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HomeMy WebLinkAbout8.1 Attch 08 Exh A Dublin Crossing Specific Plan-Final EIR Rpt DUBLIN CROSSING SPECIFIC PLAN FINAL ENVIRONMENTAL IMPACT REPORT OCTOBER 2013 Dublin Crossing Specific Plan Final Environmental Impact Report SCH # 2012062009 Prepared for City of Dublin Prepared by October 2013 Dublin Crossing Specific Plan Final EIR Page 1 Introduction The Draft Program Environmental Impact Report was circulated for a 45-day public review period from Monday, July 24, 2013 through Thursday, August 8, 2013, as assigned by the State of California Governor’s Office of Planning and Research State Clearinghouse and consistent with CEQA regulations. Copies of the document were distributed to state, regional, and local agencies, as well as organizations and individuals, for their review and comment. This document has been prepared in accordance with CEQA and state and local CEQA Guidelines and represents the independent judgment of the Lead Agency. This Response to Comments volume, together with the DEIR, technical appendices, and other written documentation prepared during the EIR process, as those documents may be modified by the City Council at the time of certification, will constitute the Final EIR, as defined in the State CEQA Guidelines, Section 15132, and the City of Dublin’s environmental document reporting procedures. Document Organization and Framework This Response to Comments package is organized as follows: Section 1 provides a brief introduction to this report. Section 2 provides a list of agencies and interested persons commenting on the DEIR. This section also contains individual comments followed thereafter by responses. To facilitate review of the responses, an index number (e.g., 1-1, 1-2, 2-1) has been assigned to each comment and to its corresponding responses. Section 3 contains revisions to the Draft EIR as a result of the comments by agencies and interested persons. The responses to comments contained in this section contain material and revisions which will be added or made to the text of the Final EIR. City Staff has reviewed this material and determined that none of this material constitutes the type of significant new information that requires a recirculation period for further public comment under CEQA Guideline Section 15088.5. None of this new material indicates that the project will result in a significant new environmental impact not previously disclosed in the DEIR. Additionally, none of this material indicates that there would be a substantial increase in the severity Dublin Crossing Specific Plan Final EIR Page 2 of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation as described in Section 15088.5. CEQA Requirements Regarding Comments and Responses CEQA Guidelines Section 15204 (a) outlines parameters for submitting comments, and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be, “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated.” Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible… CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by those submitting comments. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.” Dublin Crossing Specific Plan Final EIR Page 1 List of Commenters on the Draft Program EIR This section includes all written responses received on the DEIR and the City’s responses to each comment. Comment letters and specific comments are given letters and numbers for reference purposes. Where sections of the DEIR are excerpted in this document, the sections are shown indented. Changes to the DEIR text are shown in underline for additions and strikeout for deletions. The following is a list of agencies and persons that submitted comments on the Recirculated Draft EIR during the public review period: Table 2-1: List of Written Comments Received on the Draft EIR Comment Letter No. Commenting Person/Agency Date of Comment 1 CA Department of Transportation (Caltrans) August 7, 2013 2 Alameda County Community Development Agency – Planning Department August 7, 2013 3 Alameda County Community Development Agency –Surplus Property Authority August 8, 2013 4 Alameda County Fire Department July 12, 2013 5 Alameda County Transportation Commission August 1, 2013 6 Alameda County Flood Control and Water Conservation District, Zone 7 August 8, 2013 7 Dublin San Ramon Services District August 7, 2013 8 Dublin Unified School District August 7, 2013 9 California Clean Energy Committee August 2, 2013 10 William M. (Tim) Neilson June 27, 2013 11 Jasmeet July 10, 2013 12 Thomas McKinney July 24, 2013 13 Thomas McKinney July 29, 2013 14 Dublin Crossing, LLC July 22, 2013 Dublin Crossing Specific Plan Final EIR Page 1 Response to Comment Letter #1 from Mr. Erik Alm, CA Department of Transportation, dated August 7, 2013 Response to Comment 1-1 – Trip Generation For calculating the project trip generation rates, the project land uses were added to the baseline land uses and then the model was run to evaluate the traffic impacts. In the absence of layering approach, it is not feasible to create project only trips at intersections. Please see detailed explanation on this approach on page 3-228 of the DEIR (June 2013). Turning traffic diagrams, including distribution per study intersection for all scenarios, is provided in Appendix I of the Draft EIR and is available through the City of Dublin website at: http://dublinca.gov/index.aspx?NID=202. Response to Comment 1-2 – Highway Operations Intersection Delays The decrease in delay of intersections under future conditions would be reduced due to existing roadway improvements that are planned by the City of Dublin and funded by transportation impact fees. The model results reflect not only changes in the land uses, but also changes to the street network over time. The reason some of the impacts are lower in future year of 2035 is due to the fact that some of the improvements to the street network are expected to come on-line between 2020 and 2035. Therefore the model shows redistribution of traffic due to these anticipated changes. Please refer to pages 3-225 to 3-234 of the Draft EIR (June 2013) for detailed description of street network changes. Freeway Volumes The traffic volumes for the study freeway segments were developed using the Alameda County Travel Demand Forecast (TDF) model for forecast years 2020 and 2035. Because the Alameda County TDF model does not include a 2012 land use data set, the City of Dublin TDF model was used for the 2012 forecast year. For each horizon year (2012, 2020, and 2035), the proposed project was coded into the appropriate model and the output traffic volumes were reported directly from the model. There are several reasons why the study scenarios show no increase in traffic volumes on some study freeway segments. First, the proposed project would be an “infill” development, which would change the origin/destination trip pairs in the project vicinity. For example, the proposed project would include a retail component. Some of these trips are currently made from residents of Dublin to retail destinations outside of Dublin. With more local retail options, residents of Dublin are now more likely to stay in Dublin (on local streets) as opposed to using the freeway to access retail establishments outside of the area. In addition, the project includes a large residential component and is located (1) directly west of an existing industrial park in Dublin and (2) north of a large industrial park in Pleasanton. In some cases, project trips would replace Dublin Crossing Specific Plan Final EIR Page 2 longer home-based work trips that currently commute to/from these industrial parks from outside the area. Second, the TDF models consider the travel time of each route between origin/destination pairs, and the models will divert ambient traffic in accordance with the quickest path between origin/destination trip pairs. For example, when the project adds traffic to a freeway segment, this creates an increase in delay for existing users. As a result, some existing freeway users will change their routes because using a local street may result in a shorter net travel time. Thus, the proposed project could add traffic to a freeway segment, but the diversion of ambient traffic may result in little or no increase in the overall peak hour traffic volume. Third, the TDF models consider the lengthening of the peak commute period (commonly referred to as “peak hour spreading”). In areas that are congested (such as I-580 and I-680), TDF models will spread trips throughout the commute period, rather than just assigning them during the peak hour. This behavior is common among motorists. For example, if traffic around the project site is heavily congested during the 5:00 PM to 6:00 PM period, the model will consider the travel time for each origin/destination trip pair and move a small number of trips outside of the peak hour (to 4:50 PM instead of 5:05 PM). When all of these aspects of the TDF models are considered, the unadjusted (raw) model output showed small decreases in traffic volumes on some study roadway segments with the addition of the proposed project. In an effort to disclose the impacts of the project as conservatively as possible, decreases in baseline traffic were not permitted as part of the TDF model adjustment process. For example, if the unadjusted TDF model output showed a “no project” traffic volume on a study segment as 5,000 vehicles per hour (vph) and a “with project” traffic volume of 4,985 vph, the “with project” traffic volume was reported as 5,000 vph. Response to Comment 1-3 – Signal Operations Copies of the Syncho files utilized in the Traffic Impact Analysis are provided in Appendix I of the Draft EIR and are available through the City of Dublin website at http://dublinca.gov/index.aspx?NID=202. Dublin Crossing Specific Plan Final EIR Page 3 Response to Comment Letter #2 from Mr. Albert Lopez, Alameda County Community Development Agency – Planning Department, dated August 7, 2013 Response to Comment 2-1 – Air Quality Comment noted. Response to Comment 2-2 – Traffic and Transportation Comment noted. Response to Comment 2-3 – Alternatives As described in Section 15126.6(f) of the CEQA Guidelines, the range of alternatives required in an EIR is governed by the “Rule of Reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. As part of the project approval process, the City will prepare written findings (as defined by Section 15091 of the CEQA Guidelines). Possible findings include: (1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR. (2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. The findings will provide the basis for selection of the proposed project or one of the alternatives, based on direction as determined by the City of Dublin City Council. Response to Comment 2-4 – Air Quality / Greenhouse Gas Emissions Comment noted. The City will consider whether photovoltaic structures or solar water heaters are feasible mitigations to reduce air quality impacts as part of its findings in considering approval of the project. The Specific Plan land use designations for those portions of the project area that are closest to Dublin Boulevard and the BART station permit residential density up to 60 units/net acre and allow for a combination of residential and commercial uses, so the ability to construct high density residential development, as suggested by the commenter, is already being accommodated. Chris Bazar I Agency Directar Stuart Cook Dircclar 224 West Winton Ave Room 110 Hayward California 94544-1215 phone 510.670.5333 fax 510.670.6374 WWW. acgov,org/cda ALAMEDA COUNTY COMMUNITY DEVELOPMENT AGENCY SURPLUS PROPERTY AUTHORITY August 8,2013 Kristi Bascom, Principal Planner City of Dublin 100 Civic Plaza Dublin. CA 94568 RE: Dublin Crossing Specific Plan DEIR Dear Ms. Bascom: Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Dublin Crossing Specific Plan project. As you are aware, the Alameda County Surplus Property Authority is the master developer of both the Dublin Transit Center just to the south and the former Santa Rita property just to the east ofthis project. The Authority has four development sites directly across Dublin Boulevard from the Dublin Crossing area, including two that are currently under contract with developers. One of these sites (Site 164) is under contract with Regency Centers for a shopping center development (the Village @ Dublin), for which a DEIR has just been released by the City, approximately five weeks after the Dublin Crossing DEIR was published. We are therefore concemed that the Dublin Crossing EIR accurately describe potential impacts and adequately mitigate those impacts, and that the analysis and proposed mitigation measures for the Dublin Crossing EIR be consistent with the analysis and proposed mitigation measures in the Village @ Dublin EIR, especially since the Dublin Crossing project is very similarly situated and includes a 150,000 square foot shopping center at the northwest corner of Arnold Road and Dublin Boulevard, kitty-comer to the proposed 153,000 square foot Village @ Dublin project, located at the southeast comer of Arnold Road and Dublin Boulevard. Trip Generation Rates: The Dublin Crossings DEIR (page 3-224) uses ITE's 2008 Eighth Edition of Trip Generation for trip generation rates, including a daily trip rate of 42.94 for "shopping centers". In addition, all trip generation rates (including the shopping center rate) are reduced by 5o/o "since the project area is located near the Dublin/Pleasanton BART station". In contrast, the Village @ Dublin DEIR (page 44) uses ITE's 2012 Ninth Edition of Trip Generation with a "shopping center" daily trip rate of 56.73 (for the non-Whole Foods porlion of the project), and no reduction for proximity to BART, even though the two projects are essentially the same distance from the BART station. Kristi Bascom August 8,2013 Page 2 Both project areas are also considered to be within the BART station's "walkshed", as documented in the City of Dublin's 2010 Eastern Dublin Traffic Impact Fee Update report. Given the very similar characteristics of the "shopping center" component of these two projects, the City should be consistent in its analysis by using the same trip generation rates and reductions due to BART. Project Timing and "Cumulative" Traffic: The DEIR states (page 2-16) that anticipated build-out of the i 80 acre Dublin Crossing project is assumed to occur "over a period of approximately eight to twelve years", which seems reasonable, given the scale of the project. What's not clear is when the "period" might begin, given the complexity of the Army's phasing plan, the need to negotiate extensive biological and wetland impacts with Federal and State agencies, and the need to build significant amounts of infrastructure, both on and off-site. It's most likely that construction of the project will not begin until 2015, at the earliest, making "build-out" ln 2025 or even later. Because the identified traffic impacts associated with the Dublin Crossing project are largely related to the timing of the project relative to other projects in the vicinity, please clarifu when build-out of the project can reasonably be assumed. For instance, the Village @ Dublin DEIR assumes that the Dublin Crossing project is built-out tn2020, and that the Village project traffic will then be added to this cumulative condition. In fact, given the relative scales and complexity of the two projects, the opposite is more likely, with the Village @ Dublin project being completed prior to the majority of the Dublin Crossing project being constructed. The traffic analysis should reflect this. Eastern Dublin TIF: The Dublin Crossings project is literally surrounded on three sides by roadways and intersections that have been, or will be, improved through the Eastern Dublin Traffic Impact Fee program, including Dublin Boulevard, Dougherty Road and Arnold Road. The TlF-funded extension of Scarlett Drive from Dublin Boulevard to Dougherty Road and the TlF-funded widening of Arnold Road to four lanes north of Dublin Boulevard are almost entirely within the Dublin Crossing Specific Plan area, and Dublin Crossing traftc would necessarily utihze many other TlF-funded improvements. Yet the DEIR and the draft Specific Plan are unclear as to how the Dublin Crossings project will (or will not) participate in the Eastern Dublin TIF program, or otherwise provide mitigation. For instance, on page 3-223, the DEIR states that "presently, the proposed Dublin Crossing project is not part of the most recent update of the TIF program". Similarly, it's unclear whether the project will be responsible for constructing the Amold Road widening and Scarlett Drive extension as part of the project - or if it is being assumed that these improvements - estimated to cost over $18 million- will continue to be funded through the TIF. Kristi Bascom August 8,2073 Page 3 Given the Dublin Crossing project's location and dependence on existing and planned TIF improvements, and the fact that several planned TIF improvements are within the boundary of the project, it seems most logical for the project to be directly incorporated into the Eastern Dublin TIF program. This would create a clear method fbr the project's large volume of "new" traffic to help fund TIF improvements that would otherwise be funded by others for the benefit of this project. The Final EIR should clarifz what relationship the Dublin Crossing project will have to the E,astern Dublin TIF and the responsibility of the project to construct the Scarlett Drive and Arnold Road improvements. Traffic Mitigation: The DEIR states that the project would degrade the Iron Horse Parkway and Dublin Boulevard intersection from LOS C to LOS F under 2035 cumulative conditions, and states that the project applicant would be responsible for mitigating this condition (page 3-267). However, the proposed mitigation of adding a second northbound left turn lane on Iron Horse Parkway by widening the roadway 12 feet along approximately 400 feet the east side of Iron Horse Parkway appears to be infeasible without the loss of most (or all) of the existingiplanned sidewalk and street parking. This would be contrary to the adopted Dublin Transit Center street design standards and could impact the existing and planned residential projects along Iron Horse through the loss of pedestrian access andlor on-street parking spaces. The Final EIR should assess the practicality of this mitigation measure and the impacts the mitigation measure may create on its own. Biological Impacts The DEIR states (page 3-82) that the "Eastern Alameda Conservation Strategy (EACS) is sti11 in the developing process and has not been approved or adopted. Therefore, the proposed project would not have a conflict with the provisions of an adopted Habitat Conservation Plan.... Therefore the proposed project would have no impact". The Final East Alameda County Conservation Strategy (EACCS) was released in 2010, and was subsequently adopted by the City of Dublin. The Final EIR should therefore assess the proposed project's biological impacts against the Conservation Strategy's policy prior to determining whether or not there is an impact. As noted above, the Village @ Dublin DEIR was recently released by the City of Dublin for the development of a shopping center on a 74.2 acre site located directly across the street from the Dublin Crossing project. The Village project is located on similar terrain (relatively flat, highly disturbed grassland) as the 180 acre Dublin Crossing project, and has similar habitat characteristics as the grassland portions of the Dublin Crossing DEIR. While similar potential biological impacts have been identified for the two projects (impacts to special-status plants, Ikisti Bascom August 8,2013 Page 4 impacts to burrowing owls and impacts to nesting birds) - the proposed mitigation measures in the Dublin Crossing DEIR for these potential impacts tend to be much less stringent than the proposed mitigation measures for the Village @ Dublin project. For instance, even though Congdon's tarplant populations have been documented within the Dublin Crossing project area,the proposed mitigation measure (MM 3.3-2b because Congdon's tarplant is not a federal or state-listed plant) is to notify CDFW and prepare a mitigation plan that "shall include such measures such as transplanting plants, collecting seed or clippings and replanting species in an on-site location, if feasible or other location approved by Department of Fish and Game". In contrast, in the Village DEIR (where neither Congdon's tarplant nor any other special-status plant species has ever been identified), the special-status plant mitigation measure requires that, if populations/stands of a special-status species are identified and impacts are unavoidable, compensatory mitigation be provided, such as acquisition of off-site mitigation areas or credits at a mitigation bank, and such "mitigation shall be acquired at a minimum acreage ratio of 1:1 (acquired:impacted). For either ofisite mitigation option, measures shall be implemented (including contingency measures) providing for the long-term protection of the species". Another example is proposed mitigation for burrowing owls. While the Village DEIR requires that pre-construction surveys and (if owls are found on the site) mitigation conform to both the CDFW 2012 StaffReport on Burrowing Owl Mitigation and the EACCS, the Dublin Crossing DEIR burrowing owl mitigation measures omit any mention of the more stringent standards of the EACCS. Similarly, while both projects identifz potential impacts to nesting birds during construction, the Village DEIR has a much more stringent mitigation measure. The Dublin Crossing mitigation measure (MM 3.3.-6) states that, between March 1 and September 15, the project applicant shall have a qualified biologist conduct nest surveys no more than 30 days prior to any demolition/construction or ground-disturbing activities within 300 feet of "potential nest tress" for non-raptor species and 500 feet ofpotential nest trees for raptor species. In contrast, the Village DEIR mitigation measure requires that, for any construction between February 1 through August 37, at least three surveys of the site, spaced over several months, with the last to be conducted no more than 14 days prior to the start of work. Furthermore, the proposed mitigation measure requires that all trees, shrubs and other suitable nesting habitat within 250 feet of the project site "shall be searched for nests" (even this is offthe property). The City of Dublin needs to consistently apply mitigation measures to projects with similar biological impacts. Based on a comparison with the Village @ Dublin DEIR, the Dublin Crossing DEIR does not meet this standard. The Dublin Crossing FEIR should address this issue by modiffing the proposed biological mitigation measures so that they are consistent with other City of Dublin EIRs. Kristi Bascom August 8,2013 Page 5 Thank you for this opportunity to comment on the Dublin Crossing Draft Environmental Impact Report. We look forward to reviewing the Final EIR and commenting on the draft Dublin Crossing Specific Plan in the future. Sincerely,ffid-V--St-uart Cook Director CC: Pete Knoedler, Regency Centers Dublin Crossing Specific Plan Final EIR Page 4 Response to Comment Letter #3 from Mr. Stuart Cook, Alameda County Community Development Agency – Surplus Property Authority, dated August 8, 2013 Response to Comment 3-1 – Trip Generation Rates In determining the trip generation rates for any transportation analysis, the City uses the standards in place at the time the Notice of Preparation (NOP) is published for the EIR. In the case of the Dublin Crossing analysis, the NOP was published on June 4, 2012. At that time, the traffic analysis commenced and the trip generation rates used were those from the ITE manual in place at the time. The NOP for The Village @ Dublin, another Draft EIR that was recently prepared by the City of Dublin, was published on January 7, 2013. The ITE manual reference is updated regularly and it is a normal practice to use the most current version. A change in the trip generation to the 2012 ITE (Ninth Edition) rates is not anticipated to change the impact conclusions in the Draft EIR. With regards to the question on the five percent overall trip reduction and its application to the Dublin Crossing project, but not to The Village @ Dublin project, it is important to recognize that the two proposed land uses scenarios are different. It is a normal practice to apply the trip credits based upon the land use categories and other factors including proximity to a key traffic generator. Additionally, The Village @ Dublin has been allocated a 30 percent pass by trip credit as compared to 20 percent for commercial uses at Dublin Crossing. This difference is due to the different land use scenarios, proximity to the freeway, and overall differences between two projects. Response to Comment 3-2 – Project Timing and Cumulative Traffic The citywide traffic model, which was used for both the Dublin Crossing and The Village @ Dublin traffic analyses, assumed that approximately twenty percent of the residential units in the Dublin Crossing project would be fully occupied in Year 2020. However, in the project-level traffic analysis for 2020 for both the Crossing project and Regency project the City took a more conservative approach, and changed the assumptions to assume that the entire Dublin Crossing project would be built out and occupied by Year 2020. This approach examined the highest Project trip generation for Year 2020 and minimized the need for conducting additional interim model runs. Response to Comment 3-3 – Eastern Dublin TIF There are several transportation improvements needed for the implementation of the Dublin Crossing project. Construction or financial contributions toward some of the improvements have been identified as mitigation measures in the Draft EIR, and some improvements are required project commitments for the safe circulation of multimodal traffic. As a means of contributing its fair share toward improvements that are identified in the EIR, the developer will be required to pay a transportation Dublin Crossing Specific Plan Final EIR Page 5 fee at each building permit based on the amount such development would be subject to under the Eastern Dublin TIF, if the development were in the EDTIF. The Draft Development Agreement between the developer and the City contains language requiring the developer to complete specific transportation improvements by specific deadlines. These improvements are both EDTIF and non-EDTIF projects, and include the extension and widening of Scarlett Drive and the widening of Arnold Road from two lanes to four lanes between Dublin Boulevard and Central Parkway. The developer will receive a credit against their transportation fee obligation for EDTIF projects constructed by it above its fair share of project expense based on the traffic mitigation measures in the EIR. Response to Comment 3-4 – Traffic Mitigation Based on comments received during the Draft EIR comment period, the City is reconsidering proposed Mitigation Measure 3.12-4, which would require the addition of a northbound left-turn lane on Iron Horse Parkway at the intersection of Iron Horse Parkway and Dublin Boulevard. In an effort to conserve as much of the on-street parking and sidewalk area as possible in the Transit Center, the proposed alternative mitigation is proposed that will achieve the same mitigation result, but a more compact design will have fewer impacts on the surrounding streetscape and pedestrian mobility. MM 3.12-4 on pages ES-55 and ES-56 and pages 3-281 and 3-282 in the Draft EIR have been changed as follows: “To mitigate the impact at the intersection of Iron Horse Parkway and Dublin Boulevard would require an additional northbound left turn lane on Iron Horse Parkway. Based on the 2035 cumulative plus project conditions, the two northbound left turn lanes would need to be 400 feet each. This improvement would require the removal of parking on the east side of Iron Horse Parkway, traffic signal modifications, and changing the travel lane configuration and alignment to create:  One 16-foot wide southbound receiving lane on Iron Horse Parkway;  Two 10-foot wide northbound left turn lanes on Iron Horse Parkway; and  One 14-foot wide northbound shared through-right turn lane. Because the proposed project causes the change in operation from LOS C to LOS F, the proposed project is responsible for constructing these improvements. The timing of these improvements will be determined in the project’s mitigation monitoring program.” Under this configuration, parking would be removed on the east side of Iron Horse and the southeast corner of the intersection would need to be reconstructed, but little (if any) landscaping would be removed and no sidewalks would be removed Dublin Crossing Specific Plan Final EIR Page 6 from the proposed intersection. Operationally, this would allow for normal eight-phase signal operation and crosswalks on all four legs of the intersection. Response to Comment 3-5 – Biological Resources Comment noted and the respective change has been made to page 3-89 in the Draft EIR. The East Alameda County Conservation Strategy (EACCS) was released in December 2010. On August 21, 2012, the City of Dublin City Council adopted a resolution accepting the East Alameda County Conservation Strategy as guidance for environmental permitting for public projects affecting habitat and endangered species in Eastern Alameda County. The City recognizes that compliance with the EACCS by local jurisdictions, individual landowners, and developers who need regulatory permits is strictly voluntary. There is no requirement on behalf of the City, or private developers, to comply with the Conservation Strategy, rather the City acknowledges the EACCS as a guidance tool that could enable a more straightforward review and permitting process for projects with impacts to biological resources. Therefore, the project’s compliance with the EACCS is not a regulatory standard for determining biological impacts under CEQA. Response to Comment 3-6 – Biological Resources The mitigation measures relating to Congdon’s tarplant, Burrowing owls, and nesting birds in the Dublin Crossing Specific Plan Final EIR have been modified to be consistent with the mitigation measures identified in the Village @ Dublin Draft EIR. See Response to Comment 3-7, 3-8, 3-9, and 3-10 below. Response to Comment 3-7 – Biological Resources: Congdon’s tarplant See response to Comment 3-6. The respective changes to mitigation measures MM 3.3-2a and MM 3.3-2b on pages ES-16 to ES-18 and pages 3-74 to 3-75 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 3-8 – Biological Resources: Burrowing owls See response to Comment 3-6. The respective changes to mitigation measure MM 3.3-3a on pages ES-18 to ES-21 and pages 3-76 to 3-77 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 3-9 – Biological Resources: Nesting birds See response to Comment 3-6. The respective changes to mitigation measure MM 3.3-6 on pages ES-27 through ES-29 and pages 3-84 to 3-85 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 7 Response to Comment 3-10 – Biological Resources See response to Comment 3-6. As described above, the respective changes to the mitigation measures MM 3.3-2a, MM 3.3-2b, MM 3.3-3a, and MM 3.3-6 have been made to the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. G:\PA#\2008\PA 08-049 Camp Parks_Dublin Crossing\2011 Restart\CEQA-EIR docs\DEIR\DEIR comment letters\Fire Dept.doc Alameda County Fire Department Fire Prevention Bureau City of Dublin 100 Civic Plaza, Dublin, California 94568 Phone: 925-833-6606 Fax: 925-829-9248 APPLICATION REFERRAL LETTER COMMENTS DATE: 07/12/2013 TO: Kristi Bascom, Contract Planner FROM: Bonnie S. Terra, Division Chief/Fire Marshal SUBJECT/PERMIT #: Draft EIR and Specific Plan ADDRESS: Dublin Crossings Comments: 1. Street widths provided may not be adequate given the proposed heights of buildings. In those locations where buildings over 30 feet in height are to be built, the road width will need to be 26 feet. The 26 feet must be free and clear of any obstructions parking or medians. 2. In areas where there are fire hydrants the street widths shall be 26 feet. 3. Given that the site plan and unit configuration provided is illustrative and not definitive at this time. It is not possible to determine if there are enough ingress and egress points. Please note that multiple-family residential areas having more than 200 units, commercial projects greater than 30 feet in height and/or more than 124,000 square feet shall be provided with at least two points of access. Dublin Crossing Specific Plan Final EIR Page 8 Response to Comment Letter #4 from Ms. Bonnie Terra, Alameda County Fire Department, dated July 12, 2013 Response to Comment 4-1 – Internal Circulation Comment noted. The recommended changes have been incorporated into the Dublin Crossing Specific Plan. Dublin Crossing Specific Plan Final EIR Page 9 Response to Comment Letter #5 from Ms. Beth Walukas, Alameda County Transportation Commission, dated August 1, 2013 Response to Comment 5-1 – Agency Name Reference Comment noted and the respective changes have been made to pages 3-267 to 3-269 of the Draft EIR. Response to Comment 5-2 – Level of Service (LOS) Standard Comment noted and the respective change has been made to page 3-269 of the Draft EIR. Response to Comment 5-3 – Definition of “Unacceptable” LOS Comment noted and the respective change has been made to page 3-269 of the Draft EIR. Response to Comment 5-4 – Figure 3.12-7 Correction Figure 3.12-7 presents the trip distribution for the proposed project. The title of the figure has been revised on page 3-241 in the Draft EIR in the figures at the end of Chapter 3.12 of the Draft EIR. The trip generation for the proposed project is described in Table 3.12-7: Dublin Crossing Trip Generation. Response to Comment 5-5–Multimodal/Complete Street Design Considerations The Alameda CTC has requested that additional Transportation Demand Management (TDM) measures should be considered instead of physical improvements like addition of lanes. Following this general discussion, the letter asks for analyzing secondary impacts to other modes due to the proposed mitigations. Then three specific mitigations are recommended for additional analysis to evaluate secondary impacts. The impacts to transit, bicycle and pedestrian modes of transportation are evaluated in the EIR. Pages 3-234 to 3-236 of the Draft EIR (June 2013) provide a description of impacts on bicycle and pedestrian modes. Furthermore, on page 3-272 of the Draft EIR, Mitigation Measure 3.12-10 provides a specific mitigation to address bicycle and pedestrian circulation impacts. Additionally, the Specific Plan would incorporate the following measures from the City’s Bikeways Master Plan: • Develop a bicycle commuter route system that connects residential neighborhoods to employment areas, multi-modal terminals, and schools. • Encourage employers to provide secure bicycle parking, showers and changing rooms for bicycle commuters. • As a condition of project approval, require major development projects with major transportation impacts to construct adjacent bicycle facilities included in the proposed bicycle system. Dublin Crossing Specific Plan Final EIR Page 10 • Install bicycle stencils and bicycle-sensitive loop detectors (or other detector type) on bikeways as part of new signals, signal upgrades, and resurfacing/restriping projects. With regards to the specific mitigation measures, the following responses are provided: MM 3.12-3: The City is pursuing multiple sources of funding to conduct a feasibility analysis of the Iron Horse Trail connectivity from Dougherty Road to the (East) Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in this location could significantly enhance bike and pedestrian access to and from the project area and beyond. To support this project, the developer of the Dublin Crossing project is contributing $50,000 towards the feasibility analysis, and the City is seeking additional funding from ACTC’s own Sustainable Communities Technical Assistance Program. It is the City’s full intent to pursue a grade-separated crossing at this location, and at this time the alternative mitigation measure of removing a portion of the crosswalk across Dublin Boulevard will remain in the EIR. MM 3.12-4: See response to comment 3-4 (above). MM 3.12-6: Design of the intersection improvements will be reviewed for consistency with the City’s Bikeways Master Plan and reviewed for consistency with the City’s Complete Streets Policy (adopted by the City Council in December 2012). ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT, ZONE 7 100 NORTH CANYONS PARKWAY  LIVERMORE, CA 94551  PHONE (925) 454-5000  FAX (925) 454-5727 August 8, 2013 Ms. Kristi Bascom City of Dublin Community Development Department 100 Civic Plaza Dublin, CA 94568 Re: Dublin Crossing Specific Plan & Draft EIR Kristi: Zone 7 Water Agency (Zone 7) has reviewed the referenced CEQA document in the context of Zone 7’s mission to provide drinking water, non-potable water for agriculture/irrigated turf, flood protection, and groundwater and stream management within the Livermore-Amador Valley. We have the following comments for your consideration: 1. Section 2, Project Description, and Section 3.11, Public Services and Utilities: Zone 7’s 24- inch Santa Rita/Dougherty Pipeline runs just outside of the western boundary of this study area. A portion of Zone 7’s 18-inch Hopyard Pipeline is located within the project area along with our DSRSD Turnout No. 3. Please see the attached figure. Per Figure 5-5, it shows a relocated drainage ditch along with two underground storage ponds which may interfere with our pipeline. Any work which may interfere with Zone 7’s use of its waterline and/or turnout or full enjoyment of its easement rights requires an encroachment permit to be obtained from Zone 7. It appears that the turnout is located in what is planned to be a park/recreation area located westerly of A Street and southerly of G Street. We request that the developer provide more detailed information on the plans for that portion of the project located adjacent to our Hopyard Pipeline and DSRSD Turnout No. 3. Zone 7 does not generally allow permanent structures or trees to be planted within our easements. Any work within our easement will require an encroachment permit. Please contact John Koltz at 925-454-5067 for obtaining an encroachment permit. 2. On page 3-149 in Section 3.8.3: the DEIR mentions that the onsite recycled water demands will be 131 ac-ft/yr to 144 ac-ft/yr, but we don’t find any reference to its associated salt loading or potential effect on groundwater TDS. The RWQCB’s Basin Plan objective for this part of the groundwater basin is 1,000 mg/l TDS, but the current TDS conditions are not mentioned despite the project area having several groundwater monitoring wells located on it; some were installed for this EIR effort. 3. On page 3-142, under Groundwater Basin: While there is mention of Zone 7 serving as the groundwater Basin Manager (page 3-142), our salt management plan (SMP), as well as a groundwater demineralization plant to manage and mitigate salt buildup in the Main Basin (pages 3-143), the document lacks discussion of the State’s recent Recycled Water Policy which now requires salt management plans to provide for management of “nutrient loading” and “monitoring of contaminants of emerging concern (CEC)” by 2014. Zone 7 is working with DSRSD and other local water purveyors on an update of its SMP to meet these State’s requirements, which should be noted. Furthermore, we request Dublin’s support of these efforts to ensure a safe and reliable water source for future generations. 4. In Section 3.8: The numerous wells located on the site could lead to a groundwater contamination conduit issue if abandoned or buried during the construction of the project. Please incorporate a discussion as well as a mitigation measure that requires any existing or discovered well that is not needed for the project or groundwater basin management to be properly sealed or destroyed under a Zone 7 permit. 5. On p.2-13, under 2.8 Infrastructure Improvements: typo in last word in 2nd paragraph – change “are” to “area” Also, it is not clear what “existing trapezoidal channel across the southeastern portion of the project area” the author is referring to, as none of the Figures on stormwater drainage identify it by this name. 6. On p.2-14, 1st paragraph: there is a reference to Figure 2-11 which presents the Conceptual Stormwater Drainage and Detention System, yet Figure 3.8-3 presents the Proposed Drainage for Dublin Crossing Specific Plan. It is unclear which is the most current plan, as there are major differences associated with the use of underground storage basins. 7. On p.3-144, 2nd paragraph: Gleason is misspelled as “Gleeson.” 8. On p. 3-149, under On-site Surface Water Runoff: a reference to Figure 3.8-3 is called out. The two underground HMP storage basins proposed have a storage capacity of 3.3 acre-feet and 1.6 acre-feet; however, Figure 2-11 indicates 3.0 acre-feet and 1.5 acre-feet, respectively. Please clarify as to which is correct. Also, it is not clear how a basin size of 150’x75’x8’, as shown in Figure 3.8-3, can contain 3.3 acre-feet of storage; nor is it plausible how a 60’x40’x10.5’ basin can contain 1.6 acre-feet. This requires discussion, or possibly revision. 9. On p.3-150, 2nd paragraph should refer to the use of DUAL 96-inch diameter storm drain pipes. It is unclear how the proposed underground dual 96” storm drain pipes would act as detention basins as there is no description of how it would function or operate. Further review of the Hydrologic model is required. 10. On p.3-150, under Off-site Surface Water Runoff Management, third paragraph: “n” value is referred as “water flow velocity rate” instead of the typical designation, Manning’s coefficient. The proposed “n” value of 0.5 appears to be extremely high. Please review and correct as needed. 11. On p.3-157, Mitigation Measure 3.8-4a: it is unclear how the proposed detention basin will be operated and maintained, and by whom. 12. Hydraulic Model: Staff is still reviewing the Hydrologic Model associated with the proposed project and will not be able to provide comment before August 16. Zone 7 requests an extension of time to provide comments on the model. We appreciate the opportunity to comment on this Draft EIR. If you have any questions, please feel free to contact me at (925) 454-5005 or via email at erank@zone7water.com. Sincerely, Elke Rank cc: Carol Mahoney, Rhett Alzona, Joe Seto ZONE 7 WATER AGENCY DRAWN: 100 North Canyons Parkway Livermore, CA File: REVIEWED:LOCATION OFHOPYARD PIPELINE &DSRSD TO #3 SCALE: AS SHOWN DATE:07/23/2013 FIGURE # . PROJECT AREA ZONE 7'S HOPYARD PIPELINE AND DSRSD TO-#3 Dublin Crossing Specific Plan Final EIR Page 11 Response to Comment Letter #6 from Ms. Elke Rank, Alameda County Flood Control and Water Conservation District, Zone 7, dated August 8, 2013 Response to Comment 6-1 – Public Services and Utilities The existing DSRSD turnout and Zone 7 pipelines are located within the future City of Dublin Community Park parcel. The future planning and design of the park (which has not yet begun) will take into consideration the location of the turnout and pipeline and Zone 7 and DSRSD will be consulted on any issues relating to these facilities in the park design, including obtaining encroachment permit(s) if required. Response to Comment 6-2 – Salt Loading Effects on Groundwater Recycled water is planned for use at the project site. Potential impacts of recycled water delivered to the local groundwater basin — the Livermore-Amador Valley Groundwater Basin — was addressed in the Final Environmental Impact Report for the San Ramon Valley Recycled Water Program (Report), adopted in December 1996 by the DSRSD/EBMUD Recycled Water Authority which is incorporated herein by reference. Potential impacts to groundwater quality were discussed in Section 3.1 of the EIR; the impacts and mitigation summary for groundwater was outlined in Table 3-2. The project site is located over the Fringe Basin, groundwater basin that is not used for domestic water supply. Impacts to the Fringe Basin from the San Ramon Valley Recycled Water Program were found to be potentially significant. Potential increase in salt loading to the main basin, which is used for domestic water supply, is less than significant. Potential rise in shallow groundwater levels is possible, though unlikely; therefore the impact is also less than significant. As the Livermore-Amador Valley Groundwater Basin manager, Zone 7 developed a Salt Management Plan (SMP) in 2004 to address the increasing concentrations of salt in the groundwater basin, and to protect the long-term water quality of the Main Basin into the future. The adoption and implementation of an approved SMP was required under Provision D.1.c.ii of the San Francisco Bay Regional Water Quality Control Board’s “Master Water Recycling Permit,” Order No. 93-159. Zone 7’s Mocho Groundwater Demineralization Plant, which was completed in 2009, was one of the salt management strategies that were selected in the SMP. In 2005, Zone 7 prepared and adopted a Groundwater Management Plan (GWMP). It consisted mostly of a compilation of all of Zone 7’s then-current groundwater management policies, programs, and practices but also provided basin management objectives and included stakeholders and the public during its adoption process. The SMP was incorporated into the GWMP since it dealt with managing the sustainability of the groundwater basin’s water quality. In 2009, the State Water Resources Control Board adopted a new Recycled Water Policy (SWRCB Res No. 2009-0011). It mandated that a Salt and Nutrient Management Plan (SNMP) be prepared for basins where recycled water was to be used, and required it include plans for Constituents of Emerging Concern (CEC) Dublin Crossing Specific Plan Final EIR Page 12 monitoring. The plans are to be completed by May 2014, and include collaboration from local water, wastewater, and contributing stakeholders. Zone 7’s current SMP does not address either nutrient management or the CEC monitoring requirements. Starting in 2011, Zone 7 began working on the update of its SMP to incorporate the recent regulatory requirements. The key goals and objectives of the update effort include: 1) verifying strategies for reducing salt loading in the Main Basin, 2) addressing nutrient and CEC monitoring requirements, 3) assessing the potential salinity impacts of the water supply “portfolios” outlined in Zone 7’s 2011 Water Supply Evaluation, including increased recycled water use in the region, and 4) updating future salt and nutrient management plans. The update to the SMP is in progress. Based on compliance with these regulatory requirements and plans, the project’s impact to groundwater due to salt loading and total dissolved solids would be less than significant. Response to Comment 6-3 – Salt Loading Effects on Groundwater See Response to Comment 6-2. Response to Comment 6-4 – On-site Wells It is the City’s standard practice to include a condition of approval with any site improvement/grading plan or approval of a tentative map as follows: “Any groundwater wells found on the project site that are not needed for the project or groundwater basin management shall be properly sealed and/or destroyed under a Zone 7 permit.” Response to Comment 6-5 – Infrastructure Improvements Comment noted and the respective change has been made to page 2-15 of the EIR. The location of the existing “open” trapezoidal channel is shown in Figure 3.8-2: Existing Drainage. Response to Comment 6-6 – Clarification to Figures 2-11 and 3.8-3 Figure 2-11: Conceptual Stormwater Drainage and Detention System represents the conceptual storm water drainage and detention system. Figure 3.8-3: Proposed Drainage represents the proposed Q100 project flows and the title of the figure has been revised on pages v, 3-159, and 3-220 of the EIR to read accordingly. Response to Comment 6-7 – Misspelling “Gleeson” Comment noted and the respective change has been made to page 3-153 of the EIR. Dublin Crossing Specific Plan Final EIR Page 13 Response to Comment 6-8 – Onsite Surface Water Runoff The correct volumes are 3.3 acre-feet and 1.6 acre-feet and Figure 2-11: Conceptual Stormwater Drainage and Detention System will be revised accordingly. The corresponding basin sizes reflect the bottom dimensions of the proposed basins. With 3:1 side slopes, the basins as shown will carry the proposed volumes. Page 2-15 of the EIR has been revised to clarify the dimensions are of the bottom of the basin. Response to Comment 6-9 – Storm Drain Pipes In order to address the C.3 requirements, developed runoff must be mitigated to existing flow conditions. To accomplish this in drainage basins XX-1 and XX-2 of Dublin Crossing, flow will be routed to, and detained, in dual 96” diameter underground storage pipes. The storage pipes will be placed in a public storm drain easement. The runoff from drainage basins XX-1 and XX-2 will be conveyed to the dual 96” diameter underground storage pipes via public storm drain systems in the streets. Detailed design for the proposed dual 96” pipes will part of the construction documents approved at a later date, but the general concept is that the dual pipe systems will be connected at each end with vaults/manholes. At the downstream end of the system, the vault/manhole will have pipes or slots to meter runoff back into the City’s public storm drain system. The pipes/slots will be designed per the BAHM software to match the proposed runoff to the existing hydrograph. This storage system will be designed during the improvement plan process and will include construction details for the dual pipes and the vault/manhole structures. Response to Comment 6-10 – Off-site Surface Water Runoff Management (“n” value) The value noted (0.5) was a typographic error and has been corrected on page 3-160 of the EIR. Calculations shown in Appendix F were done based on 0.05 n-value. Response to Comment 6-11 – Mitigation Measure 3.8-4a (Detention Basin) The underground detention basins are proposed to be owned, operated, and maintained by a future Homeowners Association (HOA) or by a public agency (if an agency exists that is interested in serving in this capacity). A maintenance agreement will be executed between the City and the HOA (or agency) to ensure that the detention basins, and the Chabot Creek Channel, will be maintained properly and operated in a manner that does not impede the use of the Community Park (in which these facilities are proposed to be located). Response to Comment 6-12 – Hydraulic Model Comment noted. Additional comments were not provided by Zone 7 on the hydraulic model. Dublin Crossing Specific Plan Final EIR Page 14 Response to Comment Letter #7 from Ms. Rhodora Biagtan, Dublin San Ramon Services District, dated August 7, 2013 Response to Comment 7-1 – General Comment noted. Dublin Crossing Specific Plan Final EIR Page 15 Response to Comment Letter #8 from Ms. Kim McNeely, Dublin Unified School District, dated August 7, 2013 Response to Comment 8-1 – School Acreage Comment noted and the respective change has been made to page 2-8 of the EIR. Response to Comment 8-2 – School Site Description Comment noted and the respective change has been made to page 2-12 of the EIR. Response to Comment 8-3 – Internal Circulation Comment noted and the respective change has been made to page 2-13 of the EIR. Response to Comment 8-4 – Pedestrian and Bicycle Circulation The narrative description of the pedestrian and bicycle circulation is conceptual at this stage. Should the Dublin Unified School District (DUSD) develop an elementary school within the project area, the City of Dublin will work collaboratively with the DUSD to accommodate school-related pedestrian and bicycle circulation requirements into the final circulation plan. Response to Comment 8-5 – Soil Remediation As described on page 3-136 of the Draft EIR (June 2013), the U.S. Army and NASA are responsible for environmental remediation of existing hazardous materials within the project area and have agreed to remediate the project area to state and federal requirements. There will be no Department of Toxic Substance Control (DTSC) land use controls on the site, which means that site uses are unrestricted. Contamination that remains after the U.S. Army and NASA transfer the property to the project applicant and/or that needs to be remediated to a higher standard will either be remediated by the project applicant or by the U.S. Army or NASA prior to and during site grading and demolition activities associated with future development. Therefore, the proposed school site would be remediated and cleared to a level suitable for construction of an elementary school site. Response to Comment 8-6 – Project Phasing Comment noted. The DUSD will be consulted regarding project phasing in coordination with District needs and the availability of various parcels of land for development. Response to Comment 8-7 – Hazardous Materials Comment noted. The City acknowledges that a School Level Phase 1 clearance would be required in order for the site to be approved by the California Department of Education. Dublin Crossing Specific Plan Final EIR Page 16 Response to Comment 8-8 – Clarifications to Table 3.11-1 Comment noted and the respective change has been made to page 3-200 of the EIR. Response to Comment 8-9 – Text Clarifications to Page 3-187, 2nd Paragraph Comment noted and the respective change has been made to page 3-200 of the EIR. Response to Comment 8-10 – School Facility Act of 1998 Comment noted and the respective change has been made to page 3-205 of the EIR. Response to Comment 8-11 – Clarification to Impact 3.11-3 Comment noted and the respective change has been made to pages 3-212 and 3-213 of the EIR. Response to Comment 8-12 – Clarification to Table 3.11-3 Comment noted. The City has confirmed with DUSD that the existing data in the table is the most current data available. Response to Comment 8-13 Acres and Capacity References Comment noted. The clarifications are reflected on pages 3-212 and 3-213 of the EIR. Response to Comment 8-14 – Clarification regarding Seismic Faults Identified in Figure 3.5-1 Comment noted. A detailed discussion regarding potential fault rupture impacts and seismic ground shaking is discussed starting on page 3-105 of the Draft EIR (June 2013) and Appendix D to the Draft EIR contains both a Preliminary Geotechnical Investigation that was conducted in March 2012 and a Fault Ground-Rupture Investigation that was conducted in March 2013, which should be consulted for more information. Dublin Crossing Specific Plan Final EIR Page 17 Response to Comment Letter #9 from Mr. Eugene Wilson, California Clean Energy Committee, dated August 2, 2013 Response to Comment 9-1 – Introduction This comment provides background and introductory information about the California Clean Energy Committee. The comment does not raise any issue with respect to the contents of the Draft EIR, or any environmental issue regarding the proposed project. Because the comment does not specifically reference the Draft EIR or raise any other CEQA issue, no further response is necessary. The general summary of environmental issues raised in the letter are addressed in the responses to the specific comments on these issues below. Response to Comment 9-2 – Global Warming The comment provides background about global climate change, including providing general predictions of future global greenhouse gas (GHG) emissions and the potential effects. This comment does not specifically reference the Draft EIR or raise any other CEQA issue. Response to Comment 9-3 – GHG Emissions As described on page 3-118 of the Draft EIR, “Business as Usual” emissions refer to the emissions that would be expected to occur in the absence of GHG emission reductions. The baseline “Business as Usual” emissions for the project were calculated with the California Emissions Estimator Model (CalEEMod), as recommended by the Bay Area Air Quality Management District (BAAQMD) and the other air districts throughout California. CalEEMod utilizes emission factors provided by the various California air districts to account for local requirements and conditions. The emissions provided in the Draft EIR are based on a variety of inputs, including but not limited to, the land uses proposed for the project (1,995 residential dwelling units, 50,000 square feet of office uses, 150,000 square feet of shopping center uses, a 900-student elementary school, and 31.7 acres of park space), construction information (phases, lengths, and equipment used), and operational mobile trip generation (additional 22,047 gross daily vehicle trips). CalEEMod utilized the project information, as described above, to generate GHG emissions for the proposed project. CalEEMod contains several land use categories that are mainly based on data for land use categories published by the Institute of Transportation Engineers (ITE). The Draft EIR described that emissions would result directly from mobile and area sources, and indirectly from energy consumption, water demand, and waste generation. Emissions were calculated based on consumption rates and emissions factors from CARB, EPA, the California Air Pollution Control Officers Association (CAPCOA), CEC, California Climate Action Registry (CCAR), and the Pacific Institute. Dublin Crossing Specific Plan Final EIR Page 18 The proposed project’s GHG emission outputs are categorized by pollutant/GHG, land use, and source; refer to Appendix B, Air Quality and Greenhouse Gas Emissions Data, of the Draft EIR for detailed model input/output data. The most common GHGs emitted in association with land use developments include carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O). Carbon dioxide equivalent (CO2eq) values are also reported. In order to obtain the CO2eq, an individual GHG is multiplied by its global warming potential (GWP). The GWP designates on a pound for pound basis the potency of the GHG compared to CO2. CalEEMod calculates the emissions associated with on-road mobile sources. These are associated with residents, workers, customers, and delivery vehicles visiting the land use types in the project. The emissions associated with on-road mobile sources includes running and starting exhaust emissions, evaporative emissions, brake and tire wear, and fugitive dust from paved and unpaved roads. Starting and evaporative emissions are associated with the number of starts or time between vehicle uses are also included. The emissions from mobile sources were calculated with the trip rates, trip lengths, and emission factors for running from the CARB’s Emissions Factors 2011 (EMFAC2011), which is the recommended by CARB and the BAAQMD. Area sources include emissions calculated from hearths, consumer product use, architectural coatings, and landscape maintenance equipment. Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, roto-tillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers, as well as air compressors, generators, and pumps. The emissions associated from landscape equipment use were processed using OFFROAD 2011 and CARB’s Technical Memo: Change in Population and Activity Factors for Lawn and Garden Equipment (June 13, 2003).1 Prepared by the CEC, the California Commercial End Use Survey (CEUS)2 database was used to develop energy intensity values (electricity or natural gas usage per square feet per year) for non-residential buildings. The energy use from residential land uses is calculated based on the Residential Appliance Saturation Survey (RASS)3. The project’s emissions inventory also included emissions from natural gas consumption. The emission factors for natural gas combustion are based on the 1 California Air Resources Board, Technical Memo: Change in Population and Activity Factors for Lawn and Garden Equipment, June 13, 2003. Available at : http://www.arb.ca.gov/msei/offroad/techmemo/Lawn_and_Garden_Activity.doc 2 California Energy Commission, California Commercial End-Use Survey Results, 2006. 3 California Energy Commission, Residential Appliance Saturation Study, 2009. Dublin Crossing Specific Plan Final EIR Page 19 EPA’s AP-42, Compilation of Air Pollutant Emission Factor (AP-42) compilation of air pollutant emission factors and data from CCAR. The emissions from electricity were calculated by multiplying the energy use times the carbon intensity and other GHGs of the utility district per kilowatt hour. The amount of water used and wastewater generated by a project has indirect GHG emissions associated with it. These emissions are a result of the energy used to supply, distribute, and treat the water and wastewater. Emissions from residential water use are based on data from the Pacific Institute Waste Not Want Not report4. These values were divided by the total number of occupied households in California to give water demand per dwelling unit. Data for most commercial and industrial land uses was also obtained from the Pacific Institute’s Waste Not Want Not report.5 Total gallons of water used per day per metric were reported, where the metric is employee, student, room, acre, or square foot, depending on the land use. Indoor water end-use intensities were also obtained from the Pacific Institute report.6 Emissions from wastewater treatment are based on the CARB’s Local Government Operations Protocol (LGOP)7, which are in turn based on EPA methodologies.8 The Project’s BAU emissions do not include the reductions in GHG emissions from Specific Plan measures. Those reduction measures are described in the Draft EIR (June 2013) on pages 3-123 – 3-126, in particular Table 3.6-4. The quantification methods and reduction factors associated with the Specific Plan GHG reduction measures identified in the Draft EIR were developed and calculated using the CalEEMod model (see Appendix B to Draft EIR). CalEEMod uses the methodology prescribed by the California Air Pollution Control Officers Association (CAPCOA).9 The CAPCOA methodology presents the emissions reductions in terms of percentage reductions. For mitigation measures where the source metric is reduced, reductions are generally assessed based on a ratio comparison of a common “denominator” source metric for each source category in order to assist in the quantification of strategy impacts. For mitigation measures involving emission factor reductions, a ratio comparing the mitigated and baseline emissions factor is utilized to quantify the emission reductions. The CAPCOA source data that is used in the CalEEMod model is derived from CAPCOA’s Quantifying GHG Mitigation Measures documentation.10 The CalEEMod model allows GHG reductions to be taken for neighborhood enhancements; transit improvements; and reducing commute trips, 4 Pacific Institute, Waste Not, Want Not: The Potential for Urban Water Conservation in California, 2003. 5 Ibid. 6 Ibid. 7 California Air Resources Board, Local Government Operations Protocol. Chapter 10: Wastewater Treatment Facilities, 2008. 8 United States Environmental Protection Agency, Inventory of US Greenhouse Gas Emissions and Sinks: 1990-2006. Chapter 8: Waste, 2008. 9 Environ International Corporation, California Emissions Estimator Mode Users Guide, page 9, February 2011. 10 CAPCOA, Quantifying GHG Mitigation Measures, August 2010. Dublin Crossing Specific Plan Final EIR Page 20 water usage, energy consumption, and solid waste generation. Specific categories that were utilized in the analysis for which a GHG reduction was quantified were for increasing density, improving walkability, improving transit accessibility, providing traffic calming measures, limiting parking supply, and implementing a trip reduction program. With the reduction measures that are part of the project, the Project GHG emissions would be 18,686.60 which results in an efficiency level of 3.08 MTCO2eq/SP/year. As indicated in Section 3.6 of the Draft EIR, the City of Dublin decided to rely on the thresholds within the CEQA Thresholds of Significance Revised Draft Operations and Justification Report (dated October 2009) prepared by the BAAQMD. The BAAQMD CEQA Thresholds of Significance Revised Draft Operations and Justification Report established thresholds based on substantial evidence11 and are consistent with the thresholds outlined in the BAAQMD’s 2010 CEQA Air Quality Guidelines. City staff believes that these thresholds represent the best available science on the subject of what constitutes significant air quality and/or GHG effects under CEQA. Furthermore, pursuant to CEQA Guidelines Section 15064.7(c), “…a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” Therefore, the City is permitted to use BAAQMD’s thresholds to analyze the project’s GHG impacts on climate change, per CEQA Guidelines Section 15064.7(c). Note that BAAQMD’s adoption of its CEQA Guidance, including its recommended thresholds of significance, has been upheld in court. The First District Court of Appeal, reversing a trial court’s decision, upheld BAAQMD’s adoption of the thresholds finding that the adoption was not a project subject to CEQA review. The court reasoned that the State CEQA Guidelines establish a procedure for adopting significance thresholds, and CEQA review of the thresholds themselves is not part of that procedure. Moreover, in adopting the thresholds, BAAQMD had undertaken a public review process and considered substantial evidence in compliance with the State CEQA Guidelines, so that requiring a specific CEQA analysis and document (ex. Negative Declaration or Environmental Impact Report) would be duplicative. The GHG analysis in the Draft EIR uses the BAAQMD’s efficiency approach, which considers efficiency in terms of the GHG emissions compared to the sum of the number of jobs and the number of residents at a point in time, which is referred to as the service population (project jobs plus project residents) (SP). The efficiency metrics is intended to avoid penalizing well-planned communities that propose a large amount of development. GHG efficiency metrics act to encourage the types of 11 “Substantial evidence” includes facts, reasonable assumptions predicated upon facts, or expert opinions supported by facts, but does not include argument, speculation, unsubstantiated opinion or narrative, evidence that is clearly inaccurate or erroneous, or evidence of social or economic impacts that do not contribute to, or are not caused by, physical impacts on the environment. Cal. Pub. Res. C. §21080(c); see also CEQA Guidelines §15384. Dublin Crossing Specific Plan Final EIR Page 21 development that BAAQMD and California Governor’s Office of Planning and Research (OPR) support (i.e., infill and transit-oriented development) because these types of development result in a lower amount of GHG emissions per service population than greenfield development or development outside urban areas. 12 Additionally, it should be noted that the BAAQMD bright line threshold would not be appropriate to apply to the proposed specific plan project which is not an individual development project. The BAAQMD CEQA Guidance states that the CEQA threshold of significance for Plan-level entitlements, such as Specific Plans, should use the threshold of 4.6 CO2e/SP/yr or compliance with a locally-adopted Qualified GHG Reduction Strategy or Climate Action Plan (CAP).13 The Draft EIR applies both of these thresholds in analyzing the level of significance for the Project’s GHG emissions. The analysis in the Draft EIR shows that the Project emissions are below the threshold of 4.6 CO2e/SP/yr and the Project complies with the City adopted CAP. (See analysis of Impacts 3.6-1 and 3.6-2 in Draft EIR, pp. 3-118 – 3-126.) In addition, the BAAQMD states that the bright line threshold applies to “…areas where a qualified Climate Action Plan has not been adopted….”; the Dublin Climate Action Plan was adopted by the City in October, 2010. Therefore, the bright line threshold would not apply to the proposed project in this regard. Response to Comment 9-4 – BAAQMD Guidelines/AB 32 The BAAQMD developed their California Environmental Quality Act (CEQA) Guidelines for the purpose of assisting lead agencies in evaluating air quality impacts of projects and plans proposed in the San Francisco Bay Area Basin (SFBAAB). The Guidelines provide BAAQMD-recommended procedures for evaluating potential air quality impacts during the environmental review process consistent with CEQA requirements. The purpose of California‘s legislative mandate (AB 32) is to reduce total projected 2020 GHG emissions to 1990 levels. The BAAQMD and CARB analysis relied on the initial estimate of this reduction to equal approximately 30 percent.14 However, this is likely an overestimate of the amount of the reduction needed based on recent data. In 2011 ARB revised its “business as usual” GHG emission estimate for 2020, in order to account for the recent economic downturn in its emission projections. The estimate presented in the scoping plan (596 MMTCO2eq) was based on pre- recession, 2007 data from the Integrated Energy Policy Report. In 2011 the CARB adopted the Final Supplement to the AB 32 Scoping Plan Functional Equivalent 12 BAAQMD, CEQA Thresholds of Significance Revised Draft Options and Justification Report, October 2009. 13 BAAQMD, California Environmental Quality Act (CEQA) Guidelines, May 2010, pp. 2-7 – 2-8., . 14 BAAQMD, California Environmental Quality Act (CEQA) Guidelines, 2012 and California Air Resources Board, Assembly Bill 32 Scoping Plan, 2009. Dublin Crossing Specific Plan Final EIR Page 22 Document (2011). In the Final Supplement, CARB updated the 2020 BAU based on revised growth projections and considering the influence of the recent recession and reduction measures that are already in place. Based upon revised growth projections only, statewide emissions would need to be reduced approximately 20% from the Updated 2020 BAU of approximately 545 MMTCO2eq to meet 1990 levels. So, to the extent the BAAQMD’s CEQA Guidelines (2011 and 2012) and the CEQA Thresholds of Significance Revised Draft Operations and Justification Report (2009) rely on the GHG emission reduction goals established by AB 32, it overestimates the reduction needed by using the 30% reduction goal. In addition, courts have upheld the use of a CEQA significance threshold for GHG emissions based on a percentage reduction from BAU derived from AB 32. The use of a significance threshold based on an adopted plan or law to determine whether a project’s impact is cumulatively considerable is also specifically authorized by CEQA Guidelines Section 15064(h)(3) Unlike the 2020 target under AB 32 and the Scoping Plan, the 2050 target is only a goal set forth in Executive Order S-3-05. The Executive Order is not an adopted plan or regulation that provides specific requirements for the reduction of greenhouse gas emissions as defined under CEQA Guidelines 15064(h)(3). In addition, BAAQMD (or any other agency) does not provide methodology or emissions factors to determine 2050 emissions. It is beyond the scope of the analysis tools available at this time to examine emission levels and reasonable emissions reductions in the year 2050 in a CEQA analysis. The quantitative GHG efficiency metric threshold was used based on the BAAQMD CEQA Thresholds of Significance Revised Draft Operations and Justification Report. The BAAQMD provides several threshold options for significance of GHG emissions, including an efficiency threshold. Normalizing projected emissions from land use- related emissions sectors by utilizing a demographic unit (e.g., population and employment) provides evaluation of the GHG efficiency of a project and the opportunity to evaluate the project’s consistency with AB 32 targets. The BAAQMD established the efficiency metric threshold to avoid penalizing well- planned communities that accommodate projected growth. Instead, GHG efficiency metrics act to encourage the types of development that BAAQMD and the OPR support (i.e., infill and transit-oriented development) because they tend to reduce GHG and other air pollutant emissions on a per capita basis. Response to Comment 9-5 – Existing Uses The existing uses on-site include the Camp Parks U.S. Army Reserve Training Area, the NASA parcel, and the Alameda County Surplus Property Authority parcel. In 2002, the US Army formally requested an amendment to the General Plan to change the land use designation from “Public Lands” to a combination of commercial retail, office space, residential, and open space uses. Dublin Crossing Specific Plan Final EIR Page 23 The project description indicates that there are 934 residents and employees throughout the entire Camp Parks base. It should be noted that these residents and employees are not located on the project site. The buildings on the project site are currently vacant. Pursuant to CEQA Guidelines Section 15125 the baseline conditions for the analysis consist of the uses that exist at the time that the notice of preparation is published. Therefore, the on-site buildings were not included in the existing conditions for the project site. As a result, all emissions from the proposed project were considered new emissions and were not reduced to reflect emissions from any prior or existing uses on the project site. Response to Comment 9-6 – GHG Emissions As described in the Draft EIR, total build-out under the Specific Plan would result in a service population increase of approximately 6,070 people. The significance threshold used in the Draft EIR is not solely based on the amount of emissions for the project. It is based on the amount of emissions per service population per year (See Responses to Comments 9-3 and 9-4). The project emissions with GHG reductions that will result from Specific Plan measures will be 18, 686.60 MTCO2eq. This equates to a emission level of 3.08 MTCO2eq/sp/yr which is 33% below the significance threshold of 4.6 MTCO2eq/sp/yr. The overall project emissions are also 28.5% below the 2020 BAU projection for the proposed project. Response to Comment 9-7 – GHG Emissions Growth Refer to Response to Comment 9-6, above. Response to Comment 9-8 – City CAP This comment addresses the City of Dublin Climate Action Plan (dated October 2010). The Draft EIR analyzes the project’s consistency with the Climate Action Plan (CAP) (Draft EIR Impact 3.6-2) in response to the second CEQA Appendix G checklist item (Consistency with applicable GHG plans, policies, or regulations). The Draft EIR analyzes the compliance of the proposed Project with applicable measures in the Climate Action Plan (Table 3.6-3). The Draft EIR also analyzes whether the proposed project BAU emissions will be consistent with the goal of the CAP to reduce GHG emissions to 20% below projected Year 2020 BAU emissions by 2020 which will result in an overall level of emissions of 4.2 MTCO2eq/sp/yr. The proposed project will reduce Year 2020 BAU emissions by 28.5% which exceeds the CAP’s reduction target and will result in an overall level of 3.08 MTCO2eq/sp/yr which is below the CAP level of 4.2 MTCO2eq/sp/yr. The Draft EIR does not rely on the CAP for the GHG cumulative impacts analysis or quantification of reduction measures for the proposed project under the streamlining provisions of CEQA Guidelines section 15183.5(a) &(b)(2) This comment has detailed objections to the content and adoption of the City CAP. Since the Draft EIR does not use the CAP to calculate project emissions or reductions or rely on the CAP for the impacts analysis under CEQA Guidelines section Dublin Crossing Specific Plan Final EIR Page 24 15183.5(a) &(b)(2), these objections to the CAP are not relevant to the proposed project. Since the objections to the methodology, assumptions and reduction measures under the CAP are not relevant to the proposed project analyzed in the Draft EIR, no response is necessary. Furthermore, the CAP and the Negative Declaration for the CAP were adopted by the City in November 2011 and are no longer subject to challenge. Since the specific comments on the CAP do not raise any issue with respect to the contents of the Draft EIR, or any environmental issue regarding the proposed project, no further response is necessary. Response to Comment 9-9 – Energy Conservation The energy analysis was prepared pursuant to Public Resources Code Section 21100(b)(3) and Appendix F of the CEQA Guidelines, which require a description (where relevant) of the “wasteful, inefficient, and unnecessary consumption of energy caused by a project”. The design guidelines in the proposed Specific Plan encourage sustainable design solutions that reduce energy consumption and create simple building designs through the efficient use of space, materials, and resources while maintaining a level of design integrity and authentic architectural style (see pages 3-2 to 3-3, 3-5 to 3-8, 3-32 to 3-33, and 4-12 to 4-14 of the Specific Plan). Title 24, Part 6 of the California Code of Regulations was established to ensure energy efficiency in new developments. Therefore, project compliance with Title 24 would ensure the project’s efficient use of energy. Cases have held that a project’s compliance with Title 24 energy efficiency measures supports a finding that a project will not result in a wasteful, inefficient or unnecessary consumption of energy. Response to Comment 9-10 – Energy Conservation The reduction of emissions from off-road equipment would occur from efficient fuel consumption. The use of cleaner off-road equipment would reduce energy consumption through the reduction of fuel use. According to page 3-7 of the Draft EIR, there would not be any inefficient, wasteful, or unnecessary energy usage in comparison to similar development projects of this nature regarding construction- related fuel consumption. The proposed project would adhere to, and exceed, all Federal, State, and local requirements for energy efficiency, including Title 24 of the California Code of Regulations regarding building energy efficiency standards. Therefore, the proposed project would not result in the inefficient, wasteful, or unnecessary consumption of building energy. See Response to Comment 9-9 on building energy efficiency. Response to Comment 9-11 – Energy Conservation Refer to Response to Comment 9-9, above. The energy analysis was prepared in accordance with Appendix F of the CEQA Guidelines. The energy requirements of the proposed project were calculated with CalEEMod and are provided in Appendix B (Air Quality and Greenhouse Gas Emission Data) of the Draft EIR. Appendix B Dublin Crossing Specific Plan Final EIR Page 25 provides the projected unmitigated/mitigated operational energy consumption emissions for criteria pollutants and GHGs for the Specific Plan using CalEEMod. Energy consumption reduction measures used in the CalEEMod run include the installation of high efficiency lighting, and energy efficient appliances for all land uses proposed in the Specific Plan. The outputs in Appendix B also provide natural gas usage by land use. Please note that that the items listed in Appendix F relating to energy impacts of the project are not mandatory and not required to be addressed in the EIR for every project. Appendix F states that the items should only be discussed “to the extent relevant and applicable to the project” and “in many instances specific items may not apply”. Given the nature of the project as an infill, mixed use residential and commercial project, the project does not present any special or unusual circumstances regarding energy use that would result in wasteful, inefficient or unnecessary energy consumption. Therefore, many of the specific items of information requested in the comment letter are not required to be discussed or disclosed under CEQA. In addition, the project includes measures to reduce energy use as described below. The proposed project includes numerous measures and design features that would reduce energy consumption. The Specific Plan design guidelines promote or require energy efficient windows on exterior walls; rooftop gardens and green roofs; energy effective roof materials to meet or exceed Energy Star requirements for solar reflectance; rooftop solar panels; small-scale wind turbines; energy efficient appliances and mechanical equipment; strategic location of mechanical equipment; energy efficient, low voltage lighting; and energy efficient street lighting, among others. Furthermore, the Specific Plan requires builders to implement energy conservation measures and construction practices per Title 24 of the California Code of Regulations. The applicable Project design features mentioned above were inputted into CalEEMod as measures to reduce energy consumption from the proposed project; please refer to Table 3.6-5 of the Draft EIR. CalEEMod quantified the project’s reductions in energy consumption from the use of high efficiency lighting and energy efficient appliances. These design features would result in a reduction of 2,116 megawatt hours (MWh) per year to 11,066 MWh; a reduction of approximately 16 percent (refer to Appendix B, Air Quality and Greenhouse Gas Emissions Data, of the Draft EIR). The Specific Plan also promotes green building concepts to improve the health, welfare, and public safety by encouraging innovative and sustainable design and construction techniques through the use of green building practices. Green Street Design Project and cumulative level energy consumption and the effect on energy supplies are discussed in Section 3.11 of the Draft EIR. As described in the Draft EIR, the proposed project would not result in the need for new energy infrastructure to support the site. Since the project will not result in wasteful, inefficient or unnecessary consumption of energy, the project will not result in a significant impact. Therefore, there is no legal basis for requiring mitigation measures to increase energy-efficiency under CEQA. Dublin Crossing Specific Plan Final EIR Page 26 Response to Comment 9-12 – Energy Conservation The siting, orientation, and design of the project are measures that reduce energy consumption, including transportation energy. As described in Section 4.6, Streetscape Design, of the Specific Plan, the proposed project would incorporate green streets and sustainable landscape design to minimize the detrimental environmental effects of streets, and further reduce vehicle trips and fossil fuel emissions from the proposed project. The Specific Plan area is located approximately 0.3 miles from the Dublin/Pleasanton BART Station. The proposed mixed-use development is within close proximity to transit and would encourage residents and employees within the Specific Plan area to utilize transit. In addition, the Specific Plan Design Guidelines and proposed circulation improvements also provide innovative design elements/provisions to further reduce vehicle miles traveled (VMT) from the proposed project. Namely, the Specific Plan includes Transit Oriented Development (TOD), mixed-use development, and multi-modal circulation to reduce vehicular use and encourage alternative transportation choices. Plan-level design elements such as a “park once and walk” environment, multi-purpose trails (combined bicycle and pedestrian routes), improved bike lanes and routes, bulbouts, textured crosswalks, pedestrian linkages (to parks, schools, BART, mixed-use, transit stops, residential to commercial areas), and adequate bicycle facilities would reduce the project’s transportation energy consumption. As described in Section 3.11 of the Draft EIR, Pacific Gas and Electric (PG&E) (the electric service provider to the project area) has indicated that sufficient infrastructure exists to support the proposed project. Renewable energy makes up 19.04 percent of PG&E’s energy portfolio.15 Additionally, refer to Response to Comment 9-11. Response to Comment 9-13 – Energy Conservation As described above, the energy analysis was prepared in accordance with Appendix F of the CEQA Guidelines. Appendix F does not require or recommend an analysis of the economic viability of renewable energy strategies and energy efficient tools. Additionally, the analysis in the Draft EIR determined that the project will not result in a wasteful, inefficient or unnecessary consumption of energy. In addition, GHG emissions would be less than significant. Mitigation measures require an essential nexus with project impact and must also be roughly proportional to the impacts. Therefore, mitigation that requires 100 percent or some lesser percentage of renewable energy would not meet the nexus and rough proportionality standards pursuant to CEQA Guidelines Section 15126.4 because the mitigation would not relate to a significant environmental impact of the proposed project. Therefore, they were properly not included in the Draft EIR. It should be noted, however, that 15 California Public Utilities Commission, California Renewables Portfolio Standard (RPS), Accessed September 3, 2013. http://www.cpuc.ca.gov/PUC/energy/Renewables/index.htm Dublin Crossing Specific Plan Final EIR Page 27 the Specific Plan promotes the use of renewable sources of energy (such as solar panels and small-scale wind turbines) in the Plan area (pages 3-6 and 3-7 of the Specific Plan). Response to Comment 9-14 – Energy Conservation Refer to Response to Comment 9-12 and 9-13, above. As discussed in the Draft EIR, the electric service provider to the project area has stated that sufficient infrastructure exists to support the proposed project and that additional generation facilities would not be required. The Draft EIR analyzes the various transportation and energy efficiency design features of the proposed project. The project’s close proximity to the BART station would reduce vehicle trips (i.e., improve transportation energy efficiency), and the project’s various energy efficiency design features, as described in Response to Comment 9-11 above, would reduce electricity and natural gas consumption. Response to Comment 9-15 – Energy Conservation Refer to Response to Comment 9-11, 9-12 and 9-13, above. As discussed in the Draft EIR, the proposed project and design features will not result in a wasteful, inefficient or unnecessary consumption of energy. In addition, GHG emissions would be less than significant. Furthermore, the Specific Plan promotes the design and implementation of rooftop solar panels, and the strategic location of solar panels to effectively capture solar energy. Although rooftop solar may be included in the proposed project, it would not be required per CEQA standards because impacts are less than significant (See Response to Comment 9-13). The discussion in the comment of the costs of various types of energy sources and utility rates are economic issues which are not the proper subject of analysis under CEQA (CEQA Guidelines section 15131 (economic effects shall not be treated as environmental effects under CEQA)). Additionally, most of the information provided in the comment is opinion or speculation which is not supported by substantiated facts. The comment also provides information about various topics including utility rates, rooftop solar, and solar water heating. To the extent the comments are proposing solar power, solar water heating and LED lighting as mitigation measures, the measures could not be required as mitigations per CEQA standards because energy impacts of the project are less than significant (See Response to Comment 9-13). The other components of the comments do not raise any issue with respect to the contents of the Draft EIR, or any environmental issue regarding the proposed project. Because the comment does not specifically reference the Draft EIR or raise any other CEQA issue, no further response is necessary. Dublin Crossing Specific Plan Final EIR Page 28 Response to Comment 9-16 – Air Quality and Transportation Mitigation The Draft EIR identifies certain air quality impacts as significant and unavoidable (Draft EIR, Chapter 3.2). The Draft EIR identifies one significant and unavoidable traffic impact – Impact 3.12-7 – impact to certain freeway onramps. If the City decides to approve the proposed Project with these significant and unavoidable impacts, it will have to make findings that potential mitigation measures or alternatives to reduce these impacts to less than significant are infeasible and adopt a Statement of Overriding Considerations. As part of these findings the City will consider whether proposed mitigation measures would substantially reduce these significant and unavoidable impacts and whether the proposed mitigation measures are feasible. The City will consider the mitigation measures proposed in the comment as part of its findings. However, note that some of the mitigation measures proposed in the comment will not substantially reduce the significant unavoidable impacts of the proposed Project. The Dublin Crossing Specific Plan includes project design features that would reduce potential vehicle trips and transportation (mobile source) emissions. These features include increased density and diversity, improved walkability design, increased destination and transit accessibility, improved pedestrian network, limited parking supply, traffic calming measures, and trip reduction, ride sharing, and employee vanpool programs. It should be noted that the BAAQMD thresholds for criteria pollutants were primarily developed for analyzing individual development projects, not plan level (e.g., specific plan) or multiple development projects. Response to Comment 9-17 – Air Quality and Transportation Mitigation The Draft EIR analyzes bicycle facilities in the vicinity of the proposed project. For example, the proposed project is adjacent to and would be connected with the Iron Horse Regional Trail. The Iron Horse Regional Trail would be reconfigured with the new project frontage and Scarlett Drive, and a secondary trail pathway could be integrated along the southwestern edge of the Central Park, depending on the eventual park design. According to the Bikeways Master Plan, The Iron Horse Trail continues to the Bart station and in the future would go under Interstate 580 and travel along the alignment of Owens Drive. Associated uses along the secondary trail pathway through the park could include a café/concession, bicycle racks, wayfinding signage, lighting, restrooms, and landscaped gardens. The proposed project would also include a pedestrian trail adjacent to Dublin Boulevard that would connect to the existing trail corridor, as well as sidewalks and bicycle paths throughout the project area. The internal circulation of the proposed project would be designed in a grid pattern of different street types. The internal “backbone” street system is designed to establish connections to the existing exterior roadway network as well as internally between residential neighborhoods, parks, open spaces, an optional elementary school site, and business/commercial areas. With sidewalks on all streets, and Dublin Crossing Specific Plan Final EIR Page 29 bikeways on many, the streets will become the framework for the pedestrian and bicycle network as they connect to uses both internally and beyond the project area. Pedestrian and Bicycle Mobility impacts were analyzed in the Section 3.12 of the Draft EIR and were determined to be less than significant. Consistency of the proposed project with the Bikeways Master Plan was evaluated on pages 3-234 to 3- 236 of the Draft EIR (June 2013). Additionally, the Specific Plan would incorporate the following measures from the City’s Bikeways Master Plan:  Develop a bicycle commuter route system that connects residential neighborhoods to employment areas, multi-modal terminals, and schools.  Encourage employers to provide secure bicycle parking, showers and changing rooms for bicycle commuters.  As a condition of project approval, require major development projects with major transportation impacts to construct adjacent bicycle facilities included in the proposed bicycle system.  Install bicycle stencils and bicycle-sensitive loop detectors (or other detector type) on bikeways as part of new signals, signal upgrades, and resurfacing/restriping projects. Response to Comment 9-18 – Air Quality and Transportation Mitigation Refer to Response to Comment 9-16 and 9-17, above. As noted above, the project’s internal circulation would be designed in a grid pattern of different street types, which enhance and enable non-vehicular connectivity. Additionally, the project proposes a mix of commercial and residential uses that would reduce vehicle trips in the area. It should be noted that the Specific Plan identifies the proposed land uses within the project area, but does not specify actual end users. Therefore, while end users such as grocery stores are not specifically identified in the project description, they are also not precluded from the project. As described above, the project’s mix of uses as well as pedestrian and transit friendly design would reduce vehicle trips, thereby reducing emissions. Response to Comment 9-19 – Air Quality and Transportation Mitigation The comment suggests the use of zero-emission electric vehicles, commuter benefits programs, and shared parking in the Specific Plan. Although the project does not specifically mention zero-emission vehicles (ZEVs) or plug-in hybrid electric vehicles (PHEVs), the project design includes internal circulation and amenities that would support these vehicles, such as opportunities for electric vehicles charging stations. The circulation network would accommodate a wide variety of vehicles and alternative modes of transportation. Sidewalks, multi-use trails, bicycle parking, transit stops with shelters, and traffic calming measures all encourage the more environmentally sustainable modes of travel. This approach is often referred to as green streets. Dublin Crossing Specific Plan Final EIR Page 30 The project site would be connected by a network of on- and off-street walking and bike trails and sidewalks, to encourage safe pedestrian and bicycle access and interconnectivity. The proposed project is a mixed use development that is located approximately 0.3 miles from the Dublin/Pleasanton BART station. The mixed-use development within close proximity to transit would encourage residents and employees within the Specific Plan area to utilize transit. As described in the Draft EIR, existing transit service in the project vicinity is provided by the Livermore Amador Valley Transit Authority (LAVTA), Bay Area Rapid Transit (BART), and the Altamont Commuter Express (ACE). The Specific Plan includes various methods to reduce parking including utilizing shared parking. A major direct benefit of transit-oriented development is the reduced need for motor vehicles and vehicle parking. Mixed-use developments have differing peak parking times and may allow for shared parking between various uses. The Specific Plan encourages the reduction in off-street parking, shared parking, and time limits on on-street parking to encourage the use of alternative transportation. As described above, the Specific Plan incorporates several of the features identified in the comment. Additionally, several measures noted in the comment, including commuter benefits programs, transportation management associations, and parking cash-out programs are not specifically identified in the proposed specific plan. However, the benefits of such measures are inherent to mixed-use/transit oriented projects and are encouraged in Specific Plan policy CIR 4.22. Response to Comment 9-20 – Transportation/Plan Bay Area The comment states that the proposed project is inconsistent with Plan Bay Area. Plan Bay Area does not establish development standards or criteria for projects in Dublin or other local jurisdictions. Plan Bay Area contains a Sustainable Communities Strategy (SCS) as part of the Regional Transportation Plan (RTP) that meets greenhouse gas reduction targets adopted by the California Air Resources Board pursuant to SB 375. Local development is not required to be consistent with Plan Bay Area. Cities are not required to revise their land use policies and plans (including General Plan and Specific Plans) to be consistent with Plan Bay Area (Government Code section 65080(b)(2)(J)). Nonetheless, the Crossing Project site is part of a Priority Development Area (PDA) for Dublin identified in the Plan which is called the Transit Center. The Transit Center includes the Dublin Crossing area and other adjacent development areas, such as the Dublin Transit Center adjacent to the Dublin/Pleasanton BART Station. Therefore, the employment, population and vehicle miles traveled projections for the Transit Center PDA in Plan Bay Area include significant development outside the Dublin Crossing project. The final projections for growth in the Plan Bay Area are not completely consistent with the information on projected growth envisioned by the City. However, the Dublin Crossing Project is consistent with the type of development envisioned for PDA areas – mixed use, higher density, infill, transit-oriented development that promotes Dublin Crossing Specific Plan Final EIR Page 31 the use of alternative modes of transportation and results in lower greenhouse gas emissions from development. Response to Comment 9-21 – Transportation/Impacts to Bicycles The impacts to transit, bicycle and pedestrian modes of transportation are evaluated in the EIR. Pages 3-234 to 3-236 of the Draft EIR (June 2013) provide an analysis of the project impacts on bicycle and pedestrian modes. Furthermore, on page 3-272 of the Draft EIR, Mitigation Measure 3.12-10 provides a specific mitigation to address bicycle and pedestrian circulation impacts. Consistency of the proposed project with the Bikeways Master Plan was evaluated on page 3-236 of the Draft EIR. Additionally, the Specific Plan would incorporate the following measures from the City’s Bikeways Master Plan:  Develop a bicycle commuter route system that connects residential neighborhoods to employment areas, multi-modal terminals, and schools.  Encourage employers to provide secure bicycle parking, showers and changing rooms for bicycle commuters.  As a condition of project approval, require major development projects with major transportation impacts to construct adjacent bicycle facilities included in the proposed bicycle system.  Install bicycle stencils and bicycle-sensitive loop detectors (or other detector type) on bikeways as part of new signals, signal upgrades, and resurfacing/restriping projects. The proposed project is adjacent to and would be connected with the Iron Horse Regional Trail. The Iron Horse Regional Trail would be reconfigured with the new project frontage and Scarlett Drive, and a secondary trail pathway could be integrated along the southwestern edge of the Central Park, depending on the eventual park design. According to the Bikeways Master Plan, The Iron Horse Trail continues to the Bart station and in the future would go under Interstate 580 and travel along the alignment of Owens Drive. Response to Comment 9-22 – Transportation/Impacts to Bicycles The Iron Horse Regional Trail will continue to operate as a Class 1 facility and the development of the project will not change the function or the general location of the trail. A grade-separated crossing is the preferred mitigation measure to ensure that bicycle and pedestrian mobility across Dublin Boulevard is maintained. To this end, the City is pursuing multiple sources of funding to conduct a feasibility analysis of the Iron Horse Trail connectivity from Dougherty Road to the (East) Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in this location could significantly enhance bike and pedestrian access to and from the project area and beyond. To support this project, the developer of the Dublin Crossing project is contributing $50,000 towards the feasibility analysis, and the City is seeking additional funding from the Alameda County Transportation Dublin Crossing Specific Plan Final EIR Page 32 Commission (ACTC) Sustainable Communities Technical Assistance Program. It is the City’s full intent to pursue a grade-separated crossing at this location, although the City is also including the alternative mitigation measure of removing a portion of the crosswalk across Dublin Boulevard in the EIR. Under the alternative mitigation, bicyclists will continue to be able to cross Dublin Boulevard. Response to Comment 9-23 – Transportation/New road construction Chapter 4 of the Dublin Crossing Specific Plan describes the pedestrian and bicycle circulation network in the project area, including sections on pedestrian circulation (Section 4.2.1), bicycle circulation (Section 4.2.2), and public transit (Section 4.2.3). These provide alternative means of transportation to automobile use. Chapter 4 also contains a multitude of figures and exhibits that illustrate roadway cross sections and generous provisions for sidewalks and dedicated bike lanes (both Class 1 and Class 2) throughout the project area. Section 4.3.5 describes the intersections that connect to the street network outside of the project area and notes that these connections shall be enhanced to support the safe crossing of existing perimeter streets. So, overall, the Project development does not focus on creating additional roadway facilities and capacity. The comments on the economic costs of roadway development and automobile use are not required to be analyzed under CEQA because they are not environmental impacts. (CEQA Guidelines section 15131 (economic effects shall not be treated as environmental effects under CEQA)). 1 Wiseman, Bill From:AlamedaTim@aol.com Sent:Thursday, June 27, 2013 10:37 PM To:Kristi Bascom Subject:Dublin Crossing Comment Kristi, I and my family own a condo in the Elan project facing DeMarcus Blvd. I am thrilled that mixed use development will take place across Dublin boulevard from us. If done well, it can only benefit us, both economically (our home value) and for our convenience (with nearby retail). My one big concern is traffic mitigation on DeMarcus with so many residential units looking to BART as a primary transit provider. It appears that DeMarcus cannot be widened (with residential projects on both sides) and I'm not sure how it can take more traffic - we're already a little anxious to see what impact the current construction of added residential units on the old BART parking lot will have on DeMarcus. We enjoy our proximity to BART, one of the main reasons we bought there, but don't want it to become a drawback that would drive us away. I hope this will be considered, and look forward to hearing details on this aspect of the plan. Sincerely, William M. (Tim) Neilson Dublin Crossing Specific Plan Final EIR Page 33 Response to Comment Letter (via email) #10 from Mr. William Neilson, dated June 27, 2013 Response to Comment 10-1 – Traffic Mitigation on DeMarcus Boulevard The transportation and circulation analysis prepared for the EIR analyzed 37 intersections, including Demarcus Boulevard and Dublin Boulevard (study intersection No. 14). The existing Level of Service at this intersection in the AM peak hour is LOS C and in the PM peak hour is LOS B (see EIR Table 3.12-5). With the Dublin Crossing project and full buildout of the General Plan (“2035 Cumulative Plus Project”), the Levels of Service will measure LOS B in the AM peak hour and LOS C in the PM Peak hour (see EIR Table 3.12-10). The traffic impacts at this intersection with the proposed project are less than significant. 1 Wiseman, Bill From:jasnew99@yahoo.com Sent:Wednesday, July 10, 2013 5:52 PM To:Kristi Bascom Subject:Camp Parks Exchange / Dublin Crossing comments Hi, I strongly disagree with having more dense housing build in Dublin. I have lived in Dublin for a long time and have seen congestion and other issues including crime come up. I think dense housing is great for builders but just those is not good for the city. Our schools are now congested along with the other infrastructure like hospitals, roads, parks. Dublin lacks office spaces. As a small business owner there is hardly decent choices for office space in Dublin. Compare this with San Ramon and Pleasanton the city needs to think long term rather than short term gain. regards Jasmeet Dublin Crossing Specific Plan Final EIR Page 34 Response to Comment Letter (via email) #11 from Jasmeet, dated July 10, 2013 Response to Comment 11-1 – Proposed Project Land Uses Comment noted. Since the comment relates to the merits of the project and not environmental impacts, no further response is necessary. 