HomeMy WebLinkAboutItem 6.1.i - 9. Exhibit B to Attachment 7 IKEA Retail Center Fi
NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA
WWW.FIRSTCARBONSOLUTIONS.COM
FINAL
Supplemental Environmental Impact Report
IKEA Retail Center Project
City of Dublin, Alameda County, California
State Clearinghouse Number 2017082047
Prepared for:
City of Dublin
100 Civic Plaza
Dublin, CA 94568
925.833.6610
Contact: Amy Million, 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
Janna Waligorski, Project Manager
Date: September 14, 2018
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Table of Contents
FirstCarbon Solutions iii
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec00-01 TOC.docx
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 ................................................................................................ 3-2
Section 4: Errata.......................................................................................................................... 4-1
4.1 - Changes to Draft EIR Text ............................................................................................... 4-1
Appendix I: Supplemental Air Quality Supporting Information
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Introduction
FirstCarbon Solutions 1-1
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec01-00 Introduction.docx
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 IKEA Retail Center Project Draft
Supplemental Environmental Impact Report (SEIR). The responses to the comments and errata,
which are included in this document, together with the Mitigation Monitoring and Reporting
Program, form the Final SEIR 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 who commented on the Draft SEIR. Copies of all of the letters received
regarding the Draft SEIR and responses thereto are included in this section.
• Section 4—Errata. Includes an addendum listing refinements and clarifications on the Draft
SEIR, which have been incorporated.
The Final SEIR includes the following contents:
• Draft SEIR (provided under separate cover)
• Draft SEIR appendices (provided under separate cover)
• Master Responses, Responses to Written Comments on the Draft SEIR, and Errata (Sections 2,
3, and 4 of this document)
• Mitigation Monitoring and Reporting Program (provided under separate cover)
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Master Responses
FirstCarbon Solutions 2-1
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec02-00 Master Responses.docx
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.
2.1 - Master Response
Master Response 1—Project Merits
Summary of Relevant Comments
The City of Dublin received numerous written comments about the merits of the IKEA Retail Center
Project. The majority of these comments expressed opposition citing traffic congestion, sub-optimal
use of the site, public safety, and community image. None of the comments raise questions about
the sufficiency of the Draft SEIR’s analysis of environmental impacts.
Response
The comments primarily express a position on the merits of the proposed project—whether or not
the City should approve the project. Several letters make reference to environmental impacts of the
Project identified in the EIR as a reason for not approving the Project. Some of the environmental
impacts of the project referenced in the comments include traffic and aesthetics. However, the
comments recite the conclusions from the SEIR, and do not offer any comments on the adequacy of
the analysis itself.
With regard to comments referring to the EIR’s conclusions on traffic impacts, traffic is evaluated in
detail in Section 3.6, Transportation. The evaluation assessed 31 intersections, 39 segments of I-580,
22 segments of I-680, 12 roadways, and three I-580 freeway ramps. The analysis found that the
project would have a significant impact on certain intersection, freeway segment, and roadway
segment operations. Mitigation was proposed for significant impacts; however, for certain
intersections and roadways, the Draft SEIR concluded that traffic impacts would be significant and
unavoidable because the mitigation measure is infeasible or its implementation is in the control of
another agency. None of the comments challenge or dispute the analysis or conclusions in the SEIR
on traffic impacts and mitigation.
Because the letters do not specifically question the adequacy of the analysis of environmental
impacts in the SEIR and only address the merits of the project, no responses to these comments are
required under CEQA. These comments are provided at the end of Section 3, Responses to Written
Comments. They will be part of the project record and presented to the City of Dublin decision-
makers for consideration prior to acting on the proposed project.
Master Response 2—Comments Raising Similar Issues
Summary of Relevant Comments
The City of Dublin received five letters that contained verbatim or near verbatim comments
summarizing the SEIR’s conclusions regarding transportation and other environmental issues and
expressing objection to the proposed project.
City of Dublin—IKEA Retail Center Project
Master Responses Administrative Final SEIR
2-2 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec02-00 Master Responses.docx
Response
To the extent these letters do not specifically address environmental issues and the adequacy of the
SEIR’s analysis, no responses to these comments are required under CEQA. To the extent
environmental issues are referenced in the comments, these issues are addressed in the response to
individual comment letters. Also, see Master Response 1 for comments addressing the
transportation analysis.
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-1
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
SECTION 3: RESPONSES TO WRITTEN COMMENTS
3.1 - List of Authors
A list of public agencies, organizations, and individuals that provided comments on the Draft SEIR 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.
Additionally, the City of Dublin received 105 comments that commented on the project but did not
provide comments on any aspect of the Draft SEIR’s analysis. In accordance with CEQA Guidelines
Section 15003(g), which provides “The purpose of CEQA is not to generate paper, but to compel
government at all levels to make decisions with environmental consequences in mind”, copies of
these letters are provided at the end of this section; however, because these letters do not contain
comments specific to the analysis contained within the SEIR or any environmental issue, individual
responses to these comments are not provided, but instead are addressed in Section 2, Master
Responses.
Author Author Code
State Agencies
California Department of Transportation ................................................................................. CALTR ANS
Local Agencies
Alameda County Transportation Commission .................................................................................. ACTC
City of Pleasanton ............................................................................................................... PLEASANTON
Dublin San Ramon Services District ............................................................................................... DSRSD
Organizations/Multiple Parties
Adams Broadwell Joseph & Cardozo .................................................................................................... AB
California Native Plant Society ......................................................................................................... CNPS
Lozeau Drury ......................................................................................................................................... LD
Individuals
Tom Cignarella ...................................................................................................................... CIGNARELLA
Liana deWit-Smith ............................................................................................................. DEWIT-SMITH
Tammy Ficarra ............................................................................................................................ FICARRA
Jeff Gebel ........................................................................................................................................ GEBEL
Chenin Gonzales ...................................................................................................................... GONZALES
John Heyer ...................................................................................................................................... HEYER
Mike Kaube .................................................................................................................................... KAUBE
Lianne Marshall ...................................................................................................................... MARSHALL
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-2 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Jegadheesa Murugesa ........................................................................................................... MURUGESA
Chris Page ......................................................................................................................................... PAGE
Feroza Solaiman ...................................................................................................................... SOLAIMAN
Rupert Young ................................................................................................................................. YOUNG
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 SEIR (State
Clearinghouse No. 2017082047) for the IKEA Retail Center Project, and has prepared the following
responses to the comments received. This Response to Comments document becomes part of the
Final SEIR 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.
CALTRANS
Page 1 of 3
1
2
2
CONT
3
4
5
CALTRANS
Page 2 of 3
6
CALTRANS
Page 3 of 3
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-7
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
State Agencies
California Department of Transportation (CALTRANS)
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. No response is necessary.
Response to CALTRANS-3
Mitigation measures were identified to mitigate the project’s impacts to the freeway system,
including preparation and implementation of a transportation demand management program (MM
TRANS-4a) to reduce the overall vehicle trip generation from the levels considered in the analysis,
and payment of all local and regional transportation impact fees. Local fees include improvements
to City of Dublin streets and intersections, and regional fees include regional roadway facilities as
well as a number of Caltrans facilities. (Please see Response to ACTC Comment 7 for additional
details related to the fee programs that apply to this project.) Many of the improvements noted in
the SHOPP program, which is referenced in Caltrans letter, are upgrades of existing facilities that do
not meet current design standards, or roadway rehabilitation, which would not mitigate the project’s
impacts to the freeway system.
Caltrans should coordinate with the Tri-Valley Transportation Council to identify additional regional
projects that could be included in the regional fee program, as well as develop an Integrated
Corridor Management Plan for Interstate 580 (I-580) in the Tri-Valley area such that corridor
improvements can be identified and programmed into the regional fee program. Caltrans prepared
the Interstate 580 East Corridor System Management Plan in May 2010, which identifies a number of
corridor improvements from I-880 to I-205. In the study area, none of the identified improvements
would mitigate project impacts, with the exception of some interchange improvements, which have
been incorporated into the regional fee program and already considered in the Draft SEIR findings.
Response to CALTRANS-4
Please refer to Response to ACTC-3 and Response to ACTC-10.
Response to CALTRANS-5
The agency noted that the City of Dublin is responsible for all project mitigation. Implementation
and monitoring of mitigations will be identified in the Mitigation Monitoring and Reporting Program
adopted as part of the any Project approval.
Response to CALTRANS-6
The agency provided closing remarks to conclude the letter. No response is necessary.
THIS PAGE INTENTIONALLY LEFT BLANK
ACTC
Page 1 of 3
1
2
3
ACTC
Page 2 of 3
3
CONT
4
5
6
7
8
9
10
ACTC
Page 3 of 3
11
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-13
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
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 City of Dublin has updated ACTC’s contact information to its project notification list and the
agency received the notice of the availability of the Final SEIR and public meetings.
Note that the Draft SEIR evaluated ACTC regional roadways in Section 3.6 (Transportation) in Impact
TRANS-5, and, therefore, the City’s intent from the outset was to ensure that ACTC’s area of
jurisdiction was addressed in the document.
Response to ACTC-3
As part of Mitigation Measure TRANS-4a, the project applicant is required to prepare and implement
a transportation demand management (TDM) plan with measures targeted to site employees as well
as patrons. This plan shall be reviewed and approved by the City of Dublin, and the project applicant
shall be responsible for all costs associated with developing, implementing and monitoring the plan.
The plan will identify TDM goals and strategies for employees as well as patrons, with provisions for
monitoring.
Response to ACTC-4
An evaluation of the operations of the I-580 Express Lanes were not conducted as these lanes are
dynamically priced to maintain free-flow operations. Any increase in the demand for this facility by
the Project would be counterbalanced by an increase in pricing to maintain the same demand before
and after the Project is built. Since the demand for the Express Lanes would remain the same before
and after the Project due to dynamic pricing, demand changes from the Project only affect the
general purpose lanes and these impacts and mitigations are covered in the SEIR. The SEIR assesses
potential project impacts on State Route 84 (SR-84) between Airway Boulevard and I-680. SR-84 is
referred to as Isabel Avenue between Airway Boulevard and Vallecitos Road, and as Vallecitos Road
between Isabel Avenue and I-680. A significant impact was identified on Isabel Avenue (SR-84)
between Stanley Boulevard and Concannon Boulevard in the year 2040, as presented on Draft SEIR
page 3.6-164, and mitigation measures were identified. No additional analysis is required.
Response to ACTC-5
The comment accurately describes Table ES-2. No additional response necessary.
Response to ACTC-6
The agency is referring to the freeway analysis, which correlates freeway density to LOS. The
Highway Capacity Manual (2010) states on page 11-7 that “LOS F is identified when demand exceeds
capacity because the analytic methodology does not allow the determination of density when
demand exceeds capacity.” Therefore, the actual density numbers are not provided. For freeway
locations that are projected to operate at LOS F, significant impacts were identified where the
project added trips to the location. Since the impact is not directly tied to the increase in density,
the density calculations would not change the overall findings presented in the Draft SEIR.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-14 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to ACTC-7
The Eastern Dublin Traffic Impact Fee (local) is calculated on a per average weekday vehicle trip
basis. Funds deposited into the Eastern Dublin Traffic Impact Fee would be applied to improvements
on local roads owned and maintained by the City of Dublin, including projects such as the Scarlett
Drive Extension between Dougherty Road and Dublin Boulevard. Detailed information about the
program can be found on the City’s website: http://www.dublin.ca.gov/1330/Fee-Schedule.
The Tri-Valley Transportation Development Fund (regional) is calculated from average peak-hour
vehicle trips. Funds deposited into the Tri-Valley Transportation Development Fund would be
applied to planned improvements on the regional transportation system, such as improvements to
SR-84, auxiliary lanes on I-680, and safety improvements on Vasco Road. Details regarding the
program are provided on the Tri-Valley Transportation Council website: http://www.tvtc-
jpa.com/getattachment/f2a953a0-7122-49de-8e69-d729654a5840/TVTC-Fee-Schedule.aspx.
Mitigation Measure TRANS-4c is the fair share contribution towards the installation of an additional
mixed-flow on-ramp lane from southbound Hacienda Drive to westbound I-580. The fair-share
contribution will be calculated based on an estimate of the total project cost, the level of existing
traffic (as the location is currently deficient), the projections of non-project added traffic, and the
amount of project-added traffic. This improvement is not included in either the Eastern Dublin
Traffic Impact Fee or the Tri-Valley Transportation Development Fund. Should the project be added
to either fee program, payment of fees would constitute a fair share contribution.
Response to ACTC-8
Trip generation estimates for the IKEA portion of the project were developed based on surveys of
three existing IKEA stores over multiple days. Trip generation estimates for the other retail uses
were developed using trip generation rates in the Transportation Engineers (ITE) Trip Generation
Manual, (9th Edition).
Information contained in the ITE Trip Generation Handbook and surveys of similar uses were used to
estimate pass-by and diverted-link trips for the general retail portion of the project only. For general
retail, the average pass-by rate is 34 percent, and the average diverted linked trip rate is 16 percent
during PM peak hour (limited data is available for the AM peak hour). In other words, at a typical
shopping center, approximately 50 percent of the traffic entering and exiting the site is already on
the surrounding roadway system. Studies have also shown shopping centers with more than 50
percent pass-by/diverted trips. For this assessment, it was assumed that pass-by/diverted trips for
the retail/restaurant portion of the project would comprise 50 percent of the trip generation on a
daily basis and 30 percent on a peak-hour basis. Pass-by/diverted trips are fully captured in the
analysis of project site access locations, as well as on the deviated route.
IKEA is not a typical retail store, as it attracts trips as their primary destination from a larger
catchment area than typical retail centers. This creates the potential that some patrons who come
to the site primarily for IKEA would also patronize the other retail/restaurant establishments.
Internal capture rates from ITE for general retail land-uses (information is not available specifically
for restaurant land-uses, but they are considered similar to the retail uses) estimate that at least 20
percent of retail patrons would already be at the site. For the purpose of the trip generation
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-15
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
estimate, it is expected that up to 20 percent of the restaurant/retail patrons would be at the site
already patronizing the IKEA store, or other retail/restaurant use. This reduction was based on data
and procedures contained in the ITE Trip Generation Handbook, which yielded a higher than 20
percent internal reduction. To present a conservative assessment of potential project impacts, the
internal reduction was capped at 20 percent. Since IKEA does not open until after the AM peak hour,
internal capture reductions were not applied to the AM peak hour. As there is limited mid-day peak-
hour trip generation information available, the weekday PM peak-hour trip generation was assumed
for the midday time period.
