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HomeMy WebLinkAbout5.1 Att 8 Exh A Final EIR Kaiser FIRSTCARBONSO ±UTIONS FINAL Environmental Impact Report Kaiser Dublin Medical Center Project City of Dublin, Alameda County, California State Clearinghouse No. 2015012018 Prepared for. DUBLIN C A I FCHN : A, City of Dublin 100 CIVIC Plaza Dublin, CA 94568 925 833 6610 Contact: Knsti Bascom, Principal Planner Prepared by. FirstCarbon Solutions 1350 Treat Boulevard,Suite 380 Walnut Creek,CA 94597 925 357 2562 Contact: Mary Bean, Project Director Grant Gruber, Project Manager lanna Waligorski, Project Manager Date:August 9, 2016 NORTH AMERICA I EUROPE I AFRICA AUSTRALIA I ASIA vmwv t IRSTCARBONSOwnons(.OM AN ADEC INNOVATION City of Dublin-Kaiser Dublin McOml Center Project Fend FIR Table of Contents Table of Contents Section 1: Introduction 1-1 Section 2: Master Responses 2-1 2.1- Master Response. . ... . .... . . .... ... .... ... . .... 2-1 Section 3: Responses to Written Comments 3-1 3 1 -List of Authors . ... .... .... ... ..... 3-1 3 2- Responses to Comments ..... ... . .. . ... . .... ... 3-1 Section 4: Errata 4-1 4.1-Changes in Response to Specific Comments . . .. . .... .. 4-1 Appendix L: Letter of Map Revision List of Exhibits Exhibit 2-1:Southern Property Boundary Cross Sections.... .. . ... _. ..... . . .... . .... .2-3 FvstCavbon Solutions no City of Dublin-Kaiser oub'n Medical Center Project Final FIR Introduction SECTION 1: INTRODUCTION In accordance with the California Environmental Quality Act (CEQA)Guidelines Section 15088,the City of Dublin has evaluated the comments received on the Kaiser Dublin Medical Center Project Draft Environmental Impact Report(EIR). The Responses to the Comments and Errata, which are included In this document,together with the Mitigation Monitoring and Reporting Program comprise the Final EIR for use by the City of Dublin in its review. This document is organized into four sections. • Section 1—Introduction. • Section 2—Master Responses: Provides a single, comprehensive response to similar comments about a particular topic • Section 3—Responses to Written Comments: Provides a list of the agencies, organizations, and individuals that commented on the Draft EIR Copies of all of the letters received regarding the Draft EIR and responses thereto are included in this section • Section 4-Errata: Includes an addendum listing refinements and clarifications on the Draft EIR,which have been incorporated. The Final EIR includes the following contents: • Draft EIR (provided under separate cover) • Draft DR appendices(provided under separate cover) • Master Responses, Responses to Written Comments,and Errata (Sections 2,3, and 4 of this document) • Mitigation Monitoring and Reporting Program(provided under separate cover) FrrstCarbon Solutions 1-1 City of Oubbn-Nurser Oublm Medical Center Project Final MR Master Responses SECTION 2: MASTER RESPONSES Master responses address similar comments made by multiple public agencies, businesses, organizations,or individuals through written comments submitted to the City of Dublin. One master response is provided in this section 2.1 - Master Response Master Response 1: Livermore BART Extension Summary of Relevant Comments The California Department of Transportation (Caltrans),the Alameda County Transportation Commission (ACTC),and the City of Livermore all provided comments concerning the project's relationship to the Bay Area Rapid Transit District(BART) extension to Livermore. Caltrans inquired about the location of an existing storm drainage easement along the project site's frontage with 1- 580. ACTC reiterated comments it provided in its March 23, 2015 Notice of Preparation comment letter about the proposed project reserving right-of-way for the extension along the 1-580 frontage The City of Livermore estimated that approximately 40 feet of right-of-way would need to be acquired from the project site in order to accommodate the BART extension and requested that Exhibits 2-4a,2-4b,and 2-4c be revised to depict this area Response Exhibit 2-1 depicts a cross-section of the southern portion of the project site, including easements and BART dedication. As shown in the exhibit, two parallel easements for storm drainage (75 to 80 feet)and telecommunications(10 to 12 feet) occupy 85 to 90 feet immediately south of the project boundary, Within the storm drainage easement are the existing box culverts. A 45-foot dedication for the BART extension would overlap with a portion of the storm drainage easement and all of the telecommunication easement In summary,the project site plan provides 45 feet of dedication for the BART extension along the length of the site consistent with the recommendations of ACTC and the City of Livermore. No new structures are planned to be constructed in this area that would restrict future acquisition by BART or Caltrans Note that right-of-way acquisition and the relocation of any affected facilities are the responsibilities of BART and the other agencies involved with the Livermore BART extension,and would be evaluated as part of the environmental review process for that project. FattCarbon solutont 2-1 I",,,'",.e.""",o,u,". .Jn""°sE.wn: 'E "'C'en w..a'oon" ,o,. 3% %\ \ 22 4\ St ° « 4 4A 3y /\ G : \\ c , 36 ` 1 , ice, « } . ziy ' k\ { ° e : \ . \ \ p� ` ® .\ , \ \ 9 � { \•\\ } . tit\ / \ d 43-H i : . 2> / » . © ` \` � 1 % \ L 1 . � ` i \ \ » . . # t. It % \\ \ CNI \ � ~ ` - _\ , , { 5 \ ®, 1 _ , % \ < ` \ ! S :t. \ , , t \10 0 Vtt , ED \ � . . . ` ' a. �\ : \ City of Dublin-Kaiser Dublin Medical Center Prolert Final FIR Responses to Written Comments SECTION 3: RESPONSES TO WRITTEN COMMENTS 3.1 - List of Authors A list of public agencies,organizations,and individuals that provided comments on the Drak EIR is presented below Each comment has been assigned a code. Individual comments within each communication have been numbered so comments can be crossed-referenced with responses Following this list,the text of the communication is reprinted and followed by the corresponding response Author Author Code State Agencies California Department of Transportation . . . ... CALTRANS Local Agencies Alameda County Transportation Commission . . .ACTC Dublin San Ramon Services District . . ..... . . DSRSD City of Livermore . . . ....LIVERMORE City of Pleasanton... . . . PLEASANTON City of San Ramon . . SAN RAMON Zone 7 Water Agency .... . . ZONE 7 Private Businesses,Organizations, and Individuals Kaiser Permanente .. . . ....KAISER Lily Chai . . .CHAT 3.2 - Responses to Comments 3.2.1 - Introduction In accordance with the California Environmental Quality Act (CEQA)Guidelines Section 15088,the City of Dublin, as the lead agency,evaluated the comments received on the Draft EIR (State Clearinghouse No. 2015012018)for the Kaiser Dublin Medical Center Project,and has prepared the following responses to the comments received. This Response to Comments document becomes part of the Final EIR for the project in accordance with CEQA Guidelines Section 15132 3.2.2 - Comment Letters and Responses The comment letters reproduced in the following pages follow the same organization as used in the List of Authors First Carbon Solutions 3-1 S 1 Al L Of CAI IFORNIA-CALIFORNIA STA It TRANSPORTATION AOFNCV LDMUNn G BR(N N lr Gmnmr DEPARTMENT OF TRANSPORTATION DISTRICT 4 PO BOX 23660 OAKLAND,CA 94623-0660 PHONE 15101286-5528 Spoon Drought FAX 1510)286-5559 Help vale hater, TTY 711 wN w dot ca guy CALTRANS Page 1 of 4 March 21, 2016 ALA580881 ALA-580-PM 16.7 SCHN 2015012018 Ms. Kristi Bascom Planning Division City of Dublin 100 Civic Plaza Dublin,CA 94568 Kaiser Dublin Medical Center Project—Draft Environmental Impact Report Dear Ms. Bascom- Thank you for continuing to include the California Department of Transportation (Caltrans) in the environmental review process for the project referenced above Our comments seek to promote 1 the State's smart mobility goals that support a vibrant economy and build active communities rather than sprawl. We have reviewed the Draft Environmental Impact Report (DEIR) and have the following comments to offer. Project Understanding The proposed project is proposing to develop approximately 1.2 million square feet on a currently vacant 58-acre project site that would involve construction of up to 950,000 square feet of medical campus uses, 250,000 square feet of commercial uses, a parking structure, and associated site, roadway frontage, and landscape improvements. The project would developed in multiple phases. 2 Phase IA to be evaluated at project-level. Phases 1B, 2,and 3 are to be evaluated at program-level. The project will increase Vehicle Miles Traveled (VMT) and travel demand having a significant impact on the State Highway System Interstate (I-) 580 forms the southern boundary of the site. Regional access to the site is provided by the 1-580 Interchanges at Tassajara Road/Santa Rita Road and Fallon Road/El Charro Road approximately one mile east and west of the project site. Mitigation Responsibility As the lead agency, the City of Dublin (City) is responsible for identifying and ensuring the coordinated Implementation of all project mitigation,including any needed improvements to State 3 highways. The project's fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures. PPM idea f,vusluniable ttegtaed and efficient lmnspo, on vvvran m enfant.e Cnldanna's economy and h,abdirt-�on CALTRANS Page 2 of 4 Ms. Kristi Bascom, City of Dublin March 21,2016 Page 2 Where mitigation is a condition of approval, CEQA requires a Mitigation Monitoring and Reporting Program (MMRP) Required information is listed below We recommend the completion of required roadway Improvements prior to the issuance of a Certificate of Occupancy. Further information on the MMRP is available on the following website: http://www.dot.ca.gov/hq/tpp/offices/ocp/igr_ceqa.html. 3 • Lead Agency contact name, address, and telephone number, CON' • Location,type and implementation schedule for each mitigation measure, and • Signed and dated certification that the mitigation has been implemented, and all other reporting requirements have been adhered to, in accordance with Public Resources Code Sections 21081.6 and 21081 7 Transportation Operations Development facilitated by this project would significantly impact State facilities within 1-580 and 1-680 under Existing Plus Project Conditions, Near-Term Conditions, or Cumulative Conditions (Impact TRANS-5, 12, 18, 26. and 35) For these impacts to State facilities, please be sure to follow Caltrans Practices, Standards,Policy,and Procedures Please ensure new development pays their fair share of mitigation necessary to fund improvements needed to mitigate significant 4 Impacts to State facilities, which are evaluated and listed in the project impacts' mitigation measures (MM TRANS-5, 12, 18). These contributions for upgrading the identified interchanges should be to the same standards as the Dougherty Road and Hacienda Drive interchanges. The City and Regional Transportation Impact Fees to be used for project mitigation should be fully Identified and explained. Table ES-1. Executive Summary Matrix, summarizes the impacts, mitigation measures, and • resulting level of significance after mitigation for the relevant environmental issues areas evaluated • for the proposed project(DEIR, pg. ES-6). Please clarify if the intersections at El Charro Road/ b 1-580 eastbound Ramps and Tassajara Road/1-580 westbound ramps are impacted, mitigated, and • should be included within this matrix. • Please note, Intersection#24 of Table 3.11-5: Existing Conditions Peak-Hour Intersection Levels of Service, currently lists the PM Peak Hour Delay as 89. This should be revised to reflect actual 6 conditions (pg 3.11-12) • Vehicle Trip Reduction • The DEIR states the project will include a Transportation Demand Management (TDM) Program that will provide a comprehensive strategy to manage the travel demands created by the project • through established trip budgets based on the Trip Generation Estimate total AM and PM peak hour trips in Table 3.11-9:Trips By Analysis Phase(pg. 3.11-35).The TDM Program incorporates 7 • a number of TDM strategies that are recommended in every phase of development to encourage • alternative modes of travel (pg. 3.11-60).We commend the City's Mitigation Measure TRANS-1, • which includes subsequent annual monitoring to demonstrate the effectiveness of the TDM • 'Painde a cafe mwniahle nnep,ared and efficient mm crymmun, • system to enhance Cent f amid erom n and Innbdm ' • • CALTRANS Page 3 of 4 Ms. Knsti Bascom,City of Dublin March 21, 2016 Page 3 program that will promote mass transit use thereby reducing regional vehicle miles traveled and traffic impacts. The Caltrans Strategic Management Plan aims to increase the percentage of non- auto mode shares through tripling bicycle, and doubling pedestrian and transit by 2020. This 7 strategic objective is consistent with MTC's Regional Transportation Plan/Sustainable CONT Community Strategy goals of both increasing non-auto mode transportation, and reducing per capita VMT by 10 percent each. The Project's Phase IA would provide associated surface parking for approximately 860 to 1,075 vehicles.The subsequent Phase 2 would provide parking for approximately 600 to 1,600 vehicles. Phase 3 would include associated surface parking and a parking structure located on the southwestern portion of the Campus site for approximately 1,140 to 1,425 vehicles (pg. 2-10). We encourage the City to include a parking management plan within the TDM Program to continue discussions on pricing incentives, consider variable pricing policies, and improve coordination between on-street and off-street parking prices to meet operational and policy goals. This will 8 reduce vehicles circling by effectively balancing the parking demand across the area. Parking management policies should ensure the best use of the future parking structure through pricing, shared parking policies. restricting the number of parking permits, and support for alternative modes,e.g. bike parking, car share,etc.,that are listed as strategies within the TDM Program. For information about parking ratios, see the Caltrans funded Metropolitan Transportation Commission (MTC)report Reforming Parking Policies to Support Smart Growth or visit the MTC parking webpage. http://mtc.ca gov/sites/default/fdes/Toolbox-Handbook.pdf. Hydraulics The DEIR states there is a double 10-foot by 9-foot concrete box culvert that parallels the north side of 1-580 within the Caltrans right-of-way (pg. 2-1). Please provide Caltrans with the appropriate map or project plans that identifies the culvert's location as we seek further 9 confirmation the culvert is in fact within Caltrans' right-of-way. Early consultation with Caltrans is encouraged to identify any additional improvements or further required elements to project design and drainage facilities. Cultural Resources Caltrans requires that a project environmental document include documentation of a current archaeological record search from the Northwest Information Center of the California Historical Resources Information System if construction activities are proposed within State Right-of-way (ROW) Current record searches must be no more than five years old.Caltrans requires the records search, and if warranted, a cultural resource study by a qualified, professional archaeologist, and 10 evidence of Native American consultation to ensure compliance with the California Environmental Quality Act (CEQA), Section 50245 and 5097 of the California Public Resources Code, and Volume 2 of Caltrans' Standard Environmental Reference. Work subject to these requirements includes, but is not limited to: lane widening, channelization, auxiliary lanes, and/or modification of existing features such as slopes, drainage features, curbs, sidewalks and driveways within or adjacent to State ROW. Sec the following website for more information. -ens a cafe untamable mmxn,fed and efi rent antral,,,r,,,,t ti item UP enhnm a Gil/enun t e,nnnnn and b,vbdm" CALTRANS Page 4 of 4 Ms Kristi Bascom, City of Dublin March 21, 2016 Page 4 http://www.dot.ca.gov/ser/vol2/vol2.htm. I 10 CONT Transportation Management Plan A Transportation Management Plan(TMP) or construction TIS may be required of the developer for approval by Caltrans prior to construction when traffic restrictions and detours affect State highways. TMPs must be prepared in accordance with California Manual on Uniform Traffic Control Devices and the other transportation management plan requirements of the corresponding 11 jurisdictions.Please contact the Office of Traffic Management Plans/Operations Strategies at 510- 286-4579. Further information is available at the following website: http://www.dot.ca.gov/hq/traffops/engineering/mutcd/pdf/camutcd2014/Part6.pdf. Encroachment Permit Please be advised that any work or traffic control that encroaches onto the State ROW requires an encroachment permit that is issued by Caltrans. Traffic-related mitigation measures should be incorporated into the construction plans prior to the encroachment permit process. Since an encroachment permit is required for work in the State ROW, and Caltrans will not issue a permit until our concerns are adequately addressed, we strongly recommend that the County work with 12 both the applicant and Caltrans to ensure that our concerns are resolved during the environmental process, and in any case prior to submittal of an encroachment permit application. To apply, a completed encroachment permit application, environmental documentation, and five (5) sets of plans clearly indicating State ROW must be submitted to the following address: David Salladay, District Office Chief, Office of Permits, California Department of Transportation, District 4,P.O. Box 23660, Oakland, CA 94623-0660. See this website for more information: http://www.dot.ca.gov/hq/traffops/developserv/permits. Should you have any questions regarding this letter,please call Sherie George at 510-286-5535 or I 13 sherie.george@dot.ca.gov. Sincerely, PATRICIA MAURICE District Branch Chief Local Development-Intergovernmental Review • c: State Clearinghouse 'Provided f,sustainable,integrated and efficient transportanon system to enhance California's economy and livability" 0 City of Dublin-Kinser Dublin Medical Center Project Final OR Responses to Written Comments State Agencies California Department of Transportation ICALTRANS) Response to CALTRANS-1 The agency provided introductory remarks to open the letter. No response is necessary Response to CALTRANS-2 The agency summarized the project characteristics and noted that the project is located near the Interstate 580(1-580)interchanges at Tassajara Road/Santa Rita Road and Fallon Road/EI Charro Road The agency's specific comments on impacts to these I-580 facilities are addressed in Response to CALTRANS-4. Response to CALTRANS-3 The agency provided standard language about a lead agency's mitigation responsibilities and CEQA requirements concerning the Mitigation Monitoring and Reporting Program(MMRP). The agency recommended that required traffic improvements be completed prior to the issuance of the Certificate of Occupancy To clarify,the proposed project consists of four phases: 1A, 18, 2,and 3. For improvements that are within the jurisdictional control of the City of Dublin,the Draft EIR's mitigation measures identify the timing of traffic improvements by phase and require them to be implemented at the appropriate time noted in each mitigation measure For improvements that are outside the jurisdictional control of the City of Dublin (e.g.,the 1-580 interchanges with Tassajara Road/Santa Rita Road and Fallon Road/EI Charro Road),the Draft EIR requires that fair-share payments be made to the applicable agency at the appropriate time noted in each mitigation measure These practices are consistent with CEQA requirements in terms of implementing mitigation measures at the time that impacts occur. Response to CALTRANS-4 The agency noted that development facilitated by this project would significantly impact State facilities within 1-580 and 1-680 under Existing Plus Project, Near-Term conditions or Cumulative conditions (Impacts TRANS-5,-12, -18,-26,and-35) For these impacts to State facilities,the agency advised to follow Caltrans Practices,Standards, Policy and Procedures, and to ensure that new development pays their fair share of mitigation necessary to fund improvements needed to mitigate significant impacts to State facilities,which are evaluated and listed in the project impacts' mitigation measures (Mitigation Measures TRANS-5,TRANS-12,and TRANS-18) These contributions for upgrading the identified interchanges should be to the same standards as the Dougherty Road and Hacienda Drive interchanges The City and Regional Transportation Impact Fees to be used for project mitigation should be fully identified and explained The City of Dublin has initiated conversations with regional agencies (the cities of Livermore and Pleasanton,Alameda CTC)regarding the establishment of an escrow account where fair-share funds can be deposited for interchange improvements not included in local or regional fee programs. Regardless of establishing a regional escrow account,the City will ensure that the fair-share costs are Forst Carbon Solutions 3-7 City of Oubbn-.Kaiser Dublin Medical Center Project Responses to Written Comments Final EIR collected and maintained for the needed improvements. The fair-share payments would be above the required local and regional fee payments,unless the identified improvements are added to a local or regional fee program prior to the fair-share payment requirement being triggered The Draft EIR text has been revised to clarify the intent of MM TRANS-12 and MM TRANS-18 that fair-share contributions to these two regional improvements will be collected The change is noted in Section 4, Errata The project applicant would also be required to pay the Eastern Dublin Transportation Impact Fee as well as the To-Valley Transportation Development Fee as established by the To-Valley Transportation Council (TVTC). Response to CALTRANS-5 The agency noted that Draft EIR Table ES-1 Executive Summary Matrix summarizes the impacts, mitigation measures, and resulting levels of significance after mitigation for the relevant environmental issue areas evaluated for the proposed project The agency requested clarification if the intersections at El Charro Road/I-580 Eastbound Ramps and Tassajara Road/I-580 Westbound Ramps are impacted, mitigated,and should be included in this matrix. Project impacts were not identified at the El Charro Road/I-580 Eastbound Ramps and Tassajara Road/I-580 Westbound Ramps intersections. Impacts and mitigation measures were identified for the El Charro Road/I-580 Westbound Ramps (TRANS-1S)and Tassajara Road/I-580 Eastbound Ramps (TRANS-12) intersections, as included in Table ES-1 Response to CALTRANS-6 The agency advised that Intersection 24 provided in Table 3 11-5 is shown as having a PM peak-hour delay as"89" and noted that this value should be revised to reflect actual conditions(p. 3.11-12). The Draft EIR text has been revised to report the correct value as "9" The change is noted in Section 4, Errata This correction does not result in any change in the conclusion on level of significance for traffic impacts identified in the Draft EIR Response to CALTRANS- The agency noted that the project will include a Transportation Demand Management (TDM) Program that will provide a comprehensive strategy to manage the travel demands created by the project through established trip budgets based on the Trip Generation estimate total AM and PM peak-hour trips in Table 3.11-9 Trips by Analysis Phase(p.3.11-35) The TDM program incorporates a number of TDM strategies that are recommended in every phase of development to encourage alternative modes of travel(p 3 11-60). The agency commended the City's Mitigation Measure TRANS-1,which includes subsequent annual monitoring to demonstrate the effectiveness of the TDM program that will promote mass transit use,thereby reducing regional vehicle miles traveled (VMT)and traffic impacts The Caltrans Strategic Management Plan aims to increase the percentage of non-auto mode shares through tripling bicycle and doubling pedestrian and transit by 2020 This strategic objective is consistent with MTC's Regional Transportation Plan/Sustainable Community Strategy goals of both increasing non-auto mode transportation by 10 percent and reducing per capita VMT by 10 percent. F 3-8 Fnstoorbon Solutions sv.