & Associates report.
· Comment 4.84: Area F, page 32, Biological Impacts, Mitigation Measure 3 (ii),
unclear what this mitigation measure is calling for. Refer to Harvey Report.
Response: Mitigation Measure 3(ii), which is based on the Harvey report, would
require the project developer(s) to provide off-site mitigationfor loss of the on-site
stockpond, which also serves as a breeding pond for red-legged frogs and tiger
salamander.
· Comment 4.85: Area F, page 35, first and fifth paragraphs, the Initial Study indicates
a history of landslides, however, the geotechnical report only indicates that there is
evidence of previous landholding in some of the swales, It does not indicate extensive
landsliding as noted in the Initial Study. .
Response: The changes identified above are inc01porated by reference into this InitiaL
Study to note that there has been a history of land sliding in some of the swales and
does not imply widespread landsliding throughout the Planning Area.
· Comment 4.86: Area F, page 35, Drainage, "stream" should be revised to read
"defmed drainage."
Response: Figure 3.7-B clearly shows the presence of intermittent streams within
Planning Area F north of the existing stock pond The Planning Area F Initial Study
is hereby modified to reflect the presence of defined drainages south of the existing
stock pond.
· Comment 4.87: Area F, page 37, and throughout, the Initial Study should be revised
to reflect that there are no intermittent streams or creeks in the Planning Area, only
defined drainages.
Response: See response to Comment 4.86.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 33
January 2000
· Comment 4.88: AreaF, page 39, Land Use and Planning, Project Impacts "b" second
paragraph, the last sentence doesn't make sense, please advise regarding changes to
the Circulation Element.
Response: The Initial Study is corrected by reference to delete references "to previous
Circulation Element" changes.
· Comment 4.89: Area F, page 39, Land Use and Planning, Project Impacts "b" second
paragraph, the number of dwelling units should be changed to indicate 275 dwellings
instead of240.
Response: See response to Comment 4,62.
· Comment 4.90: Area F, page 40, Noise, Environmental Setting, the statement that
minor portions of Area F would be subject to long term noise is not correct, since the
60 d line parallels existing Central Parkway. Secondly, Tassajara Road is not a noise.
source affecting Planning Area F. Lastly, the section does not add a disclaimer that
much of the noise reaching Area F would be reduced by intervening structures prior
to reaching Area F.
Response: The Initial Study is corrected'by reference to note that Planning Area F is
outside of the future significant noise exposure level as indicated in the Eastern
Dublin EIR. However, there remains a possibility of future significant noise based on
vehicle travel on local streets, Mitigation Measures contained in the Eastern Dublin
EIR would still require individual acoustical analysis for individual subdivisions
within Planning Area F as they may be proposedfor development.
· Comment 4.91: Area F, page 41, Population and Housing, Project Impacts "a," lines 9
and 11, the Initial Study does not reflect the most recent dwelling unit count. Instead
of 1,677 for an estimated population, a population of 1,669 should be used. Instead of
a population of 1,091 in the existing SP/GP, the number should be 1,092.
Response: The Initial Study is corrected by reference to reflect the above population
numbers.
· Comment 4.92: AreaF, page 43, Recreation, Project Impacts "a," first paragraph, first
sentence, the Initial Study does not reflect that just for Area F, the amended plan
proposes a lower population figure that the existing EDSP. Only if both Areas F and
G are taken together would the population estimate exceed the existing EDSP
population figures.
Response: The comment is correct. The City still prefers to consider cumulative
impacts of all three SPIGP applications in terms of population, traffic, recreation and
others. . h- , --
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 34
January 2000
· Comment 4.93: Area F, page 43, Recreation, Project Impacts "b," the population
figure should be 1,669 and not 1,677.
Response: The Initial Study is corrected by reference to reflect the above population
number.
· Comment 4.93: Area F, page 43, Recreation, Project Impacts "b," the population
figure should be 1,669 and not 1,677.
Response: The Initial Study is corrected by reference to reflect the above population
number.
· Comment 4.94: Area F, page 44, Recreation, Project Impacts, first paragraph, the
paragraph is supposed to be discussing neighborhood park requirements, however, the
figures stated includes both neighborhood and community park requirements. The last
sentence should be rewritten to say that the overall Areas F and G neighborhood park
requirement is 6.7 acres while the two Area Plans propose 16.8 acres. This results in
an excess of 10.1 neighborhood park acres than is required to be dedicated.
Response: Estimates of park requirements for the project included in the Initial Study
are in error. For the three Planning Areas, the City uses a neighborhood park
dedication requirement of 1.5 acres per 1000 reSIdents. The amount of parkland
proposed in Planning Areas F and G exceed this standard. The requirement for
community parks is calculated separately and accounts for the remainder portiori of -
Dublin Ranch. The impact remains less-than-significant with regard to the provision
of parkland.
· Comment 4.95: Area F, page 51, "e," wastewater disposal is not discussed.
- Response: Wastewater disposal is discussed in the Eastern Dublin EIR (Impact
3.5/G), which has been incorporated by reference as part of the Initial Study. With
adherence to Mitigation Measures 3.5/11-14, impacts related to wastewater disposal
would be reduced to an insignificant level.
Comment 5: East Bay Regional Parks District
..
COl11p1ent 5.1: The subject Mitigated Negative Declaration identifies Tassajara Creek
as the proposed location for biological mitigation for the Dublin Ranch projects by
preserving, enhancing and restoring a 5,200 foot section of Tassajara Creek north of
the proposed Greenbriar development. The District is concerned that a large portion
of the proposed mitigation site is owned by the District and would therefore not be
available for mitigation for the Dublin Ranch project.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 35
January 2000
Response: The Mitigation Measure referenced in this comment proposes the
enhancement and restoration ofhabitat along a portion ofTassajara Creek, as
contained in the Harvey report. This and other mitigation measures presented in this
report are identified as options for mitigation of riparian/wetland impacts to
Planning Areas F and H Impacts to riparian resources occur only in Planning Area
F, and that Initial Study includes mitigation for the loss of riparian habitat. The
mitigation for Planning Area F riparian is the creation of an 810-foot long drainage
on the site and restoration and enhancement of a portion of the Northern Drainage.
Restoration and enhancement of riparian habitat along Tassajara Creek may be a
proposal associated with development of the remainder of Dublin Ranch. A record of
survey performed by the applicant's surveyor has determined that the proposed
mitigation area along Tassajara Creek is within the Dublin Ranch property. Afigure
has been attached, provided by the project applicant, that presents known property
boundaries in the area.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 36
January 2000
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· Comment 5.2: The Mitigated Negative Declarations identifies potentially significant
impacts to two special-status species of plants, California Tiger Salamander, red-
legged frogs, burrowing owls, badgers and nesting sparrows. Many of these impacts
were not properly addressed in the Eastern Dublin Specific Plan/General Plan (EDSP)
ElR. The City may wish to postpone consideration of the subject Dublin Ranch
applications until such time as conflicts between development and species
conservation have been resolved.. The District recommends revisions to the EDSP and
ElR as recommended by USFWS, the preparation of a multi-species habitat
conservation plan and other studies to examine cumulative impacts to special-status
speCIes.
Response: The City of Dublin is satisfied that the Eastern Dublin Specific
Plan/General Plan EIR, supplemented by additional biological analyses, contained in
the Harvey report for the proposed Dublin Ranch Planning Area F, G and H
developments, are adequate to meet the requirements of CEQA. The Harvey report
analysis reviews potential impacts to species identified in the Eastern Dublin Specific
Plan/General Plan EIR as well as species identified since certification of that EIR.
Mitigation measures adopted as part of the Eastern Dublin Specific Plan/General
Plan EIR have been applied by reference to the three proposed Dublin Ranch
projects. Additional. refined mitigation measures are set forth in the Harvey report as
modified by the Response to Comments. Also refer to the response to Comment 6.1 on
this topic.
Comment Letter 6: California Department of Fish and Game
· Comment 6.1: The Department does not believe that the FElR for the Eastern Dublin -
Specific Plan/General Plan fully discusses species occurrences, including impacts to
species not covered or adequately addressed in the original FElR. This FElR should
therefore not be referenced as adequate under CEQA for disclosure or providing
mitigation for these species,
Response: The City of Dublin is satisfied that the EDSP EIR, supplemented by
additional biological analyses, such as have been recently prepared by H T Harvey
for the proposed Dublin Ranch Planning Area F, G and H developments, are
adequate to meet the requirements ofCEQA. The Harvey report analysis reviews
potential impacts to species identified in the Eastern Dublin Specific Plan/General
Plan EIR as well as species identified since certification of that EIR. The previous
EIR contained extensive discussion of potential impacts to numerous species. It
anticipated potential effects to all of the species mentioned in the CDFG comment
letter and identifies mitigation measures as necessary to reduce identified impacts to
less-than-significant levels (se Section 3.7 of the EDSP EIR). For example Impact
3. 7/F addresses destruction of small water features which provide habitat for red-
legged frogs. This impact was reviewed and refined as part of the Dublin Ranch
project by Harvey & Associates, as the site moves closer to potential development.
Mitigation measures set forth in the cfjrtifiedEIR continu~ to be applied to
implementing projects, suchas Planning Areas F, G and H'Mitigation measures
City of Dublin Page 38
Dublin Ranch PA's F, G & H January 2000
Response to Comments
include requirements such as vegetation enhancement/management plans for open
space areas (MM 3. 7/2.0) and preconstruction surveys for certain species (MM
3. 7/20,0) and numerous other measures, Impacts and mitigations to other species,
such as the California Tiger Salamander, burrowing owl, American badger and
others, are also addressed in the EDSP EIR, Further mitigation measures required as
part of the Initial Studiesfor Planning Areas F, G and H build on the EIRfoundation
to clarify and provide more project-specific detail, The City's consulting biologist has
reviewed the original EDSP mitigation measures, the currently proposed mitigation
measures and the comment by CDFG. In the professional opinion of the consulting
biologist, the previous mitigation measures set forth in the EDSP EIR together with
the mitigation measures proposed in the three Initial Studies will reduce potential
biological impacts to less than significant levels.
· Comment 6.2: The Department does not believe mitigation measures set forth in the
Mitigated Negative Declarations would reduce potential impacts to a point of less-
than-significance as required by CEQA. A mandatory finding of significance must be
made.
Response: The City of Dublin is satisfied that compliance with CEQA has been
achieved through the three proposed Initial Studies and proposed issuance of
Mitigated Negative Declarations. Full disclosure of impacts to biological resources
have been made in the Initial Studies, supplemented by additional information
contained in the Master Response to Biological resources contained in this Response
to Comments. Mitigation has also been proposed so that impacts to biological
resources will be reduced to a level of less than significance.
· Comment 6.3: It is the opinion ofthe Department that construction of the project-
would result in fragmentation of habitat and blocking of movement corridors of the
red-legged frog and that the mitigation proposed is not adequate to reduce this impact
to a less-than-significant level.
Response: Refer to Master Response to Biological Resources which addresses
blockage of movement corridors.
· Comment 6.4: The Department does not agree with the finding contained in the Initial
Study regarding the migration pattern of the red-legged frog and that the impact to
this species has been underestimated.
Response: Refer to Master Response to Biological Resources.
· Comment 6.5: Areas along Tassajara Creek are identified as the proposed mitigation
area for red-legged frog impacts. The Department believes the proposed mitigation
area is owned by the East Bay Regional Parks District and may not be available for
mitigation.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 39
January 2000
Response: See the response for Comment 5.1.
· Comment 6.6: Surveys and mitigation measures for red-legged frogs should follow
established USFWS and Department guidelines.
Response: Surveys for sensitive biological species comply with the previously adopted
Eastern Dublin EIR, Additional surveys will follow applicable Agency and
Department guidelines.
· Comment 6.7: The Department does not agree with the finding contained in the Initial
Study that mitigation measures related to estivation habitat for the California Tiger
Salamander will be commensurate with Area F only. The Department believes all of
Areas F, G and H to be potential habitat for red-legged frogs and measures need to be
identified to minimize impacts to all of this area.
Response: Refer to Master Response to Biological Resources contained in this
document regarding the range of tiger salamander upland habitat.
· Comment 6.8: The Department does not concur with the fmding contained in the
Initial Studies that kit fox species are presumed absent from the project site. The area
lies within the western range of the kit fox and suitable denning and foraging habitat
exists on the project site. Permits are required for taking of habitat area and adequate
mitigation require compensatory preservation of habitat at a 3: 1 ratio.
Response: Refer to Master Response to Biological Resources.
· Comment 6.9: The Department considers the proposed mitigation for impacts to
burrowing owl to be inadequate. Additional mitigation is needed,
Response: Refer to Master Response to Biological Resources.
· Comment 6.10: The Department is opposed to the removal of eucalyptus trees (sic)
along the southern edge the site. These trees provide suitable habitat for various
species of tree-nesting raptors. Removal of the trees (sic) will result in a significant
temporal loss of potential nesting habitats well as a permanent loss if mitigation is not
incorporated. Any tree removal and replanting program should be described in a
Mitigation Monitoring Plan.
Response: Referto Master Response to Biological Resources.
.
Comment 6.11: The Department recommends that a thorough field survey be
completed for San Joaquin spearscale and Congdon's tarplant and appropriate
mitigation proposed. If possible, the Departmentrecomm~~ds that impacts be avoided
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 40
January 2000
where such species occur along with an appropriate buffer area. Translocation is not
approved by the Department as an acceptable mitigation measure., since it is
experimental and does not meet the standards of CEQA. The discussion found in the
Initial Study is not considered adequate.
Response: Refer to Master Response to Biological Resources.
· Comment 6.12: The Department recommends a minimum buffer of 100 feet adjacent
to wetlands. A Streambed Alteration Permit must also be obtained from the
Department prior to any work in a creek or stream corridor.
Response: The preliminary cross-section of the re-created on-site wetland submitted
by the applicant indicates that approximately 30 feet of buffer area would be reserved
on either side of the wetland/drainage channel. The Department of Fish and Game
comment and recommendation is acknowledged. It is further noted that this feature is
not intended to befull mitigation for loss of on-site wetlands; extensive off-site
wetlands are also proposed to be preserved as part of the project mitigation program.
The applicant acknowledges that the final design of this feature may change as
development plans are finalized and necessary Streambed Alteration Permits
obtained from the Department of Fish and Game.
Comment Letter 7: U.S. Fish and Wildlife Service
Comment 7.1: The Service is concerned with the segmentation of the proposed
Dublin Ranch planning areas. The piecemeal approach reduces the likelihood of the
listed species to persist on-site (within Dublin Ranch), much less within the entire
Eastern Dublin Specific Plan. The Service requests that the City of Dublin reevaluate-
these three planning documents and the remaining undeveloped portion of the Dublin
Ranch under one planning document.
Response: Although the environmental impacts of the three adjacent planning areas
have been presented in three separate Initial Studies, potential impacts have been
addressed as though one project exists. This was specifically done for potential
biological resources, where a single report (the Harvey report) was prepared to
evaluate potential impacts and recommend appropriate mitigation measures. In terms
of including other portions of Dublin Ranch, no other development proposals had
been received by the City of Dublin at the time the environmental documents for the
three planning areas were commenced Therefore, an accurate evaluation of potential
development impacts to the remainder of Dublin Ranch (a portion of which has been
approved for development) could not be made. The three projects under
consideration total approximately 300 acres of land and flexibility exists to
accommodate mitigation on and off of the project site.
· Comment 7.2: The Service does not concur with the findings of the Initial Studies
with regard to red-legged frogs and salamanc;lers. Other species may exist within
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 41
January 2000
seasonal wetlands, including the conservancy fairy shrimp, the longhorn fairy shrimp,
and the vernal pool tadpole shrimp,
Response: Refer to Master Response to Biological Resources.
· Comment 7.3: The Service does not concur with the presumed absence of kit fox
from the site, Sightings have been made of at least two kit fox sitings within ten miles
of the site. The planning areas contain suitable habitat for this species and no barriers
exist to prevent kit fox from reaching the site.
Response: Refer to Master Response to Biological Resources.
.
Comment 7.4: The Service does not concur with the presumed absence of the
conservancy fairy shrimp, the longhorn fairy shrimp or the vernal pool tadpole shrimp
from the site.
Response: Refer to Master Response to Biological Resources.
.
Comment 7.5: The Service continues to be concerned over lack of appropriate
mitigation for federally listed species within the East Dublin Planning Area.