Response to ACTC-9
The City of Dublin has installed transit signal priority on Dublin Boulevard and plans to install transit
signal priority at additional intersections along transit corridors to address bus delays for routes
serving the project area. The City has constructed queue jump lanes on westbound Dublin
Boulevard at Village Parkway, westbound Dublin Boulevard at Dougherty Road, eastbound Dublin
Boulevard at Arnold Road, and on westbound Dublin Boulevard at Tassajara Road, providing an
advantage to transit vehicles traveling through the corridor. The potential to construct queue jump
lanes at other locations is also being evaluated by the City of Dublin along the corridor.
All intersections along Dublin Boulevard (the Rapid Bus Route) are projected to operate at LOS E (the
ACTC standard) or better with the incorporation of mitigation measures in the cumulative condition
with the project, and most intersections are projected to operate at LOD D or better (the City of
Dublin standard).
With the availability of existing and planned queue jump lanes and existing transit signal priority,
coupled with project mitigation measures which include installation of adaptive traffic signal control
to provide better signal coordination along key corridors and intersection improvements, the project
is not expected to add a significant amount of delay to transit vehicles on City streets.
Express buses that use the freeway system are allowed to use the Express Lane that is dynamically
priced to maintain free-flow travel. Although the mainline operation of express buses on I-580 would
not be affected by the project, Route 580X does enter/exit the freeway at Hacienda Drive. There is a
carpool bypass lane for bus vehicles entering the freeway, and the freeway ramp terminal intersections
are projected to operate at acceptable service levels. Bus operations could be slowed in the freeway
merge/diverge areas of I-580 westbound at Hacienda Drive during the morning peak hour (diverge
area) and I-580 eastbound at the Hacienda Drive interchange in the weekday PM peak hour (merge
area). These impacts were identified in the Draft SEIR and no additional analysis is required. The
project impact on this segment of Hacienda Drive was identified as less than significant in the weekday
AM peak hour.
The 70X operates on I-680, north of I-580 where express lanes are provided. Similar to I-580, buses
are permitted to use the Express Lanes where dynamic pricing maintains free-flow travel.
Response to ACTC-10
The Draft SEIR addresses safety impacts to pedestrians and bicyclists on pages 3.6-168 to 3.6-170,
which include mitigation measures that require the applicant to provide bicycle facilities connecting
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-16 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
to the project site, bicycle detection at intersections that provide primary access to the project site,
safe and convenient pedestrian access to the project vicinity, even during construction, and
contribute to pedestrian and bicycle improvements at the I-580/Hacienda Drive interchange.
Additionally, mitigation measures that identified the need for roadway widening beyond the levels
already contemplated and approved by the City of Dublin were reviewed for their secondary impact
to pedestrians and cyclists. For example, potential secondary impacts to bicycles and pedestrians
were identified with implementation of Mitigation Measure TRANS-4c, which would widen the
Hacienda Drive on-ramp to provide additional mixed-flow vehicle storage for vehicles could result in
secondary impacts to pedestrians and bicyclists by increasing pedestrian crossing distances through
the interchange, and bicycle/vehicle conflicts. Mitigation Measure TRANS-8e was then identified to
mitigate the secondary impact.
Response to ACTC-11
The agency provided closing remarks to conclude the letter. No response is necessary.
PLEASANTON
Page 1 of 3
1
2
PLEASANTON
Page 2 of 3
3
4
PLEASANTON
Page 3 of 3
4
CONT
5
6
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-21
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
City of Pleasanton (PLEASANTON)
Response to PLEASANTON-1
The agency provided introductory remarks to open the letter. No response is necessary.
Response to PLEASANTON-2
The agency listed six roadway facilities within the Pleasanton city limits and identified deterioration
of level of service and lengthy queues as its primary concerns with these facilities. The City’s specific
concerns are addressed in Response to PLEASANTON-3 through Response to PLEASANTON-5.
Response to PLEASANTON-3
The I-580 at Santa Rita Road intersection is projected to operate at a deficient LOS F during the PM
peak hour in the near-term condition prior to the addition of project traffic. Based on the significance
criteria identified in the Draft SEIR, a significant impact was identified. In instances where the addition
of project traffic exacerbates an existing or projected deficiency, it is City of Dublin policy to require a
fair-share contribution to the improvement rather than construction of said improvement.
In the cumulative condition, the project worsens Saturday peak hour LOS F conditions. The text of the
Draft SEIR correctly identifies that the intersection would operate at LOS D with implementation of
the improvements; Table 3.6-19 of the SEIR incorrectly indicates that the improvement would result in
LOS E operations during the Saturday peak hour. This correction is noted in Section 4, Errata.
However, the range of mitigation required to return the intersection to LOS D should have also
included the following: either modifying the northbound approach to construct a third eastbound
left-turn lane or modifying the southbound approach to provide a third southbound through lane, in
addition to re-timing the traffic signal. Section 4 Errata shows the proposed edits to Mitigation
Measure TRANS-2c.
The effectiveness of modifying Mitigation Measure TRANS-2c to include constructing a third
eastbound left-turn lane and associated receiving lane, or a third southbound through lane, is
presented in Table 3-1 for the cumulative Saturday peak hour. As shown, the addition of this
broader range of improvements would ensure that the project and cumulative impact is reduced to a
less than significant level.
As indicated in the Draft SEIR, the City of Dublin and the project applicant shall work with the City of
Pleasanton, Caltrans, and ACTC to identify feasible improvements at this interchange and contribute
their fair share.
Table 3-1: Cumulative With Mitigation—Peak Hour Intersection Levels of Service
Intersection Control Peak Hour
Cumulative
Without
Project
Cumulative
With Project
Cumulative With
Project With Draft
SEIR Mitigation
Cumulative With
Project With Final
SEIR Mitigation
Delay LOS Delay LOS Delay LOS Delay LOS
Santa Rita Road/I-580
Eastbound Off-Ramp Signal Saturday 94.5 F 97.4 F 63.6 E 39.5 D
Notes:
Bold indicates LOS E/F; Bold italics indicates impacts due to the proposed project
Source: Fehr & Peers, 2018.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-22 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to PLEASANTON-4
Mitigation measures for freeway ramp meter impacts considered a tiered approach. The first tier
determined whether increasing the ramp metering rates within the allowable range by Caltrans (180
to 900 vehicles per hour) would mitigate the impact. This mitigation is identified as Mitigation
Measure TRANS-4b in the Draft SEIR and was found to mitigate the impact at the southbound
Dougherty Road to I-580 westbound ramp and southbound Hacienda Drive to I-580 eastbound
ramp. Mitigation Measure TRANS-4b would also mitigate the impact at the southbound Hacienda
Drive to westbound I-580 in the existing and near-term condition. Caltrans has agreed to work with
the City of Dublin to evaluate ramp meter rates along the I-580 corridor.
To accommodate cumulative growth, an additional mitigation measure, Mitigation Measure TRANS-
4c, that identifies the provision of a second mixed-flow on-ramp lane was required in the Cumulative
condition for the southbound Hacienda Drive to westbound I-580 ramp.
Mitigation Measure TRANS-4c in the Draft SEIR identifies the fair-share contribution to the
construction of a second mixed-flow on-ramp lane from southbound Hacienda Drive to westbound
580. As this is an existing deficiency, fair-share payment towards improvements will be required in
accordance with City of Dublin policy.
Response to PLEASANTON-5
As part of the conditions of approval, the project applicant shall be required to prepare a
transportation demand management plan that also identifies parking management strategies (refer
to Response to ACTC-3 for additional detail). As part of the parking management program,
strategies to accommodate special events and peak holiday-season parking demand will be
developed and are expected to include provision for off-site employee parking at near-by office
campuses on weekends, or valet parking. The project applicant shall be responsible for developing,
financing, and implementing the plan, and for securing overflow parking agreements with adjacent
property owners, if needed.
Although parking is not a CEQA issue, the City recognizes that periods of peak parking demand can
create excess vehicle circulation, congestion and driver frustration. The requirement to prepare a
parking management plan as part of the conditions of approval, as well as provisions for plan
monitoring, allows the City and project applicant to better peak travel flow to and around the
project site.
Response to PLEASANTON-6
The agency provided closing remarks to conclude the letter. No response is necessary.
DSRSD
Page 1 of 2
1
2
3
4
5
DSRSD
Page 2 of 2
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-25
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Dublin San Ramon Services District (DSRSD)
Response to DSRSD-1
The agency provided introductory remarks to open the letter. No response is necessary.
Response to DSRSD-2
The agency noted that Draft SEIR’s page ES-4 identified “Utilities (water and wastewater)” as an Area
of Controversy. The agency indicated that the proposed project is within the DSRSD service area and
noted that the Draft SEIR concluded that impacts on water and wastewater would be less than
significant. The agency concurred with this conclusion.
The “Areas of Controversy” portion of the Executive Summary is required by CEQA Guidelines
Section 15123(2) and is intended to identify issues raised by agencies and the public. In this case,
the City received numerous comments during the scoping process about the adequacy of
infrastructure, which is the basis for identifying “Utilities (water and wastewater)” in this context.
However, the Draft SEIR’s analysis found that impacts on water and wastewater were less than
significant and DSRSD agrees with that conclusion.
Response to DSRSD-3
The agency referenced the Impact PSU-5 conclusion that water supply impacts would be less than
significant and clarified that even if it does not have adequate recycled water supplies or
infrastructure to serve the proposed project’s irrigation needs, these needs can still be met with
potable water. No response is necessary.
Response to DSRSD-4
The agency referenced a statement on Draft SEIR page 3.5-11 about an important potable water
facility being present in the corner of the project site along Arnold Road. The agency noted that this
facility serves as a turnout (or connection point) between Zone 7 and DSRSD and that the operation
of this facility cannot be restricted or hindered by construction or operation of the proposed project.
DSRSD staff advised Dublin city staff and the applicant team of the significance of this facility during the
September 7, 2017 scoping meeting and it was noted in the Draft SEIR on pages 2-1, 3.5-11, and 3.5-
25. As stated on page 3.5-25, implementation of the proposed project would not alter this facility.
Response to DSRSD-5
The agency provided closing remarks to conclude the letter. No response is necessary.
THIS PAGE INTENTIONALLY LEFT BLANK
AB
Page 1 of 96
1
March 16, 2018
Page 2
4174-003acp
printed on recycled paper
each of these reasons, the City of Dublin (“City”) may not approve the Project until a
revised document is prepared and recirculated for public review and comment.
These comments were prepared with the assistance of biological resources
expert Scott Cashen and air quality experts Matt Hagemann and Hadley Nolan of
Soil Water Air Protection Enterprise (“SWAPE”). Mr. Cashen’s comments are
attached to this letter as Exhibit A and his curriculum vitae is attached as Exhibit
B. SWAPE’s comments are attached to this letter as Exhibit C, and Mr.
Hagemann’s and Ms. Nolan’s curriculum vitae are attached as Exhibit D. Mr.
Cashen’s and SWAPE’s are submitted to the City in addition to the comments
contained herein. The City must respond to these comments separately and
individually.
I. Statement of Interest
Dublin Residents for Responsible Development (“Dublin Residents”) is an
unincorporated association of individuals and labor unions that may be adversely
affected by the potential environmental impacts of the Project. The association
includes: City of Dublin residents Kris Gallegos, Art Mayberry, Joe Steiner, and
Francisco Rosa; the International Brotherhood of Electrical Workers Local 595,
Plumbers & Steamfitters Local 342, Sheet Metal Workers Local 104, and their
members and their families; and other individuals that live and/or work in the City
of Dublin and Alameda County.
Individual members of Dublin Residents and the affiliated unions live, work,
recreate and raise their families in Alameda County, including in the City of
Dublin. These members would be directly affected by the Project’s environmental
and health and safety impacts. Members of Dublin Residents may also work on the
Project itself. Accordingly, these individuals will be first in line to be exposed to any
health and safety hazards created by the Project. Dublin Residents has an interest
in enforcing environmental laws that encourage sustainable development and
ensure a safe working environment for its members. Environmentally detrimental
projects can jeopardize future jobs by making it more difficult and more expensive
for business and industry to expand in the region, and by making it less desirable
for businesses to locate and people to live there.
AB
Page 2 of 96
1
CONT
2
March 16, 2018
Page 3
4174-003acp
printed on recycled paper
II. CEQA REQUIRES THE DISCLOSURE OF ALL POTENTIALLY
SIGNIFICANT PROJECT IMPACTS AND THE INCORPORATION
OF ALL FEASIBLE MITIGATION MEASURES NECESSARY TO
REDUCE SUCH IMPACTS TO BELOW A LEVEL OF
SIGNIFICANCE
CEQA has two basic purposes. First, CEQA is designed to inform
decisionmakers and the public about the potential, significant environmental effects
of a project.1 Except in certain limited circumstances, CEQA requires that an
agency analyze the potential environmental impacts of its proposed actions in an
environmental impact report (“EIR”).2 An EIR’s purpose is to inform the public and
its responsible officials of the environmental consequences of their decisions before
they are made. In this respect, an EIR “protects not only the environment but also
informed self-government.”3
To fulfill this function, the discussion of impacts in an EIR must be detailed,
complete, and “reflect a good faith effort at full disclosure.”4 CEQA requires an EIR
to disclose all potential direct and indirect, significant environmental impacts of a
project.5 In addition, an adequate EIR must contain the facts and analysis
necessary to support its conclusions.6
The second purpose of CEQA is to require public agencies to avoid or reduce
environmental damage when possible by requiring appropriate mitigation measures
and through the consideration of environmentally superior alternatives.7 If an EIR
identifies potentially significant impacts, it must then propose and evaluate
mitigation measures to minimize these impacts.8 CEQA imposes an affirmative
obligation on agencies to avoid or reduce environmental harm by adopting feasible
1 CEQA Guidelines § 15002, subd. (a)(1).
2 See, e.g., Pub. Resources Code § 21100.
3 Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564.
4 CEQA Guidelines § 15151; San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus
(1994) 27 Cal.App.4th 713, 721-722.
5 Pub. Resources Code § 21100, subd. (b)(1); CEQA Guidelines § 15126.2, subd. (a).
6 See Citizens of Goleta Valley 52 Cal.3d at 568.
7 CEQA Guidelines § 15002, subds. (a)(2)-(3); see also, Berkeley Keep Jets Over the Bay Committee v.
Board of Port Commissioners (2001) 91 Cal.App.4th 1344, 1354; Citizens of Goleta Valley v. Board of
Supervisors (1990) 52 Cal.3d 553, 564; Laurel Heights Improvement Assn. v. Regents of University of
California (1988) 47 Cal.3d 376, 391, 400.
