HomeMy WebLinkAbout8.1 Attch 4, Exh B-Response to Env CommentsCity of Dublin
Grafton Plaza Project
City File # PA 07-006
Response to Environmental Comments
Introduction
The City of Dublin issued a Mitigated Negative Declaration for this project on January
4, 2010 pursuant to the California Environmental Quality Act. The proposed project
includes requested approval of amendments to the General Plan and Eastern Dublin
Specific Plan to create a new Mixed-Use 2/Campus Office land use category, revision
of the Eastern Dublin Specific Plan subareas to include the Project site as a new Grafton
Plaza subarea, a PD-Planned Development Stage 1 rezoning that would allow either a
mixed use development of approximately 235 dwellings (not to exceed 248,259 square
feet) and 248,260 square feet of commercial, hotel, campus office and/or retail
development, or, campus office development up to 496,519 square feet. A
Development Agreement has also been requested to allow the development of either
option.
The Project site is located south of Dublin Boulevard, east of Grafton Street and north
of the I-580 freeway in the Eastern Dublin Specific Plan area.
The City of Dublin published and circulated an Initial Study and Mitigated Negative
Declaration on January 8, 2010 for a 30-day public review period that ended on
February 8, 2010.
CEQA does not require the City to prepare written responses to comments received on
a Mitigated Negative Declaration. The City has nevertheless prepared these written
responses because of the public interest in the Project and to resolve any confusion or
misperceptions about the current Project.
As noted in the Mitigated Negative Declaration (MND), the City approved land use
and zoning changes in 2000 for Dublin Ranch Area H, in which the Project is located
(page 4). Based on the approved density of 0.45 FAR, development potential for the
25.33-acre Grafton Plaza site would 496,519 sq. ft. No development applications were
included in the 2000 approvals. There were also no changes to the Campus Office (CO)
General Plan and Eastern Dublin Specific Plan designations. Then, as now, the CO
designations allowed campus office uses and also allowed a residential option for up
to 50% of a site.
In 2008, the Applicants submitted a proposal for a mixed-use project of approximately
1.1 million sq. ft., more than double the approved density of the site, with residential
EXHIBIT B TO
ATTACHMENT 4
City of Dublin k Page 2
Response to Comments April 2010
Grafton Plaza Project
towers possibly up to 21 stories in height. This proposal was withdrawn by the
Applicant early in the review process.
The current Project is consistent with the density approved for the site in 2000, i.e.,
496,519 sq. ft. The current Project includes land use amendments to formalize the
residential mixed use option that has always been in the Campus Office land use
designations and to broaden the range of permitted uses (e.g., shopkeeper, live-work
units) to provide more flexibility to respond to changing market demand. The
proposed zoning would include an amended PD-Stage 1 Development Plan to provide
for either campus office development or mixed use residential development. Future
applicants would choose which option to pursue as part of any future PD-Stage 2
Development Plan, pursuant to the PD-Planned Development District regulations in
the zoning ordinance.
Against this backdrop of prior approvals, and submitted but withdrawn proposals, the
following responses to comments on the MND are provided to ensure that adequate,
accurate and up-to-date information is available to the public and decisionmakers.
Changes and Modifications to the Mitigated Negative Declaration
These responses to comments also contain clarifications and minor corrections to
information presented in the draft MND. In the course of preparing the responses,
the City generated new information as well as clarifications and modifications to the
draft MND. The City has carefully reviewed the responses in this document against
the recirculation standards of CEQA Guidelines section 15073.5. None of the new
information, clarifications or modifications in this document requires "substantial
revision" of the MND as defined in the Guidelines, therefore the City has
determined that no recirculation is required.
1) Page 37 is amended to read as follows:
Supplemental Mitigation Measure VIS-3. Project developer(s) shall incorporate
the following features into final building and improvement plans for building
elevations adjacent to Dublin Boulevard:
a) Streetlight fixtures and ground level, pedestrian oriented light fixtures
shall be equipped with cut-off-lenses to direct light patterns in a
downward direction. Photometric plans shall be included with final
building and improvement plans to ensure that spillover of light is
minimized.
b) Exterior lights on upper floors shall minimize glare off of the site.
c) Interior lights for non-residential uses shall be dimmed or turned off
when not in use or needed for building security purposes.
d) Illumination shall be limited for exterior signs. If feasible, "canister"
sign types should not be used in favor of non-illuminated or exterior
illuminated fixtures.
City of Dublin
Response to Comments
Grafton Plaza Project
Page 3
April 2010
e) Landscaping lighting shall be limited and directed appropriately to
avoid spillover of light and glare onto adjacent properties.
f) Light fixtures for interior building spaces visible from Dublin
Boulevard shall be equipped with timing devices to turn off lights
when building spaces are not in use, except for emergency lighting,
reouired by annlicable Codes.
2) Page 106 is amended to read as follows:
"In a typical year, Zone 7 gets approximately 70 to 80 percent of its water supply
from water conveyed through the Sacramento-San Joaquin Delta by the State
Water Project. Zone 7 has a 75-year contract with the California Department of
Water Resources (DWR) to receive water from the State Water Project (SWP). The
entitlement under this contract is 46,990 80,619 acre-feet annually. SWP water is
delivered to Zone 7 from the Feather River Watershed via the Sacramento-San
Joaquin Delta. This water is then transported to Zone 7 through the California
Aqueduct to the South Bay Aqueduct and Lake Del Valle. Water enters the Zone
7 system from the South Bay Aqueduct and from Lake Del Valle at two Zone 7
treatment plants: the Patterson Pass Treatment Plant and the Del Valle Water
Treatment Plant.
ZE)ne Zeae ced its full entitlement er46,990 a re feet per- year- in iQQ?9
feet -
to al A4 +?nnn cTnm , ntifinmentn, Actual water deliveries vary, depending
on hydrologic conditions, requests by other contractors, delivery capacity
and environmental/ regulatory requirements."
3) Page 107 is amended to read as follows:
"Local Surface Water: Lake Del
of the SWP. 14 r, Zone 7
the lake's watershed. However,
Valle is a local storage reservoir operated as
7
the lake's watershed after accounting for prior rights. Zone 7 estimates that
approximately 7,400 to 11,450 acre-feet is available, but could change in the
future."
4) Page 107 is amended to read as follows:
Local Groundwater: Zone 7 and DSRSD use the local underground aquifer basin
as a storage facility for imported water. The aquifer is also naturally recharged
by rainwater falling in the watershed area. it is estimated that ^ safe yield of
Tr?______?-.--_i-, _-n? ___-----.,_ near the 1-?h----bra _ _ _ f-lnnose v„r? is ? _er.c? ,. It is
jefinsprC -DnvaSS2-r1_eas [n+teF, although the yield from h purmips is
estimated that the current natural sustainable yield is 13,400 acre-feet of water.
City of Dublin Page 4
Response to Comments April 2010
Grafton Plaza Project
per year. DSRSD does not have wells. Instead they have a groundwater
pumping quota of 645 acre-feet annually that Zone 7 pumps for them "
5) Page 108 is amended to read as follows:
"Zone 7 is altering its 100% Reliability Policy, which requires Zone 7 to have
adequate supplies available to meet 100% of customer demand at all times
through conditions selected by Zone 7 staff. "
City of Dublin
Response to Comments
Grafton Plaza Project
Comments Received
The following comment letters were received by the City.
Page 5
April 2010
Commenter Date
Federal Agencies
none
State Agencies
1.1 Office of Planning and Research 1/12/10
1.2 California Department of
Transportation (Caltrans) 2/8/10
Local Agencies
2.1 City of Dublin Police Services 1/8/10
2.2 City of Dublin Parks and Community
Services Department 1/14/10
2.3 Dublin San Ramon Services District 1/20/10
2.4 Alameda County Flood Control &
Water Conservation District-Zone 7 1/28/10
2.5 Alameda County Flood Control &
Water Conservation District-Zone 7 1/29/10
2.6 Alameda County Public Works
Agency 2/5/10
Interested Persons/Organizations
3.1 Chris Didato 1/18/10
3.2 Gabrielle Blackman 2/8/10
3.3 Jon Brattebo 2/8/10
Copies of these letters are attached.
City of Dublin Page 6
Response to Comments April 2010
Grafton Plaza Project
Comment Letters
.. SE,,L F-Th
o: t
u 0
C?LIFO.
ARNOLD SCHWARZENEGGER
GOVERNOR
r
STATE OF CALIFORNIA
GOVERNOR'S OFFICE of PLANNING AND RESEARCH
STATE CLEARINGHOUSE AND PLANNING UNIT
Memorandum
Date:
To:
From
Re:
January 12, 2010
All rill Reviewing Agencies
Scott Morgan, Acting Director
SCH # 1991103064
Grafton Plaza
Letter 1.1
o??l?£oF rv,y?Ns
z
49
a
• ?T??OF CAL?F?a?\P'
CYNTmk BRYANT
DnZECTOR
COOED
JAN 14 201'
DUBLIN PLANNING
The Lead Agency has corrected some information regarding the above-mentioned
project- Please seethe attached materials for more specific information. All other project
information remains the same.
cc: Mike Porto
City of Dublin
100 Civic Plaza
Dublin, CA 94568
1400 10th Street P.O. Box 3044 Sacramento, California 95812-3044
(916) 445-0613 FAX (916) 323-3018 www.opr.ca.goV
Sc? -1,19116?m
10F >
DATE:
TO:
FROM:
SUBJECT:
Community Development Department
Planning Division
MEMORANDUM
January 11, 2010
Original Distribution List
::
20110
City of Dublin Community Development Department
Initial Study/Mitigated Negative Declaration for Grafton Plaza
Project
The City of Dublin recently released an Initial Study/Mitigated Negative Declaration for the
proposed Grafton Plaza Project, located south of Dublin Boulevard, east of Grafton Street and
north of the 1-580 Freeway (APNs 985-0061-010 and 985-0061-004).
The public review period for the document commenced Friday, January 8, 2010 and is slated to
end on Monday, February 8, 2010.
Please be advised that due to an administrative duplicating error, 11 additional pages not
related to the Grafton Plaza project were included at the back of Appendix 3, the traffic analysis.
The addition of these unrelated pages in no way affects the analysis of the proposed Grafton
Plaza project included in the remainder of the. document. The document is complete and no
information is missing.
Please remove these pages prior to your review of the document.
Should you have any questions about these pages, please call the Project Planner, Mike Porto,
at 925-833-6610.
Thank you for your attention to this.
Notice of Completion & Environmental Document Transmittal
Marl to: Slate Clearinghouse, P. 0. Box 3044, Sacramento, CA 95812-3044 (916) 445-0613
For Hand Delfvery/Slreet Address- 1400 Tenth Street, Sacramento, CA 95814
Project T-file: Grafton Plaza
Lead Agency: City of Dublin Contact Person: Mike Porto
Mailing Address: 100 Civic Plaza Phone: (925) 833 6610
City: Dublin Zip: 94568 County: Alameda
---------------------------- ---------------------
Project Location:
County: Alameda City/Nearest Community: City of Dublin
Cross Streets: Central Parkway between Tassaiara Road and Fallon Road Zip Code: 94568
Assessor's Parcel No.: 850061-010 and 985-0061-04 Section: TwQ : Range: Base:
Within 2 Miles: State Hwy #: 1-580 Waterways: Tassaiara Creek
Airports: Livermore Municipal Railways: NIA. Schools: N/A
Document Type:
CEQA ? Revised NOP
? Early Cons
? Neg Dec
M Mit Neg Dec
? Draft EIR
? Supplemental/Subsequent EIR
(Prior SCH No.)
