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Reso 186-13 Dublin Crossings EIR
RESOLUTION NO. 186-13 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DUBLIN * * * * * * * * * CERTIFYING AN ENVIRONMENTAL IMPACT REPORT, ADOPTING ENVIRONMENTAL FINDINGS, A STATEMENT OF OVERRIDING CONSIDERATIONS AND MITIGATION MONITORING AND REPORTING PROGRAM UNDER CEQA FOR THE DUBLIN CROSSING SPECIFIC PLAN PROJECT PA 08-049 WHEREAS, the City has processed a Planning Application to enable private development on approximately 189 acres of property that is currently part of Camp Parks Reserve Forces Training Area. The proposal includes the approval of the Dublin Crossing General Plan Amendments, Specific Plan, Zoning Ordinance Amendments, Rezoning properties to a new Dublin Crossing Zoning District, and consideration of a Development Agreement, among other related actions. These planning and implementing actions are collectively known as the "Dublin Crossing Specific Plan Project" or the "Project"; and WHEREAS, the Dublin Crossing Specific Plan (Specific Plan) project area is approximately 189 acres in size and is generally bound by 5th Street to the north, Scarlett Drive to the west, Dublin Boulevard to the south, and Arnold Road to the east. The project area includes properties identified by Assessor Parcel Numbers 986-0001-001-15 (partial), 986-0034-002-00, and 986-0034-006-00; and WHEREAS, the California Environmental Quality Act (CEQA), together with the State CEQA Guidelines and City environmental regulations require that certain projects be reviewed for environmental impacts and that environmental documents be prepared. It was determined that an Environmental Impact Report (EIR) be prepared to analyze the Project; and WHEREAS, the City circulated a Notice of Preparation, dated June 4, 2012, to public agencies and interested parties for consultation on the scope of the EIR. The City also conducted a public scoping meeting on June 20, 2012; and WHEREAS, the City prepared a Draft Environmental Impact Report (EIR) dated June 2013 for the proposed Project that reflected the City's independent judgment and analysis of the potential environmental impacts of the Project. The Draft EIR is a separately bound document on file at City Hall and is incorporated herein by reference; and WHEREAS, the Draft EIR was circulated for public review for 45 days, from June 24, 2013 to August 8, 2013; and Page 1 of 4 WHEREAS, the City received comment letters from state, regional, and local agencies as well as interested individuals and organizations during the public review period. In accordance with the requirements of CEQA, the City prepared written responses to all the comments received during the public comment period. The City prepared a Final EIR dated October 2013, that includes the comment letters, written Responses to Comments, and clarifications and minor corrections to information presented in the Draft EIR. The Final EIR is attached as Exhibit A and is incorporated herein by reference. The responses to comments provide the City's good faith, reasoned analysis of the environmental issues raised by the comments. The documents included in a flash drive that accompanied Comment Letter 9 were responded to to the extent that they were specifically referenced in or incorporated into the actual written comments regarding the Project included in Letter 9. Overall, the documents included in the flash drive were general resource materials that did not relate to the Project and, therefore, no specific response was required under CEQA; and WHEREAS, following release of the Final EIR, the City discovered a typographical error in the Final EIR that should be corrected as follows: In Final EIR section 2.6, last paragraph under "General Commercial/Dublin Medium Density Residential (GC/DC MDR), second to last line, the reference to "20 units/net acre" is changed to "25 units/net acre" for consistency with Table 2-1 and other text references to density for this district; and WHEREAS, the EIR for the Project includes the Draft EIR and the Final EIR collectively (EIR); and WHEREAS, the City carefully reviewed the comments and written responses and determined that the Final EIR, including the clarifications and minor corrections to the Draft EIR, do not constitute significant new information requiring recirculation of the Draft EIR under the standards in CEQA Guidelines section 15088.5; and WHEREAS, a Staff Report dated October 22, 2013 and incorporated herein by reference, described and analyzed the Project and EIR for the Planning Commission; and WHEREAS, the Planning Commission reviewed the Staff Report, the EIR, including comments and responses, at a noticed public hearing on October 22, 2013 at which time all interested parties had the opportunity to be heard; and WHEREAS, on October 22, 2013, the Planning Commission adopted Resolution 13-32 recommending that the City Council certify the EIR for the project, which resolution is incorporated herein by reference and available for review at City Hall during normal business hours; and WHEREAS, a Staff Report, dated November 5, 2013 and incorporated herein by reference, described and analyzed the Project and EIR for the City Council; and WHEREAS, the City Council reviewed the Staff Report, the EIR, including comments and responses, at a noticed public hearing on November 5, 2013 at which time all interested parties had the opportunity to be heard; and Page 2 of 4 WHEREAS, the EIR, including comments and responses, reflects the City's independent judgment and analysis on the potential for environmental impacts from the Project; and WHEREAS, the EIR identified several potentially significant impacts that will be reduced to a less than significant level with specified mitigation measures; therefore, approval of the project will require adoption of findings on impacts and mitigations as set forth in attached Exhibit B; and WHEREAS, the EIR identified significant and unavoidable environmental impacts of the project; therefore approval of the project will require adoption of findings concerning mitigations as set forth in attached Exhibit B, findings concerning alternatives as set forth in attached Exhibit C, and a Statement of Overriding Considerations as set forth in attached Exhibit D; and WHEREAS, a Mitigation Monitoring and Reporting Program, as required by CEQA, is attached as Exhibit E; and WHEREAS, the EIR and all of the documents relating to the Project are available for review in the City Planning Division at the Dublin City Hall, file PA 08-049, during normal business hours. The location and custodian of the EIR and other documents that constitute the record of proceedings for the Project is the City of Dublin Community Development Department, 100 Civic Plaza, Dublin, CA 94568, file PA 08-049. NOW, THEREFORE, BE IT RESOLVED THAT, the Dublin City Council certifies the following: A. The foregoing recitals are true and correct and made a part of this resolution. B. The EIR, consisting of the Draft EIR, the separately bound Final EIR attached as Exhibit A, and the additional typographical correction identified in the recitals above, has been completed in compliance with CEQA, the CEQA Guidelines and the City of Dublin Environmental Guidelines. C. The City Council has independently reviewed and considered the information contained in the EIR, including the written comments received during the Draft EIR review period and the oral and written comments received at the public hearing, prior to acting on the proposed Project. D. The EIR reflects the City's independent judgment and analysis on the potential environmental impacts of the Project. The EIR provides information to the decision- makers and the public on the environmental consequences of the Project. E. The EIR adequately describes the Project, its significant environmental impacts, mitigation measures and a reasonable range of alternatives to the Project. Page 3 of 4 BE IT FURTHER RESOLVED that the Dublin City Council adopts the mitigation measures and impact and mitigation findings set forth in Exhibit B, the findings concerning alternatives set forth in Exhibit C, the Statement of Overriding Considerations set forth in Exhibit D, and the Mitigation Monitoring and Reporting Program set forth in Exhibit E. Exhibits A, B, C, D and E are incorporated herein by reference, all in compliance with the requirements of CEQA. PASSED, APPROVED, AND ADOPTED this 5th day of November, 2013 by the following vote: AYES: Councilmembers Biddle, Gupta, Hart, Haubert, and Mayor Sbranti NOES: None ABSENT: None ABSTAIN: None // ,/ v Mayor ATTEST: a442 City Clerk Reso No. 186-13,Adopted 11-5-13, Item 6.1 Page 4 of 4 EXHIBIT B FINDINGS CONCERNING SIGNIFICANT IMPACTS AND MITIGATION MEASURES Pursuant to Public Resources Code section 21081 and CEQA Guidelines section 15091, the City Council hereby makes these findings with respect to the potential for significant environmental impacts from adoption and implementation of the Dublin Crossing Specific Plan Project (Specific Plan, or Project), PA 08-049, and means for mitigating those impacts. For the purpose of these findings, the term "Final EIR" means the Draft and Final EIR documents collectively, unless otherwise specified. These findings do not attempt to describe the full analysis of each environmental impact contained in the Final EIR. Instead, the findings provide a summary description of each impact, describe the applicable mitigation measures identified in the Final EIR and adopted by the City, and state the findings on the significance of each impact after imposition of the adopted mitigation measures. A full explanation of these environmental findings and conclusions can be found in the Final EIR, and these findings hereby incorporate by reference the discussion and analysis in those documents supporting the Final EIR's determinations regarding mitigation measures and the Project's impacts and mitigation measures designed to address those impacts. The facts supporting these findings are found in the record as a whole for the Project. In making these findings, the City ratifies, adopts, and incorporates into these findings the analysis and explanation in the Final EIR, and ratifies, adopts, and incorporates in these findings the determinations and conclusions of the Final EIR relating to environmental impacts and mitigation measures, except to the extent any such determinations and conclusions are specifically and expressly modified by these findings. Impact 3.2-1: The proposed project would result in future short-term air quality impacts associated with construction activities, including grading, operation of equipment, and demolition of existing structures within the project area. However, future development within the project area would be required to comply with the BAAQMD Control Measures for particulate matter and equipment emissions during construction activities. Mitigation Measures: MM 3.2-1a: Implement Short-term Construction Best Management Practices. Prior to issuance of any Grading Permit, the Public Works Director and the Building Official shall confirm that the Grading Plan, Building Plans, and specifications stipulate that the following basic construction mitigation measures shall be implemented for all construction projects : 1 • All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas and unpaved access roads) shall be watered two times per day. • All haul trucks transporting soil, sand, or other loose material off-site shall be covered. • All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. • All vehicle speeds on unpaved roads shall be limited to 15 mph. • All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. • Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. • All construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • A publicly visible sign with the telephone number and person to contact at the lead agency regarding dust complaints shall be posted. This person shall respond and take corrective action within 48 hours. The Air District's phone number shall also be visible to ensure compliance with applicable regulations. MM 3.2-1b: Implement Additional Short-term Construction Best Management Practices. Prior to issuance of any Grading Permit, the Public Works Director and the Building Official shall confirm that the Grading Plan, Building Plans, and specifications stipulate that the following additional construction mitigation measures shall be implemented for all construction projects: • All excavation, grading, and/or demolition activities shall be suspended when winds (instantaneous gusts) exceed 25 mph. • Wind breaks (e.g., trees, fences) shall be installed on the windward side(s) of actively disturbed areas of construction. • Vegetative ground cover (e.g., fast-germinating native grass seed) shall be planted in disturbed areas as soon as possible and watered appropriately until vegetation is established. • All trucks and equipment, including their tires, shall be washed off prior to leaving the site. • Site accesses to a distance of 100 feet from the paved road shall be treated with a 6 to 12 inch compacted layer of wood chips, mulch, or gravel. • Sandbags or other erosion control measures shall be installed to prevent silt runoff to public roadways from sites with a slope greater than one percent. 