8 Pub. Resources Code §§ 21002.1, subd. (a), 21100, subd. (b)(3).
AB
Page 3 of 96
3
March 16, 2018
Page 4
4174-003acp
printed on recycled paper
project alternatives or mitigation measures.9 Without an adequate analysis and
description of feasible mitigation measures, it would be impossible for agencies
relying upon the EIR to meet this obligation.
As discussed in detail below, the DSEIR fails to meet either of these two key
goals of CEQA. The DSEIR fails to adequately and completely describe the Project
and the Project setting and fails to disclose and evaluate all potentially significant
environmental impacts of the Project. In addition, it proposes mitigation measures
that are unenforceable, vague or so undefined that it is impossible to evaluate their
effectiveness. A revised DSEIR must be prepared and recirculated to comply with
CEQA’s most fundamental requirements.
III. THE DSEIR FAILLS TO ESTABLISH THE ENVIRONMENTAL
SETTING AND TO ADEQUATELY DISCLOSE, EVALUATE, AND
MITIGATE ALL POTENTIALLY SIGNFICANT IMPACTS TO
BIOLOGICAL RESOURCES
A. The DSEIR Fails to Establish the Environmental Setting
Resulting in an Inadequate Assessment of Potentially
Significant Impacts to Biological Resources
The DSEIR is legally inadequate because it fails to establish the
environmental setting of the Project, resulting in inadequate disclosure and
assessment of the Project’s potentially significant impacts on biological resources.
The environmental setting, or baseline, refers to the conditions on the ground
and is a starting point to measure whether a proposed project may cause a
significant environmental impact.10 Describing the environmental setting is a
prerequisite to an accurate and meaningful evaluation of the Project’s
environmental impacts. Without this information, an appropriate analysis cannot
be performed, effective mitigation cannot be designed, and alternatives cannot be
developed. Furthermore, the failure to provide a proper baseline precludes the
public from evaluating the scope of potential biological impacts that may result
from Project-related activities.
9 Pub. Resources Code §§ 21002-21002.1.
10 Save Our Peninsula Com. v. Monterey Bd. of Supervisors (2001) 87 Cal.App.4th 99, 125.
AB
Page 4 of 96
3
CONT
4
March 16, 2018
Page 5
4174-003acp
printed on recycled paper
Here, the City’s biological resource analysis is based upon three “non-
protocol” reconnaissance surveys of the project site. FirstCarbonSolution (“FCS”)
biologists visited the Project site two times: once in spring 2016 and once and
2017.11 Additionally, the Biological Resources Assessment (“BRA”) attached to
DSEIR was prepared by WRA, Inc. following a single site visit in August 2013.12
Neither the FCS nor the WRA visits included protocol-level surveys.13 As discussed
in the attached expert comments of biologist Scott Cashen, these not protocol
reconnaissance surveys were not adequate to establish the biological resources that
may reside on or rely upon the habitat present on the Project site.14 As a result, the
City lacks substantial evidence to support a determination that the proposed
mitigation will be sufficient to reduce impacts to biological resources to a less than
significant level.
CEQA requires that the City collect sufficient facts to enable a complete and
accurate description of the Project and its impacts.15 While a City has discretion to
determine what surveys may be necessary to provide a complete and accurate
description of the project setting, it must exercise that discretion such that its
analysis and conclusions are supported by substantial evidence. In the case at hand,
additional surveys are necessary to determine if the DSEIR’s findings regarding the
Project’s biological impacts and the effectiveness of proposed mitigation are
supported by substantial evidence.
1. The DSEIR Fails to Disclose the Potential Presence of
Vernal Pool Fairy Shrimp
The Project site lies within the Livermore Vernal Pool Region.16 Ephemeral
pools in the Livermore Vernal Pool Region provide habitat for special-status
branchiopods, including the vernal pool fairy shrimp and the California
11 DSEIR at p. 3.2-15.
12 DSEIR at Appendix C.1, p. iii (WRA, Inc. Biological Resources Assessment).
13 See DSEIR at pp. 3.2-15 – 3.2-16; Exhibit A, Scott Cashen, Comments on the Draft Supplemental
Environmental Impact Report Prepared for the “IKEA Retail Center Project”(March 15,2018 ) (“S.
Cashen Comments”), p. 2.
14 S. Cashen Comments at p. 2.
15 Sundstrom v. County of Mendocino (1988) 22 Cal.App.3d 296, 311; see also Laurel Heights
Improvement Assn. v. Regents of the Univ. of Cal. (1988) 47 Cal.3d 376, 404-05.
16 S. Cashen Comments at p. 5.
AB
Page 5 of 96
4
CONT
5
March 16, 2018
Page 6
4174-003acp
printed on recycled paper
linderiella.17 The DSEIR notes that the Project site contains seasonal wetlands or
vernal pools.18 Based upon the information provided in the Wetland Delineation
data sheets provided, biologist Scott Cashen was able to determine that the
wetlands at the project site hold water long enough to provide habitat for the
federally threatened vernal pool fairy shrimp.19
The DSEIR does not evaluate, or even disclose, the potential presence of
vernal pool fairy shrimp at the Project site. However, the Biological Resource
Assessment notes that invertebrate shells from Ostracoda were detected in two of
the wetlands in 2013.20 As Mr. Cashen explains, the presence of these ‘seed shrimp’
at the Project site provides substantial evidence that vernal pool fairy shrimp also
may occur at the Project site.21 The failure to disclose the potential presence of
vernal pool fairy shrimp thus amounts to a failure to establish the complete
environmental setting for the Project, and prevents an evaluation of potential
impacts to this special status species.
Pursuant to mitigation incorporated into the Eastern Dublin General Plan
Amendment and Specific Plan, species-specific surveys for special-status
invertebrates in appropriate wetland habitats are required prior to approval of
certain projects in the Reduced Planning Area.22 Here, the Project site is within the
Reduced Planning Area subject to the survey requirements. However, the required
surveys have not been performed. Instead, the BRA simply concluded that vernal
pool fairy shrimp are “unlikely to occur in the Project Area due to the lack of vernal
pool habitat and the area’s history of repeated discing, grading and leveling.”23 As a
result, the DSEIR contains no discussion of vernal pool fairy shrimp.
As Mr. Cashen explains, the BRA’s conclusion is not supported by evidence,
and it is contradicted by scientific information on vernal pool fairy shrimp habitat.24
First, vernal pool fairy shrimp are not limited to “vernal pool” habitat; they also
17 Id.
18 DSEIR at p. 3.2-1.
19 S. Cashen Comments at p. 5.
20 DSEIR, Appendix C.1, Appendix B (Wetland Delineation Data Form for sampling date 11/5/2013).
21 S. Cashen Comments at p. 5.
22 City of Dublin. 1993. Addendum to Eastern Dublin General Plan Amendment and Specific Plan
Environmental Impact Report. p. 22.
23 DSEIR, Appendix C.1 at p. 12.
24 S. Cashen Comments at pp. 5-6.
AB
Page 6 of 96
5
CONT
March 16, 2018
Page 7
4174-003acp
printed on recycled paper
occur in vernal pool-like habitats.25 Indeed, vernal pool fairy shrimp occur in a wide
range of habitats, including degraded or otherwise poor-quality habitats such as
pools created by tire tracks and roadside ditches. In this case, the seasonal
wetlands at the Project site provide potential habitat for vernal pool fairy shrimp.26
Second, according to the Wetland Delineation, the wetlands at the Project
site have experienced “little disturbance” since 2008.27 This contradicts the
statement in the BRA that the wetlands are unlikely to provide habitat because
they have been subject to repeated disking, grading, and leveling.28 Moreover, even
disking, grading, and leveling do not preclude the potential presence of vernal pool
fairy shrimp.29 For example, in Contra Costa County, over 100 vernal pool fairy
shrimp were documented occurring in a “non-vegetated depression in dirt road
along tracks—partially scraped by bulldozer,” and that had “routine vehicle traffic
through [the] area.”30
In sum, because substantial evidence shows that potential habitat for vernal
pool fairy shrimp occurs on the Project site and no protocol-level surveys have been
conducted to confirm or refute their presence, the DSEIR’s failure to include vernal
pool fairy shrimp as among the special-status species at the Project site is not
supported. This omission amounts to a failure to establish an accurate
environmental setting in violation of CEQA, and prevents evaluation of a
potentially significant impact to vernal pool fairy shrimp resulting from Project-
related fill activities.
2. The DSEIR Fails to Disclose the Potential Presence of
California Linderiella
Like vernal pool fairy shrimp, the DSEIR fails to disclose the potential
presence of California linderiella at the Project site, despite substantial evidence of
their potential to occur. California linderiella occupy the same type of habitat as the
vernal pool fairy shrimp.31 They have also been detected in seasonal wetlands
25 Id. at p. 6.
26 Id. at p. 6.
27 Id.
28 See also DSEIR at p. 3.2-1; S. Cashen Comments at p. 6.
29 S. Cashen Comments at p. 6.
30 Id.
31 Id. at p. 7.
AB
Page 7 of 96
5
CONT
6
March 16, 2018
Page 8
4174-003acp
printed on recycled paper
similar to those at the Project site.32 Mr. Cashen’s comments explain that California
linderiella have the potential to occur on the Project site and that their potential
presence should be disclosed in DSEIR.33
The DSEIR’s failure to disclose the potential presence of California linderiella
violates CEQA by failing to establish an accurate and complete environmental
setting. The failure to disclose the potential presence of California linderiella also
results in a failure to evaluate potentially significant impacts to this species
resulting from Project-related fill activities.
3. The DSEIR Fails to Provide Critical Information
Regarding Burrowing Owls at the Project Site
The DSEIR states that there is moderate potential for burrowing owls to
occur at the Project site.34 However, the DSEIR fails to establish the scope of the
burrowing owl population on the Project site, and fails to disclose the status and
demography of the local and regional burrowing owl populations that may be
affected by loss of this potential breeding and foraging habitat. The DSEIR also fails
to accurately disclose the amount of burrowing owl habitat on the Project site,
preventing a contextual assessment of impacts due to potential habitat loss.
CEQA requires a sufficient description of the Project setting to adequately
inform the public and decisionmakers of the potential impacts of the Project. An
accurate project setting is also necessary to permit meaningful assessment of the
sufficiency of proposed mitigation measures. Here, the DSEIR acknowledges that
the site provides potential burrowing owl habitat, but the surveys necessary to
establish the scope of burrowing owl use of the site were never conducted.35
Instead, the DSEIR’s discussion is based on reconnaissance-level surveys by FCS
and WRA.36
As Mr. Cashen’s comments explain, burrowing owls are difficult to detect due
to their cryptic coloration, extensive use of burrows, and tendency to flush (i.e., fly
32 Id.
33 Id.
34 DSEIR at p. 3.2-6.
35 S. Cashen Comments at p. 8.
36 Id.
AB
Page 8 of 96
6
CONT
7a
March 16, 2018
Page 9
4174-003acp
printed on recycled paper
away) when approached.37 Because of these characteristics, researchers and the
California Department of Fish and Wildlife (“CDFW”) have concluded that four
independent surveys are necessary to provide reliable information on the presence
of burrowing owls, and that data from the four surveys is essential to avoiding,
minimizing, and properly mitigating the impacts of a project.38
For the Project here, Mitigation Measure BIO-1c requires the Applicant to
retain a biologist to conduct two pre-construction surveys for burrowing owls prior
to the first ground disturbing activities.39 Although CDFW guidelines do
recommend “take avoidance” (i.e., pre-construction) surveys, the guidelines make it
clear that such surveys are no substitute for the four “detection surveys” that are
required to fully assess a project’s impacts and formulate appropriate mitigation.40
Because both FCS and WRA failed to implement the CDFW survey protocol during
their site visits, the City lacks the information needed to fully disclose and evaluate
the Project’s impacts to burrowing owls and to ensure effective mitigation.
The need to establish the baseline population of burrowing owls on a site
prior to assessing impacts and mitigation measures is emphasized in CDFW’s 2012
Staff Report on Burrowing Owl Mitigation:
Adequate information about burrowing owls present in and adjacent to
an area that will be disturbed by a project or activity will enable the
Department, reviewing agencies and the public to effectively assess
potential impacts and will guide the development of avoidance,
minimization, and mitigation measures.
In short, it is not possible to fully and effectively assess the extent of the
Project’s impacts on burrowing owls until surveys that adhere to CDFW guidelines
have been conducted.41 Accordingly, the City must require the Applicant to conduct
the protocol surveys described in CDFW’s 2012 Staff Report. The results of those
surveys need to be released in a revised DSEIR so that they can be thoroughly
37 Id.
38 Id.
39 DSEIR at pp. 3.2-19 – 3.2-20.
40 S. Cashen Comments at p. 8 (citing California Department of Fish and Game (2012) Staff Report
on Burrowing Owl Mitigation).
41 Id.
AB
Page 9 of 96
7a
CONT
March 16, 2018
Page 10
4174-003acp
printed on recycled paper
vetted by the public, resource agencies, and decisionmakers as a part of the CEQA
review process.
Furthermore, the DSEIR’s description of the environmental setting is
inadequate because it fails to disclose the extent of burrowing owl habitat on the
Project site, as well as the amount of habitat that would be eliminated by the
Project.42 Significantly, the DSEIR also fails to disclose the Project’s proximity to
the important Camp Parks burrowing owl population and its importance to the
continuing viability of burrowing owls in the region.43 This information is an
essential component for the DSEIR because it, along with the scope of the
population on the Project site, will enable the public and decisionmakers to evaluate
the relative significance of the Project’s impacts to the overall burrowing owl
population and to evaluate the sufficiency of the proposed mitigation.
As Mr. Cashen’s comments explain, burrowing owl populations have declined
dramatically in the San Francisco Bay Area since the Eastern Dublin Specific Plan
EIR was prepared.44 The species has been extirpated, or nearly extirpated, from six
Bay Area counties (Napa, Marin, San Francisco, Santa Cruz, Sonoma, and San
Mateo).45 Although burrowing owls were once abundant throughout Alameda and
Contra Costa counties, they are now primarily limited to the eastern portions of
those counties.46 Indeed, only two “large” breeding colonies of burrowing owls
remain in Alameda County: one in the Altamont Hills, and the second in the Camp
Parks area.47 The Project site is located at the periphery of the Camp Parks
burrowing owl population, which is the last remaining large population of
burrowing owls in the Livermore-Amador Valley.48 Because the Project would
contribute to the further decline of burrowing owl habitat in the Camp Parks area –
one of the few remaining core population areas in the region – the Project may have
a significant effect on the overall persistence of burrowing owls in the region.49
42 See Id. at p. 9.
43 Id. at pp. 7, 9.
44 Id. at p. 7.
45 Id.
46 Id.
47 Id.
48 Id.
49 Id. at pp. 7-8.
AB
Page 10 of 96
7a
CONT
7b
March 16, 2018
Page 11
4174-003acp
printed on recycled paper
The City is required to disclose sufficient information to enable a complete
assessment of whether additional mitigation is necessary due to the severity of
impacts to a core population area. The DSEIR must be revised to establish and
disclose the proximity and importance of the Camp Parks burrowing owl population
so that the Project’s potential impacts to this core population area may be evaluated
and appropriate mitigation identified.