? Other
----------------------------
Locai Action Type:
I2 f 1 Q Fib al [lbcprhent
Halt= ' P.
iNSI II Ij I ------
? General Plan Update ? Specific Plan a Reijone ?- D Annexation
® General Plan Amendment ? Master Plan ? Premnle^ I-I? i I: ,; „, , 11 Redevelopment
? General Plan Element M Planned Unit Development ? Usdl?amiit L'I E F:; y1- h B coastal Permit
? Community Plan ? Site Plan _ ? Land Dfvtsfon (Subdivision, etc.) ®Oiher SPA. DA
-------------------------------------------------
Development Type:
M Residential: Units up to 235 Acres 25 ? Water Facilities: Type MGD
BOffice: Sq.f . u too 496,519 Acres 25- Employees ? Transportation: Type
?Commercial: Sq-ft Acres Employees ? Mining: Mineral
?Industrial: Sq.it Acres Employees ? Power. Type MW
? Educational: Waste Treatment: Type MGD
? Recreational: Hazardous Waste: Type
Total Acres (approx-) 25 ? Other.
-------------------------------------------------
Project Issues Discussed in Document.
® AeslheldVisual ? Fiscal M Recreational/Parks Q Vegetation
® Agricultural Land 0 Flood Plan/Flooding ? Schools/Universities M Water Quality
® Air Quality ? Forest Land/Fire Hazard ? Septic Systems 0 Water Supply/Groundwater
® Archeological/Historical 13 Geologfc/Seismic 0 Sewer Capacity M Wetland/Riparian
B Biological Resources B Minerals H Soil Erosion/Compaction/Grading M Wildlife
? Coastal Zone IS Noise E Solid Waste 19 Growth Inducing
® Drainage/Absorplon M Population/Housing Balance M Toxic/Hazardous M Land Use
? Economics/Jobs M Public Services/Facilities B Traffic/Circulation N Cumulative Effects
? Other
-------------------------------------------------
Present Land Use/Zoning/General Plan Designation: The City of Dublin has planned and zoned the site for Campus office uses.
Approximately one-half of the site is vacant; the other approximately one-half is occupied by an existing water quality basin.
Project Description: Consideration of amendments to the General Plan and Eastern Dublin Specific Plan to create a Mixed-Use 2/Campus
Office flex land use category, revise Eastern Dublin Specific Plan to create a Grafton Plaza subarea, a Stage 1 rezoning that would allow
one of two development options: (1) a mixed use development of approximately 235 dwelfings (not to exceed 248,259 square feet) and
248,260 square feet of commercial, hotel, campus office or (2) a campus office development up to 496,519 square feet. A Development
Agreement has also been requested. Additional land use entitlements would be required for future development projects to include
development standards such as building height, building mass and setbacks.
State Clearinghouse Contact: //tr
(916) 445-0613
State Review Began: -?- 2010
SCH COMPLIANCE ?- ' -2010
Please note State Clearinghouse Number
(SCH#) on all Comments
SCH#: 1991193864
Please fonvard late comments directly to the
Lead Agency
AQMDiAPCD
(Resources:
Project Sent to the following State Agencies
X Resources State/Consumer Svcs
Boating & Waterways _ General Services
Coastal Comm Cal EPA
_
Colorado Rw Bd _ ARB - Airport Projects
_ Conservation 2 _ APB - Transportation Projects
X Fish & Game # J _ ARB - Major Industrial Projects
Delta Protection Comm _ Resources, Recycling and Recovery
Cal Fire ?4_ SWRCB: Div. Financial Assist.
Historic Preservation SWRCB: Wtr Quality
X Parks & Rec x SWRCB: Wtr R;-hts
Central Valley Flood Prot X Reg. WQCB 4'3-_-
Bay Cons & Dev Comm Toxic Sub Crri-CTC
x DWR YthlAdit Corrections
_ DES (Emergency Svcs) _ Corrections
Bus Transp Hous Independent Comm
Aeronautics Energy Commission
CHP X NAHC
X Caltrans # Public Utilities Comm
Trans Planning _ State Lands Comm
Housing & Com Dev _ Tahoe Rgl Plan Agency
_ Food & Agriculture
Health Services
Conservancy
Other:
Sent By: CALTRANS TRANSPORTATIO PLANNING; 510 286 5560; Feb-8-10 3:37PM; Pale 1/1
5TOTE ?F t:at,lFc?RNIA•--Si75INE9S,T1t IT PURTa QN AND HOUSrNC, AGENCY ARNOLD 9CHPIAEtZk?S • • _ •R Govornor
DEPARTP4ENT OF TRANSPORTATION
111 GRAND AVENUE
0-
P. O. BOX 23660
OAKT-AND, C4 94629-0(360 Flex your power/
PHONE (510) 622-5491 Be energy efficient!
FAX (510) 286-5669
= 711
Letter 1.2
February 8, 2010
ALA580712
ALA-580-16.7
SC14#1991103064
1VIr. Mike Porto
City of Dublin
Community Development Department
100 Civic Plaza
Dublin, CA 94565
Dear Mr. Porto_
Grafton Plaza Development Project - Mitigated Negative Detlarti#ion (WV D- )
Thank you for including the California iDepartit ettt. of Transpom ti b. (Department.) in the
environmental review process for the Grafton Plaza Development Project. The following
comments are based on the MND.
On page 97, Supplemental Mitigation Measure TRA-2, if the intersection improvements at Santa 1.2.1
Rita Raad/Interstate (1) 580 ate not complete prior to .issuance of building permits for the
proposed project, alternative mitigation treasure should be provided.
On page 98, point B, although the proposed project will not worsen the level of service (LOS)
since these segments already operate at LOS F, the proposed project will increase the volume to 1'2'2
capacity ratio (V/C) by 0:2 seconds delay that will result in unacceptable saturation levels. Please
provide additional mitigation measures to address these impacts.
Should you have any questions regarding this letter, please call Yatman Kwan of my staff at (510)
622-1670,
Sincerely,
LISA CARBONI
District Branch Chief
L,c?cal Development - Intergovernmental Review
c: State Clearinghouse
'Caltranv improves rnobilfiy across California"
02/00:2010 MON 15:42 [T: /P,,: NO 9854] Z001
Grafton Plaza Inital Study/Mitigated Negative Declaration Page I of
From: Diane Lowart <Dlane.Lowart@ci.dublin.ca.us>
i To: Mike Porto <mike.porto@ci.dublin.ca.us> Letter 2.2
Subject: Grafton Plaza Inital Study/Mitigated Negative Declaration
Date: Thu, Jan 14, 2010 1:45 pm
Mike:
Thank you for the opportunity to review the Initial Study/Mitigated Negative
Declaration for the Grafton Plaza project. At this time, I have no comments on the
Study.
I ,
Please let me know if you would like the document back.
Diane Lowart
Parks & Community Services Director
City of Dublin
http://webmail.aol.com/30361-111 /aol-1 /en-us/mail/PrintMessage. aspx 1/14/2010
I
Letter 2.1
0 o b
N ?
ma mo
cr' joC'o
a w
CD ? . co
b
n
5>o
o 0
co ?C ? "c3 cu
c 0.
? z
n
CD
_ R CD n
C
w p
0
ca
w ?.
C) ~ d
rt
Grafton Plaza Inital Study/Mitigated Negative Declaration Page 1 of 1
From: Diane Lowart <Diane.Lowart@ci.dublin.ca.us>
To: Mike Porto <mike.porto@ci.dublin.ca.us> Letter 2.2
Subject: Grafton Plaza Inital Study/Mitigated Negative Declaration
Date: Thu, Jan 14, 2010 1:45 pm
Mike:
Thank you for the opportunity to review the Initial Study/Mitigated Negative
Declaration for the Grafton Plaza project. At this time, I have no comments on the
Study.
Please let me know if you would like the document back.
Diane Lowart
Parks & Community Services Director
City of Dublin
http://webmail.aol.com/30361-111/aol-1 /en-us/mail/PrintMessage.aspx 1/14/2010
DUBLIN
SAN RAMON
SERVICES
DISTRICT
7051 Dublin Boulevard
Dublin, California 94568
Phone: 925 828 0515
FAX: 925 829 1180
avcxnv.dsrsd.com
January 20, 2010
City of Dublin - Community Development Department Letter 2.1
Attn: Mike Porto, Consulting Planner
100 Civic Plaza
Dublin, CA 94568
Subject: PA 07-006 Grafton Plaza Project
Notice of Intent to Adopt a Mitigated Negative Declaration
Dear Mr. Porto:
RECE ED
JAN 2 2 2010
Thank you for the opportunity to review and comment on the Notice of Intent to Adopt a Mitigated 2.3.1
Negative Declaration for the Grafton Plaza Project dated December 2009. As noted in your transmittal
letter, an Initial Study/Mitigated Negative Declaration was approved, by the City of Dublin for a proposal
in this area in 2000. The current Initial Study/Mitigated Negative Declaration of December 2009 is for a
proposal that has been significantly altered and reduced from the previous proposal.
DSRSD reviewed the Initial Study/Mitigated Negative Declaration from 2000 and found no deficiencies
in that study. As part of that review, DSRSD confirmed that the proposal site was within the District's
Service Area and that the District would be able to provide wastewater collection service, wastewater
treatment service, recycled water (irrigation) service and potable water service. DSRSD found no impacts
or necessary mitigations beyond those identified in the Notice of Intent to Adopt a Mitigated Negative
Declaration in 2000.
Similarly, DSRSD will be able to provide wastewater collection, wastewater treatment, recycled water
(irrigation) and potable water services for the current reduced proposal on the same site. The current
study includes proposed amendments to the General Plan and Eastern Dublin Specific Plan to create a
new land use category, Mixed-Use 2/Campus Office, which would permit the developer to chose between
two possible development scenarios. In either scenario, DSRSD would be able to provide the services
listed above. DSRSD found no impacts or necessary mitigations beyond those identified in the Initial
Study/Notice of Intent to Adopt a Mitigated Negative Declaration dated December 2009.
Thank you for the opportunity to comment. Should you have any questions concerning the above, please
contact Stan Kolodzie at (925) 875-2253.
Sincerely,
V
ST EY KO DZIE
Associate En ' eer
SK/ST
Dublin San Ramon Services District is a Public Entity
2.3.2
2.3.3
H.\ENGDEPT\C0A\DUBLIMPA 07-006 N0I to Adopt Mt Neg Dec Grafton. Plaza Project (Revised 12-09).doc
y
ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT
100 NORTH CANYONS PARKWAY IIVERMORE, CA94551 PHONE (925) 454-5000 FAX(925)454-5727
January 28, 2010
Mr. Michael Porto Letter 2.4
City of Dublin
Community Development Department
100 Civic Plaza
Dublin, Ca. 94568
n RECSVEDP
JAN 2 9 2010
Subject: Draft Initial Study and Mitigated Negative Declaration (IS/NYIND) for
the Grafton Plaza Project
Dear Mr. Porto:
Zone 7 Water Agency (Zone 7) has reviewed the referenced CEQA document in the context of
Zone 7's mission to provide drinking water, non-potable water for agriculture/irrigated turf,
flood protection, and groundwater and stream management within the Livermore-Amador
Valley. We have the following comments for your consideration.
1. Zone 7 currently has a long-term contract with the California Department of Water
Resources for a maximum State Water Project (SWP) water delivery of 80,619 acre-feet
annually. Revise the text on page 106, under State Water Project Supplies, from 46,000 acre-
feet annually to 80,619 acre-feet annually. In the second paragraph, please delete the first
sentence and the following portion of the second sentence that reads "With regard to all of
these SWP entitlements." For more infonnation, please refer to Zone 7's Annual Review of
the Sustainable Water Supply Report, which is available on Zone 7's website.