2 • The applicant shall reduce exhaust emissions during construction and, in particular, emissions of NOX, when using construction equipment and vehicles by implementing the following measures: o Require the use of diesel haul trucks (e.g., material delivery trucks and soil import/export) that meet EPA 2007 model year NOX emissions requirements o The following note shall be included on all grading plans: During project construction, all internal combustion engines/construction, equipment operating on the project area shall meet EPA-Certified Tier 3 emissions standards, or higher according to the following: January 1, 2012, to December 31, 2014: Off-road diesel-powered construction equipment greater than 50 hp shall meet Tier 3 off-road emissions standards. Alternatively, construction equipment shall be outfitted with BACT devices certified by GARB. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine as defined by GARB regulations. Post-January 1, 2015: Off-road diesel-powered construction equipment greater than 50 hp shall meet the Tier 4 emission standards, where available. Alternatively, construction equipment shall be outfitted with BACT devices certified by GARB. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine as defined by CARB regulations. o The contractor and applicant, if the applicant's equipment is used, shall maintain construction equipment engines by keeping them tuned and regularly serviced to minimize exhaust emissions. o Utilize existing power sources (i.e., power poles) when available. This measure would minimize the use of higher polluting gas or diesel generators. o Construction-related equipment, including heavy-duty equipment, motor vehicles, and portable equipment, shall be turned off when not in use for more than five minutes. • Use low VOC (i.e., ROG) coatings beyond the local requirements (i.e., Regulation 8, Rule 3: Architectural Coatings). • Require that all construction equipment, diesel trucks, and generators be equipped with Best Available Control Technology for emission reductions of NOX and PM. Resulting Significance: Significant and Unavoidable 3 Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR, but not to a level of less than significant. There are no additional feasible mitigation measures and no feasible alternatives that avoid this significant effect, as further addressed in Exhibit C, Findings Concerning Infeasibility of Alternatives and Additional Mitigation Measures. Rationale for Finding: The project will implement Basic and Additional measures identified by BAAQMD to mitigate short term construction impacts. The measures are designed to reduce and control both fugitive dust from construction activities and emissions from construction equipment through techniques such as watering exposed surfaces, covering haul trucks, minimizing equipment idling time, and other specified measures. However, the project is large and will be implemented through multiple developments whose timing is currently unknown. Therefore, the project could potentially violate Federal and State ambient air quality standards, even with implementation of the identified mitigation measures. The impact is significant and unavoidable and a Statement of Overriding Considerations is required in conjunction with approval of the Project. Impact 3.2-3: Build-out of the proposed project would result in regional air emissions from operational sources in exceedance of BAAQMD significance thresholds. Mitigation Measures: No feasible mitigation measures beyond the design features included as part of the Project would reduce this impact to a less than significant level. Resulting Significance: Significant and Unavoidable Finding: Design features of the project and design guidelines for implementing developments will lessen the significant environmental effect identified in the Final EIR, but not to a level of less than significant. There are no additional feasible mitigation measures and no feasible alternatives that avoid this significant effect, as further addressed in Exhibit C, Findings Concerning Infeasibility of Alternatives and Additional Mitigation Measures. Rationale for Finding: Implementation of the project would result in new long-term operational emissions, including new area, energy, and mobile source emissions. The project includes design guidelines that would reduce potential area source emissions, e.g., using only natural gas hearths and using low VOC paint. The project takes advantage of its location by proposing a mixed use project in proximity to the Dublin/Pleasanton BART station and associated transit facilities. The project design together with design guidelines in the Specific Plan further ensure that implementing development will include increased density and diversity, improved walkability, increased destination and transit accessibility, improved pedestrian 4 network, limited parking supply, traffic calming measures, trip reduction, ride sharing, and employee vanpool programs. These design features will reduce mobile source emissions to the extent feasible; however, operational emissions would still exceed thresholds for ROG, NOX, and PM10 emissions. No additional feasible mitigation measures have been identified for the project. The impact is significant and unavoidable and a Statement of Overriding Considerations is required in conjunction with approval of the Project. Impact 3.2-5: The proposed project could result in exposure of sensitive land uses in excess of applicable Toxic Air Contaminant (TAC) standards. Mitigation Measures: 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: • All new development projects that include sensitive receptors shall be located 1,000 feet away from existing TAC sources, unless a project-specific evaluation of human health risks is conducted and the results of the evaluation determine that no significant impact would occur.. Sensitive receptors include residential, schools, day care facilities, congregate care facilities, hospitals, or other places of long-term residency. • Mixed-use, residential, or school development within 1,000 feet of a BAAQMD permitted TAC source shall implement sealed HVAC systems for all multi-family development. The sealed air system shall be certified to achieve a performance effectiveness, For example, to remove at least 85 percent of ambient PM2.5 concentrations from indoor areas. Air intakes shall be located away from emission sources areas, such as major roadways and stationary sources. Resulting Significance: Significant and Unavoidable Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR, but not to a level of less than significant. There are no additional feasible mitigation measures and no feasible alternatives that avoid this significant effect, as further addressed in Exhibit C, Findings Concerning Infeasibility of Alternatives and Additional Mitigation Measures. 5 Rationale for Finding: Mitigation Measure 3.2-5 will ensure that future sensitive receptors are located a sufficient distance from existing TAC sources. If future sensitive receptors cannot be located at a sufficient distance from existing TAC sources, on-site mitigation measures such as mechanical ventilation with enhanced filtration would be required. Implementation of Mitigation Measure 3.2-5 would reduce exposure to TAC and PM2.5 emissions, but the reduction may not be enough to meet BAAQMD's criteria. The impact is significant and unavoidable and a Statement of Overriding Considerations is required in conjunction with approval of the Project. Impact 3.2-6: The proposed project would not result in increased generation of Toxic Air Contaminants (TACs) or exposure of sensitive land uses in excess of applicable TAC standards. Mitigation Measures: MM 3.2-6: Locate Commercial Development That Emits Toxic Air Contaminants Away From Sensitive Receptors and Consult with the BAAQMD to identify Toxic Air Contaminant Sources and Determine the Need for Health Risk Assessment. Prior to building permit issuance, the project applicant shall demonstrate to the City of Dublin Community Development Director that the following measure is implemented to reduce the potential for new TAC sources to be sited within 1,000 feet of residential or other existing or planned sensitive receptors: • 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. Sensitive receptors include residential, schools, day care facilities, congregate care facilities, hospitals, or other places of long-term residency. The determination of development projects that have the potential for TAC emissions and adequate distances from sensitive receptors are identified in the California Air Resources Board's —Air Quality and Land Use Handbook—A Community Health Perspective (April 2005). Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The specific commercial uses within the Specific Plan area are unknown, but could include TAC emitters such as gas stations, dry cleaners, and diesel backup generators that are subject to regulatory requirements and permitting. The mitigation measure requires that such uses will not be located close to sensitive receptors unless the proposed use provides a project-specific evaluation 6 showing no significant impact would occur. Implementation of the above mitigation measure and compliance with applicable regulatory standards that are part of the permitting process will ensure that project impacts are less than significant. Impact 3.3-1: Based on a preliminary wetland delineation of the project area, the proposed project could result in the fill of wetlands. Mitigation Measures: 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 a wetland mitigation plan that ensures no-net-loss of wetland and waters habitat that 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). (Mitigation as revised in FEIR) Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Through the required Wetland Mitigation Plan, the project will identify ways that development can be designed with measures such as buffers or free-span bridges to avoid or minimize the potential loss of wetland and waters 7 habitat. Where habitat cannot be avoided, the measure ensures that permanent compensating habitat is created or preserved so that there is no net loss of this resource. 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. Mitigation Measures: MM 3.3-2a: Conduct a Floristic Survey and Consult with 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 listed plant species with potential habitat within the project area during the blooming 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 CDFW and USFWS 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. (Mitigation as revised in FEIR). 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 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 8 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 (including contingency measures) providing for the long-term protection of the species. (Mitigation as revised in FEIR). Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigations ensures that any special status plant species, including but not limited to Congdon's tarplant, will be identified through appropriately timed floristic surveys. The mitigations further ensure that if such species are found, species-specific mitigation will be developed to avoid or transplant plants, or the loss of plants will be offset by at least 1:1 compensation through permanent offsite mitigation. 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. 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 owl take avoidance survey 14 days prior to ground disturbing activities 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 CDFW as indicated in the CDFW 2012 Staff Report. 9 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. (Mitigation as revised in FEIR). Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Because burrowing owls have been observed in the project area, the mitigation provides a detailed series of presence/absence surveys and resurveys to ensure that the owls are not present where and when ground-disturbing construction activities are imminent. The mitigation further ensures that buffer areas are created so that breeding or wintering burrowing owls are not disturbed. The mitigation ensures that any required exclusion plan during the non-breeding season shall be tailored to the specific site and circumstances to encourage the owls to move away from the construction area. Where offsite mitigation is included in the exclusion plan, the mitigation allows for permanent protection of the offsite mitigation location. CDFW oversight and monitoring ensure that the most current survey techniques and effective avoidance and compensation measures are implemented. 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 greater 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 includes re-alignment of the ephemeral drainage, which could result in the 10 potential "take" of Western Pond Turtle and/or California Red Legged Frog if found within the project area. Mitigation Measures: 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. 