4. The DSEIR Fails to Provide Information Regarding
Special Status Plant Species That is Necessary to Assess
Potential Impacts and the Effectiveness of Mitigation
While the DSEIR acknowledges that Congdon’s Tarplant is known to occur on
approximately 6.81 acres of the Project site,50 the document fails to disclose that
other special status plant species may also occur. Because no protocol-level surveys
were performed sufficient to determine whether other potentially-present special
status plant species actually occur on the Project site, there is no basis to conclude
that these other special status plants are not present.51 The failure to disclose the
potential presence of these other species and the failure to perform surveys
adequate to confirm the presence or non-presence of these species is a violation of
CEQA. The DSEIR failures to inform the public and decisionmakers which plants
may be impacted by the Project, the scope and significance of the plant population
that may be impacted, and whether effective mitigation may be designed or
alternatives should be considered. The DSEIR must be revised to adequately
identify what special-status plant species may occur on the site, incorporate the
results of protocol-level surveys for these plants, and identify appropriate
mitigation requirements.
In Mr. Cashen’s comments, he explains that at least two other special-status
plant species are known occur at the Project site and neither are addressed in the
DSEIR: (1) western dodder (Cuscuta occidentalis) and (2) Douglas' fiddleneck
(Amsinckia douglasiana).52 These two plants are listed as plants observed at the
Project site at the time of the WRA wetland delineation.53 Both of these species are
locally rare (i.e., rank “A1” and “*A1x ” by the East Bay Chapter of the California
50 DSEIR at p. 2-1.
51 S. Cashen Comments at p. 3.
52 Id. at pp. 3-4.
53 DSEIR, Appendix C.1, Appendix A (BRA List of Observed Plant and Wildlife Species).
AB
Page 11 of 96
7b
CONT
8a
March 16, 2018
Page 12
4174-003acp
printed on recycled paper
Native Plant Society).54 Locally rare plant species with an “A” designation are
considered special-status species under Sections 15380 and 15125(c) of the CEQA
Guidelines. The presence of Douglas' fiddleneck at the Project site is especially
significant because—until now—it was believed to be extirpated from Alameda and
Contra Costa counties.55
Furthermore, the BRA dismissed the potential for saline clover (Trifolium
hydrophilum) and hairless popcorn flower (Plagiobothrys glaber) to occur at the
Project site, though its conclusions are unsupported.56 According to the BRA, saline
clover is unlikely to occur at the site because “[t]he existing grassland and
seasonally wet depression habitat in the Project Area is heavily disturbed and of
low quality.”57 Additionally, the BRA states that hairless popcorn flower is unlikely
to occur at the Project site because “[t]his species is presumed extinct and has not
been found since 1954.”58
Contrary to the statements in the BRA, however, Mr. Cashen explains that
Saline clover has been detected in disturbed areas and “low quality” habitats.59
Saline clover is also known to occur in the Tassajara Area.60 Additionally, the
BRA’s statement that hairless popcorn flower has not been found since 1954 is
simply incorrect, as the species was rediscovered near Tassajara Road in Dublin
during surveys conducted in 2002 and 2006.61 Accordingly, the DSEIR’s assumption
that these plant species have no potential to be present on the Project site is not
supported by substantial evidence.
Data from focused surveys is necessary to fully disclose the existing
conditions at the Project site, analyze the Project’s impacts, formulate appropriate
mitigation, and develop possible alternatives. Deferring the surveys until after
completion of the CEQA review process fails to fully disclose potential Project
impacts on special status plants and precludes the public, resource agencies, and
54 S. Cashen Comments at p. 3.
55 Id. at p. 4.
56 DSEIR, Appendix C.1, Appendix B at pp. B-15, B-16 (Potential for Special-Status Species to Occur
in the Project Area); see also S. Cashen Comments at p. 4.
57 Id. at p. B-15.
58 Id. at p. B-16.
59 S. Cashen Comments at p. 4.
60 Id. at p. 5.
61 Id. at pp. 4-5.
AB
Page 12 of 96
8a
8b
March 16, 2018
Page 13
4174-003acp
printed on recycled paper
scientific community from meaningful comment on these potential impacts, and
precludes meaningful review of the Project’s impacts by decisionmakers exercising
their discretion in approving entitlements and permits.
5. The DSEIR Fails to Establish Baseline Conditions for
Special Status Bats at the Project Site
The DSEIR identified three special-status bat species (pallid bat, Townsend’s
big-eared bat, and Yuma myotis) that have a moderate potential of roosting in the
existing building at the Project site.62 As with the other special-status species, the
Applicant did not conduct the necessary surveys to determine whether any bat
species were in fact using the building as a roost site.63 The failure to establish
baseline conditions precludes the public, resource agencies, and scientific
community from being able to review and submit informed comments pertaining to
the Project’s impacts and the sufficiency of proposed mitigation.
B. The DSEIR Fails to Disclose, Evaluate, and Mitigate All
Potentially Significant Impacts to Biological Resources
1. The DSEIR Fails to Evaluate and Mitigate Potential
Impacts to Special Status Branchiopods
As discussed in subsection (a)(1) above, the DSEIR fails to disclose that
special status branchiopods including vernal pool fairy shrimp and California
linderiella may be present in the seasonal wetlands at the Project site.64 As a
result, the DSEIR also fails to evaluate the potential impacts that the Project may
have on these special-status species and fails to identify any measures to mitigate
potentially significant impacts. Because substantial evidence shows that potential
habitat for vernal pool fairy shrimp and California linderiella exists on the Project
site, the DSEIR must be revised to disclose this information and evaluate potential
impacts to these special status species.65
62 DSEIR at pp. 3.2-6, 3.2-11.
63 S. Cashen Comments at p. 8.
64 Id. at p. 9.
65 Id.
AB
Page 13 of 96
8b
CONT
9
10
March 16, 2018
Page 14
4174-003acp
printed on recycled paper
2. The DSEIR Fails to Evaluate and Mitigate All Potential
Impacts to Burrowing Owls
As discussed above, the DSEIR fails to adequately disclose the scope of
burrowing owls and their habitat on the Project site. The DSEIR also fails to
disclose the Project’s proximity to the critical Camp Parks burrowing owl
population. As a result of these critical omissions, the DSEIR has failed to
meaningfully evaluate and disclose the scope of potential impacts to burrowing owls
from Project construction. Without such evaluation, it is impossible to fully assess
the adequacy of the proposed mitigation measures. Furthermore, as Mr. Cashen’s
comments demonstrate, the mitigation measures that are proposed are inadequate
and do not support a finding that they would reduce Project impacts below a level of
significance.66
i. The DSEIR Fails to Evaluate Impacts from Eviction
The DSEIR fails to evaluate the potential impacts to burrowing owls from the
proposed eviction of burrowing owls from their burrows. Additionally, the DSEIR
fails to identify mitigation measures to reduce the potential impacts of eviction to a
less than significant level.
Under CDFW guidelines, passive relocation or eviction is a potentially
significant impact under CEQA that must be analyzed.67 The temporary or
permanent closure of burrows may result in a variety of impacts to the species,
including: (1) significant loss of burrows and habitat for reproduction and other life
history requirements; (2) increased stress and reduced reproductive rates; (3)
increased depredation; (4) increased energetic costs; and (5) risks posed by having to
find and compete for available burrows.68
Moreover, because the DSEIR fails to provide a burrowing owl exclusion plan,
or fundamental details contained in such plans (e.g., location of replacement
burrows and compensation habitat, whether exclusion permitted during breeding
season), it is not possible for the public, resource agencies, and decisionmakers to
66 Id. at pp. 9-10.
67 Id. at p. 10.
68 Id.
AB
Page 14 of 96
11
12
March 16, 2018
Page 15
4174-003acp
printed on recycled paper
evaluate the potential impacts to owls evicted from the Project site and the
adequacy of the mitigation.69
The DSEIR must be revised to provide sufficient detail on proposed eviction
activities to enable meaningful evaluation of impacts from these activities.
ii. Protective Buffer Requirements Are Vague and
Unenforceable
In order for mitigation measures to be effective, they must be specific,
enforceable, and feasible actions that will improve environmental conditions. In this
case, the DSEIR’s direction to avoid disturbing or otherwise impacting occupied
burrows to mitigate impacts to burrowing owls is vague and unenforceable.70 As
result, the requirement does not provide substantial evidence that impacts will be
mitigated below a level of significance. The DSEIR does not establish the minimum
buffers that need to be implemented around burrows. Nor does the DSEIR establish
monitoring that should be implemented to ensure burrowing owls are not disturbed
by construction activities.
The DSEIR’s direction to avoid burrowing owls should be revised to reflect
CDFW guidelines, which indicate buffers may need to be up to 500 meters,
depending on the time of year and level of disturbance.71 In the absence of greater
specificity, it is purely speculative to assume that the proposed mitigation will
reduce impacts below a level of significance.
iii. The DSEIR Improperly Defers Mitigation
The DSEIR violates CEQA by deferring specification of critical elements of
the mitigation measures needed to reduce the Project’s potentially significant
impacts to burrowing owls below a level of significance. Specifically, the DSEIR
defers identifying: (1) a compensatory mitigation ratio; (2) the acceptable mitigation
location and mechanism (e.g., habitat acquisition, purchase of credits at a
mitigation bank, in-lieu fee, etc.);(3) site protection methods;(4) financial
69 Id.
70 DSEIR at p. 3.2-20.
71 S. Cashen Comments at p. 17.
AB
Page 15 of 96
12
CONT
13
14
March 16, 2018
Page 16
4174-003acp
printed on recycled paper
assurances;(5) performance standards; and (6) monitoring requirements.72 Instead,
the DSEIR relies on the establishment of mitigation requirements in a future
Burrowing Owl Mitigation Plan, which is to be reviewed and accepted by CDFW
and the City prior to the first ground-disturbing activities.73
Deferring formulation of mitigation measures to post-approval studies is
generally impermissible.74 Mitigation measures adopted after Project approval deny
the public the opportunity to comment on the Project as modified to mitigate
impacts.75 Deferral of the specifics of mitigation is permissible only where the lead
agency “commits itself to mitigation” and “lists the alternatives to be considered,
analyzed and possibly incorporated in the mitigation plan.”76 If identification of
specific mitigation measures is impractical until a later stage in the project, specific
performance criteria must be articulated and further approvals must be made
contingent upon meeting these performance criteria.77 The courts have held that
simply requiring a project applicant to obtain a future report and then comply with
any recommendations that may be based upon the report is insufficient to meet the
standard for properly deferred mitigation.78
Here, the DSEIR’s proposed approach deprives the public of an opportunity to
review and submit comments on fundamental aspects of the Project’s mitigation
strategy prior to Project approval. Furthermore, neither the CDFW nor the City has
an oversight approach to ensure compensatory mitigation is occurring.79
As Mr. Cashen’s comments explain, a 1:1 ratio is not likely to be sufficient to
mitigate impacts below a level of significance in this case.80 This is due to the rapid
decline of the Camp Parks population and the limited availability of compensation
habitat to support that population.81 A project and region specific ratio is required
72 Id.
73 DSEIR at p. 3.2-20.
74 Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 308-309; Pub. Resources Code §
21061.
75 Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1393; Quail Botanical Gardens Foundation
v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1604, n. 5
76 Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, 793.
77 Id.
78 Id.
79 S. Cashen Comments at p. 17.
80 Id. at pp. 17-18.
81 Id.
AB
Page 16 of 96
14
CONT
March 16, 2018
Page 17
4174-003acp
printed on recycled paper
in this case to support a finding that the mitigation ratio will reduce impacts below
a significant level.
In this case, a regional specific mitigation ratio for loss of burrowing owl
habitat has already been established, yet was never disclosed or applied in the
DSEIR. The Eastern Alameda County Conservation Strategy (“EACCS”) establishes
the standard for mitigation needed to conserve species and habitat in Eastern
Alameda County. The EACCS requires compensatory mitigation for impacts to
burrowing owl habitat to be within one-half mile of a burrowing owl nest used
within the previous three years.82 Additionally, the EACCS establishes a
standardized mitigation ratio of 3:1 (3.5:1 if the mitigation site is in a different core
area).83 Anything lower cannot be assumed to reduce regional impacts to a less than
significant level.84
The EIR should be revised to include a provision that compensatory
mitigation shall be required for Project impacts to burrowing owls and their habitat
at a minimum of the EACCS compensatory mitigation ratio standard for burrowing
owls of 3:1 (3.5:1 if the mitigation site is in a different core area). By failing to
identify the applicability of the EACCS mitigation requirements and failing to
establish a performance standard based on regional mitigation needs, the DSEIR’s
deferral of the specific mitigation ratio requirement violates CEQA and is not
support by substantial evidence.
3. The DSEIR Fails to Adequately Evaluate and Mitigate
Potential Impacts to Special Status Plants
The DSEIR requires the Applicant to conduct a focused survey to determine
the presence of Congdon’s tarplant prior to construction.85 If no special-status plant
species are found during this pre-construction survey, then no additional mitigation
measures for special status plants will be implemented. If Congdon’s tarplant is
detected during the survey, additional mitigation requirements are triggered.
82 Id. at p. 18.
83 Id.
84 Id.
85 DSEIR at p. 3.2-18.
AB
Page 17 of 96
14
15
March 16, 2018
Page 18
4174-003acp
printed on recycled paper
The DSEIR’s proposed mitigation strategy is not sufficient to ensure impacts
to special status plants species will be less than significant.86 First, the DSEIR does
not require focused surveys or specify mitigation for any other special-status plant
species that occur, or could occur, at the Project site. As a result, potentially
significant impacts to all special-status plants besides Congdon’s tarplant remain
unmitigated.87
Second, Congdon’s tarplant is already known to occur at the Project site, thus
compensatory mitigation should not be contingent on future surveys. This is
especially true for annual plants such as Congdon’s tarplant because the presence
and abundance of annual plants can fluctuate dramatically from year to year due to
climatic conditions.88 The absence of Congdon’s tarplant from the Project site during
a preconstruction survey may be the result of adverse survey conditions rather than
actual absence of the species, which may in turn cause potentially significant
impacts to go unmitigated.