=ixmu irree 3 osm! ..newmii.o.o..m.eoo City of Dubin-Kaiser Dublin Medico)Center Project Final FIR' Responses to Written Comments The comment accurately describes Mitigation Measure TRANS-1 No additional response is necessary Response to CALTRANS-8 The agency noted that Phase 1A would provide associated surface parking for approximately 860 to 1,075 vehicles The subsequent Phase 2 would provide parking for approximately 600 to 1,600 vehicles Phase 3 would include associated surface parking and a parking structure located on the southwestern portion of the Campus for approximately 1,140 to 1,425 vehicles (p 2-10). The agency encouraged the City to include a parking management plan within the TOM program to continue discussions on pricing incentives, consider variable pricing policies, and improve coordination between on-street and off-street parking prices to meet operational and policy goals This will reduce vehicles circling by effectively balancing the parking demand across the area. Parking management policies should ensure the best use of the future parking structure through pricing, shared parking policies, restricting the number of parking permits, and support for alternative modes such as bike parking,car share,and others—all of which are listed as strategies within the TDM program Parking management strategies are expected to be a primary component of the TDM plan, and potential strategies were identified in the Transportation Assessment Monitoring of the actual parking demand as project phases are developed,such that excess parking is not provided in subsequent phases, was also recommended Response to CALTRANS-9 The agency referenced a statement on Draft EIR page 2-1 that there is a double 10-foot by 9-foot concrete box culvert that parallels the north side of 1-580 within the Caltrans right-of-way. The agency requested that the City provide it with a map or plans that identifies the culvert's location to confirm that it is in fact within Caltrans's nght-of-way The agency noted that early consultation with Caltrans is encouraged to identify any additional improvements or further required elements to project design or drainage facilities The proposed project's site plan (Exhibits 2-4a,2-4b,and 2-4c)depict the existing storm drainage easement and also illustrate a setback for the planned Bay Area Rapid Transit (BART)extension to Livermore The storm drainage easement consists of two adjacent easements (20 feet and 10 feet) that total 30 feet in width. An American Land Title Association/American Congress of Surveying and Mapping (ALTA/AGSM) Land Title Survey is provided in Appendix L that depicts the location of the existing storm drainage easement. The box culverts do not appear to be within the Caltrans right-of- way and the change is noted in Section 4, Errata Refer to Master Response 1 for further discussion of the BART extension to Livermore Response to CALTRANS-10 The agency provided standard language about its cultural resources assessment requirements if the project involves construction activities within the State right-of-way, including requirements for records searches, cultural resources study, and Native American consultation hrstembon Solutions 3-9 City ofDi hlin-Raiser Dublin Medical Center Project Responses to Written Comments Final FIR As discussed in Master Response 1,the project site plan includes a setback for the planned BART extension to Livermore. This setback begins at the edge of the 1-580 right-of-way and overlaps with the storm drainage easement on the north side of the freeway. As such, no disturbance is proposed within the existing State right-of-way and,therefore, no additional cultural resources assessments would be required Refer to Master Response 1 for further discussion of the BART extension to Livermore. Finally, it should be noted that a Phase I Cultural Resources Assessment was prepared for development activities that would occur within the project site boundaries. That assessment,which included a record search at the Northwest Information Center, a field survey,and consultation with applicable Native American tribal representatives, is provided in Draft OR Appendix D. Response to CALTRANS-11 The agency stated that a Transportation Management Plan or Construction Traffic Impact Study may be required if project-related construction activities result in traffic restrictions or detours to state highways. The agency provided standard language about the requirements of such a plan or study. The City has a standard requirement that developers prepare a construction traffic mitigation plan that identifies measures to be taken to minimize construction traffic impacts and noise on surrounding properties and public streets. The plan includes construction traffic interface with public traffic on any existing public street, hours of construction operation,speed limit for construction traffic,and identification of haul routes. This will be included as a condition of approval,and language will be included that if the plan will result in traffic restrictions and/or detours to any state highways, Caltrans may require an impact study to be prepared and the measures outlined in the study followed during construction Response to CALTRANS-12 The agency provided standard language about encroachment permit application requirements As noted in Responses to CALTRANS-10 and CALTRANS-11,the proposed project's development activities would not involve any work within the existing 1-580 right-of-way along the project frontage or at the interchanges with Tassajara Road/Santa Rita Road and Fallon Road/EI Charro Road; therefore, no encroachment permits would be required Response to CALTRANS-13 The agency provided concluding remarks to close the letter. No response is necessary. 3-I0 Fintearbon Solutions a u..e .e.e n•xi.�io.mir�inlcree swa a amnssarc wa=rc n..p......mxnv..Dmm.m.e-.. • ACTC t••I Page 1 of 3 ▪ ALAMEDA Ss County transportation • commission 1111 Broadway,smte 800,Oakland CA 94607 • 510 208 7400 • www AlamedaCTC org March 18, 2016 Kristi Bascom Principal Planner City of Dublin too Civic Plaza Dublin, CA 94568 SUBJECT: Response to the Draft Environmental Impact Report for the Kaiser Dublin Medical Center Project Dear Ms. Bascom, Thank you for the opportunity to comment on the Draft Environmental Impact Report(DEIR)for the Kaiser Dublin Medical Center Project. The project site is approximately 58.9-acres located in the eastern portion of the City of Dublin and is bounded by undeveloped land and a stormwater basin to the west, Dublin Boulevard to the north,the Fallon Gateway retail center to the east,and Interstate 58o to 1 the south. The proposed project would consist of approximately 1.2 million square feet of medical campus and commercial uses with surface and/or structured parking for 3,300 to 5,2O0 vehicles. The Alameda County Transportation Commission (Alameda CTC) respectfully submits the following comments: • The Alameda CTC's CMP requires that the DEIR address potential impacts to not only roadways on the Metropolitan Transportation System(MTS)network,but also potential impacts of the project on MTS transit operators(BART and LAVTA in this case),Countywide Bicycle Network, and Pedestrian Areas of Countywide Significance. The following revisions should be made to the DEIR to reflect the multimodal nature of the CMP requirements: o The language in Appendix J - Chapter 8 should incorporate the multimodal nature of Alameda CTC's CMP requirement. o Appendix J-Chapter 8 should include multimodal project impact analysis.The DEIR has included some elements of this analysis in the Appendix J — Chapter 9 Site Access, Circulation and Parking. Specifically. 2 • Transit impacts to consider include the effects of project vehicle traffic on mixed Bow transit operations, transit capacity,transit access/egress, need for future transit service,and consistency with adopted plans. See Appendix K of the 2015 CMP document for more details. • Bicycle related impacts to consider include effects of vehicle traffic on bicyclist conditions,site development and roadway improvements,and consistency with adopted plans. See Appendix K of the 2015 CMP document for more details. • Pedestrian related impacts to consider include effects of vehicle traffic on pedestrian conditions,site development and roadway improvements, and consistency with adopted plans. See Appendix K of the 2015 CMP document for more details. Kristi Bascom ACTC March iB,2016 Page 2 of 3 Page 2 • The DEIR indicated that the Alameda CTC travel model was applied on the MTS roadway segments analysis to analyze the impacts of the proposed project on the regional network in 2025 and 2040. The current Alameda CTC model simulates travel demand for the forecast 3 years 2020 and 2040. The DEIR should explain how 2025 traffic condition was estimated based on the Alameda CTC travel model. • Alameda CTC notes that for the purpose of developing future forecasts,the DEIR assumed BART extension to Livermore/Isabel by 2040. Please note that Alameda CTC provided the following comment to the Notice of Preparation of the DEIR in March 2015 regarding the extension: "Within your project area, the BART to Livermore Extension is a major transit 4 project included in Alameda CTC's 2014 Transportation Expenditure Plan (TEP) and Alameda CTC's CTP. This letter requests your consideration of right-of-way preservation related to this project." • The DEIR correctly stated (on page 16 of Appendix J - Chapter 9) that Alameda CTC has not adopted any policy for determining a threshold of significance for Level of Service (LOS) for the Land Use Analysis Program (LUAP) of the CM?. However,the DEIR also stated (on page 17 of Appendix J - Chapter 9) that Alameda CTC has specific LOS thresholds standards for Caltrans 5 facilities. Please correct the language to reflect that Alameda CTC has not adopted any thresholds of significance. • Alameda CTC noted that the TIA included a VMT assessment in line with the pending update of the California Environmental Quality Act(CEQA)guidelines by the Office of Planning and Research (OPR).Alameda CTC has not set thresholds for a VMT assessment and is also closely monitoring the development of the CEQA guidelines update. Our comments regarding the VMT 6 assessment are: o Appendix J-Tables 34 and 35:The VMT assessment estimated that there would be additional 3,975 employment created by the project in 2040. Please provide the source of how the DEW converted square feet of project development to number of employees to model project land use. • The DEIR indicated(on page 129)that the land use assumptions in the Alameda CTC travel model are consistent with Association of Bay Area Governments(ABAG) population and employment projections that may differ from the City of Dublin's model. While this is true, 7 please note that land use assumptions in the Alameda CTC travel model has been reviewed by City of Dublin staff in 2014 and incorporates their feedback. • The DEIR concluded that in 2040,the following MTS roadway segments would experience significant project impacts: o Dublin Boulevard between Camp Parks Boulevard and Fallon Road o Hopyard Road/Dougherty Road between I-580 and Scarlett Drive o Isabel Avenue between Airway Boulevard and Jack London Boulevard o Isabel Avenue between Stanley Boulevard and Concannon Boulevard o Vallecitos Road between I-68o and Isabel Avenue: 8 , • Alameda CTC noted that the DEIR acknowledged: • That improvements to parallel corridors in the region would provide alternative routes and additional transportation capacity in the region. • The project developers would help fund improvements through payment of the City of Dublin and Tri-Valley Regional traffic impact fees .However, since implementation of a parallel capacity cannot be assured at this time, the impacts on these roadways could remain significant and unavoidable. • Knsti Bascom ACTC March 18,moth Page 3 of 3 Page 3 Thank you for the opportunity to comment on this NOP. Please contact me at(51o)208-7428 or Daniel Wu of my staff at(510)208-7453 if you have any questions. g Sincerely, Tess Lengyel Deputy Director of Planning and Policy cc: Daniel Wu,Assistant Transportation Planner file: CMP/Environmental Review Opinions/2016 City of oubltn-xmser Dualm Mee¢a2enter Project Final FIR Responses to Written Comments Local Agencies Alameda County Transportation Commission/ACTC) Response to ACTC-1 The agency provided introductory remarks to open the letter. No response is necessary Response to ACTC-2 The agency noted that its CMP requires that the Draft EIR address potential impacts not only to roadways on the Metropolitan Transportation System (MTS) network, but also potential impacts of the project on Metropolitan Transportation System transit operators(BART and Livermore Amador Valley Transit Authority [LAVTA] in this case),County wide Bicycle Network and Pedestrian Areas of Countywide Significance. The agency stated that the following revisions should be made to Draft FIR to reflect the multimodal nature of the CMP requirements. • The language in Appendix 1—Chapter 8 should incorporate the multimodal nature of Alameda's CTC's CMP requirements • Appendix 1—Chapter 8 should include multimodal project impact analysis The DEIR has included some elements of this analysis in the Appendix 1—Chapter 9 Site Access,Circulation and Parking Specifically - Transit impacts to consider include the effects of project vehicle traffic on mixed-flow transit operations,transit capacity,transit access/egress, need for future transit service,and consistency with adopted plans See Appendix K of the 2015 CMP document for more details - Bicycle related impacts to consider include effects of vehicle traffic on bicyclist conditions, site development and roadway improvements, and consistency with adopted plans. See Appendix K of the 2015 CMP document for more details - Pedestrian related impacts to consider include effects of vehicle traffic on pedestrian conditions,site development and roadway improvements,and consistency with adopted plans. See Appendix K of the 2015 CMP document for more details. Significance criteria for transit operations, bicycle,and pedestrians are discussed on page 3 11-26 of the Draft FIR Project impacts to these modes of travel were identified from the significance criteria, and, as noted in the comment, impacts and mitigation measures were developed The commenter is correct in noting that the Countywide Bicycle Network and Pedestrian Areas of Countywide Significance were not specifically mentioned in the Draft EIR However,the potential impact to these modes were discussed and analyzed as part of the Draft EIR on pages 3 11-143 through 3 11-145 Mitigation measures that incorporate the intent of the multimodal nature of the CMP requirements were identified The level of transit trip generation was also estimated for the project as presented in the Transportation Assessment Prior to the implementation of the TDM program,approximately 20 morning peak-hour and 60 evening peak-hour transit trips are expected with Phase 1 of the project Of these trips, most would include a bus component, with some including a bus and BART component. Based on ridership information provided by LAVTA,there is currently excess capacity on transit routes that serve the study area. Of the total transit trips, a percentage may use the BART FIrsICarEOn Solutions 3-I5 City of Dublin-xoiser Dublin Medical Center Protect Responses to Written Comments Final EIR system Even if all estimated transit trips used the BART system,the Dublin/Pleasanton stations are served by 10-car trains on 15-minute headways during peak periods,and the project would add fewer than 1 passenger per car during peak hours,a less than substantial increase. As part of the TDM program,the project applicant would work with LAVTA to adjust transit service to the site to accommodate projected demand. Finally,the proposed project would provide an internal network of pedestrian facilities that would link project buildings to the Dublin Boulevard sidewalk and surrounding land uses Internal pedestrian facilities would be designed to minimize conflicts between motorists and pedestrians via the strategic siting of crosswalk locations and use of pavement treatments to alert motorists to the potential presence of pedestrians Additionally,the signalized pedestrian crossings at Dublin Boulevard/Keegan Street and Dublin Boulevard/Lockhart Street would employ the use of countdown heads to advise pedestrians of the time remaining to cross the street Response to ACTC-3 The agency noted that the Draft EIR indicated that the Alameda CTC travel model was applied on the MTS roadway segments analysis to analyze the impacts of the proposed project on the regional network in 2025 and 2040 The current Alameda CTC model simulates travel demand for the forecast years 2020 and 2040 The agency requested that the Draft EIR explain how 2025 traffic condition was estimated based on the Alameda CTC travel model. The Alameda CTC model simulates travel demand for the forecast years of 2020 and 2040 The Draft EIR text has been revised to correct the erroneous reference to 2025 and the change is noted in Section 4, Errata. Response to ACTC-4 The agency noted that the Draft EIR assumed that the Livermore BART extension would be operational by 2040 and referenced a statement from its March 2015 Notice of Preparation comment letter about reserving right-of-way ACTC's Notice of Preparation March 23,2015 comment letter is listed in Draft FIR Table 1-1 and its comments about reserving right-of-way are specifically noted in the table. Refer to Master Response 1 for further discussion of the Livermore BART extension Response to ACTC-5 The agency noted that the Draft FIR correctly stated (on p. 16 of Appendix 1—Chapter 9)that Alameda CTC has not adopted any policy for determining a threshold of significance for Level of Service for the Land Use Analysis Program (LUAP)of the CMP. However,the Draft FIR also stated (on p 17 of Appendix 1—Chapter 9)that Alameda CTC has specific thresholds standards for Caltrans facilities The agency requested that the language be corrected to reflect that Alameda CTC has not adopted any thresholds of significance. The text in Appendix 1 has been revised to remove reference to Alameda CTC related to standards for Caltrans facilities in the study area The change is noted in Section 4, Errata 3-16 First6Orbon Solutions City of Oublm-Korser Dublin Medical Center Protect Final FIR Responses to Written Comments Response to ACTC-6 The agency noted that the Transportation Assessment(Appendix 1) included A VMT assessment In line with the pending update of the California Environmental Quality Act(CEQA)guidelines by the Office of Planning and Research The agency noted that it has not set thresholds for a VMT assessment and is also closely monitoring the development of the CEQA guidelines update and provided the following comment • Appendix 1—Tables 34 and 35:The VMT assessment estimated that there would be an additional 3,975 employees created by the protect in 2040. Please provide the source of how the DEIR converted square feet of project development to number of employees to the model project land use. The transportation model that was used to estimate vehicle miles of travel for the proposed project uses dwelling units and number of employees by employment type as land use inputs General conversion factors are often used to convert a development by square foot to an associated number of employees These factors are often developed for use in fiscal assessments to estimate the level of employment within a project,and can also be correlated by reviewing the Institute of Transportation Engineer Trip Generation Manual rates when data is presented that is based on both square feet and employees For this project,an initial conversion factor of