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 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 11 between April 15 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 could preserve additional upland habitat within a USFWS approved conservation area. This measure shall be determined in consultation with the USFWS, if required. (Mitigation as revised in FEIR.) Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Western Pond Turtles are unlikely to occur on the project site, but because they have been observed in the general area, MM 3.3-4a ensures that preconstruction surveys will be conducted to determine whether the species is present prior to any construction activity. If any Western Pond Turtles are found, the mitigation ensures that they will be relocated, in consultation with CDFW, to a more suitable habitat within the immediate vicinity of the project area but away from the construction zone. The project site does not include breeding habitat for CRLF. However, because there is a possibility it could provide dispersal habitat, MM 3.3-4b ensures that preconstruction surveys will be conducted to identify the presence or absence of CRLF prior to construction activity. If CRLF are identified, implementation of the mitigation ensures there will be no net loss of habitat, using techniques for habitat avoidance, preservation, creation and/or purchase of credits. 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 12 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. California linderiella was found, during the 2002 and 2003 surveys, but not within the project area. The surveys conducted by Cardno Entrix have not been accepted by the USFWS. Therefore, the presence of this species within the project area is assumed in the analysis of project impacts. (Impact statement as revised in FEIR.) 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. Mitigation Measures: 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 (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 13 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. 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. (Mitigation as revised in FEIR.) Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation ensures that a habitat assessment for vernal pool invertebrates will be conducted by a qualified biologist and followed up by protocol-level surveys if suitable habitat is present. If any federally- protected vernal pool invertebrates are found or assumed present in the project area, implementation of the mitigation assures that there will be no net loss of habitat. Habitat mitigation techniques shall consider avoidance during construction activity first, with monitoring and reporting by a qualified biologist to avoid unnecessary take of listed species or destruction of their habitat. Where avoidance is not feasible, the mitigation ensures that an appropriate amount of habitat will be reserved, created and/or compensated through purchase of mitigation credits in order to ensure no net loss of habitat. 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 14 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. Mitigation Measures: 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 construction activities are conducted during the bird 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, 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). If active nests of protected bird species are identified in the focused nest surveys, the project applicant 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, shall delay construction in the vicinity of active nest sites during the breeding season (February 1 through August 31) while the nest is occupied with adults and/or young. A qualified biologist shall monitor any occupied nest to determine when the nest is no longer used. If the construction cannot be delayed, avoidance measures 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. b. No intensive disturbance (e.g., heavy equipment operation associated with construction, or use of cranes) or other project-related activities that could cause 15 nest abandonment or forced fledging would be initiated within the established buffer zone of an active nest between February 1 and August 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. (Mitigation as revised in FEIR.) Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation avoids disturbance of nesting birds through controls on the location and timing of construction activity. The mitigations include a suite of techniques including delaying construction during breeding season, and creating appropriately sized buffers around the nests if construction activities cannot be delayed. Other techniques include avoiding use of heavy equipment or cranes in the buffer areas; if the equipment must be used, an onsite biologist will monitor whether the birds are being disturbed. For fully protected species, the mitigation ensures that a non-disturbance buffer of 500 feet will be created so that construction completely avoids their nests. 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 15t-Oct 1st) could result in a potentially significant impact. Mitigation Measures: 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 surveys can be conducted by visual and acoustic identification and can assume presence of pallid bats or the bats can be identified to a species level with the use of an acoustic detector unit. If no roosting sites or bats are found within the project area, a letter report confirming absence shall be sent to the California Department of Fish and Game and no further mitigation would be required. MM 3.3-7b: Implement Avoidance Measures If Bat Roosts are Identified. If bats are detected during the focused surveys then the project applicant shall 16 perform monitoring and implement exclusion measures in consultation with the regulatory agencies. If bats are found during focused surveys, the project applicant shall consult with the regulatory agencies and implement the following measures based on the agencies standards and policies: a. If bats are found roosting in the project area outside of nursery season (May 1 through October 1), then they would be evicted using bat exclusion techniques developed by Bat Conservation International (BCI) and in consultation with CDFW, that allow the bats to exit the roosting site but prevent re-entry to the site. This would include but not be limited to the installation of one-way exclusion devices. The devices would remain in place for seven days and then the exclusion points and any other potential entrances shall be sealed. This work would be completed by a BCI recommended exclusion professional. b. If bats are found roosting during the nursery season, then they shall be monitored to determine if the roost site is a maternal roost. Monitoring by either visual inspection of the roost bat pups, if possible, or monitoring the roost after the adults leave for the night to listen for bat pups. If the roost is determined to not be a maternal roost, then the bats would be evicted as described above. Because bat pups cannot leave the roost until they are mature enough, eviction of a maternal roost cannot occur during the nursery season. A buffer zone as determined in consultation with CDFW would be established around the roosting site within which no construction shall occur. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation ensures that the presence or absence of bats or roosting sites will be identified prior to any construction activities. If roosting bats are present outside of the nursery season, the mitigation ensures that they will be excluded through established techniques approved by CDFW. Similar exclusion techniques will be used to exclude roosting bats during nursery season if the roost is not a maternal roost. For maternal roosts during nursery season, creation of a no-construction buffer ensures that bat pups will not be disturbed by project construction activity. 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. Mitigation Measures: 17 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 24 inches in circumference measured at four (4) feet six (6) inches above natural grade. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation requirement for a tree survey ensures that any trees protected under City regulations will be identified. Those trees to remain will be protected from construction damage through exclusion fencing to keep construction activities out of the dripline of the trees. The mitigation ensures that protected trees to be removed will be replaced at an appropriate ratio based on the size of the tree. Impact 3.4-2: The proposed project has been previously disturbed from its use as the Camp Parks Reserve Forces Training Area. Based on the prior archaeological surveys conducted within the project area, the project area is not anticipated to contain any archaeological, cultural or pre-historic resources. However, site preparation and grading activities could disrupt undiscovered archaeological and cultural resources of importance under CEQA and/or eligible for listing on the California Register. Mitigation Measures: MM 3.4-2: Halt Work/Archaeological Evaluation/Site-Specific Mitigation. If any potential archaeological, pre-historic or cultural artifacts are encountered during site grading or other construction activities, all ground disturbance within 18 50 feet of the discovery shall be halted until a qualified archaeologist can identify and evaluate the resource(s) in accordance with State CEQA Guidelines 15064.5(f). The archeological consultant shall immediately notify the project sponsor and the City staff of the encountered archeological deposit. If the deposit does not qualify as an archaeological resource, then no further protection or study is necessary. If the deposit does qualify as an archaeological resource then the impacts shall be avoided by project activities. If the deposit cannot be avoided, adverse impacts to the deposit shall be addressed in accordance with State CEQA Guidelines 15126.4(b). Measures may include, but are not limited to archaeological data recovery, etc. Upon completion of the assessment by the archaeologist, a professional-quality report shall be submitted to the City, the project applicant, and the Northwest Information Center at Sonoma State University in Rohnert Park. The project applicant shall fund and implement the mitigation in accordance with Section 15064.5(c) through (f) of the CEQA Guidelines and Public Resources Code 21083.2. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measure ensures that any undiscovered archaeological, cultural or pre-historic resources will be identified and will not be inadvertently destroyed as a result of project construction activities. Impact 3.4-3: No paleontological resources are known to exist within the project area. However, the presence of unknown paleontological resources could be discovered during site preparation and grading activities. Mitigation Measures: MM 3.4-3: Halt Work/Paleontological Evaluation/Site-Specific Mitigation. If paleontological resources are encountered during subsurface construction activities, all work within 50 feet of the discovery shall be redirected until a qualified paleontologist can evaluate the finds. If the paleontological resources are found to be significant, they shall be avoided by project construction activities and recovered by a qualified paleontologist. Upon completion of the recovery, a paleontological assessment shall be conducted by a qualified paleontologist to determine if further monitoring for paleontological resources is required. The assessment shall include: I) the results of any geotechnical investigation prepared for the project area; 2) specific details of the construction plans for the project area; 3) background research; and 4) limited subsurface investigation within the project area. If a high potential to encounter paleontological resources is confirmed, a monitoring plan of further project subsurface construction shall be 19 prepared in conjunction with this assessment. After project subsurface construction has ended, a report documenting monitoring, methods, findings, and further recommendations regarding paleontological resources shall be prepared and submitted to the Director of Community Development. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measure ensures that any undiscovered paleontological resources will be identified and will not be inadvertently destroyed as a result of project construction activities. Impact 3.4-4: Due to the disturbed nature of the project area, there are no known human remains interred outside of formal cemeteries that are anticipated to be disturbed during short-term construction activities. However, human remains could be discovered during site preparation and grading activities. Mitigation Measures: MM 3.4-4: Halt Work/Coroner's Evaluation/Native American Heritage Consultant/Compliance with Most Likely Descendent Recommendations. In the event that human remains are encountered during grading and site preparation activities, all ground-disturbing work within 50 feet of the remains shall cease immediately and a qualified archaeologist shall notify the Office of the Alameda County Coroner and advise that office as to whether the remains are likely to be Native American. If determined to be Native American, the Alameda County Coroner's Office shall notify the Native American Heritage Commission of the find, which in turn will then appoint a "Most Likely Descendent. (MLD)." The MLD in consultation with the archaeological consultant and the project sponsor will advise and help formulate an appropriate plan for treatment of the remains, which might include recordation, removal, and scientific study of the remains and any associated artifacts. After completion of the analysis and preparation of the report of findings, the remains and associated grave goods shall be returned to the MLD for burial. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. 20 Rationale for Finding: The mitigation measure ensures that any uncovered human remains will be identified and will not be inadvertently destroyed as a result of project construction activities. The mitigation measure ensures that appropriate procedures will be followed if any uncovered remains are determined to be Native American. Impact 3.5-3: Ground shaking is likely to occur in the project area in the event of a major earthquake on one of the nearby faults resulting in the exposure of people and/or structures to potentially significant adverse effects, including the risk of loss, injury or death. Mitigation Measures: 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. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measure ensures that groundshaking shall be examined specific to the project's proposed site preparation and grading, structures and improvements and that appropriate engineering and design elements, including the stringent CBC standards, are incorporated into the design level plans before building permits are issued Impact 3.5-4: Future development associated with the proposed project could expose people or structures to potential substantial adverse effects of liquefaction. Mitigation Measures: Implementation of Mitigation Measure MM 3.5-3. Resulting Significance: Less than Significant 21 Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Future development in 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 3.5-3 ensures that potential liquefaction conditions are incorporated into design level project plans. Impact 3.5-6: Implementation of the proposed project would include future development within the Specific Plan area in an area with expansive soils. With adherence to the City's Building Code and CBC requirements, this is considered a potentially significant impact. Mitigation Measures: Implementation of Mitigation Measure MM 3.5-3. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Future development in the project area would be required to comply with the City's Building Code, the CBC, and the City's standard engineering practices and design criteria. In addition, Mitigation Measure 3.5-3 ensures that appropriate techniques for potential expansive soil conditions are incorporated into design level project plans. 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. Mitigation Measures: 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. 22 Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation ensures that no development or construction in the affected areas of the project site will occur until NFA status is granted and the area is remediated to a level appropriate for planned uses of the area. 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 in peak storm water flows (i.e., 10- and 100-year storm events). MM 3.8-4a: Construction of a new Off-site Detention Basin North of the Project Area. 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. (Mitigation as revised in FEIR.) Resulting Significance: Less than Significant 23 Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measures ensure that proposed offsite and onsite detention facilities will be designed and constructed to meet applicable flow rate standards and provide adequate storm drain capacity. Impact 3.10-1: The proposed project could result in short-term construction-related noise at nearby noise sensitive land uses. Mitigation Measures: MM 3.10-la: Prepare Construction Noise Management Plan. The project applicant shall prepare a construction noise management plan that identifies measures to be taken to minimize construction noise on surrounding sensitive receptors (e.g., residential uses and schools) and includes specific noise management measures to be included into project plans and specifications subject to review and approval by the City. These measures shall include, but not be limited to the following: • All construction equipment shall be equipped with mufflers and sound control devices (e.g., intake silencers and noise shrouds) no less effective than those provided on the original equipment and no equipment shall have an un-muffled exhaust. • The contractor shall maintain and tune-up all construction equipment to minimize noise emissions. • Stationary equipment shall be placed so as to maintain the greatest possible distance to the sensitive receptors. • All equipment servicing shall be performed so as to maintain the greatest possible distance to the sensitive receptors. • The project applicant(s) shall provide, to the satisfaction of the City of Dublin Planning Department, a qualified "Noise Disturbance Coordinator." The Disturbance Coordinator shall be responsible for responding to any local complaints about construction noise. When a complaint is received, the Noise Disturbance Coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaint (e.g., starting too early, malfunctioning muffler, etc.) and shall implement reasonable measures to resolve the compliant, as deemed acceptable by the Dublin Planning Department. If any notices are sent to residential units immediately surrounding the construction site by the City and all signs posted at the construction site shall include the contact name and the telephone number for the Noise Disturbance Coordinator. • Select demolition methods to minimize vibration, where possible (e.g., sawing masonry into sections rather than demolishing it by pavement breakers). 24 MM 3.10-1 b: Construction Routes Less Disruptive to Sensitive Receptors. Construction trucks shall utilize a route that is least disruptive to sensitive receptors, preferably major roadways (Interstate 580, Interstate 680, Dublin Boulevard, Dougherty Road, and Arnold Road). Construction trucks should, to the extent practical, avoid the weekday and Saturday a.m. and p.m. peak hours (7:00 a.m. to 9:00 a.m. and 4:00 p.m. to 6:00 p.m.). Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The required construction noise management plan will identify measures to minimize construction noise on nearby sensitive receptors (e.g., residential uses and schools) and include specific noise management measures to be incorporated in project plans and specifications subject to review and approval by the City. The measures ensure that construction will be limited to less noise sensitive periods of the day and ensure that proper operating procedures are followed during construction to minimize noise exposure for nearby sensitive receptors. 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. The City of Dublin level of service standard for this intersection is LOS D. Mitigation Measures: 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 feet along the east side in advance of the intersection. It would also require realignment of travel lanes through the intersection and traffic signal modifications. This improvement has already been identified by the City of Dublin's Traffic Impact Fee program as part of the widening of Dougherty Road between Sierra Court and City limits. Because the impact is caused by the proposed project, future land use growth, and is included in the Traffic Impact Fee program, the mitigation for this impact is for the project to make a fair share monetary 25 contribution toward these improvements. The timing of these improvements will be determined in the project's mitigation monitoring program. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigation measure will result in acceptable LOS D operations at the intersection and ensures that the project contributes its fair share to the cost of the planned improvements. Impact 3.12-2: During the PM peak hour, the study intersection of Dougherty Road and Scarlett Drive would degrade from LOS D under 2035 cumulative no project conditions to an unacceptable LOS E under 2035 cumulative plus project conditions. The City of Dublin level of service standard for this intersection is LOS D. Mitigation Measures: MM 3.12-2: Converting the Eastbound All-Movement Lane to a Shared Through Right Lane and Adding an Eastbound Left-Turn Lane at Dougherty Road and Scarlett Drive. To mitigate the impact at the intersection of Dougherty Road and Scarlett Drive would require converting the eastbound all-movement lane to a shared through-right lane and adding a new 60-foot eastbound left turn lane. In addition, the eastbound and westbound legs should be converted from split phasing to protected phasing. This improvement would require widening the west approach of the intersection by approximately 12 feet into the existing pork chop island. Further improvements at this intersection have already been identified by the City's Traffic Impact Fee Program as part of the Scarlett Drive extension to Dublin Boulevard. Implementation of the identified mitigation at this location should be coordinated with the City's planned TIF improvements. Because the impact is caused by both the proposed project and future land use growth, 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 project's mitigation monitoring program. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. 26 Rationale for Finding: Implementation of the mitigation measure will result in acceptable LOS D operations at the intersection and ensures that the project contributes its fair share to the cost of the planned improvements. Impact 3.12-3: Scarlett Drive and Dublin Boulevard. During the PM peak hour, the study intersection of Scarlett Drive and Dublin Boulevard would operate at an unacceptable LOS F 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. Mitigation Measures: MM 3.12-3: Construction of a Grade Separated Crossing at the Intersection of Scarlett Drive and Dublin Boulevard. To mitigate the impacts at the intersection of Scarlett Drive and Dublin Boulevard due to higher rate of pedestrians/bicyclists crossings at Dublin Boulevard, a grade separated crossing shall 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. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. 27 Rationale for Finding: Implementation of the mitigation measure will eliminate the need for at-grade pedestrian actuation at the traffic signal, which would allow more green time to be allocated to through traffic on Dublin Boulevard and would result in acceptable LOS C operations at the intersection. The mitigation ensures that the project contributes its fair share to the cost of constructing the grade separated crossing. 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. Mitigation Measures: 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 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. (Mitigation as revised in FEIR.) Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigation measure will result in acceptable LOS D operations at the intersection. 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. 28 Mitigation Measures: 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. Therefore, this improvement would mitigate the intersection to less than significant levels. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigation measure will result in acceptable LOS D operations at the intersection. Impact 3.12-6: : During the PM peak hour, the study intersection of Tassajara Road and Dublin Boulevard would degrade from LOS D under 2035 cumulative no project conditions to an unacceptable LOS E under 2035 cumulative plus project conditions. The City of Dublin level of service standard for this intersection is LOS D. Mitigation Measures: MM 3.12-6: Install a Fourth Eastbound Through Lane on Dublin Boulevard. To mitigate the impact at the intersection of Tassajara Road and Dublin Boulevard would require a fourth eastbound through lane on Dublin Boulevard. The widening of Dublin Boulevard to six through lanes is included in the City of Dublin's Traffic Impact Fee program. The planned eastbound approach geometry supplied by the City includes two left turn lanes, two right turn lanes, and three through lanes. To return the intersection to an acceptable LOS would require converting one of the right turn lanes to a fourth through lane. A fourth eastbound through lane would require an additional receiving lane east of the Tassajara Road and Dublin Boulevard intersection. It may also require realignment of travel lanes through the intersection and traffic signal modifications. 29 Because the impact is caused by both the proposed project and future land use growth, 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 project's mitigation monitoring program. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigation measure will result in acceptable LOS D operations at the intersection and ensures that the project contributes its fair share to the cost of the planned improvements. Impact 3.12-7: The proposed project would add project trips to the following freeway on-ramps, which would not be consistent with the Alameda County CMP criteria for freeway ramps: Southbound Hacienda Drive to 1-580 Eastbound On-ramp. During the PM peak hour, the southbound Hacienda Drive to 1-580 eastbound on-ramp would degrade from a V/C ratio of 0.98 under existing conditions to a V/C ratio of 1.13 under existing plus project conditions. According to the Alameda County CMP, the acceptable V/C ratio on all MTS segments is 0.99 or less. Southbound Hacienda Drive to 1-580 Eastbound On-ramp. During the PM peak hour, the southbound Hacienda Drive to 1-580 eastbound on-ramp would degrade from a V/C ratio of 1.48 under 2035 cumulative no project conditions to a V/C ratio of 1.52 under 2035 cumulative plus project conditions. According to the Alameda County CMP, for a segment that would operate with a V/C ratio above 0.99 under no project conditions, an increase in the V/C ratio of more than 0.02 would be considered a significant impact. Southbound Tassajara Road to 1-580 Westbound On-ramp. During the AM peak hour, the southbound Tassajara Road to 1-580 westbound on-ramp would degrade from a V/C ratio of 0.97 under 2035 cumulative no project conditions to a V/C ratio of 1.05 under 2035 cumulative plus project conditions. According to the Alameda County CMP, the acceptable V/C ratio on all MTS segments is 0.99 or less. Mitigation Measures: MM 3.12-7: Freeway Ramp Metering Rates. 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 30 Caltrans, which sets metering rates based on overall operations in the freeway corridor. In the future, major improvements are planned for 1-580 in the project vicinity, including the addition of High Occupancy Vehicle and auxiliary lanes. In addition, as the Cities surrounding the 1-580 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. Resulting Significance: Significant and Unavoidable Finding: Changes or alterations identified in the EIR would avoid or substantially lessen the significant environmental effect identified in the Final EIR. However, the identified mitigation measure requires action by another public agency, Caltrans. The City therefore finds that the mitigation is within the responsibility and jurisdictions of Caltrans, and not the City. The City further finds that there is no certainty that Caltrans will implement the mitigation measure prior to the completion of the proposed Project. This impact is therefore considered significant and unavoidable. The City concludes, however, that the Project's benefits outweigh the significant unavoidable impacts of the Project, as set forth in the Statement of Overriding Considerations. There are no additional feasible mitigation measures and no feasible alternatives that avoid this significant effect, as further addressed in Exhibit C, Findings Concerning Infeasibility of Alternatives and Additional Mitigation Measures. Rationale for Finding: If implemented, MM 3.12-7 would change 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. While Caltrans can change the ramp metering rates, there is no substantial evidence in the record to show that they will make such changes. Neither the City nor the project has any control over setting the ramp metering rates. The Draft EIR notes that as planned improvements for 1-580 are completed in the future, ramp meter rates could change over time to accommodate the demand on both the freeway ramps and freeway segments. While possible, future metering rates cannot be predicted with certainty making implementation of the mitigation uncertain. The Draft EIR also notes that the project could consider implementing Transportation Demand Management (TDM) programs to reduce project impacts on the freeway ramps; however, the City can encourage but not require, employer TDM programs. In addition, TDM programs are not feasible mitigations for residential development which constitutes the largest portion of the Project development. Unlike an employment setting where a single employer can incentivize alternative transportation for many employees, the residential project will have up to 1,995 individual dwellings. There is no central or concentrated control of the residential travel patterns through which incentives could be offered and managed. 31 However, like TDM measures, the project overall encourages alternative transportation use, e.g., providing mixed uses and higher density near the south boundary of the project along transit-friendly Dublin Boulevard and near the BART station. The project design guidelines also provide for future implementing development with a high degree of on- and off-site connecting facilities between the site and bicycle, pedestrian and transit opportunities. Based on these circumstances, the City Council finds that the identified mitigation is infeasible and no other feasible mitigations have been identified (see findings in Exhibit C). Therefore, the impact remains significant and unavoidable and a Statement of Overriding Considerations is required in conjunction with approval of the Project. Impact 3.12-8: The proposed project does not include detailed information such as intersection layouts and driveway locations. For this reason, impacts to roadway safety may be potentially significant. Mitigation Measure: MM 3.12-8: Roadway Layout and Driveway Locations. As more detail for the roadway layout and driveway locations become available, the following mitigation shall be implemented: • The precise roadway alignments at both the onsite and site access intersections have yet to be designed. City staff shall review the proposed intersection alignments to insure that opposing left turn lanes can operate simultaneously, sufficient radii is provided for truck turn movements, and through lanes line up reasonably well with their respective receiving lanes across the intersection. • To maintain adequate corner sight distance consistent with Caltrans Highway Design Manual requirements, parking shall not be permitted on major onsite roadways (Central Parkway East, G Street, and, B Street) within close proximity to intersections. At all onsite intersections, landscaping, signing, and parking shall be designed so that adequate corner sight distance is achieved. • A site circulation and access study shall be conducted for the proposed school to insure that loading areas are adequately designed and the adjacent streets are safe for school age children. Flashing beacon warning signs, high visibility crosswalks, raised crosswalks, and school zone speed limit signs shall be considered, where appropriate. • The traffic control and turn pocket lengths shall be reviewed by the City as site specific development plans move forward to insure that the orientation of the private roadways (which will feed into the major and minor collector streets onsite) do not result in level of service or safety issues. • Private street roadway segments with perpendicular parking shall be relatively short in length (approximately 400 feet or less) to discourage excessive vehicle speeds. This is necessary to allow a vehicle backing out of a perpendicular parking stall to react to through traffic on the private street. 32 Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measure requires that specified design and performance standards be included in detailed roadway plans for the project. Implementation of the mitigation will ensure adequate and safe onsite circulation for the project. Impact 3.12-9: The proposed project will increase transit demand, generating an estimated 1,228 weekday daily transit trips (bus and BART combined). This will create the need for bus route adjustments and/or increased bus frequency. Mitigation Measures: 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. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The Draft EIR notes that existing bus service is expected to be adequate to serve the additional peak hour bus trips generated by the project. Implementation of the mitigation ensures that the system will be reviewed to determine if changes in the existing bus routes should be considered to enhance transit accessibility for future project residents. Impact 3.12-10: The proposed project does not include detailed information such as intersection layouts, crosswalk locations, wheelchair ramp locations, and driveway locations. This is a potentially significant impact 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 33 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 disruption to bike and pedestrian activities through the construction zone. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The mitigation measure requires that specified pedestrian and bicycle facilities and features be included in detailed roadway plans for the project. Implementation of the mitigation will ensure that individual elements of the project do not conflict with pedestrian/bike accessibility and are consistent with the policies and guidelines in the Dublin Bikeways Master Plan.. Impact 3.12-11: Project construction would occur over a period of an estimated time period of eight to ten years and has the potential to result in hundreds of construction staff on-site at one time. However, due to the nature of the project phasing over the course of time, the amount of construction traffic that may take place during peak traffic volume periods can only be estimated. The construction phase also would increase the number of daily truck trips in the project vicinity while the site is graded and materials are delivered. All truck movements to and from the site during construction would likely occur on the arterials and collector streets around the project site. The land uses to the east and south of the project along Arnold Road and Dublin Boulevard are primarily industrial and commercial uses, with some high density residential uses along the south 34 side of Dublin Boulevard. To the west of the project site, there are low density residential townhouses along Scarlett Drive. While heavy vehicle traffic is common on arterial streets near industrial, commercial, and high density residential land uses, truck traffic on streets directly adjacent to low density residential development should be minimized to the greatest extent possible. Mitigation Measures: MM 3.12-11: Construction Traffic Mitigation Plan(s). Prior to the issuance of any grading permit or any permit that authorizes construction activities on the Specific Plan site or construction of off-site improvements relating to the Specific Plan, the project applicants shall provide Construction Traffic Mitigation Plan(s) for City Staff review and approval as part of the permit application. The Mitigation Plan(s) shall include measures to minimize the construction traffic entering the roadway system during periods of peak traffic volumes (i.e. AM and PM Peak Hour). The Mitigation Plan(s) shall also include measures to minimize the number of truck trips on Scarlett Drive and should route heavy vehicle traffic to driveways on Dublin Boulevard and Arnold Road to access the site during the construction phase of the project. At a minimum, the Construction Traffic Mitigation Plan should include the following implementation measures: • Construction truck routes shall be prepared to designate principal haul routes for trucks delivering materials to and from the construction site. • Should a temporary road and/or lane closure be necessary during construction, the project applicant shall provide traffic control activities and personnel, as necessary, to minimize traffic impacts. This may include detour signage, cones, construction area signage, flagmen, and other measures as required for safe traffic handling in the construction zone. • The project applicant shall be required to keep a minimum of one lane in each direction free from encumbrances at all times on perimeter streets accessing the project site. In the event a full road closure is required, the contractor shall coordinate with the Alameda County Fire Department and the Dublin Police Department/Alameda County Sherriff's Department to designate proper detour routes and signage to appropriate proper access routes. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: The required Construction Traffic Mitigation Plan will ensure that construction truck traffic adjacent to low density residential 35 development in the project area will be minimized through controls on the timing and routes of construction vehicles. Impact 3.12-12: The proposed project may require the closure of travel lanes on Dublin Boulevard, Scarlett Drive, and Arnold Road while constructing frontage improvements, intersection improvements for new proposed roadways (G Street, B Street, Central Parkway East, E Street, D Street and A Street), and traffic signal modifications where new intersection legs are proposed. Closure of travel lanes during peak commute hours could result in restricted traffic flow on the public streets surrounding the project area. Mitigation Measure: MM 3.12-12: Restrict Lane Closures Along Dublin Boulevard and Arnold Road to Off-Peak Hours. During project construction, the lane closures along Dublin Boulevard and Arnold Road shall be restricted to off-peak hours to the greatest extent feasible. In addition, traffic handling plans shall be prepared for construction work in the public right-of-way in accordance with current California Manual on Uniform Traffic Control Devices (MUTCD) standards and guidelines. Resulting Significance: Less than Significant Finding: Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect identified in the Final EIR. Rationale for Finding: Implementation of the mitigation will limit lane closures on busy project area roadways to off-peak hours, thereby minimizing the effects of project construction and improvements on area traffic flows. 