2.4.1
2. For clarification, on page 107, under Local Surface Water, replace the second sentence with 2.4.2
the following text: "However, Zone 7 has rights to 50% of the runoff from the lake's
watershed after accounting for prior rights. Zone 7 estimates that approximately 7,400 to
11,450 acre-feet is available, but could change in the future."
3. On the same page, under Local Groundwater, replace the third and fourth sentences with the 2.4.3
following: "It is estimated that current natural sustainable yield is 13,400 acre-feet of water
per year. DSRSD does not have wells. Instead, they have a groundwater pumping quota of
645 acre-feet annually that Zone 7 pumps for them."
4. On page 108, in the second full indented paragraph, delete the text "at all times" and replace 2.4.4
it with the following text: "through conditions selected by Zone 7 staff." Also delete the
second sentence in this paragraph in its entirety.
Mr. Michael Porto
City of Dublin
January 28, 2010
Page 2 of 2
We appreciate the opportunity to comment on this document. If you have any questions or
comments, please feel free to contact me at your earliest convenience at 925-454-5036 or via e-
mail at mlimgzone7water.com.
Since ely,
Mary Lii
Environmental Services Program Manager
Cc: Kurt Arends, Jarnail Chahal, Brad Ledesma
ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT
100 NORTH CANYONS PARKWAY UVERMORE, CA 94551 PHONE (925) 454-5000 FAX(925)454-5727
RECEIVE
January 29, 2010 Letter 2.5 FEB - _i 2010
Mr. Michael Porto DUBLIN I! `` I NG
City of Dublin
Community Development Department
100 Civic Plaza
Dublin, Ca. 94568
Subject: Draft Initial Study and Mitigated Negative Declaration (IS/MND) for
the Grafton Plaza Project
Dear Mr. Porto:
Zone 7 Water Agency (Zone 7) has reviewed the referenced CEQA document in the context of
Zone 7's mission to provide drinking water, non-potable water for agriculture/irrigated turf,
flood protection, and groundwater and stream management within the Livermore-Amador
Valley. Zone 7 submitted a set of comments on January 28th, specifically related to water
supply. Zone 7 has the following additional comments related to flood protection for your
consideration.
On page 69, under the subject of Surface Water Quality, the Initial Study describes the 2.5.1
construction of a regional water quality basin on the southern portion of the Grafton Plaza
site, which was constructed as part of a stormwater management plan for the Dublin
Ranch development using specific design criteria. Please provide the stormwater
management plan (SWMP) for the Dublin Ranch development for Zone 7's review, as we
were not informed of the water quality basin's construction or what the specific design
criteria was for the basin. Also provide all hydrologic analyses associated with the water
quality basin, so that Zone 7 can determine whether operation and management of the
basin would impact Zone 7 flood control facilities (specifically Line G-3).
2. Under Flooding, on the same page, the Initial Study describes the site as once being 2.5 .2
designated by FEMA as being within a 100-year flood hazard area. The City of Dublin
filed a LOMB, which removed the site from flooding, due to the placement of up to 8 feet
of fill material on the site. Please provide the LOMR documentation for the site, as well
as the supporting documents and hydrologic analyses that show that filling the site and
forcing flood waters to be diverted elsewhere does not impact Zone 7 flood control
facilities (specifically, Line G-3) downstream of the site.
3. The Initial Study references the Easter Dublin EIR as providing Mitigation Measures for 2.5.3
the project. Since the documentation for the EIR was dated 1993, please provide copies
of the original document's proposed Mitigation Measures with relation to Hydrology and
Mr. Michael Porto
City of Dublin
_ January 29, 2010
Page 2 of 2
Water Quality, as the Initial Study does not appear to adequately describe the Mitigation
Measures that the project plans to utilize.
When would these mitigation measures be implemented? Zone 7 requests to be notified
well in advance and provided with any proposed mitigation plans to allow review prior to
implementation.
4. On page 70, the Initial Study references the 2000 MND as identifying additional 2.5.4
Mitigation Measures (5 and 6). Please provide copies of the original 2000 MND
document's Mitigation Measures as they relate to Hydrology and Water Quality, as this
Initial Study does not appear to adequately described those additional Mitigation
Measures that the project plans to utilize.
We again appreciate the opportunity to comment on this document. If you have any questions or
comments, please feel free to contact me at your earliest convenience at 925-454-5036 or via e-
mail at mlimnzone7water.com.
Sincerely,
F?
Mary Lim
Environmental Services Program Manager
Cc: Kurt Arends, Joe Seto, Jeff Tang
o?`a?\On uV"a'? s COUNTY OF ALAMEDA
PUBLIC WORKS AGENCY
DEVELOPMENT SERVICES DEPARTMENT
951 Turner Court, Room 100
PUBLIC Hayward, CA 94545-2698
WORKS (510) 670-6601
?es?Ume? FAX (510) 670-5269
February 5, 2010
Mike Porto
Community Development Department
City of Dublin Letter 2.6
100 Civic Plaza
Dublin, CA 94568
Dear Mr. Porto:
RECEIVE[)
uu'rr??-?? ?DEB - ?9 2010
l? uat. Lj j P-LA- NP I? IC,
Subject: Grafton Plaza Project - Notice of Intent to Adopt a Mitigated Negative Declaration
Reference is made to your transmittal on January 8, 2010, of the Notice of Intent to Adopt a
Mitigated Negative Declaration for the Grafton Plaza project, located at south of Dublin
Boulevard, east of Grafton Street and north of I-580 freeway in the City of Dublin.
Per our cursory review of the transmitted material, we hereby offer the following comments
regarding storm drainage that should be considered in the determination of project status:
Although the project site is located in Zone 7, runoff ultimately drains to the Alameda 2.6.1
Creek Federal Project in western Alameda County. This flood control facility is
maintained by the Alameda County Flood Control District. The District is concerned with
augmentation in runoff from the site that may impact flow capacity in the Federal Project
and in the watercourses between the site and, the Federal Project, as well as the potential
for runoff from the project to increase the rate of erosion along those same watercourses
that could cause localized damage and result in deposition of silt in the Federal Project.
There should be no augmentation in runoff quantity or duration from the project site that
will adversely impact downstream drainage facilities.
2. The applicant should provide measures to prevent the discharge of contaminated materials 2 6 2
into public drainage facilities. It is the responsibility of the applicant to comply with
Federal, State, or local water quality standards and regulations.
Thank you for the opportunity to review the Notice of Intent to Adopt a Mitigated Negative
Declaration for this project. If you have questions, please call meat (510) 670-5209.
Very truly yours,
Rzin, 'e e Leon
As? t eer
Land Development Services
TO SERVE AND PRESERVE OUR COMMUNITY
Page 1 of 2
Martha Aja
From: odhill@aol.com
Sent: Monday, January 18, 2010 9:18 AM
To: chrisdidato@gmail.com
Subject: Re: Grafton Plaza Project Letter 3.1
Chris:
Thank you for your comments. The Mitigated Negative Declaration document is the first step in a very long
process. The proposal before the City will not result in any immediate development. There are many more steps
along the way before development would ever occur on the Grafton Plaza site. Development of the first phase of
the Promenade is mostly beyond the City of Dublin's control as most all of the appropriate Planning
approvals have been obtained. Grafton Plaza has a long way to go and the proposal before the City right now
cannot result in development without a considerable amount of additional effort and approvals.
The City cannot force Charter Properties to develop the Promenade, but we do provide encouragement
throughout the process. As you know, the first phase of the Promenade which includes the Mercantile Building
and the ClubSport facility have received the necessary Planning approvals. The property has been subdivided to
create a legal building lot and Charter Properties has submitted construction drawings to the Building Department
which have been reviewed and returned to them with appropriate plan check comments.
The City has not received revised drawings. Once we receive them, will will process them quickly. We are all
interested in seeing the first phase of development as quickly as possible.
Again, thank you for your comments.
Mike Porto
----Original Message-----
From: Chris Didato <chrisdidato@gmail.com>
To: mike.porto@ci.dublin.ca.us
Sent: Sat, Jan 16, 2010 12:03 pm
Subject: Grafton Plaza Project
Mike, I'm a home owner in Dublin Ranch. I ve read over the the negative Declaration document.
I feel charter properties should be spending 100% of its efforts to complete the Promonade Project and I think the
city of Dublin should do everything it can to facilitate that.
Here is my rational:
If the promenade is completed Or real progeress can be shown to to potential buyers and investors, home and
condo sales will surge and home and property values will rise. This would no doubt raise property taxes /
increase revenues for the city and increase sales tax reveunes. AIII the while stabilizing he local relestate market,
which is projected to have TWICE the number of foreclosures this year of compared with last years record
number.
On the Down side the rise in porperty costs poses a potential LAG in the fullfilment of leases and offloading of the
properties Charter would own in the Grafton plaza project. You may think if the proprety vaules rise that would
benefit charter in the sales, however I feel with all the competition it would delay there ability to recoup ROL
On the other hand if the promonade is in not completed FIRST, i feel charter will be able to smoothly finish the
grafton plaza project. Though in the downside the above effect could be reveresed.
3.1.1
Home owners would have no viable selling points. They would have to compete with larger, up to date homes and
2/3/2010
More 2ot2
r condos selling for less or at the least, a better value.
Charter could take advantage of the lower realestate cost and sell a more competitive product to what is already
on the market. In this process it could bankrupt Toll Brothers which could put a large burden on the HOA's in
Dublin Ranch that are already struggling to sell there units and Rely M the fund from Toll Brothers.
Don't get me wrong I'd love to see Toll take a hit for its poor mangement and sales of the Terracess and other
properties. However I feel its bad for the taxe payers of dublin and in the end bad for the city of Dublin and its
revenue flow.
I'm proposing the City of Dublin spend more time investigating the Gafton Project while Pushing Charter to
Complete the long awaited and Long time needed Community Driving Promenade and finally Dublins First true
Down Town Anchor.
Pleasanton's Down town main strip is the first thing people see and experience there and its a large part why
people take a firts look to move there. All the other reasons for moving there shine through but Only after that
person makes the choice to investigate living there.
People don't make impulse decisions to move somewhere often. It's usually a word of mouth or experience there
that grabs there attention.
The problem with Dublin is it looks good on paper (statistically), but the city has no curb appeal. (No Down
Town). Nothing to experience other than a strip mall or two.
So, Although quite wordy, those are my thoughts.
I hope they help.
Chris Didato.
2/3/2010
February 8th, 2010
Attn: Mike Porto
Consulting Planner
100 Civic Plaza
Dublin, CA 94588
Letter 3.2
RE: Notice of Intent to Adopt a Mitigated Negative Declaration for the Grafton Plaza
Proj ect
Dear Mr. Porto,
I attended the earlier public hearing re the above property, & provided comments then. I
understand the developer is arguing now to have the zoning changed to enable the zoning
to fit their development plans. 2 points to consider -
1). FAR: I am happy to learn that progress has been made in reigning in the size of the
project, which had clearly exceeded its FAR in its earlier incarnation. My only concern
now is that the extent of the property being considered in the FAR calculation includes
the water quality basin, which results in a greater amount of buildable GSF. Without the
water quality basin, both the size of the development & the height of the development
would be far smaller & more in keeping with the area.
