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Home My WebLink AboutItem 6.1 The Green Mixed Use attch 13 The Green Mixed-Use Project Draft Supplemental Environmental Impact Report SCH# 2013072032 Lead Agency: City of Dublin Prepared By: Jerry Haag, Urban Planner May 2014 Table of Contents 1.0 Project Summary ..................................................................................................................1 1.1 Introduction .............................................................................................................................1 1.2 Summary of Project ................................................................................................................1 1.3 Summary of Environmental Issues .........................................................................................2 1.4 Summary of Impacts and Mitigation Measures ......................................................................3 1.5 Summary of Alternatives ........................................................................................................3 1.6 Areas of Known Controversy .................................................................................................3 2.0 Introduction .........................................................................................................................28 2.1 EIR Requirement ..................................................................................................................28 2.2 Scope of Supplemental EIR ..................................................................................................28 2.3 Legal Basis for Supplemental EIR ........................................................................................29 2.4 Organization of Draft Supplemental EIR .............................................................................30 2.5 DSEIR Review Process.........................................................................................................31 2.6 Topics Not Addressed in this DSEIR ...................................................................................31 2.7 Future Environmental Analysis ............................................................................................31 3.0 Project Description .............................................................................................................32 3.1 Project Location ....................................................................................................................32 3.2 Project Area Features ............................................................................................................32 3.3 Prior Planning Approvals ......................................................................................................32 3.4 Project Applications ..............................................................................................................36 3.5 Project Objectives .................................................................................................................39 3.6 Future Actions Using This Supplemental EIR ......................................................................40 4.0 Environmental Analysis .....................................................................................................46 4.1 Population and Housing ........................................................................................................47 4.2 Traffic and Transportation ....................................................................................................51 4.3 Community Services and Facilities ....................................................................................110 4.4 Public Utilities – Sewer and Water .....................................................................................115 4.5 Biological Resources ..........................................................................................................132 4.6 Noise ...................................................................................................................................150 4.7 Air Quality and Greenhouse Gas Emissions .......................................................................162 4.8 Hazards and Hazardous Materials ......................................................................................197 5.0 Alternatives to the Proposed Project ...............................................................................202 5.1 Alternatives Identified in the Eastern Dublin EIR ..............................................................202 5.2 Alternatives Identified in the IKEA SEIR ..........................................................................203 5.3 Alternatives Identified in this SEIR ....................................................................................203 5.4 Environmentally Superior Alternative ................................................................................208 6.0 Required CEQA Discussion .............................................................................................210 6.1 Cumulative Impacts ............................................................................................................210 6.2 Significant and Unavoidable Environmental Impacts ........................................................211 7.0 Organizations and Persons Consulted ............................................................................213 7.1 Persons and Organizations ..................................................................................................213 7.2 References ...........................................................................................................................214 8.0 Appendices .........................................................................................................................215 8.1 Initial Study 8.2 Notice of Preparation 8.3 Comments received on the Notice of Preparation 8.4 City Council Resolution No. 51-93 (1993 Eastern Dublin EIR) and Resolution 53-93 (Statement of Overriding Considerations) 8.5 City Council Resolution No. 44-04 (IKEA SEIR) 8.6 Supplemental Traffic Documentation 8.7 Supplemental Biological Analysis 8.8 Supplemental Acoustic Analysis 8.9 Supplemental Air Quality/GHG Analysis and Supplemental Exhibits List of Tables Table 1.1 Summary of Mitigation Measures ..................................................................................4 Table 4.2-1 Wheels Bus Routes ....................................................................................................54 Table 4.2-2 Signalized Intersection Level of Service Definition .................................................61 Table 4.2-3 Arterial Level of Service Definition ..........................................................................62 Table 4.2-4 Project Trip Generation .............................................................................................66 Table 4.2-5 Project Trip Distribution............................................................................................68 Table 4.2-6 Intersection Level of Services - Existing Conditions ................................................72 Table 4.2-7 Intersection Level of Services – Short-Term Cumulative Conditions ......................75 Table 4.2-8 Intersection Level of Services – Long-Term Cumulative Conditions .......................80 Table 4.2-9 Queuing Analysis – Existing Conditions ..................................................................84 Table 4.2-10 Queuing Analysis – Short-Term Cumulative Conditions .......................................86 Table 4.2-11 Queuing Analysis – Long-Term Cumulative Conditions ........................................88 Table 4.2-12 MTS Arterial & Freeway segments short term Cumulative (year 2020) ................90 Table 4.2-13 MTS Arterial & Freeway Segments-Long Term Cumulative (Year 2035) ............91 Table 4.2-14 Arterial LOS-Existing Conditions ...........................................................................93 Table 4.2-15 Arterial LOS-Short-Term Cumulative Conditions ..................................................97 Table 4.2-16 Arterial LOS-Long-Term Cumulative Conditions ................................................102 Table 4.3-1 Current Public School Enrollment v. Capacity .......................................................110 Table 4.3-2 DUSD Student Generation Rates ............................................................................113 Table 4.4-1 The Green Project-Estimated Daily Wastewater Demand (gallons/day) ................117 Table 4.4-2 DSRSD Water Supply .............................................................................................121 Table 4.4-3 DSRSD Water Supply & Demand Comparison-Normal Year (AF) .......................123 Table 4.4-4 DSRSD Water Supply & Demand Comparison-Single Dry Year (AF) ..................124 Table 4.4-5 DSRSD Water Supply & Demand Comparison-Multiple Dry Years (AF) ............125 Table 4.4-6 The Green Project-Estimated Daily Water Demand (gallons/day) .........................130 Table 4.5-1 Summary of Biological Communities on the Project Site .......................................133 Table 4.5-2 Plant and Animal Species Observed on the Site .....................................................146 Table 4.6-1 City of Dublin Land Use/Noise Compatibility Standards (decibels) ......................152 Table 4.7-1 Relevant California and National Ambient Air Quality Standards .........................164 Table 4.7-2 Highest Measured Air Pollutant Concentrations at Livermore Station ...................164 Table 4.7-3 Air Quality Significance Thresholds .......................................................................168 Table 4.7-4 Construction Period Emissions................................................................................170 Table 4.7-5 Daily Air Pollutant Emissions from Operation of the Project (pounds/day) ...........171 Table 4.7-6 Annual Air Pollutant Emissions from Operation of the Project (tons/year) ...........172 Table 4.7-7 Project Consistency with Applicable Clean Air Plan Control Measures ................176 Table 4.7-8 Cumulative Risk at Proposed Site ...........................................................................182 Table 4.7-9 Annual Project GHG Emissions in Metric Tons .....................................................190 Table 5.1-1 Alternative 2 vs. Project Trip Generation ................................................................205 Table 5.1-2 Alternative 3 vs. Project Trip Generation ................................................................207 List of Exhibits Exhibit 3.1 Regional Location ......................................................................................................42 Exhibit 3.2 Project Context in Dublin ...........................................................................................43 Exhibit 3.3 Preliminary Site Plan..................................................................................................44 Exhibit 3.4 Preliminary Roadway Network ..................................................................................45 Exhibit 4.2-2 Trip Distribution .....................................................................................................69 Exhibit 4.5-1 Biological Communities .......................................................................................148 Exhibit 4.5-2 Congdon’s Tarplant Locations ..............................................................................149 Exhibit 4.6-1 Noise Measurement Locations ..............................................................................160 Exhibit 4.6-2 2030 Traffic Noise Contours ................................................................................161 Exhibit 4.7-1 Project Site, Roadway Links, and Project Residential Receptor Locations .........192 Exhibit 4.7-2 Increased Cancer Risks (per million) From I-580 Traffic (Unmitigated) ............193 Exhibit 4.7-3 Annual PM2.5 Concentrations (μg/m3) From I-580 Traffic (Unmitigated) .........194 Exhibit 4.7-4 Increased Cancer Risks (per million) From Cumulative Sources (Unmitigated) .195 Exhibit 4.7-5 Annual PM2.5 Concentrations (μg/m3) From Cumulative Sources (Unmitigated) ..196 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 1 1.0 PROJECT SUMMARY 1.1 Introduction This chapter consists of a summary of the proposed project, a list of supplemental environmental issues to be resolved and a summary identification of each supplemental environmental impact and associated supplemental mitigation measure. A discussion of the applicability of the California Environmental Quality Act (CEQA) and implementing Guidelines to the proposed project is outlined in Chapter 2. Chapter 3 contains a detailed discussion of the proposed project. Chapter 4 includes a thorough analysis of supplemental project impacts and supplemental mitigation measures. Chapter 5 provides a range of alternatives to the proposed project as required by CEQA and a discussion of each alternative. Chapter 6 contains all other CEQA-mandated sections. Finally, Chapter 7 includes the names of the Draft Supplemental Environmental Impact Report (DSEIR) preparers, individuals and agencies contacted in the preparation of this document and references. Appendices are included as Chapter 8. 1.2 Summary of Project The project analyzed in this document is the “The Green,” a proposed mixed-use retail and residential complex located in the eastern portion of Dublin. The project site contains 27.5 acres of land is located in the Eastern Dublin Planning Area of the City of Dublin. More specifically, the project site is located on the south side of Martinelli Way between Hacienda Drive to the east and Arnold Drive to the west. Interstate 580 forms the southern boundary of the site. The Alameda County Assessor’s Parcel Numbers for the project area are 986-0033-004-00, 986-0033-005-02, and 986-0033-006-00. The project site is currently owned by the Project Applicant, BHV/Stockbridge Emerald Place Land Company, LLC. The Eastern Dublin Specific Plan has identified the project area for future General Commercial (G-C) development. The site is currently predominantly vacant and contains no major stands of trees, rock outcroppings or other significant natural features. One small vacant prefabricated office building exists in the approximate center of the site that is slated for removal. Properties to the west of the project site are vacant, but are planned for urban uses in the Dublin General Plan and Eastern Dublin Specific Plan. The Hacienda Crossings commercial center exists east of the project site. Properties north of the site are vacant, however, applications were recently approved by the City of Dublin to amend the General Plan and Eastern Dublin Specific Plan and related actions to allow construction of a commercial center anchored by a grocery store. The proposed project would involve constructing a mixed-use commercial and residential development project on the site that would include up to 40,000 gross square feet of retail and restaurant floor area and up to 400 dwellings units. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 2 The project would include grading of the site, installation of utilities and services, placement of landscaping and placement of identification signs. Project objectives include: a) Initiation of a zoning-level framework to guide future development projects within the Project area consistent with the General Plan and Eastern Dublin Specific Plan; b) Creation a community that is compatible in scale and design with the surrounding properties and land uses; c) Construction of a mix of land uses that result in a fiscally positive impact on the City’s financial and service systems; d) Ensuring a long-term financially viable infill project providing for the creation of new jobs, commercial services for the community, opportunities for public gathering spaces and open space areas; e) Offering a diverse residential unit offering that will appeal to a diverse population demographic; f) Creation of a transit-oriented, walkable urban neighborhood by providing housing with direct pedestrian and bicycle connections to retail and restaurant uses on-site, the Dublin/Pleasanton BART Station, the proposed grocery-anchored shopping center to the north, Hacienda Crossings retail center to the east, and the future Campus Office uses to the west; g) Developing a project that responds to a range of transportation choices, including walking, bicycling and public transit (BART and bus service), to reduce traffic congestion and greenhouse gas emissions; h) Providing for a broad range of open spaces integrated into the walkable urban village atmosphere, including children’s play area, green space park and vibrant open plaza surrounded by shops, cafés and restaurants; i) Implementing high-quality urban architectural design that enhances and embraces the prominence and visibility of the project location; j) Providing for a prominent physical and visual connection to the grocery-anchored shopping center to the north of the project site and continuity in architectural and site design between the two properties; and k) Creation of a gateway to the project site through prominent building siting and placement of distinctive features at both Hacienda Drive and Martinelli Way and at the main project driveway off Martinelli Way. Requested land use entitlements to implement the proposed project include amendments to the Dublin General Plan and Eastern Dublin Specific Plan, a PD rezoning with related Stage 1 and Stage 2 Development Plan, a Vesting Tentative Subdivision Map, and a Site Development Review (SDR) Permit. The Applicant will also have the opportunity to request a Development Agreement. 1.3 Summary of Environmental Issues Based on the environmental analysis contained in the Initial Study for this project (see Appendix 8.1) and responses (see DSEIR Appendices 8.2 and 8.3) to the Notice of Preparation issued by the City of Dublin, the following topics are addressed in the DSEIR: population and housing, transportation and traffic, community services and facilities, sewer and water, biological resources, noise, air quality and greenhouse gas analysis hazards and hazardous materials. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 3 1.4 Summary of Impacts and Mitigation Measures Each potentially significant impact and associated mitigation measure (if required) identified in this DSEIR is summarized on Table 1.1. The summary chart has been organized to correspond with the more detailed impact and mitigation measure discussion found in Chapter 4. Table 1.1 is arranged in three columns. The first column identifies supplemental environmental impacts by topic area and level of impact (i.e. significant supplemental impact, less-than-significant supplemental impact, or no supplemental impact) prior to implementation of any supplemental mitigation measures. The second column includes supplemental mitigation measures. The third and final column identifies the level of significance after implementation of supplemental mitigation measures. This chapter is a summary of the DSEIR, consistent with CEQA Guidelines Sec. 15123. For a complete description of the environmental setting, supplemental impacts associated with this proposed project and mitigation measures, refer to Chapter 4 of this DSEIR. 1.5 Summary of Alternatives The DSEIR analyzes three alternatives, as follows. • Alternative 1. "No Project.” This Alternative, mandated by CEQA, assumes that the project site remains in its current undeveloped condition and no development would occur. • Alternative 2. Under Alternative 2, the site would be developed under the existing Planned Development (PD) zoning that would facilitate 270,000 square feet of retail commercial floor space and 35,000 square feet of restaurant space. • Alternative 3. This Alternative would allow Campus Office development under the existing General Plan and Eastern Dublin Specific Plan land use category. Up to 218,000 square feet of office space could be constructed in a low- to mid-rise, campus-like setting at a Floor Area Ratio of 0.35. These alternatives are detailed and analyzed in Chapter 5 of the DSEIR. 1.6 Areas of Known Controversy The project consists of constructing a mixed use complex containing up to 40,000 gross square feet of retail, restaurant and similar type land uses as well as 400 attached dwellings at various densities and product types. The development would also include on-site parking, landscaping, signs and internal driveways. There are no known areas of controversy with respect to environmental issues, although it was expected that the proposal to locate residential uses immediately adjacent to Interstate I-580 could create challenges related to air quality impacts and noise impacts on future residents. Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 4 Ta b l e 1 . 1 s u m m a r i z e s t h e e n v i r o n m e n t a l i m p a c t s a n d m i t i g a t i o n s w h i c h a r e d i s c u s s e d i n d e t a i l i n th e r e m a i n d e r o f t h i s S u p p l e m e n tal Dr a f t E n v i r o n m e n t a l I m p a c t R e p o r t . Ta b l e 1 . 1 S u m m a r y o f M i t i g a t i o n M e a s u r e s Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation TR - 1 Tr a f f i c . T h e D u b l i n B o u l e v a r d a n d A r n o l d R o a d ( # 8 ) in t e r s e c t i o n w o u l d d e g r a d e f r o m L O S D t o L O S E wi t h t h e a d d i t i o n o f p r o j e c t t r i p s d u r i n g t h e A M p e a k ho u r u n d e r E x i s t i n g c o n d i t i o n s . SM - T R - 1 . T h e f o l l o w i n g m e a s u r e s s h a l l b e re q u i r e d t o i m p r o v e t h e l e v e l o f s e r v i c e t o w i t h i n ac c e p t a b l e s t a n d a r d : a) A d d a 7 5 - f o o t l o n g s o u t h b o u n d r i g h t t u r n la n e w i t h a 1 0 0 - f o o t l o n g t a p e r a r e a ; b) C o n v e r t t h e s o u t h b o u n d s h a r e d t h r o u g h - ri g h t l a n e t o t h r o u g h l a n e ; c) O p t i m i z e t r a f f i c s i g n a l s p l i t t i m e . Le s s - t h a n - S i g n i f i c a n t TR - 2 Tr a f f i c . T h e D u b l i n B o u l e v a r d a n d D o u g h e r t y R o a d in t e r s e c t i o n w o u l d o p e r a t e a t L O S E w i t h o u t t h e pr o p o s e d p r o j e c t d u r i n g t h e P M p e a k h o u r u n d e r Sh o r t - T e r m C u m u l a t i v e c o n d i t i o n s a n d im p l e m e n t a t i o n o f t h e p r o p o s e d p r o j e c t w o u l d a d d 5 0 or m o r e t r i p s t o t h e i n t e r s e c t i o n . SM - T R - 2 . T h e f o l l o w i n g m e a s u r e s w o u l d b e re q u i r e d t o i m p r o v e t h e l e v e l o f s e r v i c e t o w i t h i n ac c e p t a b l e s t a n d a r d : a) C o n v e r t a n e a s t b o u n d r i g h t - t u r n l a n e t o a th r o u g h l a n e t o p r o v i d e t w o l e f t - t u r n l a n e s , fo u r t h r o u g h l a n e s a n d o n e r i g h t - t u r n l a n e on t h e e a s t b o u n d a p p r o a c h o n D u b l i n Bo u l e v a r d ; b) P r o v i d e a c o r r e s p o n d i n g 3 0 0 - f o o t l o n g re c e i v i n g l a n e o n t h e e a s t l e g w i t h a 3 6 0 - fo o t l o n g m e r g i n g t a p e r a r e a ; c) P r o v i d e a n o v e r l a p s i g n a l p h a s i n g f o r t h e we s t b o u n d r i g h t - t u r n m o v e m e n t a n d pr o h i b i t c o n f l i c t i n g s o u t h b o u n d U - t u r n mo v e m e n t ; a n d d) O p t i m i z e t r a f f i c s i g n a l s p l i t t i m e . Si g n i f i c a n t a n d U n a v o i d a b l e Al t e r n a t i v e M i t i g a t i o n M e a s u r e S M - T R - 2 . Th e E a s t e r n D u b l i n E I R M M 3 . 3 / 2 . 0 r e q u i r e s no n - r e s i d e n t i a l p r o j e c t s w i t h 5 0 o r m o r e em p l o y e e s t o p a r t i c i p a t e i n t h e T r a n s p o r t a t i o n Sy s t e m s M a n a g e m e n t ( T S M ) p r o g r a m . A s a n al t e r n a t i v e m i t i g a t i o n m e a s u r e , t h e P r o j e c t s h a l l pr e p a r e a t r a n s p o r t a t i o n d e m a n d m a n a g e m e n t Si g n i f i c a n t a n d U n a v o i d a b l e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 5 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation (T D M ) p l a n t o e n c o m p a s s b o t h c o m m e r c i a l a n d re s i d e n t i a l u s e s a s p a r t o f t h e p r o j e c t . T h e p r o j e c t de v e l o p e r s h a l l w o r k w i t h t h e C i t y t o d e v e l o p t h e ke y e l e m e n t s o f t h e T D M p l a n , w h i c h s h a l l b e ap p r o v e d b y t h e C i t y p r i o r t o t h e i s s u a n c e o f t h e fi r s t b u i l d i n g p e r m i t . T h e T D M p l a n s h o u l d in c l u d e , b u t n o t b e l i m i t e d t o , t h e f o l l o w i n g el e m e n t s : a) A p p o i n t T r a n s p o r t a t i o n C o o r d i n a t o r t o ov e r s e e t h e T D M p r o g r a m d e v e l o p e d f o r th e p r o j e c t i n c l u d i n g p r o g r a m d e v e l o p m e n t , in f o r m a t i o n d i s t r i b u t i o n a n d p r o g r a m im p l e m e n t a t i o n . b) P r o m o t e a n d d i s t r i b u t e h a r d c o p y in f o r m a t i o n q u a r t e r l y t o a l l e m p l o y e e s a n d re s i d e n t s r e g a r d i n g 5 1 1 , R i d e m a t c h , Gu a r a n t e e d R i d e H o m e P r o g r a m , Wh e e l s / L A V T A , A l t a m o n t C o r r i d o r Ex p r e s s ( A C E ) , B A R T , s h u t t l e s t o r e g i o n a l tr a n s i t , a n d a n y c a r s h a r e p r o g r a m s . c) D i s t r i b u t e i n f o r m a t i o n q u a r t e r l y r e g a r d i n g ab o v e b y e m a i l b l a s t t o a l l e m p l o y e e s a n d re s i d e n t s . d) C o - s p o n s o r s u b a r e a t r a n s p o r t a t i o n f a i r o n c e a y e a r w i t h “ T h e V i l l a g e ” p r o p e r t y t o t h e no r t h a n d / o r o t h e r d e v e l o p m e n t s i n t h e E a s t Du b l i n a r e a . I n v i t e W h ee l s , 5 1 1 . o r g , a n d a t le a s t t w o o t h e r c o m m u t e a l t e r n a t i v e s e r v i c e pr o v i d e r s t o a t t e n d a n d d i s t r i b u t e c o m m u t e al t e r n a t i v e i n f o r m a t i o n . e) P r o v i d e b i c y c l e p a r k i n g f a c i l i t i e s f o r 2 0 pe r c e n t o f c o m m e r c i a l c a r s p a c e s o r a nu m b e r a p p r o v e d b y t h e C i t y b e y o n d t h e Ci t y ’ s b i c y c l e r a c k r e q u i r e m e n t . f) P r o v i d e s e c u r e d b i c y c l e p a r k i n g ( l o c k e r s o r ca g e s ) f o r e m p l o y e e s . g) J o i n C i t y C a r S h a r e a s a “ B i z P r i m e ” Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 6 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation me m b e r a n d p a y f o r m e m b e r s h i p o f a mi n i m u m o f f i v e p e r c e n t e m p l o y e e s . h) I m p l e m e n t a B A R T s u b s i d y p r o g r a m t h a t wo u l d p r o v i d e B A R T t i c k e t s a t n o c o s t o r su b s i d i z e d r a t e t o a l l e m p l o y e e s . i) I m p l e m e n t a C o m m u t e r T a x B e n e f i t Pr o g r a m o r e q u i v a l e n t . U n d e r S e c t i o n 13 2 ( F ) o f f e d e r a l t a x c o d e , a n e m p l o y e r c a n of f e r i t s e m p l o y e e s u p t o $ 2 4 5 p e r m o n t h fo r q u a l i f i e d t r a n s i t , v a n p o o l o r p a r k i n g co s t s . O r , a n e m p l o y e r m a y o f f e r $ 2 0 p e r mo n t h f o r b i c y c l i n g c o s t s . F u l l i n f o r m a t i o n is a v a i l a b l e a t : ht t p : / / r i d e s h a r e . 5 1 1 . o r g / r e w a r d s / t a x _ b e n e f i ts . a s p x j) P r o v i d e p r e f e r e n t i a l p a r k i n g f o r c a r p o o l s an d v a n p o o l s a s p a r t o f o f f - s t r e e t p a r k i n g re q u i r e m e n t s . TR - 3 Tr a f f i c . Th e D u b l i n B o u l e v a r d a n d H a c i e n d a D r i v e (# 1 0 ) i n t e r s e c t i o n w o u l d d e g r a d e f r o m L O S D t o L O S E w i t h t h e a d d i t i o n o f p r o j e c t t r i p s d u r i n g t h e P M p e a k ho u r u n d e r S h o r t - T e r m C u m u l a t i v e c o n d i t i o n s . SM - T R - 3 . T h e f o l l o w i n g m e a s u r e s w o u l d b e re q u i r e d t o i m p r o v e t h e l e v e l o f s e r v i c e t o w i t h i n an a c c e p t a b l e s t a n d a r d : a) C o n v e r t a n e a s t b o u n d r i g h t - t u r n l a n e t o a th r o u g h l a n e t o p r o v i d e t w o l e f t - t u r n l a n e s , fo u r t h r o u g h l a n e s a n d o n e r i g h t - t u r n l a n e on t h e e a s t b o u n d a p p r o a c h o n D u b l i n Bo u l e v a r d ; b ) P r o v i d e a c o r r e s p on d i n g r e c e i v i n g l a n e o n th e e a s t l e g w i t h a 3 6 0 - f o o t l o n g t a p e r a r e a ; an d c ) O p t i m i z e t r a f f i c s i g n a l s p l i t t i m e . Le s s - t h a n - S i g n i f i c a n t TR - 4 Tr a f f i c . Th e D u b l i n B o u l e v a r d a n d T a s s a j a r a R o a d in t e r s e c t i o n w o u l d o p e r a t e a t L O S E w i t h o u t t h e pr o p o s e d p r o j e c t d u r i n g t h e P M p e a k h o u r u n d e r Sh o r t - T e r m C u m u l a t i v e c o n d i t i o n s a n d im p l e m e n t a t i o n o f t h e p r o p o s e d p r o j e c t w o u l d a d d 5 0 or m o r e t r i p s t o t h e i n t e r s e c t i o n . SM - T R - 4 . T h e f o l l o w i n g m e a s u r e s w o u l d b e re q u i r e d t o i m p r o v e t h e l e v e l o f s e r v i c e t o w i t h i n ac c e p t a b l e s t a n d a r d : a) A d d a n e a s t b o u n d t h r o u g h l a n e t o p r o v i d e tw o l e f t - t u r n l a n e s , t h r e e t h r o u g h l a n e s a n d tw o r i g h t - t u r n l a n e o n t h e e a s t b o u n d ap p r o a c h o n D u b l i n B o u l e v a r d ; a n d Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 7 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation b) P r o v i d e a c o r r e s p o n d in g r e c e i v i n g l a n e o n th e e a s t l e g t h a t e x t e n d s f r o m T a s s a j a r a Ro a d t o B r a n n i g a n S t r e e t . TR - 5 Tr a f f i c . T h e D u b l i n B o u l e v a r d a n d S c a r l e t t D r i v e ( # 5 ) in t e r s e c t i o n w o u l d o p e r a t e a t L O S E w i t h o u t t h e pr o p o s e d p r o j e c t d u r i n g t h e A M p e a k h o u r u n d e r L o n g - Te r m C u m u l a t i v e c o n d i t i o n s a n d t h e p r o p o s e d p r o j e c t wo u l d f u r t h e r d e g r a d e t h e o p e r a t i o n s t o L O S F a n d a d d 50 o r m o r e t r i p s t o t h e i n t e r s e c t i o n . SM - T R - 5 . A t t h e i n t e r s e c t i o n o f D u b l i n Bo u l e v a r d a n d S c a r l e t t D r i v e , t h e r e i s a si g n i f i c a n t i m p a c t f r o m t h e D u b l i n C r o s s i n g pr o j e c t a c c o r d i n g t o t h e D u bl i n C r o s s i n g S p e c i f i c Pl a n ( D C S P ) - D E I R . I n t h e D S C P - D E I R , t h e re c o m m e n d e d m e a s u r e t o m i t i g a t e t h e i m p a c t s a t th e i n t e r s e c t i o n o f S c a r l e t t D r i v e a n d D u b l i n Bo u l e v a r d d u e t o t h e h i g h r a t e o f pe d e s t r i a n s / b i c y c l i s t s c r o s s i n g a t D u b l i n Bo u l e v a r d i s a g r a d e s e p a r a t e d c r o s s i n g . T h e gr a d e s e p a r a t e d c r o s s i n g w o u l d e l i m i n a t e t h e ne e d f o r a t - g r a d e p e d e s t r i a n a c t u a t i o n s a t t h e tr a f f i c s i g n a l , w h i c h w o u l d a l l o w m o r e g r e e n ti m e t o b e a l l o c a t e d t o t h r o u g h t r a f f i c o n D u b l i n Bo u l e v a r d . A l t h o u g h t h e D u b l i n C r o s s i n g s pr o j e c t h a s n o t b e e n e n v i ro n m e n t a l l y c l e a r e d , n o r ha s e n g i n e e r i n g o r r i g h t o f w a y a n a l y s i s b e e n co m p l e t e d w i t h r e g a r d s t o t h e f e a s i b i l i t y o f t h i s im p r o v e m e n t , t h e C i t y i s a g g r e s s i v e l y p u r s u i n g th i s p r o j e c t t o i m p r o v e p e d e s t r i a n a n d b i c y c l e mo b i l i t y a l o n g t h e I r o n H o r s e T r a i l . T h e C i t y al s o p l a n s t o i n c l u d e a g r a d e s e p a r a t e d c r o s s i n g at t h i s l o c a t i o n i n i t s u p d a t e t o t h e T I F p r o g r a m to s e c u r e p r o j e c t f u n d i n g . Le s s - t h a n - S i g n i f i c a n t TR - 6 Tr a f f i c . T h e D u b l i n B o u l e v a r d a n d A r n o l d R o a d ( # 8 ) in t e r s e c t i o n w o u l d d e g r a d e f r o m L O S D t o L O S E w i t h th e a d d i t i o n o f p r o j e c t t r i p s d u r i n g t h e A M p e a k h o u r un d e r L o n g - T e r m C u m u l a t i v e c o n d i t i o n s . SM - T R - 6 . T h e f o l l o w i n g m e a s u r e s w o u l d b e re q u i r e d t o i m p r o v e t h e l e v e l o f s e r v i c e t o w i t h i n ac c e p t a b l e s t a n d a r d : a) M o d i f y t h e t r a f f i c s i gn a l p h a s i n g t o p r o v i d e a p r o t e c t e d / p e r m i t t e d o v e r l a p p h a s e f o r t h e so u t h b o u n d r i g h t - t u r n m o v e m e n t a n d pr o h i b i t c o n f l i c t i n g e a s t b o u n d U - t u r n mo v e m e n t ; a n d b) O p t i m i z e t r a f f i c s i g n a l s p l i t t i m e . Le s s - t h a n - S i g n i f i c a n t TR - 7 Tr a f f i c . T h e s o u t h b o u n d l e f t - t u r n q u e u e a t t h e D u b l i n SM - T R - 7 . O p t i m i z a t i o n o f t h e t r a f f i c s i g n a l Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 8 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation Bo u l e v a r d a n d D o u g h e r t y R o a d i n t e r s e c t i o n w o u l d ex c e e d t u r n p o c k e t c a p a c i t y w i t h o u t t h e p r o p o s e d pr o j e c t d u r i n g t h e P M p e a k h o u r a n d t h e p r o p o s e d pr o j e c t w o u l d l e n g t h e n t h e q u e u e b y 2 5 f e e t o r m o r e un d e r S h o r t - T e r m C u m u l a t i v e c o n d i t i o n s . ph a s e t i m e w o u l d r e d u c e t h e 9 5 th p e r c e n t i l e qu e u e l e n g t h f o r t h e s o u t h b o u n d l e f t t u r n t o 3 7 1 fe e t d u r i n g t h e P M p e a k h o u r . W h i l e t h e q u e u e le n g t h w o u l d s t i l l e x c e e d t h e tu r n p o c k e t s t o r a g e , th e p r o j e c t t r a f f i c w o u l d l e n g t h e n t h e q u e u e b y le s s t h a n 2 5 f e e t . TR - 8 Tr a f f i c . T h e w e s t b o u n d l e f t - t u r n q u e u e a t t h e D u b l i n Bo u l e v a r d a n d H a c i e n d a D r i v e ( # 1 0 ) i n t e r s e c t i o n w o u l d ex c e e d t u r n p o c k e t c a p a c i t y w i t h o u t t h e p r o p o s e d pr o j e c t d u r i n g t h e A M p e a k h o u r a n d i m p l e m e n t a t i o n o f th e p r o p o s e d p r o j e c t w o u l d l e n g t h e n t h e q u e u e b y 2 5 fe e t o r m o r e u n d e r S h o r t - T e r m C u m u l a t i v e c o n d i t i o n s . Fu r t h e r , d u r i n g t h e P M p e a k , t h e p r o j e c t w o u l d c a u s e th e q u e u e t o e x t e n d b e y o n d t h e t u r n p o c k e t b y 2 5 f e e t wh e n i t w o u l d b e c o n t a i n e d u n d e r N o P r o j e c t s c e n a r i o . SM - T R - 8 . T h e t r a f f i c s i g n a l a t t h i s i n t e r s e c t i o n sh a l l b e m o d i f i e d t o p r o v i d e a d d i t i o n a l g r e e n ti m e f o r t h e w e s t b o u n d l e f t - t u r n m o v e m e n t b y re d u c i n g t h e g r e e n t i m e f o r t h e e a s t b o u n d th r o u g h m o v e m e n t . T h i s w i l l r e d u c e t h e q u e u e le n g t h t o 4 2 0 f e e t i n t h e A M p e a k h o u r a n d 2 7 0 fe e t i n t h e P M p e a k ho u r . W h i l e t h e q u e u e le n g t h s w o u l d s t i l l e x c e e d t u r n p o c k e t c a p a c i t y , th e p r o j e c t t r a f f i c w o u l d l e n g t h e n t h e q u e u e b y le s s t h a n 2 5 f e e t i n t h e AM p e a k h o u r a n d w o u l d ca u s e t h e q u e u e t o e x t e n d b e y o n d t h e t u r n p o c k e t by l e s s t h a n 2 5 f e e t i n t h e P M p e a k h o u r . Le s s - t h a n - S i g n i f i c a n t TR - 9 Tr a f f i c . T h e s o u t h b o u n d l e f t - t u r n q u e u e a t t h e S c a r l e t t Dr i v e a n d D o u g h e r t y R o a d in t e r s e c t i o n w o u l d e x c e e d tu r n p o c k e t c a p a c i t y w i t h o u t t h e p r o p o s e d p r o j e c t du r i n g t h e P M p e a k h o u r a n d i m p l e m e n t a t i o n o f t h e pr o p o s e d p r o j e c t w o u l d l e n g t h e n t h e q u e u e b y 2 5 f e e t o r mo r e u n d e r L o n g - T e r m C u m u l a t i v e c o n d i t i o n s . SM - T R - 9 . T h e t r a f f i c s i g n a l p h a s i n g a t t h i s in t e r s e c t i o n s h a l l b e m o d i f i e d t o p r o v i d e ad d i t i o n a l g r e e n t i m e f o r t h e s o u t h b o u n d l e f t - t u r n mo v e m e n t . T h i s w i l l r e d u c e t h e q u e u e l e n g t h b y 12 f e e t t o 8 4 5 f e e t a n d t o w i t h i n a c c e p t a b l e th r e s h o l d . A l s o , b e c a u s e t h e i m p a c t i s c a u s e d b y cu m u l a t i v e l a n d u s e g r o w t h i n t h e r e g i o n , t h e pr o j e c t d e v e l o p e r s h a l l m a k e a f a i r s h a r e co n t r i b u t i o n t o w a r d t h i s i m p r o v e m e n t . T h e f a i r sh a r e c o n t r i b u t i o n s h a l l b e p a i d p r i o r t o t h e is s u a n c e o f t h e f i r s t b u i l d i n g p e r m i t . L e s s - t h a n - S i g n i f i c a n t TR - 1 0 Tr a f f i c . T h e p r o j e c t w o u l d c a u s e t h e D u b l i n B o u l e v a r d se g m e n t b e t w e e n H a c i e n d a D r i v e a n d H i b e r n i a D r i v e t o de g r a d e f r o m L O S D t o L O S E d u r i n g t h e A M p e a k ho u r u n d e r E x i s t i n g c o n d i t i o n s . T h e p r o j e c t w o u l d o n l y ad d 3 0 t r i p s t o t h i s s e g m e n t . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 1 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e n o r t h b o u n d No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 9 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation Ha c i e n d a D r i v e s e g m e n t o f D u b l i n B o u l e v a r d t o Ce n t r a l P a r k w a y t o d e g r a d e f r o m L O S D t o L O S E . Pr o j e c t t r a f f i c w o u l d a l s o c a u se t h e v o l u m e t o c a p a c i t y ra t i o o f t h e n o r t h b o u n d H a c i e n d a D r i v e s e g m e n t be t w e e n I - 5 8 0 w e s t b o u n d r a m p t o H a c i e n d a C r o s s i n g s to i n c r e a s e b y 0 . 0 7 1 . TR - 1 2 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e v o l u m e t o ca p a c i t y r a t i o a l o n g t h e e a s t b o u n d D u b l i n B o u l e v a r d se g m e n t b e t w e e n D e M a r c u s B o u l e v a r d a n d I r o n H o r s e Pa r k w a y t o i n c r e a s e b y 0 . 0 3 w h e r e i t w o u l d o p e r a t e a t LO S E i n t h e P M p e a k h o u r u n d e r S h o r t - T e r m Cu m u l a t i v e N o P r o j e c t s c e n a r i o . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 3 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e v o l u m e t o ca p a c i t y r a t i o a l o n g t h e w e s t b o u n d D u b l i n B o u l e v a r d se g m e n t b e t w e e n S c a r l e t t D r i v e a n d D o u g h e r t y R o a d t o in c r e a s e b y 0 . 0 2 7 w h e r e i t w o ul d o p e r a t e a t L O S E i n th e A M p e a k h o u r u n d e r S h o r t - T e r m C u m u l a t i v e N o Pr o j e c t s c e n a r i o . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 4 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e v o l u m e t o ca p a c i t y r a t i o a l o n g t h e n o r th b o u n d H a c i e n d a D r i v e se g m e n t b e t w e e n I - 5 8 0 w e s t b o u n d r a m p s a n d H a c i e n d a Cr o s s i n g t o i n c r e a s e b y 0 . 0 4 5 w h e r e i t w o u l d o p e r a t e a t LO S E i n t h e A M p e a k h o u r a n d b y 0 . 0 7 1 w h e r e i t wo u l d o p e r a t e a t L O S F i n t h e P M p e a k h o u r u n d e r Sh o r t - T e r m C u m u l a t i v e N o P r o j e c t s c e n a r i o . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 5 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e n o r t h b o u n d Ta s s a j a r a R o a d s e g m e n t b e t w e e n D u b l i n B o u l e v a r d a n d Ce n t r a l P a r k w a y t o d e g r a d e f r o m L O S D t o L O S E du r i n g t h e P M p e a k h o u r u n d e r S h o r t - T e r m C u m u l a t i v e co n d i t i o n s . W h i l e t h e p r o j e c t w o u l d o n l y a d d 4 t r i p s t o th i s s e g m e n t , t h i s i m p a c t i s c o n s i d e r e d t o b e s i g n i f i c a n t . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 10 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation TR - 1 6 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e v o l u m e t o ca p a c i t y r a t i o s a l o n g t h e w e s t b o u n d D u b l i n B o u l e v a r d se g m e n t s b e t w e e n I r o n H o r s e P a r k w a y a n d C a m p P a r k s wh e r e i t w o u l d o p e r a t e a t L O S E a n d b e t w e e n C a m p Pa r k s a n d S c a r l e t t D r i v e w h e r e i t w o u l d o p e r a t e a t L O S F i n t h e A M p e a k h o u r u n d e r L o n g - T e r m C u m u l a t i v e No P r o j e c t s c e n a r i o t o i n c r e a s e b y 0 . 0 2 3 . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 7 Tr a f f i c . Th e p r o j e c t w o u l d c a u s e t h e v o l u m e t o ca p a c i t y r a t i o a l o n g t h e n o r th b o u n d H a c i e n d a D r i v e se g m e n t b e t w e e n I - 5 8 0 w e s t b o u n d r a m p s a n d H a c i e n d a Cr o s s i n g t o i n c r e a s e b y 0 . 0 2 d u r i n g t h e P M p e a k h o u r wh e r e i t w o u l d o p e r a t e a t L O S F u n d e r L o n g - T e r m Cu m u l a t i v e N o P r o j e c t s c e n a r i o . No f e a s i b l e m i t i g a t i o n a v a i l a b l e Si g n i f i c a n t a n d U n a v o i d a b l e TR - 1 8 Tr a f f i c . T h e p r o j e c t c o u l d c o n f l i c t w i t h a d o p t e d b i c y c l e pl a n s , g u i d e l i n e s , p o l i c i e s o r s t a n d a r d s . SM - T R - 1 8 . P r i o r t o i s s u a n c e o f a n y p e r m i t f o r th e p r o j e c t , t h e P r o j e c t s h al l s u b m i t d e s i g n p l a n s th a t a r e c o n s i s t e n t w i t h a p p l i c a b l e C i t y gu i d e l i n e s , p o l i c e s a n d s t a n d a r d s f o r r e v i e w a n d ap p r o v a l b y t h e C i t y . Le s s - t h a n - S i g n i f i c a n t TR - 1 9 Tr a f f i c . Th e p r o j e c t c o u l d c o n f l i c t w i t h a d o p t e d po l i c i e s , p l a n s o r p r o g r a m s u p p o r t i n g p e d e s t r i a n s . SM - T R - 1 9 . P r i o r t o i s s u a n c e o f a n y p e r m i t f o r th e p r o j e c t , t h e P r o j e c t s h al l s u b m i t d e s i g n p l a n s th a t a r e c o n s i s t e n t w i t h a p p l i c a b l e C i t y gu i d e l i n e s , p o l i c e s a n d s t a n d a r d s f o r r e v i e w a n d ap p r o v a l b y t h e C i t y . Le s s - t h a n - S i g n i f i c a n t TR - 2 0 Tr a f f i c . Th e p r o j e c t c o u l d c o n f l i c t w i t h a d o p t e d po l i c i e s , p l a n s o r p r o g r a m s u p p o r t i n g p e d e s t r i a n s , in c l u d i n g t h e C i t y ’ s C o m p l e t e S t r e e t s p o l i c i e s . SM - T R - 2 0 . P r i o r t o i s s u a n c e o f a n y p e r m i t f o r th e p r o j e c t , t h e P r o j e c t s h al l s u b m i t d e s i g n p l a n s th a t a r e c o n s i s t e n t w i t h t h e C i t y ’ s C o m p l e t e St r e e t P o l i c y a n d d e s i g n st a n d a r d s f o r r e v i e w a n d ap p r o v a l b y t h e C i t y . Le s s - t h a n - S i g n i f i c a n t TR - 2 1 Tr a f f i c . T h e p r o j e c t c o u l d in c l u d e d e s i g n f e a t u r e s t h a t wo u l d n o t b e c o n s i s t e n t w it h t h e C i t y ’ s e n g i n e e r i n g de s i g n s t a n d a r d s or st a n d a r d s p u b l i s h e d b y t h e I T E o r Ca l t r a n s . SM - T R - 2 1 . P r i o r t o i s s u a n c e o f a n y p e r m i t f o r th e p r o j e c t , t h e p r o j e c t d e v e l o p e r s h a l l s u b m i t de s i g n p l a n s t h a t a r e c o n s i s t e n t w i t h t h e C i t y ’ s Co m p l e t e S t r e e t P o l i c y f o r r e v i e w a n d a p p r o v a l by t h e C i t y . A l l d e s i g n s s h a l l c o n f o r m t o C i t y Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 11 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation st a n d a r d s . TR - 2 2 Tr a f f i c . P r o j e c t c o n s t r u c t i o n a c t i v i t i e s s u c h a s t h e im p o r t o f t h e f i l l m a t e r i a l a n d d e l i v e r y o f m a t e r i a l s co u l d r e s u l t i n i m p a c t s t o v e h i c l e , b i c y c l e a n d pe d e s t r i a n a c c e s s i n a n d a r o u n d t h e p r o j e c t a r e a . SM - T R - 2 2 . B e f o r e i s s u a n c e o f g r a d i n g p e r m i t s fo r t h e p r o j e c t , t h e p r o j e c t d e v e l o p e r s h a l l pr e p a r e a d e t a i l e d T r a f f i c M a n a g e m e n t P l a n t h a t wi l l b e s u b j e c t t o r e v i e w a n d a p p r o v a l b y t h e Ci t y o f D u b l i n , L A V T A , a n d l o c a l e m e r g e n c y se r v i c e p r o v i d e r s , i n c l u d i n g t h e C i t y o f D u b l i n Fi r e P r e v e n t i o n B u r e a u a n d t h e C i t y o f D u b l i n Po l i c e S e r v i c e s D e p a r t m e n t . T h e p l a n s h a l l en s u r e m a i n t e n a n c e o f a c c e p t a b l e o p e r a t i n g co n d i t i o n s o n l o c a l r o a d w a y s a n d t r a n s i t r o u t e s . At a m i n i m u m , t h e p l a n s h a l l i n c l u d e : a) T h e n u m b e r o f t r u c k tr i p s , t i m e , a n d d a y o f st r e e t c l o s u r e s b) T i m e o f d a y o f a r r i v a l a n d d e p a r t u r e o f tr u c k s c) L i m i t a t i o n s o n t h e s i z e a n d t y p e o f t r u c k s ; pr o v i s i o n o f a s t a g i n g a r e a w i t h a l i m i t a t i o n on t h e n u m b e r o f t r u c k s t h a t c a n b e w a i t i n g d) P r o v i s i o n o f a t r u c k c i r c u l a t i o n p a t t e r n e) P r o v i s i o n o f a d r i v e w a y a c c e s s p l a n t o ma i n t a i n s a f e v e h i c u l a r , p e d e s t r i a n , a n d bi c y c l e m o v e m e n t s ( e .g . , s t e e l p l a t e s , mi n i m u m d i s t a n c e s o f o p e n t r e n c h e s , a n d pr i v a t e v e h i c l e p i c k u p a n d d r o p o f f a r e a s ) f) S a f e a n d e f f i c i e n t a c c e s s r o u t e s f o r em e r g e n c y v e h i c l e s g) E f f i c i e n t a n d c o n v e n i e n t t r a n s i t r o u t e s h) M a n u a l t r a f f i c c o n t r o l w h e n n e c e s s a r y i) P r o p e r a d v a n c e w a r n i n g a n d p o s t e d s i g n a g e co n c e r n i n g s t r e e t c l o s u r e s j) P r o v i s i o n s f o r p e d e s t r i a n s a f e t y a n d a c c e s s . Le s s - t h a n - S i g n i f i c a n t Pa r k - 1 Co m m u n i t y S e r v i c e s & F a c i l i t i e s . B u i l d - o u t o f t h e pr o p o s e d p r o j e c t w o u l d r e q u i r e t h e d e d i c a t i o n o f 5 a c r e s of l o c a l p a r k l a n d o n t h e p r o j e c t s i t e . T h e p r o p o s e d pr o j e c t p r o v i d e s n o pu b l i c p a r k s p a c e . SM - P a r k - 1 . As p a r t o f t h e f i r s t f i n a l s u b d i v i s i o n ma p f o r t h e p r o j e c t , t h e p r o j e c t d e v e l o p e r ( s ) s h a l l de d i c a t e a m i n i m u m 2 - ac r e N e i g h b o r h o o d Sq u a r e t o t h e C i t y o f D u b l i n . T h e s i z e , co n f i g u r a t i o n a n d l o c a t i o n o f t h e N e i g h b o r h o o d Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 12 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation Sq u a r e s h a l l b e a p p r o v e d b y t h e D u b l i n p a r k s an d C o m m u n i t y S e r v i c e s D e p a r t m e n t . P r o j e c t de v e l o p e r ( s ) s h a l l s a t i s f y r e m a i n i n g l o c a l p a r k re q u i r e m e n t s b y p a y i n g f e e s t o t h e C i t y o f D u b l i n pr i o r t o i s s u a n c e o f b u i l d i n g p e r m i t s . BI O - 1 Bi o l o g i c a l R e s o u r c e s . T h e p r o p o s e d p r o j e c t w o u l d re s u l t i n t h e f i l l o f p o t e n t i a l l y j u r i s d i c t i o n a l w a t e r s o f th e U . S . a n d / o r w a t e r s o f t h e S t a t e . SM - B I O - 1 . T h e a p p l i c a n t s h a l l u n d e r t a k e t h e fo l l o w i n g p r i o r t o i s s u a n c e o f a g r a d i n g p l a n f o r th e s i t e : a) A w e t l a n d s d e l i n e a t i o n s h a l l b e c o m p l e t e d fo r t h e s i t e c o n s i s t e n t w i t h U . S . A r m y C o r p s of E n g i n e e r s p r o t o c o l s . b) I f j u r i s d i c t i o n a l w e t l a n d s a r e f o u n d o n t h e si t e a n d i f a v o i d a n c e o f t h e s e j u r i s d i c t i o n a l wa t e r s o n t h e s i t e i s n o t f e a s i b l e , s u i t a b l e co m p e n s a t o r y m i t i g a t i o n s h a l l b e p r o v i d e d ba s e d o n t h e c o n c e p t o f n o n e t l o s s o f we t l a n d h a b i t a t v a l u e s o r a c r e a g e s . I n s u c h an e v e n t u a l i t y , a w e t l a n d m i t i g a t i o n p l a n sh a l l b e d e v e l o p e d a n d i m p l e m e n t e d t h a t in c l u d e s c r e a t i o n , r e s t o r a t i o n , a n d / o r en h a n c e m e n t o f o f f - s i t e w e t l a n d s p r i o r t o pr o j e c t g r o u n d d i s t u r b a n c e . M i t i g a t i o n a r e a s sh a l l b e e s t a b l i s h e d i n p e r p e t u i t y t h r o u g h de d i c a t i o n o f a c o n s e r v a t i o n e a s e m e n t ( o r si m i l a r m e c h a n i s m ) t o a n a p p r o v e d en v i r o n m e n t a l o r g a n i z a t i o n a n d p a y m e n t o f an e n d o w m e n t f o r t h e l o n g - t e r m ma n a g e m e n t o f t h e s i t e . I f w e t l a n d s a r e de t e r m i n e d t o b e j u r i s d i c t i o n a l u n d e r S e c t i o n 40 4 o f t h e C l e a n W a t e r Ac t , t h e m i t i g a t i o n pl a n w i l l b e s u b j e c t t o t h e r e v i e w a n d ap p r o v a l o f t h e C o r p s a n d R e g i o n a l W a t e r Qu a l i t y C o n t r o l B o a r d ( R W Q C B ) . I f t h e po t e n t i a l s e a s o n a l w e t l a n d s a r e n o n - ju r i s d i c t i o n a l u n d e r S e c t i o n 4 0 4 , t h e mi t i g a t i o n p l a n w i l l b e s u b j e c t t o t h e r e v i e w an d a p p r o v a l o f t h e R W Q C B . Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 13 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation BI O - 2 Bi o l o g i c a l R e s o u r c e s . Ap p r o v a l a n d c o n s t r u c t i o n o f t h e pr o p o s e d p r o j e c t w o u l d i m p a c t C o n g d o n ’ s t a r p l a n t a n d ot h e r s p e c i a l - s t a t u s p l a n t s p e c i e s o n t h e s i t e . SM - B I O - 2 . F o c u s e d s u r v e y s f o r s p e c i a l - s t a t u s pl a n t s s h a l l b e c o n d u c t e d o n t h e s i t e c o n s i s t e n t wi t h t h e C a l i f o r n i a D e p a r t m e n t o f F i s h & Wi l d l i f e ’ s 2 0 0 9 P r o t o c o l s f o r S u r v e y i n g a n d Ev a l u a t i n g I m p a c t s t o S p e c i a l - S t a t u s P o p u l a t i o n s an d n a t u r a l C o m m u n i t i e s . P l a n t s u r v e y s s h a l l b e co n d u c t e d t h r o u g h o u t t h e b l o o m i n g p e r i o d th r o u g h o u t t h e b l o o m i n g p e r i o d o f t h o s e s p e c i a l - st a t u s f o r w h i c h s u i t a b l e h a b i t a t i s p r e s e n t . T w o or t h r e e s e p a r a t e s u r v e y s m a y b e r e q u i r e d t o co v e r t h e b l o o m i n g p e r i o d o f p l a n t s l i s t e d i n Ta b l e 4 . 4 - 1 . I f p o p u l a t i o n s / s t a n d s o f a s p e c i a l - st a t u s s p e c i e s a r e i d e n t i f i e d d u r i n g t h e s u r v e y s an d i m p a c t s c a n n o t b e a v o i d e d , c o m p e n s a t o r y mi t i g a t i o n s h a l l b e p r o v i d e d , s u c h a s t h e ac q u i s i t i o n o f o f f - s i t e m i t i g a t i o n a r e a s p r e s e n t l y su p p o r t i n g t h e s p e c i e s i n q u e s t i o n , p u r c h a s e o f cr e d i t s i n a m i t i g a t i o n ba n k t h a t i s a p p r o v e d t o se l l c r e d i t s f o r t h e a f f e c t ed s p e c i e s , o r p a y m e n t of i n - l i e u f e e s t o a p u b l i c a g e n c y o r c o n s e r v a t i o n or g a n i z a t i o n ( e . g . . a l o c a l l a n d t r u s t ) f o r t h e pr e s e r v a t i o n a n d m a n a g e m e n t o f e x i s t i n g po p u l a t i o n s . T h e l o c a t i o n o f m i t i g a t i o n s i t e s s h a l l be d e t e r m i n e d i n c o n s u l t a t i o n w i t h a n d s u b j e c t t o ap p r o v a l o f U S F i s h a n d W i l d l i f e S e r v i c e a n d / o r Ca l i f o r n i a D e p a r t m e n t o f F i s h & W i l d l i f e . I n t h e ca s e w h e r e s p e c i a l - s t a t u s p l a n t s a r e n e i t h e r fe d e r a l - o r s t a t e - l i s t e d , t h e l e a d a g e n c y s h a l l ap p r o v e t h e m i t i g a t i o n a p p r o a c h u s i n g t h e gu i d a n c e p r o v i d e d b y t h e E a s t e r n A l a m e d a Co u n t y C o n s e r v a t i o n S t r a t e g y i n c o n s u l t a t i o n wi t h t h e C i t y ’ s c o n s u l t i n g b i o l o g i s t . O f f - s i t e co m p e n s a t o r y s h a l l b e a c q u i r e d a t a m i n i m u m ac r e a g e r a t i o o f 1 : 1 ( a c q u i re d : i m p a c t e d ) . F o r o f f - si t e m i t i g a t i o n o p t i o n s , m e a s u r e s s h a l l b e im p l e m e n t e d ( i n c l u d i n g c o n t i n g e n c y m e a s u r e s ) pr o v i d i n g f o r t h e l o n g - t e r m p r o t e c t i o n o f t h e s e Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 14 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation sp e c i e s . BI O - 3 Bi o l o g i c a l R e s o u r c e s . T h e p r o p o s e d p r o j e c t c o u l d im p a c t t h e h a b i t a t f o r n e s t i n g o r w i n t e r i n g b u r r o w i n g ow l b y d i s t u r b i n g t h e e x i s t i n g g r o u n d s u r f a c e . SM - B I O - 3 . P r e c o n s t r u c t i o n s u r v e y s s h a l l b e co n d u c t e d f o r b u r r o w i n g o w l s p r i o r t o g r a d i n g o r co n s t r u c t i o n a c t i v i t i e s . T h e s e s u r v e y s s h o u l d co n f o r m t o t h e s u r v e y p r o t o c o l e s t a b l i s h e d i n t h e St a f f R e p o r t o n B u r r o w i n g O w l M i t i g a t i o n (C D F W 2 0 1 2 b ) . T h e C o n s e r v a t i o n S t r a t e g y de p i c t s t h e p r o j e c t s i t e a s b e i n g l o c a t e d i n Co n s e r v a t i o n Z o n e 2 , w h i c h s u p p o r t s 1 1 p e r c e n t of t h e C o n s e r v a t i o n S t r a t e g y ’ s s t u d y a r e a ’ s un p r o t e c t e d p o t e n t i a l h a b i t a t f o r b u r r o w i n g o w l ) . Bu r r o w i n g o w l s c o u l d n e s t o r w i n t e r i n t h e s i t e ’ s ap p r o x i m a t e 1 3 a c r e s o f r u d e r a l / d i s t u r b e d n o n - na t i v e g r a s s l a n d h a b i t a t a n d w i t h i n t h e s u i t a b l e gr a s s l a n d h a b i t a t a d j a c e n t t o t h e s i t e . T h e fo l l o w i n g m e a s u r e s a r e c o n s i s t e n t w i t h t h e pr o v i s i o n s o f t h e M i g r a t o r y B i r d T r e a t y A c t a n d th e C a l i f o r n i a D e p a r t m e n t o f F i s h & W i l d l i f e st a n d a r d s . a) N o m o r e t h a n 1 4 d a y s p r i o r t o a n y g r o u n d di s t u r b i n g a c t i v i t i e s , a q u a l i f i e d b i o l o g i s t sh a l l c o n d u c t a t a k e a v o i d a n c e s u r v e y f o r bu r r o w i n g o w l s . I f n o o w l s a r e f o u n d du r i n g t h i s f i r s t s u r v e y , a f i n a l s u r v e y w i l l be c o n d u c t e d w i t h i n 4 8 h o u r s p r i o r t o gr o u n d d i s t u r b a n c e t o c o n f i r m t h a t bu r r o w i n g o w l s a r e s t i l l a b s e n t . I f g r o u n d di s t u r b i n g a c t i v i t i e s a r e d e l a y e d o r su s p e n d e d fo r m o r e t h a n 1 4 d a y s a f t e r t h e in i t i a l t a k e a v o i d a n c e s u r v e y , t h e s i t e s h a l l be r e s u r v e y e d ( i n c l u d i n g t h e f i n a l s u r v e y wi t h i n 4 8 h o u r s o f d i s t u r b a n c e ) . A l l su r v e y s s h a l l b e c o n d u c t e d i n a c c o r d a n c e wi t h C a l i f o r n i a D e p a r t m e n t o f F i s h & Wi l d l i f e g u i d e l i n e s . b) I f b u r r o w i n g o w l s a r e f o u n d o n t h e s i t e du r i n g t h e s u r v e y s , m i t i g a t i o n s h a l l b e Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 15 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation im p l e m e n t e d i n a c c o r d a n c e w i t h a p p l i c a b l e Ca l i f o r n i a D e p a r t m e n t o f F i s h & W i l d l i f e st a n d a r d s . M o r e s p e c i f i c a l l y , i f t h e s u r v e y s id e n t i f y b r e e d i n g o r w i n t e r i n g b u r r o w i n g ow l s o n o r a d j a c e n t t o t h e s i t e , o c c u p i e d bu r r o w s c a n n o t b e d i s t u r b e d a n d s h a l l b e pr o v i d e d w i t h p r o t e c t i v e b u f f e r s . W h e r e av o i d a n c e i s n o t f e a s i b l e d u r i n g t h e n o n - br e e d i n g s e a s o n , a s i t e - s p e c i f i c e x c l u s i o n pl a n ( i . e . , a p l a n t h a t c o n s i d e r s t h e t y p e a n d ex t e n t o f t h e p r o p o s e d a c t i v i t y , t h e d u r a t i o n an d t i m i n g o f t h e a c t i v i t y , t h e s e n s i t i v i t y an d h a b i t u a t i o n o f t h e o w l s , a n d t h e di s s i m i l a r i t y o f t h e p r o p o s e d a c t i v i t y w i t h ba c k g r o u n d a c t i v i t i e s ) s h a l l b e im p l e m e n t e d t o e n c o u r a g e o w l s t o m o v e aw a y f r o m t h e w o r k a r e a p r i o r t o co n s t r u c t i o n a n d t o m i n i m i z e t h e p o t e n t i a l to a f f e c t t h e r e p r o d u c t i v e s u c c e s s o f t h e ow l s . T h e e x c l u s i o n p l a n s h a l l b e s u b j e c t t o Ca l i f o r n i a F i s h & W i l d l i f e a p p r o v a l a n d mo n i t o r i n g r e q u i r e m e n t s . C o m p e n s a t o r y mi t i g a t i o n c o u l d a l s o b e r e q u i r e d b y Ca l i f o r n i a F i s h & W i l d l i f e a s p a r t o f t h e ap p r o v a l o f a n e x c l u s i o n p l a n . M i t i g a t i o n ma y i n c l u d e t h e p e r m a n e n t p r o t e c t i o n o f ha b i t a t a t a n e a r b y o f f - s i t e l o c a t i o n ac c e p t a b l e t o t h e C a l i f o r n i a D e p a r t m e n t o f Fi s h & W i l d l i f e . BI O - 4 Bi o l o g i c a l R e s o u r c e s . C o n s t r u c t i o n o f t h e p r o p o s e d pr o j e c t c o u l d i m p a c t b r e e d i n g b i r d s o n t h e s i t e . SM - B I O - 4 . V e g e t a t i o n r e m o v a l a n d / o r i n i t i a l gr o u n d d i s t u r b a n c e o n t h e s i t e s h a l l o c c u r d u r i n g th e n o n - b r e e d i n g s e a s o n f r o m S e p t e m b e r 1 t o Ja n u a r y 3 1 . I f i n s t e a d t h e s e a c t i o n s w i l l o c c u r fr o m F e b r u a r y 1 t o A u g u s t 3 1 , t h e n a p r e - co n s t r u c t i o n b r e e d i n g b i r d s u r v e y s h a l l b e co n d u c t e d n o m o r e t h a n 1 4 d a y s p r i o r t o co n s t r u c t i o n . A n y a c t i v e n e s t s f o u n d s h a l l b e Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 16 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation pr o t e c t e d b y a m i n i m u m 5 0 - f o o t e x c l u s i o n bu f f e r . T h e b u f f e r s i z e m a y v a r y d e p e n d i n g o n bi r d s p e c i e s , t h e l o c a t i o n o f t h e n e s t , a n d o t h e r fa c t o r s . BI O - 5 Bi o l o g i c a l R e s o u r c e s . C o n s t r u c t i o n o f t h e p r o p o s e d pr o j e c t c o u l d i m p a c t s p e c i a l - s t a t u s b a t s t h a t c o u l d in h a b i t t h e s i t e , s p e c i f i c a l l y t h e r e m o v a l o f t h e e x i s t i n g bu i l d i n g . SM - B I O - 5 . T h e m a r k e t i n g b u i l d i n g s h a l l b e re m o v e d f r o m t h e p r e m i s e s d u r i n g S e p t e m b e r o r Oc t o b e r . P r e - c o n s t r u c t i o n s u r v e y s o f t h e ma r k e t i n g b u i l d i n g f o r b a t s s h a l l o c c u r n o m o r e th a n 3 0 d a y s b e f o r e i t s r e m o v a l . I f b a t s a r e fo u n d , a q u a l i f i e d b i o l o g i s t s h a l l d e v e l o p a n ap p r o p r i a t e r e l o c a t i o n p l a n c o n s i s t e n t w i t h U S Fi s h & W i l d l i f e , C a l i f o r n i a D e p a r t m e n t o f F i s h & W i l d l i f e a n d E A C C S s t a n d a r d s a n d p o l i c i e s . Le s s - t h a n - S i g n i f i c a n t NO I S E - 1 No i s e . Re s i d e n t i a l l a n d u s e s p r o p o s e d b y t h e p r o j e c t co u l d b e e x p o s e d t o e x t e r i o r n o i s e l e v e l s e x c e e d i n g 6 0 dB A C N E L a n d i n t e r i o r n o i s e l e v e l s e x c e e d i n g 4 5 d B A CN E L . SM - N O I S E - 1 . R e d u c e e x t e r i o r a n d i n t e r i o r no i s e l e v e l s i n n o i s e s e n s i t i v e a r e a s o f t h e p r o j e c t to m e e t C i t y s t a n d a r d s . T o m e e t C i t y n o i s e st a n d a r d s , t h e f o l l o w i n g m i t i g a t i o n s h a l l b e u s e d :  Lo c a t e n o i s e - s e n s i t i v e o u t d o o r u s e a r e a s aw a y f r o m I n t e r s t a t e 5 8 0 . E n s u r e t h a t a l l re s i d e n t s h a v e a c c e s s t o o u t d o o r u s e a r e a s th a t a c h i e v e e x t e r i o r n o i s e c r i t e r i a ( 6 0 d B A CN E L f o r r e s i d e n t i a l u s e s ) .  A s u i t a b l e f o r m o f f o r c e d - a i r m e c h a n i c a l ve n t i l a t i o n , a s d e t e r m i n e d b y t h e l o c a l bu i l d i n g o f f i c i a l , s h a l l b e p r o v i d e d f o r u n i t s th r o u g h o u t t h e s i t e , s o t h a t w i n d o w s c a n b e ke p t c l o s e d a t t h e o c c u p a n t ’ s d i s c r e t i o n t o co n t r o l i n t e r i o r n o i s e a n d a c h i e v e t h e i n t e r i o r no i s e s t a n d a r d s .  Fo r t h e f i r s t r o w o f b u i l d i n g s f a c i n g In t e r s t a t e 5 8 0 , t h e b u i l d i n g s s h a l l b e de s i g n e d t o h a v e s e a l e d w i n d o w s a n d n o ba l c o n i e s o n e l e v a t i o n s f a c i n g t h e f r e e w a y .  Fo r r e s i d e n t i a l u s e s , n o i s e i n s u l a t i o n f e a t u r e s sh a l l b e d e s i g n e d t o a c h i e v e t h e 4 5 d B A CN E L i n t e r i o r n o i s e s t a n d a r d . S o u n d r a t e d Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 17 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation wi n d o w s a n d d o o r s s h a l l b e p r o v i d e d t o ma i n t a i n i n t e r i o r n o i s e l e v e l s a t a c c e p t a b l e le v e l s . A d d i t i o n a l t r e a t m e n t s m a y i n c l u d e , bu t a r e n o t l i m i t e d t o , s o u n d r a t e d w a l l co n s t r u c t i o n , a c o u s t i c a l c a u l k i n g , i n s u l a t i o n , ac o u s t i c a l v e n t s , e t c . L a r g e w i n d o w s a n d do o r s s h o u l d b e o r i e n t e d a w a y f r o m t h e I - 58 0 w h e r e p o s s i b l e . B e d r o o m s s h o u l d b e lo c a t e d a w a y f r o m I - 5 8 0 .  Th e f i n a l s p e c i f i c a t i o n s f o r n o i s e i n s u l a t i o n tr e a t m e n t s s h a l l b e r e v i e w e d b y a q u a l i f i e d ac o u s t i c a l c o n s u l t a n t d u r i n g f i n a l d e s i g n o f th e p r o j e c t t o e n s u r e t h a t e x t e r i o r a n d in t e r i o r n o i s e l e v e l s o n s i t e a c h i e v e t h e 4 5 dB A C N E L i n t e r i o r n o i s e s t a n d a r d f o r re s i d e n t i a l u s e s a n d h o u r l y a v e r a g e n o i s e le v e l s t o 4 5 d B A L e q f o r c o m m e r c i a l u s e s . Re s u l t s o f t h e a n a l y s i s , i n c l u d i n g t h e de s c r i p t i o n o f t h e n e c e s s a r y i n t e r i o r a n d ex t e r i o r n o i s e c o n t r o l t r e a t m e n t s , s h a l l b e su b m i t t e d t o t h e C i t y a l o n g w i t h t h e b u i l d i n g pl a n s a n d s h a l l a p p r o v e d by t h e C i t y p r i o r t o is s u a n c e o f a b u i l d i n g p e r m i t .  Th e f i n a l d e s i g n a n d l o c a t i o n o f p r o j e c t me c h a n i c a l e q u i p m e n t s h al l b e r e v i e w e d b y a q u a l i f i e d a c o u s t i c a l c o n s u l t a n t t o c o n f i r m th a t o p e r a t i o n a l n o i s e l e v e l s w o u l d n o t ex c e e d 6 0 d B A C N E L a t e x t e r i o r p r o j e c t re s i d e n t i a l u s e s a n d w o u l d n o t e x c e e d 4 5 dB A C N E L i n s i d e t h e s e r e s i d e n c e s . I f ne e d e d , t h e f i n a l d e s i g n a n d l o c a t i o n o f me c h a n i c a l e q u i p m e n t s h al l b e m o d i f i e d t o co n f o r m w i t h n o i s e p a r a m e t e r s s e t f o r t h i n th i s a n a l y s i s .  A t r u c k d e l i v e r y p l a n s h a l l b e s u b m i t t e d t o th e C i t y f o r t h e c o m m e r c i a l p o r t i o n o f t h e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 18 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation pr o j e c t s i t e , w h i c h w o u l d i n c l u d e t h e pr o p o s e d h o u r s o f a l l o w a b l e d e l i v e r i e s a n d th e l o c a t i o n s a n d r o u t e s o f t h e d e l i v e r y tr u c k s o n t h e p r o j e c t s i t e . A q u a l i f i e d ac o u s t i c a l c o n s u l t a n t s h a l l r e v i e w t h e de l i v e r y p l a n t o e n s u r e t h a t i n t e r i o r a n d ex t e r i o r n o i s e l e v e l s o n s i t e a c h i e v e ac c e p t a b l e l e v e l s . T h e t r u c k d e l i v e r y p l a n an d a c o u s t i c a l c o n s u l t a n t r e p o r t s h a l l b e su b j e c t t o a p p r o v a l b y t h e C i t y p r i o r t o t h e is s u a n c e o f a c e r t i f i c a t e o f o c c u p a n c y f o r an y c o m m e r c i a l b u i l d i n g . Ai r Qu a l i t y SM - A Q - 1 . T h e p r o j e c t a p p l i c a n t s h a l l a d h e r e t o th e f o l l o w i n g d u s t c o n t r o l m e a s u r e s , w h i c h s h a l l re p l a c e t h o s e i n c l u d e d i n E D S P E I R M i t i g a t i o n Me a s u r e 3 . 1 1 / 1 . 0 : a) A l l e x p o s e d s u r f a c e s ( e . g . , p a r k i n g a r e a s , st a g i n g a r e a s , s o i l p i l e s , g r a d e d a r e a s , a n d un p a v e d a c c e s s r o a d s ) s h a l l b e w a t e r e d t w o ti m e s p e r d a y . b) A l l h a u l t r u c k s t r a n s p o r t i n g s o i l , s a n d , o r ot h e r l o o s e m a t e r i a l o f f - s i t e s h a l l b e co v e r e d . c) A l l v i s i b l e m u d o r d i r t t r a c k - o u t o n t o ad j a c e n t p u b l i c r o a d s s h a l l b e r e m o v e d u s i n g we t p o w e r v a c u u m s t r e e t s w e e p e r s a t l e a s t on c e p e r d a y . T h e u s e o f d r y p o w e r sw e e p i n g i s p r o h i b i t e d . d) A l l v e h i c l e s p e e d s o n u n p a v e d r o a d s s h a l l b e li m i t e d t o 1 5 m p h . e) A l l r o a d w a y s , d r i v e w a y s , a n d s i d e w a l k s t o be p a v e d s h a l l b e c o m p l e t e d a s s o o n a s po s s i b l e . B u i l d i n g p a d s s h a l l b e l a i d a s s o o n as p o s s i b l e a f t e r g r a d i n g u n l e s s s e e d i n g o r so i l b i n d e r s a r e u s e d . f) I d l i n g t i m e s s h a l l b e m i n i m i z e d e i t h e r b y sh u t t i n g e q u i p m e n t o f f w h e n n o t i n u s e o r Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 19 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation re d u c i n g t h e m a x i m u m i d l i n g t i m e t o 5 mi n u t e s ( a s r e q u i r e d b y t h e C a l i f o r n i a ai r b o r n e t o x i c s c o n t r o l m e a s u r e T i t l e 1 3 , Se c t i o n 2 4 8 5 o f C a l i f o r n i a C o d e o f Re g u l a t i o n s [ C C R ] ) . C l e a r s i g n a g e s h a l l b e pr o v i d e d f o r c o n s t r u c t i o n w o r k e r s a t a l l ac c e s s p o i n t s . g) A l l c o n s t r u c t i o n e q u i p m e n t s h a l l b e ma i n t a i n e d a n d p r o p e r l y t u n e d i n a c c o r d a n c e wi t h m a n u f a c t u r e r ’ s s p e c i f i c a t i o n s . A l l eq u i p m e n t s h a l l b e c h e c k e d b y a c e r t i f i e d me c h a n i c a n d d e t e r m i n e d t o b e r u n n i n g i n pr o p e r c o n d i t i o n p r i o r t o o p e r a t i o n . h) P o s t a p u b l i c l y v i s i b l e s i g n w i t h t h e te l e p h o n e n u m b e r a n d p e r s o n t o c o n t a c t a t th e L e a d A g e n c y r e g a r d i n g d u s t c o m p l a i n t s . Th i s p e r s o n s h a l l r e s p o n d a n d t a k e co r r e c t i v e a c t i o n w i t h i n 4 8 h o u r s . T h e A i r Di s t r i c t ’ s p h o n e n u m b e r s h a l l a l s o b e v i s i b l e to e n s u r e c o m p l i a n c e w i t h a p p l i c a b l e re g u l a t i o n s . AQ - 1 Ai r Q u a l i t y . T h e p r o j e c t w o u l d r e s u l t i n a c u m u l a t i v e l y co n s i d e r a b l e n e t i n cr e a s e o f c r i t e r i a p o l l u t a n t s f o r w h i c h th e p r o j e c t r e g i o n i s n o n - a t t a i n m e n t u n d e r a p p l i c a b l e Fe d e r a l o r S t a t e a m b i e n t a i r q u a l i t y s t a n d a r d s d u e t o em i s s i o n s o f N O X. SM - A Q - 2 . T h e p r o j e c t a p p l i c a n t s h a l l r e d u c e fu t u r e r e s i d e n t i a l a n d e m p l o y e e t r i p s t h r o u g h a Tr a f f i c D e m a n d M a n a g e m e n t ( T D M ) p r o g r a m ap p r o v e d b y t h e C i t y a n d i n c l u d i n g , b u t n o t li m i t e d t o , t h e f o l l o w i n g m e a s u r e s : a) A p p o i n t T r a n s p o r t a t i o n C o o r d i n a t o r t o ov e r s e e t h e T D M p r o g r a m d e v e l o p e d f o r t h e pr o j e c t i n c l u d i n g p r o g r a m d e v e l o p m e n t , in f o r m a t i o n d i s t r i b u t i o n a n d p r o g r a m im p l e m e n t a t i o n . b) P r o m o t e a n d d i s t r i b u t e h a r d c o p y in f o r m a t i o n q u a r t e r l y t o a l l e m p l o y e e s a n d re s i d e n t s r e g a r d i n g 5 1 1 , R i d e m a t c h , Gu a r a n t e e d R i d e H o m e P r o g r a m , Wh e e l s / L A V T A , A l t a m o n t C o r r i d o r Si g n i f i c a n t a n d U n a v o i d a b l e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 20 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation Ex p r e s s ( A C E ) , B A R T , s h u t t l e s t o r e g i o n a l tr a n s i t , a n d a n y c a r s h a r e p r o g r a m s . c) D i s t r i b u t e i n f o r m a t i o n q u a r t e r l y r e g a r d i n g ab o v e b y e m a i l b l a s t t o a l l e m p l o y e e s a n d re s i d e n t s . d) C o - s p o n s o r s u b a r e a t r a n s p o r t a t i o n f a i r o n c e a y e a r w i t h “ T h e V i l l a g e ” p r o p e r t y t o t h e no r t h a n d / o r o t h e r d e v e l o p m e n t s i n t h e E a s t Du b l i n a r e a . I n v i t e W h ee l s , 5 1 1 . o r g , a n d a t le a s t t w o o t h e r c o m m u t e a l t e r n a t i v e s e r v i c e pr o v i d e r s t o a t t e n d a n d d i s t r i b u t e c o m m u t e al t e r n a t i v e i n f o r m a t i o n . e) P r o v i d e b i c y c l e p a r k i n g f a c i l i t i e s f o r 2 0 pe r c e n t o f c o m m e r c i a l c a r s p a c e s o r a nu m b e r a p p r o v e d b y t h e C i t y b e y o n d t h e Ci t y ’ s b i c y c l e r a c k r e q u i r e m e n t . f) P r o v i d e s e c u r e d b i c y c l e p a r k i n g ( l o c k e r s o r ca g e s ) f o r e m p l o y e e s . g) J o i n C i t y C a r S h a r e a s a “ B i z P r i m e ” me m b e r a n d p a y f o r m e m b e r s h i p o f a mi n i m u m o f f i v e p e r c e n t e m p l o y e e s . h) I m p l e m e n t a B A R T s u b s i d y p r o g r a m t h a t wo u l d p r o v i d e B A R T t i c k e t s a t n o c o s t o r su b s i d i z e d r a t e t o a l l e m p l o y e e s . i) I m p l e m e n t a C o m m u t e r T a x B e n e f i t Pr o g r a m o r e q u i v a l e n t . U n d e r S e c t i o n 13 2 ( F ) o f f e d e r a l t a x c o d e , a n e m p l o y e r c a n of f e r i t s e m p l o y e e s u p t o $ 2 4 5 p e r m o n t h f o r qu a l i f i e d t r a n s i t , v a n p o o l o r p a r k i n g c o s t s . Or , a n e m p l o y e r m a y o f f e r $ 2 0 p e r m o n t h fo r b i c y c l i n g c o s t s . F u l l i n f o r m a t i o n i s av a i l a b l e a t : ht t p : / / r i d e s h a r e . 5 1 1 . o r g / r e w a r d s / t a x _ b e n e f i t s .a s p x j) P r o v i d e p r e f e r e n t i a l p a r k i n g f o r c a r p o o l s a n d Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 21 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation va n p o o l s a s p a r t o f o f f - s t r e e t p a r k i n g re q u i r e m e n t s . k) P r o v i d e s h a d i n g i n t h e p a r k i n g l o t , t o t h e ma x i m u m e x t e n t p o s s i b l e , t o r e d u c e ev a p o r a t i v e R O G e m i s s i o n s . AQ - 2 Ai r Q u a l i t y . Th e p r o j e c t w o u l d r e s u l t i n a v i o l a t i o n o f re g i o n a l a i r q u a l i t y s t a n d a r d a n d w o u l d c o n t r i b u t e su b s t a n t i a l l y t o a n e x i s t i n g o r p r o j e c t e d a i r q u a l i t y vi o l a t i o n . Se e S M - A Q - 2 Si g n i f i c a n t a n d U n a v o i d a b l e AQ - 3 Ai r Q u a l i t y . T h e p r o j e c t w o u l d c o n f l i c t w i t h t h e re g i o n a l C l e a n A i r P l a n . Se e S M - A Q - 2 Si g n i f i c a n t a n d U n a v o i d a b l e AQ - 4 Ai r Q u a l i t y . T h e p r o j e c t w o u l d e x p o s e s e n s i t i v e re c e p t o r s t o e x c e s s c a n c e r r i s k a n d P M 2. 5 c o n c e n t r a t i o n s th a t a r e a b o v e h e a l t h - b a s e d t h r e s h o l d s . SM - A Q - 3 . T h e p r o j e c t s h a l l i n c l u d e t h e fo l l o w i n g m e a s u r e s t o mi n i m i z e l o n g - t e r m t o x i c ai r c o n t a m i n a n t ( T A C ) e x p o s u r e f o r n e w re s i d e n c e s : a. E n s u r e t h a t n o r e s i d e n t i a l b u i l d i n g s w o u l d ha v e a f u l l y e a r o f o c c u p a n c y p r i o r t o 1/ 1 / 2 0 1 7 . b. D e s i g n b u i l d i n g s a n d s i t e t o l i m i t e x p o s u r e fr o m s o u r c e s o f T A C a n d f i n e p a r t i c u l a t e ma t t e r ( P M 2 . 5 ) e m i s s i o n s . T h e s i t e l a y o u t sh a l l l o c a t e w i n d o w s a n d a i r i n t a k e s a s f a r a s po s s i b l e f r o m I - 5 8 0 t r a f f i c l a n e s . A n y mo d i f i c a t i o n s t o t h e s i t e d e s i g n s h a l l in c o r p o r a t e b u f f e r s b e t w e e n r e s i d e n c e s a n d th e f r e e w a y . c. T o t h e g r e a t e s t d e g r e e p o s s i b l e , p l a n t ve g e t a t i o n a l o n g t h e p r o j e c t s i t e b o u n d a r y wi t h I - 5 8 0 t h a t i n c l u d e s t r e e s a n d s h r u b s t h a t pr o v i d e a d e n s e v e g e t a t i v e b a r r i e r . d. I n s t a l l a i r f i l t r a t i o n i n r e s i d e n t i a l b u i l d i n g s a t ro o f t o p l e v e l t h a t h a v e p r e d i c t e d c a n c e r ri s k s i n e x c e s s o f 1 0 i n o n e m i l l i o n o r P M 2. 5 co n c e n t r a t i o n s a b o v e 0 . 3 m i c r o g r a m s p e r cu b i c m e t e r ( µ g / m 3) a s s h o w n i n E x h i b i t Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 22 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation 4. 7 - 4 . T h e t y p e o f a i r f i l t r a t i o n d e v i c e s h a l l be a s s e t f o r t h i n s u b s e c t i o n e b e l o w . . T o en s u r e a d e q u a t e h e a l t h p r o t e c t i o n t o se n s i t i v e r e c e p t o r s , a v e n t i l a t i o n s y s t e m sh a l l m e e t t h e f o l l o w i n g m i n i m a l d e s i g n st a n d a r d s ( D e p a r t m e n t o f P u b l i c H e a l t h , Ci t y a n d C o u n t y o f S a n F r a n c i s c o , 2 0 0 8 ) :  At l e a s t o n e a i r e x c h a n g e ( s ) p e r h o u r o f fr e s h o u t s i d e f i l t e r e d a i r ;  At l e a s t f o u r a i r e x c h a n g e ( s ) p e r h o u r re c i r c u l a t i o n ; a n d  At l e a s t 0 . 2 5 a i r e x c h a n g e ( s ) p e r h o u r i n un f i l t e r e d i n f i l t r a t i o n . e. T h e t y p e o f M E R V - r a t e d f i l t r a t i o n r e q u i r e d to b e i n s t a l l e d a s p a r t o f t h e v e n t i l a t i o n sy s t e m i n t h e r e s i d e n t i a l b u i l d i n g s s h a l l b e as f o l l o w s : 1) M E R V 1 3 f i l t r a t i o n s h a l l b e i n s t a l l e d i n a re s i d e n t i a l b u i l d i n g p a r t i a l l y o r co m p l e t e d l o c a t e d i n a n a r e a w h e r e t h e ca n c e r r i s k i s 1 0 p e r o n e m i l l i o n o r gr e a t e r b u t l e s s t h a n o r e q u a l t o 2 2 p e r on e m i l l i o n a s s h o w n i n E x h i b i t 4 . 7 - 4 fo r u n m i t i g a t e d c a n c e r r i s k s . 2) M E R V 1 6 f i l t r a t i o n s h a l l b e i n s t a l l e d i n a re s i d e n t i a l b u i l d i n g p a r t i a l l y o r co m p l e t e d l o c a t e d i n a n a r e a w h e r e t h e ca n c e r r i s k i s g r e a t e r t h a n 2 2 p e r o n e mi l l i o n a n d l e s s t h a n 5 0 p e r o n e m i l l i o n as s h o w n i n E x h i b i t 4 . 7 - 4 f o r un m i t i g a t e d c a n c e r r i s k s . 3) M E R V 1 6 f i l t r a t i o n a n d s e a l e d , in o p e r a b l e w i n d o w s a n d n o b a l c o n i e s on b u i l d i n g e l e v a t i o n s f a c i n g I - 5 8 0 fr e e w a y ( M E R V 1 6 P l u s ) s h a l l b e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 23 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation in s t a l l e d i n a r e s i d e n t i a l b u i l d i n g pa r t i a l l y o r c o m p l e t e d l o c a t e d i n a n a r e a wh e r e t h e c a n c e r r i s k i s a g r e a t e r t h a n o r eq u a l t o 5 0 p e r o n e m i l l i o n a n d l e s s t h a n 62 . 5 p e r o n e m i l l i o n a s s h o w n i n Ex h i b i t 4 . 7 - 4 f o r u n m i t i g a t e d c a n c e r ri s k s . 4) I n a r e a s w h e r e t h e c a n c e r r i s k i s 6 2 . 5 p e r on e m i l l i o n o r g r e a t e r , r e s i d e n t i a l u n i t s sh a l l n o t b e b u i l t u n l e s s t h e d e v e l o p e r in c l u d e s s p e c i f i c m i t i g a t i o n m e a s u r e s th a t a r e a p p r o v e d b y a q u a l i f i e d a i r qu a l i t y c o n s u l t a n t a n d t h e C i t y t h a t re s u l t s i n a r e d u c t i o n o f t h e c a n c e r r i s k to b e l o w 1 0 p e r o n e m i l l i o n . f. A s p a r t o f i m p l e m e n t i n g t h i s m e a s u r e , a n on g o i n g m a i n t e n a n c e p l a n f o r t h e b u i l d i n g s ’ he a t i n g , v e n t i l a t i o n , a n d a i r c o n d i t i o n i n g (H V A C ) a i r f i l t r a t i o n s y s t e m s h a l l b e re q u i r e d . R e c o g n i z i n g t h a t e m i s s i o n s f r o m ai r p o l l u t i o n s o u r c e s a r e d e c r e a s i n g , t h e ma i n t e n a n c e p e r i o d s h a l l l a s t a s l o n g a s si g n i f i c a n t e x c e s s c a n c e r r i s k o r a n n u a l PM 2. 5 e x p o s u r e s a r e p r e d i c t e d . S u b s e q u e n t st u d i e s m a y b e c o n d u c t e d b y a n a i r q u a l i t y ex p e r t a p p r o v e d b y t h e C i t y t o i d e n t i f y t h e on g o i n g n e e d f o r t h e f i l t e r e d v e n t i l a t i o n sy s t e m s a s f u t u r e i n f o r m a t i o n b e c o m e s av a i l a b l e . g. E n s u r e t h a t t h e l e a s e a g r e e m e n t a n d o t h e r pr o p e r t y d o c u m e n t s ( 1 ) r e q u i r e c l e a n i n g , ma i n t e n a n c e , a n d m o n i t o r i n g o f t h e a f f e c t e d bu i l d i n g s f o r a i r f l o w l e a k s ; ( 2 ) i n c l u d e as s u r a n c e t h a t n e w o w n e r s a n d t e n a n t s a r e pr o v i d e d i n f o r m a t i o n o n t h e v e n t i l a t i o n sy s t e m ; a n d ( 3 ) i n c l u d e p r o v i s i o n s t h a t f e e s Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 24 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation as s o c i a t e d w i t h o w n i n g o r l e a s i n g a u n i t ( s ) in t h e b u i l d i n g i n c l u d e f u n d s f o r c l e a n i n g , ma i n t e n a n c e , m o n i t o r i n g , a n d r e p l a c e m e n t s of t h e f i l t e r s , a s n e e d e d . h. C o n s i d e r p h a s i n g d e v e l o p m e n t s l o c a t e d cl o s e s t t o I - 5 8 0 t o a v o i d s i g n i f i c a n t e x c e s s ca n c e r r i s k s a n d r e q u i r e d i n s t a l l a t i o n o f fi l t e r e d v e n t i l a t i o n s y s t e m s ( d e s c r i b e d ab o v e ) . N o t e t h a t n e w U n i t e d S t a t e s En v i r o n m e n t a l P r o t e c t i o n A g e n c y ( U . S . EP A ) e n g i n e s s t a n d a r d s c o m b i n e d w i t h Ca l i f o r n i a A i r R e s o u r c e s B o a r d ( C A R B ) ru l e s a n d r e g u l a t i o n s w i l l r e d u c e o n - r o a d em i s s i o n s o f d i e s e l p a r t i c u l a t e m a t t e r ( D P M ) an d P M 2 . 5 s u b s t a n t i a l l y , e s p e c i a l l y a f t e r 20 1 4 . i. R e q u i r e t h a t , p r i o r t o b u i l d i n g o c c u p a n c y , a n au t h o r i z e d a i r p o l l u t a n t c o n s u l t a n t v e r i f y t h e in s t a l l a t i o n o f a l l n e c e s s a r y m e a s u r e s t o re d u c e t o x i c a i r c o n t a m i n a n t ( T A C ) ex p o s u r e a s s e t f o r t h i n t h i s m i t i g a t i o n me a s u r e . AQ - 5 Ai r Q u a l i t y . T h e p r o j e c t w o u l d g e n e r a t e g r e e n h o u s e ga s e m i s s i o n s , b o t h d i r e c t l y a n d i n d i r e c t l y , t h a t w o u l d ha v e a s i g n i f i c a n t i m p a c t o n t h e e n v i r o n m e n t a n d w o u l d co n f l i c t w i t h a n a p p l i c a b l e p l a n , p o l i c y , o r r e g u l a t i o n ad o p t e d f o r t h e p u r p o s e o f r e d u c i n g t h e e m i s s i o n s o f gr e e n h o u s e g a s e s . SM - A Q - 4 . T h e f i n a l d e s i g n o f t h e p r o j e c t s h a l l in c l u d e a l l r e q u i r e m e n t s o f t h e C i t y C l i m a t e Ac t i o n P l a n , i n c l u d i n g p o l i c i e s A . 1 . 4 ( B i c y c l e Pa r k i n g R e q u i r e m e n t s ) , A . 1 . 5 ( S t r e e t s c a p e Ma s t e r P l a n ) , A . 1 . 8 ( G e n e r a l P l a n C o m m u n i t y De s i g n a n d S u s t a i n a b i l i t y E l e m e n t ) , A . 1 . 9 ( W o r k wi t h L A V T A t o I m p r o v e T r a n s i t ) , A . 2 . 1 ( G r e e n Bu i l d i n g O r d i n a n c e ) , A . 2 . 5 ( L E D S t r e e t l i g h t Sp e c i f i c a t i o n s ) , A . 3 . 1 ( C o n s t r u c t i o n a n d De m o l i t i o n D e b r i s O r d i n a n c e ) , A . 3 . 6 (C o m m e r c i a l R e c y c l i n g ) . I n a d d i t i o n , t h e p r o j e c t pr o p o n e n t i s e n c o u r a g e d t o p a r t i c i p a t e i n s u b s i d y pr o g r a m s s u c h a s C l i m a t e A c t i o n P l a n p o l i c e s A. 2 . 4 ( R e d u c e d S o l a r I n s t a l l a t i o n P e r m i t F e e ) Si g n i f i c a n t a n d U n a v o i d a b l e Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 25 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation an d A . 3 . 5 ( C o m m e r c i a l F o o d W a s t e C o l l e c t i o n Pr o g r a m ) , a n d n o n - s u b s i d y p r o g r a m s s u c h a s po l i c i e s A . 3 . 7 ( M u l t i - F a m i l y R e c y c l i n g ) , A . 3 . 8 (C u r b s i d e R e c y c l i n g ) , a n d A . 3 . 9 ( C u r b s i d e Or g a n i c s C o l l e c t i o n ) . I m p l e m e n t a t i o n o f t h e s e mi t i g a t i o n m e a s u r e w o u l d r e d u c e G H G em i s s i o n s , b u t n o t b e l o w t h e s i g n i f i c a n c e th r e s h o l d s . T h e p r o j e c t , a s a w h o l e , s h a l l a d o p t a wa t e r u s e r e d u c t i o n g o a l o f a t l e a s t 2 0 p e r c e n t . A wa t e r u s e r e d u c t i o n p l a n s h a l l b e d e v e l o p e d b y th e p r o j e c t a p p l i c a n t t h a t m a y i n c l u d e m e a s u r e s su c h a s t h e i n s t a l l a t i o n o f l o w - f l o w w a t e r f i x t u r e s in s h o w e r s a n d s i n k s , l o w - f l u s h t o i l e t s , a n d t h e us e o f w a t e r e f f i c i e n t l a n d s c a p i n g . T h e p r o j e c t ap p l i c a n t s h a l l i m p l e m e n t a s o l i d w a s t e r e c y c l i n g pr o g r a m t h r o u g h r e c y c l i n g a n d c o m p o s t i n g st r a t e g i e s , w h i c h r e s u l t s i n a p r o j e c t - w i d e s o l i d wa s t e d i v e r s i o n r a t e o f a t l e a s t 2 0 p e r c e n t . Fi n a l l y , t h e p r o j e c t s h a l l e x c e e d 2 0 0 8 T i t l e 2 4 Bu i l d i n g S t a n d a r d s ( w h i c h C a l E E M o d i s b a s e d on ) b y a t l e a s t 2 0 p e r c e n t i n t e r m s o f e n e r g y - ef f i c i e n c y . HA Z - 1 Ha z a r d s . T h e s i t e h a s b e e n r e m e d i a t e d f o r c o m m e r c i a l an d o t h e r n o n - r e s i d e n t i a l l a n d u s e s . A s a p a r t o f t h e s i t e ma n a g e m e n t t e r m s t h a t w e r e a p p r o v e d w h e n t h e re m e d i a t i o n o c c u r r e d i n 20 1 0 , t h e A l a m ed a C o u n t y De p a r t m e n t o f E n v i r o n m e n t a l H e a l t h ( A C D E H ) re q u i r e d t h a t i f a n y r e s i d e n t i a l o r o t h e r s i m i l a r l a n d u s e is p r o p o s e d a t t h e P r o p e r t y , t h e A C D E H m u s t b e no t i f i e d . A C D E H w i l l t h e n r e - e v a l u a t e t h e c a s e u p o n re c e i p t o f a p p r o v e d d e v e l o pm e n t / c o n s t r u c t i o n p l a n s . SM - H A Z - 1 . T h e A p p l i c a n t / D e v e l o p e r s h a l l no t i f y A C D E H o f t h e p r o p o s e d p r o j e c t a n d t h e in t e n t t o u t i l i z e t h e s i t e f o r r e s i d e n t i a l u s e s s o AC D E H c a n r e - e v a l u a t e t h e c a s e . If d i r e c t e d b y AC D E H , a P h a s e I I s i t e i n v e s t i g a t i o n o r s i t e he a l t h r i s k a s s e s s m e n t s h a l l b e c o m p l e t e d f o r po r t i o n s o f t h e s i t e a n t i c i p a t e d f o r r e s i d e n t i a l de v e l o p m e n t a n d e x c a v a t i o n p r i o r t o i s s u a n c e o f a g r a d i n g a n d / o r s i t e i m p r o v e m e n t p e r m i t . T h e si t e i n v e s t i g a t i o n s h a l l b e c o o r d i n a t e d w i t h t h e Al a m e d a C o u n t y D e p a r t m e n t o f E n v i r o n m e n t a l He a l t h . T h e i n v e s t i g a t i o n p l a n s h a l l i n c l u d e a de s c r i p t i o n o f t h e w o r k t o b e p e r f o r m e d , t h e la b o r a t o r y a n a l y t i c a l m e t h o d s t o b e u s e s a n d re q u i r e m e n t s f o r q u a l i t y c o n t r o l . I f a d d i t i o n a l Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 26 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation re m e d i a t i o n i s n e c e s s a r y , a r e m e d i a t i o n p l a n sh a l l b e p r e p a r e d a n d a p p r o v e d b y t h e A C D E H . Gr a d i n g o r e x c a v a t i o n o f a n y i d e n t i f i e d co n t a m i n a t e d r e s i d e n t i a l a r e a o n t h e s i t e s h a l l n o t oc c u r u n t i l A C D E H i s s u e s a c l o s u r e l e t t e r au t h o r i z i n g r e s i d e n t i a l u s e s o n t h e s i t e . T h e Ap p l i c a n t / D e v e l o p e r s h a l l p r o v i d e t h e C i t y w i t h do c u m e n t a t i o n t h a t t h e a b o v e a c t i o n s h a v e t a k e n pl a c e . T o p r o t e c t t h e h e a l t h a n d s a f e t y o f co n s t r u c t i o n w o r k e r s , H e a l t h a n d S a f e t y P l a n t h a t me e t s t h e f e d e r a l O c c u p a t i o n a l S a f e t y a n d H e a l t h Ad m i n i s t r a t i o n r e q u i r e m e n t s s h a l l b e p r e p a r e d an d i m p l e m e n t e d i f a d d i t i o n a l r e m e d i a t i o n i s re q u i r e d . HA Z - 2 Ha z a r d s . If r e q u i r e d , c o n s t r u c t i o n d e w a t e r i n g a c t i v i t i e s co u l d r e l e a s e i d e n t i f i e d a c c u m u l a t i o n s o f r e s i d u a l hy d r o c a r b o n s , s o l v e n t s , a n d o t h e r c o n t a m i n a n t s i n t o t h e en v i r o n m e n t , p o s s i b l y e x p o s i n g c o n s t r u c t i o n w o r k e r s , an d s u r r o u n d i n g r e s i d e n t s a n d v i s i t o r s d u r i n g co n s t r u c t i o n . SM - H A Z - 2 . I f c o n s t r u c t i o n d e w a t e r i n g i s ne c e s s a r y , a c o n s t r u c t i o n d e w a t e r i n g p l a n s h a l l be p r e p a r e d a n d s u b m i t t e d w i t h a d e w a t e r i n g pe r m i t a p p l i c a t i o n . R e u s e o f g r o u n d w a t e r a s a n on - s i t e d u s t p a l l i a t i v e o r f o r s o i l c o m p a c t i o n i s ac c e p t a b l e i f r e q u i s i t e t e s t i n g a n d c o m p a r i s o n t o CA L - E P A s c r e e n i n g t h r e s h o l d s i n d i c a t e t h a t t h e gr o u n d w a t e r i s s u i t a b l e f o r r e u s e . I f r e u s e i s n o t po s s i b l e , c o n t a m i n a t e d wa t e r s h a l l b e s a f e l y re m o v e d t o a n a p p r o v e d s i t e . G r o u n d w a t e r re m o v e d d u r i n g c o n s t r u c t i o n d e w a t e r i n g s h a l l b e tr e a t e d t o t h e e x t e n t r e q u i r e d b y t h e p e r m i t ag e n c y p r i o r t o d i s c h a rg e a n d t h e a p p r o p r i a t e pe r m i t s h a l l b e o b t a i n e d f r o m t h e R e g i o n a l W a t e r Qu a l i t y C o n t r o l B o a r d ( R W Q C B ) , D u b l i n S a n Ra m o n S e r v i c e s D i s t r i c t , o r o t h e r a g e n c y w i t h ju r i s d i c t i o n , i f t h e w a t e r i s t o b e d i s c h a r g e d i n t o a st o r m o r s a n i t a r y s e w e r s y s t e m . Le s s - t h a n - S i g n i f i c a n t HA Z - 3 Ha z a r d s . De m o l i t i o n a c t i v i t i e s c o u l d r e l e a s e si g n i f i c a n t q u a n t i t i e s o f l e a d b a s e d p a i n t a n d a s b e s t o s co n t a i n i n g m a t e r i a l a n d o t h e r c o n t a m i n a n t s i n t o t h e en v i r o n m e n t , p o s s i b l y e x p o s i n g c o n s t r u c t i o n w o r k e r s , an d s u r r o u n d i n g r e s i d e n t s a n d v i s i t o r s d u r i n g SM - H A Z - 3 . Pr i o r t o i s s u a n c e o f a d e m o l i t i o n pe r m i t f o r t h e e x i s t i n g o n - s i t e b u i l d i n g , t e s t i n g sh a l l b e p e r f o r m e d b y a q u a l i f i e d a n d l i c e n s e d en v i r o n m e n t a l p r o f e s s i o n a l t o d e t e r m i n e t h e pr e s e n t o f s i g n i f i c a n t q u a n t i t i e s o f l e a d b a s e d Le s s - t h a n - S i g n i f i c a n t Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 27 Im p a c t T o p i c / S u p p l e m e n t a l I m p a c t S u p p l e m e n t a l M i t i g a t i o n M e a s u r e Ne t S u p p l e m e n t a l I m p a c t A f t e r Mitigation co n s t r u c t i o n . pa i n t a n d a s b e s t o s c o n t a i n i n g m a t e r i a l . I f de t e c t e d , s u c h m a t e r i a l s h a l l b e r e m o v e d b y a qu a l i f i e d c o n t r a c t o r a n d d i s p o s e d o f i n a n ap p r o v e d d i s p o s a l f a c i l i t y . N e c e s s a r y p e r m i t s sh a l l b e o b t a i n e d f r o m a p p r o p r i a t e r e g u l a t o r y ag e n c i e s p r i o r t o r e m e d i a t i o n . The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 28 2.0 INTRODUCTION 2.1 EIR Requirement This Environmental Impact Report supplements the earlier Environmental Impact Report prepared to address the impacts of the Eastern Dublin General Plan Amendment and Specific Plan. The Environmental Impact Report for the Eastern Dublin General Plan Amendment and Specific Plan was adopted by the City of Dublin on May 10, 1993 by Resolutions No. 51-93 and 53-93 and included approximately 6,920 acres of land for the General Plan Amendment (GPA) and 3,328 acres of land for the Specific Plan within the GPA area generally bounded by the I-580 freeway to the south, the Alameda County/Contra Costa County line to the north, Parks Reserve Forces Training Area (Parks RFTA) to the west and the ridgeline between Collier and Doolan Canyon to the east. This Environmental Impact Report is hereafter referred to as the Eastern Dublin EIR. The State Clearinghouse Number (SCH) for this EIR is 91103064. The City Council Resolutions related to the Eastern Dublin EIR are included as Appendix 8.4. A Supplemental Environmental Impact Report (SEIR) was prepared for a proposed IKEA furniture store on the site and associated development in 2003 (SCH #2003092076). The SEIR analyzed a General Plan and Eastern Dublin Specific Plan Amendment and related applications to allow the development of a 317,000 square foot IKEA store on the westerly portion of the site and a 137,000 square foot separate “lifestyle” retail center on the eastern portion of the site. The IKEA project was never built and new entitlements are being sought for the property. Consequently, as required by CEQA, the City has prepared and circulated a Notice of Preparation (NOP) for this Draft Supplement EIR to interested public and private parties. A copy of the NOP is included as Appendix 8.2 and responses to the NOP are included in Appendix 8.3. 2.2 Scope of Supplemental EIR Once an EIR is certified for a project, CEQA prohibits Lead Agencies from preparing a supplemental or subsequent EIR except under specific circumstances. According to CEQA Guidelines Section 15162, additional EIR-level review may be required only when substantial changes to the project would cause new or substantially increased significant effects, or when substantial changes in circumstances would result in new or substantially increased significant effects, or when substantial new information shows the project would cause new or substantially increased significant effects, or shows that previously infeasible mitigation measures would now be feasible but the project proponent declines to adopt them. As reflected in the Initial Study (Appendix 8.1), the proposed project (“The Green” Mixed Use project) is a modification to Campus Office development as analyzed in the Eastern Dublin EIR and the proposed General Commercial development as analyzed in the IKEA SEIR. Many of the impacts are similar to the impacts disclosed and analyzed in the Eastern Dublin EIR and the IKEA SEIR, although new and/or more intensive environmental impacts are also analyzed in the document. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 29 The Green project Initial Study identifies impacts to the categories of air quality and greenhouse gas emissions, biological resources, noise, public services, recreation, population and housing, utilities and services and transportation for further review in a Supplemental EIR. After completion of the Initial Study, the topic of hazards and hazardous materials was also found to be potentially significant and has been analyzed in this document. This DSEIR describes the degree to which the project’s potential impacts to these environmental categories were adequately addressed in the previously certified Eastern Dublin EIR. It further describes the type and extent of potential significant impacts affecting the project site beyond those analyzed in previous EIRs. Where supplemental significant impacts are identified, supplemental mitigation measures are proposed to reduce the impacts to a less-than-significant level to the extent feasible. CEQA requires that an EIR identify a reasonable range of alternatives, which was done in the Eastern Dublin EIR. One of these alternatives was adopted in modified form in the 1993 approvals. However, to address the potential for new and/or substantially intensified significant impacts on the project site, this revised DSEIR identifies additional alternatives for the project site that could avoid or potentially lessen identified impacts. The Eastern Dublin EIR and IKEA SEIR are available for review at the City of Dublin Community Development Department, 100 Civic Plaza, Dublin, CA 94568. 2.3 Legal Basis for Supplemental EIR Based on the previous EIR analysis and CEQA Guidelines Sections 15162 and 15163, the City has determined that a Supplemental EIR should be prepared for this project rather than a Subsequent EIR. Subsequent and Supplemental EIRs are both similar in procedural and substantive respects. Both types of EIRs build on a previously certified EIR. Both types of EIRs analyze potentially significant changes to a project and/or environmental circumstances when those changes would result in a new significant impact or would substantially increase the severity of previously identified impacts. Both types of EIRs are circulated by themselves, without the previously certified EIR. With the above similarities, the choice between a Subsequent and Supplemental EIR is a matter of the degree of additions or modifications to the previous EIR needed to analyze the new or substantially increased significant impacts. Neither is a “new” EIR; both types of EIRs analyze the substantial changes from the previous analysis. Based on the Initial Study prepared for the project, the City has determined that a Supplemental EIR is appropriate for the following reasons: 1. The project includes a proposal to change the land use on the site from General Commercial to Mixed–Use, which allows a combination of residential and non- residential uses. The overall type and urban character of land uses on the project site would be similar to the approved General Plan and Eastern Dublin Specific Plan. 2. Proposed additions or modifications needed to update the previous EIR do not require a full re-analysis of a particular impact. 3. The proposed project includes actions identified in the previously certified EIR as implementing actions of the Eastern Dublin development program. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 30 For the above reasons, the City has determined that the current project does not raise new policy issues as to the type, location, direction or extent of growth. Further, the nature of the potential changes identified in the project Initial Study generally requires updating or refinement of the previous EIR analysis, rather than a full re-analysis. Irrespective of the label, and consistent with both Subsequent and Supplemental EIR provisions of CEQA Guidelines Section 15162 and 15163, the City will not approve the project without first certifying an EIR which comprehensively addresses the potential for significant environmental impacts of the current project beyond those addressed in previous EIRs. 2.4 Organization of Draft Supplemental EIR The Draft Supplemental EIR (“DSEIR”) supplements the Program EIR and Addenda certified by the City of Dublin for the Eastern Dublin General Plan Amendment and Specific Plan (SCH #911003064, “Eastern Dublin EIR, or “EDEIR,” incorporated herein by reference). It also supplements the Previous IKEA Supplemental EIR (SCH #2003092076), prepared for a previous development project on this site that was never constructed. This document is organized as follows: • Chapter 1: Summary of impacts and mitigation measures. This is presented in tabular form. • Chapter 2: Introduction. Chapter 2 describes the organization of the DSEIR. • Chapter 3: Project Description. This chapter describes the proposed project, project location and setting. Project Objectives are also described as well as future approvals required to implement the proposed project. • Chapter 4: Environmental Setting, Impacts and Mitigation Measures. Chapter 4 includes the impact and mitigation analysis for the project. Each environmental topic includes existing conditions (the setting); potential supplemental environmental impacts and their level of significance; and mitigation measures recommended to reduce identified significant impacts. • Chapter 5: Alternatives. This chapter addresses alternatives to the proposed project and a discussion of an environmentally superior alternative. • Chapter 6: References. Chapter 6 includes references used in the preparation of the DSEIR. • Chapter 7: Report Authors. Chapter 7 lists the authors of the EIR and organizations and persons consulted as part of the environmental analysis. • Chapter 8: Appendices. Contained in the Appendices are the Initial Study, Notice of Preparation (NOP), responses to the NOP, Resolutions No. 51-93 and 53-93 approving the Eastern Dublin Project EIR, including mitigation findings, overriding considerations The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 31 and mitigation monitoring program; and copies of the supplemental air quality analysis, biological analysis, noise analysis and traffic analysis. 2.5 DSEIR Review Process The DSEIR will be circulated for public review and comment pursuant to CEQA. Written responses will be prepared to all relevant comments on environmental issues received during the public review period. Public comments and responses will be compiled in a Final Supplemental EIR (FSEIR). After certification, the City will consider the requested project approvals and make appropriate findings based on the certified SEIR. 2.6 Topics Not Addressed in this DSEIR Based on the Initial Study prepared by the City of Dublin (see Appendix 8.1), the following topics will not be further analyzed in this DSEIR. They are listed with the main heading and specific issue area. • Aesthetics-impacts to scenic vistas, substantial damage to scenic resources and substantial degradation of the visual character of the project site. • Agricultural and Forestry Resources-impacts to prime farmland, agricultural zoning, Williamson Act contracts and forestlands. • Cultural Resources-impacts to significant historical resources • Geology and Soils-seismic impacts, landslides, erosion of topsoil other soil and geologic hazards. • Hydrology and Water Quality- violation of water quality and waste discharge standards, impacts to groundwater resources, flooding, drainage and water quality impacts. • Land Use-division of an existing community, conflicts with land use policies or plans, conflicts with habitat conservation plan. • Mineral Resources. • Noise-Impacts related to groundborne vibration and airport noise. • Public Services-impacts to fire, police, solid waste and other utilities. • Transportation and Traffic-changes to air traffic patterns, impacts related to design hazards, emergency access impacts. • Utilities and Service Systems- impacts related to drainage and solid waste facilities and systems. 2.7 Future Environmental Analysis This SEIR contains a project-level environmental review and is intended to serve as the CEQA review for future land use entitlements, including Stage 1 and 2 PD-Planned Development rezonings, any future Conditional Use Permits, Site Development Review, Parcel or Tentative Maps, and any other permit-level entitlements that may be required for individual development projects on the project site. Further CEQA environmental review is not anticipated to be required for future implementing projects. However, the determination of whether further CEQA environmental review, if any, is required for implementing discretionary approvals will be determined in accordance with the standards under CEQA and the CEQA Guidelines. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 32 3.0 PROJECT DESCRIPTION 3.1 Project Location The project site contains 27.5 acres of land and is located in the Eastern Dublin Planning Area of the City of Dublin. More specifically, the site is located on the south side of Martinelli Way between Hacienda Drive to the east and Arnold Drive to the west. The I-580 freeway forms the southern boundary of the site. The Alameda County Assessor’s Parcel Numbers are 986-0033- 004-00, 986-0033-005-02, and 986-0033-006-00. The project site is currently owned by Stockbridge BHV Emerald Place Land Company LLC. The Dublin General Plan and the Eastern Dublin Specific Plan has identified the project area for future General Commercial (GC) development. Exhibit 3.1 depicts the regional setting of Dublin and Exhibit 3.2 shows the location of the project area in context with nearby features, including nearby roadways and adjacent land uses. 3.2 Project Area Features Site history and existing land uses. Historically, the project site was formerly occupied by a portion of the U.S. Army’s Camp Parks Reserve Forces Training Area (Parks RFTA). This portion of the Training Area was closed and property ownership was transferred to Alameda County in the late 1960’s. The site is vacant and contains no major stands of trees, rock outcroppings or other significant natural features. Existing ground cover is primarily natural and introduced grass and other ruderal plant material. Although the site is generally flat, there is some topographic relief, likely as a result of previous land uses. The site does contain one small modular office building, currently vacant, that was used as the marketing office for a previous development proposal on the site. It will be removed prior to site development. Adjacent land uses. Properties to the west and north of the project site are vacant, but are planned for urban uses in the Dublin General Plan and Eastern Dublin Specific Plan. The Hacienda Crossings commercial center exists east of the project site. The I-580 freeway forms the southern boundary of the site. Site topography. The topography of the site is generally flat. Small mounds of fill material have been deposited on the site. 3.3 Prior Planning Approvals Eastern Dublin General Plan Amendment. In 1993, the City Council approved the Eastern Dublin General Plan Amendment and Specific Plan (hereafter, “Eastern Dublin project”). The approved project was a modified version of the original General Plan Amendment (hereafter, “GPA”) for a 6,920-acre planning area generally known as Eastern Dublin. The original GPA proposed to change commercial land use designations on County property in the southwest portion of the GPA area and agriculture/open space designations elsewhere in the planning area to a range of urban uses, as shown on Figure 2-E of the Eastern Dublin Draft EIR. Within the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 33 nearly 7,000 acre planning area, a new Eastern Dublin Specific Plan proposed land use policy at a greater level of detail in order to “bridge” general plan policy and individual development projects. Intended for both policy and regulatory use, the Specific Plan addressed 3,328 acres, supplementing the GPA with more detailed land use designations, policies, programs and regulations. (Eastern Dublin Draft EIR, hereafter, “Eastern Dublin EIR.”) The GPA planning area was located east of the City of Dublin. The planning area is characterized by a relatively flat plain along I-580, which gives way to rolling foothills and increasingly steep slopes to the northeast. Apart from facilities on County property in the southwest portion of the planning area (former Santa Rita Rehabilitation Center, U.S. Naval Hospital), the Eastern Dublin project area consisted primarily of open grasslands used for grazing and dry farming, and scattered residences. (Eastern Dublin EIR, p. 2-3.) The original GPA land use plan proposed to replace the undeveloped planning area with a mixed-use urban community. The project concept is set forth in the following excerpt from the Eastern Dublin EIR. Residential and employment-generating uses will be balanced to enable residents to live near work. Employment-generating uses include retail, service, office, governmental, research and development (“R & D”), and light industrial. Residential designation [sic] range from Rural Residential to High Density multi-family. Higher density housing has been located near the future BART station and along a key transit corridor. Higher densities have also been located close to commercial centers where the concentration of population will contribute to that center’s social and economic vitality. The project provides a full complement of regional office and retail land uses located near freeway interchanges, local-serving commercial centers are envisioned as pedestrian- and transit-oriented mixed-use concentrations which include retail, service, office, and residential uses, and are carefully integrated with surrounding residential neighborhoods. Open space is a major component of the project’s land use plan, giving form and character to the urban development pattern. The open space concept envisions a community ringed by undeveloped ridgelines. Urban and open space areas will be linked by an open space network structured along enhanced stream corridors. The circulation concept calls for an integrated, multi-modal system that reduces potential traffic impacts by providing area residents with choices for a preferred mode of transportation. (DEIR pp. 2-4, Eastern Dublin Responses to Comments, hereafter, “FEIR” p. 66.) At build-out, the GPA planning area was projected to provide 17,970 new residences, including 2,672 acres designated for Rural Residential with a 100-acre minimum parcel size. Approximately 10.6 million square feet of new commercial space, 25 parks on 287 acres, 571 acres of designated open space, and 12 new schools were also planned, all on 6,920 acres of land. (Eastern Dublin EIR, p. 2-7.) Build-out was expected to occur over a 20 – 30 year period from the start of construction. (Eastern Dublin EIR, p. 2-6, Eastern Dublin Final EIR p. 8.) The major policies of the GPA are summarized on pages 2-9 -10 of the Eastern Dublin EIR. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 34 Exhibit 3.5 depicts the project area in relation to the current General Plan land use map and Eastern Dublin Specific Plan (EDSP). Eastern Dublin Specific Plan. The Eastern Dublin Specific Plan addresses 3,301 acres in the western portion of the GPA planning area. Seventy percent of the GPA residential development and 94% of the new commercial space was planned for in the Specific Plan area. (Eastern Dublin EIR, p. 2-8.) The land use plan calls for compact villages with residential and neighborhood serving uses. Employment-generating commercial uses are provided along arterials with transit access. (Id.) The major policies of the Specific Plan are set forth on pages 2-10 to 2-14 of the Eastern Dublin EIR. Eastern Dublin EIR. The City of Dublin prepared a Program EIR for the Eastern Dublin project based on the original 6,920 acre GPA planning area and land use designations, and 3,301 acre Specific Plan area, both as described above. (SCH # 91103064.) The EIR also identifies a third component of Project Implementation. (Eastern Dublin EIR, p. 2-4.) This component includes “procedural steps … to be undertaken for full implementation of the [GPA and Specific Plan] Project; Alameda County Local Agency Formation Commission (LAFCO) determinations on annexation to the City of Dublin and the Dublin San Ramon Services District (DSRSD), detachment from the Livermore Area Recreation and Park Department (LARPD), and sphere-of- influence boundary changes; prezoning, and review and approval of specific development projects.” (Id.) The City initiated the Eastern Dublin project in 1988 after several separate development projects were proposed for the area. The goal of the project was to provide comprehensive planning for development types, locations and patterns in Eastern Dublin, which would be implemented through future individual development projects. As noted in the Eastern Dublin EIR statement of project objectives, one of the objectives of the project was to preserve visually-sensitive and biologically-sensitive habitat areas, encourage development patterns that support transit on local and regional levels, and maintain balanced employment and housing opportunities to reduce traffic congestion and air pollution. (Eastern Dublin EIR, p. 2-5.) The EIR analyzes the potential environmental effects of adopting and implementing the GPA and Specific Plan project. The EIR also analyzes the cumulative effects of the Eastern Dublin project, that is, the project “within the context of regional development.” (DEIR p. 5.0-1.) As required by CEQA, the Eastern Dublin EIR includes a list of ongoing and future development projects that, together with the Eastern Dublin project, might “compound subregional (i.e. Tri- Valley) environmental problems.” (Id.) Reflecting a surge of development interest at the time, the cumulative projects in Dublin alone included 924 units, plus another 3,133 units on 3,140 acres in Western Dublin, and the potential intensification of uses at Parks RFTA. The Dougherty Valley Specific Plan projected 11,000 units; while the City of Livermore was considering the North Livermore General Plan Amendment with a buildout potential between 3,713 and 16,513 units. The various cumulative projects also proposed several million square feet of non- residential development. The list of cumulative projects from the Eastern Dublin EIR is shown on Figure 5-A of that DEIR. Virtually all of the potential new development areas in the list of cumulative projects was undeveloped land, primarily in agriculture and/or open space uses, as The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 35 evidenced by the aerial photographs which form the base maps for Figures 2-B and 2-C of the Eastern Dublin DEIR. As would be expected for a major general plan level project during a time of major development activity, the Eastern Dublin EIR identified many potential significant impacts on both a project (GPA and Specific Plan) level and a cumulative (regional) level. Mitigation measures were proposed and adopted for most of the significant impacts to reduce them to less than significant. The City of Dublin would implement some of the mitigation measures directly; examples include but are not limited to adopting a stream corridor restoration program, designating substantial areas within the project area as Open Space or Rural Residential where low density development will also provide foraging habitat, and continuing to participate in regional studies of future transportation requirements, improvements and funding. Other mitigations would be implemented through conditions or development standards for future development projects; examples include but are not limited to proportionate-share contributions to roadway improvements and transit service extensions. Many of the mitigation measures also included policies and action programs identified in the Eastern Dublin GPA and Specific Plan documents. Even with mitigation, however, some of the identified significant impacts could not be reduced to a less than significant level. Several of these impacts were cumulative level impacts, such as loss of agriculture and open space, I-580 and other regional traffic impacts, and air quality impacts. As required by CEQA, the Draft EIR identified project alternatives, including No Project and No Development alternatives, a Reduced Land Use Intensities alternative, and a Reduced Planning Area alternative, and analyzed whether the alternatives would avoid any of the otherwise unavoidable impacts. As further discussed below, the City Council adopted a modified version of the Reduced Planning Area alternative after certifying the EIR as adequate and in compliance with CEQA on May 10, 1993. (Resolution 51-93.) The City Council also certified an Addendum dated May 4, 1994 which assessed the modifications to the Reduced Planning Area alternative and concluded that this alternative “will have no environmental impacts not addressed in the Draft Environmental Impact Report for the Eastern Dublin General Plan Amendment and Specific Plan.” (May 4, 1993 Addendum, p. 1.) The Addendum further concluded that no subsequent or supplemental EIR was required under CEQA Guidelines section 15162 or 15163 for approval of the modified alternative. A second Addendum was later prepared. Dated August 22, 1994, the second Addendum updated plans for providing sewer services to Eastern Dublin. The May 10, 1993 certified EIR, the May 4, 1993 Addendum and the August 22, 1994 Addendum are collectively referred to hereafter as the Eastern Dublin EIR, or the “EDEIR” and are incorporated herein by reference. IKEA Project Supplemental EIR (State Clearinghouse #2003092076). A Supplemental Environmental Impact Report for proposed development of an IKEA store and ancillary commercial uses was certified by the City Council on March 16, 2004 by Resolution No. 44-04. This document will be referred to as the "IKEA SEIR." It evaluated the following impacts:  Air Quality;  Biological Resources; and  Transportation and Circulation. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 36 The City adopted a Statement of Overriding Considerations (City Council Resolution No. 44-04) for the following impacts:  Excessive levels of ozone precursors above regulatory thresholds on a project and cumulative basis,  Excessive levels of carbon monoxide emissions above regulatory thresholds,  Increase of project traffic on local freeways on a cumulative basis. A copy of City Council Resolution No. 44-04 is contained in Appendix 8.5 of this SEIR. 3.4 Project Applications Overview. The proposed project would involve constructing a mixed-use commercial and residential development project on the site that would include up to 40,000 gross square feet of retail and restaurant floor area and 400 dwelling units. The conceptual site plan is shown on Exhibit 3.3. The project would include grading of the site, construction of all commercial and residential buildings, installation of utilities and services, placement of landscaping and placement of identification signs. A number of land use approvals are required to be granted by the City of Dublin in order to construct The Green project, including amendments to the Dublin General Plan and Eastern Dublin Specific Plan. These are described below. A portion of the project also includes amending the Dublin General Plan and the Eastern Dublin Specific Plan to change the land use designation from General Commercial to Mixed Use, which allows a combination of Medium density (6.1-14.0 units/acre) to Medium-High density (14.1- 25.0 units/acre) residential uses and at least one non-residential use such as office or retail. Proposed land uses. Proposed uses would include a mix of residential and commercial uses. Proposed commercial uses would include up to 5,000 square feet of retail space and up to 35,000 square feet of restaurant space. Specific tenants have not yet been identified but future uses would be consistent with the Dublin General Plan, Eastern Dublin Specific Plan and appropriate site zoning. Proposed residential uses would include up to 400 condominium and townhome dwellings in buildings clustered throughout the project site. The proposed project also includes a private open space area to serve the residential neighborhood and a proposed trail to connect the project site to points west. Proposed retail/restaurant buildings would be sited facing a central landscaped plaza area, “The Green,” extending in a north-south direction from Martinelli Way to a point approximately in the center of the site. Restaurant buildings would be located facing The Green plaza area as well as several pad buildings along Martinelli Way. The final design, number and location of the retail and restaurant buildings may change depending on market demand, but the overall amount of commercial development would remain The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 37 at 40,000 gross square feet. The final design, number, and precise location of residential uses may change slightly to respond to market conditions, but the residential uses would be located around the retail/residential buildings as shown on Exhibit 3.3 and would not exceed 400 units on the project site. On-site resident and guest parking would be provided for both retail and residential uses. Key features of the project would be a central landscaped plaza surrounded by retail and restaurant uses. Plaza and open space areas would comprise approximately 2.25 acres of land. Building design features. It is anticipated that the commercial buildings within the project area will be a combination of one and two story construction. The residential buildings generally have 6-12 units per building and are three to four stories tall (up to 50 feet maximum). The architectural design of buildings, use of materials and exterior colors will be reviewed and approved by the City of Dublin through the Site Development Review (SDR) process. Circulation and access. Vehicular access is proposed to be provided into and out of the site from two adjacent public roadways, as follows: • Martinelli Way: A main signalized full entry would be provided along Martinelli Way in the approximate center of the site. This drive would mirror a main entry for the approved Village at Dublin commercial center to the north (now referred to as “Persimmon Place”). A secondary limited right-turn in and out would be constructed east of the main entry along Martinelli Way. • Arnold Drive: One restricted right-turn in and out driveway would be provided to and from this street, located on the west side of the project site. No vehicular access would be provided onto Hacienda Drive and access is precluded along the I- 580 freeway. Interior vehicular circulation is proposed to be provided by a major east-west drive, as shown on Exhibit 3.4 along with a number of smaller driveways within the site that would serve residential buildings. Pedestrian connections would be made to the Eastern Dublin/Pleasanton BART station located west of the site and to the existing Hacienda Crossings Center to the east. Interior pedestrian and bicycle circulation opportunities would be provided. Public sidewalks would be constructed along all adjacent public street frontages. An approximately 15-foot wide trail would be provided on the site adjacent to the I-580 freeway. The trail would be on private property and would be privately maintained. The trail would provide access between Hacienda Drive and the Dublin-Pleasanton BART station to the west. Bicycle parking will be provided throughout the site in accordance with the requirements of the Zoning Ordinance and the California Building Code. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 38 Site grading. The applicant proposes to re-grade the site to improve site drainage and to allow for building pads to be constructed on the site. Landscaping. Plantings in the form of trees, shrubs and groundcover would be provided adjacent to Hacienda Drive, Martinelli Way, Arnold Drive, I-580 freeway frontage, and throughout the project site. Trees would also be planted within the parking lots, adjacent to proposed buildings, and concentrated in the commercial plaza and residential open space areas. Detailed landscape plans will be reviewed and approved by the City of Dublin through the Site Development Review (SDR) process. Inclusionary Housing Provision. The City of Dublin requires that a minimum of 12.5% of the number of dwelling units within a proposed project be reserved as affordable dwellings. Under certain conditions and with the approval of the City, project developers may elect to pay a fee in lieu of constructing up to 40% of the required number of affordable units. The City Council may also allow developers to construct affordable units at an off-site location or to satisfy the Inclusionary Ordinance by some other alternative means at their sole discretion. Public Art. Since the proposed project would include more than 20 dwelling units as well as a significant non-residential component, the project developer will be required to either install one or more pieces of public art on the project site or to provide in-lieu funds for the installation of public art in a different location. The value of public art, or the in-lieu fee payment, is required to be equivalent to 0.5% of the project’s building valuation, not including land value. Signs. Signs would be constructed to identify the overall project as well as future individual tenants within the commercial portion of the complex and residential developments. The number, type, location and design of future signs will be determined through the Site Development Review process. Utility services. Domestic and recycled water service and sewer service would be provided to the project by Dublin San Ramon Services District (DSRSD). The project applicant will be required to develop a storm drain and water quality master plan to ensure that stormwater runoff is collected and transported off of the site in a manner consistent with Zone 7 Flood Control and Water Conservation District and City of Dublin engineering standards and requirements. The project applicant will also be required to comply with City of Dublin surface water quality standards. Requested land use approvals. As noted above, a number of land use approvals are required to construct the project as proposed. These are described in more detail below. General Plan Amendment. The City of Dublin General Plan Land Use Map designates the project site as “General Commercial,” which provides land for a range of regional- and community-serving retail, service, and office uses. Uses allowed in this designation include, but are not limited to: retail uses, including major community-serving uses (e.g., supermarkets, drug stores, hardware stores, apparel stores, etc.) and regionally-oriented retail uses (e.g., high-volume retail uses such as discount centers, promotional centers, home The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 39 improvement centers, furniture outlets, and auto malls); all office uses; hotels; banks; service uses; and restaurants and other eating and drinking establishments. An application has been filed with the City to change the land use to a “Mixed-Use” land use designation, which allows the combination of Medium to Medium-High Density residential housing and at least one non-residential use, such as office or retail. Office or retail uses could include uses such as stores, restaurants business and professional offices, and entertainment facilities. Eastern Dublin Specific Plan Amendment. An amendment to the Eastern Dublin Specific Plan has also been requested by the applicant that would change the Specific Plan land use designation from “General Commercial” to “Mixed-Use.” Stage 1 and Stage 2 Development Plan and Rezoning. The project site is presently zoned PD- Planned Development. The existing PD zoning district only allows commercial land uses. In order to allow the development to be constructed as proposed, a Stage 1/Stage 2 Planned Development Rezone is required to permit the proposed uses, square footage of commercial development, number and type of residential units, number of proposed parking spaces, landscaping and other features. A Planned Development Rezone is being considered to ensure consistency with the requested General Plan and Specific Plan Amendments. Site Development Review. Site Development Review (SDR) approvals must be granted by the City of Dublin to ensure that building architecture, landscaping, signs and other facilities are consistent with design guidelines and other policies contained in various City land use regulations and guidelines. Parcel or Vesting Tentative Map(s). Subdivision maps must be approved by the City of Dublin to create individual building lots on the project site. Development Agreement. The Applicant may request a Development Agreement (DA). A DA would articulate Applicant responsibilities for development impact fees, Community Benefit contributions, reimbursements to other parties for oversizing of infrastructure, as well as project vesting timeframes. The above described approvals and activities constitute the project for the purposes of this DSEIR. 3.5 Project Objectives The objectives of the Eastern Dublin Specific Plan are set forth in the Eastern Dublin EIR. (DEIR p. 2-5.) All of the identified objectives for the Eastern Dublin Specific Plan remain objectives of the current project as it implements the comprehensive land use plan adopted in 1993. Additional objectives of the project include. a) Initiation of a zoning-level framework to guide future development projects within the Project area consistent with the General Plan and Eastern Dublin Specific Plan; b) Creation a community that is compatible in scale and design with the surrounding properties and land uses; The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 40 c) Construction of a mix of land uses that result in a fiscally positive impact on the City’s financial and service systems; d) Ensuring a long-term financially viable infill project providing for the creation of new jobs, commercial services for the community, opportunities for public gathering spaces and open space areas. e) Offering a diverse residential unit offering that will appeal to a diverse population demographic; f) Creation of a transit-oriented, walkable urban neighborhood by providing housing with direct pedestrian and bicycle connections to retail and restaurant uses on-site, the Dublin/Pleasanton BART Station, the proposed grocery-anchored shopping center to the north, Hacienda Crossings retail center to the east, and the future Campus Office uses to the west; g) Developing a project that responds to a range of transportation choices, including walking, bicycling and public transit (BART and bus service), to reduce traffic congestion and greenhouse gas emissions; h) Providing for a broad range of open spaces integrated into the walkable urban village atmosphere, including children’s play area, green space park and vibrant open plaza surrounded by shops, cafés and restaurants; i) Implementing high-quality urban architectural design that enhances and embraces the prominence and visibility of the project location; j) Providing for a prominent physical and visual connection to the grocery-anchored shopping center to the north of the project site and continuity in architectural and site design between the two properties and k) Creation of a gateway to the project site through prominent building siting and placement of distinctive features at both Hacienda Drive and Martinelli Way and at the main project driveway off Martinelli Way. 3.6 Future Actions Using This Supplemental EIR This Draft SEIR supplements the certified Eastern Dublin EIR and IKEA SEIR pursuant to Sections 15162 and 16163 of the CEQA Guidelines for the following anticipated future actions related to the proposed project.  City action on the General Plan Amendment and Specific Plan Amendment;  City action on the Stage 1 Planned Development Rezoning and Development Plan approval;  City actions on the Stage 2 Planned Development Rezoning and Development Plan approval;  City actions on future Parcel or Tentative Maps, Site Development Review, Conditional Use Permit, and on any future Development Agreement; and  City actions on building, grading, encroachment, and site improvement permits. In addition to the above approvals, the DSEIR may also be used by state or regional agencies in their review of other permits required for the project (e.g. Army Corps of Engineers permit related to on-site wetlands, CDFW Streambed Alteration Agreements, California Endangered Species Act permits, Water Quality Certification or waiver by the Regional Water Quality Control Board under the Clean Water Act), permits issued by the Dublin San Ramon Services The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 41 District, a Notice of Intent from the State Water Resources Control Board and other approvals/agencies as needed. CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) Hayward SanLeandro Oakland Berkeley WalnutCreek Richmond San Francisco DalyCity Alam e d a Mar tinez SanRafael MillValley S AN P A B L O B A Y SanJose Santa Clara Sunnyvale PaloAlto RedwoodCity HalfMoonBay Concord DUBLIN Fremont Pleasanton Livermore SAN FRA NCISC O B A Y P a c i f i c O c e a n Newark San Mateo 0 2 4 6 8 10 miles 4 280 280 880 680 580 580 580 680 680 80 880 Blue Ox Assoc iates, Be r k e l e y , C a l i f o rni a 3- 1 4 - 2 0 1 4 Exhibit 3.1 REGIONAL LOCATION PROJECT SITE Blue Ox Assoc iates, Be r k e l e y , C a l i f o rni a 0 3 -1 4 - 2 0 1 4 CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) County Line Project Site DUBLI N P L EASANT O N Exhibit 3.2 PROJECT CONTEXT IN DUBLIN CONTRA C O S T A COUNTY ALAMEDA C O U N T Y I-580 I - 6 8 0 Do u g h e rty R o a d Ho p y a rd R d Ha c i e n d a D r i v e daoR arajassaT Dublin Blvd Central Parkway Gleason D r i v e El C h a r ro R d Fall o n R o a d Sant a R i t a R d CI T Y O F D U B L I N TH E G R E E N P R O J E C T SU P P L E M E N T A L E I R ( S E I R ) Ex h i b i t 3 . 3 PR E L I M I N A R Y S I T E P L A N 3- s t o r i e s , 3 6 ‘ 3- s t o r i e s w i t h s o m e l o f t b o n u s , 3 6 ’ t o 4 6 ’ 4- s t o r i e s , 4 6 ’ BU I L D I N G S T O R I E S , H E I G H T TH E G R E E N , D U B L I N , C A KT G Y | B C V | S M I T H + S M I T H | Q U A T T R O 1/ 2 4 / 2 0 1 4 SO U R C E : KT G Y , B C V , S m i t h + S m i t h , a n d Q u a t t r o , 1 - 2 4 - 2 0 1 4 . CI T Y O F D U B L I N TH E G R E E N P R O J E C T SU P P L E M E N T A L E I R ( S E I R ) Ex h i b i t 3 . 4 PR E L I M I N A R Y R O A D W A Y N E T W O R K TH E G R E E N A T P A R K P L A C E Qu a t t r o 50 0 L a G o n d a W a y Su i t e 2 9 5 Da n v i l l e , C A 9 4 5 2 6 DU B L I N , C A KT G Y G r o u p , I n c . Ar c h i t e c t u r e + P l a n n i n g 58 0 S e c o n d S t r e e t Su i t e 2 0 0 Oa k l a n d , C A 9 4 6 0 7 51 0 . 4 6 3 . 2 0 4 7 kt g y . c o m OP T I O N A : R O A D H E I R A R C H Y KT G Y # 2 0 1 3 - 0 0 1 0 SO U R C E : KT G Y G r o u p , I n c . , 2 - 1 0 - 2 0 1 4 . The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 46 4.0 ENVIRONMENTAL ANALYSIS Topics Addressed in the DEIR This section of the DEIR identifies specific environmental areas which may be affected as a result of the implementation of the proposed project. The impact areas are discussed individually in subsections 4.1 through 4.8: 4.1 Population and Housing 4.2 Transportation and Traffic 4.3 Community Services and Facilities 4.4 Sewer, Water and Water Quality 4.5 Biological Resources 4.6 Noise 4.7 Air Quality and Greenhouse Gas Emissions 4.8 Hazards and Hazardous Materials Each topic area is covered in the following manner: A. Environmental Setting A discussion of existing conditions, facilities, services and general environmental conditions on and around the project sites. B. Impacts and Mitigation Measures from the Eastern Dublin EIR and 2002 IKEA SEIR C. Supplemental Environmental Impacts An identification and evaluation of whether the potential impacts on the environment identified in the Initial Study, should the project be constructed as proposed would result in a significant substantially increased manner beyond the analysis in the Eastern Dublin EIR based on the standards of significance set forth therein. D. Supplemental Mitigation Measures An identification of specific efforts and measures which can be incorporated into the project to reduce identified supplemental environmental impacts to a less-than- significant level. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 47 4.1 POPULATION AND HOUSING INTRODUCTION This topic of population, housing and employment was addressed in Section 3.2 of the Eastern Dublin EIR. This section of the DEIR updates the analysis in the EDSP based upon the proposed amendment to the Dublin General Plan and Eastern Dublin Specific Plan to add population through residential development on this site that is currently approved for commercial land uses. ENVIRONMENTAL SETTING The project site is vacant and contains no dwellings. The most recent action of the City of Dublin was to approve a Stage 2 Planned Development rezoning on the site to allow development of up to 305,000 square foot shopping center, which was not constructed. The project site is currently designated as “General Commercial” on the Dublin General Plan Land Use Diagram and in the Eastern Dublin Specific Plan. IMPACTS AND MITIGATIONS FROM PREVIOUS EIRs Eastern Dublin EIR. The Eastern Dublin EIR discussed the anticipated build-out number of jobs within the Eastern Dublin General Plan Amendment and Specific Plan area as 28,238 and the number of anticipated residents as 27,794. At build-out, there would be approximately 17,970 dwellings at various densities and product types. The topic of jobs/housing balance in the Tri-Valley area was also discussed in the EDSP EIR. No impacts or mitigation measures were identified in the Eastern Dublin EIR. IKEA SEIR. The topic of population, housing and employment was not analyzed in the IKEA SEIR. REGULATORY FRAMEWORK Dublin General Plan. The General Plan land use designation allows for a range of regional and community serving retail, service and office uses, restaurant and other eating and drinking establishments and similar uses. Mixed-use projects incorporating retail, service and/or office uses with residential uses are allowed as part of a mix when location and design ensure compatibility. The Dublin General Plan includes the following guiding and implementing policies dealing with residential compatibility. • Guiding Policy 2.5.4.A. Encourage the development of a balanced mixed-use community in the Eastern Extended Planning Area, that is well integrated with both natural and urban systems, and provides for a safe, comfortable and attractive environmental for living and working. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 48 Eastern Dublin Specific Plan. The Specific Plan designed the project site as “General Commercial,” that allows a range of regional and community service retail, service and office uses. Mixed–use projects incorporating retail, service and/or residential uses are encouraged with residential uses also allowed as part of the mix when location and design ensure compatibility. The following Specific Plan policies address land use and residential location and diversity. • Policy 4.2. Encourage higher density residential development within convenient walking distance of shopping areas, employment centers, transit stations/stops and other community facilities. • Policy 4-5. Concentrate residential development in the less environmentally constrained portions of the plan area and encourage cluster development as a method of reducing or avoiding impact to constrained or environmentally sensitive areas. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES This section of the SEIR assess the impacts of introducing up to 400 dwellings within the commercial-designated site and the potential to induce, directly or indirectly, population growth on surrounding properties. Significance Criteria. The following criterion has been used to identify the significance of any supplemental population and housing as a result of approving and implementing a proposed project: Induce substantial population growth in an area, either directly or indirectly (for example, through extension of roads or other infrastructure). Potential Growth Inducement Impact. As noted in the Project Description, proposed residential uses would include up to 400 condominium and townhome dwellings in buildings clustered throughout the project site. The City of Dublin currently uses a standard per dwelling unit household population of 2.7 persons per dwelling. This is based on the 2010 federal census and State Department of Finance population data (Marnie Delgado, Dublin Community Development Department, 8/19/13), Based on the current dwelling unit occupancy rate, there would be up to 1,080 residents on the site at full build-out of the residential portion of the project. The 1993 Eastern Dublin EIR used differing per-dwelling occupancy calculations (see Table 3.2- 5). These factors are 2.0 persons per dwelling for attached units (condominium and townhouses) and 3.2 persons per dwelling for single-family detached dwellings. Using these occupancy factors, the residential portion of the project would generate up to 800 residents. The proposed project would not induce substantial population growth in the area beyond that already forecasted for the City of Dublin. The City of Dublin Housing Element estimates that the population of the City will be 62,700 residents in 2020. The proposed project provides for the future development of up to 400 residential dwelling units. Based on population estimates of 2.7 persons per household, the proposed project would increase the population by approximately The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 49 1,080 persons. Dublin’s current population (2013) is 50,254 persons. The addition of 1,080 people is expected to be within the projected number of City residents in 2020. To the extend the Project’s population growth is in addition to the projected population growth in 2020, it will not constitute substantial population growth because it would only represent a 1.7% increase in the total anticipated population for the City. The proposed project would increase the residential population generate by the project site over that currently permitted. The current General Commercial General Plan land use designation allows “mixed use projects incorporating retail, service, and/or office uses are encouraged, with residential uses also allowed as part of the mix when location and design ensure compatibility,” so some number of residential uses could be permitted on site without a General Plan Amendment. Additionally, the City is either considering, or has already approved, a number of projects where the proposed/approved number of residential units is less than previously anticipated, and where the development density on several different parcels within the Eastern Dublin Specific Plan has been reduced. These projects include: 1. The Groves Lot 3: Previously approved for 304 units, now approved for 122 units; 2. Dublin Ranch Subarea 3: Previously approved for 484 units, project reconfigured and approved with 437 units; 3. Transit Center Site A-1: The Transit Center Master Plan allocated 131 units to the site, the City is currently processing a General Plan Amendment request to reduce the number of units on site to 52; and 4. Wallis Ranch: Previously approved for 935 units, the current project proposal is for 806 units. Taking into account the above projects, the number of units expected to be constructed in the Eastern Dublin Specific Plan is reduced by 437 units. With the addition of the proposed 400 unit project, the end result is still a 37 unit reduction in the total number of units expected in Eastern Dublin. The proposed mixed-use project would also be consistent with applicable policies contained in the Dublin General Plan and Eastern Dublin Specific Plan that encourage higher-density mixed- use developments near transit stops. The proposed project would also further the intent and purpose of the regional Bay Area Plan by providing higher density housing with a mix of commercial uses in a Priority Development Plan (PDA) plan area. Finally, the proposed project would rely on existing roads to provide access to and from the site as well as using existing major water and wastewater lines in adjacent toads. There would be no requirement to extend roads or major utility lines to serve the project, since these currently exist. For the reasons set forth above, the proposed project would not result in substantial population growth in the City. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 50 Cumulative impacts. The appropriate area of analysis for cumulative population growth inducing impacts is the Eastern Dublin Specific Plan as described in the Project Description section of this DSEIR. The project site is surrounded on three sides by properties that are already currently developed or have pending development applications on file with the City of Dublin. The Dublin Transit Center has been approved west of the project site and the Hacienda Crossings regional commercial site is located east of The Green site. The City of Dublin has approved The Village at Dublin retail commercial project to the north. Therefore, all surrounding properties have been developed or are considering development and there would be no cumulative impact with respect to inducement of population growth within the immediately surrounding area. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 51 4.2 TRAFFIC AND TRANSPORTATION INTRODUCTION Transportation and circulation for this development site was analyzed in Chapter 3.3 of the 1993 Eastern Dublin Specific Plan Environmental Impact Report (Eastern Dublin EIR), a program EIR for the East Dublin General Plan Amendment and Specific Plan area. It was also analyzed in the IKEA SEIR. This section describes the current transportation-related setting. It examines the potential effects associated with the implementation of the proposed project on the near-term and future transportation system to determine if they would result in new significant impacts or substantial increase in severity of previously identified impacts in the previous EIRs. Information and analysis included in the following section was prepared by Kittelson & Associates in October 2013. Technical information, including level of service calculations, is on file with the City of Dublin. ENVIRONMENTAL SETTING Existing Roadway Network. The roadway network is made up of freeways, arterials, collectors and local streets. Figure 4.2-1 illustrates the roadway network in the project vicinity. Freeways. Regional vehicular access to the site is provided primarily by the freeway system that serves eastern Alameda County. Interstate 580 (I-580) is an east-west facility that runs along the southern boundary of the project site. It spans between US Highway 101 in the North Bay city of San Rafael and Interstate 5 just south of the Central Valley city of Tracy with direct connections to Interstate 80, Interstate 680, Interstate 205, and State Route 238. It has eight-to-ten travel lanes in the vicinity of the project site and carries approximately 197,000 average daily vehicles and 15,800 peak hour vehicles1 between Hacienda Drive and Tassajara Road. The nearest access to I- 580 from the project site is provided by the ramps on Hacienda Drive and Tassajara Road. I-580 is designated as a Route of Regional Significance (RRS) in the Tri-Valley Transportation Plan and Action Plans Update (Tri-Valley Action Plan) adopted by the Tri-Valley Transportation Council (TVTC) in November 2009. Routes of Regional Significance in the Tri-Valley Action Plan are major roadway and freeway corridors that serve regional traffic. Aside from I-580, Tassajara Road, Hacienda Drive, Dublin Boulevard, and Dougherty Road in the project vicinity are also designated as Routes of Regional Significance. These routes along with other key arterials, collectors, and local streets in the study area are described below. 1 California Department of Transportation, Traffic Data Branch, 2012. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 53 Arterials, Collectors and Local Streets. A network of arterial, collector and local roadways provide local and regional connections to and from the project site.  Martinelli Way is an east-west collector that spans between Iron Horse Parkway and Hacienda Drive. It serves as the northern boundary and provides the main vehicular access to the project site. In the immediate vicinity of the project site, Martinelli Way is a divided road with two to three travel lanes on each direction but narrows to one travel lane in each direction west of Arnold Road.  Hacienda Drive is a six-lane divided roadway in the project’s vicinity and serves as the eastern boundary of the Project site. It serves as the eastern boundary of the project site. The north-south roadway extends between Gleason Drive in Dublin to West Las Positas Boulevard in Pleasanton serving a number of retail commercial centers and business parks along the corridor. Hacienda Drive provides access to I-580 at its ramps just south of the project site and is a designated Route of Regional Significance. It is classified as a collector road north of I-580 and an arterial south of I-580.  Arnold Road serves as the western boundary and provides vehicular access to the project site. It has two travel lanes in the immediate vicinity of the site. The collector road extends between Santa Rita Jail just north of Broder Boulevard and Altamirano Avenue which is a frontage road on the north side of I-580 that provides access to the Dublin/ Pleasanton BART station. There is no freeway access from Arnold Road.  Dublin Boulevard runs parallel to I-580 in the east-west direction through Dublin. The Route of Regional Significance is classified as a six-lane divided arterial west of Tassajara Road through Dougherty Road past Interstate 680. Dublin Boulevard extends east of Tassajara Road to Fallon Road as a four- to five-lane collector road.  Tassajara Road/ Santa Rita Road is a north-south arterial that extends from the Contra Costa County line to I-580 east of the project site as Tassajara Road. North of the Contra Costa County line, it continues as Camino Tassajara, which runs northwesterly to just west of Interstate 680 in Danville. The Danville segment is called Sycamore Valley Road. South of I-580, the road continues as Santa Rita Road, which runs southwesterly to downtown Pleasanton. The segment that runs through downtown is called Main Street. The route of regional significance provides access to I-580 and has five to seven lanes in the study area.  Dougherty Road is a six-lane arterial that spans from I-580 north to Contra Costa County, where it continues as Bollinger Canyon Road and travels northwesterly to terminate at Crow Canyon Road west of Interstate 680 in San Ramon. South of I-580, Dougherty Road is known as Hopyard Road, which extends southerly to downtown Pleasanton.  Central Parkway is a collector, which runs in an east-west direction parallel to Dublin Boulevard between Arnold Road and Fallon Road. It is a two-lane divided road with raised landscaped medians. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 54 Existing Transit Service. Public transit services in the vicinity of the project site include Livermore-Amador Valley Transit Authority (LAVTA) fixed-route and paratransit bus services and Bay Area Rapid Transit (BART) commuter rail. Livermore-Amador Valley Transit Authority. Wheels is a fixed-route bus service provided by the LAVTA for the Tri-Valley communities of Dublin, Livermore, and Pleasanton. There are currently seven routes that serve the project site vicinity including two school-focused routes (Route 501 and 502). All but the school routes include stops on Dublin Boulevard and at the (East) Dublin/Pleasanton BART station less than a quarter mile from the project site. In addition, bus stops are also found along Arnold Road and Hacienda Drive. Table 4.2-1 describes the routes, schedule, average number of passengers per hour on each route, and estimated number of boardings during the peak hour. Table 4.2-1. Wheels Bus Routes Bus Line Route Description Schedule Average Passengers/Hr* Peak Hour Boardings* 1 Dublin/Pleasanton BART to East Dublin Weekdays 6:00 a.m. and 9:00 p.m. and between 8:00 a.m. and 9:00 p.m. over the weekend, 30- minute headways 7.3 13 2 Dublin/Pleasanton BART BART to Dublin Ranch Weekdays 7:00 a.m. to 9:00 a.m. and 4:00 p.m. and 6:30 p.m., 45-60 minutes headways 11.6 25 12 Transit Center to Dublin/Pleasanton BART Weekdays between 6:30 a.m. and 11:00 p.m., 30-60 minute headways 13.5 48 54 Pleasanton ACE Station to Hacienda Business Park to Dublin/Pleasanton BART Weekdays between 5:30 a.m. and 8:30 a.m. and 3:30 p.m. and 5:30 p.m., 60-90 minute headways 24.7 25 R^ Livermore to Dublin/ Pleasanton BART to Stoneridge Mall Weekdays between 5:15 a.m. and 7:00 p.m., 15- minute headways N/A N/A 501 East Dublin to Dublin High School One bus operates between 7:10 a.m. and 7:40 a.m. in the morning and one between 2:55 p.m. and 3:25 p.m. in the afternoon on weekdays N/A N/A 502 Dublin Ranch Village and Dublin High School One bus operates between 7:10 a.m. and 7:40 a.m. in the morning and one between 2:55 p.m. and 3:25 p.m. in the afternoon on weekdays N/A N/A N/A = not available; * Per LAVTA Fiscal Year 2011 data. ^ Route R is a bus RAPID transit route that provides faster transit service in the Tri-Valley area. Source: LAVTA Wheels website: <http://www.wheelsbus.com/>accessed on October 14, 2013. LAVTA, Short Range Transit Plan FY2012-2021, adopted November 2012. Bay Area Rapid Transit (BART). BART provides transit rail service to San Francisco, Oakland, Pleasanton, Pittsburg, Richmond, Fremont and a number of intermediate stations from the (East) Dublin/Pleasanton BART station, which is approximately one-quarter mile from the project site. The BART station also serves as a transit hub, where bus lines converge and offer bus transfers. BART operates in 5- to 20-minute intervals between 4:00 a.m. and midnight, Monday through Friday; 6:00 a.m. to midnight on Saturdays; and 8:00 a.m. to midnight on Sundays and major holidays. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 55 Existing Bicycle Facilities. The existing and proposed bicycle facilities in Dublin are identified in the City’s Bikeways Master Plan2 and in the Circulation and Scenic Highways Element of the City of Dublin General Plan3. Originally adopted in 2007, the Bikeways Master Plan is being updated. Bikeways are defined by the following three classes in the California Department of Transportation’s (Caltrans) Highway Design Manual: Class I – Provides a completely separated facility designed for the exclusive use of bicyclists and pedestrians with crossing points minimized. Class II – Provides a restricted right-of-way designated lane for the exclusive or semi- exclusive use of bicycles with through travel by motor vehicles or pedestrians prohibited, but with vehicle parking and cross-flows by pedestrians and motorists permitted. Class III – Provides a right-of-way designated by signs or permanent markings and shared with pedestrians and motorists. A Class I bike path, the Iron Horse Trail, is located roughly a half mile from the project site. The Iron Horse Trail is a regional Class I bikeway that currently starts near the (East) Dublin/Pleasanton BART station and runs northerly through Tri-Valley cities to terminate near State Route 4 in Concord. When completed, the Iron Horse Trail will extend east from the (East) Dublin/Pleasanton BART station to the San Joaquin County line east of Livermore. Another Class I bikeway on the north side of Dublin Boulevard connects the Iron Horse Trail with Tassajara Creek Trail, another Class I bikeway to the east that continues northeasterly to Tassajara Road. A Class I bike path is also provided along the east side of Dougherty Road from its intersection with the Iron Horse Trail to the Contra Costa County line. Class II bike lanes are provided on both sides of Dublin Boulevard, Hacienda Drive, Tassajara Road, and Central Parkway. In addition, Class II bike lanes can be found on the west side of Arnold Road between Dublin Boulevard and Martinelli Way and on both sides of Arnold Road north of Dublin Boulevard. The City of Dublin has proposed the completion of the Class II bikeways on Arnold Drive from Martinelli Way to (East) Dublin/Pleasanton BART Station, on Martinelli Way between Arnold Road and Iron Horse Parkway, and along Altamirano Avenue between Arnold Road and the (East) Dublin/Pleasanton BART parking lot, which would provide a multimodal connection to the project site. Class II bike lanes are also proposed on the west side of Dougherty Road, and along Iron Horse Parkway and DeMarcus Boulevard south of Dublin Boulevard. Existing Pedestrian Facilities. The City is currently developing a Pedestrian Master Plan. The Plan will establish goals and policies related to pedestrian facilities and circulation in Dublin. Sidewalks are generally provided along the frontage of developed parcels in the project vicinity. Even along undeveloped parcels, a separated walkway is usually provided to provide uninterrupted pedestrian access. The sidewalks are often separated from the roadway by planting strips or screening trees particularly along arterials. While there are no concrete sidewalks along 2 City of Dublin Bikeways Master Plan, Fehr and Peers, June 2007. 3 City of Dublin General Plan, adopted February 11, 1985 and amended as of June 2013. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 56 Martinelli Way and Arnold Road along the project site frontage, paved asphalt walkways are provided along the north side of on Martinelli Way and along the west side on Arnold Road. On the eastside of project site along Hacienda Drive, there is a concrete sidewalk with planting strip. A concrete sidewalk is also provided along the south side of Altamirano Avenue connecting the project site with the (East) Dublin/Pleasanton BART station. Marked crosswalks and pedestrian signal heads are provided across all legs of the Martinelli Way intersections of Arnold Road and the project driveway access and across all but the south leg of the Hacienda Drive intersection. They are also provided across all legs of the Dublin Boulevard intersections of Hacienda Drive and Arnold Road. Curb ramps are also provided at all corners of these five intersections. Regulatory Setting. A number of agencies have jurisdictions over the project area. These agencies are briefly discussed below. The California Department of Transportation (Caltrans). Caltrans has jurisdiction over state highways in the project vicinity. Caltrans constructs and maintains all state highways, and sets design standards that are often used by local governments. Metropolitan Transportation Commission (MTC). MTC is the state-designated metropolitan planning organization for the nine-county San Francisco Bay Area; it has authority for regional planning, distributing and administering federal and state funds for all modes of transportation, and assuring that projects are consistent with the Regional Transportation Plan. Alameda County Transportation Commission (Alameda CTC). Alameda CTC coordinates transportation planning efforts throughout Alameda County and programs local, regional, state and federal funding for project implementation. It develops Countywide Transportation Plan (CTP), a long-range policy document that guides transportation funding decisions. The Alameda CTC also acts as the Congestion Management Agency for Alameda County which is legislatively required to develop a Congestion Management Program (CMP). CMP requires analysis of Metropolitan Transportation System (MTS) roadway and transit systems if a project generates 100 or more PM peak hour trips. Tri-Valley Transportation Council (TVTC). TVTC is comprised of the Cities of Dublin, San Ramon, Pleasanton, and Livermore, the Town of Danville, and Alameda and Contra Costa Counties. It developed the Tri-Valley Transportation Plan/Action Plan, last updated in 2009, to address transportation issues within the Tri-Valley area. The Plan designates Routes of Regional Significance, which are roadways and freeway corridors that serve regional traffic. TVTC coordinates the transportation planning in the Tri-Valley area and oversees the expenditures of the Tri-Valley Transportation Development Fee, which is a traffic impact fee levied on new developments. City of Dublin. The City of Dublin is the primary local agency for determining the future success of the East Dublin community. The City’s General Plan outlines the goals for future growth and the City of Dublin municipal codes enforce the rules and regulations. Also, the Eastern Dublin The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 57 Specific Plan, last updated in 2010, sets forth specific goals, polices and standards applicable to East Dublin. The City of Dublin has adopted three fee programs to fund necessary improvements. All development projects in East Dublin are require to contribute a proportionate share to these fee programs or construct the improvements included in the programs. East Dublin Traffic Impact Fee Program. The City of Dublin has adopted the East Dublin Traffic Impact Fee Program in 1995 to fund transportation improvements in 1) the Specific Plan/General Plan Amendment project area; 2) other areas of Dublin; and 3) the region where developments in East Dublin would affect. Such improvements includes those assumed in the Eastern Dublin Specific Plan EIR, identified as mitigation measures in the EIR, and necessary for the East Dublin area to develop. The portion of the fee program that funds regional improvements has been replaced by the Tri-Valley Transportation Development Fee described below. Tri-Valley Transportation Development Fee. The Tri-Valley Transportation Development Fee was established in conjunction with the Cities of Pleasanton, Livermore and San Ramon, the Town of Danville, and the Counties of Alameda and Contra Costa in 1998. The intent of the fee is to fund transportation improvements that would benefit the Tri- Valley region. Freeway Interchange Fee. The Freeway Interchange Fee was adopted by the City of Dublin to reimburse Pleasanton for funding construction of certain interchanges on I-580 that also benefit East Dublin. IMPACTS AND MITIGATION MEASURES FROM PREVIOUS EIRs Eastern Dublin EIR. The East Dublin EIR evaluated transportation conditions for Year 2010 scenario and Cumulative Build-out scenario. All adopted mitigation measures of the Eastern Dublin EIR would apply to development projects within East Dublin. The City has established fee programs to collect fair share contributions for implementation of the improvements. Such programs are described in the “City of Dublin Fee Program” section below. Other impacts and mitigation measures from the Eastern Dublin EIR are summarized below. Freeway Operations. The EIR concluded that the Specific Plan project would have residual significant and unavoidable impact related to freeway operations at the following segments under Year 2010 and/or Cumulative Buildout scenarios:  I-580 between I-680 and Hacienda Drive (IM 3.3/B) Upon certification of the East Dublin Specific Plan EIR and approval of the Eastern Dublin General Plan Amendment and Specific Plan, the City adopted a Statement of Overriding Considerations (Resolution No. 53.93) for this significant and unavoidable impact. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 58 The EIR further concluded that the significant impacts related to the following freeway segments would be reduced to level of insignificance under Year 2010 and/or Cumulative Buildout scenarios:  I-580 between Tassajara Road and Airway Boulevard (IM 3.3/C)  I-680 north of I-580 interchange (IM 3.3/D)  I-580 east of Airway Boulevard (IM 3.3/E) The following measures were adopted to alleviate impacts on freeway operations:  Require all non-residential projects with 50 or more employees to participate in a Transportation Systems Management (TSM) program. (MM 3.3/2.0)  The Project shall contribute a proportionate amount to regional transportation mitigation programs (MM 3.3/2.1, MM 3.3/3.0, and MM 3.3/4.0) and shall require all future developments to participate in regional transportation mitigation programs (MM 3.3/5.0) as determined by regional transportation studies.  The Project shall contribute a proportionate share to planned ultimate improvements at the I-580/I-680 interchange as implemented by Caltrans. The assessed costs of freeway interchange improvements shall include the costs of revised freeway ramp connections to Dublin and the associated mitigation on adjacent local streets. (MM 3.3/4.0)  The Project shall contribute a proportionate amount to the construction of auxiliary lanes on I-580 east of Airway Boulevard as implemented by Caltrans. (MM 3.3/5.0) Intersection Operations. The Eastern Dublin EIR concluded that the Specific Plan project would have residual significant and unavoidable impacts at the following intersections under Year 2010 and/or Cumulative Buildout scenarios:  Santa Rita Road with the I-580 eastbound ramps (IM 3.3/I) (#18) 4  Hacienda Drive with Dublin Boulevard (IM 3.3/M) (#10)  Tassajara Road with Dublin Boulevard (IM 3.3/M) (#16) Upon certification of the East Dublin Specific Plan EIR and approval of the Eastern Dublin General Plan Amendment and Specific Plan, the City adopted a Statement of Overriding Considerations (City Council Resolution No. 53-93) for these significant and unavoidable impacts. The EIR further concluded that the significant impacts related to the following intersections would be reduced to level of insignificance under Year 2010 and/or Cumulative Buildout scenarios:  Dougherty Road with Dublin Boulevard (IM 3.3/F) (#2)  Hacienda Drive with the I-580 eastbound ramps (IM 3.3/G) (#13)  Tassajara Road with the I-580 westbound ramps (IM 3.3/H) (#17) 4 The intersection numbers of the Supplemental EIR are provided for reference if applicable. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 59  Airway Boulevard with Dublin Boulevard/North Canyons Parkway (IM 3.3/J)  Airway Boulevard with the I-580 westbound ramps (IM 3.3/K)  Tassajara Road with Fallon Road (IM 3.3/N)  Tassajara Road with Gleason Road (IM 3.3/N)  Tassajara Road with the Transit Spine (IM 3.3/N) The following measures were adopted to alleviate impacts on intersection operations:  The Project shall contribute a proportionate share towards the costs of the improvements as determined by a regional transportation study. (MM 3.3/6.0, MM 3.3/7.0, MM 3.3/9.0, MM 3.3/10.0, MM 3.3/11.0, MM 3.3/12.0, MM3.3/14.0 ) Transit. The Eastern Dublin EIR concluded that the significant impacts related to introduction of significant development in an area not served by public transit would be reduced to level of insignificance. (IM 3.3/O) The following measures were adopted to alleviate impacts on transit:  The Project shall contribute a proportionate amount to the capital and operating costs of transit service extensions. (IM 3.3/15.2) Pedestrians and Bicycles. The Eastern Dublin EIR concluded that the potentially significant impact related to street crossing for pedestrians and bicyclists would be reduced to level of insignificance. (IM 3.3/P) The following measures were adopted to alleviate impacts on street crossing for pedestrians and bicyclists:  Provide a Class I paved bicycle/pedestrian path parallel to Tassajara Creek. (IM 3.3/16.0)  Locate pedestrian and bicycle paths so that their crossings of major arterial streets coincide with signalized street intersections, provide a signalized pedestrian and bicycle crossing of the major street. (IM 3.3/16.1) IKEA SEIR. This Supplemental EIR identified the following supplemental impacts and contained the following the supplemental mitigation measures. • Supplemental Impact TRA-1 found a potentially significant supplemental impact at key intersections near the project site, including the Martinelli Way/Hacienda Drive intersection, the I-580 eastbound off-ramps/Hacienda Drive intersection, the I-580 westbound ramps/Hacienda Drive intersection and the Dublin Boulevard/Dougherty Road intersection. With construction of future roadway improvements included in the Eastern Dublin Transportation Impact Fee Program and Capital Improvement Budget, these impacts were found to be less-than-significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 60 • Supplemental Impact TRA-2 identified cumulative impacts at study area intersections, which are identified above. Adherence to Supplemental Mitigation Measure SM-TRA-2 required payment of fair share fees to fund the construction of a southbound-to- westbound right-turn lane at the Dublin Boulevard/Arnold Road intersection reduced this impact to a less-than-significant level. • Supplemental Impact TRA-3 found that project related trips would add more vehicles to already congested local freeway segments. Mitigation for this impact was found to be infeasible since freeway improvements are not under the jurisdiction of the City of Dublin, although the project developer was required to pay Tri-Valley Transportation Development fees, of which a portion is directed toward freeway improvements. The current project will be required to adhere to applicable mitigation measures from previous CEQA documents SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES This supplemental analysis is intended to identify changes in impacts and mitigation measures due to the land use modifications and other changes. The methodologies and approach are described below. Analysis Methodology. Level of service is a qualitative measure that describes operational conditions as they relate to the traffic stream and perceptions by motorists and passengers. The level of service generally describes these conditions in terms of such factors as speed and travel time, delays, freedom to maneuver, traffic interruptions, comfort, convenience, and safety. The operational levels of service (LOS) are given letter designations from “A” to “F,” with “A” representing the best operating conditions (free-flow) and “F” the worst (severely congested flow with high delays). Intersections generally are the capacity-controlling locations with respect to traffic operations on arterial and collector streets. Signalized Intersections. Signalized intersection analyses were conducted using the operational methodology outlined in the Highway Capacity Manual (Transportation Research Board, Washington, D.C., 2000, Chapters 10 and 16). It was conducted using Synchro analysis software tool. The HCM procedure calculates an average controlled delay per vehicle at a signalized intersection, and assigns a level of service designation based upon the delay. Delay is a complex measure and is dependent upon a number of variables, including the number of vehicles in the traffic stream. It is also dependent on the quality of signal progression, the signal cycle length, and the “green” ratio for each approach or lane group. Table 4.2-2 provides descriptions of the level of service and the corresponding ranges of delays for signalized intersections. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 61 Table 4.2-2. Signalized Intersection Level of Service Definition Level of Service Description of Traffic Conditions Average Delay Per Vehicle (Seconds) A Free flowing. Most vehicles do not have to stop. 10.0 B Minimal delays. Some vehicles have to stop, although waits are not bothersome. >10.0 and 20.0 C Acceptable delays. Significant numbers of vehicles have to stop because of steady, high traffic volumes. Still, many pass without stopping. >20.0 and 35.0 D Tolerable delays. Many vehicles have to stop. Drivers are aware of heavier traffic. Cars may have to wait through more than one red light. Queues begin to form, often on more than one approach. >35.0 and 55.0 E Significant delays. Cars may have to wait through more than one red light. Long queues form, sometimes on several approaches. >55.0 and 80.0 F Excessive delays. Intersection is jammed. Many cars have to wait through more than one red light, or more than 60 seconds. Traffic may back up into “up-stream” intersections. >80.0 Source: Transportation Research Board, 2000. Highway Capacity Manual. Queues. Queue analyses were conducted for 95th percentile left-turn queues using Synchro analysis software tool. The 95th percentile queue is the maximum back of queue with 95th percentile traffic volumes. This condition is not typically experienced by an average driver. When multiple lanes are provided, the queue length for the lane with the highest queue was reported. Metropolitan Transportation System Arterial and Freeway Segments. Levels of service for roadway segments analyzed using the Florida Department of Transportation level of service methodology, which provides a planning level analysis based on Transportation Research Board’s 2000 Highway Capacity Manual. As a planning level analysis, the level of service is based on forecasts of traffic and assumptions for roadway and signalization control conditions, such as facility type (freeway, and arterial classification), speeds, capacity and number of lanes. The traffic forecasts for the MTS analysis were estimated based on the latest Alameda Countywide Travel Demand Model. Trips generated by land use on the project site assumed in the 2020 and 2035 models were first removed from the MTS arterial and freeway segments; then volumes generated by the proposed project were added to derive the estimated volumes on the segments. The removal and addition of the trips generated by the project site on MTS arterial and freeway segments was perform using Traffix software. Routes of Regional Significance Arterial Segments. Arterial level of service was conducted for Routes of Regional Significance based on methodology outlined in the Highway Capacity Manual (Transportation Research Board, Washington, D.C., 2000, Chapter 15) using Synchro software tool. The HCM procedure calculates an average through-vehicle travel speed for the arterial segment and assigns a level of service designation based upon the speed. The level of service criteria is shown in Table 4.2-3. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 62 Table 4.2-3. Arterial Level of Service Definition Urban Street Class I II III IV Typical Free Flow Speed 50 mi/hr 40 mi/hr 35 mi/hr 30 mi/hr Level of Service Average Travel Speed (miles/hr) A >42 >35 >30 >25 B >34-42 >28-35 >24-30 >19-25 C >27-34 >22-28 >18-24 >13-19 D >21-27 >17-22 >14-18 >9-13 E >16-21 >13-17 >10+14 >7-9 F <= 16 <= 13 <= 10 <= 7 Source: Transportation Research Board, 2000. Highway Capacity Manual. Analysis Approach. Transportation impact analysis was performed for Existing conditions, Short-Term (Year 2020) Cumulative conditions, and Long-Term (Year 2035) Cumulative conditions. Full development of the proposed project is assumed to occur under each project scenario. The analysis primarily built upon a set of Synchro traffic analysis files prepared for The Village development by TJKM Consultants in August 2013 and the updated City of Dublin’s Citywide Travel Demand Model files prepared for the Dublin Crossing development by Hexagon Transportation Consultants, Inc. The Synchro files contain intersection volume and lane geometry data used in The Village project analysis for the Existing, Short-Term Cumulative, and Long-Term Cumulative conditions and the model files contain travel demand forecasting runs for Year 2011 base year, Year 2020 and Year 2035 future years. The analysis approach is detailed below. Existing Conditions. The existing volumes and lane geometries were primarily compiled from The Village project’s Synchro files and the Dublin Crossing Specific Plan Draft Environmental Impact Report (Dublin Crossing DEIR). Peak hour turning movement volumes for the Glynnis Rose Drive and Dublin Boulevard intersection was collected for this study. All peak hour volumes for the study intersections were collected in 2012 and 2013. The new external trips generated by the proposed project were distributed based on the select zone analysis and assigned onto the roadway network using Traffix software. The project trips at each of the study intersections were then added to existing volumes to derive the intersection volumes for the Existing plus Project scenario. The existing lane geometries and intersection turning movement volumes for the Existing No Project scenario and the Existing plus Project scenario are provided in Appendix B (See SEIR Appendix 8.6). Short-Term Cumulative (Year 2020) Conditions. For the 22 study intersections that are included in The Village project, the volumes and lane geometries of the Short-Term Cumulative plus The Village project scenario are assumed to be the same as those of the Short-Term Cumulative No Project scenario of the proposed project. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 63 For the remaining three intersections, the 2020 No Project volumes were developed by adding The Village project trips to the future background volumes. The future background volumes were based on the citywide model as applied in the Dublin Crossing EIR. The proposed project trips were added to the Short-Term Cumulative No Project volumes to derive the intersection volumes for the Short-Term Cumulative plus Project scenario. The following improvements are assumed in the analysis under Short-Term Cumulative conditions: City of Dublin Traffic Impact Fee Program – Roadway Improvements:  I-580 westbound: Addition of a westbound auxiliary lane along I-580 between Fallon Road and Tassajara Road  I-580 westbound: Addition of a westbound HOV/Express lane along I-580 between Greenville Road and San Ramon Road Dublin Crossing project5:  Dublin Boulevard and Iron Horse Parkway/D Street intersection (#7)6: Construct a separate left turn lane and a shared through-right lane on southbound D Street/Iron Horse Parkway, and a westbound right turn lane and an eastbound left turn lane (within the existing median) on Dublin Boulevard, along with the necessary signal modifications to accommodate the new north leg of the intersection  Arnold Road and Central Parkway intersection (#19): Construct a separate left turn lane and a shared through-right lane on eastbound Central Parkway, and a northbound left turn lane on Arnold Road, along with the necessary signal modifications to accommodate the new west leg of the intersection. The Village project7:  Martinelli Way and Project Driveway intersection (#23): Construct a new north leg at Martinelli Way between Arnold Road and Hacienda Drive as The Village project’s south project access driveway. The project would also make the necessary signal modifications to accommodate the new southbound, eastbound left-turn and westbound right-turn movements. 5 These improvements would be constructed as a part of the Dublin Crossing project by Year 2020. If the Dublin Crossing project is not constructed by Year 2020, the projected volumes at the intersections would be reduced and the improvements would likely not be required since these improvements are project-specific and would not be needed without the project. In addition, The Green project would not add traffic to those movements, e.g., eastbound left and westbound right on Dublin Boulevard, that provide access to the Dublin Crossing project. 6 The intersection numbers of the Supplemental EIR are provided for reference if applicable. 7 These improvements would be constructed as a part of The Village project by Year 2020. If The Village project is not constructed by Year 2020, these improvements, which provide access to The Village, would not be needed. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 64 The lane geometries and intersection turning movement volumes for the Short-Term Cumulative No Project scenario and the Short-Term Cumulative plus Project scenario are provided in Appendix B of Appendix 8.6. Long-Term Cumulative (Year 2035) Conditions. For the 22 study intersections that are included in The Village project, the volumes and lane geometries of the Long-Term Cumulative plus The Village project scenario are assumed to be the same as those of the Long-Term Cumulative No Project scenario of the proposed project. For the remaining three intersections, the 2035 No Project volumes were developed by adding The Village project trips to the future background volumes. The future background volumes were based on the citywide model as applied in the Dublin Crossing EIR. The proposed project trips were added to the Long-Term Cumulative No Project volumes to derive the intersection volumes for the Long-Term Cumulative plus Project scenario. An additional step was required to estimate the intersection volumes for the Long-Term Cumulative plus Project scenario. As discussed under the Trip Generation section, the city traffic model assumed land uses on the project site in 2035. Trips generated by the assumed land uses were removed first before the trips generated by the proposed project were added to the study intersections. This resulted in a net change in vehicle trips due to the proposed project relative to the previously assumed land use at the site. In addition to those identified under Short-Term Cumulative conditions, the following improvements are assumed under Long-Term Cumulative conditions: City of Dublin Traffic Impact Fee Program – Roadway Improvements:  Tassajara Road: Widening of Tassajara Road to six lanes between Fallon Road and Dublin Boulevard  Tassajara Road: Widening of Tassajara Road to eight lanes between Dublin Boulevard and I-580 westbound ramps  Dublin Boulevard : Dublin Boulevard six lane extension, from Fallon Road to Airway Boulevard  Arnold Road: Widening Arnold Road to four lanes from Dublin Blvd to Central Parkway  Hacienda Drive: Widening Hacienda Drive to six lanes from Dublin Boulevard to Central Parkway  Hacienda Drive: Widening Hacienda Drive to four lanes from Central Parkway to Gleason Road  Scarlett Drive: Extend/Widen Scarlett Drive to four lanes from Dublin Boulevard to Dougherty Road City of Dublin Traffic Impact Fee Program – Intersection Improvements:  Dougherty Road and Scarlett Drive (#1): Adding one southbound through lane and converting the existing northbound right-turn lane to a shared through-right turn lane on The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 65 Dougherty Road; and adding two westbound right-turn lanes and converting the existing shared through-right turn lane to an exclusive through lane.  Dublin Boulevard and Scarlett Drive (#5): Constructing two southbound left-turn lanes and one shared through-right lane for the new Scarlett Drive extension; converting the existing northbound right-turn lane to a shared through-right lane on Scarlett Drive; and adding an exclusive westbound right-turn lane.  Dublin Boulevard and Arnold Road (#8): Adding a southbound right turn lane and converting the existing shared through-right turn lane to an exclusive through lane on Arnold Road; and adding an eastbound left turn lane on Dublin Boulevard and corresponding northbound receiving lane.  Dublin Boulevard and Hacienda Drive (#10): Converting an existing northbound right- turn lane to a through lane on Hacienda Drive; and adding a westbound right turn lane and converting the existing shared through-right turn lane to an exclusive through lane on Dublin Boulevard  Hacienda Drive and Martinelli Way/Hacienda Crossings (#11): Removing the existing raised delineators to allow for three northbound left-turn lanes on Hacienda Drive  Hacienda Drive and Central Parkway (#20): Adding a southbound through lane; converting the existing northbound shared through-right turn lane to an exclusive through lane; and adding a northbound right-turn trap lane from the Dublin Boulevard intersection  Hacienda Drive and I-580 EB Ramps (#13): Adding a northbound through lane on Hacienda Drive and an additional eastbound left-turn lane on the I-580 eastbound off- ramp  Tassajara Road and Dublin Boulevard(#16): Adding two northbound through lanes on Tassajara Road, an eastbound through lane on Dublin Boulevard, and a westbound right turn lane and a through lane; and converting the existing shared through-right turn lane a through lane  Tassajara Road and I-580 WB Ramps (#17): Adding a northbound through lane on Tassajara Road. City of Pleasanton Intersection Improvements:  Santa Rita Road and I-580 EB Ramps (#18): Adding a southbound left-turn lane on Santa Rita Road The future lane geometries and intersection turning movement volumes for the Long-Term Cumulative No Project scenario and the Long-Term Cumulative plus Project scenario are presented in Appendix B (see SEIR Appendix 8.6). Project Characteristics. The proposed project is a mixed-use development located at the southwest quadrant of the Hacienda Drive and Martinelli Way intersection. Its land uses are different from those assumed on the project site in the Eastern Dublin EIR. For the purpose of this analysis, the proposed project consists of 35,000 square feet of restaurant space, 5,000 square feet of other retail space, 50 single family detached dwelling units, 260 townhouse units, and 90 condominium units (400 units total). The traffic impacts of this product mix are more intensive than the impacts of 400 condominium and townhome units, so although the product type mix changed to not include any single family detached dwelling units, the analysis was not changed because it was known that impacts identified would be “worst case” scenario. The The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 66 project site also contains 2.25 acres of open plaza and green space that would serve visitors and residents of the project. One vehicular access is provided on Martinelli Drive aligned with the future access of The Village development. Another vehicular driveway is provided on Arnold Drive. The turning movement at this secondary access is assumed to be restricted to right turns only. Project Trip Generation. The trip generation of the proposed project is based upon information compiled by Institute of Transportation Engineers (ITE) in the latest Trip Generation Manual and User’s Guide and Handbook (9th Edition). It is assumed all 35,000 square-feet of restaurant space would comprise of High Turnover (Sit Down) Restaurants (ITE Code 932). This assumption yields higher trip generation than other types of non-fast food restaurants. Therefore, this analysis can accommodate a reasonable mix of restaurants that would ultimately be developed. The project would generate 560 trips during the AM peak hour and 405 trips during the PM peak hour as presented in Table 4.2-4. Table 4.2-4. Project Trip Generation Land Use Category Amount ITE Code Weekday^ AM Peak Hour PM Peak Hour In Out Total In Out Total Trip Generation Rate Restaurants* 932 127.15 5.95 4.86 10.81 5.91 3.94 9.85 Other Retail 820 193.80 3.10 1.90 5.00 7.78 8.42 16.20 Condo/Townhouse 230 5.47 0.07 0.33 0.40 0.32 0.16 0.48 Single Family Detached 210 11.10 0.23 0.68 0.90 0.71 0.41 1.12 Trip Generation Restaurants* 21.0 ksf 932 2,670 125 102 227 124 83 207 Restaurants* 14.0 ksf 932 1,780 83 68 151 83 55 138 Other Retail 5.0 ksf 820 969 16 10 25 39 42 81 Condo/Townhouse 350 du 230 1,913 24 117 141 113 55 168 Single Family 50 du 210 555 11 34 45 35 21 56 Total Project Trips 7,887 259 331 589 394 256 650 Internal Trip Reduction -1,084 -44 -44 -87 Walk Trip to BART Reduction (5%) -340 -13 -17 -29 -18 -11 -28 New External Trips before Pass-by Reduction 6,463 246 314 560 333 201 535 Pass-By Trips High Turn Over Restaurant (5% Weekday; 35% PM) -200 -54 -54 -108 Other Retail (5% Weekday; 30% PM) -44 -11 -11 -22 New External Trips 6,219 246 314 560 267 136 405 Approved Use Trips per Year 2035 Dublin Model 8,075 184 71 255 228 307 535 Year 2035 Cumulative Net Additional Trips -1,856 62 243 305 39 -171 -130 Note: * Based on "High Turnover Sit Down Restaurant" land use category from ITE Source: ITE Trip Generation Manual 9th Edition and User's Guide and Handbook The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 67 There are two line items in the table for restaurants representing the two distinct restaurant spaces. It is assumed that each space would contain a number of different restaurants. The trip generation was calculated using either weighted average rate or regression equation based on recommended procedures in the Trip Generation Handbook. Specifically, trip generation for the restaurant land use were based on average rates; while trip generation for other retail use (ITE 820 Shopping Center), condominiums and townhouses (ITE 230 Residential Condominium/ Townhouse) and single family homes (ITE 210 Single-Family Detached Housing) were calculated using equations. Regardless of the use of rates or equations, the resulting trip generation rates are presented in Table 4.2-4. An adjustment was made to account for internal trips between retail, which includes restaurants and other retail, and residential land uses within the project site. The internal trip adjustment was performed using procedures recommended by ITE for multi-use developments. Internal trips are trips that would occur between different land uses on the same site without accessing the external street system. Therefore, this analysis assumes direct access would be provided between the residential and commercial uses. While it is reasonable to assume a small number of internal trips would occur during the AM peak hour, ITE does not provide any guidance. The exclusion of AM peak hour internal trip adjustments results in a conservative analysis. Further details on the internal trip calculations may be found in Appendix A of Appendix 8.6. Due to the project site’s close proximity to the Dublin/Pleasanton BART station, adjustments were made to account for walk trips between the project and the station. Based upon City staff’s local knowledge, a five-percent trip reduction was assumed for all land use types during all time periods. After adjusting for internal trips and BART walk trips, adjustments were made to account for pass-by trips to the restaurant establishments and other retail land uses. Pass-by trips are trips that are already in the existing traffic stream that passes by the site and that would be attracted to the project when it is completed. These trips are included in the total count of traffic generated by the project and are included in the project driveway volumes, but are not included as new trips at intersections outside of the influence of the project driveways. Since pass-by vehicles on Hacienda Drive have to divert onto Martinelli Way to access the project, the Hacienda Drive and Martinelli Way intersection is considered to be within the influence of the project driveways and is affected by pass-by trips. The amount of a project's pass-by trips varies by type of land uses and the magnitude of existing traffic on the adjacent streets. The pass-by trips assumptions were derived from guidelines in ITE’s Trip Generation Manual User’s Guide and Handbook. However, in collaboration with the City, modifications were made to reflect local conditions. Both modifications, from ITE average of 43 percent to 35 percent for restaurants and from 34 percent to 30 percent for other retail uses, were downward reductions; reflecting a consistently conservative approach in this analysis. Table 4.2- indicates the number of trips projected to be generated by land uses assumed on the project site by Year 2035 in the Dublin Citywide Travel Demand Model. The assumed land uses primarily consist of office and commercial uses. The net difference in trips that would be generated by the proposed project is also provided. The proposed project would result in net The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 68 reductions of daily and PM peak hour trips but a net increase of AM peak hour trips under the Long Term Cumulative conditions. Project Trip Distribution. The distribution of trips associated with the project site was derived from the Dublin Citywide travel demand model as well as trip distribution information for The Village at Dublin (also known as Site 16A, “Persimmon Place”) project8, a 167,200-square-foot retail shopping center located in the southwest quadrant of the Dublin Boulevard/Hacienda Drive intersection. To estimate the trip distribution for retail and service uses including restaurants, the traffic analysis zone within which the project is located was isolated and its peak hour trips were assigned to the network using Year 2035 future year model. From this select zone assignment, the distributions of trips for retail/service uses in both AM and PM peak hours were estimated. The distribution percentages were then compared to those of The Village project and adjusted based on project land use, the study area, and comments from City staff. To estimate the trip distribution for residential land use, the same select zone process was followed for the zone at the northeast corner of Hacienda Drive and Dublin Boulevard. This zone serves as a proxy for the project site as it is the nearest zone where residential housing is the primary use. The estimated trip distribution percentages for residential and retail/service uses to and from selected gateways are graphically presented in Exhibit 4.2-2 and shown in Table 4.2-5 below. Table 4.2-5. Project Trip Distribution AM Peak Hour PM Peak Hour To/From Residential (%) Retail/ Service (%) Residential (%) Retail/ Service (%) Interstate 580 west of Dougherty/Hopyard Interchange 25 5 20 5 Interstate 580 east of Santa Rita/Tassajara Interchange 15 10 11 10 Dublin Blvd. west of Dougherty Rd. 20 10 13 12 Dublin Blvd. east of Tassajara Rd. 1 10 2 12 Hacienda Dr. north of Central Pkwy. 1 3 3 3 Hacienda Dr south of Owens Dr 9 10 10 10 Tassajara Rd north of Central Pkwy 1 7 1 6 Santa Rita Rd south of Pimlico Dr 10 13 10 10 Central Pkwy east of Tassajara Rd 3 3 5 2 Dougherty Rd north of Scarlett Dr 4 10 5 10 Owens Dr southeast of Hacienda Dr 5 12 12 12 Martinelli Wy west of Arnold Rd 5 4 5 5 Hacienda Crossing 1 3 3 3 Total 100 100 100 100 8 TJKM Consultants, “Trip Generation and Distribution for Traffic Impact Study of the Proposed Retail Development at Site 16A,” Technical memorandum to Jerry Haag. January 23, 2013. The Green Draft Supplimental EIR December 2013 ¯ Figure4.4-2 H:\projfile\13410 - Dublin Greens Supplemental EIR\GIS\TripDistribution.mxd - bkorporaal - 4:12 PM 12/23/2013 Coordinate System: WGS 1984 Web Mercator Auxiliary Sphere Trip DistributionThe GreenDublin, California SITE Dublin Blvd Dublin Blvd Arnold Rd Arnold Rd Martinelli Way Dougherty Blvd Scarlett Dr Owens Dr Hacienda Crossing Central Pkwy Central Pkwy Tassajara Rd Hacienda Dr Owens Dr Dublin Blvd 4% 10%(5%) (10%)3% (5%) 3% (2%) 5% (5%) 4% (5%) 1% (3%) 3% (3%) Hacienda Dr 1% 7%(1%) (6%)1% 3%(3%) (3%) 1% (2%) 10% (12%) 25% (20%) 5% (5%)15% (11%) 10% (10%)§¨¦I-580 §¨¦I-580 Legend Residential AM% (PM%) Retail/Services AM% (PM%) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 70 Project Trip Assignment. Project trips were assigned onto the roadway network based on assumed project access points, shortest paths, and availability of alternate paths. The assignments were modified for the Long Term Cumulative scenario to account for new roadways projected to be completed by Year 2035 as described under the Analysis Approach section. The intersection turning movement volumes generated by the project are provided in Part B of SEIR Appendix 8.6. Standards of Significance. In accordance with CEQA, the effects of a project are evaluated to determine whether they will result in a significant adverse impact on the environment. In this analysis, an impact is considered significant if the proposed project would have effects described below. The Eastern Dublin EIR did not identify specific standards for queuing, Routes of Regional Significance, public transit, pedestrian circulation, bicycle facilities and Complete Street Policy. Further, the standards for the remaining criteria have also been modified. The proposed project would have a significant supplemental impact if the following impacts have the potential to occur but were not analyzed in the Eastern Dublin EIR, or are substantially more severe than analyzed in the Eastern Dublin EIR requiring additional mitigations. City of Dublin Intersections. Project impact is considered to be significant if:  The project traffic causes the intersection operations to degrade from an acceptable LOS D or better under no project conditions to LOS E or worse under project conditions; or  If the intersection is already operating below an acceptable threshold (i.e. at LOS E or LOS F) under no project conditions and the project adds 50 or more peak hour trips to the intersection. City of Pleasanton Intersections. Project impact is considered to be significant if:  The project traffic causes the intersection operations to degrade from an acceptable LOS D or better under no project conditions to LOS E or worse under project conditions; or  If the intersection is already operating below an acceptable threshold (i.e. at LOS E or LOS F) under no project conditions, the project adds 10 or more peak hour trips to the intersection. The City of Pleasanton has identified a few exceptions to the LOS standard for the City of Pleasanton gateway intersections9. These intersections may have a LOS below LOS D if there is no reasonable mitigation possible or if the necessary mitigation conflict with other goals and policies of the City of Pleasanton. Queuing. Project impact would be considered significant if: 9 The following study intersections are included as Pleasanton’s gateway intersections: I-580 Eastbound Off-Ramp & Hopyard Road, I-580 Westbound Off-Ramp & Dougherty/Hopyard Road; I-580 Westbound Off-Ramp & Hacienda Dr; I-580 Eastbound Off-Ramp & Hacienda Dr; I-580 Westbound Off-Ramp & Tassajara/Santa Rita Rd; I-580 Eastbound Off-Ramp & Santa Rita Rd/Pimlico Drive; and Ownes Drive & Hacienda Dr. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 71  For the study intersections operating at unacceptable level of service, or at the upper portion of the LOS D delay range (average intersection delay of 45 to 55 seconds): o the project traffic causes the 95th percentile queue in a left turn pocket to extend beyond the turn pocket by 25 feet or more (i.e., the length of one vehicle) into adjacent traffic lanes that operate (i.e., move) separately from the left turn lane; or o If the 95th percentile queue already exceeds that turn pocket length under no project conditions, the project traffic lengthens the queue by 25 feet or more. MTS Arterial and Freeway Segments. Project impact would be considered significant if:  The project traffic cause a MTS network segment to fall from an acceptable LOS E (roadway segment, freeway segment, or freeway ramp v/c ratio of 0.99 or less) under no project conditions to an unacceptable LOS F (v/c of 1.00 or more); or,  If a segment is already operating at LOS F in the No Project case, the v/c ratio increases by more than 0.02 (for example, from 1.03 to 1.06). Routes of Regional Significance. Project impact would be significant if:  The project traffic causes an arterial segment to degrade below LOS D based on HCM 2000 Methodology during a peak hour; or  If an arterial were already at LOS E or worse, the project would cause the volume/capacity ratio to increase by 0.02 or more. Public Transit. Project impact would be significant if:  The demand for public transit service increases above that which local transit operators or agencies could accommodate; or  The project conflicts with adopted policies, plans or programs supporting alternative transportation; or  The project disrupts existing transit service or does not provide amenities necessary to accommodate transit demand. Bicycle Facilities. Project impact would be significant if:  The project disrupts existing bicycle facilities or interferes with planned bicycle facilities, which includes failure to dedicate right-of-way for planned on- and off-street bicycle facilities included in an adopted Bicycle Master Plan or to contribute toward construction of planned bicycle facilities along the project’s frontages; or  The project conflicts or creates inconsistencies with adopted bicycle system plans, guidelines, policies or standards; or, a project fails to provide on-site parking for bicycles as required by the City’s municipal codes. Pedestrian Circulation. Project impact would be significant if:  The project conflicts with adopted policies, plans, or programs supporting pedestrians. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 72 Complete Streets Policy. Project impact would be significant if:  The project conflicts with the City of Dublin’s Complete Streets Policy, including public transit and pedestrian and bicycle circulation accommodations. Traffic Safety. Project impact would be significant if:  The project includes a project design feature, such as a sharp curve or potentially hazardous intersection that would not be consistent with City of Dublin engineering design standards or standards published by the Institute of Transportation Engineers (ITE) or Caltrans. Supplemental Impacts to Intersections. Twenty-five signalized intersections in the project vicinity were selected for analysis. Nine of these intersections were analyzed in the Eastern Dublin EIR.10 The results of the analysis under Existing, Short-Term Cumulative and Long-Term Cumulative conditions are presented in this section. Detailed worksheets are included in Appendix C of SEIR Appendix 8.6. Existing Conditions. The intersection level of service results for Existing and Existing plus Project scenarios are summarized in Table 4.2-6. The results indicate that all but one of the study intersections would operate within acceptable LOS standards during both peak hours with the addition of project traffic. The Dublin Boulevard and Arnold Road intersection would degrade to substandard level in the AM peak hour. With the addition of project traffic, the average delays at some intersections are lower than those under the No Project scenario. The primary reason for such occurrences is that the HCM methodology used for this operations analysis is based on average delay per vehicle at the intersection. Therefore, under certain circumstances, while the total volume increases, the additional vehicles at a particular movement or movements that experience less delay would result in a lower intersection average delay per vehicle. For example, if the project adds trips to a through movement that has lower delay than most of the other traffic movements, the overall intersection average delay would decrease. Table 4.2-6. Intersection Level of Services - Existing Conditions No. Intersection Peak Period Existing no Proj Existing plus Proj Delay LOS Delay LOS 1 Dougherty Rd & Scarlett Dr AM 8.9 A 9.1 A PM 11.2 B 11.6 B 2 Dougherty Rd & Dublin Blvd AM 39.1 D 37.6 D PM 42.6 D 43.7 D 3 I-580 Westbound Off-Ramp & Dougherty Rd^ AM 10.9 B 10.9 B 10 Intersections studied in both the Eastern Dublin EIR and The Green Draft SEIR are: Dougherty Rd/Dublin Blvd (#2), Dougherty Rd/I-580 westbound ramps (#3), Hopyard Rd/I-580 eastbound ramps (#4), Hacienda Dr/Dublin Blvd (#10), Hacienda Dr/I-580 Westbound off-ramp (#12), Hacienda Drive/I-580 Eastbound off-ramp (#13), Tassajara Rd/Dublin Blvd (#16), Tassajara Rd/I-580 westbound off ramp (#17), and Tassajara Rd/I-580 eastbound off ramp (#18). The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 73 No. Intersection Peak Period Existing no Proj Existing plus Proj Delay LOS Delay LOS PM 14.9 B 15.0 B 4 I-580 Eastbound Off-Ramp & Hopyard Rd^ AM 46.9 D 46.9 D PM 19.2 B 19.2 B 5 Dublin Blvd & Scarlett Dr AM 4.7 A 4.8 A PM 10.3 B 10.5 B 6 Dublin Blvd & Camp Parks Blvd AM 16.7 B 16.3 B PM 10.6 B 11.1 B 7 Dublin Blvd & Iron Horse Pkwy AM 9.3 A 9.6 A PM 10.1 B 9.8 A 8 Dublin Blvd & Arnold Rd AM 48.5 D 55.8 E PM 17.6 B 20.6 C 9 Dublin Blvd & Sybase Dr AM 1.5 A 1.4 A PM 2.0 A 2.3 A 10 Dublin Blvd & Hacienda Dr AM 35.3 D 36.7 D PM 29.2 C 30.0 C 11 Hacienda Dr & Martinelli Way AM 14.0 B 18.4 B PM 24.4 C 26.2 C 12 I-580 Westbound Off-Ramp & Hacienda Dr^ AM 7.0 A 7.2 A PM 8.5 A 9.5 A 13 I-580 Eastbound Off-Ramp & Hacienda Dr^ AM 14.6 B 14.8 B PM 12.0 B 13.0 B 14 Dublin Blvd & Hibernia Dr AM 18.0 B 17.7 B PM 24.1 C 24.4 C 15 Dublin Blvd & Myrtle Dr AM 10.4 B 9.9 A PM 14.4 B 14.1 B 16 Dublin Blvd & Tassajara Rd AM 27.0 C 27.4 C PM 32.7 C 33.5 C 17 I-580 Westbound Off-Ramp & Tassajara Rd^ AM 9.0 A 9.0 A PM 9.4 A 9.5 A 18 I-580 Eastbound Off-Ramp & Santa Rita Rd^ AM 27.4 C 27.3 C PM 34.8 C 34.7 C 19 Central Pkwy & Arnold Rd AM 4.3 A 4.3 A PM 4.6 A 4.7 A 20 Central Pkwy & Hacienda Dr AM 15.3 B 16.7 B PM 15.8 B 17.3 B 21 Martinelli Way & Arnold Rd AM 9.1 A 8.8 A PM 6.7 A 6.8 A 22 Central Pkwy & Tassajara Rd AM 12.3 B 12.4 B PM 11.4 B 11.4 B The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 74 No. Intersection Peak Period Existing no Proj Existing plus Proj Delay LOS Delay LOS 23 Martinelli Way & Project Drwy AM Future Intersection 13.0 B PM 29.1 C 24 Dublin Blvd & Glynnis Rose Dr AM 18.3 B 18.9 B PM 18.7 B 19.0 B 25 Owens Dr & Hacienda Dr^ AM 12.8 B 14.2 B PM 26.3 C 28.0 C Notes: ^ denotes intersections under City of Pleasanton jurisdictions. LOS = level of service Delay = Average delay per vehicle in seconds Source: Kittelson & Associates, 2013. Dublin Boulevard/Arnold Road Intersection impact. Construction of the project would result in an impact at the intersection identified below. Supplemental Impact TR-1 (impacts at the Dublin Blvd./Arnold Rd. intersection). The Dublin Boulevard and Arnold Road (#8) intersection would degrade from LOS D to LOS E with the addition of project trips during the AM peak hour under Existing conditions (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-1 (impacts at the Dublin Blvd./Arnold Rd. intersection). The following measures shall be required to improve the level of service to within acceptable standard: a) Add a 75-foot long southbound right turn lane with a 100-foot long taper area; b) Convert the southbound shared through-right lane to through lane; c) Optimize traffic signal split time. Upon implementation of the, the operations would improve to LOS D in the AM peak hour and LOS B in the PM peak hour and the project impact would be less-than-significant. The required improvements are identified in the City’s Transportation Impact Fee (TIF) program for implementation in 2035, but would be required earlier due to this project. Therefore, the project shall make a fair share contribution toward these improvements. Since the improvement is required prior to 2035, the project would pay for the full cost of this improvement prior to the issuance of the first building permit and the costs of the improvement would be credited towards the TIF payment requirement for the development. Short-Term Cumulative Conditions. The intersection level of service results for Short-Term Cumulative and Short-Term Cumulative plus Project scenarios are summarized in Table 4.2-7. The results indicate that all study intersections in the AM peak hour and all but three intersections in the PM peak hour would operate within acceptable LOS standards under Short- Term Cumulative plus Project scenario. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 75 Table 4.2-7. Intersection Level of Services – Short-Term Cumulative Conditions No. Intersection Peak Period Short-Term no Proj Short-Term plus Proj Trips added Delay LOS Delay LOS 1 Dougherty Rd & Scarlett Dr AM 23.3 C 23.8 C PM 24.6 C 25.3 C 2 Dougherty Rd & Dublin Blvd AM 43.0 D 44.1 D PM 56.0 E 58.0 E 133 3 I-580 Westbound Off-Ramp & Dougherty Rd^ AM 11.5 B 11.5 B PM 13.2 B 13.2 B 4 I-580 Eastbound Off-Ramp & Hopyard Rd^ AM 23.8 C 23.8 C PM 33.4 C 33.6 C 5 Dublin Blvd & Scarlett Dr AM 12.8 B 13.2 B PM 14.9 B 15.5 B 6 Dublin Blvd & Camp Parks Blvd AM 31.3 C 31.4 C PM 23.0 C 23.5 C 7 Dublin Blvd & Iron Horse Pkwy AM 16.3 B 15.8 B PM 22.2 C 23.0 C 8 Dublin Blvd & Arnold Rd AM 41.0 D 49.9 D PM 47.4 D 48.9 D 9 Dublin Blvd & Sybase Dr AM 8.9 A 9.3 A PM 9.9 A 9.9 A 10 Dublin Blvd & Hacienda Dr AM 26.7 C 27.0 C PM 54.7 D 62.4 E 11 Hacienda Dr & Martinelli Way AM 19.8 B 22.4 C PM 31.5 C 34.5 C 12 I-580 Westbound Off-Ramp & Hacienda Dr^ AM 7.1 A 7.3 A PM 6.4 A 6.9 A 13 I-580 Eastbound Off-Ramp & Hacienda Dr^ AM 13.0 B 13.2 B PM 12.8 B 13.6 B 14 Dublin Blvd & Hibernia Dr AM 13.3 B 13.3 B PM 21.3 C 21.2 C 15 Dublin Blvd & Myrtle Dr AM 10.7 B 10.7 B PM 18.8 B 18.7 B 16 Dublin Blvd & Tassajara Rd AM 41.3 D 41.9 D PM 61.2 E 62.6 E 71 17 I-580 Westbound Off-Ramp & Tassajara Rd^ AM 10.0 A 10.0 B PM 13.4 B 13.5 B 18 I-580 Eastbound Off-Ramp & Santa Rita Rd^ AM 30.7 C 31.1 C PM 30.6 C 31.0 C 19 Central Pkwy & Arnold Rd AM 7.8 A 7.8 A PM 6.3 A 6.3 A The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 76 No. Intersection Peak Period Short-Term no Proj Short-Term plus Proj Trips added Delay LOS Delay LOS 20 Central Pkwy & Hacienda Dr AM 19.1 B 19.4 B PM 19.2 B 20.2 C 21 Martinelli Way & Arnold Rd AM 10.4 B 10.2 B PM 9.0 A 8.8 A 22 Central Pkwy & Tassajara Rd AM 19.2 B 19.7 B PM 27.3 C 27.8 C 23 Martinelli Way & Project Drwy AM 13.1 B 13.3 B PM 12.5 B 15.1 B 24 Dublin Blvd & Glynnis Rose Dr AM 14.8 B 14.6 B PM 24.6 C 24.7 C 25 Owens Dr & Hacienda Dr^ AM 14.0 B 14.2 B PM 46.9 D 47.9 D Notes: ^ denotes intersections under City of Pleasanton jurisdictions. LOS = Level of service. Delay = Average delay per vehicle in seconds Bold font denotes sub-standard operations Highlight indicates significant impact Source: Kittelson & Associates, 2013. The Dublin Boulevard intersections of Dougherty Road (#2) and Tassajara Road (#16) would already experience sub-standard operations at LOS E without the proposed project. Because the project would add more than 50 trips to each of these intersections in the PM peak hour, the project impacts are considered to be cumulatively significant. Project generated traffic would cause the operations at the intersection of Dublin Boulevard and Hacienda Drive (#10) to degrade from LOS D to LOS E in the PM peak hour. Therefore, the project impact is considered to be significant. As discussed under the Existing Conditions, the reason why the average delays at some intersections with the project-added traffic are lower than those under the No Project scenario is primarily due to the HCM methodology used for the analysis. Dublin Boulevard/Dougherty Road Intersection short-term cumulative impact. Construction of the project would result in an impact at the intersection identified below during the short-term cumulative time frame. Supplemental Impact TR-2 (short-term cumulative impacts at the Dublin Blvd./Dougherty Rd. intersection during the PM peak period). The Dublin Boulevard and Dougherty Road (#2) intersection would operate at LOS E without the proposed project during the PM peak hour under Short-Term Cumulative conditions and implementation of the proposed project would add 50 or more trips to the intersection (significant supplemental impact remains significant and unavoidable). The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 77 Supplemental Mitigation Measure SM-TR-2 (short-term cumulative impacts at the Dublin Blvd./Dougherty Rd. intersection during the PM peak period). The following measures would be required to improve the level of service to within acceptable standard: a) Convert an eastbound right-turn lane to a through lane to provide two left-turn lanes, four through lanes and one right-turn lane on the eastbound approach on Dublin Boulevard; b) Provide a corresponding 300-foot long receiving lane on the east leg with a 360-foot long merging taper area; c) Provide an overlap signal phasing for the westbound right-turn movement and prohibit conflicting southbound U-turn movement; and d) Optimize traffic signal split time. Upon implementation of the above supplemental mitigation measure, the operations would improve to LOS D in both peak hours and the project impact would be less-than-significant. However, the mitigation measures would require widening of the east leg of the intersection to accommodate the additional receiving lane. Such widening of Dublin Boulevard might not be feasible due to right-of-way constraints. Further, it would result in secondary impact to pedestrians as the longer crossing distance would increase the length of time pedestrians are exposed to traffic. Therefore, the project impact would remain significant and unavoidable. Alternative Mitigation Measure SM-TR-2. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The project developer shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, the following elements: a) Appoint Transportation Coordinator to oversee the TDM program developed for the project including program development, information distribution and program implementation. b) Promote and distribute hard copy information quarterly to all employees and residents regarding 511, Ridematch, Guaranteed Ride Home Program, Wheels/LAVTA, Altamont Corridor Express (ACE), BART, shuttles to regional transit, and any car share programs. c) Distribute information quarterly regarding above by email blast to all employees and residents. d) Co-sponsor subarea transportation fair once a year with “The Village” property to the north and/or other developments in the East Dublin area. Invite Wheels, 511.org, and at least two other commute alternative service providers to attend and distribute commute alternative information. e) Provide bicycle parking facilities for 20 percent of commercial car spaces or a number approved by the City beyond the City’s bicycle rack requirement. f) Provide secured bicycle parking (lockers or cages) for employees. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 78 g) Join City Car Share as a “Biz Prime” member and pay for membership of a minimum of five percent employees. h) Implement a BART subsidy program that would provide BART tickets at no cost or subsidized rate to all employees. i) Implement a Commuter Tax Benefit Program or equivalent. Under Section 132(F) of federal tax code, an employer can offer its employees up to $245 per month for qualified transit, vanpool or parking costs. Or, an employer may offer $20 per month for bicycling costs. Full information is available at: http://rideshare.511.org/rewards/tax_benefits.aspx j) Provide preferential parking for carpools and vanpools as part of off-street parking requirements. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve intersection operations can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Dublin Boulevard/Hacienda Drive Intersection short-term cumulative impact. Construction of the project would result in an impact at the intersection identified below during the short-term cumulative time frame. Supplemental Impact TR-3 (short-term cumulative impacts at Dublin Blvd./Hacienda Dr. intersection). The Dublin Boulevard and Hacienda Drive (#10) intersection would degrade from LOS D to LOS E with the addition of project trips during the PM peak hour under Short-Term Cumulative conditions (significant supplemental impact remains significant and unavoidable). Supplemental Mitigation Measure SM-TR-3 (short-term cumulative impacts at Dublin Blvd./Hacienda Dr. intersection). The following measures would be required to improve the level of service to within an acceptable standard: a) Convert an eastbound right-turn lane to a through lane to provide two left-turn lanes, four through lanes and one right-turn lane on the eastbound approach on Dublin Boulevard; b) Provide a corresponding receiving lane on the east leg with a 360-foot long taper area; and c) Optimize traffic signal split time. While this intersection is part of the City’s Traffic Impact Fee (TIF) program, the TIF improvement would not adequately lessen the project impact. Upon implementation of the supplemental mitigation measure, the operations would improve to LOS C in the AM peak hour and LOS D in the PM peak hour and the project impact would be less-than-significant. However, the mitigation measures would require removal/modification of the curb extension at the southeast corner of the intersection and relocating the existing bike lane to accommodate the additional receiving lane, which would adversely impact pedestrians by increasing the crossing distance and exposure to traffic and bicyclists by increasing conflict at The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 79 downstream driveway. Therefore, this mitigation measure may be infeasible and the project impact would remain significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve intersection operations can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Dublin Boulevard/Tassajara Road Intersection short-term cumulative impact. Construction of the project would result in an impact at the intersection identified below during the short-term cumulative time frame. Supplemental Impact TR-4 (short-term cumulative impacts at the Dublin Blvd./Tassajara Rd. intersection). The Dublin Boulevard and Tassajara Road (#16) intersection would operate at LOS E without the proposed project during the PM peak hour under Short- Term Cumulative conditions and implementation of the proposed project would add 50 or more trips to the intersection (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-4 (short--term cumulative impacts at the Dublin Blvd./Tassajara Rd. intersection). The following measures would be required to improve the level of service to within acceptable standard: a) Add an eastbound through lane to provide two left-turn lanes, three through lanes and two right-turn lane on the eastbound approach on Dublin Boulevard; and b) Provide a corresponding receiving lane on the east leg that extends from Tassajara Road to Brannigan Street. Upon implementation of the above supplemental measure, the operation would improve to LOS D. The required mitigation measure for this impact is identified in the City’s Transportation Impact Fee (TIF) program as part of the widening of Dublin Boulevard to six through lanes at this location. The Project shall make a fair share contribution toward these improvements. The TIF fees shall be paid prior to the issuance of the first building permit. Upon the payment, the project impact would be less-than-significant. Long-Term Cumulative Conditions. The intersection level of service results for Long-Term Cumulative and Long-Term Cumulative plus Project scenarios are summarized in Table 4.2-8. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 80 The results indicate the 12 intersections would operate below acceptable standards under Long- Term Cumulative No Project and plus Project scenarios. However, the impact at only the Dublin Boulevard Scarlett Drive (#5) intersection is considered to be cumulatively significant because the project would add 50 or more trips to this Dublin intersection. Therefore, the impact is not considered to be significant. This reduction in average intersection delay could be attributed to two factors. The project would add trips to the southbound through movement, which in general experiences lower delay than other movements at the intersection. As explained under the Existing Conditions section, when trips are added to a movement that experience less delay, the result may be a reduction in the average intersection delay per vehicle. Furthermore, because trips that were projected to be generated by land uses assumed on the project site by the Citywide Model were first removed from the roadway network, the net traffic volume on the southbound left-turn movement with the addition of the project is lower than that of the No Project scenario. Because this movement would require the most green time from the traffic signal, any volume reduction would again reduce the average intersection delay. Table 4.2-8. Intersection Level of Services – Long-Term Cumulative Conditions No. Intersection Peak Period Long-Term no Proj Long-Term plus Proj Trips added Delay LOS Delay LOS 1 Dougherty Rd & Scarlett Dr AM 28.8 C 29.3 C PM 112.1 F 113.8 F 15 2 Dougherty Rd & Dublin Blvd AM 48.7 D 50.4 D PM 77.3 E 78.4 E 15 3 I-580 Westbound Off-Ramp & Dougherty Rd^ AM 12.4 B 12.4 B PM 14.3 B 14.3 B 4 I-580 Eastbound Off-Ramp & Hopyard Rd^ AM 34.7 C 34.7 C PM 21.1 C 21.1 C 5 Dublin Blvd & Scarlett Dr AM 79.0 E 82.9 F 82 PM 76.7 E 78.5 E 26 6 Dublin Blvd & Camp Parks Blvd AM 24.9 C 27.4 C PM 73.1 E 73.1 E 33 7 Dublin Blvd & Iron Horse Pkwy AM 21.5 C 23.8 C PM 181.2 F 183.2 F 27 8 Dublin Blvd & Arnold Rd AM 53.0 D 59.9 E PM 70.8 E 68.5 E 17 9 Dublin Blvd & Sybase Dr AM 5.1 A 5.1 A PM 13.2 B 13.2 B 10 Dublin Blvd & Hacienda Dr AM 31.9 C 31.7 C PM 139.4 F 137.2 F -11 11 Hacienda Dr & Martinelli Way AM 26.7 C 26.8 C PM 64.2 E 63.6 E 29 12 I-580 Westbound Off-Ramp & Hacienda Dr^ AM 8.0 A 8.2 A PM 24.7 C 27.8 C The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 81 No. Intersection Peak Period Long-Term no Proj Long-Term plus Proj Trips added Delay LOS Delay LOS 13 I-580 Eastbound Off-Ramp & Hacienda Dr^ AM 13.2 B 13.2 B PM 17.9 B 18.5 B 14 Dublin Blvd & Hibernia Dr AM 15.9 B 16.1 B PM 36.8 D 36.1 D 15 Dublin Blvd & Myrtle Dr AM 9.8 A 9.8 A PM 77.4 E 75.7 E -21 16 Dublin Blvd & Tassajara Rd AM 53.4 D 54.0 D PM 185.4 F 184.3 F -14 17 I-580 Westbound Off-Ramp & Tassajara Rd^ AM 9.5 A 9.5 A PM 10.7 B 10.6 B 18 I-580 Eastbound Off-Ramp & Santa Rita Rd^ AM 29.8 C 30.8 C PM 29.2 C 29.5 C 19 Central Pkwy & Arnold Rd AM 9.4 A 9.4 A PM 11.1 B 11.1 B 20 Central Pkwy & Hacienda Dr AM 35.1 D 35.5 D PM 18.0 B 19.2 B 21 Martinelli Way & Arnold Rd AM 9.7 A 9.7 A PM 12.3 B 12.4 B 22 Central Pkwy & Tassajara Rd AM 24.6 C 24.9 C PM 35.7 D 36.5 D 23 Martinelli Way & Project Drwy AM 14.1 B 13.9 B PM 15.1 B 15.9 B 24 Dublin Blvd & Glynnis Rose Dr AM 13.7 B 13.6 B PM 57.8 E 56.7 E -19 25 Owens Dr & Hacienda Dr^ AM 96.0 F 93.1 F 41 PM 45.1 D 40.8 D Notes: ^ denotes intersections under City of Pleasanton jurisdictions. LOS = Level of service. Delay = Average delay per vehicle in seconds Bold font denotes sub-standard operations Highlight and trips more than 50 at Dublin intersections or 10 at Pleasanton intersection indicates significant impact Further, the operation at the Dublin Boulevard and Arnold Road intersection (#8) would degrade from LOS D under No Project scenario to LOS E under plus Project scenario in the AM peak hour; thereby resulting in a significant impact. The average delays at some intersections with the project-added traffic are lower than those under the No Project scenario. In addition to the HCM methodology discussed under Existing conditions, the reduced delays can also be attributed to the application of the net change in trips generated by the site to the Year 2035 No Project scenario as a result of the project to obtain the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 82 volumes for the Plus Project scenario. As shown in Table 4.2-4, the project would result in a net negative trip generation in the PM peak hour under Year 2035 conditions. Dublin Boulevard/Scarlett Drive Intersection long-term cumulative impact. Construction of the project would result in an impact at the intersection identified below during the long-term cumulative time period. Supplemental Impact TR-5 (long-term cumulative impact at the Dublin Blvd./Scarlett Dr. intersection). The Dublin Boulevard and Scarlett Drive (#5) intersection would operate at LOS E without the proposed project during the AM peak hour under Long-Term Cumulative conditions and the proposed project would further degrade the operations to LOS F and add 50 or more trips to the intersection (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-5 (long-term cumulative impact at the Dublin Blvd./Scarlett Dr. intersection). At the intersection of Dublin Boulevard and Scarlett Drive, there is a significant impact from the Dublin Crossing project according to the DCSP- DEIR. In the DSCP-DEIR, the recommended measure to mitigate the impacts at the intersection of Scarlett Drive and Dublin Boulevard due to the high rate of pedestrians/bicyclists crossing at Dublin Boulevard is a grade separated crossing. 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 the Dublin Crossings 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. A significant impact has been identified at this intersection in the Dublin Crossing Specific Plan DEIR. The recommended measure is installation of a grade-separated crossing because of the large number of pedestrians and bicyclists crossing Dublin Boulevard at this location. A grade separation would not only minimize conflicts between pedestrians/bicyclists and vehicles, it would also allow more green time, that would otherwise be allotted to pedestrian crossing, to be assigned to through vehicular traffic on Dublin Boulevard. Although engineering or right of way analysis has not 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. With the implementation of a grade-separated pedestrian/bicycle crossing, the levels of service would improve to LOS D during both peak hours under the Long-Term Cumulative plus Project Conditions. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 83 The required mitigation measure for this impact is currently not included in the City’s Transportation Impact Fee (TIF) program. Because the impact is caused by cumulative land use growth in the region, the Project Applicant shall make a fair share contribution toward these improvements prior to occupancy of the last building on the project site. Upon payment, the project impact would be less-than-significant. In the event that the grade separated crossing improvement is not constructed by year 2035, an alternative mitigation would be to eliminate the crosswalk on the east leg of the intersection across Dublin Boulevard, which would also improve the intersection operations to LOS D and mitigate the project impact to a less-than-significant level. However, this alternative measure is undesirable as it would require pedestrians and bicyclists from the Iron Horse Trail to cross three crosswalks rather than one. Therefore, the grade separated crossing is the City’s preferred mitigation. Since the grade separation option has not yet received environmental approval, and to ensure that the impacts are adequately mitigated, the project developer is required to provide their fair-share contribution for the alternative mitigation of removing the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. The Green’s fair share contribution shall be paid prior to the issuance of the first building permit. Dublin Boulevard/Arnold Road Intersection long-term cumulative impact. Construction of the project would result in an impact at the intersection identified below during the long-term cumulative time frame. Supplemental Impact TR-6 (long-term cumulative impact at the Dublin Blvd./Arnold Rd. intersection). The Dublin Boulevard and Arnold Road (#8) intersection would degrade from LOS D to LOS E with the addition of project trips during the AM peak hour under Long-Term Cumulative conditions (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-6 (long-term cumulative impact at the Dublin Blvd./Arnold Rd. intersection). The following measures would be required to improve the level of service to within acceptable standard: a) Modify the traffic signal phasing to provide a protected/ permitted overlap phase for the southbound right-turn movement and prohibit conflicting eastbound U-turn movement; and b) Optimize traffic signal split time. Upon implementation of the above mitigation measure, the operations would improve to LOS D. The required mitigation measure for this impact is currently not included in the City’s Transportation Impact Fee (TIF) program. Because the impact is caused by cumulative land use growth in the region, the project developer shall make a fair share contribution toward these improvements. The fair share contribution shall be paid prior to the issuance of the first building permit. Upon payment, the project impact would be less-than-significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 84 Supplemental Impacts to Intersection Queuing. Ninety-fifth percentile queuing analysis was conducted for the left-turn movements of Dublin intersections operating at unacceptable level of service or at the upper portion of the LOS D delay range. The 95th percentile queue is defined to be the queue length that has only a five percent probability of being exceeded during the analysis time period. The results of the analysis are presented in this section. Detailed worksheets are included in Appendix D. In some instances, the queue length for a particular movement is shorter under the Plus Project scenario than the No Project scenario. This is a result of the way 95th percentile queue length is calculated by the Synchro analysis software tool and does not affect the overall findings. For example, the eastbound left-turn queue length is decreased by four feet under the Existing plus Project scenario as compared to the Existing No Project scenario (Table 4.2-9) where the project would not add any trips to this movement. Existing Conditions. As shown in Table 4.2-9, left-turn queues would exceed turn pocket capacity at the Dublin Boulevard and Arnold Road (#8) intersection under both Existing No Project and Existing plus Project scenarios. However, project traffic would not lengthen the queues by 25 feet or more. Therefore, the project impact is less-than-significant and no mitigation measures are required. Table 4.2-9. Queuing Analysis – Existing Conditions No. Intersection Approach Storage Length (ft) AM Peak Hour PM Peak Hour Queue Length (ft) Queue Length (ft) No Project Plus Project Impact No Project Plus Project Impact 8 Dublin Blvd & Arnold Rd EBL 240 251 247 No 235 237 No WBL 360 18 19 No 13 18 No NBL 160 10 63 No 11 51 No SBL 175 27 27 No 54 56 No Short-Term Cumulative Conditions. As shown in Table 4.2-10, left-turn queues would exceed the length of the turn pockets at all four study intersections under both Short-Term Cumulative No Project and plus Project scenarios. However, project traffic would lengthen the queues by 25 feet or more at only two intersections. The southbound left-turn queue at the Dublin Boulevard and Dougherty Road (#2) intersection would increase by 32 feet in the PM peak hour and the westbound left-turn queue at the Dublin Boulevard and Hacienda Drive (#10) intersection would increase by 27 feet in the AM peak hour and 49 feet in the PM peak hour. Therefore, the project impacts at these two intersections are considered to be significant. Dublin Boulevard/Dougherty Road Intersection short-term cumulative queuing impact. Construction of the project would result in an impact at the intersection identified below during the short-term cumulative time frame. Supplemental Impact TR-7 (short-term cumulative plus project queuing impact at the Dublin Blvd./Dougherty Rd. intersection). The southbound left-turn queue at the Dublin Boulevard and Dougherty Road (#2) intersection would exceed turn pocket capacity The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 85 without the proposed project during the PM peak hour and the proposed project would lengthen the queue by 25 feet or more under Short-Term Cumulative conditions. (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-7 (short-term cumulative plus project queuing impact at the Dublin Blvd./Dougherty Rd. intersection). Optimization of the traffic signal phase time would reduce the 95th percentile queue length for the southbound left turn to 371 feet during the PM peak hour. While the queue length would still exceed the turn pocket storage, the project traffic would lengthen the queue by less than 25 feet. Alternatively, implementation of Supplemental Mitigation Measure TR-2 would also reduce the 95th percentile queue length. However, its implementation would require widening of Dublin Boulevard, which would have right-of-way constraints and impacts to pedestrians; therefore, it is considered to be infeasible. The required mitigation measure is currently not included in the City’s Transportation Impact Fee (TIF) program. Because the impact is caused by cumulative land use growth in the region, the project developer shall make a fair share contribution toward the improvement. The fair share contribution shall be paid prior to the issuance of the first building permit. Upon payment, the project impact would be less-than-significant. Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 86 Ta b l e 4 . 2 - 1 0 . Q u e u i n g A n a l y s i s – S h o rt - T e r m C u m u l a t i v e C o n d i t i o n s No . I n t e r s e c t i o n A p p r o a c h St o r a g e Le n g t h (f t ) AM P e a k H o u r P M P e a k H o u r Qu e u e L e n g t h ( f t ) Q u e u e L e n g t h ( f t ) No P r o j e c t P l u s P r o j e c t I m p a c t N o P r o j e c t P l u s P r o j e c t I m p a c t 2 Du b l i n B l v d & Do u g h e r t y R d EB L 2 4 5 3 5 3 5 N o 1 3 6 1 3 6 N o WB L 5 6 5 1 6 7 1 6 8 N o 3 0 2 3 0 3 N o NB L 4 9 0 2 5 9 2 5 9 N o 3 7 7 3 7 7 N o SB L 2 0 5 31 7 3 3 9 No 35 1 38 3 Yes 8 Du b l i n B l v d & Ar n o l d R d EB L 2 4 0 37 5 3 7 6 No 53 9 5 3 3 No WB L 3 6 0 1 0 8 1 0 9 N o 9 9 1 0 1 N o NB L 1 6 0 2 0 7 4 N o 4 4 7 8 N o SB L 1 7 5 2 6 0 2 6 0 N o 5 1 0 5 1 0 N o 10 Du b l i n B l v d & Ha c i e n d a D r EB L 2 5 0 3 6 3 6 N o 2 3 4 2 3 4 N o WB L 2 5 0 39 8 42 5 Ye s 22 6 27 5 Yes NB L 2 3 5 1 3 1 1 3 1 N o 61 8 6 1 8 No SB L 2 7 0 2 1 2 1 N o 5 2 5 2 N o 16 Du b l i n B l v d & Ta s s a j a r a R d EB L 2 2 0 9 0 9 3 N o 48 8 4 9 4 No WB L 3 5 5 1 5 3 1 5 4 N o 1 0 8 1 0 8 N o NB L 3 2 0 4 2 6 4 3 1 N o 65 9 6 6 4 No SB L 2 5 0 1 9 1 9 N o 5 3 5 3 N o So u r c e : K i t t e l s o n A s s o c i a t e s , 2 0 1 4 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 87 Dublin Boulevard/Hacienda Drive Intersection short-term cumulative queuing impact. Construction of the project would result in an impact at the intersection identified below during the short-term cumulative time frame. Supplemental Impact TR-8 (short-term cumulative plus project queuing impact at the Dublin Blvd./Hacienda Dr. intersection). The westbound left-turn queue at the Dublin Boulevard and Hacienda Drive (#10) intersection would exceed turn pocket capacity without the proposed project during the AM peak hour and implementation of the proposed project would lengthen the queue by 25 feet or more under Short-Term Cumulative conditions. Further, during the PM peak, the project would cause the queue to extend beyond the turn pocket by 25 feet when it would be contained under No Project scenario (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-8 (short-term cumulative plus project queuing impact at the Dublin Blvd./Hacienda Dr. intersection). The traffic signal at this intersection shall be modified to provide additional green time for the westbound left-turn movement by reducing the green time for the eastbound through movement. This will reduce the queue length to 420 feet in the AM peak hour and 270 feet in the PM peak hour. While the queue lengths would still exceed turn pocket capacity, the project traffic would lengthen the queue by less than 25 feet in the AM peak hour and would cause the queue to extend beyond the turn pocket by less than 25 feet in the PM peak hour. Alternatively, implementing Supplemental Mitigation Measure TR-3 would also reduce the queue length to within acceptable threshold in the PM peak hour; however, its implementation would result in adverse effects on pedestrians and bicyclists; thereby not feasible. The required mitigation measures for these impacts are currently not included in the City’s Transportation Impact Fee (TIF) program. Because the impacts are caused by cumulative land use growth in the region, the project developer shall make fair share contributions toward these improvements. The fair share contributions shall be paid prior to the issuance of the first building permit. Upon payment, the project impacts would be less-than-significant. Long-Term Cumulative Conditions. As shown in Table 4.2-11, left-turn queues would exceed the length of the turn pockets at 10 intersections under both Long-Term Cumulative No Project and plus Project scenarios. However, project traffic would lengthen the queues by 25 feet or more at only one intersection. The southbound left-turn queue at the Scarlett Avenue and Dougherty Road (#1) intersection would increase by 31 feet in the PM peak hour. Therefore, the project impact at this intersection is considered to be significant. While the project traffic would cause the northbound left-turn queue at the Martinelli Way and Hacienda Drive (#11) to extend beyond the turn pocket capacity in the PM peak hour, the queue would extend beyond the turn pocket by less than 25 feet. Therefore, the project impact at this intersection is less-than-significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 88 Table 4.2-11. Queuing Analysis – Long-Term Cumulative Conditions No. Intersection Approach Storage Length (ft) AM Peak Hour PM Peak Hour Queue Length (ft) Queue Length (ft) No Project Plus Project Impact No Project Plus Project Impact 1 Dougherty Rd & Scarlett Ave WBL 100 163 163 No 152 151 No NBL 135 39 39 No 105 105 No SBL 100 891 909 No 830 861 Yes 2 Dublin Blvd & Dougherty Rd EBL 245 39 39 No 136 136 No WBL 565 131 129 No 312 314 No NBL 490 261 261 No 520 520 No SBL 205 336 336 No 240 240 No 5 Dublin Blvd & Scarlett Dr EBL 90 14 13 No 10 10 No WBL 200 57 57 No 87 80 No NBL 0 66 66 No 141 141 No SBL 0 682 693 No 488 506 No 6 Dublin Blvd & Camp Parks Blvd EBL 200 209 209 No 177 176 No WBL 250 56 55 No 127 127 No NBL 185 269 269 No 196 196 No SBL 90 109 109 No 225 223 No 7 Dublin Blvd & Iron Horse Pkwy EBL 100 44 43 No 182 179 No WBL 275 108 103 No 123 125 No NBL 0 254 254 No 1042 1042 No SBL 0 155 152 No 108 105 No 8 Dublin Blvd & Arnold Rd EBL 240 246 246 No 142 139 No WBL 360 250 252 No 178 181 No NBL 160 40 102 No 98 97 No SBL 175 286 286 No 483 483 No 10 Dublin Blvd & Hacienda Dr EBL 250 50 50 No 359 359 No WBL 250 138 144 No 239 231 No NBL 235 102 102 No 751 751 No SBL 270 28 28 No 52 52 No 11 Martinelli Way & Hacienda Dr EBL 165 48 97 No 396 415 No WBL 0 80 80 No 241 241 No NBL 345 226 232 No 317 356 No SBL 120 17 17 No 55 55 No 15 Dublin Blvd & Mrtlye Dr EBL 250 22 21 No 34 34 No WBL 225 88 88 No 287 287 No 16 Dublin Blvd & Tassajara Rd EBL 220 174 174 No 1051 1041 No WBL 355 288 288 No 392 392 No NBL 320 567 570 No 1123 1117 No SBL 250 20 20 No 43 43 No 24 Dublin Blvd & Glynnis Rose Dr EBL 250 47 47 No 160 160 No WBL 200 53 53 No 119 119 No The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 89 No. Intersection Approach Storage Length (ft) AM Peak Hour PM Peak Hour Queue Length (ft) Queue Length (ft) No Project Plus Project Impact No Project Plus Project Impact NBL 75 39 39 No 141 139 No SBL 150 70 70 No 46 46 No Scarlett Drive/Dougherty Road Intersection long-term cumulative queuing impact. Construction of the project would result in an impact at the intersection identified below during the long-term cumulative time frame. Supplemental Impact TR-9 (long-term cumulative plus project queuing impact at the Scarlett Dr./Dougherty Rd. intersection). The southbound left-turn queue at the Scarlett Drive and Dougherty Road (#1) intersection would exceed turn pocket capacity without the proposed project during the PM peak hour and implementation of the proposed project would lengthen the queue by 25 feet or more under Long-Term Cumulative conditions (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-9 (long-term cumulative plus project queuing impact at the Scarlett Dr./Dougherty Rd. intersection). The traffic signal phasing at this intersection shall be modified to provide additional green time for the southbound left-turn movement. This will reduce the queue length by 12 feet to 845 feet and to within acceptable threshold. Also, because the impact is caused by cumulative land use growth in the region, the project developer shall make a fair share contribution toward this improvement. The fair share contribution shall be paid prior to the issuance of the first building permit. Upon payment of the fee and traffic signal modification, the project impact would be less-than- significant. Supplemental Impacts to MTS Arterial and Freeway Segment. Because the proposed project would generate at least 100 PM peak hour trips over existing conditions, a traffic analysis is required by the CMP to be conducted on MTS arterial and freeway segments for Year 2020 and Year 2035 conditions using the Countywide Transportation Demand Model. Short-Term Cumulative Conditions. The MTS arterial and freeway segment analysis results for Year 2020 conditions are presented in Table 4.2-12. The results indicate that all study MTS arterial and freeway segments would be within acceptable thresholds. Therefore, the project impacts are not considered to be significant. Long-Term Cumulative Conditions. The MTS arterial and freeway segment analysis results for Year 2035 conditions are presented in Table 4.2-13. The results indicate that, with the exception of Dublin Boulevard east of Hacienda Drive in the AM peak hour and west of Arnold Road in the PM peak hour, all other MTS arterial and freeway segments would be within acceptable thresholds. The two segments of Dublin Boulevard would operate at LOS F under both No Project and plus Project scenarios. However, the volume-to-capacity ratio would not increase by 0.02 or more. Therefore, the project impacts are not considered to be significant. Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 90 Ta b l e 4 . 2 - 1 2 . M T S A r t e r i a l & F r e e w a y s e g m e n ts s h o r t t e r m C u m u la t i v e ( y e a r 2 0 2 0 ) Sh o r t ‐Te r m Cu m u l a t i v e No Pr o j e c t Sh o r t ‐Te r m Cu m u l a t i v e plus Project AM Pe a k Ho u r NB / E B SB / W B NB / E B SB/WB Vo l u m e V/ C LO S Vo l u m e V/ C LO S Vo l u m e V/ C LO S Vo l u m e V/CLOS In t e r s t a t e Hi g h w a y s I‐58 0 ‐ we s t of Ha c i e n d a Dr i v e 8, 1 3 8 0. 6 0 C 8, 2 1 1 0. 7 8 C 8, 1 4 9 0. 6 1 C 8,233 0.79 C I‐58 0 ‐ we s t of Ta s s a j a r a Rd 6, 4 5 0 0. 6 2 B 8, 3 1 4 0. 6 6 C 6, 4 7 6 0. 6 2 B 8,340 0.66 C Ar t e r i a l s Du b l i n Bl v d we s t of Ar n o l d Rd 37 3 0. 1 4 C 2, 3 6 2 0. 8 7 D 41 9 0. 1 5 C 2,414 0.89 D Du b l i n Bl v d ea s t of Ha c i e n d a Dr 19 3 0. 0 7 C 2, 6 7 8 0. 9 9 E 22 0 0. 0 8 C 2,709 1.00 E Ta s s a j a r a Rd no r t h of Du b l i n Bl v d 31 7 0. 1 2 C 1, 5 3 8 0. 5 7 C 32 2 0. 1 2 C 1,543 0.57 C PM Pe a k Ho u r NB / E B SB / W B NB / E B SB/WB Vo l u m e V/ C LO S Vo l u m e V/ C LO S Vo l u m e V/ C LO S Volume V/C LOS In t e r s t a t e Hi g h w a y s I‐58 0 ‐ we s t of Ha c i e n d a Dr i v e 11 , 3 4 7 0. 8 4 D 6, 8 9 9 0. 6 6 C 0. 7 9 0. 7 9 D 6,911 0.66 C I‐58 0 ‐ we s t of Ta s s a j a r a Rd 9, 4 1 1 0. 9 0 D 7, 1 7 8 0. 5 7 B 0. 6 6 0. 6 6 D 7,201 0.57 B Ar t e r i a l s Du b l i n Bl v d we s t of Ar n o l d Rd 1, 4 6 0 0. 5 4 C 2, 3 5 2 0. 8 7 D 0. 8 9 0. 8 9 C 2,391 0.88 D Du b l i n Bl v d ea s t of Ha c i e n d a Dr 2, 0 7 4 0. 7 7 C 63 9 0. 2 4 C 1. 0 0 1. 0 0 C 675 0.25 C Ta s s a j a r a Rd no r t h of Du b l i n Bl v d 1, 5 8 1 0. 5 8 C 67 8 0. 2 5 C 0. 5 7 0. 5 7 C 681 0.25 C So u r c e : K i t t e l s o n & A s s o c i a t e s , 2 0 1 3 Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 91 Ta b l e 4 . 2 - 1 3 . M T S A r t e r i a l & F r e e w a y S e g m en t s - L o n g T e r m C u m u l a t i v e ( Y e a r 2 0 3 5 ) Lo n g ‐Te r m Cu m u l a t i v e No Pr o j e c t Lo n g ‐Te r m Cu m u l a t i v e plus Project AM Pe a k Ho u r NB / E B SB / W B NB / E B SB/WB Vo l u m e V/ C LO S Vo l u m e V/ C LO S Vo l u m e V/ C LO S VolumeV/CLOS In t e r s t a t e Hi g h w a y s I‐58 0 ‐ we s t of Ha c i e n d a Dr i v e 9, 7 9 3 0. 7 3 C 9, 1 9 1 0. 8 8 C 9, 7 9 8 0. 7 3 C 9,198 0.88 C I‐58 0 ‐ we s t of Ta s s a j a r a Rd 7, 8 4 1 0. 7 5 C 8, 9 1 3 0. 7 0 C 7, 8 6 0 0. 7 5 C 8,937 0.71 C Ar t e r i a l s Du b l i n Bl v d we s t of Ar n o l d Rd 1, 5 9 5 0. 5 9 C 2, 5 8 3 0. 9 5 E 1, 6 3 6 0. 6 0 C 2,615 0.97 E Du b l i n Bl v d ea s t of Ha c i e n d a Dr 77 7 0. 2 9 C 3, 0 1 7 1. 1 1 F 80 2 0. 3 0 C 3,047 1.12 F Ta s s a j a r a Rd no r t h of Du b l i n Bl v d 46 5 0. 1 7 C 2, 2 1 9 0. 8 2 D 47 0 0. 1 7 C 2,223 0.82 D PM Pe a k Ho u r NB / E B SB / W B NB / E B SB/WB Vo l u m e V/ C LO S Vo l u m e V/ C LO S Vo l u m e V/ C LO S Volume V/C LOS In t e r s t a t e Hi g h w a y s I‐58 0 ‐ we s t of Ha c i e n d a Dr i v e 11 , 7 4 1 0. 8 7 D 7, 9 5 2 0. 7 6 C 11 , 7 5 6 0. 8 7 D 7,935 0.76 C I‐58 0 ‐ we s t of Ta s s a j a r a Rd 10 , 2 1 7 0. 9 7 D 7, 9 0 9 0. 6 3 C 10 , 2 1 8 0. 9 7 D 7,931 0.63 C Ar t e r i a l s Du b l i n Bl v d we s t of Ar n o l d Rd 2, 6 3 0 0. 9 7 E 3, 1 7 1 1. 1 7 F 2, 6 8 4 0. 9 9 E 3,178 1.17 F Du b l i n Bl v d ea s t of Ha c i e n d a Dr 2, 9 5 5 1. 0 9 F 2, 5 1 7 0. 9 3 D 2, 9 7 2 1. 1 0 F 2,552 0.94 D Ta s s a j a r a Rd no r t h of Du b l i n Bl v d 2, 4 9 8 0. 9 2 D 90 5 0. 3 3 C 2, 5 0 2 0. 9 2 D 906 0.33 C So u r c e : K i t t e l s o n & A s s o c i a t e s , 2 0 1 3 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 92 Supplemental Impacts to Routes of Regional Significance. Arterial level of service analysis was conducted for Routes of Regional Significance in the project area to determine if the project would cause the segment to degrade below LOS D or if the project would cause the volume to capacity ratio to increase by 0.02 or more when the arterial is already operating below LOS D without the project. The volume to capacity ratio was calculated by dividing the volume on the segment by the capacity of the segment. The results of the analysis are presented in this section. Detailed worksheets are included in Appendix E of SEIR Appendix 8.6. Existing Conditions. As shown in Table 4.2-14, arterial segments would operate below LOS D standard under Existing conditions but the project impacts are considered to be significant at only the following roadways:  The eastbound Dublin Boulevard segment between Hacienda Drive and Hibernia Drive would degrade to LOS E with the project in the AM peak hour.  The northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing would operate at LOS F under No Project scenario and the project would cause the volume to capacity ratio to increase by more than 0.02 in the PM peak hour; while the northbound segment between Dublin Boulevard and Central Parkway would degrade to LOS E with the project in the PM peak hour. Dublin Boulevard Between Hacienda Drive and Hibernia roadway segment impact s Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-10 (roadway segment impact along Dublin Blvd. between Hacienda Dr. and Hibernia Dr.). The project would cause the Dublin Boulevard segment between Hacienda Drive and Hibernia Drive to degrade from LOS D to LOS E during the AM peak hour under Existing conditions. The project would only add 30 trips to this segment (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impact on Dublin Boulevard. The deterioration of level service on Dublin Boulevard is caused by long delays at the larger intersections along Dublin Boulevard such as Dougherty Road, Hacienda Drive and Tassajara Road. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed along Dublin Boulevard. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 93 Ta b l e 4 . 2 - 1 4 . A r t e r i a l L O S- E x i s t i n g C o n d i t i o n s Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Do u g h ‐ er t y Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 D D 2 0. 0 0 1 D D 4 0.001 I‐58 0 WB Ra m p s Du b l i n Bl v d 26 7 0 F F 2 0. 0 0 1 F F 4 0.001 Du b l i n Bl v d Sc a r l e t t Dr i v e 26 7 0 B B 23 0. 0 0 9 C C 20 0.007 Do u g h ‐ er t y Rd SB Sc a r l e t t Dr Du b l i n Bl v d 35 6 0 D D 23 0. 0 0 6 D D 29 0.008 Du b l i n Bl v d I‐58 0 WB Ra m p s 35 6 0 D D 0 0. 0 0 0 D D 0 0.000 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 26 7 0 D D 0 0. 0 0 0 C C 0 0.000 Du b l i n Bl v d EB Do u g h e r t y Ro a d Sc a r l e t t Dr i v e 26 7 0 B C 52 0. 0 1 9 C C 80 0.030 Sc a r l e t t Dr De M a r c u s Bl v d 26 7 0 B B 52 0. 0 1 9 C C 80 0.030 De M a r c u s Bl v d Ir o n Ho r s e Pk w y 26 7 0 C C 52 0. 0 1 9 C C 80 0.030 Ir o n Ho r s e Pk w y Ar n o l d Rd . 26 7 0 E E 52 0. 0 1 9 C C 80 0.030 Ar n o l d Rd . Sy b a s e Dr 26 7 0 B B 2 0. 0 0 1 B B 2 0.001 Sy b a s e Dr Ha c i e n d a Dr 26 7 0 C D 2 0. 0 0 1 D D 2 0.001 Ha c i e n d a Dr Hi b e r n i a Dr 26 7 0 D E 30 0. 0 1 1 YE S D D 28 0.010 Hi b e r n i a Dr To y o t a Dr 26 7 0 B B 30 0. 0 1 1 C C 28 0.010 To y o t a Dr Jo h n Mo n e g o Ct 26 7 0 A A 30 0. 0 1 1 B B 28 0.010 Jo h n Mo n e g o Ct Gl y n n i s Ro s e Dr 26 7 0 D D 30 0. 0 1 1 C C 28 0.010 Gl y n n i s Ro s e Dr Ta s s a j a r a Rd 26 7 0 F F 30 0. 0 1 1 F F 28 0.010 Du b l i n Bl v d WB Ta s s a j a r a Rd Gl y n n i s Ro s e Dr 26 7 0 C C 36 0. 0 1 3 D D 42 0.016 Gl y n n i s Ro s e Dr Jo h n Mo n e g o Ct 26 7 0 B B 33 0. 0 1 2 B B 42 0.016 Jo h n Mo n e g o Ct My r t l e Dr 26 7 0 B B 33 0. 0 1 2 C C 42 0.016 My r t l e Dr Hi b e r n i a Dr 26 7 0 C C 33 0. 0 1 2 F F 42 0.016 Hi b e r n i a Dr Ha c i e n d a Dr 26 7 0 E E 32 0. 0 1 2 C D 43 0.016 Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 94 Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Du b l i n Bl v d WB Ha c i e n d a Dr Sy b a s e Dr 26 7 0 B B 2 0. 0 0 1 B B 3 0.001 Sy b a s e Dr Ar n o l d Rd . 26 7 0 E F 2 0. 0 0 1 C C 3 0.001 Ar n o l d Rd . Ir o n Ho r s e Pk w y 26 7 0 C C 73 0. 0 2 7 C C 52 0.019 Ir o n Ho r s e Pk w y Ca m p Pa r k s 26 7 0 D D 73 0. 0 2 7 C D 52 0.019 Ca m p Pa r k s Sc a r l e t t Dr i v e 26 7 0 B B 73 0. 0 2 7 B B 52 0.019 Sc a r l e t t Dr i v e Do u g h e r t y Rd 26 7 0 D D 73 0. 0 2 7 E E 53 0.020 Ha c i e n ‐ da Dr NB Ow e n s Dr i v e I‐58 0 EB Ra m p s 35 6 0 D D 51 0. 0 1 4 D D 83 0.023 I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 C C 68 0. 0 2 5 C D 121 0.045 I‐58 0 WB Ra m p s Ha c i e n d a Cr o s s i n g s 26 7 0 D D 12 0 0. 0 4 5 F F 190 0.071 YES Ha c i e n d a Cr o s s i n g s Du b l i n Bl v d 35 6 0 F F 48 0. 0 1 3 F F 43 0.012 Du b l i n Bl v d Ce n t r a l Pk w y 17 8 0 D D 21 0. 0 1 2 D E 17 0.010 YES Ha c i e n ‐ da Dr SB Ce n t r a l Pk w y Du b l i n Bl v d 25 4 0 F F 20 0. 0 0 8 F F 27 0.011 Du b l i n Bl v d Ma r t i n e l l i Wa y 33 9 0 E E 50 0. 0 1 5 E E 66 0.019 Ma r t i n e l l i Wa y I‐58 0 WB Ra m p s 33 9 0 C C 12 6 0. 0 3 7 C C 99 0.029 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 D D 58 0. 0 2 3 C C 53 0.021 I‐58 0 EB Ra m p s Ow e n s Dr i v e 33 9 0 C C 58 0. 0 1 7 C C 53 0.016 Ta s s a ‐ ja r a Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 16 9 0 B B 3 0. 0 0 2 C C 4 0.002 I‐58 0 WB Ra m p s Du b l i n Bl v d 25 4 0 D D 6 0. 0 0 2 E E 8 0.003 Du b l i n Bl v d Ce n t r a l Pk w y 16 9 0 C C 5 0. 0 0 3 C C 4 0.002 Ta s s a ‐ ja r a Rd SB Ce n t r a l Pk w y Du b l i n Bl v d 25 4 0 C C 5 0. 0 0 2 D D 6 0.002 Du b l i n Bl v d I‐58 0 WB Ra m p s 33 9 0 C C 6 0. 0 0 2 C C 4 0.001 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 D D 7 0. 0 0 3 D D 4 0.002 So u r c e : K i t t e l s o n A s s o c i a t e s , 2 0 1 4 The Green Project/ Draft Supplemental EIR City of Dublin Page 95 The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Hacienda Drive Between Dublin Boulevard and Central Parkway roadway segment impact. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-11 (roadway segment impact along Hacienda Dr. between Dublin Blvd. and Central Pkwy.). The project would cause the northbound Hacienda Drive segment of Dublin Boulevard to Central Parkway to degrade from LOS D to LOS E. Project traffic would also cause the volume to capacity ratio of the northbound Hacienda Drive segment between I-580 westbound ramp to Hacienda Crossings to increase by 0.071 (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impacts on Hacienda Drive. The deterioration of level service is primarily due to the long cycle length required to facilitate pedestrian crossings of Hacienda Drive at the Dublin Boulevard intersection as well as the signal priority given to Dublin Boulevard; hence holding back traffic on Hacienda Drive. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition pedestrian crossings may help improve the travel speed on Hacienda Drive. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the project developer shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The project developer shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. The Green Project/ Draft Supplemental EIR City of Dublin Page 96 Short-Term Cumulative Conditions. As shown in Table 4.2-15, 19 arterial segments would operate below LOS D standard under Short-Term Cumulative conditions but the project impacts are considered to be significant at only the following four segments:  The eastbound Dublin Boulevard segment between DeMarcus Boulevard and Iron Horse Parkway would operate at LOS E under No Project scenario and the project would cause the volume to capacity ratio to increase by more than 0.02 in the PM peak hour.  The westbound Dublin Boulevard segment between Scarlett Drive and Dougherty Road would operate at LOS E under No Project scenario and the project would cause the volume to capacity ratio to increase by more than 0.02 in the AM peak hour.  The northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing would operate at LOS E in the AM peak hour and LOS F in the PM peak hour under No Project scenario and the project would cause the volume to capacity ratio to increase by more than 0.02.  The northbound Tassajara Road segment between Dublin Boulevard and Central Parkway would degrade to LOS E with the project in the PM peak hour. Dublin Boulevard Between DeMarcus Boulevard and the Iron Horse Parkway roadway segment impact. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-12 (roadway segment impact along Dublin Blvd. between DeMarcus Blvd. and Iron Horse Pkwy.) The project would cause the volume to capacity ratio along the eastbound Dublin Boulevard segment between DeMarcus Boulevard and Iron Horse Parkway to increase by 0.03 where it would operate at LOS E in the PM peak hour under Short-Term Cumulative No Project scenario. (significant supplemental impact remains significant and unavoidable). Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 97 Ta b l e 4 . 2 - 1 5 . A r t e r i a l LO S - S h o r t - T e r m C u m u l a t i v e C o n d i t i o n s Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Do u g h ‐ er t y Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 C C 2 0. 0 0 1 D D 4 0.001 I‐58 0 WB Ra m p s Du b l i n Bl v d 26 7 0 F F 2 0. 0 0 1 F F 4 0.001 Du b l i n Bl v d Sc a r l e t t Dr i v e 26 7 0 C C 23 0. 0 0 9 D D 20 0.007 Do u g h ‐ er t y Rd SB Sc a r l e t t Dr Du b l i n Bl v d 26 7 0 D D 23 0. 0 0 9 E E 29 0.011 Du b l i n Bl v d I‐58 0 WB Ra m p s 35 6 0 D D 0 0. 0 0 0 D D 0 0.000 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 26 7 0 D D 0 0. 0 0 0 D D 0 0.000 Du b l i n Bl v d EB Do u g h e r t y Ro a d Sc a r l e t t Dr i v e 26 7 0 C C 52 0. 0 1 9 C C 80 0.030 Sc a r l e t t Dr De M a r c u s Bl v d 26 7 0 D D 52 0. 0 1 9 D D 80 0.030 De M a r c u s Bl v d Ir o n Ho r s e Pk w y 26 7 0 E E 52 0. 0 1 9 E E 80 0.030 YES Ir o n Ho r s e Pk w y Ar n o l d Rd . 26 7 0 D D 52 0. 0 1 9 C D 80 0.030 Ar n o l d Rd . Sy b a s e Dr 26 7 0 C C 2 0. 0 0 1 B B 2 0.001 Sy b a s e Dr Ha c i e n d a Dr 26 7 0 E E 2 0. 0 0 1 F F 2 0.001 Ha c i e n d a Dr Hi b e r n i a Dr 26 7 0 C C 30 0. 0 1 1 E E 28 0.010 Hi b e r n i a Dr To y o t a Dr 26 7 0 D D 30 0. 0 1 1 D D 28 0.010 To y o t a Dr Jo h n Mo n e g o Ct 26 7 0 B B 30 0. 0 1 1 C C 28 0.010 Jo h n Mo n e g o Ct Gl y n n i s Ro s e Dr 26 7 0 D D 30 0. 0 1 1 F F 28 0.010 Gl y n n i s Ro s e Dr Ta s s a j a r a Rd 26 7 0 F F 30 0. 0 1 1 F F 28 0.010 Du b l i n Bl v d WB Ta s s a j a r a Rd Gl y n n i s Ro s e Dr 26 7 0 C C 33 0. 0 1 2 E E 42 0.016 Gl y n n i s Ro s e Dr Jo h n Mo n e g o Ct 26 7 0 B B 33 0. 0 1 2 D D 42 0.016 Jo h n Mo n e g o Ct My r t l e Dr 26 7 0 B B 33 0. 0 1 2 D D 42 0.016 My r t l e Dr Hi b e r n i a Dr 26 7 0 C C 33 0. 0 1 2 C C 42 0.016 Hi b e r n i a Dr Ha c i e n d a Dr 26 7 0 C C 32 0. 0 1 2 E E 43 0.016 Du b l i n Bl v d WB Ha c i e n d a Dr Sy b a s e Dr 26 7 0 C C 2 0. 0 0 1 B B 3 0.001 Sy b a s e Dr Ar n o l d Rd . 26 7 0 E F 2 0. 0 0 1 E E 3 0.001 Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 98 Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Ar n o l d Rd . Ir o n Ho r s e Pk w y 26 7 0 C C 73 0. 0 2 7 C C 52 0.019 Ir o n Ho r s e Pk w y Ca m p Pa r k s 26 7 0 D D 73 0. 0 2 7 D D 52 0.019 Ca m p Pa r k s Sc a r l e t t Dr i v e 26 7 0 C C 73 0. 0 2 7 C C 52 0.019 Sc a r l e t t Dr i v e Do u g h e r t y Rd 26 7 0 E E 73 0. 0 2 7 YE S D D 53 0.020 Ha c i e n ‐ da Dr NB Ow e n s Dr i v e I‐58 0 EB Ra m p s 35 6 0 D D 51 0. 0 1 4 D D 83 0.023 I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 C C 68 0. 0 2 5 C C 121 0.045 I‐58 0 WB Ra m p s Ha c i e n d a Cr o s s i n g s 26 7 0 E E 12 0 0. 0 4 5 YE S F F 190 0.071 YES Ha c i e n d a Cr o s s i n g s Du b l i n Bl v d 26 7 0 F F 48 0. 0 1 8 F F 43 0.016 Du b l i n Bl v d Ce n t r a l Pk w y 17 8 0 D D 21 0. 0 1 2 D D 17 0.010 Ha c i e n ‐ da Dr SB Ce n t r a l Pk w y Du b l i n Bl v d 25 4 0 F F 20 0. 0 0 8 F F 27 0.011 Du b l i n Bl v d Ma r t i n e l l i Wa y 33 9 0 F F 50 0. 0 1 5 F F 66 0.019 Ma r t i n e l l i Wa y I‐58 0 WB Ra m p s 33 9 0 D D 12 6 0. 0 3 7 C C 99 0.029 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 D D 58 0. 0 2 3 C C 53 0.021 I‐58 0 EB Ra m p s Ow e n s Dr i v e 33 9 0 D D 58 0. 0 1 7 D D 53 0.016 Ta s s a ‐ ja r a Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 16 9 0 D D 3 0. 0 0 2 E E 4 0.002 I‐58 0 WB Ra m p s Du b l i n Bl v d 25 4 0 E E 6 0. 0 0 2 F F 8 0.003 Du b l i n Bl v d Ce n t r a l Pk w y 16 9 0 C C 5 0. 0 0 3 D E 4 0.002 YES Ta s s a ‐ ja r a Rd SB Ce n t r a l Pk w y Du b l i n Bl v d 33 9 0 F F 5 0. 0 0 1 F F 6 0.002 Du b l i n Bl v d I‐58 0 WB Ra m p s 33 9 0 C C 6 0. 0 0 2 C C 4 0.001 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 D D 7 0. 0 0 3 D D 4 0.002 So u r c e : K i t t e l s o n A s s o c i a t e s , 2 0 1 4 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 99 No feasible mitigation measure has been identified for the project impacts on Dublin Boulevard. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Dublin Boulevard. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The project developer shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Dublin Boulevard Between Scarlett Drive and Dougherty Road roadway segment impact. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-13 (roadway segment impact along Dublin Blvd. between Scarlett Dr. and Dougherty Rd.) The project would cause the volume to capacity ratio along the westbound Dublin Boulevard segment between Scarlett Drive and Dougherty Road to increase by 0.027 where it would operate at LOS E in the AM peak hour under Short-Term Cumulative No Project scenario (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impact on Dublin Boulevard. The deterioration of level service on Dublin Boulevard is caused by long delays at the larger intersections along Dublin Boulevard such as Dougherty Road, Hacienda Drive and Tassajara Road. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Dublin Boulevard. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 100 include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Hacienda Drive between the I-580 Westbound Ramps and Hacienda Crossings roadway segment impact. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-14 (under short-term cumulative No Project conditions, roadway segment impact along northbound Hacienda Dr. between the I-580 westbound ramps and Hacienda Crossing). The project would cause the volume to capacity ratio along the northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing to increase by 0.045 where it would operate at LOS E in the AM peak hour and by 0.071 where it would operate at LOS F in the PM peak hour under Short-Term Cumulative No Project scenario (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impacts on Hacienda Drive. The deterioration of level service is primarily due to delay resulting from long cycle length necessary to facilitate pedestrian crossings across Hacienda Drive at the Dublin Boulevard intersection as well as the signal priority given to Dublin Boulevard; hence holding back traffic on Hacienda Drive. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Hacienda Drive. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The project developer shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 101 Tassajara Road between Dublin Boulevard and Central Parkway. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-15 (under short-term cumulative conditions, roadway segment impact along northbound Tassajara Rd. between Dublin Blvd. and Central Pkwy.). The project would cause the northbound Tassajara Road segment between Dublin Boulevard and Central Parkway to degrade from LOS D to LOS E during the PM peak hour under Short-Term Cumulative conditions. While the project would only add 4 trips to this segment, this impact is considered to be significant (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impact on Tassajara Road. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Tassajara Road. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Long-Term Cumulative Conditions. As shown in Table 4.2-16, most of the study arterial segments would operate below LOS D standard under Long-Term Cumulative conditions but the project impacts are considered to be significant at only the following roadways: Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 102 Ta b l e 4 . 2 - 1 6 . A r t e r i a l L O S - L o n g - T er m C u m u l a t i v e C o n d i t i o n s Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Do u g h ‐ er t y Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 C C 2 0. 0 0 1 D D 0 0.000 I‐58 0 WB Ra m p s Du b l i n Bl v d 26 7 0 F F 2 0. 0 0 1 F F ‐2 ‐0.001 Du b l i n Bl v d Sc a r l e t t Dr i v e 26 7 0 F F 0 0. 0 0 0 F F 0 0.000 Do u g h ‐ er t y Rd SB Sc a r l e t t Dr Du b l i n Bl v d 26 7 0 F F 0 0. 0 0 0 F F ‐1 0.000 Du b l i n Bl v d I‐58 0 WB Ra m p s 35 6 0 E E 0 0. 0 0 0 D D 0 0.000 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 26 7 0 F F 0 0. 0 0 0 D D ‐2 ‐0.001 Du b l i n Bl v d EB Do u g h e r t y Ro a d Sc a r l e t t Dr i v e 26 7 0 C C 12 0. 0 0 4 E E 16 0.006 Sc a r l e t t Dr De M a r c u s Bl v d 26 7 0 C C 20 0. 0 0 7 D D 32 0.012 De M a r c u s Bl v d Ir o n Ho r s e Pk w y 26 7 0 D D 19 0. 0 0 7 F F 30 0.011 Ir o n Ho r s e Pk w y Ar n o l d Rd . 26 7 0 D D 17 0. 0 0 6 C C 29 0.011 Ar n o l d Rd . Sy b a s e Dr 26 7 0 B B 2 0. 0 0 1 C C ‐2 ‐0.001 Sy b a s e Dr Ha c i e n d a Dr 26 7 0 E E 2 0. 0 0 1 F F 0 0.000 Ha c i e n d a Dr Hi b e r n i a Dr 26 7 0 B B 21 0. 0 0 8 F F ‐21 ‐0.008 Hi b e r n i a Dr To y o t a Dr 26 7 0 C C 22 0. 0 0 8 F F ‐19 ‐0.007 To y o t a Dr Jo h n Mo n e g o Ct 26 7 0 A A 22 0. 0 0 8 C C ‐18 ‐0.007 Jo h n Mo n e g o Ct Gl y n n i s Ro s e Dr 26 7 0 C C 22 0. 0 0 8 F F ‐18 ‐0.007 Gl y n n i s Ro s e Dr Ta s s a j a r a Rd 35 6 0 F F 22 0. 0 0 6 F F ‐16 ‐0.004 Du b l i n Bl v d WB Ta s s a j a r a Rd Gl y n n i s Ro s e Dr 26 7 0 D D 16 0. 0 0 6 F F 1 0.000 Gl y n n i s Ro s e Dr Jo h n Mo n e g o Ct 26 7 0 B B 15 0. 0 0 6 D D ‐2 ‐0.001 Jo h n Mo n e g o Ct My r t l e Dr 26 7 0 C C 15 0. 0 0 6 C C ‐2 ‐0.001 My r t l e Dr Hi b e r n i a Dr 26 7 0 D D 14 0. 0 0 5 D D ‐3 ‐0.001 Hi b e r n i a Dr Ha c i e n d a Dr 35 6 0 E E 13 0. 0 0 4 F F ‐4 ‐0.001 Du b l i n WB Ha c i e n d a Dr Sy b a s e Dr 26 7 0 C C 2 0. 0 0 1 D D 3 0.001 Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 103 Di r Fr o m To Ca p a ‐ ci t y AM Pe a k Ho u r PM Peak Hour LO S Pr o j e c t Tr i p s V/ C In c r e a s e Im ‐ pa c t LO S Project Trips V/C Increase Im‐pact No Pr o j e c t Pl u s Pr o j e c t No Pr o j e c t Pl u s Pr o j e c t Bl v d Sy b a s e Dr Ar n o l d Rd . 26 7 0 F F 2 0. 0 0 1 F F 2 0.001 Ar n o l d Rd . Ir o n Ho r s e Pk w y 26 7 0 C D 60 0. 0 2 2 F F 0 0.000 Ir o n Ho r s e Pk w y Ca m p Pa r k s 26 7 0 E E 61 0. 0 2 3 YE S F F 3 0.001 Ca m p Pa r k s Sc a r l e t t Dr i v e 26 7 0 F F 61 0. 0 2 3 YE S D D ‐6 ‐0.002 Sc a r l e t t Dr i v e Do u g h e r t y Rd 26 7 0 D D 41 0. 0 1 5 E E 2 0.001 Ha c i e n ‐ da Dr NB Ow e n s Dr i v e I‐58 0 EB Ra m p s 35 6 0 D D 7 0. 0 0 2 E E 13 0.004 I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 26 7 0 C C ‐ 9 ‐ 0. 0 0 3 E E 25 0.009 I‐58 0 WB Ra m p s Ha c i e n d a Cr o s s i n g s 26 7 0 E E ‐55 ‐ 0. 0 2 1 F F 54 0.020 YES Ha c i e n d a Cr o s s i n g s Du b l i n Bl v d 26 7 0 F F 37 0. 0 1 4 F F ‐22 ‐0.008 Du b l i n Bl v d Ce n t r a l Pk w y 17 8 0 F F 19 0. 0 1 1 D D ‐1 ‐0.001 Ha c i e n ‐ da Dr SB Ce n t r a l Pk w y Du b l i n Bl v d 25 4 0 F F 7 0. 0 0 3 F F 15 0.006 Du b l i n Bl v d Ma r t i n e l l i Wa y 33 9 0 F F 17 0. 0 0 5 F F 8 0.002 Ma r t i n e l l i Wa y I‐58 0 WB Ra m p s 33 9 0 D D 90 0. 0 2 7 C C ‐38 ‐0.011 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 D D 33 0. 0 1 3 C C ‐36 ‐0.014 I‐58 0 EB Ra m p s Ow e n s Dr i v e 33 9 0 E E 35 0. 0 1 0 D D ‐36 ‐0.011 Ta s s a ‐ ja r a Rd NB I‐58 0 EB Ra m p s I‐58 0 WB Ra m p s 16 9 0 C C 3 0. 0 0 2 D D ‐5 ‐0.003 I‐58 0 WB Ra m p s Du b l i n Bl v d 33 9 0 E E 4 0. 0 0 1 F F ‐8 ‐0.002 Du b l i n Bl v d Ce n t r a l Pk w y 25 4 0 D D 0 0. 0 0 0 D D ‐7 ‐0.003 Ta s s a ‐ ja r a Rd SB Ce n t r a l Pk w y Du b l i n Bl v d 33 9 0 F F ‐2 ‐ 0. 0 0 1 F F ‐8 ‐0.002 Du b l i n Bl v d I‐58 0 WB Ra m p s 33 9 0 C C 6 0. 0 0 2 C C 1 0.000 I‐58 0 WB Ra m p s I‐58 0 EB Ra m p s 25 4 0 E E 7 0. 0 0 3 D D 2 0.001 So u r c e : K i t t l e s o n & A s s o c i a t e s ( 2 0 1 4 ) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 104  The westbound Dublin Boulevard segments between Iron Horse Parkway and Scarlett Drive would operate at LOS E and LOS F in the AM peak hour under No project scenario and the project would cause the volume to capacity ratio to increase by more than 0.02.  The northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing would operate at LOS F in the PM peak hour under No Project scenario and the project would cause the volume to capacity ratio to increase by 0.02. Dublin Boulevard between Iron Horse Parkway and Camp Parks roadway segment impact. Construction of the project would result in an impact at the roadway segment identified below. Supplemental Impact TR-16 (under long-term cumulative conditions, roadway segment impact along westbound Dublin Blvd. between Iron Horse Pkwy. and Camp Parks). The project would cause the volume to capacity ratios along the westbound Dublin Boulevard segments between Iron Horse Parkway and Camp Parks where it would operate at LOS E and between Camp Parks and Scarlett Drive where it would operate at LOS F in the AM peak hour under Long-Term Cumulative No Project scenario to increase by 0.023 (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impacts on Dublin Boulevard. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Dublin Boulevard. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Dublin Boulevard between Hacienda Drive and Hibernia roadway segment impacts Construction of the project would result in an impact along the following roadway segment. Supplemental Impact TR-17 (under long-term cumulative No Project conditions, roadway segment impact along northbound Hacienda Dr. between the I-580 westbound ramps and Hacienda Crossing). The project would cause the volume to capacity ratio along the northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 105 Crossing to increase by 0.02 during the PM peak hour where it would operate at LOS F under Long-Term Cumulative No Project scenario (significant supplemental impact remains significant and unavoidable). No feasible mitigation measure has been identified for the project impact on Hacienda Drive. The deterioration of level service is primarily due to long cycle length required to facilitate pedestrian crossings across Hacienda Drive at the Dublin Boulevard intersection as well as the signal priority given to Dublin Boulevard; hence holding back traffic on Hacienda Drive. Optimization of the traffic signals in the network, reduction of the number of turn and through lanes, or prohibition of pedestrian crossings may help improve the travel speed on Hacienda Drive. However, such measures would potentially result in secondary impacts related to pedestrian mobility and intersection level of service. Therefore, the project impact remains significant and unavoidable. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The Project shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, elements described under Alternative Supplemental Mitigation Measure SM-TR-2. However, it cannot be ascertained that the potential benefits of the TDM measures to reduce traffic volumes and improve speed along the corridor can reduce the project impact to less-than- significant. Therefore, the project impact would remain significant and unavoidable. Supplemental Impacts to Public Transit. The demand for public transit service resulting from the implementation of the proposed project was estimated using the Alameda Countywide Travel Demand Model (2035 forecast) and project trip generation. The Countywide Model indicates the following mode shares for trips to and from the project site:  59% Drive Alone  30% Shared Ride  1% Transit  10% Bike/Walk Applying these percentages to the project trip generation, after converting from vehicle trip generation to total person trip generation, the project would generate approximately eight additional transit trips during the AM and PM peak hours. Given the current peak hour boardings on key LAVTA bus routes, the transit trips added by the project would represent a seven percent increase in peak hour boardings compared to existing bus service. If it is conservatively assumed that most or all of the project boardings would be on the highest ridership route, Route 12, the resulting passenger load would be well within seated capacity. Therefore, the project impact would be less-than-significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 106 The Alameda County travel model may not fully represent the additional transit use induced by the project’s close proximity to BART. The vehicle trip generation for the project incorporates a five percent reduction for BART use. This would correspond to 40 to 50 BART passengers during peak hours. The added passengers are within BART’s ridership forecast of approximately 6,000 annual increase in weekday ridership per year and consistent with BART’s future service and capacity plans.11 Therefore the project would not require changes in BART’s planned service levels. Therefore, the project impact would be less-than-significant and no mitigation measures are required. The Eastern Dublin EIR concluded that the GPA/SP Project would create a need for substantial expansion of transit systems, resulting in a significant impact. The impact of the project on BART and LAVTA bus service was adequately analyzed in the Eastern Dublin EIR. The project is subject to the mitigation measures in the Eastern Dublin EIR as applicable. Supplemental Impacts to Bicycle Facilities. As stated in the Environmental Setting section, the City of Dublin Bikeway Master Plan proposes a number of new bicycle facilities along roadways in the study area, including bike lanes on Arnold Road directly adjacent to the project site, and on Martinelli Way and Altamirano Road immediately west of the project site. The proposed project would not interfere with implementation of the planned bike lanes or disrupt existing bikeways in the project area. Since the project’s limited access driveway on Arnold Road would only serve as a secondary access, any potential conflict with bicyclists is anticipated to be minimal. Driveway access design should ensure sight distance is adequate to allow a clear view of bicyclists for both inbound and outbound vehicles. Because detailed plans containing such information as the proposed number of on-site bicycle parking space and driveway design are not available at the time of this analysis, the project impact is potentially significant. Supplemental Impact TR-18 (impacts to bicycle facilities). The project could conflict with adopted bicycle plans, guidelines, policies or standards (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-18 (impacts to bicycle facilities). Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with applicable City guidelines, polices and standards for review and approval by the City. Upon implementation of this measure, the project impact would be less-than-significant. The project is subject to the mitigation measures in the Eastern Dublin EIR as applicable, and the project plans are expected to incorporate such mitigations subject to review and approval by the City. Supplemental Pedestrian Impacts. The project would result in an increase in walk trips in the project area by visitors and residents. While the project is not anticipated to result in unsafe condition for pedestrians or conflict with adopted policies, plans, or program, detailed plans containing such information as pedestrian improvements along the frontage and within the 11 Bay Area Rapid Transit District Short-Range Transit Plan, FY08 through FY17, 2007. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 107 project site are not available at the time of this analysis, the project impact is potentially significant. Supplemental Impact TR-19 (impacts to pedestrian facilities). The project could conflict with adopted policies, plans or program supporting pedestrians (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-19 (impacts to pedestrian facilities). Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with applicable City guidelines, polices and standards for review and approval by the City. Upon implementation of this measure, the project impact would be less-than-significant. The project is subject to the mitigation measures in the Eastern Dublin EIR as applicable, and the project plans are expected to incorporate such mitigations subject to review and approval by the City. Supplemental Impacts to Complete Street Policy. A detailed site plan was not available for review at the time of this analysis. However, a preliminary drawing indicates short residential blocks with walkways between buildings that would facilitate pedestrian circulation within the project site. It also shows curb extensions throughout the site that would help calm traffic in both the retail commercial area near the main entry and the residential portions of the site thereby creating a safer environment for pedestrians and bicyclists. The Project may consider the following features that would further accommodate pedestrians, bicyclists and transit riders:  Ensure direct pedestrian access points are provided onto Hacienda Drive, Arnold Road and Martinelli Way in addition to the proposed vehicular access locations in order to facilitate convenient access for pedestrians and transit riders. This is particularly important in the southwestern portion through which residents and visitors might access the BART station along the frontage road and in the southeast portion where no driveway is proposed along Hacienda Drive.  Provide secure long-term bicycle storage for employees of the retail commercial land use in addition to the required short-term bicycle parking spaces. Supplemental Impact TR-20 (impacts to pedestrian Complete Streets policies). The project could conflict with adopted policies, plans or program supporting pedestrians, including the City’s Complete Streets policies (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-20 (impacts to pedestrian Complete Streets policies). Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with the City’s Complete Street Policy and design standards for review and approval by the City. Upon implementation of this measure, the project impact would be less-than-significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 108 Supplemental Impacts to Traffic Safety. A detailed design plan is not available at the time of this analysis; therefore, it is uncertain if the project would include features that would directly or indirectly cause or expose roadway users to a permanent and substantial transportation hazard. Supplemental Impact TR-21 (traffic safety impacts). The project could include design features that would not be consistent with the City’s engineering design standards or standards published by the ITE or Caltrans (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-21 (traffic safety impacts). Prior to issuance of any permit for the project, the project developer shall submit design plans that are consistent with the City’s Complete Street Policy for review and approval by the City. All designs shall conform to City standards. (significant supplemental impact and mitigation required). Upon implementation of this measure, the project impact would be less-than-significant. Supplemental Impacts during Construction. The project would be constructed over a period of time. Construction would include numerous disruptions to the transportation system in and around the project area, which may include temporary street closures and sidewalk closures. Heavy vehicles would access the project area and would need to be staged for construction. Short-term construction activities and staging of construction vehicles and equipment would result in degraded roadway operations. Supplemental Impact TR-22 (construction period impacts). Project construction activities such as the import of the fill material and delivery of materials could result in impacts to vehicle, bicycle and pedestrian access in and around the project area (significant supplemental impact and mitigation required). Supplemental Mitigation Measure SM-TR-22 (construction period impacts). Before issuance of grading permits for the project, the project developer shall prepare a detailed Traffic Management Plan that will be subject to review and approval by the City of Dublin, LAVTA, and local emergency service providers, including the City of Dublin Fire Prevention Bureau and the City of Dublin Police Services Department. The plan shall ensure maintenance of acceptable operating conditions on local roadways and transit routes. At a minimum, the plan shall include: a) The number of truck trips, time, and day of street closures b) Time of day of arrival and departure of trucks c) Limitations on the size and type of trucks; provision of a staging area with a limitation on the number of trucks that can be waiting d) Provision of a truck circulation pattern e) Provision of a driveway access plan to maintain safe vehicular, pedestrian, and bicycle movements (e.g., steel plates, minimum distances of open trenches, and private vehicle pick up and drop off areas) f) Safe and efficient access routes for emergency vehicles The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 109 g) Efficient and convenient transit routes h) Manual traffic control when necessary i) Proper advance warning and posted signage concerning street closures j) Provisions for pedestrian safety and access Upon implementation of this measure, the project impact would be less-than-significant. Cumulative Impacts. Cumulative traffic and transportation impacts are addressed above. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 110 4.3 COMMUNITY SERVICES AND FACILITIES INTRODUCTION This section of the DSEIR analyzes potential supplemental impacts with respect to schools and parks and recreation services. ENVIRONMENTAL SETTING Schools. Public education facilities within the City of Dublin are provided by the Dublin Unified School District (DUSD). The District operates six elementary schools, two middle schools, and one high school. A continuation high school and a K-3 parent participation program is also operated by the DUSD. Schools that would be affected by the proposed project include: • Dougherty Elementary, 5301 Hibernia • Fallon Middle School, 3601 Kohnen Way • Dublin High School, 8151 Village Parkway • Valley High School, 6901 York Drive Elementary schools located near the project site are operating near or at planned enrollment capacity. The District may modify local school enrollment boundaries to optimize attendance at each individual school. Table 3.3-1 summarizes current enrollment and optimum capacity for affected local public schools. Table 4.3-1. Current Public School Enrollment v. Capacity School Facility 2013/14 Enrollment School Capacity Dougherty Elementary 805 933 Fallon Middle School 1,110 1,232 Dublin High 1,737 2,232 Valley High 80 360 Source: Dublin Unified School District, 2013 In addition to the public schools identified above, a number of private schools are located in Dublin and the larger Tri-Valley area. In 1998 Senate Bill 50 became effective as a result of the California voters approving Proposition 1A. SB 50 establishes an amount of allowable developer fees, which is known as a Level 1 fee. The statute allows a school district to exceed the base Level 1 fees and impose higher Level 2 fees if the district 1) is determined to be eligible for State funding; 2) adopts a school facilities needs analysis; and 3) satisfies other criteria of SB 50. Statutory provisions establish a maximum amount of Level 2 fees for all projects within a particular school district. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 111 The statute also allows a district to impose Level 3 fees if Level 2 fees have been imposed and state funding is no longer available. Currently, the DUSD collects Level 2 fees from developers. Parks. The City of Dublin operates and extensive local parks system as well as a comprehensive array of recreation programs within local parks and elsewhere in the community. No neighborhood or community parks are located on the project site. Parks closest to the project site include Emerald Glen Park, consisting of approximately 48 acres of parkland with ball courts, tennis courts, picnic areas, turf areas, restrooms and similar facilities. Emerald Glen Park is located on the north side of Central Parkway west of Tassajara Road. Another nearby facility is the Dublin Sports Grounds located adjacent to the Dublin Civic Center on the south side of Dublin Boulevard at Sierra Court. This facility offers baseball and football/soccer fields, a play area, picnicking, turf areas and restrooms. The City recently approved and is designing a passive linear park adjacent to the Iron Horse Trail north of Amador Valley Boulevard. Regional park and recreational facilities are provided by the East Bay Regional Park District. The City of Dublin Parks and Recreation Master Plan (May 2006) recommends that the City provide a total of 5 acres of parks per 1,000 residents, which includes 1.5 acres of neighborhood parkland and 3.5 acres of community parkland. In lieu of providing new parkland to the City, project builders and developers may elect to pay a Community Facility Fee that includes a component for “in-lieu” park fees to satisfy park dedication requirements. REGULATORY FRAMEWORK The following regulatory programs and policies regulate provision of parks and schools in Dublin. Dublin General Plan. The Open Space Element of the Dublin General Plan contains the following policies regarding open space within the Primary and Extended Planning Areas of the community. • Expand park area throughout the Primary and Extended Planning Areas to serve new development (Guiding Policy A.1). • Maintain and improve existing outdoor facilities in conformance with the recommendations of the City’s parks and Recreation Master Plan (Guiding Policy A.2). • Acquire and improve parklands in conformance with the standards and policies in the City’s Parks and Recreation Master Plan (Implementing Policy B.1) • Provide active parks and facilities which are adequate o meet citywide needs for open space, cultural and sports facilities, as the local needs of the Eastern Extended Planning Area (Guiding Policy A.1) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 112 • Require land dedication and improvements in parks designated in the General Plan for the eastern Extended Planning Area and based on a standard of 5 net acres per 1,000 residents. Collect in-lieu park fees as required by City policies (Implementing Policy B.1). The following General Plan policy deals with provision of public schools. • Require provision of school sites through dedication and/or developer fees. Establish appropriate mechanism for funding development of school facilities. (Implementing Policy B.1). Eastern Dublin Specific Plan. The Eastern Dublin Specific Plan contains he following goals and policies relative to public schools. • To provide school facilities adequate to meet the community’s need to quality education (Goal 8.1). • Ensure that adequate school facilities are available prior to development in Eastern Dublin, to the extent permitted by law. Dublin Parks and Recreation Master Plan. The Parks and Recreation Master Plan, updated in 2006, has been adopted to establishing goals, long-term policies and standards to guide the City in the acquisition, development and management of Dublin Park’s and Recreation facilities for a twenty-year period. State of California SB 50. This act (also known as the School Facilities Act of 1998) provides for state of California funding of school facilities under certain criteria,; however, it also limits the amount of impact fees that local school districts could charge. IMPACTS AND MITIGATION MEASURES FROM PREVIOUS EIRs Eastern Dublin EIR. Applicable mitigation measures contained in Eastern Dublin EIR addressing fire and police protection include: • Mitigation Measure 3.4/29.0: Ensure, as a part of the approval process, that each new development provide its fair share of planned open space, parklands and trail corridors. • Mitigation Measure 3.4/31.0: Calculate and assess in-lieu park fees based on the City’s parkland dedication ordinance. Credit towards parkland dedication requirements will only be given for level or gently sloping areas suitable for active recreation use. IKEA SEIR. The topic of community facilities was not analyzed in the IKEA SEIR. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 113 Development on the project site will be required to pay the City of Dublin Public Facilities fee, which includes park development fees. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES This section identifies potentially significant impacts to schools and parks. Significance criteria. A proposed project would be considered to result in a significant impact if there is a demonstrable need for new or expanded parks or school facilities to serve the proposed project, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratio or other performance objectives of the public service provider. Supplemental school impacts. No residences currently exist on the site that generate school children that need to be served by the Dublin Unified School District. Approval and construction of the proposed project would add up to 400 residences. According to the DUSD, 127 students would be generated at full project build-out. This is shown on Table 4.3-2, below. Table 4.3-2. DUSD Student Generation Rates Grade Level/School Students Generated K-5/Dougherty Elementary 69 6-8/Wells or Fallon Middle School 27 9-12/Dublin High or Valley High School 31 Total Students Generated 127 Source: DUSD, 2014 Under SB 50, payment of the permitted school fees is deemed to be full and complete mitigation of school facilities impacts for CEQA and other purposes. SB 50 limits the amount of fees a school district may legally impose on new development. DUSD imposes these fees on new development; therefore, there would be no supplemental impacts related to funding of school facilities. Supplemental park impacts. Approval and construction of the project would result in up to 400 attached dwellings on The Green site. Based on information contained in Section 4.1 of the DSEIR (Population and Housing), build-out of these dwellings would generate approximately 1,080 residents on the site that would require local park space. The proposed project would also result in new commercial development that would attract visitors, shoppers and employees to the site that may use local park facilities. The current project proposal does not include the provision of any public park space, although the site is proposed to contain approximately 2.25 acres of open gathering spaces for both the commercial uses and private residences. According to the City of Dublin’s Park and Community Facilities Director (Paul McCreary, 8/23/13), this portion of Dublin is considered underserved by neighborhood parkland. Pursuant to the City’s park dedication ratio of 5 acres of parks per 1,000 residents, the proposed project would require the dedication of 5 acres of local parkland to the City of Dublin. This The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 114 amount is not proposed to be dedicated to the City. Since this portion of Dublin is considered underserved for neighborhood parks, this would be a significant supplemental impact. Supplemental Impact Park-1 (lack of adequate local parkland). Build-out of the proposed project would require the dedication of 5 acres of local parkland on the project site. The proposed project provides no public park space (significant supplemental impact and mitigation required). Adherence to the following supplemental measure would mitigate the above impact to a less- than-significant level by requiring a combination of dedicating a minimum 2-acre neighborhood square and partial payment of Community Facility fees. Supplemental Mitigation Measure SM-Park-1 (lack of adequate local parkland). As part of the first final subdivision map for the project, the project developer(s) shall dedicate a minimum two-acre Neighborhood Square to the City of Dublin. The size, configuration and location of the Neighborhood Square shall be approved by the Dublin Parks and Community Services Department. Project developer(s) shall satisfy remaining local park requirements by paying fees to the City of Dublin prior to issuance of building permits. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 115 4.4 PUBLIC UTILITIES – SEWER & WATER Sewer, water, storm drainage, electricity and natural gas, and solid waste were analyzed in Chapter 3.4 and Chapter 3.5 of the Eastern Dublin EIR. Based on the analysis in the NOP, only sewer and water required supplemental analysis under CEQA standards. WASTEWATER Wastewater (referred to as “Sewer” in the Eastern Dublin EIR) Collection, Treatment and Disposal impacts were analyzed in Chapter 3.5, Sewer, Water, Storm Drainage, of the Eastern Dublin EIR. This supplemental analysis is provided in accordance with CEQA standards. ENVIRONMENTAL SETTING The Eastern Dublin EIR examined wastewater collection, treatment, and disposal issues for the Project area. DSRSD, which owns and operates a treatment plant in Pleasanton, was identified as the future provider of collection and treatment services for the Project area with disposal provided by the Livermore Amador Valley Water Management Agency (LAVWMA), a joint powers authority composed of Livermore, Pleasanton and DSRSD. LAVWMA operates a pipeline that carries treated wastewater over the Dublin grade and into East Bay Dischargers Authority (EBDA) facilities for eventual discharge into San Francisco Bay. The Eastern Dublin EIR identified the Tri-Valley Wastewater Authority (TWA), a joint powers authority which, at that time, was planning for disposal capacity beyond that which could be provided by LAVWMA. TWA was at that date proposing to transport untreated wastewater through the Central Contra Costa Sanitary District collection system for treatment and disposal in Martinez. In 1994 TWA transferred authority over acquiring/constructing additional disposal capacity to LAVWMA. LAVWMA, as described below, subsequently chose to construct improvements to its existing disposal pipeline and the construction of a second disposal pipeline over the Dublin Grade for discharge into San Francisco Bay using EBDA facilities (1994 Addendum to the Eastern Dublin EIR). Most recently, LAVWMA have confirmed that wastewater disposal pipeline from the Tri-Valley area to the East Bay Dischargers outfall facility has been constructed and is fully operational. The pipeline has been designed and constructed to accommodate maximum General Plan build- out of all of the participating communities in the Tri-Valley area including Dublin (source: Ed Cunningham, LAVMWA Executive Director 8/25/13). Regulatory framework The EDSP established Goals, Policies and Action Programs to guide cooperation between the City, the DSRSD and the project developers in producing new wastewater collection, treatment and disposal facilities. These policies included coordinating with DSRSD on the expansion of their recycled water service boundary, ensuring availability of wastewater treatment and disposal capacity by working with DSRSD and requiring developers to get “will-serve” letters from DSRSD prior to City grading permit approval. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 116 IMPACTS AND MITIGATION MEASURES FROM PREVIOUS EIRs The Eastern Dublin EIR identified numerous potential impacts related to wastewater. The lack of a collection system was identified as a significant impact and Mitigation Measures 3.5/1.0-5.0, generally preventing development until such facilities are constructed by developers, were adopted to mitigate this impact to a less than significant level. Potential growth inducing impacts of pipeline construction were mitigated by preventing the construction of facilities greater than those required for the GPA/SP project. Inadequate treatment plant capacity in DSRSD's treatment plan and inadequate disposal capacity were identified as significant impacts: both were mitigated to a less-than-significant level by mitigation measures requiring developers to obtain "will-serve" letters from DSRSD prior to issuance of grading permits; DSRSD will not issue a "will-serve" letter in the absence of treatment plant and disposal capacity. An additional mitigation measure requires Eastern Dublin developers to prepare detailed wastewater capacity investigations. Other mitigation measures supported DSRSD, TWA and, subsequently, LAVWMA in efforts to expand treatment and disposal capacity (along with recycled water projects). Other impacts to the planned TWA disposal systems and the recycled water systems related to noise, odors and potential spills also were identified and mitigated to levels of insignificance. The impact of the use of recycled water on the main groundwater basin was identified as a potential impact and a mitigation measure requiring coordination of recycled water projects with Zone 7's salt mitigation program mitigated this impact to insignificance. Even with these mitigation measures, several impacts related to increased energy use for the sewer systems (Impact 3.5/F,H,V) and growth-inducement (Impact 3.5/T) remained significant and unavoidable. Upon approval of the GPA/SP, the City adopted a Statement of Overriding Considerations for these impacts (Resolution No. 53-93). Wastewater issues were not analyzed in the IKEA Supplemental EIR. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES The project includes a change in the type of development proposed on the site from large commercial development evaluated in the Eastern Dublin EIR and IKEA SEIR to a mixed-use residential and commercial project. This may create potentially significant impacts to wastewater treatment and disposal capacity. Significance Criteria. Implementation of the project would be considered to have a significant wastewater impact if, in addition to the impacts previously analyzed in the Eastern Dublin EIR, it were to:  exceed wastewater treatment standards of the applicable Regional Water Quality Control Board; or  require the construction of new wastewater treatment facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects. Supplemental impacts. The following project level impacts are analyzed in this section of the DSEIR: the adequacy of the wastewater collection, wastewater treatment capacity and treatment and the adequacy of wastewater disposal systems. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 117 Estimated wastewater generation. DSRSD staff estimated the generation of wastewater from The Green project as compared to the approved use of 305,000 sq. ft. of General Commercial that would occur under currently approved development plans. This is shown on Table 4.4-1, below. The table shows that the project would generate an additional estimated 50,885 gallons of wastewater per day at build-out over the amount of wastewater expected to be generated by the approved General Commercial use. Table 4.4-1. The Green Project-Estimated Daily Wastewater Demand (gallons/day) Land Use Amount Use Factor Wastewater (GPD) Approved Use General Commercial Estimated Wastewater Demand 305,000 sq. ft. 0.1 gpd/sq ft 30,500 gpd Proposed Uses Retail/Commercial 5000 sq. ft. 0.1 gpd/sq ft 500 gpd Restaurant 35,000 sq. ft. 0.1 gpd/sq ft 3,500 gpd Residential Condominium/ Townhouse 400 DU 120 gpd/DU 48,000 gpd Total Estimated Project Wastewater Demand52,000 gpd Difference between Approved Project and Proposed Project +21,500 gpd with Proposed Project Source: Stan Kolodzie, DSRSD, 4/25/2014 Wastewater treatment capacity. DSRSD operates a wastewater treatment plant that serves customers from both DSRSD and the City of Pleasanton. Raw wastewater from Dublin, including the project site, is treated at the District’s regional treatment plant which is located north of Stoneridge Drive in Pleasanton. The regional plant has been designed and maintained Regional Water Quality Board approvals to treat 17.0 million gallons of wastewater (mgd) per day. Inflow on untreated wastewater into the plant averages 11.0 mgd in the dry season (source: S. Kolodzie, DSRSD, 10/24/13). Therefore, the District has adequate wastewater treatment capacity at the regional plant to accommodate the estimated 81,385 gallons of wastewater that would be generated per day. No new or expanded wastewater facilities would be needed to serve the proposed project nor would the amount of additional wastewater flows exceed the Regional Water Board’s approved limit of the DSRSD wastewater treatment plan. The amount of additional wastewater would result in a less-than-significant impact on a project and cumulative level. Wastewater disposal capacity. LAVWMA, a joint powers agency, was created in 1974 by the cities of Livermore and Pleasanton and the DSRSD to dispose of treated wastewater in the Tri- Valley area. Effluent from the wastewater treatment plants operated by the City of Livermore and DSRSD is conveyed to LAVWMA regulating reservoirs in Pleasanton and then via a 16- The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 118 mile export pipeline to the East Bay Dischargers Authority (EBDA) pipeline in San Leandro. The EBDA pipeline conveys the effluent for ultimate discharge to San Francisco Bay. The Livermore-Amador Valley Water Management Agency (LAVWMA) pipeline that disposes of treated wastewater into San Francisco Bay via East Bay Dischargers facilities may have inadequate capacity to accommodate the increased amount of treated wastewater generated by the proposed The Green project. The export pipeline has been expanded in size in 1983, 1987 and 2003. It has a current maximum capacity of 41.2 million gallons per day and was designed to accommodate the maximum build- out of the General Plans from all participating LAVWMA agencies. Currently, average daily flows in the export pipeline are far below the design capacity of pipe and more than adequate wastewater disposal capacity exists for The Green project. The project would not require the construction of new wastewater disposal facilities or the expansion of existing facilities. This impact would be less-than-significant on a project level. Similarly, the proposed project would be less-than-significant on a cumulative level, since no new or expanded wastewater facilities would be required. The area of cumulative analysis is the DSRSD boundary, which includes the City of Dublin and surrounding jurisdictions in the Tri- Valley area. WATER Water supply and distribution impacts were analyzed in Chapter 3.5, Sewer, Water, and Storm Drainage, of the Eastern Dublin EIR and in an addendum dated August 22, 1994. This supplemental analysis is provided in accordance with CEQA standards. It also evaluates these issues in light of the project’s revised land uses. ENVIRONMENTAL SETTING Domestic and recycled water is supplied to The Green site by the Dublin San Ramon Services District (DSRSD or District). DSRSD obtains its potable water supplies from Zone 7 of the Alameda County Flood Control and Water Conservation District (Zone 7), which wholesales treated local surface water, groundwater, and imported water from the State Water Project to retail water agencies. Recycled water is provided from DSRSD’s wastewater treatment plant in Pleasanton and meets the State of California Title 22 requirements for unrestricted reuse. Water Supply and Infrastructure. The City of Dublin and the Dougherty valley portion of San Ramon are supplied by water provided by DSRSD, headquartered in Dublin. DSRSD owns and operates a water distribution system, including transmission lines, pump stations, reservoirs, and water turnouts. DSRSD obtains its potable water from Zone 7. Treated potable water is supplied to DSRSD by Zone 7 via four pipelines owned by Zone 7: Cross Valley Pipeline, Santa Rita-Dougherty Pipeline, Santa Rita Pipeline, and Dougherty Pipeline. This water is supplied through five turnouts. Turnout No. 1 is located at the intersection of Dougherty Road and the Iron Horse Trail. Turnout No. 2 is located at the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 119 intersection of Amador Valley Boulevard and Stagecoach Road. The third turnout is in the vicinity of Arnold Drive and Altamirano Road. The fourth turnout is located on Friesman Road, south of I-580, adjacent to Eastern Dublin. A fifth, seldom used, emergency turnout is located on 4th Street within Camp Parks. Water received from the turnouts is distributed throughout DSRSD’s water service area, including Dublin, via a grid of underground water transmission lines, delivering water to residences, businesses, and other customers within the District’s service area. Such water transmission facilities are present in Arnold Road, which is adjacent to the Project site. Both Zone 7 and DSRSD impose fees on development to assist in funding each District’s respective water infrastructure and pumping and storage of water supplies. DSRSD currently charges connection and other fees on new development within the District’s service area. Fees are used for construction of planned water system capital improvements, including storage, pumping, transmission, and ongoing system water maintenance and improvements. The District also provides recycled water for irrigation and other non-potable uses. DSRSD has been aggressive in encouraging and requiring the use of recycled water. In November 2010, DSRSD added to its regulatory code Section 3.20.110, Duty to Connect – Recycled Water. This section requires new development to use recycled water for irrigation except under specific conditions. Compliance is required if an applicant is to receive potable water service from DSRSD. The proposed Project will use recycled water for all outdoor water use, including irrigation, and the recycled water line will be extended down Martinelli Way to serve the site. DSRSD also provides financial incentives for using recycled water. Developers do not pay Zone 7 water connection fees for their connections to DSRSD’s recycled water system and recycled water rates are 11 percent less than potable water rates. New development within the Eastern Dublin area has been required to install dual water systems and a recycled water distribution system has been installed within the major streets, including Dublin Boulevard. A recycled water pipeline is present in Martinelli Way near the Project site, and recycled water is available to serve the Project once that line is extended as will be conditioned by the project approvals. The City of Dublin also has Water-Efficient Landscaping Regulations that reduce water use for irrigation (Dublin Municipal Code Chapter 8.88). DSRSD’s most recent Urban Water Management Plan was adopted by the DSRSD Board of Directors in June 2011(DSRSD UWMP). It is based on Zone 7’s 2010 Urban Water Management Plan (Zone 7 UWMP). Both the DSRSD UWMP and Zone 7 UWMP include a projection of future potable and recycled water supply and demand through the year 2035. The DSRSD UWMP and Zone 7 UWMP are incorporated herein by reference and are available for public review at the City Public Works Department during normal business hours. The analysis of water supply and demand for the DSRSD service area relies on these most recent UWMPs as permitted under CEQA. Potable Water. By contract, Zone 7 is DSRSD’s sole potable water supplier. The current contract between Zone 7 and DSRSD was entered into on August 23, 1994 and has a 30-year term. The current contract is expected to be renewed beyond 2024, with substantially similar provisions (source Stan Kolodzie, 4/14/14). Zone 7 uses a combination of water supplies and The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 120 water storage facilities to meet DSRSD’s water demands. Zone 7’s water supply sources include the following: State Water Project (SWP), Table A and Yuba accord, Byron-Bethany Irrigation District (BBID), and local runoff from Arroyo Del Valle (which is stored in Lake Del Valle). Zone 7 also uses the local underground aquifer basin as storage and another source of water (the Main Basin). The DSRSD UWMP estimates the amount of supply available from Zone 7 in the short-term and long-term, beginning in 2015 and ending in 2035. The UWMP analyzes available supply during normal water years, a single dry water year, and multiple dry water years. It includes projected water supply under two scenarios: (1) with Zone 7 planned projects and programs implemented; and (2) with Zone 7 planned projects and programs not implemented. In the DSRSD UWMP, all of Zone 7’s customers, including the water retailers in the Livermore-Amador Valley, are assumed to proportionally share the impacts of the shortages during dry water years. Recycled Water. DSRSD’s water supply contract with Zone 7 allows it to pursue recycled water opportunities. DSRSD currently produces and distributes recycled water in its service area. DSRSD owns and operates recycled water treatment facilities (RWTF) at its wastewater treatment plant (WWTP). To maximize the beneficial use of recycled water, DSRSD and East Bay Municipal Utility District formed a joint powers authority, DSRSD-EBMUD Recycled Water Authority (DERWA), in 1995. DERWA operates the recycled water transmission system that supplies recycled water from DSRSD’s RWTF to portions of DSRSD’s and EBMUD’s service areas. DSRSD expects to increase DERWA deliveries as recycled water demands in its service area and EBMUD’s service area increase. The total wastewater volume collected and treated at the WWTP includes wastewater from both DSRSD’s service area and the City of Pleasanton, which DSRSD treats by contract. The total volume of recycled water produced includes recycled water for DERWA deliveries to both DSRSD and EBMUD. The DSRSD UWMP projects the following amounts of recycled water supply available for its service area in the following timeframes: 2015 2,500 area feet per year (afy) 2020 3,800 afy 2025 4,400 afy 2030 4,500 afy 3035 4,600 afy Overall, the DSRSD water supply projections for 2015 – 2035 are set forth in Table 4.4-1, below. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 121 Table 4.4-2. DSRSD Water Supply Water Source 2015 2020 2015 2030 2015 Water Purchased from Zone 7 Water Agency, af/yr(a) 12,255 15,355 16,855 17,655 17,855 Groundwater Pumped by Zone 7 on DSRSD’s Behalf, af/yr(a) 645 645 645 645 645 DSRSD Recycled Water, af/yr(a) 2,500 3,800 4,400 4,500 4,600 Total, af/yr 15,400 19,800 21,900 22,800 23,100 Source: DSRSD, 2014 Reliability of Water Supply to Meet Demand. Water supply reliability is discussed in detail in the DSRSD UWMP. Maximizing water supply resources and minimizing dependence on imported water are important strategic goals of Zone 7 and DSRSD. DSRSD’s potable water supply comes solely from Zone 7, which depends on imported surface water for over 80 percent of its supply. To minimize demand for this imported water, DSRSD has implemented an extensive water conservation program and plans to maintain its efforts, including continuing to expand the use of recycled water within its service area. Potable Water Supply Reliability. Zone 7 Reliability Policy The most recent reliability policy was adopted by the Zone 7 Board of Directors on October 17, 2012, and includes the following level of service goals: 1. Meet 85 percent of M&I water demands 99 percent of the time; 2. Meet 100 percent of M&I water demands 90 percent of the time; and 3. Meet at least 80 percent of the maximum month demand during an extended unplanned outage. This reliability policy is different than the policy in place at time of adoption of the Zone 7 UWMP and DSRSD UWMP. Previously, Zone 7’s Reliability Policy was to meet 100% of its customers’ potable water need under specified hydrologic conditions. The 2012 Reliability Policy lowered the 100% reliability standard. However, it does not change the amount of water supply available to the retailers under Normal, Single Dry, or Multiple Dry water years. Rather, it provides Zone 7 with the additional flexibility and time necessary to evaluate, develop, and implement cost effective solutions necessary to allow Zone 7 to continue to provide a reliable, high quality water supply to its customers in the face of any future uncertainty in water supply. Changing the third goal to reflect a prolonged outage on the maximum month instead of the maximum day should allow Zone 7 to develop more cost effective solutions to major, prolonged outages, while also providing the time necessary to communicate with and obtain a response from its customers (the water retailers). The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 122 Zone 7 Water Supply Reliability As part of Zone 7 UWMP, the projected water supplies during Normal, Single Dry, and Multiple Dry water years were compared with its customers’ demand scenarios, both without potential water conservation (“high water demand”) and with potential water conservation (“low water demand”) associated with the Water Conservation Act of 2009. The results of this analysis are excerpted from Section 16 of Zone 7 UWMP and summarized below. Under Normal water years in the short-term, through 2015, Zone 7 has sufficient supply to meet projected water demands, with or without additional conservation measures, assuming Zone 7 can successfully implement planned programs and projects. Note that a portion of the water demand during a Normal water year includes the storage of water supply for use during dry water years. The maximum potential shortage in the long-term, based on the high water demand scenario, could be as high as 10,500 afy between 2020 and 2030 if Zone 7 cannot implement planned programs and projects. Under Single Dry years, Zone 7 does not expect shortages through 2030 with the implementation of planned programs and projects. The maximum potential shortage, based on the high water demand scenario, could be as high as 8,700 afy between 2020 and 2030 if Zone 7 cannot implement planned programs and projects. The maximum potential shortage during Single Dry water years is lower than that for Normal water years, because Zone 7 makes use of its stored water distributed between the local groundwater basin and the banking programs in Kern County. Finally, under Multiple Dry water years, planned programs and projects have similarly been designed to prevent any shortages. Zone 7’s analysis indicates that, without such programs and projects, shortages of up to 36,000 afy can be expected under a Multiple Dry water year scenario ending in 2030, based on the high water demand scenario. Zone 7 also is aggressively developing a strategy via its 2011 Water Supply Evaluation (2011 WSE) for providing a reliable, high quality water supply that will meet the needs of the Livermore Amador Valley through buildout of adopted general plans. Zone 7 2013 Annual Review Zone 7 prepares annual reviews on water supply and programs. The most recent annual review was completed in 2013 (2013 Annual Review). The conclusions of the 2013 Annual Review are summarized below and incorporated herein by reference. The 2013 Annual Review concludes that Zone 7 has sufficient water supplies to meet projected demands over the next five years with or without water conservation measures. The 2013 Annual Review notes that water demand over the next five-year period is anticipated to increase from 50,400 afy to 52,700 afy in 2017, with or without water conservation. Imposition of water conservation measures would decrease estimated water use by approximately 8.3% during the same time period. Zone 7’s long-term water supply remains at some risk due to certain factors, including court rulings and biological opinions associated with the Sacramento-San Joaquin Delta and climate change. In response to such uncertainty, Zone 7 continues to investigate and implement the recommendations of the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 123 2011 WSE. As recommended in the 2011 WSE, Zone 7 is moving forward and evaluating a set of actions to minimize the risk of water supply shortages, including: working with the local water supply retailers to develop additional water conservation savings and recycled water programs; continuing to implement the Well Master Plan and Chain of Lakes projects; confirming water supply available from the existing contract with BBID; minimizing or reusing brine losses from the existing Mocho Groundwater Demineralization Plan; reducing unaccounted-for water; and enhancing Zone 7’s existing in-lieu recharge program. In addition, Zone 7 is evaluating several major water supply portfolios, which include the Current Plan (i.e., Delta Fix), an In-Valley Portfolio (i.e., focused on recycled water), and an Intertie Portfolio (i.e., water transfers or regional desalination). DSRSD DSRSD Water Supply Reliability Zone 7 is DSRSD’s sole potable water supplier. In analyzing the reliability of DSRSD’s potable water supply, DSRSD calculated the percentage of possible water shortage if Zone 7’s planned programs and projects are implemented, and if they are not implemented. Without implementation, Zone 7’s customers will experience water supply shortages. All of Zone 7’s customers, including the water retailers in the Livermore Amador Valley, are assumed to proportionally share the impacts of the shortages. DSRSD’s potable water supply reliability for Normal, Single Dry, and Multiple Dry water years is shown on Tables B, C, and D. Each Table analyzes two scenarios: (1) Zone 7 planned projects and programs are implemented; and (2) Zone 7 planned projects and programs are not implemented. In Table 4.4-3 DSRSD’s potable water demand is compared to Zone 7’s water supply during a Normal water year. If Zone 7’s planned programs and projects are implemented, DSRSD anticipates no water supply shortage. However, if Zone 7’s planned programs and projects are not implemented, DSRSD anticipates shortage of approximately 3 percent starting 2030. A slight increase in shortage is expected by 2035; however, the water shortage remains under 4 percent. Table 4.4-3. DSRSD Water Supply & Demand Comparison-Normal Year (AF) 2015 2020 2025 2030 2035 Potable Water Zone 7 Planned Projects & Programs Implemented Zone 7 Water Supply Totals(a) 12,900 16,000 17,500 18,300 18,500 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0%0%0%0% 0% Difference as % of Demand 0%0%0%0% 0% Zone 7 Planned Projects & Programs NOT Implemented Zone 7 Water Supply Totals(a,b) 12,900 16,000 17,500 17,711 17,857 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 -589 -643 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 124 2015 2020 2025 2030 2035 Difference as % of Supply 0%0%0%-3.32% -3.60% Difference as % of Demand 0%0%0%-3.22% -3.48% Recycled Water DSRSD Supply Totals(c) 2,500 3,800 4,400 4,500 4,600 DSRSD Demand Totals 2,500 3,800 4,400 4,500 4,600 Difference 0 0 0 0 0 Difference as % of Supply 0%0%0% 0%0% Difference as % of Demand 0%0%0% 0%0% Includes DSRSD’s 645 af/yr GPQ pumped by Zone 7 and blended with Zone 7’s other water supply sources. Rounded up to nearest 100 af. Assumes that water supply shortage is shared equally amongst water retailers supplied by Zone 7. Recycled water from DSRSD’s RWTF. In Table 4.4-4, DSRSD’s potable water demand is compared to Zone 7’s water supply during a Single Dry water year. In a Single Dry water year, Zone 7 makes use of its stored water distributed between the local groundwater basin and the banking programs in Kern County. Overall, Zone 7 water demands are lower for the year because water demand that is normally for groundwater storage banking is not included in the water demands in a Single Dry water year. If Zone 7’s planned programs and projects are implemented, DSRSD anticipates no water supply shortage. However, if Zone 7’s planned programs and projects are not implemented, DSRSD anticipates a shortage of approximately one percent starting 2035. Table 4.4-4. DSRSD Water Supply & Demand Comparison-Single Dry Year (AF) 2015 2020 2025 2030 2035 Potable Water Zone 7 Planned Projects & Programs Implemented Zone 7 Water Supply Totals(a) 12,900 16,000 17,500 18,300 18,500 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0%0%0%0% 0% Difference as % of Demand 0%0%0%0% 0% Zone 7 Planned Projects & Programs NOT Implemented Zone 7 Water Supply Totals(a,b) 12,900 16,000 17,500 18,128 18,326 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 -172 -174 Difference as % of Supply 0%0%0%-1% -0.95% Difference as % of Demand 0%0%0%-1% -0.94% Recycled Water DSRSD Supply Totals(c) 2,500 3,800 4,400 4,500 4,600 DSRSD Demand Totals 2,500 3,800 4,400 4,500 4,600 Difference 0 0 0 0 0 Difference as % of Supply 0%0%0%0% 0% Difference as % of Demand 0%0%0%0% 0% (a) INCLUDES DSRSD’S 645 AF/YR GPQ PUMPED BY ZONE 7 AND BLENDED WITH ZONE 7’S OTHER WATER SUPPLY SOURCES. ROUNDED UP TO NEAREST 100 AF. (b) ASSUMES THAT WATER SUPPLY SHORTAGE IS SHARED EQUALLY AMONGST WATER RETAILERS SUPPLIED BY ZONE 7. (c) RECYCLED WATER FROM DSRSD’S RWTF. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 125 In Table 4.4-5, DSRSD’s potable water demands are compared to Zone 7’s water supply during Multiple Dry water year events. If Zone 7’s planned programs and projects are implemented, DSRSD anticipates no water supply shortage. However, if Zone 7’s planned programs and projects are not implemented, water shortages may occur as follows: • For a Multiple Dry water year event that starts in 2025, DSRSD will receive 100 percent of its total potable demand in the first year, 100 percent of its total potable demand in the second year, and 72 percent of its total potable water demand (28 percent water shortage) in the third year; • For a Multiple Dry water year event that starts in 2030, DSRSD will receive 98 percent of its total potable water demand (2 percent water shortage) in the first year, 100 percent of its total potable demand in the second year, and 69 percent of its total potable water demand (31 percent water shortage) in the third year; • For a Multiple Dry water year event that starts in 2035, DSRSD will receive 98 percent of its total potable water demand (2 percent water shortage) in the first year, 100 percent of its total potable demand in the second year, and 69 percent of its total potable water demand (31 percent water shortage) in the third year. Zone 7 plans to implement programs and projects to meet its customers’ demands in Multiple Dry water years. However, if Zone 7 is unable to implement those programs and projects, DSRSD may have to implement its Water Shortage Contingency and Drought Plan, as described below. Table 4.4-5. DSRSD Water Supply & Demand Comparison- Multiple Dry Years (AF) 2015 2020 2025 2030 2035 Potable Water Zone 7 Planned Projects & Programs Implemented Multiple dry year first year supply Zone 7 Water Supply Totals1 12,900 16,000 17,500 18,300 18,500 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Multiple dry year second year supply Zone 7 Water Supply Totals1 13,500 16,300 17,700 18,300 18,500 DSRSD Demand Totals 13,500 16,300 17,700 18,300 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Multiple dry year third year supply Zone 7 Water Supply Totals1 14,800 16,900 18,000 18,400 18,500 DSRSD Demand Totals 14,800 16,900 18,000 18,400 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Zone 7 Planned Projects & Programs Not Implemented Multiple dry year first year supply Zone 7 Water Supply Totals 1,2 12,900 16,000 17,500 17,994 18,133 DSRSD Demand Totals 12,900 16,000 17,500 18,300 18,500 Difference 0 0 0 -306 -367 Difference as % of Supply 0% 0% 0% -1.70% -2.02% The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 126 2015 2020 2025 2030 2035 Potable Water Difference as % of Demand 0% 0% 0% -1.67% -1.98 Multiple dry year second year supply Zone 7 Water Supply Totals 1,2 13,500 16,300 17,700 18,300 18,500 DSRSD Demand Totals 13,500 16,300 17,700 18,300 18,500 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Multiple dry year third year supply Zone 7 Water Supply Totals 1,2 14,800 16,900 12,880 12,620 12,676 DSRSD Demand Totals 14,800 16,900 18,000 18,400 18,500 Difference 0 0 -5,120 -5,780 -5,824 Difference as % of Supply 0% 0% -39.8 -45.8% -45.9% Difference as % of Demand 0% 0% -28.4 -31.4% -31.5% Recycled Water Multiple dry year first year supply DSRSD Supply Totals 3 2,500 3,800 4,400 4,500 4,600 DSRSD Demand Totals 2,500 3,800 4,400 4,500 4,600 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Multiple dry year second year supply DSRSD Supply Totals 3 2,800 3,900 4,400 4,500 4,600 DSRSD Demand Totals 2,800 3,900 4,400 4,500 4,600 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% Multiple dry year third year supply DSRSD Supply Totals 3 3,300 4,200 4,500 4,600 4,600 DSRSD Demand Totals 3,300 4,200 4,500 4,600 4,600 Difference 0 0 0 0 0 Difference as % of Supply 0% 0% 0% 0% 0% Difference as % of Demand 0% 0% 0% 0% 0% 1 INCLUDES DSRSD’S 645 ACRE-FT/YEAR GPQ PUMPED BY ZONE 7 AND BLENDED WITH ZONE 7’S OTHER WATER SUPPLY SOURCES. ROUNDED UP TO THE NEAREST 100 ACRE-FT. 2 ASSUMES THAT WATER SUPPLY SHORTAGES IS SHARED EQUALLY AMONGST WATER RETAILERS SUPPLIED BY ZONE 7. SEE APPENDIX O FOR DETERMINATION OF SHORTAGES. 3 RECYCLED WATER FROM DSRSD’S RWTF. Source: DSRSD Water Supply Reliability Plans DSRSD has developed plans to address water reliability issues and potential future water shortages. These include a Water Shortage Contingency Plan and a Drought Plan and Demand Management Measures. The Water Shortage Contingency Plan addresses events that cause a serious interruption in the normal water supply, including, but not limited to, drought, earthquake, major power outages, and similar events. The Contingency Plan establishes four stages to address water supply shortages:  A Stage 1 Level is to be implemented when there is a reasonable probability of less- than-expected water delivery to DSRSD in the next few years. A voluntary 5% or greater water cut-back is requested.  A Stage 2 Level is to be implemented when there is a reasonable probability of less- The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 127 than-expected water delivery in the upcoming year. A voluntary or mandatory 15% or greater water cut-back is imposed.  Stage 3 Level would be triggered if normal water supplies to DSRSD are reduced in the current year. A Stage 3 Level triggers a 30% or greater water cut-back.  A Stage 4 Level would be imposed when water shortage conditions have been in effect and water reduction targets imposed under Stages 1 through 3 have not been achieved to maintain an adequate water supply or when new events require greater water conservation efforts. Under a Stage 4 Level, a water cut-back of 50% or more is mandated by DSRSD. DSRSD also has adopted Demand Management Measures to reduce water demand through water conservation measures. DSRSD has been a member of the California Urban Water Conservation Council (CUWCC) since 1991 and is an original signatory to the Memorandum of Understanding Regarding Urban Water Conservation in California (CUWCC MOU). DSRSD has been implementing various Best Management Practices (BMPs) for water conservation since 1991, and has been submitting biennial reports to the CUWCC since 1992. DSRSD’s water conservation program includes the Demand Management Measures (DMMs). Its current conservation efforts and rates were established to address varying hydrological conditions (droughts) that occur from year to year. Because customers modified their water consumption behavior when the DSRSD Board of Directors declared Stage 1 water shortage conditions in 2009, DSRSD currently meets and exceeds the 2020 urban water use target of 163 GPCD. The list of BMPs is set forth in Section 6 of the DSRSD UWMP and is incorporated herein by this reference. On January 19, 2014, the DSRSD Board of Directors declared a Community Drought Emergency and called for a 20% reduction on the amount of water use compared to the same period in 2013. This includes a 5% reduction in the amount of indoor water use and a 40% reduction in the amount of outdoor water use. Zone 7 also asked all customers in the Livermore- Amador Valley to reduce water use by 20 percent due to drought conditions. Zone 7 identified specific steps that customers could take to reduce water use with reductions in outdoor water use presenting the greatest opportunity for reductions - http://www.zone7water.com/conservation- rebates/water-conservation. IMPACTS AND MITIGATION MEASURES FROM PREVIOUS EIRs The Eastern Dublin EIR identified significant impacts related to the supply of water to the Specific Plan area. Mitigation measure 3.5/23.0 addresses possible salinity in the groundwater basin. Mitigation measures 3.5/24.0–40.0 were adopted to prevent overdraft of ground water resources by requiring or encouraging annexation and connection to DSRSD; to minimize the effect of additional demand for water by encouraging water recycling and conservation and by encouraging the development of new facilities and supplies; and to ensure the development of a water distribution system by generally preventing development until such facilities are constructed by developers. Other mitigations (3.5/41.0–43.0) were adopted to deal with the potential for reservoir failures, the potential for loss of system pressure, and noise from water system pump stations. The Eastern Dublin EIR noted that the Eastern Dublin General Plan and The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 128 EDSP would increase demand to serve development at build-out under the then-applicable general plans and required an additional 25,000 acre-feet annually. Mitigation Measure 3.5/28.0 relied on Zone 7’s planning to acquire additional supplies. Impact 3.5/S found a lack of a water distribution system and required a “will serve” letter prior to grading permit (mitigation measure 3.5/3.8.0). Impact 3.5/T, Inducement of Substantial Growth, was deemed to be significant even after mitigation. Upon approval of the GPA/EDSP, the City adopted a Statement of Overriding Consideration for this significant unavoidable impact (Resolution No. 53–93). No supplemental impacts to water resources were analyzed in the IKEA SEIR. Regulatory framework. Water services to Dublin and the Project site are governed by the following documents. Dublin General Plan. The Dublin General Plan includes the Environmental Resources Management: Water Resources Element. The purpose of this optional Element is to “ensure that the City’s water resources are sustained and protected and to consolidate information and policies related to the conservation and management of water resources...” (page 12-1). The Element contains the following Guiding and Implementing Policies related to water resources. • Guiding Policy 12.3.1.A: Work with Zone 7 and DSRSD to secure an adequate water supply for, and provide water delivery to, existing and future customers in Dublin. • Implementing Policy 12.3.1.B: In anticipated of planned Future growth, continue working with DSRSD and Zone 7 to plan and provide sufficient water supplies. • Guiding Policy 12.3.3.A: Promote the conservation of water in new development. Eastern Dublin Specific Plan (EDSP). The EDSP includes Goals, Policies and Action Programs to guide cooperation between the City, the DSRSD and the project developers in providing an adequate water supply system for all new development in Eastern Dublin (Policy 9-1). Action Program 9A within the EDSP requires new development projects in the EDSP planning area to maximize water conservation by using water-conservation devices such as low-flow shower heads, adhering to DSRSD Best Management Practices (BMPs) for water conservation, installing water efficient irrigation systems, using native, drought tolerant plant materials and using recycled water for dust control during individual project construction. City of Dublin Climate Action Plan (CAP). The City of Dublin adopted a CAP in 2010 and completed a major update to this document in July 2013. The CAP provides a local inventory of estimated Greenhouse Gas Emissions (GHG) from the City currently and in the future. The CAP also includes strategies to be employed by the City to reduce community emissions by 15% below the 2010 GHG inventory by the year 2020. The CAP includes specific measures to achieve the emission reduction target. Strategy B.3.1 calls for use of Bay-friendly landscaping in new developments. This strategy includes an integrated solution to new landscaping that reduced water use, promotes soil health, reduced green waste, and results in a net reduction of GHG emissions. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 129 Zoning Ordinance Chapter 8.88 (Water Efficient Landscape Ordinance). Chapter 8.88 of the Zoning Ordinance requires water efficient landscape installations for new construction and rehabilitated landscapes for both public and private development projects. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES The proposed Project envisions a different development pattern than was assumed in the Eastern Dublin EIR and IKEA SEIR. This SEIR examines whether water use related to potential development of the project area might differ significantly from that previously analyzed and whether there is a reasonable likelihood that water would be available to serve the Project. Significance criteria. Implementation of the Project would be considered to have a significant impact on water supply and distribution if it were to:  require or result in the need to construct new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; or  have insufficient water supplies available to serve the project from existing entitlements and resources and require new or expanded entitlements or resources. Under CEQA standards, the EIR must analyze the “reasonable likelihood” that adequate water supply will be available to serve the Project and other water demand under near-term and long- term conditions. The “reasonably likely” finding does not require certainty of future water supplies through signed, enforceable agreements with providers and already built or approved facilities. An EIR must include a reasoned analysis of the circumstances affecting the likelihood of the water’s availability. “Paper water,” speculative sources or unrealistic allocations are not “reasonably likely” sources under CEQA. Uncertainty in the form of competition for identified water sources is an important point that should be discussed, but it does not necessarily render development of the planned water supply too unlikely. It is not necessary that the EIR show that total water supply in the long-term would be sufficient to meet total demand, but a discussion of total supply and demand is necessary to evaluate the cumulative impacts of development on water supply. A level of uncertainty regarding the availability of water supplies does not require a finding of a significant impact. However, the EIR must provide decision makers with information to evaluate the sources of water for the Project and their impacts. The EIR can rely on and incorporate analysis of the impacts from water sources performed by the water purveyors. The analysis of replacement or alternative sources is only required if it is impossible to confidently determine that anticipated future water sources will not be available. As long as an EIR discloses potential uncertainties and contains substantial evidence demonstrating that water supplies will likely be available in the future despite uncertainties, an EIR is not required to identify and analyze alternative water supplies. Supplemental water use impact. DSRSD UWMP includes demand from the development of a 305,000 square foot retail/commercial project on the project site under the existing City entitlements. Based on Table 4.4-6 below, this use would require an estimated 30,500 gallons The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 130 per day at full build-out. The proposed project would generate an estimated need for 52,000 gallons of potable water per day, which would be an estimated 21,500 gallons of water per day greater than anticipated water demand in the DSRSD UWMP. The project would use recycled water for exterior landscape irrigation and other exterior uses. Therefore, estimated water use shown in Table E does not include use of potable water for landscape irrigation. Table 4.4-6. The Green Project-Estimated Daily Water Demand (gallons/day) Land Use Amount Water Use Factor Water Use (GPD) Approved Use included in DSRSD UWMP General Commercial 305,000 sq. ft. 0.1 gpd/sq ft 30,500 gpd Proposed Project Uses Retail/Commercial 5000 sq. ft. 0.1 gpd/sq ft 500 gpd Restaurant 35,000 sq. ft. 0.1 gpd/sq ft 3,500 gpd Residential Condo/Townhouse 400 DU 120 gpd/DU 48,000 gpd Est. Water Demand. 52,000 gpd Difference +21,500 gpd Source: Stan Kolodzie, DSRSD, 4/13/2014 Construction of the proposed project would increase estimated potable water demand by 21,500 gallons per day (24.08 acre feet per year). This is an increase in water demand assumed in the DSRSD UWMP for Dublin and surrounding communities served by DSRSD and Zone 7. This amount of water (24.08 afy) constitutes only 0.13% of DSRSD’s long-term potable water supply of 18,500 afy, and .03% of the lowest annual available water supply of 72,326 afy, contained in the Zone 7 UWMP. DSRSD has determined that potable water is available for overall water demand within its service area, including this Project, until at least 2018 with or without water conservation measures (2013 Annual Review). The incremental increase in potable water demand is relatively small and DSRSD does not believe that the increase would have a significant impact on the District’s ability to provide water supplies to its customers in this area (Source: Stan Kolozdie, DSRSD, 3/27/14). DSRSD also will not issue construction permits for the proposed Project if there is not available water, in accordance with DSRSD Code Section 6.2.01. So, the proposed project will not be allowed to begin construction under DSRSD regulations unless there is adequate water to serve Project demand. At the time of collection of connection fees and issuance of a construction permit, a connection to the DSRSD water supply system would be made and water provided to the project in accordance with DSRSD regulations. Additionally, Mitigation Measure 3.5/38 in the Eastern Dublin EIR requires a “will-serve” letter from DSRSD prior to grading permit approval. A “will serve” letter was provided for the previous Ikea project and new letter will be required for this proposed project in the Conditions of Approval for the Tentative Map. Based on the above discussion, adequate water supplies to meet existing and future demand (including the proposed project) are reasonably likely. Zone 7 has potential greater supply under The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 131 existing contracts and potential new sources of supply are being pursued by Zone 7. DSRSD also has existing water supplies available under its contract with BMID, and recycled water and additional conservation measures that could be implemented which could be used to meet project and cumulative demand. Both Zone 7 and DSRSD have implemented such conservation measures in response to the current drought. In addition, a 20% reduction in indoor water use for new development mandated under the State Green Building Code was not taken into account in the demand estimates under the Zone 7 UWMP and DSRSD UWMP. The State Green Building Code requires a 20% reduction in indoor water use in new residential development beginning in 2014. This requirement will apply to all residential building for which building permits are issued after January 1, 2014 and will apply to the proposed Project. A similar 20% reduction for non-residential development become mandatory in the 2010 State Green Building Code. Zone 7 and DSRSD also have current water conservations measures that are in effect during droughts and may be expanded to address shortages resulting from other causes. Both Zone 7 and DSRSD have programs to address drought conditions during multi-dry year. DSRSD has specific measures and programs to reduce demand during drought conditions as set forth in its Water Shortage Contingency Plan and Demand Management Measures described above. Under a Stage 4 Level, a reduction of 50% or more in water use may be mandated by DSRSD. This reduction in demand greatly exceeds any projected shortfalls in the DSRSD UWMP. With regard to the increase in demand for recycled water in the near-term and long-term, DSRSD has a sufficient supply to meet anticipated demand and has the ability to increase the supply of recycled water in the future. A recycled water distribution main is located adjacent to the project property. There is a sufficient supply of recycled water available to serve project and cumulative demand and a less-than-significant impact would result with regard to recycled water supply. Based on the foregoing, water supplies are reasonably likely to be available to serve the proposed project and existing demand in the near-term, and project and cumulative demand in the long- term. Therefore, the proposed project impact is less than significant. The project contribution to any significant cumulative impact is less than cumulatively considerable and, therefore, less than significant. Since water supplies are reasonably likely, the EIR is not required to analyze alternative sources of water. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 132 4.5 BIOLOGICAL RESOURCES This section provides information on the biological resources on The Green project site. Biological resources were analyzed in Chapter 3.7 of the 1993 Eastern Dublin EIR, a program EIR for the Eastern Dublin General Plan Amendment and Specific Plan area. Further analysis regarding biological resources was included in the IKEA SEIR. The purpose of this section is to supplement the Eastern Dublin EIR and the IKEA SEIR in accordance with CEQA standards. The following analysis is based on a report dated August 30, 2013, prepared by WRA Biological Consultants. The WRA report is included as Appendix 8.5 of this SEIR. ENVIRONMENTAL SETTING Project site characteristics. The project site is located in an urban area that consists of a patchwork of developed commercial and residential areas interspersed with undeveloped, open areas. Adjacent to the project site to the north and west are private open spaces dominated by non-native annual grassland and non-native mustards. Adjacent to the east is the Hacienda Crossings commercial center, and to the south is Interstate 580. A majority of the site is characterized by non-native annual grassland with occasional stands of non-native mustard. The site is relatively flat, sloping downward from north to south. The elevation ranges from approximately 350 feet in the north to approximately 340 feet in the south. The project site has been graded and some areas have been piled and excavated. As a result, minor topographic variation occurs, sometimes as obvious depressions and plateaus. Based on satellite imagery (Exhibit 4.4-1) and existing vegetation, it appears that some limited parts of the site experience prolonged inundation during part of the year and have the potential to be wetland habitat The majority of the project site was recently mowed, though no other recent activity is evident. One building currently exists on the site, which was used for past marketing efforts and will be removed at the time the site is developed. Ornamental olive trees in containers are located around the building; most are living but in poor health. Several large piles of debris exist in the western portion of the site. Biological communities. Table 4.4-1 summarizes the area of each biological community type observed in the Project Area. Non-sensitive biological communities in the Project Area include non-native annual grassland and ruderal herbaceous stands. One potentially sensitive biological community is found in the project area. Descriptions for each biological community are contained in the following sections. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 133 Table 4.5-1. Summary of Biological Communities on the Project Site Community Type Acres Non-native annual grassland 25.53 Ruderal herbaceous stands 2.26 Potential seasonal wetlands 1.17 Source: WRA, 2013 Non-Sensitive Biological Communities Non-Native Annual Grassland. Non-native annual grassland typically occurs in open areas of valleys and foothills throughout California, usually on fine textured clay or loam soils that are somewhat poorly drained. Non-native grassland is typically dominated by non-native annual grasses and forbs along with scattered native wildflowers. Non-native annual grassland comprises the majority of the site and is a mix of grasses and other herbaceous species. Common species include slender oat (Avena barbata), soft chess (Bromus hordeaceus), ripgut brome (Bromus diandrus), Italian rye grass (Festuca perennis [Lolium multiflorum]), mouse barley (Hordeum murinum ssp. leporinum), stink wort (Dittrichia graveolens) and redstem stork’s bill (Erodium cicutarium). Coyote brush (Baccharis pilularis) is sparsely scattered throughout the site. Native plant cover is less than 10%. Ruderal Herbaceous Stands. Ruderal herbaceous stands are located in areas where there has been recent or repeated disturbance. These communities are dominated by non-native herbaceous species adapted to growing in conditions of disturbance. Ruderal herbaceous stands dominated by black mustard (Brassica nigra) occur primarily in the southwest portion of the site on a variety of topographic features. Sensitive Biological Communities Seasonal Wetland. Seasonal wetland plant communities occur in swales and depressions that are ponded during the rainy season for sufficient duration to support vegetation adapted to wetland conditions. Seasonal wetlands in California are highly variable in plant composition, depending on the length of ponding or inundation. There are four potential seasonal wetlands on the site, totaling 1.17 acres. All appear to exist as a result of past alterations to the landscape, but have existed long enough to be dominated by plants often found in seasonal wetlands. Typical plant species observed in potential seasonal wetlands on the site include hyssop loosestrife (Lythrum hyssopifolia), pygmy willowherb (Epilobium campestre [E. pygmaeum]), doormat knotweed (Polygonum aviculare [P. arenastrum]), and popcornflower (Plagiobothrys sp.). Special-Status Species. Plants. Based upon a review of the resources and databases, 35 special-status plant species have been documented in the vicinity of the project site. Appendix B (contained in the full biological analysis, SEIR Appendix 8.7) summarizes the potential for occurrence for each special-status plant species occurring in the vicinity of the site. One special-status plant species, Congdon’s tarplant, was observed on the site during the assessment site visit. No other special-status plant The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 134 species have a high or moderate potential to occur on the project site. The remaining species documented to occur in the vicinity of the site are unlikely, have no potential to occur, or were not found during the August 1, 2013 survey by WRA. Congdon’s tarplant is discussed below. Congdon’s tarplant (Centromadia parryi ssp. congdonii). CNPS Rank 1B.1. Present. Congdon’s tarplant is an annual forb in the sunflower family (Asteraceae) that blooms from June to November. It occurs in terraces, swales, floodplains, grassland, and disturbed sites, sometimes alkaline, at elevations ranging from 0-990 feet (Baldwin et al. 2012, CDFW 2013, CNPS 2013). Congdon’s tarplant is known from 31 USGS 7.5-minute quadrangles in Alameda, Contra Costa, Monterey, Santa Clara, Santa Cruz, San Luis Obispo, San Mateo, and Solano counties (CNPS 2013). Congdon’s tarplant occurs in abundance on the site. A few individuals were scattered in the east half of the site, but thousands occurred in the west half. Wildlife. Twenty-six special-status species of wildlife have been recorded in the vicinity of the site. Appendix B (contained in the full biological analysis) summarizes the potential for each of these species to occur on the project site. All of the wildlife species observed in the site are commonly found species, and many are adapted to occupying disturbed or urban areas. One special-status wildlife species was observed on the project site during the site assessment. In addition, there are no special-status wildlife species that have a high potential to occur on the site, but four special-status wildlife species have a moderate potential to occur on the site. Special-status wildlife species that were observed or have a moderate potential to occur on the project site are discussed below. Present species White tailed kite (Elanus leucurus). CDFW Species of Special Concern. Present. White- tailed kite occurs in low elevation grassland, agricultural, wetland, oak woodland, and savannah habitats. Riparian zones adjacent to open areas are also used. Vegetative structure and prey availability seem to be more important than specific associations with plant species or vegetative communities. Lightly grazed or ungrazed fields generally support large prey populations and are often preferred to other habitats. Kites primarily feed on small mammals, although, birds, reptiles, amphibians, and insects are also taken. Nest trees range from single isolated trees to trees within large contiguous forests. Preferred nest trees are extremely variable, ranging from small shrubs (less than 10 ft. tall), to large trees (greater than 150 ft. tall). At the time of the August 2013 site visit, a kite was seen foraging over the site. The grassland areas on the site provide foraging habitat for this species and the trees planted along the medians of the roads surrounding the project site may provide nesting habitat during the breeding season. Species with moderate potential to occur Burrowing owl (Athene cunicularia). CDFW Species of Special Concern. Moderate Potential. Burrowing owl (BUOW) is a ground-dwelling owl found throughout most of California and the western United States. In California, it occurs either as a resident or winter visitor. BUOW inhabit flat, open grassland or gentle slopes and sparse shrub-lands. This species The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 135 prefers annual or perennial grasslands, typically with sparse or nonexistent tree or shrub canopies and short vegetation; however, it also colonizes agricultural and other developed areas including; debris piles, old pipes, airports, golf courses, vacant lots and agricultural fields. This species is dependent on burrowing mammals to provide the burrows that are characteristically used for shelter and nesting, and in northern California is typically found in close association with California ground squirrels (Spermophilus beecheyi). Breeding typically takes place from March to July. The project site provides suitable habitat for BUOW, as it contains disked ruderal grassland with many ground squirrel burrows. Furthermore, the CDFW CNDDB has several recorded occurrences of BUOW less than two miles from the site, the closest being approximately 0.15 mile north of the site. At the time of the August 2013 site visit, no BUOW or signs of BUOW (e.g. feathers, pellets, feces, or nest decoration) were observed. However, due to the habitat suitability and documented occurrences of this species nearby, there is a moderate potential for burrowing owl to move into and occur on the site. Pallid bat (Antrozous pallidus). California Species of Special Concern. Moderate Potential. Pallid bat is found from southern British Columbia and Montana to central Mexico, and east to Texas, Oklahoma, and Kansas. Roosts are typically in rock crevices, tree hollows, mines, caves, and a variety of man-made structures, including vacant and occupied buildings. Tree roosting has been documented and they have also been reported roosting in stacks of burlap sacks and stone piles. Pallid bat may use the marketing building on the site to roost, and may forage within the site, giving the species a moderate potential to occur in the site. Townsend’s big-eared bat (Corynorhinus townsendii).CDFW Species of Special Concern. Moderate Potential. This species ranges throughout western North America, from British Columbia to central Mexico. It is typically associated with caves but is also found in man- made structures, including mines and buildings. This bat may forage over the site and use the building on the site to roost, thus having a moderate potential to occur on the project site. Yuma myotis (Myotis yumanensis). BLM Sensitive Species. Moderate Potential. Yuma myotis is found throughout most of California at lower elevations in a wide variety of habitats. Day roosts are found in buildings, trees, mines, caves, bridges, and rock crevices. Night roosts are usually associated with buildings, bridges or other man-made structures. The existing marketing building on the site may provide night roosting habitat and the bat may use the site for foraging. Therefore, there is a moderate potential for Yuma myotis to occur on the site. Listed species unlikely to occur. Federally listed species that are documented to occur within the vicinity of the site include: San Joaquin kit fox (Vulpes macrotis mutica). Federal Endangered Species. San Joaquin kit fox is found in the San Joaquin Valley and in surrounding foothills, from Alameda County east to Stanislaus County. It is a desert-adapted species which occurs mainly in arid, flat grasslands, scrublands, and alkali meadows where the vegetation structure is relatively short (generally less than 1.5 feet tall). This species uses dens year-round and needs loose-textured soils suitable for burrowing. Kit fox prey consists primarily of kangaroo rats and other small The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 136 rodents, as well as large insects and occasionally rabbits. San Joaquin kit fox has been extirpated from much of its historic range and is now only found in the southern and eastern portions of its historic range and a study by Sproul and Flett indicates that the species is absent west of the Altamont Hills, which includes the project site. California red-legged frog (Rana draytonii). Federal Threatened Species. California red- legged frog (CRLF) occurs in isolated localities in the Sierra Nevada, northern Coast and northern Transverse Ranges but is still common in the San Francisco Bay Area and along the central coast. CRLF breeding habitat is characterized by dense, shrubby riparian vegetation associated with deep, still or slow moving water. Estivation and dispersal habitat may consist of riparian vegetation, presence of small mammal burrows, and continuous connective stretches of grassland, wetland or oak woodland habitat. On average, CRLF tend to disperse a mile away from breeding sites. CRLF are unlikely to occur in or around the project site. The site does not contain any riparian vegetation, and is surrounded by urban development and surrounded on all sides by paved roads at least 80 feet wide, which act as barriers to dispersal. There are no apparent accessible breeding features within two miles of the site, and according to satellite imagery the site has had a history of disturbance and has been graded multiple times. The nearest CNDDB occurrence of CRLF to the project site is approximately 1.3 miles to the east, and there are several occurrences within four miles. Most of these occurrences are prior to 2005, when much of the area to the east of the site was undeveloped. Dense urban development and other land use changes over the past ten years have very likely decreased the habitat suitability of the immediate area and rendered it much less suitable for CRLF dispersal. For these reasons, it is unlikely that CRLF will occur on the site or move to the site. California tiger salamander (Ambystomacaliforniense). Federal Endangered/State Threatened Species. California tiger salamander (CTS) inhabits valley and foothill grasslands and the grassy understory of open woodlands, usually within one mile of water. Currently, six distinct populations are known to inhabit areas including; the Central Valley and Sierra Nevada foothills; Yolo County south to Tulare County; and the coastal valleys and foothills from Sonoma County south to Santa Barbara County. Adult salamanders spend most of their time underground in upland subterranean refugia, usually in small mammal burrows. During the first rainfall events of the year, adult CTS emerge and migrate to breed and lay eggs in ponds, depressional pools, vernal pools and other wetlands. CTS are unlikely to occur on the project site, as the surrounding roads and development prevent dispersal. As in the case of CRLF, there are no evident breeding features accessible to CTS within two miles of the site and the site has already undergone disturbance with repeated grading activities. Vernal pool fairy shrimp (Branchinecta lynchi). Federal Threatened Species. Vernal pool fairy shrimp are endemic to the grasslands of the Central Valley, central coast mountains, and south coast mountains. They inhabit a variety of different vernal pool habitats, from small, clear sandstone rock pools to large, turbid, alkaline, grassland valley floor pools. Shrimp can also be found in natural and artificial wetlands including stock ponds, ditches, and ephemeral drainages (Helm 1997). This species is unlikely to occur on the site due to the lack of vernal pool habitat and the area’s history of repeated disking, grading and leveling. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 137 IMPACTS AND MITIGATION MEASURES FROM PREVIOUS CEQA DOCUMENTS Eastern Dublin EIR. The Eastern Dublin EIR included a comprehensive assessment of habitat and wildlife resources in the EIR planning area. The EIR identified potential impacts related to the general effects of potential development in Eastern Dublin, including direct habitat loss, indirect habitat loss due to vegetation removal for construction and development activities, and loss or degradation of sensitive habitat (Impacts 3.7/A, B, and C). The Eastern Dublin EIR also identified potential impacts related to wildlife species such as the San Joaquin kit fox, CRLF, CTS, and others (Impacts 3.7/D – S). Raptor electrocutions associated with proposed high- voltage power lines were addressed in depth in the 1993 Eastern Dublin EIR and included a number of mitigation measures (MM 3.7/26.0a-d). Mitigation measures were adopted to, among other things, prepare resource management plans, avoid development in sensitive areas, and revegetate disturbed areas (generally MM 3.7/1.0 – 28.0). All mitigation measures adopted upon approval of the Eastern Dublin EIR continue to apply to the proposed project. Even with mitigation, the City concluded that the cumulative loss or degradation of botanically sensitive habitat was significant and unavoidable. Upon approval of the Eastern Dublin GPA/SP, the City adopted a Statement of Overriding Considerations for this significant unavoidable impact (Resolution No. 53-93). The Eastern Dublin EIR analyzed cumulative impacts on biological resources within the portions of Alameda and Contra Costa counties in the general vicinity of the Eastern Dublin area. At that time, Contra Costa County had an Urban Limit Line that functioned as a growth boundary. That Urban Limit Line placed all of the Dougherty and Tassajara valleys inside the growth boundary (i.e., allowing development of those areas), and placed lands to the east of Tassajara Valley and north of the County line outside the growth boundary. Alameda County had no comparable growth boundaries; instead, planning for the Alameda County portions of this region was performed by the cities of Dublin and Livermore. The Eastern Dublin EIR identified one significant cumulative biological impact. Impact 3.7/C identified the continued loss and deterioration of botanically sensitive habitat, particularly riparian habitat. IKEA SEIR. The IKEA SEIR identified Supplemental Impact BIO-1, which included potential impacts to newly-identified biological resources, specifically Congdon’s tarplant, a special-status plant. No evidence was found at that time that the Congdon’s tarplant species was actually present on the site so no supplemental mitigation measures were included in the IKEA SEIR. REGULATORY SETTING Biological resources are regulated by the following: Federal Endangered Species Act. The Federal Endangered Species Act (FESA) protects listed wildlife species from harm or “take” which is broadly defined as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, collect, or attempt to engage in any such conduct. Take can also include habitat modification or degradation that directly results in death or injury to a listed The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 138 wildlife species. An activity can be defined as “take” even if it is unintentional or accidental. Listed plant species are provided less protection than listed wildlife species. Listed plant species are legally protected from take under FESA if they occur on federal lands or if the project requires a federal action, such as a Section 404 fill permit. The U.S. Fish and Wildlife Service (USFWS) has jurisdiction over federally listed threatened and endangered species under the FESA. The USFWS also maintains lists of proposed and candidate species. Species on these lists are not legally protected under the FESA, but may become listed in the near future and are often included in their review of a project. California Endangered Species Act. The California Endangered Species Act (CESA) prohibits the take of any plant or animal listed or proposed for listing as rare (plants only), threatened, or endangered. In accordance with the CESA, the California Department of Fish and Wildlife (CDFW) has jurisdiction over state-listed species (California Fish and Wildlife Code Sec. 2070). Additionally, the CDFW maintains lists of "species of special concern" that are defined as species that appear to be vulnerable to extinction because of declining populations, limited ranges, and/or continuing threats. California Environmental Quality Act. Section 15380(d) of the California Environmental Quality Act (CEQA) Guidelines provides that a species not listed on the federal or state lists of protected species may be considered rare or endangered if the species can be shown to meet certain specified criteria. These criteria have been modeled after the definitions in FESA and CESA and the section of the California Fish and Game Code dealing with rare or endangered plants or animals. This section was included in the guidelines primarily to deal with situations in which a public agency is reviewing a project that may have a significant effect on a species that has not yet been listed by either the USFWS or CDFW. Clean Water Act. Under Section 404 of the Clean Water Act, the Corps is responsible for regulating the discharge of fill material into waters of the United States. Waters of the U.S. and their lateral limits are defined in 33 CFR Part 328.3 (a) and include streams that are tributary to navigable waters and their adjacent wetlands. Wetlands that are not adjacent to waters of the U.S. are termed “isolated wetlands” and, depending on the circumstances, may not be subject to Corps jurisdiction. California Water Quality and Waterbody Regulatory Programs. Pursuant to Section 401 of the federal Clean Water Act, projects that are regulated by the Corps must obtain water quality certification from the RWQCB. This certification ensures that the project will uphold state water quality standards. The RWQCB may impose mitigation requirements even if the Corps does not. Isolated wetlands that are not jurisdictional under Section 404 of the federal Clean Water Act are considered waters of the State under the Porter-Cologne Act. Discharge of fill into waters of the State is subject to Waste Discharge Requirements as issued by the RWQCB. The CDFW exerts jurisdiction over the bed and banks of rivers, lakes, and streams according to provisions of Section 1601 to 1603 of the Fish and Wildlife Code. The Fish and Wildlife Code The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 139 requires a Streambed Alteration Agreement for the fill or removal of material within the bed and banks of a watercourse or waterbody and for the removal of riparian vegetation. The Federal Migratory Bird Treaty Act (16 U.S.C. Sec. 703) prohibits killing, possessing, or trading in migratory birds except in accordance with regulations prescribed by the Secretary of the Interior. This act encompasses whole birds, parts of birds, and bird nests and eggs. Most native bird species in the project area are covered by this Act. The California Native Plant Society (CNPS), a non-governmental conservation organization, has developed lists of plant species of concern in California. Vascular plants included on these lists are defined as follows: List 1A Plants considered extinct. List 1B Plants rare, threatened, or endangered in California and elsewhere. List 2 Plants rare, threatened, or endangered in California but more common elsewhere. List 3 Plants about which more information is needed - review list. List 4 Plants of limited distribution-watch list. Although the CNPS is not a regulatory agency and plants on these lists have no formal regulatory protection, plants appearing on List 1B or List 2 are, in general, considered to meet CEQA’s Section 15380 criteria and adverse effects to these species are considered significant. East Alameda County Conservation Strategy. The project site is located in Alameda County and although as a private development project it is technically not subject to the EACCS guidance, permitting agencies will utilize the guidance and policies contained in the EACCS to analyze the project. Conservation goals and objectives are described in Chapter 3 of the Final EACCS. There are multiple objectives listed in the Conservation Strategy; here are some objectives that apply directly to the project Area: Goal 1: Protect and enhance natural and semi‐natural landscapes that are large enough to accommodate natural processes beneficial to populations of native species. Objective 1.1: Protect a range of environmental gradients (such as slope, elevation, aspect) across a diversity of natural communities within the conservation zones. Objective 1.2: Protect riverine systems and hydrologic function within the study area through protection and management of terrestrial land covers, streams, ponds, and wetlands across all watersheds of the study area. Goal 4: Protect and enhance functional grassland communities (alkali meadow and scald, California annual grassland, non‐serpentine native bunchgrass grassland, serpentine bunchgrass grassland, rock outcrop, valley sink scrub) that benefit focal species and promote native biodiversity. Objective 4.1: Field verify the Conservation Strategy land cover map of native grasslands and create a refined map that better accounts for mapped stands. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 140 Goal 8: Improve the overall quality of riparian communities and the hydrologic and geomorphic processes that support them to increase the amount of riparian habitat for focal species and promote native biodiversity. Objective 8.1: Field verify the Conservation Strategy land cover map of riparian forest and scrub stands and create a refined map that reflects species composition, key riparian community attributes, and conservation opportunities at the stream reach level. Objective 8.2: Avoid or minimize direct impacts on riparian forest and scrub communities during project construction and indirect impacts that result from post-project activities by implementing avoidance measures outlined in Table 3‐2 and 3‐3 of the EACCS. Goal 9: Improve the overall quality of wetlands (perennial freshwater marsh, seasonal wetland, alkali wetland); ponds; and their upland watersheds to maintain functional aquatic communities that benefit focal species and promote native biodiversity. Objective 9.1: Field verify the Conservation Strategy land cover map of seasonal and perennial wetlands and create a refined map that reflects habitat quality and restoration opportunities. Objective 9.2: Avoid or minimize direct impacts on wetland or pond communities during project construction and indirect impacts that result from post-project activities by implementing avoidance measures outlined in Table 3‐2 and 3‐3 of the EACCS. The Dublin Heritage Tree Ordinance (City of Dublin Municipal Code Sec. 5.60) states that preservation of existing trees is beneficial to the health and welfare of the City. Tree removal permits are required under this section for removal of heritage trees, which are defined in the ordinance. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES Significance Criteria. The project’s impacts to biological resources would be considered significant if the project results in the actions or outcomes listed below. These significance criteria are based on the CEQA Guidelines’ (CCR Title 14, Div. 6, Ch. 3) recommended tools for determining the potential for significant environmental effects, including the model Initial Study checklist (Appendix G of the Guidelines) and mandatory findings of significance (Guidelines sec. 15065). The proposed project would have a significant supplemental impact on biological resources if the following impacts have the potential to occur but were not analyzed in the Eastern Dublin EIR or the IKEA SEIR, or are substantially more severe than analyzed in the Eastern Dublin EIR or the IKEA SEIR: The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 141 • Have a substantial adverse effect, either directly or indirectly or through habitat modification, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS; • Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the CDFW or USFWS; • Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption or other means; Supplemental Impacts. The proposed project is expected to develop the entire site. Therefore, the project would permanently impact all of the approximate 27.5 acres of habitat on the site and may impact special-status plants, nesting and/or wintering burrowing owls, and nesting birds protected by the MBTA and California Fish and Game Code. For each of the potential impacts identified, the following avoidance, minimization, and compensatory measures are recommended. Supplemental mitigation measures SM-BIO-3 (Burrowing Owls) are identified below to update and clarify EDSP mitigation measures in light of current biological regulatory requirements. Impacts to jurisdictional waters. Construction of the proposed project would result in disturbance of the entire site and filling of a small amount of seasonal wetlands that could be potentially jurisdictional waters of the U.S. and/or waters of the State. If wetlands are present on the site, this would be a significant supplemental impact. Supplemental Impact BIO-1 (wetland and other waters). The proposed project would result in the fill of potentially jurisdictional waters of the U.S. and/or waters of the State (significant supplemental impact and mitigation required). Implementation of the following supplemental mitigation measure will reduce this impact to a less-than significant level, both on a project and cumulative level. The supplemental mitigation measure requires that if jurisdictional waters are identified on the site and cannot be avoided as part of the development, compensatory wetlands shall be secured so that no net loss of wetlands will occur. Supplemental Mitigation Measure SM-BIO-1 (wetland and other waters). The applicant shall undertake the following prior to issuance of a grading plan for the site: a) A wetlands delineation shall be completed for the site consistent with U.S. Army Corps of Engineers protocols. b) If jurisdictional wetlands are found on the site and if avoidance of these jurisdictional waters on the site is not feasible, suitable compensatory mitigation shall be provided based on the concept of no net loss of wetland habitat values or acreages. In such an eventuality, a wetland mitigation plan shall be developed and implemented that includes creation, restoration, and/or enhancement of off-site wetlands prior to project ground disturbance. Mitigation areas shall be established in perpetuity through dedication of a conservation easement (or similar mechanism) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 142 to an approved environmental organization and payment of an endowment for the long-term management of the site. If wetlands are determined to be jurisdictional under Section 404 of the Clean Water Act, the mitigation plan will be subject to the review and approval of the Corps and Regional Water Quality Control Board (RWQCB). If the potential seasonal wetlands are non-jurisdictional under Section 404, the mitigation plan will be subject to the review and approval of the RWQCB. Impacts to special-status plant species. The proposed project could impact special-status plant species on the site, specifically Congdon’s tarplant. Supplemental Impact BIO-2 (impacts to Congdon’s tarplant and other special-status plant species). Approval and construction of the proposed project would impact Congdon’s tarplant and other special-status plant species on the site (significant supplemental impact and mitigation required). Implementation of the following supplemental mitigation measure will reduce this impact to a less-than significant level, both on a project and cumulative level. The supplemental mitigation measure requires acquisition and preservation of suitable off-site habitat for special-status plant species prior to site development. Supplemental Mitigation Measure SM-BIO-2 (impacts to Congdon’s tarplant and other special-status plant species). Focused surveys for special-status plants shall be conducted on the site consistent with the California Department of Fish & Wildlife’s 2009 Protocols for Surveying and Evaluating Impacts to Special-Status Populations and natural Communities. Plant surveys shall be conducted throughout the blooming period throughout the blooming period of those special-status for which suitable habitat is present. Two or three separate surveys may be required to cover the blooming period of plants listed in Table 4.4-1. If populations/stands of a special-status species are identified during the surveys and impacts cannot be avoided, compensatory mitigation shall be provided, such as the acquisition of off-site mitigation areas presently supporting the species in question, purchase of credits in a mitigation bank that is approved to sell credits for the affected species, or payment of in-lieu fees to a public agency or conservation organization (e.g.. a local land trust) for the preservation and management of existing populations. The location of mitigation sites shall be determined in consultation with and subject to approval of US Fish and Wildlife Service and/or California Department of Fish & Wildlife. In the case where special-status plants are neither federal- or state-listed, the lead agency shall approve the mitigation approach using the guidance provided by the Eastern Alameda County Conservation Strategy in consultation with the City’s consulting biologist. Off-site compensatory shall be acquired at a minimum acreage ratio of 1:1 (acquired:impacted). For off-site mitigation options, measures shall be implemented (including contingency measures) providing for the long-term protection of these species. Burrowing Owls. The proposed project could impact nesting and/or wintering habitat for burrowing owl. This impact was identified as Impact 3.7/M. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 143 Supplemental Impact BIO-3 (impacts to burrowing owls). The proposed project could impact the habitat for nesting or wintering burrowing owl by disturbing the existing ground surface (significant supplemental impact and mitigation required). Mitigation Measure 3.7/27.0 contained in the Eastern Dublin EIR reduced impacts to burrowing owl to a less-than-significant level. However, adherence to the following supplemental mitigation measure provides enhanced mitigation that is consistent with current California Department of Fish and Wildlife standards whereas EDSP EIR Mitigation Measure 3.7/27.0 is no longer consistent with these standards. The following measure requires completion of a pre- construction survey for burrowing owl and, if found, implementation of either an exclusion zone around nests or development of an exclusion plan with protective buffers. With adherence to the following mitigation measure, this impact will be less-than-significant. Supplemental Mitigation Measure SM-BIO-3 (impacts to burrowing owls). Preconstruction surveys shall be conducted for burrowing owls prior to grading or construction activities. These surveys should conform to the survey protocol established in the Staff Report on Burrowing Owl Mitigation (CDFW 2012b). The Conservation Strategy depicts the project site as being located in Conservation Zone 2, which supports 11 percent of the Conservation Strategy’s study area’s unprotected potential habitat for burrowing owl). Burrowing owls could nest or winter in the site’s approximate 13 acres of ruderal/disturbed non-native grassland habitat and within the suitable grassland habitat adjacent to the site. The following measures are consistent with the provisions of the Migratory Bird Treaty Act and the California Department of Fish & Wildlife standards. a) No more than 14 days prior to any ground disturbing activities, a qualified biologist shall conduct a take avoidance survey for burrowing owls. If no owls are found during this first survey, a final survey will 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 site shall be resurveyed (including the final survey within 48 hours of disturbance). All surveys shall be conducted in accordance with California Department of Fish & Wildlife guidelines. b) If burrowing owls are found on the site during the surveys, mitigation shall be implemented in accordance with applicable California Department of Fish & Wildlife standards. More specifically, if the surveys identify breeding or wintering burrowing owls on or adjacent to the site, 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 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 California Fish & Wildlife approval and monitoring requirements. Compensatory mitigation could also be required by California Fish & Wildlife as part of the approval of an exclusion plan. Mitigation may include the permanent The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 144 protection of habitat at a nearby off-site location acceptable to the California Department of Fish & Wildlife. Impacts to breeding birds. The proposed project could impact nesting birds on the site. Supplemental Impact BIO-4 (impacts to breeding birds). Construction of the proposed project could impact breeding birds on the site (significant supplemental impact and mitigation required). Adherence to the following will reduce impacts to breeding birds that may nest on or immediately adjacent to the site to a less-than-significant level by requiring prohibiting project construction during the nesting season. If this cannot be met, a preconstruction survey for nesting birds shall be completed and, if found, it will be necessary to establish a protective buffer around identified nests. Supplemental Mitigation Measure SM-BIO-4 (impacts to breeding birds). Vegetation removal and/or initial ground disturbance on the site shall occur during the non-breeding season from September 1 to January 31. If instead these actions will occur from February 1 to August 31, then a pre-construction breeding bird survey shall be conducted no more than 14 days prior to construction. Any active nests found shall be protected by a minimum 50-foot exclusion buffer. The buffer size may vary depending on bird species, the location of the nest, and other factors. Impacts to bats. Three special-status bat species have a moderate potential of occurring on the project site by using the existing marketing building on the site for roosting and/or foraging in the area. The marketing building is capable of supporting bat roosts. If special status bat species roosts are present, project development may impact these species either through direct removal of roosts or nearby disturbance. In addition, an increase in night lighting during the construction phase of the project may result in disturbance to bat movement and behavior and may be a potential indirect impact. Loss of potential bat roosts would constitute a significant impact. Bat foraging habitat on a regional scale is not expected to be significantly impacted by the project. Supplemental Impact BIO-5 (impacts to special-status bats). Construction of the proposed project could impact special-status bats that could inhabit the site, specifically the removal of the existing building (significant supplemental impact and mitigation required). Adherence to the following will reduce impacts to potential bats on the site by removing the potential bat habitat at a time when it is not likely to be occupied. Supplemental Mitigation Measure SM-BIO-5 (impacts to special-status bats). The marketing building shall be removed from the premises during September or October. Pre- construction surveys of the marketing building for bats shall occur no more than 30 days before its removal. If bats are found, a qualified biologist shall develop an appropriate relocation plan consistent with US Fish & Wildlife, California Department of Fish & Wildlife and EACCS standards and policies. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 145 Cumulative impacts. The Eastern Dublin EIR found that direct habitat loss of implementing the Eastern Dublin General Plan Amendment and Specific Plan (Impact IM 3.7/A) and loss or degradation of botanically sensitive habitat (Impact 3.7/C) to be cumulative biological resource impacts. The proposed project is located within the Eastern Dublin planning area and would disturb approximately 27.5 acres of vacant land within this area. No new or more severe impacts with respect to cumulative biological impacts would occur than analyzed in the Eastern Dublin EIR. No cumulatively considerable biological resource impacts were identified in the IKEA SEIR. Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 146 Ta b l e 4 . 5 - 2 — Pl a n t S p e c i e s O b s e r v e d i n t h e P r o j e c t A r e a D u r i n g a S i t e V i s i t o n A u g u s t 1 , 2 0 1 3 Fa m i l y Sc i e n t i f i c N a m e Co m m o n N a m e In d i c a t o r St a t u s Ra r i t y St a t u s Or i g i n Form Fa b a c e a e Ac m i s p o n a m e r i c a n u s va r . am e r i c a n u s [ L o t u s p u r s h i a n u s va r . p . ] Am e r i c a n l o t u s N L - - n a t i v e a n n u a l f o r b Bo r a g i n a c e a e Am s i n c k i a sp . fi d d l e n e c k N L n a t i v e a n n u a l f o r b Er i c a c e a e Ar b u t u s u n e d o st r a b e r r y t r e e N L - - n o n - n a t i v e e v e r g r e e n t r e e Ap o c y n a c e a e [A s c l e p i a d a c e a e ] As c l e p i a s f a s c i c u l a r i s Me x i c a n m i l k w e e d F A C - - n a t i v e p e r e n n i a l f o r b Po a c e a e Av e n a b a r b a t a sl e n d e r o a t N L - - n o n - n a t i v e a n n u a l g r a m i n o i d As t e r a c e a e Ba c c h a r i s p i l u l a r i s ss p . c o n s a n g u i n e a co y o t e b r u s h N L - - n a t i v e e v e r g r e e n s h r u b Br a s s i c a c e a e Br a s s i c a n i g r a bl a c k m u s t a r d N L - - n o n - n a t i v e a n n u a l f o r b Po a c e a e Br o m u s d i a n d r u s ri p g u t b r o m e N L - - n o n - n a t i v e a n n u a l g r a m i n o i d Po a c e a e Br o m u s h o r d e a c e u s so f t c h e s s F A C U - - n o n - n a t i v e a n n u a l g r a m i n o i d As t e r a c e a e Ca r d u u s p y c n o c e p h a l u s It a l i a n t h i s t l e N L - - n o n - n a t i v e a n n u a l f o r b As t e r a c e a e Ce n t a u r e a s o l s t i t i a l i s ye l l o w s t a r t h i s t l e N L - - n o n - n a t i v e a n n u a l f o r b As t e r a c e a e Ce n t r o m a d i a p a r r y i ss p . co n g d o n i i [He m i z o n i a p . ss p . c . ] Co n g d o n ' s t a r p l a n t F A C R a n k 1 B . 2 n a t i v e a n n u a l f o r b As t e r a c e a e Ci r s i u m v u l g a r e bu l l t h i s t l e F A C U - - n o n - n a t i v e p e r e n n i a l f o r b Co n v o l v u l a c e a e Co n v o l v u l u s a r v e n s i s fi e l d b i n d w e e d N L - - n o n - n a t i v e p e r e n n i a l f o r b Po a c e a e Co r t a d e r i a sp . Pa m p a s g r a s s F A C U - - n o n - n a t i v e p e r e n n i a l g r a m i n o i d Co n v o l v u l a c e a e [C u s c u t a c e a e ] Cu s c u t a o c c i d e n t a l i s [ C . c a l i f o r n i c a va r . b r e v i f l o r a ] we s t e r n d o d d e r N L - - n a t i v e a n n u a l v i n e As t e r a c e a e Di t t r i c h i a g r a v e o l e n s st i n k w o r t N L - - n o n - n a t i v e a n n u a l f o r b Po a c e a e El y m u s t r i t i c o i d e s [ L e y m u s t . ] be a r d l e s s w i l d r y e F A C - - n a t i v e p e r e n n i a l g r a m i n o i d On a g r a c e a e Ep i l o b i u m b r a c h y c a r p u m an n u a l w i l l o w h e r b N L - - n a t i v e a n n u a l f o r b On a g r a c e a e Ep i l o b i u m c a m p e s t r e [ E . p y g m a e u m ] py g m y w i l l o w h e r b O B L - - n a t i v e a n n u a l f o r b Ge r a n i a c e a e Er o d i u m c i c u t a r i u m re d s t e m s t o r k ' s b i l l N L - - n o n - n a t i v e a n n u a l f o r b Pa p a v e r a c e a e Es c h s c h o l z i a c a l i f o r n i c a Ca l i f o r n i a p o p p y N L - - n a t i v e p e r e n n i a l f o r b Eu p h o r b i a c e a e Eu p h o r b i a s e r p e n s [ C h a m a e s y c e s . ] ma t t e d s a n d m a t F A C - - n o n - n a t i v e a n n u a l f o r b Th e G r e e n P r o j e c t / D r a f t S u p p l e m e n t a l E I R Ci t y o f D u b l i n M a y 2 0 1 4 Page 147 Fa m i l y Sc i e n t i f i c N a m e Co m m o n N a m e In d i c a t o r St a t u s Ra r i t y St a t u s Or i g i n Form Po a c e a e Fe s t u c a m y u r o s [ V u l p i a m . v a r . m . ] ra t t a i l f e s c u e F A C U - - n o n - n a t i v e p e r e n n i a l g r a m i n o i d Po a c e a e Fe s t u c a p e r e n n i s [ L o l iu m m u l t i f l o r u m ; L. p e r e n n e ] It a l i a n r y e g r a s s N L - - n o n - n a t i v e a n n u a l g r a m i n o i d Ap i a c e a e Fo e n i c u l u m v u l g a r e fe n n e l N L - - n o n - n a t i v e p e r e n n i a l f o r b Rh a m n a c e a e Fr a n g u l a c a l i f o r n i c a [ R h a m n u s c . ] co f f e e b e r r y N L - - n a t i v e e v e r g r e e n s h r u b As t e r a c e a e He l m i n t h o t h e c a e c h i o i d e s [ P i c r i s e . ] br i s t l y o x - t o n g u e F A C - - n o n - n a t i v e p e r e n n i a l f o r b Po a c e a e Ho r d e u m m u r i n u m s s p . l e p o r i n u m mo u s e b a r l e y F A C - - n o n - n a t i v e a n n u a l g r a m i n o i d Po a c e a e Co r t a d e r i a s p . Pa m p a s g r a s s F A C U - - n o n - n a t i v e p e r e n n i a l g r a m i n o i d Fa b a c e a e Me l i l o t u s s p . sw e e t c l o v e r - - n o n - n a t i v e a n n u a l f o r b As t e r a c e a e La c t u c a s e r r i o l a pr i c k l y l e t t u c e F A C U - - n o n - n a t i v e a n n u a l f o r b Ly t h r a c e a e Ly t h r u m h y s s o p i f o l i a hy s s o p l o o s e s t r i f e O B L - - n o n - n a t i v e a n n u a l f o r b Ma l v a c e a e Ma l v a n i c a e e n s i s bu l l m a l l o w N L - - n o n - n a t i v e a n n u a l f o r b Ma l v a c e a e Ma l v e l l a l e p r o s a al k a l i m a l l o w F A C U - - n a t i v e p e r e n n i a l f o r b Fa b a c e a e Me d i c a g o p o l y m o r p h a bu r m e d i c F A C U - - n o n - n a t i v e a n n u a l f o r b Fa b a c e a e Me l i l o t u s s p . sw e e t c l o v e r - - n o n - n a t i v e a n n u a l f o r b Po a c e a e Ph a l a r i s m i n o r li t t l e s e e d c a n a r y g r a s s N L - - n o n - n a t i v e a n n u a l g r a m i n o i d Bo r a g i n a c e a e Pl a g i o b o t h r y s s p . po p c o r n f l o w e r - - n a t i v e a n n u a l f o r b Po l y g o n a c e a e Po l y g o n u m a v i c u l a r e [ P . a r e n a s t r u m ] do o r y a r d k n o t w e e d F A C - - n o n - na t i v e p e r e n n i a l f o r b Po a c e a e Po l y p o g o n m o n s p e l i e n s i s ra b b i t ' s - f o o t g r a s s F A C W -- n o n - n a t i v e a n n u a l g r a m i n o i d Po l y g o n a c e a e Ru m e x c r i s p u s cu r l y d o c k F A C - - n o n - n a t i v e p e r e n n i a l f o r b Ad o x a c e a e [C a p r i f o l i a c e a e ] Sa m b u c u s n i g r a s s p . c a e r u l e a [ S . me x i c a n a ] bl u e e l d e r b e r r y F A C U - - n a t i v e d e c i d u o u s s h r u b As t e r a c e a e Si l y b u m m a r i a n u m mi l k t h i s t l e N L - - n o n - n a t i v e p e r e n n i a l f o r b As t e r a c e a e So n c h u s a s p e r s s p . a s p e r pr i c k l y s o w t h i s t l e F A C U - - n o n - n a t i v e a n n u a l f o r b Fa b a c e a e Tr i f o l i u m h i r t u m ro s e c l o v e r N L - - n o n - n a t i v e a n n u a l f o r b Pl a n t a g i n a c e a e [S c r o p h u l a r i a c e a e ] Ve r o n i c a p e r e g r i n a ss p . x a l a p e n s i s ne c k w e e d O B L - - n a t i v e a n n u a l f o r b CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) Exhibit 4.5-1 BIOLOGICAL COMMUNITIES SOURCE: WRA Environmental Consultants, 8/19/2013. Map Date: August 2013 Map By: Chris Zumwalt Base Source: ESRI Streaming 5/12/10 "The Green" Mixed Use Project Alameda County, California . 0 130 26065 Feet "The Green" Biological Communities 8/19/13 Path: L:\Acad 2000 Files\23000\23055\gis\ArcMap\Figure Bio Communities.mxd Legend Study Area Non-native annual grassland = 25.53 acres Ruderal herbaceous stand = 2.26 acres Potential seasonal wetland = 1.17 acres CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) Exhibit 4.5-2 CONGDON’S TARPLANT LOCATIONS SOURCE: WRA Environmental Consultants, 8/19/2013. Map Date: August 2013 Map By: Chris Zumwalt Base Source: ESRI Streaming 5/12/10 "The Green" Mixed Use Project Alameda County, California . 0 120 24060 Feet "The Green" Rare Plant Map 8/19/13 Path: L:\Acad 2000 Files\23000\23055\gis\ArcMap\Figure Congdons Tarplant.mxd Legend Study Area Congdon's tarplant population = 6.81 acres !(Congdon's tarplant individuals The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 150 4.6 NOISE INTRODUCTION Noise impacts were analyzed in Chapter 3.9 of the Eastern Dublin EIR. This supplement examines whether any changes in the proposed project would result in new or substantially more significant impacts that were not identified in the previous EIRs. This DSEIR section is based on a project specific noise study prepared by Illingworth & Rodkin dated April 15, 2014 and the full text is included in Appendix 8.8 of the DSEIR. ENVIRONMENTAL SETTING Environmental noise fundamentals. Noise is defined as unwanted sound. Airborne sound is a rapid fluctuation of air pressure above and below atmospheric pressure. Sound levels are usually measured and expressed in decibels (dB) with 0 dB corresponding roughly to the threshold of hearing. Decibels and other technical terms are defined in Table 4.6-1. Most of the sounds that we hear in the environment do not consist of a single frequency, but rather a broad band of frequencies, with each frequency differing in sound level. The intensities of each frequency add together to generate a sound. The method commonly used to quantify environmental sounds consists of evaluating all of the frequencies of a sound in accordance with a weighting that reflects the facts that human hearing is less sensitive at low frequencies and extreme high frequencies than in the frequency mid-range. This is called "A" weighting, and the decibel level so measured is called the A-weighted sound level (dBA). In practice, the level of a sound source is conveniently measured using a sound level meter that includes an electrical filter corresponding to the A-weighting curve. Typical A-weighted levels measured in the environment and in industry are shown in Table 4.6-2 for different types of noise. Although the A-weighted noise level may adequately indicate the level of environmental noise at any instant in time, community noise levels vary continuously. Most environmental noise includes a conglomeration of noise from distant sources which create a relatively steady background noise in which no particular source is identifiable. To describe the time-varying character of environmental noise, the statistical noise descriptors, L01, L10, L50, and L90, are commonly used. They are the A-weighted noise levels equaled or exceeded during 1%, 10%, 50%, and 90% of a stated time period. A single number descriptor called the Leq is also widely used. The Leq is the average A-weighted noise level during a stated period of time. In determining the daily level of environmental noise, it is important to account for the difference in response of people to daytime and nighttime noises. During the nighttime, exterior background noises are generally lower than the daytime levels. However, most household noise also decreases at night and exterior noise becomes very noticeable. Further, most people sleep at night and are very sensitive to noise intrusion. To account for human sensitivity to nighttime noise levels, a descriptor, DNL (day/night average sound level), was developed. The DNL divides the 24-hour day into the daytime of 7:00 AM to 10:00 PM and the nighttime of 10:00 PM to 7:00 AM. The nighttime noise level is weighted 10 dB higher than the daytime noise level. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 151 The Community Noise Equivalent Level (CNEL) is another 24-hour average which includes both an evening and nighttime weighting. Table 1 contained in Appendix 8.8 contains definitions of terminology used in this SEIR. Updated noise environment. The project site is located north of Interstate 580 (I-580) in Dublin, California. The project site is bounded by Martinelli Way to the north, Hacienda Drive to the east, Interstate 580 to the south, and Arnold Road to the west. Illingworth & Rodkin, Inc. completed a series of noise measurements to quantify existing ambient noise levels. The noise monitoring survey consisted of two long-term noise measurements; LT-1 was made from Wednesday, May 8th to Friday, May 10th, 2013 and LT-2 was made from Thursday, May 16th to Tuesday, May 21st, 2013. Two short-term (10-minute) noise measurements were also made to complete the survey. Noise monitoring locations are shown on Exhibit 4.6-1 and long-term measurement data are shown in Appendix A of the full noise analysis (see Appendix 8.8). The proposed project location is currently an undeveloped, vacant property with one small modular office building; currently a vacant, existing commercial building that would be relocated with the development of the project. Noise-sensitive residential land uses are located northeast of the Dublin Boulevard and Hacienda Drive intersection, approximately 750 feet from the site. Existing hotel (which is considered a sensitive noise receptor) and commercial land uses are located east of Hacienda Drive. The noise environment in the site vicinity results primarily from vehicle traffic along Interstate 580, and local traffic along Hacienda Drive and Dublin Boulevard, and operations associated with the existing commercial land uses near the site. Site LT-1 was located near the southwest corner of the project site, 230 feet from the center of I- 580. This location was selected to quantify the daily trend in noise levels from traffic noise along I-580. Hourly average noise levels typically ranged from 74 to 76 dBA Leq during the day, dropping to a low of 66 dBA Leq at night. The 24-hour average Community Noise Equivelant Level at this location was 79 dBA CNEL. Site LT-2 was located near the northwest corner of the project site, near the intersection of Arnold Road and Martinelli Way, 75 feet from the center line of Martinelli Way and 50 feet from the center of Arnold Road. This location was selected to quantify the daily trend in noise levels near the northern portions of the project site. The primary noise source during the measurement was traffic on Arnold Road and Martinelli way. Hourly average noise levels typically ranged from 61 to 66 dBA Leq during the weekday daytime hours, dropping to a low of 55 dBA Leq at night. The Community Noise Equivelant Level at this location ranged from 67 to 69 dBA CNEL for the weekdays and was 65 dBA CNEL during the weekend. Two short-term noise measurements were also made in order to quantify the variation in noise levels at receptors near the project site. Site ST-1 was located 100 feet west of the center of Arnold Road, and 140 feet south of Dublin Boulevard. The 10-minute average noise level measured between 12:10 p.m. and 12:20 p.m. was 65 dBA Leq. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 152 Site ST-2 was located approximately 60 feet from the center of Martinelli Way and 150 feet from the center of Hacienda Boulevard. Noise levels were measured from 12:30 p.m. to 12:40 p.m., yielding an average noise level of 61 dBA Leq. REGULATORY BACKGROUND The State of California and the City of Dublin establish guidelines, plans, and policies designed to limit noise exposure at noise sensitive land uses. The State CEQA Guidelines, Appendix G and the policies contained in the Noise Element of the City of Dublin General Plan are used as significance criteria in the impact assessment. Applicable criteria are as follows: State CEQA Guidelines. The significance of environmental noise impacts resulting from a proposed project are evaluated based on the California Environmental Quality Act (CEQA) guidelines. For purposes of this project, CEQA asks the following applicable questions. Would the project result in: 1. Exposure of persons to or generation of noise levels in excess of standards established in the local General Plan or Noise Ordinance, or applicable standards of other agencies? 2. A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project? 3. A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? CEQA does not define what noise level increase would be considered substantial. Project- generated noise level increases of 3 dBA CNEL or greater are considered significant where exterior noise levels would exceed the normally acceptable noise level standard (60 dBA CNEL for residential and hotel land uses). Where noise levels would remain at or below the normally acceptable noise level standard with the project, noise level increases of 5 dBA CNEL or greater are considered significant. City of Dublin General Plan. Dublin’s Plan identifies noise and land use compatibility standards for community noise environments. Table 4.6-1 shows that noise levels at retail and commercial office land uses should normally not exceed the 70 dBA CNEL threshold, that motel and hotel land uses should not normally exceed 60 dBA CNEL, and that residential land uses should normally be less than 60 dBA CNEL. Table 4.6-1. City of Dublin Land Use/Noise Compatibility Standards (decibels) Land Use Normally Acceptable Conditionally Acceptable Normally Unacceptable Clearly Unacceptable Residential 60 or less 60-70 70-75 75+ Motels, hotels 60 or less 61-80 71-80 Over 80 Schools, churches, nursing homes 60 or less 61-70 71-80 Over 80 Neighborhood parks 60 or less 61-65 66-70 Over 70 Offices: retail commercial 70 or less 71-75 76-80 Over 80 Industrial 70 or less 71-75 Over 75 -- Source: Dublin General Plan Noise Element, Table 9.1 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 153 IMPACTS AND MITIGATIONS FROM PREVIOUS CEQA DOCUMENTS Eastern Dublin EIR. The Eastern Dublin EIR identified a number of potentially significant impacts related to noise. These include: IM 3.10/A (Exposure of Proposed Housing to Future Roadway Noise) identified future vehicular traffic associated with development proposed in the Eastern Dublin Specific Plan as potentially significant to future residents of Eastern Dublin. This impact would be mitigated to a level of insignificance through adherence to Mitigation Measure 3.10/1.0 that requires acoustic studies for all future residential development in the Eastern Dublin area. IM 3.10/B (Exposure of Existing Residences to Future Roadway Noise) would be a potentially significant impact to residents in the Eastern Dublin area as development occurs in accord with the Eastern Dublin General Plan Amendment and Specific Plan. This impact would be reduced through adherence to Mitigation Measure 3.10/2.0, which required future development projects to provide noise protection to existing residential uses in Eastern Dublin; however, noise impacts to existing residents along Fallon Road would remain significant and unavoidable. IM 3.10/C (Exposure of Existing and Proposed Development to Airport Noise) Was considered an insignificance impact and no mitigation was required. IM 3.10/D (Exposure of Proposed Residential Development to Noise from Future Military Training Activities at Parks Reserve Forces Training Area and the County Jail) identified potentially significant noise for future residents within 6000 feet of Parks RFTA. This impact would be reduced through adherence to Mitigation Measure 3.10/3.0 that requires acoustic studies for development near Parks RFTA for the Alameda County Government facility; however, reduction of noise from Parks RFTA may not be feasible, so this impact would be significant and unavoidable. IM 3.10/E (Exposure of Existing and Proposed Residences to Construction Noise) would be a potentially significant impact related to noise associated with construction of the proposed Eastern Dublin Specific Plan improvements, including but not limited to buildings, roads, and utilities. Adherence to Mitigation Measures 3.10/4.0 and 5.0 would reduce construction noise impacts to a level of insignificance through preparation and submittal of Construction Noise Management Plans and compliance with local noise standards. IM 3.10/F (Noise Conflicts due to the Adjacency of Diverse Land Uses Permitted by Plan Policies Supporting Mixed-Use Development) would result from close proximity of different land use types that may result in potentially significant impacts. Mitigation Measures 3.10/6.0 requires the preparation on noise management plans for all mixed-use developments within the Eastern Dublin area. This measure would reduce noise generated by mixed-use development to a level of insignificance. IKEA SEIR. The topic of noise was not analyzed in this document. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 154 All of these impacts and mitigation measures would apply to the currently proposed project. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES The project proposes to construct a mixed-use center on the site, which would include up to 400 residential units and up to 40,000 square feet of commercial space. The commercial space would include up to 5,000 square feet of retail space and up to 35,000 square feet of restaurant space. The retail space would typically be located on the ground floor, with multi-family residential units above. The conceptual site plan shows residential uses in the eastern, western, and southern portion of the site, with commercial uses in the center portion of the site. A trail is proposed along the southern boundary of the site. Based on the Initial Study, there is the potential for potentially significant impacts that could expose persons to generation of noise levels in excess of City standards due to vehicular traffic and other noise sources such as truck unloading. These development level impacts are identified below. Significance criteria. The following standards of significance are used to assess potential impacts related to noise: Noise and Land Use Compatibility. A significant noise impact would occur if land use areas proposed as part of the project would be exposed to noise levels exceeding the applicable noise standards presented in the General Plan. For retail and commercial land uses, exterior noise levels of 70 dBA CNEL or less are considered normally acceptable, between 71 -75 dBA are considered conditionally acceptable, between 76 – 80 dBA CNEL are normally unacceptable and above 80 dBA CNEL are clearly unacceptable. For residential land uses, exterior noise levels of 60 dBA CNEL or less are considered normally acceptable, between 61-70 dBA are considered conditionally acceptable, between 71-75 dBA CNEL are normally unacceptable, and above 75 dBA CNEL are clearly unacceptable. The interior noise standard for residential dwellings shall be at or below 45 dBA CNEL. For neighborhood parks, exterior noise levels of 60 dBA CNEL or less are considered normally acceptable, between 61-65 dBA are considered conditionally acceptable, between 66-70 dBA CNEL are normally unacceptable and above 70 dBA CNEL are clearly unacceptable. Substantial Permanent Noise Increases. The impact would be considered significant if traffic or commercial noise sources generated by the project would:  cause the CNEL to increase by 5 dBA or more but remain below the normally acceptable noise threshold (60 dBA CNEL for residential uses, 70 dBA CNEL for commercial uses); The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 155  cause the CNEL to increase by 3 dBA or more and exceed normally acceptable noise threshold. Significant Supplemental Impacts. The proposed project would introduce new noise sensitive uses into an area where noise levels are in excess of City standards. In addition, project operations could generate noise levels that could exceed City standards at project residences. Based on a comparison of existing and future traffic volumes from the project’s traffic study, a noise increase of about 2 dB above existing levels is calculated to occur by 2030 assuming future plus project traffic conditions, due primarily to cumulative traffic volume increases along I-580. Existing + Project conditions would not measurably increase noise levels at the site above Existing conditions, as project traffic would add only a very small volume percentage of vehicles to existing traffic on the freeway. The project itself is expected to add 200 peak hour trips in both the a.m. and p.m. hours, which would result in noise increase of less than 3 dB, which is the threshold of significance. Preliminary Year 2030 traffic noise contours, which indicated the ‘worst case’ traffic noise scenario, were calculated using SoundPLAN 7.0, a three-dimensional noise modeling software (shown in Exhibit 4.6-2). Noise and Land Use Compatibility of Residential Exterior Use Areas. The results of the noise modeling are shown in Exhibit 4.6-2. As indicated in this exhibit, exterior use areas located in well-shielded portions of the site would achieve the 60 dBA CNEL standard for residential uses. However, the proposed trail location would exceed the 60 dBA CNEL “normally acceptable” standard for residential outdoor use areas and for neighborhood parks. Mitigation options are limited for exterior land uses nearest I-580 because of the high noise levels generated by traffic. Portions of the proposed trail, which is adjacent to I-580, noise levels would exceed 80 dBA CNEL without mitigation. Although it is not desirable from an aesthetic point of view, a sizable noise barrier (e.g. 14 feet or less in height), constructed on the project site, was examined and it was concluded that it would not provide enough attenuation for exterior noise levels areas along the proposed trail to achieve the 60 dBA CNEL standard. A 14 foot high barrier, located along the site’s southern boundary, would reduce noise levels along the proposed trail by only 8 to 10 dB, would reduce noise levels at ground level first row southern facing residential facades by only 3 to 4 dB, and would reduce noise levels at upper stories and in partially shielded or well shielded areas by 1 dB or less. Even with the construction of a barrier, trail users would still be exposed to noise levels exceeding 70 dBA CNEL, which would be considered “normally unacceptable” for residential outdoor use areas and “clearly unacceptable” for neighborhood parks. However, the trail does not clearly fall into either of these land use categories in that it is a secondary outdoor use and there are several other areas on site that residents have access to for outdoor enjoyment that achieve the 60 dBA CNEL “normally acceptable” standard for residential uses. Noise and Land Use Compatibility of Project Residential Interiors. Interior noise levels within new residential units are required to be maintained at or below 45 dBA CNEL. Residential buildings throughout much of the project site would be exposed to future exterior noise levels greater than the normally acceptable exterior standard of 60 dBA CNEL, with some exterior The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 156 levels exceeding 80 dBA CNEL without mitigation. Exterior levels at residential facades would exceed the normally acceptable residential criteria in much of the site and would fall into the clearly unacceptable category in some areas. However, with use of site planning, architectural layout (placing bedrooms away from I-580 for example), and construction modifications, interior noise levels could be maintained below the 45 dBA CNEL interior threshold, as described below. The highest future noise exposures would occur nearest Interstate 580. Upper level residences would typically be exposed to noise levels that are about 1 dBA higher than ground level residences (indicated in Exhibit 4.6-2) due to the lack of ground absorption between the traffic noise source and the receptor location. Interior noise levels would vary depending on the final design of the buildings (relative window area to wall area) and construction materials and methods. Standard residential construction provides approximately 15 dBA of exterior to interior noise reduction assuming the windows are partially open for ventilation. Standard construction with the windows closed provides approximately 20 to 25 dBA of noise reduction in interior spaces. In exterior noise environments ranging from 60 dBA CNEL to 65 dBA CNEL, interior noise levels can typically be maintained below City standards with the incorporation of an adequate forced air mechanical ventilation system in each residential unit. Preliminary calculations indicate that this measure would be applicable to the northern portion of the site, adjacent to Martinelli Way, in the northeastern and northwestern portions of the site, adjacent to Hacienda Drive and Arnold Road, but well shielded from I-580, and in well shielded areas in the southern central portion of the site. It is assumed that standard thermal-pane residential windows/doors with a minimum rating of STC 28 would be installed in these residences. In exterior noise environments of 65 dBA CNEL or greater, a combination of forced-air mechanical ventilation and sound-rated construction methods is often required to meet the interior noise level limit. Attaining the necessary noise reduction from exterior to interior spaces is readily achievable in noise environments less than 75 dBA CNEL with proper wall construction techniques, the selection of proper windows and doors, and the incorporation of forced-air mechanical ventilation systems. Preliminary calculations show that it is likely that windows/doors with ratings of STC 30 to 40 would be required in noise environments of 75 dBA CNEL or less. This measure would be applicable to partially shielded areas in the south central portion of the site. In exterior noise environments exceeding 75 dBA CNEL, the construction materials and techniques necessary to reduce interior noise levels to acceptable levels become more expensive and difficult to implement. Noise insulation features such as stucco-sided staggered-stud walls and high STC-rated windows and doors (STC 36 to 42) would likely be required for first-row receptors adjacent to I-580. First-row residences would also need to be equipped with a full heating and air-conditioning system because it is unlikely residents would open their windows for ventilation. On-site commercial uses would be located in the north central portion of the site and would be exposed to noise levels within the normally acceptable range (70 dBA CNEL or less). The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 157 Project Residential Noise Compatibility with Proposed Retail and Restaurant Operational Noise. The project would introduce new sources of noise into the existing noise environment. Typical noise sources would include rooftop heating ventilating and air-conditioning (HVAC) equipment and truck deliveries to the site. Since the site is surrounded primarily by undeveloped land, these operational noise sources would not impact existing noise sensitive uses in the project vicinity. However, noise levels generated by commercial operations could generate noise levels in excess of the Noise and Land Use Compatibility guidelines at project residences. Noise impacts resulting from HVAC systems can vary considerably depending on the equipment selected, the system design, and the location of the equipment relative to the noise sensitive use. Noise levels from commercial HVAC systems are typically in the range of 60 to 70 dBA Leq at a distance of 15 feet. Maximum instantaneous noise levels generated by delivery trucks are generally in the range of 60 to 70 dBA Lmax at a distance of 50 feet. In the southernmost portion of the site, adjacent to Interstate 580, HVAC and delivery truck noise would not generally be distinguishable from traffic noise. However, depending on the time of day that deliveries occur, noise generated by commercial delivery activities and HVAC systems could annoy residential land uses that are located in well shielded areas in the northernmost portion of the site. In some portions on the project site, residential uses and commercial uses are separated by 40 feet. Supplemental Impact NOISE-1 (noise and land use compatibility). Residential land uses proposed by the project could be exposed to exterior noise levels exceeding 60 dBA CNEL and interior noise levels exceeding 45 dBA CNEL (potentially significant supplemental impact). Mitigation options are limited for residential land uses nearest Interstate 580 because of the high noise levels generated by traffic. With the current site plan, noise levels in centrally and northern located outdoor common use areas are well shielded from I-580 and would achieve the 60 dBA CNEL normally acceptable standard for residential uses. Reasonable height noise barriers, constructed on the project site, would not provide enough attenuation for exterior noise levels along the proposed trail to achieve the 60 dBA CNEL “normally acceptable” standard for residential outdoor use areas and neighborhood parks. However, all residents would have access to outdoor use areas in the central portion of the site which would achieve the 60 dBA CNEL normally acceptable standard. Adherence to the following supplemental mitigation measures will mitigate this impact to a less- than-significant level by ensuring that the final design and location of project mechanical equipment would not result in noise exposure exceeding City standards for noise sensitive uses. Supplemental Mitigation Measure SM-NOISE-1 (noise and land use compatibility). Reduce exterior and interior noise levels in noise sensitive areas of the project to meet City standards. To meet City noise standards, the following mitigation shall be used:  Locate noise-sensitive outdoor use areas away from Interstate 580. Ensure that all residents have access to outdoor use areas that achieve exterior noise criteria (60 dBA CNEL for residential uses). The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 158  A suitable form of forced-air mechanical ventilation, as determined by the local building official, shall be provided for units throughout the site, so that windows can be kept closed at the occupant’s discretion to control interior noise and achieve the interior noise standards.  For the first row of buildings facing Interstate 580, the buildings shall be designed to have sealed windows and no balconies on elevations facing the freeway.  For residential uses, noise insulation features shall be designed to achieve the 45 dBA CNEL interior noise standard. Sound rated windows and doors shall be provided to maintain interior noise levels at acceptable levels. Additional treatments may include, but are not limited to, sound rated wall construction, acoustical caulking, insulation, acoustical vents, etc. Large windows and doors should be oriented away from the I-580 where possible. Bedrooms should be located away from I-580.  The final specifications for noise insulation treatments shall be reviewed by a qualified acoustical consultant during final design of the project to ensure that exterior and interior noise levels on site achieve the 45 dBA CNEL interior noise standard for residential uses and hourly average noise levels to 45 dBA Leq for commercial uses. Results of the analysis, including the description of the necessary interior and exterior noise control treatments, shall be submitted to the City along with the building plans and shall approved by the City prior to issuance of a building permit.  The final design and location of project mechanical equipment shall be reviewed by a qualified acoustical consultant to confirm that operational noise levels would not exceed 60 dBA CNEL at exterior project residential uses and would not exceed 45 dBA CNEL inside these residences. If needed, the final design and location of mechanical equipment shall be modified to conform with noise parameters set forth in this analysis.  A truck delivery plan shall be submitted to the City for the commercial portion of the project site, which would include the proposed hours of allowable deliveries and the locations and routes of the delivery trucks on the project site. A qualified acoustical consultant shall review the delivery plan to ensure that interior and exterior noise levels on site achieve acceptable levels. The truck delivery plan and acoustical consultant report shall be subject to approval by the City prior to the issuance of a certificate of occupancy for any commercial building. Noise from increased vehicle project trips. The development of the project will cause an increase in vehicular traffic on the street network. An increase is considered to be a significant impact if project related traffic were to cause the CNEL to increase by 5 dBA or more but remain below the normally acceptable noise threshold (60 dBA CNEL for residential uses, 70 dBA CNEL for commercial uses), or cause the CNEL to increase by 3 dBA or more and exceed the normally acceptable noise threshold. The noise exposure levels along roadways in the vicinity of the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 159 project were evaluated to determine whether or not the increased volumes of vehicular traffic would cause a significant increase in the noise environment. Twenty five intersections were analyzed. Traffic noise along a street is logarithmically proportional to the volume of traffic. Traffic data was reviewed along roadways expected to be serving the project to calculate potential traffic noise level increases attributable to the project. Based on the traffic volume data developed for this study, traffic noise levels along most roadways in the project vicinity are anticipated to increase by less than 1 dBA CNEL above existing conditions as a result of the project (existing + project conditions). Noise levels from traffic increases are calculated to increase by 3 to 4 dBA CNEL along Arnold Road, between Martinelli Way and Dublin Boulevard, and on Martinelli Way, west of Hacienda Drive. Both of these roadway segments are adjoined by undeveloped lands and there are no noise sensitive land uses along either roadway segment. Under Future 2035 + Project conditions, traffic noise increases are calculated to be less than 1 dB above Future 2035 conditions. The increase in noise levels would not exceed 3 dBA CNEL at sensitive receivers adjacent to the project site and the impact is less-than-significant. Cumulative Impacts. The project site is located in a primarily undeveloped area. Based on the traffic volume data developed for this study, Year 2035 traffic noise levels along all of the studied roadways in the project vicinity are anticipated to increase by less than 3 dBA CNEL as a result of the project. As a result, the impact would be considered less-than-significant. Construction noise impacts or operational noise impacts resulting from the project would not combine with noise from other projects in the vicinity, or increased noise levels resulting from the general growth of the area, to increase the severity of project noise impacts as discussed above. Based on the findings of the site-specific acoustic analysis, no supplemental noise impacts are anticipated. CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) Exhibit 4.6-1 NOISE MEASUREMENT LOCATIONS Exhibit 4.6-1. Noise Measurement Locations LT-2 LT-1 ST-2 ST-1 Project Site SOURCE: Illingworth & Rodkin, 2014. CITY OF DUBLIN THE GREEN PROJECT SUPPLEMENTAL EIR (SEIR) Exhibit 4.6-2 2030 TRAFFIC NOISE CONTOURS FOR GROUND LEVEL RECEPTORS Exhibit 4.6-2. 2030 Traffic Noise Contours for Ground Level Receptors SOURCE: Illingworth & Rodkin, 2014. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 162 4.7 AIR QUALITY AND GREENHOUSE GAS EMISSIONS INTRODUCTION Air quality impacts were analyzed in Chapter 3.11 of the Eastern Dublin EIR. Since the project requires an amendment to the City General Plan and Eastern Dublin Specific Plan to allow new land uses, this supplement to the EIR examines the potential air quality impacts of these new land uses. ENVIRONMENTAL SETTING Background. The project is located in the San Francisco Bay Area Air Basin. Ambient air quality standards have been established at both the State and Federal level. The Bay Area meets all ambient air quality standards with the exception of ground-level ozone, respirable particulate matter (PM10) and fine particulate matter (PM2.5). High ozone levels are caused by the cumulative emissions of reactive organic gases (ROG) and nitrogen oxides (NOx). These precursor pollutants react under certain meteorological conditions to form high ozone levels. Controlling the emissions of these precursor pollutants is the focus of the Bay Area’s attempts to reduce ozone levels. Highest ozone levels in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources. High ozone levels aggravate respiratory and cardiovascular diseases, reduced lung function, and increase coughing and chest discomfort. Particulate matter is another problematic air pollutant in the Bay Area. Particulate matter is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM10) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM2.5). Elevated concentrations of PM10 and PM2.5 are the result of both region-wide (or cumulative) emissions and localized emissions. High particulate matter levels aggravate respiratory and cardiovascular diseases, reduce lung function, increase mortality (e.g., lung cancer), and result in reduced lung function growth in children. The ambient air quality in a given area depends on the quantities of pollutants emitted within the area, transport of pollutants to and from surrounding areas, local and regional meteorological conditions, as well as the surrounding topography of the air basin. Air quality is described by the concentration of various pollutants in the atmosphere. Units of concentration are generally expressed in parts per million (ppm) or micrograms per cubic meter (µg/m3). Dublin is located in the San Ramon Valley, where wind speeds rank as some of the lowest in the Bay Area. Air temperatures are cooler in the winter and warmer in the summer because these valleys are further from the moderating effect of large water bodies, and because the Coast Range blocks marine air flow. During the summer, average daily maximum temperatures in the San Ramon/Tri-Valley region are in the high 80's to 90 degrees. Average minimum temperatures in winter are in the low to mid 40's. Shielded by the Coast Range to the west, rainfall amounts in the San Ramon/Tri- Valley region are relatively low. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 163 Pollution potential is significant in these valleys. In the winter, light winds at night, coupled with a surface-based inversion and terrain blocking to the east and west does not allow much dispersion of pollutants. San Ramon Valley with its very narrow width could easily have pollution buildups from emissions contributed by the major freeway in its center, and by emissions from fireplaces and wood stoves. In the summer months, ozone can be transported into the valleys from both the Central Valley and the central Bay Area. National and state ambient air quality standards. As required by the Federal Clean Air Act, National Ambient Air Quality Standards (NAAQS) have been established for six major air pollutants: carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), particulate matter, including respirable particulate matter (PM10) and fine particulate matter (PM2.5), sulfur oxides, and lead. Pursuant to the California Clean Air Act, the State of California has established the California Ambient Air Quality Standards (CAAQS). Relevant Current State and Federal standards are summarized in Table 4.7-1. CAAQS are generally the same or more stringent than NAAQS. Air Quality Monitoring Data. The significance of a pollutant concentration is determined by comparing the concentration to an appropriate ambient air quality standard. The standards represent the allowable pollutant concentrations designed to ensure that the public health and welfare are protected, while including a reasonable margin of safety to protect the more sensitive individuals in the population. The San Francisco Bay Area is considered to be one of the cleanest metropolitan areas in the country with respect to air quality. The Bay Area Air Quality Management District (BAAQMD) monitors air quality conditions at more than 20 locations throughout the Bay Area. The closest monitoring station to the project site is in Livermore at the 793 Rincon Avenue monitoring station. Summarized air pollutant data for this station is provided in Table 4.7-2. This table shows the highest air pollutant concentrations measured at the station over the five-year period from 2008 through 2012. Note that BAAQMD discontinued monitoring of carbon monoxide in 2009. These data show that ozone levels exceeded State or Federal standards each year over the past five years. The PM2.5 24-hour standard was exceeded in 2008 and 2009. Ambient Air Quality Status. Areas with air pollutant levels that exceed adopted air quality standards are designated as “nonattainment” areas for the relevant air pollutants. Nonattainment areas are sometimes further classified by degree (marginal, moderate, serious, severe, and extreme for ozone, and moderate and serious for carbon monoxide and PM10) or status (“nonattainment-transitional”). Areas that comply with air quality standards are designated as “attainment” areas for the relevant air pollutants. “Unclassified” areas are those with insufficient air quality monitoring data to support a designation of attainment or nonattainment, but are generally presumed to meet the ambient air quality standard. State Implementation Plans must be prepared by states for areas designated as federal nonattainment areas to demonstrate how the area will come into attainment of the exceeded federal ambient air quality standard. The Bay Area is considered a marginal nonattainment area for ozone under the NAAQS and nonattainment for ozone under the CAAQS (both 1- and 8-hour standards). The Bay Area is also designated as nonattainment for the 24-hour PM2.5 NAAQS. The Bay Area is also considered nonattainment for the State annual PM2.5 standard and the 24-hour PM10 standard. The region is designated attainment or unclassified for all other ambient air quality standards. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 164 Table 4.7-1. Relevant California and National Ambient Air Quality Standards Pollutant Averaging Time California Standards National Standards Ozone 8-hour 0.070 ppm (137 µg/m3) 0.075 ppm (147µg/m3) 1-hour 0.09 ppm (180 µg/m3) — Carbon monoxide 1-hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) 8-hour 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3) Nitrogen dioxide 1-hour 0.18 ppm (339 µg/m3) 0.100 ppm (188 µg/m3) Annual 0.030 ppm (57 µg/m3) 0.053 ppm (100 µg/m3) Sulfur Dioxide 1-hour 0.25 ppm (655 µg/m3) 0.075 ppm (196 µg/m3) 24-hour 0.04 ppm (105 µg/m3) 0.14 ppm (365 µg/m3) Annual —0.03 ppm (56 µg/m3) Particulate Matter (PM10) Annual 20 µg/m3 — 24-hour 50 µg/m3 150 µg/m3 Particulate Matter (PM2.5) Annual 12 µg/m3 12 µg/m3 24-hour —35 µg/m3 Source: BAAQMD and EPA, 2013. Notes: ppm = parts per million mg/m3 = milligrams per cubic meter µg/m3 = micrograms per cubic meter Table. 4.7-2. Highest Measured Air Pollutant Concentrations at Livermore Station Pollutant Average Time Measured Air Pollutant Levels 2008 2009 2010 2011 2012 Ozone (O3) 1-Hour 0.141 ppm 0.113 ppm 0.150 ppm 0.115 ppm 0.102 ppm 8-Hour 0.111 ppm 0.086 ppm 0.098 ppm 0.085 ppm 0.090 ppm Carbon Monoxide (CO) 8-Hour 1.4 ppm 1.3 ppm ND ND ND Nitrogen Dioxide (NO2) 1-Hour 0.058 ppm 0.052 ppm 0.058 ppm 0.053 ppm 0.057 ppm Annual 0.013 ppm 0.012 ppm 0.011 ppm 0.011 ppm 0.011 ppm Respirable Particulate Matter (PM10) 24-Hour 46.8 ug/m3 ND ND ND ND Annual ND ND ND ND ND Fine Particulate Matter (PM2.5) 24-Hour 52.7 ug/m3 45.7 ug/m3 34.7 ug/m3 23.6 ug/m3 31.1 ug/m3 Annual 10.1 ug/m3 9.2 ug/m3 7.6 ug/m3 7.8 ug/m3 6.5 ug/m3 Source: CARB, 2012. Notes: ppm = parts per million and ug/m3 = micrograms per cubic meter. Values reported in bold exceed ambient air quality standard. ND = No data. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 165 Sensitive Receptors. There are groups of people more affected by air pollution than others. The California Air Resources Board (CARB) has identified the following persons who are most likely to be affected by air pollution: children under 14, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, elementary schools, and parks. The closest sensitive receptors are residences located to the north and south of the project site over 1,000 feet away. La Petite Academy school is located approximately 1,400 feet north of the project site. Toxic Air Contaminants. Toxic air contaminants (TAC) are a broad class of compounds known to cause morbidity or mortality (usually because they cause cancer). TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter near a freeway). Because chronic exposure can result in adverse health effects, TACs are regulated at the regional, state, and Federal level. Diesel exhaust is the predominant TAC in urban air and is estimated to represent about three- quarters of the cancer risk from TACs (based on the Bay Area average). According to the CARB, diesel exhaust is a complex mixture of gases, vapors and fine particles. This complexity makes the evaluation of health effects of diesel exhaust a complex scientific issue. Some of the chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the CARB, and are listed as carcinogens either under the state's Proposition 65 or under the Federal Hazardous Air Pollutants programs. CARB has adopted and implemented a number of regulations for stationary and mobile sources to reduce emissions of diesel particulate matter (DPM). Several of these regulatory programs affect medium and heavy-duty diesel trucks that represent the bulk of DPM emissions from California highways. These regulations include the solid waste collection vehicle (SWCV) rule, in-use public and utility fleets, and the heavy-duty diesel truck and bus regulations. In 2008, CARB approved a new regulation to reduce emissions of DPM and nitrogen oxides from existing on-road heavy-duty diesel fueled vehicles.12 The regulation requires affected vehicles to meet specific performance requirements between 2012 and 2023, with all affected diesel vehicles required to have 2010 model-year engines or equivalent by 2023. These requirements are phased in over the compliance period and depend on the model year of the vehicle. BAAQMD. The BAAQMD is the regional agency tasked with managing air quality in the region. At the State level, CARB (a part of the California Environmental Protection Agency) oversees regional air district activities and regulates air quality at the State level. The BAAQMD published CEQA Air Quality Guidelines are used in this assessment to evaluate air quality impacts of projects.13 Greenhouse Gases. Global temperatures are affected by naturally occurring and anthropogenic- 12 Available online: http://www.arb.ca.gov/msprog/onrdiesel/onrdiesel.htm. Accessed: July 31, 2012. 13 BAAQMD, 2011. California Environmental Quality Act Air Quality Guidelines. May. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 166 generated (generated by humankind) atmospheric gases, such as water vapor, carbon dioxide, methane, and nitrous oxide. Gases that trap heat in the atmosphere are called greenhouse gases (GHG). Solar radiation enters the earth's atmosphere from space, and a portion of the radiation is absorbed at the surface. The earth emits this radiation back toward space as infrared radiation. Greenhouse gases, which are mostly transparent to incoming solar radiation, are effective in absorbing infrared radiation and redirecting some of this back to the earth's surface. As a result, this radiation that otherwise would have escaped back into space is now retained, resulting in a warming of the atmosphere. This is known as the greenhouse effect. The greenhouse effect helps maintain a habitable climate. Emissions of GHGs from human activities, such as electricity production, motor vehicle use and agriculture, are elevating the concentration of GHGs in the atmosphere, and are reported to have led to a trend of unnatural warming of the earth's natural climate, known as global warming or global climate change. The term "global climate change" is often used interchangeably with the term "global warming," but "global climate change" is preferred because it implies that there are other consequences to the global climate in addition to rising temperatures. Other than water vapor, the primary GHGs contributing to global climate change include the following gases: • Carbon dioxide (CO2), primarily a byproduct of fuel combustion; • Nitrous oxide (N2O), a byproduct of fuel combustion; also associated with agricultural operations such as the fertilization of crops; • Methane (CH4), commonly created by off-gassing from agricultural practices (e.g. livestock), wastewater treatment and landfill operations; • Chlorofluorocarbons (CFCs) were used as refrigerants, propellants and cleaning solvents, but their production has been mostly prohibited by international treaty; • Hydrofluorocarbons (HFCs) are now widely used as a substitute for chlorofluorocarbons in refrigeration and cooling; and • Perfluorocarbons (PFCs) and sulfur hexafluoride (SF6) emissions are commonly created by industries such as aluminum production and semiconductor manufacturing. These gases vary considerably in terms of Global Warming Potential (GWP), a term developed to compare the propensity of each GHG to trap heat in the atmosphere relative to another GHG. GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and the length of time of gas remains in the atmosphere. The GWP of each GHG is measured relative to CO2. Accordingly, GHG emissions are typically measured and reported in terms of CO2 equivalent (CO2e). For instance, SF6 is 22,800 times more intense in terms of global climate change contribution than CO2. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 167 IMPACTS AND MITIGATIONS FROM THE EASTERN DUBLIN EIR The Eastern Dublin EIR identified significant impacts related to construction, mobile source and stationary source emissions (Impacts 3.11/A, B, C, E). Mitigation measures were adopted to control construction dust and exhaust emissions, and to minimize mobile and stationary source emissions through, among other things, cooperative transportation and air quality planning and transportation demand management. All mitigation measures adopted upon approval of the Eastern Dublin GPA/SP continue to apply to implementing actions and projects such as the proposed Project. Even with mitigation, however, significant cumulative construction, mobile source and stationary source impacts remained. (Impacts 3.11/A, B, C, E). Upon approval of the Eastern Dublin GPA/SP, the City adopted a Statement of Overriding Considerations for these significant unavoidable impacts. (Resolution No. 53-93.) The topic of greenhouse gas emissions was not analyzed in the Eastern Dublin EIR. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES The proposed General Plan and Specific Plan amendment would change land uses and development intensity from those analyzed in the Eastern Dublin EIR. Potential supplemental impacts of the proposed project are analyzed below in accordance with CEQA standards. Significance criteria. The following standards have been used to assess potential impacts related to air quality and greenhouse gas emissions: • Conflict with or obstruct implementation of the applicable air quality plan; • Violate any air quality standard or contribute substantially to an existing or projected air quality violation; • Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions, which exceed quantitative thresholds for ozone precursors); • Expose sensitive receptors to substantial pollutant concentrations;  Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; and/or  Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs. This assessment is based on BAAQMD’s 2010 CEQA thresholds. BAAQMD’s adoption of its 2010 thresholds have been challenged in the lawsuit of California Building Industry Association v. BAAQMD which is pending before the California Supreme Court (Supreme Court Case No. S213478). The Supreme Court granted review on the issue of whether CEQA requires the analysis of the impacts of the environment on the project. The Court of Appeal decision upheld BAAQMD’s adoption of the thresholds. The issue pending before the Supreme Court is not directly related to the scientific basis of BAAQMD’s analysis of what levels of pollutants should be deemed significant. The scientific and evidentiary basis supporting the BAAQMD CEQA Thresholds are set forth in the studies and documents in BAAQMD’s record for adoption of the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 168 thresholds, including, but not limited to, the Options and Justification Report (dated October 2009) prepared by BAAQMD. Per CEQA Guidelines Section 15064.7 (Thresholds of Significance) the City exercise its own discretion to use the significance thresholds in the BAAQMD’s 2011 CEQA thresholds based on substantial evidence contained in BAAQMD’s record for adoption of the thresholds (which is relied on and incorporated herein).14 Accordingly, this assessment uses the 2010 thresholds and methodologies from BAAQMD’s May 2011 CEQA Air Quality Guidelines to determine the potential impacts of the project on the existing environment. The significance thresholds used in this analysis are based on BAAQMD standards and are summarized in Table 4.7-3. Table 4.7-3. Air Quality Significance Thresholds Pollutant Construction Thresholds Operational Thresholds Average Daily Emissions (lbs./day) Average Daily Emissions (lbs./day) Annual Average Emissions (tons/year) Criteria Air Pollutants ROG 54 54 10 NOx 54 54 10 PM10 82 82 15 PM2.5 54 54 10 CO Not Applicable 9.0 ppm (8-hour avg.) or 20.0 ppm (1-hour avg.) Fugitive Dust Best Management Practices Not Applicable Health Risks and Hazards for New Sources and Receptors Excess Cancer Risk 10 per one million 10 per one million Hazard Index 1.0 1.0 Incremental annual average PM2.5 0.3 µg/m3 0.3 µg/m3 Health Risks and Hazards for Sensitive Receptors (Cumulative from all sources within 1,000 foot zone of influence) and Cumulative Thresholds for New Sources Excess Cancer Risk 100 per one million Chronic Hazard Index 10.0 Annual Average PM2.5 0.8 µg/m3 Greenhouse Gas Emissions GHG Emissions (Annual) Compliance with a Qualified GHG Reduction Strategy or 1,100 metric tons or 4.6 metric tons per capita Note: ROG = reactive organic gases, NOx = nitrogen oxides, PM10 = course particulate matter or particulates with an aerodynamic diameter of 10 micrometers (µm) or less, PM2.5 = fine particulate matter or particulates with an aerodynamic diameter of 2.5µm or less; and GHG = Greenhouse gases. Source: BAAQMD, 2010 and 2011. SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES The following significant supplemental air quality impacts and mitigation measures are identified in this DSEIR. Contribution to cumulatively considerable air pollutants. The Bay Area is considered a non- attainment area for ground-level ozone and fine particulate matter (PM2.5) under both the Federal Clean Air Act and the California Clean Air Act. The area is also considered non-attainment for 14 BAAQMD. 2010. California Environmental Quality Act Guidelines Update Proposed Thresholds of Significance. May. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 169 respirable particulates or particulate matter with a diameter of less than 10 micrometers (PM10) under the California Clean Air Act, but not the Federal act. The area has attained both State and Federal ambient air quality standards for carbon monoxide. The California Emissions Estimator Model (CalEEMod) Version 2013.2.2 was used to predict emissions from construction and operation of the site assuming full build out of the project. The project land use types and size, and trip generation rate were input to CalEEMod. Construction period emissions. CalEEMod provided annual emissions for construction. CalEEMod provides emission estimates for both on-site and off-site construction activities. On- site activities are primarily made up of construction equipment emissions, while off-site activity includes worker and vendor traffic. As a balanced site, no substantial hauling of soils is expected. A construction build-out scenario, including CalEEmod default equipment list and phasing schedule for a project of this type and size was used. No cranes are expected for use and, since temporary line power is expected to be available, no generators were modeled. Attachment 1 (see Appendix 8.9) includes the CalEEMod output for construction emissions. The proposed land uses were input into CalEEMod, 35,000 square feet (s.f.) “High Turnover (Sit Down Restaurant),”5,000 s.f. “Strip Mall,” or other retail, and 400 dwelling units “Condo/Townhouse.” The modeling scenario assumes that the project would be built out over a period of approximately 26 months beginning in Spring of 2014, or an estimated 575 construction workdays. Average daily emissions were computed by dividing the total construction emissions by the number of construction days. Table 4.7-4 shows average daily construction emissions of ROG, NOX, PM10 exhaust, and PM2.5 exhaust during construction of the project. As indicated in Table 4.7-4, predicted project emissions would not exceed the BAAQMD significance thresholds. Construction activities, particularly during site preparation and grading would temporarily generate fugitive dust in the form of PM10 and PM2.5. Sources of fugitive dust would include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site would deposit mud on local streets, which could be an additional source of airborne dust after it dries. Fugitive dust emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. Fugitive dust emissions would also depend on soil moisture, silt content of soil, wind speed, and the amount of equipment operating. Larger dust particles would settle near the source, while fine particles would be dispersed over greater distances from the construction site. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 170 Table 4.7-4. Construction Period Emissions Scenario ROG NOx PM10 Exhaust PM2.5 Exhaust 2014 Construction emissions (tons)0.49 tons 4.00 tons 0.22 tons 0.20 tons 2015 Construction emissions (tons)0.55 tons 3.21 tons 0.20 tons 0.18 tons 2016 Construction emissions (tons)3.47 tons 1.10 tons 0.07 tons 0.06 tons Average daily emissions (pounds)1 15.7 lbs.28.9 lbs.1.7 lbs.1.5 lbs. BAAQMD Thresholds (pounds per day) 54 lbs.54 lbs.82 lbs.54 lbs. Exceed Threshold? No No No No Notes: 1 Assumes 575 workdays. Although EDSP EIR air quality Mitigation Measure 3.11/1.0 provides specific methods for reduction of fugitive dust from construction sites, the BAAQMD has adopted updated measures to further reduce construction level impacts. Therefore, the project applicant shall adhere to Supplemental Mitigation Measure SM-AQ-1, which shall replace EDSP EIR Mitigation Measure 3.11/1.0. Supplemental Mitigation Measure SM-AQ-1 (construction period air emissions). The project applicant shall adhere to the following dust control measures as recommended by the BAAQMD, which shall replace those included in EDSP EIR Mitigation Measure 3.11/1.0: a) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. b) All haul trucks transporting soil, sand, or other loose material off-site shall be covered. c) 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. d) All vehicle speeds on unpaved roads shall be limited to 15 mph. e) All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. f) Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 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. g) 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. h) Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 171 corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations. With adherence to the above supplemental mitigation measure, construction period air quality impacts will be less-than-significant. Operational Period Emissions. Operational air emissions from the project would be generated primarily from autos driven by future residents, customers, employees and delivery trucks. Evaporative emissions from architectural coatings and maintenance products are other typical emissions from commercial uses. CalEEMod was used to predict emissions from operation of the site assuming full build out of the project. The project land use types and size, and trip generation rate were input to CalEEMod. Adjustments to the model are described below. Model output worksheets are included in Attachment 1(see Appendix 8.9). Emissions associated with vehicle travel depend on the year of analysis because emission control technology requirements are phased-in over time. Therefore, the earlier the year analyzed in the model, the higher the emission rates CalEEMod uses. The earliest full year the residential portion of the project could possibly be constructed and be occupied would be 2017. Use of this date is considered conservative, as emissions associated with build-out later than 2017 would be lower. CalEEMod allows the user to enter specific trip generation rates. Kittelson & Associates, Inc., provided trip generation rates for the project by land use type, which were entered into the model. Kittelson & Associates, Inc., also provided specific pass-by trip rates (5 percent for the restaurants and 5 percent for the Other Retail) for the project, internal trip reduction, and a walking trips to BART reduction (5 percent), which were input to the model. The default trip lengths and trip types specified by CalEEMod were used. This includes customer trip length of 7.3 miles per one-way trip. Table 4.7-5 reports the predicted average daily operational emissions and Table 4.7- 6 reports annual emissions. As shown in Tables 4.7-5 and 4.7-6, average daily and annual emissions of ROG, PM10, or PM2.5 emissions associated with operation would not exceed the BAAQMD significance thresholds. However, NOX, emissions would exceed BAAQMD significance thresholds, which would be a significant impact. Table 4.7-5. Daily Air Pollutant Emissions from Operation of the Project (pounds/day) Scenario ROG NOx PM10 PM2.5 2017 Project 36.0 68.2 30.0 8.88 Daily Emission Thresholds 54 54 82 54 Exceed Threshold? No Yes No No The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 172 Table 4.7-6. Annual Air Pollutant Emissions from Operation of the Project (tons/year) Scenario ROG NOx PM10 PM2.5 Area 2.30 0.04 0.02 0.02 Energy 0.09 0.80 0.06 0.06 Mobile 4.18 11.61 5.39 1.54 Waste 0.00 0.00 0.00 0.00 Water 0.00 0.00 0.00 0.00 Total 2017 Project 6.6 12.5 5.5 1.6 Annual Emission Thresholds 10 10 15 10 Exceed Threshold? No Yes No No Supplemental Project Impact AQ-1 (emission of cumulative considerable air pollutants during project operation). The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under applicable Federal or State ambient air quality standards due to emissions of NOX (Significant and Unavoidable supplemental impact). Site-specific land use features that could reduce vehicle emissions were also input to the model, including the approximate number of intersections per square miles (influencing walkability) and accessibility to nearby transit. Emissions reductions from these specific site features are included in the mitigated emissions output, by the nature of the CalEEMod air model. Results of modeling indicate that consideration of these site-specific features would reduce operational NOX emissions to 11.4 tons annually, which would still be significant. The following measure is recommended to partially reduce the above impact. Supplemental Mitigation Measure SM-AQ-2 (emission of cumulative considerable air pollutants during project operation). The project applicant shall reduce future residential and employee trips through a Traffic Demand Management (TDM) program approved by the City and including, but not limited to, the following measures: a) Appoint Transportation Coordinator to oversee the TDM program developed for the project including program development, information distribution and program implementation. b) Promote and distribute hard copy information quarterly to all employees and residents regarding 511, Ridematch, Guaranteed Ride Home Program, Wheels/LAVTA, Altamont Corridor Express (ACE), BART, shuttles to regional transit, and any car share programs. c) Distribute information quarterly regarding above by email blast to all employees and residents. d) Co-sponsor subarea transportation fair once a year with “The Village” property to the north and/or other developments in the East Dublin area. Invite Wheels, 511.org, and at least two other commute alternative service providers to attend and distribute commute alternative information. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 173 e) Provide bicycle parking facilities for 20 percent of commercial car spaces or a number approved by the City beyond the City’s bicycle rack requirement. f) Provide secured bicycle parking (lockers or cages) for employees. g) Join City Car Share as a “Biz Prime” member and pay for membership of a minimum of five percent employees. h) Implement a BART subsidy program that would provide BART tickets at no cost or subsidized rate to all employees. i) Implement a Commuter Tax Benefit Program or equivalent. Under Section 132(F) of federal tax code, an employer can offer its employees up to $245 per month for qualified transit, vanpool or parking costs. Or, an employer may offer $20 per month for bicycling costs. Full information is available at: http://rideshare.511.org/rewards/tax_benefits.aspx j) Provide preferential parking for carpools and vanpools as part of off-street parking requirements. k) Provide shading in the parking lot, to the maximum extent possible, to reduce evaporative ROG emissions. Supplemental Mitigation Measure SM-AQ-2 from the IKEA SEIR shall also be implemented. Considering that 78 full-time employees are anticipated, this accounts for about 7 percent of future expected service population of the project (future full-time employees plus residents – 1,080 residents are expected based on 2.7 persons per dwelling unit, as indicated by the project applicant). However, even with the TDM program in place, it is not certain that annual NOX emissions would be reduced below 10 tons per year because it is not possible at this time to accurately quantify possible emissions reductions. Similarly, it is not possible to quantify possible emissions reductions from residential uses. A TDM program has not yet been proposed and would likely only affect a small amount of the overall project trips. Of the retail-related trips, only a small percentage is from employee commute, which a TDM program would be most effective in controlling. Therefore, even with the TDM program in place, operational NOX emissions could still exceed the established significance thresholds. Because the vast majority of NOX emissions will be from mobile sources, and it is not possible to quantify potential emissions reductions from implementation of a TDM program at this time, this impact would remain Significant and Unavoidable. Violation of air quality standards. As discussed above, the project would have operational NOX emissions that exceed the significance thresholds adopted by BAAQMD. Therefore, the project would contribute substantially to existing or projected violations of those standards. Carbon monoxide emissions from traffic generated by the project would be the pollutant of greatest concern at the local level. Congested intersections with a large volume of traffic have the greatest potential to cause high-localized concentrations of carbon monoxide. Air pollutant monitoring data indicate that carbon monoxide levels have been below State and Federal standards in the Bay Area since the early 1990s. As a result, the region has been designated as attainment for the standard. There is an ambient air quality monitoring station in Livermore that measures carbon monoxide concentrations. The highest measured level over any 8-hour averaging period during the last 5 years is less than 2.0 parts per million (ppm), compared to the ambient air quality standard of 9.0 ppm. BAAQMD screening guidance indicates that projects would have a less than significant impact to carbon monoxide levels (including potential The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 174 localized hotspots) if project traffic projections indicate traffic levels would not increase at any affected intersection to more than 44,000 vehicles per hour. The intersections affected by the proposed project would have much lower traffic volumes (less than 10,000 vehicles per hour including the project, based on the project traffic analysis). Therefore, the change in traffic caused by the proposed project would be minimal and the project would not cause or contribute to a violation of an ambient air quality standard. However, because operation of the project would exceed significance thresholds for NOX, as discussed above, the project would contribute substantially to existing and future violations of ozone ambient air quality standards. This impact is considered Significant and Unavoidable. Supplemental Project Impact AQ-2 (violation of air quality standards). The project would result in a violation of regional air quality standard and would contribute substantially to an existing or projected air quality violation (Significant and Unavoidable supplemental impact) Adherence to Supplemental Mitigation Measure SM-AQ-2 would partially, but not fully, mitigate the above impact and Supplemental Impact AQ-2 will remain Significant and Unavoidable. Conflict with applicable air quality plan. The most recent clean air plan is the Bay Area 2010 Clean Air Plan (Clean Air Plan) that was adopted by BAAQMD in September 2010. This plan addresses air quality impacts with respect to obtaining ambient air quality standards for non- attainment pollutants (i.e., ozone and particulate matter or PM10 and PM2.5), reducing exposure of sensitive receptors to TACs, and reducing greenhouse gas emissions such that the region can meet AB 32 goals of reducing emissions to 1990 levels by 2020. Emissions of non-attainment criteria air pollutants are addressed above. The consistency of the proposed project with the Clean Air Plan is primarily a question of whether or not a project would attain air quality standards (i.e., result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under applicable Federal or State ambient air quality standards). The proposed project would not substantially affect traffic forecasts adversely and, as discussed in the traffic chapter, projected trips due to project implementation would be less than those approved for the current use per the Year 2035 Dublin Model. However, as discussed above, implementation of the project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under applicable Federal or State ambient air quality standards; therefore, the project is inconsistent with the Clean Air Plan because the project would not support the Clean Air Plan’s goal of attaining air quality standards. For informational purposes, project consistency with the Clean Air Plan control measures are summarized below. Consistency with Clean Air Plan Control Measures. The CAP includes emissions control measures that are intended to reduce air pollutant emissions in the Bay Area either directly or indirectly. The control measures are divided in to five categories that include: The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 175  measures to reduce stationary and area sources;  mobile source measures;  transportation control measures;  land use and local impact measures; and  energy and climate measures In developing the control measures, BAAQMD identified the full range of tools and resources available, both regulatory and non-regulatory, to address emissions. Implementation of each control measure will rely on some combination of the following:  Adoption and enforcement of rules to reduce emissions from stationary sources, area sources, and indirect sources;  Revisions to BAAQMD’s permitting requirements for stationary sources;  Enforcement of CARB rules to reduce emissions from heavy-duty diesel engines;  Allocation of grants and other funding by the Air District and/or partner agencies;  Promotion of best policies and practices that can be implemented by local agencies through guidance documents, model ordinances, etc.;  Partnerships with local governments, other public agencies, the business community, non-profits, etc.;  Public outreach and education;  Enhanced air quality monitoring;  Development of land use guidance and CEQA guidelines, and Air District review and comment on Bay Area projects pursuant to CEQA; and  Leadership and advocacy. This approach relies upon lead agencies to assist in implementing some of the control measures. A key tool for local agency implementation is the development of land use policies and implementing measures that address new development or redevelopment in local communities. The consistency of the proposed General Plan amendment is evaluated with respect to each set of control measures. Stationary and Area Source Control Measures. The CAP includes Stationary Source Control measures that BAAQMD adopts as rules or regulations through their authority to control emissions from stationary and area sources. The BAAQMD is the implementing agency, since these control measures are applicable to sources of air pollution that must obtain District permits. Any new stationary sources would be required to obtain proper permits through BAAQMD. However, no new stationary sources are proposed as part of the project. In addition, the City uses BAAQMD’s CEQA Air Quality Guidelines to evaluate air pollutant emissions from new sources. Mobile Source Measures. The CAP includes Mobile Source Measures that would reduce emissions by accelerating the replacement of older, dirtier vehicles and equipment through programs such as the BAAQMD’s Vehicle Buy-Back and Smoking Vehicle Programs, and promoting advanced technology vehicles that reduce emissions. The implementation of these measures relies heavily upon incentive programs, such as the Carl Moyer Program and the Transportation Fund for Clean Air, to achieve voluntary emission reductions in advance of, or in The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 176 addition to, CARB requirements. CARB has new regulations that require the replacement or retrofit of on-road trucks, construction equipment and other specific equipment that is diesel powered. However, these measures are not directly applicable to the proposed project. Transportation Control Measures. The CAP includes transportation control measures (TCMs) that are strategies meant to reduce vehicle trips, vehicle use, vehicle miles traveled, vehicle idling, or traffic congestion for the purpose of reducing motor vehicle emissions. While most of the TCMs are implemented at the regional level (e.g., by MTC or Caltrans), there are measures that the CAP relies upon local communities to assist with implementation. In addition, the CAP includes land use measures and energy and climate measures where implementation is aided by proper land use planning decisions. The City’s General Plan, along with the Climate Action Plan,15 include measures to reduce vehicle travel that are generally consistent with the CAP TCMs. Land use and Local Impact Measures- TAC Exposure. The CAP includes measures to reduce TAC exposure to sensitive receptors. The City, as Lead CEQA Agency, uses the BAAQMD CEQA Air Quality Thresholds to identify significant risks and develop appropriate mitigation measures. Energy and Climate Measures. Supplemental Impact AQ-5 addresses energy and climate issues with the proposed project. The City has adopted a Qualified GHG Reduction Strategy, or Climate Action Plan, that addresses the Clean Air Plan’s control measures regarding energy and climate. Table 4.7-7 lists the relevant Clean Air Plan policies to the project indicates compliance or non- compliance with the policies. Table 4.7-7. Project Consistency with Applicable Clean Air Plan Control Measures Control Measure Project Consistency Transportation Control Measures TCM B-2: Improve Transit Efficiency and Use Partially consistent. The project’s proximity to the Dublin/Pleasanton BART station and associated transit facilities would result in increased transit use. However, the project should implement a TDM program that would include measures such as a BART subsidy program that would provide BART tickets at no cost or subsidized rates to all employees. TCM C-1: Support Voluntary Employer-Based Trip Reduction Program Inconsistent. The project should implement a TDM program that would include measures such as a commuter tax benefit program (e.g., WageWorks) or equivalent on qualified transit, vanpool or parking costs and a rideshare program, such as Ridematch, Guaranteed Ride Home, Wheels/LAVTA, shuttles to regional transit, and City CarShare, and provide preferential parking for carpools and vanpools as part of off-street parking requirements. TCM C-3: Promote Rideshare Services and Incentives TCM D-1: Improve Bicycle Access and Facilities Partially consistent. The project would provide bicycle 15 City of Dublin, 2013. City of Dublin Climate Action Plan Update. July. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 177 Control Measure Project Consistency Transportation Control Measures parking in accordance with the requirements of the Zoning Ordinance. The project should implement a TDM program that commits to providing a defined number of bicycle parking facilities (i.e., 20% of the number of car spaces or a number approved by the City) and provide secured bicycle (lockers or cages) for employees. TCM D-2: Improve Pedestrian Access and Facilities Consistent. The project proposes to develop a pedestrian network that would connect to the Dublin- Pleasanton BART station and Hacienda Drive. Pubic sidewalks would be constructed along all adjacent public street frontages. TCM D-3: Support Local Land Use Strategies Consistent. The proposed project includes a variety of mixed retail services that would serve future nearby land uses, including project on-site residential. TCM E-2: Parking Pricing and Management Strategies Inconsistent. The project should implement a TDM program that would include measures such as preferential parking for carpools and vanpools. Energy and Climate Control Measures ECM-1: Energy Efficiency Consistent. The project would be required to comply with City’s Green Building section of the Municipal Code (Section 7.94), State energy efficiency standards, and the CALGreen building code. ECM-4: Tree-Planting Consistent. The project would plant trees adjacent to Hacienda Drive, Martinelli Way, Arnold Drive, the I- 580 freeway frontage and throughout the project site. Trees would also be planted within the parking lots, adjacent to proposed buildings, and concentrated in the commercial plaza and residential open space areas. As shown in Table 4.7-7, the project would be inconsistent with several of the Clean Air Plan control measures. This would be a potentially significant impact. Implementation of Supplemental Mitigation Measure SM-AQ-2 would reduce this impact. Supplemental Project Impact AQ-3 (conflict with applicable clean air plan). The project would conflict with the regional Clean Air Plan (Significant and Unavoidable supplemental impact). Adherence to Supplemental Mitigation Measure SM-AQ-2 would require implementation of a TDM program to reduce trips associated with the proposed project. However, even after mitigation, the project could still result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under applicable Federal or State ambient air quality standards. Therefore, the project would be inconsistent with the Clean Air Plan because the project would not support the Clean Air Plan’s goal of attaining air quality standards. As a result, the project impact from the project would remain Significant and Unavoidable. Impacts to Sensitive Receptors. Project impacts related to increased health risk can occur either by introducing a new sensitive receptor, such as a residential use, in proximity to an existing The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 178 source of TACs or by introducing a new source of TACs with the potential to adversely affect existing sensitive receptors in the project vicinity. The BAAQMD recommends using a 1,000- foot screening radius around a project site for purposes of identifying community health risk from siting a new sensitive receptor or a new source of TACs. The proposed project would introduce new sensitive receptors (residences) to the project site. Project Operation. Implementation of the project would locate new residences near Interstate 580 (I-580), local roadways, and one stationary source that emits TACs. The BAAQMD Guidelines include thresholds to evaluate single source and cumulative source impacts of TACs and PM2.5 on proposed sensitive receptors. At the direction of the City, the single source risk and hazards significance thresholds were used to evaluate impacts from all nearby existing TAC sources. Annual concentrations of DPM and total organic compounds were used to predict cancer and non-cancer health risks, in accordance with BAAQMD recommended methodology. Highway TAC Emissions. Traffic on high volume roadways is a source of TAC emissions that may adversely affect sensitive receptors that reside in close proximity to these roads. For roadways, BAAQMD has published screening tables and data to determine if roadways with traffic volumes of over 10,000 vehicles per day may have a significant effect on a proposed project. In the vicinity of the project area I-580 has 214,000 average daily trips (ADT), as reported by Caltrans.16 Therefore, a refined analysis of the impacts of toxic air contaminant (TAC) and fine particulate matter (PM2.5) is necessary to evaluate potential cancer risks and PM2.5 concentrations from I-580. A review of the traffic information reported by Caltrans indicates that I-580 traffic includes about 6.8 percent trucks, of which 5.1 percent are considered heavy duty trucks and 1.7 percent are medium duty trucks. Roadway Emissions Modeling. This analysis involved the development of DPM, organic TACs, and PM2.5 emissions for traffic on I-580 using the California Air Resources Board (CARB) EMFAC2011 emission factor model and the traffic mix developed from Caltrans data. EMFAC2011 is the most recent version of the CARB motor vehicle emission factor model. DPM emissions are projected to decrease in the future and are reflected in the EMFAC2011 emissions data. CARB regulations require on-road diesel trucks to be retrofitted with particulate matter controls or replaced to meet new 2010 engine standards that have require low DPM and PM2.5 emissions. This regulation will substantially reduce these emissions between 2013 and 2023, with the greatest reductions occurring in 2013 through 2015. While new trucks and buses will meet strict federal standards, this measure is intended to accelerate the rate at which the fleet either turns over so there are more cleaner vehicles on the road, or retrofitted to meet similar standards. With this regulation, older, more polluting trucks would be removed from the roads much quicker. CARB anticipates a 68 percent reduction in PM2.5 (including DPM) emission from trucks in 2014 with this regulation. Emission factors were developed for the years 2017, 2020, and 2025 using the calculated mix of cars and trucks on I-580. Default EMFAC2011 vehicle model fleet age distributions for Alameda County were assumed. Average daily traffic volumes and truck percentages were based on 16 California Department of Transportation, 2013. 2012 Traffic Volumes on the California State Highway System. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 179 Caltrans data for I-580.5,17 Traffic volumes were assumed to increase one percent per year. Average hourly traffic distributions for Alameda County roadways were developed using the EMFAC mode, which were then applied to the site-specific average daily traffic volumes to obtain estimated hourly traffic volumes and emissions for I-580. For all hours of the day, other than during peak a.m. and p.m. periods, an average speed of 65 mph was assumed for all vehicles other than trucks which were assumed to travel at a speed of 60 mph. An average travel speed of 50 mph was used for westbound traffic during the 2-hour peak a.m. period and a speed of 25 mph was used for eastbound traffic during the peak p.m. period.18 In addition to evaluating health risks from DPM, the BAAQMD recommends evaluating health effects from total organic gas (TOG) exhaust emissions from tailpipes and from evaporative running losses from non-diesel vehicles.19 Emissions of TOG were calculated for 2017, 2020, and 2025 using the EMFAC2011 model. These TOG emissions were then used in modeling organic TACs. TOG emissions from both exhaust and running evaporative loses from gasoline vehicles were calculated using EMFAC2011 default model values for Alameda County along with the traffic volumes and vehicle mixes for I-580. The hourly traffic distributions and DPM and TOG emission rates used in the analysis are shown in Attachment 1 (see Appendix 8.9). Roadway Dispersion Modeling. Dispersion modeling of TAC emissions was conducted using the CAL3QHCR model, which is recommended by the BAAQMD for this type of roadway analysis. A 5-year set of hourly meteorological data (2001 – 2005) for Pleasanton obtained from BAAQMD was used in the modeling. This monitoring station is about 1.25 miles southwest of the project site. Other inputs to the model included road geometry, hourly traffic volumes, and emission factors. East and west bound traffic on I-580 within about 1,000 feet of the project site were evaluated with the model. The modeling used a grid of receptors with receptors spaced every 15 meters (about 49 feet) within the proposed residential area for the project. Receptor heights of 1.5 meters were used for all receptors. Exhibit 4.7-1 shows the roadway links and residential receptor locations used in the modeling. Computed Cancer Risk. Using the modeled long-term average DPM and TOG concentrations, the individual cancer risks were computed using the most recent methods recommended by BAAQMD.20 The factors used to compute cancer risk are highly dependent on modeled concentrations, exposure period or duration, and the type of receptor. The exposure level is determined by the modeled concentration; however, it has to be averaged over a representative exposure period. The averaging period is dependent on many factors, but mostly the type of sensitive receptor that would reside at a site. This assessment conservatively assumed long-term residential exposures. BAAQMD has developed exposure assumptions for typical types of sensitive receptors. These include nearly continuous exposures of 70 years for residences. It should be noted that the cancer risk calculations for 70-year residential exposures reflect use of BAAQMD’s most recent cancer risk calculation method, adopted in 2010. The cancer risk 17 Caltrans, 2012. 2011 Annual Average Daily Truck Traffic on the California State Highways. Available: www.dot.ca.gov/hq/traffops/saferesr/trafdata/ 18 Alameda County Transportation Commission, 2011. 2011 Level of Service Monitoring Report. January 2013. 19 BAAQMD, 2012. Recommended Methods for Screening and Modeling Local Risks and Hazards. May. 20 BAAQMD, 2010. Air Toxics NSR Program Health Risk Screening Analysis (HSRA) Guidelines. January. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 180 calculations were based on applying age sensitivity weighting factors for each emissions period modeled. Age-sensitivity factors reflect the greater sensitivity of infants and small children to cancer causing TACs. Cancer risks from I-580 traffic are greatest for the residential units closest to the highway, with the maximum increased cancer risks occurring at receptors near the southeastern corner of the project site closest to I-580. Cancer risks decrease with distance from the highway. The maximum increased cancer risk for a ground level residential unit was computed as 60.7 in one million. The location of maximum cancer risk is shown on Exhibit 4.7-1. Cancer risks for ground level exposure throughout the site range from 15.4 in one million to 60.7 in one million. Exhibit 4.7-2 shows the computed cancer risk at each modeled ground level receptor location overlaid on the conceptual site plan for the project. Cancer risks above 10 per million would be considered a significant impact by the BAAQMD. Implementation of Supplemental Mitigation Measure SM- AQ-3 would reduce this impact to a level of less than significant. Potential non-cancer health effects due to chronic exposure to DPM were also evaluated. The chronic inhalation reference exposure level (REL) for DPM is 5 micrograms per cubic meter (μg/m3). The maximum predicted annual DPM concentration is 0.134 μg/m3, which is much lower than the REL. The Hazard Index (HI), which is the ratio of the annual DPM concentration to the REL, is 0.03. This HI is much lower than the BAAQMD significance criterion of a HI greater than 1.0. The modeling results and health risk calculations from I-580 traffic are provided in Attachment 1 (see Appendix 8.9). PM2.5 Concentrations from Roadway Traffic. In addition to evaluating the health risks from TACs, potential impacts from PM2.5 emissions from vehicles traveling on I-580 were evaluated. PM2.5 concentrations were modeled to evaluate the potential impact of exposure to PM2.5. To evaluate potential non-cancer health effects due to PM2.5, the BAAQMD adopted a significance threshold of an annual average PM2.5 concentration greater than 0.3 µg/m3. The same basic modeling approach that was used for assessing TAC impacts was used in the modeling of PM2.5 concentrations. PM2.5 emissions from all vehicles were used, rather than just the diesel powered vehicles, because all vehicle types (i.e., gasoline and diesel powered) produce PM2.5. Additionally, PM2.5 emissions from vehicle tire and brake wear were included in these emissions. The assessment involved, first, calculating PM2.5 emission rates from traffic traveling on I-580. Then, dispersion modeling using emission factors and traffic volumes was conducted. The dispersion model provides estimated annual PM2.5 concentrations. PM2.5 emissions were calculated using the EMFAC2011 model for the years 2017, 2020, and 2025. Average hourly traffic volumes were calculated in the same manner as discussed earlier for the TAC modeling. The emission rate calculations and traffic volumes are shown in Attachment 1 (see Appendix 8.9). Annual average PM2.5 concentrations from I-580 traffic are greatest for the residential units closest to the highway, with the maximum increased concentrations occurring at receptors near the southeastern corner of the project site closest to I-580. PM2.5 concentrations decrease with distance from the highway. The maximum increased annual PM2.5 concentration for a ground level residential unit was 0.67 μg/m3. The location of maximum PM2.5 concentration is the same The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 181 as shown for cancer risk on Exhibit 4.7-1. Annual PM2.5 concentrations for ground level exposure throughout the site range from 0.16 μg/m3 to 0.67 μg/m3. Exhibit 4.7-3 shows the maximum annual PM2.5 concentrations at each modeled ground level receptor location overlaid on the conceptual site plan for the project. PM2.5 concentrations greater than 0.3 µg/m3 are considered significant. Implementation of Supplemental Mitigation Measure SM-AQ-3 would reduce this impact to a level of less than significant. Local Roadway TAC Emissions. BAAQMD provides Roadway Screening Analysis Tables that can be used to assess potential excess cancer risk and annual PM2.5 concentrations from surface streets for each Bay Area county. There are two roadways in the project area that could affect the project site (i.e. average daily traffic or ADT volumes at or above 10,000 trips). Hacienda Drive and Martinelli Way are adjacent to the eastern and northern parts of the project site, respectively. The traffic study provides peak a.m. and p.m. hourly traffic volumes. The ADT for these roadways were computed by assuming that the p.m. peak hour is 10 percent of the average daily traffic volume, and then taking the average of Existing Plus Project and 2035 Plus Project conditions to estimate volumes at project operational year. Hacienda Drive would have an ADT of 39,170 vehicles and Martinelli Way would have an ADT of 12,628 daily vehicles. Modeling of Hacienda Drive and Martinelli Way to assess cancer risks and PM2.5 concentrations from vehicle traffic on these roadways was conducted in a similar manner as was done for I-580 impacts. The CAL3QHCR model was run using five years of hourly Pleasanton meteorological data and roadway-specific geometry, hourly traffic volumes, and emission factors to calculate DPM, PM2.5, and TOG TAC concentrations at residential receptor locations in the project height of 1.5 meters Emission factors for traffic on Hacienda Drive and Martinelli Way were calculated using CARB’s EMFAC2011 model assuming the default Santa Clara County traffic mix and a speed of 30 mph for Hacienda Drive and 35 mph for Martinelli Way. Emissions for 2020 were used for the modeling and in developing estimates of increased cancer risks from these roads. Use of 2020 emissions provides a conservative estimate of roadway emissions for the 70-year period evaluated for cancer risks. Traffic volumes for 2020 were based on the traffic study for the project, as discussed above, and a BAAQMD recommended truck percentage of 4.09 percent for Alameda County.21 Approximately 67 percent of the truck traffic was assumed to be medium- duty trucks (i.e., delivery type trucks) and the remainder as being heavy duty trucks. Results of local roadway risk modeling are shown in Table 4.7-8. Stationary Source TAC Emissions. Permitted stationary sources of air pollution near the project site were identified using the BAAQMD’s Stationary Source Risk and Hazard Analysis Tool. This mapping tool uses Google Earth to identify the location of stationary sources and their estimated risk and hazard impacts. At BAAQMD’s direction, risk and PM2.5 concentrations from one diesel generator was adjusted for distance based on BAAQMD distance adjustment factors. 21 BAAQMD, 2012. Recommended Methods for Screening and Modeling Local Risks and Hazards. May. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 182 A diesel back-up generator operated Oracle USA, Inc. (BAAQMD Plant No. 17753) at 5805 Owens Drive, is located approximately 500 feet southwest of the project site. Modeling of the emergency back-up generator was conducted assess cancer risks and PM2.5 concentrations at residential receptor locations in the project height of 1.5 meters. The ISCST3 model was run using five years of hourly Pleasanton meteorological data to calculate DPM and PM2.5 concentrations at project receptor locations. Based on the BAAQMD 2011 Toxic Inventory, annual DPM emissions from this source are 1.77 pounds per year. Default BAAQMD stack parameters for generator screening (6 feet high stack, 3 inch diameter, 50 meter/sec exit velocity, and exit temperature of 656 degrees F) were used for the modeling. Increased cancer risks were calculated based on the modeled concentrations and BAAQMD recommended methods. Details of the in the analysis for the generator are shown in Attachment 1 (see Appendix 8.9). Results of the emergency back-up generator modeling are shown in Table 4.7-8. Cumulative Risks. Cumulative TAC impacts to proposed sensitive receptors were evaluated by adding the cancer risk, Hazard Index and PM2.5 concentrations at the maximally exposed individual (MEI) from each source. As discussed above, at the direction of the City, the single source thresholds were used to evaluate impacts from all nearby existing TAC sources. Table 4.7-8 shows the community risk impacts from each source upon sensitive receptors. As shown in Table 4.7-8, cumulative cancer risk and PM2.5 concentrations would be above the significance threshold. This would be a potentially significant impact. Hazard index would be below BAAQMD thresholds. However, as shown in Table 4.7-8, with implementation of Supplemental Mitigation Measure SM-AQ-3, cumulative cancer risks and PM2.5 concentrations would be reduced to below the BAAQMD significance thresholds of 10 in one million cancer risk and 0.3 µg/m3 PM2.5 concentration, representing a less than significant impact with mitigation. Table 4.7-8. Cumulative Risk at Proposed Site Distance from MEI (feet) Source/ Plant No. Facility Name Street Address Cancer Risk (per million) Hazard Index PM2.5 (µg/m3) 60 I-580a 60.70 0.03 0.67 250 Hacienda Drive a 1.01 <0.01 0.03 700 Martinelli Way a 0.13 <0.01 <0.01 675 17753 a Oracle USA, Inc. 5805 Owens Drive 0.04 <0.01 <0.01 Total 61.9 <0.06 <0.70 BAAQMD Significance Thresholds 10 1.0 0.3 Significant? Yes No Yes With Implementation of Mitigation Measure SM-AQ-3 60 I-580a 9.60 <0.03 0.10 250 Hacienda Drive a 0.22 <0.01 <0.01 700 Martinelli Way a 0.03 <0.01 <0.01 675 17753 a Oracle USA, Inc. 5805 Owens Drive <0.01 <0.01 <0.01 Total <9.9 <0.06 <0.13 BAAQMD Significance Thresholds 10 1.0 0.3 Significant? No No No Notes: a Based on project-specific emissions and dispersion modeling The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 183 Mechanical Ventilation with Filtration. The U.S. EPA reports particle size removal efficiency for filters rated MERV13 of 90 percent for particles in the size range of 1 to 3 µm and less than 75 percent for particles 0.3 to 1 µm.22 MERV16 filters are listed to have removal efficiency for those particles (i.e., 0.3 to 3 µm) of 90 percent or greater. Recent studies by the South Coast Air Quality Management District indicate that MERV13 filters could achieve reductions of about 60 percent for ultra-fine particles and about 35 percent for black carbon, while MERV16 filters exceeded 85 percent.23 In 2012, CARB compiled a synthesis of the status of potential mitigation concepts to reduce exposure to nearby traffic air pollution.24 Because mechanical ventilation has not been used in residential buildings until recently, there has been limited assessment of its impact on entry of particles and other pollutants into homes. CARB-reviewed studies of homes and schools have shown that high-efficiency filtration in mechanical ventilation systems can be effective in reducing levels of incoming outdoor particles. They noted that one study of residences in Northern California found that the homes with active filtration in a mechanical system had a notably lower portion of indoor particles from outdoors when the systems were on (filtration active) than when they were turned off (no filtration). In another study reviewed by CARB that included modeling study of Korean residential units with mechanical ventilation, filters rated lower than MERV7 were insufficient for reducing contaminants that enter through the ventilation filter; the study concluded that filters should exceed MERV11. The CARB review also notes that in a school pilot study, a combination of MERV16 filters used as a replacement for the normal panel filter in the ventilation system and in a separate filtration unit reduced indoor levels of outdoor-generated black carbon, ultrafine particles and PM2.5 by 87 percent to 96 percent in three Southern California schools.11 Use of the MERV16 panel filter alone in the HVAC system achieved average particle reductions of nearly 90 percent. Another study reviewed by CARB found indoor submicron particle counts in a Utah school were reduced to just one-eighth of the outdoor levels in a building with a mechanical system using a MERV8 filter. Based on these studies, it is assumed that MERV13 filtration could reduce particulate levels by 60 percent and MERV16 filtration could achieve an 85 percent reduction. Supplemental Project Impact AQ-4 (exposure of sensitive receptors to substantial pollutant concentrations). The project would expose sensitive receptors to excess cancer risk and PM2.5 concentrations that are above health-based thresholds (Less than Significant with Mitigation) Adherence to the following supplemental mitigation measure will ensure that the proposed project reduces excess cancer risk and PM2.5 impacts caused by I-580 and local area traffic. 22 American Society of Heating, Refrigerating, and Air-Conditioning Engineers, Inc., 2007, Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size. ANSI/ASHRAE Standard 52.2- 2007. 23 South Coast Air Quality Management District (SCAQMD), 2009, Pilot Study of High Performance Air Filtration for Classrooms Applications. Draft Report, October. 24 California Air Resources Board (CARB), 2012, Status of Research on Potential Mitigation Concepts to Reduce Exposure to Nearby Traffic Pollution, August. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 184 Supplemental Mitigation Measure SM-AQ-3 (exposuree of sensitive receptors to substantial pollutant concentrations). The project shall include the following measures to minimize long-term toxic air contaminant (TAC) exposure for new residences: a. Ensure that no residential buildings would have a full year of occupancy prior to 1/1/2017. b. Design buildings and site to limit exposure from sources of TAC and fine particulate matter (PM2.5) emissions. The site layout shall locate windows and air intakes as far as possible from I-580 traffic lanes. Any modifications to the site design shall incorporate buffers between residences and the freeway. c. To the greatest degree possible, plant vegetation along the project site boundary with I-580 that includes trees and shrubs that provide a dense vegetative barrier. d. Install air filtration in residential buildings at roof top level that have predicted cancer risks in excess of 10 in one million or PM2.5 concentrations above 0.3 micrograms per cubic meter (µg/m3) as shown in Exhibit 4.7-4. The type of air filtration device shall be as set forth in subsection e below.. To ensure adequate health protection to sensitive receptors, a ventilation system shall meet the following minimal design standards (Department of Public Health, City and County of San Francisco, 2008):  At least one air exchange(s) per hour of fresh outside filtered air;  At least four air exchange(s) per hour recirculation; and  At least 0.25 air exchange(s) per hour in unfiltered infiltration. e. The type of MERV- rated filtration required to be installed as part of the ventilation system in the residential buildings shall be as follows: 1) MERV13 filtration shall be installed in a residential building partially or completed located in an area where the cancer risk is 10 per one million or greater but less than or equal to 22 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 2) MERV16 filtration shall be installed in a residential building partially or completed located in an area where the cancer risk is greater than 22 per one million and less than 50 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 3) MERV16 filtration and sealed, inoperable windows and no balconies on building elevations facing I-580 freeway (MERV 16 Plus) shall be installed in a residential building partially or completed located in an area where the cancer risk is a greater than or equal to 50 per one million and less than 62.5 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 4) In areas where the cancer risk is 62.5 per one million or greater, residential units shall not be built unless the developer includes specific mitigation measures that are approved by a qualified air quality consultant and the City that results in a reduction of the cancer risk to below 10 per one million. f. As part of implementing this measure, an ongoing maintenance plan for the buildings’ heating, ventilation, and air conditioning (HVAC) air filtration system shall be required. Recognizing that emissions from air pollution sources are decreasing, the maintenance period shall last as long as significant excess cancer risk or annual PM2.5 exposures are predicted. Subsequent studies may be conducted The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 185 by an air quality expert approved by the City to identify the ongoing need for the filtered ventilation systems as future information becomes available. g. Ensure that the lease agreement and other property documents (1) require cleaning, maintenance, and monitoring of the affected buildings for air flow leaks; (2) include assurance that new owners and tenants are provided information on the ventilation system; and (3) include provisions that fees associated with owning or leasing a unit(s) in the building include funds for cleaning, maintenance, monitoring, and replacements of the filters, as needed. h. Consider phasing developments located closest to I-580 to avoid significant excess cancer risks and required installation of filtered ventilation systems (described above). Note that new United States Environmental Protection Agency (U.S. EPA) engines standards combined with California Air Resources Board (CARB) rules and regulations will reduce on-road emissions of diesel particulate matter (DPM) and PM2.5 substantially, especially after 2014. i. Require that, prior to building occupancy, an authorized air pollutant consultant verify the installation of all necessary measures to reduce toxic air contaminant (TAC) exposure as set forth in this mitigation measure. Three air filtration cases were identified and modeled as mitigation scenarios. In order of increased DPM removal effectiveness, these are: use of a filtration system using MERV13, use of a filtration system using MERV16, and use of a filtration system using MERV16 with sealed, inoperable windows and no balconies. The last case is referred to as “MERV16 Plus”. In all cases the air intakes for the filtration systems would be located at roof top level and as far away from I-580 as possible. Mitigated concentrations were modeled at the roof top level of the residential buildings, where intakes for the air filtration systems would be located as required by Supplemental Mitigation Measure SM-AQ-3. Roof top concentrations were calculated at heights of 40 and 50 feet, representative of three and four story buildings plus the approximate height of the air filtration units. Increased cancer risks for each of the three filtration cases were calculated assuming a combination of outdoor and indoor exposure. For use of MERV13 and MERV16 filtration systems, without the additional use of sealed, inoperable widows and no balconies, 3 hours of outdoor exposure to ambient DPM concentrations and 21 hours of indoor exposure to filtered air was assumed. In this case, the effective control efficiency using a MERV13 filtration system is about 53 percent and for a MERV16 filtration system, the effective control efficiency is about 74 percent. For use of MERV16 air filtration systems with the additional requirements of sealed, inoperable windows and no balconies (MERV16 Plus), 2 hours of outdoor exposure to ambient DPM concentrations and 22 hours of indoor exposure to filtered air was assumed. The effective control efficiency for the MERV16 Plus case is about 78 percent. The projected cancer risks associated with use of these filtration systems would be reduced to less than 10 in one million at all residences, or below the BAAQMD significance criterion and, thus, to a level of less than significant. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 186 With use of project-specified air filtration systems, exposure to PM2.5 in the residential areas throughout the project site would be reduced to below the BAAQMD significance criterion of 0.3 μg/m3 and, thus, to a level of less than significant. Appendix 9 contains the modeling data and Exhibits 4.7-6 through 4.7-11, which graphically illustrate the resulting cancer risk and PM2.5 exposure in the residential areas with the three levels of air filtration in place. Construction period impacts. Emissions from construction projects have the potential to expose nearby sensitive receptors (i.e., residences) to elevated levels of TACs. Construction equipment and trucks fueled by diesel emit diesel particulate matter or DPM, which is a TAC. However, as discussed above, the closest existing sensitive receptors to the project site are located over 1,000 feet from project construction activities. At this distance, construction of the project does not have the potential to cause a significant impact with regards to construction health risk. Therefore, this impact would be considered less than significant. Greenhouse gas emission impacts. The City of Dublin Climate Action Plan25 serves as a Qualified Greenhouse Gas Reduction Strategy or a community-wide plan approved by BAAQMD to reduce greenhouse gas (GHG) emissions in accordance with AB 32 goals. A Scoping Plan for AB 32 was adopted by CARB in December 2008. It contains the State of California’s main strategies to reduce GHGs from business-as-usual emissions projected in 2020 back down to 1990 levels. Business-as-usual (BAU) is the projected emissions in 2020, including increases in emissions caused by growth, without any GHG reduction measures. The Scoping Plan has a range of GHG reduction actions, including direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, and market- based mechanisms such as a cap-and-trade system. According to the City Climate Action Plan, the Dublin community emitted approximately 357,211 metric tons of carbon dioxide equivalent (MT CO2e) in the year 2005. Of that, 51.4 percent came from state highways, 16.8 percent from commercial/industrial uses, 14.3 percent from residential uses, 13.9 percent from local roads, and 3.5 percent from the waste sector. The purpose of a Qualified Greenhouse Gas Reduction Strategy is to streamline the decision- making process regarding a proposed project’s impact on GHG emissions within the City. However, because the project would require a General Plan Amendment that changes the land use from commercial to mixed use residential and commercial/retail, a quantified assessment of the project’s GHG emissions has been conducted. In addition, the project’s consistency with the relevant goals and reduction measures of the City Climate Action Plan is evaluated. The following emissions reduction measures and policies are relevant to the proposed project: A.1.3 Mixed-Use Development: The project would incorporate both residential housing and at least one nonresidential use. 25 City of Dublin, 2013. City of Dublin Climate Action Plan Update. July. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 187 A.1.4 Bicycle Parking Requirements: Under the City’s Off-Street Parking and Loading Regulations, parking lots with 20 or more spaces in nonresidential zoning districts are required to provide bicycle parking. Pursuant to the Zoning Ordinance, one bicycle parking space in a bicycle rack for each 40 vehicular parking spaces. A.1.5 Streetscape Master Plan: The Zoning Ordinance has requirements for planting trees in parking lots (minimum of one tree for every four parking spaces). A.1.8 General Plan Community Design and Sustainability Element: The Community Design and Sustainability Element established design principles, policies, and implementation measures to enhance the livability of Dublin and encourages a high level of quality design that supports sustainability. The Community Design and Sustainability Element applies to new development and redevelopment throughout the City. A.1.9 Work with the Livermore Amador Valley Transit Authority to Improve Transit (LAVTA): As part of the review process for proposed development projects, the City and project proponents work with LAVTA on planning future bus stops locations and extending service routes. A.2.1 Green Building Ordinance: In 2009, the City passed a Green Building Ordinance (DMC Chapter 7.94) requiring residential projects over 20 units to reach 50 points on the GreenPoint Rated system. Alternatively, LEED for Homes is approved in the ordinance. A.2.4 Reduce Solar Installation Permit Fee: In 2006, the City of Dublin reduced the building permit fee related to the installation of photovoltaic systems as an incentive for property owners to install solar electricity generating capacity on their homes and businesses. The City of Dublin recognizes the value of solar energy as a clean source of electricity that does not produce GHG emissions. A.2.5 LED Streetlight Specifications for New Projects: The City has developed a LED streetlight specification that requires all future development projects to install LED streetlights. A.3.1 Construction and Demolition Debris Ordinance: Since 2005, the City has implemented a Construction and Demolition Debris Ordinance, which requires that 100% of asphalt and concrete be recycled and a minimum of 50% of all other materials be recycled. A.3.4 Commercial Recycling Program: In 2005, the City began offering a free commercial recycling program that also includes free indoor recycling containers for businesses. Indoor recycling containers encourage employees to recycle by conveniently locating recycling containers near their work areas. A.3.5 Commercial Food Waste Collection Program: In 2005, the City began offering a commercial food waste recycling program, which includes a subsidy to encourage greater food waste recycling. Reducing the amount of food waste sent to the landfill also reduces The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 188 the CH4 emissions produced when organic waste decomposes in the absence of oxygen at the landfill. CH4 is a powerful GHG, 21 times more potent than CO2. A.3.6 Promote Commercial Recycling: In 2005, the City began promoting commercial recycling in the City. The City has developed commercial recycling guides for businesses and the City’s franchise waste hauler conducts two business audits per business day to increase diversion efforts in the commercial sector. The 2010 CALGreen Code requires a recycling area in new commercial buildings. A.3.7 Promote Multi-Family Recycling: In 2005, the city began promoting multi-family recycling. Increased recycling reduces the GHG emissions from extracting, processing, and transporting virgin materials. A.3.8 Curbside Residential Recycling Program: The City offers a convenient, free recycling program that includes curbside pickup for residential neighborhoods to encourage greater recycling efforts. A.3.9 Curbside Organics Collection Program: The City offers a convenient organics program that includes curbside pickup of food waste and yard waste for residential neighborhoods. While the project would comply with Climate Action Plan Policy A.1.3 (Mixed-Use Development), compliance with the majority of policies has not yet been incorporated into the project. Supplemental Mitigation Measure SM-AQ-4 would ensure that all requirements of the City Climate Action Plan are implemented. GHG Emissions Quantification. The BAAQMD May 2011 CEQA Guidelines included GHG emissions-based significance thresholds. These thresholds for land-use type projects include an emissions level of 1,100 MT CO2e per year or a GHG efficiency threshold of 4.6 MT CO2e per year per service population (residents and employees). Projects with emissions above the thresholds would be considered to have a significant cumulative impact on global climate change. The same CalEEMod model run that was used to predict criteria air pollutants was also used to predict GHG emissions from operation of the site assuming full build-out of the project. The same project land use types and size, trip generation rates and other project-specific information were input to the model. CalEEMod output worksheets are included in Appendix 8.9. The model uses mobile emission factors from the California Air Resources Board’s EMFAC2011 model. This model is sensitive to the year selected, since vehicle emissions have and continue to be reduced due to fuel efficiency standards and low carbon fuels. The Year 2017 was analyzed since it is the first full year that the project could conceivably be occupied. Site-specific land use features that could reduce vehicle emissions were also input to the model, including the approximate number of intersections per square miles (influencing walkability) and accessibility to nearby transit. Emissions reductions from these specific site features are included The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 189 in the mitigated emissions output, by the nature of the CalEEMod air model. Default rates for energy consumption were assumed in the model. Emissions rates associated with electricity consumption were adjusted to account for Pacific Gas & Electric utility’s (PG&E) projected 2017 CO2 intensity rate. This 2017 rate is based, in part, on the requirement of a renewable energy portfolio standard of 33 percent by the year 2020. CalEEMod uses a default rate of 641.35 pounds of CO2 per megawatt of electricity produced. The derived 2017 rate for PG&E was estimated at 348.86 pounds of CO2 per megawatt of electricity delivered and is based on the California Public Utilities Commission (CPUC) GHG Calculator.26 The per capita rate for this project is the annual GHG emissions expressed in metric tons divided by the estimated number of new residents and employees. The number of new residents is anticipated to be 1,080 and the number of future employees is anticipated at 78, for a total service population of 1,158, as indicated by the project applicant. Default model assumptions for GHG emissions associated with area sources, solid waste generation and water/wastewater use were applied to the project. No wood burning from woodstoves or fireplaces was assumed in the modeling. Construction Emissions. GHG emissions associated with construction were computed to be 1,334 MT CO2e, anticipated to occur over three separate calendar years. These are the emissions from on-site operation of construction equipment, hauling truck trips, vendor truck trips, and worker trips. The BAAQMD does not have an adopted Threshold of Significance for construction-related GHG emissions. The District recommends quantifying emissions and disclosing that GHG emissions would occur during construction. BAAQMD also encourages the incorporation of best management practices to reduce GHG emissions during construction where feasible and applicable, including, but not limited to: using local building materials of at least 10 percent and recycling or reusing at least 50 percent of construction waste or demolition materials. The City’s Construction and Demolition Debris Ordinance requires that 100 percent of asphalt and concrete be recycled and a minimum of 50 percent of all other materials be recycled. Operational Emissions. As shown in Table 4.7-9, operation of the project would exceed the threshold of 1,100 MT of CO2e/yr. The 2017 project per service population (employees) emissions of 7.0 MT CO2e/year/service population would exceed the BAAQMD threshold of 4.6 MT CO2e/year. Therefore, this impact is considered significant and implementation of Mitigation Measure SM-AQ-4 would be required. Emissions with mitigation in place (see Supplemental Mitigation Measure SM-AQ-4) are projected to be 6.3 MT CO2e/year/service population, which would still exceed the BAAQMD threshold. As shown in Table 4.7-10, a vast majority of the emissions are from traffic. It should be noted that, according to the project traffic report, projected trip generation due to project implementation would be substantially less than those approved for the current use per 26 California Public Utilities Commissions GHG Calculator version 3c, October 7, 2010. Available on-line at: http://ethree.com/public_projects/cpuc2.php. Accessed: April 11, 2013. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 190 the Year 2035 Dublin Model. Personal communication with BAAQMD staff27 indicated that due this substantial reduction (1,856 net trips daily), and if the project were to comply with all applicable climate action plan measures (through adherence to Supplemental Mitigation Measure SM-AQ-4), this could provide evidence of a less than significant impact determination. However, to be conservative, the lead agency has decided to measure the project’s impact on global climate change against the quantified BAAQMD standards. Given that, there are no additional feasible measures that the project could implement to reduce this impact to less than significant. Therefore, this impact would be considered Significant and Unavoidable. Table 4.7- 9. Annual Project GHG Emissions in Metric Tons Source Category 2017 Project Emissions 2017 Mitigated Emissions Area 25 25 Energy Consumption 1,385 1,259 Mobile 6.290 5,687 Solid Waste Generation 292 234 Water Usage 88 76 Total 8,080 7,281 Per Capita Emissions1 7.0 6.3 BAAQMD Thresholds 4.6 MT CO2e/year/service population 4.6 MT CO2e/year/service population Notes: 1Based on service population of 1,158. Supplemental Impact AQ-5 (project generation of greenhouse gas emissions). The project would generate greenhouse gas emissions, both directly and indirectly, that would have a significant impact on the environment or would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases (significant and unavoidable impact). Adherence to the following supplemental mitigation measure will ensure that the proposed project would comply with the City of Dublin’s Climate Action Plan, but the project’s on-going operations would exceed greenhouse gas emissions established by the Bay Area Air Quality Management District. Supplemental Mitigation Measure SM-AQ-4 (project generation of greenhouse gas emissions). The final design of the project shall include all requirements of the City Climate Action Plan, including policies A.1.4 (Bicycle Parking Requirements), A.1.5 (Streetscape Master Plan), A.1.8 (General Plan Community Design and Sustainability Element), A.1.9 (Work with LAVTA to Improve Transit), A.2.1 (Green Building Ordinance), A.2.5 (LED Streetlight Specifications), A.3.1 (Construction and Demolition Debris Ordinance), A.3.6 (Commercial Recycling). In addition, the project proponent is encouraged to participate in subsidy programs such as Climate Action Plan polices A.2.4 (Reduced Solar Installation 27 Personal communication between Alison Kirk of BAAQMD and Joshua Carman of Illingworth and Rodkin, Inc., April 10, 2014. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 191 Permit Fee) and A.3.5 (Commercial Food Waste Collection Program), and non-subsidy programs such as policies A.3.7 (Multi-Family Recycling), A.3.8 (Curbside Recycling), and A.3.9 (Curbside Organics Collection). Implementation of these mitigation measure would reduce GHG emissions, but not below the significance thresholds. The project, as a whole, shall adopt a water use reduction goal of at least 20 percent. A water use reduction plan shall be developed by the project applicant that may include measures such as the installation of low-flow water fixtures in showers and sinks, low-flush toilets, and the use of water efficient landscaping. The project applicant shall implement a solid waste recycling program through recycling and composting strategies, which results in a project-wide solid waste diversion rate of at least 20 percent. Finally, the project shall exceed 2008 Title 24 Building Standards (which CalEEMod is based on) by at least 20 percent in terms of energy-efficiency. With the incorporation of Supplemental Mitigation measure SM-AQ-4, the project will be consistent with the City’s Climate Action Plan. However, the Project GHG emissions would still exceed the efficiency threshold of threshold of 4.6 MT CO2e/year. Therefore, the impact of the Project due to GHG emissions would be significant and unavoidable. Cumulative impacts. Cumulative air quality and greenhouse gas emissions are addressed in the above section. 59 7 2 0 0 5 9 7 3 0 0 5 9 7 4 0 0 5 9 7 5 0 0 5 9 7 6 0 0 5 9 7 7 0 0 5 9 7 8 0 0 5 9 7 9 0 0 5 9 8 0 0 0 5 9 8 1 0 0 5 9 8 2 0 0 5 9 8 3 0 0 UT M - E a s t ( m e t e r s ) 41 7 3 2 0 0 41 7 3 3 0 0 41 7 3 4 0 0 41 7 3 5 0 0 41 7 3 6 0 0 41 7 3 7 0 0 41 7 3 8 0 0 UTM - North (meters) I- 5 8 0 Pr o j e c t S i t e 56 . 1 56 . 4 56 . 6 56 . 8 57 . 2 57 . 5 57 . 9 58 . 2 58 . 4 58 . 6 58 . 8 59 . 1 59 . 3 59 . 5 59 . 7 59 . 8 60 . 0 60 . 2 60 . 3 60 . 4 60 . 5 60 . 6 60 . 7 46 . 7 46 . 9 47 . 1 47 . 4 47 . 7 48 . 0 48 . 3 48 . 6 48 . 8 49 . 0 49 . 2 49 . 4 49 . 6 49 . 8 49 . 9 50 . 1 50 . 2 50 . 4 50 . 5 50 . 6 50 . 6 50 . 7 50 . 8 50 . 9 51.051.0 39 . 8 40 . 1 40 . 3 40 . 5 40 . 8 41 . 0 41 . 3 41 . 6 41 . 8 42 . 0 42 . 2 42 . 4 42 . 5 42 . 7 42 . 8 43 . 0 43 . 1 43 . 2 43 . 3 43 . 4 43 . 5 43 . 5 43 . 6 43 . 7 43.743.8 34 . 7 34 . 9 35 . 1 35 . 3 35 . 6 35 . 8 36 . 0 36 . 3 36 . 5 36 . 7 36 . 9 37 . 0 37 . 2 37 . 3 37 . 5 37 . 6 37 . 7 37 . 8 37 . 9 37 . 9 38 . 0 38 . 0 38 . 1 38 . 2 38.238.238.2 30 . 6 30 . 9 31 . 1 31 . 3 31 . 5 31 . 7 31 . 9 32 . 1 32 . 3 32 . 5 32 . 7 32 . 8 33 . 0 33 . 1 33 . 2 33 . 3 33 . 4 33 . 5 33 . 6 33 . 6 33 . 7 33 . 7 33 . 8 33 . 9 33.933.933.9 27 . 4 27 . 6 27 . 8 28 . 0 28 . 2 28 . 4 28 . 6 28 . 8 29 . 0 29 . 1 29 . 3 29 . 4 29 . 6 29 . 7 29 . 8 29 . 9 30 . 0 30 . 0 30 . 1 30 . 2 30 . 2 30 . 3 30 . 3 30 . 4 30.430.430.4 24 . 8 25 . 0 25 . 1 25 . 3 25 . 5 25 . 7 25 . 9 26 . 0 26 . 2 26 . 4 26 . 5 26 . 6 26 . 7 26 . 9 27 . 0 27 . 0 27 . 1 27 . 2 27 . 2 27 . 3 27 . 3 27 . 4 27 . 4 27 . 5 27.527.527.5 22 . 6 22 . 7 22 . 9 23 . 1 23 . 2 23 . 4 23 . 6 23 . 7 23 . 9 24 . 0 24 . 1 24 . 3 24 . 4 24 . 5 24 . 6 24 . 7 24 . 7 24 . 8 24 . 8 24 . 9 24 . 9 24 . 9 25 . 0 25 . 0 25.025.025.0 20 . 7 20 . 9 21 . 0 21 . 2 21 . 3 21 . 5 21 . 6 21 . 8 21 . 9 22 . 0 22 . 1 22 . 2 22 . 3 22 . 4 22 . 5 22 . 6 22 . 7 22 . 7 22 . 7 22 . 8 22 . 8 22 . 9 22 . 9 22 . 9 22.922.922.9 19 . 1 19 . 2 19 . 4 19 . 5 19 . 7 19 . 8 19 . 9 20 . 1 20 . 2 20 . 3 20 . 4 20 . 5 20 . 6 20 . 7 20 . 8 20 . 8 20 . 9 20 . 9 21 . 0 21 . 0 21 . 0 21 . 1 21 . 1 21 . 1 21.121.121.0 17 . 7 17 . 8 18 . 0 18 . 1 18 . 2 18 . 4 18 . 5 18 . 6 18 . 7 18 . 8 18 . 9 19 . 0 19 . 1 19 . 1 19 . 2 19 . 3 19 . 3 19 . 4 19 . 4 19 . 4 19 . 5 19 . 5 19 . 5 19 . 5 19.519.519.4 16 . 5 16 . 6 16 . 7 16 . 9 17 . 0 17 . 1 17 . 2 17 . 3 17 . 4 17 . 5 17 . 6 17 . 7 17 . 7 17 . 8 17 . 9 17 . 9 18 . 0 18 . 0 18 . 0 18 . 1 18 . 1 18 . 1 18 . 1 18 . 1 18.118.118.0 15 . 4 15 . 5 15 . 6 15 . 8 15 . 9 16 . 0 16 . 1 16 . 2 16 . 3 16 . 3 16 . 4 16 . 5 16 . 5 16 . 6 16 . 7 16 . 7 16 . 8 16 . 8 16 . 8 16 . 8 16 . 9 16 . 9 16 . 9 16 . 9 16.816.816.8 59 7 5 5 0 5 9 7 6 0 0 5 9 7 6 5 0 5 9 7 7 0 0 5 9 7 7 5 0 5 9 7 8 0 0 5 9 7 8 5 0 5 9 7 9 0 0 5 9 7 9 5 0 5 9 8 0 0 0 UT M - E a s t ( m e t e r s ) 41 7 3 3 0 0 41 7 3 3 5 0 41 7 3 4 0 0 41 7 3 4 5 0 41 7 3 5 0 0 41 7 3 5 5 0 41 7 3 6 0 0 41 7 3 6 5 0 UTM - North (meters) 0. 6 1 0. 6 1 0. 6 1 0. 6 2 0. 6 2 0. 6 3 0. 6 3 0. 6 3 0. 6 4 0. 6 4 0. 6 4 0. 6 5 0. 6 5 0. 6 5 0. 6 5 0. 6 6 0. 6 6 0. 6 6 0. 6 6 0. 6 6 0. 6 6 0. 6 7 0. 6 7 0. 5 0 0. 5 1 0. 5 1 0. 5 1 0. 5 2 0. 5 2 0. 5 2 0. 5 3 0. 5 3 0. 5 3 0. 5 3 0. 5 4 0. 5 4 0. 5 4 0. 5 4 0. 5 5 0. 5 5 0. 5 5 0. 5 5 0. 5 5 0. 5 5 0. 5 6 0. 5 6 0. 5 6 0.560.56 0. 4 3 0. 4 3 0. 4 3 0. 4 4 0. 4 4 0. 4 4 0. 4 5 0. 4 5 0. 4 5 0. 4 5 0. 4 6 0. 4 6 0. 4 6 0. 4 6 0. 4 6 0. 4 7 0. 4 7 0. 4 7 0. 4 7 0. 4 7 0. 4 7 0. 4 7 0. 4 8 0. 4 8 0.480.48 0. 3 7 0. 3 7 0. 3 8 0. 3 8 0. 3 8 0. 3 8 0. 3 9 0. 3 9 0. 3 9 0. 3 9 0. 4 0 0. 4 0 0. 4 0 0. 4 0 0. 4 0 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 2 0.420.420.42 0. 3 3 0. 3 3 0. 3 3 0. 3 3 0. 3 4 0. 3 4 0. 3 4 0. 3 4 0. 3 5 0. 3 5 0. 3 5 0. 3 5 0. 3 5 0. 3 6 0. 3 6 0. 3 6 0. 3 6 0. 3 6 0. 3 6 0. 3 6 0. 3 6 0. 3 7 0. 3 7 0. 3 7 0.370.370.37 0. 2 9 0. 2 9 0. 3 0 0. 3 0 0. 3 0 0. 3 0 0. 3 0 0. 3 1 0. 3 1 0. 3 1 0. 3 1 0. 3 1 0. 3 2 0. 3 2 0. 3 2 0. 3 2 0. 3 2 0. 3 2 0. 3 2 0. 3 2 0. 3 3 0. 3 3 0. 3 3 0. 3 3 0.330.330.33 0. 2 6 0. 2 6 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 8 0. 2 8 0. 2 8 0. 2 8 0. 2 8 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 3 0 0. 3 0 0.300.300.30 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0.270.270.27 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 5 0.250.250.25 0. 2 0 0. 2 0 0. 2 0 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0.230.230.23 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0.210.210.21 0. 1 7 0. 1 7 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0.190.190.19 0. 1 6 0. 1 6 0. 1 6 0. 1 6 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 7 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0. 1 8 0.180.180.18 59 7 5 5 0 5 9 7 6 0 0 5 9 7 6 5 0 5 9 7 7 0 0 5 9 7 7 5 0 5 9 7 8 0 0 5 9 7 8 5 0 5 9 7 9 0 0 5 9 7 9 5 0 5 9 8 0 0 0 UT M - E a s t ( m e t e r s ) 41 7 3 3 0 0 41 7 3 3 5 0 41 7 3 4 0 0 41 7 3 4 5 0 41 7 3 5 0 0 41 7 3 5 5 0 41 7 3 6 0 0 41 7 3 6 5 0 UTM - North (meters) 56 . 4 56 . 7 56 . 9 57 . 1 57 . 5 57 . 8 58 . 2 58 . 6 58 . 8 59 . 1 59 . 3 59 . 6 59 . 9 60 . 1 60 . 3 60 . 5 60 . 7 60 . 9 61 . 1 61 . 3 61 . 5 61 . 7 61 . 9 47 . 0 47 . 2 47 . 4 47 . 7 48 . 0 48 . 3 48 . 7 49 . 0 49 . 2 49 . 5 49 . 7 49 . 9 50 . 2 50 . 4 50 . 6 50 . 7 50 . 9 51 . 1 51 . 3 51 . 4 51 . 6 51 . 8 52 . 0 52 . 3 52.653.0 40 . 1 40 . 4 40 . 6 40 . 9 41 . 1 41 . 4 41 . 7 42 . 0 42 . 2 42 . 5 42 . 7 42 . 9 43 . 1 43 . 3 43 . 5 43 . 6 43 . 8 44 . 0 44 . 1 44 . 3 44 . 4 44 . 6 44 . 8 45 . 1 45.445.7 35 . 0 35 . 2 35 . 4 35 . 7 35 . 9 36 . 2 36 . 5 36 . 7 37 . 0 37 . 2 37 . 4 37 . 6 37 . 8 37 . 9 38 . 1 38 . 3 38 . 4 38 . 5 38 . 7 38 . 8 39 . 0 39 . 2 39 . 4 39 . 6 39.940.340.8 31 . 0 31 . 2 31 . 4 31 . 6 31 . 9 32 . 1 32 . 3 32 . 6 32 . 8 33 . 0 33 . 2 33 . 4 33 . 6 33 . 7 33 . 9 34 . 0 34 . 2 34 . 3 34 . 4 34 . 6 34 . 7 34 . 9 35 . 1 35 . 3 35.636.036.5 27 . 8 28 . 0 28 . 2 28 . 4 28 . 6 28 . 8 29 . 0 29 . 3 29 . 5 29 . 6 29 . 8 30 . 0 30 . 2 30 . 3 30 . 5 30 . 6 30 . 7 30 . 8 31 . 0 31 . 1 31 . 2 31 . 4 31 . 6 31 . 8 32.132.533.1 25 . 1 25 . 3 25 . 5 25 . 7 25 . 9 26 . 1 26 . 3 26 . 5 26 . 7 26 . 9 27 . 0 27 . 2 27 . 4 27 . 5 27 . 6 27 . 8 27 . 9 28 . 0 28 . 1 28 . 3 28 . 4 28 . 6 28 . 8 29 . 0 29.329.630.2 23 . 0 23 . 1 23 . 3 23 . 5 23 . 7 23 . 9 24 . 0 24 . 2 24 . 4 24 . 6 24 . 7 24 . 9 25 . 0 25 . 1 25 . 3 25 . 4 25 . 5 25 . 6 25 . 7 25 . 9 26 . 0 26 . 2 26 . 3 26 . 6 26.827.227.8 21 . 1 21 . 3 21 . 5 21 . 6 21 . 8 22 . 0 22 . 1 22 . 3 22 . 5 22 . 6 22 . 8 22 . 9 23 . 0 23 . 1 23 . 3 23 . 4 23 . 5 23 . 6 23 . 7 23 . 8 24 . 0 24 . 1 24 . 3 24 . 5 24.825.225.8 19 . 5 19 . 7 19 . 9 20 . 0 20 . 2 20 . 3 20 . 5 20 . 6 20 . 8 20 . 9 21 . 1 21 . 2 21 . 3 21 . 4 21 . 5 21 . 6 21 . 7 21 . 8 21 . 9 22 . 1 22 . 2 22 . 3 22 . 5 22 . 7 23.023.424.0 18 . 2 18 . 3 18 . 5 18 . 6 18 . 8 18 . 9 19 . 1 19 . 2 19 . 3 19 . 5 19 . 6 19 . 7 19 . 8 19 . 9 20 . 0 20 . 1 20 . 2 20 . 3 20 . 4 20 . 5 20 . 7 20 . 8 21 . 0 21 . 2 21.521.822.5 17 . 0 17 . 2 17 . 3 17 . 4 17 . 6 17 . 7 17 . 8 18 . 0 18 . 1 18 . 2 18 . 3 18 . 4 18 . 5 18 . 6 18 . 7 18 . 8 18 . 9 19 . 0 19 . 1 19 . 2 19 . 4 19 . 5 19 . 7 19 . 9 20.120.521.1 16 . 0 16 . 2 16 . 3 16 . 4 16 . 5 16 . 7 16 . 8 16 . 9 17 . 0 17 . 1 17 . 2 17 . 3 17 . 4 17 . 5 17 . 6 17 . 7 17 . 8 17 . 9 18 . 0 18 . 1 18 . 2 18 . 3 18 . 5 18 . 7 19.019.320.0 59 7 5 5 0 5 9 7 6 0 0 5 9 7 6 5 0 5 9 7 7 0 0 5 9 7 7 5 0 5 9 7 8 0 0 5 9 7 8 5 0 5 9 7 9 0 0 5 9 7 9 5 0 5 9 8 0 0 0 UT M - E a s t ( m e t e r s ) 41 7 3 3 0 0 41 7 3 3 5 0 41 7 3 4 0 0 41 7 3 4 5 0 41 7 3 5 0 0 41 7 3 5 5 0 41 7 3 6 0 0 41 7 3 6 5 0 UTM - North (meters) 0. 6 2 0. 6 2 0. 6 2 0. 6 3 0. 6 3 0. 6 4 0. 6 4 0. 6 4 0. 6 5 0. 6 5 0. 6 5 0. 6 6 0. 6 6 0. 6 7 0. 6 7 0. 6 7 0. 6 8 0. 6 8 0. 6 8 0. 6 9 0. 6 9 0. 7 0 0. 7 0 0. 5 1 0. 5 1 0. 5 2 0. 5 2 0. 5 3 0. 5 3 0. 5 3 0. 5 4 0. 5 4 0. 5 4 0. 5 5 0. 5 5 0. 5 5 0. 5 6 0. 5 6 0. 5 6 0. 5 7 0. 5 7 0. 5 7 0. 5 8 0. 5 8 0. 5 9 0. 5 9 0. 6 0 0.610.62 0. 4 4 0. 4 4 0. 4 4 0. 4 5 0. 4 5 0. 4 5 0. 4 6 0. 4 6 0. 4 6 0. 4 7 0. 4 7 0. 4 7 0. 4 8 0. 4 8 0. 4 8 0. 4 8 0. 4 9 0. 4 9 0. 4 9 0. 5 0 0. 5 0 0. 5 1 0. 5 1 0. 5 2 0.530.54 0. 3 8 0. 3 8 0. 3 9 0. 3 9 0. 3 9 0. 4 0 0. 4 0 0. 4 0 0. 4 1 0. 4 1 0. 4 1 0. 4 1 0. 4 2 0. 4 2 0. 4 2 0. 4 3 0. 4 3 0. 4 3 0. 4 3 0. 4 4 0. 4 4 0. 4 5 0. 4 5 0. 4 6 0.470.480.49 0. 3 4 0. 3 4 0. 3 4 0. 3 4 0. 3 5 0. 3 5 0. 3 5 0. 3 6 0. 3 6 0. 3 6 0. 3 7 0. 3 7 0. 3 7 0. 3 7 0. 3 8 0. 3 8 0. 3 8 0. 3 8 0. 3 9 0. 3 9 0. 3 9 0. 4 0 0. 4 0 0. 4 1 0.420.430.45 0. 3 0 0. 3 0 0. 3 1 0. 3 1 0. 3 1 0. 3 1 0. 3 2 0. 3 2 0. 3 2 0. 3 3 0. 3 3 0. 3 3 0. 3 3 0. 3 4 0. 3 4 0. 3 4 0. 3 4 0. 3 5 0. 3 5 0. 3 5 0. 3 6 0. 3 6 0. 3 7 0. 3 7 0.380.390.41 0. 2 7 0. 2 8 0. 2 8 0. 2 8 0. 2 8 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 3 0 0. 3 0 0. 3 0 0. 3 0 0. 3 1 0. 3 1 0. 3 1 0. 3 1 0. 3 2 0. 3 2 0. 3 2 0. 3 3 0. 3 3 0. 3 3 0. 3 4 0.350.360.38 0. 2 5 0. 2 5 0. 2 5 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 8 0. 2 8 0. 2 8 0. 2 8 0. 2 9 0. 2 9 0. 2 9 0. 2 9 0. 3 0 0. 3 0 0. 3 0 0. 3 1 0. 3 2 0.320.340.35 0. 2 3 0. 2 3 0. 2 3 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 6 0. 2 6 0. 2 6 0. 2 6 0. 2 7 0. 2 7 0. 2 7 0. 2 7 0. 2 8 0. 2 8 0. 2 9 0. 2 9 0.300.310.33 0. 2 1 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 4 0. 2 4 0. 2 4 0. 2 4 0. 2 5 0. 2 5 0. 2 5 0. 2 5 0. 2 6 0. 2 6 0. 2 6 0. 2 7 0. 2 7 0.280.300.31 0. 2 0 0. 2 0 0. 2 0 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 3 0. 2 4 0. 2 4 0. 2 4 0. 2 5 0. 2 5 0. 2 6 0.270.280.30 0. 1 9 0. 1 9 0. 1 9 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0. 2 3 0. 2 4 0. 2 4 0. 2 5 0.250.270.29 0. 1 8 0. 1 8 0. 1 8 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 1 9 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 0 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 1 0. 2 2 0. 2 2 0. 2 2 0. 2 3 0. 2 4 0.240.260.28 59 7 5 5 0 5 9 7 6 0 0 5 9 7 6 5 0 5 9 7 7 0 0 5 9 7 7 5 0 5 9 7 8 0 0 5 9 7 8 5 0 5 9 7 9 0 0 5 9 7 9 5 0 5 9 8 0 0 0 UT M - E a s t ( m e t e r s ) 41 7 3 3 0 0 41 7 3 3 5 0 41 7 3 4 0 0 41 7 3 4 5 0 41 7 3 5 0 0 41 7 3 5 5 0 41 7 3 6 0 0 41 7 3 6 5 0 UTM - North (meters) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 197 4.8 HAZARDS AND HAZARDOUS MATERIALS INTRODUCTION Impacts related to hazards and hazardous materials issues on the project site were not analyzed in the Eastern Dublin EIR. Subsequently, Phase I Environmental Site Assessment (ESA) for hazardous materials have been completed on the site. This chapter examines the potential for substantial soil or groundwater contamination on or adjacent to the site. The following analysis is based on a Phase I ESA completed by the firm of ENGEO on the project site dated August 2, 2013. The ENGEO report is hereby incorporated by reference into this DSEIR and is available for review at the Dublin Community Development Department during normal business hours. ENVIRONMENTAL SETTING Project site conditions. The approximately 27.45-acre site is generally vacant with the exception of a small building in the approximate center of the site. The project site was part of a larger Camp Parks area transferred to Alameda County in 1969. While a part of Camp Parks, the site number of former military buildings, paved roads, an athletic field and similar uses. All structures and related military improvements were removed by the mid-1990’s. Potential on-site contamination. The Phase I ESA found no evidence of Recognized Environmental Conditions (RECs) on the site, although such conditions have been identified on surrounding properties, specifically to the north, which is identified as Site 16A. A previous Underground Storage Tank on the property was removed in 2008 and surrounding soil excavated and removed. The Alameda County Department of Environmental Health (ACDEH) granted a case closure on the project property on September 3, 2010 for commercial land uses only. In the event residential land use is proposed on the property the closure letter stated that ACDEH is required to be notified and will re-evaluate site conditions based on the submitted plans. The applicant has also indicated that the small existing office building would be removed from the site prior to commencement of construction activities. This building could contain lead based paints or asbestos building materials. REGULATORY FRAMEWORK Following is a partial listing of federal, state and local agencies that have regulatory authority over the use, storage and disposal of hazardous wastes in the City of Dublin and Alameda County. Environmental Protection Agency (EPA). The EPA regulates chemical and hazardous materials use, storage, treatment, handling, transport and disposal practices. This agency protects workers and the community and integrates requirements of the federal Clean Water Act and Clean Air Act into state legislation. State of California Regional Water Quality Control Board (RWQCB): The RWCQB, San Francisco Bay Region, protected surface and groundwater resources from pollutants discharged The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 198 into waters of the state. This agency issues and enforces National Pollutant Discharge Elimination Systems (NPDES) permits. California Department of Toxic Substances Control (DTSC): This state agency regulates hazardous substances and wastes, oversees remedial investigations, protects drinking water from contamination and warns the public of possible danger from listed carcinogens. Bay Area Air Quality Management District (BAAQMD): The BAAQMD issues permits for industrial air emissions, restaurant venting and similar operations. The District also establishes regional air quality emissions standards. Alameda County Health Department. The Alameda County Health Department operates the Hazardous Materials/Waste Program for most cities in Alameda County, including Dublin and unincorporated properties in the County. Specific programs include tracking leaking storage tanks and similar activities. City of Dublin. The Seismic Safety and Safety Element of the Dublin General Plan contains Guiding Policy A, that directs the City to maintain and enhance the ability to regulate uses, transport and storage of hazardous materials and to quickly identify substances and take appropriate action during emergencies. The City of Dublin contracts with the Alameda County Fire Department to provide fire and emergency rescue service to City residences. The Department provides emergency response to hazardous materials incidents in the community. IMPACTS AND MITIGATIONS FROM PREVIOUS EIRs The topic of hazards and hazardous materials was not addressed in the 1993 Eastern Dublin EIR or the IKEA SEIR SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES As described in the Setting section, several recent hazardous materials studies have been identified since the Eastern Dublin EIR and IKEA SEIR analyses. Supplemental impacts are identified based on the recent Environmental Site Assessment for the project property. Significance Criteria. Based on the findings of the Initial Study for the project, implementation of the Project would be considered to have a significant impact with respect to hazardous materials if it were to: • Create a significant hazard to the public or the environment through reasonably foreseeable upset or accident conditions involving the release of hazardous materials into the environment. Supplemental Impacts. . The proposed project would include grading of the entire site to allow construction of proposed buildings parking areas and similar improvements as described in the Project Description. Trenching of portions of the site would also occur for placement of underground utilities. Installation of proposed landscaping would also require soil excavation for The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 199 installation of plant material and irrigation lines. Any of these activities could disturb previously identified on-site contamination and release this into the environment. Residential uses are included as part of the proposed project which were not part of the previously approved commercial project. Under the Standards of Significance, this would be a significant impact. Supplemental Impact HAZ-1 (potential for release of hazardous materials into the environment during construction). The site has been remediated for commercial and other non-residential land uses. As a part of the site management terms that were approved when the remediation occurred in 2010, the Alameda County Department of Environmental Health (ACDEH) required that if any residential or other similar land use is proposed at the Property, the ACDEH must be notified. ACDEH will then re-evaluate the case upon receipt of approved development/construction plans (potentially significant impact and mitigation required). Adherence to the following supplemental mitigation measure will reduce this impact to a less- than-significant level by requiring additional site testing and remediation, if required, before grading for residential uses is allowed. Supplemental Mitigation SM-HAZ-1 (potential for release of hazardous materials into the environment during construction). The Applicant/Developer shall notify ACDEH of the proposed project and the intent to utilize the site for residential uses so ACDEH can re- evaluate the case. If directed by ACDEH, a Phase II site investigation or site health risk assessment shall be completed for portions of the site anticipated for residential development and excavation prior to issuance of a grading and/or site improvement permit. The site investigation shall be coordinated with the Alameda County Department of Environmental Health. The investigation plan shall include a description of the work to be performed, the laboratory analytical methods to be uses and requirements for quality control. If additional remediation is necessary, a remediation plan shall be prepared and approved by the ACDEH. Grading or excavation of any identified contaminated residential area on the site shall not occur until ACDEH issues a closure letter authorizing residential uses on the site. The Applicant/Developer shall provide the City with documentation that the above actions have taken place. To protect the health and safety of construction workers, a Health and Safety Plan that meets the federal Occupational Safety and Health Administration requirements shall be prepared and implemented if additional remediation is required. Approval of the proposed project could result in a significant impact by causing a release of hazardous materials into the environment if dewatering of the site is required by appropriate regulatory agencies prior to commencement of construction. Supplemental Impact HAZ-2 (potential for release of hazardous materials into the environment due to dewatering activities). If required, construction dewatering activities could release identified accumulations of residual hydrocarbons, solvents, and other contaminants into the environment, possibly exposing construction workers, and The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 200 surrounding residents and visitors during construction (potentially significant impact and mitigation required). Adherence to the following supplemental mitigation measure will reduce this impact to less than significant by requiring preparation and approval of necessary permits to safely dewater the site and appropriate treatment of dewatered material to be reused. Permits and approvals may be required from the California Department of Toxic Substances Control, the San Francisco Bay Regional Water Quality Control Board, Alameda County Health Department, State Water Resources Control Board discharge permits or potentially an air quality permit from the Bay Area Air Quality Control Board if Volatile Organic Compounds (VOCs) are found. Supplemental Mitigation SM-HAZ-2 (potential for release of hazardous materials into the environment due to dewatering activities). If construction dewatering is necessary, a construction dewatering plan shall be prepared and submitted with a dewatering permit application. Reuse of groundwater as an on-site dust palliative or for soil compaction is acceptable if requisite testing and comparison to CAL-EPA screening thresholds indicate that the groundwater is suitable for reuse. If reuse is not possible, contaminated water shall be safely removed to an approved site. Groundwater removed during construction dewatering shall be treated to the extent required by the permit agency prior to discharge and the appropriate permit shall be obtained from the Regional Water Quality Control Board (RWQCB), Dublin San Ramon Services District, or other agency with jurisdiction, if the water is to be discharged into a storm or sanitary sewer system. Demolition of the existing building on the site could result in a significant impact by causing a release of lead based paint and asbestos containing material into the environment if these materials are present in the building. Supplemental Impact HAZ-3 (potential for release of lead based paint and asbestos containing material). Demolition activities could release significant quantities of lead based paint and asbestos containing material and other contaminants into the environment, possibly exposing construction workers, and surrounding residents and visitors during construction (potentially significant impact and mitigation required). Adherence to the following supplemental mitigation measure will reduce this impact to a less than significant level by requiring the safe remediation of potentially hazardous material that could be located in the existing building. Supplemental Mitigation SM-HAZ-3 (potential for release of lead based paint and asbestos containing material). Prior to issuance of a demolition permit for the existing on-site building, testing shall be performed by a qualified and licensed environmental professional to determine the present of significant quantities of lead based paint and asbestos containing material. If detected, such material shall be removed by a qualified contractor and disposed of in an approved disposal facility. Necessary permits shall be obtained from appropriate regulatory agencies prior to remediation. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 201 Supplemental Cumulative Impacts. On-site hazardous conditions would be mitigated to a less- than-significant level with adherence to the above mitigation measures. No additional supplemental impacts related to the potential for release of hazardous material have been identified for adjacent properties in the Environmental Site Assessments prepared for this project. Therefore, the project will not make a cumulatively considerable contribution to any cumulative hazardous conditions. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 202 5.0 ALTERNATIVES TO THE PROPOSED PROJECT The California Environmental Quality Act requires identification and comparative analysis of feasible alternatives to the proposed project which have the potential of achieving most of the project objectives, but would avoid or substantially lessen any significant impacts of the project. The following discussion considers alternative development scenarios. Through comparison of these alternatives to the proposed project, the advantages of each can be weighed and considered by the public and by decision-makers. CEQA Guidelines Section 15126.6 requires a range of alternatives "governed by the rule of reason" and require the EIR to set forth a range of alternatives necessary to permit a reasoned choice. 5.1 Alternatives Identified in the Eastern Dublin EIR The Eastern Dublin EIR was prepared for a General Plan Amendment encompassing approximately 6,920 acres of land and for a Specific Plan for 3,328 acres within the General Plan Amendment area. The General Plan Amendment and Specific Plan (GPA/SP) proposed a variety of types and densities of housing, as well as employment-generating commercial, campus office and other land uses. Other portions of the planning area were designated schools, open space and other community facilities. Protection for natural features of the planning area, including riparian corridors and principal ridgelands, was provided through restrictive land use designations and policies. The land use plan reflected the Eastern Dublin Project Objectives as set forth in the Eastern Dublin EIR, Section 2.5. As required by CEQA, the Eastern Dublin EIR identified project alternatives that could eliminate or reduce significant impacts of the Eastern Dublin Project. The four identified alternatives included: No Project, Reduced Planning Area, Reduced Land Use Intensities and No Development. These are described below: No Project Alternative. The No Project alternative evaluated potential development of the GPA/SP area under the then-applicable Dublin General Plan for the unincorporated portion of the planning area under the Alameda County General Plan. Reduced Planning Area Alternative. The Reduced Planning Area Alternative evaluated development of the Specific Plan as proposed, but assumed development beyond the Specific Plan only to the Dublin Sphere of Influence boundary. The effect of this alternative was to exclude Upper and Lower Doolan Canyon properties from the project. Reduced Land Use Intensities Alternative. The Reduced Land Use Intensities Alternative evaluated potential development of the entire GPA/SP area, but reduced some higher traffic generating commercial uses in favor of increased residential dwellings. No Development. The No Development Alternative assumed no development would occur in the planning area other than agricultural, open space and similar land uses then in place. The Dublin City Council certified the Eastern Dublin EIR on May 10, 1993, under Resolution No. 51-93. The City Council found the No Project, Reduced Land Use Intensities and No The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 203 Development alternatives infeasible and then approved a modification of the Reduced Planning Area Alternative rather than the GPA/SP project as proposed (Resolution No. 53-93). This alternative was approved based on City Council findings that this alternative land use plan would reduce land use impacts, would not disrupt the Doolan Canyon community, would reduce growth-inducing impacts on agricultural lands and would reduce traffic, infrastructure and noise impacts of the originally proposed Eastern Dublin Project. Even under this alternative project, however, significant unavoidable impacts would remain. Therefore, upon approval of the GPA/SP, the City Council adopted a Statement of Overriding Considerations (Resolution No. 53-93). 5.2 Alternatives Identified in the IKEA SEIR The following alternatives were analyzed in the IKEA Supplemental EIR. No Project. This Alternative assumed development pursuant to the Dublin General Plan and the Eastern Dublin Specific Plan, which, at that time, was Campus Office. Development intensity between 0.25 and 0.75 was assumed, consistent with the EDSP. Less-than-significant impacts after mitigation were identified with respect to air quality and biological resources. Traffic and circulation impacts were found to be significant and unavoidable. No Development. The No Development Alternative assumed that the project site would remain vacant and undeveloped. No impacts were identified under this Alternative. Reduced Intensity. A Reduced Density Alternative was considered in the IKEA SEIR. The development scenario analyzed development of 299,475 square feet of commercial uses on the site. Air quality and biological resource impacts were found to be less-than-significant after mitigation. Traffic and circulation impacts were found to be significant and unavoidable. Mixed Use. The final Alternative considered in the IKEA SEIR was a mixed-use development that included 600,000 square feet of office space, 450 apartment dwellings and 21,000 square feet of commercial land use. Similar to the No Project and Reduced Intensity Alternatives, impacts to air quality and biological resources could be mitigated to a less-than-significant level while traffic and circulation impacts were found to be significant and unavoidable. In certifying the IKEA SEIR by adopting Resolution No. 44-04 on March 16, 2004, the Dublin City Council found all of the Alternatives identified in the SEIR to be infeasible. A Statement of Overriding Considerations was adopted as part of Resolution No. 44-04 for air quality and traffic and circulation impacts that could not be mitigated to a less-than-significant level. 5.3 Alternatives Identified in this SEIR Alternatives are described and evaluated below. Alternative 1-No Project/No Development. CEQA requires an analysis of a "No Project" alternative. Under this alternative, it is assumed that the site would remain vacant as it presently exists and no development would occur. Existing General Plan and Eastern Dublin Specific Plan land use designations would remain as they currently exist. This alternative would avoid the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 204 range of environmental impacts described in the Eastern Dublin EIR, the IKEA SEIR and this DSEIR, including: • Population and Housing: Land use within the project area would remain vacant and there would be no impacts related increasing the local population on the project site. • Transportation and Traffic: No new vehicle trips would be generated from the project site that would be added to existing nearby roadways and freeways. No project traffic would be added to existing left-turn lane queuing conditions. Similarly, there would be no new pedestrian or bicycle traffic to and from the site nor any new users of public transit systems from the proposed project. There would be no significant and unavoidable impacts related to project contributions to congested Dublin arterial roadways or freeways. • Community Services and Facilities: No increases in the demand for public schools would be created nor would there be an increased demand for local or regional park and recreation facilities. • Sewer and Water: There would be no demand for potable or recycled water or increased wastewater from the site since no development would occur. • Biological Resources: No special-status plant or wildlife species on the site would be impacted since there would be no disturbance of the site. Similarly, there would be no impacts to wetlands or other waters as would occur under the proposed project. • Noise: No new noise sources would be generated on the site as a result of increased traffic, noise from loading and unloading activities, use of trash compactors or mechanical equipment since no development would occur. • Air Quality and Greenhouse Gas Emissions: There would be no short-term construction related air or greenhouse gas emissions or long-term operational air quality and greenhouse emission impacts associated with the project since no construction would occur and there would be no vehicle trips to and from the site. No sensitive receptors would be located on the site and no impacts would occur with respect to exposure of sensitive receptors to Toxic Air Contaminants. There would be no contribution to long- term, cumulative air quality or greenhouse emissions since no vehicular traffic would be attracted to the site or other activities occur that would cumulatively contribute to greenhouse gas emissions. • Hazards and Hazardous Materials: No notification to the Alameda County Environmental Health Department of pending residential development on the site would be required under the No Project Alternative. No disturbance of hazardous materials located on the site would occur. Overall, the No Project/No Development Alternative would result in significantly less impacts than the proposed project. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 205 Alternative 2-General Commercial Development. Alternative 2 would include development of the site under the existing Planned Development zoning. The existing PD zoning would provide for 270,000 square feet of retail space and 35,000 square feet of restaurant space on the project site. The alternative would also include on-site parking, new driveways from adjoining roads, landscaping and other improvements. Implementation of this Alternative would not require amendments to the Dublin General Plan, the Eastern Dublin Specific Plan or existing site zoning. An analysis of the impacts of the Mixed-Use Alternative is as follows: • Population and Housing: The project site would be developed with one or more retail and restaurant space as currently envisioned in the Dublin General Plan and Eastern Dublin Specific Plan. No housing would be located on the site, so there would be no impacts due to housing and population which would be less than the proposed project. • Transportation and Traffic: Under Alternative 2, A.M. peak hour trips would be less than the proposed project, so impacts on roadways during the A.M. peak hour would be less for this alternative as compared to the proposed project. Table 5.1-1. Alternative 2 vs. Project Trip Generation A.M. Peak Trips P.M. Peak Trips Proposed Project1 560 405 Alternative 2 -Retail Development2 351 842 Difference -209 +437 Notes: 1) Project trip rates contained in DSEIR Table 4.2-2 2) Alternative 2 trip rates provided by Kittelson & Associates, 2014 P.M. peak hour trips would be substantially greater, estimated to be 437, than the proposed project. Therefore, traffic and transportation impacts on local roadways and freeways would be expected to be greater than the proposed project. Significant and unavoidable impacts would still occur at the Dublin Boulevard and Dougherty Road intersection and the Dublin Boulevard and Hacienda Drive intersection. It is likely that other significant and unavoidable impacts could also occur at other nearby intersections during the P.M. peak hour due to the increased volume of traffic in this period. Significant and unavoidable impacts in terms of queuing lengths at local intersections would also occur, similar to the proposed project. Impacts to traffic safety, pedestrian, bicycle and public transit systems as identified in the Traffic and Transportation section of this DSEIR for the proposed project could also The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 206 occur with respect to Alternative 2, but these impacts could be mitigated to a less-than- significant level as noted in the DSEIR. • Community Services and Facilities: Development under Alternative 2 would likely result in less-than-significant impacts to Dublin Unified School District facilities and local and regional park facilities, since no residences would be built that would use community services and facilities. Therefore, the impact of Alternative 2 would be less than the proposed project. • Sewer and Water: Potable water use for commercial development that could be built under Alternative 2 would be less than the proposed project as shown in Table 4.4-1 of this DSEIR. This is because proposed residential uses require more water use than commercial and other non-residential uses. Similarly, commercial uses considered under Alternative 2 would generate less wastewater since less water would be used. Therefore, the impact of Alternative 2 would be less than the proposed project. • Biological Resources: Development under Alternative 2 would be approximately the same as the proposed project, since the same amount of ground disturbance would occur and the same impacts to special-status plant and wildlife resources would occur. The same impacts to wetlands and other waters would also occur. Similar to the proposed project, all biological resource impacts could be mitigated to a less-than-significant level. • Noise: New sources of noise would be introduced onto the project site in terms of vehicle traffic, loading and unloading activities and mechanical noise. However, there would not be a permanent residential population that would be affected by increased noise or be subject to existing noise from the I-580 freeway south of the site. Overall, noise impacts under Alternative 2 would be less than the proposed project. • Air Quality and Greenhouse Gas Emissions: Development that could occur under Alternative 2 would result in an estimated 11,814 daily trips (source: Kittelson Associates, 4/9/14), which would be significantly greater than the estimated 6,219 trips for the proposed project as documented in Table 4-2-4. This would result in emissions of a significantly higher emission of air pollutants and greenhouses on a project and cumulative basis than the proposed project. However, there would not be a permanent on-site resident population that would be impacted by Toxic Air Contaminants as would residents under the proposed project. It is anticipated that impacts related to violation of air quality standards, conflicts with applicable regional clean air plans, and greenhouse gas emissions would be significant and unavoidable, similar to the proposed project. • Hazards and Hazardous Materials: No notification to the Alameda County Environmental Health Department of pending residential development on the site would be required under Alternative 2 since no residential development would occur. However, development of the site under Alternative 2 would have similar impacts to proposed project due to exposure to and disposal of hazardous materials. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 207 Alternative 3- Campus Office Development. Under this alternative the site would be developed consistent with the existing Campus Office General Plan and Eastern Dublin Specific Plan land use designation. This Alternative considers construction of up 218,000 square feet of administrative, business and professional offices and a Floor Area Ratio of 0.35, consistent with nearby properties in the Eastern Dublin Planning Area. Development of this alternative would also include on-site surface parking lots, landscaping, signs and similar improvements normally and customarily included in an office park development. No amendments to the General Plan or the Eastern Dublin Specific Plan would be required to implement Alternative 3. This alternative would generally result in the same type and intensity of impacts as analyzed in the Eastern Dublin EIR, including: • Population and Housing: The project site would be developed with multiple low-rise, offices in a campus-like setting, as currently envisioned in the Dublin General Plan and Eastern Dublin Specific Plan, similar to Alternative 2. No impacts would occur with respect to inducing additional population growth or housing on this site. • Transportation and Traffic: New peak hour vehicle trips would be added to the local and regional roadways system. Based on Table 5.1-2, there would be slightly fewer peak hour trips than the proposed project, but impacts to local and regional roads, key nearby intersections and queuing conditions would occur on a project and cumulative basis. It is likely the same significant and unavoidable impacts would occur as would occur for the proposed project since approximately the same number of peak trips would occur. Table 5.1-2. Alternative 3 vs. Project Trip Generation A.M. Peak Trips P.M. Peak Trips Proposed Project1 560 405 Alternative 3 –Office Development2 402 344 Difference -158 -61 Notes: 1) Project trip rates contained in DSEIR Table 4.2-2 2) Alternative 2 trip rates provided by Kittelson & Associates, 2014 Impacts to traffic safety, pedestrian, bicycle and public transit systems as identified in the Traffic and Transportation section of this DSEIR for the proposed project could also occur with respect to Alternative 2, but these impacts could be mitigated to a less-than- significant level as noted in the DSEIR. • Community Services and Facilities: Similar to Alternative 2, development of the site under Alternative 3 would result in less-than-significant impacts to Dublin Unified The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 208 School District facilities and local and regional park facilities, since no residences would be built. • Sewer and Water: Impacts to use of water and generation of wastewater would be less than Alternative 2, since water demand for office use is considered approximately the same as retail use by DSRSD staff (Source: S. Kolodzie, DSRSD, 3/3/14) and would result in an estimated build-out water use of approximately 21,800 gallons per day based on DSRSD water use rates shown in Table 4.2-1. Impacts to water and sewer would be less under Alternative 3 than the proposed project. • Biological Resources: Development under Alternative 3 would be approximately the same as the proposed project and Alternative 2, since the same amount of ground disturbance would occur and the same impacts to special-status plant and wildlife resources would occur. The same impacts to wetlands and other waters would also occur. Similar to the proposed project, all biological resource impacts could be mitigated to a less-than-significant level. • Noise: New sources of noise would be introduced onto the project site in terms of vehicle traffic and mechanical noise. However, similar to Alternative 2, there would not be a permanent residential population on the site as would occur under the proposed project that would be affected by increased on-site noise or be subject to existing noise from the I-580 freeway south of the site. Overall, noise impacts under Alternative 3 would be approximately the same as Alternative 2 and would be less than the proposed project. • Air Quality and Greenhouse Gas Emissions: Emissions of air pollutants and greenhouse gasses under Alternative 3 is estimated to be less than either the proposed project or Alternative 2. This is due to fewer total daily trips that would be generated by Alternative. The estimated total daily vehicle trips for Alternative 3 would be 2,547 (Kittleson & Associates, 4/9/14), which is fewer total daily trips than either Alternative 2 or the proposed project. Similar to Alternative 2, there would not be an on-site population of sensitive receptors that would be impacts from TAC emissions from the adjacent I-580 freeway as would occur under the proposed project. It is likely that Alternative 3 would result in the same significant and unavoidable impacts with respect to violation of air quality standards, conflicts with applicable clean air plans and emission of greenhouse gasses. • Hazards and Hazardous Materials: No notification to the Alameda County Environmental Health Department of pending residential development on the site would be required under Alternative 3 since no residential development would occur. 5.4 Environmentally Superior Alternative Section 15126 (d) (4) of the State of California CEQA Guidelines states that if the environmentally superior alternative is the "No Project" alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. Alternative 1, the No Project alternative, would result in fewer and less intensive environmental impacts than the proposed project and all other alternatives that propose development, since the project site would remain The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 209 vacant and no development impacts would occur. Therefore, Alternative 1 would be the Environmentally Superior Alternative. Between the remaining alternatives, Alternative 2 would then be the next most environmentally superior alternative. Alternative 2 (general commercial development) would result in significantly fewer total daily trips than either the proposed project or Alternative 3 (campus office development), although Alternative 2 would result in slightly higher p.m. peak hour trips than the proposed project. Alternative 2 would result in less intense impacts to air quality and greenhouse gas emissions than the proposed project since it would result in significantly fewer daily vehicle trips. Alternative 2 would also result in less intense impacts to community services and facilities (schools and parks), on-site noise impacts, water use and wastewater generation than the proposed project, since there would not be an on-site population that would require these services. Impacts to on-site biological resources would be approximately the same as the proposed project since the same amount of ground surface would be disturbed for grading and construction. Impacts to hazards and hazardous materials would be less under Alternative 2 than the proposed project, since there would not be an on-site resident population that could be affected by any residual contaminants. Similarly, impacts regarding Toxic Air Contaminants and noise would be slightly less than the proposed project due to an absence of an on-site residential population. Alternative 3 (campus office development) is anticipated to have approximately the same environmental impacts as the proposed project in terms of water use and wastewater generation, hazards, and biological impacts as the proposed project. Impacts regarding traffic and transportation, air quality and greenhouse gas emissions would be greater than the than the proposed project and Alternative 2. Impacts regarding Toxic Air Contaminants and noise would be similar to Alternative 2. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 210 6.0 REQUIRED CEQA DISCUSSION This section of the DEIR addresses the potential cumulative impacts of implementing the proposed Project, as required by CEQA. 6.1 Cumulative Impacts Cumulative impacts are defined by CEQA Guidelines (Section 15126.2) as those which taken individually may be minor but, when combined with similar impacts associated with existing development, proposed development projects and planned but not built projects, have the potential to generate more substantial impacts. CEQA requires that cumulative impacts be evaluated when they are significant and that the discussion describe the severity of the impacts and the estimated likelihood of their occurrence. CEQA also states that the discussion of cumulative impacts contained in an EIR need not be as detailed as that provided for the Project alone. The analyses of cumulative impacts for the project are contained in each of the impact sections addressed in this SEIR. The cumulative impacts analysis for impacts not addressed in this EIR are contained in the Eastern Dublin EIR and IKEA SEIR. A number of cumulative impacts were identified in the Eastern Dublin EIR. • Cumulative loss of agricultural and open space lands (Impact 3.1/F) • Cumulative degradation of I-580 freeway operations between Tassajara Road and Fallon Road (Impact 3.3/A) • Cumulative degradation of I-580 freeway operations between I-680 freeway and Dougherty Road (Impact 3.3/B) • Cumulative degradation of I-580 freeway operations between Tassajara Road and Airway Boulevard Impact 3.3/C) • Cumulative degradation of I-680 freeway operations north of I-580 (Impact 3.3/D) • Cumulative degradation of I-580 east of Airway Boulevard and between Dougherty Road and Hacienda Boulevard (Impact 3.3/D) • Cumulative degradation of Dublin Boulevard intersections with Hacienda Drive and Tassajara Road (Impact 3.3/M) • Cumulative degradation of Tassajara Road intersections with Gleason Road, Fallon Road and Transit Spine (renamed to Central Boulevard) (Impact 3.3/N) • Increased solid waste production and impact on solid waste facilities (Impact 3.4 O and P) • Future lack of wastewater treatment plant capacity (Impact 3.5/E) • Increase in demand for water (Impact 3.5/Q) • Direct habitat loss (Imapct3.7/A) • Loss or degradation of botanically sensitive habitat (Impact 3/7/C) • Construction equipment/vehicle emissions (Impact 3.11/B) • Mobile source emissions of reactive organic gasses and oxides of nitrogen (Impact 3.11/C) • Stationary source emissions (Impact 3.11/E) The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 211 IKEA SEIR. The following cumulative impacts were documented in the IKEA SEIR, as follows. • Exceedances of BAAQMD thresholds of significance for ozone precursors (Supplemental Impact SM-AQ-3) • Cumulative traffic and transportation impacts at study area intersections (Supplemental Impact SM-TRA-2) • Cumulative increase of project-related traffic on adjacent freeways (Supplemental Impact SM-TRA-3) This DSEIR identifies additional cumulative impacts: • Supplemental Impact TR-2: Short-term cumulative impacts at the Dublin Blvd./Dougherty Rd. intersection during the PM peak period. • Supplemental Impact TR-3: Short-term cumulative impacts at the Dublin Boulevard/Hacienda Drive intersection during the PM peak period. • Supplemental Impact TR-4: Short-term cumulative impacts at the Dublin Boulevard/Tassajara Road intersection. • Supplemental Impact TR-5: Long-term cumulative impact at the Dublin Boulevard/Scarlett Drive intersection. • Supplemental Impact TR-6: Long-term cumulative impact at the Dublin Boulevard/Arnold Road intersection. • Supplemental Impact TR-7: Short-term cumulative plus project queuing impact at the Dublin Boulevard/Dougherty Road intersection. • Supplemental Impact TR-8: Short-term cumulative plus project queuing impact at the Dublin Boulevard/Hacienda Drive intersection. • Supplemental Impact TR-9: Long-term cumulative plus project queuing impact at the Scarlett Drive/Dougherty Road intersection. • Supplemental Impact TR-15: Short-term cumulative conditions roadway segment impact along northbound Tassajara Road between Dublin Boulevard and Central Parkway. • Supplemental Impact TR-16: Roadway segment impact along westbound Dublin Boulevard between Iron Horse Parkway and Camp Parks. • Supplemental Impact AQ-2: Emission of cumulative considerable air pollutants during project operation. • Supplemental Impact AQ-4: Generation of greenhouse gas emissions, both directly and indirectly, that would have a significant impact on the environment and would conflict with applicable plans, policies and regulations adopted for the purpose of reducing greenhouse gas emissions. 6.2 Significant and Unavoidable Environmental Impacts Unavoidable significant adverse impacts are those impacts that cannot be mitigated to a less- than-significant level. CEQA requires decision-makers to balance the benefits of a proposed Project against its unavoidable impacts in considering whether to approve the Project. If the benefits of the proposed Project outweigh the anticipated unavoidable impacts, the adverse environmental impacts may be considered acceptable by the Lead Agency. To approve the The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 212 Project without significantly reducing or eliminating an adverse impact, the Lead Agency must make a Statement of Overriding Consideration supported by the information in the record. Upon approval of the Eastern Dublin project, the City Council adopted a Statement of Overriding Considerations for the significant unavoidable impacts identified in the Eastern Dublin EIR. (Resolution 53-93, May 10, 1993.) Any approval of the current project would likewise require adoption of a Statement of Overriding Considerations for the significant unavoidable supplemental impacts identified in this DSEIR, i.e., Supplemental Impacts TR-2 (short-term cumulative impacts at the Dublin Blvd./Dougherty Rd. intersection during the PM peak period), TR-3 (short-term cumulative impacts at Dublin Blvd./Hacienda Dr. intersection), TR-10 (roadway segment impact along Dublin Blvd. between Hacienda Dr. and Hibernia Dr.), TR-11 (roadway segment impact along Hacienda Dr. between Dublin Blvd. and Central Pkwy.), TR-12 (roadway segment impact along Dublin Blvd. between DeMarcus Blvd. and Iron Horse Pkwy.), TR-13 (roadway segment impact along Dublin Blvd. between Scarlett Dr. and Dougherty Rd), TR-14 (short-term cumulative impact under No Project conditions, roadway segment impact along northbound Hacienda Dr. between the I-580 westbound ramps and Hacienda Crossing), TR-15 (short-term cumulative impact, roadway segment impact along northbound Tassajara Rd. between Dublin Blvd. and Central Pkwy.), TR-16 (long-term cumulative impact, roadway segment impact along westbound Dublin Blvd. between Iron Horse Pkwy. and Camp Parks), TR-17 (long-term cumulative impact under No Project conditions, roadway segment impact along northbound Hacienda Dr. between the I-580 westbound ramps and Hacienda Crossing). The following additional impacts have been determined to be significant and unavoidable as well: Supplemental Impact AQ-1 (emission of cumulative considerable air pollutants during project operation), Supplemental Impact AQ-2 (violation of air quality standards) and Supplemental Impact AQ-3 (conflict with applicable clean air plan) and Supplemental Impact AQ-5 (project generation of greenhouse gas emissions). Pursuant to the Citizens for a Better Environment case, the Statement of Overriding Considerations would also be required to address the significant unavoidable impacts from the Eastern Dublin EIR that are related to the project. The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 213 7.0 ORGANIZATIONS AND PERSONS CONSULTED 7.1 Persons and Organizations EIR Preparers The following individuals participated in the preparation of this document. Jerry Haag, Urban Planner (project manager) Alice Chen P.E., Kittleson & Associates (traffic and transportation) Debby Yueh, P.E., Kittleson & Associates (traffic and transportation) Michael Thill, Illingworth & Rodkin (acoustics) James Reyff, Illingworth & Rodkin (air quality/greenhouse gas emissions) Joshua Carmen, Illingworth & Rodkin (air quality/greenhouse gas emissions) Pat Lam, ENGEO (hazards) Tom Fraser, WRA (biological resources) Jane Maxwell, Blue Ox Associates (graphics) City of Dublin Staff Luke Sims AICP, Community Development Director Jeff Baker, Assistant Community Development Director Tim Cremin, Assistant City Attorney Kristi Bascom, Principal Planner Andy Russell, P.E. City Engineer Obaid Khan P.E., Traffic Engineer Bonnie Terra, Fire Marshall, Alameda County Fire Department Tom McCarthy, Dublin Police Services Applicant Consulting Team Mike Parker and David Clock, Quattro Realty Other Agencies and Organizations Contacted Stan Kolozdie and Rhodora Biagtan, Dublin San Ramon Services District Patricia Benavidez and Shirley Edward, Dublin Unified School District The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 214 7.2 References The following documents, in addition to those included in the Appendix, were used in the preparation of this DSEIR. Annual Review of Sustainable Water Supply for Zone 7 Water Agency, Alameda County Flood Control and Water Conservation District, May 15, 2013 Bay Area Air Quality Management District CEQA Guidelines, 2011 Climate Action Plan, City of Dublin, updated July 2013 Dublin Bikeways Master Plan, 2007 Dublin Crossing Specific Plan Draft EIR, RBF Consulting, June 2013 Dublin General Plan, City of Dublin, Updated through 2/13 Eastern Dublin General Plan, Wallace Roberts & Todd, 1993 Eastern Dublin Specific Plan and General Plan Environmental Impact Report, Wallace Roberts & Todd, 1994 Livermore Municipal Airport, Airport Land Use Compatibility Plan, Alameda County ALUC, August 2012 Parks and Recreation Master Plan, City of Dublin, 2006 update The Village at Dublin Supplemental EIR (Draft and Final), Jerry Haag, October 2013 Urban Water Master Plan 2010, Dublin San Ramon Services District, 2011 The Green Project/ Draft Supplemental EIR City of Dublin May 2014 Page 215 8.0 Appendices All Appendices are under separate cover The Green Mixed Use Project Final Supplemental EIR PLPA-2013-00013 Lead Agency: Prepared by: Jerry Haag, Urban Planner August 2014 Final Supplemental EIR: The Green Mixed Use Project Page 2 City of Dublin August 2014 Table of Contents Introduction.............................................................................................................................3 Clarifications and Modifications to the DSEIR.........................................................................4 Summary of DSEIR Comment Letters..................................................................................11 Responses to DSEIR Comment Letters................................................................................12 Attachments Attachment 1: Annotated Comment Letters Attachment 2: Table 1.1 (Summary of Mitigation Measures) Attachment 3: Breeding Bird Survey Report, dated April 2014 Attachment 4: Alameda County Department of Environmental Health letter, dated June 2014 Attachment 5: Ground Zero Report for Alameda County Department of Environmental Health letter, dated April 2014 Attachment 6: Sacramento Metropolitan Air Quality Management District " Guidance for Construction GHG Emissions Reductions", dated September 2010. Final Supplemental EIR: The Green Mixed Use Project Page 3 City of Dublin August 2014 Introduction The project area contains approximately 27.5 acres of land located on the south side of Martinelli Way between Hacienda Drive to the east and Arnold Road to the west. Interstate 580 forms the southern boundary of the site. The Alameda County Assessor’s Parcel Numbers for the project area are 986-0033-004-00, 986-0033-005-02, and 986-0033-006- 00. A Draft Supplemental Environmental Impact Report (DSEIR) dated May 2014 was prepared for this project and distributed for public review. Under the California Environmental Quality Act (CEQA) and implementing CEQA Guidelines, after completion of the DSEIR, lead agencies are required to consult with and obtain comments from public agencies and organizations having jurisdiction by law over elements of the Project and to provide the general public with an opportunity to comment on the DSEIR. Lead agencies are also required to respond to substantive comments on environmental issues raised during the DSEIR review period. As the lead agency for this Project, the City of Dublin held a 45-day public review period beginning on May 7, 2014 and ending on June 23, 2014. This Comments and Responses document augments the DSEIR and, together with the DSEIR, comprises the Final Supplemental EIR (FSEIR) for this project. This document contains all public comments received during the public review period regarding the DSEIR and responses to those comments. Included within the document is an annotated copy of each comment letter, identifying specific comments, followed by a response to that comment. The FSEIR also contains clarifications and minor corrections to information presented in the DSEIR. In the course of preparing the responses to comments, the City generated clarifications and modifications to the text of the DSEIR. The City has carefully reviewed the responses in this document, especially any new information or clarifications and modifications to the DSEIR text, against the recirculation standards of CEQA Guidelines section 15088.5. None of the new information, clarifications, or modifications in this document constitutes significant new information as defined in the Guidelines, such as new or substantially more severe significant impacts, therefore the City has determined that no recirculation is required. Final Supplemental EIR: The Green Mixed Use Project Page 4 City of Dublin August 2014 Clarifications and Modifications to the DSEIR The following clarifications and modifications to the DSEIR are incorporated by reference into the DSEIR document. 1. Page 4: Table 1.1 (Summary of Mitigation Measures) has been re-printed in its entirety to ensure that the text in the summary table matches exactly the text in the body of the DSEIR. Table 1.1 is included as Attachment 1 to the FSEIR. Additionally, several Supplemental Mitigation Measures have been modified based on the responses provided herein. All changes to Table 1.1 are shown in underline and strikethrough. 2. Page 37: Under the “Circulation and Access” heading, the first sentence in the second paragraph from the bottom shall be modified to read: An approximately 10 15 foot wide trail would be provided on the site adjacent to the I-580 freeway. 3. Page 38: A new paragraph will be added, as follows: Site lighting. The project site will contain lighting adequate for safety and security purposes. Several of the light fixtures will be solar and wind powered and each individual fixture will contain small solar panels/small-scale wind turbines to generate the electricity needed to power the lights. Other light fixtures will be LED to ensure maximum efficiency. 4. Page 51. Fourth paragraph shall be modified as follows. The updated data does not change the traffic impact analysis of the DSEIR. This information was provided as background context only. Freeways. Regional vehicular access to the site is provided primarily by the freeway system that serves eastern Alameda County. Interstate 580 (I-580) is an east-west facility that runs along the southern boundary of the project site. It spans between US Highway 101 in the North Bay city of San Rafael and Interstate 5 just south of the Central Valley city of Tracy with direct connections to Interstate 80, Interstate 680, Interstate 205, and State Route 238. It has eight-to-ten travel lanes in the vicinity of the project site and carries approximately 214,000197,000 average daily vehicles and 15,800 peak hour vehicles between Hacienda Drive and Tassajara Road. The nearest access to I-580 from the project site is provided by the ramps on Hacienda Drive and Tassajara Road. The footnote on Page 51 shall also be modified to note that the source of the updated traffic volume is: “California Department of Transportation, 2013. 2012 Traffic Volumes on the California State Highway System.” 5. Page 67: Second paragraph shall be modified as follows: An adjustment was made to account for internal trips between retail, which includes restaurants and other retail, and residential land uses within the project site. The internal trip adjustment was performed using procedures recommended by ITE for multi-use developments. Internal trips are trips that would occur between different land uses on the same site without accessing the external street system. Therefore, this analysis assumes Final Supplemental EIR: The Green Mixed Use Project Page 5 City of Dublin August 2014 direct access would be provided between the residential and commercial uses. While it is reasonable to assume a small number of internal trips would occur during the AM peak hour, ITE does not provide any guidance. The exclusion of AM peak hour internal trip adjustments results in a conservative analysis. Further details on the internal trip calculations may be found in Appendix A of Appendix 8.6. 6. Page 82: Supplemental Mitigation Measure SM-TR-5 shall be modified as follows” Supplemental Mitigation Measure -TR-5. At the intersection of Dublin Boulevard and Scarlett Drive, there is a significant impact from the Dublin Crossing project according to the Dublin Crossing Specific Plan (DCSP)-DEIR. In the DSCP-DEIR, the recommended measure to mitigate the impacts at the intersection of Scarlett Drive and Dublin Boulevard due to the high rate of pedestrians/bicyclists crossing at Dublin Boulevard is a grade separated crossing. 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 the Dublin Crossings 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 separated bridge has not yet been environmentally cleared, and to ensure that the impacts are adequately mitigated, the Applicant/Developer is required to provide a fair-share contribution for the alternative mitigation of removing the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. 7. Pages 106 and 107. Supplemental Mitigation Measures SM-TR-18 and SM-TR-19 shall be modified as follows: Supplemental Mitigation Measure SM-TR-18 and 19. Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with applicable City guidelines, polices and standards for review and approval by the City. Prior to the issuance of any permit for the project, the Applicant shall prepared final Site Improvement Plans for both onsite and offsite improvements that are consistent with the Site Development Review and Vesting Tentative Tract Map plans, which have been determined to be consistent with applicable City guidelines, policies and standards, including but not limited to the City of Dublin General Plan Community Design & Sustainability Element, Chapter 8.76 of the Dublin Zoning Ordinance, and the Bikeway Master Plan, for review and approval by the City. 8. Page 110: The third paragraph on this page and Table 4.3-1 shall be modified as follows based on information from DUSD. The updated data does not change the conclusion in the DSEIR that the project’s impact on schools is less than significant. Schools that would likely be affected by the proposed project include: • Kolb Elementary, 3150 Palermo Way • Dougherty Elementary, 5301 Hibernia • Fallon Middle School, 3601 Kohnen Way • Dublin High School, 8151 Village Parkway • Valley High School, 6901 York Drive Final Supplemental EIR: The Green Mixed Use Project Page 6 City of Dublin August 2014 Table 4.3-1. Current Public School Enrollment v. Capacity School Facility 2013/14 Enrollment School Capacity Kolb Elementary 1009 1007 Dougherty Elementary 818 805 826 933 Fallon Middle School 1,110 1,232 Dublin High 1,922 1,737 2,198 2,232 Valley High 78 80 360 Source: Sherrie Sylva, Dublin Unified School District, 2013 3/31/2014 9. Page 114: Supplemental Mitigation Measure SM-Park-1 shall be modified as follows: Supplemental Mitigation Measure SM-Park-1 (lack of adequate local parkland). As part of the first final subdivision map for the project, the project developer(s) shall dedicate a minimum two-acre Neighborhood Square to the City of Dublin. The size, configuration and location of the Neighborhood Square shall be approved by the Dublin Parks and Community Services Department. Project developer(s) shall satisfy remaining local park requirements by paying fees to the City of Dublin prior to issuance of building permits. Prior to approval of the first Final Subdivision Map for the project, the project developer(s) shall satisfy the requirement to provide parkland through the payment of in-lieu fees to the City of Dublin prior to issuance of building permits. 10. Page 116: The following paragraph will be added under the heading “IMPACTS AND MITIGATION MEASURES FROM PREVIOUS EIRs”: The City of Dublin expresses its continued support of the Zone 7 Water Agency Salt Management Plan. New development in Dublin will continue to pay impact fees to Zone 7 as the time of permit issuance to provide funding for the implementation of the Plan. 11. Page 117: The first paragraph on this page, Table 4.4-1, and the third paragraph on this page shall be modified as follows based on updated information from DSRSD. The updated data does not change the conclusion in the DSEIR that the project’s impact due to wastewater generation is less than significant. Estimated wastewater generation. DSRSD staff estimated the generation of wastewater from The Green project as compared to the approved use of 305,000 sq. ft. of General Commercial that would occur under currently approved development plans. This is shown on Table 4.4-1, below. The table shows that the project would generate an additional estimated 68,135 50,885 gallons of wastewater per day at build-out over the amount of wastewater expected to be generated by the approved General Commercial use. Table 4.4-1. The Green Project-Estimated Daily Wastewater Demand (gallons/day) Land Use Amount Use Factor Wastewater (GPD) Approved Use General Commercial Estimated Wastewater Demand 305,000 sq. ft. 0.1 gpd/sq ft 30,500 gpd Proposed Uses Retail/Commercial 5000 sq. ft. 0.1 0.05 gpd/sq ft 250 500 gpd Final Supplemental EIR: The Green Mixed Use Project Page 7 City of Dublin August 2014 Restaurant 35,000 sq. ft. 0.1 0.6 gpd/sq ft 21,000 3,500 gpd Residential Condominium Townhouse 193 400 DU 207 DU 165 120 gpd/DU 220 gpd/DU 31,845 48,000 gpd 45,540 gpd Total Estimated Project Wastewater Demand 98,635 52,000 gpd Difference between Approved Project and Proposed Project +68,135 21,500 gpd with Proposed Project Source: Stan Kolodzie, 4/25/14 Ryan Pendergraft, DSRSD, 5/29/2014 Therefore, the District has adequate wastewater treatment capacity at the regional plant to accommodate the estimated 68,135 81,385 gallons of wastewater that would be generated per day. No new or expanded wastewater facilities would be needed to serve the proposed project nor would the amount of additional wastewater flows exceed the Regional Water Board’s approved limit of the DSRSD wastewater treatment plan. The amount of additional wastewater would result in a less-than-significant impact on a project and cumulative level. 12. Page 129: The last paragraph on this page and Table 4.4-6 shall be modified as follows based on updated information from DSRSD. The updated data does not change the conclusion in the DSEIR that the project’s impact due to water supply demand is less than significant. Supplemental water use impact. DSRSD UWMP includes demand from the development of a 305,000 square foot retail/commercial project on the project site under the existing City entitlements. Based on Table 4.4-6 below, this use would require an estimated 30,500 gallons per day at full build-out. The proposed project would generate an estimated need for 101,650 52,000 gallons of potable water per day, which would be an estimated 71,150 21,500 gallons of water per day greater than anticipated water demand in the DSRSD UWMP. The project would use recycled water for exterior landscape irrigation and other exterior uses. Therefore, estimated water use shown in Table 4.4-6 E does not include use of potable water for landscape irrigation. Table 4.4-6. The Green Project-Estimated Daily Water Demand (gallons/day) Land Use Amount Water Use Factor Water Use (GPD) Approved Use included in DSRSD UWMP General Commercial 305,000 sq. ft. 0.1 gpd/sq ft 30,500 gpd Proposed Project Uses Retail/Commercial 5000 sq. ft. 0.1 0.05 gpd/sq ft 250 500 gpd Restaurant 35,000 sq. ft. 0.1 0.6 gpd/sq ft 21,000 3,500 gpd Residential Condo/Townhouse 400 DU 201 120 gpd/DU 80,400 48,000 gpd Est. Water Demand. 101,650 52,000 gpd Difference +71,150 21,500 gpd Source: Stan Kolodzie, 4/13/14 Ryan Pendergraft, DSRSD, 5/29/2014 13. Page 132: The following paragraph shall be modified as follows: Biological communities. Table 4.4-1 4.5-1 summarizes the area of each biological community type observed in the Project Area. Non-sensitive biological communities in the Project Area include non-native annual grassland and ruderal herbaceous stands. One Final Supplemental EIR: The Green Mixed Use Project Page 8 City of Dublin August 2014 potentially sensitive biological community is found in the project area. Descriptions for each biological community are contained in the following sections. 14. Page 134: The following paragraph will be added under the heading “Present Species”: Loggerhead shrike (Lanius ludovicianus). CDFW Species of Special Concern. Present. A breeding bird survey was conducted on April 22, 2014 by a WRA wildlife biologist. During the visit, one active loggerhead shrike nest was observed in a coyote bush along the northern fence of the Project Area, located near the Martinelli Way gate.1 The female was observed incubating the nest and the male was foraging in the area. Any potential impacts to this species will be reduced to less than significant by Mitigation Measure BIO-4. 15. Page 142: The following paragraph will be added after Supplemental Mitigation Measure SM-BIO-1: Given the presence of California Tiger Salamander (CTS) in the Eastern Dublin area, mitigation of project wetlands impacts off-site through the implementation of SM-BIO-1 may have impacts on CTS. The potential impacts on CTS from development and the implementation of mitigation measures in Eastern Dublin and adjacent areas was studied in the 1993 EDSP EIR, and Mitigation Measure 3.7/20.0, MM 3.7/21.0, and MM 3.7/22.0 were developed to address these impacts. The types of potential impacts on the CTS from any off-site mitigation due to the implementation of SM-BIO-1 would be similar to the impacts described and analyzed in the 1993 EDSP EIR. The 1993 EDSP EIR mitigation measures noted above would apply to any future impacts of off-site mitigation and current regulatory requirements by resource agencies would apply as well. With the implementation of the 1993 EDSP EIR mitigation measures and current regulatory requirements, the potential impact on the CTS due to off-site implementation of mitigation measures to address project wetlands impacts would be reduced to less than significant as identified in the 1993 EDSP EIR. 16. Page 142: Supplemental Mitigation Measure SM-BIO-2 shall be modified as follows: Supplemental Mitigation Measure SM-BIO-2 (impacts to Congdon’s tarplant and other special-status plant species). Focused surveys for special-status plants shall be conducted on the site consistent with the California Department of Fish & Wildlife’s 2009 Protocols for Surveying and Evaluating Impacts to Special-Status Populations and natural Communities. Plant surveys shall be conducted throughout the blooming period throughout the blooming period of those special-status for which suitable habitat is present. Two or three separate surveys may be required to cover the blooming period of plants listed in Appendix Ai of the Supplemental Biological Analysis (Appendix 8.7 of the DSEIR) Table 4.4- 1. If populations/stands of a special-status species are identified during the surveys and impacts cannot be avoided, , compensatory mitigation shall be provided, such as the acquisition of off-site mitigation areas presently supporting the species in question, purchase of credits in a mitigation bank that is approved to sell credits for the affected species, or payment of in-lieu fees to a public agency or conservation organization (e.g.. a local land trust) for the preservation and management of existing populations. The location of 1 Valcarcel, Tricia. 2014. Re: Breeding Bird Survey at The Green, Dublin, California (survey letter report). April 22, 2014. 3pp. Final Supplemental EIR: The Green Mixed Use Project Page 9 City of Dublin August 2014 mitigation sites shall be determined in consultation with and subject to approval of US Fish and Wildlife Service and/or California Department of Fish & Wildlife. In the case where special-status plants are neither federal- or state-listed, the lead agency shall approve the mitigation approach using the guidance provided by the Eastern Alameda County Conservation Strategy in consultation with the City’s consulting biologist. Off-site compensatory shall be acquired at a minimum acreage ratio of 1:1 (acquired:impacted). For off-site mitigation options, measures shall be implemented (including contingency measures) providing for the long-term protection of these species. 17. Page 144: Supplemental Mitigation Measure SM-BIO-4 shall be modified as follows: Supplemental Mitigation Measure SM-BIO-4 (impacts to breeding birds). Vegetation removal and/or initial ground disturbance on the site shall occur during the non-breeding season from September 1 to January 31. If instead these actions will occur from February 1 to August 31, then a pre-construction breeding bird survey shall be conducted no more than 14 days prior to construction. Any common bird active nests found shall be protected by a minimum 50-foot exclusion buffer. The buffer size may vary depending on bird species, the location of the nest, and other factors. If a breeding bird survey determines that a special- status species is located on the site, a larger buffer would be required, such as a 100-foot buffer for minor disturbances and a 250-foot buffer for major disturbances. In the case of special-status species, the size of buffers and other measures would be implemented based on any applicable CDFW guidance and standards. 18. Page 190. Supplemental Mitigation Measure SM-AQ-4 shall be modified as follows: SM-AQ-4 (project generation of greenhouse gas emissions). The final design of the project shall include all requirements of the City Climate Action Plan, including policies A.1.4 (Bicycle Parking Requirements), A.1.5 (Streetscape Master Plan), A.1.8 (General Plan Community Design and Sustainability Element), A.1.9 (Work with LAVTA to Improve Transit), A.2.1 (Green Building Ordinance), A.2.5 (LED Streetlight Specifications), A.3.1 (Construction and Demolition Debris Ordinance), A.3.6 (Commercial Recycling). In addition, the project proponent is encouraged to participate in subsidy programs such as Climate Action Plan polices A.2.4 (Reduced Solar Installation Permit Fee) and A.3.5 (Commercial Food Waste Collection Program), and non-subsidy programs such as policies A.3.7 (Multi- Family Recycling), A.3.8 (Curbside Recycling), and A.3.9 (Curbside Organics Collection). Implementation of these mitigation measure would reduce GHG emissions, but not below the significance thresholds. The project, as a whole, shall adopt a water use reduction goal of at least 20 percent. A water use reduction plan shall be developed by the project applicant that may include measures such as the installation of low-flow water fixtures in showers and sinks, low-flush toilets, and the use of water efficient landscaping. The project applicant shall implement a solid waste recycling program through recycling and composting strategies, which results in a project-wide solid waste diversion rate of at least 20 percent. Finally, the project shall exceed 2008 Title 24 Building Standards (which CalEEMod is based on) by at least 20 percent in terms of energy-efficiency. The project shall implement the supplemental list of greenhouse gas reduction measures included as Attachment 6 to the Final SEIR. 19. Page 207: The first paragraph on this page shall be modified as follows: Final Supplemental EIR: The Green Mixed Use Project Page 10 City of Dublin August 2014 Alternative 3- Campus Office Development. Under this alternative the site would be developed consistent with the existing Campus Office General Commercial General Plan and Eastern Dublin Specific Plan land use designation. This Alternative considers construction of up 218,000 square feet of administrative, business and professional offices and a Floor Area Ratio of 0.1835, consistent with the concept of a low-rise office campus nearby properties in the Eastern Dublin Planning Area. Development of this alternative would also include on-site surface parking lots, landscaping, signs and similar improvements normally and customarily included in an office park development. 