2185556.3 36 EXHIBIT C FINDINGS CONCERNING INFEASIBILITY OF ALTERNATIVES AND PROPOSED ADDITIONAL MITIGATION MEASURES CEQA provides that decisionmakers should not approve a project as proposed if there are feasible alternatives or feasible mitigation measures that would substantially lessen the significant impacts of the project (CEQA Section 21002). The Project EIR identified feasible mitigation measures that would reduce most of the potentially significant impacts to less than significant, as further set forth in the Exhibit B findings above. However, the following four impacts in the EIR either remained significant after mitigation or no feasible mitigation was identified: (1) Air Quality Impact 3.2-1 — Short-term air quality impacts from construction. (2) Air Quality Impact 3.2-3 - Operational emissions exceed thresholds for ROG, NOX, and PM10. (3) Air Quality Impact 3.2-5 - exposure of sensitive land uses to Toxic Air Contaminants (TAC). (4) Transportation Impact 3.12-7 - Southbound Hacienda Drive to 1-580 Eastbound On- ramp under Existing Plus Project and Cumulative Plus Project conditions in PM peak hour, and Southbound Tassajara Road to 1-580 Westbound On-ramp under Cumulative Plus Project conditions in AM peak hour. As required by CEQA, the following findings address whether there are any feasible alternatives or any additional feasible mitigation measures available that would reduce any of these four impacts to less than significant. FINDINGS CONCERNING ALTERNATIVES CEQA requires that an EIR "describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project..." (CEQA Guidelines Section 15126.6(a)). If a project alternative will substantially lessen the significant environmental effects of a proposed project, the decisionmaker should not approve the proposed project unless it determines that specific economic, legal, social, technological, or other considerations,... make the project alternative infeasible" (CEQA Sections 21002 and 21081(a)(3), and CEQA Guidelines Section 15091(a)(3)). The City Council hereby makes these findings with respect to alternatives. The Project objectives are set forth in Section 2.5 of the DEIR. Alternatives are identified and analyzed in Section 4.7 of the DEIR and include the required No Project Alternative, a Reduced Development Alternative and an Alternate Use Alternative. Each of the alternatives was assessed for each resource topic and compared to potential Project impacts. As further set forth below, the City Council considered the alternatives identified and analyzed in Section 4.7 of the DEIR and finds them to be infeasible for specific economic, social, or other considerations pursuant to CEQA 1 Sections 21002 and 21081(a)(3), and CEQA Guidelines Section 15091(a)(3). For CEQA purposes, "feasible" means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, technological, and legal factors. (CEQA Section 21061.1, CEQA Guidelines Section 15364.) Alternative #1: No Project Alternative CEQA Guidelines Section 15126.6(e)(3) requires that a "No-Project" alternative be evaluated as part of an EIR, proceeding under one of two scenarios: the project area remaining in its current state or development of the project area under its current General Plan land use and zoning designations. Because the project proposes General Plan land use changes, Alternative #1 — No Project Alternative considers the environmental effects of not approving the proposed project, with the continuation of the existing permitted land uses and the "public" land use designation associated with the Camp Parks into the future. By eliminating project construction and operation, the No Project Alternative would eliminate the significant and unavoidable impacts from short-term construction emissions and long-term operational emissions. The No Project Alternative would also eliminate 22,047 trips to the project area, which would eliminate the significant and unavoidable impact to the freeway ramps at Southbound Hacienda Drive and 1-580 Eastbound On-Ramp under project conditions and the significant and unavoidable impact to the Southbound Hacienda Drive to 1-580 Eastbound On-ramp and Southbound Tassajara Road to 1-580 Westbound On-Ramp during cumulative conditions in comparison to the proposed project. The No Project Alternative would not create any new significant impacts. It would, however, increase aesthetics impacts compared to the project since the existing scattered project site structures are not consistent with the urban mixed use character to the west and south of the project site. This alternative would also continue military uses on the project site and the storage of potentially hazardous materials in proximity to nearby residential uses, which would be a greater impact compared to the project. The No Project Alternative avoids the project's significant unavoidable impacts; however the City finds this alternative infeasible because it would increase aesthetics and hazardous materials impacts compared to the project and would not be consistent with the project's objectives. The No Project Alternative is inconsistent with the most basic objectives of ensuring a long-term financially viable infill project on a portion of the Camp Parks, providing housing to meet the City's projected housing needs in its Housing Element; and creating a desirable livable community with a strong sense of place and a range of amenities and housing options for the residents of the City of Dublin. This alternative does not take advantage of the site's proximity to either the BART station or the Iron Horse Trail and the opportunities these facilities provide for alternative transportation choices and amenities. Under this alternative, the project's development standards and design guidelines would not be adopted to facilitate upgraded development that would be an attractive and distinctive amenity to the area. 2 This alternative would not provide streetscape amenities or parkland. It would retain existing development that is not compatible with the urban mixed use character of development to the west and south. Finding: The City Council considered the No Project Alternative and declines to adopt it because it will not avoid or substantially lessen all of the project's significant unavoidable impacts and is infeasible for the specific economic, social, or other considerations described above, as supported by the administrative record for the project. Alternative #2: Reduced Development Alternative (Single Family Residential and Commercial Uses) Alternative #2 — Reduced Development Alternative assumes construction of all single family development at much lower density in comparison to the proposed project for a maximum of 1,121 units at an average of 10 dwelling units per acre for a total population within the project area of 3,060 residents. This alternative also includes 200,000 square feet of general commercial uses similar to the proposed project. This alternative assumes that the development standards and design guidelines in the Specific Plan would apply to future development. With the reduction in residential units, the Reduced Density Alternative would decrease the amount of long-term operational emissions compared to the proposed project. However, the significant and unavoidable impacts would remain as short-term construction and long-term operational air quality emissions are still anticipated to exceed the BAAQMD thresholds. The Reduced Density Alternative would reduce the number of daily trips by approximately 1,070 trips, which would reduce the number of trips to the Southbound Hacienda Drive to 1-580 Eastbound On-Ramp during both project and cumulative conditions, as well as the impacts to the Southbound Tassajara Road to 1-580 Westbound On-Ramp under cumulative conditions. However, the reduced number of trips would not be enough to result in acceptable V/C ratios based on applicable CMP standards; thus, it is anticipated that the significant and unavoidable impact to the ramps would remain. The Reduced Development Alternative would not cause any new significant impacts, but would increase Greenhouse Gas Emissions impacts compared to the project because it would increase per capita GHG emissions. Alternative #2 is consistent with the project's objectives to the extent that it provides for infill development on the site and would upgrade the visual quality of the site through implementation of proposed design guidelines. This alternative would not be consistent with several important project objectives and would promote project objectives to a lesser extent than the proposed Project. With the reduced number of units and the single family character, this alternative would not create a strong desirable living environment with a range and mix of housing alternatives. Similarly the lower density and single family residential use would not be at a compatible scale and design that integrates with the nearby higher density and mixed uses. The reduced number of units would reduce the ability to provide additional new housing supply by nearly half 3 compared to the project. With the reduced number of units, this alternative would not take advantage of nearby transit opportunities and amenities, especially the BART station located approximately 1/4 mile south of the site, and would provide reduced alternative transportation options compared to the project. Finding: The City Council considered the Reduced Development Alternative and declines to adopt it because it will not avoid or substantially lessen the project's significant unavoidable impacts and is infeasible for the specific economic, social, or other considerations described above, as supported by the administrative record for the project. Alternative #3: Alternate Use Alternative (Residential and a Regional Serving Commercial Complex) Alternative #3 - Alternate Use Alternative would alter the mix of land uses with a reduction in the amount of residential development and construction of a 20 to 30 acre regional-serving commercial complex. This alternative would result in a reduction of 735 residential dwelling units for a total of 1,260 residential dwelling units and an increase of 126,700 square feet of commercial uses for a total of 326,700 square feet. The proposed commercial uses would be mostly comprised of big-box retail. This alternative assumes that the development standards and design guidelines in the Specific Plan would also apply to future development. The Alternate Use Alternative would not eliminate the significant and unavoidable impacts from short-term construction emissions and long-term operational air quality emissions. In addition, the Alternate Use Alternative would not eliminate the significant and unavoidable impacts to the Southbound Hacienda Drive to 1-580 Eastbound On- Ramp under project and cumulative conditions, as well as the impact to the Southbound Tassajara Road to 1-580 Westbound On-Ramp under cumulative conditions. This alternative would not create new significant impacts but would increase a number of impacts compared to the project, mostly related to the regional serving commercial complex with its big-box retail uses. The proposed design guidelines would be implemented and would visually upgrade the site; however, aesthetics impacts would be greater than the project due to the large commercial buildings with expansive parking lots. The extensive parking lots would also increase the impervious surfaces compared to the project, increasing runoff and related hydrology and water quality impacts. This large scale commercial development would less likely be compatible with the urban character of nearby higher density residential and mixed use areas. Traffic generation from the increased commercial component would be higher than for the project, resulting in greater air quality and traffic impacts. Regional serving retail, commercial uses under this alternative are more likely to be auto-dependent. These uses would be incompatible with more compact higher density and transit-oriented development in the area. Alternative #3 is consistent with the project's objectives to the extent that it provides for infill development on the site, provides new housing, and would upgrade the visual 4 quality of the site through implementation of proposed design guidelines. This alternative would not be consistent with several important project objectives and would promote project objectives to a lesser extent than the proposed Project. With the reduced number of units and the location of housing near a regional retail center, this alternative would not create a strong desirable living environment with a range and mix of housing