Third, the DSEIR indicates that compensatory mitigation would not be
required if activity exclusion zones can be installed around habitat occupied by
Congdon’s tarplant during construction of the Project.89 However, based on the site
plan, Mr. Cashen states that all existing plants will be directly or indirectly affected
by the Project.90 Therefore, even if activity exclusion zones are feasible, the plant
populations have no chance for long-term persistence at the site once the Project is
operational.
The DSEIR must be revised to address these deficiencies in the proposed
mitigation strategy and ensure all potentially significant impacts are mitigated to
the extent feasible.
i. The DSEIR Defers Mitigation for Congdon’s Tarplant Impacts
The DSEIR requires that the Applicant prepare a mitigation plan if impacts
to Congdon’s tarplant cannot be avoided. The DSEIR states:
86 See S. Cashen Comments at p. 14.
87 Id.
88 Id.
89 DSEIR at pp. 3.2-18 – 3.2-19.
90 S. Cashen Comments at p. 14.
AB
Page 18 of 96
15
CONT
16
March 16, 2018
Page 19
4174-003acp
printed on recycled paper
A mitigation plan may include but is not limited to the following: the
acquisition of off-site mitigation areas presently supporting the Congdon’s
tarplant, purchase of credits in a mitigation bank that is approved to sell
credits for the Congdon’s tarplant, or payment of in-lieu fees to a public
agency or conservation organization (e.g., a local land trust) for the
preservation and management of existing populations of Congdon’s
tarplant.91
As proposed, the DSEIR improperly defers formulation of the mitigation plan
without establishing fundamental aspects needed to ensure effectiveness and
enforceability. Such fundamental aspects include: (1) the performance standards (or
success criteria) for the proposed mitigation, (2) a definitive enforcement
mechanism that ensures performance standards are met; (3) the contingency or
remedial action measures that would be triggered if success standards are not
achieved; (4) the measures that would be implemented to ensure the long-term
protection and management of sensitive biological resources at mitigation sites; and
(5) the required monitoring program, including the monitoring techniques, effort,
and frequency.92 Because the DSEIR lacks these fundamental details, the City has
failed to ensure that Project impacts to sensitive botanical resources would be
reduced to a less than significant level.93
Furthermore, the DSEIR’s deferral of the mitigation plan is exacerbated by
its failure to provide evidence that the proposed mitigation is feasible. As Mr.
Cashen’s comments note, there do not appear to be any mitigation banks that sell
credits for impacts to Congdon’s tarplant.94 Additionally, there do not appear to be
any in-lieu fee programs that cover impacts to Congdon’s tarplant, and the DSEIR
fails to provide evidence that sites suitable for acquisition exist.95
The City must produce a revised DSEIR to establish that the proposed
mitigation is feasible. Specifically, the DSEIR should identify: (1) the potential
mitigation sites, and status of Congdon’s tarplant at those sites; (2) the actual
mitigation ratio proposed; (3) performance standards for the mitigation sites; (4) the
required monitoring program; and, (5) measures that will be implemented to ensure
91 DSEIR at p. 3.2-19.
92 S. Cashen Comments at pp. 14-15.
93 Id.
94 Id. at p. 15.
95 Id.
AB
Page 19 of 96
16
March 16, 2018
Page 20
4174-003acp
printed on recycled paper
the long-term protection and management of Congdon’s tarplant populations at the
mitigation site(s).96 Without such details, the DSEIR lacks substantial evidence to
support a finding that the proposed mitigation will reduce impacts below a level of
significance.
ii. The Proposed Compensatory Mitigation is Vague and
Inconsistent with the EACCS
According to the DSEIR, the Congdon’s tarplant mitigation plan should
incorporate a compensatory mitigation ratio of at least 1:1.97 However, the Eastern
Alameda County Conservation Strategy (“EACCS”) establishes the standard for
mitigation needed to conserve species and habitat in Eastern Alameda County, and
the proposed mitigation ratio does not adhere to EACCS standards.98 The EACCS
establishes a standardized mitigation ratio of 5:1 for impacts to focal plant species
(e.g., Congdon’s tarplant).99
Notably, the 1:1 ratio proposed in the DSEIR is not even consistent with
other projects in the City of Dublin. For example, the City is requiring a 5:1 ratio for
impacts to Congdon’s tarplant at the nearby Zeiss Innovation Center Project site.100
The DSEIR offers no explanation as to why a 5:1 ratio was needed to mitigate
impacts at the Zeiss project site but the Project site here only requires a 1:1 ratio.
Because the DSEIR fails to include a sufficiently detailed mitigation strategy,
and because the measures listed in the DSEIR do not comply with the EACCS, the
City has failed to provide substantial evidence that the Project’s impact to
Congdon’s tarplant and other special-status plant species would be reduced to a less
than significant level.
4. The DSEIR Fails to Adequately Evaluate and Mitigation
Potential Impacts to Special Status Bats
The DSEIR’s proposed mitigation measures fail to ensure that the Project’s
impacts to special status bats are mitigated to a less than significant level. The
96 Id.
97 DSEIR at p. 3.2-19.
98 S. Cashen Comments at p. 15.
99 Id.
100 Id.
AB
Page 20 of 96
16
CONT
17
18
March 16, 2018
Page 21
4174-003acp
printed on recycled paper
DSEIR proposes the following mitigation for potentially significant impacts to
special-status bat species:
Pre-removal bat surveys of the existing on-site building shall occur no more
than 30 days before its removal. If bats are found, then a qualified biologist
shall develop an appropriate relocation plan consistent with USFWS, CDFW,
and East Alameda County Conservation Strategy standards and policies.101
However, the DSEIR fails to identify the survey techniques that should be
implemented for the pre-removal surveys, and it is unclear that the listed standards
and policies even exist.102
As Mr. Cashen explains, establishing the required survey techniques for
special status bat species is a necessary prerequisite to ensuring that potential
impacts to bat species are identified and mitigated.103 First, bat detection often
requires specialized techniques, and a technique that is effective for one species
may be completely ineffective for other species.104 Second, pallid bats and
Townsend’s big-eared bats are extremely sensitive to human disturbance, and
human disturbance may cause the colony to abandon the roost (which contributes to
population declines).105 Third, the establishment of minimum qualifications for the
biologist conducting the pre-removal surveys fails is necessary to ensure the surveys
will be effective and avoid additional impacts to the species.106 Because the DSEIR
fails to establish critical performance standards for ensuring future surveys will be
effective, the DSEIR’s conclusion that such surveys will reduce impacts below a
level of significance is not supported by substantial evidence.
Suitable roost sites are the limiting factor for most bat populations.107 The
DSEIR does not require the Applicant to provide replacement roosts as
compensation for impacts to potential roosts at the Project site. Therefore, even if
the bats are properly excluded from the existing on-site building, they may not have
a suitable alternate roost in the vicinity, and the local population may be
101 DSEIR at p. 3.2-20 – 3.2-21.
102 See S. Cashen Comments at p. 19.
103 Id. at pp. 18-19.
104 Id. at p. 18.
105 Id.
106 Id.
107 Id. at p. 19.
AB
Page 21 of 96
18
CONT
March 16, 2018
Page 22
4174-003acp
printed on recycled paper
extinguished.108 This constitutes a potentially significant impact that remains
unmitigated. Without ensuring that suitable replacement roosts will be available,
the DSEIR lacks substantial evidence to support its finding that the proposed
mitigation strategy will reduce impacts below a level of significance.
5. The DSEIR Fails to Adequately Evaluate Cumulative
Impacts of the Project
The DSEIR’s analysis of cumulative impacts to biological resources fails to
satisfy the requirements of CEQA for several reasons.
First, the DSEIR fails to define the geographic scope of the City’s cumulative
impacts analysis beyond that it includes “the region surrounding the project site.”
This description is too vague to understand the geographic scope of the analysis and
prevents the public from assessing the conclusions presented in the DSEIR.
Second, the list of cumulative projects provided in the DSEIR omits the Zeiss
Innovation Center Project, which is located approximately 700 feet north of the
Project site. The Zeiss Innovation Center Project would impact many of the same
biological resources as the proposed Project, including Congdon’s tarplant, seasonal
wetlands, burrowing owl (and other raptor) habitat, and potential habitat for the
vernal pool fairy shrimp and California linderiella.
Third, the DSEIR concludes the Project’s contribution to any significant
cumulative impact on special-status plant species would be less than cumulatively
considerable because Congdon’s tarplant would be relocated if it is found on the
Project site during preconstruction surveys. However, there is no basis for this
conclusion because the DSEIR does not require (or propose) relocation of Congdon’s
tarplant as mitigation. Further, the DSEIR’s conclusion is not justified because the
DSEIR fails to incorporate mitigation for the numerous other special-status plant
species that occur, or could occur, at the Project site.
Fourth, the DSEIR acknowledges the Project would (or could) impact
wetlands, special-status plants (Congdon’s tarplant), and special-status animals
(nesting birds, burrowing owl, bats). However, the DSEIR fails to provide any actual
108 Id.
AB
Page 22 of 96
18
CONT
19
March 16, 2018
Page 23
4174-003acp
printed on recycled paper
analysis of cumulative impacts to these resources, including whether cumulative
impacts to these specific resources would be significant. As Mr. Cashen points out:
1. None of the biological resource mitigation measures are designed to
alleviate the cumulative impact; all three mitigation measures are specific to
the Project site and to Project activities and do not address the cumulative
impact posed by other projects.
2. Habitat loss, including the incremental loss of habitat from numerous
small projects, is the greatest threat to most special-status species. The
DSEIR does not require habitat compensation for all of the special-status
species that would (or could) be affected by the Project. As a result, the
Project’s contribution to the cumulatively significant loss of habitat would not
be mitigated.109
Mr. Cashen concludes that the Project’s incremental contribution to
cumulative impacts to the burrowing owl and Congdon’s tarplant would be
cumulatively considerable.110 Furthermore, the Project may have cumulatively
considerable impacts to other species as well (e.g., vernal pool fairy shrimp, special-
status bats), but DSEIR’s omission of baseline data pertaining to the presence of
such species on the Project site prevents such a determination.111
C. The DSEIR Fails to Adequately Mitigate Potential Impacts to
Wetlands and Improperly Defers Mitigation
The DSEIR includes two measures to mitigate potential impacts to wetlands.
First, Mitigation Measure BIO-3a requires the Applicant to complete an updated
wetland delineation to determine if the wetlands at the Project are subject to
jurisdiction under Section 404 of the Clean Water Act.
Second, Mitigation Measure BIO-3b requires the Applicant to acquire
appropriate permits under Section 404 of the Clean Water Act from the USACE if
the wetlands are determined to be subject to USACE jurisdiction, and to obtain
Section 401 certification from the Regional Water Quality Control Board
109 Id. at p. 13.
110 Id. at pp. 13-14.
111 Id.
AB
Page 23 of 96
19
CONT
20
March 16, 2018
Page 24
4174-003acp
printed on recycled paper
(“RWQCB”). BIO-3b further requires the Applicant to prepare a wetland mitigation
plan to be approved by the USACE and RWQCB. Specifically:
A mitigation plan shall be prepared that will establish suitable compensatory
mitigation based on the concept of no net loss of wetland habitat values or
acreages, to the satisfaction of the regulatory agencies. Specifically, a wetland
mitigation plan shall be developed and implemented that includes creation,
restoration, and/or enhancement of off-site wetlands prior to project ground
disturbance. Mitigation areas shall be established in perpetuity through
dedication of a conservation easement (or similar mechanism) to an approved
environmental organization and payment of an endowment for the long-term
management of the site.83
On the basis of these two mitigation measures, the DSEIR concludes the Project’s
impacts to wetlands would be reduced to a less-than-significant level.
The DSEIR’s conclusion that impacts would be mitigated to below a level of
significance is not supported by substantial evidence for two reasons:
First, the DSEIR impermissibly defers analysis and critical aspects of the
wetlands mitigation strategy. Under CEQA, the City is obligated to identify the
specific mitigation needed to mitigate Project impacts to less-than-significant levels.
This includes the specific mitigation strategy, mitigation ratio, monitoring program,
and performance standards and that will be implemented to ensure the Project
would have less-than-significant impacts on the environment. Contrary to what the
DSEIR suggests, the City cannot rely on deferred mitigation and the permitting
requirements of other agencies to conclude impacts to wetlands would be mitigated
to less-than-significant levels.
Second, compliance with regulatory permits provides no assurances that
Project impacts to jurisdictional wetlands would be less-than-significant.112 To the
contrary, numerous studies have demonstrated that many compensatory mitigation
projects permitted under Sections 401 and 404 of the Clean Water Act are not
achieving the goal of “no overall net loss” of wetland acres and functions.113
112 Id. at pp. 20-21.
113 Id.
AB
Page 24 of 96
20
CONT
March 16, 2018
Page 25
4174-003acp
printed on recycled paper
IV. THE DSEIR’S CONCLUSION THAT AIR QUALITY IMPACTS
WOULD BE LESS THAN SIGNIFICANT IS NOT SUPPORTED BY
SUBSTANTIAL EVIDENCE
The DSEIR explains that Project emissions were quantified using the
California Emissions Estimator Model Version CalEEMod.2016.3.2
(“CalEEMod”).114 When modeling a project’s emissions, CalEEMod provides the user
with recommended default values based on information such as land use type,
meteorological data, project type, and typical equipment associated with the project
type.115 The user may replace default values when more site-specific information is
available. However, CEQA requires that any changes to CalEEMod defaults must
be supported by substantial evidence.116
CalEEMod generates “output files” for each model that reveal to the viewer
the parameters used when creating a given model. We retained SWAPE to review
the CalEEMod output files generated for the Project. In reviewing the CalEEMod
output files, SWAPE found several of the input parameters used to be inconsistent
with information disclosed in the DSEIR.117 As further explained in the attached
SWAPE letter, these changes resulted in an underestimation of the Project’s
construction and operational emissions.118
Because the DSEIR fails to accurately disclose and analyze the Project’s air
quality impacts, the DSEIR’s conclusions that air quality impacts from Nitrogen
Oxides (“NOx”) emissions during Project construction and operations will be less
than significant are not supported by substantial evidence. A revised DSEIR must
be prepared to include an air quality analysis that accurately discloses and
evaluates the air quality impacts of the Project.