20. Page 213: Add Paul McCreary, Parks and Community Facilities Director to the list of persons consulted under heading “City of Dublin Staff”. Final Supplemental EIR: The Green Mixed Use Project Page 11 City of Dublin August 2014 Summary of DSEIR Comment Letters Comment letters were received by the City of Dublin during the public comment period on the DSEIR from the following agencies, organizations and other interested parties. Commenter Date No. State Agencies 1.1 Department of Transportation 6/23/14 Local Agencies 2.1 Alameda County Public Works Agency 6/17/14 2.2 Alameda County Transportation Commission 6/18/14 2.3 Alameda County Community Development Agency 6/23/14 2.4 Dublin San Ramon Services District 6/23/14 Other Comments 3.1 Adams Broadwell, Joseph & Cardozo 6/23/14 Final Supplemental EIR: The Green Mixed Use Project Page 12 City of Dublin August 2014 Responses to DSEIR Comment Letters Letter 1.1: California Department of Transportation Comment 1.1.1: The commenter notes that the anticipated number of project trips (589 vehicles in the a.m. peak and 650 in the pm peak) would result in impacts to the I-580/Hacienda Drive interchange. The DSEIR should include a traffic analysis since more than 100 vehicles per hour would result. The traffic analysis should also include turning movements per study intersection under Existing, Project Only, 2035 and 2035 Cumulative + Project Conditions. Response: Please see Tables 4.2-6, 4.2-7, 4.2-8, 4.2-14, 4.2-15, and 4.2-16 of the DSEIR for the requested traffic analysis associated with this Caltrans facility. Additionally, TR -11, TR -14, and TR 17 provides information on Arterial Level of Service analysis along Hacienda Drive corridor in the vicinity of the I-580 interchange. . Comment 1.1.2: The commenter requests the traffic impact fees to be used for project mitigation. Development fees should require traffic impact fees based on projected traffic volumes and/or cost estimated for public transportation fees necessitated by development. Response: As required by the Eastern Dublin Specific Plan and other applicable City fee resolutions, the project developer will be required to pay the Eastern Dublin Traffic Impact Fee in place at the time building permits are issued. The Eastern Dublin Traffic Impact Fee is designed to fund a wide variety of roadway, pedestrian, bicycle and public transportation improvements throughout the Eastern Dublin Planning Area. Additionally, the project developer will pay the Tri-Valley Transportation Development Fees (TVTD) and Freeway Interchange Fee, both of which will help fund regional transportation improvements. Comment 1.1.3: The commenter requests that safety mitigation measures should be addressed for the I-580 and Hacienda Drive interchange and the I-580 mainline. Coordination with Caltrans is requested regarding roadway recovery zones, outer separation, fixed object and other items. Response: The City of Dublin has always coordinated with Caltrans regarding traffic safety and will continue to do so in the future. In regard to the Green project, the development is proposed to occur wholly on private lands and no encroachment into Caltrans right-of-way is required. The Project will not have any impacts on the safety of the I-580 and Hacienda Drive interchange and the I-580 main line, so no safety mitigation measures are required for the Project. Final Supplemental EIR: The Green Mixed Use Project Page 13 City of Dublin August 2014 Letter 2.1: Alameda County Public Works Agency Comment 2.1: The commenter has reviewed the Notice of Preparation and has no comment on the project. Response: Comment noted. No further response is required. Final Supplemental EIR: The Green Mixed Use Project Page 14 City of Dublin August 2014 Letter 2.2: Alameda County Transportation Commission Comment 2.2.1: On page 67 of the DSEIR, the document notes that a 5 percent trip reduction has been assumed for walk to BART trips. This assumption may be low given proximity to heavy rail and the proposed project density and land use mix. No trip reductions have been taken for external trips by walking or bicycling even though the project would be located in close proximity to shopping, dining and similar uses. Consideration should be given to using a trip generation methodology to more accurately reflect transit-oriented developments or using a trip reduction that is based on observed data from similar projects Response: As for various other projects in this area, ITE trip generation manual, and User’s Guide and Handbook were used for this project to generate trips for different land uses. As per the ITE guidelines, vehicular trips were adjusted for Internal Trips (Appendix 6 of the DSEIR), and for the Pass By trips (Table 4.2-4). Additionally a total of 5% trip reduction was applied for bicycle, pedestrian and transit trips in the area including commercial developments to the north (Persimmon Place). The DSEIR provides a brief discussion on the trip reduction approach on Page 67. Staff feels that the trip adjustments are consistent with transportation mode share in the project vicinity. Comment 2.2.2: Impact TR-1 and supplemental mitigation measure TR-1 analyzes impacts to Dublin Boulevard and Arnold Road intersection. The DSEIR should provide an assessment of potential secondary impacts to other road users from the proposed supplemental mitigation measure as is done for other impacts in the DSEIR. Response: City’s thresholds of significance evaluate primary impacts to signalized intersections which includes an evaluation of congestion and delays to vehicles. Similar to many other traffic analyses that have been conducted in the City, the Synchro traffic model was utilized for this project for the signalized intersection analyses. This model inherently addresses pedestrian and bicycle access issues. For example, the model allocates green time for all modes of transportation on the basis of pedestrian crossing times at a crosswalk, and therefore the potential for secondary impacts to other road users have already been accounted for in the analysis and there are no impacts identified. Comment 2.2.3: The commenter requests that the City consider other elements as part of a proposed TDM such as minimum requirements for quality of bicycle parking, level of parking provision, parking restrictions and parking pricing strategies. Response: On-site parking provisions are governed by the City’s Zoning Ordinance and, at present, the Ordinance does not include policies on parking pricing or parking restrictions. Also, these types of measures are not feasible for the proposed type of development in Dublin. It is Staff’s opinion that due to the close proximity of the project site to the BART station, and the site should include TDM measures to help meet the future needs of resident and businesses. As per the mitigation measure SM-TR-2, the City would require bicycle parking at a rate of 20% or an amount approved by the City, of the required vehicular parking spaces. As part of the Site Development Review application for the project, Staff has ensured that long-term bicycle parking will be accommodated in bike lockers in addition to the short-term parking in bike racks. In Final Supplemental EIR: The Green Mixed Use Project Page 15 City of Dublin August 2014 addition, Conditions of Approval are being applied to the project that will require the development of a TDM plan that contains those measures identified in Alternative Mitigation Measure SM-TR-2 as well as additional measures that will be aimed at reducing the need for parking and single-occupant vehicle use in the residential units at the project site. At the time of review of the full TDM plan proposed by the Applicant/Developer, the City’s Traffic Engineer will assess the additional measures included in the plan to supplement those noted in Alternative Mitigation Measure SM-TR- 2. Comment 2.2.4: Impact TR-4 and supplemental mitigation measure TR-4 analyzes impacts to Dublin Boulevard and Hacienda Drive intersection. The DSEIR should provide an assessment of potential secondary impacts to other road users from the proposed supplemental mitigation measure as is done for other impacts in the DSEIR. Response: The commenter is directed to the response to Comment 2.2.2, above. Comment 2.2.5: Pages 82 and 83 of the DSEIR discuss a grade separated crossing for pedestrians and bicyclists near the Dublin Boulevard and Scarlett Drive intersection. The DSEIR should clarify if project developers will be required to make mitigation payments towards construction of this facility prior to the occupancy of the last building on the project site or prior to the issuance of the first building permit. Response: Since the grade-separated crossing has not yet been environmentally cleared, and to ensure that the impacts are adequately mitigated, the project developer is required to provide a fair-share contribution for the alternative mitigation of removing the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. The timing for payment of fair share fee is prior to the issuance of the first building permit. Comment 2.2.6: Regarding information on pages 106 and 107 of the DSEIR, commenter requests that the City encourages design of project streets to promote walking and bicycling and provide for additional treatment of bicycle facilities to facilitate mobility and safety at high volume intersections near the site. Response: Please see Supplemental Impacts review on pages 106 to 108 of the DSEIR, including mitigation measures SM-TR-18, 19, and 20, which require compliance with the City’s Bikeways Master Plan, Complete Streets policies, and other plans that promote pedestrian and bicycle travel. Through Staff’s review of the Site Development Review plans and Vesting Tentative Tract Map for the project, Staff has ensured that bicycle and pedestrian access is enhanced both inside the project and on the public streets in the project vicinity. The pedestrian and bicycle circulation system that has been reviewed will be further refined at the time Staff reviews the off-site improvement plans, and special attention will be paid to maintain safety and access for alternate modes of transportation at all intersections. Final Supplemental EIR: The Green Mixed Use Project Page 16 City of Dublin August 2014 Letter 2.3: Alameda County Community Development Agency Comment 2.3.1: The commenter notes concerns about the potential conflicts between the proposed mixed-use project and future office development on property to the west. Pursuant to the Dublin Transit Center Specific Plan that governs development to the west, office buildings of up to 10 stories are allowed with 15-foot wide setbacks from Arnold Road on the eastern boundary of the site. Future development on the Transit Center site, which could extend to 150 feet in height, could cast shadows on the westerly portion of The Green site. Response: The potential for shade and shadow impacts on The Green site cannot be analyzed in a meaningful way at this point in time because there is no proposed or known development plans for Site D-2 on the Dublin Transit Center immediately to the west of The Green project. Therefore, this impact cannot be accurately analyzed. CEQA only requires the analysis of the Project’s impact on the environment. The potential for shade and shadow due to development of the Site D-2 will be reviewed by the City of Dublin at the time specific development proposals are filed for Site D-2. Comment 2.3.2: There could be other compatibility issues between development on the Dublin Transit site to the west and the project site, including construction noise, night lighting and privacy concerns. Response: The potential for construction noise impacts on The Green site will be less- than-significant since future development projects on the Transit Center site will be required to prepare and implement a Construction Noise Management Plan pursuant to Mitigation Measure 4.9-1 of the certified Dublin Transit Center EIR. This Construction Noise Management Plan is required to contain, at minimum, limitation on the hours of construction, use of mufflers on construction equipment, limitations on on-site construction traffic speeds and similar items. Therefore, there would be no impact with respect to construction noise. The potential for spillover of light from the Transit Center site onto the Green site will be reviewed by the City of Dublin Community Development Department Staff as part of future Site Development Review applications for specific projects on Site D-2, once submitted to the City. The comment regarding future privacy concerns is not a CEQA issue and is not required to be addressed in the DSEIR. Comment 2.3.3: The commenter notes that the potential for future land use compatibility will be greatest if lower residential development is allowed on the site. Typically, “Medium Density” development in Dublin has resulted in single-family detached development dwellings which may not be appropriate on this site. Response: Please see Response to Comments 2.3.1 and 2.3.2 on issues regarding alleged impacts of future office development on Site D-2 of the Transit Center and The Green residential development The residential development on site will be a combination of stacked-flat condominiums and townhouses in buildings that are primarily Final Supplemental EIR: The Green Mixed Use Project Page 17 City of Dublin August 2014 three- and four-stories with occasional two-story elements. There are no single-family detached units proposed on the project site. Comment 2.3.4: The commenter notes that future office development within the Dublin Transit Center is a goal of the Surplus Property Authority and the City of Dublin. Residential development on The Green site may not be compatible with office uses planned to the west of the project site on the Transit Center site and may reduce the value of this property. The City is encouraged to consider additional supplemental mitigation measures: increasing the residential setback along Arnold Road to minimize future shade and shadow, construction noise and privacy, proper noticing of future residents of planner mid-rise offices on the Transit Center site and specifically prohibiting future single-family dwellings on the project site. Response: Please see Response to Comments 2.3.1, 2.3.2 and 2.3.3 on issues regarding alleged impacts of future office development on Site D-2 of the Transit Center on The Green. Based on the responses, no mitigation is required for The Green Project. Final Supplemental EIR: The Green Mixed Use Project Page 18 City of Dublin August 2014 Letter 2.4: Dublin San Ramon Services District (DSRSD) Comment 2.4.1: The commenter notes that DSRSD is the water and sewer service provider to the City of Dublin and that the project will require new water, recycled water, and wastewater facilities. The commenter also notes that the provision of services to the project site must be done in a way so as to not interrupt DSRSD’s ability to continue to provide service to properties in the immediate vicinity of the project site. Response: Comment noted. Comment 2.4.2: The commenter notes that DSRSD operates a facility adjacent to the project site and that future use of the project site should not interfere with DSRSD’s ability to continue to access and use the facility. Response: Comment noted. The project plans have been designed so that access to DSRSD’s Turnout 4 will continue to be maintained. Comment 2.4.3: The commenter notes that as a condition of providing potable water to the project site, DSRSD will require the project developer to develop and operate a recycled water distribution system for landscape irrigation on the project site. Response. Comment noted. The project plans include utilizing recycled water for irrigation. Comment 2.4.4: DSRSD will require the Developer to enter into a planning agreement with DSRSD to cover wastewater collection and wastewater treatment, which will include a service analysis. Response: Comment noted. Comment 2.4.5: Disposal of wastewater in DSRSD’s service area is the responsibility of the Livermore-Amador Valley Water Management Agency. Response: Comment noted. Final Supplemental EIR: The Green Mixed Use Project Page 19 City of Dublin August 2014 Letter 3.1: Adams Broadwell Joseph and Cardozo Exhibits A-P to Letter 3.1 were reviewed for additional comments. Many of the Exhibits are studies or reference materials cited in the comment letter that do not contain specific comments on the project (See Exhibits B-P). It was determined that all relevant comments that appeared in the exhibits (in particular, Exhibit A) were also stated in the body of Letter 3.1 itself. Therefore the exhibits were not annotated for additional comments and responses. All responses to comments contained in Exhibits A-P are set forth in the responses to Comment Letter 3.1 below. Comment 3.1.1: The commenter states that the DSEIR fails to comply with the requirements of CEQA and may not be used as part of the project approval. The commenter also includes a Statement of Interests of the commenters. The Commenter generally states that the DSEIR fails as an informational document and will result in significant adverse impacts. The Comment contains a summary of the comments which are explained in more detail in the Letter. The DSEIR does not adequately identify, evaluate and mitigate these potentially significant impacts, including potential contamination of the site, reliance on out-of-date mitigation measures addressing groundwater salinity, impacts to biological resources, lacks findings regarding traffic impacts and does not include all feasible greenhouse gas impact mitigation. The document must therefore be withdrawn and revised to correct the above deficiencies. Response: The commenter’s assertions regarding deficiencies of the DSEIR are noted but are not correct. The City believes the DSEIR accurately and correctly identifies the environmental baseline for each topic, provides a thorough analysis of each potentially significant and provides feasible measures to mitigate most significant impacts except for those impacts identified as significant and unavoidable. The specific responses to the general allegations made in this Comment are contained in the following responses to comments in the remainder of these responses. Comment 3.1.2: The two main purposes of CEQA are to (1) inform decision makers and public about the significant environmental impacts of the Project; and (2) avoid or reduce significant environmental impacts where possible. The DSEIR fails to completely describe the project and project setting and fails to disclose all potentially significant impacts. Proposed mitigation measures are unenforceable, vague or undefined so the effectiveness cannot be evaluated. Response: The City believes that the commenter’s assertions are incorrect and The Green DSEIR is fully consistent with the purposes and requirements of CEQA and CEQA Guidelines. See below responses to comments for specific response to general issues raised in this comment. Comment 3.1.3: The DSEIR fails to disclose impacts or provide adequate mitigation for risks from contaminated soils, including contamination from contaminated soil vapor, the potential for herbicide contaminated soils and other discolored soils on the project site. No testing or mitigation is identified for this contamination. Failure to identify, disclose and mitigate potential contamination puts workers and residents at risk. Response: See Responses to Comments 3.1-4 through 3.1.8, below. Final Supplemental EIR: The Green Mixed Use Project Page 20 City of Dublin August 2014 Comment 3.1.4: The DSEIR fails to disclose or evaluate the potential for volatile organic compounds (VOCs) on the site. The Phase I Environmental Site Assessment recommends an analysis of potential contamination from this source, including a human health risk assessment. Response: The DSEIR notes that the project site has been remediated from contamination from previous site users for commercial and other non-residential users as approved by the Alameda County Department of Environmental Health (ACDEH). The ACDEH will permit the site to be utilized for residential use only after evaluation of the site as required by Supplemental Mitigation Measure HAZ-1. SM- HAZ-1 notes that, if required by the ACDEH, additional testing of the site for acceptability of the site for residential use may well be required and, if required by the ACDEH, remediation of potentially contaminated materials may be required, including any VOCs found on the site. As required by Supplemental Mitigation Measure HAZ-1, no grading or construction can occur until authorized by the ACDEH. Therefore, this impact will be fully mitigated in accordance with the requirements of the ACDEH and, after ACDEH-approved remediation has occurred, no impacts will remain with respect to VOCs. Since the publication of the DSEIR, the Project Applicant/Developer and their technical consultants have been in contact with the ACDEH to determine a suitable Workplan for Further Investigation for the site. On June 11, 2014, the ACDEH provided the Project Applicant/Developer with a letter noting that the proposed workplan has been conditionally approved by the ACDEH (Attachments 4 and 5) and that investigation on the site as outlined in the approved scope of work could commence. Based on the foregoing, no revisions to the DSEIR are required. Comment 3.1.5: The site could be contaminated by herbicides that were commonly used on former military sites. The DSEIR fails to require any risks from this contaminant and does not require any additional sampling or testing of the soil. No mitigation measures are included in the DSEIR and a revised DSEIR should be prepared to disclose the results on testing for herbicides. Response: As noted above, the project site cannot be used for residential development until reviewed and cleared by the ACDEH. A Workplan for Further Investigation has been approved for the site by the ACDEH, which requires soil and groundwater sampling in the former Fuel Depot area, shallow soil sampling along the former Railroad Spur, sampling of soil stockpiles, and sampling for metals at five locations on the project site. If it is determined by the ACDEH to be necessary beyond the sampling noted above, the ACDEH may require additional sampling and testing for potential presence of herbicides at concentrations above ACDEH regulatory threshold levels. If found, significant concentrations of herbicide on the site will be required to be remediated prior to site grading or excavation. Therefore, this impact will be fully mitigated and no impacts will remain with respect to herbicides, and revisions to the DSEIR are not warranted. Comment 3.1.6: The Phase I Environmental Site Assessment identifies a small patch of discolored soil on the site that may be contaminated. The DSEIR fails to disclose this and does not require any additional testing or mitigation for this potential contamination. The Final Supplemental EIR: The Green Mixed Use Project Page 21 City of Dublin August 2014 DSEIR’s failure to disclose this potential contamination violates CEQA requirements to describe the project’s environmental setting, evaluate all potential impacts and provide mitigation measures to the extent feasible. Response: As noted in the responses to comments 3.1.4 and 3.1.5 above, the ACDEH has approved a Workplan for Further Investigation on the project site. The results of the further investigation will identify those measures to be taken that are necessary to ensure that the site meets ACDEH standards for residential occupancy. If required by the ACDEH, the discolored soil will be required to be remediated if found to be contaminated above ACDEH standards. Any soil remediation plan will include measures to address any re-use and/or disposal of contaminated soil. Therefore, the DSEIR provides adequate mitigation for any potential soil contamination on-site and there is no need for revisions to the DSEIR. Comment 3.1.7: The DSEIR fails to disclose any potential impacts from a small stockpile of soil on the site, including potential re-use on the site and the possibility of off-site disposal. The failure of the DSEIR to disclose, evaluate and mitigate potential impacts from this small soil stockpile violates CEQA. Response: Please see the response to Comment 3.1.6 above. The DSEIR does provide adequate mitigation with respect to this topic. Comment 3.1.8: The DSEIR must be revised to adequately disclose and investigate potentially contaminated materials and provide appropriate mitigation measures to protect the health and safety of construction workers. Response: The Green DSEIR adequately describes hazardous conditions on the site and provides adequate mitigation to ensure the protection of workers and adjacent residents. Any future remediation plan/Corrective Action Plan that is approved by ACDEH will include measures to protect the health and safety of construction workers by requiring the preparation and implementation of a Health and Safety Plan that addresses the safe handling and transportation of contaminated soil (See Supplemental Mitigation Measure HAZ-1). Revisions to the DSEIR are not warranted. Comment 3.1.9: The DSEIR is legally inadequate since it fails to address potential impacts related to groundwater salinity raised by a Trustee Agency, Zone 7. Although identified as an impact in the 1993 Eastern Dublin EIR and mitigated to a less-than-significant level by Mitigation Measure 3.5/20.0, this mitigation measure no longer adequately reduces salinity impacts to a less-than-significant level. Recent studies by the Zone 7 water agency indicate that with the increased use of recycled water, additional studies need to be done to mitigate salinity of groundwater. The commenter notes that the DSEIR failure to disclose and evaluate this impact violates CEQA’s disclosure requirements and the document must be revised to provide a meaningful evaluation of these impacts. Response: The Eastern Dublin EIR analyzed the impact of the use of recycled water on the main groundwater basin, including salinity. The Eastern Dublin EIR identified groundwater salinity as a potential impact and included a mitigation measure requiring coordination of recycled water projects with Zone 7's salt mitigation program to mitigate this impact to less than significance. Mitigation Measure Final Supplemental EIR: The Green Mixed Use Project Page 22 City of Dublin August 2014 3.5/20.0 requires construction of a recycled water distribution system to be in accordance with all applicable regulations of the State Department of Health Services, the San Francisco Bay Regional Water Quality Control Board and Zone 7. The commenter offers no validation to the claim and is incorrect when stating that the “Zone 7 District itself, has stated that based on new information, its current mitigation is no longer sufficient.” The actual letter from Zone 7 staff dated August 9, 2013, in response to the Notice of Preparation, merely requests that “potential impacts to groundwater quality need be considered in the supplemental CEQA review.” The same letter notes Zone 7’s appreciation of “Dublin’s support of Zone 7’s efforts in managing and mitigating the salinity of the Livermore Groundwater Basin through our Salt Management Plan and groundwater demineralization operations.” The Salt Management Plan can be found on Zone 7’s website at: http://www.zone7water.com/publications-reports/reports-planning-documents/158- salt-management-plan-2004 City of Dublin Staff’s recent discussions with Zone 7 Staff have revealed that the project site has been included in Zone 7 calculations for use of recycled water (Source: Tom Rooze, Zone 7, 2014). As noted in the Salt Management Plan, one of the main goals of the Plan is to “to achieve sustainable groundwater quality as well as quantity and to allow for increased use of recycled water . . .” The use of recycled water for irrigation at The Green Project is consistent with this goal and subject to Plan requirements. Further, the proposed Green project will be required to pay water connection fees to Zone 7 to assist in funding the District’s Salt Management Plan (source: J. Chahal, Zone 7, 2014). Zone 7 also requests that the City include a statement in the Final SEIR requiring continued support of Zone 7 in implementing Zone 7’s Salt Management Plan (See Clarifications and Modifications section of the Final SEIR). Comment 3.1.10: The DSEIR is inadequate because it fails to establish the environmental setting of the project resulting in inadequate disclosure and assessment of the project’s potentially significant biological impacts. Specifically, this includes the proximity of the project’s Congdon Tarplant population and other important populations of this plant, an identification of other special-status plant species on the project site, impacts to burrowing owl populations, the presence of vernal pool fairy shrimp on the site and the presence of protected bat species on the site. The DSEIR fails to adequately describe the existing environmental setting which is needed to meaningfully analyze project impacts. The DSEIR analysis is based on a single limited non-protocol level reconnaissance survey that was not adequate to establish biological resources on the site. As a result, the City lacks substantial evidence to support a determination that proposed mitigation measures will be sufficient to reduce impacts to a less-than-significant level. Response: For responses to particular comments summarized in this comment, see later responses to comments. On the issue of inadequate description of or information on existing setting, the commenter is incorrect. During preparation of the DSEIR, the project site was thoroughly traversed by both a wildlife biologist and a botanist/wetland specialist on the WRA staff on August 1, 2013. The level of detail used in these surveys was equivalent to a rare plant survey and a burrowing owl survey. The surveys occurred at an ideal time for observing late-blooming plant Final Supplemental EIR: The Green Mixed Use Project Page 23 City of Dublin August 2014 species such as Congdon’s tarplant (Centromadia parryi ssp. congdonii). The surveys also occurred during the portion of the burrowing owl (Athene cunicularia) nesting season when owls and owl sign are most detectable (later spring/ summer when chicks are viewable outside the burrow) and evidence of use most abundant. WRA biologists are experts in assessing properties for the habitat conditions likely to support special status species, so the onsite observations provide substantial evidence for the determination of whether additional special status species are likely to occur there. Protocol surveys for special status species were not recommended for the Project Site because either suitable habitat was not present, or because (in the case of burrowing owl) there was no evidence of site use. Under these circumstances, the preconstruction survey for burrowing owl required in the DSEIR is a sufficient measure to verify that the burrowing owls are not present. However, the mitigation provides measures to ensure that if any burrowing owl is found on-site, impacts to the burrowing owl will be reduced to less than significant. Similarly, while the site appears to be unsuitable for most spring-blooming rare plant species, a spring survey for rare plants was required as mitigation in the DSEIR to verify absence or require compensatory mitigation for any protected plants that are found. As the commenter notes, “a City has discretion to determine what protocol level surveys may be necessary to provide a complete and accurate description of the project setting.” In the case of The Green, the City of Dublin reasonably relied on the expert biological analysis completed for the DSEIR and included supplemental mitigation measures based on the existing environmental setting for the project. Comment 3.1.11: The DSEIR lacks sufficient evidence to support the conclusion that vernal pool fairy shrimp are unlikely to occur on the site. The site has four seasonal wetlands that have the potential to support this species. The applicant has not conducted protocol-level surveys needed to determine the presence of vernal pool fair shrimp. The commenter claims that vernal pool fairy shrimp may also exist in vernal-pool like habitats and the DSEIR provides no evidence that vernal pool habitat is necessary for this species to occur on the site. The commenter also notes that disking and grading of the site do not preclude the potential presence of vernal pool fairy shrimp. Although the DSEIR notes that seasonal wetlands on the site appear to be the result of past alterations of the landscape, these wetlands have existed long enough to be dominated by plants often found in seasonal wetlands. This indicates that the wetlands have not been disked for several years, which is long enough for vernal pool fairy shrimp to colonize or recolonize the site following disturbance. Therefore, since potential habitat for vernal pool fairy shrimp exists on the site, protocol-level surveys should have been conducted to confirm or refute the presence of this species. Response: As described in the above response, WRA biologists are experts at assessing properties for the habitat conditions likely to support special status species. According to the U.S. Fish and Wildlife Service (USFWS) Recovery Plan, vernal pool complexes [including wetlands] that cannot support a viable population are not considered suitable for vernal pool fairy shrimp (VPFS; Branchinecta lynchi)2. The seasonal wetlands onsite are not natural features, but were recently created in 2008 during development activities3. Prior to 2008, the project site was maintained in 2 USFWS. 2005. Recovery Plan for Vernal Pool Ecosystems of California and Southern Oregon. 3 WRA. 2013. Delineation of Waters of the U.S., “The Green” Mixed Use Project, Dublin, Alameda County, California. 59pp. Final Supplemental EIR: The Green Mixed Use Project Page 24 City of Dublin August 2014 a developed state for many decades and did not contain wetlands on or adjacent to the site4. Soil disturbance such as grading and disking has occurred numerous times, going back many decades. There are no records of VPFS occurring on the project site or within 5 miles of the site5; and there are no areas of suitable VPFS habitat within more than 5 miles67. Therefore, contrary to assertions made by the commenter, land management actions at the site in combination with an absence of available suitable habitat on and contiguous with the site preclude these features from supporting a viable population over time and thus are not suitable for VPFS. The commenter further suggests that VPFS could have colonized the seasonal wetlands on the site in the period of time since their creation in 2008. However, according to the USFWS, flooding and wildlife movement within vernal pool complexes are the only documented dispersal mechanisms for VPFS8. Based on this, it is highly unlikely that pools may have been colonized given the absence of any suitable habitat in the vicinity. Given these facts and observations, there is no substantial evidence or reasonable basis to believe that VPFS could be present on the project site, and thus protocol surveys are unwarranted. Comment 3.1.12: The commenter notes that the DSEIR fails to establish the scope of the burrowing owl population of on the project site and fails to disclose the status and demography of the local and regional burrowing owl population that may be affected by loss of potential breeding and foraging habitat. Although the DSEIR acknowledges that the site provides potential burrowing habitat, it fails to conduct the surveys necessary to establish the scope of burrowing owl habitat use of the site. Instead, efforts were limited to a single reconnaissance-level survey during an unreliable time of year for establishing owl use of the site. In addition, the document fails to disclose the amount of burrowing owl habitat on the site. California Department of Fish & Wildlife have concluded that four independent surveys are necessary to determine presence of owls and data from the four surveys are necessary for avoiding, minimizing and properly mitigating the impacts of the project. The DSEIRs also underreports the extent of burrowing owl habitat on the site and the amount of habitat that would be eliminated by the project. The commenter notes that the amount of potential habitat on the site is 27.79 acres, more than double the amount reported in the DSEIR. The DSEIR also fails to disclose the proximity of nearby Camp parks burrowing habitat and the continuing vitality of burrowing owl in the region. Burrowing owl populations have been extirpated or nearly extirpated in much of the Bay Area and are now generally found in the Altamont Hills and the Camp Parks area. The DSEIR must be revised to establish and disclose the proximity and importance of the Camp Parks burrowing owl population in order that the project’s potential impacts to this core population may be evaluated and appropriate mitigation identified. 4 City of Dublin. 2003. IKEA Draft Supplemental EIR. State Clearinghouse #2003092076. 5 California Department of Fish and Wildlife (CDFW). 2014. California Natural Diversity Database. Wildlife and Habitat Data Analysis Branch, Sacramento, CA. Accessed July 2013-July 2014. 6 California Wetlands Monitoring Workgroup (CWMW). 2014. EcoAtlas. http://www.ecoatlas.org. Accessed July 2013-July 2014. 7 Google Earth. 2014. Aerial imagery, including historic imagery 1993-2014. Accessed July 2013-July 2014. 8 USFWS. 2007. Vernal Pool Fairy Shrimp (Branchinecta lynchi) 5-Year Review Summary and Evaluation. USFWS Sacramento. September. Final Supplemental EIR: The Green Mixed Use Project Page 25 City of Dublin August 2014 Response: WRA biologists concluded that burrowing owl does not occur on the site and that the site provides little value as potential breeding or foraging habitat for nearby owl populations. This conclusion is based on evidence collected during the site assessment which corresponded with a period in which signs from recent nesting activities would have been observable WRA biologists have considerable experience and are experts in conducting burrowing owl surveys, and the 2013 survey in support of the BRA had a level of detail equivalent to a burrowing owl survey. WRA biologists have expertise and experience in recognizing indicators of recent use of a site by this species, such as pellets, whitewash, feathers, and prey remains typically found near burrows. No owls or owl signs (indicators) were observed during surveys used as the basis of the DSEIR, whereas signs have been observed by WRA biologists at other occupied sites around the Bay Area on a year-round basis. There are no records of burrowing owl ever using the project site5. A subsequent survey for burrowing owl was also performed by WRA at the peak of the 2014 breeding season9, which similarly found no owls or owl sign. Similarly, no owls or owl sign were observed during WRA’s November 2013 wetland delineation, or during a follow-up visit in March 2014. WRA has recommended preconstruction surveys as a precautionary measure to confirm the absence of the species on the site and require mitigation in accordance with CDFW protocols and standards if burrowing owls are found. These measures are included in SM-BIO-3. The mitigation measure (SM-BIO-3) requires that the pre- construction surveys conform with the CDFW protocol for pre-construction surveys. A series of four surveys was not recommended as a component of the SEIR because of the lack of indications that owls use the site. The initial site survey, a subsequent survey, and subsequent site visits support this. The surveys, actions, and mitigation measure in the SEIR are adequate to address burrowing owl impacts under CEQA. The commenter cites the California Department of Fish and Wildlife’s (CDFW) 2012 Staff Report on Burrowing Owl Mitigation10 in support of his recommendation to conduct multiple surveys for burrowing owl within the project site. It is important to note that the CDWF staff report provides recommendations with regard to burrowing owls, not requirements. Based on the considerations described above, it was determined that multiple surveys within the project site were unwarranted as part of the SEIR. The commenter describes the project site as being of potential value for the population of burrowing owls located in the Camp Parks area to the northeast. It is important to note that these owls have been consistently observed to utilize the same general areas, while there are no known records of owls utilizing the project site. Occurrence records for the Camp Parks population show that the owls typically utilize two general areas, including a number of contiguous vacant lots approximately ½ mile to 1 mile northeast of the project site, and undeveloped land 1-2 miles north 9 Valcarcel, Tricia. 2014. Re: Breeding Bird Survey at The Green, Dublin, California (survey letter report). April 22, 2014. 3pp. 10 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resources Agency, Department of Fish and Game. 36pp. Final Supplemental EIR: The Green Mixed Use Project Page 26 City of Dublin August 2014 of the site near the County line.11 Based on these considerations, there is no reason to believe that the project site is of substantial importance to the burrowing owl population in the Camp Parks area. The commenter cites the 2010 Wilkerson and Siegel study as a basis for concluding owls have been extirpated or nearly extirpated in six San Francisco Bay Area counties. However, the methodology in this study included only passive observational surveys performed by volunteers. The commenter notes that it is difficult to identify a breeding pair through observation alone due to cryptic coloration, use of burrows, and tendency to flush. Thus a more robust survey would have included transect surveys to look for evidence of use (or “sign”) such as whitewash, prey remains, pellets, or feathers. Furthermore, unpublished data from other consultants has revealed burrowing owls in some Bay Area counties can occur in taller grassland habitats resulting in fewer owls being identifiable through traditional passive surveys. Close inspection of a site for evidence of use is likely more reliable than a few passive surveys and thus, WRA’s assessment provides substantial evidence for detecting presence or absence of a breeding pair at the site. Comment 3.1.13: The DSEIR fails to provide sufficient project setting information to describe special-status plants may occur on the site and to incorporate the results of protocol-level surveys for these plants. The commenter’s biologist identified the following special-status plant species that should be surveyed: heartscale, btittlescale, lesser saltscale, big-scale balsamroot, big tarweed, Mt. Diablo fairy lantern, palmate salty bird’s beak, San Joaquin spearscale, Diablo helianthella, Brewer’s western flax, shining navarretia, prostrate vernal pool navarettia, saline clover. Mitigation measure SM-BIO-2 refers to the wrong table in the SEIR. Response: The level of detail used in the surveys in support of the DSEIR, including a thorough traversal of the project site by an experienced and expert botanist, was equivalent to a rare plant survey for late-blooming species. WRA biologists are experts and very experienced in surveying for special-status plants and are experienced in recognizing the habitat conditions likely to support these species. In many cases, WRA biologists have firsthand experience with the particular species of special-status plants known to occur in the San Francisco Bay Area. Even during a late-season survey such as the one performed in support of the DSEIR, numerous indications inform biologists about the habitat conditions and plant species likely to be present earlier in the growing season. For example, in many cases the senesced (older) remains of early-season vegetation are still present and recognizable. The associations of these species along with topography and other factors allow for an understanding of the community types present and whether adequate conditions exist to support rare plants. Based on these observations during the survey, all early- season (spring-blooming) special status plant species known to occur in the vicinity were determined to be unlikely to occur or to have no potential for occurrence. However, as a precautionary measure, an early-season survey for special-status plants and potential additional mitigation are requirements of the DSEIR (SM-BIO-2). 11 California Department of Fish and Wildlife (CDFW). 2014. California Natural Diversity Database. Wildlife and Habitat Data Analysis Branch, Sacramento, CA. Accessed July 2013 – July 2014. Final Supplemental EIR: The Green Mixed Use Project Page 27 City of Dublin August 2014 With regard to late-blooming special-status plant species known to occur in the vicinity of the Project Site, the fact that the species was not observed along with a lack of suitable habitat conditions is a sufficient basis to conclude that the species has no potential to occur onsite, contrary to the commenter’s assertions. In particular, the survey was conducted at an ideal time for the detection of many of the species mentioned by the commenter, including heartscale (Atriplex cordulata var. cordulata), brittlescale (Atriplex depressa), lesser saltscale (Atriplex miniscula), big tarweed (Blepharizonia plumosa), palmate salty bird’s beak (Chloropyron palmatum), and San Joaquin spearscale (Extriplex joaquinana). In addition, the survey occurred one day outside of the established blooming period for Brewer’s western flax (Hesperolinon breweri), shining navarretia (Navarretia nigelliformis ssp. radians), and prostrate vernal pool navarretia (Navarretia prostrata), although these species would likely still have been observable during the survey. For the remaining four species specifically mentioned by the commenter and any other spring-blooming special- status plant species, the required spring survey under Mitigation Measure SM-BIO-2 would be sufficient for detection of these species if they are indeed present on the project site and provides measures to address any impacts on protected plants if found on site. Regarding the comment on the table, the commenter is correct. The correct reference should be to Appendix Ai of the Supplemental Biological Analysis (Appendix 8.7 of the DSEIR). The Clarifications and Modifications section of the FSEIR reflects this change. In summary, the DSEIR adequately addresses the issue of special-status plants for the following reasons: Surveys in support of the DSEIR detected Congdon’s tarplant and adequately mapped the population of this species within the Project Site; surveys in support of the DSEIR confirmed that other late-blooming special-status species were absent from the site; surveys in support of the DSEIR found that habitat within the site was of low quality for spring-blooming special-status plant species, or suitable habitat was absent altogether, such that these species are unlikely to occur or have no potential for occurrence; a rare plant survey for spring- blooming species will be conducted as a precautionary measure under Mitigation Measure SM-BIO-2; performing the spring survey after completion of the DSEIR is adequate due to the low potential for detection of additional special-status plant species. Comment 3.1.14: The DSEIR discloses that a robust population of Congdon’s tarplant occurs on the project site. This species has been identified as a rare and imperiled species. Additional information is needed in the DSEIR regarding the ecological context of Congdon’s tarplant population on the site. Without information on the scope and location of this population, the public and decision makers are precluded from being able to evaluate the relative severity of the population of this species and from evaluating the sufficiency of proposed mitigation. Response: Congdon’s tarplant is distributed from the San Francisco Bay Area to San Luis Obispo County, California. Clusters of occurrence records signifying regional populations are centered in the Salinas area, around the margins of South San Final Supplemental EIR: The Green Mixed Use Project Page 28 City of Dublin August 2014 Francisco Bay, and in an area from the foothills of Mt. Diablo to the Livermore Valley12. The latter area includes the project site. Based on the observations of WRA botanists with experience in the San Francisco Bay Area and expertise on this plant, Congdon’s tarplant has a fairly wide distribution with robust populations in many areas, and in areas where the species has been documented, numerous undocumented occurrences are often found in the surrounding area. This suggests that the species may merit a rarity designation lower than what has been assigned by the California Native Plant Society (CNPS)13. Documented occurrences in the Livermore Valley area and undocumented occurrences such as the population within the project site also suggest that this species is widely distributed in the vicinity. The distribution of Congdon’s tarplant in the western portion of the Project Site closely matches the area that received the most substantial soil disturbance during development activities in 20083, demonstrating that this species has the ability to respond to disturbance and even benefit from it. Congdon’s tarplant was not reported within the Project Site during assessments in 20034, suggesting that this species recently colonized the site or had a very limited presence on the site prior to earthwork activities in 2008. Mitigation is required for impacts to Congdon’s tarplant within the project site (see Supplemental Mitigation Measure SM-BIO-2) and the response of this species to disturbance suggests that this species could be successfully introduced to an appropriate mitigation site in the vicinity. Due to the project site’s location close to an urban center, and due to the site’s past and current uses as a development site, the nearly-isolated population of Congdon’s tarplant within the project site is not ideal for preservation, and mitigation through establishment of this species at a more appropriate site would be beneficial for long-term preservation of the species. The exact details of mitigation will be determined in coordination with CDFW. The mitigation includes specific standards, such as a minimum 1:1 ratio, allowing for complete replacement of the population impacted within the project site which will result in a less than significant impact. In summary, the DSEIR adequately addresses Congdon’s tarplant for the following reasons: Congdon’s tarplant has numerous occurrences in the San Francisco Bay Area and in the Livermore Valley area; the location of Congdon’s tarplant on-site was specifically determined through surveys; impacts to the population of Congdon’s tarplant within the site will be mitigated through complete replacement at a site appropriate for long-term protection; the population of Congdon’s tarplant within the project site likely appeared or dramatically expanded recently in response to human activities, and the on-site occurrence does not necessarily represent a natural or historic population. Comment 3.1.15: The commenter notes that three special-status bat species (pallid bat, Townsend’s big-ear bat and Yuma myotis) have a moderate potential of roosting on an existing building on the site. Surveys were not conducted to determine if any bat species 12 Calflora [web application]. 2014. Berkeley, California: The Calflora Database. http://www.calflora.org/ Accessed: July 2013-July 2014. 13 California Native Plant Society (CNPS). 2013. Inventory of Rare and Endangered Plants of California. California Native Plant Society, Sacramento, California. Online at: http://www.rareplants.cnps.org. Accessed: July 2013-July 2014. Final Supplemental EIR: The Green Mixed Use Project Page 29 City of Dublin August 2014 were using the building as a roost site. The City’s failure to establish baseline conditions precludes the public, resource agencies and the scientific community from being able to submit informed comments pertaining to project impacts and from having those comments vetted during the environmental review process. Response: WRA biologists assumed presence of bat species on the site. The SEIR contains a mitigation measure (SM-BIO-5) which requires that a pre-construction survey be performed prior to building removal and mitigation if bats are found. Removal of any roost site for these three species is considered a significant impact regardless of the type of roost and thus baseline surveys do not yield any more valuable information pertaining to the type of mitigation that would be employed as both the impact and the mitigation would be the same whether detected initially or in the future. For these reasons, the assumed presence and mitigation requirement complies with CEQA standards. Comment 3.1.16: The DSEIR fails to disclose the potential for the presence of vernal pool fairy shrimp within on-site seasonal wetlands. As a result, the DSEIR fails to evaluate potential impacts of the project on this species and fails to include mitigation measures. The DSEIR lacks substantial evidence to confirm or refute the presence of this species and must be revised to disclose and evaluate this potential impact. Response: As discussed in the Response to Comment 3.1.11, the site does not contain suitable habitat for Vernal Pool Fairy Shrimp and thus there would be no impacts to this species and no mitigation would be required. Comment 3.1.17: The DSEIR fails to disclose the potential for the presence of burrowing owl habitat on the site and fails to disclose the proximity of the site to critical Camp Parks burrowing owl populations. As a result, the DSEIR fails to evaluate potential impacts of the project on this species and fails to include mitigation measures. The DSEIR lacks substantial evidence to confirm or refute the presence of this species and must be revised to disclose and evaluate this potential impact. Response: As discussed in Response to Comment 3.1.12, WRA biologists concluded that burrowing owl does not currently occupy the site. While unlikely, should owls be documented at the site in the future, adequate compensatory mitigation for the loss of nesting and/or foraging habitat would be done in accordance with CDFW requirements as stated in the DSEIR (see Supplemental Mitigation Measure SM-BIO-3). Comment 3.1.18: The DSEIR fails to evaluate potential impacts to burrowing owls from proposed temporary or permanent closure of burrows. Proposed supplemental mitigation set forth in the DSEIR that requires an exclusion plan for burrows is a potentially significant impact under CDFW guidelines. Temporary or permanent closure may result in a significant loss of burrows and habitat for reproduction, increased stress on burrowing owls and reduced reproduction rates, increased depredation, increased energetic costs and risks associated with the need to find and compete for available burrows, the DSEIR must be revised to thoroughly analyze these impacts. Final Supplemental EIR: The Green Mixed Use Project Page 30 City of Dublin August 2014 The commenter notes research that indicates most translocation projects have resulted in fewer breeding pairs of burrowing owls at the translocated site and translocated projects have failed to produce self-sustaining populations. The proposed Supplemental Mitigation Measure is inadequate in that it does not identify what will happen if avoidance is not feasible during the breeding season. Also, the Supplemental Mitigation Measure does not require the applicant to establish whether the burrowing owls occupy the project site until immediately prior (14 days or less) to ground disturbance. It is impractical to assume the applicant would be able to develop and implement an effective exclusion plan according to CDFW standards during the narrow time frame. Because the DSEIR fails to provide a burrowing owl exclusion plan or fundamental details associated with that plan, it is impossible for the public, resource agencies and decision makers to evaluate the probability that there will be significant impacts evicted from project site. The DSEIR must be revised to provide sufficient detail on proposed eviction activities to permit the evaluation of impacts from these activities. Response: Passive relocation activities as prescribed in the 2012 CDFW Staff Report are considered an avoidance measure to ensure no take occurs as result of construction activities. If relocation is necessary, such activities will be done in consultation with CDFW at which time the department may prescribe additional avoidance measures to ensure any direct or indirect effects are minimized. The commenter also concludes that most translocation projects are unsuccessful. While there is some evidence of unsuccessful translocation efforts, there is also evidence of successful translocation efforts. WRA has conducted highly successful translocations for previous projects resulting in greater numbers of owl pairs than previously documented14. WRA agrees with the commenter that it is impracticable to prepare and implement a successful relocation plan within 14 days. The purpose of the minimum 14-day window as set forth in Supplemental Mitigation Measure SM-BIO-3 to conduct nest surveys is based on the potential for owls to re-nest in an area within a short time frame. If documented, site development would be delayed until approval can be obtained to passively relocate the owls. Nowhere in the DSEIR does it state that work will begin within 14 days of the nest survey, only that the survey should be performed no more than 14 days prior to the planned construction start date. Comment 3.1.19: The DSEIR’s reliance on protective buffers around any occupied nests to mitigate impacts of project construction is not supported by substantial evidence because it fails to identify the buffer size. The mitigation should be revised to reflect CDFW guidelines, which indicate that buffers may need to be up to 500 meters, depending on the time of year and level of disturbance. The mitigation measure must be specific, enforceable and feasible to identify specific standards. Response: As recommended by WRA biologists, Mitigation Measure SM-BIO-3 requires a pre-construction survey prior to site development to ensure no presence 14 WRA, Inc. 2007. Burrowing Owl 2007 Annual Monitoring Report, Pacific Commons Preserve, Fremont, Alameda County, California. 5pp. Final Supplemental EIR: The Green Mixed Use Project Page 31 City of Dublin August 2014 of burrowing owls. If owls are determined to be present during the nesting season, SM-BIO-3 requires that a buffer be established in consultation with CDFW around the active nest. While the actual buffer distance is not stated, the specific standard is 500 meters. A smaller buffer may be utilized with approval from CDFW; the minimum buffer for low levels of disturbance is 200 meters. Comment 3.1.20: The commenter notes that reliance on compensatory mitigation to reduce impacts to burrowing owl below a level of significance is not supported by substantial evidence. Proposed compensatory mitigation is vague, unenforceable and inconsistent with the regional requirements of the East Alameda County Conservation Strategy. Proposed supplemental mitigation measures fails to identify specific conditions which would trigger compensatory mitigation, establish success standards for proposed mitigation and a mechanism to ensure these standard are met and demonstrate that there is a nearby off-site location for acquisition of compensatory mitigation. The mitigation ratio applied to the project must be disclosed in order to permit assessment of its adequacy. Generally a 1:1 ratio is required to mitigate burrowing owl impacts, but may not be sufficient to reduce impacts below levels of less-than-significance due to the rapid decline of species in the immediate vicinity along with the limited scope of nearby remaining habitat and proximity of the Camp Parks owl population. Adherence to the EACCS compensatory mitigation should be required at a standardized rate of 3:1 or 3.5:1 if the mitigation site is in a different core area. Anything less cannot be assumed to reduce regional impact to a less-than-significant level. The DSEIR should be revised to include a provision that compensatory mitigation shall be required for project impacts to burrowing owl and their habitat at the EACCS compensatory mitigation ratio standard for burrowing owl at a 3:1 ratio. Because the DSEIR does not contain this provision, the impact to burrowing owl and their habitat would remain significant. Response: The commenter states that the DSEIR is inadequate because it does not do the following: 1) identify the specific conditions that would trigger mitigation; 2) establish success standards for the proposed mitigation; and 3) demonstrate that there is a nearby off-site location to relocate owls to. Supplemental Mitigation Measure SM-BIO-3 contained in the DSEIR requires that if a breeding pair is found on the site during the pre-construction survey then additional protection steps would be required. Standards under the mitigation are based on CDFW standards. The final mitigation plan would be developed in coordination with CDFW per the guidelines stated in the 2012 CDFW Staff Report. While the Eastern Alameda County Conservation Strategy (EACCS) will be used for guidance, the measures contained in the document are to be used as guidance, not requirements. The City of Dublin has accepted the EACCS as guidance for public construction projects, however the City does not require compliance with the EACCS for private development projects. As required by Supplemental Mitigation Measure SM-BIO-3, an appropriate ratio will be determined in consultation with CDFW if owls are found to nest at the site. The supplemental mitigation measure complies with CEQA and adequately reduces impacts to burrowing owl to a less-than-significant level. Final Supplemental EIR: The Green Mixed Use Project Page 32 City of Dublin August 2014 Comment 3.1.21: The DSEIR fails to identify what special-status plant species may be impacted by proposed project construction and the scope and significance of the plant populations to be impacted. Due to lack of detail in the DSEIR there could be other impacts and further study is needed. Also, it is impossible to determine whether effective mitigation may be designed or alternative project designs considered. Supplemental Mitigation Measure BIO-2 contains requirements that are vague and inconsistent with the Eastern Alameda County Conservation Strategy. Therefore, the details provided in this supplemental mitigation measure are not sufficient to support a finding that compliance with this measure will reduce this impact below a level of significance. Response: As described in the Response to Comment 3.1.14, the level of mitigation offered for Congdon’s tarplant is considered to be adequate to reduce the project’s impact to less than significant based on WRA’s knowledge and expertise with respect to this species. Mitigation Measure SM-BIO-2 contains specific mitigation requirements for impacts to Congdon’s tarplant on the project site. The species’ success in re-populating even disturbed sites demonstrates that replacement in an appropriate nearby mitigation site will be successful. Final details of mitigation will be determined in coordination with CDFW. The mitigation will be a minimum 1:1 ratio, allowing for complete replacement of the population impacted within the project site. While the Eastern Alameda County Conservation Strategy (EACCS) will be used for guidance, the measures contained in the document are to be used as guidance, not requirements. The City of Dublin has accepted the EACCS as guidance for public construction projects. However, the City does not require compliance with the EACCS for private development projects. . Comment 3.1.22: The DSEIR notes that bat foraging habitat on a regional scale is not expected to be significantly impacted on a regional scale. This statement is conclusory and not supported by any substantial evidence. A substantial amount of bat foraging habitat has already been lost to urban development and other activities. Remaining habitat is under threat for conversion. Therefore, loss of bat foraging habitat on the project site is a potentially significant impact and must be evaluated in a revised DSEIR. Moreover, the supplemental mitigation included in the DSEIR is insufficient to support a finding that the supplemental mitigation measure will reduce this impact to a level of less- than-significant. Specifically, critical periods of the life cycle of bats vary by species, location and year. Removal of the existing on-site building during the months of September and October may not be effective. Also, the DSEIR fails to identify survey techniques to be implemented. Detection of bats often requires specialized techniques that may be effective for one species but not another. The DSEIR fails to establish standards to ensure that preconstruction surveys do not have a significant impact on bats in the existing marketing building. Pallid bats and Townsend’s big-eared bats are known to be sensitive to human disturbance. The DSEIR fails to cite or identify standards and policies for any relocation plan consistent with US Fish & Wildlife Service, California Department of Fish & Wildlife and EEACCS standard and policies. Such policies and standards cited in the DSEIR may not exist. Moreover, even if bats are properly excluded, there may not be a suitable alternative roost available in the vicinity and the local population may be extinguished. Survey protocols must be specifically identified by bat species in order to ensure that the proposed mitigation is effective and meaningful. Final Supplemental EIR: The Green Mixed Use Project Page 33 City of Dublin August 2014 Response: As discussed in Response to Comment 3.1.15, the loss of any roost site is a significant impact. Avoidance measures have been prescribed to minimize impacts. The period from September through October represents the period when bats are the least likely to be present, thus minimizing any potential for take. A pre- construction survey to allow removal of the building when bats are not present reduces potential impacts to a less than significant level by assuring take does not occur. Supplemental Mitigation Measure SM-BIO-5 requires that if bats are found, an appropriate relocation plan shall be prepared consistent with EACCS and in consultation with CDFW to ensure impacts to special-status bats will be reduced to a less-than-significant level. The CDFW standard is that relocation and suitable roost replacement measures must be established through direct consultation with CDFW. WRA does not agree with the commenter that development of the site would constitute an impact on a regional scale. This conclusion is based on the small size of the site compared with suitable habitats in the surrounding regional area not currently proposed for development. The commenter notes that pre-construction surveys could potentially impact bats due to the sensitivity of these species. In fact, the site has been actively disturbed by human activity for many years including activities which would certainly be loud enough to disturb roosting bats, if present. Thus, the potential for these species to be present is likely to be low and thus, only completion of pre-construction surveys is required. The mitigation measure is sufficient in that in the unlikely event that a pre- construction survey identifies bats on site, a relocation plan consistent with CDFW standards and policies would be established. Comment 3.1.23: The DSEIR does not contain any analysis to substantiate the conclusion that the proposed project would not cause any new or more severe impacts with respect to cumulative biological impacts than was analyzed in the Eastern Dublin EIR. Since certification of the Eastern Dublin EIR (1992) and the IKEA SEIR (2003), a significant amount of new information has been submitted regarding Congdon’s tarplant, burrowing owl and other sensitive species. There was no evidence that Congdon’s tarplant existed on the site when the IKEA SEIR was prepared. In addition, surveys have documented a dramatic decline in burrowing owl populations in Alameda County and Contra Costa counties. It is now known that the Camp Parks property plays an important role in the overall persistence of burrowing owl populations. Previously accepted mitigations are ineffective in conservation of burrowing owl. The presence of seasonal wetlands is also new information that was not documented in prior EIRs. The commenter’s biologist concludes that the project’s incremental contribution to cumulative impacts to burrowing owl, Congdon’s tarplant, vernal pool fairy shrimp and special-status bats would be cumulatively considerable. Cumulative impacts cannot be accurately assessed until the missing baseline pertaining to the above species on the project is provided. The DSEIR must be revised to evaluate the project’s cumulative impact on biological resources taking into account new information that is available since the 1992 Eastern Dublin EIR. Response: The proposed project would not result in new or substantially more severe significant cumulative impacts to biological resources than identified in the Eastern Dublin EIR and IKEA SEIR. All project and cumulative impacts (except one) Final Supplemental EIR: The Green Mixed Use Project Page 34 City of Dublin August 2014 continue to be reduced to less than significant through the implementation of mitigation measures contained in the Eastern Dublin EIR and IKEA SEIR as augmented and revised by mitigation measures contained in the DSEIR. The one cumulative impact that remains significant and unavoidable as identified in the Eastern Dublin EIR is the cumulative loss or degradation of botanically sensitive habitat. With regard to Congdon’s tarplant, the Project impact will be less than cumulatively considerable. The impact will be reduced to less than significant through mitigation requiring 1:1 replacement habitat at a more appropriate site which would be more beneficial for long-term preservation of the species. The population of Congdon’s tarplant within the project site appears to have become established or greatly expanded recently in response to human disturbance. Due to the project site’s location close to an urban center, and due to the site’s past and current uses as a development site, the nearly-isolated population of Congdon’s tarplant within the project site is not ideal for preservation, and mitigation would provide for long-term preservation of the species. With regard to the burrowing owl, no owls or owl signs (indicators) were observed during multiple surveys of the project site. There are no records of burrowing owl ever using the project site and the project site is located some distance away from the Camp Parks population of burrowing owls. However, in the event owls are found during pre-construction surveys, mitigation in conformance with CDFW standards is required which will reduce any impacts to less than cumulatively considerable (See Response to Comment 3.1.12). With regard to wetlands, mitigation will result in no net loss of wetland habitat values or acreages through the development and implementation of a wetland mitigation plan that includes creation, restoration, and/or enhancement of off-site wetlands in accordance with regulatory agency standards. This will reduce any impact to less than cumulatively considerable. In addition, all wetlands on the site are features created during development activities on the site in 2008 and are not naturally occurring. Incidentally created wetlands are relatively common in partially developed landscapes and rarely support protected plant and wildlife species. With regard to VPFS, as discussed in Response to Comment 3.1.11, there is no substantial evidence or reasonable basis to believe that VPFS could be present on the project site, thus the project would not result in a cumulatively considerable impact to VPFS. With regard to special-status bats, the presence of bats in the limited building located on-site is presumed but not known. If bats are found during required pre- construction surveys, a relocation plan shall be develop and implemented in accordance with regulatory agency standards. Therefore, the project would not result in a cumulatively considerable impact to bats (See Response to Comment 3.1.15) Comment 3.1.24: The DSEIR finds that the project would result in significant and unavoidable traffic impacts at numerous intersections and roadways. Before a finding of significant and unavoidable impact can be made, the City must implement all feasible Final Supplemental EIR: The Green Mixed Use Project Page 35 City of Dublin August 2014 mitigation measures for such an impact. For this document, not all feasible mitigation measures have been considered. In addition, several of the mitigation measures are vague and unenforceable as written Response: The City disagrees with the commenter’s assertion that not all feasible mitigation measures have been identified and applied to the project. Proposed mitigation measures included in the DSEIR are consistent with CEQA and CEQA Guidelines. For those traffic impacts which are identified as significant and unavoidable, the City will need to make findings regarding the feasibility of proposed mitigation measures at the time of Project approval in accordance with CEQA. Comment 3.1.25: Supplemental Mitigation Measure TR-2 sets forth two separate alternative methods to reduce traffic impacts. at the Dublin Boulevard and Dougherty Road intersection during the PM peak period. The DSEIR concludes that traffic impacts at this intersection even with implementation of the supplemental mitigation measures. However, the primary and alternative supplemental mitigation measures are not mutually exclusive and address different aspects of the project’s impacts. Because neither supplemental mitigation measure reduces impacts below a level of significance and because both measures are feasible, the DSEIR errs in stating these supplemental mitigation measures are alternative measures. Accordingly, both measures should be required to mitigate Impact TR-2 to the fullest extent feasible. In addition, the DSEIR must be revised to evaluate potential measures to address pedestrian and bike safety concerns over Supplemental Mitigation Measure TR-1. At a minimum, the DSEIR should address the feasibility of pedestrian and bicycle overpasses. Response: As documented in the DSEIR, implementation of additional vehicle lanes at the Dublin Boulevard and Dougherty Road intersections as outlined in Supplemental Mitigation Measure TR-2 is not feasible or practical. All properties abutting this intersection are fully built out and purchase of additional right-of-way to accommodate additional lanes would encroach into parking lots on three corners and a City public art installation on the southeast corner of this intersection. This, there is not sufficient right-of-way to construct improvements identified in Supplemental Mitigation Measure TR-2. Proposed trip reduction measures outlined in Alternative Supplemental Mitigation Measure TR-2 would likely reduce peak hour trips through the Dublin Boulevard and Dougherty Road by some number of trips, however, the actual amount of trip reduction cannot be measured and may not be sufficiently effective to reduce project contribution of peak hour trips at the major intersection. The development of a TDM plan is required by Alternative Mitigation Measure SM- TR-2. However, because the reductions in vehicle trips from the TDM measures cannot not be determined with certainty, the DSEIR finds that Impact TR-2 will be significant and unavoidable. The concept advanced by the commenter that one or more pedestrian and bicycle overpasses be constructed at this intersection is also found to be infeasible due to the extreme length of raised walkways needed to span these very wide arterial roadways and lack of sufficient right-of-way to provide for entrances and exits for such overcrossings. At the time of Project approval, the City will need to make Final Supplemental EIR: The Green Mixed Use Project Page 36 City of Dublin August 2014 findings regarding the infeasibility of constructing pedestrian and bicycle overcrossings at this intersection. Comment 3.1.26: Alternative Supplemental Mitigation Measure TR-2 is also inadequate because it is vague and unenforceable as written. Subsection “h” that would require BART tickets be provided at no cost or subsidized rates to all employees does not contain any minimum amount of subsidy. Subsection (i) contains no minimum benefit requirements. With lack of details and standards, this means that implementation is impermissibly deferred and the success is uncertain. The supplemental measure should be revised to set forth feasible minimum subsidy and benefit requirements. For instance, the City of Santa Monica requires a minimum transit pass subsidy of 50% or a minimum pre-tax benefit program equal to the full price of a transit pass. The City should require subsidies or benefits that, at a minimum, meet City of Santa Monica standards. Response: As documented in the DSEIR, Alternative Supplemental Mitigation Measure TR-2 requires the developer to develop a TDM Plan as part of the project approvals. This TDM Plan will outline the details that are requested by the commentator. At the minimum the project would implement a BART subsidy program that would provide BART tickets at no cost or a subsidized rate to all employees. The exact amount of the subsidy is not set in the mitigation, but “at no cost” would be a full subsidy. The exact requirements under the Mitigation Measure will be determined at the time of the City approval of the overall TDM Plan when the relationship between the BART subsidy and other components of the Plan will be evaluated. This is not an improper deferral of mitigation. Mitigation Measure TR-2 requires the preparation of a transportation demand management (TDM) plan to encompass both commercial and residential uses which contains certain types of specified and detailed types of programs. The fact that the City will approve the exact requirements of the Plan before the issuance of any building permit is not improper deferral under CEQA. The proposed Conditions of Approval for the project require the Developer/Applicant to provide a minimum monthly Clipper card/transit pass subsidy for each residential unit. Comment 3.1.27: Page 6 of the DSEIR notes that Impact TR-3, impacts to the Dublin Boulevard and Hacienda Drive intersection, would be less-than-significant. Page 79 of the DSEIR notes that this impact is significant and unavoidable. The finding that Traffic Impact TR-3 would be less-than-significant after mitigation is not supported by substantial evidence. In addition, the DSEIR should be revised to evaluate potential mitigation measures to address pedestrian and bike safety to support the conclusion that changes in turn lanes and signal phasing would not be feasible. The DSEIR should evaluate the feasibility of pedestrian overpasses and driveway safety warnings or safer driveway existing designs. Response: The Summary of Impacts and Mitigation Measures for Impact TR-3 contained on page 6 of the DSEIR has a typographical error which is inconsistent with the text of the DSEIR with the actual analysis on pages 78-79. Impact TR-3 identifies the short-term cumulative impacts at the Dublin Boulevard and Hacienda Drive intersection during the PM peak period. As noted on pages 78 and 79 of the DSEIR, roadway improvements (as outlined in Supplemental Mitigation Measure SM-TR-3) required to mitigate this impact to less than significant are infeasible since the improvements would require the removal or modification of an existing curb extension on the southeast corner of this intersection and relocation of an existing Final Supplemental EIR: The Green Mixed Use Project Page 37 City of Dublin August 2014 bike lane to accommodate an additional vehicle lane. Construction of the new travel lane would increase the crossing distance for pedestrians wishing to cross this street and impact bicycle use of Dublin Boulevard. Since the proposed traffic improvements are infeasible, the DSEIR requires the development of a TDM program as required under Alternative Supplemental Mitigation Measure SM-TR-2 to reduce this impact. However, since the reductions in vehicle trips from the TDM measures are difficult to determine with certainty, the DSEIR finds that Impact TR-3 will be significant and unavoidable. The commenter is also directed to the Clarifications and Modifications section to this Final SEIR regarding correction of the document. Comment 3.1.28: The supplemental mitigation for Impact TR-5 is speculative and unenforceable and does not support the conclusion that Impact TR-5 will be mitigated to a less-than significant level. The Supplemental Mitigation measure requires the Green project developer to assist in funding the construction of a grade separated crossing of Scarlett Drive at Dublin Boulevard as identified in the Dublin Crossings EIR. The commenter notes that the proposed grade separated structure has not received environmental clearances nor has engineering right-of-way studies been completed to assure success of this supplemental mitigation measure. When success of a mitigation measure cannot be guaranteed, an agency cannot reasonably determine that significant effects will not occur. Therefore, the City lacks sufficient evidence to support the DSEIR conclusion. Response: The commenter is incorrect in the assertion that Supplemental Mitigation Measure TR-5 lacks certainty and will not mitigate the Dublin Boulevard and Scarlett Drive intersection to a less-than-significant level in the long-term, cumulative condition. Proposed construction of the grade separation structure is located on City right-of-way and funding will be provided by development impact fees and other sources. Environmental review of the project has not yet been completed, but will be finalized by the City of Dublin prior to when it will be needed for pedestrian and bicycle use under the long-term cumulative condition. There is no need to have final designs and environmental review completed at this early stage of the project. With the construction of the grade separation structure as planned, the impact will be less than significant. However, in the event the grade separation is not constructed by 2035, the DSEIR also includes an alternative mitigation of removing the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. The removal of the crosswalk will also result in a less than significant impact. The Project is required to make a fair share contribution to the construction of this improvement. Comment 3.1.29: The DSEIR concludes that no feasible mitigation is available for Impacts TR-10, TR-11, TR-12, TR-13, TR-14, TR-15, TR-16 and TR-17. This conclusion is in conflict with the identification of the preparation of a TDM Plan as a feasible mitigation measure. Such a plan that promotes ridesharing, van pools, public transportation use, bicycle use can reduce the projects generation of traffic and the project’s contribution to these traffic impacts. A transportation management plan must be more specific than set forth in the Alternative Supplemental Mitigation Measure and include an enforceable minimum subsidy and enforcement mechanism to identify and assess compliance and effectiveness. In addition, the DSEIR should be revised to evaluate potential measures to address pedestrian Final Supplemental EIR: The Green Mixed Use Project Page 38 City of Dublin August 2014 and bicycle concerns that led the DSEIR to determine that changes in turn lanes and signal phasing changes will not be feasible. The DSEIR should evaluate the potential for pedestrian overpasses or other additional pedestrian safety designs that could make rejected traffic mitigation measures feasible. Response: The DSEIR concludes that a TDM Plan, as outlined in Alternative Supplemental Mitigation Measure SM-TR-2, is a feasible mitigation and will reduce the impacts of all the supplemental impacts referenced by the commenter. Mitigation Measure SM-TR-2 sets forth with specificity that types of measures that will be part of the program and will be required as a condition of approval for the Project. However, since the exact amount of the trip reductions from the TDM program are difficult to determine with certainty at this time, the DSEIR concludes that the traffic impacts TR-10, TR-11, TR-12, TR-13, TR-14, TR-15, TR-16 and TR-17 will be significant and unavoidable. The DSEIR did not evaluate the potential to construct above- or below-grade crossings at other impacted intersections due to the fact that none of these other intersections include a regional trail that is considered a significant pedestrian/bicycle route along a well-travelled commute and recreational corridor. Comment 3.1.30: The DSEIR fails to describe the project in sufficient detail to meaningful evaluate project impacts to bicycle and improperly defers mitigation for potential impacts to bicyclists. The City’s Bikeway Master Plan identifies bike lanes along Arnold Road and other roads immediately adjacent to the site. The DSEIR states that no detailed plans have been submitted to the City to determine if adequate sight distance will be provided to allow for a clear view of bicyclists for vehicles entering or exiting the project site. Nor is sufficient data available to review whether sufficient bicycle parking will be provided. Accordingly, the DSEIR assumes project imparts to these topics to be significant. The failure of a sufficient project description is a violation of CEQA and does not allow all impacts to be fully evaluated or appropriate mitigation measures to be developed. In addition, mitigation provided in the DSEIR is improperly deferred and lacks performance standards. The document fails to disclose what City guidelines, policies and standard are applicable and provides no evidence that compliance with standards will reduce future impacts to a less- than-significant level. The DSEIR also fails to describe the project in sufficient detail to allow meaningful evaluation of impacts to pedestrians. Similar to lack of detail regarding bicycle impacts, lack of detail does not allow a full analysis of pedestrian impacts, improperly defers mitigation and lacks performance standards. Response: Staff has analyzed architectural, site, and civil plans that comprise the Site Development Review and Vesting Tentative Tract Map application for the proposed project. Through Staff’s review of these application materials, Staff has ensured that bicycle and pedestrian access is enhanced both inside the project and on the public streets in the project vicinity. With the more detailed plans available, Staff is able to make the determination that adequate sight distance is being provided to allow for a clear view of bicyclists for vehicles entering or exiting the project site. Staff has also reviewed the plans to determine that sufficient bicycle parking is being provided. The pedestrian and bicycle circulation system that has been reviewed will be further refined at the time Staff reviews the off-site improvement plans, and special attention will be paid to maintain safety and access for alternate modes of transportation at all intersections. Based on the plans Final Supplemental EIR: The Green Mixed Use Project Page 39 City of Dublin August 2014 submitted by Applicant at this time, the Project complies with City Plans relating to pedestrians and bicycles (including Bikeway Master Plan, Complete Streets, and all other applicable City plans on this issue). However, Supplemental Mitigation Measures SM-TR-18 and -19 require final review for compliance based on final plans at the time of sitework permits. Regarding the portion of the comment regarding applicable “guidelines, policies and standards” Supplemental Mitigation Measures SM-TR-18 and -19 are hereby amended to read as follows: “Prior to the issuance of any permit for the project, the Applicant shall prepared final Site Improvement Plans for both onsite and offsite improvements that are consistent with the Site Development Review and Vesting Tentative Tract Map plans, which have been determined to be consistent with applicable City guidelines, policies and standards, including but not limited to the City of Dublin General Plan Community Design & Sustainability Element, Chapter 8.76 of the Dublin Zoning Ordinance, and the Bikeway Master Plan, for review and approval by the City.” Pedestrian and bicycle requirements contained in the above City requirements are based on city-wide experience in the development of the Eastern Dublin Planning area and have proven successful in ensuring that pedestrian and bicycle facilities will be constructed to reduce pedestrian and pedestrian impacts to a less-than-significant level. The requirement in a mitigation measure to comply with specific standards is not improper deferral under CEQA. Comment 3.1.31: The DSEIR finds that significant and unavoidable greenhouse gasses would be emitted by the project. CEQA requires that all feasible mitigation be identified and imposed before a finding of significant and unavoidable impacts can be made. For this project, the requirement that the project exceed 2008 Title 24 energy efficiently requirements by 20% is inadequate because the 2013 Title 24 energy efficiency requirements now in effect exceed the 2008 Title 24 standards by approximately 25%. The commenter cites that Title 24 CalGreen Tier 1 and Tier 2 call for exceeding 2013 Title 24 energy standard by 15 to 30%. Because these are currently regulatory requirements, they are presumed feasible. Based on this information, the DSEIR must be revised to require the project to exceed the 2013 Title 24 energy efficiency standards by 30% or as much as determined feasible by the City based on evidence submitted in the record. Response: The Project will be required to comply with the California State Energy Efficiency (Title 24) standards in effect at the time of Building Permit issuance. At the time of publication of this Final SEIR, the 2013 Title 24 standards are currently in effect. For details on these requirements, please refer to the State’s website: www.energy.ca.gov/title24/2013standards/index.htm. In addition to required compliance with the Title 24 standards in effect at the time of permit issuance, the Project will also be required to be in compliance with the 2013 California Green Building Standards Code (‘CalGreen’), which was adopted by the City. Dublin’s Chief Building Official enforces the mandatory measures of CalGreen, but did not adopt Tiers 1 or 2. Dublin also enforces Chapter 7.94 of the Municipal Code, which is the City’s Green Building Ordinance. The goal of the ordinance is to increase energy efficiency and it applies to the planning, design, operation, Final Supplemental EIR: The Green Mixed Use Project Page 40 City of Dublin August 2014 construction, use and occupancy of every newly constructed building or structure in the City, including residential developments over 20 units. The Project will also be required to comply with all other applicable regulatory requirements to reduce greenhouse gas emissions as noted in the Draft SEIR. Please refer to the Draft SEIR, beginning on page 186, for a summary of the greenhouse gas reduction strategies and requirements that will be imposed on the Project by the City’s Climate Action Plan. In addition to the above requirements, the Applicant/Developer has identified additional measures to reduce the construction-related greenhouse gas emissions of the Project during it multi-year construction timeframe. The list of measures, developed by the Sacramento Metropolitan Air Quality Management District and included as Attachment 6 to this Final SEIR, are considered best management practices providing options for reducing greenhouse gas emissions from construction projects. By including this list of measures in the Final SEIR, the Applicant is required to implement them and SM-AQ-4 is modified to include a reference to the measures. The City’s greenhouse gas emissions consultant reviewed the request of the commenter to determine if supplemental mitigation for the project were to have required a 30% in excess of 2013 Title 24 energy standards will reduce greenhouse gas emissions to a less-than-significant level. The City’s consultant determined such an increase would not change the significant and unavoidable impact conclusion in the DSEIR , due to the fact that mitigated mobile emissions alone (not including energy usage) are enough to result in a significant and unavoidable impact (Illingworth & Rodkin, July 2014). Since the DSEIR finds that the Project’s impacts due to GHG emissions is significant and unavoidable, at the time of Project approval, the City Council will need to make findings on the feasibility of any proposed additional mitigation measures to reduce GHG emissions. Comment 3.1.32: CEQA requires a lead agency to recirculate an EIR when significant new information is added to an EIR following public review but before certification. The commenter notes that the project will have numerous impacts that are different and more severe than described in the EIR, including groundwater impacts, soil impacts, biological resource impacts and traffic impacts. The DSEIR lacks adequate mitigation for the potentially significant impacts previously mentioned and a revised and recirculated EIR is required. Response: The commenter is incorrect in the assertion that new or more severe impacts would occur with the projects than have been analyzed in the DESIR. See the previous responses noting that no new or more severe significant impacts would occur with respect to groundwater resource, hazards and contamination, biological resources and traffic. The City therefore believes that the standards for recirculation are not met. In addition, the limited clarifications and modifications to the DSEIR contained in the Final SEIR do not meet the standards for recirculation. The changes in the Final SEIR clarify, amplify or make insignificant modifications to an adequate DSEIR in compliance with CEQA standards. Final Supplemental EIR: The Green Mixed Use Project Page 41 City of Dublin August 2014 Comment 3.1.33: commenter thanks the City of Dublin for an opportunity to provide comments. The City is urged to ensure that project impacts are fully disclosed, evaluated and mitigated before the project is allowed to proceed. Response: This comment is noted. The City believes that the DSEIR, with the minor modifications and clarifications in the Final SEIR, is legally adequate, fully discloses all project supplemental impacts, evaluates those impacts and, to the extent feasible, provides legally adequate supplemental mitigation measures, all in compliance with CEQA standards. Attachment 1: Annotated Comment Letters Attachment 2: Table 1.1 (Summary of Mitigation Measures) Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 1 Table 1.1 Summary of Mitigation Measures Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation TR-1 Traffic. The Dublin Boulevard and Arnold Road (#8) intersection would degrade from LOS D to LOS E with the addition of project trips during the AM peak hour under Existing conditions. SM-TR-1. The following measures shall be required to improve the level of service to within acceptable standard: a) Add a 75-foot long southbound right turn lane with a 100-foot long taper area; b) Convert the southbound shared through-right lane to through lane; c) Optimize traffic signal split time. Less-than-Significant TR-2 Traffic. The Dublin Boulevard and Dougherty Road intersection would operate at LOS E without the proposed project during the PM peak hour under Short-Term Cumulative conditions and implementation of the proposed project would add 50 or more trips to the intersection. SM-TR-2. The Eastern Dublin EIR MM 3.3/2.0 requires non-residential projects with 50 or more employees to participate in the Transportation Systems Management (TSM) program. As an alternative mitigation measure, the Project shall prepare a transportation demand management (TDM) plan to encompass both commercial and residential uses as part of the project. The project developer shall work with the City to develop the key elements of the TDM plan, which shall be approved by the City prior to the issuance of the first building permit. The TDM plan should include, but not be limited to, the following elements: a) Appoint Transportation Coordinator to oversee the TDM program developed for the project including program development, information distribution and program implementation. b) Promote and distribute hard copy information quarterly to all employees and residents regarding 511, Ridematch, Guaranteed Ride Home Program, Wheels/LAVTA, Altamont Corridor Express (ACE), BART, shuttles to regional transit, and any car share programs. c) Distribute information quarterly regarding above by email blast to all employees and residents. d) Co-sponsor subarea transportation fair once a year with “The Village” property to the north and/or other developments in the East Dublin area. Invite Wheels, 511.org, and at least two other commute alternative service providers to attend and distribute commute alternative information. e) Provide bicycle parking facilities for 20 percent of commercial car spaces or a number approved by the City beyond the City’s bicycle rack requirement. f) Provide secured bicycle parking (lockers or cages) for employees. g) Join City Car Share as a “Biz Prime” member and pay for membership of a minimum of five percent employees. h) Implement a BART subsidy program that would provide BART Significant and Unavoidable Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 2 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation tickets at no cost or subsidized rate to all employees. i) Implement a Commuter Tax Benefit Program or equivalent. Under Section 132(F) of federal tax code, an employer can offer its employees up to $245 per month for qualified transit, vanpool or parking costs. Or, an employer may offer $20 per month for bicycling costs. Full information is available at: http://rideshare.511.org/rewards/tax_benefits.aspx j) Provide preferential parking for carpools and vanpools as part of off-street parking requirements. The following measures would be required to improve the level of service to within acceptable standard: a) Convert an eastbound right-turn lane to a through lane to provide two left-turn lanes, four through lanes and one right-turn lane on the eastbound approach on Dublin Boulevard; b) Provide a corresponding 300-foot long receiving lane on the east leg with a 360-foot long merging taper area; c) Provide an overlap signal phasing for the westbound right-turn movement and prohibit conflicting southbound U-turn movement; and d) Optimize traffic signal split time. Alternative Mitigation Measure SM-TR-2. Significant and Unavoidable TR-3 Traffic. The Dublin Boulevard and Hacienda Drive (#10) intersection would degrade from LOS D to LOS E with the addition of project trips during the PM peak hour under Short-Term Cumulative conditions. SM-TR-3. Implement SM-TR-2. The following measures would be required to improve the level of service to within an acceptable standard: a) Convert an eastbound right-turn lane to a through lane to provide two left-turn lanes, four through lanes and one right-turn lane on the eastbound approach on Dublin Boulevard; b) Provide a corresponding receiving lane on the east leg with a 360- foot long taper area; and c) Optimize traffic signal split time. Less-than-Significant Significant and Unavoidable TR-4 Traffic. The Dublin Boulevard and Tassajara Road intersection would operate at LOS E without the proposed project during the PM peak hour under Short-Term Cumulative conditions and implementation of the proposed project would add 50 or more trips to the intersection. SM-TR-4. The following measures would be required to improve the level of service to within acceptable standard: a) Add an eastbound through lane to provide two left-turn lanes, three through lanes and two right-turn lane on the eastbound approach on Dublin Boulevard; and b) Provide a corresponding receiving lane on the east leg that extends from Tassajara Road to Brannigan Street. Less-than-Significant TR-5 Traffic. The Dublin Boulevard and Scarlett Drive (#5) intersection would operate at LOS E without the SM-TR-5. At the intersection of Dublin Boulevard and Scarlett Drive, there is a significant impact from the Dublin Crossing project according to the Dublin Crossing Specific Plan (DCSP)-DEIR. In the DSCP-DEIR, the Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 3 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation proposed project during the AM peak hour under Long-Term Cumulative conditions and the proposed project would further degrade the operations to LOS F and add 50 or more trips to the intersection. recommended measure to mitigate the impacts at the intersection of Scarlett Drive and Dublin Boulevard due to the high rate of pedestrians/bicyclists crossing at Dublin Boulevard is a grade separated crossing. 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 the Dublin Crossings 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 separated bridge has not yet been environmentally cleared, and to ensure that the impacts are adequately mitigated, the Applicant/Developer is required to provide a fair-share contribution for the alternative mitigation of removing the crosswalk on the east leg of the Scarlett Drive and Dublin Boulevard intersection. TR-6 Traffic. The Dublin Boulevard and Arnold Road (#8) intersection would degrade from LOS D to LOS E with the addition of project trips during the AM peak hour under Long-Term Cumulative conditions. SM-TR-6. The following measures would be required to improve the level of service to within acceptable standard: a) Modify the traffic signal phasing to provide a protected/ permitted overlap phase for the southbound right-turn movement and prohibit conflicting eastbound U-turn movement; and b) Optimize traffic signal split time. Less-than-Significant TR-7 Traffic. The southbound left-turn queue at the Dublin Boulevard and Dougherty Road intersection would exceed turn pocket capacity without the proposed project during the PM peak hour and the proposed project would lengthen the queue by 25 feet or more under Short-Term Cumulative conditions. SM-TR-7. Optimization of the traffic signal phase time would reduce the 95th percentile queue length for the southbound left turn to 371 feet during the PM peak hour. While the queue length would still exceed the turn pocket storage, the project traffic would lengthen the queue by less than 25 feet. Less-than-Significant TR-8 Traffic. The westbound left-turn queue at the Dublin Boulevard and Hacienda Drive (#10) intersection would exceed turn pocket capacity without the proposed project during the AM peak hour and implementation of the proposed project would lengthen the queue by SM-TR-8. The traffic signal at this intersection shall be modified to provide additional green time for the westbound left-turn movement by reducing the green time for the eastbound through movement. This will reduce the queue length to 420 feet in the AM peak hour and 270 feet in the PM peak hour. While the queue lengths would still exceed turn pocket capacity, the project traffic would lengthen the queue by less than 25 feet in the AM peak hour and would cause the queue to extend beyond the turn pocket by less than 25 feet in the PM peak hour. Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 4 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation 25 feet or more under Short-Term Cumulative conditions. Further, during the PM peak, the project would cause the queue to extend beyond the turn pocket by 25 feet when it would be contained under No Project scenario. TR-9 Traffic. The southbound left-turn queue at the Scarlett Drive and Dougherty Road intersection would exceed turn pocket capacity without the proposed project during the PM peak hour and implementation of the proposed project would lengthen the queue by 25 feet or more under Long-Term Cumulative conditions. SM-TR-9. The traffic signal phasing at this intersection shall be modified to provide additional green time for the southbound left-turn movement. This will reduce the queue length by 12 feet to 845 feet and to within acceptable threshold. Also, because the impact is caused by cumulative land use growth in the region, the project developer shall make a fair share contribution toward this improvement. The fair share contribution shall be paid prior to the issuance of the first building permit. Less-than-Significant TR-10 Traffic. The project would cause the Dublin Boulevard segment between Hacienda Drive and Hibernia Drive to degrade from LOS D to LOS E during the AM peak hour under Existing conditions. The project would only add 30 trips to this segment. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-11 Traffic. The project would cause the northbound Hacienda Drive segment of Dublin Boulevard to Central Parkway to degrade from LOS D to LOS E. Project traffic would also cause the volume to capacity ratio of the northbound Hacienda Drive segment between I-580 westbound ramp to Hacienda Crossings to increase by 0.071. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-12 Traffic. The project would cause the volume to capacity ratio along the eastbound Dublin Boulevard segment between DeMarcus Boulevard and Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 5 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation Iron Horse Parkway to increase by 0.03 where it would operate at LOS E in the PM peak hour under Short- Term Cumulative No Project scenario. TR-13 Traffic. The project would cause the volume to capacity ratio along the westbound Dublin Boulevard segment between Scarlett Drive and Dougherty Road to increase by 0.027 where it would operate at LOS E in the AM peak hour under Short-Term Cumulative No Project scenario. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-14 Traffic. The project would cause the volume to capacity ratio along the northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing to increase by 0.045 where it would operate at LOS E in the AM peak hour and by 0.071 where it would operate at LOS F in the PM peak hour under Short-Term Cumulative No Project scenario. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-15 Traffic. The project would cause the northbound Tassajara Road segment between Dublin Boulevard and Central Parkway to degrade from LOS D to LOS E during the PM peak hour under Short-Term Cumulative conditions. While the project would only add 4 trips to this segment, this impact is considered to be significant. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-16 Traffic. The project would cause the volume to capacity ratios along the westbound Dublin Boulevard Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 6 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation segments between Iron Horse Parkway and Camp Parks where it would operate at LOS E and between Camp Parks and Scarlett Drive where it would operate at LOS F in the AM peak hour under Long-Term Cumulative No Project scenario to increase by 0.023. TR-17 Traffic. The project would cause the volume to capacity ratio along the northbound Hacienda Drive segment between I-580 westbound ramps and Hacienda Crossing to increase by 0.02 during the PM peak hour where it would operate at LOS F under Long-Term Cumulative No Project scenario. Implement SM-TR-2. No feasible mitigation available Significant and Unavoidable TR-18 Traffic. The project could conflict with adopted bicycle plans, guidelines, policies or standards. SM-TR-18. Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with applicable City guidelines, polices and standards for review and approval by the City. Prior to the issuance of any permit for the project, the Applicant shall prepared final Site Improvement Plans for both onsite and offsite improvements that are consistent with the Site Development Review and Vesting Tentative Tract Map plans, which have been determined to be consistent with applicable City guidelines, policies and standards, including but not limited to the City of Dublin General Plan Community Design & Sustainability Element, Chapter 8.76 of the Dublin Zoning Ordinance, and the Bikeway Master Plan, for review and approval by the City. Less-than-Significant TR-19 Traffic. The project could conflict with adopted policies, plans or program supporting pedestrians. SM-TR-19. Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with applicable City guidelines, polices and standards for review and approval by the City. Prior to the issuance of any permit for the project, the Applicant shall prepared final Site Improvement Plans for both onsite and offsite improvements that are consistent with the Site Development Review and Vesting Tentative Tract Map plans, which have been determined to be consistent with applicable City guidelines, policies and standards, including but not limited to the City of Dublin General Plan Community Design & Sustainability Element, Chapter 8.76 of the Dublin Zoning Ordinance, and the Bikeway Master Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 7 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation Plan, for review and approval by the City. TR-20 Traffic. The project could conflict with adopted policies, plans or program supporting pedestrians, including the City’s Complete Streets policies. SM-TR-20. Prior to issuance of any permit for the project, the Project shall submit design plans that are consistent with the City’s Complete Street Policy and design standards for review and approval by the City. Less-than-Significant TR-21 Traffic. The project could include design features that would not be consistent with the City’s engineering design standards or standards published by the ITE or Caltrans. SM-TR-21. Prior to issuance of any permit for the project, the project developer shall submit design plans that are consistent with the City’s Complete Street Policy for review and approval by the City. All designs shall conform to City standards. Less-than-Significant TR-22 Traffic. Project construction activities such as the import of the fill material and delivery of materials could result in impacts to vehicle, bicycle and pedestrian access in and around the project area. SM-TR-22. Before issuance of grading permits for the project, the project developer shall prepare a detailed Traffic Management Plan that will be subject to review and approval by the City of Dublin, LAVTA, and local emergency service providers, including the City of Dublin Fire Prevention Bureau and the City of Dublin Police Services Department. The plan shall ensure maintenance of acceptable operating conditions on local roadways and transit routes. At a minimum, the plan shall include: a) The number of truck trips, time, and day of street closures b) Time of day of arrival and departure of trucks c) Limitations on the size and type of trucks; provision of a staging area with a limitation on the number of trucks that can be waiting d) Provision of a truck circulation pattern e) Provision of a driveway access plan to maintain safe vehicular, pedestrian, and bicycle movements (e.g., steel plates, minimum distances of open trenches, and private vehicle pick up and drop off areas) f) Safe and efficient access routes for emergency vehicles g) Efficient and convenient transit routes h) Manual traffic control when necessary i) Proper advance warning and posted signage concerning street closures j) Provisions for pedestrian safety and access. Less-than-Significant Park-1 Community Services & Facilities. Build-out of the proposed project would require the dedication of 5 acres of local parkland on the project site. The proposed project provides no public park space. SM-Park-1. Prior to approval of the first Final Subdivision Map for the project, the project developer(s) shall satisfy the requirement to provide parkland through the payment of in-lieu fees to the City of Dublin prior to issuance of building permits. As part of the first final subdivision map for the project, the project developer(s) shall dedicate a minimum 2-acre Neighborhood Square to the City of Dublin. The size, configuration and location of the Neighborhood Square shall be approved by the Dublin parks and Community Services Department. Project developer(s) shall satisfy Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 8 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation remaining local park requirements by paying fees to the City of Dublin prior to issuance of building permits. BIO-1 Biological Resources. The proposed project would result in the fill of potentially jurisdictional waters of the U.S. and/or waters of the State. SM-BIO-1. The applicant shall undertake the following prior to issuance of a grading plan for the site: a) A wetland delineation shall be completed for the site consistent with U.S. Army Corps of Engineers protocols. b) If jurisdictional wetlands are found on the site and if avoidance of these jurisdictional waters on the site is not feasible, suitable compensatory mitigation shall be provided based on the concept of no net loss of wetland habitat values or acreages. In such an eventuality, a wetland mitigation plan shall be developed and implemented that includes creation, restoration, and/or enhancement of off-site wetlands prior to project ground disturbance. Mitigation areas shall be established in perpetuity through dedication of a conservation easement (or similar mechanism) to an approved environmental organization and payment of an endowment for the long-term management of the site. If wetlands are determined to be jurisdictional under Section 404 of the Clean Water Act, the mitigation plan will be subject to the review and approval of the Corps and Regional Water Quality Control Board (RWQCB). If the potential seasonal wetlands are non-jurisdictional under Section 404, the mitigation plan will be subject to the review and approval of the RWQCB. Less-than-Significant BIO-2 Biological Resources. Approval and construction of the proposed project would impact Congdon’s tarplant and other special-status plant species on the site. SM-BIO-2. Focused surveys for special-status plants shall be conducted on the site consistent with the California Department of Fish & Wildlife’s 2009 Protocols for Surveying and Evaluating Impacts to Special-Status Populations and natural Communities. Plant surveys shall be conducted throughout the blooming period throughout the blooming period of those special-status for which suitable habitat is present. Two or three separate surveys may be required to cover the blooming period of plants listed in Appendix Ai of the Supplemental Biological Analysis (Appendix 8.7 of the DSEIR) Table 4.4-1. If populations/stands of a special-status species are identified during the surveys and impacts cannot be avoided, compensatory mitigation shall be provided, such as the acquisition of off - site mitigation areas presently supporting the species in question, purchase of credits in a mitigation bank that is approved to sell credits for the affected species, or payment of in-lieu fees to a public agency or conservation organization (e.g.. a local land trust) for the preservation and management of existing populations. The location of mitigation sites shall be determined in consultation with and subject to approval of US Fish and Wildlife Service and/or California Department of Fish & Wildlife. In the case Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 9 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation where special-status plants are neither federal- or state-listed, the lead agency shall approve the mitigation approach using the guidance provided by the Eastern Alameda County Conservation Strategy in consultation with the City’s consulting biologist. Off-site compensatory shall be acquired at a minimum acreage ratio of 1:1 (acquired:impacted). For off -site mitigation options, measures shall be implemented (including contingency measures) providing for the long-term protection of these species. BIO-3 Biological Resources. The proposed project could impact the habitat for nesting or wintering burrowing owl by disturbing the existing ground surface. SM-BIO-3. Preconstruction surveys shall be conducted for burrowing owls prior to grading or construction activities. These surveys should conform to the survey protocol established in the Staff Report on Burrowing Owl Mitigation (CDFW 2012b). The Conservation Strategy depicts the project site as being located in Conservation Zone 2, which supports 11 percent of the Conservation Strategy’s study area’s unprotected potential habitat for burrowing owl). Burrowing owls could nest or winter in the site’s approximate 13 acres of ruderal/disturbed non-native grassland habitat and within the suitable grassland habitat adjacent to the site. The following measures are consistent with the provisions of the Migratory Bird Treaty Act and the California Department of Fish & Wildlife standards. a) No more than 14 days prior to any ground disturbing activities, a qualified biologist shall conduct a take avoidance survey for burrowing owls. If no owls are found during this first survey, a final survey will 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 site shall be resurveyed (including the final survey within 48 hours of disturbance). All surveys shall be conducted in accordance with California Department of Fish & Wildlife guidelines. b) If burrowing owls are found on the site during the surveys, mitigation shall be implemented in accordance with applicable California Department of Fish & Wildlife standards. More specifically, if the surveys identify breeding or wintering burrowing owls on or adjacent to the site, 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 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 Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 10 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation be subject to California Fish & Wildlife approval and monitoring requirements. Compensatory mitigation could also be required by California Fish & Wildlife 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 California Department of Fish & Wildlife. BIO-4 Biological Resources. Construction of the proposed project could impact breeding birds on the site. SM-BIO-4. Supplemental Mitigation Measure SM-BIO-4 (impacts to breeding birds). Vegetation removal and/or initial ground disturbance on the site shall occur during the non-breeding season from September 1 to January 31. If instead these actions will occur from February 1 to August 31, then a pre-construction breeding bird survey shall be conducted no more than 14 days prior to construction. Any common bird active nests found shall be protected by a minimum 50-foot exclusion buffer. The buffer size may vary depending on bird species, the location of the nest, and other factors. If a breeding bird survey determines that a special-status species is located on the site, a larger buffer would be required, such as a 100-foot buffer for minor disturbances and a 250-foot buffer for major disturbances. In the case of special-status species, the size of buffers and other measures would be implemented based on any applicable CDFW guidance and standards. Less-than-Significant BIO-5 Biological Resources. Construction of the proposed project could impact special-status bats that could inhabit the site, specifically the removal of the existing building. SM-BIO-5. The marketing building shall be removed from the premises during September or October. Pre-construction surveys of the marketing building for bats shall occur no more than 30 days before its removal. If bats are found, a qualified biologist shall develop an appropriate relocation plan consistent with US Fish & Wildlife, California Department of Fish & Wildlife and EACCS standards and policies. Less-than-Significant NOISE- 1 Noise. Residential land uses proposed by the project could be exposed to exterior noise levels exceeding 60 dBA CNEL and interior noise levels exceeding 45 dBA CNEL. SM-NOISE-1. Reduce exterior and interior noise levels in noise sensitive areas of the project to meet City standards. To meet City noise standards, the following mitigation shall be used:  Locate noise-sensitive outdoor use areas away from Interstate 580. Ensure that all residents have access to outdoor use areas that achieve exterior noise criteria (60 dBA CNEL for residential uses).  A suitable form of forced-air mechanical ventilation, as determined by the local building official, shall be provided for units throughout the site, so that windows can be kept closed at the occupant’s discretion to control interior noise and achieve the interior noise standards.  For the first row of buildings facing Interstate 580, the buildings shall be designed to have sealed windows and no balconies on elevations facing the freeway.  For residential uses, noise insulation features shall be designed to Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 11 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation achieve the 45 dBA CNEL interior noise standard. Sound rated windows and doors shall be provided to maintain interior noise levels at acceptable levels. Additional treatments may include, but are not limited to, sound rated wall construction, acoustical caulking, insulation, acoustical vents, etc. Large windows and doors should be oriented away from the I-580 where possible. Bedrooms should be located away from I-580.  The final specifications for noise insulation treatments shall be reviewed by a qualified acoustical consultant during final design of the project to ensure that exterior and interior noise levels on site achieve the 45 dBA CNEL interior noise standard for residential uses and hourly average noise levels to 45 dBA Leq for commercial uses. Results of the analysis, including the description of the necessary interior and exterior noise control treatments, shall be submitted to the City along with the building plans and shall approved by the City prior to issuance of a building permit.  The final design and location of project mechanical equipment shall be reviewed by a qualified acoustical consultant to confirm that operational noise levels would not exceed 60 dBA CNEL at exterior project residential uses and would not exceed 45 dBA CNEL inside these residences. If needed, the final design and location of mechanical equipment shall be modified to conform with noise parameters set forth in this analysis.  A truck delivery plan shall be submitted to the City for the commercial portion of the project site, which would include the proposed hours of allowable deliveries and the locations and routes of the delivery trucks on the project site. A qualified acoustical consultant shall review the delivery plan to ensure that interior and exterior noise levels on site achieve acceptable levels. The truck delivery plan and acoustical consultant report shall be subject to approval by the City prior to the issuance of a certificate of occupancy for any commercial building. Air Quality Air Quality. Dust Control Measures. SM-AQ -1. The project applicant shall adhere to the following dust control measures, which shall replace those included in EDSP EIR Mitigation Measure 3.11/1.0: a) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. b) All haul trucks transporting soil, sand, or other loose material off -site shall be covered. c) All visible mud or dirt track-out onto adjacent public roads shall be Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 12 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. d) All vehicle speeds on unpaved roads shall be limited to 15 mph. e) All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. f) Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 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. g) 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. h) Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. 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. AQ-1 Air Quality. The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is non- attainment under applicable Federal or State ambient air quality standards due to emissions of NOX. SM-AQ -2. The project applicant shall reduce future residential and employee trips through a Traffic Demand Management (TDM) program approved by the City and including, but not limited to, the following measures: a) Appoint Transportation Coordinator to oversee the TDM program developed for the project including program development, information distribution and program implementation. b) Promote and distribute hard copy information quarterly to all employees and residents regarding 511, Ridematch, Guaranteed Ride Home Program, Wheels/LAVTA, Altamont Corridor Express (ACE), BART, shuttles to regional transit, and any car share programs. c) Distribute information quarterly regarding above by email blast to all employees and residents. d) Co-sponsor subarea transportation fair once a year with “The Village” property to the north and/or other developments in the East Dublin area. Invite Wheels, 511.org, and at least two other commute alternative service providers to attend and distribute commute alternative information. e) Provide bicycle parking facilities for 20 percent of commercial car Significant and Unavoidable Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 13 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation spaces or a number approved by the City beyond the City’s bicycle rack requirement. f) Provide secured bicycle parking (lockers or cages) for employees. g) Join City Car Share as a “Biz Prime” member and pay for membership of a minimum of five percent employees. h) Implement a BART subsidy program that would provide BART tickets at no cost or subsidized rate to all employees. i) Implement a Commuter Tax Benefit Program or equivalent. Under Section 132(F) of federal tax code, an employer can offer its employees up to $245 per month for qualified transit, vanpool or parking costs. Or, an employer may offer $20 per month for bicycling costs. Full information is available at: http://rideshare.511.org/rewards/tax_benefits.aspx j) Provide preferential parking for carpools and vanpools as part of off- street parking requirements. k) Provide shading in the parking lot, to the maximum extent possible, to reduce evaporative ROG emissions. AQ-2 Air Quality. The project would result in a violation of regional air quality standard and would contribute substantially to an existing or projected air quality violation. See Implement SM-AQ-2 Significant and Unavoidable AQ-3 Air Quality. The project would conflict with the regional Clean Air Plan. See Implement SM-AQ-2 Significant and Unavoidable AQ-4 Air Quality. The project would expose sensitive receptors to excess cancer risk and PM2.5 concentrations that are above health-based thresholds. SM-AQ -3. The project shall include the following measures to minimize long-term toxic air contaminant (TAC) exposure for new residences: a. Ensure that no residential buildings would have a full year of occupancy prior to 1/1/2017. b. Design buildings and site to limit exposure from sources of TAC and fine particulate matter (PM2.5) emissions. The site layout shall locate windows and air intakes as far as possible from I-580 traffic lanes. Any modifications to the site design shall incorporate buffers between residences and the freeway. c. To the greatest degree possible, plant vegetation along the project site boundary with I-580 that includes trees and shrubs that provide a dense vegetative barrier. d. Install air filtration in residential buildings at roof top level that have Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 14 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation predicted cancer risks in excess of 10 in one million or PM2.5 concentrations above 0.3 micrograms per cubic meter (µg/m 3) as shown in Exhibit 4.7-4. The type of air filtration device shall be as set forth in subsection e below.. To ensure adequate health protection to sensitive receptors, a ventilation system shall meet the following minimal design standards (Department of Public Health, City and County of San Francisco, 2008):  At least one air exchange(s) per hour of fresh outside filtered air;  At least four air exchange(s) per hour recirculation; and  At least 0.25 air exchange(s) per hour in unfiltered infiltration. e. The type of MERV- rated filtration required to be installed as part of the ventilation system in the residential buildings shall be as follows: 1) MERV13 filtration shall be installed in a residential building partially or completed located in an area where the cancer risk is 10 per one million or greater but less than or equal to 22 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 2) MERV16 filtration shall be installed in a residential building partially or completed located in an area where the cancer risk is greater than 22 per one million and less than 50 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 3) MERV16 filtration and sealed, inoperable windows and no balconies on building elevations facing I-580 freeway (MERV 16 Plus) shall be installed in a residential building partially or completed located in an area where the cancer risk is a greater than or equal to 50 per one million and less than 62.5 per one million as shown in Exhibit 4.7-4 for unmitigated cancer risks. 4) In areas where the cancer risk is 62.5 per one million or greater, residential units shall not be built unless the developer includes specific mitigation measures that are approved by a qualified air quality consultant and the City that results in a reduction of the cancer risk to below 10 per one million. f. As part of implementing this measure, an ongoing maintenance plan for the buildings’ heating, ventilation, and air conditioning (HVAC) air filtration system shall be required. Recognizing that emissions from air pollution sources are decreasing, the maintenance period shall last as long as significant excess cancer risk or annual PM2.5 exposures are predicted. Subsequent studies may be conducted by an air quality Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 15 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation expert approved by the City to identify the ongoing need for the filtered ventilation systems as future information becomes available. g. Ensure that the lease agreement and other property documents (1) require cleaning, maintenance, and monitoring of the affected buildings for air flow leaks; (2) include assurance that new owners and tenants are provided information on the ventilation system; and (3) include provisions that fees associated with owning or leasing a unit(s) in the building include funds for cleaning, maintenance, monitoring, and replacements of the filters, as needed. h. Consider phasing developments located closest to I-580 to avoid significant excess cancer risks and required installation of filtered ventilation systems (described above). Note that new United States Environmental Protection Agency (U.S. EPA) engines standards combined with California Air Resources Board (CARB) rules and regulations will reduce on-road emissions of diesel particulate matter (DPM) and PM2.5 substantially, especially after 2014. i. Require that, prior to building occupancy, an authorized air pollutant consultant verify the installation of all necessary measures to reduce toxic air contaminant (TAC) exposure as set forth in this mitigation measure. AQ-5 Air Quality. The project would generate greenhouse gas emissions, both directly and indirectly, that would have a significant impact on the environment and would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. SM-AQ -4. The final design of the project shall include all requirements of the City Climate Action Plan, including policies A.1.4 (Bicycle Parking Requirements), A.1.5 (Streetscape Master Plan), A.1.8 (General Plan Community Design and Sustainability Element), A.1.9 (Work with LAVTA to Improve Transit), A.2.1 (Green Building Ordinance), A.2.5 (LED Streetlight Specifications), A.3.1 (Construction and Demolition Debris Ordinance), A.3.6 (Commercial Recycling). In addition, the project proponent is encouraged to participate in subsidy programs such as Climate Action Plan polices A.2.4 (Reduced Solar Installation Permit Fee) and A.3.5 (Commercial Food Waste Collection Program), and non-subsidy programs such as policies A.3.7 (Multi-Family Recycling), A.3.8 (Curbside Recycling), and A.3.9 (Curbside Organics Collection). Implementation of these mitigation measure would reduce GHG emissions, but not below the significance thresholds. The project, as a whole, shall adopt a water use reduction goal of at least 20 percent. A water use reduction plan shall be developed by the project applicant that may include measures such as the installation of low-flow water fixtures in showers and sinks, low-flush toilets, and the use of water efficient landscaping. The project applicant shall implement a solid waste recycling program through recycling and Significant and Unavoidable Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 16 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation composting strategies, which results in a project-wide solid waste diversion rate of at least 20 percent. Finally, the project shall exceed 2008 Title 24 Building Standards (which CalEEMod is based on) by at least 20 percent in terms of energy-efficiency. The project shall implement the supplemental list of greenhouse gas reduction measures included as Attachment 6 to the Final SEIR. HAZ-1 Hazards. The site has been remediated for commercial and other non-residential land uses. As a part of the site management terms that were approved when the remediation occurred in 2010, the Alameda County Department of Environmental Health (ACDEH) required that if any residential or other similar land use is proposed at the Property, the ACDEH must be notified. ACDEH will then re- evaluate the case upon receipt of approved development/construction plans. SM-HAZ-1. The Applicant/Developer shall notify ACDEH of the proposed project and the intent to utilize the site for residential uses so ACDEH can re-evaluate the case. If directed by ACDEH, a Phase II site investigation or site health risk assessment shall be completed for portions of the site anticipated for residential development and excavation prior to issuance of a grading and/or site improvement permit. The site investigation shall be coordinated with the Alameda County Department of Environmental Health. The investigation plan shall include a description of the work to be performed, the laboratory analytical methods to be uses and requirements for quality control. If additional remediation is necessary, a remediation plan shall be prepared and approved by the ACDEH. Grading or excavation of any identified contaminated residential area on the site shall not occur until ACDEH issues a closure letter authorizing residential uses on the site. The Applicant/Developer shall provide the City with documentation that the above actions have taken place. To protect the health and safety of construction workers, Health and Safety Plan that meets the federal Occupational Safety and Health Administration requirements shall be prepared and implemented if additional remediation is required. Less-than-Significant HAZ-2 Hazards. If required, construction dewatering activities could release identified accumulations of residual hydrocarbons, solvents, and other contaminants into the environment, possibly exposing construction workers, and surrounding residents and visitors during construction. SM-HAZ-2. If construction dewatering is necessary, a construction dewatering plan shall be prepared and submitted with a dewatering permit application. Reuse of groundwater as an on-site dust palliative or for soil compaction is acceptable if requisite testing and comparison to CAL-EPA screening thresholds indicate that the groundwater is suitable for reuse. If reuse is not possible, contaminated water shall be safely removed to an approved site. Groundwater removed during construction dewatering shall be treated to the extent required by the permit agency prior to discharge and the appropriate permit shall be obtained from the Regional Water Quality Control Board (RWQCB), Dublin San Ramon Services District, or other agency with jurisdiction, if the water is to be discharged into a storm or sanitary sewer system. Less-than-Significant HAZ-3 Hazards. Demolition activities could release significant quantities of lead based paint and asbestos containing SM-HAZ-3. Prior to issuance of a demolition permit for the existing on-site building, testing shall be performed by a qualified and licensed environmental professional to determine the present of significant Less-than-Significant Table 1.1 (Summary of Mitigation Measures): The Green Mixed Use Project City of Dublin August 2014 Page 17 Impact Topic/Supplemental Impact Supplemental Mitigation Measure Net Supplemental Impact After Mitigation material and other contaminants into the environment, possibly exposing construction workers, and surrounding residents and visitors during construction. quantities of lead based paint and asbestos containing material. If detected, such material shall be removed by a qualified contractor and disposed of in an approved disposal facility. Necessary permits shall be obtained from appropriate regulatory agencies prior to remediation. Attachment 3: Breeding Bird Survey Report, dated April 2014 April 22, 2014 David Clock Stockbridge/BHV Emerald Place Land Company LLC c/o Quattro Realty Group 500 La Gonda Way, Suite 295 Danville, CA 94526 Re: Breeding Bird Survey at The Green, Dublin, California Dear Mr. Clock: The purpose of this letter is to report the findings of a take avoidance survey for burrowing owl (Athene cunicularia) and breeding birds within ”The Green” site (Project Area) in Dublin, Alameda County, California. This survey was performed as a precautionary measure prior to vegetation maintenance activities such as mowing and/or disking. The survey was performed due to the presence of potential burrowing owl habitat onsite, including burrows and debris piles, and the presence of other bird nesting habitat including tall grasses, shrubs, or bare rocky ground. Project Area Description The Project Area is approximately 27.5 acres and bordered by city streets and highways on all sides, Martinelli Way to the north, Hacienda Drive to the east, Arnold Drive to the west, and Interstate 580 to the south. The Project Area is a mostly-undeveloped land parcel characterized by disturbed soil, grasses, and weeds. A single small building is located near the northern edge of the property, and this is the only building on the property. Past grading activity moved soil from some portions of the site to piles in other areas, resulting in some areas of relatively flat ground and other areas with mounds, depressions, or low man-made plateaus. Vegetation within the Project Area consists primarily of ruderal, non-native grasses and herbaceous species dominated by wild oats (Avena spp.), soft chess (Bromus hordeaceus), and common mustard (Brassica nigra) with scattered coyote bush (Baccharis pilularis) in the north- central area. A small portion of the northern Project Area was recently mowed, and other areas appear to have occasional mowing and vegetation maintenance. Methods A breeding bird survey, including a burrowing owl take avoidance survey, was conducted on April 22, 2014 by WRA wildlife biologist Patricia Valcarcel. Specifically, the survey covered all portions of the Project Area and within 250 feet of the Project Area for raptor species. The survey was conducted in the dawn and morning hours and was deemed adequate to effectively cover the surveyed area. The Project Area was traversed on foot in accordance with the Staff Report on Burrowing Owl Mitigation 1. Burrows, pipes, and other burrow surrogates were inspected for evidence of burrowing owl occupancy (feathers, whitewash, pellets, prey remains). In addition, the site was investigated for any evidence of avian territorial behavior (e.g., singing, chasing intruders out of territories, etc.), breeding bird behavior (e.g., adult birds carrying nesting material or food), or the presence of active nests and/or pre-fledged juvenile birds. Observations were made with binoculars and the naked eye. Results No burrowing owl were observed within the Project Area, nor was any evidence of burrowing owl observed within the Project Area. One active loggerhead shrike (Lanius ludovicianus) nest was observed in a coyote bush along the northern fence of the Project Area, located near the Martinelli Way gate (Attachment 1). The female was observed incubating the nest and the male was foraging in the area. Loggerhead shrike are a California Department of Fish and Wildlife Species of Special Concern. A typical buffer surrounding the nest of a special-status passerine species such as loggerhead shrike is 100 feet. Attachment 1 shows the nest location with a buffer of 100 feet. All other bird activity was limited to foraging by species commonly observed in urban and ruderal areas, and no other nesting activity was observed. Summary One active loggerhead shrike nest was observed within the surveyed area along the northern fence line of the Project Area. It is recommended that no work be performed within 100 feet of the nest (as shown on Attachment 1) until after August 31, 2014, or until it can be shown that all fledgling birds have vacated the nest and/or the nest has been abandoned. Per common breeding bird survey standards, the results of this survey are valid for 14 days from the survey date. If mowing or disking activities have not been initiated within 14 days (i.e., by May 5, 2014), a follow-up pre-construction survey is recommended to determine if any nesting has been initiated in the interim. Please do not hesitate to contact me if you have questions or comments. Sincerely, Patricia Valcarcel Wildlife Biologist Attachment: Nest Location and Buffer Area Map 1 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. State of California Natural Resources Agency, Department of Fish and Game. 2 f e e t me t e r s 10 0 0 400 At t a c h m e n t 1 . L o g g e r h e a d s h r i k e n e s t l o c a t i o n ( r e d ) an d a 10 0 - f o o t b u f f e r ( y e l l o w ) w i t h i n "T h e Gr e e n " P r o j e c t A r e a . Attachment 4: Alameda County Department of Environmental Health letter, dated June 2014 ENVIRONMENTAL HEALTH SERVICES ENVIRONMENTAL PROTECTION 1131 Harbor Bay Parkway, Suite 250 Alameda, CA 94502-6577 (510) 567-6700 FAX (510) 337-9335 June 11, 2014 Mr. Mike Parker (Sent via E-mail to: mparker@quattrorealty.com) Quattro Realty Group 500 La Gonda Way, Suite 295 Danville, CA 94526 Stephen Pilch Stockbridge/BHV Emerald Land Co., LLC 4 Embarcadero Center San Francisco, CA 94111 Subject: Work Plan Review for SLIC Case No. RO0003131 and GeoTracker Global ID T10000005547, The Green, 5411 Martinelli Way, Dublin, CA 94568 Dear Mr. Parker and Mr. Pilch: Alameda County Environmental Health (ACEH) has reviewed the Spills, Leaks, Investigations, and Cleanup (SLIC) case for the above referenced site including the document entitled, “Addendum to Workplan for Further Investigation,” dated May 28, 2014 (Work Plan Addendum). The Work Plan Addendum, which was prepared in response to technical comments in ACEH correspondence dated May 7, 2014, is an addendum to a document entitled, ““Workplan for Further Investigation,” dated April 23, 2014 (Work Plan). The proposed scope of work as modified in the Work Plan Addendum is conditionally approved and may be implemented provided that the technical comment below is addressed and incorporated during the proposed investigation. Submittal of a revised Work Plan is not required unless an alternate scope of work outside that described in the Work Plan Addendum and technical comment below is proposed. We request that you address the following technical comment, perform the proposed work, and send us the reports described below. TECHNICAL COMMENTS 1. Stockpile Soil Analysis. In addition to the proposed laboratory analyses for stockpile soil samples described in the Work Plan Addendum, we request that the stockpile soil samples also be analyzed for creosote and polycyclic aromatic hydrocarbons (PAHs) using EPA Method 8270, asbestos using polarized light microscopy, and PCBs using EPA Method 8082. Please present the results in the Site Investigation Report requested below for ACEH approval prior to reuse of the stockpiles on site. ALAMEDA COUNTY HEALTH CARE SERVICES AGENCY ALEX BRISCOE, Director Stockbridge/BHV Emerald Land Co., LLC RO0003131 June 11, 2014 Page 2 TECHNICAL REPORT REQUEST Please upload technical reports to the ACEH ftp site (Attention: Jerry Wickham), and to the State Water Resources Control Board’s GeoTracker website according to the following schedule and file-naming convention:  October 10, 2014 – Site Investigation Report File to be named: SWI_R_yyyy-mm-dd RO3131 If you have any questions, please call me at (510) 567-6791 or send me an electronic mail message at jerry.wickham@acgov.org. Case files can be reviewed online at the following website: http://www.acgov.org/aceh/index.htm. Sincerely, Jerry Wickham, California PG 3766, CEG 1177, and CHG 297 Senior Hazardous Materials Specialist Attachment: Responsible Party(ies) Legal Requirements/Obligations Enclosure: ACEH Electronic Report Upload (ftp) Instructions cc: Greg Stahl, Ground Zero Analysis, Inc., 1172 Kansas Avenue, Modesto, CA 95351 (Sent via E-mail to: gstahl@groundzeroanalysis.com) Ryan Batty, California Department of Toxic Substances Control, Sacramento, CA (Sent via E-mail to: rbatty@dtsc.ca.gov) Jerry Wickham, ACEH (Sent via E-mail to: jerry.wickham@acgov.org) GeoTracker, eFile Attachment 1 Responsible Party(ies) Legal Requirements / Obligations REPORT REQUESTS These reports are being requested pursuant to California Health and Safety Code Section 25296.10. 23 CCR Sections 2652 through 2654, and 2721 through 2728 outline the responsibilities of a responsible party in response to an unauthorized release from a petroleum UST system, and require your compliance with this request. ELECTRONIC SUBMITTAL OF REPORTS ACEH’s Environmental Cleanup Oversight Programs (LOP and SLIC) require submission of reports in electronic form. The electronic copy replaces paper copies and is expected to be used for all public information requests, regulatory review, and compliance/enforcement activities. Instructions for submission of electronic documents to the Alameda County Environmental Cleanup Oversight Program FTP site are provided on the attached “Electronic Report Upload Instructions.” Submission of reports to the Alameda County FTP site is an addition to existing requirements for electronic submittal of information to the State Water Resources Control Board (SWRCB) GeoTracker website. In September 2004, the SWRCB adopted regulations that require electronic submittal of information for all groundwater cleanup programs. For several years, responsible parties for cleanup of leaks from underground storage tanks (USTs) have been required to submit groundwater analytical data, surveyed locations of monitoring wells, and other data to the GeoTracker database over the Internet. Beginning July 1, 2005, these same reporting requirements were added to Spills, Leaks, Investigations, and Cleanup (SLIC) sites. Beginning July 1, 2005, electronic submittal of a complete copy of all reports for all sites is required in GeoTracker (in PDF format). Please visit the SWRCB website for more information on these requirements (http://www.waterboards.ca.gov/water_issues/programs/ust/electronic_submittal/). PERJURY STATEMENT All work plans, technical reports, or technical documents submitted to ACEH must be accompanied by a cover letter from the responsible party that states, at a minimum, the following: "I declare, under penalty of perjury, that the information and/or recommendations contained in the attached document or report is true and correct to the best of my knowledge." This letter must be signed by an officer or legally authorized representative of your company. Please include a cover letter satisfying these requirements with all future reports and technical documents submitted for this fuel leak case. PROFESSIONAL CERTIFICATION & CONCLUSIONS/RECOMMENDATIONS The California Business and Professions Code (Sections 6735, 6835, and 7835.1) requires that work plans and technical or implementation reports containing geologic or engineering evaluations and/or judgments be performed under the direction of an appropriately registered or certified professional. For your submittal to be considered a valid technical report, you are to present site specific data, data interpretations, and recommendations prepared by an appropriately licensed professional and include the professional registration stamp, signature, and statement of professional certification. Please ensure all that all technical reports submitted for this fuel leak case meet this requirement. UNDERGROUND STORAGE TANK CLEANUP FUND Please note that delays in investigation, later reports, or enforcement actions may result in your becoming ineligible to receive grant money from the state’s Underground Storage Tank Cleanup Fund (Senate Bill 2004) to reimburse you for the cost of cleanup. AGENCY OVERSIGHT If it appears as though significant delays are occurring or reports are not submitted as requested, we will consider referring your case to the Regional Board or other appropriate agency, including the County District Attorney, for possible enforcement actions. California Health and Safety Code, Section 25299.76 authorizes enforcement including administrative action or monetary penalties of up to $10,000 per day for each day of violation. Alameda County Environmental Cleanup Oversight Programs (LOP and SLIC) REVISION DATE: May 15, 2014 ISSUE DATE: July 5, 2005 PREVIOUS REVISIONS: October 31, 2005; December 16, 2005; March 27, 2009; July 8, 2010, July 25, 2010 SECTION: Miscellaneous Administrative Topics & Procedures SUBJECT: Electronic Report Upload (ftp) Instructions The Alameda County Environmental Cleanup Oversight Programs (LOP and SLIC) require submission of all reports in electronic form to the county’s ftp site. Paper copies of reports will no longer be accepted. The electronic copy replaces the paper copy and will be used for all public information requests, regulatory review, and compliance/enforcement activities. REQUIREMENTS  Please do not submit reports as attachments to electronic mail.  Entire report including cover letter must be submitted to the ftp site as a single portable document format (PDF) with no password protection.  It is preferable that reports be converted to PDF format from their original format, (e.g., Microsoft Word) rather than scanned.  Signature pages and perjury statements must be included and have either original or electronic signature.  Do not password protect the document. Once indexed and inserted into the correct electronic case file, the document will be secured in compliance with the County’s current security standards and a password. Documents with password protection will not be accepted.  Each page in the PDF document should be rotated in the direction that will make it easiest to read on a computer monitor.  Reports must be named and saved using the following naming convention: RO#_Report Name_Year-Month-Date (e.g., RO#5555_WorkPlan_2005-06-14) Submission Instructions 1) Obtain User Name and Password a) Contact the Alameda County Environmental Health Department to obtain a User Name and Password to upload files to the ftp site. i) Send an e-mail to deh.loptoxic@acgov.org b) In the subject line of your request, be sure to include “ftp PASSWORD REQUEST” and in the body of your request, include the Contact Information, Site Addresses, and the Case Numbers (RO# available in Geotracker) you will be posting for. 2) Upload Files to the ftp Site a) Using Internet Explorer (IE4+), go to ftp://alcoftp1.acgov.org (i) Note: Netscape, Safari, and Firefox browsers will not open the FTP site as they are NOT being supported at this time. b) Click on Page located on the Command bar on upper right side of window, and then scroll down to Open FTP Site in Windows Explorer. c) Enter your User Name and Password. (Note: Both are Case Sensitive.) d) Open “My Computer” on your computer and navigate to the file(s) you wish to upload to the ftp site. e) With both “My Computer” and the ftp site open in separate windows, drag and drop the file(s) from “My Computer” to the ftp window. 3) Send E-mail Notifications to the Environmental Cleanup Oversight Programs a) Send email to deh.loptoxic@acgov.org notify us that you have placed a report on our ftp site. b) Copy your Caseworker on the e-mail. Your Caseworker’s e-mail address is the entire first name then a period and entire last name @acgov.org. (e.g., firstname.lastname@acgov.org) c) The subject line of the e-mail must start with the RO# followed by Report Upload. (e.g., Subject: RO1234 Report Upload) If site is a new case without an RO#, use the street address instead. d) If your document meets the above requirements and you follow the submission instructions, you will receive a notification by email indicating that your document was successfully uploaded to the ftp site. Attachment 5: Ground Zero Report for Alameda County Department of Environmental Health letter, dated April 2014 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc 1172 Kansas Avenue , Suite A Modesto, CA 95351 209.522.4119 – PH 209.522.4227 - FAX groundzeroanalysis.com April 23 , 2014 Mr. Jerry Wickham Alameda County Health Care Services Agency, Environmental Health Services 1131 Harbor Bay Pa rkway, Suite 250 Alameda, CA 94502 -6577 Subject: Workplan for Further Investigation The Green , 5411 Martinelli Way, Dublin, CA SLIC Case No. RO0003131 Dear Mr. Wickham : The following Workplan is submitted by Ground Zero Analysis, Inc. (Ground Zero) on behalf of Quattro Realty Group and Stockbridge BHV Emerald Place Land Company, LLC in response to your directive letter dated January 30, 2014. The location of the subject S ite is shown on Figure 1. A site plan is shown o n Figure 2 . BACKGROUND Stockbridge BHV Emerald Place Land Company, LLC (“Stockbridge”) is the owner of the 27.45 -acre property in Du blin known as “The Green”. Stockbridge is proposing mixed-use development of the property involving construction of commercial as well as medium d ensity residential structures. The City of Dublin is the lead agency preparing a Supplement Environmental Impact Report (“SEIR”) for an amendment to the City’s General Plan allowing for the proposed development. The SEIR will contain certain mitigation measures that will require the input of the Alameda Environment al Health (“ACEH”) involving potential environmental contamination issues arising from the past use of the property. Mr. Jerry Wickham Page 2 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc Stockbridge requested that ACEH provide such regulatory oversight as is nece ssary to satisfy the mitigation measures of the SEIR. A meeting was held with ACEH on January 9 , 2014 to discuss the background of the S ite and the measures that would be necessary for ACEH to provide the requested services. On January 9, 2014, ACEH ope ned Spills, Leaks, Investigations and Cleanup (SLIC) Case No. RO0003131 for the Site. After reviewing background informa tion on Site investigations, ACEH issued the letter dated January 30, 2014 requesting a workplan to address specific technical question s. A copy of the ACEH letter is included in Appendix A. Property Information The subject Site is located at 5411 Martinelli Way in Dublin, California. Martinelli Way borders the Site to the north, Hacienda Drive borders the Site to the east, Interstate-580 borders the Site to the south and Arnold Road borders the Site to the west. The Site has an area of approximately 27.45 acres and is identified as Assessor’s Parcel Numbers (APNs) 986-033-004, 986-033-005-2 and 986-033-006. The Site is relatively flat and at an elevation of approximately 340 feet above mean sea level. The subject Site was previously occupied by a portion of the U.S. Army’s Camp Parks Reserve Forces Training Area. The subject portion of the base was closed and property ownership was transferred to Alameda County in the late 1960s. The structures on the property were demolished in the mid-1990s. The property is currently undeveloped open space, mainly covered by grasses and low weeds, with one small unoccupied structure in the north central portion of the site. Historic Site Investigations Beginning as early as 1991 and to date, numerous Phase I and Phase II investigations have been conducted on behalf of various potential developers of the Site and surrounding properties. The subject property has been referred to in several reports as “Parcel 16”. At some point prior to 2012 the portion of Parcel 16 north of Martinelli Way and south of Dublin Blvd. was severed and subsequently identified as “Parcel 16A”. Property north of Dublin Blvd, between Hacienda Drive and Arnold Road and south of Central Parkway has been referred to as “Parcel 15”. Property to the west of the Site and south of Martinelli Way has been referred to as the “Option Parcel”. These designations are shown on Figure 2. Mr. Jerry Wickham Page 3 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc A detailed summary of all investigations conducted on properties surrounding the Site is beyond the scope of this report. Investigations specific to the Site are summarized below. In 1998 Erler and Kalinowsik (E&K) conducted a soil and groundwater investigation on Parcel 16 and the Option Parcel. A geophysical survey was conducted in two areas of Parcel 16 where underground fuel storage tanks were suspected based on historical military base records: the former guard house boiler room and the former underground fuel storage depot. The fuel storage depot was located on the current Site. No tanks were found. Trenching revealed buried debris, which was removed. Grab groundwater samples from the fuel depot area detected total petroleum hydrocarbons as diesel (TPHd) at a maximum concentration of 120,000 parts per billion (ppb). Stepout borings detected low levels of TPHd in groundwater no more than 55 feet downgradient of the depot area. No benzene, toluene, ethylbenzene or xylenes (BTEX) compounds were detected. E&K collected grab groundwater samples from several borings located throughout the investigation area. Samples were analyzed for TPHd, BTEX and volatile organic compounds (VOCs). Other than a trace of xylenes in one boring, no VOCs were detected in samples collected from the current Parcel 16 and Parcel 16A. Some VOCs, including tetrachloroethene (PCE) and trichloroethene (TCE) were detected in certain borings on the Option Parcel and along the south boundary of Parcel 15. E&K also collected soil samples along the former railroad spur that traversed Parcels 16 and 16A from northwest to southeast. Samples were collected from native soil beneath the ballast at five locations, three of which were located on the subject Site. The samples were analyzed for chlorinated herbicides, selected metals and total extractable petroleum hydrocarbons (TEPH). Trace levels of TEPH were found in two samples; a trace of 2,4-DB was found in one sample; metals concentrations were at naturally-occurring background levels. In 2003, Levine-Fricke (LF) conducted limited soil sampling along the railroad spur. Four soil borings were advanced and sampled at locations generally similar to those sampled by E&K. The samples were analyzed for organochlorine pesticides (OCPs), for polychlorinated biphenyls (PCBs), for phenols and for creosote. Low levels of DDT in two of the soil samples were the only contaminants of concern detected during their investigation. Based on the results LF concluded that no further investigation was warranted in the area of the former railroad spur on the property. In 2001 Lowney and Associates and Subsurface Consultants, Inc. (SCI) investigated a former incinerator and burn pit area located along the northeast corner of the current Parcel 16. Significant analyses determined that lead was the only constituent of concern. 3,400 cubic yards of lead-contaminated soil was excavated in 2001 and transported to the Waste Management Kettleman Mr. Jerry Wickham Page 4 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc Hills facility for disposal. The case was closed by Alameda County Health Care Services Agency in 2003 as “clean-closed with no restrictions on future development”. Additional sampling was conducted by Treadwell & Rollo in 2005 which resulted in a second closure letter in December 2005 from DTSC which concluded “… the incinerator/Burn Dump at Hacienda Drive and Martinelli Drive does not appear to pose a threat to human health or the environment under a residential land use scenario.” In September 2008 during grading activities a steel underground storage tank (UST) was discovered in the southwest corner of the Site. In October 2008 the UST was removed by ADR Environmental Group (ADR) and the soil in the vicinity of the former UST was excavated. Additional remedial over -excavation and groundwater pumping was conducted in 2009 and 2010. The results of the final confirmation soil samples were non -detect for all fuel analytes. Only a de -minimus concentration of diesel was detected in the final groundwater sample. Case closure was granted for the site in September 2010. In the ir August 2013 Phase I Environmental Site Assessment report, ENGEO concluded that the presence of VOCs in soil vapor beneath the parcel located north of the subject property constitutes a Recognized Environmental Condition . ENGEO recommended, in pertinent part, the following actions: • “A soil vapor monitoring study and a human health risk assessment should be considered at the Property to…evaluate impacts due to the upgradient VOC source …” • “…it is our experience that historical use of herbicides was co mmon on former military sites: as such, it may be prudent to consider the health risk of near -surface soil at contemplated residential development areas.” A subsurface investigation conducted by Ground Zero in October 2013 wa s intend ed to address those recommendations. A total of five (5) soil borings (HAB1 through HAB5) were advanced in a rough grid pattern across the site on October 8, 2013, by a Geologist from Ground Zero. The locations of the shallow soil borings are shown on Fig ure 3. The shallow soil borings were all advanced with a hand auger and soil samples were collected at depths of approximately 1, 2 and 3 feet below grade. All soil samples collected from the depth of one foot were analyzed for chlorinated and nitrophenol herbicides by EPA Method 8151A. No herbicides were detected in any of the 1 -foot soil samples collected. In order to investigate the potential for detectable concentrations of VOCs in soil vapor, five (5) te mporary soil vapor wells (VW -1 through VW -5) were constructed in close proximity to the hand Mr. Jerry Wickham Page 5 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc auger borings on October 15, 2013 (Figure 3). Soil vapor samples were collected and analyzed for VOC s by EPA Method TO -15 . Various VOCs were detected in the vapor samples. Several fuel -related VOCs were de tected at similar concentrations a cross the site; several solvent -related VOCs were detected at similar concentrations across the site; and acetone was detected at similar concentrations across the site. The relative uniformity of the chemicals detected a nd their concentrations suggests that these are anthropogenic background levels. The concentrations of VOCs were all well below their respective residential vapor intrusion ESL and CHHSL values. The total lifetime excess risk for carcinogenic constituen ts was calculated at 4.0E -07, an order of magnitu de below the threshold level of significance of 1E -06. Similarly, the total hazard index was calculated at 7.2E-03, several orders of magnitude below the threshold level of significance of 1E+00. Results w ere reported in the Subsurface Investigation Report dated October 25, 2013. Current Status and Summary of Concerns Based on investigations conducted by Ground Zero and others, we presented our summary and conclusions regarding potential environmental c oncerns to ACEH at the January 9, 2014 meeting: 1) 1,000-gallon LUST near southwest corner of property. This was remediated by excavation (545 yards of soil) and groundwater extraction (9,240 gallons) and the case was closed by Alameda County Health Care Services Agency in September 2010 under commercial property use standards. The only residual contamination was 114 ppb TPHd in groundwater. Volatilization to indoor air would be the only potential concern and diesel is not volatile. GZA c onclusion: no further action should be necessary. Shown on Figure 4 as area “1”. 2) Contamination associated with the former fuel depot on east side of property. Erler and Kalinowski investigated potential USTs at the former fuel depot area in 1998. No USTs were found, debris was removed from the backfilled tankpit area. Groundwater samples were collected, one of which had 120,000 ppb TPHd with no associated BTEX. Stepout borings were advanced and the downgradient borings contained TPHd up to 180 ppb with no associated BTEX. No soil samples were analyzed. E&K performed a screening level risk assessment for vapor intrusion of VOCs for the site and Alameda County issued a closure letter July 10, 1998 stating that the “primary COCs in groundwater…do not pose a significant health risk…for current or proposed uses of the subject sites”. GZA conclusion: some further investigation or evaluation may be necessary. Shown on Figure 4 as area “2”. 3) Contamination associated with former burn pit on east side of property, intersection of Hacienda and Martinelli. A former incinerator and burn debris was associated with the military base. 3,400 cubic yards of lead-contaminated soil was excavated in 2001. Case was closed by Alameda County Health Care Services Agency in 2003 as “clean-closed with no restrictions on future development”. The DTSC issued a second closure letter in December 2005 which Mr. Jerry Wickham Page 6 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc concluded “… the incinerator/Burn Dump at Hacienda Drive and Martinelli Drive does not appear to pose a threat to human health or the environment under a residential land use scenario.” GZA conclusion: no further action should be necessary. Shown on Figure 4 as area “3”. 4) Question of area-wide or limited contamination with VOC vapors. E&K in 1998 found no detectable HVOCs in groundwater. GZA found low levels in soil vapor in 2013, below residential screening levels. GZA c onclusion: no further action should be necessary. Boring locations and results are shown on Figure 4. 5) Question of herbicides in shallow soil. GZA found none in 2013. GZA conclusion: this has been adequately addressed for residential development; no further action should be necessary. Sampling locations are shown on Figure 4. 6) Question of herbicides, metals, OCPS, phenols, creosote and PCBs associated with former rail spur. E&K collected samples from 5 borings in 1998 which were analyzed for herbicides, metals and hydrocarbons. Trace levels of hydrocarbons were found in two samples and a single sample contained a detectable concentration of the herbicide 2,4-DB. Levine Fricke sampled 4 borings in 2003 and analyzed for the above. All were non-detect except for DDT which was detected at a maximum concentration of 60 ppb. This is below the residential screening levels of 1,600 – 1,700 ppb. GZA conclusion: this has been adequately addressed for residential development; no further action should be necessary. Sampling locations are shown on Figure 4. In their January 2014 letter, ACEH agreed with some of these c onclusions but found that other issues required additi onal information/investigation. In particular, EHS agreed that no further investigation was necessary for the 1,000 -gallon LUST or the incinerator/burn pit area. REQUESTED INFORMATION In the directive letter, ACEH requested a workplan that addresses sp ecific data gaps regarding potential issues of concern at the site. These issues are paraphrased from the letter and addressed below. Volatile Organic Compounds in Groundwater. ACEH requested a map and table that shows the following: • The five 2013 soil vapor sampling locations collected by Ground Zero. • All grab groundwater data collected within 500 feet of the site boundary. • All soil vapor data collected within 500 feet of the site boundary. • Locations of sanitary sewer lines which could act as sources. • Former site features within Parcels 15, 16 and 16A. Mr. Jerry Wickham Page 7 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc Figure 5 depict s the locations of all groundwater and soil vapor sampling points within 500 feet of the site boundary (except to the south of Interstate 580). Underground utilities are shown on Figure 6 . Figure s 7 and 8 show the former site features associated with the former military base. All groundwater analytical data are summarized in Table 1 and all soil vapor analytical data are summarized in Table 2. Fuel Depot ACEH requested additional inv estigation to define the extent of soil and groundwater contamination in the Fuel Depot area. Previous investigation by E&K in 1998 indicated that groundwater contamination by medium chain petroleum hydrocarbons (i.e. diesel or fuel oil range) extended no more than 55 feet to the southwest of the former fuel depot UST installation (Figure 4) No soil samples were collected. To further investigate the extent of soil and groundwater contamination, we will utilize a direct -push drill rig to sample at the a pproximate locations shown on Figure 9. Soil samples will be collected in acetate sleeves at five -foot intervals to total depth which is estimated to be just below the water table or approximately 12 -15 feet below grade. Groundwater samples wil l be colle cted from each boring using a Hydropunch or similar discrete sampling equipment. Samples will be screening in the field for evidence of contamination using a photoionization detector. Selected samples will be submitted to a state -certified laboratory for analysis of total extractable petr oleum hydrocarbons (TEPH) by EPA Method 8015M and for benzene, toluene, ethylbenzene and xylenes (BTEX) by EPA Method 8021B. Railroad Spur ACEH requested the following: • Description of whether rails, ties and ballast r emain at the site. • Description of the extent of grading along the railroad spur. • Summary of results of previous investigations along the railroad spur. • Sampling of railroad ballast if it remains or adjacent soil if it does not remain. A site inspection wa s conducted on April 19, 2014 No evidence of t he former rail spur was found. The area has been smooth -graded with no sign of ballast, ties, etc. Previous soil sampling locations are shown on Figure 4. Previous analytical results for samples collected a long the spur are summarized in Table 3. Mr. Jerry Wickham Page 8 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc We will collect shallow soil samples adjace nt to the former spur along three transects as shown on Figure 9. Samples will be collected from locations approximately 10 feet and 20 feet either side of the former spu r from a depth of approximately 2 feet. The samples will be analyzed for CAM -17 metals, total oil and grease, creosote and PCBs by the appropriate EPA Methods. Site Grading and Stockpiles ACEH requested a description of the sampling or removal actions t hat will be undertaken. Recent historical aerial photos on Google Earth indicate that several grading events occurred between 2007 and 2009 (Attachment B). Currently one large soil stockpile and a smaller gravel stockpile are located on the site as shown on Figure 9. We will collected a composite sample from the soil stockpile and from the gravel stockpile. The samples will be analyzed for TPHg, TEPH, VOCs, OCPs and CAM -17 metals by the appropriate EPA laboratory Methods. Herbicides /Metals ACEH reque sted that the 2013 GZA herbicide sampling locations also be analyzed for metals. Shallow soil samples will be collected at locations duplicating the previous GZA herbicide sampling locations and will be analyzed for CAM -17 metals using EPA Method 6010. Environmental Concern from Phase I Report ACEH requested a discussion of the area of discolored soil that was observed east of the existing structure and whether sampling has or will be conducted. On April 19, 2014 a small area east of the structure was o bserved to retain some water from previous storm events. The mud was dark -colored but did not appear to have any unusual discoloration. We do not see a need to sample this area. Transformers ACEH requested information on whether any electrical transfor mers were previously present at the site. Transformers presumably were present at the site during its use as a military base. We have no specific information concerning the number, location or specifications of historical transformers nor do we know of a ny potential sources of this information. Mr. Jerry Wickham Page 9 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc Well Along Western Boundary of Site ACEH requeste d our future plans for this well. Stockbridge intends to properly destroy this well under permit prior to site development. REFERENCES ACEH, 1998, Letter to Rod Frietag, Alameda County GSA, re no further action required, Parcel 16 and Option Parcel, July 10, 1998 ACEH, 2003, Letter to Jeri Ram, City of Dublin re closure of burn pit, January 31, 2003 ACEH, 2010, Letter to Brad Blake, Stockbridge, re closure of u nderground storage tank case, September 3, 2010 ADR Environmental Group, Inc., 2008, Tank Closure Report for The Green on Park Place , October 29, 2008 ADR Environmental Group, Inc., 2009, Remedial Soil Excavation and Sampling Data Report for The Green o n Park Place , July 31, 2009. CA DTSC, 2005, Letter to Karen Moroz, ACEH regarding burn pit closure, December 5, 2005 ENGEO, Inc ., 2013, Phase I Environmental Site Assessment , The Green – General Plan Amendment Study, APNs 986 -033 -004, 986 -033 -005 -2 and 9 86 -033 -006, August 2, 2013. Erler & Kalinowsi, Inc., 1998, Results of Soil and Groundwater Investigations and Screening Human Health Risk Assessment for Properties Located at Hacienda Drive and Dublin Boulevard, June 19, 1998 Ground Zero Analysis, Inc. 2 013, Subsurface Investigation Report, The Green, 5411 Martinelli Way, Dublin, CA, October 25, 2013 Levine -Fricke, 2003, Limited Soil Sampling and Analysis Program , October 9, 2003 Strata Environmental , 2007 , Phase I Environmental Site Assessment , Emeral d Place, Hacienda Drive and Martinelli Way, February 2007 Mr. Jerry Wickham Page 11 of 11 G:\Data\GROUNDZE \STOCKBRIDGE THE GREEN\REPORTS\SECOND PHASE\Final Workplan.doc Appendices Appendix A – AC EHS Directive Letter (01/09/14) Appendix B – Recent Historical Aerial Photos from Google Earth cc: Mr. David Clock, Quattro Realty FIGURES 1 2 3 ND 12 0 , 0 0 0 <4 0 NT <5 0 <0 . 5 NT <5 0 <0 . 5 NT 11 0 <0 . 5 NT <2 0 0 <0 . 5 NT 18 0 <0 . 5 NDND6.6 Xyle n e s NDNDND NDNDND VO C s TP H - D BT E X 1, 2 , 3 1 2 3 1, 2 , 3 TABLES TA B L E 1 Gr o u n d w a t e r A n a l y t i c a l R e s u l t s Th e G r e e n 54 1 1 M a r t i n e l l i W a y Du b l i n , C A (i n p p b ) Pa g e 1 o f 3 Da t e S a m p l e I D T P H g T P H d T P H m o B e n z e n e T o l u e n e E t h y l b e n z e n e X y l e n e s M T B E P C E T C E Ca r b o n Te t r a c h l o r i d e Chloroform Fe b . 1 9 9 8 P - 1 - - 12 0 - - <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 P- 2 -- 6 9 - - <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 P- 3 -- <5 0 -- <2 < 2 < 2 < 2 - - 83 <2 < 2 < 2 P- 4 -- <5 0 -- <2 < 2 < 2 < 2 - - 10 0 4 . 2 <2<2 P- 5 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 P- 6 -- <5 0 -- <2 < 2 < 2 6. 6 -- < 2 < 2 < 2 < 2 P- 7 -- 1 2 0 , 0 0 0 - - <4 0 < 4 0 < 4 0 < 2 - - < 4 0 < 4 0 < 4 0 < 4 0 Ap r . 1 9 9 8 P - 8 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 P- 9 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 P- 1 0 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 1 -- 9 2 - - <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 2 -- 9 6 - - <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 3 -- 5 7 - - <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 4 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 5 -- <5 0 -- <2 < 2 < 2 < 2 - - 29 5 <2<2 OA - 6 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 OA - 7 -- <5 0 -- <2 < 2 < 2 < 2 - - < 2 < 2 < 2 < 2 FD - 1 < 5 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - FD - 2 < 2 0 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - FD - 3 < 5 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - FD - 4 < 5 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - FD - 5 < 5 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - Er l e r & K a l i n o w s k i 1 9 9 8 FD - 6 < 5 0 -- <2 < 2 < 2 < 2 - - - - - - - - - - FD - 7 11 0 - - <2 < 2 < 2 < 2 - - - - - - - - - - FD - 8 18 0 - - <2 < 2 < 2 < 2 - - - - - - - - - - Oc t . 2 0 0 0 E B - 8 < 5 0 50 0 <1 , 3 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 < 5 . 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 EB - 9 < 5 0 72 0 <1 , 2 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 < 5 . 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 EB - 2 0 < 5 0 63 <5 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 - - 12 0 <0 . 5 < 0 . 5 < 0 . 5 EB - 2 1 < 5 0 51 <5 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 - - < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 EB - 2 2 < 5 0 83 <5 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 - - < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 EB - 2 3 < 5 0 53 <5 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 - - < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 EB - 2 4 < 5 0 88 <5 0 0 < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 - - < 0 . 5 < 0 . 5 < 0 . 5 < 0 . 5 Lo w n e y A s s o c i a t e s 2 0 0 0 TA B L E 1 Gr o u n d w a t e r A n a l y t i c a l R e s u l t s Th e G r e e n 54 1 1 M a r t i n e l l i W a y Du b l i n , C A (i n p p b ) Pa g e 2 o f 3 Da t e S a m p l e I D T P H g T P H d T P H m o B e n z e n e T o l u e n e E t h y l b e n z e n e X y l e n e s M T B E P C E T C E Ca r b o n Te t r a c h l o r i d e Chloroform 20 1 1 K - 1 1 - - 62 0 1 , 6 0 0 6 . 5 <0 . 5 K- 1 4 - - 89 <2 5 0 37 2 . 9 K- 1 5 - - < 5 0 < 2 5 0 < 0 . 5 < 0 . 5 K- 1 6 - - < 5 0 < 2 5 0 9. 0 0 . 6 7 K- 1 7 - - 84 <2 5 0 3. 9 <0 . 5 K- 1 8 - - < 5 0 < 2 5 0 < 0 . 5 < 0 . 5 K- 1 9 - - 96 0 7 7 0 <0 . 5 < 0 . 5 K- 2 0 - - 20 0 4 5 0 <0 . 5 < 0 . 5 K- 2 1 - - < 5 0 < 2 5 0 20 . 6 2 K- 2 2 - - < 5 0 < 2 5 0 19 1 . 5 K- 2 3 - - < 5 0 < 2 5 0 11 1 K- 1 0 6 - - - - - - 2. 7 0 . 5 1 K- 1 0 5 - - - - - - 7. 1 0 . 5 8 K- 1 0 4 - - 13 0 9 2 0 7 . 7 0 . 8 K- 1 0 3 - - < 5 0 < 2 5 0 41 1 . 5 K- 1 0 2 - - 64 3 4 0 4 4 1 . 8 K- 1 0 1 - - 67 <2 5 0 45 1 . 9 Au g . 2 0 1 2 S B - 1 - - 98 2 0 0 -- - - - - - - - - - - - - - - - - SB - 2 - - 76 1 4 0 -- - - - - - - - - - - - - - - - - SB 3 <6 2 <1 2 0 Kl e i n f e l d e r 2 0 1 1 Te r r a p h a s e 2 0 1 2 SB -3 -- <6 2 <1 2 0 -- - - - - - - - - - - - - - - - - SB - 3 D - - < 5 2 < 1 0 0 - - - - - - - - - - - - - - - - - - SB - 4 - - < 6 2 < 1 2 0 - - - - - - - - - - - - - - - - - - SB - 5 - - 93 35 0 - - - - - - - - - - - - - - - - - - SB - 6 - - 13 0 2 1 0 -- - - - - - - - - - - - - - - - - SB - 7 - - 19 0 3 6 0 -- - - - - - - - - - - - - - - - - GG W - 1 - - < 5 2 < 1 0 0 - - - - - - - - - - - - - - - - - - GG W - 2 - - < 5 2 < 1 0 0 - - - - - - - - - - - - - - - - - - TA B L E 1 Gr o u n d w a t e r A n a l y t i c a l R e s u l t s Th e G r e e n 54 1 1 M a r t i n e l l i W a y Du b l i n , C A (i n p p b ) Pa g e 3 o f 3 Da t e S a m p l e I D T P H g T P H d T P H m o B e n z e n e T o l u e n e E t h y l b e n z e n e X y l e n e s M T B E P C E T C E Ca r b o n Te t r a c h l o r i d e Chloroform Ma r . 2 0 1 2 C P T - 1 < 5 0 11 0 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 2 < 5 0 86 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 3 < 5 0 53 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 4 31 0 8 8 -- < 2 . 5 < 2 . 5 < 2 . 5 < 5 . 0 41 0 -- - - - - - - No v . 2 0 1 2 C P T - 5 < 5 0 59 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 6 < 5 0 54 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 7 < 5 0 < 5 4 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - CP T - 8 < 5 0 < 5 0 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - MW - 1 < 5 0 97 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - MW - 2 < 5 0 < 4 8 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - - - - - MW - 3 < 5 0 58 -- < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - MW - 4 < 5 0 < 4 8 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 < 0 . 5 - - - - MW - 5 10 0 <4 8 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 96 -- - - MW - 6 < 5 0 < 5 0 - - < 0 . 5 < 0 . 5 < 0 . 5 < 1 . 0 1. 7 -- - - No t e s : pp b = P a r t s p e r b i l l i o n ( m i c r o g r a m s p e r l i t e r ) TP H g = T o t a l p e t r o l e u m h y d r o c a r b o n s a s g a s o l i n e TP H d = T o t a l p e t r o l e u m h y d r o c a r b o n s a s d i e s e l TP H m o = T o t a l p e t r o l e u m h y d r o c a r b o n s a s m o t o r o i l MT B E = M e t h y l t e r t b u t y l e t h e r Co n e s t o g a R o v e r s S h e l l S t at i o n I n v e s t i g a t i o n PC E = T e t r a c h l o r o e t h e n e TC E = T r i c h l o r o e t h e n e < = L e s s t h a n i n d i c a t e d d e t e c t i o n l i m i t ( n o t - d e t e c t e d ) -- = N o t a n a l y z e d ND = N o t d e t e c t e d TA B L E 2 So i l V a p o r A n a l y t i c a l R e s u l t s Th e G r e e n 54 1 1 M a r t i n e l l i W a y Du b l i n , C A Da t e S a m p l e I D He (% ) Be n z e n e T o l u e n e E t h y l b e n z e n e X y l e n e s A c e t o n e A c r o l e i n B r o m o m e t h a n e M E K Ca r b o n Di s u l f i d e Et h a n o l Et h y l Ac e t a t e 4- E t h y l t o l u e n e 2 - H e x a n o n e M I B K P C E 1 , 2 , 4 - T M B 1 , 3 , 5 - T M B 8/ 2 0 / 2 0 1 2 S G - 1 N D 6. 2 3 . 5 ND 5. 6 3 0 ND N D 4. 3 7 . 6 ND N D < 2 . 0 1. 7 <1.6200NDND SG - 2 N D 7. 4 <4 . 4 N D < 1 5 < 5 . 5 N D N D < 6 . 8 8. 2 ND N D < 5 . 7 < 4 . 8 < 4 . 8 23NDND SG - 3 N D 7. 5 <3 . 3 N D < 1 1 . 6 23 ND N D < 5 . 2 23 ND N D < 4 . 4 < 3 . 6 < 3 . 6 14NDND SG - 4 N D 2. 9 1 7 ND 5. 2 4 2 ND N D 4. 3 6 . 4 ND N D < 2 . 0 1. 9 <1.610NDND SG - 5 N D 3. 9 2 . 9 ND 10 . 5 4 3 ND N D 7. 5 <4 . 3 N D N D 3. 5 3 . 2 3 . 6 3 7 NDND SG - 6 N D 11 4 . 6 ND 15 . 9 1 7 ND N D < 6 . 0 76 ND N D < 5 . 0 < 4 . 1 < 4 . 1 7.0NDND SG - 7 N D 3. 0 <1 . 5 N D < 5 . 2 18 ND N D 3. 5 <2 . 5 N D N D < 2 . 0 1. 6 <1.6<2.7NDND 10 / 1 5 / 1 3 V W - 1 0. 0 2 7 3 . 0 1 8 5 . 2 2 8 2 7 0 <0 . 2 3 8. 6 7 6 5 . 2 <9 6 < 1 . 8 3. 2 <2 . 1 8.6<3.410<2.5 VW - 2 0. 0 0 6 1 2 4 2 1 1 5 2 1 1 0 8 . 0 4 . 9 <7 5 < 1 . 6 < 9 6 3. 3 3 . 2 2 . 6 2 6 <3.49.84.3 VW - 3 0. 3 1 3 . 7 9 . 4 <2 . 2 < 6 . 6 87 7 . 5 <2 . 0 < 7 5 < 1 . 6 10 0 5 . 6 <2 . 5 3. 2 2 2 4 . 5 <2.5<2.5 VW - 4 < 0 . 0 0 5 2. 9 3 0 7 . 2 3 3 1 5 0 1 0 4 . 8 <7 5 < 1 . 6 14 0 2 . 6 <2 . 5 < 2 . 1 4.2<3.47.53.3 VW - 5 < 0 . 0 0 5 9. 4 7 5 1 7 7 8 1 6 0 <1 2 < 2 . 0 < 7 5 < 1 . 6 < 9 6 2. 5 4 . 4 2 . 4 2 1 <3.4156.4 VW - 5 D U P 0. 0 5 9 . 5 7 5 1 7 7 9 1 6 0 <1 2 11 <7 5 < 1 . 6 < 9 6 3. 2 5 . 0 3 . 1 2 1 <3.4166.3 ES L - - - - 42 16 0 , 0 0 0 4 9 0 5 2 , 0 0 0 1 6 , 0 0 0 , 0 0 0 - - 2 , 6 0 0 2 , 6 0 0 , 0 0 0 - - - - - - - - - - 1 , 6 0 0 , 0 0 0 2 1 0 - - - - CH H S L - - - - 36 14 0 , 0 0 0 4 2 0 3 2 0 , 0 0 0 - - - - - - - - - - - - - - - - - - - - 1 8 0 - - - - No t e s : Re s u l t s i n m i c r o g r a m s p e r c u b i c m e t e r ( u g / m 3 ) e x c e p t H e l i u m i n p e r c e n t He = H e l i u m ME K = M e t h y l e t h y l k e t o n e ( 2 - B u t a n o n e ) MI B K = M e t h y l i s o b u t y l k e t o n e ( 4 - M e t h y l - 2 - p e n t a n o n e ) PC E = T e t r a c h l o r o e t h e n e 1, 2 , 4 - T M B = 1 , 2 , 4 - T r i m e t h y l b e n z e n e 1, 3 , 5 - T M B = 1 , 3 , 5 - T r i m e t h y l b e n z e n e Gr o u n d Z e r o A n a l y s i s O c t o b e r 2 0 1 3 Te r r a p h a s e A u g u s t 2 0 1 2 ES L = E n v i r o n m e n t a l S c r e e n i n g L e v e l f o r S o i l G a s t o R e s i d e n t i a l I n d o o r A i r ( R W Q C B , R e g i o n 2 , M a y 2 0 1 3 ) CH H S L = C a l i f o r n i a H u m a n H e a l t h S c r e e n i n g L e v e l f o r S o i l G a s t o R e s i d e n t i a l I n d o o r A i r , B u i l d i n g s C o n s t r u c t e d w i t h o u t E n g i n e e r e d F i l l ( O E H H A , S e p t . 20 1 0 ) < = L e s s t h a n i n d i c a t e d d e t e c t i o n l i m i t ( n o t - d e t e c t e d ) -- = N o p u b l i s h e d s c r e e n i n g l e v e l ND = N o t d e t e c t e d TA B L E 3 Ra i l S p u r S o i l A n a l y t i c a l R e s u l t s Th e G r e e n 54 1 1 M a r t i n e l l i W a y Du b l i n , C A (i n p p m ) Da t e S a m p l e I D C r e o s o t e P h e n o l s D D T O t h e r O C P s 2 , 4 - D B Ot h e r He r b i c i d e s TE P H A s C d C r C u P b N i Z n 2/ 2 6 / 1 9 9 8 R R - 1 - - -- - - -- 0. 0 5 1 ND < 1 . 0 40 . 1 7 3 2 2 8 6 . 3 3 4 5 2 RR - 2 - - -- -- - - < 0 . 0 4 0 N D < 1 . 0 4. 2 0 . 0 8 7 3 1 2 6 7 . 2 3 3 4 7 RR - 3 - - -- -- - - < 0 . 0 4 0 N D < 1 . 0 3.4 0 . 0 9 2 5 2 0 6 3 0 3 9 RR - 4 - - -- - - -- < 0 . 0 4 0 N D 2. 9 1 5 0 . 0 8 3 2 7 3 7 7 . 2 3 3 5 4 RR - 5 - - -- - - -- < 0 . 0 4 0 N D 6. 6 3 . 4 0 . 0 9 1 2 7 2 2 7 3 4 4 4 09 / 1 6 / 1 3 I K H A 0 0 1 N D N D < 0 . 0 1 7 N D -- - - - - - - - - - - - - - - - - - - IK H A 0 0 2 N D N D 0. 0 6 0 ND -- - - - - - - - - - - - - - - - - - - IK H A 0 0 3 N D N D 0. 0 0 3 7 ND -- - - - - - - - - - - - - - - - - - - IK H A 0 0 4 N D N D < 0 . 0 3 3 N D -- - - - - - - - - - - - - - - - - - - No t e s : pp m = P a r t s p e r m i l l i o n ( m g / k g ) OC P s = O r g a n o c h l o r i n e p e s t i c i d e s TE P H = T o t a l e x t r a c t a b l e p e t r o l e u m h y d r o c a r b o n s As = A r s e n i c Cd = C a d m i u m Cr = C h r o m i u m Cu = C o p p e r Pb = L e a d Ni = N i c k e l Zn = Z i n c Le v i n e - F r i c k e S e p t e m b e r 2 0 0 3 Er l e r & K a l i n o w s k i F e b r u a r y 1 9 9 8 -- = N o t a n a l y z e d < = L e s s t h a n i n d i c a t e d d e t e c t i o n l i m i t ( n o t d e t e c t e d ) ND = N o t d e t e c t e d ( m u l t i p l e a n a l y t e s ) APPENDIX A REGULATORY CORRESPONDENCE ENVIRONMENTAL HEALTH SERVICES ENVIRONMENTAL PROTECTION 1131 Harbor Bay Parkway, Suite 250 Alameda, CA 94502-6577 (510) 567-6700 FAX (510) 337-9335 January 30, 2014 Mr. Mike Parker (Sent via E-mail to: mparker@quattrorealty.com) Quattro Realty Group 500 La Gonda Way, Suite 295 Danville, CA 94526 Subject: Case File Review for SLIC Case No. RO0003131 and GeoTracker Global ID T10000005547, The Green, 5411 Martinelli Way, Dublin, CA 94568 Dear Mr. Parker: Alameda County Environmental Health (ACEH) has opened a Spills, Leaks, Investigations, and Cleanup (SLIC) case for the above referenced site in order to review the proposed development of the site. A mix of residences and commercial development is currently planned for the 27-acre site. One of the supplemental mitigation measures presented in the Environmental Impact Report for the development requires that the Applicant/Developer notify ACEH of the proposed project and the intent to utilize the site for residential uses. If directed by ACEH, a site investigation or health risk assessment shall be completed prior to commencement of construction. Our review of the case file, which is described in the Technical Comments below, has identified several issues that need to be addressed in order to complete assessment of the site. Therefore, we request that you submit a Work Plan by March 31, 2014 that addresses the technical comments below. REQUEST FOR INFORMATION We request that you submit copies of any reports you have documenting additional investigation activities or other work that are relevant to the environmental site conditions and not currently in ACEH case files. This includes Phase I environmental site assessment reports and site investigations conducted for potential real estate transactions. ACEH case files may be reviewed online using the ACEH website (http://www.acgov.org/aceh). Specific relevant reports that appear to be missing from ACEH case files include the following: ADR Environmental Group, Inc., Phase I Environmental Site Assessment for the Future Emerald Place Property, April 15, 2006. Levine Fricke, Due Diligence Environmental Review, Commerce One Parcel, Hacienda Drive and Interstate 580, Dublin, CA, May 20, 2003. Levine Fricke, Limited Soil Sampling and Analysis Program, Commerce One Parcel, Hacienda Drive and Interstate 580, Dublin, CA, October 9, 2003. Terraphase, Phase II Site Investigation Report, Parcel 16A Southwest Corner of Dublin Boulevard and Hacienda Drive, Dublin, California, September 12, 2012. ALAMEDA COUNTY HEALTH CARE SERVICES AGENCY ALEX BRISCOE, Director Quattro Realty Group RO0003131 January 30, 2014 Page 2 Treadwell & Rollo, Phase I Environmental Site Assessment Proposed IKEA Store Development, Interstate 580 and Hacienda Drive, April 9, 2004. 5411 ma Treadwell & Rollo, Soil Sampling and Chemical analysis, Martinelli Way at hacienda Drive, IKEA – Dublin Off-site Development, Dublin, California, October 31, 2005. TECHNICAL COMMENTS 1. Underground Storage Tank Removed in 2008. On September 5, 2008, a 1,100-gallon steel underground storage tank (UST) was discovered during grading activities near the southwest corner of the site. The UST was removed on September 30, 2008. After removal of the UST, observations and confirmation soil sampling indicated that elevated concentrations of petroleum hydrocarbons were present in soils outside the excavation. Fuel leak case RO0002993 was opened by ACEH in February 2009. Tank pit soil overexcavation was conducted in May 2009. Further excavation in the southwestern portion of the excavation was conducted in September and October 2009 along with pumping of water from the excavation. The tank pit water sample collected in October 2009 detected TPH as gasoline and TPH as diesel at concentrations of 109 and 42,300 micrograms per liter (µg/L), respectively. Additional pumping of groundwater from the tank pit was conducted in November 2009. Following the pumping in November 2009, a grab groundwater sample was collected from the tank pit. TPH as diesel was detected at a concentration of 114 µg/L in the tank pit groundwater sample. Fuel leak case RO0002993 was closed by ACEH with a site management requirement that ACEH will re-evaluate the case if a change in land use to any residential or other conservative land use scenario is proposed. Residential land use is currently proposed for the site. ACEH has reviewed the case and evaluated site conditions under the framework of the State Water Resources Control Board Low-threat Closure Policy. Site conditions in the area of the former UST appear to meet the criteria for unrestricted use. ACEH is not requesting further work in the area of the former UST in the southwestern portion of the site at this time. 2. Volatile Organic Compounds in Groundwater. Volatile organic compounds (VOCs) were detected at concentrations up to 100 µg/L in grab groundwater samples collected north of the site in 1998. The source of the VOCs was not identified but was suspected to be within Parcel 15 north of the site. Potential sources within Parcel 15 included two gasoline service station, a public works shop, and a laundry. In order to help assess whether VOCs in groundwater may pose a risk for the site, soil vapor samples were collected in a grid pattern from five locations by Ground Zero Analysis in 2013. VOCs were not detected in the five soil vapor samples at concentrations above relevant screening levels. In order to provide further information with regard to the location of the potential VOC sources and the five soil vapor samples collected at the site, we request that you present a map and table in the Work Plan requested below that shows the following:  The five 2013 soil vapor sampling locations collected by Ground Zero Analysis.  All grab groundwater data collected within 500 feet of the site boundary including but not restricted to data collected by Erler & Kalinowski in 1998, Versar in 1998, or Terraphase in 2012.  All soil vapor data collected within 500 feet of the site boundary including but not restricted to data collected by Erler & Kalinowski in 1998, Versar in 1998, or Terraphase in 2012. Quattro Realty Group RO0003131 January 30, 2014 Page 3  Locations of sanitary sewer lines which could act as sources.  Former site features within Parcels 15, 16, or 16A. 3. Fuel Depot. Further investigation of the Fuel Depot Area is necessary. On April 15, 1998, trenches were excavated to remove buried debris in the Fuel Depot Area as described in the Erler & Kalinowski June 19, 1998 report entitled, “Results of Soil and Groundwater Investigations and Screening Human Health Risk Assessment.” The trenches were backfilled with removed soil and “track-walked” for compaction. However, no soil samples were collected to define the extent of contamination within the tank pit. It is also not clear whether all debris was removed from the area. Grab groundwater samples were collected from 25-foot deep boreholes to evaluate the extent of groundwater contamination. Based on the results of the groundwater sampling, Erler & Kalinowski Report concluded that diesel fuel in groundwater was limited to the immediate vicinity of the fuel storage depot. The extent of soil contamination in the Fuel Depot area remains undefined. In the Work Plan requested below, please propose additional investigation to define the extent of soil and groundwater contamination in the Fuel Depot area. 4. Railroad Spur. Further investigation of the railroad spur appears to be necessary to evaluate whether railroad operations affected the near surface soils. Results from five soil borings along the railroad spur are presented in the Erler & Kalinowski June 19, 1998 report entitled, “Results of Soil and Groundwater Investigations and Screening Human Health Risk Assessment.” The borings extended to a depth of 6 to 9 feet with one soil sample collected at the interface between gravel fill (possibly railroad ballast) and first encountered soil (approximately 3.5 to 5.5 feet bgs). No soil samples appear to have been collected from near-surface soils. The extent of grading or removal of the railroad spur since 1998 is not clear. In the Work Plan requested below, we request the following:  Description of the whether rails, rail ties, and ballast still remain at the site.  Description of the extent of grading that appears to have been conducted along the railroad spur.  Summary of results from previous investigations along the railroad spur.  If the railroad ballast remains on site, sampling of the railroad ballast will be required to evaluate for heavy metals such as lead, which was used in rail car bearings, heavy aliphatic petroleum hydrocarbons, creosote, and PCBs.  If the ballast has been or will be removed, sampling of the near surface soils adjacent to the ballast will be required.  Please propose soil sampling and analysis as appropriate to evaluate the former railroad spur. 5. Incinerator. An incinerator was formerly located in the northeastern corner of the site. In 2001, approximately 3,400 cubic yards of burn waste and impacted fill was removed from the site and disposed at the Chemical Waste management facility in Kettleman Hills, CA. In correspondence dated December 5, 2005, the California Department of Toxic Substances concluded that the site does not appear to pose a threat to human health and the environment under a residential land use scenario. Based on the DTSC evaluation, no further investigation of the Incinerator area is requested at this time. Quattro Realty Group RO0003131 January 30, 2014 Page 4 6. Site Grading and Stockpiles. Site grading and stockpiling has been conducted at various times on this site. Since the grading and stockpiling has not been well documented, some investigation of the source of the stockpiled material may be necessary. In the Work Plan requested below, please describe the sampling and/or removal actions that will be undertaken for the soil stockpiles at the site. 7. Herbicides. The Phase I Environmental Site Assessment dated August 2, 2013 and prepared by Engeo Incorporated, recommended sampling of near-surface soils for herbicides within areas of proposed residential development. During the 2013 investigation by Ground Zero Analysis, soil samples were collected at a depth of 1 feet bgs from hand auger borings near five soil vapor sampling locations and were analyzed for chlorinated and nitrophenol herbicides. Herbicides were not reported at concentrations above relevant screening criteria. However, the soil samples were only analyzed for herbicides and not other constituents of concern such as metals are frequently detected in areas where chemical have been applied for weed control. The lack of metals data appears to be a data gap. In the Work Plan requested below, we request that you propose soil sampling with metals analysis for near-surface soil samples to address this data gap, 8. Environmental Concern from Phase I Report. The Phase I Environmental Site Assessment dated August 2, 2013 and prepared by Engeo Incorporated, recommended sampling of discolored soil that was observed east of the existing structure on the site. Please discuss this area in the Work Plan and whether sampling has been or will be conducted for this area. 9. Transformers. Please indicate whether any electrical transformers were previously present at the site. 10. Well Along Western Boundary of Site. One well was observed along the western property boundary as described in the Engeo “Phase I Environmental Site Assessment,” dated August 2, 2013. In the Work Plan requested below, please describe future plans to investigate, utilize, and/or destroy this well. TECHNICAL REPORT REQUEST Please submit technical reports to Alameda County Environmental Health (Attention: Jerry Wickham), according to the following schedule:  March 31, 2014 – Work Plan Quattro Realty Group RO0003131 January 30, 2014 Page 5 If you have any questions, please call me at (510) 567-6791 or send me an electronic mail message at jerry.wickham@acgov.org. Case files can be reviewed online at the following website: http://www.acgov.org/aceh/index.htm. Sincerely, Jerry Wickham, California PG 3766, CEG 1177, and CHG 297 Senior Hazardous Materials Specialist Attachment: Responsible Party(ies) Legal Requirements/Obligations Enclosure: ACEH Electronic Report Upload (ftp) Instructions cc: Greg Stahl, Ground Zero Analysis, Inc., 1172 Kansas Avenue, Modesto, CA 95351 (Sent via E-mail to: gstahl@groundzeroanalysis.com) Ryan Batty, California Department of Toxic Substances Control, Sacramento, CA (Sent via E-mail to: rbatty@dtsc.ca.gov) Jerry Wickham, ACEH (Sent via E-mail to: jerry.wickham@acgov.org) GeoTracker, eFile Attachment 1 Responsible Party(ies) Legal Requirements/Obligations REPORT/DATA REQUESTS These reports/data are being requested pursuant to Division 7 of the California Water Code (Water Quality), Chapter 6.7 of Division 20 of the California Health and Safety Code (Underground Storage of Hazardous Substances), and Chapter 16 of Division 3 of Title 23 of the California Code of Regulations (Underground Storage Tank Regulations). ELECTRONIC SUBMITTAL OF REPORTS ACEH’s Environmental Cleanup Oversight Programs (Local Oversight Program [LOP] for unauthorized releases from petroleum Underground Storage Tanks [USTs], and Site Cleanup Program [SCP] for unauthorized releases of non-petroleum hazardous substances) require submission of reports in electronic format pursuant to Chapter 3 of Division 7, Sections 13195 and 13197.5 of the California Water Code, and Chapter 30, Articles 1 and 2, Sections 3890 to 3895 of Division 3 of Title 23 of the California Code of Regulations (23 CCR). Instructions for submission of electronic documents to the ACEH FTP site are provided on the attached “Electronic Report Upload Instructions.” Submission of reports to the ACEH FTP site is in addition to requirements for electronic submittal of information (ESI) to the State Water Resources Control Board’s (SWRCB) Geotracker website. In April 2001, the SWRCB adopted 23 CCR, Division 3, Chapter 16, Article 12, Sections 2729 and 2729.1 (Electronic Submission of Laboratory Data for UST Reports). Article 12 required electronic submittal of analytical laboratory data submitted in a report to a regulatory agency (effective September 1, 2001), and surveyed locations (latitude, longitude and elevation) of groundwater monitoring wells (effective January 1, 2002) in Electronic Deliverable Format (EDF) to Geotracker. Article 12 was subsequently repealed in 2004 and replaced with Article 30 (Electronic Submittal of Information) which expanded the ESI requirements to include electronic submittal of any report or data required by a regulatory agency from a cleanup site. The expanded ESI submittal requirements for petroleum UST sites subject to the requirements of 23 CCR, Division, 3, Chapter 16, Article 11, became effective December 16, 2004. All other electronic submittals required pursuant to Chapter 30 became effective January 1, 2005. Please visit the SWRCB website for more information on these requirements. (http://www.waterboards.ca.gov/water_issues/programs/ust/electronic_submittal/) PERJURY STATEMENT All work plans, technical reports, or technical documents submitted to ACEH must be accompanied by a cover letter from the responsible party that states, at a minimum, the following: "I declare, under penalty of perjury, that the information and/or recommendations contained in the attached document or report is true and correct to the best of my knowledge." This letter must be signed by an officer or legally authorized representative of your company. Please include a cover letter satisfying these requirements with all future reports and technical documents submitted for this fuel leak case. PROFESSIONAL CERTIFICATION & CONCLUSIONS/RECOMMENDATIONS The California Business and Professions Code (Sections 6735, 7835, and 7835.1) requires that work plans and technical or implementation reports containing geologic or engineering evaluations and/or judgments be performed under the direction of an appropriately registered or certified professional. For your submittal to be considered a valid technical report, you are to present site specific data, data interpretations, and recommendations prepared by an appropriately licensed professional and include the professional registration stamp, signature, and statement of professional certification. Please ensure all that all technical reports submitted for this fuel leak case meet this requirement. UNDERGROUND STORAGE TANK CLEANUP FUND Please note that delays in investigation, late reports, or enforcement actions may result in your becoming ineligible to receive grant money from the state’s Underground Storage Tank Cleanup Fund (Senate Bill 2004) to reimburse you for the cost of cleanup. AGENCY OVERSIGHT If it appears as though significant delays are occurring or reports are not submitted as requested, we will consider referring your case to the Regional Board or other appropriate agency, including the County District Attorney, for possible enforcement actions. California Health and Safety Code, Section 25299.76 authorizes enforcement including administrative action or monetary penalties of up to $10,000 per day for each day of violation. Alameda County Environmental Cleanup Oversight Programs (LOP and SCP) REVISION DATE: July 25, 2012 ISSUE DATE: July 5, 2005 PREVIOUS REVISIONS: October 31, 2005; December 16, 2005; March 27, 2009; July 8, 2010 SECTION: Miscellaneous Administrative Topics & Procedures SUBJECT: Electronic Report Upload (ftp) Instructions The Alameda County Environmental Cleanup Oversight Programs (petroleum UST and SCP) require submission of all reports in electronic form to the county’s FTP site. Paper copies of reports will no longer be accepted. The electronic copy replaces the paper copy and will be used for all public information requests, regulatory review, and compliance/enforcement activities. REQUIREMENTS  Please do not  Entire report including cover letter must be submitted to the ftp site as a single Portable Document Format (PDF) with no password protection. submit reports as attachments to electronic mail.  It is preferable that reports be converted to PDF format from their original format, (e.g., Microsoft Word) rather than scanned.  Signature pages and perjury statements must be included and have either original or electronic signature.  Do not password protect the document. Once indexed and inserted into the correct electronic case file, the document will be secured in compliance with the County’s current security standards and a password. Documents with password protection will not  Each page in the PDF document should be rotated in the direction that will make it easiest to read on a computer monitor. be accepted.  Reports must be named and saved using the following naming convention: RO#_Report Name_Year-Month-Date (e.g., RO#5555_WorkPlan_2005-06-14) Submission Instructions 1) Obtain User Name and Password a) Contact the Alameda County Environmental Health Department to obtain a User Name and Password to upload files to the ftp site. i) Send an e-mail to .loptoxic@acgov.org b) In the subject line of your request, be sure to include “ftp PASSWORD REQUEST” and in the body of your request, include the Contact Information, Site Addresses, and the Case Numbers (RO# available in Geotracker) you will be posting for. 2) Upload Files to the ftp Site a) Using Internet Explorer (IE4+), go to ://alcoftp1.acgov.org (i) Note: Netscape, Safari, and Firefox browsers will not open the FTP site as they are NOT being supported at this time. b) Click on Page located on the Command bar on upper right side of window, and then scroll down to Open FTP Site in Windows Explorer. c) Enter your User Name and Password. (Note: Both are Case Sensitive.) d) Open “My Computer” on your computer and navigate to the file(s) you wish to upload to the ftp site. e) With both “My Computer” and the ftp site open in separate windows, drag and drop the file(s) from “My Computer” to the ftp window. 3) Send E-mail Notifications to the Environmental Cleanup Oversight Programs a) Send email to .loptoxic@acgov.org notify us that you have placed a report on our ftp site. b) Copy your Caseworker on the e-mail. Your Caseworker’s e-mail address is the entire first name then a period and entire last name @acgov.org. (e.g., firstname.lastname@acgov.org) c) The subject line of the e-mail must start with the RO# followed by Report Upload. (e.g., Subject: RO1234 Report Upload) If site is a new case without an RO#, use the street address instead. d) If your document meets the above requirements and you follow the submission instructions, you will receive a notification by email indicating that your document was successfully uploaded to the ftp site. Attachment 6: Sacramento Metropolitan Air Quality Management District " Guidance for Construction GHG Emissions Reductions", dated September 2010. Construction GHG Emissions Reductions Sacramento Metropolitan Air Quality Management District Page | 1 CEQA Guide December 2009, Revised September 2010 GUIDANCE FOR CONSTRUCTION GHG EMISSIONS REDUCTIONS These measures are considered best management practices providing options for reducing greenhouse gas emissions from construction projects. Emission reductions must be quantified and documented on a case-by-case basis. Improve fuel efficiency from construction equipment: o Minimize idling time either by shutting equipment off when not in use or reducing the time of idling to no more than 3 minutes (5 minute limit is required by the state airborne toxics control measure [Title 13, sections 2449(d)(3) and 2485 of the California Code of Regulations]). Provide clear signage that posts this requirement for workers at the entrances to the site. o Maintain all construction equipment in proper working condition according to manufacturer’s specifications. The equipment must be checked by a certified mechanic and determined to be running in proper condition before it is operated. o Train equipment operators in proper use of equipment. o Use the proper size of equipment for the job. o Use equipment with new technologies (repowered engines, electric drive trains). Perform on-site material hauling with trucks equipped with on-road engines (if determined to be less emissive than the off-road engines). Use alternative fuels for generators at construction sites such as propane or solar, or use electrical power. Use an ARB approved low carbon fuel for construction equipment. (NOx emissions from the use of low carbon fuel must be reviewed and increases mitigated.) Encourage and provide carpools, shuttle vans, transit passes and/or secure bicycle parking for construction worker commutes. Reduce electricity use in the construction office by using compact fluorescent bulbs, powering off computers every day, and replacing heating and cooling units with more efficient ones. Recycle or salvage non-hazardous construction and demolition debris (goal of at least 75% by weight). Construction GHG Emissions Reductions Page | 2 Sacramento Metropolitan Air Quality Management District CEQA Guide December 2009, Revised September 2010 Use locally sourced or recycled materials for construction materials (goal of at least 20% based on costs for building materials, and based on volume for roadway, parking lot, sidewalk and curb materials). Wood products utilized should be certified through a sustainable forestry program. Minimize the amount of concrete for paved surfaces or utilize a low carbon concrete option. Produce concrete on-site if determined to be less emissive than transporting ready mix. Use SmartWay certified trucks for deliveries and equipment transport. Develop a plan to efficiently use water for adequate dust control. References: 1. California Green Building Standards Code. http://www.bsc.ca.gov 2. US EPA. Potential for Reducing Greenhouse Gas Emissions in the Construction Sector, February 2009. http://www.epa.gov/sectors/pdf/construction-sector- report.pdf 3. US EPA SmartWay Program. http://www.epa.gov/smartway/index.htm 4. US Green Building Council. LEED Green Building Rating System. http://www.usgbc.org/