Specifically, measures fail to avoid impacts to kit foxes, red-legge(frogs,
salamanders and vernal pool invertebrates. The documents fail to describe impacts to
upland portions of the planning areas or the indirect impacts associated with grading
the upland portions of the seasonal wetland.
Response: Refer to Master Response to Biological Resources.
.
Comment 7.6: The proposed projects are likely to result in a take of kit foxes and red-
legged frogs and possible the fairy shrimp, the longhorn fair shrimp, or the vernal
pool tadpole shrimp. A formal Section 7 consultation may be needed.
Response: Refer to Master Response to Biological Resources regarding potential
impacts to the species listed in the comment. It is likely that Planning Areas F and H
would require Section 7 consultations prior to issuance of necessary permits or other
authorizations.
.
Comment 7.7: In conclusion, the proposed projects will further isolate and fragment
populations of red-legged frogs within the Tassajara Creek watershed and areas to the
east of Tassajara Creek. A minimum buffer of300 feet between all wetlands and
upland dispersal corridors are necessary to ensure the project does not isolate the red-
legged frog, The development of these corridors would also minimize impacts to
other species, including the kit fox.
City of Dublin
Dublin Ranch PAIs F, G & H
Response to Comments
Page 42
January 2000
Response: Refer to Master Response to Biological Resources regarding the
fragmentation of red-legged frog population. The Master Response also recommends
the dedication of a minimum 63-acre off-site mitigation area that would very likely
include a minimum 300-foot wide buffer.
Comment Letter 8: California Regional Water Quality Control Board, San Francisco
Bay Region
· Comment 8.1: Board staff are concerned that the Negative Declaration may not
adequately address the project's potential impacts to wetlands, riparian waters and
associated endangered species, including the red-legged frog and California tiger
salamander.
Response: Refer to Master Response to Biological Resources.
· Comment 8.2: Board staff are further concerned that project would increase the levels
of pollutants discharged from the site and could alter the site's runoffhydrograph,
potentially impacting downstream bed and bank stability.
Response: The three Initial Studies acknowledge the potential increase of stormwater
runoff from the site as a result of proposed urban development. Discussion of such
impacts are found in the Hydrology and.Water Quality sections of the three
documents. Each of the three Initial Studies contain a mitigation measure that
requires project developers to prepare an updated project specific storm water study
to show the impacts of individual developments against the master drainage study. In
terms of impacts of downstream bank and bed stability, This mitigation is consistent
with Mitigation Measures 3.5/44 -48 contained in the Eastern Dublin EIR, which_
require the preparation of master storm drain master plans. Follow-on studies would
also include reviewing potential impacts to downstream bank stability. Each project
will be required to implement Best Management Practices for construction and post-
construction activities to minimize polluted storm water runoff from leaving the site.
· Comment 8.3: It appears that the project will impact the number and range of existing
rare, threatened and/or endangered species that are known to be present or could be
present on the site. Under CEQA, such impacts require a mandatory finding of
significance and it does not appear that the proposed Negative Declaration complies
with CEQA. An EIR or appropriate subsequent or addendum is required, Although an
EIR was prepared in 1992, substantial new information has been developed since that
time. Therefore, the Board believes a Negative Declaration is not appropriate and an
EIR or similar document should be prepared.
Response: The City of Dublin is satisfied that the Eastern Dublin Specific
Plan/General Plan EIR, supplemented by additional biological analyses, contained in
the Harvey report for the proposed Dublin Ranch Planning Area F, G and H
developments, are adequate to meet the requirements of CEQA. The Harvey report
analysis reviews potenti{JJ impacts to species- identifie4 in the Eastern Dublin Specific
City of Dublin
Dublin Ranch PA's F, G & H
RespOnse to Comments
Page 43
January 2000
Plan/General Plan EIR as well as species identified since certificatipnofthat EIR.
Mitigation measures adopted as part of the Eastern Dublin Specific Plan/General
Plan EIR have been applied by reference to the three proposed Dublin Ranch
projects. Additional. refined mitigation measures are set forth in the Harvey report as
modified by the Response to Comments. Also refer to the response to Comment 6.1 on
this topic.
· Comment 8.4: The proposed development would disturb more than five acres of land
during construction and must be covered under the State NPDES General Permit.
Response: Each of the three Initial Studies clearly identifies that a Notice of Intent is
required to be filed with the State Water Resources Control Board This reference is
contained in the section entitled Other Public Agency Required Approvals.
· Comment 8.5: Approximately 6.8 acres of U.S. Army Corps of Engineers
jurisdictional wetlands and 1.02 other waters of the United States would be impacted
with the proposed development. Because the project involves potential disturbance to
all or some of this area, a Section 401 Water Quality Certification or other approval
from the State would be needed and should be references in the CEQA document.
Response: Each of the three Initial Studies clearly identifies that permits are
necessary from the San Francisco Bay Regional Water Quality Con/rol Board.
· Comment 8.6: Section 404 (b) (1) of the Clean Water Act identifies the sequence in
which wetlands and other waters of the United States should be treated. This includes
avoidance, minimizing impacts and mitigation. Mitigation should be in-kind and on- -
site, with no net destruction of habitat value.
Response: The project is proposing to mitigate for thefill of wetland areas at a 2: 1
ratio, mitigate for the fill of non-wetland waters at a 1: 1 ratio and to restore and
enhance an off-site drainage area. There will be no net loss of wetland acreage or
habitat value.
.
Comment 8.7: Although the proj ect design would fill certain areas of creeks and
wetlands, it has not yet received required approvals from state and federal agencies.
The design of the project may change during agency review and this uncertainty
should be reflected inthe CEQA documentation. For example, the City could commit
to complete any additionally required CEQA documentation necessary for the project
to be in compliance following any design changes.
Response: The City of Dublin has reviewed the proposed project as submitted by the
applicant. The City believes that there is some degree of flexibility to allow minor
changes to the project should changes be required as the three projects are reviewed
by state and federal regulatory agencies. Ho~ev,er, should the project change
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 44
January 2000
significantly, the City will undertake additional CEQA reviews as necessary and
appropriate based on the modified project description.
.
Comment 8.8: The proposed project must comply with NPDES permit CAS002831.
Specific measures incorporated in the permit to minimize stormwater runoff pollution
includes minimizing land disturbance, minimizing impervious surfaces, use of
clustering and other measures.
Response: Each of the Initial Studies require the project developer(s) to prepare and
implement Storm water Pollution Prevention Plans (SWPPPs) prior to issuance of
grading permits, in accordance with the 1999 edition of the Design Guideline Manual
for Storm water Quality Protection. These Plans would require the developer to
institute construction and post-construction pollution prevention plans. SWP P Ps must
be approved by the City of Dublin, the San Francisco Bay Regional Water Quality
Control Board and the State Water Resources Control Board Included within the
Specific Plan document are stormwater quality guidelines which reference specific
criterion for the above-referenced manual.
· Comment 8.9: The project could substantially alter the existing runoff hydro graph
and flow into streams, Such alterations could result in impacts to downstream bed and
bank stability and associated impacts to loss of habitat and threats to existing
structures adjacent to the streams. The present hydrographic analys~ is limited to
ensuring that peak flows will not create a flooding hazard and should be expanded,
Response: See Response to Comment 1.
Comment Letter 9: California Department of Transportation
· Comment 9.1: Traffic impacts discussed in the document are dependent on the
accuracy of forecasting used. As the office, commercial, retail and residential
development occurs, a more specific and detailed traffic analysis should be carried out
for all projects within the Dublin Ranch area, all of which are close to 1-580.
Response: For the traffic analysis contained in the Initial Studies for the three
Planning Areas, the City has attempted to be as accurate as possible in terms of
including the impacts of all known or reasonably foreseeable projects in the vicinity.
As additional development is proposed in the Eastern Dublin area, including Dublin
Ranch, additional specific traffic analyses will be completed
Comment Letter 10: Bruce Webb, Dublin San Ramon Services District
.
Comment 10.1: The District has made significant progress in providing recycled
water to the Eastern Dublin area and it is fully anticipated that recycled water will be
available to the project at th.~ !~me. of development.
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 45
January 2000
Response: Comment acknowledged As stated in the three Initial Studies, connections
to the District's recycled water system would be made at the time of development if
available. Project developer(s) would be required to obtain permits from DSRSD and
install reclaimed waterfacilities in accordance with DSRSD standards during project
implementation.
.
Comment 10.2: Planning Area G, page 47 "b," the statement is made that sewer lines
will be extended from the east. In fact, all sewer lines and potable water lines will be
extended from the west.
Response: The Initial Study is hereby corrected by reference to reflect the above
change.
.
Comment 10.3: Planning Area G, page 47 "e," the statement is made that the local
wastewater treatment plant contains adequate capacity for the project, the District is
currently expanding wastewater treatment capacity through implementation of "Stage
IV" improvements, anticipated for completion on 2001. Also, LA VWMA wastewater
discharge facilities are being expanded at this time.
Response: The comment is acknowledged and the Initial Study is hereby corrected by
reference to reflect the above change. -,
City of Dublin
Dublin Ranch P A's F, G & H
Response to Comments
Page 46
January 2000
Comment Letters
City of Dublin
Dublin Ranch PA's F, G & H
Response to Comments
Page 47
January 2000
ALAMEDA COUNTY FLOOD CONTROL AND W.A.TER CONSERVATION DISTRICT
5997 PARKSIDE DRIVE i PlEASANTON. CALIFORNIA 945SE-5i27 A PHOJ;E (925)484-2600 'AX i925) 462.39i4
December 6, 1999
Mr. Dennis H. Carrington, Senior Planner
City of Dublin
100 Civic Plaza
Dublin, CA 94568
Letter 1
RECEIVED
DEe 7 1999
DUBUN PLANNING
Re: Mitigated Negative Declaration Dublin Ranch Areas F, G and H
Dear Mr. Carrington:
Zone 7 has reviewed the above-referenced Negative Declaration, Comments have been made in the following areas
and are described below 1) Flood Control.
Flood Control:
1. Page 37, item c, substantially alter drainage patterns, including streambed courses such that
substantial siltation or erosion would occur? The'paragraph states that storm drain runoff would
eventually flow to the Alameda County Flood Control and Water Conservation District G-3 facility
immediately north of the 1-580 freeway. It should be knO'WI1 this is a master planned drainage facility that
currently does not exist. This facility (Line G-3) would have to meet Zone 7 standards if Zone 7 is to take
ownership of the facilities.
Thank you for the opportunity to comment on your environmental document. If you have any questions regarding
our response, please call me at ext. 231.
~m7JjAr~
Sal Segura ~
Water Supply Advance Planning
Environmental Document Coordinator
SS:ss
cc: Ed Cummings, Zone 7
Dennis Gambs, Zone 7
Dave Lunn, Zone 7
John Koltz, Zone 7
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COUNTY OF ALAMEDA
PUBLIC WORKS AGENCY
DEVELOPMENT SERVICES DEPARTMENT
951 Turner Court, Room 100
Hayward, CA 94545-2698
(5]0) 670-6601
FAX (5]0) 670-5269 November 30 1999
,
RECEiVED
DEe. - Z 1999
,I..' PLANN\NG
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Anne Kinney, Assistant Planner
City of Dublin, Planning Department
PO Box 2340
Dublin, CA 94568
Letter 2
Dear Ms. Kinney:
Reference is made to YOUT correspondence dated November 8, 1999, transmitting a copy of the
bitial Study!.M:itigated Negative Declarations for Dublin Ranch Planning Areas F, G and H: PA 98-068
"lu-ea F, PA 98-069 "Area G' and PA 98-070 "Area H". We thank you tor the opportunity to revIew
these documents. Please consider the following in establishing the conditions of approval
2.1
1. It is our understanding that all Flood Control issues are being addressed by Zone 7, Alameda County
Flood Control and Water Conservation District and the City of Dublin. However, drainage impacts
from this proposed development on downstream facilities should be addressed. In particular the
Arroyo de la Laguna has been experiencing numerous erosion problems in recent years. The effect
that runoff from this new development will have o~ the Arroyo should be addressed
2.2
2. Require the applicant to designate proposed haul routes, and to repair damage to County roads used
as a haul route, or damaged by construction activity. Typically, we work out a letter agreement with
the developer, and issue a permit. Tnis guarantees repair of any damaged portions of the roadway,
and/or contribution to future overlay projects.
3. It was unclear where the limits of widening of Tassajara Road are proposed, Are improvements
2.3 proposed along the County of Alameda maintained portion of the roadway? The report should
adequately address this issue.
2.4
4. All roadway and stonn drain facilities in the County right-of-way are to conform to Alameda
County's Subdivision Design Guidelines and Hydrology and Hydraulics Criteria Summary. All work
must be in compliance with Alameda County ordinances, guidelines, and permit requirements. Any
'rl' on' l-ot--way ll-edJ'ca('I'Orl J....a. (j- l'nlpl'(jH'-"""-le--'l". ,-,,"'\,' n"''' ~,-,,-_. rnlo~~~:"''''' 0'" "~;l~;-,' -r""'l'I;;-;n:: ,,'h., 11 he :1t
::, ., \...1 1 """"l.l. 11.;), .......1.) 1 .....v""".:J..>a...) \.... \..t&J.LJ.'UJ.J. J. .......1. "''''.J .._-... .... ....1.._.... ~.....w.,u -
no costto the County.
If you have any questions please feel free to contact me at 510-670-5260.
Very truly YOUTS,
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William Lepere
Development Services
Attorney at Law
RECEIVED
UtG b 1999
MARTIN W. INDERBITZEN
DUBLIN PLANNING
December 6, 1999
Mr. Eddie Peabody, Jr.
Director or Community Development
City or Dublin
100 Civic Plaza
Dublin, Calirornia 94568
Letter 3
Re: Mitigated Negative Declaration and Initial Studies Areas F, G, and H
Dear Mr. Peabody:
Thank you ror the opportunity to review the Mitigated Negative Declaration and Initial
Study documents ror Dublin Ranch Areas F, G, and H. We offer our comments on the
attached sheets, however, issues or specific concern are discussed below.
3.1 We have many concerns regarding the biology sections. First, the recommendations
included in the Ecological Impacts and Mitigation report prepared by H. T. Harvey, dated
October 25, 1999, should be used and included in these Initial Studies. Within the studies
there is certain verbiage that implies certain plant and animal species are present on site, -
when evidence submitted is to the contrary. Additionally, there is a statement that "a
minimum buffer or 300 reet along the stream in the northern drainage" will be preserved
ror red-legged frogs. We disagree with this and believe that it should be replaced with
"appropriate buffers along the drainage will be preserved" because the specific dimension
will be dependent upon the outcome or our discussions with the Corps and other
agencies. Finally, we are confused with the burrowing owl mitigation plan ror habitat. It
should be made clear that ir owls are not round on the site, then a habitat set-aside is not
required
3.2 Many concerns exist regarding wetlands and jurisdictional areas. Generally, conditions
and recotnmendations included in the Ecological Impacts and Mitigation report prepared
by H. T. Harvey, dated October 25, 1999, should be used and included in these Initial
Studies. Specific issues include Area F teArt describing the proposed mitigation reature as
the existing condition. Additionally, we are concerned about how the text implies, in
error, certain types, locations and amounts or mitigation that will be provided by us. This
needs to be remedied by referring to the jurisdictional mitigation sections orthe H. T.
Harvey report.
A:\\\'ll\'Do\\5RMh~u~~oulevard, Suite A, Pleasanton, California 94566 Phone 925 485-1060 Fax 925 485-1065
3.3
3.4
3.7
Mr. Eddie Peabody, Jr.
December 6, 1999
Page Two
Mitigation Measure 5 of the Initial Study requires that the project's "fair share
contribution" for downstream improvements be documented. It should be noted that
ACFC Zone 7 has a drainage program for This purpose and that the project will pay Zone
7 fees and the need to study or "document" this should removed from the Initial Study.
There is a concern regarding the floodplain discussion. The mitigation measure calling
for certification prior to approval of grading permits is unclear and we suspect that the
intention is not consistent with flood plain processing. We believe the "certification"
which the Initial Study is referring to is a certification that the property is filled that '
FEMA requires prior to taking the property out of the floodplain. The mitigation measure
should reflect FEMA requirements and read "Applicant shall remove habitable portions
of the project from the 100 year FEMA floodplain prior to occupancy permits being
issued." The applicant has already obtained a conditional letter of map revision.