114 DSEIR at p. 3.1-1.
115 SWAPE Comments at p. 2
116 See CalEEMod 2012.2.2 User’s Guide, p. 9 (July 2013), available at
http://www.aqmd.gov/docs/default-source/caleemod/usersguideSept2016.pdf?sfvrsn=6; SWAPE
Comments at p. 2.
117 SWAPE Comments at p. 2.
118 Id.
AB
Page 25 of 96
21
March 16, 2018
Page 26
4174-003acp
printed on recycled paper
A. The DSEIR Emission Estimates Fail to Account for Materials
Export Hauling Trips
In reviewing the CalEEMod output files, SWAPE first found that the
DSEIR’s emissions estimates do not account for emissions from materials hauling
trips that the DSEIR states will occur during the grading phase.119 According to the
DSEIR, the proposed project’s grading activities would involve 95,000 cubic yards of
cut and 73,700 cubic yards of fill. Thus, 21,300 cubic yards would be exported off-
site.” However, SWAPE’s review of the CalEEMod output files found that the
Project’s construction-related emissions assume zero hauling truck trips will occur
during the grading phase.120
In CalEEMod modeling, hauling truck trips are estimated based on the total
amount of material that will be imported or exported and assuming that a single
hauling truck can transport 16 cubic yards of material per trip.121 CalEEMod
calculates the number of hauling truck trips assuming that each hauling truck will
have 2 one-way trips (e.g., a hauling truck importing material will have a loaded
arrival trip and an empty return trip, while a hauling truck exporting material will
have an empty arrival trip but a loaded departure trip).122 Accordingly, the DSEIR
should have modeled the Project’s emissions assuming that there would be a total of
2,662 (2 x 1,331 hauling trips) trips in order to account for the 2 one-way truck
trips.123 As noted above, SWAPE’s review of the output files found that zero hauling
truck trips are accounted for in the DSEIR’s CalEEMod model, and no explanation
is provided as to why hauling trips would not occur for the off-site soil exports.124
Because the Project’s CalEEMod model assumes no hauling truck trips would
occur during the grading phase of construction, SWAPE explains that that the
DSEIR’s CalEEMod model underestimates the actual emissions that will be
generated during construction activities.125 NOx and fugitive dust emissions are
generated as a result of haul truck trips.126 In this case, the DSEIR’s air quality
119 Id. at pp. 2-3.
120 Id. at p. 2.
121 Id. at p. 3.
122 Id.
123 Id.
124 Id. at p. 2.
125 Id. at pp. 3-4.
126 Id. at p. 3.
AB
Page 26 of 96
22
March 16, 2018
Page 27
4174-003acp
printed on recycled paper
analysis shows that the Project’s construction NOx emissions are just below the
BAAQMD threshold of significance (52.44 lbs/day compared to 54 lbs/day) after
mitigation.127 SWAPE concludes that the inclusion of the omitted haul truck trips
would very likely result in Project construction emissions exceeding the BAAQMD
threshold of significance for NOx based on the total number of truck trips
excluded.128
Because the DSEIR’s emission model fails to account for the haul truck trips
disclosed in the DSEIR, the Project’s construction emissions are underestimated
and the City’s conclusion that impacts will be mitigated to below a level of
significance is not supported by substantial evidence. Moreover, substantial
evidence supports a finding that the Project’s construction emissions will exceed the
BAAQMD threshold of significance. A revised DSEIR should be prepared to
accurately disclose, evaluate, and mitigate the Project’s construction emission
impacts.
B. The DSEIR Emission Estimates Fail to Account for All Daily
Vehicle Trips
In reviewing the CalEEMod output files, SWAPE found that the DSEIR’s
emissions calculations underestimate the number of daily vehicle trips during
Project operations.129 As a result of this miscalculation, the Project’s operational
emissions are underestimated and not supported by substantial evidence, and
therefore cannot be relied on to determine the significance of the Project’s air
quality impacts.130
According to DSEIR Appendix B, the Project would generate a total of 16, 898
vehicle trips per day.131 However, Appendix B Table 10 erroneously represents that
the total number of project vehicle trips would be 16,840 per day.132 The latter
figure was used in the CalEEMod model to estimate emissions from Project
operations.133 As a result of this miscalculation, SWAPE found that the emissions
127 DSEIR at pp. 3.1-44 – 3.1-45.
128 SWAPE Comments at p. 4.
129 Id. at pp. 6-7.
130 SWAPE Comments at p. 8.
131 DSEIR, Appendix B, p. 29, Table 10; see also SWAPE Comments at pp. 6-7.
132 Id.
133 SWAPE Comments at p. 7.
AB
Page 27 of 96
22
CONT
23
March 16, 2018
Page 28
4174-003acp
printed on recycled paper
model underestimates the number of daily trips by approximately 60 trips per day,
or 21,900 vehicle trips per year.134
As SWAPE explains by underestimating the total number of vehicle trips
expected to occur during Project operations, the DSEIR underestimates the Project’s
operational mobile-source emissions.135 Moreover, this underestimation is
important because the CalEEMod files demonstrate that the Project’s mitigated
emissions are close to the BAAQMD’s significance threshold for operational NOx
emissions.136 The DSEIR shows that the Project’s mitigated operational emissions
would result in a maximum daily emission of approximately 51.54 lbs/day of NOx,
or approximately 2.5 pounds below the BAAQMD’s NOx significance threshold of 54
lbs/day.137 However, because the DSEIR’s CalEEMod model underestimates the
number of operational daily vehicle trips by 60 trips per day or 21,900 trips per
year, SWAPE concludes it is possible that the Project’s NOx emissions would in fact
exceed this threshold.138
By failing to include total number of vehicle trips expected to occur during
Project operations, the DSEIR underestimates the Project’s operational mobile
source emissions.139 For this reason, the DSEIR’s emissions estimates are
inaccurate and not supported by substantial evidence. New modeling must be
performed to accurately disclose and evaluate the Project’s operational emissions,
and to evaluate compliance with the applicable thresholds of significance.
V. THE DSEIR’S DETERMINATION THAT GLOBAL WARMING
IMPACTS WOULD BE LESS THAN SIGNIFICANT IS NOT
SUPPORTED BY SUBSTANTIAL EVIDENCE
In an attempt to analyze the potential impacts of the Project’s operational
greenhouse gas (“GHG”) emissions, the DSEIR employs two thresholds of
significance – one for operational emissions in the year 2020, and another for
operational emissions after the year 2020.140 For the Project’s anticipated opening
134 Id.
135 Id.
136 Id.
137 DSEIR at p. 3.1-46.
138 SWAPE Comments at p. 8.
139 Id. at p. 6.
140 DSEIR, pp. 3.1-59 – 3.1-67.
AB
Page 28 of 96
23
CONT
24
March 16, 2018
Page 29
4174-003acp
printed on recycled paper
year, 2020, the DSEIR relies on an assessment of the Project’s consistency with the
City of Dublin’s 2013 Climate Action Plan Update (“CAP”). Under this threshold,
the DSEIR concludes that GHG emissions from operation of the project in the year
2020 will be less than significant because the Project complies with the applicable
CAP measures for meeting 2020 GHG reduction goals. It is estimated that the
Project will not commence operations until at least December 2020, however,
meaning that the DSEIR’s CAP analysis only supports a determination for one
month of operations and does not address operational emissions for the whole of the
Project’s expected lifespan.141
Because the CAP does not provide a plan for meeting GHG reduction goals
beyond 2020, the DSEIR uses a separate “business as usual” (“BAU”) GHG
threshold for Project emissions after 2020 that is based on the Senate Bill (“SB”) 32
2030 statewide GHG reduction goal. This secondary threshold, however, is identical
to the threshold of significance that was struck down by the California Supreme
Court struck down in Center for Biological Diversity v. California Department of
Fish and Wildlife (“Newhall”) and is not supported by substantial evidence.142
The DSEIR’s BAU threshold assumes that operational emissions after 2020
would not be significant if the Project’s 2030 emissions would be “40 percent below
1990 levels consistent with SB 32.”143 The DSEIR concludes that the Project’s 2030
operational GHG emissions would be more than 40 percent below 1990 business as
usual emissions and thus operational emissions after 2020 would have a less than
significant impact on global climate change.144 The DSEIR, however, offers no
evidence to support its conclusion that impacts would be less than significant solely
because the Project will reduce emissions from a business-as-usual scenario by a
percentage that exceeds the statewide emissions targets in SB 32. Because the
DSEIR’s use of the SB 32 2030 statewide GHG BAU reduction goal as a threshold of
significance for project-level impacts is not supported by substantial evidence, its
finding that the Project’s post 2020 operational emissions would be less than
significant also is not supported by substantial evidence.
141 See CEQA Guidelines §15378(a) (requiring evaluation of all impacts that make up the “whole” of
the project); see also Natural Resources Defense Council v. City of Los Angeles (“NRDC v. LA”) (2002)
103 Cal.App.4th 268. (CEQA requires examination of the environmental impacts of “the entire
project, from start to finish”).
142 Center for Biological Diversity v. California Department of Fish and Wildlife (2015) 62 Cal.4th 204.
143 DSEIR, p. 3.1-61.
144 DSEIR, p. 3.1-63.
AB
Page 29 of 96
24
CONT
March 16, 2018
Page 30
4174-003acp
printed on recycled paper
Rather than using inapplicable and disapproved thresholds of significance,
the DSEIR should have applied the GHG thresholds set by the Bay Area Air
Quality Management District (“BAAQMD”). As discussed below, the project’s
operational emissions greatly exceed the BAAQMD threshold of significance for
operational GHG emissions. Accordingly, the DSEIR must be revised to disclose this
impact and to impose all feasible mitigation.
A. The Determination that GHG Impacts Are Less Than
Significant Because the Project Will Comply with the City of
Dublin CAP Is Not Applicable to the Whole of the Project
In Impact Air-7, the DSEIR considers whether the Project is consistent with
the City of Dublin CAP to assess the significance of the Project’s GHG emissions for
its opening year, 2020.145 This plan consistency approach is based on CEQA
Guidelines sections 15064, 15130, and 15183.5, which together provide that public
agencies may analyze and mitigate significant GHG emissions in a qualified
reduction plan and later tier from that analysis when considering individual
projects. Lead agencies may determine that an individual project’s contribution to
global climate change is not cumulatively significant if the project complies with an
adopted GHG reduction plan under specified circumstances.146 Guidelines section
15183.5 subdivision (b)(1) sets forth the recommended steps for agencies preparing
such plans:
(A)Quantify greenhouse gas emissions, both existing and projected over a
specified time period, resulting from activities within a defined geographic
area;
(B)Establish a level, based on substantial evidence, below which the
contribution to greenhouse gas emissions from activities covered by the
plan would not be cumulatively considerable;
(C)Identify and analyze the greenhouse gas emissions resulting from specific
actions or categories of actions anticipated within the geographic area;
145 DSEIR, pp. 3.1-65-3.1-67.
146 Guidelines §15183.5(b)
AB
Page 30 of 96
24
CONT
25
March 16, 2018
Page 31
4174-003acp
printed on recycled paper
(D)Specify measures or a group of measures, including performance
standards, that substantial evidence demonstrates, if implemented on a
project-by-project basis, would collectively achieve the specified emissions
level;
(E)Establish a mechanism to monitor the plan's progress toward achieving
the level and to require amendment if the plan is not achieving specified
levels;
(F) Be adopted in a public process following environmental review.
BAAQMD’s CEQA Guidelines also endorse the use of a GHG reduction plan
consistency analysis where appropriate and “recommend[] the Plan Elements in the
state CEQA Guidelines as the minimum standards to meet the GHG Reduction
Strategy Thresholds of Significance option.”147 Finally, Guidelines section 15064
subdivision (h)(3) specifies that such GHG reduction plans “must be specified in law
or adopted by the public agency with jurisdiction over the affected resources
through a public review process . . . .”
As explained in the DSEIR, the City’s CAP satisfies the above requirements
and constitutes a qualified GHG reduction plan for purposes of CEQA for activities
through 2020.148 However, activities and GHG emissions after 2020 are not covered
by the City’s CAP. Guidelines section 15183.5 subdivision (b)(1)(B) provides that
consistency with GHG reduction plans may only be used as a threshold for
“activities covered by the plan.” Because the plan does not establish GHG reduction
goals for emissions after 2020, it does not cover activities or emissions after 2020
and is not applicable to the Project’s post-2020 operational emissions.
The current CAP includes a total of 45 measures that the City determined
would achieve its 2020 target of “15% below 2010 emissions levels by 2020.”149 The
CAP explains that implementation of the plan’s measures and the reduction target
will reduce the impact from covered activities to a less than significant level.150
147 BAAQMD CEQA Guidelines (May 2017) p. 4-8.
148 DSEIR at p. 3.1-65.
149 City of Dublin Climate Action Plan Update (July 2013), p. 24 (“CAP”).
150 CAP at p. 6.
AB
Page 31 of 96
25
CONT
March 16, 2018
Page 32
4174-003acp
printed on recycled paper
However, because the current CAP was prepared to achieve the City’s 2020
reduction target only, it does not address activities, emission levels or reductions
required beyond that year. More importantly, the CAP does not provide any
evidence that compliance with the plan’s measures will reduce the impact from
covered activities to a less than significant level beyond 2020. For that reason, the
DSEIR correctly finds that the current CAP “does not contain adequate reduction
measures to reduce California’s GHG emissions to the AB197 and SB32 targets of
40 percent below 1990 levels by 2030.”151
Reliance on a CAP consistency threshold for post-2020 emissions would also
be flawed because the CAP no longer reflects prevailing scientific knowledge on
climate change. CEQA requires a lead agency to evaluate effects based to the extent
possible on scientific and factual data.152
As stated above, the DSEIR acknowledges that the current CAP does not
include sufficient measures to ensure reductions consistent with SB 32.153 The
targets of SB 32 were adopted in accordance with current scientific understanding
of human contributions to climate change. , “They represent benchmarks, consistent
with prevailing climate science, charting an appropriate trajectory forward that is
in line with California’s role in stabilizing global warming below dangerous
thresholds.”154 The “2030 target reflects the same science that informs the
agreement reached in Paris by the 2015 Conference of Parties to the United Nations
Framework Convention on Climate Change (UNFCCC), aimed at keeping the global
temperature increase below 2 degrees Celsius (°C).”155 These targets are set to
avoid California’s activities “contributing to an escalation of serious problems,
including raging wildfires, coastal erosion, disruption of water supply, threats to
agriculture, spread of insect-borne diseases, and continuing health threats from air
pollution” that rising temperatures create. 156
151 DSEIR at p. 3.1-60.
152 See 14 C.C.R. § 15064.4; see also Cleveland National Forest Foundation v. San Diego Assoc. of
Govts. (2017) 3 Cal. 5th 497, 518-519.