2). Zoning Change: The desire to change the zoning designation to accommodate the
developer's needs seems unethical. I, as well as perhaps other homeowners at the
Terraces, purchased our property knowing that the land across Dublin Blvd was zoned for
Campus Office...per documents reviewed in the Toll Brothers sales office, as well as
signs along Dublin Blvd declaring "Campus Office" zoning for the site in question (these
have since been removed....limmm.). Now... had the property across Dublin Blvd been
originally designated for residential development during the initial planning stages for the
entire area, the net result would have been an entirely different plan for East Dublin. But
that is not where we are today. Today there is an abundant amount of residential
property per the master plan. Adding new & unplanned residences to this area will over-
saturate the market, & given the marketplace, drive property values down. This creates a
down-ward spiral: property tax revenues decrease & the rate of foreclosure increases =
not the desired end result the East Dublin plan envisioned. Owners at the Terraces want
to retain the value of their investment & not see it impacted by saturating the residential
market in this area. We purchased property here because we wanted to invest in the
vision depicted in the plan for East Dublin, & we want the area completed as originally
envisioned, & zoned.
As a tax-paying citizen of the City of Dublin, I must object to the developer's proposal to
modify the zoning to Mixed-Use-2/Campus Office. I must also object to any motion by
the city to adopt a change in zoning of the property / Grafton Plaza Project..
3.2.1 '
3.2.2
I look forward to the public hearing...
Gabrielle Blackman
Condo owner / the Terraces.
February 8, 2010
)on Brattebo
Letter 3.3 3385 Dublin Blvd. Unit 422
.Dublin, CA. 94568
(925)479-9177
City of Dublin
Community Development Department
Attn: Mike Porto, Consulting Planner
100 Civic Plaza
Dublin, CA. 94568
Re: Comments, Environmental Checklist, Initial Study, and Mitigated Negative Declaration.
Project: Grafton Plaza, P07-006.
Dear Mr. Porto:
Thank you for your work and effort on the preparation of this initial study regarding the
Grafton Plaza Project. I also want to thank the City of Dublin for providing the opportunity for Dublin
homeowners/residents to comment on this study, and the proposed Project.
I live in Dublin, in the Terraces at Dublin Ranch, which was built by Toll Brothers. In this letter, I'm
going to try to be brief with my comments and concerns because, frankly, I am very busy with my
own work/employment to write considerably regarding concerns about the Project.
The single greatest impact of the Grafton Plaza Project in this immediate area concerns 3.3.1
the impact on the quality of life for homeowners, such as myself, who have purchased their
homes in the immediate area of Dublin Ranch, and committed ourselves to Dublin by living in those
homes, and who live within one half mile of the Project.
The second greatest impact of the Project would be on the City's infrastructure and their ability to 3.3.2
support and maintain the additional resources necessary to sustain a project of this size.
In order to address the concern regarding the impact on the quality of life of Dublin
homeo'wners/residents, the City of Dublin and their planners must put themselves "in the shoes" of 3.3.3
homeowners who have committed themselves to life in Dublin, by purchasing property in Dublin, with
the intent of living in Dublin; i.e., the City of Dublin Planning Commission must try to understand the
impact of this project, and its size, on the immediate residents of the area by trying to imagine what
life would be like living near Grafton Plaza.
Significant impacts affecting quality of life would include those addressed in the Study's,
"Environmental Impacts Checklist", which begins on page-21. The following represents my immediate
concerns regarding each environmental impact with subsequent rating...
1a) [Environmental impacts, Aesthetics] - Impact, with proposed mitigation, discussion beginning
on page-31. I disagree with the study's environmental impact rating regarding Aesthetics.
First, there seems to be an emphasis on the preservation of scenic views from transportation
corridors/arteries coming into Dublin, per the Eastern Dublin Scenic Corridor Policies and Standards
which serves to implement the Eastern Dublin Specific Plan, and the Dublin General Plan.
On page-32, "Land Use and Circulation Element. Policy 5.6 A. Incorporate County-designated scenic
routes..., in the General Plan as adopted City-designated scenic routes and work to enhance a positive
image of Dublin as seen by through travelers." As a Dublin resident and homeowner, I can
understand that the City of Dublin would want to protect defined scenic corridors to try and- maintain
or improve the image/perception of Dublin, but what about the preservation of those same scenic
3.3.4
Grafton Plaza - Initial Study with Mitigated Negative Declaration - 02-08-2010 - Comments. doc - jb
1 of 5
views of the Tri-Valley for Dublin residents and homeowners? Does the City of Dublin care more about
its image in the eyes of people who don't live in Dublin, those "through travelers", or do they care
more about maintaining and/or improving the quality of life for the residents, citizens, and
homeowners of Dublin?
Understand that with respect to a rating regarding the aesthetic impact of Grafton Plaza, a rating of
"Less Than Significant With Mitigation" is not realistic, and does nothing to address the very real,
significant impact to homeowners in Dublin in the immediate area of the Grafton Plaza Project; and
that said impact will largely be governed by the height, positioning and location of proposed buildings
representing the Grafton Plaza project on the proposed lot.
Second, the proposed enhancements to the visual appeal of the building(s) through the proposed 3.3.5
mitigation measures (discussion beginning on page-34), while notable, still fall far short in addressing
major concern regarding building height and the preservation of scenic views and corridors of the
natural beauty of the Tri-Valley area, per the City's own guidelines.
On page-35, section (c), homeowners and residents of the Terraces at Dublin Ranch are identified as
being impacted by the project: "Future construction of the Grafton Plaza Project, under either Option,
would change the character of the site for residents of The Terraces, especially for residents on the
southern portion of the complex with views of the Grafton Plaza site and for travelers along Dublin
Boulevard and the I-580 freeway near the Grafton Plaza site. The proposed change of visual character
of the Project site would include construction of one or more multi-story structures along Dublin
Boulevard that could be visually obtrusive to travelers, residents and visitors in the area and would be
a potentially significant impact."
I very much appreciate the proposed effort to make the building(s) on the site more visually appealing,
but again, one must ask oneself, "Would I rather look at the natural beauty of the Tri-Valley, or would
I prefer to look at one or more large, multi-story buildings just across the street and in very close
proximity to my residence?"
Again, in that quotation (c) from page-35, it seems the City of Dublin is more concerned about its
image in the eyes of non-residents that it is about its homeowners who live in Dublin.
One can do everything to address how a building looks, or its external appearance and visual appeal,
but its size governs its aesthetic impact (negatively or positively) on the surrounding area, and hence
has a very real impact on the quality of life for Dublin residents living in the immediate area of the
Project.
Third, and regarding light sources and the use of lighting at the site, there will be a significant impact. 3.3.6
Some concerns regarding light sources can be addressed through the proposed mitigated measures,
for both project Options. However, in the case of the Commercial-Use Option, Dublin
homeowners/residents should not be exposed to light sources within the building(s) after regular
working hours, at nighttime, through windows facing Dublin Boulevard. Light sources inside building(s)
should have sensors which turn off when no one is working, or the building hours should be controlled
and light sources automated, especially at night, so as not to disturb residents across the street
(across Dublin Boulevard).
1b) [Environmental Impacts, Aesthetics] - Impact, with proposed mitigation, discussion beginning
on page-31: One impact/issue not addressed by the Study...
One critical concern was omitted from the study: privacy. Homeowners/residents of The Terraces at 3.3.7
Dublin Ranch whose homes face south and border Dublin Boulevard, have windows and French doors
in each unit open and facing a southerly direction. Because of the Project's proposed multi-story
buildings to be built alongside Dublin Boulevard, this will create a situation, or conditions, such that
people on the Grafton Plaza Project site living or working in one, or more, of the multi-story buildings
would be able to see into the residences/dwellings of some homes located at the Terraces.
Regardless of whether or not residents at the Terraces have/use window treatments, or not, the issue
of privacy should be recognized and considered in this Study. Currently, this is not the case, and
Grafton Plaza - Initial Study with Mitigated Negative Declaration - 02-08-2010 - Comments. doc - jb
2of5
regardless of the ultimate Option/Use determined for the Project, the necessary mitigation measures
must be created, addressed and implemented.
2) [Environmental Impacts, Noise] - Impact, with proposed mitigation, discussion beginning on
page-73 (Checklist item #11, discussion item #12). I disagree with the study's environmental impact
rating regarding Noise.
As a homeowner, living directly across the street from the project, it is already noisy, and just barely
acceptable. That is my experience, and I've lived here for almost three years. Cars racing up and
down Dublin Boulevard, and loud motorcycles, are the main contributors to noise on Dublin Blvd. anc
in that traffic corridor from Keegan Street to Tassajara. The I-580 interstate highway can also be
heard from our residence.
Now, add to that existing noise the additional noise which would emanate from the proposed intent of
Grafton Plaza, and hopefully there will be a'-greater understanding of the impact. However, I believe
the noise impact would vary depending on the Project's proposed intent (commercial vs. mixed-use).
Right now, I'm not certain which use/intent I would favor, but I would oppose any plan that does not
sufficiently address the additional noise introduced to the immediate surroundings by the Grafton
Plaza project.
Right now, I think my immediate concern regarding any additional noise emanating from the Project
would concern certain rowdy or boisterous individuals loitering or hanging around the finished Project,
if the Project was the Mixed-Use Option, providing shops and restaurants which might remain open for
business past 9:00pm in the evening. Under those conditions, mitigation efforts would be difficult,
unless public access to the site was restricted only from Grafton Street, not Dublin Boulevard, and
sufficient courtyard space constructed for the visiting public.
Regarding the Commercial-Use Option, I think I would have less concern. However, the concerns I
would have with this Option would be the traffic times for employees coming to work, and leaving
work to go home, and the noise which comes from outdoor generators and other machinery, like
backup power, which is typically located outdoors. This type of ground-based equipment is very noisy,
and should be addressed in all/any mitigation effort, including the prevention of the installation of this
ground-based equipment along Dublin Boulevard.
Also, I believe there are other mitigation measures, separate from those discussed in the study, which
can greatly assist in any negative impact to quality of life in the immediate area.
3) [Environmental Impacts, Population and Housing] - Impact, with proposed mitigation,
discussion beginning on page-83 (Checklist item #12, discussion item #13). I disagree with the
study's environmental impact rating regarding Population and Housing.
I think there will be a significant impact, not a less than significant impact, but that impact may not be
observable until other projects along the Dublin Boulevard traffic corridor are considered.
The immediate impact to the immediate area, within one half-mile, would the increase in population
density, and the traffic density. Right now, there are still many unsold homes in The Terraces at
Dublin Ranch. Now, combine that with the number of new developments in the surrounding area, and
it is easy to recognize that in a very short period of time, say within 2 - 3 years, population and traffic
density in the immediate area of the Project will be significant, and hence a significant impact. It is
not enough to only consider ABAG (Association of Bay Area Governments) estimates concerning
growth, when currently our nation's economy has been down and struggling, and now projected to
begin a slow return to health.
My concern is the impact on the quality of life of current residents of the immediate area of the Project,
when many more people are added to the area.
3.3.8
3.3.9
Grafton Plaza - Initial Study with Mitigated Negative Declaration - 02-08-2010 - Comments. doc - jb
3of5
4) (Environmental Impacts, Public Services] - Impact, with proposed mitigation, discussion
beginning on page-84 (Checklist item #13, discussion item #14). I disagree, in part, with the study's 3.3. 10
environmental impact rating regarding Public Services.
We have a problem here in the Terraces, and I believe the Dublin Police Department would be
impacted if considering the Mixed-Use Option.
Living here in Dublin Ranch, in the Terraces, I have a perception that our police officers are "stretched
thin". In other words, we may not have enough public servants, or police officers, to do the job. The
Terraces at Dublin Ranch have experienced several incidents of crime, and documented cases of
individuals who live on the other side of Keegan, in the Groves apartments, breaking into cars and
individual homes in the Terraces. While I do not think there have been incidents of violent crime, it is
disturbing to homeowners here, and is a constant topic of concern in our homeowners meetings.