3.5
I
I
Much of the tex"t in these documents appear to be written generally so as to cover all three
i\Teas. Because of this, additional clarification of certain issues is needed to prevent
confusion and inaccuracies, such as the Initial Study text concerning cultural resources
and tiger salamanders is pertinent only to Area F.
3.6
The Initial Studies include numerous traffic mitigations that are very specific and were
taken directly from the traffic report. It should be pointed out that these mitigation
measures assume a long list of developments and improvements having occurred in the
area before this project comes on line. This long list of assumptions is highly speculative
and mayor may not be accurate. Rather than require a specific list of improvements, the
mitigation measures should require that the project be conditioned to maintain acceptable
levels of service and that the improvements necessary may include the list attached. We
suspect that some of the improvements listed may not be able to be done today since the
intersection configurations assumed in the traffic reports do not even exist today. Also, it
should be pointed out that the mitigation measures listed apply to all three areas, not just
each individual area.
In regards to park acreage requirements for both Areas F and G, the population figures to
determine park need have been miscalculated. The numbers included in the Initial Study
represent dwelling units rather than population. This error then affects the quantity of
park acreage required to service the projected population. Additionally, for both Areas F
and G, the park acreage requirement per capita has been miscalculated. The Initial Study
uses the full 5 acres of required park land to project local park acreage, whereas 1.5 acres
should be used. (The other 3.5 acres is the community parks requirement).
A:\WIl\'DOW-l\l6034-1.DOC
Mr. Eddie Peabody, Jr.
December 6, 1999
Page Thee
. 3.8 We have a couple of different concerns regarding the noise sections. First, for Area H
and G, it is noted that the planning area would be subject to significant long-term noise
exposure, defined as a CNEL of 60 dB fot exterior noise. However, this CNEL standard
applies only to residential development, none of which is proposed to occur in Area H
and in Area G, only a portion of the overall land plan. There are additional inaccurate
statements concerning the extent and level of existing noise impacts to the proposed
projects.
3 . 9 There are no residential uses proposed for Area H. Hence, all references to inclusionary
zoning and residential uses should be eliminated from this document.
3.10 In all three Areas, the words "intermittent creeks", "creeks" and/or "streams" are used.
There are no "creeks" or "streams," intermittent or not, on the property. These features
are should be referred to as "defmed drainages" or "swales", depending upon their
physiology.
Tnank you for permitting us to review and comment upon these documents. Our list of
comments for the three Areas is attached. We believe that our concerns should be
addressed and corrected prior to the Planning Commission hearing. Please contact me if
you have any questions or comments.
Very truly yours,
C/77~~
MARTIN W. INDERBITZEN
cc: M. Porto and A. Kinney
Enclosure
A:\WINDOW':'I\16034-1.DOC
Letter 4
RECEIVED
IJ t: (; ti 1999
DUBLIN PLANNING
Below are comments provided by the Lin Team in response to their review of the Dublin
Rancn Areas F, G, and H Mitigated Negative Declaration and Initial Study documents.
Overall
4.1 1. Much of text is written generally to cover all three project areas, but makes
information confusing and in many instances, not appropriate to a specific Area.
Area H
1. Page 3, first paragraph, second line: The use of the word "vacant" is wrong. 'While
4.2 it is true the land is not developed, agricultural and cattle grazing uses continue on the
site.
2. Page 3, Project Description, first paragraph: Does not mention that a Master
4.3 Tentative Map is also intended to be addressed by this Initial Study or that of Area F,
only a "lot line adjustment to separate Planning Area from the balance of Dublin
Ranch. "
4.4 3. Exhibit 3- Site Location: Figure number should be 2, not 3.
4.5
4. Page 4, Stagel Development Plan, first paragraph: It is not necessarily true that that
a Stage 2 PD Rezone application will be filed at the same time as the Tentative Map
and Site Development Review. A Stage 2 PD Rezone could be submitted prior to or
with a Tentative Map and/or Site Development ReVIew application.
5. Page 4, Stage 1 Development Plan, fourth paragraph: Internal collector roads are
4 . 6 only one instance of providing a roadway system. Other potential systems may be
provided via a collector loop, or some other system. The final system will be
determined prior to the submittal of the individual tentative map and created only as
specific users are found. This Initial Study comment implies that this is the final and
only solution. The word "collector" should be eliminated from the teA'!.
. 6. Page 5, second paragraph: No housing is proposed for Area H, therefore, there
4 . 7 should be no discussion of inclusionary zoning here. This paragraph should be
deleted.
7. Page 5, Assessment Districts, second paragraph, second line: We believe "initial
4.8 study" should be "assessment district",
8. Page 5, Other Entitlements, first paragraph: Although a lot line adjustment is noted,
4.9 Master Tentative Map has not been included as an entitlement as part of this
application/Initial Study.
9. Page 10, Other public age~~y ;equired approvals, last li~e: We-think "Permits"
4.10 should be "Authorization" or "401 Certification" instead.
Pa~ 1
A:\WINDOW-l\lSREVE-I.DOC
10. Page 10, Project Description: Again, Master Tentative Map is not noted as being part
4.11 of this application/Initial Study.
11. Page 11, Environmental Factors Potentially Affected: It is noted that "The
-;;4.12 environmental factors checked below would be potentially affected by this project,
involving at least one impact that is a -"potentially significant impact" as indicated by
the check/ist on the following pages." However, no "potentially significant impact"
exists on this checklist. All environmental impacts are "less than significant with
mitigation" or less. This statement is not accurate. Rather, it should state that
impacts are potentially significant unless mitigation is incorporated.
Additionally, this page contains no signature or date.
4 .13 12. Page 15, V Cultural Resources: Refer to Item 27.
13. Page 19, XIII Public Services, a): We don't understand the basis for which this is
4 14 checked as "less than significant with mitigation". This should be "less than
. significant impact" or "no impact".
14. Page 21 and 22, .l'171 .A1andatory Findings of Significance, a) and b): We question
the "No impact". Tnis depends on how the item is interpreted. If the item is referring
4.15 to the region, the assessment is valid. If it is referring to just the project site, the
assessment conclusion is not valid since the project proposes to wipe out everything,
including jurisdictional wetlands.
4.16 15. Page 23, last paragraph, second line: Area F should be revised to Area H.
4.17 16. Page 24, I Aesthetics, Environmental Setting: Refer to Item 1 regarding "vacant".
17. Page 24, I Aesthetics, Project Impacts and Mitigation Measures, a), second line:
4.1 8 The use of the word "former" is inaccurate as the fields are still being used for
agricultural use. Refer to Item 1 regarding "vacant",
18. Page 24, I Aesthetics, Project Impacts and Mitigation Measures, b), second
4.19 paragraph: "Where there is a Statement of Overriding Considerations, the impact
remains potentially significant and unavoidable. It isn't reduced to "less than
significant" in succeeding environmental documents as stated by this item.
19. Page 24, I Aesthetics, Project Impacts and ~Mitigation Measures, c): Where there is a
Statement of Overriding Considerations, the impact remains potentially significant
4.20
and unavoidable. It isn't reduced to "less than significant" in succeeding
environmental documents as stated by.this item.
Page 2
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20. Page 25, IlAgricultural Resources, Environmental Setting, third line: Same as
4.21 above.
4.2221. Page 26, Project Impacts and Mitigation Measures, b): Refer to Item 19 above.
22. Page 26, IV. Biological Resources, Environmental Setting, third line: The word
4.23 "one" should be replaced with "at least once".
23. Page 28, Wetlands, last sentence: This sentence is not accurate. CDFG jurisdictional
4. 24 habitat does exist in Area H. This occurs in a ditch, paralleling the frontage road,
which ex"tends from the elevated farm road to the G-3 channel. As a side note, we
have received a verification letter from the Corps that they have accepted our
jurisdictional delineation for Areas H and F. We will forward you a courtesy copy
shortly.
24. Page 28, Project impacts and mitigation measures: This section implies that certain
4 .25 plant and animal species are present on site when evidence has been submitted to the
contrary. Refer to the H. T. Harvey report.
25. Exhibit 5.' Title should be "Jurisdictional Areas", not "wetlands" as the map shows all
4.26 waters subj ect to Corps jurisdiction, not just wetlands.
26. Page 28, Project Impacts and JvJitigation Measures, a): There are no California tiger
7 salamanders within Area G based on all on-site surveys undertaken to date. The
4.2
reference to them needs to be removed. Additionally, we are confused about the
borrowing owL It should be made clear that if owls are not found on the site, then a
habitat set-aside is not required.
27. Page 30, Cultural Resources, Environmental Setting, first paragraph: Based upon
4.28 the FEIR, no potentially significant archaeological resources have been identified
within Area H. The Initial Study statement is not accurate here and is only true for
Area F. The second paragraph should be deleted completely as this resurvey did not
occur in Area H. Because of this error, Project Impacts and Mitigation Measures and
the Checklist should be reviewed and revised as necessary.
28. Page 30, Project Impacts and Mitigation Measures, Mitigation Measure 2: We are
. 4.29 concerned that the verbiage specifies a 23 acre mitigation site in Livermore. We do
not believe it is appropriate at this time to refer to a specific size as mitigation
amounts will be dependent upon the outcome of our discussions with the Corps and
other agencies. The text should be revised to delete the words "23 acres."
29. Page 31, throughout- Why are Areas F and G b~ing discussed here? This is the
4 .30 Initial Study only for Area ij. __
Page. 3
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4.31 30. Page 32, first full paragraph, second to last line: Delete" minllnizing grading on
steep slopes" there are no steep slopes within Area H.
31. Page 33, VIII Hydrology and Water Quality, Environmental Setting: The following
sentence is not accurate- "The project site is hilly with several intermittent creeks
4.32 .
flowing through it". There are no hills or intermittent creeks in Area H. In additIon,
there are no creeks within Areas F or 6 either. These elements are properly referred
to as defmed drainages.-
32. Page 33, Mitigation Measure 4, second paragraph: The NPDES verbiage needs to
4.33 be revised. It should say "file a notice of intent with the state", not "obtain a notice
from the state".
33. Page 34, e), Mitigation Measure 5: This measure requires that the project's "fair
4.34 share contribution" for dovvnstream improvements be documented. It should be noted
that ACFC Zone 7 has an existing drainage program for this purpose and that the
project will pay Zone 7 fees. The need to further study or "document" this item
should removed from the Initial Study.
34. Page 34, g) and Page 35, h,i): The mitigation measures and probably the discussion
of the flood plain issues need to be rewritten:- We have already obtained a conditional
4.35 letter of map revision from FEMA in which they agree to take the property out of the
flood plain once it is filled to specific elevations. Once the fill is done, FEMA will
take the area out of the flood plain. The mitigation measure calling for certification
prior to approval of grading permits is unclear and we suspect that the intention is not
consistent with flood plain processing. We believe the "certification" the Initial
Study is referring to is a certification that the property is filled which FEMA requires
prior to taking the property out of the flood plain.
The mitigation measure should reflect FEMA requirements and read "Applicant shall
remove habitable portions of the project from the 100 year FEMA flood plain prior to
occupancy permits being issued". For your reference, the applicant has already
obtained a conditional letter of map revision,
35. Page 35, h,i).: The study concludes that there are no hazards due to dam or levee
break because the upstream stock pond will be removed. However, there should
4.36 probably be a comment that in the event the pond is not removed, embankments will
be reinforced to eliminate dam failure as a potential hazard.
36. Page 37, Xl Noise, Environmental Setting, second paragraph: There are a couple of
issues here. One, the Eastern Dublin EIR notes that a "CNEL of 60 dB or less is
4 . 3 7 considered normally acceptable for residential de:velopment. The paragraph in the
Initial Study should be rewri1:tentoseflecrthis as no residential uses are proposed in
Area H. Secondly, the use of sound walls along 1-580 are excluded from occurring by
Page 4
A:\WINDOW-l\lSREVE- LDOC
the City's Eastern Dublin Scenic Corridor Policies and Standards. This sentence
should also be revised.
37. Page 38, Project Impacts and Mitigation Measures, a): The study lists fire sprinklers
4.38 as an element of the project. We suspect that there are portions of the project that.
may not be required to have sprinklers and, if so, this comment should be removed.
38. Page 43: There is no table present on Page 43, Table 2 Comparison of Trip
4.39 Generation. We assume this was for the table on Page 47 and 47.5. Wby are Area F
- and G comparisons included here?
39. Page 44, Mitigation Measure 7 and Page 46, Mitigation Measure 8: The study
includes numerous traffic mitigations that are very specific and we assume are taken
4.40 from the Areas F, G, and H traffic report directly.
It should be pointed out that mitigation measures taken from the traffic report assume
a long list of developments and improvements having occurred in the area before this
project comes on line. This long list of assumptions is highly speculative and mayor
may not be accurate. Rather than require a specific list of improvements, the
mitigation measure should require that the project be conditioned to maintain
acceptable levels of service and that the list ef improvements ~ include the list
. attached. We suspect that some of the improvements necessary may not be able to be
done today since the intersection configurations assumed in the traffic reports do not
even exist today.
Also, it should be noted that the mitigation measures listed apply to all of Dublin
Ranch Areas F, G, and H, not just each individual Area. This should be pointed out in
the Initial Study.
4.41 40. Page 46, d), second line and g), first line: Substitute Area H for Area F.
4.42 41. Page 46, e): No new residences are planned in Area H.
Area G
4.43 1. Refer to comments on Area H.
4.44 2. Page 2, second to last line: Refer to AreaH concerning use of the word "vacant."
4.45
3. Page 3, Specific Plan/General Plan Amendment, first paragraph: This paragraph is
incorrect, since there are no Medium High Density Residential, Open Space, Middle
School and Elementary School designations sho\YD- for the Area G in the current
Specific Plan. Table 1 points,thisout.-,----
Page~
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4..<46 4. Page 4, sixth paragraph, first sentence: This sentence is not clear and it appears
something is missing.
4.47 5, Page 9, Exhibit 4: It is unclear which area is Area G.
4.48 6. Page 10, 7. Zoning: This appears to be the zoning for Area F not Area G.
4.49
7. Page 11, Environmental Factors Potentially Affected: It is noted that "The
environmental factors checked below would be potentially affected by this project,
involving at least one impact that is a "potentially significant impact" as indicated by
the checklist on the following pages." However, no "potentially significant impact"
exists on this checklist. All environmental impacts are "less than significant with
mitigation" or less. This statement is not accurate. Rather, it should state that
impacts are potentially significant unless mitigation is incorporated.
8.
4.50
Page 24, Project Impacts and Mitigation, c): Where there is a Statement of
Overriding Considerations, the impact remains potentially significant and
unavoidable. It isn't reduced to "less than significant" in succeeding environmental
documents as stated by this item.
4.51 9. Page 26, e): Refer to above concerning Statement of Overriding Considerations.
10. Page 26, fl/. Biological Resources, Environmental Setting, first paragraph, second to
4.52 last line: "Fallow" implies abandonment. It should be made clear that this land is
disced for weed control, grazed, etc. Exchange the word" one" for" at least once." _
4.53 11. Page 26, IV. Biological Resources, Environmental Setting, secondparagraph, second
line: Delete the word "draft".
4.54 12. Page 27, second paragraph, first line: Add "ponded areas and" in front of
"wetlands" .
J3.Page 27, second paragraph, second line: After the second "lu-ea G" add "contained
4 . 5 5 small isolated areas of short term ponding along the access road, bisecting Area G
(and Area H) and these ponded areas".
14. Page 31, Drainage, first paragraph, first and second line: There are no intermittent
4 .56 streams on the property. These are gentle swales. Streams are considered to be
jurisdictional.
15. Page 32, VllI Hydrology and Water Quality, Environmental Setting, first line: Refer
4.57 to item 14 above concerning the word "stream".
16. Page 33, Project Impacts and Mitigation Measures, b): Wedon'funderstand this
4.58 rationale. As noted in our various hydrology and Corps permit reports that because of
Paae-6
o
A:\WlNDOW-IUSREVE-I.DOC
the clay soil type found on site there is little, if any recharge of groundwater. The
dense clay layer near the surface prevents downward movement of water.
4.59 17. Page 33, Project Impacts and Mitigation Measures, c), first paragraph: Refer to
item 14 above concerning streams.
4.60 18. Page 34, c), fifth line: Refer to item 14 above concerning streams.
4.6119. Page 35, hi): The discussion does not answer the question.
4 62 20. Page 35, IX. Land Use Planning, last line of page: 240 dwellings should be revised
. to 275 dwellings.