153 DSEIR, p. 3.1-60.
154 California’s 2017 Climate Change Scoping Plan, California Air Resources Board (Nov. 2017) p.
ES3.
155 Id. at 2.
156 Id. at p. ES2.
AB
Page 32 of 96
25
CONT
March 16, 2018
Page 33
4174-003acp
printed on recycled paper
Because the CAP is based on meeting pre-AB 32 2020 GHG reduction targets,
the CAP fails to incorporate sufficient measures to ensure covered projects do not
contribute to the significant effects the targets of SB 32 were adopted to prevent.157
For the above reasons, consistency with the CAP was not relied upon (and
could not be relied upon) by the DSEIR to support a finding that the Project’s post-
2020 GHG operational emissions would be less than significant.
The DSEIR states that the Project is scheduled to open in December 2020 –
but this assumes no unexpected delays. Accordingly, the Project will only have one
month of 2020 operational emissions at the most, and potentially no 2020 emissions
at all. Practically all of the Projects emissions will, instead, occur from 2021 to 205
(assuming a 30 year lifespan).158 The Project will continue to operate and contribute
to GHG emissions for decades to come. As a result, the determination that the
Project’s operational GHG emissions in 2020 would be less than significant has no
relevance to the significance of impacts from GHG emissions during the
overwhelming majority of the Project’s operational life.
CEQA requires that lead agencies consider long term impacts for projects
with long term operations, particularly in the context of GHG emissions.159 Relying
on a project’s emissions at one point in time does not meet CEQA’s requirement to
assess all foreseeable impacts. Indeed, the California Supreme Court addressed this
point in Newhall, noting that “over time consistency with the year 2020 goals will
become a less definitive guide, especially for long term projects that will not begin
operations for several years.” Here, the DSEIR’s conclusion that the Project will not
result in significant impacts for the year 2020 on the grounds it is consistent with
the City’s CAP does not support a determination that the Project will not result in
significant greenhouse gas impacts over its operational lifespan.
157 Cleveland National Forest Foundation, 3 Cal. 5th at 519 (“CEQA requires public agencies . . . to
ensure that [greenhouse gas impact] analysis stay in step with evolving scientific knowledge and
state regulatory schemes.”)
158 The IKEA store in Emeryville, California, for example, is already in its 19th year of operation with
no announced plans for closure anytime soon. Emeryville Today – 1990s to 2000s, City of Emeryville,
https://www.ci.emeryville.ca.us/663/Emeryville-Today-1990s-to-2000s (Noting Emeryville IKEA
opened in April 2000).
159 See CEQA Guidelines, § 15126.2 (discussing impacts both during the “initial and continued
phases of the project”); see also Natural Resources Defense Council v. City of Los Angeles (“NRDC v.
LA”) (2002) 103 Cal.App.4th 268 (CEQA requires examination of the environmental impacts of “the
entire project, from start to finish”).
AB
Page 33 of 96
25
CONT
March 16, 2018
Page 34
4174-003acp
printed on recycled paper
B. The Determination that Long-Term GHG Emissions Are Less
Than Significant Is Not Supported By Substantial Evidence
In recognition of the limits of a CAP consistency analysis is this case, the
DSEIR uses a second threshold of significance for operational GHG emissions after
2020. While the DSEIR’s characterizes the analysis for 2030 as a “City of Dublin
CAP Consistency Analysis,” the threshold it applies is a SB 32 2030 statewide GHG
BAU reduction goal consistency threshold. The DSEIR bases this analysis on a
direct comparison of the Project’s estimated reductions from a 2000 BAU scenario to
the 2030 statewide emission reduction target set in SB 32.160 In this respect, the
DSEIR employs the exact same methodology the California Supreme Court struck
down in Center for Biological Diversity v. California Department of Fish and
Wildlife (“Newhall”). Furthermore, like in that case, the DSEIR’s assumption that
impacts would be less than significant based on consistency with a statewide
(rather than a project-specific) goal is not supported by substantial evidence.
In Newhall, the California Supreme Court squarely addressed the issue of
using statewide GHG emission reduction targets as a threshold of significance for
purposes of CEQA.161 In that case, the project at issue, Newhall Ranch, was a large
development that included residential, community, and commercial uses to be
developed on nearly 12,000 acres near the City of Santa Clarita. To assess the
project’s GHG emissions the Newhall EIR considered whether the proposed
Project’s emissions .would impede the State of California’s compliance with the
statutory 2020 emissions reduction mandate established by AB 32.162 Relying on a
similar “business-as-usual” or “BAU” methodology as the DSEIR uses here, the
Newhall EIR concluded that:
Because the EIR’s estimate of actual annual project emissions . . . is 31
percent below its business-as-usual estimate . . . , exceeding the Air Board’s
determination of a 29 percent reduction from business as usual needed
statewide, the . . . project’s likely greenhouse gas emissions will not impede
160 DSEIR, p. 3.1-63, Table 3.1-21: City of Dublin CAP Consistency Analysis – Operational Year
2030. The statewide targets of AB 197 and SB32 are not a climate action plan or a qualified
greenhouse reduction plan and a direct comparison between anticipated project emissions and the
reduction targets is not a “CAP Consistency Analysis.” See Guidelines § 15183.5. Furthermore, the
City of Dublin CAP only addresses a 2020 reduction target.
161 Center for Biological Diversity v. California Dept. of Fish and Wildlife (2015) 62 Cal. 4th 204.
162 Id. at p. 218.
AB
Page 34 of 96
26
March 16, 2018
Page 35
4174-003acp
printed on recycled paper
achievement of A.B. 32’s goals and are therefore less than significant for
CEQA purposes.163
In Newhall, the California Supreme Court concluded that assessing a
project’s consistency with statewide GHG reduction goals is not per se prohibited
under CEQA, but that such an assessment required substantial evidence and
analysis demonstrating that such a consistency comparison was applicable. The
Newhall decision held that, in that case, the EIR failed to provide substantial
evidence “that Newhall Ranch’s project-level reduction of 31 percent in comparison
to business as usual is consistent with achieving A.B. 32’s statewide goal of a 29
percent reduction from business as usual . . . .”164 The EIR provided no evidence to
support finding that the “required percentage reduction from business as usual is
the same for an individual project as for the entire state population and
economy.”165 The Court held that a straight-line comparison between statewide
reduction goals and project-specific reductions from BAU, without more, does not
support a conclusion that project emission will result in a less than significant
impact.
Here, the DSEIR employs the exact same unsubstantiated methodology that
the Court struck down in Newhall. The DSEIR states that “[t]he proposed project
would meet the 40 percent reduction requirement over year 1990 by 2030, as
required by AB 197 and SB 32.”166 Because of the Project’s estimated reduction
over the BAU scenario, the DSEIR concludes that impacts from GHG emissions
would be less than significant for the year 2030. The DSEIR’s analysis thus
completely ignores the Supreme Court’s guidance in Newhall and employs the same
flawed approach of directly comparing the Project’s anticipated reduction from BAU
to the percentage of statewide reductions required under SB32. Furthermore, the
DSEIR makes no attempt to determine the level of reduction an individual project
must achieve to stay consistent with achieving statewide goals, as the Supreme
163 Id. The 2020 emission reduction target established by AB 32 has been superseded by the target in
SB 32, which requires that statewide greenhouse gas emission are reduced to 40% below the 1990
level by 2030.
164 Id. at 225.
165 Id. at 225-226.
166 DSEIR, p. 3.1-63.
AB
Page 35 of 96
26
CONT
March 16, 2018
Page 36
4174-003acp
printed on recycled paper
Court instructed would be required.167 The DSEIR simply assumes, without any
evidence, that the Project must meet the same level of reduction set forth in
statewide targets to avoid a significant impact.
Both the California Air Resources Board and the California Supreme Court
have recognized that the percent reduction required to be made by specific projects
in order for the state to achieve statewide GHG reduction goal is not the same as
the statewide GHG reduction goal. In Newhall, the Supreme Court noted that a
greater degree of reduction is likely to be needed from new land use projects as
compared to the economy as a whole because it is impractical and infeasible to
require or obtain uniform reductions from all sources of GHG emissions, regardless
of size or type. The Court also cited California Attorney General’s Office comments
that “new development must be more GHG-efficient than [the statewide ‘business
as usual’ reduction goals], given that past and current sources of emissions, which
are substantially less efficient than this average, will continue to exist and emit.”168
New development, in particular, needs to be one of the primary sources of these
greater reductions. This is because designing new buildings and infrastructure for
maximum energy efficiency and renewable energy use is more feasible and more
likely to occur than achieving the same savings by retrofitting older structures and
systems.
In sum, the DSEIR’s determination that impacts from the Project’s GHG
emissions will be less than significant for operational emissions after 2020 is not
supported by substantial evidence. The DSEIR employs the same approach and
reasoning the Supreme Court considered in Newhall, yet it ignores the Court’s clear
direction regarding the use of statewide targets as a threshold for project level
analysis. The City cannot use statewide GHG emission goals in the absence of an
analysis of how those targets translate to an individual project, and no such
analysis is included in the DSEIR here.
167 See Newhall 62 Cal. 4th at 229 (explaining that a BAU comparison may be appropriate where the
lead agency determines what level of reduction a particular project at the proposed location must
contribute in order to comply with statewide goals.).
168 Id. at p. 226.
AB
Page 36 of 96
26
CONT
March 16, 2018
Page 37
4174-003acp
printed on recycled paper
C. Substantial Evidence Shows That GHG Emissions from the
Project Would Be Significant
In order to properly evaluate the significance of the Project’s GHG emissions,
SWAPE performed an analysis of the Project’s GHG emissions using BAAQMD’s
threshold of 1,100 metric tons of carbon dioxide equivalents per year (“MTCO2e”).169
Relying on the City’s CalEEMod model, SWAPE explains that Project construction
would generate 63 MTCO2e per year (amortized over 30 years).170 Additionally,
Project operations would generate 13,634 MTCO23 per year after mitigation.171
Combined, the Project’s annual GHG emissions amount to 13,697 MTCO2e per
year, which exceeds BAAQMD’s threshold of significance by approximately 12,597
MTCO2e per year.172
SWAPE’s analysis of the Project’s GHG emissions demonstrates that when
using a legally valid threshold of significance, established by BAAQMD, substantial
evidence shows that the Project would result in a cumulatively significant
contribute to global climate change.173 Until an updated GHG analysis is prepared
in a revised DSEIR that adequately evaluates the Project’s total GHG impact
consistent with a legally valid threshold of significance, the DSEIR determination
that the Project would not result in a significant GHG impact is not supported by
substantial evidence.
For each of these reasons, the City of Dublin (“City”) may not approve the
Project until a revised document is prepared and recirculated for public review and
comment.
Sincerely,
Collin S. McCarthy
CSM:acp
169 SWAPE Comments at pp. 12-13.
170 Id. at p. 13.
171 Id.
172 Id.
173 Id.
AB
Page 37 of 96
27
28
EXHIBIT A
AB
Page 38 of 96
Scott Cashen, M.S.—Independent Biological Resources Consultant
3264 Hudson Avenue, Walnut Creek, CA 94597 1
March 15, 2018
Mr. Collin S. McCarthy
Adams Broadwell Joseph & Cardozo
520 Capitol Mall, Suite 350
Sacramento, CA 95814
Subject: Comments on the Draft Supplemental Environmental Impact Report
Prepared for the Ikea Retail Center Project
Dear Mr. McCarthy:
This letter contains my comments on the Draft Supplemental Environmental Impact
Report (“DSEIR”) prepared by the City of Dublin (“City”) for the Ikea Retail Center
Project (“Project”). Ikea Property, Inc. (“Applicant”) proposes the development of up to
432,099 square feet of commercial uses on 27.45 acres of mostly undeveloped land in
Dublin, California.
I am an environmental biologist with 25 years of professional experience in wildlife
ecology and natural resources management. I have served as a biological resources
expert for over 100 projects in California. My experience and scope of work in this
regard has included assisting various clients with evaluations of biological resource
issues, reviewing environmental compliance documents prepared pursuant to the
California Environmental Quality Act (“CEQA”) and the National Environmental Policy
Act (“NEPA”), and submitting written comments in response to CEQA and NEPA
documents. My work has included the preparation of written and oral testimony for the
California Energy Commission, California Public Utilities Commission, and Federal
courts. My educational background includes a B.S. in Resource Management from the
University of California at Berkeley, and a M.S. in Wildlife and Fisheries Science from
the Pennsylvania State University. A true and correct copy of my current curriculum
vitae is attached hereto.
The comments herein are based on my review of the environmental documents prepared
for the Project and other projects in the region, a review of scientific literature pertaining
to biological resources known to occur in the Project area, consultations with other
biological resource experts, and the knowledge and experience I have acquired during my
25-year career in the field of natural resources management.
AB
Page 39 of 96
A1
2
ENVIRONMENTAL SETTING
FirstCarbon Solutions (“FCS”) biologists visited the Project site two times: once in the
spring of 2016, and again on November 24, 2017.1 FCS did not conduct any focused
(protocol-level) surveys for special-status plants or animals during these site visits.
Instead, the primary purpose of the site visits was to obtain an overview of the existing
habitat conditions within the Project site and the site’s potential to support sensitive
biological resources so FCS could conduct a peer review of the Biological Resources
Assessment (“BRA”) and Wetland Delineation (“WD”) conducted by WRA, Inc. in
2013.2 The BRA prepared by WRA was based on a single site visit (August 1, 2013) and
did not include any protocol-level surveys.3 As a result, protocol-level surveys have
never been conducted at the Project site.
Data from protocol-level surveys are required to fully assess existing conditions, analyze
Project impacts, and formulate appropriate mitigation. Deferring the surveys until after
completion of the CEQA review process—as proposed in the DSEIR—prevents full
disclosure of Project impacts. It also precludes the public, resource agencies, and
scientific community from being able to submit informed comments pertaining to Project
impacts, and from having those comments vetted during the environmental review
process. These sentiments are reflected in the survey protocols prepared by the
California Department of Fish and Wildlife (“CDFW”), California Burrowing Owl
Consortium, and California Native Plant Society.4
Protocol-level survey data provide essential information on the presence, distribution, and
abundance of sensitive biological resources at a project site. These data in turn facilitate
proper understanding of the magnitude and severity of the project’s impacts to specific
resources (e.g., various species), and thus, the feasibility of various mitigation options.