approximately 1 employee per 250 square feet was used for the retail component of the project site, and approximately 1 employee per 400 square feet was used for the medical components of the project. The resulting trip generation estimated by the model was then compared with the trip generation estimates used to evaluate off site impacts. For consistency between the VMT assessment and the off-site intersection analysis,the conversion rates were reduced for the medical component of the project to approximately 1 employee per 330 square feet such that the vehicle trip generation estimated by the model closely matched trip generation used in the off-site intersection assessment Response to ACTC-7 The agency noted that the Draft DR indicated that the and use assumptions in the Alameda CTC travel model are consistent with the Association of Bay Area Governments (ABAG) population and employment projections may differ from the City of Dublin's model. While this is true,the agency noted that land use assumptions in the Alameda CTC model has been reviewed by City of Dublin staff in 2014 and incorporates its feedback The comment is noted, no further response is necessary Response to ACTC-8 The agency noted that the Draft EIR concluded that in 2040,the following MTS roadway segments would experience significant project impacts • Dublin Boulevard between Camp Parks Boulevard and Fallon Road • Hopyard Road/Dougherty Road between 1-580 and Scarlett Drive • Isabel Avenue between Stanley Boulevard and Concannn Boulevard • Vallecitos Road between 1-680 and Isabel Avenue [ ] First Carbon Solutions 3-17 City of Dublin-Kosser Dublin Medical Center Protect Responses to Written Comments ;mot EIR The agency noted that the Draft EIR acknowledged • That improvements to parallel corridors in the region would provide alternative routes and additional transportation capacity in the region. • The project developers would help fund improvements through payment of the City of Dublin and Tri-Valley Regional traffic impact fees However,since implementation of a parallel capacity cannot be assured at this time,the impacts on these roadways would remain significant and unavoidable The commenter correctly identifies the projects cumulative impact to MTS roadway segments, as well as the identified mitigation measures and conclusions on significant and unavoidable impacts. No further response necessary Response to ACTC-9 The agency provided concluding remarks to close the letter. No response is necessary 3-18 serstCarbon Solutions DSRSD Page 1 of 2 0 Dublin San Ramon 0510ublinBoulevard phone(9251828-0515 Services District Dublin,CA 94568-3018 fax(925)829-1180 Water,systevt le(regxkdwater www dsrsd corn March 21,2016 Kristi Bascom,Principal Planner City of Dublin Community Development Department 100 Civic Plaza Dublin,CA 94568 Subject: Comments on Draft Environmental Impact Report(DEIR) Kaiser Dublin Medical Center Project(PA 08-050) Dear Ms Bascom: Thank you for providing Dublin San Ramon Services District(DSRSD,District)the opportunity to review and comment on the Draft Environmental Impact Report(DEIR)for The Kaiser Dublin Medical Center Project(Project) DSRSD has a significant role in the area to be developed by the Project. Our agency took note of the list of environmental issues f covered by the Draft EIR We have included our comments below on the environmental topics that bear on our agency's responsibilities in the area of the Project Land Use and Planning DSRSD currently serves as the potable water,recycled water,wastewater collection and wastewater treatment utility for the area of the Project and surrounding areas. As the provider for these utilities, DSRSD is responsible for the planning and development of the infrastructure necessary for those services. Our intent is to ensure the infrastructure Is adequately planned to meet the interim as well as the ultimate build-out needs of the area. 2 DSRSD is the utility provider for the currently developed sections of Dublin surrounding the Project. The development of services for the Project must be done in a way that does not disrupt or eliminate the services for the active portions of the City of Dublin near the Project. Those services are to remain ongoing throughout the construction and completion of the Project. Potable Water Supply and Senate DSRSD will provide potable water to the Project The wholesale provider for the District is Zone 7 Water Agency. Zone 7 provides potable water to retailers In the Tn-Valley area including DSRSD,City of Pleasanton,City of Livermore and California Water Company(also in Livermore)and regulates the withdrawal and recharge of the underlying groundwater 3 DSRSD adopted a Water Supply Assessment and Availability for the project on September 1,2015 Subsequent to this adoption,Zone 7 adopted its 2015 Urban Water Management Plan(UWMP)on March 16,2016. DSRSD is preparing its 2015 UWMP and expects to adopt the plans to adopt it in June 2016. All studies show that adequate water supply will be available for the project through its projected phases. Fire flow Water Supply DSRSD currently provides facilities that will provide a maximum fireflow water volume of 4,000 gpm. If this project will require a larger volume than 4,000 gpm for fireflow conditions,the additional volume must be provided by the 4 project's own internal potable water storage Recycled Water Supply and Service DSRSD currently provides recycled water service to sections of the City of Dublin around the Project. As a 5 condition of potable water service,DSRSD will require the Project to plan for and build a recycled water H\ENGDEPI\PERMfl5' eveiopmennindustnal_CommerciaiKaver Permanence Dublin Medical Center OP-15-289L15PF01-Kaisen06 Studies and Reports\Karser DEIRLCOmments Final-DOR Kaiser Dublin Med Cir PA 08-05 3-21-16 doe DSRSD Page 2 of 2 0 Dublin San Ramon 7051 Dublin Boulevard phone(925)828-0515 Services District Dublin,CA 94560-3018 fax(925)829-1180 Winer,RUStewarq recycled water wwwdsrsd.com Kaiser DEIR Comments Page 2 of 2 distribution network for landscape irrigation in the Project area. This is a potable water conservation element. An Increase in the use of recycled water in the Tri-Valley area has an impact on reducing the ultimate total potable $ water demand on Zone 7's water supply. Currently DSRSD owns and operates a facility for recovering recycled water at its wastewater treatment plant at 7399 Johnson Drive In Pleasanton. DSRSD is also framing plans to CONT increase the production and distribution of recycled water from the plant. Please note that text on page 2-18 of the DEIR raises the possibility that recycled water would be used for"...toilet flushing(to the extent consistent with legal requirements for medical facilities and patient safety)." DSRSD does not currently have standards and guidelines established for using recycled water for any other purpose than landscape irrigation. If the Project plans to use recycled water for purposes other than landscape irrigation,those 6 plans must be discussed and reviewed with the District and ultimately must receive approval from the Engineering Services Manager Wastewater Treatment DSRSD believes that current capacity at the wastewater treatment plant is adequate to serve the proposed Project. However,because this is a large project in the commercial/industrial category;source control requirements may be required. Pretreatment of the wastewater may also be required depending on the constituents in the raw 7 wastewater The source control requirements are intended to protect the District's wastewater treatment process. This project may be required to obtain a DSRSD wastewater discharge permit as part of the application process. Wastewater Disposal The proposed Project would increase the amount of treated wastewater leaving the Tri-Valley area. Disposal of treated effluent from DSRSD's wastewater treatment plant is the responsibility of the Livermore Amador Valley Water Management Agency(LAVWMA). LAVWMA currently exports secondary treated wastewater to the East 8 Bay Dischargers Authority(EBDA)interceptor pipeline for ultimate discharge to the San Francisco Bay via a deepwater outfall Water treated at DSRSD's treatment plant that is not converted to recycled water for landscape irrigation is disposed of through the LAVWMA system. Thank you for notifying DSRSD of the upcoming Draft Environmental Impact Report Please contact Stan Kolodzie 9 at(925)875-2253 or me at(925)875-2255 should you have any questions. Sinc- y / /// 'HODORA N.BIAGTA Principal Engineer SK/RN B/ST cc: Stan Kolodzie Bonifacio Duenas Ryan Pendergraft File: DP-15-289,15PF01(5.0)Chron H.\EHGDEPI\PERMnS\Development\Industrial_Commertlal\xalter Permanente Dublin Medical renter DP-15-289\15Pr01-xaner\065tudies and Reporis\karser DEIR\Comments Final-DEIR Kaiser Dublin me('-Or PA w-05 321-16.dm City of Dublin-Kaiser Dublin Medical Center Project Final SIR Responses to Written Comments Dublin San Ramon Services District/DSRSD) Response to DSRS0-1 The agency provided introductory remarks to open the letter No response is necessary. Response to DSRSD-2 The agency provided background information about the services it provides and its infrastructure planning efforts. The agency stated that the development of the proposed project must be done in a way that does not disrupt or eliminate services for active portions of the City of Dublin near the project site As discussed on Draft EIR pages 2-17 and 2-18,the proposed project would connect via service laterals to existing underground potable water, recycle water,and sewer lines located within Dublin Boulevard Installation of service lateral connections will be conducted in accordance with DSRSD's regulations, including those that pertain to avoidance of disruption of service to other users Moreover,the existing potable water, recycled water, and sewer lines within Dublin Boulevard have adequate capacity to serve the project and no off-site improvements would be necessary This would avoid the potential for disruption or elimination of services for other users in Dublin. Response to DSRSD-3 The agency stated that it would provide potable water to the proposed project and provided background information about local water supply sources. DSRSD noted that it adopted a Water Supply Assessment and Availability for the proposed project on September 1, 2015 and indicated that Zone 7 Water Agency adopted its 2015 Urban Water Management Plan on March 16,2016 The agency advised that it is currently preparing its 2015 Urban Water Management Plan and expects to adopt it in June 2016. DSRSD stated that all three studies show that adequate water supply would be available for the proposed project through its projected phases. The Draft EIR also concluded that adequate water supply would be available for the proposed project through its projected phases,which is based on the Water Supply Assessment and Availability the agency adopted on September 1, 2015 The complete Water Supply Assessment and Availability is provided in Draft EIR Appendix 1 Response to DSRSD-4 The agency stated that it currently provides a maximum fire flow volume of 4,000 gallons per minute and noted that if the project requires a higher volume,the additional capacity must be provided by the project's internal potable water storage Prior to issuance of building permits for each phase,the City of Dublin and D5R5D will have the opportunity to review the proposed project's building plans to determine applicable fire flow requirements and whether additional internal potable water storage must be provided. Response to DSRSD-5 The agency stated that it will require the proposed project to plan and build a recycled water distribution network for landscape irrigation in the project area. DSRSD provided background on its recycled water system First Carbon Solutions 3-21 City ofOublin-Kmser Dublin Medical Center Project Responses to Written Comments Final FIR The Draft EIR discloses that the proposed project includes a recycled water distribution system on pages 2-17 and 2-18 and its impacts were evaluated where appropriate in the Draft EIR. Response to DSRSD-6 The agency referenced a statement from Draft DR page 2-18 about recycled water being used for toilet flushing to the extent it is consistent with legal requirements for medical facilities and patient safety. DSRSD noted that it does not have any current standards or guidelines for using recycled water for any other purpose than landscape irrigation and stated that any proposed use of recycled water for non-landscape use must be reviewed and approved by the agency. Prior to issuance of building permits for each phase,the City of Dublin and DSRSD will have the opportunity to review the proposed project's building plans to determine if recycled water is proposed for non-landscape use If such use is proposed,the agency will be engaged as appropriate for review and approval. The analysis of project potable water demand did not include use of recycled water for any indoor uses. Response to DSRSD-7 The agency stated that it believes that the current capacity at the Regional Wastewater Treatment Facility in Pleasanton is adequate to serve the proposed project. DSRSD noted that because the proposed project falls in the"commercial/industrial" category,source controls may be required, including pretreatment. The agency indicated that the proposed project may be required to obtain a DSRSD wastewater discharge permit as part of the application process Prior to issuance of building permits for each phase,the City of Dublin and DSRSD will have the opportunity to review the proposed project's building plans to determine if source controls or a wastewater discharge permit is required If source controls or a wastewater discharge permit is determined to be necessary,the agency's existing regulations and process will be followed. Response to DSRSD-8 The agency noted that the proposed project would increase the amount of treated wastewater leaving the Tn-Valley area and provided background about the Livermore Amador Valley Water Management Agency,which conveys effluent to an outfall in San Francisco Bay. DSRSD noted that wastewater treated at the Regional Wastewater Treatment Facility that is not reused as recycled water is discharged into San Francisco Bay. As previously noted,the proposed project would use recycled water for landscape irrigation and potential toilet flushing To the extent that this allows treated effluent to be reused as recycled water instead of being discharged into San Francisco Bay,this would be considered beneficial in terms of conveyance capacity for the Livermore Amador Valley Water Management Agency Response to DSRSD-9 The agency provided concluding remarks to close the letter. No response is necessary. 3-22 F,rsttorbon Solutions LIVERMORE U V L RM&T E Page 1 of 3 CAI imp NIA March 21, 2016 City of Dublin Community Development Department 100 Civic Plaza Dublin, CA, 94568 Attn: Kristi Bascom, Principal Planner RE: Draft Environmental Impact Report for the Kaiser Dublin Medical Center Project Dear Ms. Bascom: Thank you for sending the City of Livermore the Draft Environmental Impact Report (Draft EIR) for the proposed Kaiser Medical facility in Dublin. The new medical facility 1 will provide important services that will benefit the Tri-Valley region. Here are the City's comments after review of the Draft EIR sent by your office on February 5, 2016. 1. The City of Livermore is currently engaged in a multi-agency effort to facilitate a Bay Area Rapid Transit (BART) extension to Livermore. The City of Livermore requests that the City of Dublin consider potential right-of-way (ROW) expansion necessary to extend BART to Livermore in planning and approving proposed developments along the 1-580 corridor. Preliminary highway widening 2 designs shows the necessity of 40+1-feet of ROW at this location. Exhibits 2- 4a, b and c include potential BART right-of-way in the legend. However, right- of-way line is not shown on the figure. The City recommends Figures 2-4a, b and c depict the BART right-of-way line on the site plans and that Dublin coordinate with BART staff to ensure adequate right-of-way is available for the BART extension to Livermore. 2. Staff requests the Draft EIR acknowledge that the City is currently conducting the land use planning process to prepare the Isabel Neighborhood Plan that will meet the needs of the Livermore community, support City and community goals, and complement BART'S proposed extension to Livermore. The table 3 below summarizes new land uses associated with development or redevelopment of opportunity sites. Livermore staff is available to provide additional information regarding the planning process and timing. oy hall 1052:9 4411 L■eunuie Axenu. L rcennore,CA 94550 omle a lne,mui, .a u. LIVERMORE NOA of a DEIR for Kaiser Dublin Medical Center Project Page 2 of 3 March 21, 2016 Page 2 of 3 Within the 1/2 Total New Land Use Type mile radius of Outside the 1 Development BART station mile radius in Planning (focus area) Area Residential (housing units) 4,000 225 4,225 Non-residential(square feet) Office 1,300,0001 550,000 1,850,000 3 Business Park 0 r 400,000 400,000 COW Neighborhood 375,000 0 375,000 Commercial General Commercial 275,000 100,000 375,000 Total 1,950,000 1,050,000 3,000,000 Jobs 7,470 2,800 10,270 3. Considering the potential trip generation with full campus buildout, the El Charro Road at 1-580 Westbound Ramps (LOS E, AM peak hour) intersection is projected to degrade to an overall LOS E. Further, at Project buildout, the intersection of Isabel Avenue and Jack London Boulevard is projected to degrade to LOSE in the am peak. The Draft EIR notes that the City of Livermore General Plan, describes this intersection as potentially exempt from the City of Livermore LOS D standard, 4 as it carries a high proportion of regional cut-through traffic and further widening • above planned levels may not be feasible or desirable (City of Livermore General Plan Policy CIR-4.1, p. 4). Further, that the City of Dublin cannot make the determination of whether the exemption under the City of Livermore General Plan applies. That decision is in the control of the City of Livermore, which is a separate agency from the City 4. Project buildout would potentially result in vehicle queues exceeding the available storage, or would increase vehicle queues by more than 25 feet (1 vehicle) for at least one movement where the queue is projected to already exceed the available storage at the following intersections: • • Airway Boulevard/North Canyons Parkway 5 • Isabel Avenue/Jack London Boulevard • Isabel Avenue/Stanley Boulevard •r The City of Livermore respectfully requests that the City of Dublin and applicant ti explore alternatives in coordination with the City of Livermore to mitigate these potentially significant transportation impacts. .. • LIVERMORE NOA of a DEIR for Kaiser Dublin Medical Center Project Page 3 of 3 March 21, 2016 Page 3 of 3 5. The DEIR notes the location of the Project within Conservation Zone 2 of the East Alameda County Conservation Strategy. Further, that the City of Dublin adopted the EACCS as guidance for public infrastructure/capital improvement projects and uses the document to provide input on managing biological 6 resources and conservation priorities during public project-level planning and environmental permitting. The City of Livermore strongly recommends that the applicant consult the Conservation Strategy for guidance regarding avoidance and minimization measures for any sensitive habitat for focal animal and plant species. Thank you again for the opportunity to comment on the Drat EIR. Please continue to inform Livermore regarding the status of this application, the ER process and any 7 other CEQA related notices and documents. If you have any questions, please call me at (925) 960-4475. /CI Andy Ross, Assistant Planner cc: Bob Vinn, Assistant City Engineer Steve Stewart, Principal Planner City of Dublin-Kaiser Dublin Medical Center Project Final EIR Responses to Written Comments City of Livermore(LIVERMORE) Response to LIVERMORE-1 The agency provided introductory remarks to open the letter. No response is necessary Response to LIVERMORE-2 The agency noted that it is currently engaged in a multi-agency effort to extend BART to Livermore and requested that the City of Dublin consider potential right-of-way expansion necessary to facilitate the extension The agency noted that preliminary designs indicated that approximately 40 feet of right-of-way would need to be acquired at this location and noted that Draft EIR Exhibits 2-4a, b, and c show BART right-of-way in the legend The agency noted that the right-of-way line is not shown on the exhibits,and it recommended that they be revised to depict this feature and that the City of Dublin coordinate with BART staff to ensure that adequate right-of-way is available The Livermore BART extension is addressed in Master Response 1. Response to LIVERMORE-3 The agency requested that the Draft EIR acknowledge that the City is currently conducting the land use planning process to prepare the Isabel Neighborhood Plan that will complement the proposed Livermore BART extension. The agency referenced a table showing that the Isabel Neighborhood Plan has a buildout of 4,225 dwelling units and 3 million square feet of commercial uses At the time of Draft FIR release(February 3, 2016),the City of Livermore had not begun the CEQA process for the Isabel Neighborhood Plan Thus, it was omitted as a cumulative project m Draft EIR Table 4-1 However,certain projects that are within the boundaries of the Isabel Neighborhood Plan area were listed as cumulative projects in Table 4-1 (for example,the Sage Residential Project and the Livermore BART extension). Thus,the Draft EIR accounted for all known cumulative projects at time of public release,which included two that were encompassed by the Isabel Neighborhood Plan For these reasons,there is no basis to revise the Draft EIR to include mention of additional projects Response to LIVERMORE-4 The agency noted that the intersection of El Charro Road/I-580 Westbound Ramps (LOS E,AM peak hour) intersection is projected to degrade to an