21. Page 36, XI Noise, Environmental Setting, second paragraph: Refer to Area H, Item
4.63"'6 . 'd' I' d d
:J concernmg non-res 1 entIa nOIse stan ar s.
4.64
22. Page 36, XI Noise, Environmental Setting, third paragraph: This statement is
inaccurate and should be revised. First, it does not separate noise exposure/levels by
land use type and secondly, it infers that the projected noise level within all of Area G
is at 65 dB. This is not true, only a very small portion of Area G has an overlay dB of
65 with the rest of the Area being less than 6S dB. Additionally, this paragraph does
not add the disclaimer included in Area H, being that foreground buildings, walls, etc.
v..rill attenuate and reduce much of the exterior noise before it reaches Area G. This
statement has more bearing on this Area than in Area H as it is a greater distance from
the freeway. Finally, the text needs to be revised to clarify that Areas G and Fare no(
impacted by noise generated by Tassajara Road.
23. Page 37, XII Population and Housing, Project Impacts and Mitigation Measures, a),
ninth line: The total population number of Area G should be 2,808, not the 1,404
4.65 number listed, which is the dwelling count. Two lines later a figure of 2,084 is listed
for the approved Planning Area G plan. If this is the East Dublin Specific Plan
(EDSP) population, this number is an error. The EDSP permits 818 dwellings which
works out to 1636 residents. If this 2,084 figure is not the EDSP population for Area
G, additional explanation needs to be provided? The subsequent analysis will need to
be revised. Area F population should be included in this discussion as land uses and
densities have been re-allocated between the two areas and would help to present a
clearer picture of the overall units and population anticipated between the EDSP and
our proposal.
4.66
l
24. Page 40, paragraph b), third line: The number 1,404 should be revised to 2,808
(refer to item 19 above). The total park acreage of 7.02 acres noted on Line 5, which
calculates the acreage required for local parks, is incorrect. First, it uses the 'Wrong
population figure. Second, it.:us~?the standard of 5 acres per WOO residents. Per
current City standards, local parks are' only 1.5 acres of the total, With community
Page,?
A:\WINDOW-l\ISREVE-l,DOC
parks making up the remaining 3.5 acres per 1,000 population. Hence, the 7.02 acre
figure should be revised to 4.2 acres for local parks.
Additionally, this will affect the overall Area F and G park acreage total, which
should be revised to 6.7 acres instead of the existing 15.3 acres.
Because of this acreage difference, the fmdings of this paragraph need to be revised to
state that the amended Area G plan provides an additional 5.0 acres of local park land
than is required and when, combined with Area F, an excess of 10.1 local park acres
are provided.
4.67 25. Page 46, throughout: Revise the four "Area F" to "Area G".
Area F
4.68 1. Refer to comments on Areas H and G.
4.69 2. Page 3, second line: Refer to Area H concerning the word "creek".
3. Page 3, Project Description, Specific Plan/General Plan Amendment, second
4.70 paragraph: The first line should be revised to read all of the Medium Hi.gh Density,
not a portion as noted.
4.
4.71
Page 4, Table 1: Land Use acreages where not updated as submitted on EDGP/SP A
Exhibit as provided by MacKay & Somps and included in the Initial Study. Acreages.
that are not correct are Medium Density Residential (68.9), Public/Semi-Public (3.9),
and Open Space (2.8) and the units of Medium Density Residential (689).
5. Page 4, first paragraph of page: This paragraph is not really true. All north-south
4.72 streets shown in our land plans are illustrated in the EDSP Land Use Map. It is only
the intent of the central north-south street that has been adjusted by our proposal.
Additionally, these streets do not go through Area H as stated.
4.73 6. Page 5, Assessment Districts, first paragraph: Need to add Area F in addition to or
instead of the Area Gs.
4.74
7. Page 6, second paragraph: Again, there is no discussion of a Master Tentative Map
being included under this Initial Study. Additionally, the lot line adjustment that is
noted does not include Parcel 0 by reference.
4.75 8. Page 11,1. Project Description: See above.
9. Page 11, 6. General Plan designations-: Middle School,Elenientary School,
4.76 Neighborhood Park, Neighborhood Square, Public and Semi-Publfc are not zoning
PageS
A:\WINDOW-l\ISREVE-l.DOC
districts. If this remains, the Middle School should be revised to High School as this
is what is illustrated in the GP and EDSP.
10. Page 12, first paragraph: It is noted that "The environmental factors checked below
would be potentially affected by this project, involving at least one impact that is a
4.77 "potentially significant impact" as indicated by the checklist on the following pages. "
However, no "potentially significant impact" exists on this checklist. All
environmental impacts are "less than significant with mitigation" or less. This
statement is misleading and erroneous. Rather, it should state that impacts are
potentially significant unless mitigation is incorporated.
4.78
11. Page 25, Project Impacts and Mitigation Measures, c): Where there is a Statement of
Overriding Considerations, the impact remains potentially significant and
unavoidable. It isn't reduced to "less than significant" in succeeding environmental
documents as stated by this item.
4.79 12. Page 27, b), secondparagraph: Refer to Item 11 above concerning Statement of
Overriding Considerations.
13. Page 27, d,e): Refer to Item 11 above concerning Statement of Overriding
4.80 C'd
ons! erations.
14. Page 27, IV. Biological Resources, Environmental Setting, first paragraph, second to
4 . 81 last line: Exchange the word " one" for" at least once."
4.82
15. Page 31, (iii), last sentence: The reference to "a minimum buffer of 300 feet along
the stream in the northern drainage" to be preserved ror red-legged frogs should be
replaced with "appropriate buffers along the drainage will be preserved." This is
because the specific dimension will be dependent upon the outcome of our
discussions with the Corps and other agencies and it has not been set at this time.
"Stream" should be replaced with "tributary drainage" to accurately describe this
feature.
4.83
16. Page 32, Mitigation Measure 3 (i), sentence beginning at end of line four: This
sentence describes the proposed mitigation configuration, yet says".., will be filled
and later recreated..." (specific text in line six). This implies that our proposed
mitigation is the existing condition to be filled and recreated. "Filled and later
recreated near its former location" should be changed to "created" to clarify that these
are the measurements for the constructed feature, and not the jurisdictional area.
Additionally, in the third to last line of the paragraph, the word "in-kind" is used. We
have not proposed mitigation to be "in-kind," but have proposed mitigation to be
provided by seasonally ponded areas.
Page.9
A:\WINDOW-l\ISREVE-l.DOC
4.84
17. Page 32, Mitigation Measure 3 (ii), second and third line: See above. Additionally,
we are confused as to what this is saying we are offering for mitigation. Refer to the
H. T. Harvey report.
4.85
18. Page 35, first and fifth paragraph of page: The Initial Study text reads "The
preliminary geotechnical report indicates a history of landslides on the site".
However, the Berlogar report text referenced by this statement reads: "Some of the
swales on the site show evidence of previous landsliding." This is doesn't indicate an
extensive history of landslides across the site. The Initial Study text should be
rewritten to more accurately reflect the existing conditions.
19. Page 35, Drainage, second line: "Stream" should be revised to "defined drainage."
4.86
20. Page 37, throughout: As noted previously in this Area and other Areas, no
4 . 8 7 intermittent creeks or streams are located on site, only defined drainages. Initial
Study teA"! should be revised accordingly.
21. Page 39, IX. Land Use and Planning, Project Impacts and Mitigation Measures, (b),
4.88 first paragraph: The last sentence doesn't make sense. Please advise the meaning of
". ..changes to Circulation Element...".
22. Page 39, IX. Land Use and Planning, Project Impacts and Mitigation Measures, (b),
4.89 second paragraph: As in Area G, the 240 dwellings should be changed to 275.
23. Page 40. Xl. Noise, Environmental Setting, second paragraph: There are a few issue.s
of concern here. One, the EIR Future Noise Contours Map shows the 60 dB line as
4.90 bordering Area F (i.e.: the line parallels Central Parkway). The sentence in the Initial
Study is in error by stating that "minor portions of Area F would be subject to
significant long-term noise exposm:e" when in fact it is not. Secondly, Tassajara
Road is not a noise source affecting Area F per the EIR Future Noise Contours Map
since the noise contours are not even close to Area F. Lastly, this paragraph does not
add the disclaimer included in Area H, that foreground buildings, walls, etc. will
attenuate and reduce much ofthe exterior noise before it reaches Area F. This
statement has more bearing in this Area as it is a greater distance from noise
generators. This entire paragraph should be rewritten to incorporate these items.
24. Page 41, XII Population and Housing, Project Impacts and Mitigation Measures, a),
lines 9 and 11: Because the most current dwelling unit totals were not used in Table
4.91 '1, these population figures are slightly off. Instead of 1,677 for an amended
population, the figure should be 1,669. Instead of 1,091 for the existing GP/SP A, the
number should be 1,092.
25. Page 43, XlV. Recreation, Proje.0.t}mpactsand MitigationMeasures, a), first
paragraph, first sentence: This sentence does not take into account that for just Area
4.92 F, our amended plan proposes a lower population figure than the existing EDSP plan
PageLO
A:\WlNDOW-l\1SREVE-I.DOC
does (i.e.: 1,669 people vs. 2,297 people). Only if both Area F and Area G are looked
at together does the amended population figure exceed the existing GPIEDSP
population figure.
26. Page 43, XIV. Recreation, Project Impacts and Mitigation Measures, b), second line:
4.93 Again, the population figure should be 1,669 and not 1,677.
4.94
26. Page 44, first paragraph: This paragraph is supposed to be discussing the Area F
neighborhood park dedication requirements. However, the figure noted is for all
(community and local) park acreage. Neighborhood park acreage requirements for
Area Fare 2.5 acres, not the 8.3 noted. Because of this error and the problems
already noted in Area G, the second to the last sentence needs to be rewritten to say
that the overall Area F and G neighborhoodllocal park requirement is 6.7 acres while
the Area plans provide a total of 16.8 acres. This creates an excess of 10.1 acres of
neighborhood/local park provided by the amended plan than is required to be
dedicated.
4.95 27. Page 51, e): Wastewater disposal is not discussed here.
Page,l1
A:\WlNDOW-I\!SREVE-I_DOC
REGIONAL PARKS
~
~..
EAST BAY REGIONAL PARK DISTRICT
December 7, 1999 .
RECEIVED
DEe 1 3 1999
DUBLIN PLANNING
Letter 5
Mr. Jerry Haag
. Community Development Department
City of Dublin
P.O. Box 2340
Dublin, CA 94568
Subject: Comments on Mitigated Negative Declarations for Dublin Ranch Areas F, G & H
P A-98-068, -069 and -070, Tassajara Creek Regional Trail
Dear Mr, Haag:
BOARD OF DIRECTORS
Beverly Lane
PreSIdent
Ward 6
Carol Severin
Vlce-Presldeni
Ward 3
John Sutier
Treasurer
Ward 2
Ayn Wieskamo
Secre:ary .
Ward 5
ied Radke
Ward i
Doug Siden
Ward 4
Jean Siri
Waro 1
The East Bay Regional Park District (District) has reviewed the proposed Mitigated Negative ". .~.
Declarations (MND) for the proposed Dublin Ranch Developments, Areas F, G and H in Dublin, ~~~~ltJ~~e~ger
are submitting written comments on the subject proposal as part of our on-going interest in completing
the Tassajara Creek Regional Trail, and in protecting Tassajara Creek and the important natural
resources of the East Dublin area.
. -
The District has for the past 65 years promoted the conservation of open space and"protection of
important natural resources in the East Bay. District staff have participated in a variety of public
planning issues in the City of Dublin where we have promoted these interests, including the City's East
Dublin General Plan and Specific Plan, and subsequent development proposals along Tassajara Creek,
including the Casterson and Greenbriar Homes developments.
In our comments on the Greenbriar Homes development proposal, we raised several concerns about
the adequacy of the East Dublin Specific Plan (EDSP) Environmental Impact Report (EIR) to address
project impacts to Tassajara Creek and the Federally-threatened California red-legged frog in light of
significant new information that has been documented since the EDSP EIR was Certified in 1993, We
also stated that the proposed MND for Greenbriar Homes would be inadequate for our CEQA
compliance purposes (as a responsible agency) should the District assume management responsibility
for portions of the Tassajara Creek Regional Trail which are constructed as a required element of the
Greenbriar Homes development.
To the extent that development projects in the East Dublin area either directly affect the Tassajara
Creek Corridor in which the regional trail is located, or propose off-site mitigation within that corridor,
it is a concern of the District that impacts on the corridor are environmentally acceptable to the State
and federal resource agencies, and to the District.
Imnacts to District Pronertv
The subject MND contains a report prepared by H.T. Harvey & Associates entitled "Dublin Ranch
Areas F, G and H Ecological Impacts and Mitigation". Page 33 of this report identifies Tassajara
Creek as the proposed location to mitigate for Dublin Ranch project impacts to "CDFG jurisdictional
areas and red-legged frog habitat" by preserving, enhancing and restoring a 5200 foot section of
Tassajara Creek to the north of the pr0posed Greeribriar Homes Development. We are concerned
because a large portion of this proposed mitigation site is already owned by the District and
consequently would not be available for use as a mitigation site for the Dublin Ranch Development.
5.1
2950 Peralta Oaks Court P.O. Box 5381 Oakland, CA 94605-0381
www.ebparks.org ~ TEL: 510 635-0135
~~~. :::.rl t::??rlAt::rl ~4 "_v' ::;1nr:;;:;q.A."I19
Figure 5 of the H. T. Harvey Report depicts the proposed locations for these mitigation measures along
Tassjara Creek, yet it does not contain any property boundaries which would show precisely where
these mitigation sites are located or who owns the underlying land. Using this existing figure, we have
attempted to overlay existing District land ownership information in this map and have discovered that
approximately one-half of the west bank of the Tassajara Creek mitigation site may already be owned
by the District as public open space and as a regional trail. Furthermore, at least one entire and 1\vo
partial proposed restoration sites may be contained within District lands.
Since this project will result in significant impacts to wetlands and red-legged frog habitat and because
the MND proposes use of Tassajara Creek as the mitigation site, it is imperative that the MND contain
adequate information on property ownership and assurances that the proposed mitigation sites are
actually available for use by the applicant to mitigate for project impacts. Absent such information,
the MND cannot adequately demonstrate that potentially significant impacts can and will be mitigated
to a less-than-significant level. I have enclosed two maps showing our property ownership in this area,
Cumulative Impacts to Tassaiara Creek and Snecial-Status Species
The District, City of Dublin, Greenbriar Homes, US Fish and Wildlife Service (USFWS) and -
5.2 California Depart:rnent ofFish and Game (CDFG) are currently seeking to resolve conflicts between
the proposed Greenbriar Homes Development, including a segment of the Tassajara Creek Regional
Trail, and the species conservation and mitigation requirements for project impacts to red-legged frog
and Tassajara Creek. It is likely that resolution of this complex issue will take several months and will
require major revisions to Greenbriar Homes Development proposals and to subsequent development
proposals that affect Tassajara Creek or special-status species in the East Dublin area.
The proposed Dublin Ranch MND identifies potentially significant impacts to two special-status
plants, California tiger salamander, red-legged frogs, burrowing owls, badgers and nesting raptors.
Many of these potential impacts were not properly addressed in the EDSP Final ErR or the species
were not known to be present in the project area at the time the Final EIR was certified. The City may
wish to postpone consideration of new developments in the East Dublin area that impact special-status -
species until such time as conflicts between development and species conservation have been resolved
in some regional fashion. This would likely require revisions to the East Dublin Specific Plan and
Final ErR, and as recommended by USFWS, the preparation of a multi-species habitat conservation
plan that addresses the individual and cumulative effects to special-status species. This approach is
being considered by the Cities ofLivermore;-Clayton, Pittsburg, Antioch and Brentwood through
individual and regional habitat conservation planning efforts.
Please call me at (510) 544-2622 should you have any questions about this comment letter or Steve
Fiala at (510) 544-2602 for any specific questions about Tassajara Creek Regional Trail.
Sincerely,
~vrf tfllL~"
Brad Olson
Environmental Specialist
attachments (2)
cc: Dennis Carrington, City of Dublin Planning Department
Janice Gan/Scott Wilson, California Department ofFish and Game
Curt McCasland, US Fish and Wildlife Service
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6.1
~ate of Cali~ornia_= The Resources A~ency __._______.._________
GRAY DAVIS, Governor
DEPARTMENT OF FISH AND GAME
http://www.dfg.ca.gov
POST OFFICE BOX 47
YOU NTVI LLE, CALIFORNIA 94599
(707) 944-5500
--
December 8,1999
RECEIVED
DEG 1 3 1999
DUBLIN pLANNING
Mr. Dennis Carrington
Ci ty of Dublin .