Please do not misunderstand, I believe our police are the best, and my wife and I enjoy seeing their
presence in the community. However, we do not see them much in the Dublin Ranch area where we
live, which may or may not be of concern, but definitely gives the perception that we don't have
enough police officers in Dublin.
That is the reason why I believe that the Mixed-Use Option might not be as good for the immediate
community, as the Commercial-Option. I think with a Mixed-Use Option, that bad element which
comes from the apartments directly east of the Terraces, and across from Keegan, will represent a
real problem for the Project, and for patrons and the immediate community.
5) (Environmental Impacts, Transportation and Traffic] - Impact, with proposed mitigation, 3.3.11
discussion beginning on page-88 (Checklist item #15, discussion item #16). I disagree with the
study's environmental impact rating regarding Transportation and Traffic.
There should be no doubt that there will be a huge increase in traffic and parking problems in the
immediate area of Grafton Plaza.
There will be thousands of vehicles and each will require a parking space. Also, regardless of whether
the Project adopts a Commercial-Use or Mixed-Use Option, people will be taking many short trips
throughout the day, going to work, going to lunch, running errands, leaving work, etc...
Now, take into consideration new projects which are yet to be developed along Dublin Boulevard, just
east of the Project site, and maybe there will be a clear understanding of the impact of just the size of
Grafton Plaza on the immediate neighborhood.
Regarding parking, it has always been a problem out here in Dublin Ranch, specifically in the area of 3.3.12
The Terraces at Dublin Ranch, and the Sorrento at Dublin Ranch, and the Courtyards at Dublin Ranch,
etc... All Toll Brothers properties. One need only come out here and drive around the various
neighborhoods to see all the cars parked outside and along the streets. It looks awful.
Grafton Plaza must do two things: (1) There must be more-than-adequate parking provided for
visitors, workers and residents to the Project site, and (2) people who visit, or work, or live at the site
must be prevented from parking in a place other than at Grafton Plaza.
I would like to offer a thought I had while viewing the exhibits to the proposed Project plan. Granted,
I am not in the business of construction, or city planning, so please forgive me if this suggestion
appears naive... I would like to know if the Project considered for the northern-side of the proposed
lot in question, be swapped with the south-side of the lot which currently contains the water quality
control basin?
I'm suggesting that the water quality basin be moved and built on the north portion of the site, and a 3.3.13
small park built around it and made publicly accessible, and the Grafton Plaza project, with its
associated buildings be built instead on the southern portion of the site, closer to I-58Q.
Grafton Plaza - Initial Study with Mitigated Negative Declaration - 02-08-2010 - Comments. doc - jb
4 of5
If this is possible, many concerns and mitigation measures would be addressed, and residents living in
the immediate area would likely have much less concern about the Project and its impact on the
immediate area/neighborhood.
Finally, Mr. Porto, if you would like, I would invite you to our home, to see for yourself the possible 3.3.14
impact, or impacts, this Project will have on the quality of life for us. Please let me know if you would
be interested in doing that, I would be happy to provide you that opportunity.
Again, thank you for the opportunity to respond with comments to the Environmental Impact Initial
Study for the Grafton Plaza Project.
Sincerely, and kind regards,
Jon Brattebo
Grafton Plaza - Initial Study with Mitigated Negative Declaration - 02-08-2010 - Comments. doc - jb
5of5
City of Dublin Page 7
Response to Comments April 2010
Grafton Plaza Project
Responses
The following are responses to each of the comment letters.
1.1) State of California Office of Planning and Research, State Clearinghouse
Comment : The Lead Agency has submitted corrected information for this project. No
other changes are proposed.
Response: This comment is acknowledged and no additional response is required.
1.2) State of California Department of Transportation
Comment 1.2.1: Regarding Supplemental Mitigation Measure TRA-2 on page 97 of the
Initial Study, an alternative mitigation measure should be provided for improvements
at the Santa Rita Road/ I-580 ramps should improvements not be completed prior to
issuance of a building permit.
Response: This comment is acknowledged. Supplemental Mitigation Measure TRA-2
would improve operations at the Santa Rita Road/I-580 Eastbound ramp to an
acceptable level of service by adding a second northbound left turn lane under long-
term, cumulative (2030) conditions. That is, the impact is not projected to occur in
the near term; instead, it would be a long term cumulative impact of the project and
other development between the present and 2030 buildout. As written,
Supplemental Mitigation Measure TRA-2 provides for two methods of providing the
identified second left-turn lane. The first option, included as point "a" in the text of
the supplemental mitigation measure, notes that the identified improvement is
planned to be included in the City of Pleasanton's Traffic Impact Fee. If this does not
occur, then, as required by point "b" in the text of the supplemental mitigation
measure, an alternative method would be required to make the needed
improvement, including but not limited to funding of the improvement by the
Project developer with an appropriate reimbursement arrangement.
The mitigation measure as written is adequate because it provides for establishment
of a funding mechanism for the I-580 ramp improvements prior to issuance of
building permits for the Project. That funding can be either the planned update of
the Pleasanton traffic fee, or an alternate mechanism that funds the improvement.
Contrary to the commenter's suggestion, mitigation improvements need not be
completed before issuance of building permits; this is because the long term
cumulative impact is not expected to occur then. Instead, funding for the
improvements must be established before issuance of building permits (see CEQA
Guidelines section 15130(a)(3)). This is exactly what the mitigations provide, as
written, so the requested mitigations are not required under CEQA.
City of Dublin
Response to Comments
Grafton Plaza Project
Page 8
April 2010
Therefore, the City of Dublin believes that mitigation for the long term cumulative
(2030) impacts at Santa Rita Road/I-580 ramps was adequately addressed within the
current Supplemental Mitigation Measure.
Comment 1.2.2: The commenter notes that based on information contained on page 98
of the Initial Study, the proposed Project will increase the volume -to-capacity (v/c)
ratio by 0.2 seconds for mainline freeway segments which will result in an unacceptable
saturation level. The City is requested to provide additional mitigation measures for
this impact.
Response: This comment is acknowledged. Volume-to-capacity ratio (v/c) is a ratio,
which does not have units, and "seconds [of] delay" is not applicable to the roadway
segment analysis that is the subject of the comment.
As stated on page 98 of the Initial Study, the standard of significance for impacts on
the subject roadway segments is: "The addition of project trips causes the volume-
to-capacity (v/c) ratio to increase by more than 0.02 on a segment that operates at
Level of Service (LOS) F." Note that the applicable numeric threshold is 0.02, not the
0.2 cited in the comment.
As shown in Tables 15, 16, and 17 in the Initial Study (pp. 100, 102-103), the Project
would not cause the v/c ratio to increase by more than 0.02 on any segment that
operates at LOS F. In Table 16, for SR 84 south of I-580, the southbound p.m. peak
values suggest a possible v/c increase of 0.02 with the project due to rounding, but a
footnote clearly demonstrates that the actual v/ c increase is 0.014 and well under the
"more than 0.02" threshold.
As stated on pages 99 and 101 of the MND, the project will have no significant
impact on the subject roadway segments, and therefore no additional mitigation is
required.
2.1) City of Dublin Police Services
Comment: The commenter has no comment on the Initial Study.
Response: This comment is acknowledged and no further response is
required.
2.2) City of Dublin Parks and Community Services Department
Comment: The commenter has no comment on the Initial Study.
Response: This comment is acknowledged and no further response is
required.
City o1 Dublin Page 9
Response to Comments April 2010
Grafton Plaza Project
2_.3) Dublin San Ramon Services District
Comment 2.3.1: The commenter notes that an. Initial Study/Mitigated Negative
Declaration was approved on this site in 2000. The current proposal for the site
has been significantly altered and reduced from the previous proposal.
Response: This comment is acknowledged and no further response is required other
than to clarify that the referenced "previous proposal" is the 2008 proposal that was
withdrawn. The current Project is consistent with the density approved in 2000.
Comment 2.3.2: The District reviewed the previous 2000 MND and found no
deficiencies in that study. At that time, DSRSD found that the Project site is within the
DSRSD Service area and the District could provide wastewater, potable and recycled
water service. No new impacts or mitigation measures were identified than were
analyzed in the 2000 MND.
Response: This comment is acknowledged and no further response is required.
Comment 2.3.3: The commenter notes that the District will be able to provide
wastewater collection, wastewater treatment, recycled water and potable water to serve
the Project under either development scenario.
Response: This comment is acknowledged and no further response is required.
2_.4) Alameda County Flood Control and Water Conservation District (Tanuary_
28 2010
Comment 2.4.1: The commenter requests that the text on page 106 of the Initial
Study be revised to state that Zone 7's annual allocation of State Water Project
water is 80,619 acre-feet on an annual basis. Also, delete the first sentence and a
potion of the second sentence that reads: "With regard to all of SWP
entitlements."
Response: This comment is acknowledged and the text of the Initial Study is
corrected to read as follows. Also see the Changes and Modifications section of these
responses to comments.
"In a typical year, Zone 7 gets approximately 70 to 80 percent of its water supply
from water conveyed through the Sacramento-San Joaquin Delta by the State
Water Project. Zone 7 has a 75-year contract with the California Department of
Water Resources (DWR) to receive water from the State Water Project (SWP). The
entitlement under this contract is 46,000 80,619 acre-feet annually. SWP water is
delivered to Zone 7 from the Feather River Watershed via the Sacramento-San
Joaquin Delta. This water is then transported to Zone 7 through the California
Aqueduct to the South Bay Aqueduct and Lake Del Valle. Water enters the Zone
City of Dublin
Response to Comments
Grafton Plaza Project
Page 10
April 2010
7 system from the South Bay Aqueduct and from Lake Del Valle at two Zone 7
treatment plants: the Patterson Pass Treatment Plant and the Del Valle Water
Treatment Plant.
or+ +? ,, + , Actual water deliveries vary, depending on hydrologic conditions,
requests by other contractors, delivery capacity and environmental/ regulatory
requirements."
Comment 2.4.2: The commenter requests a clarification on page 107 under Local Surface
Water to clarify the District's water rights from Lake Del Valle.
Response: This comment is acknowledged and the text of the Initial Study is
clarified to read as follows. Also see the Changes and Modifications section of these
responses to comments.
"Local Surface Water: Lake Del Valle is a local storage reservoir operated as part
of the SWP. Plewever, 7 rights +„ a??nn „ feet efwater per- year- frem
water-,;Led. However, Zone 7 has rights to 50 percent of the runoff fron
the lake's watershed after accounting for prior rights. Zone 7 estimates that
approximately 7,400 to 11,450 acre-feet is available, but could change in the
future."
Comment 2.4.3: The commenter requests a clarification on page 107 under Local
Groundwater to clarify the text regarding DSRSD pumping facilities.
Response: This comment is acknowledged and the text of the Initial Study is
corrected to read as follows. Also see the Changes and Modifications section of these
responses to comments.
Local Groundwater: Zone 7 and DSRSD use the local underground aquifer basin
as a storage facility for imported water. The aquifer is also naturally recharged
by rainwater falling in the watershed area. it is estimated that ^ safe yiel a of
13,400 aEr-e feet A--f ;vater- per year c---;;:p be 444Ldr-Aw4Q fxA;:A tLp 12)PIqin F=)SRSF=)
Comment 2.4.4: Text changes are requested on page 108 of the Initial Study regarding
future alternative sources of water that could be available to the District.
per year. DSRSD does not have wells. Instead, they have a groundwater
pumping quota of 645 acre-feet annually that Zone 7 pumps for them."