overall LOSE and the intersection of Isabel Avenue/Jack London Boulevard is projected to degrade to LOS E in the AM peak hour The agency indicated that the Draft EIR notes that the City of Livermore General Plan describes this intersection as potentially exempt from the City of Livermore LOS D standard,as it carries a high proportion of regional cut-through traffic and further widening above planned levels may not be feasible or desirable. The agency asserted that the City of Dublin cannot make the determination of whether the exemption under the City of Livermore General Plan applies and such a decision is in the control of the City of Livermore. In the context of Isabel Avenue/lack London Boulevard,the Draft EIR states on page 3 11-113 that The City of Dublin cannot make a determination of whether the exemption under the City of Livermore General Plan applies"and That decision is in the control of the City of Livermore " The Draft EIR's text is consistent with the City of Livermore's position on this matter. The EIR concluded there was no feasible mitigation measure available to address this impact that is within the control of the City of Dublin. FnstCarbon solutions — - 3-27 City of Dublin-Kinser Dublin Medico:Center Project Responses to Written Comments Final FIR In the context of El Charro Road/I-580 Westbound Ramps,the Draft EIR evaluated impacts using City of Pleasanton criteria. A significant impact was identified and mitigation measures were proposed As the interchange is not under the control of the City of Dublin, a significant and unavoidable impact was identified. The project will be required to provide a fair-share contribution to fund the construction of improvements. Response to LIVERMORE-5 The agency noted that project buildout may result in vehicle queues exceeding the available storage, or would increase vehicle queues by more than 25 feet(1 vehicle)for at least one movement where the queue is projected to already exceed the available storage at the following intersections-Airway Boulevard/North Canyons Parkway, Isabel Avenue/Jack London Boulevard;and Isabel Avenue/Stanley Boulevard. The City of Livermore requested that the City of Dublin and applicant explore alternatives in coordination with the City of Livermore to mitigate these potentially significant transportation impacts. The Draft EIR used the following significance criteria for queuing impacts: • 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 0 e, move)separately from the left turn lane, or • 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 Vehicle queue impacts were identified at a number of intersections, particularly those close to the project site where project traffic would be most concentrated, in addition to the intersections noted m in the comment. Mitigation measures for queue impacts typically include traffic signal upgrades or u. timing adjustments, extending the available vehicle storage length to minimize the effects of vehicle queue spillback, constructing additional transportation capacity on parallel routes to disperse travel or demand, and implementing project-level TMD programs to reduce net-new vehicle trip generation u, The project applicant will be required to pay all applicable local and regional transportation impact fees that will fund the construction of transportation projects in the In-Valley area Additionally,the w„ project will be conditioned to implement and monitor a TDM program Furthermore, Mitigation Measures TRANS-3,TRANS-6a,TRANS-7a,TRANS-7b,TRANS-7c,TRANS-7d,TRANS-8,TRANS-19b, ^' TRANS-19c,TRANS-19d, and TRANS-34a all provide improvements that either fully mitigate or its partially mitigate queueing impacts at local intersections However, as the effectiveness of these 0 measures to reduce vehicle queue spillback is uncertain,the queue impact was identified as Illik significant and unavoidable The ultimate design of the Airway Boulevard/North Canyons Parkway intersection is dependent on the potential Dublin Boulevard extension from Fallon Road connecting to the current terminus of North Canyons Parkway The timing and ultimate design of this connection is unknown, and the City OP looks forward to a collaborative planning process with the City of Livermore as plans for this connection develop. 3-28 FRSttarbon solutions �,..a...n e.m....n�. i.x,xoe ao•ew�a rover cw.. .m=m ..oe.< mne..omm.rmmo rr City of Dublin-Kaiser Dublin Medical Center Protect Final FIR Responses to Written Comments City of Dublin staff have already reached out to Livermore staff to coordinate potential improvements. Response to LIVERMORE-6 The agency referenced the Draft El Ws evaluation of the proposed project's consistency with the East Alameda County Conservation Strategy (EACCS) and noted that the City of Dublin uses the EACCS as guidance for public infrastructure/capital improvement projects Although Applicants are encouraged to consult the EACCS,the EACCS guidance is not required by the City of Dublin to be applied to private projects such as this one. A biological survey was conducted of the project site and found that it provides suitable habitat for the burrowing owl,the California red-legged frog, San Joaquin spearscale, and Congdon's tarplant (The other special-status species or sensitive habitats did not have potential to occur on-site). As such, Mitigation Measures BIO-la (rare plants), BIO-1c(burrowing owl), and B10-1d/le (California red-legged frog)were proposed to mitigate impacts on these species Even though the EACCS is not required to be applied,this is consistent with the EACCS's conservation priorities and would ensure that impacts on these species are mitigated to a level of less than significant. Response to LIVERMORE-7 The agency provided concluding remarks to close the letter No response Is necessary FirstCarbon Solutions 3-29 THE CITY OF PLEASANTON Page 1 of 2 pLEASANTON< March 21, 2016 Kristi Bascom Principal Planner City of Dublin Community Development Department 100 Civic Plaza Dublin, CA 94568 RE: Draft Environmental Impact report Kaiser Medical Center, Dublin Dear Ms. Bascom: Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Kaiser Medical Center Project, an approximately 1 2 million square foot 1 medical campus and commercial uses. It is my understanding that the project site contains approximately 58.7 acres and is located in the eastern portion of the City of Dublin. The DEIR states that the proposed project would require amendments to both the City of Dublin General Plan and Eastern Dublin Specific Plan to create a new "Campus Medical" designation and to re-designate the project site from "Campus Office" to 2 "Campus Medical." The City of Pleasanton respectfully submits the following comments: 1. The Dublin intersection analysis includes a 95% queue analysis for left turn pockets; a similar analysis should be completed for the intersections to determine if similar safety related impacts exist in Pleasanton. Specifically intersections 15 and 25 in Appendix J, which have 250 to 300 project generated left turns in each 3 peak hour. While the turn pocket lengths are generous, queue impacts may extend beyond the available storage and should be reviewed for safety purposes. 2. Mitigation Measure TR-12 identifies the need for a second south-bound left-turn lane at the intersection of Santa Rita Road and 1-580 eastbound ramps The mitigation states that Kaiser will be required to pay its "fair share " Please 4 include language requiring Kaiser to enter into a reimbursement agreement, a memorandum of understanding, and / or impose a condition of approval that clarifies how the "fair share" will be calculated and when the payment will be required and to whom it shall be paid. COMMUNITY DEVELOPMENT P. O. BOX 520, Pleasanton, CA 94566-0802 Planning Building& Safety Engineering Traffic Inspection 200 Old Denial Are 200 Old Bernal Are 200 Old Rcrnal Ave 200 Old Bernal Ave 157 Main Sired (9251931-5600 (925) 9315300 19251 931-5650 (925)931.5650 (9251 931-5680 Fax. 931-5483 lax 931-5478 Fax 931-5479 Fax 931-5479 Fax 911.5484 PLEASANTON Page 2 of 2 Kaiser Medical Center Project Page 2 March 21,2016 3. Mitigation Measure TR-18 (El Charro Interchange Improvements) identifies the need for Phase 2 interchange modifications (page 86 of Appendix J — Transportation Assessment), but only requires Kaiser to pay fees to mitigate the impact. Given that the mitigation is the construction of additional lanes on the 5 overpass and the Kaiser project will generate 674 PM project trips on the southbound section of the overpass, the project should be required to construct the improvement. The added volume will require nearly one full vehicle travel lane. Additional capacity does not exist and the Kaiser project should be required to mitigate their impact by constructing the improvement. Thank you for the opportunity to comment. I look forward to our continued cooperative and proactive effort in addressing possible future impacts of this project. 6 If you have any questions, please contact me or Mike Tassano, Traffic Engineer at (925) 931-5600. Sinc ely, erry Beau in Director of Community Development Cc: Mike Tassano, Traffic Engineer City of Dublin—loner Dublin Medico)Center Project Final EIR Responses to Written Comments City of Pleasanton(PLEASANTON) Response to PLEASANTON-1 The agency provided introductory remarks and a summary of the project to open the letter No response is necessary. Response to PLEASANTON-2 The agency summarized the proposed General Plan and Specific Plan Amendments. No response is necessary. Response to PLEASANTON-3 The agency noted that the Draft EIR's intersection analysis includes a 95th percentile queue analysis for left-turn pockets and stated that a similar analysis should be completed for the intersections to determine if similar safety-related impacts exist in Pleasanton The agency specifically listed the intersections of Santa Rita Road/I-580 Eastbound Ramps and El Charro Road/I-580 Eastbound Ramps,which have 250 to 300 project-generated left turns in each peak hour. While turn pocket lengths are generous, queue impacts may extend beyond the available storage and should be reviewed for safety purposes Vehicle queues were reviewed at intersections in Pleasanton and, specifically,the two intersections listed by the agency. No 15 (Santa Rita Road/I-580 Eastbound Ramps)and No 25(El Charro Road/I- 580 Eastbound Ramps) A significant queue and level of service impact was identified at Santa Rita Road/I-580 Eastbound Ramps. Vehicle queues at the El Charro Road/I-580 Eastbound Ramps are expected to remain within the available storage, as detailed in the Transportation Assessment in Draft EIR Appendix 1 Mitigation measures were proposed to reduce the intersection and queue impact to a less than significant level (Mitigation Measure TRANS-12, constructing a second southbound left-turn lane and traffic signal upgrades)were identified However, as the intersection is not within the control of the City of Dublin,the impact would remain significant and unavoidable. Response to PLEASANTON-4 The agency noted that Mitigation Measure TRANS-12 identifies the need for a second southbound left-turn lane at the intersection of Santa Rita Road and 1-580 eastbound ramps and indicated that the mitigation states that Kaiser will be required to pay its "fair share " The agency requested that language be added requiring Kaiser to enter into a reimbursement agreement, a memorandum of understanding, or impose a condition of approval that clarifies how the "fair share"will be calculated,when the payment will be required,and to whom it shall be paid. The City of Dublin has initiated conversations with regional agencies (City of Livermore, City of Pleasanton, and Alameda CTC)regarding the establishment of an escrow account where fair-share funds can be deposited for interchange improvements not included in local or regional fee programs. The fair-share payments would be in addition to the required local and regional fee payments,unless the identified improvements are added to a local or regional fee program prior to the fair-share payment requirement being triggered;this language is included in revised MM TRANS-12 as shown in Section 4, Errata First Carbon Solutions 3-33 City of Dublin-Kaiser Dublin Medical Center Project Responses to Written Comments Final EIR Response to PLEASANTON-5 The agency noted that Mitigation Measure TRANS-18 identifies the need for Phase 2 interchange modifications,but only requires Kaiser to pay fees to mitigate the impact Given that the mitigation is the construction of additional lanes on the overpass and the Kaiser project will generate 674 PM project trips on the southbound section of the overpass,the project should be required to construct the improvement The added volume will require nearly one full vehicle travel lane. The agency stated that additional capacity does not exist and the Kaiser project should be required to mitigate their impact by constructing the improvement. The Phase 2 Fallon Road interchange project is identified in the Alameda CTC Capital Project Delivery Plan as a freeway improvement project (1-580 Freeway Corridor Management System)that will need federal, regional,and local funding The City of Dublin is the Sponsor Agency for this project and Is working with the Alameda CTC to develop the preliminary engineering documents for Phase 2 project. As this is a planned improvement of regional significance, it is beyond the scope of a single development project to construct. Legal nexus requirements apply to mitigation measures under CEQA Therefore,given the extent of the project impact,fair-share payment is the appropriate mitigation measure for this project rather than requiring construction of the improvement by the applicant Response to PLEASANTON-6 The agency provided concluding remarks to close the letter No response is necessary. 3-30 FrstCorbon Solutions e o os. i,o xu er,.senweu run v ecw .m.'`o..o="=="ew."..c.mm..vao., SAN RAMON Page 1 of 2 ENGINEERING SERVICES DIVISION San Ramon MEMORANDUM DATE: March 21, 2016 TO: Kristi Bascom, Principal Planner City of Dublin CC: Brian Bornstein. City Engineer Dehhie Chamberlain. Division Manager Mike Talley. City Traffic Engineer Deborah Fehr, Associate Traffic Engineer FROM: Theresa Peterson, Associate Engineer SUBJECT: Dublin Kaiser DEIR Review Comments Please see the below comments from traffic Engineering on the subject Dublin Kaiser DFIR• The City of San Ramon Traffic Engineering Division has the following comments on the Dublin 1 Kaiser DEIR 1. Dougherty Road is a major regional arterial that provides north-south access and runs through the City of San Ramon The City of San Ramon requires the analysis of intersections when a project adds 50 or more new trips to any intersection The DEIR does not analyze any intersections on Dougherty Road north of Dublin Boulevard: 2 therefore, the Project Trips (specifically, the northbound and southbound trips north of the intersection) at the intersection of Dougherty Road / Dublin Boulevard were reviewed • a Project Full-Buildout Added Trips — There are 204(128) southbound trips and 55(271) northbound trips added to Dougherty Road north of Dublin Boulevard. Flow man) of these trips would be added to, for example, Dougherty Road 3 Bollinger Canyon Road (South)? If more than 50 new trips, this intersection should be Included in the analysis • h. Project Full-Buildout Added Trips Cumulative (2040) Conditions — The number of Project Trips drops significantly from the Project Full-Buildout Added Trips to 41127) southbound trips and 16(75) northbound trips on Dougherty Road north of 4 Dublin Boulevard. Please justify. 2. Westbound left turns at Dougherty Road / Dublin Boulevard. Under the Near-Term (2025) Conditions the westbound left turn shows volumes of 310(1,120). Under 5 Cumulative (2040) Conditions there are 50(60) westbound. Please provide the justification for the 260(1.060) volume reduction for the westbound left turn? 3. A mitigation to consider is the installation of an adaptive traffic signal system to lessen the impacts. 'Me City of San Ramon has seen a significant reduction in delay along the 6 SAN RAMON Page 2 of 2 Bollinger Canyon Road and Crow Canyon Road corridors where an adaptive signal 6 system was installed. The City of San Leandro installed an adaptive signal system with CONT the new ly constructed Kaiser facility • • r rI I• City of Dublin—Kaiser Dublin Medical Center Protect Final DR Responses to Written Comments City of San Ramon(SAN RAMON) Response to SAN RAMON-1 The agency provided introductory remarks to open the letter No response is necessary. Response to SAN RAMON-2 The agency stated that Dougherty Road is a major regional arterial that provides north-south access and runs through the City of San Ramon,and it noted that the City requires analysis of intersections when a project adds 50 or more new trips to any intersection The agency noted that the Draft EIR did not evaluate any intersections north of Dublin Boulevard/Dougherty Road As noted on page 3 11-6 of the Draft EIR,the study intersections were selected in consultation with respective jurisdiction staff(including San Ramon), based on a review of the project location and the amount of traffic that could be added to the intersections in the project vicinity In the case of Dougherty Road, it should be noted that the Dublin/San Ramon city limit line is located 1.8 miles north of the intersection of Dublin Boulevard/Dougherty Road The segment of Dougherty Road between Dublin Boulevard and the Dublin/San Ramon city limit line includes the signalized intersections of Dougherty Road/Sierra Lane, Dougherty Road/Scarlett Drive, Dougherty Road/Camp Parks Boulevard, and Dougherty Road/Amador Valley Boulevard—all of which are in the Dublin city limits Furthermore, all of these intersections would experience equivalent or greater project- related traffic volumes than any intersection on Dougherty Road within the San Ramon city limits. The City of Dublin determined that evaluation of City of Dublin intersections on Dougherty Road north of Dublin Boulevard was not warranted because project-related traffic would not have the potential to substantially increase traffic volumes to cause level of service to deteriorate to unacceptable levels Thus,the same conclusion would apply to City of San Ramon intersections on Dougherty Road Response to SAN RAMON-3 The agency noted that there are 204 AM peak-hour and 128 PM peak-hour southbound trips,and 55 AM peak-hour and 271 PM peak-hour northbound trips added to Dougherty Road north of Dublin Boulevard The agency inquired how many of these trips will be added to the intersection of Dougherty Road/Bollinger Canyon Road, and asserted if they exceed 50 trips,then this intersection should be included in the analysis The intersection of Dougherty Road/Bollinger Canyon Road (south) is approximately 3 miles from Dublin Boulevard with numerous intervening intersections that would allow for the distribution project traffic Since this segment of Dougherty Road primarily adjoins residential neighborhoods in Dublin and San Ramon, it would be expected that most project-related trips on this roadway would be made by local residents traveling to and from their place of residence. Thus, it would be logical to assume that project traffic would be distributed to the neighborhoods that connect to Dougherty Road such that there would be fewer than 50 peak-hour net-new project trips traveling through the intersection of Dougherty Road/Bollinger Canyon Road (south) Since fewer than 50 new peak-hour project trips are expected to travel though this intersection, no analysis is required Firstcarboa Solutions 3-37 City of Dublin—Kaiser Dublin Medical Center Project Responses to Written Comments Final FIR Response to SAN RAMON-4 The agency noted that,at full project buildout(2040),the number of project trips drops significantly from the project full-buildout added trips to 41 AM peak hour and 27 PM peak hour southbound trips and 16 AM peak hour and 75 PM peak hour northbound trips on Dougherty Road north of Dublin Boulevard and requested justification. The changes in added traffic at the Dougherty Road/Dublin Boulevard intersection in the Cumulative condition are primarily due to the future Scarlett Drive extension,that will provide an alternate travel route to Dougherty Road Response to SAN RAMON-5 The agency indicated that near-term (2025)westbound left-turn volumes at Dougherty Road/Dublin Road are 310 AM peak-hour trips and 1,120 PM peak-hour trips. The agency noted that cumulative (2040)westbound left-turn volumes at Dougherty Road/Dublin Road are 50 AM peak-hour trips and 60 PM peak-hour trips The agency requested justification for the decrease in left-turn volumes between the two scenarios It appears that the agency is referring to the westbound right-turn movement, not the left-turn movement The volume reduction is associated with the planned construction of the Scarlett Drive extension that would provide an alternate connection between Dougherty Road and Dublin Boulevard This connection would result in travel pattern shifts, including a reduction in the southbound left-turn movement volume from Dougherty Road to Dublin Boulevard, and the westbound right-turn volume from Dublin Boulevard to Dougherty Road Response to SAN RAMON-6 The agency noted that a mitigation to consider is the installation of an adaptive traffic signal system to lessen the impacts. The City of San Ramon has seen a significant reduction in delay along the Bollinger Canyon Road and Crow Canyon Road corridors where an adaptive signal system was installed The agency also noted that City of San Leandro installed an adaptive signal system with the newly constructed Kaiser facility The City is currently in the process of installing an adaptive traffic signal system along the Dublin Boulevard corridor and may add Dougherty Road to the Adaptive System as appropriate However, the adaptive system alone may not be adequate to fully mitigate the impacts, and the project impacts at the intersection of Dougherty Road and Dublin Boulevard will remain significant and unavoidable. 