Planning Department
Post Office Box 2340
Dublin, California 94568
Letter 6
Dear Mr. Carrington:
Dublin. Ranch Residential Development
Planning Application Numbers,
Area F PA 98-068, Area G PA 98-069, Area H PA 98-070
Mitigated Negative Declaration
City of Dublin, Alameda County
Department of Fish and Game personnel have reviewed the
subject documents. This project, is part of a four-phase
development known as Dublin Ran.ch. Phase One has already been
permitted and is under construction. Negative Declarations have
been submitted for the remaining 3D5 acres which have been
divided into three Planning Areas, F, G, and H. Area F is 147
acres. It lies south of Phase One and immediately north of Areas
G (87 acres), and H (71 acres). These comments address
development of these three planning areas of the Dublin Ranch.
The proposed project lies within the Eastern Dublin Specific
Plan Area. A program-level Environmental Impact Report (EIR) was
prepared for this planning area in 1992 and a Final EIR (FEIR)
was adopted in.1993. The Initial Study Checklist was prepared to
determine whether there are potential significant site-specific
environmental impacts not examined in the FEIR and whether
project-specific mitigation measures would reduce the level of
impacts to a point where a Mitigated Negative Declaration would
be adequate to meet California Environmental Quality Act (CEQA)
requirements.
Based on substantial new information, including species
listing and cumulative impacts, the Department does not believe
that the FEIR for the Dublin Specific Area Plan fully discussed
species occurrences or established appropriate mitigation for
these species. The Dublin Ranch projects involve impacts to
species not covered or not adequately addressed in the FEIR. The
FEIR, therefore, should not be referenced as adequate under CEQA
for disclosure or providing mitigation for these species.
C,04N''~-0J/ C.d:;.}:O"v14'/} VJ;jJ;J;ji 5-0-v..L- 1~70
'0 v v
Mr. Dennis Carrington
December 8, 1999
Page Two
The determination in the Ini~ia1.Study page 12 states
6.2~a1though the proposed project ~ou1d have significant effect on
the environment there will not be a significant effect in this
case because the mitigation measure...have been added to the
project." It is the Department's opinion that mitigation
measures proposed for this project will not reduce the effects or
mitigate the effects to a point where clearly no significant
effect on the environment would occur as required by CEQA. Page
52 of the Initial Study for PA F states that the project ~il1 not
~reduce the number or restrict the range of a rare, endangered
plant or animal." However, page 29 states that impacts to
California red-legged frog (Rana aurora draytonii) and California
tiger salamander (Ambystoma californiense) will result from the
project. In addition, the Department disagrees with this
determination due to potential impacts to kit fox. Therefore,
due to the fact that the construction of this project will reduce
the number and restrict the range of an endangered, rare, or
threatened species, a mandatoryfirlding of significance must be
made.
California Red-legged Frog
6.3 It is the opinion of the Department that construction of
this project will result in fragmentation of habitat and blocking
of movement corridors of the California red-legged frog and that
the mitigation as proposed is not adequate to reduce the impacts
to a level that is less than-significant.
According to the Initial Study PA F, red-legged frogs have
been documented in the pond on Area F of the site, within 3/4
mile to the north, and within 1/2 mile to the east. The
applicant states no frogs were detected to the south or west of
the site and, therefore, the development of the site is not
expected to provide a barrier to dispersal of California red-
legged frogs. The applicant also states that areas of the site
other than the stock pond are likely not of substantial
importance to this species.
6.4
The Department does not agree with this finding and believes
that impacts to red-legged frogs have been underestimated.
\ Recent research has shown that red-legged frogs frequently
utilize upland habitat adjacent!o water feat~res. Regular
movement of red-legged frogs have~-been d.ocu.ri:terite~ between 200-300
feet from the edge of the creek, however, several frogs in one
Mr. Dennis Carrington
December 8, 1999
Page Three
study were documented moving over one and one-half miles during
dispersal. In addition, the February 1999 observation of a red-
legged frog in Tassajara Creek.to the west of the project site
confirms red-legged frogs occupying habitats to the west, north,
and east of the project site. Therefore, the proposed
development will impact dispersal, breeding, and foraging habitat
of the red-legged frog.
6.5
Areas along Tassajara Creek are identified as the proposed
location to mitigate for Dublin Ranch project impact to the
Department's jurisdictional areas and red-legged frog habitat.
The preservation, enhancement, and restoration of a 5200-foot
section of Tassajara Creek to the north of the proposed
Greenbriar Homes Development is discussed. The Department
believes that some of this area is owned by the East Bay Regional
Park District. The availability of this area as a mitigation
site is questionable and therefore is not likely to provide
adequate mitigation for impacts to red-legged frogs. The
Department recommends that the United States Fish andcWildlife
Service (USFWS) be consuited regarding the adequacy of the
proposed mitigation.
6.6
Surveys and mitigation measures for red legged-frogs shou~d
follow established USFWS and Department guidelines. The
Department recommends that measures be implemented to avoid red-
legged frog habitat within the project area.
California Tiger Salamander "-
In the October 25, 1999, report by H.T. Harvey, Ecological
6.7 Impacts and Mitigation, page 18, it states that the majority of
California tiger salamander (CTS) (Ambystoma californiense) use
occurred in Area F. Mitigation Measure 2(ii) states that
mitigation for impacts to estivation habitat will be commensurate
with impacts on Area F only.
The Department does not agree with this finding. Because
there is documentation that CTS move long distances between
breeding habitats and estivation sites, effects of development
should be considered from the perspective of fragmentation of
habitat and blocking of movement corridors. Recent research
conducted by Peter Trenham for completion of his doctorate
requirements at u. C. Davis documentCTS'movements up to 670
meters from breeding ponds .-:"~-In addi tion, dat.a .'col1ected at the
Byron airport showed between 5 percent to 10 percent of the
Mr. Dennis Carrington
December 8, 1999
Page Four
population was moving up to 500 meters. Based on this data, the
Department considers Areas F, G, and H to be potential habitat
and recommends that measures be implemented to avoid and minimize
impacts to CTS that result through loss and modification of
estivating habitat in these areas.
Unavoidable impacts may be mitigated both by 1) implementing
a relocation program approved by the Department to minimize
~take" and; 2) developing and implementing a Mitigation Agreement
acceptable to the Department to compensate for the loss of CTS
habitat. Compensation for the loss of habitat must address the
loss of the entire breeding and estivating habitat of the CTS
population, since significant disruption of the aestivating
habitat will likely result in the inability to sustain the entire
population locally. The Mitigation Agreement must preserve
existing occupied habitat of CTS at a site acceptable to the
Department. Mitigation habitat should be provided at a minimum
1:1 compensation ratio for both estivation and breeding habitat.
Implementation of a relocation program for CTS cannot be
conducted until a Mitigation Agreement is signed by the
Department. Due to the potential that this species will be
listed by the USFWS prior to the construction of the proj.ect, we
recommend that the USrWS be consulted regarding potential permit
requirements.
San Joaquin Kit Fox
The Initial Study PA F states on pages 15 and 28 that the
6.8 San Joaquin kit fox (Vulpes macrotis mutica) is presumed absent
from the site. The Department does not concur with these
findings. The area is in the western range of the kit fox and
suitable denning and foraging habitat exists on the project site.
The document states that only the first phase of surveys were
conducted in 1997 followed by reconnaissance level surveys. In
this area, because kit foxes occur in low numbers and the
detection rate is low even in areas where they are known to be
denning, negative findings based on the survey methods employed
are not acceptable.
Close consultation with the Deoartment and the USFWS will be
needed to assure compliance with th~ State and Federal Endangered
Species Acts. Loss of habitat 1.5 considered a taking under these
Acts and will require permits ~-from both agenci-es ~ Currently,
mitigation standards for permanent loss of habitat require
Mr. Dennis Carrington
December 8, 1999
Page Five
compensatory preservation of habitat at a 3:1 ratio. Information
on what lands would be acquired or otherwise preserved as
mitigation should be provided.. Lands which are dedicated to a
public agency should include a permanent fund to cover the costs
of maintenance for the life of the project. The Department
recommends focusing mitigation to create a small number of larger
preserves in high value habitat with interconnecting corridors
for the kit fox.
Burrowing Owl
6.9 Mitigation Measure 2 (iv), page 31, describes proposed mitigation
for impacts to burrowing' owl (Athene cunicularia). The
Department considers the proposed mitigation to be inadequate.
Surveys according to established Department protocol should be
conducted on the entire project site and within a 500-foot zone
around the project site during the nesting and non-nesting
seasons. Buffers should be established around occupied burrows
at all times of the year, not only'during the breeding season.
Disturbance of burrows used by owl pairs or single birds during
the nesting or non-nesting season should. be mitigated by the
completion of a Mitigation Agreement with the Department and the
acquisition and conservation of 6.5 acres of suitable owl hab~ta!
per owl pair or single bird in a location acceptable to the
Department.
Eucalyptus Trees
The Department is opposed to the removal of the eucalyptus
6.10 trees along the southern edge of the site. As stated on page 28
of the Initial Study PA F, these trees provide potentially
suitable nesting sites for loggerhead shrike (Lanius
lUdovicianus), white-tailed kite (Elanus caeruleus), and other
tree-nesting raptors which are protected under the Migratory Bird
Treaty Act and have been observed on the project site. Golden
Eagles (Aquila chrysaetos) are also known to breed locally. Due
to the scarcity of nesting sites in the area, the proposed action
is considered by the Department to be significant if not
mitigated. Removal of these trees will result in a significant
temporal loss of potential nesting habitat and permanent loss if
mitigation is not incorporated. If it is not possible to avoid
tree removal, the Department recommends planting of large trees
in an area preserved in perpetuity as. open $p~.c:_e and otherwise
suitable -for nesting. Any--f-ree removal and 'replanting program
should be fully described in a Mitigation and Monitoring Plan
Mr. Dennis Carrington
December 8, 1999
Page Six
that would discuss the species to be planted, location,
maintenance, monitoring, succe~s criteria and security issues.
The plan would. need to be acceptable to the Department.
Based on location and the abundance of grassland habitat, it
is likely the site provides nesting and foraging habitat for a
number of species. The California horned lark (Eremophila
alpestris actia), a State Species of Special Concern, likely
breeds in the grassland on site. Suitable grassland/open space
area should be preserved to mitigate impacts to these species.
San Joaquin spearscale (Atriplex joaquiniana) and Congdon's
6.11 tarplant (Hemizonia parryi sp congdonii) were observed on the
site. A thorough field 8urvey, conducted according to the
Department's Rare Plant Survey Guidelines by a qualified botanist
during the appropriate months, is needed to determine the extent
of these species on the project si~e. CEQA Guidelines Section
15380(d) states that these species be addressed as other
threatened and endangered species and adequate mitigation be
provided for any impacts. The Department recommends that impacts
be avoided in areas where these species occur on the project
site. Conservation areas should also include an appropriate
buffer. The Department does not approve of translocation as an
acceptable mitigation measure. There is no evidence to support
that translocation is a successful technique to perpetuate
populations of these plant species and, therefore, the proposed
mitigation is viewed as experimental and does not meet the
mitigation standards of CEQA.
If avoidance of impacts to these species is not possible, a
Mitigation and Monitoring Plan should be developed that will
provide for off-site conservation of populations of these
species. The plan should be reviewed and approved by the
Department. Surveys to be conducted at a later time, or
mitigation measures to be identified at some future time, are not
acceptable. It has been determined by court ruling that such
studies and mitigation measures would be improperly exempted from
the process of public and governmental scrutiny which is required
under the CEQA. The Initial Study requests future studies and
future identification of mitigation and; therefore, is considered
inadequate.
Mr. Dennis Carrington
December 8, 1999
Page Seven
Wetlands
6.12 The project will impact 1.6 acres of wetlands in the
Department's jurisdiction including 2970 linear feet of impacts
along two seasonal drainages. Mitigation proposed is 0.48 acre
in the northern drainage and creation on-site of an 810-foot long
drainage with a 33-foot buffer on each side. The Department
recommends a minimum 100-foot buffer be established to protect
wetlands. The buffer should be measured outward from the edge of
any wetland. A recreated channel surrounded by development is
not expected to fully compensate for the functions and values of
the impacted channel. Enhancement of additional linear feet of
channel, at least equivalent to that. being impacted, should be
required.
A Streambed Alteration Agreement must be obtained from the
Department prior to any work in a lake or stream corridor. Since
the issuance of such an Agreement is subject to CEQA review,
disclosure and incorporation of mitigation measures requested by
the Department is needed to meet the requirements of CEQA.
The project will impact approximately 6.80 acres of wetlands
and waters in U. S. Army Corps of Engineers jurisdiction. It is -
the policy of this Department that a project should cause no net
loss of either wetland acreage or wetland habitat value.
Department personnel are available to address these concerns
in more detail. To arrange a meeting please contact Ms. Janice
Gan, Associate Biologist, at (209) 835-6910; Mr. Scott Wilson,
Environmental Specialist, at (707) 944-5529; or Mr. Carl Wilcox,
Environmental Program Manager, at (707) 944-5525.
Sincerely,
/~~ Hunter
Regional Manager
. Central Coast Region
cc: See next page
Mr. Dennis Carrington
December 8, 1999
Page Eight
cc: Mr. Curt McCasland
U. S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, California 97232-6340
Ms. Sheila Larsen
U. S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, California 97232-6340
Mr. Keith Lichten
State Water Resource
2101 Webster Street,
Oakland, California
Control Board
Suite 500
94612
Mr. Ed Wylie
u. S. Army Corps of Engineers
333 Market Street
San Francisco, California 94105-2197
IN REPLY REFER TO:
1-1-00-TA-371
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Sacramento Fish and Wildlife Office
2800 Cottage Way, Room W-2605
Sacramento, California 95825-1846
RECEIVED
~ ... .' J. 3 1999
DUBLIN PLANNING
December 9, 1999
Ms. Anne Kinney
City of Dublin
Planning Department
P.O. Box 2340
Dublin, California 94568
Letter 7
Subject:
Initial Study/Mitigated Negative Declarations for Dublin Ranch Planning
Areas F, G, and H.
Dear Ms. Kinney:
This is in response to the City of Dublin's Mitigated Negative Declarations and Initial Studies
dated November 8, 1999, for each of the three Dub-lin Ranch Planning Areas (F, G, and H) in the
City of Dublin, Alameda County. At issue are impacts to the San Joaquin kit fox
(Vulpes macrotis mutica) (kit fox), conservancy fail}' shrimp (Branchinecta consenJatio),
longhorn fairy shrimp (B. longiantenna), vernal pool tadpole shrimp (Lepidurus packardi),
the California red-legged frog (Rana aurora draytonii) (red-legged frog), and California tiger
salamander (Ambystoma califomiense) (salamander). The kit fox and vernal pool invertebrates
are federally listed as endangered and the red-legged frog is federally listed as threatened pursuant
to the Endangered Species Act of 1973, as amended (Act). The salamander is a candidate
species. The Service has judged the salamander to be warranted but precluded from listing action
at present by higher listing priorities. Planning Areas F, G, and H contain approximately 147, 87,
and 71 acres, respectively, and are all part of the' larger Dublin Ranch planned development, which
contains 1,310 acres. This letter provides the U.S. Fish and Wildlife Service's (Service)
COmments on the proposed modifications pursuant to the Act.
7.1 The Service is concerned with the segmentation of the proposed Dublin Ranch planning area.
The Service has previously met with the consultants for Dublin Ranch and discussed project
impacts associated with the entire Dublin Ranch project area, including the three parcels which
make up Planning Areas F, G, and H. This piecemeal approach proposed within these three
planning documents reduces the likelihood of the listed species to persist onsite (i.e., Dublin
Ranch), much less within the entire Eastern Dublin Specific Plan area. The Service requests that
the City of Dublin reevaluate these three planning documents and the remaining undeveloped
portions of the Dublin Ranch Project under one planning document. This coordinated evaluation
will allow a more practicable and realistic approlich to conserving list~~ species within your
jurisdiction. ' ',-- - "
2
Beyond the Service's concerns over the segmentation ofthe overall project, the Service does not
concur with the findings of the Initial Studies. Red-legged frogs and salamanders have been
7.2 . .
found within Planning Area F and to the west, east, and north of the project areas.. Theremammg
portions of the project areas consist primarily .of nonnative annual grassland that were historically
farmed but are currently fallow. The Service believes that the seasonal wetland found within
Planning Area H contains suitable habitat for-the conservancy fairy shrimp, the longhorn fairy
shrimp, the vernal pool tadpole shrimp, the red-legged frog, and the salamander; the surrounding
grasslands in all three planning areas, as well as the rest of Dublin Ranch, contain suitable habitat
7 .3 for red-legged frogs and salamanders. Furthennore, the Service does not concur 'with the
r presumed absence of kit foxes from the site, there have been at least two kit fox sightings within
ten miles of the project site. The planning areas contain habitat suitable for kit foxes and there are
no current impediments or barriers that would prevent kit foxes from reaching the planning areas.