City oaf Dublin
Response to Comments
Grafton Plaza Project
Page 11
April 2010
Response: This comment is acknowledged and the text of the Initial Study is
corrected to read as follows. Also see the Changes and Modifications section of these
responses to comments.
"Zone 7 is altering its 100% Reliability Policy, which requires Zone 7 to have
adequate supplies available to meet 100% of customer demand at a
through conditions selected by Zone 7 staff. "
2.5) Alameda County Flood Control and Water Conservation District (January 29, 2010)
Comment 2.5.1: The commenter notes references to a regional water quality basin for
the Dublin Ranch project. The commenter requests a copy of the stormwater
management plan for the basin, stating that the District was not informed of basin
construction or the specific design criteria used. The commenter also requests all
hydrologic analyses associated with the basin so it can be determined if there would be
any impact on Zone 7 facilities.
Response: This comment is acknowledged. As noted in the Initial Study, the
water quality basin is an existing privately owned facility. The purpose of the
basin is to meet surface water quality standards rather than serve as a drainage
facility. The basin was installed in compliance with permit conditions imposed
by the San Francisco Bay Regional Water Quality Control Board for development
of Dublin Ranch. The basin is designed to hold low-flow stormwater runoff so
that pollutants settle out into the basin prior to release of treated water back into
the regional storm drain system. The basin system diverts only low flows into the
basin, with peak stormwater flowing directly into the regional drainage system.
The downstream Zone 7 drainage system is therefore not impacted by the
management and operation of the basin.
Additional design data on the water quality pond as well as documentation of the 2005
approval of the basin is on file in the City Public Works Department and available for
review during normal business hours. As noted on page 7 of the Initial Study: "no
changes are proposed to the existing water quality basin within the Project site and no
further discussion is provided in this Project Description."
Comment 2.5.2: The Initial Study states that the Project site was once within a 100-year
flood hazard area; however, the City filed a Letter of Map Revision (LOMR) which
removed the site from flooding with placement of up to 8 feet of fill. The commenter
requests copies of the LOMR documentation as well as supporting documents and
hydrologic analyses that show that filling of the site and forcing floodwaters elsewhere
will not impact Zone 7 flood control facilities downstream of the site.
Response: Per the FEMA floodplain maps for the City of Dublin, the lower
portion of Dublin Ranch was subject to overflow from the Arroyo Mocho, due to
a restriction in the unimproved Arroyo Mocho channel through Staples Ranch,
south of the I-580 freeway within the City of Pleasanton. This restriction in the
City of Dublin
Response to Comments
Grafton Plaza Project
Page 12
April 2010
channel caused peak flood flows to back up and cross I-580 to the Dublin Ranch
property, flooding a portion of the Project site. The floodwaters then flowed to
the west and drained to the south through a number of box culverts installed as
part of I-580 freeway construction.
Then, the G-3 drainage system was constructed, consisting of both open channels
and a large box culvert, to accommodate increased quantities of stormwater from
development of Dublin Ranch. The G-3 system collects stormwater runoff and
transports this water south, under the I-580 freeway, into the. Arroyo Mocho
channel and ultimately into San Francisco Bay.
Subsequently, Dublin Ranch was graded and filled. The graded condition of the
Grafton Plaza site left a small v-ditch immediately north of the I-580 freeway to
serve as a secondary overflow channel that would collect flood flows that might
cross the freeway and direct such flows back into the G-3 channel.
Since the time that the Dublin Ranch grading and the G-3 box culvert were
completed, Zone 7 has completed capacity improvements to the Arroyo Mocho
through Staples Ranch. It is the City's understanding that these improvements
eliminated the overflow of the Arroyo Mocho across I-580 and, when combined
with site grading, raised the Grafton Plaza site out of the 100-year flood hazard
area without redirecting floodwaters.
Additional details on the hydraulic design of the G-3 box culvert and the LOMR
are on file in the City Public Works Department and available for review during
normal business hours. Zone 7 should have information on the hydraulic
capacity of the improved Arroyo Mocho channel.
Comment 2.5.3: The commenter notes that the Grafton Plaza Initial Study references the
Eastern Dublin EIR. Since this document was dated 1993, the commenter asks for copies
of the original document's Mitigation Measures related to Hydrology and Water
Quality, since the Initial Study does not appear to adequately describe the required
mitigation measures.
Response: This commenter is directed to pages 69 and 70 of the Initial Study that
accurately summarizes hydrologic impacts and mitigation measures adopted in
connection with the Eastern Dublin approvals. The Eastern Dublin EIR is on file in
the Dublin Community Development Department and available for review during
normal business hours. From the time the Eastern Dublin mitigation measures were
adopted, they have been implemented routinely throughout Eastern Dublin,
including Dublin Ranch. Consistent with CEQA Guidelines sections 15162/15163
regarding subsequent environmental reviews, the MND provides adequate
description of the background mitigations already applicable to the project and
project site by virtue of the Eastern Dublin approvals. That is, the referenced
measures are not proposed for adoption; they were previously adopted and are
applicable to any future development on the Project site. Based on implementation
of those previously approved mitigation measures at the appropriate stage of Project
City of Dublin
Response to Comments
Grafton Plaza Project
Page 13
April 2010
development, the MND identified no additional significant impacts beyond those
previously identified and thus, no need for additional mitigations. The description
of the Eastern Dublin EIR mitigation measures is adequate for the purposes of
CEQA Guidelines section 15162/15163.
Comment 2.5.4: The commenter asks when these mitigation measures will be
implemented. Zone 7 staff requests to be notified well in advance and provided with
proposed mitigation plans.
Response: As required by CEQA and CEQA Guidelines, mitigation measures
included in adopted environmental documents will be implemented in accord with
the related Mitigation Monitoring Programs. Many of the mitigation measures
adopted as part of the Eastern Dublin EIR have already been implemented. These
include, for example, a requirement for individual project developers to prepare and
implement master drainage plans (Mitigation Measure 3.5/46.0) and construction of
the G-3 regional drainage system and related facilities (Mitigation Measures
3.5/45.0,47.0 and 48.0).
The adopted mitigation monitoring programs are on file in the City planning
department and available for review during normal business hours. As may be
appropriate for individual mitigation measures, Zone 7 staff will be included in the
implementation of such measure.
Comment 2.5.5: The commenter asks to see the original 2000 MND that contains
mitigation Measures 5 and 6 related to Hydrology and Water Quality.
Response: This commenter is directed to page 70 of the Initial Study that accurately
summarizes Mitigation Measures 5 and 6. See Response to Comment 2.5.3
regarding the use and adequacy of descriptions of previously adopted mitigation
measures. The same principles apply to the mitigations adopted through the 2000
MND and described in the current Project MND.
2.6) Alameda County Public Works Agency
Comment 2.6.1: The commenter is concerned that augmentation in runoff from the
Project site may impact flow capacity in the Alameda Creek Federal Project and in
watercourses between the site and the Federal Project. There is also concern about
increases in the rate of erosion along these same watercourses that could cause localized
damage and result in deposition of silt in the Federal Project. The commenter notes that
there should be no augmentation of runoff quantity or duration from the Project site
that would adversely impact downstream drainage facilities.
Response: This comment is acknowledged. Based on information contained on
pages 70 and 71 of the Grafton Plaza Initial Study document, the Project developer is
required to prepare a storm drain master plan pursuant to Eastern Dublin EIR
Mitigation Measure 3.5/46.0. The plan must be designed to City of Dublin and Zone
City of Dublin
Response to Comments
Grafton Plaza Project
Page 14
April 2010
7 drainage criteria to minimize augmented stormwater runoff into nearby creeks
and streams.
The Dublin Ranch Master Drainage Plan has been prepared to address mitigation
measures from previous CEQA documents applicable to this site. Based on this
Master Plan the regional G-3 drainage system has been designed and constructed to
accommodate increased peak storm flows from the entire Dublin Ranch portion of
Eastern Dublin, including proposed development on the Grafton Plaza Project site.
To address meeting water quality regulations, including the potential for increases
in downstream siltation, the Project developer has constructed the water quality
basin on the southern portion of the Grafton Plaza site. For more information of the
purpose, function and operation of the water quality basin, the commenter is
directed to the Response to Comment 2.5.1.
Based on the above information and information contained in the Initial Study, the
City of Dublin does not believe that approval and construction of the Grafton Plaza
Project would exceed the drainage design capacity for stormwater flows through the
Federal Alameda Creek facility. Due to-the construction of the water quality basin,
there would also not be a significant increase in the amount of silt deposited in
Alameda Creek.
Comment 2.6.2: The commenter requests that the applicant provide measures to
prevent discharge of contaminated materials into public drainage facilities. It is the
responsibility of the applicant to comply with Federal, State and local water quality
standards and regulations.
Response: The MND sets forth the regulatory setting for ensuring that new
development maintains applicable water quality standards. EDEIR mitigations
require water quality investigations to control pollutant discharge into drainage
facilities. These mitigations were updated in the 2000 MND through Mitigation
Measure 5 that requires development projects to prepare Storm Water Pollution
Prevention Plans (SWPPPs) to maintain acceptable water quality during and after
project construction. As noted above, an area wide master drainage plan was
prepared in 2003.
Pursuant to these Mitigation Measures and the master drainage plan, the Dublin
Ranch Project has secured a Water Quality Certification and Waste Discharge Permit
from the Regional Water Quality Control Board (Order No. R2-2003-0032). This
permit sets forth the requirements for compliance with water quality standards and
regulations, including adherence to the Dublin Ranch Stormwater Management Plan
and preparation of Stormwater Pollution Prevention Plans (SWPPP) pursuant to the
general Storm Construction Permit, for development of the Dublin Ranch.
The Dublin Ranch Stormwater Management Plan includes a requirement to
construct and maintain the water quality basin in the southern portion of the
Grafton Plaza site, which serves as the major water quality infrastructure element
for the overall Dublin Ranch, including the Grafton Plaza Project. The basin was
City of Dublih
Response to Comments
Grafton Plaza Project
Page 15
April 2010
built in 2005 and includes features such as swales, plantings and other passive water
quality improvement features.
Dublin Ranch has secured and maintains a construction a SWPPP (WID No.
201C320937), which is revised as individual construction projects begin and end
within the overall Dublin ranch. This SWPPP will be updated to include the specifics
of the Grafton Plaza Project once development details are known. Project-specific
water quality investigations are required with submittal of future Site Development
Review, Stage 2 Development Plans and subdivision map applications to the City of
Dublin.
Through these regulatory requirements and previously adopted mitigations, the
Project will prevent discharge of contaminated materials into public drainage
facilities. Any potential water quality impacts have been adequately identified and
mitigated through applicable regulatory requirements and EDEIR and 2000 MND
mitigation. No further measures are required under CEQA.
3.1) Chris Didato
Comment 3.1.1: The commenter states his belief that the Project applicant (Charter
Properties) should be spending 100 percent of their effort to complete the Promenade
development, northwest of the Project site. The City should also do everything to
facilitate the Promenade.
The commenter notes that completion of the Promenade will increase sales for nearby
dwellings, property values will rise and there would be a rise in taxes to the City. The
local real estate market would also be stabilized. There could also be downsides to this
approach due to a lag in fulfillment of leases for the proposed Grafton Plaza Project.