3-38 FrstCarbon Solutions • ZONE 7 Page 1 of 2 ore Amito,44, " ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT, ZONE 7 100 NORTH CANYONS PARKWAY• LIVERMORE,CA 94551 •PHONE(925)454-5000•FM(925)454-5727 r. March 16.2016 Pee C titer) City of Dublin Community Dec elopment Depanment n• 2 3 /u, 100 CI x rc Plaza D VB Dublin.CA 94568 L// ` Attn: Kristi Bascom.Principal Planner Re Comments on DEIR(ur Kaiser Dublin Medical Center Knsti. Zone 7 Water Agency(Zone 71 has ie rowed the referenced Draft EIR in the context of Zone 7's mission to pro)ide water supply. flood protection,and groundwater and stream management within the Livermore-Amador Valle) 1 We have comments for your consideration: I On page 3.7-2. • 1 he FIR should clarify Arroyo Mucha empties into the Alamo Canal,which from that 2 point downstream is called Arroyo de la Laguna 2 On p 3 7-2, W atcrohed • The project site is located in the Line G-3'watershed, not Tassalara Creek watershed 3 3 On p 3.7-3. Flood Hazard Areas: • The City might want to mention to the reader that the Area is based on FEMA 2009 4 information (as indicated in Exhibit 3.7-1) 4 On p.3 7-6. Alameda County Flood Control and Water Consen anon District(ACFC'WC D1. • For clant). change heading to"Zone 7 Water Agenc) (Zone 7)",as ACFCWC D does not hazejunsdiction in Dublin. • Revise paragraph to read. 'lone 7 is responsible for prosidling flood protection to the residents of Eastern Alameda Count) Zone 7 owns and maintains the downstream facility I me G-3.to which the project proposes to drain Drainage plans for 5 development projects must be nee iewed by Zone 7 to ensuic that the project does not propose an) impacts to downstream facilities In addition, dm elopment projects that in nh'e work 'Anhui Zone 7's right-of-way or that nnveli e construction.modification.or connection to a Lone 7 facility,ate required to obtain an Encroachment Permit and compls w all Lone 7 standards and specifications." 5 On p 3 7-13,Impact HYD-3. • Explain how new discharges occurring from 2/3 of the project site into an existing 6 stornwvatei basin does not require any additional treatment of rev icw Page 1 of 2 ZONE 7 Page 2 of 2 6. On p.3 7-14,MM HYD-3: • Change Alameda County Flood Control and Water Conservation District to Zone 7. 7 7 On p 3 7-14,Impact HYD-4: • The EIR needs to include an analysis of the displacement(shifting downstream)of the 8 flood hazard area as a result of the project. 8 On p 3.7-15,MM HYD-4' • Mitigation measure does not address the displacement of the flood hazard area in the event that the project constructs in the flood hazard area There is a potentially g significant impact if the floodplain were to be displaced downstream due to construction within the flood hazard area. Applicant must demonstrate that there is no impact We appreciate the opportunity to comment on this project If you have any questions on this letter, please feel free to contact me at(925)454-5005 or via email at eranbo zone7water corn. 10 Sincerely, CUR h Elkc Rank cc Carol Mahoney,Jeff Tang,Joe Seto,file Page 2 of 2 City of OuNm-kmser Dublin Medical Center Protect Final CM Responses to Written Comments Zone 7 Water Agency(ZONE 7) Response to ZONE 7-1 The agency provided introductory remarks to open the letter No response is necessary Response to ZONE 7-2 The agency stated that the Draft EIR's description of the Tassajara Creek watershed on page 3 7-2 should be revised to state that Arroyo Mocho empties into the Alamo Canal,which from that point downstream is called Arroyo de la Laguna The revision has been made and the change is noted in Section 4, Errata Response to ZONE 7-3 The agency stated that the project site is located in the"Line G-3"watershed, not the Tassajara Creek watershed,as stated on Draft EIR page 3 7-2 The revisions have been made and the changes are noted in Section 4, Errata Response to ZONE 7-4 The agency suggested that the discussion of Flood Hazard Areas on Draft EIR page 3.7-3 note that the flood mapping was conducted by the Federal Emergency Management Agency in 2009. The text on page 3 7-3 has been revised to note that three Letters of Map Revision were processed by the Federal Emergency Management Agency between 2004 and 2007 that determined that grading associated with the Dublin Ranch project had raised the developable portions of the project site to above the 100-year flood elevation The changes are noted in Section 4, Errata. The most recent Letter of Map Revision is provided in Appendix L Response to ZONE 7-5 The agency requested changes to the final paragraph on Draft EIR page 3.7-6, including changing the name of the agency to Zone 7 and using narrative text, as provided, summarizing its regulatory responsibilities The revisions have been made and the changes are noted in Section 4, Errata. Response to ZONE 7-6 The agency referenced the discussion in Impact HVD-3 and requested further explanation as to why runoff from the western two-thirds of the project site would not require any additional treatment or review In 2003,the Regional Water Quality Control Board (RWQCB)approved Waste Discharge Requirements and a Water Quality Certification for the Dublin Ranch Project under Order No R2- 2003-0032 The project site is located within the area covered by the Order and,therefore, is subject to the water quality requirements and the Stormwater Management Plan (SWMP)that was prepared for the Dublin Ranch development and approved by the RWQCB in conjunction with the Order In accordance with the approved SWMP for the Dublin Ranch Development,the existing regional water-quality basin was designed to accept and treat post-construction stormwater runoff from approximately two-thirds of the project site (western portion). Thus, stormwater runoff from FirstCarbon Solutions 3-41 c u ee v.,.,r.w., ,..L i„Ja i,.,,,mod, ...o...,,a..,,.,.omm..,.�.. City of Dublin-Kaiser Dublin Medical Center Project Responses to Written Comments Final EIR the western portion of the project site will not need to be treated and can he discharged directly into the public system. Stormwater runoff from the project site area that is outside the area served by the Regional Water Quality Pond (eastern portion)will need to be treated prior to discharge to the public system using current Low Impact Development standards contained in Order No. R2-2009-0074 (revised R2-2011- 0083) The LID standards will be reviewed during the Grading and Site Improvement Plan submittal Furthermore,subject to Order No. R2-2003-0031, hydro-modification (detention)will not be required for any portion of the project site In summary,the proposed project complies with all applicable stormwater quality regulations Response to ZONE 7-7 The agency requested that the agency name in Mitigation Measure HYD-3 be changed from Alameda County Flood Control and Water Conservation District to Zone 7 The revision has been made and the change is noted in Section 4, Errata Response to ZONE 7-8 The agency referenced Draft EIR Impact HVD-4 and stated that the Draft EIR needs to include an analysis of the displacement of the flood hazard area downstream as a result of the project Three Letters of Map Revision were processed by the Federal Emergency Management Agency between 2004 and 2007 that determined that grading associated with the Dublin Ranch project had raised the developable portions of the project site to above the 100-year flood elevation A copy of the May 3, 2007 Letter of Map Revision is provided in Final EIR Appendix L and documents all three revisions. As such,the text in Impact HYD-4 has been (1) revised to note that the developable portions of the project site are outside of a 100-year flood hazard area and (2)revised to strike Mitigation Measure HYD-4 The changes are noted in Section 4, Errata Response to ZONE 7-9 The author referenced Mitigation Measure HVD-4 and reiterated the previous comment about the EIR needing to provide analysis of the displacement of the flood hazard area downstream as a result of the project Refer to Response to ZONE-7-8. Response to ZONE 7-10 The agency provided closing remarks to conclude the letter No response is necessary. 3-02 NrstCarbon Solutions KAISER Page 1 of 5 thi KAISER PERMANENTE® National Facilities Services NCAL Service Delivery Operations 1950 Franklin Street, 12'"Floor Oakland,CA 94612 March 21, 2016 By E-mail: kristi.bascom(a)dublin.ca.gov Ms. Kristi Bascom, Principal Planner City of Dublin Community Development Department 100 Civic Plaza Dublin, CA 94568 Re Kaiser Dublin Medical Center Project— Draft Environmental Impact Report Dear Ms Bascom On behalf of Kaiser Foundation Hospitals, I am writing to express our appreciation for the opportunity to review and comment on the Draft Environmental Impact Report prepared for the Kaiser Dublin Medical Center Project ("DEIR") When Kaiser made the decision to acquire this large approximately 58 7 acre site in Dublin in 2006, it was with the intention of locating a major medical center We are grateful for the welcome Kaiser has continued to receive from the community and Dublin officials. We also appreciate the professional and collaborative approach 1 City Staff has shown as we have moved forward with our plans to provide enhanced health care services to the community on this terrific site. As noted in the City's 2012 Economic Development Strategy, Kaiser acquired land in East Dublin "for a medical facility that could create spinoff economic activity, possibly including medical services and retail amenities." Dublin is now closer than ever to realizing this vision. Project Overview The Medical Center will serve a critical public safety role by eventually serving over 134,000 Kaiser Permanente members in Dublin and the Tri-Valley region who currently must travel to Kaiser Permanente facilities in Walnut Creek, San Leandro or Antioch to access the wide range of health care services the Medical Center will offer. At full buildout, the Medical Center is anticipated to offer comprehensive services in state-of-the-art facilities, including urgent care, radiation/oncology services, outpatient surgery, diagnostic services, women's services, inpatient 2 care, surgical services and emergency care, and supporting ancillary health care services such as optical, pharmacy, laboratory, education and training These facilities will employ over 2,500 medical, professional, and supporting staff, and enhance local business revenues as employees and visitors purchase goods and services in the area. In addition, development of the western portion of the site for commercial uses will contribute jobs, tax revenue, and amenities for Dublin residents. KAISER Page 2 of 5 DEIR Review The DEIR provides a thorough description of the proposed Medical Center, including the measures that Kaiser will implement during the construction period to minimize impacts to residents, employees, and visitors in the area. We wish to emphasize that Kaiser is committed to contributing its "fair share" of traffic and infrastructure improvements at each phase of project 3 construction to ensure orderly development and integration of the Medical Center into the East Dublin neighborhood. At project buildout, we believe that these improvements will have a substantial contribution to the pedestrian, bicycle, transit, and vehicle circulation system. We also wish to note that the DEIR's analysis is based on very conservative assumptions regarding the impacts of project construction. While this approach is appropriate to ensure that all potential impacts are adequately studied, it necessarily results in "worst-case" conclusions regarding impacts such as traffic, air quality, and greenhouse gas emissions. To take greenhouse gases as an example, the DEIR assumes that all vehicle trips associated with the Medical Center will be "new" trips—rather than trips that would occur as part of the baseline, diverted from other existing medical facilities. Under these circumstances, we believe it is appropriate to acknowledge that using conservative assumptions may cause the Project-specific impacts to be overstated since as a practical matter, there are substantial traffic, air quality and 4 greenhouse gas benefits when health care services are closer to residents. Kaiser also prides itself on voluntarily implementing green building features and sustainability strategies—many of which are mentioned in the DEIR—that will reduce the Project's greenhouse gas contributions to the greatest extent feasible, including seeking LEED Gold certification. Green building features may include PVC-free materials (such as resilient flooring, carpet and roofs), low or VOC-free paints, construction waste diversion programs, formaldehyde-free casework, turf-free and indigenous native planting for low irrigation demand, and non-smoking campus, to name just a few measures incorporated into our building design. Attached, please find a list with a few minor suggestions to include in the Final EIR. 15 We are grateful for the time and attention that City staff have devoted to processing our applications and working with FirstCarbon Solutions to produce a high-quality DEIR. We look 6 forward to continued collaboration as we work to make the Kaiser Dublin Medical Center a reality. Sincerely, Wo&4 Wannid Hollis Harris Vice President National Facilities Services cc. 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CP CP j > 00 OD ct cc f , \ \ \ ? ± % z; 0 _ j7 - N To{ \ }} \ T - _ ! 7 ;\ § ! \ © % i \ • \ % ! f 1 \ \ « ` a y 0i } \ } , \ \ \ } � : ` \}k\ } rWtO ! \ {; \ C \ } t \- 2 o % i } ! § § \ { w _c C2 4i.\ a !{ > % \ 3 \ \} a \! \ y \ ) \ \�\ : } \\ \- _ \ . d _ % \ \ i { f \\\\\\ \ _ \ \ \ /ƒc\\�\\/. \ \/ E\ \00 c t .6S \\} 2 \\ \ } % % \ : ` \ \ \\ }* 5 0ras ° 3= a ` : T \ ! \ { ! %; }* f � • � at : a ; : ; tlt& 1 , ± ; ! ! - - } ; ia ® \ } { \ » � } \ } }\ 1 » » ® ` 3 ° of \ } \ t (\ { _ \ \ }\{ \\ \\ . \\ \\ \(/ \ 75 : itionlinsaillii SIR URIniall City of Dublin-Kaiser Dublin Medical Center Project Final EIR Responses to Written Comments Private Businesses, Organizations,and Individuals Kaiser Permanente(KAISER) Response to KAISER-1 The author provided introductory remarks to open the letter. No response is necessary Response to KAISER-2 The author provided background about the Kaiser Dublin Medical Center Project. No response is necessary. Response to KAISER-3 The author stated that the Draft EIR provides a thorough description of the proposed Medical Center, including measures Kaiser will implement during construction to minimize impacts. The author stated that Kaiser is committed to contributing its"fair share"of traffic and infrastructure improvements at each phase and believes that these improvements will have substantial contributions to the local transportation system. No response is necessary Response to KAISER-4 The author stated that the Draft EIR's analysis is based on very conservative assumptions regarding the impacts of project construction and noted that this approach yields"worst-case"conclusions about subjects such as traffic, air quality, and greenhouse gas emissions The author used the example of greenhouse gas emissions and noted that the Draft EIR assumed that all vehicle trips would be "new"trips, rather than trips that would be diverted from other existing medical facilities. The author stated that this results in project-specific impacts being overstated, particularly given that the project would be expected to bring health care services closer to residents The author also listed various voluntary measures the project would implement that would reduce greenhouse gas emissions such as green building and operational practices. The author is correct in noting that the Draft OR employs conservative assumptions that yield "worst-case"conclusions Regarding the example of all vehicle trips being considered"new" and not adjusting for reassignment of existing trips, it is a widely accepted practice employed by lead agencies in California and throughout the United States to treat all trips associated with a project as "new" This is in large part due to the speculative nature of attempting to forecast what type of trips would be reassigned (employee, patient, visitor,vendor, etc ) and where they would be diverted from, particularly given that many details of the Kaiser Dublin Medical Center(and associated commercial use)are not yet known. As such,any attempts to adjust for reassignment of trips would be very difficult to substantiate and would likely be considered an understatement of the full impacts of the proposed action. Consequently,the mobile source emissions values reported in Table 3 2-79—the single largest emissions source—likely overstate actual greenhouse emissions. A statement has been added to Impact AIR-6(Greenhouse Gas Emissions) explaining why vehicle trips were treated as"new" and the change is noted in Section 4, Errata Response to KAISER-5 The author referenced an attachment with minor suggested revisions to the Draft EIR. Refer to Response to KAISER-7 through Response to KAISER-27. FnstCarbon Solutions 349 City ofDublin—Moser Dublin Metl¢o!Center Protect Responses to Written Comments Final FIR Response to KAISER-6 The author provided closing remarks to conclude the letter No response is necessary. Response to KAISER-7 The author requested that the list of discretionary and ministerial actions on Draft EIR page 2-19 he clarified to note that a Vesting Tentative Parcel Map is a discretionary action. The change has been made and is noted in Section 4, Errata. Response to KAISER-8 The author requested that the list of responsible and trustee agencies on Draft EIR page 2-20 be amended to include the California Department of Fish and Wildlife The change has been made and is noted in Section 4, Errata. Response to KAISER-9 The author requested that the first paragraph on page 3 2-7 be updated to note the regulatory status of inventorying short-lived climate pollutants pursuant to Senate Bill 605. The change has been made and is noted in Section 4, Errata Response to KAISER-10 The author requested that the discussion of the legal challenge to the Bay Area Air Quality Management District (BAAQMD)2010 CEQA thresholds on page 3.2-19 be revised to note the outcome of the case in December 2015 The changes have been made and is noted in Section 4, Errata Response to KAISER-11 The author requested that the discussion of Renewable Electricity Standards on page 3.2-29 be revised to note legislation that superseded the Executive Orders issued in 2002 and 2010. The change has been made and is noted in Section 4, Errata. Response to KAISER-12 The author requested that Table 3.2-17 be revised to correct the values shown in the "Average Daily Emissions (pounds/day)" row The author indicated that the correct values represent "Total Emissions (pounds)" in the preceding row divided by 153 working days The values in the row have been corrected as described and the changes are noted in Section 4, Errata. These revisions do not result in any changes to the conclusions on significance of impacts in the Draft EIR Response to KAISER-13 The author requested that Mitigation Measure AIR-3b be revised to (1)state that use of Tier 4 is only required to the extent feasible,and (2)the City of Dublin Community Development Director has the discretion to waive this requirement with respect to individual pieces of equipment provided that 3-50 F,rstcarbon Solutions i„mom. m...,,.,..�,..,,..r,mm..,.a.. G4'of Dub/on—Kaiser oobbn Medical enter Project Final FIR Responses to Wr itten Comments the applicant demonstrates that the waiver will not cause exceedance of applicable thresholds of significance for criteria pollutants Mitigation Measure AIR-3b reflects BAAQMD guidance for mitigating construction emissions Moreover,her 4 construction equipment is widely available in the San Francisco Bay Area region and would be expected to be even more so by the time construction begins. Should the applicant encounter challenges in securing Tier 4 construction equipment, the City of Dublin Is willing to work with the applicant to identify alternative approaches that satisfy this mitigation measure. Response to KAISER-14 The author requested that a typographical error on page 3 2-69 be corrected The change has been made and is noted in Section 4,Errata. Response to KAISER-15 The author requested that the title of Table 3 2-63 be amended to include the word"Existing" The change has been made and is noted in Section 4, Errata Response to KAISER-16 The author requested that the columns in Table 3 2-63 labeled "1-580 Link 599 Health Risks" be amended to include the words Per Million People." The change has been made and is noted in Section 4, Errata. Response to KAISER-17 The author requested that the energy consumption values in Table 3.2-79 be revised to reflect the recent change in Renewable Portfolio Standard objective of 50 percent by 2030 The residual significance of Impact AIR-6(Greenhouse Gas Emissions)was found to be significant and unavoidable. This accounted for the previous Renewable Portfolio Standard objective of 33 percent by 2030 However,as shown in Table 3 2-78,the analysis only assumed a 20 4 percent greenhouse gas reduction (and not 33 percent) pursuant to the ARB's "PG&E Emission Factor Local Government Operations Protocol." If the energy consumption values in Table 3 2-79 were recalculated to account for 50 percent Renewable Portfolio Standard,the full 50 percent reduction could not be taken for the same reasons the full 33 percent Renewable Portfolio Standard could not be taken (i.e,ARB's"PG&E Emission Factor Local Government Operations Protocol"). Regardless, even if the full 50 percent could be accounted for, it would not materially alter the conclusion because energy consumption represents a small percent(16 percent) of total project greenhouse gas emissions. Thus,the project's greenhouse gas emissions would still exceed the BAAQMD significance threshold and the conclusion would remain significant and unavoidable For these reasons,there is no basis to revise to recalculate the values in Table 3.2-79 in the manner requested by the author. FirstCOrbon Solutions 3-SI c w+n.v ine.�o on �rA"..