1 Wiseman, Bill From:Thomas McKinney <tfmckinney@gmail.com> Sent:Wednesday, July 24, 2013 5:18 PM To:Kristi Bascom Subject:Comments on the DEIR for Dublin Crossing Project By e-mail and US mail Ms Bascom: I am a retired geologist living in Dublin and provide the following comments on Appendix D - Geology and Soils. I have additional concerns about Hazardous Material raised by the Phase 1 site assessment but have not completed a review of that section. APPENDIX D - Preliminary Geotechnical Analysis - Geological Hazards Page 7 - Potential For Surface Rupture This paragraph is inappropriate and misleading, and does not adequately summarize the findings of the Fault to Ground-rupture investigation discussed at length later in Appendix D. It should be updated to better reflect these studies and related comments on the DEIR. Page 8 - Liquefaction - bottom paragraph indicates that the thickness of potentially liquefiable sandy layers used in the analysis of liquefaction was 1/2 to 2 feet. However, on p.5 it is indicated that the sandy soil layers were generally encountered below depths of 15 ft, with thicknesses ranging to 6 feet, What was the thickness of sandy layers that was used in the analysis and did it include layers up to 6 ft and if not why not? Fault To Ground-Rupture Investigation - Page 3 - Faulting Reference is made to Plate 5 - Fault Activity Map with no discussion in the text or a reference in the text to its source. Full disclosure would indicate that the reference is CGS (2010) and should include a discussion of the fact that Plate 5 shows that site is in the southern part of the Pleasanton Fault Zone and is mapped at the site as - "Holocene fault displacement (during the past 11,700 years) without historical record" (orange color). The site is in the southern portion of this zone and is shown as a solid line while areas of the fault to the north of the site are shown as the same classification (orange) but as a dashed line. The southern part of the Pleasanton Fault Zone south of Highway 580 is designated as "Quaternary Fault (age undifferentiated)" (Purple). Page 3 - 2nd paragraph - last sentence. "The Pleasanton Fault Zone at the site is depicted by short dashed lines on the Pleasanton Fault Zone Map, which indicates that the CGS considers this trace to be an inferred location." This is true but again full disclosure would require that it should be pointed out that study maps of the site area (CGS FER 109 - 1/30/81 and Division of Mines and Geology Open File Report - 81-9 (1981) which apparently formed the basis for CGS FER 109 10/31/81, show both solid and dashed lines for the fault traces within the site boundary. The map legend indicates " Solid lines indicate well defined features; dashed lines indicate less- well defined features." All of the trenches examined in this site investigation were located in the southern part of the site where CGS indicates that the races are less-well defined and did not include any in the northern portion where CGS indicates that they are well-defined. TRENCH STRATIGRAPHY 2 Page 10 first paragraph indicates that Log Unit D, the inferred base of the modern soil profile (Holocene) which occurs in trenches across the site is an uninterrupted layer without distortion. This does not appear to be the case. The northeastern portion of T-1 at about 0 + 70 ft Log Unit D as well as six other Log Units is interrupted along a straight steep line and is indicated on the trench profile with question marks along its length. Page 10 - last Paragraph indicates that this feature in T-1 and other segments of T-2 and T-3 trenches are channel features which have channel deposits which have channel deposits which do not extend up into the modern soil (Log Units A thru D) and are inferred to be older than about 3,000 years. Again this is not true for for the feature in T-1 where Unit D is interrupted. In addition this questioned feature is distinctly different from the other channel features and deposits elsewhere in the trenches (T-2 and T-3). The feature in T-1 is much steeper and deeper that the other inferred channels. The T-1 feature is about 14 ft deep while the inferred channels in T-2 and T-3 are 4 to 5 ft deep, comparable to the current drainage culvert. In addition, the log comment on T-! "Failure Slicks" is not addressed in the text and lends additional support for a structural and not a channel origin for this feature in T-1. CONCLUSION Thus, the siting of trenches away from the northern portion of the site where the fault traces are well defined, the interruption of portion of the modern soil profile, Log Unit D in T-1, the steep and deeper nature of the questioned feature in T-1 compared to other areas which show channel deposits and the notation of "Failure Slicks" in the T-1 log, do not support the conclusion that ".. it is unlikely that surface rupture due to fault displacement will occur at the site." Thomas F. McKinney, PhD Dublin Crossing Specific Plan Final EIR Page 35 Response to Comment Letter (via email) #12 from Mr. Thomas McKinney, dated July 24, 2013 Note: All comments are in reference to Appendix D – Preliminary Geotechnical Analysis Response to Comment 12-1 – Potential For Surface Rupture The paragraph the commenter refers to is in Appendix D, the Preliminary Geotechnical Investigation, Dublin Crossing Project at Camp Parks, Dublin California that was completed in March 2012. Additional analysis related to potential fault rupture (Fault Ground-Rupture Investigation Proposed Dublin Crossing Mixed Use Development, Camp Parks Reserve Forces Training Area, Dublin CA) was later completed in March 2013, which is also included in Appendix D. The paragraph in the March 2012 document is superceded by the 2013 analysis. The Draft EIR reflects the conclusions of the more detailed fault rupture study that was completed in March 2013. Response to Comment 12-2 – Liquefaction The only dimensions in the bottom paragraph on page 8 of the Preliminary Geotechnical Investigation are to half an inch to two inches of differential settlement and there are no comments on the thickness of potentially liquefiable sand layers. Pages 8-9 of the Preliminary Geotechnical Investigation states: “Settlement calculations due to liquefaction indicate that the potential for liquefaction-induced settlement can range from half an inch to two inches with differential settlement on the order of 1 inch.” For liquefaction-induced settlement calculations, the engineers used sandy layers with a thickness up to six feet, which was indicative of the site-soil conditions as presented by the boring logs. Response to Comment 12-3 – Plate 5 – Fault Activity Map Source of the Fault Activity Map is shown on Plate 5. The map was included in the report to show the most recently published and generalized fault setting with respect to the San Francisco Bay Area. As stated in the report immediately preceding the citing of Plate 5 – “The project site and the San Francisco Bay Area are located in an area characterized by moderate to high seismic activity”. The detail suggested by the commenter is presented on the Fault Activity Map and is not needed in the report text because it would have no impact on the interpretation or findings presented in the report. Response to Comment 12-4 – Pleasanton Fault Zone The California Geologic Survey (CGS) Revised Official Special Studies Zones (SSZ) Map of the Dublin quadrangle (effective January 1, 1982) was published after both CGS FER 109 - 1/30/81 and Division of Mines and Geology Open File Report - 81-9 (1981). The 1982 CGS SSZ map provides CGS’ most up-to-date and official best estimate of where faults may be located. The map shows all three fault traces Dublin Crossing Specific Plan Final EIR Page 36 through the entire SSZ as short dashes (inferred) and shows the two longer traces as queried (additional uncertainty). The authors of the Preliminary Geotechnical Investigation conclude, and the EIR supports the conclusion, that the locations of the exploratory trenches with respect to project-site coverage are adequate, reasonable, and comply with the intent of the Alquist-Priolo Act. Response to Comment 12-5 – Trench Stratigraphy The “straight steep line” noted by the commenter is the west margin of “clayey sand/sandy clay (CL), light to medium brown, wet, loose to medium dense, channel deposit”. The contact is queried to indicate an indistinct boundary between the channel deposit and soil stratigraphic layers. No sharp contact, slickensides, gouge, distorted beds adjacent to the contact, or other features that would be associated with fault offset are present along the contact. The contact conforms to an erosional feature and not a structural feature. Response to Comment 12-6 – T-1, T-2, and T-3 Trench Features Because of the presence of caving and an erosion channel at the location of Trench T-1, Trench T-6 was later excavated and logged between Trenches T-1 and T-2. Trench T-6 was located to fill in information that was obscured in Trench T-1 and provided an overlapping profile of the soil layers observed in Trenches T-1 and T-2. The overlapping configuration of Trenches T-1, -2, and -3 shows that Log Unit D, and other soil layers, are continuous and uninterrupted across that part of the project site. The depth of the channel deposit logged in Trench T-1 is based on exposure in the trench and would be expected to be deeper or shallower at other locations. Channel deposits can be of differing depths depending on relief of base level, energy and volume of the water flow, localized erodability of the soil, and other factors. Evidence observed in Trench T-1 including continuity of soil layers across the project site indicates that the feature east of about Station 0+70 is an erosional channel cut into the soil layers. The “Failure Slicks” notation on trench log T-1 is included in the shaded area of the log representing caving and refers to slickensides in the clay soil that failed during caving of the trench. The most recent and official SSZ map shows the inferred fault traces as similarly uncertain across the project site and throughout the SSZ. The possible fault traces in northern portion of the site are no more certain than in the southern portion. The location of the BSA trenches adequately covers the project site. The soil profile in Trench T-1 is locally eroded by a clayey sand / sandy clay channel deposit that has an indistinct (queried) contact with adjoining older soil layers. The contact is without features that would be associated with fault offset. An additional Trench (T-6) was excavated and logged between and overlapping T-1 and T-2 that Dublin Crossing Specific Plan Final EIR Page 37 showed that Log Unit D is continuous and uninterrupted by faulting. The steep and deep nature of the channel deposit appears to be a consequence of several local factors causing erosion, none of which are associated with fault displacement. Based on geologic interpretation of the six exploratory trenches and other evidence presented in the March 2013 Fault Ground-Rupture Investigation report, it was concluded that an active trace of the inferred Pleasanton fault does not cross the Dublin Crossing project site. The conclusion in the report that "it is unlikely that surface rupture due to fault displacement will occur at the site" is an apt and appropriate interpretation of the observed evidence and complies with the intent of the Alquist-Priolo Act. The report and findings have been peer reviewed and approved by a consulting geologist for the City of Dublin as required by the State of California Alquist-Priolo Earthquake Fault Zoning Act of 1972 and represents accurate information and analysis for the purposes of this EIR. 1 Wiseman, Bill From:Thomas McKinney <tfmckinney@gmail.com> Sent:Monday, July 29, 2013 3:10 PM To:Kristi Bascom Subject:Comments on Appendix E on the DEIR for Dublin Crossing Project By E-mail and US Mail Ms Bascom: Appendix E - Impact 3.7-4 Results in the Disturbance of Contaminated Soil and Groundwater Page 3-135 Indicates based on the Phase I ESA that 3 sites are identified which have potentially significant impact but indicates that the US Army has committed to remediating them to regulatory approval. There is only one paragraph which addresses groundwater contamination and indicates that an upgradient property has affected the underlying groundwater with petroleum hydrocarbons and concludes without providing any information that based on the distance of this site, it is unlikely that the property could have affected the project area. Is this property mentioned the Federal Correction Institute located a few blocks away on 8th Street? This dismissal of potential affects at the project area cannot be accepted without location and time of occurrence information, and a groundwater analysis evaluating contaminant and groundwater travel times and distances. Provide these further details. What are the plans, if any, for a Phase II ESA and when would it occur, it's focus and its relationship to the EIR process? Trench Contamination - There is no mention of the petroleum odor contamination observed in Fault Rupture Study Trench T-3 which was found at and below the water table. What soil and groundwater investigations, if any, have been conducted for this contamination. Provide their results. Secondary Impacts - The proposed action includes the removal of Army facilities and activities from the project area. What, if any, of these activities will be relocated and/or developed in adjacent areas and what will be their short- and long-term impacts and the cumulative impacts from these relocation actions and the project area impacts? Thanks for your consideration. Thomas F. McKinney, PhD Dublin Crossing Specific Plan Final EIR Page 38 Response to Comment Letter (via email) #13 from Mr. Thomas McKinney, dated July 29, 2013 Response to Comment 13-1 – Potential Effects from the Federal Correction Institute The Federal Correction Institute is located at 5701 8th Street approximately 0.298 miles northwest of and up-gradient of the project area. On April 25, 2008, a 3,000-gallon diesel aboveground storage tank overflowed at the property, releasing approximately 100 gallons of diesel. Excavation of the diesel-impacted soil and asphalt within the spilled area was conducted from April through May 2008. A soil and groundwater investigation was performed in September 2008 to initially characterize the impact of the spill. Results of the investigation indicated elevated concentrations of diesel in the soil samples and detectable concentrations of diesel in the groundwater samples. A supplementary investigation was conducted in August and September 2009. As part of the investigation, three monitoring wells were installed. Soil and groundwater analytical data from the investigation indicated elevated diesel concentrations within the spilled area. A closure report prepared by the U.S. Department of Justice Federal Bureau of Prisons was submitted to Alameda County Environmental Health for their review in October 2010. The report concluded that the impacted area was limited to the immediate vicinity of the spilled area and that the residual contaminants present in the soil and groundwater should naturally attenuate over time. Based on the localized impacted area and distance from the project area (approximately one-quarter mile or greater), it is unlikely that the property could have impacted the project area. Response to Comment 13-2 – Preparation of a Phase II ESA There are currently no plans for a Phase II ESA. As described on page 3-136, the U.S. Army and NASA are responsible for environmental remediation of existing hazardous materials within the project area and have agreed to remediate the project area to state and federal requirements. Contamination that remains after the U.S. Army and NASA transfer the property to the project applicant and/or that needs to be remediated to a higher standard (e.g. residential) will either be remediated prior to and during site grading and demolition activities associated with future development within the project area. Response to Comment 13-3 – Trench Contamination Remedial activities to remove the impacted material that was observed in Trench T-3 is being conducted by the U.S. Army in conjunction with the local regulatory agencies. The remedial activities are still ongoing. Response to Comment 13-4 – Secondary Impacts from Relocation of Existing Army Facilities Dublin Crossing Specific Plan Final EIR Page 39 The existing Army facilities located within the project area would be demolished and new facilities constructed within the remaining portion of Camp Parks outside the proposed project area. An analysis of impacts associated with redevelopment of Camp Parks was analyzed previously in the U.S. Army Draft and Final EIR on Master Planned Redevelopment at Camp Parks (2009). Comments on Draft EIR from SunCal Page 1 July 22, 2013 ES-2 proposed project includes up to 1,995 residential units (not including secondary units); Need to delete reference to secondary units being above the cap ES-10 MM 3.2-5: Locate Sensitive Receptors Away from Existing Toxic Air Contaminants and Implement HVAC systems for Sensitive Receptors in the vicinity of BAAQMD permitted Toxic Air Contaminant sources. Prior to building permit issuance, the project applicant shall demonstrate to the City of Dublin Community Development Director that the following mitigation measures will be implemented in order to reduce the potential impact from TAC exposure due to the potential siting of residential or other sensitive receptor development within 1,000 feet of a BAAQMD identified stationary TAC source: This gets into more detail later, but it is very unclear if this is claiming that there are any instances of land use controls which need to exist on the project site due to any sort of TAC. ES-12 All new commercial development projects that have the potential to emit TACs shall be located 1,000 feet away from existing and proposed development used by sensitive receptors, unless a project-specific evaluation of human health risks is conducted and the results of the evaluation determine that no significant impact would occur. Same as above ES-13 prepare a wetland mitigation plan that ensures no-net-loss of wetland and waters habitat and is approved by the City and applicable resource agencies. Approval by City? Page ES-15 MM 3.3-2a ….If no special-status plants are located during the surveys, no further mitigation measures would be required. If any federal or state plant ESA listed species are found during the rare plant surveys, the project applicant shall consult with the CDFW and USFWS to obtain incidental take permits under Section 2081 of the CESA and either Section 7 or 10 of the FESA. Request clarity that this mitigation measure applies to plants listed under the State or Federal ESA, and that MM 3.3-2b applies to other special status plant species Page ES-21 The project applicant shall could preserve additional upland habitat within a USFWS approved conservation area as determined in consultation with the USFWS. The Project proponent shall coordinate or consult” This measure would be determined in consultation with the USFWS, if required. Impact 3.3-5: Protocol level surveys for vernal pool invertebrates were conducted throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as during the Comments on Draft EIR from SunCal Page 2 July 22, 2013 summer of 2012 (dry season) and 2013 wet season by Cardno Entrix. No vernal pool fairy shrimp, vernal pool tadpole shrimp or longhorn fairy shrimp were found during these surveys. California linderiella was found during the 2002-2003 surveys, but not within the project area. New surveys are currently being conducted by Cardno ENTRIX. Since the new surveys have not been completed at this time, the presence of this species within the project area is assumed in the analysis of project impacts. They list the surveys and say that there are no shrimp, but then they contradict themselves and say that new surveys are being conducted and that presence is assumed. I am fine with the mitigation measures, as we don’t have concurrence on the survey results from the USFWS yet, but it needs to be clear that the 2012-2013 surveys were conducted as MM 3.3-5, not in addition to it. MM 3.3-5: Consult with the USFWS and Reduce Impacts on Vernal Pool Invertebrates and Their Habitat. The project applicant shall prepare a habitat assessment for the vernal pool invertebrates. If vernal pool invertebrates are found within the project area during the habitat assessment, the project applicant shall comply with the following steps to ensure protection of vernal pool invertebrates and their habitat and that impacts are reduced to a less than significant level. a. The project applicant shall retain a qualified biologist to conduct habitat assessments for protected vernal pool invertebrates and based on the results of the habitat assessments, determine in consultation with the USFWS if protocol level vernal pool invertebrate surveys will be required within the project area. b. If suitable habitat is present, the project applicant, in consultation with the USFWS and CDFW, shall either (1) conduct a protocol-level survey for federally listed vernal pool crustaceans, which will identify other protected vernal pool invertebrates (curvefooted Hygrotus beetle and San Francisco fork-tailed damselfly), or (2) assume presence of federally-listed vernal pool crustaceans and curve footed Hygrotus beetle and San Francisco fork-tailed damselfly in areas of suitable habitat. Surveys shall be conducted by qualified biologists in accordance with the most recent USFWS guidelines or protocols to determine the time of year and survey methodology (survey timing for these species is dependent on yearly rainfall patterns and seasonal occurrences, and is determined on a case-by-case basis). The USFWS protocol level surveys shall be conducted as part of the Section 404 permit process within 2-years of the application. If surveys reveal no occurrences of federally listed vernal pool crustaceans or other protected vernal pool invertebrates, no further mitigation would be required. c. If surveys determine that one or more special-status vernal pool invertebrate species occurs within the project area, or if the project applicant, in consultation with the USFWS and/or CDFW, assumes presence of federally-listed vernal pool invertebrates in all affected habitats, the project applicant shall provide information to the USACE to support Section 7 consultation with the USFWS and the project applicant shall ensure no net loss of habitat shall be achieved through avoidance, preservation, creation and/or purchase of credits as a part of the Section 7 Consultation process. The selected measures may be part of the permitting process. Comments on Draft EIR from SunCal Page 3 July 22, 2013 USFWS and CDFG have no published protocol for curvefooted Hygrotus beetle and San Francisco fork-tailed damselfly. It is likely best to exclude all reference to the 2012-2013 Branchiopod surveys to avoid confusion. By including referencing to them, but omitting the negative findings, it may obligate the project to additional surveys that would not be necessary otherwise. Pg. ES -37 MM 3.8-4b .Discuss with City the intent of the proposed rerouting of the Basin #2 outfall . ES-38 MM 3.8-4b: Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the grading permit associated with the construction of the proposed community park, the project applicant shall submit to the City a revised stormwater drainage plan that realigns the stormwater outflow associated with the proposed North Basin #2 from the 1.7 acre Chabot Creek riparian channel (as is currently proposed) to a separate underground pipe that connects directly with the existing box culvert located at proposed Scarlett Court Extension and Dublin Boulevard, and thereby avoids stormwater discharge into the 1.7 acre Chabot Creek riparian channel. This is a new proposal. It is unclear why it is necessary. ES-48 IHT. I_n_ _t_h_e_ _e_v_e_n_t_ _t_h_a_t_ _t_h_e_ _g_r_a_d_e_ _s_e_p_a_r_a_t_e_d_ _c_r_o_s_s_i_n_g_ _p_r_o_j_e_c_t_ _c_a_n_n_o_t_ _b_e_ _c_o_n_s_t_r_u_c_t_e_d_ _b_y_ _y_e_a_r_ _2_0_3_5_,_ _a_n_ _a_l_t_e_r_n_a_t_i_v_e_ _m_i_t_i_g_a_t_i_o_n_ _w_o_u_l_d_ _b_e_ _t_o_ _e_l_i_m_i_n_a_t_e_ _t_h_e_ _c_r_o_s_s_w_a_l_k_ _o_n_ _t_h_e_ _e_a_s_t_ _l_e_g_ _o_f_ _t_h_e_ _S_c_a_r_l_e_t_t_ _D_r_i_v_e_ _a_n_d_ _D_u_b_l_i_n_ _B_o_u_l_e_v_a_r_d_ _i_n_t_e_r_s_e_c_t_i_o_n_._ _T_h_i_s_ _w_o_u_l_d_ _r_e_q_u_i_r_e_ _p_e_d_e_s_t_r_i_a_n_s_ _a_n_d_ _b_i_k_e_s_ _f_r_o_m_ _t_h_e_ _I_r_o_n_ _H_o_r_s_e_ _T_r_a_i_l_ _t_o_ _c_r_o_s_s_ _t_h_r_e_e_ _c_r_o_s_s_w_a_l_k_s_ _r_a_t_h_e_r_ _t_h_a_n_ _o_n_e_._ _B_e_c_a_u_s_e_ _o_f_ _t_h_e_ _e_f_f_e_c_t_s_ _o_f_ _t_h_e_ _a_l_t_e_r_n_a_t_i_v_e_ _m_i_t_i_g_a_t_i_o_n_ _o_n_ _p_e_d_e_s_t_r_i_a_n_ _a_n_d_ _b_i_k_e_ _m_o_b_i_l_i_t_y_,_ _t_h_e_ _g_r_a_d_e_ _s_e_p_a_r_a_t_e_d_ _c_r_o_s_s_i_n_g_ _i_s_ _t_h_e_ _C_i_t_y_’s_ _p_r_e_f_e_r_r_e_d_ _m_i_t_i_g_a_t_i_o_n_ _a_t_ _t_h_i_s_ _l_o_c_a_t_i_o_n_._ _ Pragmatically this seems to be a nonfunctional solution. Should we reference changing the timing of pedestrian triggered light sequencing? ES-51 The project impacts to freeway ramps could be mitigated by changing the ramp metering rates so that more vehicles could access the freeway. However, the freeway ramps are operated by Caltrans, which sets metering rates based on overall operations in the freeway corridor. In the future, major improvements are planned for I-580 in the project vicinity, including the addition of High Occupancy Vehicle and auxiliary lanes. In addition, as the Cities surrounding the I-580 corridor continue to build out and additional parallel east/west connectors such as the Stoneridge Drive and Dublin Boulevard extensions are completed, it is likely that the ramp meter rates would change over time to accommodate the demand on both the freeway ramps and freeway segments. If “major improvements are planned” then should we have language that if these improvements were to occur that our significant unavoidable impact could be mitigated? If impact is same in no project scenario is it still a significant impact of project? Comments on Draft EIR from SunCal Page 4 July 22, 2013 Pg. 2-7 2.6 Proposed Land Use & Development Plan - Should reference Figure 2-7, not 2-9. Pg. 2-7 Table 2-1 - Header should read "net" acreage instead of "total" acreage Pg. 2-10 Central Park and Iron House Trail Realignment - 3rd paragraph should read "two underground onsite storm drainage detention basins…" 2-13 T_h_e_ _C_a_m_p_ _P_a_r_k_’s_ _e_n_t_i_r_e_ _1_,_8_0_0_+_ _a_c_r_e_ _w_a_t_e_r_s_h_e_d_ _d_r_a_i_n_s_ _t_h_r_o_u_g_h_ _t_h_e_ _p_r_o_j_e_c_t_ _a_r_e_a_._ _ Pg. 2-14 Storm Drain Infrastructure - Last paragraph should read "two underground onsite storm drainage detention basins…" 2-15 Former Building 109/Parks Reserve Forces Training Area (PRFTA) 2 - Former Building 109/PRFTA 2 located at the southwestern portion of the project area containing concentrations of dioxin and lead within the surficial soil above the acceptable risk-based screening levels for closure. The U.S. Army is awaiting confirmation from the regulatory agencies regarding the remediation of this site (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013). This site is fully remediated. The only remaining activity is monitoring wells. Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of the project area and requires land use controls by the CRWQCB to obtain an NFA status. The CRWQCB issued a Pre-NFA determination on May 28, 2008. This determination acknowledged that groundwater cleanup objectives have been met. However, a deed restriction (land use control) is required to achieve a full NFA designation due to the presence of soil which contains diesel concentrations greater than acceptable levels. The Department of Toxic Substances Control (DTSC) concurred with these findings in January 20, 2012. Page 2-15 (twice), Page 3-128 (twice), Page 3-135 (twice), Page 3-145 Reference to Central Valley Flood Board or CRWQCB is inapplicable to this project. All instances should reference the San Francisco RWQCB, which had jurisdiction in this area. Comments on Draft EIR from SunCal Page 5 July 22, 2013 Pg. 2-17 Table 2-2 Phasing Plan – Footnote #1 missing. 3-11 Building heights associated with the proposed project would range from a maximum height of 40 feet and three stories for the DC Lower Density Residential (DC LDR) and DC Medium Density (DC MDR) land use districts to 75 feet and six stories for the General Commercial/DC Medium Density Residential (GC/DC MDR) and General Commercial/DC High Density Residential (GC/DC HDR) land use districts. We need to identify methodology of measuring. What start and end point? 3-34 under total emissions: Due to the scale of the proposed project, which would generate 19,641 new trips per day, emissions would exceed the BAAQMD thresholds This total trip number is different than the one in traffic section (22,047). 3-36 There are no mobile TAC sources located within 1,000 feet of the project area as Interstates 580 and 680 are located 1,500 feet to the south and 5,000 feet to the west of the project area, respectively. However, there are several stationary TAC and PM2.5 sources located within 1,000 feet of the project area (BAAQMD 2013). Including several diesel generators associated with the commercial area approximately 300 feet east of the project area, and three diesel engines located within Camp Parks, adjacent to the northern site boundary. Based on the screening level data provided by the BAAQMD, these stationary TAC sources have the potential to exceed the BAAQMD cancer risk thresholds of 10 in one million (BAAQMD 2012). Again this is unclear if there are controls being suggested? Page 3-45 Cardno Entrix prepared a biological resource technical report on behalf of the project applicant in May June 2013, which updates previous biological technical studies that were prepared by the U.S. Army for the Final Environmental Impact Statement on Master Planned Redevelopment at Camp Parks (U.S. Army 2009). This technical report was peer reviewed by RBF Consulting for technical accuracy and is included as Appendix C. May should be June In addition to approximately 77 acres of developed and semi-developed land within the project area, wetlands and non-native grasslands are also located within the project area. The acreage of these vegetation communities is shown below in Table 3.3-1: Habitats and Vegetation Communities within the Project Area and on Figure 3.3-1: Existing Biological Habitats. The table and figure do not represent the Project Area as defined in the document. No data/references for the Alameda County Surplus Property (ACSP). Overall, section Comments on Draft EIR from SunCal Page 6 July 22, 2013 provides insufficient data to reach conclusion for this area, as the biological resources technical report Study Area is not synonymous with the Project Area. Table 3.3-1. Habitats and Vegetation Communities within the Project Area Appears to include acreages for other waters (as included in the Cardno biological resources technical report Study Area) located outside the Project Area as defined in the DEIR. Page 3-47 Wetlands and Drainage Ditches This section only addressed the drainage ditches (linear features) within the project that qualify as wetlands per the USACE protocol, that is, wetland drainage ditches. Other wetlands are included on page 3-48. Other waters of the U.S. include Chabot Canal (Canal 01), and an unnamed canal (Canal 02). A portion of Canal 02 addressed in the Cardno biological resources technical report falls outside the Project Area as defined in the DEIR. Page 3-50 According to the CNDDB, USFWS, and CNPS queries, a total of 68 special-status species and three rare natural communities and USFWS-designated critical habitat for California tiger salamander (Ambystoma californiense), California red-legged frog (Rana draytonii), Alameda whipsnake (Masticophis lateralis euryxanthus), and vernal pool fairy shrimp (Branchinecta lynchi) are known to occur in the project area within the Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical quadrangle. Produce reference for statement regarding SSP occurrence in project area (as defined in the DEIR): According to biological resources technical report these species are known to occur within the Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical quadrangles, not the Study Area or Project Area. Cardno Entrix performed queries of the California Department of Fish and Game, Natural Diversity Database (CNDDB), California Native Plant Society (CNPS) Online Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPSEI) and the United States Fish and Wildlife (USFWS) Online Species List of Federal Endangered and Threatened Species to identify known biological resources within the greater project vicinity project area. This is incorrect; the Cardno report identified known biological resources within the overall project vicinity, extending greater than 5 miles from the Project Area as defined in the DEIR. Page 3-51 Previous Biological Surveys Inconsistent with mitigation measures and text; update to include 2012-2013 Branchiopods surveys or remove references to 2012-2013 in other locations in the DEIR. Surveys should consistently be applied to analysis, and referenced as such throughout the document. One option is to say that updated surveys are in progress, as results have not yet been accepted by the USFWS Comments on Draft EIR from SunCal Page 7 July 22, 2013 Life histories of special-status plant and animal species identified by the CNDDB, USFWS, and the California Native Plant Society (CNPS) lists that have a moderate or higher likelihood of occurring in the project area are described below: Inconsistent with species included below, many are listed as having a low likelihood of occurrence: conservancy fairy shrimp, Longhorn fairy shrimp, Vernal pool fairy shrimp, curved-foot hygrotus diving beetle, San Francisco forktail damselfly, California linderiella, Western pond turtle, California tiger salamander, California red-legged frog, tricolored blackbird, ferruginous hawk, Swainson’s hawk, Prairie falcon, San Joaquin kit fox, Palmate-bracted bird’s-beak, and Northern California black walnut. There are no known occurrences in Alameda County. Although not a target species, this species was not detected in focused surveys between 2002 and 2003 and during wet and dry surveys conducted by Cardno Entrix in 2012 and 2013. Same as above comment regarding 2012-2013 Branchiopod surveys. If including survey results they should be consistently incorporated into text and Mitigation Measures. Page 3-53 Separate paragraph for Western pond turtle (FYI: this was a typo in the Cardno report as well). Page 3-54 There are several known CNDDB occurrences for this species within two miles of the project area. The nearest occurrences are 1.4 miles to the north and 1.2 miles to the northeast of the project area. USFWS protocol requires that occurrences be evaluated within one mile of a proposed project. The first occurrence is located within Camp Parks training area. The second during the March 2012 field survey occurrence is located within Tassajara Creek Clarify that no occurrences are located in the project area. No CRLF were observed during the March 2012 field survey. Page 3-55 CRLF were not observed during any of these surveys. No suitable aquatic habitat was observed within the project area during the March 2012 survey conducted by Cardno Entrix Therefore, the likelihood of California Tiger Salamander California Red-legged frog occurring within the project area is considered low. Should reference CRLF not California Tiger Salamander Page 3-61 As the CNDDB contains recorded occurrences of this species within the project area and it was observed during the plant surveys, the likelihood of Congdons tarplant to occur within the project area is considered moderate high. Given that this species is known to occur within the Project area, and conditions have not changed significantly since those occurrences, the likelihood of this species occurring is high. Page 3-62 Hairless popcorn-flower (Plagiobothrys glaber) This species is believed to have been extirpated in California. CNNDB occurrence is from 2002, but identification is uncertain and has been disputed. All other occurrences are from pre-1954. This species is an annual herb ascending to erect with cauline leave Comments on Draft EIR from SunCal Page 8 July 22, 2013 that occurs in meadows and alkaline seeps, as well as coastal salt marshes and swamps. During floristic surveys, this species was not found within the project area. Hairless popcorn-flower (Plagiobothrys glaber) has a low likelihood of occurrence. Does not state likelihood of occurrence consistent with other species analysis, suggest additional text. Page 3-64 The California Endangered Species Act (CESA, Fish and Game Code of California, Chapter 1.5, Sections 2050-2116) prohibits the take of any plant or animal listed or proposed for listing as rare (plants only), threatened, or endangered. CESA does not afford protection to rare species, plants or otherwise. Rare plant protection is granted by the NPPA. 1977. This statement is confusing and inaccurate. Page 3-65 California Department of Fish and Game Wildlife (CDFW) Code The California Fish and Game Wildlife Code includes regulations governing the use of, or impacts on, many of the state’s fish, wildlife, and sensitive habitats. While California Department of Fish and Game (CDFG) and the new name of the department, California Fish and Wildlife (CDFW), is used inconsistently throughout the document, the regulatory code name has not changed and should be referenced as the California Fish and Game Code in all cases. Page 3-68 1.4 acres of other waters of the U.S. A portion of this acreage appears to be outside Project area. No analysis of ACSP is included. Page 3-70 If any federal or state ESA listed plant species are found during the rare plant surveys, the project applicant shall consult with the CDFW and USFWS to obtain incidental take permits under Section 2081 of the CESA and either Section 7 or 10 of the FESA. Need to clarify that this consultation only applies to ESA listed species. Special Status Wildlife Species – Mammals Page 3-72 Although no surveys specific for Western Pond Turtle have been conducted, Western Pond Turtle was observed within the project area greater Camp Parks Training Area during surveys for California Red Legged Frog. Inaccurate, Western Pond Turtle was observed within the Camp Parks Training area but outside the Project area. Please provide reference for observations within project area. Page 3-73 The Cantonment Area of - Camp Parks Recommend specifying project area for consistency. Page 3-76 ES-21 Comments on Draft EIR from SunCal Page 9 July 22, 2013 The project applicant shall could preserve additional upland habitat within a USFWS approved conservation area as determined in consultation. The Project proponent shall coordinate or consult” This measure would be determined in consultation with the USFWS, if required. Protocol level surveys for vernal pool invertebrates were conducted throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as during the summer of 2012 (dry season) and 2013 wet season (in progress) by Cardno Entrix. Since the new surveys have not been completed at this time, the presence of this species within the project area is assumed in the analysis of project impacts. References new surveys with negative findings and then contradicts survey findings, needs consistency. Removal of these wetlands could result in the potential take of protected vernal pool branchiopods and other protected invertebrates, if they were to occur, and their habitat. This would be considered a potentially significant impact. Surveys have previously been conducted for curve-footed Hygrotus beetle and San Francisco fork-tailed damselfly been conducted with negative findings. Since there is no published survey protocol, and these species would be identified as part of the branchiopod survey protocol, recommend striking, or specifying that they would be identified during branchiopod surveys. MM 3.3-5 See comments regarding consistency on how in-progress branchiopod surveys are applied. Page 3-51 (3 times), Page 3-55 (three times), Page 3-60, Page 3-61, Page 3-74, and Page 4-10. Recommend that they either define or change the “Cantonment Area.” This area is not defined or otherwise identified in the DEIS and it is unclear to a reader that is not familiar with the project background that the project is located within the former Camp Parks Cantonment Area. Page 3-151 and Page 3-208 Order No. 99-08-DWQ is a previously expired regulation (expired in 2004, and extended to 2009) and does not apply to this project. This project is expected to fall under 2009- 0009-DWQ as amended by 2010-0014-DWQ. However, as 2009-0009-DWQ is set to expire September 2, 2014 alternative text may be that the project shall comply with requirements of the NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities. (Construction General Permit). Pg.3-165 School shown under impact 3.9-3 as 11 acres . 3-166 table Consistent. The Specific Plan includes a maximum of 1,995 residential units; 200,000 square feet of commercial uses, a 30 net-acre community park; five acres of neighborhood park and an 11 acre elementary school site. Comments on Draft EIR from SunCal Page 10 July 22, 2013 Change school to 12 acres. 3-187 A_c_c_o_r_d_i_n_g_ _t_o_ _t_h_e_ _D_u_b_l_i_n_ _U_n_i_f_i_e_d_ _S_c_h_o_o_l_ _D_i_s_t_r_i_c_t_’s_ _D_e_m_o_g_r_a_p_h_i_c_ _S_t_u_d_y_ _a_n_d_ _F_a_c_i_l_i_t_i_e_s_ _P_l_a_n_,_ _2_0_1_1_-_2_0_1_2_,_ _e_a_c_h_ _n_e_w_ _s_i_n_g_l_e_-_f_a_m_i_l_y_ _h_o_m_e_ _(_l_a_r_g_e_ _a_n_d_ _m_e_d_i_u_m_ _l_o_t_ _s_i_n_g_l_e_ _f_a_m_i_l_y_ _h_o_m_e_)_ _g_e_n_e_r_a_t_e_s_ _a_n_ _a_v_e_r_a_g_e_ _o_f_ _0_._7_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _h_o_m_e_;_ _m_e_d_i_u_m_ _d_e_n_s_i_t_y_ _h_o_u_s_i_n_g_ _i_n_c_l_u_d_i_n_g_ _s_i_n_g_l_e_ _f_a_m_i_l_y_ _r_e_s_i_d_e_n_t_i_a_l_ _w_i_t_h_ _l_o_t_s_ _l_e_s_s_ _t_h_a_n_ _4_,_0_0_0_ _s_q_u_a_r_e_ _f_e_e_t_ _g_e_n_e_r_a_t_e_s_ _a_n_ _a_v_e_r_a_g_e_ _o_f_ _0_._5_2_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _h_o_m_e_;_ _m_e_d_i_u_m_-_h_i_g_h_ _d_e_n_s_i_t_y_ _a_t_t_a_c_h_e_d_ _h_o_u_s_i_n_g_ _(_o_t_h_e_r_w_i_s_e_ _k_n_o_w_n_ _a_s_ _“t_o_w_n_h_o_m_e_s_”)_ _g_e_n_e_r_a_t_e_ _a_n_ _a_v_e_r_a_g_e_ _0_._2_9_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _h_o_m_e_;_ _a_n_d_ _a_ _n_e_w_ _h_i_g_h_ _d_e_n_s_i_t_y_ _r_e_s_i_d_e_n_t_i_a_l_ _(_m_u_l_t_i_f_a_m_i_l_y_ _h_o_u_s_i_n_g_ _d_e_v_e_l_o_p_m_e_n_t_)_ _g_e_n_e_r_a_t_e_s_ _a_n_ _a_v_e_r_a_g_e_ _o_f_ _0_._1_2_5_ _K_-_1_2_ _s_t_u_d_e_n_t_s_ _p_e_r_ _u_n_i_t_ _(_D_U_S_D_ _2_0_1_2_)_._ _ Pg. 3-199 School shown under impact 3.11-3 as 11 acres. 3-200 The project applicant would build both the community park and neighborhood parks, as well as provide a $2.5 million dollar park maintenance endowment to the City. You sure about that? 4-23 under no project alt Hydrology and Water Quality (less). Surface water runoff under this alternative would be less in comparison to the proposed project since additional development would not occur under the Specific Plan and the project are is anticipated to remain in its current condition. Therefore, the No Project Alternative would result in less impacts in comparison to the proposed project. Not true due to mitigations. The project alternative will have superior water quality impacts. Pg.3-265 MM 3.12-1 left turn Dougherty road- Clarify with City intent of fair share monetary contribution. Pg.3-266 MM 3.12-2- Clarify with City intent of fair share monetary contribution. Comments on Draft EIR from SunCal Page 11 July 22, 2013 Pg. 3-266,67 MM 3.12-3 – Clarify with City intent of fair share monetary contribution. Pg.3-267 MM 3.12-4 - Clarify with City intent of fair share monetary contribution. Pg.3-268,69 MM 3.12-6- Clarify with City intent of fair share monetary contribution. 4-26 under Alt 2 Land Use and Planning (greater). Similar to the proposed project, the Reduced Development Alternative would not physically divide an established community and/or conflict with applicable land use plan, policies or regulations. Therefore, the No Project Alternative would result in similar impacts as compared to the proposed project. Says greater but concludes similar Figure 2-10 FEMA Flood Zones - Project boundary is missing. Figure 2-11 Conceptual Stormwater Drainage & Detention System – legend incorrectly identifies "ponds" instead of "underground detention basin." Figure 2-15 Phasing Map – adjust phase boundaries 2, 4 & 5 to follow street. General Please note that Phasing map is being updated to correct two typos. ACSPA parcel sometimes in sometimes out – no references to Transit Village EIR Dublin Crossing Specific Plan Final EIR Page 40 Response to Comment Letter #14 from Dublin Crossing LLC, received July 22, 2013 Response to Comment 14-1 – Secondary Units Comment noted and the respective change has been made to page ES-2 of the Draft EIR. Response to Comment 14-2 – Toxic Air Contaminants The air toxics analysis in the Draft EIR is based on the BAAQMD’s list of permitted toxic air contaminant (TAC) sources located within 1,000 feet of the project boundary (including diesel generators). The BAAQMD has identified emission rates and associated health risks for these sources. For residential uses, the BAAQMD requires that either a 1,000 foot buffer from air toxic sources be incorporated or other mitigation measures as identified in Mitigation Measure MM 3.2-5 of the Draft EIR. The closest TAC source is the Camp Parks generator, which is located 200 feet north of the project area. However, most of the sources in the project vicinity are 500 to 1,000 feet from the boundary of the project area. Response to Comment 14-3 – Approval of a Wetland Mitigation Plan Comment noted and the respective changes have been made to pagesES-15, 3-72, and 3-73 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-4 – Plants Listed under the State and/or Federal Endangered Species Act Comment noted and the respective changes have been made to pages ES-16 to ES-18 and pages 3-74 and 3-75 of the Draft EIR. Revisions to the Draft EIR do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-5 – Preservation of Upland Habitat and Protocol Level Surveys for Vernal Pool Invertebrates Comment noted and the respective changes have been made to page ES-25 to ES-26 and page 3-81 of the Draft EIR. Revisions to the Draft EIR do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-6 – Vernal Pool Invertebrates Comment noted and the respective changes have been made to pages ES-25 to ES-26 and pages 3-82 to 3-83of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 41 Response to Comment 14-7 – Stormwater Basin #2 Outfall Mitigation Measure 3.8-4b on pages ES-43, 3-168, and 3-169 of the Draft EIR has been revised to more clearly correlate directly to the project impact, as follows: MM 3.8-4b: Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the first grading/sitework permit associated with the construction of the proposed community park, the project applicant shall submit to the City for review and approval, plans, details, and calculations for the proposed underground stormwater detention structure(s) and associated storm drain system within the park parcel to ensure that adequate capacity will be provided; that the resultant discharge flow rates meet the requirements of the Regional Water Quality Control Board; and that the placement of the underground facilities in the park will not impact the park design and construction of recreational facilities. The location and layout of the underground detention structures and the connection of these facilities to the proposed Chabot Creek riparian channel, box culvert or downstream facilities shall be agreed upon by both the project applicant and the City. The method and location of stormwater discharge of the underground facilities shall be reviewed and approved by all appropriate regulatory and/or permitting agencies. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-8 – Stormwater Outfall from Proposed North Basin #2 See Response to Comment 14-7. Response to Comment 14-9 – Grade Separated Crossing Project The City is pursuing multiple sources of funding to conduct a feasibility analysis of the Iron Horse Trail connectivity from Dougherty Road to the (East) Dublin/Pleasanton BART station. It is recognized that a grade-separated crossing in this location could significantly enhance bike and pedestrian access to and from the project area and beyond. To support this project, Sun Cal is contributing $50,000 towards the feasibility analysis, and the City is seeking additional funding from ACTC’s own Sustainable Communities Technical Assistance Program. It is the City’s full intent to pursue a grade-separated crossing at this location, and at this time the alternative mitigation measure of removing a portion of the crosswalk across Dublin Boulevard will remain in the EIR. Response to Comment 14-10 – Significant and Unavoidable Impact at Southbound Hacienda Drive to I-580 Eastbound On-Ramp and Southbound Tassajara Road to I-580 Westbound On-Ramp Comment noted. Even if the freeway ramps could be mitigated by changing the ramp metering rates so that more vehicles could access the freeway, the proposed project would exacerbate a significant impact until the ramps are metered. Therefore, this would be considered a significant and unavoidable impact. Dublin Crossing Specific Plan Final EIR Page 42 Response to Comment 14-11 – Land Use and Development Plan Figures Comment noted. In Section 2.6, Land Uses and Development Plan, Figure 2-7 Conceptual Land Use Plan was referenced to show the land use diagram of the proposed project and Figure 2-8: Illustrative Site Plan was referenced to show a conceptual plan for the proposed project. Figure 2-9: Proposed Street Network as noted by the commenter is not referenced within Section 2.6. Response to Comment 14-12 – Table 2-1 Comment noted and the respective changes have been made to page 2-8 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-13 – Central Park and Iron Horse Regional Trail Alignment Comment noted and the respective changes have been made to page 2-11 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-14 – Camp Parks Watershed Commenter provides text from the Draft EIR that the 1,800+ acre watershed drains through the project area. The text on pages 2-14 and 3-153 of the Draft EIR has been revised to state that the majority of the Camp Parks watershed drains through the project area. The off-site watershed area and amount of watershed drainage that flows through the project area in the Draft EIR analysis was based on the correct information. Response to Comment 14-15 – Storm Drain Infrastructure Comment noted and the respective changes have been made to page 2-14 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-16 – Former Building 109/Parks Reserve Forces Training Area (PRFTA) 2 Comment noted. According to Mark Hall, Environmental Coordinator at U.S. Army, Camp Parks, the contamination at the Former Building 109/PRFTA 2 was remediated by the U.S. Army and cleaned to industrial standards. There are currently groundwater monitoring wells at the site and the U.S. Army has completed three quarters of sampling in coordination with the Department of Toxic Substances and Control (DTSC). The respective changes have been made to page 2-17 and page 3-138 and 3-139 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 43 Response to Comment 14-17 – Reference to the San Francisco Regional Water Quality Control Board Comment noted and the respective changes have been made to pages 2-17, 3-137, 3-146, 3-154 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-18 – Footnote to Table 2-2: Phasing Plan Comment noted. The project applicant has been noted in the footnote of Table 2-2: Phasing Plan on page 2-18 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-19 – Building Heights Comment noted. Method of building height measurement has been added to the Specific Plan. Response to Comment 14-20 – Number of Trips per Day Analyzed in the Air Quality Modeling The air quality modeling modeled 22,047 trips per day (See Appendix B of the Draft EIR). Page 3-35 in the Draft EIR has been revised to reflect the correct value. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-21 – Toxic Air Contaminants Comment noted. See Response Comment 14-2. Response to Comment 14-22 – Date of Technical Report and Alameda County Surplus Property Comment noted and the respective changes have been made to pages 3-47 and 3-48 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. A Draft EIR was prepared for the Dublin Transit Center included the Alameda County Surplus Property. The EIR was certified by the City Council on November 19, 2002. Based on the analysis completed in the Dublin Transit Center EIR, the Alameda County Surplus Property was not found to contain any special status species or significant biological features (e.g. wetlands), etc. However, the mitigation measures included in the Draft EIR for the proposed project would apply to future development on the Alameda County Surplus Property site as well, which would ensure that the proposed project would have a less than significant impact on biological resources. Dublin Crossing Specific Plan Final EIR Page 44 Response to Comment 14-23 – Table 3.3-1: Habitats and Vegetation Communities within the Project Area Comment noted and the respective changes have been made to page 3-47 and 3-48 of the Draft EIR. See Response to Comment 14-22. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-24 – Wetlands and Drainage Ditches Comment noted and respective changes have been made to page 3-49 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-25 - Other Waters of the U.S. and an Unnamed Canal (Canal 02) Comment noted and respective changes have been made to pages 3-50 and 3-51 of the Draft EIR. Revisions do not change the analysis in the Draft EIR. Response to Comment 14-26 – Reference for Special Status Species Occurrence in the Project Area Comment noted and the respective changes have been made to page 3-53 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-27 – Identification of the Project Area Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-28 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-29 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-30 – Previous Biological Surveys Comment noted and the respective changes have been made to page 3-54 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 45 Response to Comment 14-31 – Western Pond Turtle Comment noted and the respective changes have been made to page 3-56 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-32 - California Red Legged Frog Comment noted and the respective changes have been made to page 3-58 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-33 –California Red Legged Frog Comment noted and the respective changes have been made to page 3-58 of the Draft EIR. This revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-34 – Congdon’s Tarplant Comment noted and the respective changes have been made to page 3-64 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-35 – Hairless popcorn-flower Comment noted and the respective changes have been made to page 3-64 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-36 – Regulatory Framework, California Endangered Species Act Comment noted and the respective changes have been made to page 3-68 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-37 – California Fish and Game Code Comment noted and the respective changes have been made to page 3-69 of the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-38 – Other Waters of the U.S. and the Alameda County Surplus Property Comment noted and the respective changes have been made to page 3-72 to 3-73 of the Draft EIR. The Alameda County Surplus Property is addressed in Response to Comment 14-22 Dublin Crossing Specific Plan Final EIR Page 46 Response to Comment 14-39 – Endangered Species Act Comment noted and the respective changes have been made to pages 3-74 and 3-75 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-40 – Western Pond Turtle Comment noted and the respective changes have been made to page 3-77 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-41 – Reference to Cantonment Area of Camp Parks Comment noted and the respective changes have been made to page 3-79 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-42 – California Red Legged Frog Comment noted and the respective changes have been made to page 3-79 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-43 – Vernal Pool Invertebrates Comment noted and the respective changes have been made to page 3-82 and 3-83 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-44 – Mitigation Measure 3.3-5 Comment noted and the respective changes have been made to page 3-83 the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-45 - Reference to Cantonment Area of Camp Parks Comment noted and the respective changes have been made to pages 2-2, 3-53, 3-54, 3-79, and 4-11 the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-46 – Stormwater Pollution Prevention Plans (SWPPs) Comment noted and the respective changes have been made to page 3-161 of the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 47 Response to Comment 14-47 – Acreage of the School Site Comment noted and the respective changes have been made to page 3-177 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-48 – Acreage of the School Site Comment noted and the respective changes have been made to pages 3-178 and 3-179 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-49 – Student Generation Commenter does not provide a specific comment on the student generation rates. Therefore, no response is necessary. Response to Comment 14-50 - Acreage of the School Site Comment noted and the respective changes have been made to page 3-212 and 3-213 in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-51 – Funding for the Community Park and Neighborhood Parks The project will provide the funds for and the City will design and construct both the Community Park and the two neighborhood parks. Response to Comment 14-52 – No Project Alternative Comment noted. The No Project Alternative would result in a reduction of impacts to hydrology and water quality in comparison to the proposed project as the alternative would not result in a significant increase in impervious surfaces compared to existing conditions. Dublin Crossing Specific Plan Final EIR Page 48 Response to Comment 14-53– Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips. Response to Comment 14-54– Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips. Response to Comment 14-55– Fair Share Monetary Contribution Comment noted. The project contributes to the cumulative impact at this location. The fair share monetary contribution mitigates the impact of the projects additional trips. Response to Comment 14-56– Fair Share Monetary Contribution Comment noted. The mitigation measure requires the project to complete this improvement. There is no provision for fair share contribution. Response to Comment 14-57 – Fair Share Monetary Contribution Comment noted. The project adds vehicle trips to an improvement already identified by the City’s Traffic Impact Fee program. The fair share monetary contribution mitigates the impact of the project’s additional trips. Response to Comment 14-58 – Alternative #2 Comment noted and the respective changes have been made to page 4-27 of the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-59 – Figure 2-10 Comment noted and the respective changes have been made to Figure 2-10 in the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-60 – Figure 2-11 Comment noted and the respective changes have been made to Figure 2-11 in the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-61 – Figure 2-15 Comment noted and the respective changes have been made to the Draft EIR. The revision does not change the analysis or impact conclusion in the Draft EIR. Dublin Crossing Specific Plan Final EIR Page 49 Response to Comment 14-62 – Phasing Map Comment noted. An updated Phasing Map (to correct minor typographical errors) is included in the Draft EIR. Revisions do not change the analysis or impact conclusion in the Draft EIR. Response to Comment 14-63 – Alameda County Surplus Property Comment noted. See Response to Comment 14-22. Dublin Crossing Specific Plan Final EIR Page 50 Changes to the Draft EIR Changes to the Draft EIR are shown on the following pages. Dublin Crossing Specific Plan Final EIR Table of Contents Page v Figure 3.7-1: Sound Levels and Human Response Figure 3.8-1: Hydrologic Features Figure 3.8-2: Existing Drainage Figure 3.8-3: Proposed DrainageProposed Q100 Project Flows Figure 3.10-1: Sound Levels and Human Response Figure 3.12-1: Site Location and Off-Site Study Intersections Figure 3.12-2: Future Project Study Intersections Figure 3.12-3: Existing Bicycle Facilities Figure 3.12-4: Existing Transit Routes Figure 3.12-5a and 3.12-5b: Existing Lane Configurations Figure 3.12-6a and 3.12-6b: Existing Peak Hour Intersection Volumes Figure 3.12-7: Project Trip Distribution Figure 3.12-8a and 3.12-8b: Existing Plus Project Peak Hour Intersection Volumes Figure 3.12-9a and 3.12-9b: 2020 Background No Project Peak Hour Intersection Volumes Figure 3.12-10a and 3.12-10b: 2020 Background No Project Lane Configurations Figure 3.12-11: 2020 Background No Project Roadway Configurations Figure 3.12-12a and 3.12-12b: 2020 Background Plus Project Peak Hour Intersection Volumes Figure 3.12-13a and 3.12-13b: 2035 Cumulative No Project Peak Hour Intersection Volumes Figure 3.12-14a and 3.12-14b: 2035 Cumulative No Project Lane Configurations Figure 3.12-15: 2035 Cumulative No Project Roadway Improvements Figure 3.12-16a and 3.12-16b: 2035 Cumulative Plus Project Peak Hour Intersection Volumes Figure 3.12-17: 2035 Cumulative Plus Project Lane Configurations Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-2 In 2004, the US Army developed a master plan summary report describing the proposed future development and revitalization of the portion of the project area within Camp Parks. The Final Environmental Impact Statement (FEIS) on Master Planned Redevelopment at Camp Parks (U.S. Army Garrison Camp Parks 2009) was the federal environmental document prepared to analyze the environmental consequences of implementation of the master plan for redevelopment of Camp Parks. The FEIS included consideration of the proposed project. In December 2007 the Army prepared a “Notice of Availability” to solicit a master developer for the Camp Parks Real Property Exchange Area. The Exchange Agreement provides the Army with an opportunity to modernize facilities through the provision of 180-acres of Army owned property (including the NASA parcel but excluding the 8.7-acre Alameda County Surplus Property Authority parcel), to a developer in exchange for Camp Parks facilities improvements. The Exchange Agreement is not a part of the Specific Plan but was necessary to facilitate acquisition of the property by the project developer. In October 2008, the Army announced the selection of the master developer for the Project. In April 2011, the developer and the U.S. Army officially finalized the Exchange Agreement, authorizing the developer to commence the Specific Plan process. Project Description The Specific Plan addresses the future development of the project area, which is comprised of residential, commercial, parks and open space, and an elementary school. Specifically, the proposed project includes up to 1,995 residential units (not including secondary units); up to 200,000 square feet of commercial uses, 30 net- acre community park; five acres of neighborhood parks; and provisional space for a 12-acre elementary school site. Summary of Environmental Impacts All impacts identified in the subsequent environmental analysis are summarized in Table S-1: Executive Summary of Project Impacts, which identifies impacts by each technical section. Summary of Cumulative Considerable Effects The proposed project would result in a significant cumulative impact from short- term construction air quality emissions and long-term operational air quality emissions, as well as a significant cumulative impact to the Southbound Hacienda Drive to I-580 Eastbound On-Ramp and the Southbound Tassajara Road to I-580 Westbound On-Ramp. Summary of Alternatives CEQA Guidelines require that an EIR describe and evaluate alternatives to the project that could eliminate significant adverse project impacts or reduce them to a Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-15 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance Impact 3.2-7: The proposed project would allow some uses which generate airborne odors, which could be considered offensive. However, limited exposure and compliance with applicable regulatory requirements will ensure that any impact is less than significant. Less than Significant No mitigation measures are necessary. Less than Significant Impact 3.2-8: The proposed project is consistent with population growth assumptions in the 2010 Bay Area Clean Air Plan, is anticipated to result in reduced Vehicle Miles Travelled (VMT) compared to population growth, and is consistent with several of the Clean Air Plan’s Control Measures. Less than Significant No mitigation measures are necessary. Less than Significant Biological Resources Impact 3.3-1: Based on a preliminary wetland delineation of the project area, the proposed project could result in the fill of wetlands. Potentially Significant MM 3.3-1: Prepare and Implement a Wetland Mitigation Plan. Prior to commencing any activities that would impact wetlands or waters habitat, the project applicant shall obtain all required public agency permits and shall prepare Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-16 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance a wetland mitigation plan that ensures no-net- loss of wetland and waters habitat and is approved by the City andthat is approved by the applicable resource agencies and submitted to the City. The wetland mitigation plan shall include measures for avoidance, minimization, and compensation for wetland impacts. Avoidance and minimization measures may include the designation of buffers around wetland features to be avoided, or project design measures, such as free-span bridges. Compensation measures shall include the preservation and/or creation of wetland or waters. The final mitigation ratios (the amount of wetlands and waters created or preserved compared to the amount impacted) shall be determined by the applicable resource agencies and the City. The wetland mitigation and monitoring plan shall include the following:  Descriptions of the wetland types, and their expected functions and values;  Performance standards and monitoring protocol to ensure the success of the mitigation wetlands over a period to be determined by the resource agencies;  Engineering plans showing the location, size and configuration of wetlands to be created or restored;  An implementation schedule showing that construction or preservation of mitigation areas shall commence prior to or concurrently with the initiation of Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-17 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance construction; and  A description of legal protection measures for the preserved wetlands (i.e., dedication of fee title, conservation easement, and/or an endowment held by an approved conservation organization, government agency or mitigation bank). Impact 3.3-2: A query of the CNPS lists 34 plant species that occur within the project vicinity. Based on habitats within the project area during the March 2012 survey by Cardno Entrix, the list was reduced to four special status plant species that have the potential to be located within the project area including: Congdon’s tarplant (Centromadia parryi ssp. Congdonii), Palmate- bracted bird’s-beak (Cordylanthus palmatus), Northern California Black Walnut (Juglans hindsii), and Hairless popcorn-flower (Plagiobothrys glaber). Out of these four special status plant species, the only special status plant species that has the potential to be located within the project area is the Congdon’s tarplant, which was documented as occurring within the project area based on floristic surveys Potentially Significant .MM 3.3-2a: Conduct a Floristic Survey and Consult with CDFG CDFW and USFWS if State or Federally Listed ESA Plants are Found and Comply with Incidental Take Permits. The project applicant shall retain a qualified botanist to conduct rare plant surveys within the construction zone for Congdon’s tarplant or other state or federally species with potential habitat within the project area during the appropriate time of yearblooming period of those species for which suitable habitat is present in accordance with agency protocols. These plant surveys shall be conducted in accordance with the 2009 California Department of Fish and GameCDFW and United States Fish and Wildlife ServiceUSFWS rare plant survey protocols. Two or three separate surveys may be required to cover the blooming periods of species where suitable habitat is present. The results of the surveys shall be summarized in a report and submitted to CDFW and USFWS, and would be valid for two years. If no special-status plants are located during the surveys, no further mitigation measures would be required. If any federal or state ESA plant species are found during the rare plant surveys, the project applicant shall consult Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-18 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance conducted between 1995 and 2000. with the CDFW and USFWS to obtain incidental take permits under Section 2081 of the CESA and either Section 7 or 10 of the FESA. Consultation with USFWS under Section 7 of the FESA could occur as part of the CWA Section 404 permit process as part of the wetland mitigation, described under Mitigation Measure MM 3.3-1. MM 3.3-2b: Develop and Implement Mitigation in Consultation with CDFW if Other Special Status Plant Species Are Found. If populations or stands of Congdon’s tarplant or other special- status plant species (excluding federal or state listed plants) are found during the rare plant surveys and impacts are unavoidable, the project applicant shall notify the CDFW. A compensatory mitigation plan shall be developed in consultation with and approved by the CDFW and the City prior to the commencement of any activities that would impact any special status plants, such as the acquisition of off-site mitigation areas presently supporting the species in question or purchase of credits in a mitigation bank that is approved to sell credits for the affected species. The location of mitigation sites shall be determined in consultation with, and subject to approval of USFWS and/or CDFW. Off-site compensatory mitigation shall be acquired at a minimum acreage of 1:1 (acquired: impacted). For either off-site mitigation option, measures shall be implemented providing for the long-term protection of the species. The mitigation plan shall include measures such as transplanting Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-19 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance plants, collecting seed or clippings and replanting species in an on-site location, if feasible or other location approved by Department of Fish and Game. Impact 3.3-3: Several California burrowing owl pairs have been documented within the project area, including during the winter and breeding season. Due to the security fencing that surrounds Camp Parks, low human use, and maintenance activities, the project area provides suitable breeding, foraging and wintering habitat for the California burrowing owl. Implementation of the proposed project could result in the displacement of burrowing owls during construction activities, and once completed the proposed project could result in the removal of suitable burrowing owl (breeding and wintering) habitat. Permanent loss of occupied burrow(s) and habitat. Potentially Significant MM 3.3-3a: Conduct a Burrowing Owl Survey and Impact Assessment. The project applicant shall retain a qualified biologist to conduct a California burrowing owl take avoidance surveys 14 days prior to ground disturbing activities and impact assessment following the 2012 California Department of Fish and Game Staff Report on Burrowing Owl Mitigation (CDFW 2012) or as updated at the time of the implementation of the proposed project. If no owls are found during this first survey, a final survey shall be conducted within 48-hours prior to ground disturbance to confirm that burrowing owls are still absent. If ground disturbing activities are delayed or suspended for more than 14 days after the initial take avoidance survey, the project area shall be resurveyed including the final survey within 48- hours of disturbance. The report(s) shall be submitted to California Department of Fish and GameCDFW as indicated in the CDFW 2012 Staff Report. If it is determined that project activities may result in impacts to nesting, occupied, and satellite burrows and/or burrowing owl habitat, the project applicant shall consult with the CDFW. More specifically, if the surveys identify breeding or wintering burrowing owls on or adjacent to the project area, occupied burrows Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-20 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance cannot be disturbed and shall be provided with protective buffers. Where avoidance is not feasible during the non-breeding season, a site specific exclusion plan (i.e. a plan that considers the type and extent of the proposed activity, the duration and timing of the activity, the sensitivity and habituation of the owls, and the dissimilarity of the proposed activity with background activities) shall be implemented to encourage the owls to move away from the work area prior to construction and to minimize the potential to affect the reproductive success of the owls. The exclusion plan shall be subject to the CDFW approval and monitoring requirements. Compensatory mitigation could also be required by the CDFW as part of the approval of an exclusion plan. Mitigation may include the permanent protection of habitat at a nearby off- site location acceptable to the CDFW. and develop a detailed mitigation plan such that the habitat acreage, number of burrows, and burrowing owl impacted are replaced. The mitigation plan shall be based on the requirements set forth in Appendix A of the CDFW 2012 Staff Report on Burrowing Owl Mitigation. MM 3.3-3b: Implement Avoidance Measures. If California burrowing owl are located within the project area and direct impacts can be avoided, the project applicant shall implement the following avoidance measures during all phases of construction to reduce or eliminate potential impacts to California burrowing owls. Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-21 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance  Avoid disturbing occupied burrows during the nesting period, from 1 February through 31 August.  Avoid impacting burrows occupied during the non-breeding season by migratory or non-migratory resident burrowing owls.  Avoid direct destruction of burrows through chaining (dragging a heavy chain over an area to remove shrubs), disking, cultivation, and urban, industrial, or agricultural development.  Develop and implement a worker awareness program to increase the on- site worker’s recognition of and commitment to burrowing owl protection.  Place visible markers near burrows to ensure that farm equipment and other machinery does not collapse burrows.  Do not fumigate, use treated bait or other means of poisoning nuisance animals in areas where burrowing owls are known or suspected to occur (e.g., sites observed with nesting owls, designated use areas).  Restrict the use of treated grain to poison mammals to the months of January and February. MM 3.3-3c: Conduct Burrow Exclusion. In the event that California burrowing owls are located Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-22 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance within the project area, the project applicant shall conduct a Burrowing Owl Relocation Plan. If avoidance of burrowing owl or their burrows is not possible, the project applicant in consultation with the California Department of Fish and Wildlife shall prepare a Burrowing Owl Relocation Plan as indicated and following the CDFW 2012 Staff Report. Monitoring of the excluded owls shall be carried out as per the California Department of Fish and Game 2012 Staff Report. Mitigation for permanent impacts to nesting, occupied, and satellite burrow and/or burrowing owls shall be developed based on the CDFW 2012 Staff Report on Burrowing Owl Mitigation. Impact 3.3-4: Habitat assessments or surveys for special-status amphibians and reptiles were performed within the project area by the U.S. Army in 2006, including California Red Legged Frog and California Tiger Salamander. Although no surveys specific for Western Pond Turtle have been conducted, Western Pond Turtle was observed within the project areagreater Camp Parks Training Area during surveys for California Red Legged Frog. During the field surveys conducted by in March 2012, the Potentially Significant MM 3.3-4a: Conduct Pre-Construction Surveys for Western Pond Turtle (WPT) The project applicant shall retain a qualified biologist to conduct pre-construction surveys for Western Pond Turtle no more than 30 days prior to work in or adjacent to any habitat suitable for WPT within the project area. If no Western Pond Turtles are found, no further mitigation is required. If Western Pond Turtles are found, the consulting biologist shall consult with the California Department of Fish and Game for authorization to relocate the species to suitable habitat away from the construction zone. The turtle shall be relocated to either a pond within the Training Area (if authorization from the US Army is granted) or downstream from the construction zone to similar or better habitat. Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-23 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance project area was not found to provide suitable breeding habitat for these species. However, the proposed project includes re- alignment of the ephemeral drainage, which could result in the potential “take” of Western Pond Turtle and/or California Red Legged Frog if found within the project area. MM 3.3-4b: Consult with United States Fish and Wildlife Service and Reduce Impacts on California Red-Legged Frog. The project applicant shall comply with the following requirements: a. The project applicant shall retain a qualified herpetologist to conduct habitat assessments for CRLF and based on the results of the habitat assessments, determine in consultation with the USFWS if protocol-level CRLF surveys will be required within the project area. The project area consists of multiple phase areas within which separate CRLF habitat assessments may be conducted. It shall then be determined on a phase- by-phase basis, if further surveys will be required. The project applicant can forgo the habitat assessments and conduct protocol-level surveys. If required, the focused surveys shall follow the Revised Guidance on Site Assessment and Field Surveys for the California Red-legged Frog (USFWS 2005). A CRLF survey report prepared to meet the protocol guidelines shall be submitted to the USFWS. If no CRLF are found then no further mitigation is required. b. If CRLF are found then the project applicant shall provide information to the USACE to support Section 7 consultation with the USFWS and the project applicant shall ensure no net loss Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-24 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance of habitat that shall be achieved through avoidance, preservation, creation and/or purchase of credits. The final selected measures may be part of the Section 7 permitting process. c. The project applicant shall obtain a biological opinion from the U.S Fish and Wildlife Service and comply with the conditions and mitigation requirements of those agencies to ensure that no net loss of habitat occurs. Mitigation may include, but would not be limited to, onsite and offsite preservation and creation of CRLF habitat, purchase of credits at mitigation banks, payment of in lieu fees approved by the agencies, or other agency approved and required mitigation measures. d. Avoidance measures may include the following or equivalent protective measures:  To minimize disturbance of breeding and dispersing CRLF, construction activity within CRLF upland habitat shall be conducted during the dry season between April15 and October 15 or before the onset of the rainy season, whichever occurs first. If construction activities are necessary in CRLF upland habitat between October 15 and April 15, the project applicant would contact the USFWS for approval to extend the work period. Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-25 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance  To minimize disturbance and mortality of adult and juvenile CRLF in aquatic habitat and underground burrows, the project applicant could minimize the extent of ground-disturbing activities within these habitats by requiring the contractor to limit the work area to the minimum necessary for construction. In addition, the project applicant could ensure that the contractor would install temporary exclusion fence between the construction work area and potential aquatic habitat for all construction within grasslands near aquatic habitat.  The project applicant could ensure that a qualified wildlife biologist monitors all construction activities within CRLF upland habitat. This would ensure no take of individual CRLF occurs during project construction. If a CRLF is found, then the monitor would immediately stop construction in that area and contact USFWS for advice.  The project applicant shall could preserve additional upland habitat within a USFWS approved conservation area. This measure shall be determined in consultation with the USFWS, if required.The Project proponent shall coordinate or consult Impact 3.3-5: Protocol level surveys for vernal pool Potentially Significant MM 3.3-5: Consult with the USFWS and Reduce Impacts on Vernal Pool Invertebrates and Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-26 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance invertebrates were conducted throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as during the summer of 2012 (dry season) and 2013 (wet season) by Cardno Entrix. No vernal pool fairy shrimp, vernal pool tadpole shrimp or longhorn fairy shrimp were found during these surveys. California linderiella was found, during the 2002 and 2003 surveys, but not within the project area. New The surveys are currently being conducted by Cardno Entrix have not been accepted by the USFWS. Since the new surveys have not been completed at this timeTherefore, the presence of this species within the project area is assumed in the analysis of project impacts. Surveys for curve-footed Hygrotus beetle and San Francisco fork-tailed damselfly were also conducted within Camp Parks in 2002 and 2003 and neither of these species were observed. Site conditions have not changed significantly and these species are not expected to occur. Potentially suitable habitat was observed within the Their Habitat. The project applicant shall prepare a habitat assessment for the vernal pool invertebrates. If vernal pool invertebrates are found within the project area during the habitat assessment, the project applicant shall comply with the following steps to ensure protection of vernal pool invertebrates and their habitat and that impacts are reduced to a less than significant level. a. The project applicant shall retain a qualified biologist to conduct habitat assessments for protected vernal pool invertebrates and based on the results of the habitat assessments, determine in consultation with the USFWS if protocol- level vernal pool invertebrate surveys will be required within the project area. b. If suitable habitat is present, the project applicant, in consultation with the USFWS and CDFW, shall either (1) conduct a protocol-level survey for federally listed vernal pool crustaceans, which will identify and other protected vernal pool invertebrates (curve-footed Hygrotus beetle and San Francisco fork- tailed damselfly), or (2) assume presence of federally-listed vernal pool crustaceans and curve footed Hygrotus beetle and San Francisco fork-tailed damselfly in areas of suitable habitat. Surveys shall be conducted by qualified biologists in accordance with the most recent USFWS guidelines or protocols to Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-27 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance survey area for vernal pool invertebrates and these areas would be removed during proposed construction activities. Removal of these wetlands could result in the potential take of protected vernal pool branchiopods and other protected invertebrates, if they were to occur, and their habitat. determine the time of year and survey methodology (survey timing for these species is dependent on yearly rainfall patterns and seasonal occurrences, and is determined on a case-by-case basis). The USFWS protocol level surveys shall be conducted as part of the Section 404 permit process within two years of the application. If surveys reveal no occurrences of federally listed vernal pool crustaceans or other protected vernal pool invertebrates, no further mitigation would be required. c. If surveys determine that one or more special-status vernal pool invertebrate species occurs within the project area, or if the project applicant, in consultation with the USFWS and/or CDFW, assumes presence of federally-listed vernal pool invertebrates in all affected habitats, the project applicant shall provide information to the USACE to support Section 7 consultation with the USFWS and the project applicant shall ensure no net loss of habitat shall be achieved through avoidance, preservation, creation and/or purchase of credits as a part of the Section 7 Consultation process. The selected measures may be part of the permitting process. d. Where feasible, all vernal pool invertebrate habitat shall be avoided. If habitat that can be avoided during Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-28 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance construction activities is identified at a distance determined in consultation with USFWS, a USFWS-approved biologist (monitor) shall inspect any construction- related activities to ensure that no unnecessary take of listed species or destruction of their habitat occurs. The Project proponent will establish monitoring and reporting protocols to reduce impacts to vernal pool invertebrate species and habitat. e. The project applicant shall ensure that an appropriate number of acres, as approved by USFWS during consultation, are preserved to mitigate for direct or indirect impacts on vernal pool crustacean habitat. f. Water quality in the avoided wetlands shall be protected using erosion control techniques, such as silt fencing or straw wattles during construction in the watershed. Impact 3.3-6: A variety of special-status birds are expected to be located within the project area. Some of these species are resident species and some are migratory species that breed within the project area. The special-status birds known to nest in the Livermore Valley area include the Golden eagle, white- tailed kite, tricolored blackbird, Potentially Significant MM 3.3-6: Protect Birds Covered by the Migratory Bird Treaty Act (Including, but not limited to White-Tailed Kite, golden eagle, Cooper’s hawk, Loggerhead Shrike, and Other Special-Status Species). Project contractors shall avoid construction activities during the bird nesting season (February 1 through August 31). If Between March 1 and September 15construction activities are conducted during the bird nesting season, the project applicant shall have a qualified biologist conduct at least Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-29 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance northern harrier, California horned, prairie falcon, Cooper’s hawk and loggerhead shrike. Trees, fresh emergent wetland vegetation and grassland could provide potentially suitable nesting habitat for these species, which are protected under the Migrant Bird Treaty Act and the Fish and Game Code. The proposed project would require grading and possible removal of existing trees and vegetation. three nest surveys of the project area to develop a baseline of nesting activity on and adjacent to the project area. Depending on the construction schedule, pre-construction surveys shall be initiated prior to planned construction activity to allow for multiple site visits (e.g. for construction activities planned for mid-May, the first survey shall be conducted no more than 14 days prior to the start of work). no more than 30 days prior to any demolition/construction or ground- disturbing activities that are within 300 feet of potential nest trees for non-raptor species (i.e. trees, cattails, or grassland) and 500 feet of potential nest trees for raptor species or suitable nesting habitat (i.e., trees, cattails, grassland). Where access to property adjacent to the construction activities is prohibited by the owner/operator, the survey shall be conducted using binoculars or spotting scope. A pre- construction survey report shall be submitted to the California Department of Fish and Game that includes, at a minimum: (1) a description of the methodology including dates of field visits, the names of survey personnel with resumes, and a list of references cited and persons contacted; and (2) a map showing the location(s) of any bird nests observed on the project area. If no active nests of Migratory Bird Treaty Act covered species are identified, then no further mitigation is required. If active nests of protected bird species are identified in the focused nest surveys, the project applicant will shall consult with the appropriate regulatory agencies to identify project-level Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-30 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance mitigation requirements, based on the agencies’ standards and policies as then in effect. Performance measures may include the following, based on current agency standards and policies. a. The project applicant, in consultation with California Department of Fish and Game, would delay construction in the vicinity of active nest sites during the breeding season (February 1 through September 15) while the nest is occupied with adults and/or young. A qualified biologist would shall monitor any occupied nest to determine when the nest is no longer used. If the construction cannot be delayed, avoidance measures would shall include the establishment of protective buffer zones around the nests as follows: for raptor nests, the size of the buffer zone shall be a minimum 250 foot radius centered on the nest; for other birds, the size of the buffer zone shall be a 50-foot radius centered on the nest. In some cases, these buffers may be increased or decreased depending on the bird species and the level of disturbance that will occur near the nest. Changes to the buffer should be made by the project biologist in consultation with the CDFW. of a non-disturbance buffer zone around the nest site. The size of the buffer zone would be determined in consultation with the CDFW and may vary depending on the species, but will be a minimum of Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-31 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance 250 feet. The buffer zone would be delineated with highly visible temporary construction fencing. b. No intensive disturbance (e.g., heavy equipment operation associated with construction, or use of cranes) or other project-related activities that could cause nest abandonment or forced fledging would be initiated within the established buffer zone of an active nest between February 1 and September 15August 31. c. If construction activities are unavoidable within the buffer zone, the project applicant shall retain a qualified biologist to monitor the nest site to determine if construction activities are disturbing the adult or young birds. d. If fully protected species (white-tailed kites, golden eagles) are found to be nesting near the proposed construction area, their nests would be completely avoided until the birds fledge. Avoidance would include the establishment of a non-disturbance buffer zone of 500 feet, or as determined in consultation with the CDFW. Impact 3.3-7: Removal of trees and/or buildings or structures from the project area could impact roosting sites for pallid bat and Yuma myotis. Potentially Significant MM 3.3-7a: Conduct Bat and Bat Roosting Site Surveys. Prior to construction activities, the project applicant shall retain a qualified biologist to conduct a focused survey for bats and potential roosting sites within the project area. The Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-42 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance and/or lead based paint (LBPs). Impact 3.7-4: The project area is not located on a hazardous material site pursuant to Government Code Section 65962.5. However, based on the Phase I ESA there are three sites currently being evaluated by the U.S. Army. Hazardous materials may be encountered during construction. Potentially Significant MM 3.7-4: Remediation of Hazardous Materials. Future development within the vicinity of Former Building 109/PRFTA, Area 761/PRFTA 13, and the Potential Construction Debris Dump Sites shall not proceed until a NFA status is granted and the project area has been cleaned to the appropriate land use standard to the satisfaction of Department of Toxic Substances and Control (DTSC). The NFA status paperwork shall be submitted to the City in conjunction with the Building and Grading/Site work permit and shall be found acceptable by the City prior to ground disturbance. Less than Significant Impact 3.7-5: There are no schools located within a quarter mile of the project area. However, the proposed project includes construction of an 11 12 net usable acre school site that would be located adjacent to proposed residential uses. In addition, commercial businesses proposed within the project area would be required to comply with federal, state and local regulations regarding hazardous substances. Less than Significant No mitigation measures are necessary. Less than Significant Hydrology and Water Quality Impact 3.8-1: Portions of the proposed project and lower Less than Significant No mitigation measures are necessary. Less than Significant. Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-43 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance portion of the Base watershed are within the FEMA mapped floodplain. Future development would be required to comply with the existing floodplain regulations to ensure that structures do not impede or redirect flows. Impact 3.8-2: Construction- related activities resulting from implementation of the proposed project may result in the degradation of surface water quality. Less than Significant No mitigation measures are necessary. Less than Significant. Impact 3.8-3: The proposed project would not result in adverse impacts to the amount of available groundwater available, degrade groundwater quality, or decrease groundwater recharge in the project area. Less than Significant No mitigation measures are necessary. Less than Significant. Impact 3.8-4: Implementation of the proposed project would substantially increase the impervious surface area on the project site, thereby altering the existing drainage pattern and amount of surface runoff resulting in a potential increase Potentially Significant MM 3.8-4a: Construction of a new Off-site Detention Basin North of the Project SiteArea. Prior to the issuance of grading permits for Phase 2 of the proposed project, the project applicant shall work in coordination with the U. S. Army (Camp Parks) to design and construct a new off- site detention basin designed to ensure that flow rates to Line G-1 do not exceed the maximum Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-44 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance in peak storm water flows (i.e., 10- and 100-year storm events). Q100 discharge flow rate of 950 cfs as required by Zone 7. The design plans for this new off-site detention basin will be reviewed by the City, in coordination with Zone 7, for verification of compliance with all applicable regulations and consistency with on-site drainage requirements, prior to construction. MM 3.8-4b: Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the first grading/sitework permit associated with the construction of the proposed community park, the project applicant shall submit to the City for review and approval, plans, details, and calculations for the proposed underground stormwater detention structure(s) and associated storm drain system within the park parcel to ensure that adequate capacity will be provided; that the resultant discharge flow rates meet the requirements of the Regional Water Quality Control Board; and that the placement of the underground facilities in the park will not impact the park design and construction of recreational facilities. The location and layout of the underground detention structures and the connection of these facilities to the proposed Chabot Creek riparian channel, box culvert or downstream facilities shall be agreed upon by both the project applicant and the City. The method and location of stormwater discharge of the underground facilities shall be reviewed and approved by all appropriate regulatory and/or permitting agencies. a revised stormwater drainage plan that realigns the stormwater outflow associated with the proposed North Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-45 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance Basin #2 from the 1.7 acre Chabot Creek riparian channel (as is currently proposed) to a separate underground pipe that connects directly with the existing box culvert located at proposed Scarlett Court Extension and Dublin Boulevard, and thereby avoids stormwater discharge into the 1.7 acre Chabot Creek riparian channel. Impact 3.8-5: The proposed project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. Structures and personnel would not be subject to greater risk with implementation of the proposed project as compared to existing conditions. Less than Significant No mitigation measures are necessary. Less than Significant. Land Use and Planning Impact 3.9-1: The proposed project would result in the construction of 200,000 square feet of commercial uses, which would contribute to the economic vitality of the City, as well as result in the creation of indirect or induced jobs. Based on the City’s existing vacancy rate, the amount of taxable sales, and the population growth in the City, the additional commercial Less than Significant No mitigation measures are necessary. Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-50 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance would result in the need for or the construction of new or physically altered facilities to meet the City’s response times or other standards for fire protection services. Impact 3.11-2: The proposed project would not significantly increase the need for law enforcement services, which would result in the need for the construction of new or physically altered facilities in order to meet the City’s response times. Less than Significant No mitigation measures are necessary. Less than Significant Impact 3.11-3: Implementation of the proposed project would increase the number of students in the Dublin Unified School District (DUSD) with the construction of a maximum of 1,995 residential units, which would increase the capacity of the schools, which are operating above optimum capacity. The proposed project includes an 11 12 net usable acre school site and future development would be required to pay school impact fees as required under State law to the DUSD. Less than Significant No mitigation measures are necessary. Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-53 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance stormwater infrastructure, this would be considered a less than significant impact. Impact 3.11-9: Implementation of the proposed project would increase the generation of solid waste, but would be served by landfills with adequate capacity to accommodate the increase. Less than Significant No mitigation measures are necessary. Less than Significant Impact 3.11-10: The proposed project may result in the expansion of electricity, gas, and telecommunications on-site; however, the project site area is already served by these utilities and there is adequate infrastructure in place both on and adjacent to the project area to serve the proposed project. Less than Significant No mitigation measures are necessary. Less than Significant Transportation and Circulation Impact 3.12-1: During the PM peak hour, the study intersection of Dougherty Road and Amador Valley Boulevard would operate at an unacceptable LOS E under both 2020 background no project conditions and 2020 background plus project conditions. Potentially Significant MM 3.12-1: Addition of Northbound Left-Turn Lane on Dougherty Road. The proposed project shall add an additional northbound left-turn lane on Dougherty Road at the Dougherty Road and Amador Valley Boulevard intersection. Based on the 2020 background plus project conditions, the two northbound left turn lanes would need to be 325 feet each. This improvement would require widening Dougherty Road by approximately 12 Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-56 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance Because the impact is caused by future land use growth in the region as well as this proposed project, the mitigation for this impact is for the project to make a fair share monetary contribution toward these improvements. The timing of these improvements will be determined in the Mitigation Monitoring and Reporting Program and developer obligations will be outlined in the Developer Agreement. In the event that the grade separated crossing project cannot be constructed by year 2035, an alternative mitigation would be to eliminate the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. This would require pedestrians and bikes from the Iron Horse Trail to cross three crosswalks rather than one. Because of the effects of the alternative mitigation on pedestrian and bike mobility, the grade separated crossing is the City’s preferred mitigation at this location. Impact 3.12-4: During the PM peak hour, the study intersection of Iron Horse Parkway and Dublin Boulevard would degrade from LOS C under 2035 cumulative no project conditions to an unacceptable LOS F under 2035 cumulative plus project conditions. The City of Dublin level of service standard for this intersection is LOS D. Potentially Significant MM 3.12-4: Addition of a Northbound Left-turn lane on Iron Horse Parkway at the Intersection of Iron Horse Parkway and Dublin Boulevard. To mitigate the impact at the intersection of Iron Horse Parkway and Dublin Boulevard would require an additional northbound left turn lane on Iron Horse Parkway. Based on the 2035 cumulative plus project conditions, the two northbound left turn lanes would need to be 400 feet each. This improvement would require widening Iron Horse Parkway by approximately 12 feet along the east side in advance of the Less than Significant Dublin Crossing Specific Plan Final EIR Executive Summary Page ES-57 Project Impacts Level of Significance Without Mitigation Mitigation Measures Resulting Level of Significance intersection. It may also require removal of parking, realignment of travel lanes through the intersection, relocation of sidewalks, and traffic signal modifications. the removal of parking on the east side of Iron Horse Parkway, traffic signal modifications, and changing the travel lane configuration and alignment to create:  One 16-foot wide southbound receiving lane on Iron Horse Parkway;  Two 10-foot wide northbound left turn lanes on Iron Horse Parkway; and  One 14-foot wide northbound shared through-right turn lane. Because the proposed project causes the change in operation from LOS C to LOS F, the proposed project is responsible for constructing these improvements. The timing of these improvements will be determined in the project’s mitigation monitoring program. Impact 3.12-5: During the PM peak hour, the study intersection of Hacienda Drive and Dublin Boulevard would operate at an unacceptable LOS E under both 2035 cumulative no project conditions and 2035 cumulative plus project conditions. The City of Dublin level of service standard for this intersection is LOS D. Potentially Significant MM 3.12-5: Convert one of the through lanes to a second right turn lane at the Hacienda Drive and Dublin Boulevard Intersection. As part of the City of Dublin’s Traffic Impact Fee program, the intersection of Hacienda Drive and Dublin Boulevard has a planned northbound approach geometry of three left turn lanes, three through lanes, and one right turn lane. To mitigate the impact at the intersection of Hacienda Drive and Dublin Boulevard would require converting one of the through lanes to a second right turn lane, which is the existing northbound geometry at the Less than Significant Dublin Crossing Specific Plan Final EIR Project Description Page 2-2 consequences of implementation of the master plan for redevelopment of Camp Parks. The FEIS included consideration of the proposed project. In December 2007 the Army prepared a “Notice of Availability” to solicit a master developer for the Camp Parks Real Property Exchange Area. The Exchange Agreement provides the Army with an opportunity to modernize facilities through the provision of 180-acres of Army owned property (including the NASA parcel but excluding the 8.7-acre Alameda County Surplus Property Authority parcel), to a developer in exchange for Camp Parks facilities improvements. The Exchange Agreement is not a part of the Specific Plan but was necessary to facilitate acquisition of the property by the project developer. In October 2008, the Army announced the selection of the master developer for the Project. In April 2011, the project applicant and the U.S. Army officially finalized the Exchange Agreement, authorizing the project applicant to commence the Specific Plan process. 2.2 Regional Location The project area is located in the City of Dublin in northern Alameda County, near the center of the Tri Valley region. Regional access to the City is from Interstate 580, Interstate 680, and the Dublin/Pleasanton line of Bay Area Rapid Transit (BART). Cities that border Dublin include San Ramon to the north (in Contra Costa County), Pleasanton to the south and Livermore to the east. The regional location is shown in Figure 2-1: Regional Location. 2.3 Project Location The project area is centrally located in the City of Dublin, between the major urban areas of West and East Dublin. The project area is bound by a network of streets; 5th and 6th street to the north, Arnold Road to the east, Dublin Boulevard to the south and Scarlett Drive (with future extension) and the Iron Horse Regional Trail to the west. The project area would connect with the Iron Horse Regional Trail, which provides access to the Dublin/Pleasanton BART station, approximately one-third mile to the south. The project vicinity map is shown in Figure 2-2: Project Vicinity. The project area is generally flat and a significant portion is undeveloped. Two seasonal drainages traverse the project area, one north to south generally through the middle of the project area and another along the eastern border, parallel to Arnold Road. Existing Setting/Baseline Conditions The project area was historically used as grazing land prior to the installation of Camp Parks in the 1940s. The portion of the project area within Camp Parks is known as the “Cantonment” area. The project area contains former and/or existing supply buildings and warehouses, infrastructure maintenance facilities, vehicle Dublin Crossing Specific Plan Final EIR Project Description Page 2-6 the Environmental Impact Report. The City of Dublin and the project applicant have provided the following project objectives for the proposed project:  Ensure a long-term financially viable infill project that provides for the creation of new jobs, recreational opportunities, and expanded housing opportunities.  Create a community that is compatible in scale and design with surrounding land uses.  Create a project that has a fiscally-neutral impact on the City’s financial and services resources.  Create a community with a strong sense of place and a range of recreation and mobility amenities by designing a unique streetscape that will serve to tie the neighborhoods together with an integrated design theme.  Establish a cohesive community feel in the project area through the development and implementation of design guidelines that ensure consistency between individual neighborhoods while allowing unique architectural expression.  Provide sufficient land for the Dublin Unified School District (DUSD) to construct an elementary school within the project site.  Provide a new community park that will be the centerpiece of Dublin Crossing and serve as the focus for major social, cultural, and recreational events for the project, residents of Dublin, and the Tri-Valley region.  If the City of Dublin, the Dublin Crossing project developer and the County of Alameda come to an agreement on the transfer of the Alameda County Surplus Property Authority (ACSPA) property to either the City of Dublin or the Dublin Crossing project developer, include the 8.7-acre ACSPA parcel in the project area and plan for its full integration into the project design while maintaining the park acreage at some location within the project area.  Create a distinctive Dublin Boulevard with amenities and facilities that are consistent with the City of Dublin Streetscape Master Plan, Bikeways Master Plan, and the City of Dublin General Plan.  Provide a range of transportation choices; including walking, bicycling, and access to transit (BART and bus service), ridesharing, and vanpooling to reduce traffic congestion and greenhouse gas emissions.  Provide enhanced transportation amenities that encourage non-vehicular access to and on the Iron Horse Regional Trail, the Dublin/Pleasanton BART station, and to both on-site and adjacent commercial services.  Provide an east-west roadway through the project site area to enhance circulation between the points east and points west of the area. Dublin Crossing Specific Plan Final EIR Project Description Page 2-7  Construct one or more neighborhood parks that are conveniently located and serve as a focal point of recreation and neighborhood events.  Provide flexibility in land use regulations to allow for site constraints, variations in housing styles, and changing market conditions.  Provide a mixture of residential unit types appropriate to the projected housing needs as identified in the City of Dublin General Plan Housing Element.  Mitigate the unusual phasing impacts of the proposed project by ensuring that each phase (or combination of phases) can stand alone as a well- designed neighborhood with an adequate circulation network and an alternative transition between the proposed project and the remaining Camp Parks base.  Promote environmental stewardship through the inclusion of progressive energy programs and standards in construction and ongoing operation of residential and commercial buildings. 