Response: This comment is acknowledged. The comment does not address
environmental issues. The City notes that it has no authority to require the developer
to complete the Promenade project prior to approval of the proposed Grafton Plaza
Project. The City also notes that the entire Promenade Project has secured a Stage 2
Planned Development. The Clubsport/Mercantile and parking garage has received a
Site Development Review approval. An additional 5 sites make up the Promenade
area and these sites will require a Site Development Review Permit prior to
construction. Charter Properties is actively marketing this site to businesses. The
proposed action for the Grafton Plaza Project represents the first phase of many future
approvals required to actually construct buildings on the Grafton Plaza Project site.
As noted on Page 10 of the Initial Study document, the applicants must secure a Stage
2 Planned Development and other approvals that would identify specific land uses on
the site, precise density, development regulations and similar Project details.
City of Dublin
Response to Comments
Grafton Plaza Project
3.2) Gabrielle Blackman
Page 16
April 2010
Comment 3.2.1: The commenter states her happiness in the reduction of the Floor Area
Ratio (FAR) of the proposed Project. She is concerned that the current Project includes
FAR that would be transferred from the adjacent water quality pond, which results in a
greater amount of gross square footage on the site. Without the FAR transfer from the
water quality basin, the proposed Grafton Plaza building would be smaller with a lower
height, more in keeping with the area.
Response: This commenter's opinion regarding the overall Project is noted. The
Project square footage is consistent with the density approved for the 25.33-acre site
in 2000. The Project proposes to cluster development on the northerly portion of the
site, which is not an uncommon planning technique and has been used on other sites
throughout Dublin for various purposes, e.g., along major stream corridors. The
clustering technique inevitably increases density in the development area, while
reducing or eliminating density in the non-development area. Thus, the Project
consolidates future potential development in the northerly portion of the site, but
open space and recreation resources have also been consolidated with the water
quality basin. The basin provides a large, distinct green space with recreational
facilities, such as a pedestrian pathway. These areas would normally be located
throughout a development area in the form of smaller, intermittent spaces and
would not provide the Project's views across the basin site.
The specific development standards for any future Project development would be
established with future PD-Stage 2 Development Plans. Building height and
massing standards would be approved at that time; however, based on the City's
standard parking requirements, future development on the site could be expected to
be approximately 3-6 stories, which is consistent with the overall character of the
area. For example, the Promenade development is anticipated for up to 3 stories,
while the existing Terraces development is 4 stories of residential development. The
Floor Area Ratio (FAR) for the Terraces is 2.16.
The Project is consistent with the applicable 0.45 FAR and employs the clustering
technique to provide a unique combination of open space and recreational features
with a large-scale water quality facility and a development area that would be
generally similar in character and scale to other development in the area. The MND
has assessed the potential environmental impacts of the Project as proposed. Future
application reviews and implementation of adopted and proposed mitigations
would ensure that any future development will be attractive and appropriate for the
Project site area.
Comment 3.2.2: The commenter states her opinion that the requested PD rezoning seems
unethical. She and her neighbors purchased homes north of the Grafton Plaza site with
the understanding that this site was to be developed with Campus Office uses, not for
residential development. The commenter notes that there is an abundant amount of
residential property in Eastern Dublin and adding new residential will oversaturate the
market and drive down property values. There would then be a downward spiral, with
City of Dublin
Response to Comments
Grafton Plaza Project
Page 17
April 2010
decreased revenues to the City and more foreclosures. The commenter desires to retain
the value of her property at the Terraces and the Grafton Plaza site should be developed
as originally planned and zoned.
Response: This commenter's opinion regarding the proposed rezoning and
proposed residential uses on the Grafton Plaza site is noted. The comment does not
raise environmental issues; however, the City notes that the existing Campus Office
land use designation contained in the General Plan and Eastern Dublin Specific Plan
has always allowed inclusion of residential units as part of a mixed-use
development that would decrease overall traffic generation or increase social
interaction. The maximum amount of residential development is limited to 50% of
the developed area. Therefore, the proposed Grafton Plaza Project could include up
to 50% residential development under the current General Plan and Eastern Dublin
Specific Plan without the requested approvals.
Further, all required procedures for processing rezoning requests are being
followed. Under both State law and the Dublin Zoning Ordinance, property owners
may request rezoning of their property. The rezoning request cannot be approved
by the Dublin City Council until fully noticed public hearings are held by the Dublin
Planning Commission and City Council and necessary findings are made. Notice
for the proposed rezoning hearing by the Dublin Planning Commission has been
mailed out and published in the local newspaper, as required by law. The rezoning
is requested pursuant to the City's PD-Planned Development regulations, which is
usually a 2-step process. The Applicant is requesting the first step, which is a PD-
Stage 1 Development Plan. A PD rezoning is not always the more typical rezoning
from one district to another and from one set of uses to another. The proposed
campus office and residential mixed use options are largely permitted under the
existing land use designations and PD-Stage 1 Development Plan zoning.
As noted in the Introduction, the proposed land use and zoning changes formalize
the alternate campus office and residential mixed use options already permitted in
CO areas. If approved, the proposal also would expand permitted uses in the
residential mixed use option, e.g., to allow shopkeeper, live-work units, etc. Thus,
the effect and character of future development would be generally similar to what is
already permitted. Under these circumstances, the City does not agree that the
proposed rezoning is unethical. If neighbors in the Terraces had reviewed the CO
land use designations for the site, the uses would be very similar to the Project.
3.3) Ton Brattebo
Comment 3.3.1: The commenter notes that the single greatest impact of the proposed
Project concerns the impact of quality of life for homeowners who have purchased
residences in Dublin Ranch within a one-half mile radius of the Project.
Response: This commenter's opinion regarding Project impacts of quality of
life on existing residences is noted. Also see the Response to Comment 3.3.3.
City of Dublin
Response to Comments
Grafton Plaza Project
Page 18
April 2010
Comment 3.3.2: The second greatest impact would be on the City's infrastructure and
their ability to support and maintain the additional resources necessary to sustain a
project of this size.
Response: This commenter's opinion regarding the City's infrastructure system is
noted. However, as set forth in the Eastern Dublin Specific Plan and a number of
subsequent documents, the City of Dublin, working with Zone 7, Dublin San Ramon
Services District and other local and regional agencies have carefully planned for
development of Eastern Dublin since 1993. This planning included extensions and
widening of roadways, new water facilities, wastewater collection and treatment
infrastructure, new drainage facilities, new and/or expanded schools, additional
police staffing, new fire stations and other infrastructure needed to support planned
development. Infrastructure planning assumed development of Campus Office uses
on the Project site, such as adoption of Traffic Impact Fees by the City of Dublin to
fund new and expanded roadways, water and sewer master planning by Dublin San
Ramon Services District (DSRSD) and others, so that adequate infrastructure would
exist to serve the proposed Grafton Plaza Project. The potential impacts of
urbanizing Eastern Dublin and the Project site were further examined in the certified
EDEIR and in the 2000 MND for Area H. These reviews, approvals, mitigations and
compliance with regulatory and development standards will provide infrastructure
adequate to support the Project.
Comment 3.3.3: The commenter asks the City of Dublin and City planners to put
themselves in the shoes of homeowners in Dublin. The Planning Commission must try
to understand the impact of the Project and its size on the immediate residents of the
area by trying to imagine what life would be like near Grafton Plaza.
Response: This commenter's request that the Dublin Planning Commission and
other City officials understand the impact of the Project on nearby residents is
acknowledged. Effects of the Project on quality of life is not a CEQA issue. Through
the EDEIR, the 2000 MND and the Project MND, the City has adequately analyzed
the potential environmental effects of the Project.
Comment 3.3.4: The commenter disagrees with the conclusion contained in the Initial
Study regarding aesthetics. The Initial Study seems to place an emphasis on the
preservation of scenic views from transportation corridors and arteries coming into
Dublin. The commenter is concerned about the preservation of those same scenic views of
the Tri-Valley for Dublin residents and homeowners. The finding of the Initial Study that
the Project would be Less-than-Significant is not realistic and does nothing to address the
significant impact to homeowners in the immediate vicinity of the Grafton Plaza site. The
impact will be governed largely by the height, positioning and location of proposed
buildings on the lot.
Response: This commenter is correct that the Initial Study applies existing Eastern
Dublin Specific Plan visual resource standards and the Eastern Dublin Scenic
Corridor Policies and Standards to assess the anticipated aesthetic impacts of the
City of Dublin
Response to Comments
Grafton Plaza Project
Page 19
April 2010
Grafton Plaza Project. These standards and policies were adopted many years ago
when no residential development existed within the Eastern Dublin Planning Area.
They were therefore largely directed at the anticipated aesthetic impacts of
converting the vacant Eastern Dublin area to urban uses, which has been in progress
since 1993. The Eastern Dublin EIR assumed that the open space character of the
vacant lands (at the time the EIR was certified in 1993) would be lost as development
proceeded over time. As applied to the Project site, which has been designated for
urban-level development since adoption of the Eastern Dublin General Plan
Amendment and Specific Plan, the Eastern Dublin EIR disclosed that the open space
character and views would be replaced by development in Eastern Dublin. Given
these unavoidable impacts, aesthetic impacts were therefore directed to views of the
Eastern Dublin area from passersby on I-580 and other major roadways.
The concern raised by the commenter is subsection "c" of the Initial Study found on
page 35. The impact criteria reads: " Would the project substantially degrade the
visual character or quality of the site and its surroundings?"
The response to this question in the Initial Study notes that the Grafton Plaza site
contains no significant scenic resources, since the site has been graded. CEQA
defines scenic resources as including major stands of trees, major rock outcroppings,
creeks or similar natural features. Since none of these resources exist on the Project
site, there would be a less-than-significant impact on these resources.
The Initial Study also addresses views from adjacent residents onto the Grafton
Plaza site and associated aesthetic impacts. Given that the site has long been
planned for urbanization, the Initial Study contains Supplemental Mitigation
Measure VIS-1 to ensure that building elevations fronting on Dublin Boulevard and
adjacent to residences on the north side of Dublin Boulevard will be interesting and
attractive. Any future development on the Project site would require Site
Development Review to ensure that proposed development is well designed.
Comment 3.3.5: The commenter states that the proposed enhancements to building
elevations through implementation of Mitigation Measure VIS-1 falls far short of
addressing concerns regarding building height and the preservation of scenic views and
corridors of the natural beauty of the Tri-Valley area. The commenter concurs with the
conclusion stated in the Initial Study that construction of the Grafton Plaza Project
would have a potentially significant impact on nearby resident, travelers and visitor to
the area (see page 35 of the Initial Study). The commenter asks if one would rather look
at the natural beauty of the Tri-Valley, or more large multi-story buildings across the
street. It seems that the City of Dublin is more concerned about its image in the eyes of
non-residents than homeowners who live in Dublin.
Response: This commenter's opinion regarding the effectiveness of Mitigation
Measure VIS-1 is noted. The City of Dublin notes that the Grafton Plaza site has been
designated for urban development through the Campus Office designation since
1993. Leaving the site as vacant open space is not realistic and would not be
consistent with the General Plan or Eastern Dublin Specific Plan. The potential
rv + City of Dublin Page 20
Response to Comments April 2010
Grafton Plaza Project
effects of converting open space lands to urban uses was identified as significant and
unavoidable in Eastern Dublin EIR Impact 3.8/13. Adopted mitigations emphasized
retention of predominant natural features, but the loss of open space characteristics
throughout East Dublin could not be avoided as urbanization proceeded.