•4 nlvssysrocme FEIR\37 zam,sem cok.w.iw w[wn mmmrm.ec. City of Dublin—Kinser Dublin Medical Center Protect Responses to Written Comments Final FIR Response to KAISER-18 The author requested that the entry in Table 3 2-81 regarding"A 3 4 Commercial Recycling Program" be amended to include the word "Consistent" The change has been made and is noted In Section 4, Errata Response to KAISER-19 The author requested that the discussion of the drainage ditch on Draft EIR pages 3.3-5 and 3 3-6 address whether or not the feature would be subject to State jurisdiction The change has been made and is noted in Section 4, Errata Response to KAISER-20 The author noted that the discussion on page 33-16 regarding Sections 2050 through 2098 of the California Fish and Game Code is duplicative of the prior discussion of the California Endangered Species Act and requested that brief discussion about California Fish and Game Code Sections 3503 (raptors) and 1600(jurisdictional streambeds) be added Although the discussion of California Fish and Game Code Sections 2050 through 2098 is indeed duplicative of the California Endangered Species Act,this is no different from how regulatory framework is addressed elsewhere in the Draft EIR (e g.,the Geology, Soils, and Seismicity section discusses the California Budding Code and then, later, how the City of Dublin has adopted the same code as part of its Municipal Code) Thus,there is no basis to make any changes to this discussion Discussion of California Fish and Game Code Sections 1600 and 3503 has been added to the Draft EIR and the change is noted in Section 4, Errata Response to KAISER-21 The author requested that Mitigation Measure BIO-lc be clarified to note that occupied burrows must be avoiding during the nesting season The change has been made and is noted in Section 4, Errata. Response to KAISER-22 W The author requested that the discussion of the drainage ditch on page 3.3-26 be revised to include the words or State law" n S. The change has been made and is noted in Section 4, Errata Response to KAISER-23 oi The author requested that Draft EIR Section 3 4,Cultural Resources include discussion of Assembly Bill 52 tribal consultation requirements, which took effect on July 1, 2015 but do not apply to the r proposed project because the Notice of Preparation was released prior to that date The change has been made and is noted in Section 4, Errata r, 3-52 FrstCarbon Solutions '"""‘q x..sse��..a,. reins zwx .m.nn..o",.mwm..oo.m...a". 4 City of Dublin-Koper Dublin Me0cal Center protect Final EIR Responses to Written Comments Response to KAISER-24 The author requested that the discussion of National Pollution Discharge Elimination System (NPDES) requirements on page 3.7-4 be revised to note that the proposed project is not subject to hydromodification requirements. The change has been made and is noted in Section 4, Errata Response to KAISER-25 The author requested that Mitigation Measure NVD-ib be revised to note that the proposed project is not subject to hydromodification requirements The change has been made and is noted in Section 4, Errata Response to KAISER-26 The author requested that the text on page 3.11-93 be clarified to note that the cumulative traffic scenario represents Year 2040 The change has been made and is noted in Section 4, Errata Response to KAISER-27 The author requested that the description of the Corporate Office Campus Alternative on page 5-10 be revised to remove a statement that"buildings would employ a contemporary appearance with extensive use of glass,"as it would be premature to comment on design aspects of an alternative that has not been designed As stated on Draft EIR page 5-10,the purpose of the Corporate Office Campus Alternative is to provide the decision-makers with a comparison of what level of development could occur under the existing General Plan and Specific Plan land use designations of"Office Campus" It is a conceptual land use alternative that is evaluated strictly for CEQA purposes; no architectural drawings or engineering plans have prepared for any aspect of this alternative The statement that the"buildings would employ a contemporary appearance with extensive use of glass" is general in nature and simply intended to give the reader a basic idea of the visual appearance of the Corporate Office Campus Alternative It is in no way premature to make this statement,just as it is not premature to make any other statements about the basic characteristics of this alternative(number of buildings, layout, location of access points, parking facilities, etc ) On the contrary,the more description that can be provided about the alternative,the better the reader can understand how this alternative compares with the proposed project,which is consistent with CEQA informed decision-making principles For these reasons,there is no basis to revise this statement. NrstCabon Solutions - - - 3-53 CHAI Page 1 of 1 From: Lily Chai [rialto lilychai @'gmail corn] Sent:Thursday, March 17, 2016 11:38 AM To: Knsti Bascom Subject: Not in support of Kaiser Dubin Medical Center at 3200 Dublin Blvd Dear Ms. Bascom. My parents and I own a condo across the street from the proposed site. They intend to retire in this location and we are very familiar with the Dublin area. Were active in the community and love the environment and 1 appreciate the boom of growth we've experienced the last several years. lowever, along with this growth, we'\e also experienced some pain points that I'm certain has been echoed by many Dublin constituents. We know and fear the bottleneck traffic that will occur should the Kaiser hospital be built across the street. Additionally, the noise pollution will become even worse. Its already pretty bad now as it is, the Toll Brother's condos did not use high quality double pane windows to keep noise out. My parents 2 already limit when they open their window at this point due to the current traffic on Dublin Blvd, but with the entrance of Kaiser, they'll never be able to open their windows again due to the constant traffic that will be on Dublin Blvd at every hour of the day and night. I believe there are several other viable options for the Kaiser property that isn't so close to residential neighborhoods. The City of Dublin has made many good choices in the past for buildouts -such as the 3 Hacienda Crossings and Target center at the corner of El Charro and Dublin. Please continue to make wise decisions and stop the build of the Kaiser hospital on 3200 Dublin. Thank you for your time and consideration, 4 Lily Chai City ofvcblm-KmmrWblm Meehan Center Project Final FIR Responses to Written Comments Lily Choi(CHAT/ Response to CHAT-1 The author explained that she and her parents own a condominium on the opposite side of Dublin Boulevard from the project site,and noted that her parents intend to retire at this location No response is necessary Response to al/11-2 The author expressed concern about traffic congestion that would occur as a result of the proposed project. She also noted that existing traffic noise levels were"pretty bad"and noted that her condominium does not have double paned windows She indicated that her parents currently limit the times they open their windows based on existing traffic noise levels and stated that"they'll never be able to open their windows again due the constant traffic that will be on Dublin Boulevard every hour of the day and night" The Draft EIR evaluated traffic impacts associated with the proposed project, including the intersections of Dublin Boulevard/Keegan Street and Dublin Boulevard/Lockhart Street—the intersections closest to the Terraces at Dublin Ranch; refer to Draft EIR pages 3 11-49 through 3.11-118 Mitigation measures are proposed to improve operations; refer to Section 3 11, Transportation for further discussion The Draft EIR's noise analysis included ambient noise monitoring at locations around the project site, including at locations the "Terraces at Dublin Ranch,'the author's condominium complex. Two locations within the Terraces at Dublin Ranch were monitored between 12:00 p m.and 3 30 p m on Wednesday,January 21, 2015 (ST-2 and ST-3; refer to Exhibit 3 9-1) and the results were reported in Table 3 9-4 As indicated in the table, Location ST-2 (the pool area)was exposed to an average noise level(Leq)of 56 0 dBA and a maximum noise level (Lm,„)of 76.8 dB, while location ST-3(the Dublin Boulevard entrance)was exposed to an average noise level(Leq) of 65 0 dRA and a maximum noise level (Lm,„)of 80 7 dB. For comparison purposes,the City of Dublin's Land Use Compatibility Noise Standards (reproduced in Draft EIR Table 3 9-9) indicated that noise levels up to 60 dB are"Normally Acceptable”for residential uses and noise levels between 61 and 70 dB are"Conditionally Acceptable”for residential uses. (It should be noted that the noise levels are based on average noise levels overa 24-hour period with penalties applied for nighttime noise.) Thus,the average noise level at ST-2 (56.0 dB) would fall within the "Normally Acceptable" range,while the average noise levels at ST-3(65 0) would fall within the "Conditionally Acceptable" range. Moreover,the ST-3 noise readings indicate this receptor location is exposed to substantial roadway noise from both Dublin Boulevard and 1-580. Accordingly,the Draft HR evaluated changes in roadway noise levels associated with the proposed project in Impact NOI-3 in Section 3.9, Noise. This included an evaluation of roadway noise levels at receptors located along Dublin Boulevard, including the Terraces at Dublin Ranch. The analysis found that the proposed project would serve to reduce roadway noise exposure for most receptors on the north side of Dublin Boulevard because of the shielding provided by the Kaiser Dublin Medical Center buildings. This reduction in noise levels is graphically depicted in Exhibit 3.9-5 (Cumulative No Project)and Exhibit 3.9-6(Cumulative With Project). Post-project noise levels at the Terraces at First(urban Solutions 3-57 City of Dublin—Kinser Dublin Med,col Centel-Pro/Mt Responses to Written Comments Final FIR Dublin would range from 0 0(no change)to a -3.5 reduction compared with the without project scenario Moreover, no receptors would experience an increase in noise levels. For these reasons, the proposed project would not exacerbate roadway noise impacts at the Terraces at Dublin Ranch or any other land use in the project vicinity. Response to CHAT-3 The author stated that there are several other viable options for the project site and stated that the City of Dublin has made good choices in the past,citing the examples of Hacienda Crossings and Fallon Gateway The author urged the City to stop the development of the Kaiser Medical Center at the project site The Draft EIR evaluated two development alternatives to the proposed project in Section 5, Alternatives to the Proposed Project The Reduced Density Alternative consisted of a 25 percent reduction in the size of the proposed project,and the Corporate Office Campus Alternative considered a 1 2-million-square-foot office complex on the project site Both alternatives were found to lessen the severity of, but not to avoid,the proposed project's significant impacts associated with air quality/greenhouse gas emissions and transportation Additionally,the Draft EIR considered three separate locations for the proposed project and found none of them were feasible because of small size, commitment to other uses, or that Kaiser did not own,control,or have access to the site. In summary,the Draft EIR considered both alternative land use concepts for the project site and alternative locations for the proposed project,and found that they did not avoid the proposed project's significant impacts or were not feasible locations Response to CHAI-4 The author provided closing remarks to conclude the letter No response is necessary 3-58 FinrCarbon solutions om...on.n= o.,nen.umlo+'mn,zcusemn0_ onvsxw...m=w r..00.:.uo m..,fmm..ne... City of Dublin-Kaiser Dublm Medico!Center Project Final EIR Errata SECTION 4: ERRATA The following are revisions to the Draft EIR for the Kaiser Dublin Medical Center Project These revisions are minor modifications and clarifications to the document, and do not change the significance of any of the environmental issue conclusions within the Draft EIR. The revisions are listed by page number. All additions to the text are underlined (underlined) and all deletions from the text are stricken (staeken) 4.1 - Changes in Response to Specific Comments Executive Summary Page ES-I, Project Description The fourth bullet has been modified to reference in the inclusion of related services(skilled nursing, assisted living,or licensed care facilities) in Phase 3 of the project. Such uses have been shifted from Phase 1E3 • Phase 3: 280,000 square feet of medical office building, related services (skilled nursing,assisted living, or licensed care facilities),and parking garage This phase would be developed between 2035 and 2040. Section 2, Project Description Page 2-1, Existing Land Use Activities The second paragraph has been modified to strike the reference to the storm drain box culvert being in the Caltrans right-of-way Two storm drainage utility easements cross the project site in a north-south direction The western easement extends into the project site along the Keegan Street alignment and contains a 96-inch-diameter underground storm drain line The eastern easement extends into the project site along the Lockhart Street alignment and contains a 10-foot by 8-foot concrete box culvert Both lines discharge into a double 10-foot by 9-foot concrete box culvert that parallels the north side of 1-580 within ho ^'•'^ ight of way Page 2-9, Kaiser Medical Campus The bulleted list of health care services to be provided by Kaiser Permanente at the project site has been modified to add skilled nursing,assisted living, or licensed care facilities. These uses have been shifted to a possible use in Phase 3 of the medical campus instead of on the commercial parcel • Skilled nursing, assisted living, or licensed care facilities. Page 2-10, Phase 3 The last sentence has been modified to include reference to skilled nursing, assisted living, or licensed care facilities These uses have been shifted to a possible use in Phase 3 of the medical campus instead of on the commercial parcel F ctcarbon Solutions •1 City of Dublin-Kaiser Dublin Medical Center Project Errata Finnan? Depending upon future demand, Phase 3 may be repurposed for other Kaiser Medical Campus health care functions, including regional laboratory,skilled nursing, assisted living licensed care facilitiesccall center, or medical office functions Page 2-10,2.3.3-Commercial Uses The second to the last sentence has been removed to reflect the uses being shifted to Phase 3 of the medical campus. Page 2-19, Discretionary and Ministerial Actions The bulleted list of discretionary and ministerial actions has been modified to note that a Vesting Tentative Parcel Map is a discretionary action Discretionary approvals and permits are required by the City of Dublin for implementation of the proposed project The project application would require the following discretionary approvals and actions, including F • EIR Certification • General Plan Amendment • Specific Plan Amendment • Planned Development Rezone (Stage 1 and Stage 2 Development Plans) r • Site Development Review • Vesting Tentative Parcel Map(Discretionary)or Lot Line Adjustment (Ministerial) • Subsequent Permits including, but not limited to,grading,sitework,and building permits Page 2-10, Responsible and Trustee Agencies The bulleted list of responsible and trustee agencies has been amended to include the California Department of Fish and Wildlife r A number of other agencies in addition to the City of Dublin will serve as Responsible and Trustee Agencies, pursuant to CEQA Guidelines Section 15381 and Section 15386, r respectively This Draft EIR will provide environmental information to these agencies and other public agencies,which may be required to grant approvals or coordinate with other agencies,as part of project implementation These agencies may include but are not limited to the following y" • California Department of Transportation M • California Department of Fish and Wildlife fr • California Regional Water Quality Control Board San Francisco Region • County of Alameda • Alameda County Airport Land Use Commission r • City of Livermore v 0-3 Firstcarbon Solutions ,ccmns Fin meuu+,.n..wino,a� IPI Y CO of Dublin-Kaiser Dublin Medical Center Project Final EIF Errata • City of Pleasanton • Bay Area Rapid Transit District • Dublin-San Ramon Services District Section 3.2,Air Quality/Greenhouse Gas Emissions Page 3.2-7, First Paragraph The first paragraph has been updated to note the regulatory status of inventorying short-lived climate pollutants pursuant to Senate Bill 605 The State has begun the process of addressing pollutants referred to as short-lived climate pollutants Senate Bill 605,approved by the Governor on September 14, 2014, requires the ARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants by January 1, 2016. ARB will complete an emission inventory of these pollutants, identify research needs, identify existing and potential new control measures that offer co- benefits, and coordinate with other state agencies and districts to develop measures. As of April 2016,ARB had issued a Draft Short-Lived Climate Pollutant Reduction Strategy and held several public workshops, but a final strategy has yet to be adopted. Page 3.2-19, Fourth Paragraph, Sentences 1 through 6 The discussion of the legal challenge to the Bay Area Air Quality Management District(BAAQMD) 2010 CEQA thresholds has been revised to note the outcome of the case This assessment is based on BAAQMD's 2010 CEQA thresholds. BAAQMD's adoption of its 2010 thresholds were have haye-lieea challenged in the lawsuit of California Building Industry Association v BAAQMD which was decided by ispnd.:g-befere the California Supreme Court on December 17, 2015(Supreme Court Case No. S213478) The3upreme-Eeurt The California Supreme Court Eeu4-ef-Appeal decision that CEQA does not require the analysis of the impacts of the existing environment on the Project except in limited circumstances The Supreme Court ruling did not address BAAQMD's adoption of the thresholds and the adequacy of the scientific basis for those thresholds - : - - :-': • -- - - -- -- - - -- - -- - -- - 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 thresholds, including, but not limited to,the Options and Justification Report(dated October 2009) prepared by BAAQMD. Page 3.2-29, Third Paragraph The discussion of Renewable Electricity Standards has been revised to note legislation that superseded the Executive Orders SB 1078-Renewable Electricity Standards. On September 12, 2002,Governor Gray Davis signed SB 1078 requiring California to generate 20 percent of its electricity from renewable Forst Corbon Solutions 0-3 City of Dublin-Kamer Dublin Medical Center Project Errata Fnal FIR energy by 2017. SB 1078 changed the due date to 2010 instead of 2017 On November 17, 2008,Governor Arnold Schwarzenegger signed Executive Order 5-14-08,which established a Renewable Portfolio Standard target for California requiring that all retail sellers of electricity serve 33 percent of their load with renewable energy by 2020 Governor Schwarzenegger also directed the ARB(Executive Order S-21-09)to adopt a regulation by July 31, 2010, requiring the State's load serving entities to meet a 33 percent renewable energy target by 2020 The ARB Board approved the Renewable Electricity Standard on September 23, 2010 by Resolution 10-23 These Executive Orders were superseded by statute under SB 1X-2,signed by Governor Brown on April 12, 2011 Subsequently,on October 7, 2015, Governor Brown signed SB 350, Increasing the standard to 50 percent renewable energy by 2030. Page 3.2-51, Table 3.2-17 Table 3 2-17 has been revised to correct the values shown in the"Average Daily Emissions (pounds/day)" row The corrected values represent "Total Emissions(pounds)" in the preceding row divided by 153 working days,which was the value originally erroneously shown Table 3.2-17:2016 Mitigated Construction Criteria Air Pollutants Emissions (Average Daily Rate) Air Pollutants Parameter ROG NO, PM10' PMsss Total Construction Emissions Total Emissions(tons) 016 089 001 001 Total Emissions(pounds) 319 1,770 29 6 28 Average Daily Emissions 2 08 11 57 0 19 0.18 (pounds/day)' 13.3 183 433 133 Significance Threshold 54 54 82 54 Exceeds Significance Threshold? No No No No Notes ' Exhaust only 2 Calculated by dividing the total pounds by 153 working days of construction for the year ROG=reactive organic gases NO,=oxides of nitrogen PMio=particulate matter 10 micr ons in diameter PMr 5=particulate matter 2 5 microns in diameter Source FirstCarbon Solutions 2015,Appendix B Page 3.2-69, Last Paragraph, Third Sentence The third sentence has been revised to correct a typographical error. Note that under the recent California Supreme Court case of California Building Industry Association v. Bay Area Air Quality Management District,the court ruled that the existing environment's impact on of-project users is not required to be analyzed under CEQA except in limited circumstances <L FntCarbon Solutions .m,Po my,,...