alternatives. Similarly, the combination of residential units near a large big- box oriented retail center would be very different from the existing residential, commercial and mixed use character in the area; as such, this alternative would not be compatible in scale and design that integrates with the nearby higher density and mixed uses. The retail center would be more characteristically suburban, with large buildings and expansive parking lots, while nearby existing higher density housing and mixed uses tend to be more compact. The reduced number of units would supply substantially less new housing to meet the City's housing need. With the reduced number of units and a regional serving big box retail focus, this alternative would not take advantage of nearby transit opportunities and amenities, especially the BART station located approximately 1/4 mile south of the site. Finding: The City Council considered the Alternate Use Alternative and declines to adopt it because it will not avoid or substantially lessen the project's significant unavoidable impacts and is infeasible for the specific economic, social, or other considerations described above, as supported by the administrative record for the project. FINDINGS REGARDING INFEASIBILITY OF ADDITIONAL ALTERNATIVES PROPOSED IN COMMENTS In comments on the DEIR, one commenter (Comment 2-4), in general terms, suggested an alternative to the Project. The City does not consider the comment to propose a specific alternative that is required to be considered under CEQA. In addition, the proposed alternative is not substantially different from the project or other alternatives already considered in the EIR. Nevertheless, the City has carefully considered the proposed alternative, and finds it infeasible as further described below even though the City believes that these findings are not required under CEQA. Comment 2-4. The commenter generally suggest that the project incorporate a stronger level of mixed use and high density residential development as close as possible to the BART station so as to minimize the necessity of using single-occupancy vehicles for commuting and shopping. Finding: See Response 2-4 in the Final EIR. The base density for residential uses in the Project extends up to 25 du/acre; however, the Mixed Use district allows up to 60 du/acre on a 13.2 acre portion of the Project site. This juxtaposition of high density residential use near supporting jobs and shopping accomplishes exactly what the commenter is suggesting. The rest of the residential density in the Project area is consistent with densities in nearby residential and commercial uses. It would not be feasible to substantially increase the Project density and still be consistent with the character of the nearby areas. The Project proposes medium density and medium-high density residential uses in the east and west portions 5 of the site for consistency with existing residential development. Substantially increasing density in these areas would create a marked difference in scale that would not be consistent with Project objectives to be compatible with the scale of surrounding land uses. Further, the Project already facilitates increased density potential up to 60 units/acre in the south part of the Project site which would be compatible with similar existing development in the mixed use areas south of the site. In any case, substantially increasing the intensity of the Project would also increase aesthetic impacts and would likely increase vehicle trips and related significant unavoidable regional air emissions and freeway ramps impacts compared to the project. While increased densities over the Project could place more people closer to BART and other transit facilities, there is no guarantee that all additional residents and commuters would use those facilities. The end result is more likely to be an increase in vehicle trips compared to the Project. The City finds that the suggested alternative would not avoid, and could exacerbate, the Project's significant unavoidable traffic and regional air emissions impacts, and declines to adopt or consider it further and further finds it infeasible for the specific economic, social, or other considerations described above, as supported by the administrative record for the project.. FINDINGS REGARDING INFEASIBILITY OF ADDITIONAL MITIGATION MEASURES PROPOSED IN COMMENTS In comments on the DEIR, commenters suggested additional mitigation measures and/or modifications to the measures recommended in the DEIR. The City carefully considered the proposed mitigations, and finds the proposed mitigations infeasible, not necessary to avoid identified significant impacts of the Project, or otherwise rejected the suggested mitigation, as further described below. In considering specific recommendations on mitigation measures from commenters, the City is guided by CEQA's legal standard to substantially lessen or avoid significant environmental effects to the extent feasible. The mitigation measures recommended in the Project EIR represent the professional judgment and long experience of the City's expert staff and environmental consultants. The City therefore believes that these recommendations should not be modified unless necessary to comply with CEQA legal standards. Thus, in considering commenters' suggested changes or additions to the mitigation measures, the City, in determining whether to accept such suggestions, either in whole or in part, has considered the following factors, among others: 1) whether the suggestion relates to a significant and unavoidable environmental effect of the Project, or instead relates to an effect that can already be mitigated to less-than-significant levels by mitigation measures identified in the EIR; 2) whether the suggested mitigation represents a clear improvement, from an environmental standpoint, over the EIR mitigation that a commenter seeks to replace; 3) whether the suggested mitigation is sufficiently clear as to be easily understood by those who will implement the mitigation as finally adopted; 4) whether the suggested language might be too inflexible to allow for pragmatic implementation; 5) whether the suggestions are "feasible" as defined under CEQA including being able to be accomplished in a successful manner in a reasonable period of time taking into account economic, environmental, technical, legal, 6 social or other factors; and 6) whether the proposed mitigation is consistent with the project objectives. Comment 2-4. The commenter suggests that new homes and businesses use photovoltaic and solar hot water systems to reduce pollutant air emissions, and improve energy conservation and greenhouse gas generation. Finding: No significant energy or greenhouse gas impacts will result from the Project, so these measures are not needed to avoid a significant unavoidable impact for those resources. The measures could possibly reduce air emissions and will be offered to homebuyers as an option. However, it is not possible to quantify the emissions reductions that could be achieved, so any reduction in long term operational emissions would be speculative. The measures would not reduce construction emissions or TACs, and would not affect trip generation. Further, the suggested systems are costly to implement and could increase construction costs, having an adverse impact on the economic viability of the Project. Also, it is the City's policy to encourage, but not require photovoltaic and solar hot water systems in new homes and businesses as a condition of approval. For these reasons, the suggested measures are infeasible and the City declines to impose them. Comment 5-5. The commenter addresses circulation impacts and requests additional TDM measures be considered instead of improvements like addition of lanes. Finding: See Response 5-5 in the Final EIR. As noted in the response, the Project already includes TDM measures to encourage bicycling and walking as alternate modes for commuting. Like TDM measures, the Project design itself encourages alternative transportation choices by placing higher residential densities near commercial uses, the BART station, the Iron Horse Trail, and along the Dublin Boulevard transit corridor. Also, implementing development will be required to include bicycle access and support facilities consistent with the Specific Plan and the City's Bicycle Master Plan (see, e.g., Specific Plan policies 4.14, 4.17 and 4.18), and to reduce parking demand and allow shared parking (see Specific Plan policies 4.23, 4.24). Further, as noted in Response 5-5, the developer will be contributing $50,000 to a feasibility study for analysis of the Iron Horse Trail connectivity from Dougherty Road to the BART station. If developed, a grade-separated crossing at this location would significantly improve bicycle access in the project area. The City can encourage but not require employer TDM measures. However, the above features of the Project design and implementation support the same goals of facilitating alternative modes of transportation. For the above reasons, it is infeasible for the City to impose additional TDM measures beyond those already included in the Project. Comment 9-15. The commenter suggests that commercial and residential units provide for rooftop solar and that solar PV parking canopies be provided in parking areas as energy conservation measures. The comment also suggests that LED lighting be required throughout, including parking lots. Finding: As discussed in Response 9-15 in the Final EIR, the Specific Plan already encourages rooftop solar. In any case, there are no significant unavoidable energy impacts identified for the Project, therefore no additional mitigation measures are required. The measures could possibly reduce air emissions off-site energy sources and will be offered to homebuyers as an option. 7 However, it is not possible to quantify the emissions reductions that could be achieved, so any reduction in long term operational emissions would be speculative. The measures would not reduce construction emissions or TACs, and would not affect trip generation. Further, the suggested systems are costly to implement and could increase construction costs, having an adverse impact on the economic viability of the Project. Also, it is the City's policy to encourage, but not require photovoltaic systems in new homes and businesses as a condition of approval. For these reasons, the City finds the additional mitigation measure infeasible and declines to impose the suggested measures. Comments 9-16, 9-19. The commenter suggests that a number of measures be required relating to electronic vehicles, including electric vehicle charging facilities, homes prewired for electric vehicles, and public charging stations on-site and off-site. The comment also suggest unbundled parking, and creation of a Transportation Management District. Finding: See Responses 9-16 and 9-19 in the Final EIR. With respect to the Project's significant unavoidable traffic impact, the suggested measures would not reduce vehicle trips using the freeway ramps and thus, would not substantially reduce the impact. Similarly, the suggested measures would likely have little if any effect on the Project's significant unavoidable air quality effects regarding short term construction and TAC emissions. The effect of the measures on long term regional emissions is uncertain. Electric vehicle facilities may be offered by the homebuilder as an option; however requiring the systems would add costs to homes with no guarantee that the systems would be used. As noted in Response 9-19, the project itself is designed to reduce vehicle trips and related emissions by providing higher density housing near existing transit facilities such as BART, local transit, and the regional Iron Horse Trail. These facilities all provide readily available and practical means for Project residents and employees to use alternative transportation modes to reduce automobile emissions. Because the suggested measures could be of uncertain effect and/or would not substantially reduce the Project's significant unavoidable air quality and traffic impacts, the City finds them infeasible and declines to impose them. Comments 9-17, 9-18. The commenter suggests that off-site bicycle enhancements such as freeway crossings be required, as well as walking and bicycle connections between residential and commercial components of the Project. The commenter further suggests that local grocery and other retail uses be required. Finding: See Responses 9-17 and 9-18 in the Final EIR. The Project will provide direct connections to the Iron Horse Trail. As noted in Response 9-17, the Iron Horse Trail is a regional facility providing access to the BART station and planned to extend under 1-580 in the future. As such, the Project already reflects the potential for off-site bicycle facilities that Project residents and employees could use to reduce automobile trips. While individual developments within the Project have not been designed, the transportation backbone network is defined and includes connections within the site for bicyclists and pedestrians. Future development projects are required to implement and be consistent with the Specific Plan, its design