As stated in the Initial Study, future buildings within the Grafton Plaza will be
subject to approval of both a Stage 2 Development Plan and a Site Development
Review (SDR) permit by the City of Dublin, assuming the pending General and
Specific Plan Amendments and rezoning applications are approved by the City of
Dublin. When reviewing the Stage 2 Development Plan and SDR applications, the
City of Dublin will consider the aesthetics of final Project design, building heights,
landscaping and screening. Adherence to Supplemental Mitigation Measure VIS-1
will also be confirmed as part of the final design of future buildings. As noted in
Response 3.2.1, the character of the Project is anticipated to be similar to existing
development in the area. Scenic vistas are identified in the General Plan through the
Visually Sensitive Ridgelands to the north and east of the site. A visual analysis will
be required for any future development applications; however, the City notes that
the Project site has maintained a major corridor across the water quality basin for
views of the scenic ridgelands from I-580 and other public vantage points.
The City notes that the public, including adjacent residents, will have an
opportunity to review and comment on future specific development plans when
they are submitted to the City of Dublin.
Comment 3.3.6: With respect to light and glare impacts of the proposed Project, the
commenter requests the Mitigation Measure VIS-3 be amended to require that interior
light fixtures should have sensors to turn off lights when office spaces are unoccupied,
or the hours of operation for businesses within buildings be controlled adjacent to
Dublin Boulevard so as not to disturb nearby residents.
Response: The mitigation measures identified in the MND would reduce the light
and glare impact to less than significance. However, the City agrees that the
commenter's suggestion would help to further reduce the identified impact. Based
on this comment, with minor revisions to provide for emergency lighting,
Supplemental Mitigation Measure VIS-3 is hereby modified to read as follows:
Supplemental Mitigation Measure VIS-3. Project developer(s) shall
incorporate the following features into final building and improvement
plans for building elevations adjacent to Dublin Boulevard:
a) Streetlight fixtures and ground level, pedestrian oriented light fixtures
shall be equipped with cut-off-lenses to direct light patterns in a
downward direction. Photometric plans shall be included with final
building and improvement plans to ensure that spillover of light is
minimized.
b) Exterior lights on upper floors shall minimize glare off of the site.
City of Dublin
Response to Comments
Grafton Plaza Project
Page 21
April 2010
c) Interior lights for non-residential uses shall be dimmed or turned off
when not in use or needed for building security purposes.
d) Illumination shall be limited for exterior signs. If feasible, "canister"
sign types should not be used in favor of non-illuminated or exterior
illuminated fixtures.
e) Landscaping lighting shall be limited and directed appropriately to
avoid spillover of light and glare onto adjacent properties.
f) Light fixtures for interior building spaces visible from Dublin
Boulevard shall be equipped with timing devices to turn off lights
when building spaces are not in use. except for emergencv lighting. z
Comment 3.3.7: The commenter notes that the Initial Study omits an analysis of privacy
on existing residences. Occupants of multi-story buildings within the Grafton Plaza
Project would be able to see into southern facing residences of The Terraces complex.
Regardless of whether or not Terrace residences have window treatments, the issue of
privacy should be considered and appropriate mitigation measures created.
Response: The issue of resident privacy within The Terraces development is
important, but privacy is not considered an environmental topic under CEQA or the
CEQA Guidelines. In an urban setting where development of the site and the larger
area is assumed, the issue of privacy is typically addressed through building
setbacks, building orientation, window placement, landscape screening and other
design review features, taking into account proximity to other buildings and the
intervening presence of streets, such as Dublin Boulevard. These features will be
reviewed and addressed by the City of Dublin at the Site Development Review
(SDR) stage of future Project review, when site design and layout, specific buildings
and building orientations are proposed within the Grafton Plaza Project.
Comment 3.3.8: The commenter disagrees with the conclusion of potential noise impacts
beginning on page 73 of the Initial Study. Specifically, there is already a significant level
of noise along Dublin Boulevard from autos and motorcycles using this road as well as
noise from I-580. There could be additional noise depending on the development option
chosen on the Grafton Plaza site, but the commenter would oppose any plan that does
not sufficiently address additional noise. Of concern would be noisy or boisterous
individuals loitering near the proposed Project. Concerns with the mixed-use option
would be restaurants open past 9:00 pm, unless access were restricted only from Grafton
Street. The commenter would have noise concerns for development under the
Commercial-Use Option, including vehicle traffic, back up generators and other ground-
mounted equipment
Response: Potential noise impacts of approving and developing the proposed
Project are addressed in Section 12 of the Initial Study. The Initial Study does note
that existing (pre-Project) noise levels on Dublin Blvd. are 66 CNEL (see Table 9 of
the Initial Study), which is within the "conditionally acceptable" noise exposure
level as set forth in Table 10 of the Initial Study. As noted in the Initial Study, future
traffic volumes would not significantly exceed future volumes predicted in the
City of Dublin
Response to Comments
Grafton Plaza Project
Page 22
April 2010
Eastern Dublin EIR and no new or substantially more severe impacts would be
expected beyond those previously identified.
Construction of buildings on the Project site would shield some buildings within the
Terraces from noise emanating from I-580. Outdoor decks for dwellings within the
Terraces complex have been equipped with plexiglass panels to attenuate noise from
Dublin Boulevard.
Potential noise from generators and ground-mounted equipment will be regulated
by adherence to Supplemental Mitigation Measure NOISE-1 that requires a site-
specific acoustic report for all future buildings within the Grafton Plaza Project that
includes a residential complex. Each report must contain specific noise reduction
techniques to ensure that exterior noise levels meet City requirements.
Noise generated by loud or boisterous visitors to the Grafton Plaza site would be a
management and security issue and is not considered a significant environmental
impact under CEQA.
Comment 3.3.9: The commenter disagrees with the conclusion of the Initial Study with
respect to Population and Housing. There will be a significant impact along the Dublin
Boulevard corridor, but this impact may not be observable until other projects are built.
There would be an immediate impact to the Project area, within one-half mile, with an
increase in population and traffic density. There are a number of unsold houses in The
Terraces and a number of other development projects in the surrounding area. Within a
short period of time, population and traffic density will be significant. There is a concern
with the quality of life of current residents in the immediate area of the Project when
many more people are added.
Response: The commenter misconstrues the type of analysis required by the CEQA
Guidelines in the Population and Housing category. Issues analyzed include a
discussion of inducement of a substantial population growth to an area, either
directly or indirectly, and whether there would be a displacement of existing
housing units or people.
As indicated on page 84 of the Initial Study, the future development included in the
proposed Grafton Plaza Project has long been assumed in the Dublin General Plan
and the Eastern Dublin Specific Plan. Growth inducing impacts of developing the
entire Eastern Dublin area was analyzed in the 1993 Eastern Dublin EIR. As noted in
the Initial Study on p. 84, the proposed Grafton Plaza Project somewhat expands the
General Plan and Specific Plan permitted uses, but retains the 0.45 FAR density
approved in 2000. There would be no growth inducement beyond that analyzed in
the prior CEQA documents.
Since the site is vacant, there would be no impact with respect to displacement of
residences or people should the Project be approved and built. Therefore, the
finding contained in the Initial Study is valid.
City of Dublin Page 23
Response to Comments April 2010
Grafton Plaza Project
Comment 3.3.10: The commenter disagrees with the conclusion of the Initial Study with
respect to public services. The commenter has a perception that the Dublin Police
Department is stretched thin in terms of not having enough police officers to do the job.
There are documented cases of crime in The Terraces and in other nearby residential
projects. The commenter does not see a major police patrol presence in the Dublin Ranch
area and there is a perception that there are not enough police officers in Dublin.
Therefore, the proposed Mixed-Use Option may not be as good for the immediate area as
the Commercial option. The Mixed-Use Option could attract a bad element of people
from across Keegan, which would be a real problem for the Project.
Response: The commenter's opinion regarding police protection in Dublin is noted.
Based on a discussion with the Dublin Police Services Department (Val Guzman,
2.24/ 10), the City of Dublin Police Services Department is staffed with 1.15 officers
per 1,000 residents, which is consistent with the Department's staffing goals.
Further, the Police Services Department reviewed the MND and had no comments.
(See Letter 2.1.) Based on this information and the police services analyses in the
prior EIR and MND, this impact is less-than-significant, as concluded in the Initial
Study.
Comment 3.3.11: The commenter disagrees with the conclusion of the Initial Study that
states transportation and traffic impacts would be less-than-significant. There would be a
huge increase in traffic and parking problems near the Project site, including thousands
of vehicles needing parking. There is also a concern with adding anticipated Grafton
Plaza parking needs with all other to-be-developed projects along Dublin Boulevard.
Response: The commenter's opinion regarding traffic impacts is noted. A traffic
impact analysis was prepared for this Project by TJKM Transportation Consultants,
consultants to the City of Dublin. This report is included in the Initial Study
document as Appendix 3. The traffic analysis studied the potential impacts of the
Project on existing conditions as well as short term cumulative (2015) and long term
cumulative (2030) conditions. Table 11 of the Initial Study notes that buildout of the
Grafton Plaza Project would add an estimated 482 vehicle trips in the morning peak
and 951 vehicle trips in the evening peak period. The Initial Study shows that
Project traffic is not expected to cause unacceptable peak hour traffic conditions
when added to existing traffic (Table 12) or to projected short term cumulative
(2015) traffic (Table 13). Under long term cumulative (2030) conditions, however,
the traffic analysis identified two new potential impacts with related mitigation
measures to reduce the impacts to less than significant. Supplemental Mitigation
Measures TRA-1 and TRA-2 require improvements to the Dublin
Boulevard / Tassaj ara Road intersection and the Santa Rita Road / I-580 freeway
ramps as part of long-term (2030) buildout conditions. The MND adequately
updates prior environmental analyses regarding increased traffic from future
development of the Project and appears to provide exactly the review the
commenter seems to be suggesting. The conclusions contained in the Initial Study
regarding traffic impacts are valid, as analyzed.
City of Dublin
Response to Comments
Grafton Plaza Project
Page 24
April 2010
Comment 3.3.12: The commenter notes that parking has always been an issue in the
Dublin Ranch area, including at The Terraces, Sorrento and the Courtyards. Many cars
are parked outside of the neighborhoods and on local streets. There must be more than
adequate parking for Grafton Plaza visitors; workers and residents and people visiting
Grafton Plaza must be prevented from parking at a place other than Grafton Plaza.
Response: The commenter's opinion regarding potential parking impacts is
noted. Potential parking impacts are addressed on page 104 of the Initial
Study. Future developer(s) of the Grafton Plaza Project will be required to
comply with Supplemental Mitigation Measure TRA-3 that requires the
provision of on-site parking within the Grafton Plaza site to comply with City
of Dublin parking standards. The City of Dublin will confirm the quantity of
on-site parking in compliance with City codes when a Stage 2 Development
Plan is submitted for review in the future, when specific land uses are
proposed for the Grafton Plaza site. The amount of parking could only be
reduced based on a shared parking analysis that demonstrates that an
adequate amount of parking could be provided. With adherence to this
supplemental measure, no significant parking impacts would be created.
Specific design details regarding parking will be addressed in conjunction
with future Stage 2 Development Plans and Site Development Reviews by the
City of Dublin.
Comment 3.3.13: The commenter asks if the proposed site plan could be modified to
locate the water quality basin on the north side of the site, with development occurring
on the south side of the site, where the pond is currently located. If this were done, many
local residents would have less concern about the Grafton Plaza Project.
Response: The commenter's question about the possibility of "swapping" land uses
on the site is noted. However, based on the large cost of constructing the water
quality basin in its current location, the additional cost to fill and compact the
existing basin, and then excavate a new basin just north of the current basin would be
prohibitive and this proposal would not be feasible.
Comment 3.3.14: The commenter extends an offer to the Dublin City staff to visit his
house and see the potential impacts of the Grafton Plaza Project on their quality of life.
Response: This comment is noted and no further response is required.