7 .4 Furthennore complete protocol surveys have not been completed and the Service does not concur
I with the presumed absence of the conservancy fairy shrimp, the longhorn fairy shrimp, or the
vernal pool tadpole shrimp.
7 . 5 The Service continues to be concerned over the lack of appropriate measures to minimize impacts
to federally listed species within the East Dublin Planning Area. The measures included within all
three planning documents fail to adequately avoid significant impacts to kit foxes, red-legged
frogs, salamanders, or the vernal pool invertebrates., Your planning document~ fail to include the
upland portion of the planning areas as habitat for kit foxes, red-legged frogs, or salamanders, or
the indirect impacts associated with grading the upland portions of the seasonal wetland found in
area H. Red-legged frogs have been documented to forage beyond 200 feet of aquatic habitat in
uplands with little to no available cover. In addition, red-legged frogs have been observed
traveling distances of approximately 1-3 kilometers (0.6-1.8 miles) between breeding and
nonbreeding habitat. These dispersing frogs were observed to make both straight line movements
over upland habitat as 'well as moving along riparian corridors. Salamanders also require upland
habitat. Adult sal manders spend the majority of their lives inhabiting burrows within upland
areas. Given thes observations, it is important to preserve upland areas for adequate dispersal
corridors and non reeding habitat for both red-legged frogs and salamanders, not to mention the
use of grasslands y foraging kit foxes.
7.6 The proposed pro ects are likely to result in take of kit foxes and red-legged frogs and possibly
the conservancy fi' shrimp, the longhorn fairy shrimp, or the vernal pool tadpole shrimp. The
Service recornme ds that the project applicant discuss the entire project with the Service to
ensure that prope measures are implemented to minimize impacts to federally listed species. If a
Federal agency is volved with the permitting, funding, or carrying out of this project, then
initiation of fonn consultation between that agency and the Service pursuant to section 7 of the
Act, is required. uch consultation would result in a biological opinion addressing anticipated
effects of the project to listed and proposed species and may authorize a limited level of incidental
take. If a Federal agency is not involved with the project, and federally-listed species may be
taken as part of the project, then an "incidental take" pennit pursuant to section lO(a)(1)(B) of
the Act should be obtained. The Setvicemay issue such a permifupcnlc~mpletion by the permit
..,
.J
applicant of a satisfactory conservation plan for the listed species that would be affected by the
project.
7 . 7 In conclusion, the proposed projects will further isolate and fragment populations of red-legged
-.. . frogs within the Tassajarra Creek Watershed .and areas to the east ofTassajarra Creek. The
eastern portions of Alameda and Contra Costa Counties possess the largest populations of red-
legged frogs in the East Bay area, and these areas are currently undergoing rapid growth. The
Service believes this area is important for the long-term survival and recovery of the species. To
prevent take of red-legged frogs, the Service believes a minimum buffer distance of 300 feet
between all wetlands and adequate upland dispersal corridors are necessary to ensure the project
does not isolate red-legged frogs. The development of these corridors, in conjunction with
,:p're~ef'.~ng suit~b!e salamander upland habitat, would also mini:nize impacts to kit foxes.
Furthermore, the project should be designed to avoid nuisance summer flows entering into
Tassajarra Creek or any other water course. These actions are necessary to allow kit foxes, red-
legged frogs, the conservancy fairy shrimp, the 10nghOl:n fairy shrimp, the vernal pool tadpole
shrimp, and salamanders to persist in the project vicinity.
Your continued coordination with the Service will be essential to ensure that these listed species
persist within the East Dublin Planning area. We look forward to working with you on this
project. If you have any questions, please contact .Curt McCasland or Ken Sapchez at
(916) 414-6625.
Sincerely,
%(1 (\ Ifll1' ,1 ,1 .
'C!..JU..-.(J- i v v~
, I
{ .
Karen 1. fIler
Chief: Endangered Species Division
cc:ScottWilson,CDFG, Y ountvilIe, CA
Janice Gan, CDFG, Y ountville, CA
Keith Lichten, RWQCB, Oakland, CA
Brad Olson, EBRPD, Oakland, CA
Malcolm Sproul, LSA, Pt. Richmond, CA
Ron Duke, H.T. Harvey, Milpitas, CA
Jeff1\1iller, Alameda Creek Alliance, Canyon, CA
Janice Delfino, OhIone Audobon Society, Castro Valley, CA
Karen High, Citizens Committee to Complete the Refuge,
e,
California Regional Water Quality Control Board
.San Francisco Bay Region
~
.
'Winston H. Hickox
Secretary for
Environmental
Protection
Internet Address: http://www.swrcb.ca.gov
1515 Clay Street, Suite 1400, Oakland, California 94612
Phone (510) 622-23003 FAX (510) 622-2460
Gray Davis
Governor
December 9, 1999
File No. 2198.09 (KHL)
Letter 8
RECEIVED
Df:. L; /. l:1 1999
DUBLIN PLANNING
Ms. Anne Kinney
City of Dublin
100 Civic Parkway
Dublin, CA
Re:
SCH Nos.
Dublin Ranch Planning Areas "F", "G", and "H."
99112040,99112041, and 99112042.
Dear Ms. Kinney:
We have received the above-referenced Mitigated Negative Declarations and offer the
following comments on areas with which the Regional Water Quality Contro(Board (RWQCB)
is concerned. .
The Negative Declarations address the portion of the phased Dublin Ranch project that
would be located on Areas F, G, ancl H. Areas F, G, and H are located 'within the 3,302 "acre
Eastern Dublin Specific Plan area, and are comprised of 147 acres, 87 acres, and 71 acres,
respectively. The proposed project on these areas would result in the construction of 2,188
residential units, public or semi-public uses on 7.1 acres, neighborhood and general commercial
use on 38.2 acres, campus office and/or- campus office/commercial uses on 55.1 acres, and a
variety of other uses, including schools, parks and open space.
8.1
Board staff are concerned that the Negative Declaration may not adequately address the
project's potential impacts to wetlands, riparian waters, and associated endangered species,
including the California red-legged frog (CRLF) and California tiger salamander (CTS). Further,
staff are concerned that the project, as proposed, would increase the levels of pollutants
discharged from the site and could alter the site's runoff hydrograph, potentially impacting
downstream bed and bank stability.
8.2
8.3
It appears that the project will impact the number or range of existing rare, threatened,
and/or endangered species that are known to be present or could be present on the project site.
For example, page 29 of the Initial Study for Planning Area F states that "[c]learing and grading
could result in the loss of individual tiger salamanders and their e~tivation habitat, and filling of
the stock pond would result in the loss ofD. Tacres' of red-legged frog~aD.cL tiger salamander
California Environmental Protection Agency
~~ Recvcled Paner
-2 -
breeding habitat and could potentially result in the loss of individuals." The Initial Study
subsequently identifies impacts to other rare, threatened, and/or endangered species.
Under CEQA, impacts or potential impacts to the number or range of a rare, threatened,
or endangered species require a mandatory finding of significant impact. Because the subject
CEQA documents identify such impacts, it appears that a negative declaration does not
adequately comply with CEQA. Section 15065 of the CEQA Guidelines states that "[a] lead
agency shall find that a project may have a significant effect on the environment...[when the]
project has the potential to...reduce the number or restrict the range of an endangered, rare or
threatened species...." Under this relatively strict section ofthe CEQA Guidelines, an EIR or
appropriate subsequent EIR or addendum is required for proj ects with such impacts. It appears
that the subject project, as presently proposed, has the potential to have such impacts. \Vhile an
FEIR was prepared for the Dublin Area Specific Plan in 1992, we concur with the State
Department of Fish and Game (CDFG) that substantial new information that has developed since
the FEIR's certification in 1993. Therefore, staff believes that these negative declarations are
inappropriate for the present project, and an EIR or other appropriate subsequent document
should be prepared. However, we understand that the City may not make the same finding.
Therefore, this letter also provides more detailed comment on other areas of the Negative
Declarations with which the Board is interested.
8.4
The proposed development would disturb more than five acres of land during.
construction. It must be covered under the State NPDES General Permit for Discharges of Storm
Water Associated with Construction Activity (General Permit). This can be accomplished by
filing a Notice of Intent (NOI) with the State Water Resources Control Board, Division of\Vater
Quality. Copies of the General Permit and- NOI can be obtained from the State Board's web page,
www.s\vrcb.ca.Qov. or by contacting the Board at (510) 622-2494. The project sponsor must
propose and implement control measures that are consistent with the General Permit and with the
recommendations and policies of the local agency and the RWQCB.
8.6
Approximately 6.8 acres of U.S. Army Corps of Engineers (Corps) jurisdictional area
(5.78 acres of wetlands and 1.02 acres of Waters of the U.S.) would be impacted with the
development of Areas F, G, and H. These include approximately 3000 linear feet of seasonal
creeks on the site. Because the project involves the disturbance of jurisdictional wetlands and
Waters of the State, a Section 401 Water Quality Certification or other appropriate approval from
the State will be necessary, and should be referenced in appropriate sections of the project's
CEQA documentation (e.g., paragraph 2 of the Biological Resources Section in the Area F
mitigated Negative Declaration, which presently refers only to the Corps and CDFG).
Section 404 (b )(1) ofthe Cl~an Water-Actseque~ces the o~derin which proposals should
be approached. First impacts to wetlands or Waters of the state must be avoided to the maximum
extent practicable. Second, the remaining impacts must be minimized. Finally, the remaining
8.5
California Environmental Protection Agency
I';) D...,......l...,.1 D............
- 3 -
unavoidable adverse impacts to wetlands or Waters of the State must be mitigated. Mitigation
will preferably be in-kind and on-site, with no net destruction of habitat value. If the applicant is
unable to demonstrate that the project was unable to avoid adverse impacts to wetlands or Waters
of the State, water quality certification will be denied. 40 I certification may also be denied
based on si~ficant adverse impacts to wetlands or other Waters of the State.
8. 7 Although the project design, as proposed, would fill certain areas of creeks and wetlands
on the project site, it has not yet received the required approvals from state and federal agencies.
The design may change substantially during agency review of the project application for wetland
fill, and this uncertainty should be reflected in the project's CEQA document. For example, to
address this, the City could . commit to completing any additionally required CEQA
documentation necessary for the project to come into compliance with CEQA following such
design changes.
8.8 The City of Dublin is permitted under and complies with NPDES permit CAS0029831,
the municipal storm water permit and associated Storm Water Management Plan (SWMP), as a
part of approving and conditioning new and redevelopment proj ects. As of February 19, 1998,
the S\VMP includes the following requirements:
1. Agencies will require public and private development projects to include site
planning and design techniques to prevent and minimize impacts to water quality. These m~
include the following:
a. Minimize land disturbance;
b. Minimize impervious surfaces (e.g., roadway width), especially directly
connected impervious areas (DCIA);
c. Use of clustering;
d. Preservation of quality open space, and
e. Maintain (and/or restore, if possible) riparian areas and wetlands as project
amenities, establishing vegetation buffer zones to reduce runoff into
watervvays.
2. Each Agency will require public and private development projects to include
permanent stormwater quality controls, as appropriate, if sufficient site planning measures are
not implemented or feasible. .
Therefore, this project, which is located in the City of Dublin, must include both design
measures and permanent treatment controls, as apPfopriate..As proposed in the Negative
Declarations, the project applicant would not be required to address~this issue until it obtained a
grading permit. Typically at that stage, the'project has already undergone substantial design and
it is much more difficult to incorporate into it acceptable and effective storm water design
California Environmental Protection Agency
-4-
measures and treatment controls. Post-construction storm water design measures and treatment
controls are most easily and effectively incorporated into a project at its planning stages.
Therefore, the project applicant should be" required to submit a detailed conceptual post-
construction S\VPPP as soon in the process as appropriate, and a final post-construction S\VPPP
prior to obtaining a grading permit for the project. The conceptual post-construction SWPPP
should be as detailed and site-specific as possible, and city approval of such a SWPPP should be
required prior to any other approval that would fix substantial portions of the project, and design
measures for those areas, in place.
8.9
Additionally, by substantially increasing the amount of impervious surface present on the
site and by introducing constructed storm drains, rather than the present overland flow, the
project could substantially alter the existing runoff hydrograph for the site, and flows in the
streams into which it would drain. Such alterations could result in impacts to downstream stream
bed and bank stability, and associated impacts including loss of habitat and threats to existing
structures adjacent to the streams. At present, the hydrologic analysis of downstream impacts is
limited to ensuring that peak flows will not create a flooding hazard. The analysis should be
expanded to address the issues discussed above.
Regional Board staff are unable to offer more specific comment at this time. However, I
have attached a copy of our General Comments, which discuss the Regional Board's area of
responsibility, and which should help guide in the preparation of further CEQA documentation. -
Regional Board staff also encourage the lead agency to obtain a copy of "Start at the Source," a
design guidance manual for storm water quality protection, which provides innovative ways of
designing structures, parking lots, drainage systems, and landscaping. This manual may be
obtained at most cities' planning departrilents or by calling Forbes Press, which is distributing
the manual for the Bay Area StormwaterManagement Agencies Association, at 1-800-773-7247.
If you have any questions, please contact me at (510) 622-2380, or via e-mail to
khl@rb? .swrcb.ca.gov.
. Sincerely,
~~
Keith H. Lichten
Water Resource Control Engineer
Enclosures:
General Comments
Start at the Source information page
cc (w/out attachments):
State Clearinghouse
California Environmental Protection Agency
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California Regional Water Quality Control Board
San Francisco Bay Region
, ..'iaston H. Hickox
SecrrllUj'for
Environml!n1al
Pro'l!c'ion
Internet Address: http://www.Sl.TCb.a.gov
1515 Clay Street. Suite: 1400, Oakland. California 94612
~hone (SIO) 622-2300. FAX (SIO) 622-2460
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General Comments
The San Francisco Regional Water Quality Control Board (Regional Board or ,RWQCB) is
charged with the protection of the Waters of th~ State of California in the San Francisco' Bay Region,
including wetlands and stormwater quality. The Regional Board is responsible for administering the
regulations established by the Federal Clean Water Act. Additionally, the California Water Code
establishes broad state authority for regulation of water quality. The San Francisco Bay Basin Water
Quality Control Plan (Basin Plan) explains the Regional Board's strategy for regulating water quality.
The Basin Plan' also describes the range of responses available to the Regional Board with regard to
actions and proposed actions that degrade or potentially degrade the beneficial uses of the Waters of the
State of California.
NPDES
Water quality degradation is regulated by the Federal National Pollutant Discharge Elimination
System (NPDES) Program, established by the Clean Water Act, which controls and reduces pollutants to .
water bodies from point and nonpoint discharges. In California., the program is administered by the
California Regional Water Quality Control Boards. Tne Regional Board issues NPDES pe~its for
- discharges to water bodies' in the San Francisco Bay Area., including Municipal (area- or county-wide)
Stormwater Discharge Permits.
Projects disturbing more than five acres of land during construction must be covered und~r th~
State NPDES General Permit for Discharges of Storm Water Associated with Construction Activity
(General Permit). This can be accomplished by filing a Notice of Intent. An NOI and the General
Permit can be obtained from the Board at (510) 286-0968. The project sponsor must propose and
implement control measures that are consistent with the General Permit and with. the recommendations
and policies of the local agency and the RWQCB.
Projects that include facilities with discharges of Storm Water Associated with Industrial
Activity'must be Covered 'under the State NPDES General Permit for Discharges of Storm Water
Associated with Industrial Activity. This may be accomplished by filing a Notice of Intent. The project
sponsor must propose .control measures that are consistent with this, and with recommendations and
- policies of the local agency and the RWQCB. In a few cases, the project sponsor may apply for (or the
RWQCB may require) issuance of an individual (industry- or facility-specific) permit. .