guidelines, and the City's Bikeways Master Plan; therefore, the suggested measures are already included in the Project. As for requiring particular uses, Response 9-18 notes that the Project provides for retail opportunities, 8 but does not specify (or preclude) particular uses. As a predominantly residential project, neighborhood serving uses such as a grocery store would be reasonably anticipated for the Project commercial areas. The City finds that the suggested measures are not needed because they are already substantially present in the Project. Comment 9-19. The commenter suggests increasing the use of zero emissions electric and plug-in hybrid electric vehicles, establishment of commuter benefit programs, adopting shared parking, and eliminating on-street parking from the Project. Finding: See Response 9-19 in the Final EIR for discussion of these suggestions. The Project supports and would not preclude the use of zero emissions and similar vehicles; however, it is not feasible to require the use of particular vehicles in implementing residential or commercial projects. The Project exemplifies "green street" principles by accommodating alternative modes of transportation for residents and commuters and providing related connectivity within and beyond the Project. As to commuter benefit programs, the Project as designed and with proximity to commuter facilities such as BART and the Iron Horse Trail, similarly supports and encourages commuting alternatives. The suggestion for shared parking is already included in the Project. The elimination of on-site parking is not consistent with the City policies for street design for the type of residential development proposed by the project. In addition, the on-street parking does not adversely affect the use of alternative modes of transportation which as provided for a part of the Project design. For the above reasons, the City finds that requiring zero emission or similar vehicles is infeasible and that the other suggested measures are already present in the Project. Therefore, the City declines to adopt the suggested measures. Conclusion. As evident from the specific responses given to specific suggestions, City staff and consultants spent a significant amount of time carefully considering and weighing alternatives and mitigation language proposed in comments on the DEIR. For those suggested alternatives and mitigation measures not incorporated or adopted by the City, the City finds them either not necessary to reduce a significant impact to less than significant, already present in the Project, or infeasible, as explained above. 2188848.4 9 EXHIBIT D STATEMENT OF OVERRIDING CONSIDERATIONS 1. General. Pursuant to CEQA Guidelines Section 15093, the City Council of the City of Dublin makes the following Statement of Overriding Considerations. The City Council has balanced the benefits of the Dublin Crossing Specific Plan project (Project) to the City of Dublin against the significant adverse impacts identified in the Environmental Impact Report(EIR) that cannot be reduced to less than significant through feasible mitigations or alternatives. Pursuant to Section 15093, the City Council hereby determines that the benefits of the Project outweigh the adverse impacts and the Project should be approved. The City Council has carefully considered each impact in reaching its decision to approve the Project. Even with mitigation, the City Council recognizes that implementation of the Project carries with it unavoidable adverse environmental effects as identified in the EIR. The City Council specifically finds that to the extent the identified significant adverse impacts for the Project have not been reduced to acceptable levels through feasible mitigation or alternatives, there are specific economic, social, land use and other considerations that support approval of the project. 2. Significant Unavoidable Adverse Impacts. The following significant unavoidable air quality and traffic impacts are associated with the Project as identified in the EIR. Short-term Construction Air Quality — The proposed project would result in future short-term air quality impacts associated with construction activities, including grading, operation of equipment, and demolition of existing structures within the project area. The BAAQMD requires the construction mitigation measures to be implemented at all construction sites, regardless of size. However, as the proposed project would facilitate future development and generate construction emissions that could potentially exceed BAAQMD thresholds, a significant unavoidable impact would occur. (Impact 3.2-1.) Long-term Operational Air Quality— The total unmitigated operational emissions associated with buildout of the proposed project would exceed the BAAQMD thresholds for ROG, NOx, PM10, and PM2.5. With application of the measures/design features regarding area and mobile source emissions within the Specific Plan, operational emissions would still exceed the thresholds for ROG, NOx, and PM 10. The proposed project could also result in exposure of sensitive land use in excess of applicable Toxic Air Contaminant standards, even with mitigation. Therefore, these would be considered significant and unavoidable impacts. (Impacts 3.2-3, 3.2-5.) 1 Long-term Operational Impacts to Freeway Ramps — The proposed project would result in a significant impact to the following freeway ramps: Southbound Hacienda Drive to 1-580 Eastbound On-ramp under project and cumulative conditions and Southbound Tassajara Road to 1-580 Westbound On-ramp under cumulative conditions. Mitigation measures 3.12-7 would require modification of 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. As the cities surrounding the 1-580 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. Because the future metering rates cannot be predicted with certainty, the project impacts to freeway ramps would be considered a significant and unavoidable impact. (Impact 3.12-7.) 3. Overriding Considerations. The City Council has carefully considered each impact in reaching its decision to approve the Dublin Crossing Specific Plan project. The City Council now balances those unavoidable impacts against its benefits, and hereby determines that the unavoidable impacts are outweighed by the benefits of the Project as further set forth below. Any one of these benefits is sufficient to justify approval of the Project. The substantial evidence supporting the various benefits can be found in the record as a whole. The Project will facilitate development of an infill area, fully served by public utilities, and convenient to major arterials, services, BART and public transit. The Project includes medium and medium-high density residential and commercial uses to make more efficient use of its infill location and proximity to transit facilities. The Project includes design standards for residential and commercial uses as well as streetscapes that will result in an attractive and vibrant community. The Project emphasizes higher density, compact development patterns appropriate to its location near the BART station and the Iron Horse Trail where a diverse mix of uses would be readily accessible through alternative transport modes. It also emphasizes pedestrian level development where walking and bicycling would be safe, feasible alternatives to automobile trips within the Project area and to or from nearby neighborhoods, transit and commercial uses. Development standards and design guidelines provide measures for ensuring attractive, visually appealing development of private projects and public spaces. The Project includes a significant residential component that will assist the City in meeting its Housing Element RHNA goals. The potential housing will be at densities complementary to existing residential and non-residential uses in the area. The Project will also provide approximately 35 net acres of new parkland as well as funding for future construction and maintenance of a 30-acre community park and 5- 2 acre neighborhood park. This amount of parkland and funding exceeds what the Project would otherwise be required to provide. The Project provides an elementary school site. In addition, the developers will contribute $18.7 million to the City for use on municipal capital projects and other benefits as part of the Development Agreement relating to the Project. The Project includes a minimum of 75,000 square feet (and potential up to 200,000 square feet) of revenue producing commercial development that will create new jobs and sales and property taxes. The Project is also expected to have a fiscally beneficial impact on the City's financial and services resources, estimated by the City's financial consultant to be a net benefit of over$100,000 annually upon full build out. Future development of the site will provide construction employment and permanent employment opportunities for Dublin residents. The Project provides an effective means to implement the City's objectives for the area, as described in the Specific Plan and EIR. 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O L D N 'Q a) a`) (i GO (B 0 >CD 0 _0 f1 C L -C .� N o -C -� = o cs 0 a E w cL c 0 cT c _ 0 .`n o o . 0 .tt-tt Q r cn a) .•--. a) u) °` 'o C O O Q _? m O CD c m — V -a te--' Ca 0 m c E 3 ° 0 = = a) -0 0 c cn c o a) 5. o a) ai _C o U °- -C E C m 0 o 0 o - > U n-o o c B m m .o .o 5 e .� a) ° a, � E c C 0 w = 9 m U m ..-- a 0 cn O 0 0 "a U) v) = m s C ° a) cn N O) G C N ca -° N N c — °- o -U N U 02-0 O v) .� a- a) O U -Q 0 E 0 a) c U --'O ca -c cB .� 0 co � c, 0_-o a) a) n c Q _� o f o G c °- °o o a "` UQo 0w 0 c 0_ Qm ° o • m o :a .'_ E 2 a m o ° m m 0- U c c U ° ° m a UE c v L.L. ca c p a E ° u m °) ° c a)n o - a c c $ o ° c -C c o , - E o N a) OU N Q C [n O °0 ca a) a 0 m Ij_ U 0)" U . O a)` v � w o lL °- (C-0) _ a) 3 "a) 0) a m = a = F- o 0 a U _. — _ — o U E a m c G — a) C -a a.) m 0- as -O = d E m U co m -0 U - > 0 O_ , . 0_ c `° ca o c a)°_ U 7 c 0 2 ° o 0 - � Q ° a o f E " o c -c - m m U fl c o Q o ciu- ° v)m i z •O c c N o N "- m m �i fn n ca D >^ o a s W N ° -O O O — ° co C.• a cn U n �- a 8-E U . CO c >. O - 0� W 41 O a m > a o a) O m C i i LL -0 _ ° E � 0 0- 7 as m a-0 N 0 v) a U u0_-0 o) 0 6 0 co o0 E a) a) co u-) '0 (/) _ E a Qco c P- Ca C i .D ;�- o = in- m:E U = � C t C' m Q _T:3 Y_ co co:4 E Q C as w c_c-._c _0 C N 0`12 M 0 E O O U D 0 a) a) ai T° 5 m_73 U) C 3 > N U 0 U co -ci 0 ,_ O m U .O ri C.:= . a1 E -0 cn G O co d U -p C Q c 0 C E o 56 m N U -0 t O— • -a -a -o a) 'O a) a) C o t o C '� N G) N m CO — y C m C - C o C C C O .> C O m ,O O " C C) c > a) 6 m m m = m a ' O O a -.1-_, 0 'O to ". m U a) - E 0 G) o L L� a) LL C ° m N O_ ? O O 0 0 '0 U- 5 us22 ca 0 a >, 0 U h ,E 5 m N Q 0 C 0 0 ° m ca �0 c c ° n ' a) o m F- o C 0 °a o a E U` a -0 = -a ° c Q m 0_ °- U N L Ca) a CD - m p ° L - 6,..c °? - -0 w N cn § >, 2 E .2 a. C B _c 2 o W O O -0 2 C C U = 0 'O 03 _ - 0_ m I- p C1 = O = J C m = E § T U 'Z 3 r) 0 2, _ C 0 E ai LE E Ta o � U o m 0 a) (o = > N U O a O O m a N a3-0 O � co a 3 L a = U 'O N U O .? U a) o o ( Q U = C V' _ ° Q 2 j L ° o O a F- a C o � ...0° a> m U i 0 2 a) ° Q m ° .- O m p - N -° 0 Cy) o . EOo _ yo c0 U 2 N m U m � - �a o o . a ° a) 0 -0 a) � � -C C' § 2 m U °i U m = o ° U _ o m � E . 0 p n = d m * p 0-E cu' o m c-..)n m o o n a o - � n- 0 '5 -0 2 ° Q c O Q T 4- a N 0 u) Q i = CD ate C Q c m Q p n = O o m 4 - a) a C u 'O N p cn CO O O- y ° -° 2 im = nu O 2 � = 0 -, E a) c = �)o L .,.. o O O m a)) C O o Q 0 _o p C Q fl- p ' p L- G) M -C > O C ...= o m .0 >_ca U) cpi aJ = 0 c6 . E C 0' N CO °--o V) N N °) - O _° (6 Z o -0 Q L 0 0 -0 c) --� o .0 m p = m 0 0' 0 a) 92 _c O o 0 U a) 41 d a = -.=.. = = O m o a; • -O ct a Q (6 -' O-'-' m X N -8 O O " C C U cn Q> 0) O ° 0 0 .0 0 a) O U) y m O . +. co 6C =- cc) . O m o , 0. . w = C0 p a U E J E - . Q a' 'o a) m a' m > a) a) Q_c) � a_ 0 o _C w a ci, a3 cv N -- m � O . Q > U)U= a) O � a) m p m • m L L c 'a m U _a (/) E - N C 7,8 Z L o a o 3E E o E o i = ° o CD ° o 0 ai - ° _ °= = 2 N m III! lifluiI mo °ai N O = a _ ` hi o v F a) m m m U o _ ovo - a) w - °' oa a) o o o m ._ -p a3 o o C m O =- N 4 . = > F O co N ca C c 2 y _0 _ - N f- N m M ya) 0 -a > 0 0 ) -_,.=. _- N y0 cQ >. -.. co t) ) L . _c 0 E c 'w rn O E 50 ,- U N m U v' Q N N - m U E Ll E u) a)= 2 w- =p -= a) a) - o a) U O D S a) a p = , = U m Q- w s 0).E w - m - o .m .0 Ux) m m m UE U U) s ( = ° o m o m o 2 E o O ° O O ' a m m >' _ 'O E N . m N _ C a a) a_2 m O = U 4 m - O = 2 1C O Z _ m O o o f ° 2 _0 7 d a. 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Q E c c _ a.. a) p C a w L o 0 0 0 .° o) m n m e c� o o a F- o N N C LL. 00 C — � C Q .E C `p C -0 a) 0 0 0 0 C cn 0 0 C a) n3 a) o Q ti o_ C c -o CD L C a) 0 o a) C C 3 L C -0 ~ O -o i.::2) ff-- 3 C ° 0 4) C C N C O C a) "C CD_ 0 CCD 0 -C ° cn -0 O „c, o U0 °' ° -oc c °- coi a) C E F - °--oz a) ca ° o a) ai L -� ,c c L O a) 0 C O C 0 • .- O O 'O O w 0 - ia) : 'O 00 in CD Cr Q- a-) _c o c� c�_o o 0 o _c 0 ° >, o -o 0 a) .22 °- -o .o = `n m o c ° - n.- cn c o_ �_ `_o w c ° - _ C o E ,_ p c` ° C CD 0 > a) U c 0 '0 w - o _ = a) .5 `n p t_ E 0 ° o) = o n - C (Y N O — [B C U7 C > cn 0) C -0 0 a) w Co Q o ° o co c O a) 0 .c ._ a) -- C Co a) C C _ '00 00-� C O e 0 c 0 -c —,Q N _—° LL. 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