„,,,,ssm„,. Fenn o,,.m.Po.....a no City of Dublin—Kaiser Dublin Medical Center Project Final E/R Errata Page 3.2-83, Table 3.2-63 The title of Table 3.2-63 has been amended to include the word "Existing" and note that the columns labeled "1-580 Link 599 Health Risks" represent health risks per 1 million persons Table 3.2-63: Existing Cumulative 1-580 Health Risks Receptor Location I-580 Link 599 Health Risks Per 1 Million Persons Distance Receptor from l-580 PM" Number Receptor Description X Y (feet) Cancer Risk (psJm'I Chronic Hl Acute HI 1 MFR west side 600274 4,173,522 670 414 052 007 0011 2 MFR west side 600268 4,173,605 950 316 041 005 0011 3 MFR northwest side 600,282 4,173,692 1,250 23.1 041 005 0014 4 MFR north side 600,369 4,173,685 1,200 245 041 005 0 019 5 MFR north side 600,448 0173,684 1,200 24.5 041 005 0030 6 MFR north side 600,573 4,173,688 1,210 242 041 005 0 043 7 MFR north side 600,668 4,173,691 1,220 239 041 005 0040 8 MFR north side 600,764 4,173,695 1,240 233 041 0.05 0034 9 MFR north side 600,849 4,173,709 1,360 199 041 005 0036 10 MFR northeast side 600,910 4,173,736 1370 196 041 005 0 032 11 MFR south side 601,027 4,173,227 105 794 062 010 0 026 12 SFR south side 600.837 4,173,221 140 704 0.64 010 0 025 13 SFR south side 600,692 4,173,234 105 79 4 0.62 0.10 0 035 14 SFR south side 600,558 4,173,236 100 807 058 008 0028 15 SFR south side 600,414 4,173,236 100 80.7 058 008 0012 16 SFR southwest side 600,246 4,173,235 100 807 058 008 0006 Notes Receptor location based on World Geodetic System 19801 W G584),Universal Transverse Mercator i UTMI MFR=muit'1am iiy residential SF■=single-family residential Source BAAQMD Page 3.2-107,After Table 3.2-80 A statement has been added explaining why vehicle trips were treated as "new." Finally, it should be noted that this analysis treats all vehicle trips associated with the proposed project as"new"and does not attempt to account for the reassignment of trips from other existing Kaiser Medical facilities to the proposed Kaiser Dublin Medical Center. It is a widely accepted practice employed by lead agencies in California to treat all trips associated with a protect as "new" This is In large part due to the speculative nature of attempting to forecast what type of trips would be reassigned (employee, patient,visitor, vendor, etc 1 and where they would be diverted from, particularly given that many details of firsWarbon Solutions 4-5 V. s\ 01,0∎ uan.5en 5mmsrea circa my ..a_ City of oubI,rrxaiser Oublm Medical Center Project Errata Final FIR the Kaiser Dublin Medical Center(and associated commercial use)are not yet known. As such, any attempts to adjust for reassignment of trips would be very difficult to substantiate and would likely be considered an understatement of the full impacts of the proposed action Consequently,the mobile source emissions values reported in Table 3.2-79—the single largest emissions source—mare a conservative worst-case analysis of actual greenhouse gas emissions. Page 3.2-109, Table 3.2-81 The word "Consistent" has been added to the beginning of the "Project Consistency"discussion for "A 3 4 Commercial Recycling Program" CAP Measure Project Consistency A.3 Solid Waste and Recycling Measures Consistent. In 2005,the City began offering a free commercial recycling program that also includes free indoor recycling containers for businesses Indoor A 3 4 Commercial Recycling Program recycling containers encourage employees to recycle by conveniently locating recycling containers near their work areas. The project would include recycling areas within the medical facilities Page 3.2-109, Summary The summary has been expanded to explain how certain mitigation measures would reduce the severity of greenhouse gas emissions impacts, but would not lessen the impact to a level of less than significant Summary The project would exceed the BAAQMD GHG efficiency measure. Accordingly,this is a significant Impact Mitigation Measures TRANS-la,TRANS-40a,TRANS-40b,and TRANS-40c require that a transportation demand management program, public transit facilities, bicycle facilities, and pedestrian facilities be incorporated into the proposed prolect All of these measures would also serve to promote reductions in greenhouse gas emissions from mobile sources;however,substantiating such reductions is very difficult Therefore,the residual significance of this impact is significant and unavoidable Page 3.2-109, Mitigation Measures . The list of mitigation measures has been revised to correct erroneous references. Mitigation Measures Implement Mitigation Measures TRANS-la,TRANS-40a,TRANS-40b, and TRANS-40c. TRANS 8a,TRANS Sb,and TRANS 8c. w. 0-6 F,rstcarbon Solutions ei oac. .e«,r..x.....rpm,xixiusesussmW_ royssro■s.rw m Err ale do.. ■ City Of Dub!n-Nurser Dublin Medico!Center Protect Final Em Errata Section 3.3, Biological Resources Page 3.3-6, First Paragraph The discussion of the drainage ditch has been amended to note that the feature is not subject to federal or state jurisdiction. Because the subject drainage ditch only drains stormwater from the project site and does not contain continuously flowing water for 3 months or longer, it meets this definition of a roadside ditch. Thus, it is not subject to federal or state jurisdiction Page 3.3-17,After First Paragraph The text on page 3 3-17 has been amended to include summaries of California Fish and Game Code 1600 and 3503 The California Fish and Game Code Section 1600 mandates that"it is unlawful for any person to substantially divert or obstruct the natural flow or substantially change the bed, channel or bank of any river,stream,or lake designated by the department, or use any material from the stream beds,without first notifying the department of such activity" CDFW's jurisdiction includes ephemeral, intermittent,and perennial watercourses(including dry washes) characterized by (1)the presence of hydrophytic vegetation, 12)the location of definable bed and banks, and 13)the presence of existing fish or wildlife resources. Furthermore,CDFW jurisdiction is often extended to habitats adjacent to watercourses,such as oak woodlands in canyon bottoms or willow woodlands that function as part of the riparian system. Historic court cases have further extended CDFW jurisdiction to include watercourses that seemingly disappear, but re-emerge elsewhere. Under the CDFW definition,a watercourse need not exhibit evidence of an Ordinary High Water Mark to be claimed as jurisdiction However,CDFW does not regulate isolated wetlands;that is,those that are not associated with a river, stream,or lake California Fish and Wildlife Code Sections 3503,3503.5,and 3800 prohibit the"take possession,or destruction of birds,their nests or eggs." Disturbance that causes nest abandonment or loss of reproductive effort (killing or abandonment of eggs or young)is considered a take Pages 3.3-21 and 3.3-22, Mitigation Measure RIO-1c Mitigation Measure BIO-lc has been revised to clarify that certain actions would occur during the nesting season. MM B10-1c Prior to the first ground-disturbing activities for Phase 1A,the project applicant shall implement the following measures that pertain the burrowing owl,as applicable 1 Conduct a Burrowing Owl Survey and Impact Assessment Prior to the first ground-disturbing activities,the project applicant shall retain a qualified biologist to conduct two pre-construction surveys for the F stCarban Solutions <7 City of nubhn—Katser Duban Medical Center Protect Errata Final FIF burrowing owl for the entire site The first survey shall be conducted no more than 14 days prior to ground-disturbing activities and the second survey shall be conducted within 48 hours of initial ground disturbance. The surveys shall be conducted in accordance with the California Department of Fish and Wildlife(CDFW)Staff Report on Burrowing Owl Mitigation If the surveys determine owls are present,then the measures set forth in this mitigation shall be followed. 2 Implement Avoidance Measures If direct impacts to owls can be avoided, prior to the first ground-disturbing activities,the project applicant shall implement the following avoidance measures during all phases of construction to reduce or eliminate potential impacts to California burrowing owls • Avoid disturbing occupied burrows during the nesting period,from February 1 through 31 August. • Avoid impacting burrows occupied during the non-breeding season by migratory or non-migratory resident burrowing owls. • Avoid direct destruction of burrows through chaining(dragging a heavy chain over an area to remove shrubs), disking,cultivation, and urban, industrial,or agricultural development • Develop and implement a worker awareness program to increase the on-site worker's recognition of and commitment to burrowing owl protection • Place visible markers near burrows to ensure that equipment and other machinery do not collapse burrows. • Do not fumigate, use treated bait or other means of poisoning nuisance animals in areas where burrowing owls are known or suspected to occur(e.g,sites observed with nesting owls, designated use areas) 3. Conduct Burrow Exclusion. If avoidance of burrowing owl or their burrows is not possible during the nesting season, prior to the first ground-disturbing activities,the project applicant, in consultation with the California Department of Fish and Wildlife, shall prepare a Burrowing Owl Relocation Plan as indicated and following the CDFW 2012 Staff Report. Monitoring of the excluded owls shall be carried out as per the California Department of Fish and Game 2012 Staff Report. 4 Prepare and Implement a Mitigation Plan. If avoidance of burrowing owl or their burrows is not possible and project activities may result In impacts to nesting,occupied,and satellite burrows and/or burrowing owl habitat during the nesting season,the project applicant shall consult with the CDFW and develop a detailed mitigation plan that shall include replacement of impacted habitat, number of burrows, and burrowing owl at a ratio approved by CDFW. The mitigation plan shall be based on •1 the requirements set forth in Appendix A of the CDFW 2012 Staff Report .R on Burrowing Owl Mitigation and the Plan shall be reviewed and sr 0-8 F stcurbon Solutions •r ........... .....NOs,,,.aIro -E■au.n,,...,m,.n. on Pr City of Dublin-NOrser Dublin Medical Center Project Final EIF Errata accepted by CDFW and the City prior to the first ground-disturbing activities Pages 3.3-24 and 3.3-25, Mitigation Measure BIO-le Mitigation Measure 1310-le has been revised to strike Items 2 and 3, as a Section 7 consultation and a biological opinion are not required for the proposed project. MM BIO-le Prior to ground disturbing activities for Phase 1A,the project applicant shall implement the following measures for the California red-legged frog(CRLF),as applicable 1 The project applicant shall retain a qualified herpetologist to conduct habitat assessments for CRLF within the entire project area and based on the results of the habitat assessments,determine in consultation with the USFWS if protocol-level CRLF surveys will be required within the entire project area. The project applicant can forgo the habitat assessments and conduct protocol-level surveys If required,the focused surveys shall follow the Revised Guidance on Site Assessment and Field Surveys for the California Red-legged Frog (USFWS 2005). A CRLF survey report prepared to meet the protocol guidelines shall be submitted to the USFWS If no CRLF are found then no further mitigation is required 2. If CRLF are found on the project site then the project applicant shall ensure no net loss of habitat that shall be achieved through avoidance, preservation, creation and/or purchase of credits. Mitigation may include, but would not be limited to, on-site and off-site preservation and creation of CRLF habitat, purchase of credits at mitigation banks payment of in lieu fees approved by the agencies,or other agency approved and required mitigation measures i^..�a«�.^..g^ ^..e.a•^ne, re-c^^tie^,crc'Hen'art/er purchase of perimffteg-pr-rac-ess7 • 3.4,Avoidance measures may include the following or equivalent protective measures: Frrst[arbon Solutions - 4-9 City of Dublin-Muses Dublin Medical Center Project Errata Final1IR • To minimize disturbance of breeding and dispersing CRLF, construction activity within CRLF upland habitat shall be conducted during the dry season between April 15 and October 15 or before the onset of the rainy season, whichever occurs first. If construction activities are necessary in CRLF upland habitat between October 15 and April 15,the project applicant would contact the USFWS for approval to extend the work period • To minimize disturbance and mortality of adult and juvenile CRLF in aquatic habitat and underground burrows,the project applicant should minimize the extent of ground-disturbing activities within these habitats by requiring the contractor to limit the work area to the minimum necessary for construction. In addition,the project applicant should ensure that the contractor installs temporary exclusion fence between the construction work area and potential aquatic habitat for all construction within grasslands near aquatic habitat. A minimum buffer zone of 150 feet shall be maintained around CRLF aquatic habitat during construction. No staging, parking, material storage or ground disturbance shall be allowed in the buffer zone The buffer zone will be clearly defined with construction fencing prior to the initiation of construction activities and shall be maintained until completion of construction • The project applicant should ensure that a qualified wildlife biologist monitors all construction activities within CRLF upland habitat to ensure no take of individual CRLF occurs during project construction If a CRLF is found,then the monitor would immediately stop construction in that area and contact USFWS for development of a plan for how to proceed with construction • If preservation of upland habitat is required by USFWS,the habitat land shall be within a USFWS approved conservation area. Page 3.3-26, Second Paragraph, First Sentence The discussion of the drainage ditch in Impact BI0-3 has been amended to note that it also is not consider jurisdictional under state law Ditches constructed on dry land and draining only uplands are not considered jurisdictional under Section 404 of the Clean Water Act or state law Because the subject drainage ditch only drains stormwater from the project site and does not contain continuously flowing water for 3 months or longer, it is not federally or state jurisdictional Section 3.4, Cultural Resources Page 3.4-8,After Third Paragraph The discussion of regulatory framework has been amended to include a summary of Public Resources Code 21080.3.1 tribal consultation requirements 4-10 — FirsKOrbon Solutions '"' sn icon sus.ion 4.nu PP Dry of Dublin-Kaiser Dublin Medal Center Project Final FIR Errata Tribal Consultation Public Resources Code 21080.3.1 establishes tribal consultation requirements for new development projects that may impact Tribal Cultural Resources. The requirements took effect on July 1, 2015 Because the Notice of Preparation was issued on January 12,2015 and,thus, predate the date the requirements took effect,they do not apply to the proposed project Section 3.7, Hydrology and Water Quality Page 3.7-2, First Paragraph The first paragraph has been revised to correct the name of the watershed and to state that Arroyo Mocho empties into the Alamo Canal,which from that point downstream is called Arroyo de la Laguna Watershed The project site is located within the Line G-3 Taoca arc-Creek watershed,which drains the eastern portion of Dublin North of Interstate 580(1-580), Line G-3 Ta ;aza:a-Creek is located within a natural watercourse. South of the freeway, it is located in an earthen-lined channel and flows south to Arroyo Mocho in Pleasanton Arroyo Mocho, an earthen-lined flood channel,empties into Alamo Canal S^atl-San °amen r --k near 1-680,which from that point downstream is called continue ..--°°"'°Arroyo De La Laguna. This drainage reverts to a natural watercourse and is tributary to Alameda Creek in Sunol, which ultimately outlets to San Francisco Bay in Fremont Page 3.7-3, Flood Hazard Areas The discussion of flood hazard areas has been amended to note that the flood mapping was conducted by the Federal Emergency Management Agency in 2009. Flood Hazard Areas As shown in Exhibit 3.7-1,the southern portion of the project site is located in Flood Hazard Area Zone AH, a 100-year flood hazard area defined as "Flood Depths 1-3 feet(usually sheet flow)". However,three Letters of Map Revision were processed by the Federal Emergency Management Agency between 2004 and 2007 that indicate that grading associated with the Dublin Ranch protect raised the developable portion of the prolect site to above the 100- year flood elevation These Letters of Map Revision take precedence over the mapping shown in Exhibit 3.7-1 Page 3.7-4,Second Paragraph The second paragraph has been revised to strike the final sentence,as hydromodification requirements would not apply to the proposed project in accordance with Regional Water Quality Control Board Order No R2-2003-0031 Fnstcarbon Solutions 4-31 Dry of Dublur'Nmser Dublin Medical Center Project Errata Final EIF Municipal Regional Permit Provision C.3.g pertains to hydromodification management. This Municipal Regional Permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition Increases in runoff flow and volume must be managed so that the post-project runoff does not exceed estimated pre-project rates and durations,where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks,silt pollutant generation,or other adverse impacts on beneficial uses due to increased erosive force. . . - .. ,. .-..-. . . .. . .. . .... . . . . mats Page 3.7-6, Last Paragraph The last paragraph has been revised to correct the name of the agency and to use text provided by Zone 7 Water Agency to summarize its regulatory responsibilities. Zone 7Water Aaencv - • (ArKVIri Zone 7 is responsible for providing flood protection to the residents of Eastern Alameda County Zone 7 owns and maintains the downstream facility, Line G-3, into which the project proposes to drain Drainage plans for development protects must be reviewed by Zone 7 to ensure that the project does not propose any impacts to downstream facilities. In addition development projects that involve work within Zone 7's right-of-way or that involve construction, modification, or connection to a Zone 7 facility are required to obtain an Encroachment Permit and comply with Zone 7 standards and specifications .he-..CFOIVC i n^^•ra'reeks•• nhl^ Ala''ed- Courty As-a -f receivieg ^d n-ge permit, must comply with ACFCWC standards and spec, c`tions. Page 3.7-11, Mitigation Measure HYD-1b Y' Mitigation Measure HYD-lb has been revised to strike all references to"hydromodification,"as this Y' would not apply to the proposed project • MM HYD-1b Prior to issuance of building permits for the proposed project,the •� City of Dublin shall verify that the project applicant has prepared al operational stormwater quality control measures that comply with the requirements of the current Municipal Regional Permit a' Responsibilities include but are not limited to designing BMPs into a-u FatEarbon Solutions ■i City of Dublin-Kaner Dublin Medico!Center Project Final CIF &rota project features and operations to reduce potential impacts to surface water quality and to manage changes in the timing and quantity of runoff P, hyrke"ed",ree'4 associated with operation of the project These features shall be included in the design-level drainage plan and final development drawings. Specifically,the final design shall include measures designed to mitigate potential water quality degradation wren ^ ^e'f from all portions of completed developments The proposed project shall incorporate site design and BMPs described in the current version of Alameda County Clean Water Program,C 3 Stormwater Technical Guidance manual Low Impact Development features, including minimizing disturbed areas and impervious cover and then infiltrating,storing,detaining, evapotranspiring, or biotreating stormwater runoff close to its source,shall be used at each development covered by the Municipal Regional Permit Funding for long-term maintenance of all BMPs must he specified For each development project,the project sponsor shall establish a self-perpetuating Operation and Maintenance of Stormwater Treatment Systems plan (Municipal Regional Permit provision C 3 h) This plan shall specify a regular inspection schedule of stormwater treatment facilities in accordance with the requirements of the Municipal Regional Permit Reports documenting inspections and any remedial action conducted shall be submitted regularly to the City for review and approval. Page 3.7-11, Mitigation Measure HYD-3 Mitigation Measure HYD-3 has been revised to change the reference to Alameda County Flood Control and Water Conservation District to Zone 7 Water Agency MM HYD-3 Prior to issuance of building permits for the proposed project,the City of Dublin shall verify that the applicant has prepared a storm drainage and hydraulic study in accordance with City requirements The storm drainage and hydraulic study shall quantify the increase in stormwater runoff peak flow rates and volumes resulting from the project,and identify the potential to exceed the conveyance and storage capacity of the local storm drainage system. The study shall incorporate the stormwater treatment controls and LID measures that will be designed to capture and treat runoff The analysis shall verify whether the existing drainage infrastructure is adequate to receive and convey runoff from the proposed project. If the findings of the analysis reveal that implementation of a proposed project would create runoff beyond the capacity of the existing stormwater drainage systems,the project shall be required to upgrade undersized components or adopt a different form of stormwater Firstccrbon Solutions 0-13 City of Dublin-Kaiser Dublin Maraca!Center Protect Errata Final EIR runoff management Prior to approval of a proposed project,the final design drainage plans shall be reviewed and approved by the City of Dublin Public Works Department and Zone 7 Water Agencythe Alameda County flood Control and Water Conservation Dist-Het Pages 3.7-14 and 3.7-IS, Impact HYD-4 and Mitigation Measure HVD-4 Impact HYD-4 has been revised to note that the project site is outside a 100-year flood area,which eliminates the need for Mitigation Measure HYD-4. 100-Year Flood Hazard Areas Impact HYD-4: The proposed project would not may locate structures within a 100-year flood hazard area. Impact Analysis This impact addresses the potential for the project to place structures or housing within a 100-year flood hazard area(checklist questions g and h) As shown in Exhibit 3.7-1,the southern portion of the project site is located in Flood Hazard Area Zone AH,which is a 100-year flood hazard area,which is defined as"Flood Depths 1-3 feet (usually sheet flow)" However,three Letters of Map Revision were processed by the Federal Emergency Management Agency between 2004 and 2007 that indicate that grading associated with the Dublin Ranch project raised the developable portion of the protect site to above the 100- year flood elevation These Letters of Map Revision take precedence over the mapping shown in Exhibit 3.7-1. As such, the proposed project would not locate structures within a 100-year flood hazard area Impacts would be less than significant h A..", prricN bw1d)^gs-9-a-f1e' d-aee :. dne d ts; tke Level of Significance Before Mitigation Less than significant impact Mitigation Measures No mitigation is necessary. 