2.6 Proposed Land Uses and Development Plan The proposed project will redevelop the project area into a new, mixed-use community with residential, commercial, retail, and parks and open space land uses. Figure 2-9: Land Use Diagram shows the proposed land use designations at the project area. Development within the project area would be constructed according to the Dublin Crossing Specific Plan (Specific Plan). The Specific Plan is a planning document for the proposed project identifies the ultimate land use plan, circulation, infrastructure, and fiscal impacts on public services. The Specific Plan also includes a set of development regulations and design guidelines that will be referenced as part of all subsequent development reviews and approvals. The proposed project includes up to 1,995 residential units; 200,000 square feet of commercial uses, a 30-net acre community park (exclusive of the creek corridor); five acres of neighborhood parks; and provisional space for a 12 net usable acre elementary school site. The land use breakdown is included in Table 2-1: Dublin Crossing Specific Plan Land Use Breakdown. The land use diagram for the proposed project is shown in Figure 2-7: Conceptual Land Use Plan. An illustrative site plan, which is a conceptual plan for the proposed project is shown in Figure 2-8: Illustrative Site Plan. Dublin Crossing Specific Plan Final EIR Project Description Page 2-8 Table 2-1: Dublin Crossing Specific Plan Land Use Breakdown Land Use Total Acreage1 Permitted Density Total Development Potential Dublin Crossing Lower Medium Density Residential (DC LDRMDR) 41.9 6.0 – 14.0 units/net acre Up to 1,995 dwelling units.5 Dublin Crossing Medium-High Density Residential (DC M-HDR) 46.5 14.1 – 20 25 units/net acre Mixed Use (MU)2 13.2 20.1 – 60 units/net acre 0.25 to 1.0 FAR 75,000 to 200,000 gross square feet General Commercial/DC Medium Density Residential (GC/DC M- HDR)3 9.1 14.1 - 20 25 units/net acre 0.25 to 1.0 FAR General Commercial/DC High Density Residential (GC/DC HDR)3 9.9 20.1 - 60 units/net acre 0.25 to 1.0 FAR Park (P)4 30 n/a n/a Open Space (OS) 2.6 n/a n/a School (S)5 12 n/a n/a Roadways, Utilities, and other Infrastructure 23.8 n/a n/a Total Net Project Area Acreage 189 Notes: (1) Acreages are rounded to the nearest whole number. Net acreage is defined as the gross acreage less backbone street, public street, and right-of-way area. (2) The Mixed Use land use district shall contain a minimum of 75,000 gross square feet of commercial uses (with a maximum floor area ratio (FAR) of 1.0) and a 5 acre neighborhood park. In conjunction with an application that meets the commercial and park requirements above, residential uses are permitted with a density of up to 60 units/net acre. FAR applies only to commercial uses. (3) Can have commercial only, mixed-use, or residential-only uses. FAR applies only to commercial uses. (4) Park acreage is net usable acres. In the case of the 30 net-acre Community Park, the park is exclusive of Chabot Creek, the north-south drainage in the western portion of the project area. (5) Net usable acreage. The school site can be developed at the Dublin Crossing Lower Density Residential (DC LDR) use and density if the site is not utilized by the Dublin Unified School District and if the Specific Plan maximum of 1,995 residential units is not exceeded. The proposed project will be connected by a hierarchy of streets, trails, linked open spaces, and interconnected neighborhoods. Land uses will also visually and physically connected by circulation infrastructure, continuity of streetscapes, complementary design features, and by the nature of their compatibility. Land uses in the project area reflect the optimal type and mix necessary to achieve the vision of a livable and sustainable, transit-oriented urban village. The types of uses and transportation network proposed support transit-oriented development (TOD) for the Dublin/Pleasanton BART station, local transit service. It will also link to the Iron Horse Regional Trail and reinforce a stronger connection between West and East Dublin. Dublin Crossing Specific Plan Final EIR Project Description Page 2-9 Residential Neighborhoods The proposed project will contain 88.4 acres of residential neighborhoods accommodating up to 1,995 residential units with densities ranging from 6 to 20 25 dwelling units per net acre.  Dublin Crossing Lower Medium Density Residential (DC LDRMDR) has a density of 6 to 14 units per net acre;  Dublin Crossing Medium-High Density Residential (DC M-HDR) has a density of 14.1 to 20 25 units per net acre; and Three other non-residential land use districts and the school site also allow the potential for residential uses, some up to a maximum of 60 units per acre depending on the district. However, the maximum number of residential units allowed within the project area is 1,995 units, which includes any units in these non-residential land use districts. There will be a variety of housing types throughout the project area including single-family detached, single-family attached and multi-family units. They will be located to provide a logical transition from the existing high density residential development adjacent to the BART station and from the existing medium-density residential neighborhood east across Scarlett Drive. Residential density ranges within each residential neighborhood are allowed to provide flexibility of subdivision design and to adapt to changing future housing market conditions. Commercial Mixed Use The Mixed Use (MU) land use district is proposed for 13.2 acres at the northwest corner of Arnold Road and Dublin Boulevard. The Mixed Use land use district will contain a minimum of 75,000 and a maximum of 200,000 gross square feet of commercial uses (with a maximum floor area ratio (FAR) of 1.0) and a 5 acre neighborhood park. In conjunction with an application that meets the commercial and park requirements above, residential uses are permitted with a density of up to 60 units/net acre that is not included in the commercial FAR calculations. Residential-only uses are not permitted. Mixed-use can take the form of vertical mixed-use, horizontal mixed-use, or a combination of both. Vertical mixed-use is characterized by residential use above and adjacent to the base commercial. Horizontal mixed-use is characterized by residential use adjacent to the base commercial, as either attached or detached units, but the project is designed so that the residential and commercial uses are integrated and built simultaneously to function as a single project. Dublin Crossing Specific Plan Final EIR Project Description Page 2-10 Typical permitted commercial uses include a variety of eating and drinking establishments, hotel, entertainment, retail stores, bank branches, bookstores, markets, personal and professional services, and office uses. A five acre Neighborhood Park will be located north of the commercial uses and will be designed in concert with the surrounding development. A gateway plaza located at the northwest corner of Dublin Boulevard and Arnold Road will create a public focal point along Dublin Boulevard. This gateway plaza will include generous landscape and hardscape treatment around a water feature with trellises and seating areas to encourage activation of the space. A second plaza is envisioned in an internal courtyard between the commercial and/or mixed-use buildings. This plaza will feature a smaller water feature, and possibly an outdoor eating area for restaurants. Accent planting in pots and planters will be located throughout the interior plaza to provide color. These plazas will be constructed concurrent with the commercial and/or mixed-use development. General Commercial/Dublin High Density Residential (GC/DC M-HDR) General Commercial/Dublin Crossing Medium-High Density Residential (GC/DC M- HDR) is proposed for 9.9 acres on the periphery of the project area along Dublin Boulevard, as shown in Figure 2-7, Conceptual Land Use Plan. Uses allowed in this district are commercial, mixed use (as described in the MU land use district above), and residential. In combination with the Mixed Use land use district (which will contain a minimum of 75,000 square feet of commercial uses), the GC/DC M-HDR land use district can contain an additional 125,000 of commercial uses, up to a Specific Plan area total of 200,000 square feet. The maximum floor area ratio (FAR) of commercial uses in the district is 1.0 and the maximum density for residential development in the land use district is 60 25 units/net acre. Residential uses do not count toward the commercial FAR limits. General Commercial/Dublin Medium Density Residential (GC/DC MDR) To provide flexibility to accommodate future market conditions and City housing needs, a combination land use district is proposed for areas along Arnold Road – north of the Mixed Use land use district. General Commercial/Dublin Crossing Medium Density Residential (GC/DC MDR) is proposed for 9.1 acres on the periphery of the project area along Arnold Road, as shown in Figure 2-7, Conceptual Land Use Plan. Uses allowed in this district are commercial, mixed use (as described in the MU land use district above), and residential. In combination with the Mixed Use land use district (which will contain a minimum of 75,000 square feet of commercial uses), the GC/DC MDR land use district can contain an additional 125,000 of commercial uses, up to a Specific Plan area total of 200,000 square feet. The maximum floor area ratio (FAR) of Dublin Crossing Specific Plan Final EIR Project Description Page 2-11 commercial uses in the district is 1.0 and the maximum density for residential development in the land use district is 20 units/net acre. Residential uses do not count toward the commercial FAR limits. Parks, Open Space, and Public Facilities The project area contains a total of 73.4 acres of land designed for public use which includes parks/open space (including the five acre neighborhood park within the Mixed Use land use district), an elementary school site, and public roadways. Central Park and Iron Horse Regional Trail Realignment Located at the crossroads of Dublin Boulevard, Scarlett Drive and the Iron Horse Regional Trail is the proposed 30 net usable acre Dublin Crossing Central Park (Central Park). The Central Park is envisioned as an innovative and uniquely designed community gathering place for the residents of Dublin Crossing and the broader community of Dublin. The Central Park will provide high-quality recreational amenities for both passive and active recreation and civic events (e.g., festivals, farmer’s market, art shows, etc.). Amenities could include an amphitheater, organized and informal sports fields, sport courts, restrooms, walking paths, parking, a community garden, demonstration vineyards, play areas, picnic grounds, a carousel, a rose garden, and possibly a museum. Chabot Creek extends north to south along the eastern side of the proposed Central Park. This channel has intermittent seasonal flows and provides regional drainage from Camp Parks (to the north) and eventually flows under I-580 and into the Chabot channel. This channel will be relocated and grade contoured as a natural riparian corridor and could include a multi-use trail with staggered observation lookouts and interpretive signage and will be located adjacent to the eastern border of the Central Park. The daylit section of the riparian corridor is not included in the net usable park acreage total. Two underground onsite storm drainage detention basins (sized at 1.5 and 3.0 acre-feet) will be constructed within the Central Park. A gateway plaza at the southeast corner of Central Park at the visually prominent corner of Dublin Boulevard and the future extended Scarlett Drive will serve as the primary entrance into the park. The Dublin Boulevard frontage will create an opportunity for a strong visual civic statement at a key central location within the City. The gateway plaza will include a large signage treatment and significant landscaping, seating and other street furniture and a sculptural element(s). The Iron Horse Regional Trail will be reconfigured with the new project frontage and Scarlett Drive, and a secondary trail pathway will be integrated along the southwestern edge of the Central Park. Associated uses adjacent to the secondary trail pathway through the park could include a café/concession, bicycle racks, wayfinding signage, lighting, restrooms, and landscaped gardens. Dublin Crossing Specific Plan Final EIR Project Description Page 2-12 Neighborhood Parks The five net-acre Neighborhood Park will be located within the Mixed Use land use district. The amenities and facilities within the park will depend to a great deal on the land use adjacencies, so therefore design details in the Specific Plan have been limited. The intent is to create a Park Master Plan that is highly responsive to the surrounding uses, land use pattern, and neighborhood needs. School The proposed project provides an opportunity for the Dublin Unified School District (DUSD) to acquire 12 net usable acres of land for a public elementary school site which is designated as School (S) on Figure 2-7: Conceptual Land Use Plan. This elementary school will be designed to accommodate up toapproximately 900 children and will may include classrooms, a gymnasiummulti-purpose room, administrative offices, a multi-use sports field, sport courts, a playground, and parking. The school site will have an overlay designation of Dublin Crossing Lower Medium Density Residential (DC LDRMDR). In the event that DUSD does not acquire the site, residential uses will be allowed in accordance with the DC LDR MDR land use district, development standards, and design guidelines contained in the Specific Plan. 2.7 Site Access and Circulation Vehicular Circulation Regional and Local Circulation  Interstate Highways – Interstate Highway access to the Specific Plan area is provided by I-580 and I-680. I-580 runs south of the Specific Plan area and connects to I-680 and I-880 to the west and I-5 to the east. I-680 runs west of the Specific Plan area and connects to the northerly cities of San Ramon, Danville, Walnut Creek and Concord and the southerly cities of Fremont, Milpitas, San Jose, and Silicon Valley.  Dublin Boulevard – Dublin Boulevard is the main east-west arterial that runs through the city and is the southern boundary of the Specific Plan area. Dublin Boulevard provides access to the Dublin/Pleasanton and West Dublin/Pleasanton BART stations and commercial, office, and residential areas in the downtown and West and East Dublin. Dublin Boulevard has an existing bikeway network consisting of Class I bike paths and Class II bike lanes. Livermore-Amador Valley Transit Authority (Wheels) bus transit service and a bus rapid transit (BRT) line run along Dublin Boulevard.  Arnold Road – Arnold Road is a local roadway extending north from Dublin Boulevard into Camp Parks. Existing office buildings are located on the east side of the roadway. The City of Dublin has future plans for a Class I bike path Dublin Crossing Specific Plan Final EIR Project Description Page 2-13 along one side of the road at the Dublin Boulevard and Arnold Road intersection, which will connect to an existing Class II bike lane on both sides of the street.  Scarlett Drive – Scarlett Drive is a local roadway located along the west side of the Specific Plan area. The current alignment terminates at Houston Place and picks up again at Dublin Boulevard. To implement the City’s existing approved Capital Improvement Plan street network it is anticipated that the Specific Plan development will provide for construction of the planned extension of Scarlett Drive from Houston Place to Dublin Boulevard, adjacent to the Iron Horse Regional Trail. Internal Circulation A grid pattern of streets, each with different character and function, will serve the transportation needs of the proposed project. The internal “backbone” street system is designed to establish connections to the existing exterior roadway network as well as internally between residential neighborhoods, parks, open spaces, a potential elementary school site, and business/commercial areas. With sidewalks on all public streets, and bikeways on many, these backbone streets will become the framework for the pedestrian and bicycle network that connect to uses both internally and beyond the project area. This internal circulation network will also allow for adequate and safe pedestrian, bicycle, and vehicle access and drop off to the school site. Internal roadway classifications include Collector Streets, Local Streets, and Private Streets, each of which is described below. The proposed backbone street network is shown in Figure 2-9: Proposed Backbone Street Network. Collector Streets Collector Streets will serve as the primary conduits for interior neighborhood traffic and provide access to and from neighborhood residential streets and perimeter streets outside of the project area. These streets are not intended to support regional traffic, but they may provide direct access to schools and parks. Collector Streets include B Street, Central Parkway, and G Street, as well as the future extension of Scarlett Drive. Local Streets Local Streets will provide direct multi-modal access to neighborhoods by residents and visitors while discouraging through traffic and high speeds. Local Streets are intended to provide low-speed access between and within neighborhoods, promoting a multi-modal network with an emphasis on comfort, safety, and amenities for pedestrians and bicyclists. Private Streets Private Streets will be privately owned and maintained streets that provide access to common interest subdivisions (future development subdivisions) and Dublin Crossing Specific Plan Final EIR Project Description Page 2-14 commercial and mixed-use developments. Private Streets will be designed for a low volume of traffic with limited vehicular access. Private Streets may be narrower than public residential streets and may or may not include sidewalks, on-street parking, or other street features. Pedestrian and Bicycle Circulation The project area is adjacent to and will be connected with the Iron Horse Trail which is the longest trail system in Alameda and Contra Costa counties. The Iron Horse Trail provides a direct link with the Dublin/Pleasanton BART station, located one-quarter of a mile south of the project area. The proposed project would also include a pedestrian trail adjacent to Dublin Boulevard that would connect to the existing trail corridor, as well as sidewalks and bicycle paths throughout the project area. Public Transportation The proposed project would be served by the Bay Area Rapid Transit (BART) and the Livermore-Amador Valley Transit Authority (Wheels).  BART – BART is the regional rail service in the San Francisco Bay Area, with stations and stops throughout the greater Bay Area, including the Dublin/Pleasanton and West Dublin/Pleasanton stations. The Dublin/Pleasanton BART station is located approximately a quarter mile south of the Specific Plan area.  Livermore-Amador Valley Transit Authority (Wheels) – The Livermore- Amador Valley Transit Authority provides services in Dublin and the Tri- Valley area via Wheels, which provides local, regional, and paratransit bus service. Nearby stops are located along Dublin Boulevard and at the Dublin/Pleasanton BART station. The project proposes to provide new bus shelters along Dublin Boulevard. 2.8 Infrastructure Improvements Storm Drain Infrastructure The Camp Park’s entire 1,800+ acreA majority of the Camp Parks watershed drains through the project area. The majority of the runoff from this watershed is conveyed through Camp Parks in natural and man-made swales. These swales cross the project area and are intercepted along the north side of Dublin Boulevard and conveyed to various existing Zone 7 drainage facilities. The main drainage channel for runoff from Camp Parks crosses the project area and is currently a mapped FEMA 100-year floodplain as shown in Figure 2-10: FEMA Flood Zone. To the northeast and east of Camp Parks, runoff is collected in an existing channel and conveyed south along Arnold Road. Near Arnold Road and Central Parkway, a flow “splitter” divides flow between two existing Zone 7 drainage facilities. A portion of this flow continues down Arnold Road, while the remainder is conveyed Dublin Crossing Specific Plan Final EIR Project Description Page 2-15 in an existing trapezoidal channel across the southeastern portion of the project area. Two underground onsite storm drainage detention basins (sized at 1.5 6 and 3.0 3 acre-feet) will be constructed within the Central Park to accommodate a range of 10 percent of the 2 year storm flows to the 10 year storm flows. The basin size reflects the bottom dimensions of the proposed basins with 3:1 slopes. An offsite basin (sized at 76 acre-feet) to meet the 950 cfs maximum requirement is proposed north of the Specific Plan area along the existing drainage channel. Additionally, best management practices (BMPs) shall be implemented in new developments within the project area to ensure that runoff in storm drains does not lower water quality within or outside of the project area. Refer to Figure 2-11: Conceptual Stormwater Drainage and Detention System. Wastewater The wastewater collection, treatment, and disposal services provider for the project area will be provided by the Dublin San Ramon Services District (DSRSD). DSRSD provides wastewater collection and treatment at the Regional Wastewater Treatment Facility located in the City of Pleasanton. Several existing sanitary sewer mains currently convey wastewater through and around the project area. These sewer mains will be rerouted through the project area as required to accommodate phased development (see Figure 2-12: Conceptual Sanitary Sewer System). Wastewater generated from the proposed project would be collected and conveyed through a conventional gravity system of pipes located within the new street network. The onsite wastewater system will connect to the existing DSRSD sewer conveyance facilities surrounding the site. Potable Water Supply Infrastructure The DSRSD owns and operates potable water system within the boundaries of Camp Parks including the project area. They also maintain potable water facilities in the streets adjacent to Camp Parks, including Dougherty Road, Scarlett Drive, Dublin Blvd. and Arnold Road. Several existing water mains currently traverse the project area providing service to existing buildings through a looped water system. As shown in Figure 2-13: Conceptual Potable Water System, these water mains will be rerouted through the project area as required to accommodate phased development. Recycled Water The DSRSD produces and distributes recycled water for landscape irrigation in Dublin as part of its Potable Water Conservation and Water Recycling Program. Except for certain isolated locations, all new irrigation systems serving parks, streetscapes, and common area landscaping for multi-family or commercial Dublin Crossing Specific Plan Final EIR Project Description Page 2-17  Former Building 109/Parks Reserve Forces Training Area (PRFTA) 2 - Former Building 109/PRFTA 2 located at the southwestern portion of the project area containing concentrations of dioxin and lead within the surficial soil above the acceptable risk-based screening levels for closure. The contamination was remediated by the U.S. Army and cleaned to industrial standards. There are currently groundwater monitoring wells at this site and the U.S. Army has completed three quarters of sampling in coordination with the Department of Toxic Substances and Control (DTSC). The U.S. Army is awaiting confirmation from the regulatory agencies regarding the remediation of this site (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013 and September 17, 2013).  Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of the project area and requires land use controls by the San Francisco CRWQCB to obtain an NFA status. The CRWQCB San Francisco RWQCB issued a Pre-NFA determination on May 28, 2008. This determination acknowledged that groundwater cleanup objectives have been met. However, a deed restriction (land use control) is required to achieve a full NFA designation due to the presence of soil which contains diesel concentrations greater than acceptable levels. The Department of Toxic Substances Control (DTSC) concurred with these findings in January 20, 2012.  Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern portion of the potential construction debris dump sites consists of large mounds of soil and debris north of Dublin Boulevard and east of the installation entrance road. Construction and demolition debris, asbestos containing material (ACM), waste asphalt, drill cuttings, and grass clippings were observed in the mounds during site visits conducted from 1990 through 2002. DTSC stated that the area may need further investigation prior to receiving an NFA. Soil samples revealed that there were high hydrocarbons in the soil. The soil has been removed and re-sampled with negative results and have been subsequently submitted to DTSC for review (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013). In addition, many of the existing structures located within the project area that would be demolished contain Asbestos Containing Material (ACM) and Lead Based Paints (LBPs). Contamination that remains after the U.S. Army or NASA transfers the property to the project applicant will either be remediated by the project applicant or by the U.S. Army or NASA, prior to and during site grading and demolition activities with future development activities. Dublin Crossing Specific Plan Final EIR Project Description Page 2-18 2.10 Project Phasing Phasing Plan Development of the project area will include five development phases, with anticipated build-out occurring over a period of approximately eight to twelve years. Ultimate development timing will depend on market demands, U.S. Army contracts, and according to an orderly extension of roadways, infrastructure, public services, and utilities, and the provision of parks, recreational facilities, school, and other public amenities. Figure 2-15: Conceptual Phasing Plan and Table 2-2: Phasing Plan identifies the proposed phasing plan for development within the project area. The development phases shall occur sequentially, although portions of phases may occur concurrently. Development of each phase shall include all infrastructure, services, facilities and amenities, both public and private, needed to serve the uses and structures within that phase in accordance with the Specific Plan. Development of each phase will result in a project that could “stand alone” if future phases were not constructed. It is anticipated that each phase may include sub-phases which may result in multiple Final Maps. Table 2-2: Phasing Plan Project Phase Gross Area 1 Maximum Number of Residential Units Maximum Amount of Commercial Square Footage 1 33 570 - 2 54 421 75,000 3 48 435 50,000 4 26 156 75,000 5 28 413 - Total 189 acres Up to 1,995 residential units Up to 200,000 Commercial SF Source: Dublin Crossing, LLC 2.11 Requested Actions, Entitlements, and Required Approvals Initial entitlements required for future development in the Specific Plan area include the following actions to be taken by the Dublin City Council:  EIR Certification: Certification of the Dublin Crossing Specific Plan Environmental Impact Report (EIR), including findings that identify significant environmental impacts of the Project and mitigation measures that must be implemented as part of the Project, which will be reflected in the Mitigation Monitoring and Reporting Program (MMRP) and imposed as conditions of approval on subsequent discretionary approvals. This action will be adopted by resolution. Dublin Crossing Specific Plan Final EIR Aesthetics and Visual Resources Page 3-11 Degradation of the Visual Character of the Project Area and Surrounding Area Impact 3.1-2: Implementation of the proposed project would alter the existing aesthetic character of the project area by redeveloping the project area with residential, commercial and mixed-use development. However, the project area has been partially disturbed as part of its use as the Camp Parks Reserve Forces Training Area. In addition, the proposed Specific Plan includes development standards and design guidelines that are designed to create a more visually appealing environment within the project area. Therefore, the proposed project is not anticipated to degrade the visual character of the project area and surrounding uses and is therefore considered a less than significant impact. The project area contains approximately 62 acres of developed land, which is primarily located in the western portion of the project area and includes 18 buildings, which are currently used for installation operations, academic activities, administration, equipment storage and maintenance for Camp Parks. Buildings are interspersed with open areas, which consist of primarily non-native grasslands. The proposed project would result in the conversion of the project area from partially developed land to urban uses, which would change the existing views to and from surrounding properties and roadways. As shown in the Figure 2-7: Conceptual Land Use Plan and Figure 2-8: Illustrative Site Plan, the proposed project includes development of up to 1,995 residential units; 200,000 square feet of commercial uses, a 30 net-acre community park, five acres of neighborhood park, and a 12 net usable acre elementary school site, which would be developed within five phases over ten years. Figures 3.1-1a, 3.1-1b and 3.1-1c: Visual Simulations illustrate future development of the project area from Dublin Boulevard, Scarlett Drive and the Iron Horse Regional Trail, and Arnold Road including the construction of buildings and the installation of new landscaping (e.g. trees) within the project area1. As shown in the visual simulations, development of the proposed project would further urbanize the project area and would slightly detract the viewer from these distant views of the hills along these roadways. However, the project area is partially degraded and the views have already been compromised because portions of the project area were previously developed associated with the Camp Parks. The proposed Specific Plan includes both development standards and design guidelines to guide site design, architecture, circulation, parking, lighting, and other distinguishing features. The design guidelines will address overall building design 1 The visual simulations are for illustrative purposes and building heights could be higher than what is shown in the simulations. Dublin Crossing Specific Plan Final EIR Aesthetics and Visual Resources Page 3-12 (e.g. siting, architectural details), building articulation, building massing, indoor- outdoor relationship, building materials, colors, and finishes, base and top treatments, entry designs, windows and doors, roofs, mechanical equipment and utilities, service, storage and loading areas, perimeter walls and fences, onsite public art, and exterior lighting. These development standards and design guidelines will also be used during the design review process to guide future development. Building heights associated with the proposed project would range from a maximum height of 40 feet and three stories for the DC Lower Medium Density Residential (DC LDRMDR) and DC Medium Density (DC M-HDR) land use districts to 75 feet and six stories for the General Commercial/DC Medium-High Density Residential (GC/DC M-HDR) and General Commercial/DC High Density Residential (GC/DC HDR) land use districts. The overall change in the visual character of the project area from a partially developed area to more urban and suburban land uses would result in a permanent change in the character of the project area. However, the project area is surrounded by primarily by urban uses and would be of high quality design, which would complement the surrounding uses. Therefore, implementation of the proposed Specific Plan would help ensure that properties and buildings contribute to visually appealing neighborhoods, commercial areas, parks and environments and would not result in the degradation of the visual character of the project area and surroundings. Therefore, the proposed project would be considered a less than significant impact, and no mitigation is required. Light and Glare Impact 3.1-3: The project area and its surroundings are currently developed with some buildings and site improvements that were part of the Camp Parks facility, which generate daytime and night-time light and glare. Additional sources of daytime glare and nighttime lighting would be introduced through build-out of the Specific Plan. The proposed Specific Plan includes development standards and design guidelines to reduce light and glare. This is considered a less than significant impact. Implementation of the proposed project would introduce new development within the Specific Plan area, increasing the potential for daytime and nighttime light and glare. The main sources of daytime glare would be from sunlight reflecting from structures with reflective surfaces, such as windows. The main sources of nighttime light and glare would be from additional lighting, including, but not limited to, internal and external building lights, parking lot lights, street lighting, site lighting, lights associated with vehicular travel (i.e., vehicle headlights), and any new security lighting associated with future development. The proposed Specific Plan includes design guidelines that address lighting in the project area, including, but not limited to the following: Dublin Crossing Specific Plan Final EIR Air Quality Page 3-35 Threshold Exceeded ? Yes Yes Yes No Notes: 1. Emissions estimates calculated using CalEEMod. 2. Area source mitigation includes the use of low VOC paints and only natural gas hearths, which are proposed for the project. Refer to Appendix B, Air Quality and Greenhouse Gas Data, for detailed model input/output data. Energy Source Emissions Energy source emissions would be generated as a result of electricity and natural gas (non-hearth) usage including space heating and cooling, water heating, ventilation, lighting, appliances, and electronics. Mobile Source Emissions Mobile sources are emissions from motor vehicles, including tailpipe and evaporative emissions. According to the Traffic Impact Analysis prepared by Hexagon in 20122013, the proposed project would generate 19,64122,047 net new daily vehicle trips. Project-generated vehicle emissions were calculated using the CalEEMod model and are shown in Appendix B. This model was utilized to predict ROG, NOX, and PM10 emissions from motor vehicle traffic associated with the proposed project based on the trip generation in the iTraffic Impact Analysis. As shown in Table 3.2-6: Proposed Project Long-Term Operational Emissions, unmitigated mobile source emissions generated by vehicle traffic associated with the proposed project would not exceed established BAAQMD thresholds for PM2.5, but would exceed thresholds for ROG, NOX, and PM10. The proposed project includes project design features that would reduce potential mobile source emissions. Section 3.0 (Design Guidelines) of the Dublin Crossing Specific Plan provide the basis for development that includes increased density and diversity, improved walkability design, increased destination and transit accessibility, improved pedestrian network, limited parking supply, traffic calming measures, and trip reduction, ride sharing, and employee vanpool programs, which were applied in CalEEMod air quality model; refer to Appendix B, Air Quality and Greenhouse Gas Data for a description of model inputs and design features/mitigation measures. Total Emissions As shown in Table 3.2-6: Proposed Project Long-Term Operational Emissions, the total unmitigated operational emissions associated with build-out of the proposed project would exceed BAAQMD thresholds for ROG, NOX, PM10, and PM2.5. Stationary source emissions would be reduced with compliance with BAAQMD Regulation 6, Rule 3 (Wood-Burning Devices), which restricts wood burning and places limits on excessive smoke. However, as indicated in Table 3.2-6: Proposed Project Long- Term Operational Emissions, mobile source emissions are the largest contributor to the estimated air pollutant levels. Due to the scale of the proposed project, which would generate 19,64122,047 new trips per day, emissions would exceed the BAAQMD thresholds. As described above, the proposed project is a mixed use project in proximity to the Dublin/Pleasanton BART station and associated transit Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-47 3.3 Biological Resources Several sensitive biological resources are known to occur or have the potential to occur within and adjacent to the project area as identified during biological studies and surveys that were conducted as part of the Master Planned Development at the Camp Parks Reserve Forces Training Area between 1995 and 2003. Several of these sensitive biological resources have the potential to be affected by the proposed project. Therefore, this section describes the existing biological resources within and adjacent to the project area; assesses the potential impacts to these biological resources associated with the proposed project; and recommends mitigation measures for impacts that are considered significant under Federal, State and Local policies and regulations, including, but not limited to, the Clean Water Act (CWA), the Federal Endangered Species Act (ESA), the California Endangered Species Act (CESA), the California Environmental Quality Act (CEQA), and City of Dublin Ordinances. Cardno Entrix prepared a biological resource technical report on behalf of the project applicant in May June 2013, which updates previous biological technical studies that were prepared by the U.S. Army for the Final Environmental Impact Statement on Master Planned Redevelopment at Camp Parks (U.S. Army 2009). This technical report was peer reviewed by RBF Consulting for technical accuracy and is included as Appendix C. Environmental Setting In addition to approximately 77 acres of the developed and semi-developed land withinportions of the project area surveyed by Cardno Entrix, two other vegetation communities are located within the project area: wetlands and non-native grasslands are also located within the project area. The acreage of these vegetation communities is shown below in Table 3.3-1: Habitats and Vegetation Communities within the Project Area and on Figure 3.3-1: Existing Biological Habitats. Table 3.3-1. Habitats and Vegetation Communities within the Project Area Habitat Vegetation Community Acreage Wetlands and Other Waters 2 1.61 Acres Non-native grassland 105 104.32 Acres2 Developed, or semi-developed 77 73.66 Acres1 Total 183 179.59 acres Notes: 1. Includes buildings, roadways, and landscaped areas. Approximately 62 acres are impervious. Source: Cardno Entrix 2013 Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-48 The Alameda County Surplus Property portion of the project area was surveyed as part of the Dublin Transit EIR and is comprised of non-native grassland. The EIR was certified by the City Council on November 19, 2002. Based on the analysis completed in the Dublin Transit Center EIR, the Alameda County Surplus Property was not found to contain any special status species or significant biological features (e.g. wetlands), etc. Wetlands and Other Waters Drainage Ditches There are seven drainage ditches within the project area as shown in Figure 3.3-2: Preliminary Wetlands and Other Waters. All are manmade features created to channel runoff away from various parts of the project area. These drainage ditches were either dry or were saturated due to recent rains at the time of the survey conducted by Cardno Entrix in March 2012, but did not contain standing water and did not appear to be subject to high-velocity flows as there was no scour or distinct bed and bank. Based on the vegetation present, these features function as intermittent drainages to channel runoff during rain events. Individual descriptions of the ditches are provided below. Ditch 01 is a shallow roadside drainage ditch designed to carry flows from an asphalt pad and adjacent paved roads in a southern direction along Keppler Avenue, before entering a culvert under the road, and flowing north of 5th Street into a culvert east of Hutchins Avenue to Chabot Canal (Canal 01). The majority of the ditch is dominated by annual grassland vegetation including brome species, yellow star thistle, and stinkwort, and lacked evidence of hydrology or an ordinary high water mark. A portion of the drainage ditch has begun to fill in with sediment along Keppler Avenue near 5th Street; this portion is discussed as Wetland Drainage Ditch 01 in Wetland Drainage Ditches below. Ditch 02 is a drainage ditch designed to flow in a southern direction from 6th Street, becoming progressively deeper before tying into Chabot Canal (Canal 01) at approximately the ordinary high water mark. The majority of the ditch is dominated by annual grassland vegetation and lacks an ordinary high water mark. An existing culvert allows for vehicle access over the ditch into an industrial yard approximately 155 feet south of 6th Street. This drainage appears to receive sheet flow from the adjacent roadway, and developed areas, as well as seasonal irrigation runoff from landscaping to the west and lacks an OHW, scour, or evidence of high flows. Ditch 03 begins north of 4th Street near Hutchinson Avenue, and flows west towards Chabot Canal, becoming progressively deeper before tying into the Canal at approximately the ordinary high water mark. This drainage ditch is dominated by annual grassland vegetation and lacks an ordinary high water mark, scour, or evidence of high flows. The drainage is encased in existing culverts, each Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-49 approximately 100-feet long, in two areas. This drainage appears to receive sheet flow from Hutchison Road, 4th Street, and the adjacent annual grasslands. Ditch 04 consists of a very shallow, poorly drained portion south of 4th Street, a maintained ditch flowing north to south that intersects with an east to west flowing segment that eventually discharges into Ephemeral Drainage 01. This ditch exhibits variable vegetation and hydrology. In three locations (Wetland Drainage Ditch 02, 03 and 04) the ditch is shallow and poorly drained and has developed wetland indicators that are discussed in more detail below. The north to south flowing portion near 4th Street is maintained through dredging of sediment, vegetation removal, and grading to maintain flows and prevent stormwater from ponding on 4th Street. Further south the ditch was used to direct water away from temporary facilities on an adjacent concrete pad, and existing drainage pipes from the pads to the ditch were observed. The southern portion of the ditch no longer appears to receive maintenance and does not have positive flow towards Chabot Canal during low flow events resulting in stormwater ponding in Wetland Drainage Ditch 04 (discussed below). Ditch 05 is a shallow roadside ditch that may have originally overtopped into Canal 02, but does not appear to receive sufficient flows to exhibit wetland characteristics or evidence of an ordinary high water mark. No surface water connection to Canal 01 or Canal 02 was observed. Ditch 06 is an incised feature south of a industrial yard that flows to Chabot Canal that exhibits evidence of intermittent flow, and is dominated by non-native grassland species and canary grass (Phalaris minor). Ditch 07, is a section of open ditch that transfers water from storm drain pipe draining road runoff from Dublin Boulevard into Chabot Canal. Wetlands and Drainage Ditches In four locations, the above described drainage ditches pond water for a sufficient period of time to develop hydric soils, a dominance of hydrophytic vegetation, and exhibit primary or secondary hydrology indicators for wetlands. These areas are indicated as Wetland Drainage Ditch 01, 02, 03, and 04 as shown in Figure 3.3-2: Preliminary Wetlands and Other Waters. Soil samples SP6 and SP8 that were conducted by Cardno Entrix exhibit typical wetland indicators observed within the wetland drainage ditches. These samples were taken in depressions and/or poorly drained locations within the manmade drainage ditches. These areas were dominated by a variety of facultative wetland or obligate wetland plants species, such as tall flatsedge (Cyperus eragrostis), Baltic rush (Juncus balticus), western dock (Rumex occidentalis), and common spikerush (Eleocharis macrostachya) and exhibited depleted or gleyed soils. Hydrology indicators included ponding water, saturation, or surface soil cracks. Wetland Drainage Ditch 01 appears to have formed due to a blocked culvert in roadside drainage ditch, while Wetland Drainage Ditch 02, 03, and 04 are the result of poor Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-50 flow due to low initial grade or sediment buildup in manmade drainage ditches. All associated drainage ditches flow to Chabot Canal. Ephemeral Drainage A portion of drainage ditch between Camp Parks Boulevard and Chabot Canal displays evidence of an ordinary high water mark with minor shelving and rilling and receives intermittent flows. The ditch is dominated by upland grasses, but was observed ponding at a higher frequency then adjacent drainage ditches. This drainage connects Drainage Ditch 04 to Chabot Canal and is approximately 905 feet (0.288 29 acres). Canal Other waters of the U.S. include Chabot Canal (Canal 01), and an unnamed canal (Canal 02). Both canals are Canal 01 is an ephemeral features with water marks/staining and drift deposits indicating the ordinary high water mark. This ordinary high water mark was used to delineate the edge of the feature. Margins of Canal 01 were dominated by Harding grass (Phalaris aquatica) and canary grass. Canal 02 is a maintained concrete lined channel with evidence of flow, but dominated by ruderal vegetation and mowed/maintained annual grasses. These features appear to be improved flood control channels, designed to convey high flows during rain events and have steep sides that extend well past the ordinary high water mark. Chabot Canal (Canal 01), exhibited minor scouring in areas that appear to be from frequent low flows, and shelving in the southern section due to higher flows. Indicators of hydrology range from ponding and saturation to water stained leaves and drainage patterns. Vegetation with Chabot Canal ranges from emergent vegetation such as cattails, rushes and sedge in the southern section, to a small area of riparian vegetation in the central portion, to mowed or cleared vegetation with a shallow low-flow channel and annual grassland margins in the northern section. Chabot Canal is primarily a vegetated canal, but is concrete lined at the southern perimeter of the project area and has rip-rap and/or concrete at culverts and where existing storm drain systems outfall into the Canal. The Canal receives nuisance flows from existing storm drain systems and manmade drainage ditches throughout the project area, and conveys off-site flows from north of the project area through the area into the City of Dublin storm drain system. Canal 02 consists of a concrete and riprap-lined low-flow channel, and margins are dominated by immature annual grasslands and ruderal vegetation. Canal 02 appears to conveyed flows from a historic creek in the Tassajara Regional Park as well as stormwater flows from developed areas to the northeast of the project area. Through the project area a portion of this feature has been previously incased and consists of underground drainage facilities. The majority of flows appear to be diverted into an encased storm drain system at the southeastern edge of the project area. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-51 Emergent Wetland Two emergent wetlands (Emergent Wetland 01, Emergent Wetland 02) located west of Chabot Canal, were dominated by cattails, stinkwort, curly dock, and canarygrass, and exhibited gleyed sandy clay soils. Both features exhibited primary hydrology indicators including saturation, surface water, water marks and/or water-stained leaves. These features are a direct result of a leaking potable water pipeline containing chlorinated and fluoridated water, and owned by the Dublin San Ramon Services District, and as such would not typically be considered jurisdiction wetlands by the USACE. Seasonal Wetland A 0.092 024 acre marginal seasonal wetland feature is located north of 3rd Street and east of Fernandez Boulevard, which is dominated by non-native facilitative wetland plants consisting primarily of common plantain (Plantago lanceolata) and seaside barley (Hordium Marinum). This feature lacked hydrology and was dry during two of three wet season site visits. Soils are fill material and lack strong hydric indicators. The feature is adjacent to intermittent Drainage Ditch 01. Potential Section 404 Jurisdictional Wetland and Other Waters Based on the area delineated, approximately 1.605 61 acres of potentially jurisdictional wetlands and Other Waters were identified within the project area, including 0.103 11 acres of wetland drainage ditch, 0.092 24 acres of seasonal wetland, and 1.409 27 acres of other waters of the U.S. These features appear to be subject to the United States Army Corps of Engineers’ (USACE) jurisdiction pursuant to the Clean Water Act for the following reasons:  1.409 27 Acres of Other Waters: Chabot Canal (Canal 01) and Canal 02 areis an ephemeral surface tributaries to Alamo Creek, which is a relatively permanent water. Ephemeral Drainage 01 is a tributary to Chabot Canal that displays and ordinary high water mark(OHW).  0.196 24 Acres of Wetlands: The seasonal wetland and wetland drainage ditches meet the USACE’s three-parameter wetland criteria (hydrophytic vegetation, hydric soils, and wetland hydrology); and are hydrologically linked to Chabot Canal, thus, the wetlands has a significant nexus to a non- relatively permanent water that flows directly to a Traditional Navigable Water. Drainage ditches (Drainage Ditch 01, 02, 03, 04, 05, 06, and 07) within the project area are man-made drainage features designed to drain adjacent upland areas toward Chabot Canal and did not exhibit a dominance of wetland vegetation, hydric soils, or hydrology. Additionally, they lacked indicators of an ordinary high water mark and appear to be only sporadically inundated. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-52 Manmade ditches created in upland habitats to direct runoff from upland habitats are typically not classified as jurisdiction wetlands by the USACE. Emergent wetlands (0.022 acres) were found to be a direct result of a leaky potable water pipe and are not typically considered jurisdictional. Waters of the State Using the USACE guidance, all wetlands and other waters of the U.S mapped within the project area using would likely be considered jurisdictional by the Regional Water Quality Control Board (RWQCB) under the Porter-Cologne Act. Additionally, 0.494 acres of drainage ditch (Drainage Ditch 01, 02, 03, 04, 05, 06 and 07) that were created in uplands to drain uplands may be considered jurisdictional by the RWQCB Non-native grasslands Non-native grassland is composed of annual grasses, with cover ranging from sparse to dense, and associated species of native and non-native flowering forbs. Most of the plants are dead in the summer and fall seasons. Non-native grassland usually occurs on fine-textured soils that are moist or very wet during the winter rainy season and very dry during the summer. It is distributed throughout the valleys and foothills of most of California, and generally ranges from sea level up to about 3,000 feet elevation. Non-native grasslands within the project area contain both native and non-native species. The plant composition within the project area has not changed since the previous surveys (2003 to 2004) were conducted. Dominant species include slender wild oat (Avena barbata), wild oat (Avena fatua), Bermuda grass (Cynodon dactylon), slender wild oat (Avena barbata), ryegrasses (Lolium spp.) and several barley species (Hordeum spp.) and canarygrass (Phalaris ssp.). Associated annual forbs include primarily non-native plants such as black mustard (Brassica nigra), short pod mustard (Hirschfeldia incana), bristly ox-tongue (Picris echioides), alkali mallow (Malvella leprosa), stinkwort (Dittrichia graveolens), annual fireweed (Epilobium brachycarpum), and yellow star-thistle (Centaurea solstitialis). The ruderal grassland habitat covers approximately 104.69 acres and occurs in previously disturbed areas, evident by concrete footings, asphalt, rebar, and pipes from demolished buildings. Some of these ruderal grassland areas are mowed or disked for fuel control. Developed Areas The project area includes approximately 77 acres of developed areas that include hardscape and landscape areas. Developed areas include buildings, parking areas, storage areas and roads. The developed areas within the project area are concentrated towards the west. However, the eastern portion also includes a few buildings, storage yards and associated parking lots. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-53 Special Status Species According to the CNDDB, USFWS, and CNPS queries, a total of 68 special-status species and three rare natural communities and USFWS-designated critical habitat for California tiger salamander (Ambystoma californiense), California red-legged frog (Rana draytonii), Alameda whipsnake (Masticophis lateralis euryxanthus), and vernal pool fairy shrimp (Branchinecta lynchi) are known to occur in the project areawithin the Dublin, Livermore, Diablo and Tassajara 7.5 minutes topographical quadrangle. Information gathered during the site visits and data on range, habitat requirements, and known localities was used to refine the species list and determine which species were likely to occur based on the plant communities (i.e. habitat types) within the project area. Based on the database queries and biological surveys, nine wildlife species and one plant species have a moderate or higher likelihood of occurrence in the project area. No rare natural communities occur within the project area. Similarly, there is no-USFWS designated critical habitat within the project area. Survey Methods Cardno Entrix performed queries of the California Department of Fish and Game, Natural Diversity Database (CNDDB), California Native Plant Society (CNPS) Online Electronic Inventory of Rare and Endangered Vascular Plants of California (CNPSEI) and the United States Fish and Wildlife (USFWS) Online Species List of Federal Endangered and Threatened Species to identify known biological resources within the project areagreater project vicinity. Results of those queries are shown in the technical appendices in Appendix C. A reconnaissance-level survey was conducted by Cardno Entrix biologist on March 6, 2012. The survey consisted of walking meandering transects through accessible representative vegetation or plant communities that occur within the project area to assess their suitability for native plant and animal species. Particular attention was given to areas that appeared to provide the most suitable habitat for special-status species expected to occur in the region. Previous Biological Surveys A special-status plant species survey was completed at Camp Parks in 1995 by Jones & Stokes (as cited in US Army 2006), followed by a field reconnaissance in 1997 by the U.S. Army Corps of Engineers-Louisville District 2003 (as cited in US Army 2006). An extensive two-year floristic survey, which included three performance of surveys coinciding with the progression of flowering, was conducted between spring 2001 and spring 2003. In 2003, a sensitive plant survey was conducted in appropriate habitat within Camp Parks with special focus on the Cantonment Areaon the project area, and southwest portion of the Training Area. No federal or state-listed or candidate plant species were detected during any survey, site conditions have not changed significantly since the surveys were conducted and none are believed to occur within the project area. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-54 An installation-wide faunal survey focusing on rare species was completed in 1995 by Jones & Stokes (as cited in U.S. Army, 2006). In addition, surveys were performed in 2003 for vernal pool invertebrates, California red-legged frog, burrowing owls, San Joaquin kit foxes, and other sensitive species including raptors and loggerhead shrikes. Most of the latter surveys focused on the project area (Cantonment Area) and adjacent portions of the southwest Training Area at Camp Parks. However, the vernal pool surveys were done in appropriate habitat throughout Camp Parks and the San Joaquin kit fox surveys addressed appropriate habitat in the project area Cantonment and southern training area. Site conditions have not changed significantly since these surveys were conducted as confirmed by Cardno Entrix in the March 2012 reconnaissance survey. A United States Fish and Wildlife Service protocol dry season branchiopod survey was conducted April 17, 2012 by Cardno Entrix. Wet season vernal pool invertebrate surveys were conducted winter through spring of 2012-2013. However, results of these surveys shall be considered preliminary until accepted by the USFWS. Species Accounts Life histories of special-status plant and animal species identified by the CNDDB, USFWS, and the California Native Plant Society (CNPS) lists that have a moderate or higher likelihood of occurringthe potential to occur in the project area are described below: Conservancy fairy shrimp (Branchinecta conservation) The conservancy fairy shrimp is endemic to California’s Central Valley, with one outlying population in Ventura County, southwest of the Valley. Within the Central Valley, records for this species come from Tehama, Butte, Glenn, Solano and Yolo County. There are no known occurrences in Alameda County. Although not a target species, this species was not detected in focused surveys between 2002 and 2003. This species was also not detected and during wet and dry surveys conducted by Cardno Entrix in 2012 and 2013. However, these surveys are considered preliminary until accepted by the USFWS. Suitable large playa pools that this species typically occurs in are not present in the project area. Therefore, the likelihood of Conservancy fairy shrimp occurring within the project area is considered low. Longhorn fairy shrimp (Branchinecta longiantenna) Typical habitats for Longhorn fairy shrimp include vernal pools, seasonally ponded areas within vernal swales, and ephemeral freshwater habitats. There are only eight known populations of the longhorn fairy shrimp. The nearest occurrence of this species is within the Altamont Pass and these occurrences occur within clear depression pools in sandstone outcrops. Vernal pools in other parts of California that support these fairy shrimp consist of either loam and sandy loam or shallow, Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-55 alkaline pools. The seasonal pool habitat is subject to seasonal variations, and longhorn fairy shrimp are dependent on the ecological characteristics of such variations. These characteristics include duration of inundation and presence or absence of water at specific times of the year. The longhorn fairy shrimp is capable of living in vernal pools of relatively short duration (pond 6 to 7 weeks in winter and 3 weeks in spring). This species was not found during USFWS protocol level surveys conducted from 2002 to 2003 of by the surveys conducted in 2012 and 2013 by Cardno Entrix. Therefore, the likelihood of Longhorn fairy shrimp occurring within the project area is considered low. Vernal pool fairy shrimp (Branchinecta lynchi) Vernal pool fairy shrimp are federally listed as threatened. Vernal pool fairy shrimp occur in vernal pools and seasonal wetlands that fill during winter and spring rains and then dry up fall until rains return. Cysts lie in the soil through dry periods, hatching with the next season’s rains, or may even remain dormant for decades before hatching. There are known occurrences of this species within Springtown in northeast Livermore, approximately eight miles east of the project area. This species was not detected during focused biological surveys from 2002 to 2003 or the 2012 and 2013 surveys conducted by Cardno Entrix. The results of the 2012 and 2013 surveys are considered preliminary until accepted by the USFWS. Therefore, the likelihood of Vernal pool fairy shrimp occurring within the project area is considered low. Curved-foot hygrotus diving beetle (Hygrotus curvipes) The curved-foot hygrotus diving beetle is not state or federally listed or a species of concern, but is included on the CDFG CDFW Special Animals list. This aquatic beetle occurs in small seasonal pools and wetlands and small pools left in dry creek beds, and is typically associated with alkaline tolerant vegetation. Occurrences of this species are known from the northeast portion of Livermore and Altamont Pass. Suitable habitat within the project area exists along the drainage canals. This species was not detected during focused biological surveys from 2002 to 2003 and site conditions have not changed significantly since that time. Therefore, the likelihood of Curved-foot hygrotus diving beetle occurring within the project area is considered low. San Francisco forktail damselfly (Ischnura gemina) The San Francisco forktail damselfly is found from Tomales Bay in Marin County, south to the north side of Monterey Bay in Santa Cruz County. This species is known to occur in and around seeps, ponds, small creeks and canals. Males and females are extremely sexually dimorphic, showing a great range of color. Females deposits eggs in plant stems, generally without being guarded by a male. This species is believe to be restricted to the San Francisco Bay region and may have disappeared from locations in the southern part of its former range, perhaps from hybridization with black-fronted damselflies. Suitable habitat within the project area exists along the Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-56 drainage canals. This species was not detected during focused biological surveys conducted from 2002 to 2003 and site conditions have not changed significantly since that time. Therefore, the likelihood of San Francisco forktail damselfly occurring within the project area is considered low. California linderiella (Linderiella occidentalis) California linderiella is not state or federally listed or a Species of Special Concern, but is included on the CDFW Special Animals list. This small fairy shrimp occurs in vernal pools and other seasonal wetlands. Their life history is very similar to that of the vernal pool fairy shrimp, but this species is more widespread. California linderiella commonly occur in Alameda County, the nearest CNDDB occurrence is approximately 1.17 miles to the northeast just south of the Air Force Communication Annex. This species was not detected during focused biological surveys between 2002 and 2003 or during the surveys conducted by Cardno Entrix in 2012 and 2013. Therefore, the likelihood of California linderiella occurring within the project area is considered low. Western pond turtle (Actinemys marmorata) Western Pond Turtle The western pond turtle (WPT) is a California Species of Special Concern. This aquatic turtle ranges throughout much of the state, from the Sierra Nevada foothills to the coast, and in coastal drainages from the Oregon border to the Mexican border. They typically inhabit ponds, slow-moving streams and rivers, irrigation ditches, and reservoirs with abundant emergent and/or riparian vegetation. The turtle requires adjacent (i.e., within 200 to 400 meters of water) uplands for nesting and egg laying, typically in soils with high clay or silt component on unshaded, south- facing slopes. In colder climates, they may spend the winters hibernating in these upland habitats. There are known CNDDB occurrences for this species within one- half mile of the project area within ponds and perennial drainages that provide potential habitat for this species. This species was not detected during focused biological surveys from 2002 to 2003. Therefore, the likelihood of Western pond turtle occurring within the project area is considered low. California tiger salamander (Ambystoma californiense) The California tiger salamander (CTS) is federally listed as threatened and a California threatened species. CTS is most commonly found in annual grassland habitat, but also occurs in grassy understory of open valley foothill hardwood habitats. The species occurs from near Petaluma, Sonoma County, east through the Central Valley to Yolo and Sacramento counties and south to Tulare County, and from the vicinity of San Francisco Bay south into Santa Barbara County. Adults spend most of the year in subterranean refugia, especially burrows of California ground squirrels, and occasionally man-made structures. The primary cause of decline of CTS populations is the loss and fragmentation of habitat from human activities and the encroachment of nonnative predators. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-58 There are several known CNDDB occurrences for this species within two miles of the project area. The nearest occurrences are 1.4 miles to the north and 1.2 miles to the northeast of the project area. USFWS protocol requires that occurrences be evaluated within one mile of a proposed project. The first occurrence is located within Camp Parks training area. The second during the March 2012 field surveyoccurrence is located within Tassajara Creek. No suitable habitat for the CRLF was observed during the March 2012 field survey. The ephemeral drainage/storm drainage canal in the center of the project area does not support deep pools where this species may breed. Similarly, the drainage canal along the eastern border of the project area is channelized and concrete lined. In both of these canals, cattails were present. Booz Allen Hamilton and GANDA surveyed the project area and additional sections of the Cantonment Area of Camp Parks in 2003. The survey concentrated on sixteen wetlands within or immediately north of the Cantonment Area. Of sixteen sites visited, two areas within the Cantonment Area contained standing water. The first wetland (ephemeral drainage/ storm drainage canal) is located just southwest of the intersection of 8th Street and Hutchins Avenue. The second wetland is grassy ditch located just west of the intersection between 8th Street and Davis Ave. The Booz Allen Hamilton (2004) report state that it was abnormal for this grassy ditch, to contain water during the summer months and it was believed that this water was due to runoff from landscaping; this ditch is nearly surrounded by developed areas with several landscaped areas. Although these areas did not contain sufficient water for breeding, additional surveys were conducted. CRLF were not observed during any of these surveys. No suitable aquatic habitat was observed within the project area during the March 2012 survey conducted by Cardno Entrix. Therefore, the likelihood of California Tiger SalamanderCRLF occurring within the project area is considered low. Cooper’s hawk (Accipiter cooperii) This hawk is found throughout California, except in the high altitudes of the Sierra Nevada. The Cooper’s hawk is protected under the Migratory Bird Treaty Act (MBTA). Cooper’s hawks typically breed in forest, or in groves of trees along rivers, but also in low scrub of treeless areas. The wooded area is often near the edge of a field or a water-opening. The nesting season for this hawk begins late February, however, lost clutches are replaced. The Audubon eBird database contains observations of Cooper’s hawks in the Dublin and Livermore area. Based on the survey conducted in March 2012 by Cardno Entrix there is limited nesting habitat in the project area, Cooper’s hawk is a year round resident of the project vicinity. Therefore, the likelihood of Cooper’s hawk occurring within the project area is considered moderate. Golden eagle (Aquila chrysaetos) Golden eagle is a California fully protected species and is protected under the Bald and Golden Eagle Protection Act. One of North America’s largest predatory birds, the golden eagle is more common in southern California than in northern California. Ranging from sea level up to 11,500 feet, the golden eagle’s habitat typically consists Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-64 The 2003 San Joaquin Kit Fox survey identified potentially suitable habitat, but no kit foxes were observed. Site conditions have not changed significantly since the 2003 surveys. Therefore, the likelihood of San Joaquin kit fox to occur within the project area is considered low. Plant Species A query of the California Native Plant Society (CNPS) lists 34 plant species that occur within the project vicinity. Based on habitats within the project area during the March 2012 survey by Cardno Entrix, the list was reduced to four species including: Congdon’s tarplant Centromadia parryi ssp. congdonii), Palmate-bracted Bird’s-beak (Chloropyron palmatum), Northern California Black Walnut (Juglans hindsii), and Hairless popcorn-flower (Plagiobothrys glaber). Congdon’s tarplant (Centromadia parryi ssp. congdonii) The Congdon’s tarplant is listed as a Rare Plant Rank (RPR) 1B.2 by the CNPS. Congdon’s tarplant is a prostrate to erect, yellow flowered annual herb in the Sunflower Family (Asteraceae). It generally occurs in annual grasslands with poorly- drained, somewhat alkaline, clay or sandy-loam soils, at elevations between sea level and 230 meters (754 feet). It has historic occurrences in Alameda, Contra Costa, Monterey, Santa Clara, Santa Cruz, San Luis Obispo and Solano Counties, but is thought to be extirpated from Santa Cruz and Solano Counties (Tibor 2001 as cited in Booz Allen Hamilton 2004). Congdon’s tarplant is described as severely threatened by development (Tibor 2001 as cited in Booz Allen Hamilton 2004), although it is evidently tolerant of mowing and some other physical disturbances within the ruderal grasslands within the project area. Jones & Stokes Associates, Inc. surveyed for nine of the potential special-status plant species at Camp Parks in 1995 and 1997. Congdon’s tarplant populations were first observed during the 1997 survey. Before its discovery at Camp Parks, this species had not been recorded in the Amador Valley, which includes Camp Parks, for more than 30 years. Subsequent surveys in August 1999 and July 2000 confirmed that known populations occur in 107 acres in the Training and Cantonment Areas. In addition, the potential habitat for this species covers more than 1,200 acres. According to the CNDDB, over 10,000 plants were estimated for this area in 1997. Additionally, a small patch of approximately 26 plants was identified in 2000 just south of Camp Parks, across Dublin Boulevard in the vicinity of a BART facility. The majority of the populations are found in highly disturbed or mowed areas (i.e., along the edge of parking lots and abandoned roads) and along the edges of annual grasslands at PRFTA. The soil in these locations is heavy alkaline clay in the Clear Lake and Diablo series. As the CNDDB contains recorded occurrences of this species within the project area and it was observed during the plant surveys, the likelihood of Congdon’s tarplant to occur within the project area is considered moderatehigh. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-65 Palmate-bracted Bird’s-beak (Chloropyron palmatum). Palmate-bracted bird’s-beak is known to occur in seven meta-populations with the closest in the Springtown alkali sink in the Livermore Valley, approximately six miles east of Project area. It was federally designated as endangered in 1986 (FR 51:23767 as cited in US Army 2006) and state designated as endangered in 1984 due to agricultural conversion; it is threatened by agriculture, urbanization, vehicles, altered hydrology, grazing, and development.26 This species occurs on saline-alkaline soils and is a component of alkali sink scrub vegetation (CDFW 1998 as cited in Booz Allen Hamilton 2004). During floristic surveys, this species was not found within the project area. Therefore, the likelihood of Palmate-bracted Bird’s- beak to occur within the project area is considered low. Northern California Black Walnut (Juglans hindsii) Northern California black walnut is designated RPR 1B.1, rare and endangered in California and elsewhere, in the CNPS inventory. It is a deciduous tree in the Walnut Family (Juglandaceae) that is approximately 50 to 80 feet tall with dark, narrowly furrowed bark. Its male flowers are arranged in greenish-yellow catkins and its small green female flowers are borne singly or in small clusters near the ends of the new twigs. Its habitat is riparian scrub and woodland. Northern California walnut grows in deep, alluvial soils associated with rivers and creeks, in riparian forest or riparian woodland (Hickman 1993, CNPS 2001 – as cited in Booz Allen Hamilton 2004). The original range of Northern California black walnut appears to have been limited to Contra Costa, Napa, Sacramento, Solano, and Yolo Counties. This species was reported to occur along the Sacramento River prior to 1949, but is now extirpated in Sacramento, Solano, and Yolo Counties (Smith 1949 in CNDDB 2001 as cited in Booz Allen Hamilton 2004). Currently, only two native occurrences are known: one stand in Napa County and one stand in Contra Costa County (Tibor 2001; CNDDB 2002; CNPS 2001 as cited in Booz Allen Hamilton 2004). Native stands of Northern California black walnut are threatened by hybridization with orchard trees, conversion to agriculture and development. Although specimens have been observed within Camp Parks none have been observed within the project area. Therefore, the likelihood of Northern California Black Walnut to occur within the project area is considered low. Hairless popcorn-flower (Plagiobothrys glaber) This species is believed to have been extirpated in California. CNNDB occurrence is from 2002, but identification is uncertain and has been disputed. All other occurrences are from pre-1954. This species is an annual herb ascending to erect with cauline leave that occurs in meadows and alkaline seeps, as well as coastal salt marshes and swamps. During floristic surveys, this species was not found within the project area. Therefore, hairless popcorn-flower has a low likelihood of occurrence. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-68 California Endangered Species Act The California Endangered Species Act (CESA, Fish and Game Code of California, Chapter 1.5, Sections 2050-2116) prohibits the take of any plant or animal listed or proposed for listing as rare (plants only), threatened, or endangered. In accordance with the California Endangered Species Act (CESA), the CDFG CDFW has jurisdiction over state-listed species. The CDFG CDFW regulates activities that may result in “take” of individuals listed under the Act (i.e., “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill”). Habitat degradation or modification is not expressly included in the definition of “take” under the Fish and Game Code. The CDFGCDFW, however, has interpreted “take” to include the “killing of a member of a species which is the proximate result of habitat modification.” California Environmental Quality Act The California Environmental Quality Act (CEQA) is a state law that requires state and local agencies, such as the City, to document and consider the environmental implications of their actions and to refrain from approving projects with significant environmental effects if there are feasible alternatives or mitigation measures that can substantially lessen or avoid those effects. CEQA requires the full disclosure of the environmental effects of agency actions, such as approval of a general plan update or the projects covered by that plan, on resources such as air quality, water quality, cultural resources, and biological resources. The State Resources Agency promulgated guidelines for implementing CEQA known as the State CEQA Guidelines. Section 15380(b) of the State CEQA Guidelines provides that a species not listed on the federal or state lists of protected species may be considered rare if the species can be shown to meet certain specified criteria. These criteria have been modeled after the definitions in FESA and CESA and the section of the California Fish and Game Code dealing with rare or endangered plants or animals. This section was included in the guidelines primarily to deal with situations in which a public agency is reviewing a project that may have a significant effect on a species that has not yet been listed by either the USFWS or CDFG CDFW or species that are locally or regionally rare. The CDFG CDFW has produced three lists (amphibians and reptiles, birds, and mammals) of “species of special concern” that serve as “watch lists.” Species on these lists are of limited distribution or the extent of their habitats has been reduced substantially, such that threat to their populations may be imminent. Thus, their populations should be monitored. They may receive special attention during environmental review as potential rare species, but do not have specific statutory protection. All potentially rare or sensitive species, or habitats capable of supporting rare species, are considered for environmental review per the CEQA Guidelines Section 15380(b). Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-69 The CNPS, a non-governmental conservation organization, has ranked plant species of concern in California. Vascular plants included on these lists are ranked as follows: Rank 1A Plants considered extinct. Rank 1B Plants rare, threatened, or endangered in California and elsewhere. Rank 2 Plants rare, threatened, or endangered in California but more common elsewhere. Rank 3 Plants about which more information is needed - review list. Rank 4 Plants of limited distribution-watch list. These CNPS listings are further described by the following threat code extensions: 1. Seriously endangered in California 2. Fairly endangered in California 3. Not very endangered in California. Although the CNPS is not a regulatory agency and plants in these ranks have no formal regulatory protection, plants appearing in Rank 1B or Rank 2 are, in general, considered to meet CEQA’s Section 15380 criteria, and adverse effects to these species may be considered significant. Impacts on plants that are listed by the CNPS as Rank 3 or 4 are also considered during CEQA review, although because these species are typically not as rare as those in Rank 1B or 2, impacts on them are less frequently considered significant. California Department of Fish and Wildlife (CDFW) Code The California Fish and Wildlife Game Code includes regulations governing the use of, or impacts on, many of the state’s fish, wildlife, and sensitive habitats. The CDFW exerts jurisdiction over the bed and banks of rivers, lakes, and streams according to provisions of Sections 1601–1603 of the Fish and Game Code. The Fish and Game Code requires a Streambed Alteration Agreement for the fill or removal of material within the bed and banks of a watercourse or water body and for the removal of riparian vegetation. Certain sections of the Fish and Game Code describe regulations pertaining to certain wildlife species. For example, Fish and Game Code Sections 3503, 2513, and 3800 (and other sections and subsections) protect native birds, including their nests and eggs, from all forms of take. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “take” by the CDFW. Raptors (i.e., eagles, falcons, hawks, and owls) and their nests are specifically protected in California under Fish and Game Code Section 3503.5. Section 3503.5 states that it is “unlawful to take, possess, or destroy any birds in the order of Falconiformes or Strigiformes (birds of prey) or to take, possess, or destroy the nest or eggs of any such bird Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-72 Impacts and Mitigation Measures Standards of Significance A proposed project would result in a significant impact to biological resources if it were to result in a:  Substantial effect, either directly or through habitat modifications, on any candidate, sensitive, or special-status species;  Substantial effect on any riparian habitat or other sensitive natural community;  Substantial effect on protected wetlands;  Substantial interference with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites; or  Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan. Jurisdictional Wetlands, Other Waters of the U.S. and Waters of the State Impact 3.3-1: Based on a preliminary wetland delineation of the project area, the proposed project could result in the fill of wetlands, which would result in a potentially significant impact. Based on the preliminary wetland delineation of the project area by Cardno Entrix, approximately 0.09 24 acres of seasonal wetlands; 0.11 acres of wetland drainage ditch; and 1.4 27 acres of other waters of the U.S. were mapped within the boundaries of the project area. Additionally, 0.5 49 acres of drainage ditch, created in uplands to drain uplands may be considered jurisdictional by the Regional Water Quality Control Board (RWQCB). Based on the conceptual land use plan for the proposed project, the ephemeral drainage canals would be partially avoided and a small section (approximately 900 linear feet) will be re-routed due to construction. All other wetlands within the project area would be permanently filled due to construction activities. Since fill of wetlands and “other waters of the U.S.” are prohibited under state and federal regulations described above, without first obtaining permits and approvals from the federal and state agencies, fill of wetlands, waters of the U.S., and waters of the State would result in a potentially significant impact. Mitigation Measure MM 3.3-1 Prepare and Implement a Wetland Mitigation Plan. Prior to commencing any activities that would impact wetlands or waters habitat, the project applicant shall obtain all required public agency Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-73 permits and shall prepare a wetland mitigation plan that ensures no- net-loss of wetland and waters habitat and is approved by the City andthat is approved by the applicable resource agencies and submitted to the City. The wetland mitigation plan shall include measures for avoidance, minimization, and compensation for wetland impacts. Avoidance and minimization measures may include the designation of buffers around wetland features to be avoided, or project design measures, such as free-span bridges. Compensation measures shall include the preservation and/or creation of wetland or waters. The final mitigation ratios (the amount of wetlands and waters created or preserved compared to the amount impacted) shall be determined by the applicable resource agencies and the City. The wetland mitigation and monitoring plan shall include the following:  Descriptions of the wetland types, and their expected functions and values;  Performance standards and monitoring protocol to ensure the success of the mitigation wetlands over a period to be determined by the resource agencies;  Engineering plans showing the location, size and configuration of wetlands to be created or restored;  An implementation schedule showing that construction or preservation of mitigation areas shall commence prior to or concurrently with the initiation of construction; and  A description of legal protection measures for the preserved wetlands (i.e., dedication of fee title, conservation easement, and/or an endowment held by an approved conservation organization, government agency or mitigation bank). Special-Status Plant Species Impact 3.3-2: A query of the CNPS lists 34 plant species that occur within the project vicinity. Based on habitats within the project area during the March 2012 survey by Cardno Entrix, the list was reduced to four special status plant species that have the potential to be located within the project area including: Congdon’s tarplant (Centromadia parryi ssp. Congdonii), Palmate-bracted bird’s-beak (Cordylanthus palmatus), Northern California Black Walnut (Juglans hindsii), and Hairless popcorn-flower (Plagiobothrys glaber). Out of these four special status plant species, the only special status plant species that has the potential to be located within the project area is the Congdon’s tarplant, which was documented as occurring within the project area based on floristic surveys conducted between 1995 and 2000. The Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-74 potential loss of Congdon’s tarplant within the project area would be considered a potentially significant impact. The majority of the Congdon’s tarplant populations within the project area are found in highly disturbed or mowed areas (i.e., along the edge of parking lots and abandoned roads) and along the edges of ruderal grasslands at Camp Parks. Disturbance or removal of grassland and wetland habitat could potentially result in the loss of this special status species, which would be considered a potentially significant impact. The following mitigation measures would reduce this potentially significant impact to special status species to a less than significant level by identifying the presence or absence of this plant species through a floristic survey for special-status plant species and if any special-status plant species are found, avoiding, transplanting, and monitoring plants that would be affected by the proposed project. Mitigation Measures MM 3.3-2a Conduct a Floristic Survey and Consult with CDFG CDFW and USFWS if State or Federally ESA Listed Plants are Found and Comply with Incidental Take Permits. The project applicant shall retain a qualified botanist to conduct rare plant surveys within the construction zone for Congdon’s tarplant or other state or federally listed plant species with potential habitat within the project area during the blooming period of those species for which suitable habitat is present appropriate time of year in accordance with agency protocols. These plant surveys shall be conducted in accordance with the 2009 California Department of Fish and Game CDFW and United States Fish and Wildlife ServiceUSFWS rare plant survey protocols. Two or three separate surveys may be required to cover the blooming periods of species where suitable habitat is present. The results of the surveys shall be summarized in a report and submitted to CDFW and USFWS, and would be valid for two years. If no special-status plants are located during the surveys, no further mitigation measures would be required. If any federal or state ESA plant species are found during the rare plant surveys, the project applicant shall consult with the CDFW and USFWS to obtain incidental take permits under Section 2081 of the CESA and either Section 7 or 10 of the FESA. Consultation with USFWS under Section 7 of the FESA could occur as part of the CWA Section 404 permit process as part of the wetland mitigation, described under Mitigation Measure MM 3.3-1. MM 3.3-2b Develop and Implement Mitigation in Consultation with CDFW if Other Special Status Plant Species Are Found. If populations or stands of Congdon’s tarplant or other special-status plant species (excluding federal or state listed plants) are found during the rare Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-75 plant surveys, the project applicant shall notify the CDFW. A mitigation plan shall be developed in consultation with and approved by the CDFW and the City prior to the commencement of any activities that would impact any special status plants, such as the acquisition of off-site mitigation areas presently supporting the species in question or purchase of credits in a mitigation bank that is approved to sell credits for the affected species. The location of mitigation sites shall be determined in consultation with, and subject to approval of USFWS and/or CDFW. Off-site compensatory mitigation shall be acquired at a minimum acreage ratio of 1:1 (acquired: impacted). For either off-site mitigation option, measures shall be implemented (including contingency measures) providing for the long-term protection of the species. The mitigation plan shall include measures such as transplanting plants, collecting seed or clippings and replanting species in an on-site location, if feasible or other location approved by Department of Fish and Game. Special Status Wildlife Species - Mammals Impact 3.3-3: Several California burrowing owl pairs have been documented within the project area, including during the winter and breeding season. Due to the security fencing that surrounds Camp Parks, low human use, and maintenance activities, the project area provides suitable breeding, foraging and wintering habitat for the California burrowing owl. Implementation of the proposed project could result in the displacement of burrowing owls during construction activities, and once completed, the proposed project could result in the removal of suitable burrowing owl (breeding and wintering) habitat. Permanent loss of occupied burrow(s) and habitat would be considered a potentially significant impact. The following mitigation measure would reduce impacts to the California burrowing owl to a less than significant level by documenting information on burrowing owls in the project area and by conducting a California burrowing owl survey and if any burrowing owls are found, avoiding, or excluding the owls outside the breeding season, and mitigating for the loss of habitat that would be affected by the proposed project. Because California burrowing owls have been observed within the project area, the following mitigation measures would reduce this potentially significant impact to a less than significant level. Mitigation Measures MM 3.3-3a Conduct a Burrowing Owl Survey and Impact Assessment. The project applicant shall retain a qualified biologist to conduct a California burrowing owls take avoidance surveys 14 days prior to ground disturbing activities and impact assessment following the Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-76 2012 California Department of Fish and Game Staff Report on Burrowing Owl Mitigation (CDFW 2012) or as updated at the time of the implementation of the proposed project. If no owls are found during this first survey, a final survey shall be conducted within 48- hours prior to ground disturbance to confirm that burrowing owls are still absent. If ground disturbing activities are delayed or suspended for more than 14 days after the initial take avoidance survey, the project area shall be resurveyed including the final survey within 48- hours of disturbance. The report(s) shall be submitted to California Department of Fish and Game CDFW as indicated in the CDFW 2012 Staff Report. If it is determined that project activities may result in impacts to nesting, occupied, and satellite burrows and/or burrowing owl habitat, the project applicant shall consult with the CDFW. More specifically, if the surveys identify breeding or wintering burrowing owls on or adjacent to the project area, occupied burrows cannot be disturbed and shall be provided with protective buffers. Where avoidance is not feasible during the non-breeding season, a site specific exclusion plan (i.e. a plan that considers the type and extent of the proposed activity, the duration and timing of the activity, the sensitivity and habituation of the owls, and the dissimilarity of the proposed activity with background activities) shall be implemented to encourage the owls to move away from the work area prior to construction and to minimize the potential to affect the reproductive success of the owls. The exclusion plan shall be subject to the CDFW approval and monitoring requirements. Compensatory mitigation could also be required by the CDFW as part of the approval of an exclusion plan. Mitigation may include the permanent protection of habitat at a nearby off-site location acceptable to the CDFW. and develop a detailed mitigation plan such that the habitat acreage, number of burrows, and burrowing owl impacted are replaced. The mitigation plan shall be based on the requirements set forth in Appendix A of the CDFW 2012 Staff Report on Burrowing Owl Mitigation. MM 3.3-3b Implement Avoidance Measures. If California burrowing owl are located within the project area and direct impacts can be avoided, the project applicant shall implement the following avoidance measures during all phases of construction to reduce or eliminate potential impacts to California burrowing owls.  Avoid disturbing occupied burrows during the nesting period, from 1 February through 31 August. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-77  Avoid impacting burrows occupied during the non-breeding season by migratory or non-migratory resident burrowing owls.  Avoid direct destruction of burrows through chaining (dragging a heavy chain over an area to remove shrubs), disking, cultivation, and urban, industrial, or agricultural development.  Develop and implement a worker awareness program to increase the on-site worker’s recognition of and commitment to burrowing owl protection.  Place visible markers near burrows to ensure that farm equipment and other machinery does not collapse burrows.  Do not fumigate, use treated bait or other means of poisoning nuisance animals in areas where burrowing owls are known or suspected to occur (e.g., sites observed with nesting owls, designated use areas).  Restrict the use of treated grain to poison mammals to the months of January and February. MM 3.3-3c Conduct Burrow Exclusion. In the event that California burrowing owls are located within the project area, the project applicant shall conduct a Burrowing Owl Relocation Plan. If avoidance of burrowing owl or their burrows is not possible, the project applicant in consultation with the California Department of Fish and Wildlife shall prepare a Burrowing Owl Relocation Plan as indicated and following the CDFW 2012 Staff Report. Monitoring of the excluded owls shall be carried out as per the California Department of Fish and Game 2012 Staff Report. Mitigation for permanent impacts to nesting, occupied, and satellite burrow and/or burrowing owls shall be developed based on the CDFW 2012 Staff Report on Burrowing Owl Mitigation. Special-Status Species - Amphibians and Reptiles Impact 3.3-4: Habitat assessments or surveys for special-status amphibians and reptiles were performed within the project area by the U.S. Army in 2006, including California Red Legged Frog and California Tiger Salamander. Although no surveys specific for Western Pond Turtle have been conducted, Western Pond Turtle was observed within the project areagreater Camp Parks Training Area during surveys for California Red Legged Frog. During the field surveys conducted by in March 2012, the project area was not found to provide suitable breeding habitat for these species. However, the proposed project Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-78 includes re-alignment of the ephemeral drainage, which could result in the potential “take” of Western Pond Turtle and/or California Red Legged Frog if found within the project area. Therefore, this would be considered a potentially significant impact. During the 2012 field surveys conducted by Cardno Entrix, the ephemeral drainage located within the project area did not contained deep pools that could provide suitable breeding habitat for California Red Legged Frog. In addition, none of the seasonal wetlands retain water long enough to provide suitable breeding habitat for the California Tiger Salamander. Similarly, the ephemeral drainage does not provide suitable habitat for the Western Pond Turtle since it dries during the summer months and does not appear to provide suitable nesting or refuge habitat for this species. California Tiger Salamander During installation wide surveys conducted at Camp Parks in 2005, California Tiger Salamander breeding locations were identified within the Camp Parks Training Area, however no breeding habitat was identified within the project area. The project area is approximately 1.4 miles away from the nearest known breeding location and approximately 0.90 miles south of an upland observation during the 2005 surveys. Existing development (i.e. buildings, roads and parking areas) between the project area and the Camp Parks Reserve Forces Training Area would likely hinder dispersal and reduce the survival potential of dispersing California Tiger Salamander (CTS). Potential of CTS occurring within the project area decreases with distance from known breeding habitat, potential breeding habitat, and suitability of habitat. Based on existing conditions and the lack of habitat, it is unlikely that CTS would occur within the project area. Additionally, implementation of the proposed project is not expected to result in habitat modification or degradation because potential dispersal habitat within the project area lacks suitable aquatic components, thus breeding, sheltering, and feeding of CTS would not be significantly impaired. Therefore, implementation of the proposed project would have no impact on this species and no mitigation is required. Western Pond Turtle Although a survey specific for Western Pond Turtle has not been conducted within the project area or the Camp Parks Forces Training Area, WPT have been observed within the installationwithin the greater Camp Parks Training Area during surveys for CTS and CRLF by the U.S. Army in 2006. All of the observations have been made within man-made ponds in the Training Area. No observations of WPT have been made within the project area (US Army 2006). The habitat within the project area does not provide suitable breeding or aestivating habitat for the WPT. Implementation of the proposed project calls for the re-alignment of the ephemeral drainage. It is expected that this realignment would occur during the dry season Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-79 and thus it would be unlikely that a Western Pond Turtle would be present. Nevertheless, re-alignment of the stream could result in the “take” of Western Pond Turtle. This would be considered a potentially significant impact. Implementation of the following mitigation measure would reduce impacts to Western Pond Turtle to less than significant level by identifying the presence or absence of WPT by conducting a pre-construction survey for Western Pond Turtle and if any Western Pond Turtles are found, avoiding, excluding and/or relocating the Western Pond Turtle to a more suitable habitat within the immediate vicinity of the project area but away from the construction zone. Mitigation Measure MM 3.3-4a Conduct Pre-Construction Surveys for Western Pond Turtle (WPT) Prior to Re-Alignment of the Ephemeral Drainage. The project applicant shall retain a qualified biologist to conduct pre-construction surveys for Western Pond Turtle no more than 30 days prior to work in or adjacent to any habitat suitable for WPT within the project area. If no Western Pond Turtles are found, no further mitigation is required. If Western Pond Turtles are found, the consulting biologist shall consult with the California Department of Fish and Game for authorization to relocate the species to suitable habitat away from the construction zone. The turtle shall be relocated to either a pond within the Training Area (if authorization from the US Army is granted) or downstream from the construction zone to similar or better habitat. California Red-Legged Frog The Cantonment Area of - Camp Parks -–The project area was previously surveyed in August 2003. The survey followed the measures prescribed in the USFWS Guidance on Site Assessment and Field Surveys for California Red-Legged Frog (Rana aurora draytonii). None of the six potential wetlands within the project area were found to provide suitable habitat for the California Red Legged Frog based on a habitat assessment prepared in 2003. Based on the surveys conducted by Cardno Entrix in March 2012, conditions within the project area have not changed since 2003 and thus the habitat within these areas is primarily unchanged. However, since the surveys were conducted in 2003, new focused field surveys may be warranted. The habitat within the project area does not provide breeding habitat for the CRLF, and the nearest known CRLF breeding site is 1.32 miles north of the project area within Camp Parks. Existing development (i.e. buildings, roads and parking areas) between the project area and the Camp Parks Training Area likely hinders dispersal and reduces the survival potential of dispersing CRLF. Nevertheless, there is a possibility that CRLF could disperse within the project area and therefore could be Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-81 not be limited to, onsite and offsite preservation and creation of CRLF habitat, purchase of credits at mitigation banks, payment of in lieu fees approved by the agencies, or other agency approved and required mitigation measures. d. Avoidance measures may include the following or equivalent protective measures:  To minimize disturbance of breeding and dispersing CRLF, construction activity within CRLF upland habitat shall be conducted during the dry season between April15 and October 15 or before the onset of the rainy season, whichever occurs first. If construction activities are necessary in CRLF upland habitat between October 15 and April 15, the project applicant would contact the USFWS for approval to extend the work period.  To minimize disturbance and mortality of adult and juvenile CRLF in aquatic habitat and underground burrows, the project applicant could minimize the extent of ground- disturbing activities within these habitats by requiring the contractor to limit the work area to the minimum necessary for construction. In addition, the project applicant could ensure that the contractor would install temporary exclusion fence between the construction work area and potential aquatic habitat for all construction within grasslands near aquatic habitat.  The project applicant could ensure that a qualified wildlife biologist monitors all construction activities within CRLF upland habitat. This would ensure no take of individual CRLF occurs during project construction. If a CRLF is found, then the monitor would immediately stop construction in that area and contact USFWS for advice.  The project applicant shall could preserve additional upland habitat within a USFWS approved conservation area. The Project proponent shall coordinate or consultThis measure shall be determined in consultation with the USFWS, if required. Vernal Pool Invertebrates Impact 3.3-5: Protocol level surveys for vernal pool invertebrates were conducted throughout Camp Parks in 2002 and 2003 by the U.S. Army, as well as during the summer of 2012 (dry season) and 2013 (wet season) by Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-82 Cardno Entrix. No vernal pool fairy shrimp, vernal pool tadpole shrimp or longhorn fairy shrimp were found during these surveyss. California linderiella was found during the 2002 and 2003 surveys, but not within the project area. The New surveys are currently being conducted by Cardno Entrix have not been accepted by USFWS. Since the new surveys have not been completed at this timeTherefore, the presence of this species within the project area is assumed in the analysis of project impacts. Surveys for curve-footed Hygrotus beetle and San Francisco fork- tailed damselfly were also conducted within Camp Parks in 2002 and 2003 and neither of these species were observed. Site conditions have not changed significantly and these species are not expected to occur. Potentially suitable habitat was observed within the survey area for vernal pool invertebrates and these areas would be removed during proposed construction activities. Removal of these wetlands could result in the potential take of protected vernal pool branchiopods and other protected invertebrates, if they were to occur, and their habitat. This would be considered a potentially significant impact. Implementation of the following mitigation measures would reduce potential impacts to vernal pool invertebrates to a less than significant level by preparing a habitat assessment for vernal pool invertebrates. If the habitat assessment concludes that vernal pool invertebrates could be located within the project area, the project applicant could either conduct protocol-level surveys or assume presence. If any federally-protected vernal pool invertebrates are found within the project area or if the project applicant assumes presence, then the project applicant shall ensure no net loss of habitat occurs and shall be achieve through avoidance, reservation, creation and/or purchase of mitigation credits. Implementation of the following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure MM 3.3-5 Consult with the USFWS and Reduce Impacts on Vernal Pool Invertebrates and Their Habitat. The project applicant shall prepare a habitat assessment for the vernal pool invertebrates. If vernal pool invertebrates are found within the project area during the habitat assessment, the project applicant shall comply with the following steps to ensure protection of vernal pool invertebrates and their habitat and that impacts are reduced to a less than significant level. a. The project applicant shall retain a qualified biologist to conduct habitat assessments for protected vernal pool invertebrates and based on the results of the habitat Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-83 assessments, determine in consultation with the USFWS if protocol-level vernal pool invertebrate surveys will be required within the project area. b. If suitable habitat is present, the project applicant, in consultation with the USFWS and CDFW, shall either (1) conduct a protocol-level survey for federally listed vernal pool crustaceans, which will identify and other protected vernal pool invertebrates (curve-footed Hygrotus beetle and San Francisco fork-tailed damselfly), or (2) assume presence of federally-listed vernal pool crustaceans and curve footed Hygrotus beetle and San Francisco fork-tailed damselfly in areas of suitable habitat. Surveys shall be conducted by qualified biologists in accordance with the most recent USFWS guidelines or protocols to determine the time of year and survey methodology (survey timing for these species is dependent on yearly rainfall patterns and seasonal occurrences, and is determined on a case-by-case basis). The USFWS protocol level surveys shall be conducted as part of the Section 404 permit process within two years of the application. If surveys reveal no occurrences of federally listed vernal pool crustaceans or other protected vernal pool invertebrates, no further mitigation would be required. c. If surveys determine that one or more special-status vernal pool invertebrate species occurs within the project area, or if the project applicant, in consultation with the USFWS and/or CDFW, assumes presence of federally-listed vernal pool invertebrates in all affected habitats, the project applicant shall provide information to the USACE to support Section 7 consultation with the USFWS and the project applicant shall ensure no net loss of habitat shall be achieved through avoidance, preservation, creation and/or purchase of credits as a part of the Section 7 Consultation process. The selected measures may be part of the permitting process. d. Where feasible, all vernal pool invertebrate habitat shall be avoided. If habitat that can be avoided during construction activities is identified at a distance determined in consultation with USFWS, a USFWS-approved biologist (monitor) shall inspect any construction-related activities to ensure that no unnecessary take of listed species or destruction of their habitat occurs. The Project proponent will establish monitoring and reporting protocols to reduce impacts to vernal pool invertebrate species and habitat. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-84 e. The project applicant shall ensure that an appropriate number of acres, as approved by USFWS during consultation, are preserved to mitigate for direct or indirect impacts on vernal pool crustacean habitat. f. Water quality in the avoided wetlands shall be protected using erosion control techniques, such as silt fencing or straw wattles during construction in the watershed. Migrant Bird Treaty Act (MBTA) – Nesting Birds Impact 3.3-6: A variety of special-status birds are expected to be located within the project area. Some of these species are resident species and some are migratory species that breed within the project area. The special- status birds known to nest in the Livermore Valley area include the Golden eagle, white-tailed kite, tricolored blackbird, northern harrier, California horned, prairie falcon, Cooper’s hawk and loggerhead shrike. Trees, fresh emergent wetland vegetation and grassland could provide potentially suitable nesting habitat for these species, which are protected under the Migrant Bird Treaty Act and the Fish and Game Code. The proposed project would require grading and possible removal of existing trees and vegetation. Therefore, implementation of the proposed project could result in the loss of active nests, which would be considered a potentially significant impact on special- status bird species and birds protected under the MBTA. The proposed project includes creation of an open space area along the ephemeral drainage canal, which would provide potentially suitable nesting habitat for some of these species following construction. However, implementation of the following mitigation measure would reduce impacts to nesting birds to less than significant level by requiring that pre-construction bird surveys are conducted and that the project applicant avoid any nests if found. Mitigation Measure MM 3.3-6 Protect Birds Covered by the Migratory Bird Treaty Act (Including, but not limited to White-Tailed Kite, golden eagle, Cooper’s hawk, Loggerhead Shrike, and Other Special-Status Species). Project contractors shall avoid construction activities during the bird nesting season (February 1 through August 31). If Between March 1 and September 15construction activities are conducted during the nesting season, the project applicant shall have a qualified biologist conduct at least three nest surveys of the project area to develop a baseline of nesting activity on and adjacent to the project area. Depending on the construction schedule, preconstruction surveys shall be initiated prior to the planned construction activity to allow adequate time for Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-85 multiple site visits (e.g. for construction activities planned for mid- May, the first survey shall be conducted no more than 14 days prior to the start of work). no more than 30 days prior to any demolition/construction or ground-disturbing activities that are within 300 feet of potential nest trees for non-raptor species (i.e. trees, cattails, or grassland) and 500 feet of potential nest trees for raptor species or suitable nesting habitat (i.e., trees, cattails, grassland). Where access to property adjacent to the construction activities is prohibited by the owner/operator, the survey shall be conducted using binoculars or spotting scope. A pre-construction survey report shall be submitted to the California Department of Fish and Game that includes, at a minimum: (1) a description of the methodology including dates of field visits, the names of survey personnel with resumes, and a list of references cited and persons contacted; and (2) a map showing the location(s) of any bird nests observed on the project area. If no active nests of Migratory Bird Treaty Act covered species are identified, then no further mitigation is required. If active nests of protected bird species are identified in the focused nest surveys, the project applicant will shall consult with the appropriate regulatory agencies to identify project-level mitigation requirements, based on the agencies’ standards and policies as then in effect. Performance measures may include the following, based on current agency standards and policies. a. The project applicant, in consultation with California Department of Fish and Game, would shall delay construction in the vicinity of active nest sites during the breeding season (February 1 through September 15August 31) while the nest is occupied with adults and/or young. A qualified biologist would monitor any occupied nest to determine when the nest is no longer used. If the construction cannot be delayed, avoidance measures would shall include the establishment of protective buffer zones around the nests as follows: for raptor nests, the size of the buffer zone shall be a minimum 250 foot radius centered on the nest; for other birds, the size of the buffer zone shall be a 50-foot radius centered on the nest. In some cases, these buffers may be increased or decreased depending on the bird species and the level of disturbance that will occur near the nest. Changes to the buffer should be made by the project biologist in consultation with the CDFW.of a non-disturbance buffer zone around the nest site. The Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-86 size of the buffer zone would be determined in consultation with the CDFW and may vary depending on the species, but will be a minimum of 250 feet. The buffer zone would be delineated with highly visible temporary construction fencing. b. No intensive disturbance (e.g., heavy equipment operation associated with construction, or use of cranes) or other project-related activities that could cause nest abandonment or forced fledging would be initiated within the established buffer zone of an active nest between February 1 and September 15August 31. c. If construction activities are unavoidable within the buffer zone, the project applicant shall retain a qualified biologist to monitor the nest site to determine if construction activities are disturbing the adult or young birds. d. If fully protected species (white-tailed kites, golden eagles) are found to be nesting near the proposed construction area, their nests would be completely avoided until the birds fledge. Avoidance would include the establishment of a non-disturbance buffer zone of 500 feet, or as determined in consultation with the CDFW. Special Status Bat Species Impact 3.3-7: Removal of trees and/or buildings or structures from the project area could impact roosting sites for pallid bat and Yuma myotis. Disturbance of roosting sites during the maternity season (May 1st- Oct1st) could result in a potentially significant impact. No bat surveys have been conducted within the project area. However, trees and existing old buildings or structures may represent potentially suitable roosting habitat for a variety of regionally occurring bat species. The two bat species with a likelihood of occurrence include the pallid bat and Yuma myotis. These species have been documented as roosting approximately 2.06 miles southwest of the project area. Removal of trees and/or buildings or structures from: the project area could impact roosting sites for these species. These roosting sites can also be used as maternity roosts. Disturbance of roosting sites during the maternity season (May 1st-Oct1st) could result in a potentially significant impact. Implementation of the following measure would reduce the potentially significant impact on special-status bats and their roost sites to less than significant level. Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-88 Preservation of Heritage Trees and Tree Preservation Impact 3.3-8: Trees are located within the project area and a detailed tree survey has not been conducted for the proposed project. Nevertheless, trees within the project area could fall under the definition of heritage trees per Section 5.60 of the City of Dublin Municipal Code. Removal of protected trees, due to construction activities within the project area would be considered a potentially significant impact. If the proposed project were to remove and/or damage trees that are considered heritage trees per Section 5.60 of the City of Dublin Municipal Code, this would be considered a potentially significant impact. Implementation of the following mitigation measure would reduce this impact to a less than significant level by requiring that the project applicant survey all the trees within the project area and identify those that shall be removed with implementation of the proposed project Mitigation Measure MM 3.3-8 Conduct Tree Survey and Replace Trees at Suitable Ratios. The project applicant shall retain a certified arborist to survey all trees located within the project area in order to identify and evaluate those trees that shall be removed with implementation of the proposed project. An arborist report shall be prepared consistent with the certified arborist to survey trees within the project area and identify and evaluate trees that shall be removed. The arborist report shall be prepared and submitted to the City of Dublin to document the trees that are to be removed. If any of the trees fall under the jurisdiction Section 5.60 of the City’s Municipal Code, the project applicant shall then mitigate impacts to trees based on the following or equivalent protective measures depending on the size and health of trees to be removed. a. Prior to the start of construction, the project applicant shall install exclusion fencing at the dripline of any tree that will not be affected by the construction and prohibit any parking or storage of construction materials or other materials inside the fence. b. Mitigation, at an inch-by-inch ratio, shall be provided for native trees larger than 24inches in circumference measured at four (4) feet six (6) inches above natural grade. Potential Conflicts with a Habitat Conservation Plan There is no habitat conservation plan within Alameda County or the City of Dublin that the proposed project would be able to participate in. The Eastern Alameda Conservation Strategy (EACS) is still in the developing process and has not been approved or adoptedwas released in December 2010 and the City of Dublin adopted Dublin Crossing Specific Plan Final EIR Biological Resources Page 3-89 a resolution accepting the EACS as guidance for environmental permitting for public projects affecting habitat and endangered species in Eastern Alameda County. The City acknowledges the EACS as a guidance tool. Therefore the proposed project would not have a conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation, or other approved local, regional, or state habitat conservation plan. Therefore, the proposed project would have no impact. Dublin Crossing Specific Plan Final EIR Geology and Soils Page 3-116 expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking which would reduce this potentially significant impact to a less than significant level. Mitigation Measure MM 3.5-3 Preparation of Design-Level Geotechnical Report. Future development within the project area shall consult with a registered geotechnical engineer to prepare a design level geotechnical report that incorporates the recommendations in the preliminary geotechnical investigation by Berlogar, Stevens and Associates (March 2012). The design level geotechnical report shall address site preparation and grading (including measures to address potential liquefaction and expansive soils), building foundations, CBC seismic design parameters, and preliminary pavement sections. This report shall be submitted in conjunction with Building Permit application(s) and reviewed and approved by the City. The Report’s recommendations shall be incorporated into the project design and construction documents. Liquefaction Impact 3.5-4: Future development associated with the proposed project could expose people or structures to potential substantial adverse effects of liquefaction. This is considered a potentially significant impact. Generally, when liquefaction occurs because of earthquakes, the conditions of cohesionless surface material accompanied with relatively shallow water tables underlying the area were the factor. In such cases, ground vibration increases the pore pressure resulting in water moving upward whereby turning the sand or silt into a quicksand like condition. The surface characteristics include the development of sand boils, surface cracks, ground settlement and differential compaction. Without proper soil engineering, foundation design, and construction, the project area could expose people and/or structures to hazards associated with seismic- related ground failure. The project area is located within a CGS Seismic Hazard Zone where liquefaction may occur during a strong earthquake. Based on the geotechnical investigation there is the potential for liquefaction to occur within the occasional interbedded layers of loose to medium dense sandy soils that exist below the groundwater table. These potentially liquefiable layers generally range from approximately half a foot to two feet thick and are overlain by at least ten feet of non-liquefiable cover. As part of The results of the settlement calculations performed for the liquefaction analysis, the results indicate that the potential liquefaction-induced settlement would likely range from approximately half an inch to two inches. Differential settlement is estimated to be on the order of one inch. Surface manifestation of liquefaction (e.g. sand Dublin Crossing Specific Plan Final EIR Geology and Soils Page 3-117 boils, ground fissures) are is not anticipated due to the presence of at least ten feet of non-liquefiable cover. Future development within the project area would be required to comply with the City’s Building Code, liquefaction regulations of the CBC, and the City’s standard engineering practices and design criteria. In addition, Mitigation Measure MM 3.5-3 would require that the project applicant prepare a design-level geotechnical report, which would address liquefaction and reduce this potentially significant impact to a less than significant level. Soil Erosion Impact 3.3-5: Implementation of the proposed project may result in soil erosion or the loss of topsoil during short-term construction activities within the project area. This is considered a less than significant impact. A portion of the project area is covered by roads, buildings, parking lots, and sidewalks from the Camp Parks Reserve Forces Training Area. However, earth- disturbing activities associated with future construction activities within the project area have the potential to increase erosion if proper sedimentation and erosion control methods are not in place. According to the Natural Resources Conservation (NRCS) service, the Clear Lake soil is characterized as having slow to very slow erosion potential and the Diablo Clay soils has a moderate erosion potential. The City of Dublin Public Works Department Policy No. 95-11 requires that all plans specify both long-term and short-term erosion control measures that will be implemented during construction activities to control runoff, erosion, and sediment movement prior to issuance of a building permit. In addition, in order to comply with the National Pollution Discharge Elimination System (NPDES) permit process for storm drainage and construction site discharge, projects involving construction that are greater than one acre in size within the project area is required to prepare and implement a Storm Water Pollution Prevention Plan (SWPPP) which would be submitted for review by the City of Dublin Public Works Department during the Grading/Site Work and Building Permit process, The SWPP describes the stormwater BMPs (structural and operational measures) that would control the quality (and quantity) of stormwater runoff. In addition, the NPDES permit requires implementation of non-point source control of runoff through the application of a number of Best Management Practices (BMPs). These BMPs are meant to reduce the amount of constituents, including eroded sediment, that enter streams and other water bodies. Examples of BMPs typically used in the City of Dublin include vegetated swales in parking areas. Compliance with the City of Dublin Public Works Department Policy No. 95-11: the NPDES permit process; and the City’s Building Code requirements the proposed project would result in a less than significant impact from erosion during construction activities. Dublin Crossing Specific Plan Final EIR Hazards and Hazardous Materials Page 3-138 Livermore Municipal Airport Master Plan, the project area is not located within the airport influence area and is not located within an unacceptable noise contour. North of the project area, is a heliport, which is used infrequently at approximately18 days a year. Wildland Fire Hazards Due to the urban nature of the project area, the proposed project is not located within an area that would be subject to the requirements of the City’s Wildfire Management Plan (City of Dublin 2002). Project Setting The project area was historically used as grazing land prior to the installation of Camp Parks in the 1940s. The project area contains former and/or existing supply buildings and warehouses, infrastructure maintenance facilities, vehicle repair facilities, fueling points, hazardous waste accumulation sites, office and administration buildings, a buried construction debris deposition area, several railroad spurs, former lumber yards, and soil stockpiles. The majority of the existing buildings are located within the western portion of the project area on approximately 77 acres. Approximately 112 acres in the eastern portion of the project area is generally undeveloped. There are approximately 16 existing buildings/structures warehouses that are interspersed amongst fields of non-native grasslands where other buildings once stood. Most of the buildings/warehouses were constructed as World War II temporary buildings and consist of rectangular structures that are primarily comprised of horizontal wood siding and a flat built-up roof. Hazardous Materials A total of 41areas with environmental conditions of concern were identified at the project area. Environmental remediation activities been conducted at the 38 of the 41 areas and have received or are in the process of receiving a no further action (NFA)/case closure from the regulatory agencies. The following sites, which may require additional remedial action in order to obtain a NFA status include:  Former Building 109/ Parks Reserve Forces Training Area (PRFTA) 2 - Former Building 109/PRFTA 2 located at the southwestern portion of the project area containing contained concentrations of dioxin and lead within the surficial soil above the acceptable risk-based screening levels for closure. The contamination was remediated by the U.S. Army and cleaned to industrial standards. There are currently groundwater monitoring wells at this site and the U.S. Army has completed three quarters of sampling in coordination with the Department of Toxic Substances and Control (DTSC). The U.S. Army is awaiting confirmation from the regulatory agencies regarding the remediation of this site (Personal Communication with Mark Dublin Crossing Specific Plan Final EIR Hazards and Hazardous Materials Page 3-139 Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013and September 17, 2013).  Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of the project area and requires land use controls by the San Francisco CRWQCB to obtain an NFA status. The San Francisco CRWQCB issued a Pre- NFA determination on May 28, 2008. This determination acknowledged that groundwater cleanup objectives have been met. However, a deed restriction (land use control) is required to achieve a full NFA designation due to the presence of soil which contains diesel concentrations greater than acceptable levels. The Department of Toxic Substances Control (DTSC) concurred with these findings in January 20, 2012.  Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern portion of the potential construction debris dump sites consists of large mounds of soil and debris north of Dublin Boulevard and east of the installation entrance road. Construction and demolition debris, asbestos containing material (ACM), waste asphalt, drill cuttings, and grass clippings were observed in the mounds during site visits conducted from 1990 through 2002. DTSC stated that the area may need further investigation prior to receiving an NFA. Soil samples revealed that there were high hydrocarbons in the soil. The soil has been removed and re-sampled with negative results and have been subsequently submitted to DTSC for review (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013).  Asbestos containing materials (ACM) and Lead Based Paints (LBPs) in existing structures - Asbestos is a strong, incombustible, and corrosion resistant material, which was used in many commercial products between the 1940s and the early 1970s. If inhaled, asbestos fibers can result in serious health problems. Asbestos Containing Materials (ACMs) are building materials containing more than one percent asbestos (some state and regional regulators impose a one-tenth of one percent (0.1 percent) threshold). Until 1978, when the U.S. Consumer Product Safety Commission (CPSC) phased out the sale and distribution of residential paint containing lead, many homes were treated with paint containing some amount of lead. It is estimated that over 80 percent of all housing built prior to 1978 contains some Lead-Based Paints (LBP). The mere presence of lead in paint may not constitute a material to be considered hazardous. In fact, if in good condition (no flaking or peeling), most intact LBP is not considered to be a hazardous material. LBPs can create a potential health hazard for building occupants, especially children when in poor condition. ACMs and LBPs are associated the structures located within the project area that were constructed more than 40 years ago. Dublin Crossing Specific Plan Final EIR Hazards and Hazardous Materials Page 3-146 Result in the Disturbance of Contaminated Soil or Groundwater Impact 3.7-4: The project area is not located on a hazardous material site pursuant to Government Code Section 65962.5. However, based on the Phase I ESA there are three sites currently being evaluated by the U.S. Army. Hazardous materials may be encountered during construction. This would be considered a potentially significant impact. There are approximately three sites where remedial action activities are still required to attain a commercial/industrial NFA status, which is the standard used by the U.S. Army. These sites include: Building 109/PRFTA 2; Area 761/PRFTA 13; and the eastern portion of the potential construction debris dump sites (ECP 36, 37, and 39) as described below.  Former Building 109/PRFTA - Former Building 109/PRFTA 2 located at the southwestern portion of the project area containing contained concentrations of dioxin and lead within the surficial soil above the acceptable risk-based screening levels for closure. The contamination was remediated by the U.S. Army and cleaned to industrial standards. There are currently groundwater monitoring wells at this site and the U.S. Army has completed three quarters of sampling in coordination with the Department of Toxic Substances and Control (DTSC). The U.S. Army is awaiting confirmation from the regulatory agencies regarding the remediation of this site (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013 and September 17, 2013).  Area 761/PRFTA 13 - Area 761/PRFTA 13 is located at the central portion of the project area and requires land use controls by the San Francisco CRWQCB to obtain an NFA status. The San Francisco CRWQCB issued a Pre- NFA determination on May 28, 2008. This determination acknowledged that groundwater cleanup objectives have been met. However, a deed restriction (land use control) is required to achieve a full NFA designation due to the presence of soil which contains diesel concentrations greater than acceptable levels. The Department of Toxic Substances Control (DTSC) concurred with these findings in January 20, 2012.  Potential Construction Debris Dump Sites (ECP 36, 37, 39) - The eastern portion of the potential construction debris dump sites consists of large mounds of soil and debris north of Dublin Boulevard and east of the installation entrance road. Construction and demolition debris, asbestos containing material (ACM), waste asphalt, drill cuttings, and grass clippings were observed in the mounds during site visits conducted from 1990 through 2002. DTSC stated that the area may need further investigation prior to receiving an NFA. Soil samples revealed that there were high hydrocarbons in the soil. The soil has been removed and re-sampled with negative results and have been subsequently submitted to DTSC for review Dublin Crossing Specific Plan Final EIR Hazards and Hazardous Materials Page 3-147 (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army, Camp Parks on May 21, 2013). In addition, a property located up-gradient of the project area has affected the underlying groundwater with petroleum hydrocarbons. However, based on the distance of this site from the project area, it is unlikely that the property could have affected the project area. The U.S. Army and NASA are responsible for environmental remediation of existing hazardous materials within the project area and have agreed to remediate the project area to state and federal requirements (Personal Communication with Mark Hall, Environmental Coordinator, U.S. Army Camp Parks on June 17, 2013). Contamination that remains after the U.S. Army or NASA transfers the property to the project applicant and/or that needs to be remediated to a higher standard (e.g. residential) will either be remediated by the project applicant or by the U.S. Army or NASA, prior to and during site grading and demolition activities with future development activities. Construction activities would be restricted within these portions of the project area until an NFA status has been achieved. If contamination is discovered during construction activities in the vicinity of these sites, this would be considered a potentially significant impact. The following mitigation measure would reduce this impact to a less than significant level. Mitigation Measure MM 3.7-4 Remediation of Hazardous Materials. Future development within the vicinity of Former Building 109/PRFTA, Area 761/PRFTA 13, and the Potential Construction Debris Dump Sites shall not proceed until a NFA status is granted and the project area has been cleaned to the appropriate land use standard to the satisfaction of Department of Toxic Substances and Control (DTSC). The NFA status paperwork shall be submitted to the City in conjunction with the Building and Grading/Site work permit and shall be found acceptable by the City prior to ground disturbance. Implementation of mitigation measure MM 3.7-4 would reduce potential impacts associated with contaminated soils within the project area to a less than significant level. Emit Hazardous Materials in the Vicinity of a School Impact 3.7-5: There are no schools located within a quarter mile of the project area. However, the proposed project includes construction of an 11 12 net usable acre school site that would be located adjacent to proposed residential uses. In addition, commercial businesses proposed within the project area would be required to comply with federal, state and Dublin Crossing Specific Plan Final EIR Hazards and Hazardous Materials Page 3-148 local regulations regarding hazardous substances. Therefore, the proposed project would result in a less than significant impact to the school proposed within the project area. There are no schools located within a quarter mile of the project area. However, the proposed project includes a 12 net usable acre school site and the project area is located within two miles of several existing schools: Dublin High School (8151 Village Parkway, Dublin), Valley High School and Wells Middle School (6800 Penn Drive, Dublin), Fallon Middle School (3601 Kohnen Way, Dublin), Murray Elementary School (8435 Davona Drive, Dublin), Green Elementary School (3300 Antone Way, Dublin) Dougherty Elementary School (5301 Hibernia Drive, Dublin) and Frederikson Elementary School (7243 Tamarack Drive, Dublin). New businesses that locate near residential areas or within a quarter mile from a school may expose these sensitive land uses to greater risk of exposure to hazardous materials, wastes, or emissions. While the risk of exposure to hazardous materials cannot be eliminated, measures can be implemented to maintain risk to acceptable levels. As noted in the project description, future new development will include residential, commercial, office and retail uses, as well as a community park. Hazardous materials would be typical for these types of uses with no high-risk materials such as those that are expected with industrial uses. Under these circumstances, required compliance with regulations established by federal, State and local regulatory agencies is considered adequate to avoid the negative effects related to the use, storage, emission and the transport of hazardous materials at future development/redevelopment sites within the project area. In addition, the proposed school site would be surrounded by proposed residential uses and therefore would not be in the vicinity of future commercial uses proposed within the project area. Therefore, the proposed project would have a less than significant impact on the proposed elementary school and schools in the vicinity of the project area with compliance of applicable federal, State, and local regulations. Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-150 In developed portions of the City of Dublin, storm drainage is conveyed in underground pipes, channels, and to a lesser extent, swales. New development is required to install adequately-sized storm drains, connected to the City’s system, to accommodate increased runoff volumes. Stormwater drainage is managed by the City of Dublin Public Works Department and all runoff in the vicinity is directed to regional storm drain facilities owned and maintained by Zone 7 of the Alameda County Flood Control and Water Conservation District (Zone 7). Flooding As shown in Figure 3.8-1: Hydrologic Features, a portion of the project site area is located within Zone X and Zone AE floodplains as mapped on the Flood Insurance Rate Maps prepared by FEMA (Panel 309). Zone X is defined as “areas of 0.2 percent annual chance flood; areas of 1 percent annual chance flood with average depths of less than one foot or within drainage areas less than one square mile; and areas protected by levees from one percent annual flood.” The areas adjacent to the Chabot Channel are mapped by FEMA as Zone AE, which are designated as special flood hazard areas subject to inundation by the one percent annual flood with Base Flood Elevations determined as shown in the Flood Insurance Rate Map, Plate 5. Reservoirs/Dams There are 29 reservoirs/dams in Alameda County. The following reservoirs are located within 12 miles of the proposed project:  Don Castro Reservoir is located approximately 9 miles to the east of the proposed project in Hayward. It is maintained by the Alameda County Flood Control and Water Conservation District for flood control, and by the East Bay Regional Park District as a recreational facility.  Lake Chabot Reservoir is located approximately nine miles west of the project area. It was completed in 1875 by damming San Lorenzo creek and served as the primary water source for the East Bay Area.  The Upper San Leandro Reservoir is located approximately 13 miles northwest of the project area. It was built by the East Bay Water Company in 1926 and is maintained by the East Bay Municipal Utility District.  The San Antonio Reservoir is located approximately 13 miles south- southeast of the project area. Built in 1964 by the City and County of San Francisco, it is managed by the San Francisco Public Utilities Commission (SFPUC). The reservoir captures local rain and runoff from the Alameda Watershed and contributes surface water supplies to the SFPUC Water System.  Lake de Valle is located approximately 14 miles southeast of the project area. De Valle Dam and Lake de Valle were built in 1968 as part of the State Water Project. It provides storage for the South Bay Aqueduct and flood control for Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-153 export of concentrated minerals or salts from the Main Basin and the delivery of treated water with reduced TDS and hardness levels to Zone 7’s customers. Water Quality The quality of surface and groundwater at the proposed project area is affected by land uses within the entire watershed. Drainage from the project area affects the quality of water in larger creeks and drainages downstream, including Arroyo de la Laguna, Alameda Creek, and San Francisco Bay. Water quality in surface and groundwater bodies is regulated primarily by the State and Regional Water Quality Control Boards (discussed below). Project Site Setting Watershed Characteristics As shown in Figure 3.8-2: Existing Drainage, the Camp Park’s entire 1,800+ acrea majority of the Camp Parks watershed drains through the project area. The majority of the runoff from this watershed is conveyed through natural and man- made swales. These swales cross the project area and are intercepted along the north side of Dublin Boulevard and conveyed to various existing Zone 7 drainage facilities. The largest portion of the watershed is located north of Camp Parks and drains south within the main channel, concentrating near the intersection of the proposed Scarlett Drive extension and Dublin Boulevard in Line G-1, which is currently a mapped FEMA 100-year floodplain. The smaller portion of the upstream watershed to the northeast of Camp Parks collects runoff in an existing concrete trapezoidal channel (G-5) and conveys it to the intersection of Arnold Road and Broder Boulevard. Just north of this intersection, there is a headwall with two to 48-inch pipes. These pipes currently “split” the channel flow, diverting a portion towards Camp Parks and Line G-1. The remaining flow is conveyed south under the Arnold Drive/Broder Boulevard intersection, through a small basin between Gleaeson Drive and Broader Boulevard and into an open channel along the west side of Arnold Drive. Per Zone 7, the maximum flow of 950 cubic feet per second (cfs) at Line G-1 assumes that this splitter has been removed. Based on the offsite detention basin proposed in the “Hydrologic and Hydraulic Analysis for the Proposed Camp Parks Detention Basin Study” (RJA 2013), the splitter will remain in place. A second flow splitter was installed at the Arnold Road open channel, near Central Parkway dividing flow between Drainages G-5 and G-2. A seven foot and four foot box culvert down Arnold Road to Line G-2, while a trapezoidal channel conveys runoff into the project area to Line G-5. Per the Santa Rita Drainage Master Plan, a maximum of 350 cfs can be “split” and directed to Line G-5. Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-154 Underground Drainage Facilities Underground drainage facilities include the Line G-1 channel that runs along the west side of Hutchins Avenue and across the project area towards the future Scarlett Avenue extension at Dublin Boulevard. A 48-inch corrugated metal pipe (CMP) intercepting an existing open channel is located just north of the 8th Street and west of Davis Avenue. The pipe assumed to flow south to 5th Street (RJA 2013). An approximately 30-inch re-enforced concrete pipe (RCP) exiting a curb inlet at the northwest corner of 5th Street and Davis Avenue connects to another inlet just to the west on 5th Street. This inlet is assumed to intercept the northerly 48-inch CMP. The outlet pipe from this inlet flow flows in a southeasterly direction. A box culvert discharging to Line G-1 is located in the middle of the project site. A surface investigation of the project by RJA engineers found that the size of the box culvert was indeterminable due to the amount of silt and vegetation at the outfall to the channel. It was assumed that this is the discharge point for the above mentioned drainage facilities (RJA 2013). Regulatory Setting Federal Clean Water Act The principal law governing pollution of the nation’s surface waters is the Federal Water Pollution Control Act (Clean Water Act [CWA]). Originally enacted in 1948, it was amended in 1972 and has remained substantially the same since. The CWA consists of two major parts: provisions that authorize federal financial assistance for municipal sewage treatment plant construction and regulatory requirements that apply to industrial and municipal dischargers. The CWA authorizes the establishment of effluent standards on an industry basis. The CWA also requires states to adopt water quality standards that “consist of the designated uses of the navigable waters involved and the water quality criteria for such waters based upon such uses”. National Pollutant Discharge Elimination System To achieve its objectives, the CWA is based on the concept that all discharges into the nation’s waters are unlawful, unless specifically authorized by a permit. The NPDES is the permitting program for discharge of pollutants into surface waters of the United States under Section 402 of the CWA. Thus, industrial and municipal dischargers (point source discharges) must obtain NPDES permits from the appropriate RWQCB (i.e., the Central Valley region). The existing NPDES (Phase I) stormwater program requires municipalities serving more than 1,000,000 persons to obtain a NPDES stormwater permit for any construction project larger than five acres. Proposed NPDES stormwater regulations (Phase II) expand this existing national program to smaller municipalities with populations of 10,000 persons or more and construction sites that disturb more than one acre. For other dischargers, Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-159 Alameda Countywide Clean Water Program The City of Dublin is a co-permittee of the Alameda Countywide Clean Water Program which was started in 1991. This local government and community Program educates the public on how to keep businesses and homes from contributing to stormwater pollution, and also coordinates its activities with other pollution prevention programs, such as wastewater treatment plants, hazardous waste disposal, and water recycling. 3.8.3 Relevant Project Characteristics Water Demand According to the Water Supply Assessment prepared by DSRSD, the proposed project would require additional water demand for residential and commercial uses. Water demand for the proposed uses would be approximately 371 acre feet per year for the proposed project with the proposed elementary school and 365 acre feet per year without the elementary school. Recycled water demand for the proposed project would be 144 acre feet per year for the proposed project with the elementary school and 131 acre feet per year without the elementary school (West Yost Associates 2013). Surface Water Management Surface water management consists of both on-site runoff and the management of off-site runoff extending through or around the site. On-site Surface Water Runoff As shown in Figure 3.8-3: Proposed DrainageProposed Q100 Project Flows, surface waters within the project area would be divided into four drainage sheds. Drainage sheds A9-A (63.3 acres) and A9-B (81.7 acres) would ultimately flow into the Line G- 1 drainage channel. Two underground detention basins, located within the proposed community park, would be constructed. Preliminary estimates by Ruggeri Jensen Azar (RJA) call for the construction of two underground basins (RJA 2013). Park Basin #1, which captures drainage from A9-B, would have a storage capacity of 3.3 acre feet and an outflow rate of 80 cfs. Park Basin #2, which captures drainage from A9-A, would have a storage capacity of 1.6 acre feet and an outflow of 71 cfs.7 Based on project plans, drainage from both of these underground basins would be conveyed via an underground pipe to the proposed Chabot Creek riparian channel that would be realigned through the proposed community park. 7 This analysis assumed two open-air basins and that the bottom 2 ½ feet of each basin was inundated with runoff from the previous storm event. Given the fact that these two basins are now proposed to be underground, the ultimate storage capacities would be determined as part of detailed engineering design. However, the basins would be designed so that there is sufficient capacity to ensure that runoff capacities to not exceed pre-condition flow conditions. Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-160 Drainage sheds XX-1 (23.1 acres) and XX-2 (20.9 acres), which are located in the southeast corner of the site, would ultimately flow into the Line G-5 drainage channel. Two underground detention basins consisting of 96 inch diameter storm drain pipes would be constructed along the proposed Central Parkway, or other suitable public roadway. Basin 3-1 would be capable of storing 1.6 acre feet and Basin 3-2 would be capable of storing 1.7 acre feet. Off-site Surface Water Runoff Management There are two main sources of existing offsite runoff that would have to be conveyed around or through the proposed project to accommodate development. The first off-site flow is a portion of the main 1,800 acre watershed located north of the project area. The majority of this flow currently drains from the north to via the existing Line G-1 channel, discharging at the intersection of proposed Scarlett Drive extension and Dublin Boulevard. Based on discussions with the City and the project applicant, a new offsite detention basin will be constructed on currently Army- owned property, north of the project site. This new off-site basin will be designed to reduce Q100 (storm event that occurs every 100 years) runoff flows from currently 924 cfs to 604 cfs. Water flowing out from this new off-site basin would then flow into the 1.7 acre Chabot Creek riparian channel through the proposed community park. Preliminary plans call for this drainage channel to be constructed with a four and a half foot wide channel base, 3:1 side slopes and an “n” value (water flow velocity rate, or Manning’s coefficient) of 0.050. The second offsite flow is from the area east and north of Arnold Road. This includes the watershed north of Broder Boulevard, and the separate developed area east of Arnold Drive. Improvements would include undergrounding the existing open channel along Arnold Drive via a new double 4 foot by 8 foot re-enforced concrete box culvert. The existing second flow “splitter” near the proposed Central Parkway would be removed and a new “splitter” structure would be new underground flows south on Arnold Road and the required flow split between Lines G-2 and G-5. A new dual 60 inch re-enforced concrete pipe would be constructed along Central Parkway, or other suitable public roadway, intercepting Basin’s 3 -1 and 3-2, and ultimately flowing into Line G-5 south of Dublin Boulevard. Hydromodification and Water Quality Management Hydromodification (stormwater management) for the proposed project as a whole would be addressed the construction of the four basins, described above. These facilities would be constructed prior to, or in concert with any “upstream” site development. Backbone roadway infrastructure would be constructed in phases consistent with the development of adjacent parcels. Each portion of the roadway will incorporate Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-161 roadside bioretention area to treat stormwater runoff from the roadways (see Figure 2-11: Conceptual Stormwater Drainage and Detention System, above, and roadway cross-sections in the Draft Dublin Crossing Specific Plan). These bioretention areas will be connected to the roadway stormwater systems which would then discharge into one of the four basins. In accordance with the Alameda County Clear Water Program, low impact design (LID) site design measures for water quality protection will be implemented as individual parcels are developed, to adequately address the impacts of their proposed development and to show compliance with the post-construction, long- term requirements of Provision C.3. Water quality features include bioretention areas, flow-through planters, tree well filters, median filters and “treatment trains.” Trash capture facilities would also be incorporated into the system. These on-site facilities would be connected to the stormwater drain system in the backbone roadways. Stormwater Pollution Previsions Prevention Plans (SWPPPs) would also be prepared, as a separate document, to control short-term construction-related discharge pollutants as required by the NPDES General Permit for Storm Water Discharges Associated with Construction and Land Disturbance Activities. the CA State Water Resources Control Board Order No. 99-08-DWQ, . Impacts and Mitigation Measures Criteria for Determining Significance In accordance with the CEQA, State CEQA Guidelines, and agency and professional standards, a project impact would be considered significant if the project would:  Violate any water quality standards or waste discharge requirements;  Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted;  Substantially alter the existing drainage pattern of the site or area, including the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site;  Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site; Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-168 Additionally, drainage from the proposed Park Basin #2 (the northerly basin) is shown by RJA to discharge directly into the proposed 1.7 acre Chabot Creek riparian channel, which would be realigned and extend through the proposed community park. At this point, it is unclear what entity will own the Chabot Creek riparian channel, and what measures will be put in place to ensure it is adequately managed and maintained. This could result in a potential significant environmental impact with the long-term viability of the stormwater management system as is currently proposed. Implementation of the following mitigation measures will reduce these impacts to less than significant. Mitigation Measure MM 3.8-4a Construction of a new Off-site Detention Basin North of the Project Site. Prior to the issuance of grading permits for Phase 2 of the proposed project, the project applicant shall work in coordination with the U. S. Army (Camp Parks) to design and construct a new off- site detention basin designed to ensure that flow rates to Line G-1 do not exceed the maximum Q100 discharge flow rate of 950 cfs as required by Zone 7. The design plans for this new off-site detention basin will be reviewed by the City, in coordination with Zone 7, for verification of compliance with all applicable regulations and consistency with on-site drainage requirements, prior to construction. MM 3.8-4b Re-align Stormwater Outflow from Proposed North Basin #2. Prior to issuance of the first grading/sitework permit associated with the construction of the proposed community park, the project applicant shall submit to the City for review and approval, plans, details, and calculations for the proposed underground stormwater detention structure(s) and associated storm drain system within the park parcel to ensure that adequate capacity will be provided; that the resultant discharge flow rates meet the requirements of the Regional Water Quality Control Board; and that the placement of the underground facilities in the park will not impact the park design and construction of recreational facilities. The location and layout of the underground detention structures and the connection of these facilities to the proposed Chabot Creek riparian channel, box culvert or downstream facilities shall be agreed upon by both the project applicant and the City. The method and location of stormwater discharge of the underground facilities shall be reviewed and approved by all appropriate regulatory and/or permitting agencies. a revised stormwater drainage plan that realigns the stormwater outflow associated with the proposed North Basin #2 from the 1.7 acre Chabot Creek riparian channel (as is currently proposed) to a separate underground pipe that connects directly with the existing box culvert Dublin Crossing Specific Plan Final EIR Hydrology and Water Quality Page 3-169 located at proposed Scarlett Court Extension and Dublin Boulevard, and thereby avoids stormwater discharge into the 1.7 acre Chabot Creek riparian channel. Flooding Exposure / Risk, Including the Failure of a Levee or Dam Impact 3.8-5: The proposed project would not expose people or structures to a significant risk of loss, injury, or death involving flooding, including flooding as a result of the failure of a levee or dam. Structures and personnel would not be subject to greater risk with implementation of the proposed project as compared to existing conditions. This is considered a less than significant impact. According to the Association of Bay Area Governments (ABAG) Dam Failure Inundation Maps, a very small portion of the southwestern portion of the project area is located within the limits of potential inundation zone from a catastrophic failure of the dam at Lake del Valle, which is located approximately 10.5 miles southeast of the project area (ABAG 2013). However, the State Division of Safety of Dams under the authority of the Department of Water Resources inspects this and other dams under its jurisdiction on an annual basis to confirm if each dam is safe, performing as intended and is not developing problems. Roughly a third of these inspections each year include in-depth instrumentation reviews of the dam surveillance network data. The Division also periodically reviews the stability of dams and their major appurtenances in light of improved design approaches and requirements, as well as new findings regarding earthquake hazards and hydrologic estimates in California. Based on the continued dam-safety compliance inspection conducted by the Division of Safety of Dams, the risk of flooding from catastrophic dam failure is considered low. Therefore, this would be considered a less than significant impact, and no mitigation is required. Dublin Crossing Specific Plan Final EIR Land Use and Planning Page 3-177 uses and would not physically divide an established community. Therefore, this would be considered a less than significant impact, and no mitigation is required. Conflict with Applicable Land Use Plans, Policies, or Regulations Impact 3.9-3: Implementation of the proposed project would not conflict with goals and policy of the City of Dublin General Plan, nor the City of Dublin Zoning Code. This is considered a less-than-significant impact. As described in the project description, residential, commercial, mixed-use and public uses could be developed within the project area under the proposed Dublin Crossing Specific Plan. The Specific Plan includes a maximum of 1,995 residential units; 200,000 square feet of commercial uses, a 30 net-acre community park; five acres of neighborhood park and a 12 an 11 net usable acre elementary school site. The proposed residential uses would be consistent with the existing surrounding residential uses, which are of similar density and design. Currently the majority of the project area is designated Public Facilities in the City of Dublin General Plan and is zoned Agriculture. The City of Dublin General Plan, including the General Plan Land Use Map, will be amended concurrent with the adoption of the Dublin Crossing Specific Plan to include the proposed land use designations to replace the existing General Plan land use designations for the area as shown in Figure 2-7: Conceptual Land Use Plan. The Zoning Map for the project area would be amended concurrent with the adoption of the Dublin Crossing Specific Plan to rezone the project area to Specific Plan Planned Development (PD-DX). Where land use regulations and/or development standards in the Dublin Zoning Ordinance are inconsistent with the Dublin Crossing Specific Plan, the standards and regulations of the Specific Plan prevail. Any issue not specifically addressed in the Dublin Crossing Specific Plan shall be subject to the Dublin Zoning Ordinance and/or Municipal Code. Interpretations may be made by the Community Development Director if not specifically covered in the City’s existing regulations. Proposed land use designations would include Dublin Crossing Lower Density Residential (DC LDR) with a density of 6 to 14 units per net acre; Dublin Crossing Medium Density Residential (DC MDR) with a density of 14.1 to 20 units per acre; Mixed Use with a density of 20.1 to 60 units per net acre; General Commercial/DC Medium Density Residential (GC/DC MDR) with a maximum floor to area ratio (FAR) of 1.0 and a maximum density for residential development within this district of 20 units per acre; General Commercial/DC High Density Residential (GC/DC HDR) with a maximum floor to area ratio (FAR) of 1.0 and a maximum density for residential development within this district of 55 units per acre; Parks/Open Space (P); Open Space (OS), and School (S). With the adoption of the General Plan amendments, the proposed uses would be allowed within the project area. Dublin Crossing Specific Plan Final EIR Land Use and Planning Page 3-178 The proposed project’s consistency with the City of Dublin General Plan discussed in Table 3.9-1: City of Dublin General Plan Consistency Analysis. Consistency with policies related to environmental effects are addressed in each technical section of the EIR. As demonstrated, the proposed project would not be in conflict with the applicable land use policies of the General Plan. Therefore, this would be considered a less than significant, and no mitigation is required. Table 3.9-1: City of Dublin General Plan Consistency Analysis City of Dublin General Plan Consistency Analysis Land Use Element 2.1.1 Housing Availability Implementing Policy B – Designate site available for residential development in the primary planning area for medium to medium high density where site capability and access are suitable and where the higher density would be compatible with existing residential development nearby. Consistent. The Specific Plan includes a maximum of 1,995 residential units; 200,000 square feet of commercial uses, a 30 net-acre community park; five acres of neighborhood park and an 11a 12 net usable acre elementary school site. The proposed residential uses would be consistent with the surrounding residential uses to the south and west of the project area. Parks and Open Space Element 3.1 Open Space for Preservation of Natural Resources and For Public Health and Safety Implementing Policy C - Acquire and improve parklands in conformance with the standards and policies recommended in the City’s General Plan. Consistent. The proposed project includes a 30 net-acre community park and five acres of neighborhood park within the project area. Implementing Policy D – Encourage an efficient and high intensity of use of the flat and gently sloping portions of the planning area as a means of minimizing grading requirements and potential impacts to environmental and aesthetic resources. Consistent. The project area is generally flat and higher-density urban development with residential and commercial uses would be facilitated by the proposed project. Implementing Policy I - Require land dedication and improvements for the parks designated in the General Plan for the Eastern Extended Planning Area and based on a standard of 5 net acres per 1,000 residents. Collect in-lieu park fees as required by City policies Consistent. Based on a population estimate of 2.73 persons per household and a maximum of 1,995 residential units, the proposed project would increase the population by approximately 5,446 persons. Based on 30 net acres of park space within the project area, the proposed project exceeds the City standards, which would require approximately 27 acres of parks space. Schools, Public Lands and Utilities Element 4.1 Public Schools Dublin Crossing Specific Plan Final EIR Land Use and Planning Page 3-179 City of Dublin General Plan Consistency Analysis Implementing Policy C. Initiate preparation of site plans or specific plans jointly with the Dublin Unified School District prior to sale. Consistent. The proposed project includes an 12 net usable acre site for development of a future elementary school. The project applicant has been working with the Dublin Unified School District to coordinate future dedication of this school site to the District. Circulation and Scenic Highways Element 5.1.1 Roadway Standards Guiding Policy A – Design non-residential streets to (1) accommodate forecasted average daily traffic demand on segments between intersections, and (2) minimize congested conditions during peak hours of operation at intersections and serve a balance of vehicles, bicycles, pedestrian, and transit. Consistent. The Specific Plan includes a circulation network to accommodate additional traffic associated with future development. The Transportation section of this Draft EIR analyzed the transportation circulation impacts associated with the proposed project and includes mitigation measures to help reduce traffic congestion at affected intersections. Dublin Crossing Specific Plan Final EIR Noise Page 3-193 Exposure to Long-Term Stationary Noise Impact 3.10-3: Compliance with design guidelines and development standards contained within the Specific Plan will ensure that potential future development within the project does not exceed established noise standards. This is considered a less than significant impact. The proposed project could result in long-term stationary noise impacts on sensitive receptors in the project vicinity, which consist of residential uses adjacent to and within the project area. Examples of stationary noise sources that could be located within the project area include commercial operations, generators, air conditioning facilities, and stationary noise sources at the proposed community park including an amphitheater, carousel, etc. As shown in Figure 2-7: Conceptual Land Use Plan, the proposed commercial uses would be located in the eastern portion of the project area along Arnold Road and Dublin Boulevard. The proposed 11 12 net usable acre school site would be located within the center of the project area and the proposed community park would be located at the corner of Scarlett Drive and Dublin Boulevard. Conceptual plans for the community park show the amphitheater and carousel located within the central portion of the park and would not be immediately adjacent to residential uses. Uses at parks and schools are generally compatible with residential uses as the generation of stationary noise sources typically occur during the daytime hours. The purpose of the Specific Plan is to guide development and design within the project area. This will be accomplished by a set of regulations, design principles, and related implementing actions designed to foster quality development and prevent excessive noise. For example, to reduce noise from service, storage, and loading areas, the Specific Plan recommends that the location and hours of loading and unloading areas should be designed to minimize noise impacts on the surrounding residential neighborhood (Specific Plan Design Guidelines Section 3.1.11). For drive-through and drive-up uses, the Design Guidelines specify that outdoor ordering systems are to be located to direct sound away from residential uses and common areas, or otherwise minimize noise impacts to these uses. Entertainment uses should be separated from residential and other uses that may conflict with the higher levels of light, noise, and pedestrian traffic. The Specific Plan proposes development that is consistent with existing land uses in the vicinity of the project area and is anticipated to generate similar noise levels. Where new development would abut noise sensitive uses (within the project area, as well as between the project area and existing offsite uses), the Specific Plan includes design guidelines and development standards that are aimed at reducing noise levels, including building orientation, setbacks, and buffers. By providing the necessary regulatory and design guidance, the proposed project ensures that future development within project area implements the policies of the Noise Element in the City of Dublin General Plan as well as the Municipal Code noise regulations. Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-200 police also enforce city ordinances and state laws within the limits of the City of Dublin. Schools The Dublin Unified School District (DUSD) provides public education in the City of Dublin and the surrounding area (including the proposed project area). The DUSD includes five elementary schools, one K-8 school, one middle school, a comprehensive high school, a continuation high school, and a K-3 parent participation program. The elementary schools all feature before and after school child care. Primary and secondary school facilities, 2011-2012 student enrollment, and the school’s optimum capacity are identified in Table 3.11-1: Optimum Capacity of Schools Serving the Project Area Table 3.11-1: Optimum Capacity of Schools Serving the Project Area Grade Level and School Name Student Enrollment in 2011-2012 Optimum Capacity Elementary Dougherty 758 749 Dublin 621 755 Green 781 749 Frederiksen 641 705 Murray 393 457 Kolb 760 820 Fallon (based on 6-8 grade only) 824 1,212 Middle School Fallon (based on 6-8 grade only) 824 1,212 Wells 718 1,063 High School Dublin HS 1,747 2,500 Valley Continuation HS 80 160 Source: Dublin Unified School District, 2012. The proposed project is located within the service areacurrent attendance boundaries of Frederiksen Elementary School, Wells Middle School, and Dublin High School. Depending on space availability, students may be overflowed to another campus with available capacity. For planning purposes, a school district’s projected student generation rates are based on dwelling units. Student generation rates are the average number of students residing in a home. It is also an indicator of the number of students that will come from new housing developments. According to the Dublin Unified School District’s Demographic Study and Facilities Plan, 2011-2012, each new single-family Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-202 The project area is generally flat with elevations ranging from 357 feet at the northeast corner of the project area to a low of approximately 336 feet at the southwest corner of the project area near the intersection of Dublin Boulevard and the Iron Horse Regional Trail. The entire 1,800 acre watershed within Camp Parks majority of the Camp Parks drains through the project area. The majority of the runoff from this watershed is conveyed through Camp Parks in natural and engineered swales which cross the project area and are intercepted along the north side of Dublin Boulevard and the project area and are intercepted along the north side of Dublin Boulevard and conveyed to various existing Zone 7 drainage facilities. The main drainage channel for runoff from Camp Parks crosses the project area and is currently mapped as a FEMA 100-year floodplain. Zone 7 has indicated that the peak 100-year storm runoff within this main channel concentrated at Dublin Boulevard shall not exceed 950 cubic feet per second (cfs). To the northeast and east of Camp Parks, runoff is collected in an existing channel and conveyed south along Arnold Road to a flow “splitter” near Central Parkways, which divides flow between two existing Zone 7 drainage facilities. A portion of this flow continues down Arnold Road, while the remainder is conveyed in an existing trapezoidal channel across the southeastern portion of the project area. Water The Dublin San Ramon Services District (DSRSD) is the purveyor of potable water in the City of Dublin. DSRSD has provided drinking water to more than 60,000 people in Dublin since March 1961 and in Dougherty Valley since May 2000. In addition to potable water, DSRSD also provides recycled (reclaimed) water for irrigation and other non-potable uses. DSRSD Ordinance No. 301 requires recycled water use for approved customer categories for all new land uses, including commercial, multi- family residential, and institutional irrigation uses with the DSRSD potable water service area. The City of Dublin also has Water-Efficient Landscaping Regulations that reduce water use for irrigation (refer to the Dublin Municipal Code, Chapter 8.88). DSRSD’s Urban Water Management Plan (June 2011) (hereinafter “DSRSD UWMP”) includes a projection of future potable and reclaimed water use through the year 2030. This projection is shown in Table 3.11-2: DSRSD Current and Projected Water Meter Connections by Customer Type (Potable and Reclaimed). Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-205 jurisdictions. The City of Dublin currently contracts with Amador Valley Industries (AVI), a private company for residential and commercial garbage collection within the City limits. The City of Dublin also has an aggressive and comprehensive recycling program and collects both recycling and organics. All single-family residences are provided with recycling containers. In addition, free recycling service is available to all commercial customers that subscribe to garbage service. In regards to construction and demolition debris, the City requires all construction and demolition projects to recycle at least 50-percent of waste generated on a job site. Solid waste generated within the project area would be deposited at the Altamont Landfill. The Altamont Landfill has a total estimated permitted capacity of 62,000,000 cubic yards. The total estimated capacity used is 16,280,000 cubic yards (or 26.3 percent), and the remaining estimated capacity is at 45,720,000 cubic yards (or 73.7 percent). The estimated closure date of this landfill is January 2029. Electricity and Natural Gas Pacific Gas and Electric Company (PG&E) provides electricity to all or part of 47 counties in California, and provides natural gas to all or part of 39 counties in California, constituting most of the northern and central portions of the state. PG&E provides electricity and natural gas service to the City of Dublin. PG&E charges connection and user fees for all new development, in addition to sliding rates for electrical and natural gas service based on use. Electricity and gas services are currently offered in the project vicinity. Title 24, Part 6, of the California Code of Regulations, entitled “Energy Efficiency Standards for Residential and Nonresidential Buildings,” specifies requirements to achieve the State’s minimum energy efficiency standards. The standards apply to new construction of both residential and nonresidential buildings, and regulate energy consumed for heating, cooling, ventilation, water heating and lighting. Compliance with these standards is verified and enforced through the local building permit process. Projects that apply for a building permit on or after January 1, 2010, must comply with the 2008 Energy Efficiency Standards. In addition, the California Energy Commissions’ Energy Aware Planning Guide is available as a reference tool to assist in project planning. Regulatory Setting State Schools School Facilities Act of 1998 The School Facilities Act of 1998 (also known as Senate Bill [SB] 50), provides state funding for a portion of the funding needed for new school construction projects that can satisfy certain criteria for such funding, including eligibility due to growth, Division of State Architect plan approval. However, the Act also dramatically limits the maximum amount of impact fees, which can be charged by school districts as Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-212 that there is a five-minute response time to all emergency calls. The City of Dublin has 51 sworn personnel with a population of 46,572, for a ratio of 1.09 sworn personnel per 1,000 residents (Personal Communication with Lieutenant Nate Schmidt, Alameda County Sherriff; Department/City of Dublin Police Department, June 5, 2013). Although the addition of new residents to the project area would slightly increase the demand for police services, implementation of the proposed project is not anticipated to have an adverse effect on response times for police services and would not affect the Department’s ability to serve the proposed project (Personal Communication with Lieutenant Nate Schmidt, Alameda County Sherriff; Department/City of Dublin Police Department, June 5, 2013). Future development within the project area would be required to comply with Chapter 7.32.300 (Building Security) and Chapter 7.32.310 (Nonresidential building security) of the City’s Building Code, which includes building standards aimed at reducing law enforcement calls within the City. In addition, the City would collect public facilities fees (Chapter 7.78 of the City of Dublin Municipal Code) from future development to help off-set police service capital improvements and on-going maintenance expenses incurred by the new development prior to issuance of a Building Permit to ensure that the proposed project will not cause impacts on law enforcement services that would result in significant environmental impacts. Therefore, the proposed project would have a less than significant impact on law enforcement services, and no mitigation is required. Increased Demand for Educational Facilities Impact 3.11-3: Implementation of the proposed project would increase the number of students in the Dublin Unified School District (DUSD) with the construction of a maximum of 1,995 residential units, which would increase the capacity of the schools, which are operating above optimum capacity. The proposed project includes an 11a 12 net usable acre school site and future development would be required to pay school impact fees as required under State law to the DUSD. This is considered a less than significant impact. The proposed project would allow for a future net new development potential with a maximum of 1,995 residential units within the project area. Children from the proposed residential dwelling units would likely attend DUSD schools including: Frederiksen Elementary School; Wells Middle School; and Dublin High School. Based on the DUSD’s student generation rate for medium density housing (single family residential with lots less than 4,000 square feet) of 0.525 K-12 students per home and a maximum of 1,995 homes within the project area the proposed project would generate approximately 1,047 students. As shown in Table 3.11-3: Enrollment Capacity of Schools Serving the Project Area, the DUSD has an excess of capacity of 990 students. Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-213 Table 3.11-3: Enrollment Capacity of Schools Serving the Project Area Grade Level and School Name Student Enrollment in 2011-2012 Optimum Capacity Excess Capacity Elementary Frederiksen 641 705 64 Middle School Wells 718 1,063 345 High School Dublin HS 1,474 2,500 581 Source: Dublin Unified School District, 2012. The proposed project includes a 12 net usable acre site for a future elementary school, which would be dedicated to the DUSD for a proposed school that would serve the proposed project and surrounding uses. This elementary school will be designed to accommodate up toapproximately 900 children and will include classrooms, a gymnasium, administrative offices, a multi-use sports field, sport courts, a playground, and parking. In addition, future development within the project area would be required by law to pay school impact fees at the time of the building permit issuance. The DUSD currently charges development fees in the amount of $2.97 per square foot of residential development and $0.47 per square foot for commercial and industrial uses. These fees are used by the DUSD to mitigate impacts associated with long-term operation and maintenance of school facilities. A project applicant’s fees would be determined at the time of the building permit issuance and would reflect the most current fee amount established by the DUSD. School fees exacted from residential and commercial uses would help fund necessary school service and facilities improvements to accommodate anticipated population and school enrollment growth within the DUSD service area, and would allow for the DUSD to allocate these funds as deemed necessary. Therefore, the increased demand on the DUSD is considered a less than significant impact on school services, and no mitigation is required. Increased Demand for Parks and Recreation Facilities Impact 3.11-4: The proposed project would increase the demand for park and recreational uses within the project area. However, development projects within the project area would be required to pay the City’s Public Facilities Fee prior to Building Permit issuance. This is considered a less than significant impact. Implementation of the proposed project would increase the demand for neighborhood and community parks due to the projected increase in the residential population generated by future development within the project area. The proposed Dublin Crossing Specific Plan Final EIR Public Services and Utilities Page 3-220 project Infrastructure Master Plan, which the City will be reviewing and approving in accordance with the requirement of the Specific Plan. The Infrastructure Master Plan should identify the development trigger for the future tank. The future tank should be installed prior to approval of the Final Map for the trigger point. With implementation of these measures, this would be considered a less than significant impact, and no mitigation is required. Stormwater Runoff Impact 3.11-8: Implementation of the proposed project may result in increased off-site stormwater flows and future development within the project area would be required to install proposed drainage improvements and pay applicable impact fees at the time of issuance of the building permits. This is considered a less than significant impact. As previously mentioned, the City of Dublin Public Works Department maintains the City’s storm drain pipelines that are located within public streets. Zone 7 owns and operates regional storm drain facilities that collect runoff from the City. Surface water management consists of both on-site runoff and the management of off-site runoff extending through or around the site. On-site Surface Water Runoff As shown in Figure 3.8-3: Proposed DrainageQ100 Project Flows, surface waters within the project area would be divided into four drainage sheds. Drainage sheds A9-A (63.3 acres) and A9-B (81.7 acres) would ultimately flow into the Line G-1 drainage channel. Two underground detention basins, located within the proposed community park, would be constructed. Preliminary estimates by Ruggeri Jensen Azar (RJA) call for the construction of two underground basins (RJA 2013). Park Basin #1, which captures drainage from A9-B, would have a storage capacity of 3.3 acre feet and an outflow rate of 80 cfs. Park Basin #2, which captures drainage from A9-A, would have a storage capacity of 1.6 acre feet and an outflow of 71 cfs.9 Based on project plans, drainage from both of these underground basins would be conveyed via an underground pipe to the proposed Chabot Creek riparian channel that would be realigned through the proposed community park. Drainage sheds XX-1 (23.1 acres) and XX-2 (20.9 acres), which are located in the southeast corner of the site, would ultimately flow into the Line G-5 drainage 9 This analysis assumed two open-air basins and that the bottom 2 ½ feet of each basin was inundated with runoff from the previous storm event. Given the fact that these two basins are now proposed to be underground, the ultimate storage capacities would be determined as part of detailed engineering design. However, the basins would be designed so that there i s sufficient capacity to ensure that runoff capacities to not exceed pre-condition flow conditions. Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-240 (ITE code 220), elementary school use (ITE code 520), office use (ITE code 710), shopping centers (ITE code 820), and City Park (SANDAG), the project would generate 24,563 gross daily vehicle trips, with 1,924 gross trips occurring during the AM peak hour (7:00 to 9:00) and 2,695 gross trips occurring during the PM peak hour (4:00 to 6:00). Since the proposed development would relocate the existing Camp Parks entrance on Dublin Boulevard, the trips generated by the existing use were redistributed from the current base entrance to the proposed new entrance at Dougherty Road and Amador Valley Boulevard. A retail pass-by trip reduction of 20 percent (based on prior analysis in the City of Dublin) was applied to the PM peak hour trip generation. Pass-by-trips are trips that would already be on the adjacent roadways (and are therefore already counted in the existing traffic) but would turn into the site while passing by. Justification for applying the pass-by-trip reduction is founded on the observation that such retail traffic is not actually generated by the retail development, but is already part of the ambient traffic levels. Pass-by-trips are therefore excluded from the PM peak hour traffic projections at most offsite intersections, but were assigned to the site’s planned driveways and the intersection of Arnold Road/Dublin Boulevard. Since the project area is located near the Dublin/Pleasanton BART station, a transit reduction of five percent was applied to the overall project trip generation based on results from the City of Dublin travel demand forecasting model. After applying the appropriate trip reductions, the project would generate 22,047 net new daily trips, with 1,828 net new trips occurring during the AM peak hour and 2,393 net new trips occurring during the PM peak hour. The project trip generation estimates are presented below in Table 3.12-7: Dublin Crossing Trip Generation. It should be noted that some of the trips generated by the project would be internal to the site. For example, some of the project’s residential trips would occur to and from the proposed school. While these internal trips would represent new trips on the on-site roadway network, they would not result in new trips to the off-site roadway network. The internal capture of these trips is accounted for in the Travel Demand Forecast Model assignment process. Project Trip Distribution and Assignment As part of the project trip distribution, an estimate is made of the directions to and from which the project trips would travel. In the project trip assignment, the project trips are assigned to specific streets and intersections. The directional distribution of site-generated traffic to and from the project area was developed based on a select zone analysis from the City of Dublin Travel Demand Forecast model and shown in Figure 3.12-7: Proposed Project Trip Generation RatesDistribution. The peak hour trips generated by the proposed uses were assigned to the roadway system by the model at each study location. Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-267 Table 3.12-13: 2035 Cumulative Plus Project Freeway Ramp Capacity Analysis 2035 No Project 2035 Plus Project Freeway Ramps Peak Hour Capacity (vph)1 Volumes2 V/C Ratio3 Volumes2 V/C Ratio3 I-580 at Dougherty Road/Hopyard Road SB Hopyard to WB I-580 On Ramp AM 900 627 0.70 672 0.75 PM 1800 326 0.18 399 0.22 SB Hopyard to EB I-580 On Ramp AM 1800 777 0.43 777 0.43 PM 360 213 0.59 213 0.59 I-580 at Hacienda Drive SB Hacienda to WB I-580 On Ramp AM 720 513 0.71 564 0.78 PM 1800 588 0.33 588 0.33 SB Hacienda to EB I-580 On Ramp AM 1800 337 0.19 410 0.23 PM 300 443 1.48 457 1.52 I-580 at Tassajara Road/Santa Rita Road SB Tassajara to WB I-580 On Ramp AM 720 698 0.97 755 1.05 PM 1800 676 0.38 676 0.38 SB Tassajara to EB I-580 On Ramp AM 1800 324 0.18 324 0.18 PM 300 342 1.14 343 1.14 Note: Bold and shaded V/C ratio indicates a significant impact. 1 Capacities obtained from observations at existing ramp meters. 2 Volumes obtained from Dublin TDF Model. 3 Volume-to-capacity ratio. Source: Hexagon 2012 CMACTC/MTS System Analysis Results The 2011 Alameda County Congestion Management Program (CMP) includes a Land Use Analysis component to determine the impacts of land use decisions made by local jurisdictions on the regional transportation system. The intent of this program is to:  better tie together local land use and regional transportation facilities decisions;  better assess the impacts of developments in one community on another community;  promote information sharing between local governments when decisions made by one jurisdiction will have an impact on another. Local jurisdictions have responsibilities regarding the analysis of transportation impacts of land use decisions. Among those is an analysis of project impacts on the Metropolitan Transportation System (MTS) for the 2020 and 2035 horizon years. For projects that generate more than 100 peak-hour vehicle trips, a CMP traffic analysis is required using the Alameda Countywide Transportation Demand Model Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-268 (ACTDM). In accordance with the Technical and Policy Guidelines of the Congestion Management Program, the CMP analysis requires evaluation of the traffic impacts of the project on the MTS. The Consulting firm Fehr & Peers developed a travel demand model for the City of Dublin based on the August 2011 ACTDM. Refinements were made to the Countywide model within the City of Dublin and surrounding areas to provide more detail in terms of local land uses, and the roadway and transit transportation systems. The City of Dublin Travel Demand Model (CDTDM) was developed (a) to provide daily and peak-hour traffic flow projections on freeways, arterial and collector roadways for the General Plan update, and (b) to provide a tool to analyze future land use development proposals and transportation network changes within the City. Documentation of the Dublin Citywide model, including model validation is provided in the City of Dublin Final Model Development Report, dated April 2012. Traffic impact analyses for relatively small projects typically add project traffic on top of the existing (or future no-project) volumes. This "layering" method is reasonable when the addition of project traffic is unlikely to change the travel patterns of existing traffic on the roadway system. As a result, the traffic volumes on roadway segments are by definition always higher than without the project. With large scale developments, such as the Dublin Crossing project, layering project traffic on top of existing traffic is not realistic, especially when the project is located in an area where roadways are already projected to be congested and new roadways are proposed as part of the project. There are two main reasons for this: (1) drivers may alter their route to avoid the areas where the additional project traffic is added to the roadway system because an alternate route would be faster and (2) the project would result in a change of travel patterns in the area. Two examples of this include:  Some residents of Dublin that now shop at retail uses in Pleasanton would shop at the retail center of the Dublin Crossing instead. Thus, their shopping trip would have a different destination and they would use different roads to get there. This would result in an increase in traffic on some facilities and a decrease of traffic on other facilities.  Without the project, I-580 operates at congested conditions during commute hours. Because some project traffic from the Dublin Crossing development would add to the traffic congestion on this freeway, ambient traffic would start using other facilities instead. Thus, some traffic that uses the I-580/I- 680 interchange would shift to alternate routes such as Dougherty Road, Dublin Boulevard, and Bollinger Canyon Road. Because I-580 and I-680 already operate at or near capacity, there is not much room left to add more vehicles to these facilities. Travel demand models, such as the CDTDM and the ACTDM, account for these changes in traffic patterns resulting from large development projects. For that reason, these models were used to forecast the impacts on the freeways and MTS system in the vicinity of the project. The CMA Alameda County Transportation Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-269 Commission (Alameda CTC) requires project’s to conduct the roadway segment and freeway analysis for the years 2020 and 2035 using the ACTDM. The most recent version of the ACTDM was obtained from the ACCMA Alameda CTC and future peak- hour forecasts were developed, with and without the project. Since the ACTDM set does not include a 2012 forecast year, the freeway analysis for existing and existing plus project conditions were based on forecasts developed with the CDTDM. It should be noted that, although the project would add a substantial amount of peak-hour trips to the adjacent segment of Dublin Boulevard, this does not necessarily result in the same substantial increase of vehicles on that roadway segment. Some of the ambient traffic on Dublin Boulevard would change their route and use other facilities to get to their destination (including diversion to the new proposed parallel route on G Street). Thus, the increase in traffic volumes on the freeway segments and the MTS system forecasted by the model would result in a smaller increase in traffic when compared to the layering of project trips method. The level of service standard for the CMP analysis is LOS E. The Alameda County CMACTC does not have a policy for determining a threshold of significance for CMP requirements and expects that professional judgment will be used to determine project impacts. The City Engineer, in his expert professional judgment has determined that the level of service for the CMP Land Use analysis is LOS E. Therefore, for the purpose of this traffic analysis, if a segment operates at an unacceptable LOS (per professional judgment) without the project, the impact of the project is considered significant if the contribution of project traffic results in an increase in the volume-to-capacity ratio of at least 0.02. This threshold is consistent with prior traffic impact analyses for development in the City of Dublin. In order to determine the impact of the project, peak-hour traffic volumes on the 16 directional MTS roadway segments (for 2020 and 2035) and 16 directional freeway segments (for 2012, 2020, and 2035) in the vicinity of the project were analyzed. During the AM peak hour, the 2012 existing no project and plus project data at the freeway segments is shown on Table 3.12-14: 2012 No Project and Plus Project AM Peak Hour Freeway Level of Service. During the PM peak hour, the 2012 existing no project and plus project data at the freeways is shown on Table 3.12-15: 2012 No Project and Plus Project PM Peak Hour Freeway Level of Service. During the AM peak hour, the 2020 background no project and plus project data at the freeways and roadway segments is shown on Table 3.12-16: 2020 No Project and Plus Project AM Peak Hour Freeway and Roadway Segment Level of Service. During the PM peak hour, the 2020 background no project and plus project data at these facilities is shown on Table 3.12-17: 2020 No Project and Plus Project PM Peak Hour Freeway and Roadway Segment Level of Service. During the AM peak hour, the 2035 cumulative no project and plus project data at these segments is shown on Table 3.12-18: 2035 No Project and Plus Project AM Peak Hour Freeway and Roadway Segment Level of Service. During the PM peak hour, the 2035 cumulative no project and plus project data at these facilities is shown on Table 3.12-19: 2035 No Project and Plus Project PM Peak Hour Freeway and Roadway Segment Level of Service. Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-284 crossing should be utilized. The grade separated crossing would eliminate the need for at-grade pedestrian actuations at the traffic signal, which would allow more green time to be allocated to through traffic on Dublin Boulevard. Although this project has not been environmentally cleared, nor has engineering or right of way analysis been completed with regards to the feasibility of this improvement, the City is aggressively pursuing this project to improve pedestrian and bicycle mobility along the Iron Horse Trail. The City also plans to include a grade separated crossing at this location in its update to the TIF program to secure project funding. Because the impact is caused by future land use growth in the region as well as this proposed project, the mitigation for this impact is for the project to make a fair share monetary contribution toward these improvements. The timing of these improvements will be determined in the Mitigation Monitoring and Reporting Program and developer obligations will be outlined in the Developer Agreement. In the event that the grade separated crossing project cannot be constructed by year 2035, an alternative mitigation would be to eliminate the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. This would require pedestrians and bikes from the Iron Horse Trail to cross three crosswalks rather than one. Because of the effects of the alternative mitigation on pedestrian and bike mobility, the grade separated crossing is the City’s preferred mitigation at this location. Iron Horse Parkway and Dublin Boulevard Intersection Impact 3.12-4: During the PM peak hour, the study intersection of Iron Horse Parkway and Dublin Boulevard would degrade from LOS C under 2035 cumulative no project conditions to an unacceptable LOS F under 2035 cumulative plus project conditions. This is considered a potentially significant impact. To mitigate this impact, the project applicant would be required to construct an additional northbound left turn lane on Iron Horse Parkway. With implementation of the following mitigation measure, the intersection would operate at LOS D during the PM peak hour. Therefore, this mitigation measure would reduce this impact to a less than significant level. Mitigation Measure: MM 3.12-4: Addition of a Northbound Left-Turn Lane on Iron Horse Parkway at the Intersection of Iron Horse Parkway and Dublin Boulevard. To mitigate the impact at the intersection of Iron Horse Parkway and Dublin Boulevard would require an additional northbound left turn lane on Iron Horse Parkway. Based on the 2035 cumulative plus project conditions, the two northbound left turn lanes would need to be 400 feet each. This improvement would require widening Iron Horse Parkway by approximately Dublin Crossing Specific Plan Final EIR Transportation & Circulation Page 3-285 12 feet along the east side in advance of the intersection. It may also require removal of parking, realignment of travel lanes through the intersection, relocation of sidewalks, and traffic signal modifications. the removal of parking on the east side of Iron Horse Parkway, traffic signal modifications, and changing the travel lane configuration and alignment to create:  One 16-foot wide southbound receiving lane on Iron Horse Parkway;  Two 10-foot wide northbound left turn lanes on Iron Horse Parkway; and  One 14-foot wide northbound shared through-right turn lane. Because the proposed project causes the change in operation from LOS C to LOS F, the proposed project is responsible for constructing these improvements. The timing of these improvements will be determined in the project’s mitigation monitoring program. Hacienda Drive and Dublin Boulevard Impact 3.12-5: During the PM peak hour, the study intersection of Hacienda Drive and Dublin Boulevard would operate at an unacceptable LOS E under both 2035 cumulative no project conditions and 2035 cumulative plus project conditions. The City of Dublin level of service standard for this intersection is LOS D. Because the intersection would operate at an unacceptable level of service under no project conditions, the addition of project trips would result in a potentially significant impact to the intersection based on the City of Dublin impact criteria. With implementation of the following mitigation measure, the Hacienda Drive and Dublin Boulevard intersection would operate at LOS D during the PM peak hour. Therefore, this mitigation measure would reduce this impact to a less than significant level. Mitigation Measure: MM 3.12-5: Convert One of the Through Lanes to a Second Right-Turn Lane at the Hacienda Drive and Dublin Boulevard Intersection. As part of the City of Dublin’s Traffic Impact Fee program, the intersection of Hacienda Drive and Dublin Boulevard has a planned northbound approach geometry of three left turn lanes, three through lanes, and one right turn lane. To mitigate the impact at the intersection of Hacienda Drive and Dublin Boulevard would require converting one of the through lanes to a second right turn lane, which is the existing northbound geometry at the intersection. Because no improvements relative to the existing geometry are necessary, the City of Dublin should modify its planned improvement at the northbound approach of the intersection back to the existing configuration. With this mitigation, the intersection would operate at LOS D during the PM peak hour. Dublin Crossing Specific Plan Final EIR Transportation and Circulation Page 3-290 Mitigation Measure: MM 3.12-9: Coordination with LAVTA. As the plan area develops, the project applicant shall coordinate with the City of Dublin and LAVTA to determine if route changes and/or increased service is required in the project area. In addition, the project shall provide additional bus duckouts and transit shelters to support project trips, where appropriate. Pedestrian/Bicycle Mobility Impacts Impact 3.12-10: The proposed project does not include detailed information such as intersection layouts, crosswalk locations, wheelchair ramp locations, and driveway locations. For this reason, impacts to bicycle and pedestrian safety cannot be evaluated at this time, which is considered a potentially significant impact. As more detail becomes available, a detailed analysis of pedestrian and bicycle mobility should shall be completed. With implementation of the following mitigation measures, the impact would be reduced to a less than significant level. Mitigation Measure: MM 3.12-10: Review of Intersection Layouts and Driveway Locations. As each individual site develops within the Specific Plan and more details are available, additional review by the City of Dublin will be necessary to insure that individual elements of the project do not conflict with the pedestrian/bike accessibility and are consistent with the policies and guidelines in the Dublin Bikeways Master Plan. The following mitigation measures shall be implemented:  Marked crosswalks shall be provided at all onsite intersections, where appropriate, based on the layout of the local streets. Prior to final design of the streets and pathways, the intersection designs should be reviewed by City staff to insure that the pathway crossings are clearly marked and include Americans with Disabilities Act (ADA) compliant wheelchair ramps. Bollards may also be considered so that vehicles are restricted from driving on the 10-foot wide paths.  The layout of private and minor streets within the site shall minimize, to the greatest extent possible, the number of crossings with the proposed onsite 10-foot pedestrian paths. This includes potentially realigning the Iron Horse Trail onto the Central Park site so that the driveway access to the park at Scarlett Drive does not conflict with trail operations.  Bike parking, showers, and changing rooms shall be considered at the park, office and shopping center uses, where appropriate.  During construction along Scarlett Drive, Dublin Boulevard, and Arnold Road, temporary traffic control plans shall be prepared to minimize the Dublin Crossing Specific Plan Final EIR CEQA Considerations Page 4-2 cannot be predicted with certainty, the project impacts to freeway ramps would be considered a significant and unavoidable impact. 4.2 Significant Irreversible Changes Section 15126.2(c) of the State CEQA Guidelines requires an EIR to discuss the significant irreversible environmental changes that would be involved if the proposed project would be implemented. Examples include the following: uses of nonrenewable resources during the initial and continued phases of the project, since a large commitment of such resources makes removal or nonuse thereafter unlikely; primary and secondary impacts of a project that would generally commit future generations to similar uses (e.g., highway improvements that provide access to a previously inaccessible area); and/or irreversible damage that could result from any potential environmental accidents associated with the proposed project. Analysis The proposed project would allow for the future development of residential, commercial, parks and open space, and an elementary school. Specifically, the proposed project includes a maximum of up to 1,995 residential units; 200,000 square feet of commercial uses, 35 acres of parks; and a 12 net usable acre elementary school site. A variety of nonrenewable and limited resources would be irretrievably committed for construction and operation, including but not limited to: oil, natural gas, gasoline, lumber, sand and gravel, asphalt, steel, water, land, energy, and construction materials. With respect to operational activities, compliance with all applicable building codes, as well as project mitigation measures or project requirements, would ensure that all natural resources are conserved or recycled to the maximum extent feasible. The proposed project would result in an increase in demand on public services and utilities. For example, an increase in the intensity of land uses within the project area would result in an increase in regional electric energy consumption to satisfy additional electricity demands from the proposed project. These energy resource demands relate to initial project construction, transport of goods and people, and lighting, heating, and cooling of buildings. However, the proposed project would not involve a wasteful or unjustifiable use of energy or other resources, and energy conservation efforts would occur with new construction. In addition, new development associated with the proposed project would be constructed and operated in accordance with specifications contained in Title 24 of the California Code of Regulations. Therefore, the use of energy on-site would occur in an efficient manner. Although portions of the Camp Parks property have already been developed, increased development within the project area to support urban uses may be regarded as a permanent and irreversible change. The proposed project would Dublin Crossing Specific Plan Final EIR CEQA Consideration Page 4-11 Cumulative Impacts Analysis and Assumptions Impacts associated with cumulative development were analyzed based on the proposed project’s effects in combination with a summary of projections in the adopted City of Dublin General Plan (February 11, 1985, Updated May 2013), the City’s Capital Improvement Program (CIP); and implementation of the Camp Parks Master Plan. Implementation of the Camp Parks Master Plan would involve redevelopment of the what is known as the “Cantonment Area” of Camp Parks to provide more modern and better-organized facilities. Beneficial features of the Master Plan include: peripherally located family housing, minimal impact on range training, aggregation of similar land uses, a campus-style training center, and controlled access at a main entry gate. The Camp Parks Master Plan anticipates a population increase at build- out of 11 percent for daily personnel (from 920 to 1,020 people) , the average daily use of the installation from Army stationing and full-time units/staff, and 85 percent for total of assigned personnel (from 2,297 to 4,242 people). The total of assigned personnel is projected to increase by 1,945 people between 2002 and 2012, due to increases in enlisted personnel and warrant officers. Aesthetics and Visual Resources The proposed project is located within an already urbanized area of the City; neither the project area nor surrounding area has any scenic resources. Although implementation of the proposed project would allow redevelopment of the project area from its former use as the Camp Parks Reserve Forces Training Area, the proposed project includes both development standards and design guidelines to guide the design of future development within the area. The design guidelines would also ensure that the proposed project does not introduce substantial light and glare which would pose a hazard or nuisance. The proposed project would also be required to comply with a number of other City policy documents that address urban design and aesthetics. These include: Streetscape Master Plan, Community Design and Sustainability Element of the General Plan and the Bikeways Master Plan. In addition, future development would be required to undergo Site Development Review to ensure that the Specific Plan guidelines are implemented. The above considerations ensure that cumulative development would result in a less than significant cumulative impact. Conclusion: The proposed project would be required to comply with the design guidelines in the Specific Plan as well as other City policy documents, which would ensure that the proposed project does not contribute to cumulative light and glare in the City and surrounding areas, and would ensure that the proposed project is of quality design. The existing setting together with the design features of the Specific Plan would ensure the project’s cumulative contribution to aesthetics and visual quality, would Dublin Crossing Specific Plan Final EIR CEQA Consideration Page 4-27 impacts to several special status and animal species and there would be similar impacts to protected trees. Assuming the same biological mitigation measures under this alternative, impacts would be similar in comparison to the proposed project. Cultural Resources (similar). The Reduced Density Alternative would not eliminate potential damage to any unknown cultural resources, including historic, archaeological, or paleontological resources, and/or human remains that could result with construction of the proposed project. Similar to the proposed project, the Reduced Density Alternative would result in a less than significant impact to cultural resources with mitigation measures incorporated herein and therefore, would have similar impacts in comparison to the proposed project. Geology and Soils (similar). Impacts under the Reduced Density Alternative would be similar to the proposed project in that the project area would still be exposed to seismic ground shaking, liquefaction, soil erosion, and expansive soils with development within the project area. Because this alternative would be required to comply with the City’s Building Code, and the California Building Code, the Reduced Density Alternative would result in similar impacts to the proposed project. Greenhouse Gas Emissions and Climate Change (greater). An increase in direct and indirect sources of greenhouse gas emissions associated with the proposed project would also occur under the Reduced Density Alternative. The reduction in development and density is anticipated to increase the per capita GHG emissions since the service population would decrease. The Reduced Density Alternative would locate fewer people near transit and other commercial uses and therefore vehicle trips are not anticipated to decrease proportionally. Therefore, the Reduced Development Alternative is anticipated to result in greater greenhouse gas emissions in comparison to the proposed project. Hazards and Hazardous Materials (slightly less). The Reduced Density Alternative would result in similar impacts with respect to hazards and hazardous materials due to the types of uses proposed under this alternative (e.g. residential and commercial uses). Therefore, the Reduced Development Alternative would also result in a less than significant impact. Hydrology and Water Quality (similar). Surface water runoff under this alternative would be slightly less in comparison to the proposed project due to development at lower densities, which would result in a reduction of impervious surfaces. Mitigation measures would also be required under this alternative to reduce potentially significant impacts to short and long-term surface water hydrology. Therefore, the Reduced Density Alternative would result in similar impacts in comparison to the proposed project. Land Use and Planning (greatersimilar). Similar to the proposed project, the Reduced Development Alternative would not physically divide an established community and/or conflict with applicable land use plan, policies or regulations. Dublin Crossing Specific Plan Final EIR References Page 5-2 Cardno Entrix. Biological Technical Report for Dublin Crossing. June 2013. Cal Engineering and Geology. Second Geotechnical and Geologic Review, Preliminary Geotechnical Report and Fault Ground Rupture Investigation, Dublin Crossing Project at Camp Parks, Dublin, California. April 2013. City of Dublin. Dublin Crossing Specific Plan. June 2013. City of Dublin. City of Dublin General Plan, adopted February 11, 1985, updated January 19, 2010. City of Dublin. City of Dublin Municipal Code. City of Dublin. City of Dublin Final Model Development Report. April 2012. City of Dublin. Wildfire Management Plan. Adopted July1996. Revised November 2010. City of Dublin. Dublin Transit Center General Plan Amendment. 2002. City of Dublin. Dublin Transit Center EIR. 2002. City of Dublin. Village @ Dublin Retail Project Supplemental EIR. 2013. City of Dublin. City of Dublin Climate Action Plan. 2010. Cyril M. Harris. Handbook of Noise Control. 1979. Dublin San Ramon Community Services District (DSRSD). 2010 Urban Water Management Plan. June 2011. Dublin Unified School District. CalPADS Enrollment. October 2012. Dublin Unified School District. Demographics Update, Board of Trustees Meeting. March 2012. Economic and Planning Systems (EPS). City of Dublin Economic Development Strategy. November 2012. ECORP Consulting, Inc. Supplemental Cultural Resources Assessment for the Dublin Crossing Specific Plan Environmental Impact Report Alameda County, California. April 2012. Federal Transit Administration. Transit Noise and Vibration Impact Assessment Guidelines, May 2006. Hall, Mark, Environmental Coordinator, U.S. Army, Camp Parks. Personal Communication with Erika Spencer, RBF Consulting on May 21, 2013 and September 17, 2013. ICF International (ICF). East Alameda County Conservation Strategy. October 2010. Intergovernmental Panel on Climate Change. Climate Change, The Science of Climate Change – Contribution of Working Group I to the Second Assessment Report of the IPCC. 1996. Demarcus Blvd. Campbell Ln. Scarlett Dr. Du b l i n B l v d . I S t . A St. B St. C St. D St. E St. F St. Arnold Rd. Dougherty Rd. H S t . Ce n t r a l P k w y . G S t . Sca r l e t t D r . ( F u t u r e E x t . ) Sca r l e t t D r . Iron Horse Pkwy. Houst o n Pl. Le g e n d DC M e d i u m D e n s i t y R e s i d e n t i a l DC M e d i u m - H i g h R e s i d e n t i a l Ge n e r a l C o m m e r c i a l / D C M e d i u m - H i g h D e n s i t y R e s i d e n t i a l Ge n e r a l C o m m e r c i a l / D C H i g h D e n s i t y R e s i d e n t i a l Mi x e d U s e Sc h o o l Pa r k Op e n S p a c e Pr o j e c t A r e a B o u n d a r y Du b l i n C r o s s i n g S p e c i f i c P l a n E I R Fi g u r e 2 - 7 [Da t e : 1 0 / 0 4 / 2 0 1 3 J N : 7 0 - 1 0 0 3 8 2 Co n c e p t u a l L a n d U s e P l a n Ch e c k u s o u t o n - l i n e a t : du b l i n c r o s s i n g c a . c o m Du b l i n C r o s s i n g gggggggggggggggg A P e d e s t r i a n - F r i e n d l y C o m m u n i t y o                  Du b l i n , C A 80 4 0 2 0 Du b l i n B l v d . ArnoldRoad Fut u r e S c a r l e t t D r i v e Dougherty Road G S t r e e t H S t r e e t A Street B Street D Street E Street Ce n t r a l P a r k w a y E a s t G S t r e e t I S t r e e t C Street F Street Th i s i l l u s t r a t i v e s i t e p l a n p r o v i d e s a l o o k i n t o t h e f u t u r e o f h o w D u b l i n C r o s s i n g m a y d e v e l o p . T h i s c o n c e p t i s j u s t o n e c o n f i g ur a t i o n a n d i s p r o v i d e d f o r i l l u s t r a t i v e p u r p o s e s o n l y ; i t s h o u l d n o t b e v i e w e d a s a n a b s o l u t e p l a n o r f o r m o f re g u l a t i o n d u e t o t h e m a n y u n f o r e s e e n c o n d i t i o n s , o p p o r t u n i t i e s , a n d c o n s t r a i n t s t h a t m a y a r i s e i n t h e f u t u r e . Du b l i n C r o s s i n g S p e c i f i c P l a n E I R Fi g u r e 2 - 8 [Da t e : 1 0 / 0 4 / 2 0 1 3 J N : 7 0 - 1 0 0 3 8 2 Il l u s t r a t i v e S i t e P l a n Le g e n d FE M A F l o o d Z o n e : 5 0 0 - Y e a r F l o o d Z o n e FE M A F l o o d Z o n e : 1 0 0 - Y e a r F l o o d Z o n e Pr o j e c t A r e a B o u n d a r y Du b l i n C r o s s i n g S p e c i f i c P l a n E I R FE M A F l o o d Z o n e s Fi g u r e 2 - 1 0 [Da t e : 0 9 / 1 7 / 2 0 1 3 J N : 7 0 - 1 0 0 3 8 2 3. 3 A C - F T UN D E R G R O U N D HM P S T O R A G E EX 2 1 " S D EX 2 4 " S D EX EX 4 8 " S D E X 1 8 " S D EX 2 4 " S D EX 1 8 " S D EX 2 4 " S D EX 3 6 " S D EX 2 1 " S D EX 2 4 " S D EX 2 4 " S D EX 72" SD EX 72" SD EX 2 60" SD 30"SD EX 1 8 " S D EX - 2 - 8 X 8 R C B EX 4 2 " S D EX 4 8 " S D 1. 6 A C - F T UN D E R G R O U N D HM P S T O R A G E 2- 8 ' X 8 ' B O X CU L V E R T 36"SD 36"SD 2- 9 6 " S D 36"SD 2 4 " S D 2 4 " S D 36"SD 24 " S D 24"SD 36"SD 2 4 " S D 36 " S D 30 " S D 36 " S D 2- 6 0 " S D 48 " S D 3- 8 ' X 4 ' R C B 55 A C - F T P O N D 24 " S D 30 " S D 2- 6 0 " S D 2-60"SD 24"SD 24"SD 36"SD RELOCATED DITCH 2- 9 6 " S D 2- 9 6 " S D 2- 9 6 " S D 48 " S D 8' x 4 ' R C B 24"SD 48"SD Demarcus Blvd. Campbell Ln. Scarlett Dr. Du b l i n B l v d . I S t . A St. B St. C St. D St. E St. F St. Arnold Rd. Dougherty Rd. H S t . Ce n t r a l P k w y . G S t . Sca r l e t t D r . ( F u t u r e E x t . ) Sca r l e t t D r . Iron Horse Pkwy. Houst o n Pl. Le g e n d Pr o p o s e d S t o r m D r a i n L i n e Ex i s t i n g S t o r m D r a i n L i n e Pr o p o s e d P o n d Pr o j e c t A r e a B o u n d a r y Du b l i n C r o s s i n g S p e c i f i c P l a n E I R Fi g u r e 2 - 1 1 [Da t e : 1 0 / 0 4 / 2 0 1 3 J N : 7 0 - 1 0 0 3 8 2 Co n c e p t u a l S t o r m w a t e r D r a i n a g e a n d D e t e n t i o n S y s t e m 2 1 2 2 2 3 4 4 5 5 33 3 2 4 Demarcus Blvd. Campbell Ln. Scarlett Dr. Du b l i n B l v d . I S t . A St. B St. C St. D St. E St. F St. Arnold Rd. Dougherty Rd. H S t . Ce n t r a l P k w y . G S t . Sca r l e t t D r . ( F u t u r e E x t . ) Sca r l e t t D r . Iron Horse Pkwy. Houst o n Pl. Le g e n d Ph a s i n g B o u n d a r y ( A p p r o x i m a t e ) DC M e d i u m D e n s i t y R e s i d e n t i a l DC M e d i u m - H i g h D e n s i t y R e s i d e n t i a l Ge n e r a l C o m m e r c i a l / D C M e d i u m - H i g h D e n s i t y R e s i d e n t i a l Ge n e r a l C o m m e r c i a l / D C H i g h D e n s i t y R e s i d e n t i a l Mi x e d U s e Sc h o o l Pa r k Op e n S p a c e Pr o j e c t A r e a B o u n d a r y Du b l i n C r o s s i n g S p e c i f i c P l a n E I R Fi g u r e 2 - 1 5 [Da t e : 1 0 / 0 4 / 2 0 1 3 J N : 7 0 - 1 0 0 3 8 2 Ph a s i n g M a p Dublin Crossing Specific Plan EIRExisting Biological Habitats Figure 3.3-1Date: 10-9-13 JN: 70-100382 Source: Cardno Entrix (2013) Dublin Crossing Specific Plan EIRPreliminary Wetlands and Other Waters Figure 3.3-2Date: 12/05/2012 JN: 70-100382 Source: Cardno Entrix (2012) Per 1995 Santa Rita Drainage Master Plan (pgs 10 & 19), a maximum flow of 350 would be diverted to Line G-5 Per 1995 Santa Rita Drainage Master Plan (pg 19) & 1194 letter from Alameda Co. Public Workds Agency, Option C at “U/S 580”, Q100 = 950 cfs max. Existing detention basin per “Hydrologic and Hydraulic Analysis for the Proposed Camp Parks Dentention Basin” study dated March 8, 2013. 1 2 3 Date: 09/17/2013 JN: 70-100382 Dublin Crossing Specific Plan EIR Figure 3.8-3 Proposed Q100 Project Flows Source: Ruggeri-Jensen-Azar (2013)