The RWQCB's Urban Runoff Management Program requires Bay Area municipalities to
develop and implement storm water management plans (SWMPs). The'SWMPs must include a program
for implementing new development and construction site stOnD. water quality controls. The objective of
this component is to ensure that appropriate measures to control pollutants from new development are:
considered d~g the planning ph.ase, before construction begins; implemented during the construction
phase; and maintained after construction, throughoD!. the life.ofthe projec~
California Ellvironmelbal Protection Aoelle}'
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Impacts and Miti!!ation Measures
Wetlands
Wetlands enhance water quality through such natural functions as flood and erosion control,
stream bank stabilization, and filtration and purification of contaminants. Wetlands also provide critical
habitats for hundreds of species of fish, birds, and other wildlife, offer open space, and provide many
recreational opportunities. Water quality impacts occur in wetlands from construction of structures in
waterways, dredging, filling, and altering drainage to wetlands.
The Regional Board must certify that any permit issued by the U.S. Army Corps of Engineers
pursuant to Section 404 of the Clean Water Act (covering, dredging, or filling of Waters of the United
States, including wetlands) complies with state water quality standards, or waive such certification.
Section 40 I Water Quality Certification is necessary for all 404 Nationwide permits, reporting and non-
reporting, as well as individual permits.
All projects must be evaluated for the presence of jurisdictional wetlands and other Waters of the
State. Destruction of or impact to these waters should be avoided. If the proposed project impacts
wetlands or other Waters of the State and the project applicant is unable to demonstrate that the project
was unable to avoid those adverse impacts, water quality certification will most likely be denied. 40 I
Certification may also be denied based on significant adverse impacts to wetlands or other Waters of the
State. In considering proposals to fill wetlands, the Regional Board has adopted the California Wetlands
Conservation Policy (Executive Order W-59-93, signed August 23, 1993). Tne goals of the Policy
include. ensuring "no overall net loss and achieving a long-term net gain in the quantity, quality, and
permanence of wetlands acreage and values." Under this Policy, the Regional Board also considers the
potential post-construction impacts to wetlands and Waters of the State and evaluates the measures
proposed to mitigate those impacts (see Storm Water Quality Control, below).
The Regional Board has adopted U.S. EPA's Clean Water Act Section 404(b)(1) "Guidelines for
Specification of Disposal Sites for Dredge or Fill Material," dated December 24, 1980, in the Board's
Basin Plan for determining the circumstances under which fill may be permitted.
Section 404(b)(1) Guidelines prohibit all discharges offill material into regulated waters of the
United States, unless a discharge, as proposed, constitutes the least environmentally damaging
practicable alternative that will achieve the basic project purpose. For non-water dependent projects, the
guidelines assume that there are less damaging alternatives, and the applicant must rebut that
assumption.
The Section 404(b)(1) Guidelines sequence the order ~ which proposals should be approached.
First, impacts to wetlands or Waters of the State must be avoided to the maximum extent practicable.
Second, the remaining impacts must be minimized. Finally, the remaining unavoidable adverse impacts
to wetlands or Waters of the State must be mitigated. Mitigation will be preferably in-kind and on-site,
with no net destruction of habitat value. A proportionately greater amount of mitigation is required for
projects that are out-of-kind and/or off-site. Mitigation will preferably be completed prior to, or at least
simultaneous to, the filling or other loss of existing wetlands.
Successful mitigation projects.are-coIIlplex'"tasks and diff'ic::u.lt to achieve. This issue will be
strongly considered during agency review of any proposed wetland fill. Wetland features or pondS
")
....
created as mitigation for the loss of existing jurisdictional wetlands or Waters of the United States cannot
be used as storm water treatment controls.
In general, if a proposed project impacts wetlands or Waters of the State and the project
applicant is unable to demonstrate that the project was unable to avoid adverse impacts to wetlands or
Waters of the State, water quality certification will be denied. 401 Certification may also be denied
based on significant adverse impacts to wetlands or other Waters of the State.
Storm Water Quality Control
Storm water is the major source of fresh water to creeks and waterways. Storm water quality is
affected by a variety of land uses and the pollutants generated by these activities. Development and
construction activities cause both site-specific - and cumulative water quality impacts. Water quality
degradation may occur during construction due to discharges of sediment, chemicals, and wastes to
nearby storm drains or creeks. Water quality degradation may occur after construction is complete, due
to discharges of petroleum hydrocarbons, oil, grease, and metals from vehicles, pesticides and fertilizers
from landscaping, and bacteria from pets and people. Runoff may be concentrated and storm water flow
increased by newly developed impervious surfaces, which will mobilize and transport pollutantS
deposited on these surfaces to storm drains and creeks. Changes in runoff quantity or velocity may cause
erosion or siltation in streams. Cumulatively, these discharges will increase pollutant loads in creeks and
wetlands within the local watershed, and ultimately in San Francisco Bay.
.
To assist municipalities in the Bay Area with complying with an area-wide NPDES Municipal
Storm Water Permit or to develop a Baseline Urban Runoff Program (if they are not yet aco-permitt:ee
with a Municipal Storm Water Permit), the Regional Board diStributed the Staff Recommendations for
New and Redevelopment Contro/for Storm Water Programs (Recommendations) in April 1994. The
Recommendations describe the Regional Board's expectations of municipalities in protecting Storm.
water quality from impacts due to new and redevelopment projects, including establishing policies and
requirements to apply to development areas and projects; initiating appropriate planning. review,
approval, and inspection procedures; and using best management practices (BMPs) during construction
and post-construction.
Project impacts should be minimized by developing and implementing a Storm Water Pollution
Prevention Plan (SWPPP). A SWPPP is required by the State Construction Storm Water General Permit"-
(General Permit). The SWPPP should be consistent with the ternls of the General Permit, the Manual of
Standards for Erosion & Sedimentation Control Measures by the Association of Bay Area Governments
(ABAG), policies and recommendations of the local urban runoff program (city and/or county), and the
Recommendations of the RWQCB. SWPPPs should also be required for projects that may have impacts,
but which are not required to obtain an NPDES permit Preparation of a SWPPP should be a condition of
development Implementation of the SWPPP should be enforced during the construction period via
appropriate options such as citations, stop work orders, or withholding occupancy permits.
Impacts identified should be avoided and minimized by developing and implementing the types
of controls listed below. Explanations of the controls are available in the Regional Board's construction
Field Manual, available from Friends of the San Francisco Estuary at (510) 286-0924, in BASMAA's
Start at the Sf!UTce, and in the Califo~~a ~!o.rmJfater_Best M~ageineJji Practice Handbooks.
3,
Site Planning
The project should minimize impacts from project development by incorporating appropriate site
planning concepts. This should be' accomplished by designing and proposing site planning options as
early in the project planning phases as possible. Appropriate site planning concepts to include, but are
not limited to the following: ' ,
. Phase construction to limit areas and periods of impact.
. Minimize directly connected impervious areas.
. Preserve natural topography, existing drainage courses and existing vegetation.
. Locate construction and structures as far as possible from streams, wetlands, drainage areas, etc.
. Provide undeveloped, vegetated buffer zones between development and streams, wetlands, drainage
areas, etc.
. Reduce paved area through cluster development, narrower streets, use of porous pavement and/or
retaining natural surfaces.
. Minimize the use of gutters and curbs which concentrate and direct runoff to impermeable surfaces.
. Use existing vegetation and create new vegetated areas to promote infiltration.
· Design and layout communities to reduce reliance on cars.
. Include green areas for people to walk their pets, thereby reducing build-up of bacteria, worms,
viruses, nutrients, etc. in impermeable areas, or institute ordinances requiring owners to c;ollect pets'.
excrement.
. Incorporate low-maintenance landscaping.
. Design and layout streets and storm drain systems to facilitate easy maintenance and cleaning.
. Consider the need for runoff collection and treatment systems.
. Label storm drains to discourage dumping of pollutants into them
Erosion
The project should minimize erosion and control sediment during and after construction. This
should be done by developing and implementing an erosion control plan, or equivalent plan. This plan
should be included in the SWPPP. The plaii should specify all control measures that will be used or
which are anticipated to be used, including, but not limited to, the following:
. Limit access routes and stabilize access points.
. Stabilize denuded areas as soon as possible with seeding, mulching, or other effective methods.
. Protect adjacent properties with vegetative buffer strips, sediment barriers, or other effective
methods.
. Delineate clearing limits, easements, setbacks, sensitive areas, vegetation and drainage courses by
marking them in the field.
. Stabilize and prevent erosion from temporary conveyance channels and outlets.
. Use sediment controls and filtration to remove sediment from water generated by dewatering or
collected on-site during construction. For large sites, stormwater settling basins will often be
necessary.
4
Chemical and Waste Management
The project should minimize impacts from chemicals and wastes used or generated during
construction. This should be done by developing and implementing a plan or set of control measures.
The plan or control measures should be included in the SwpPP. The plan should specify all control
measures that will be used or which are anticipated to be used, including, but not limited to, the
following:
· Designate specific areas of the site, away from -streams or storm drain inlets, for storage, preparation,
and disposal of building materials, chemical products, and wastes.
· Store stockpiled materials and wastes under a roof or plastic sheeting.
· Store containers of paint, chemicals, solvents, and other hazardous materials stored in containers
under cover during rainy periods.
· Berm around storage areas to prevent contact with runoff.
· Cover open Dumpsters securely with plastic sheeting, a tarp, or other cover during rainy periods.
· Designate specific areas of the site, away from streams or .storm drain inlets, for auto and equipment
parking and for routine vehicle and equipmentmaintenance.
· Routinely maintain all vehicles and heavy equipment to avoid leaks.
· Perform major maintenance, repair, and vehicle and equipment washing off-site, or in designated and
controlled areas on-site.
· Collect used motor oil, radiator coolant or other fluids with drip pans or drop cloths.
· Store and label spent fluids carefully prior to recycling or proper disposal.
· Sweep up spilled dry materials (cement, mortar, fertilizers, etc.) immediately....do not use water to
wash them away. ,
· Clean up liquid spills on paved or impermeable surfaces using "dry" cleanup methods (e.g.,
absorbent materials, cat litter, rags) and dispose of cleanup materials properly.
· Clean up spills on dirt areas by digging up and properly disposing of the soil. _ _
· Keep paint removal wastes, fresh concrete, cement mortars, cleared vegetation, and demolition
wastes out of gutters, streams, and storm drains by using proper containment and disposal.
Post-Construction
The project should ~inimize impacts from pollutants that may be generated by the project
follewing construction, when the project is complete and occupied or in operation. These pollutants may
include: sediment, bacteria, metals, solvents, oil, grease, and pesticides, all of which are typically
generated during the life of a residential, commercial, or industrial project after construction has ceased.
This should be done by developing and implementing a plan and set of control measures. The plan or
control measures should be included in the SWPPP.
The plan should specify all control measures that will be used or which are anticipated to be
used, including, but not limited to, the source controls and treatment controls listed in the
Recommendations. Appropriate control measures are discussed in the Reco~endations, in:
· Table 2: Summary of residential post-construction BMP selection
· Table 3: Swpmary of industrial post-co~ction BMP selection
· Table 4: Summary. of.~ercial.post-construction BMP selection
s
Additional sources of informatiori that should be consulted for BMP selection include the California
Storm Water Best Management Practice Handbooks; the Bay Area Preamble to the California Storm
Water Best Management Practice Handbooks and New Development Recommendations; the BASMAA
New Development Subcommittee meetings, minutes, and distributed information; and Regional Board
staff. Regional Board staff also have fact sheets and other information available for a variety of
structural stormwater treatment controls, such as grassy swales, porous pavement and extended detention
ponds.
6
STATE OF CAliFORNIA - BUSINESS TRANSPORTATioN AND HOUSING AGENCY
RECEIVED GRAY DAVIS. Governor
DEPARTMENT OF TRANSPORTATION
POBOX 23660
OAKlAND, CA 94623-0660
Tel; (510) 286-4444
Fax; (510) 286-5513
TOD (510) 286-4454
~. · 1 :I 1999 Q
-e;
DUBLIN PLANNING ~ ;~,..:..,.
December 9, 1999
ALA580609
ALA-580-17.94
SCH#99112040-42
Ms. Anne Kinney
Planning Department
City of Dublin
100 Civic Parl.rway
Dublin, CA 94588
Letter 9
Dear Ms. Kinney:
Dublin Ranch - Planning Areas "F" "G"and "H" (File No. P A 98-068)
Thank you for including the California Department of Transportation (Caltrans) in the
environmental review process for the above-referenced project. We have reviewed the Initial
Study and Mitigated Negative Declaration and have the following comments to offer:
_, .7
The traffic impacts discussed in the document are dependent on the accuracy of the forecasting
used, such as trip generation and distribution. While we are pleased to see the' inclusion of
mitigation measures for known impacts at this time, we would like to keep watch over traffic
and congestion problems as development continues. As the office, commercial, retail, and
residential development occurs, a more specific and detailed traffic impact analysis should be
carried out for projects within the Dublin Ranch areas, all of which are close to 1-580. Please
continue to keep us informed of the progress on these projects.
Should you require further information or have any questions regarding this letter, please call
Paul Svedersky of my staff at (510) 622-1639.
Sincerely,
HARRY Y. YAHATA
District Director
By ~~CL~
JEAN C.R. FINNEY
District Branch Chief
IGR/CEQA ,.
:
c: State Clearinghouse
DUBLIN
Slili RP-JuON
SERVICES
DISTRICT
7051 Dublin Boull'\'ard
Dublin. California 94568
FAX: 925829 1180
9258280515
December 13, 1999
Anne Kinney, Assistant Planner
City of Dublin
100 Civic Plaza
Dublin, CA 94568
Subject:
Letter 10
Initial Studic;s./Mitigated Negative Declarations: Specific Plan Amendments and
Stage 1 and 2 Development Plans for Eastern Dublin Planning Areas "F, G, and
H"
Dear Ms, Kinney:
We have reviewed the Initial Studiesl1vlitigated Negative Declarations for these projects and
would like to offer the following comments. Although our comments do not appear to require
significant revisions of the documents, and do not change any of the conclusions regarding -
impacts nor mitigations, we feel the public record must be made complete by the submission of
these comments.
10.1 L
10.2 2.
,-
Page 4 states that "When and where available" recycled water will be provided for
irrigation purposes. Please note that the District has made significant progress in
providing recycled water to the Eastern Dublin plan area since the time of
certification of the EIR. Potable water systems have been master planned for the
project area contingent on supplying recycled water to approved landscape
demands such as common areas, parks and medians. Use of recycled water
significantly reduces the sizing requirements for potable water facilities, and the
District does not consider recycled water service an optional utility dependent on
further study. Recycled water will be an integral element of the water supply for
the project area. It is fully anticipated that recycled water will be provided to the
project area at the time of development.
Paragraph "b" in the Attachment section (page 4 7 in the Area "G" IS) states lines
will bee},.1:ended fro~ t~~~as~: In fact all sewer'lines will ~e e^1:en1:i~e-EYV~ .
Lev Z 1 1999
DUBLIN PLA!'1NING
The Dubl1n San Ramon Services DlstrlCt 15 & Public EnUty
Ms. Anne Kinney
City of Dublin
December 13, 1999
Page 2
west, and potable water lines will also be extended from the south.
10.3 3.
Paragraph "e" (Page 47 in the Area "G" IS) states that wastewater treatment
capacity of the wastewater treatment plant (WWTP) is adequate for the project.
Although this is in fact true, the District is currently expanding wastewater
treatment capacity through implementation of the "Stage IV" improvements plan
at the WWTP. Facilities will be completed in year 2001. Also, the LA VWMA
wastewater discharge facilities are being expanded; design is underway and a
financing plan has been approved by the member agencies. .
Thank you for providing these documents to us for review and comment. If you have fulY
questions please contact me at 551-7230, ext. 110.
Sincerely,
~ /~U
( ~~C:/fi-
~ Bruce W. Webb,
Engineering Planner
Cc: Jim Templeton
Bob Gresens
Rhodora Biagtan
File: 806-02, DP98-068 Area F,G,H, Chron.