4-14 ----- -_�� -_—� -- FrrstCarbon Solutions City of oubltn-Kaiser Oublm Medical Center Project Final EIF Errata discharge Level of Significance After Mitigation Less than significant impact. Section 3.11,Transportation Page 3.11-12, Table 3.11-15, Fifteenth Row An erroneous value in the row has been corrected 24 El Charro Road/I-580 Westbound Ramps Signal AM 9 A PM 989 A Page 3.11-32, Trip Generation,Second Paragraph An explanation has been added to the end of the second paragraph to indicate the consideration of an assisted living facility's trip generation in Phase 3 of the project Because the assisted living facility trip generation daily rate is less than that of medical office space,this shift in land uses would not result In greater traffic generation than what was considered in the Draft ER. Trip generation estimates are shown in Table 3411-7 for the medical components of the project,which show that the Kaiser Medical Center is expected to generate approximately 32,520 weekday daily trips, including about 2,150 morning peak-hour and 3,210 evening peak-hour trips with completion of all medical uses. The Phase IA project is expected to generate approximately 7,950 daily trips, including 530 morning peak-hour and 796 evening peak-hour trips Phase 3 of the project may include skilled nursing, assisted living,or licensed care facilities as part of the 280,000 square feet However,to assess the worst case scenario only the higher trip generating medical office space land use was considered Page 3.11-33, Bulleted List The bulleted list beneath the second paragraph has been updated to remove the 250-unit assisted living facility from trip generations considered for the commercial parcel. The skilled nursing, assisted living, or licensed care facility project component has been shifted to Phase 3 Frrsttarbon SOM ions 0-15 City of Dublin-Xmser Dublin Medical Center Project Errata Final OR Page 3.11-33 and 3.11-34, Table 3.11-8 The last row of the table and the notes have been revised to remove the assisted living facility trip generation estimates, as such use has been shifted from the commercial parcel (Phase lb)to Phase 3 of the project Because the assisted living facility trip generation daily rate is less than that of medical office space,this shift in land uses would not result in greater traffic generation than what was considered in the Draft EIR 'e 234-dabs 849 4-S 34 43 Ss Notes ITE land use category 820-Shopping Center(Ad/Streets,7-94,4-6P) The analysis reflects a 30 percent pass-by reduction for the weekday PM peak hour for the retail use No AM peak-hour pass-by reduction was taken for the retail component Daily Ln(T)=0 65Ln(X)+583,R2 for fitted curve is 079,fitted curve produces slightly higher trip estimates than the average rate for this size project,which would be expected from a regional retail center AM Peak Hour Ln(T)=0 61Ln(%)+2 24,Enter=62%,Exit=38%,R2 for fitted curve is 0 56,fitted curve produces slightly higher trip estimates than the average rate for this size project,which would be expected from a regional retail center PM Peak Hour Ln(T)=067Ln(X)+3 31,Enter=48%,Exit=52%,R2 for fitted curve is 081,fitted curve produces slightly higher trip estimates than the average rate for this size project,which would be expected from a regional retail center • ITE Trip Generation(9t Edition)land use category 210-General Office Building(Ad)Streets,7-9A,4-6P) Daily T=1103'(X) AM Peak Hour T=1 56*(X)(88%in,12%out) PM Peak Hour T=149'1%I(17%in,83%out) ' ITE and use category 760-Research and Development Center(Pk Hr AM&PM) Daily LN(T)=083"LN(X)+309 R2 value is 073,fitted curve and average rate produce similar estimates for this size project AM Peak Hour LN(T)=087"LN(%)+086)83%in,17%out),R2 value is 076,fitted curve and average rate produce similar estimates for this size project PM Peak Hour LN(T)=083'LN(%)+106(15%in.85%out),R2 value is 076,fitted curve and average rate produce similar estimates for this size project • ITE land use category 310-Hotel(Ad/Streets,7-9A,4-6P) Daily T=817'(X) AM Peak Hour T=053*(%)(59%in,41%out) i PM Peak Hour T=060*(X)(51%in,49%out) Baly T -' 11*c7 , Source Fehr&Peers 2015 Page 3.11-85, Mitigation Measure TRANS-12 rl The text of the mitigation measure has been revised to clarify the intent that fair-share contributions to these two regional improvements will be collected, not actual construction of the improvements, which are regional In nature and involving multiple local and state jurisdictions. 4-16 FvstCarbon Solutions 'A %noir, ,xn-s.,_ssaw_ reiru City of Dublin-Kaiser Dublin Medical center Project Final EIR Errata MM TRANS-12 Prior to occupancy of Phase 2,the applicant shall provide its fair-share cost contribution to the Santa Rita/I-580 Eastbound ramp improvements The interchange improvements include constructing a second southbound left-turn lane and upgrading the traffic signal intersection of the Santa Rita/I-580 Eastbound ramp An escrow account where fair- share funds can be deposited for interchange improvements not included in local or regional fee programs shall be established In coordination with the cities of Livermore, Pleasanton, and the Alameda CTC. The City will ensure that the fair- share costs are collected for the escrow account and maintained for the needed improvements The fair-share payments would be above the required local and regional fee payments, unless the identified improvements are included or added to a local or regional fee program prior to occupancy of Phase 2. If the identified improvements are added to a local or regional fee program prior to occupancy of Phase 2,then the applicant shall pay the fee established under the fee program prior to occupancy of Phase 2 as satisfaction of this mitigation measure. Prer-te '•^•^g tti^' " c rg"'i i^t°•seven of Sa^Y42ita Pead/I-3°R-Eastb^und Ramps The Page 3.11-89,Mitigation Measure TRANS-18 The text of the mitigation measure has been revised to clarify the intent that fair share contributions to these two regional improvements will be collected, not actual construction of the improvements, which are regional in nature and involving multiple local and state Jurisdictions MM TRANS-18 Prior to occupancy of Phase 2,the applicant shall provide its fair-share cost contribution to the Phase 2 Fallon/I-580/El Charro interchange improvements The interchange improvements include (1) Reconstruction of overcrossrng to provide four-lanes in each direction, (2) reconstruction of the southbound to eastbound loop on-ramp; (3)widening of the eastbound off-ramp to provide two exit lanes with two left turn and two right tum lanes; 14)widening of the eastbound on-ramp; (5) widening of the westbound off-ramp to provide two left tum and two right turn lanes, (6)and widening of the westbound on-ramp. An escrow account where fair- share funds can be deposited for interchange improvements not included in local or regional fee programs shall be established in coordination with the cities of Livermore, Pleasanton, and the Alameda CTC The City will ensure that the fair- share costs are collected for the escrow account and maintained for the needed improvements. The fair-share payments would be above the required local and regional fee payments, unless the identified improvements are included or added to a local or regional fee program prior to occupancy of Phase 2. If the identified improvements are added to a local or regional fee program prior to occupancy of Phase 2,then the applicant shall pay the fee established under the fee program prior to occupancy of Phase 2 as satisfaction of this mitigation measure. T r_°,,.�- Rya° Road rrstccrbon Solutions <d] City of Dublin-Kuser Dublin Metlrml Center Project Errata Final UR Page 3.11-93, Cumulative Traffic Impacts The sentence describing the cumulative traffic impact scenario has been revised to note that it represents Year 2040. Cumulative Traffic Impacts The proposed project would generate new trips that would contribute to unacceptable traffic operations under Cumulative Conditions (Year 20401. Page 3.11-129, Last Paragraph A statement in the last paragraph has been revised to note the correct horizon year of Alameda County Transportation Commission roadway analyses This analysis considers the impact of the project on freeways, major arterials, and other major roadways as designated by Alameda CTC Main items of discussion include the geographic scope of the Alameda CTC roadway analysis,the analysis method,and the results for 2020 2025 and 2040 Section 5,Alternatives to the Proposed Project Page 5-3 and Page 5-4,Alternative 1—No Project Alternative The summary of the No Project Alternative has been amended to note the existing General Plan and Specific Plan land use designation for the project site and reference the Corporate Office Campus Alternative CEQA Guidelines Section 15126.6(e) requires EIRs to evaluate a"No Project Alternative,' which is defined as the"circumstance under which the project does not proceed" The project site currently has a land use designation under the General Plan and Eastern Dublin Specific Plan J"Office Campus"1 and a preliminary Planned Development Zoning Distnct There are no approved entitlements for the project site,so at this moment,there is no project that could be constructed without first obtaining a revised Stage 1 and Stage 2 Planned Development Zoning District and Site Development Review approval, at a minimum or any future development to take place on the site. Because the project site currently has no planning approvals,the No Project Alternative consists of the project site remaining undeveloped for the foreseeable future Refer to the Corporate Office Campus Alternative for an alternative that considers buildout of the protect site under the existing General Plan and Specific Plan land use designation of"Office Campus." Page 5-14, First Paragraph and Nine Bulleted Items The discussion of the degree to which the Corporate Office Campus Alternative would advance the project objectives has been revised to strike the first,second,fourth,fifth,seventh, and eighth objectives,as this alternative would not develop health care uses or have a commercial component with a range of end uses 4-18 First oman Solutions City of aubi,n-xoaer Dublin Medical Center Project Final ElR Errata The Corporate Office Campus Alternative would advance some—but not all—of the project objectives by virtue of developing office uses in place of a medical center. The Corporate Office Campus Alternative would advance the following objectives to an equivalent degree as the proposed project: within Dublin to serve existing and future demand in the •-• "-"ey•cg•er, � rtality,economy g•ewt'•a^d -"de rargc of employment opportunities in Dublin and th surrounding • Positively contribute to the local economy through new capital investment,the creation of new jobs,the provision of new services,and the expansion of the tax base, • Facilitating the logical, orderly, and phased development of a high-visibility, infill site in order to achieve the highest-and-best end uses at a site with good freeway access and proximity to public transportation; ne . . _ surrounding hills from I SoB,and • Closing a gap in the bicycle and pedestrian network within the community by providing on-site pedestrian and bicycle facilities that link with existing facilities along Dublin Boulevard Appendix 1,Transportation Assessment Chapter 1, Page 17, First Paragraph, Second Sentence The text on page 17 has been revised to indicate that the LOS E standard for Caltrans facilities in the study area is consistent with Tn-Valley Transportation Council guidelines. A standard of LOSE or better on a peak hour basis was used as the planning objective for the evaluation of potential impacts of this development on Caltrans facilities as that is the FnwCarbon SolutIons 0-19 Gry of Dublin—Kane(Dublin Medical Center Project Errata Final EM standard set for Caltrans facilities,consistent with In-Valley Transportation Council guidelines in th ' meda r'TC Chapter 8, Global Change All references to "2025" are hereby changed to "2020.' • 4-20 FirstCarbon Solutions 'age 1 of 2 IFollows Conditional No.:119-09-024C JDate: May 03,2007 (Case No.:07-09-0840A LOMR-F p as to Federal Emergency Management Agency �•4xo °aF Washington,D.C.20472 sb LETTER OF MAP REVISION BASED ON FILL DETERMINATION DOCUMENT (REMOVAL) COMMUNITY AND MAP PANEL INFORMATION LEGAL PROPERTY DESCRIPTION CITY OF DUBLIN,ALAMEDA A portion of Parcels 4 and 5,as shown on Parcel Map No.9003, COUNTY,CALIFORNIA recorded in Book 292, Pages 89 through 92,in the Office of the Recorder,Alameda County,California COMMUNITY The portion of property is more particularly described by the following COMMUNITY NO.:060705 metes and bounds: AFFECTED NUMBER:0607050002B I MAP PANEL DATE:9/17/1997 LOCOING SOURCE:PONDING APPROXIMATE LATITUDE 8 LONGITUDE OF PROPERTY:37.705, -121 868 SOURCE OF UT 8 LONG:PRECISION MAPPING STREETS 7.0 DATUM:WAD 83 DETERMINATION OUTCOME 1%ANNUAL LOWEST LOWEST BLOCK/ WHAT IS CHANCE ADJACENT LOT SUBDIVISION STREET REMOVED FROM FLOOD FLOOD GRADE ELEVATION SECTION THE SFHA ZONE ELEVATION ELEVATION (NGVD29) (NOVO 29) (NGVD 29) • — Portion of X 3460 feet — 3470 feel Property (unshaded) Special Flood Hazard Area (SERA) - The SFHA Is an area that would be Inundated by the flood having a I-percent chance of being ,aualed or exceeded in any given year(base flood) ADDITIONAL CONSIDERATIONS(Please refer to the appropdale section on Attachment I for the additional considerations listed below.) LEGAL PROPERTY DESCRIPTION FILL RECOMMENDATION PORTIONS REMAIN IN THE SFHA Thia document provides the Federal Emergency Management Agency's determination regarding a request for a Lester of Map Revision based m Fill for the property described above Using the information submitted and the effective National Flood Insurance Program (NFIP) map. we rave determined that the described penknife) of the property(ies) is/are not located in the SERA. an area inundated by the flood having a 1-percent chance of being equaled or exceeded In any given year (base flood) This document revises the effective NFIP map to remove the subject property from the SFHA located on the effective NFIP map, therefore, the Federal mandatory flood insurance requirement does not reply However, the lender has the option le continue the flood insurance requirement to protect its financial risk on the loan, A Preferred Risk 'alley(PRP)is available ror buildings located outside the SFHA, Information about the PRP and how one can apply is enclosed IThis determination is based en the flood data presently available. The enclosed documents provide additional Information regarding This letermination. II you have any questions about This document. please contact the FEMA Map Assistance Center loll free at (877) 336-2627 1877-FEMA MAP) or by letter addressed to the Federal Emergency Management Agency. 3601 Eisenhower Avenue. Suite 130, Alexandria, VA 223046439, William R.Blanton Jr.CFM,Chief Engineering Management Section Mitigation Division Page 2 of 2 !Follows Conditional No.:99M9-6240 'Date: May 03,2007 'Case No.:07-09-0840A I LOMR-F Federal Emergency Management Agency sp`uF Washington,D.C.20472 4xp ss� LETTER OF MAP REVISION BASED ON FILL DETERMINATION DOCUMENT (REMOVAL) ATTACHMENT 1 (ADDITIONAL CONSIDERATIONS) LEGAL PROPERTY DESCRIPTION(CONTINUED) BEGINNING at the northeast corner of Parcel 4; thence S00°00'00"W, 504.21 feet;thence N87°07'31°W, 94.54 feet;thence along the tangent curve to the right having a radius of 626.50 feet, through a central angle of 06°27'12", for an arc distance of 70.56 feet to a point of reverse curvature, along the reverse curve to the left having a radial bearing of N09°19'41"E, a radius of 1637.50 feet, through a central angle of 20°57'14',for an arc distance of 598.86 feet; thence S78 022'27"W, 92.42 feet, thence along the tangent curve to the right 376.50 feet, through a central angle of 05°18'41", for an arc distance of 34 90 feet;thence S83°41'08"W, 12.00 feel;thence N00°45'00°W, 606.01 feet; thence N17°07'28"E, 133.00 feet; thence along the non-tangent curve to the left, having a radial bearing of S17°07128°W, a radius of 5058.00 feet, through a central angle of 10°02'29",for an arc distance of 886.45 feet; thence S00°00'00°W, 18.14 feet to the POINT OF BEGINNING FILL RECOMMENDATION(This Additional Consideration applies to the preceding 1 Property.) The minimum NFIP criteria for removal of the subject area based on fill have been met for this request and the nmunity in which the property is located has certified that the area and any subsequent structure(s)built on the tined area are reasonably safe from flooding. FEMA's Technical Bulletin 10-01 provides guidance for the construction of buildings on land elevated above the base flood elevation through the placement of fill. A copy of Technical Bulletin 10-01 can be obtained by calling the FEMA Map Assistance Center toll free at(877)336-2627 (877-FEMA MAP)or from our web site at http://www.fema.gov/miVtb1001.pdf. Although the minimum NFIP standards no longer apply to this area, some communities may have floodplain management regulations that are I more restrictive and may continue to enforce some or all of their requirements in areas outside the Special Flood • Hazard Area. PORTIONS OF THE PROPERTY REMAIN IN THE SFHA(This Additional Consideration applies to the , preceding 1 Property.) Portions of this property, but not the subject of the Determination/Comment document, may remain in the Special ' Flood Hazard Area. Therefore, any future construction or substantial improvement on the property remains • subject to Federal, State/Commonwealth,and local regulations for floodplain management. it • • allachment provides additional Information regarding this rogues!. If you have any question about This allachment, please contact the s FEMA Map Assistance Center loll free at (877) 3364827 (877-FEMA MAP) or by leller addressed Ia the Federal Emergency Management Agency,3601 Eisenhower Avenue,Suite 130.Alexandria,VA 22304-6439 W e e m e;, R 4 L Z , _ • William R Blanton Jr.CFM.Chief i Engineering Management Section oESi\� y' o Federal Emergency Management Agency °jWashington, D.C. 20472 caxo se ADDITIONAL INFORMATION REGARDING LETTERS OF MAP REVISION BASED ON FILL When making determinations on requests for Letters of Map Revision based on the placement of fill (LOMR-Fs), the Department of Homeland Security's Federal Emergency Management Agency(FEMA) bases its determination on the flood hazard information available at the time of the determination. Requesters should be aware that flood conditions may change or new information may be generated that would supersede FEMA's determination.In such cases,the community will be informed by letter. Requesters also should be aware that removal of a property(parcel of land or structure) from the Special Flood Hazard Area(SFHA)means FEMA has determined the property is not subject to inundation by the flood having a 1-percent chance of being equaled or exceeded in any given year(base flood). This does not mean the property is not subject to other flood hazards. The property could be inundated by a flood with a magnitude greater than the base flood or by localized flooding not shown on the effective National Flood Insurance Program(NFIP)map. The effect of a LOMR-F is it removes the Federal requirement for the lender to require flood insurance coverage for the property described. The LOMR-F is not a waiver of the condition that the property owner maintain flood insurance coverage for the property. Only the lender can waive the flood insurance purchase requirement because the lender imposed the requirement. The property owner must request and receive a written waiver from the lender before canceling the policy. The lender may determine, on its own as a business decision,that it wishes to continue the flood insurance requirement to protect its financial risk on the loan. The LOMR-F provides FEMA's continent on the mandatory flood insurance requirements of the NFIP as they apply to a particular property. A LOMR-F is not a building permit,nor should It be construed as such.Any development, new construction, or substantial improvement of a property impacted by a LOMR-F must comply with all applicable State and local criteria and other Federal criteria. If a lender releases a property owner from the flood insurance requirement,and the property owner decides to cancel the policy and seek a refund, the NFIP will refund the premium paid for the current policy year, provided that no claim is pending or has been paid on the policy during the current policy year. The property owner must provide a written waiver of the insurance requirement from the lender to the property insurance agent or company servicing his or her policy. The agent or company will then process the refund request. Even though structures are not located in an SFHA,as mentioned above,they could be flooded by a flooding event with a greater magnitude than the base flood. In fact,more than 25 percent of all claims paid by the NFIP are for policies for structures located outside the SFHA in Zones B,C,X(shaded),or X(unshaded). More than one-fourth of all policies purchased under the NFIP protect structures located in these zones. The risk to structures located outside SFHAs is just not as great as the risk to structures located in SFHAs.Finally, approximately 90 percent of all federally declared disasters are caused by flooding, and homeowners insurance does not provide financial protection from this flooding. Therefore,FEMA encourages the widest possible coverage under the NFIP. 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