H:\ENGDEPTlDEPTSTUF\PLANNER\CEQA\kinneyltr.doc
RESOLUTION NO. 00-
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
APPROVING A GENERAL PLAN AMENDMENT AND AN AMENDMENT TO THE EASTERN
DUBLIN SPECIFIC PLAN FOR DUBLIN RANCH 'AREA F' (PA 98-068), 'AREA G' (PA 98-069)
AND 'AREA H' (P A 98-070)
WHEREAS, Ted Fairfield, representing property owner Jennifer Lin et. aI, has requested approval
to amend portions of the General Plan and the Eastern Dublin Specific Plan, which would:
1. Relocate various land uses and acreages within Areas F, G and H of Dublin Ranch on land
generally located east of Tassajara Road and North ofI-580 within the Eastern Dublin Specific
Plan area (APN: 985-0005-001, 985-0005-002) as shown on Exhibits A and B: General Plan and
Eastern Dublin Specific Plan Land Use Map and Eastern Dublin Specific Plan Planning
Subareas Map. Land use changes include relocating all of the Medium High Density
Residential, High Density Residential, and Neighborhood Commercial uses within Area F to
Area G. These three land uses would be replaced with Medium Density Residential uses within
Area F. The Neighborhood Commercial uses which are currently shown along both sides of
Central Parkway (previously the "Transit Spine") would be relocated to Area G and reoriented in
a north-south direction between Dublin Boulevard and Central Parkway along Main Street.
2. Amend text in the Land Use element of the General Plan and Eastern Dublin Specific Plan to
delete references to the "Transit Spine" and replace it with either "Central Parkway" or "Main
Street" as appropriate, in accordance with Resolution No. 77-97. This Resolution was approved
by the City Council on June 17, 1997 to amend the circulation element of the General Plan and
Eastern Dublin Specific Plan. This Amendment reclassified the "Transit Spine" from a transit-
oriented corridor to an east-west arterial and renamed it "Central Parkway" (Exhibit C: EDSP
Text Amendments).
3. Amend text in the General Plan and Eastern Dublin Specific Plan, to allow Campus Office uses
be developed on 10.5 acres ofland designated for General Commercial uses within the south-
west quadrant of Area H, pursuant to a Stage 2 Planned Development (PD) Rezone (Exhibits C
and D: EDSP and GP Text Amendments).
4. Update Appendix 4 "Eastern Dublin Specific Plan Land Use Summary By Land Owner", #19
Pao-Lin (also know as Areas F, G and H, now owned by Jennifer Lin et al) (Exhibit E).
WHEREAS, a complete application for this project is on file with the Dublin Planning Department;
and
WHEREAS, the potential environmental effects of the proposed project have been previously
addressed in the Eastern Dublin Specific Plan EIR (SCH No. 91-103064); and
WHERES, individual Initial Studies have been prepared for each of the three Dublin Ranch Areas
(Area F - SCH No.99112040, Area G - SCH No.99112041 and Area H - SCH No.99112042) to evaluate
site-specific impacts ofthe project (to a greater level of detail than in the Program EIR) pursuant to CEQA
ATTACHMENT 2
guidelines Section 15168. Based on the three Initial Studies, a Mitigated Negative Declaration and
Mitigated Monitoring Program has been prepared for each area with the finding that with the
implementation of Mitigation Measures previously adopted for the Program EIR and with site specific
Mitigation Measures contained in the Initial Studies, as further clarified by the Response to Comments,
the potential site-specific impacts of the projects would be reduced to a level of insignificance. The
Program EIR and Initial Studies adequately describe the impacts of the project, and there have been no
substantial changes or new information that would be outside the scope of the Program EIR; and
WHEREAS, the Planning Commission did hold a properly noticed public hearing on said
application on December 14, 1999, January 11, 2000 and January 25, 2000 and did adopt a Resolution
recommending that the City Council approve a General Plan Amendment and an Amendment to the
Eastern Dublin Specific Plan for Area F (P A 98-068), Area G (P A 98-069) and Area H (P A 98-070);.
and
WHEREAS, a properly noticed public hearing was held by the City Council on February 15,2000;
and
WHEREAS, a Staff Report was submitted recommending that the City Council approve the
proposed General Plan Amendment and Amendment to the Eastern Dublin Specific Plan; and
WHEREAS, the City Council did hear and use their independent judgment and considered all said
reports, recommendations and testimony hereinabove set forth.
NOW, THEREFORE, BE IT RESOLVED-THAT the Dublin City Council does hereby find that:
1. The proposed Amendments are consistent with the goals, general provisions and purpose of the
Dublin General Plan and the Eastern Dublin Specific Plan as proposed to be amended herein;
and
2. The relocation of land uses and acreages within Areas F, G and H of Dublin Ranch are
appropriate for the subject property in terms ofland use compatibility and configuration and will
provide a comprehensive plan for the development of Areas F, G and H; and
.
3. The amended land uses and text would allow the development of Main Street, a pedestrian
orientated retail and service center within walking distance of high and medium high density
residences as reflected on the Development Plan included as a part of Exhibit B to the Staff
Report. These changes are appropriate based on analysis in the staff report, will provide a
development pattern consistent with the Specific Plan goals, and will help implement policies of
the General Plan and EDSP regarding development in Eastern Dublin; and
4. The amended text would allow Campus Office uses be developed on 10.5 acres ofland
designated for General Commercial uses within the south-west quadrant of Area H, pursuant to a
Stage 2 Planned Development (PD) Rezone. The change to this land use is appropriate based
upon analysis in the staff report, will result in more efficient use of land in line with market
conditions, will provide a development pattern consistent with the Specific Plan goals, and will
help implement policies of the General Plan and EDSP regarding development in Eastern
Dublin; and
5. The revised Appendix 4 "Eastern Dublin Specific Plan Land Use Summary By Land Owner",
# 19 Pao-Lin represents updated information regarding land uses and acreages within the Pao-Lin
2
property (also know as Areas F, G and H, now owned by Jennifer Lin et al) of the Eastern
Dublin Specific Plan area.
BE IT FURTHER RESOLVED THAT THE Dublin City Council does hereby approve a
General Plan Amendment and an Amendment to the Eastern Dublin Specific Plan, as shown on
Exhibits A, B, C, D, E and F to the Staff Report for the February 15,2000 City Council meeting for P A
98-068, P A 98-069 and P A 98-070.
PASSED, APPROVED AND ADOPTED this 15th day of February, 2000.
AYES:
NOES:
ABSENT
Mayor
ATTEST:
City Clerk
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Eastern Dublin Specific Plan Amendment-
Dublin Ranch Project Applications
Area F - P A 98-068,
Area G - P A 98-069
&
Area H - P A 98-070
The following are proposed amendments to the Eastern Dublin Specific Plan as part ofPA 98-068, PA
98-069 and P A 98-070:
1. A revision to the Eastern Dublin Specific Plan Land Use Map (Figure 4.1) of the EDSP dated
January 7, 1994 to rearrange land uses. The revised portion of the map is attached as Exhibit A.
2. A revision to the Eastern Dublin Specific Plan Planning Subareas Map (Figure 4.2) of the EDSP
dated January 7, 1994 to rearrange the boundaries of the subareas. The revised portion of the
map is attached as Exhibit B.
3. A Text Amendment to Chapter 3 of the Eastern Dublin Specific Plan relating to land use
categories, the Transit Spine and east-west vehicular connections:
3.3.3 Land Use Categories, Commercial
Second Paragraph, Right Column
Note: There are several areas indicated on the land use map that could develop as either general
commercial or campus office uses. This flexibility has been provided in these key areas to
respond to changing market conditions that may occur in the future. The shift from either
campus office or general commercial (the underlying land use designation) to general
commercial or campus office would be permitted if the established traffic levels of service are
not exceeded. Appropriate traffic studies may need to be conducted in order for the City to make
the proper determination regarding traffic levels of service.
.4
3.4.1 Streets and Highways
Third Paragraph
The major east-west roads are Dublin Boulevard, providing a connection to central Dublin and
North Canyons Parkway in Livermore; tffiEl. Gleason Road, and Central Parkway which will
accommodate predominantly local trips.
3.4.2 Public Transit
Public transit opportunities will be maximized for eastern Dublin residents. Local transit service
is to be provided to all land uses with connections to regional transit, such as BART. The Plan
designates the east ',vest corridor.. midway betweon Dublin Boulevai"d~and Gleason Drive as a
"transit spine". This corridor, ',yf1ich (1](tends across the '.vidth of the planning area., '.viE link tho
To',vn Center to the Th.-r.ture East Dublin R^~RT station and dovlmown Dublin. The transit spine is
It is also planned to construct "Main Street" in a north-south orientation through fffi: the Town
Center (mid '.vay to run between Dublin Boulevard and Central Parkwav). tffiEl. fResidential and
Commercial employment use~ ~ will beeH: concentrated along the oorridor "Main Street" to
encourage transit use for local and regional travel. "Main Street" The corridor also lies within
easy walking
EXHIBIT C OF ATTACHMENT 2
distance of overhalfthe residences in eastern Dublin. Advisory design guidelines which
encourage transit use are proposed for bus shelters and transit stops.
3.6 Community Design
Sixth paragraph, left Column, page 19
The guidelines for the Circulation System (pedestrian and bike paths, and streets, and Transit
~) focus on creating community and subarea identity; encouraging pedestrian use; and
protecting sensitive natural and visual resources.
4. A Text Amendment to Chapter 4 of the Eastern Dublin Specific Plan relating to the arrangement
of land uses and the character of commercial areas:
4.5.1 Location
Policy 4-11: Concentrate regionally-oriented commercial uses south of Dublin Boulevard and
near freeway interchanges where convenient vehicular access will limit traffic impacts on the
rest of eastern Dublin.
Note: There are several areas indicated on the land use map that could develop as either general
commercial or campus office uses. This flexibility has been provided in these key areas to
respond to changing market conditions that may occur in the future. The shift froin either
campus office or ~eneral commercial (the underlying land use designation) to general
commercial or campus office would be permitted if the established traffic levels of service are
not exceeded. Appropriate traffic studies may need to be conducted in order for the City to make
the proper determination regarding traffic levels of service.
Third paragraph, left column, page 28
Community -orientated commercial development is planned for three mixed-use commercial
centers, each of which is centrally located to a residential area. These centers are: the Town
Center (along Tassjara Road between Dublin Boulevard and Gleason Drive and along "Main
Street" between Dublin Boulevard and iust north of Central Parkway); and the Village Centers
(located at the north and south ends of Fallon Road.
Policy 4-15: Concentrate pedestrian-oriented commercial uses along "Main Street" the transit
5j:3ffie and at key transit transfer points.
4.8.2 Commercial
General Commercial
After First Paragraph
Note: There is one area indicated on the amended land use map. located on the south-west
quadrant of Area H of Dublin Ranch that could develop as either ~eneral commercial or campus
office uses. This flexibility has been provided in this area to respond to changin~ market
conditions that may occur in the future. The shift from general commercial (the underlving land
use designation) to campus office would be permitted if the established traffic levels of service
are not exceeded. Appropriate traffic studies may need to be conducted in order for the City to
make the proper determination regarding traffic levels of service. The development of either
general commercial or campus office uses will be established at the Stage 2 Planned
Development application process.
4.8.4 Parks and Open Space
Second Paragraph, Right Column, third line
Replace "Transit Spine" with "Central Parkway"
2
4.9.2 Town Center - Commercial
Location:
The Town Center-Commercial subarea consists of two linear i&-cH-shaped area~ located adjacent
and perpendicular to Tassajara Road and "Main Street", The subarea extends north-south along
Tassajara Road from Dublin Boulevard to just north of Gleason Drive and north-south along
"Main Street" from Dublin Boulevard to iust north of Central Parkway. Midway bet\','eefl these
1\','0 roadT,\'ays the subarea extends apprO)~imately % mileeastT,yard along a street designated as
the transit spine (see figure 4.1)
Second Paragraph, right column, page 36.
The Neighborhood Commercial area, which extends along both sides of the transit spine "Main
Street", in intended as a more pedestrian-oriented service, retail, commercial and entertainment
center serving the daily needs of the residential neighborhood surrounding it and the more
intermittent shopping, entertainment, and service needs of the larger community.
Fourth Paragraph, right column, page 36.
The subarea has an area north of the intersection of "Main Street" and Central Parkwav and an
area west of the mid-point of "Main Street" near the midpoint of the transit spine which is
designated for Public/Semi-Public uses. The intent is that tffis these area~ be developed with
some combination of community-serving uses that will provide a public focus at the heart of the
Town-Center. Such uses might include a performing arts center, library, community center, post
office or some other community facility. It is anticipated that the uses in this' urea the Town
Center would adjoin a public plaza that could accommodate public ceremonies, events, and less
formal gatherings within the Town Center.
5. A Text Amendment to Chapter 5 of the Eastern Dublin Specific Plan relating to the
transportation and circulation systems within Eastern Dublin:
Second Paragraph, left Column, page 53
It is also planned to construct Main Street (two lanes) in a north-south orientation through the
future Eastern Dublin Town Center (midTNay running between Dublin Boulevard and Central
Parkway). The Main Street minimum right-or-way shall be::P;} 64 feet which includes &-
landscape area and .f.(f 12 foot private sidewalks on both sides with 4' public utility easements
behind the curb face for street lights. fire hydrants. etc. .^>.dditional ri;ht of 'Nay will be needed
for additional turn lanes.
6. A revision to the Eastern Dublin Specific Plan Town Center Concept Plan (Figure 7.1) of the
EDSP dated January 7, 1994 to rearrange land uses (refer to Exhibit F). The revised portion of
the map is attached. Chapter 7 of the EDSP discuss "Guidelines" for Town Center Community
Design which are advisory only. The Specific Plan makes provision for the City to consider
"equivalent or superior methods of design to achieve the objectives of the plan." As these items
are Guidelines only and the project meets the spirit and intent of the Specific Plan, no text
amendment is proposed.
7. A Text Amendment to Appendix 4, Eastern Dublin Specific Plan Land Use Summary by
Landowner, #19 Pao-Lin (also Know as Areas F, G and H, now owned by Jennifer Lin) is
attached as Exhibit E.
G:\pa\98068\EDSP Amendments
3
GENERAL PLAN AMENDMENT
Dublin Ranch Project Applications
Area F - P A 98-068,
Area G - P A 98-069 &
Area H - P A 98-070
The following are proposed amendments to the General Plan as part ofP A 98-068, P A 98-069
and P A 98-070:
1. A revision to the General Plan - Eastern Extended Planning Area Land Use Map (Figure
2.B) of the General Plan dated May 10, 1993 to rearrange land uses. The revised portion
of the map is attached (Exhibit A).
1.8.1: Land Use Classification
Eastern Extended Planning Area
Commercial/ Industrial
Page 8, insert after first paragraph
Note: There is one area indicated on the amended land use map. located on the south-
west quadrant of Area H of Dublin Ranch that could develop as either eeneral
commercial or campus office uses. This flexibility has been provided in this area to
respond to chan2:in2: market conditions that mav occur in the future. The shift from
2:eneral commercial (the underlving land use desi2:nation) to campus office would be
permitted ifthe established traffic levels of service are not exceeded. Appropriate traffic
studies may need to be conducted in order for the Citv to make the proper determination
re2:arding traffic levels of service. The development of either 2:eneral commercial or
campus office uses will be established at the Sta2:e 2 Planned Development application
process.
G:\pa\98068\GP A
EXHffiIT D OF ATTACHMENT 2
APPENDIX 4
EASTERN DUBLIN SPECIFIC PLAN
LAND USE SUMMARY BY LAND OWNER
#19 PAO-LIN (AREAS F, G & H) Acres Density Sq. Ft. Units
General Commercial * 26.9 .25 292,941
Neighborhood Commercial 22.0 .35 230,000
Campus Office 43.9 .45 860,528
Public/Semi-Public 7.0 .25 76,230
High Density Residential 25.0 35 876
Medium. High Density Residential 26.2 20 528
Medium. Density Residential 68.9 10 689
Single Family Residential 22.7 4 91
Neighborhood Park 12.3
Neighborhood Square 4.5
I
Elementary School 10.0 I
High / Middle School 30.6 I
Open Space 4.2
Total 304.2 1,459,699 2,184
*
10.5 acres of General Commercial located in the south-west quadrant of Area H (refer to
amended Land Use Map) may be used for Campus Office Uses pursuant to a Stage 2
Planned Development (PD) Application Process. If Campus Uses are constructed on the
10.5 acres, the maximum square footage would be 205,821 sq. ft.
g:planning\pa98-068\APPENDIX 4
EXHIBIT E OF ATTACHMENT 2
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