Without protocol-level survey data, the City can only speculate on the presence of
sensitive biological resources at the Project site. Similarly, without protocol-level data
the City has no ability to assess the magnitude and severity of Project impacts to various
resources, and subsequently, the ability of the proposed mitigation to reduce Project
impacts to less-than-significant levels. As a result, the City has no basis for its
conclusion that all potentially significant Project impacts would be mitigated to less-than-
significant levels by the measures proposed in the DSEIR.
1 DSEIR, pp. 3.2-1 and -16.
2 DSEIR, p. 3.2-16.
3 BRA, p. 1.
4 California Department of Fish and Game. 2009. Protocols for Surveying and Evaluating Impacts to
Special Status Native Plant Populations and Natural Communities. Available at:
<https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline>. See also California Department of
Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. Available at:
<https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843>. See also California Native Plant Society.
2001 (Revised). CNPS Botanical Survey Guidelines. Available at:
<http://www.cnps.org/cnps/rareplants/pdf/cnps_survey_guidelines.pdf>. See also California Burrowing
Owl Consortium. 1993. Burrowing Owl Survey Protocol and Mitigation Guidelines. Available at:
<https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83842>.
AB
Page 40 of 96
A1
CONT
3
For example, the City has concluded that development of a mitigation plan, which would
incorporate off-site habitat compensation, would effectively mitigate significant impacts
to any special-status plant species that might be discovered on the Project site during
preconstruction surveys.5 A conclusion of this nature relies on the presumption that all
impacts can be mitigated to a less than significant level. Such a presumption is
unrealistic. To illustrate this point, Douglas' fiddleneck (Amsinckia douglasiana) was
detected at the Project site (although its presence was not disclosed in the DSEIR).6 The
presence of Douglas' fiddleneck on the Project site represents the only known occurrence
in Alameda and Contra Costa counties (it was previously believed to be extirpated from
both counties). As a result, Project impacts to this locally rare species would be
unmitigable because there are no off-site mitigation options (i.e., properties available for
acquisition as replacement habitat).
Due to the issues described above, the City needs to prepare a revised DSEIR once
protocol-level surveys have been completed for the Project.
Special-Status Plant Species
Congdon’s tarplant (Centromadia parryi ssp. congdonii) is known to occur on
approximately 6.81 acres of the Project site.7 However, the Applicant has not conducted
protocol-level surveys to determine whether other special-status plant species occur on
the Project site. Furthermore, because WRA did not conduct protocol-level surveys, and
because its site visits were conducted after a period of below average rainfall (and during
months that are generally not conducive to finding rare plants),8 it had no basis for
concluding other special-status plants have “no potential” or are “unlikely” to occur at the
Project site simply because those plants were not observed during its survey(s).9
Similarly, the City has no basis for its conclusion that Congdon’s tarplant is the only
special-status plant species with a moderate to high potential of occurring at the Project
site.10
Indeed, at least two other special-status plant species occur at the Project site: western
dodder (Cuscuta occidentalis) and Douglas' fiddleneck (Amsinckia douglasiana).11 Both
of these species are locally rare (i.e., rank “A1” and “*A1x ” by the East Bay Chapter of
the California Native Plant Society).12 Locally rare plant species with an “A”
5 Although the DSEIR subsequently suggests the proposed mitigation would only be applied if Congdon’s
tarplant is impacted by the Project.
6 BRA, Appendix D (Plant Species Observed on 5 Nov 2013) to Appendix C.2 (Wetland Delineation).
7 DSEIR, p. 3.2-5.
8 BRA, Appendix C.2 (Wetland Delineation), p. 9 and Appendix B (Wetland Delineation Data Sheets).
9 BRA, Appendix B.
10 DSEIR, p. 3.2-17.
11 BRA, Appendix A.1 (Plant Species Observed on 1 Aug 2013) and Appendix D (Plant Species Observed
on 5 Nov 2013) to Appendix C.2 (Wetland Delineation).
12 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web
application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <
https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13).
AB
Page 41 of 96
A1
CONT
4
designations are considered special-status species under Sections 15380 and 15125(c) of
CEQA.13 The presence of Douglas' fiddleneck at the Project site is especially significant
because—until now—it was believed to have been extirpated from Alameda and Contra
Costa counties.14 The DSEIR fails to disclose the presence of these two species at the
Project site.
The BRA dismissed the potential for saline clover (Trifolium hydrophilum) and hairless
popcorn flower (Plagiobothrys glaber) to occur at the Project site.15 Saline clover has a
Rare Plant Rank of 1B.2 and hairless popcorn flower is ranked 1A.16 Both species are
associated with alkaline soils and vernal pools (and other mesic habitats),17 which are
present at the Project site.18,19 According to the BRA, saline clover is unlikely to occur at
the site because: “[t]he existing grassland and seasonally wet depression habitat in the
Project Area is heavily disturbed and of low quality,” and hairless popcorn flower is
unlikely to occur at the Project site because: “[t]his species is presumed extinct and has
not been found since 1954.”20 Consequently, the BRA recommended no further actions
(e.g., protocol-level surveys) for either species.21
Saline clover has been detected in disturbed areas and “low quality” habitats.22 In
addition, the BRA’s statement that hairless popcorn flower has not been found since 1954
is incorrect; this species was rediscovered near Tassajara Road in Dublin during surveys
13 California Department of Fish and Game. 2009. Protocols for Surveying and Evaluating Impacts to
Special Status Native Plant Populations and Natural Communities. Available at:
<https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline>. See also California Native Plant
Society. 2001 (Revised). CNPS Botanical Survey Guidelines. Available at:
<http://www.cnps.org/cnps/rareplants/pdf/cnps_survey_guidelines.pdf>.
14 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web
application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at:
<https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13).
15 BRA, Appendix B.
16 Rank 1B plants are Rare, Threatened, or Endangered in California and elsewhere. Rank 1A plants are
presumed extirpated in California and either rare or extinct elsewhere. Although hairless popcorn flower
was believed to be extirpated, its presence in the Dublin area was verified in 2006. See Lake D. 2018. Rare,
Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley,
California: East Bay Chapter of the California Native Plant Society. Available at:
<https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>.
17 California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and
Wildlife. See also Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa
Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society.
Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13).
18 BRA, Appendix C.2 (Wetland Delineation).
19 The presence of alkali mallow (Malvella leprosa) at the Project site indicates there is at least some
alkaline soil.
20 Ibid.
21 Ibid.
22 California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and
Wildlife. See also Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa
Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society.
Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13).
AB
Page 42 of 96
A1
CONT
5
conducted in 2002 and 2006.23 Saline clover is also known to occur in the Tassajara
Area. As a result, saline clover and hairless popcorn flower have the potential to occur at
the Project site. Locally rare (i.e., A-rank) species that are known to occur in the East
Dublin area (i.e., east of I-680 and north of I-580) and that have the potential to occur at
the Project site include: Amaranthus palmeri, Cuscuta indecora var. indecora, Limosella
acaulis, Stachys ajugoides, Trifolium barbigerum, Trifolium flavulum, Trifolium
gambelii, and Triphysaria versicolor subsp. faucibarbata.24
Special-Status Branchiopods
The Project site lies within the “Livermore Vernal Pool Region.”25 Ephemeral pools in
the Livermore Vernal Pool Region provide habitat for special-status branchiopods,
including the federally threatened vernal pool fairy shrimp, and the California linderiella,
which has a NatureServe Rank of G2G3 S2S3.26
Vernal Pool Fairy Shrimp
The Project site contains seasonal wetlands (vernal pools). Based on the information
provided on the Wetland Delineation data sheets, the wetlands hold water longer enough
to provide potential habitat for the vernal pool fairy shrimp.27 Indeed, aquatic
invertebrate shells from Ostracoda were detected in two of the wetlands in 2013.28 The
presence of these “seed shrimp” at the Project site provides substantial evidence that
vernal pool fairy shrimp also may occur at the Project site.
Mitigation incorporated into the Eastern Dublin General Plan Amendment and Specific
Plan requires species-specific surveys for special-status invertebrates in appropriate
wetland habitats prior to approval of specific projects in the Reduced Planning Area
(which encompasses the Project site).29 Those surveys have not been conducted at the
Project site.30 Instead, the BRA simply concluded: “[t]his species is unlikely to occur in
the Project Area due to the lack of vernal pool habitat and the area’s history of repeated
23 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web
application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at:
<https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13).
24 Personal communication with D. Lake, Unusual Plant Chair, East Bay California Native Plant Society,
on 2018 Mar 14.
25 U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of California and
Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. Figure III-6.
26 G2G3 = high to moderate risk of global extinction. S2S3 = high to moderate risk of statewide extinction.
27 BRA, Appendix C.2 (Wetland Delineation), Appendix B (Wetland Delineation Data Sheets).
28 Ibid.
29 City of Dublin. 1993. Addendum to Eastern Dublin General Plan Amendment and Specific Plan
Environmental Impact Report. p. 22.
30 United States Fish and Wildlife Service. 1996. Interim survey guidelines to permittees for recovery
permits under Section 10(a)(1)(A) of the Endangered Species Act for the listed vernal pool Branchiopods
[internet]. Sacramento (CA): United States Fish and Wildlife Service, Sacramento Fish and Wildlife Office.
Available at: <http://www.fws.gov/sacramento/es/Survey-Protocols-
Guidelines/Documents/Interim_VP_Survey_Guidelines_to_Permittees_4-96.pdf>.
AB
Page 43 of 96
A1
CONT
6
discing, grading and leveling.”31 The BRA’s conclusion is not supported by evidence
and it contradicts scientific information on vernal pool fairy shrimp habitat.
Despite the moniker, vernal pool fairy shrimp are not limited to “vernal pools;” they also
occur in vernal pool-like habitats such as seasonal wetlands and pools.32 Indeed, vernal
pool fairy shrimp occur in a wide range of habitats, including degraded or otherwise
poor-quality habitats such as pools created by tire tracks and roadside ditches.33 As a
result, the seasonal wetlands at the Project site provide potential habitat for the vernal
pool fairy shrimp.
According to the Wetland Delineation, the wetlands have experienced “little disturbance”
since 2008.34 This contradicts the BRA’s argument that the wetlands are unlikely to
provide habitat because they have been subject to repeated disking, grading, and leveling.
Nevertheless, disking, grading and leveling at the Project site do not preclude the
potential for vernal pool fairy shrimp. For example, in Contra Costa County, over 100
vernal pool fairy shrimp were documented in a “non-vegetated depression in dirt road
along tracks—partially scraped by bulldozer,” and that had “routine vehicle traffic
through [the] area.”35 At a minimum, the wetlands at the Project site have remained
undisturbed long enough to become dominated by wetland plants.36 This indicates they
have also remained undisturbed long enough for vernal pool fairy shrimp colonization (or
recolonization).37
Ultimately, the DSEIR provides no mention of the vernal pool fairy shrimp, and
consequently, no analysis of potentially significant impacts to the species. Until
protocol-level surveys have been conducted, filling of the site’s wetlands represents an
unexamined, potentially significant impact to the vernal pool fairy shrimp.
31 BRA, p. 12.
32 California Natural Diversity Database. 2018 Jan 2. RareFind 5. California Department of Fish and
Wildlife.
33 Ibid. See also U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of
California and Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. p. II-197.
34 BRA, Appendix C.2 (Wetland Delineation), Appendix B (Wetland Delineation Data Sheets). See also p.
8.
35 California Natural Diversity Database. 2018 Jan 2. RareFind 5. California Department of Fish and
Wildlife. Occurrence No. 212.
36 BRA, Appendix C.2 (Wetland Delineation).
37 United States Fish and Wildlife Service. 2007. Vernal pool fairy shrimp (Branchinecta lynchi), 5-year
review: summary and evaluation. Sacramento Fish and Wildlife Office, Sacramento, CA, p. 5. Available at:
<http://www.fws.gov/cno/es/images/Graphics/VPFS_5-
yr%20review%20CNO%20FINAL%2027Sept07.pdf>. See also Incagnone G, F Marrone, R Barone, L
Robba, L Naselli-Flores. 2015. How do freshwater organisms cross the ‘‘dry ocean’’?͒A review on passive
dispersal and colonization processes with a special focus on temporary ponds. Hydrobiologia 750:103–123.
See also Maquire B Jr. 1963. The Passive Dispersal of Small Aquatic Organisms and Their Colonization of
Isolated Bodies of Water. Ecological Monographs 33(2):161-185.
AB
Page 44 of 96
A1
CONT
7
California Linderiella (formerly California fairy shrimp)
Neither the DSEIR nor BRA mentions the California linderiella. California linderiella
occupy the same types of habitat as the vernal pool fairy shrimp,38 and they have been
detected in seasonal wetlands comparable to those found on the Project site.39 As a
result, the California linderiella has the potential to occur at the Project site. Until
protocol-level surveys have been conducted, filling of the site’s wetlands represents an
unexamined, potentially significant impact to the California linderiella.
Burrowing Owl
The DSEIR fails to disclose the status and demography of the local and regional
burrowing owl populations. This information is an essential component of the DSEIR
because it enables the public and decision makers to evaluate the relative significance of
Project impacts to the overall burrowing owl population.
Burrowing owl populations have declined dramatically in the San Francisco Bay Area
(“SFBA”) since the 1992 Eastern Dublin Specific Plan EIR was prepared.40 The species
has been extirpated, or nearly extirpated, from six SFBA counties (Napa, Marin, San
Francisco, Santa Cruz, Sonoma, and San Mateo).41 Although burrowing owls were once
abundant throughout Alameda and Contra Costa counties, they are now primarily limited
to the eastern portions of those counties.42
Two “large” breeding colonies of burrowing owls remain in Alameda County: one is in
the Altamont Hills, and the second is in the Camp Parks area. The Project site is located
at the periphery of the “Camp Parks” burrowing owl population. The Camp Parks
population is the only “large” population of burrowing owls remaining in the Livermore-
Amador Valley.43 Although the Project site provides good habitat for burrowing owls,
neither WRA nor FCS conducted the surveys needed to determine presence of burrowing
owls at the site.44
38 U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of California and
Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. pp. II-214 through II-220.
39 E.g., See EOndx #94421 in California Natural Diversity Database. 2018 Mar 6. RareFind 5. California
Department of Fish and Wildlife.
40 Wilkerson RL and RB Siegel. 2010. Assessing changes in the distribution and abundance of burrowing
owls in California, 1993-2007. Bird Populations 10:1-36. See also Townsend SE, C Lenihan. 2003.
Burrowing Owl Status in the Greater San Francisco Bay Area. Proceedings of the California Burrowing
Owl Syposium. Bird Populations Monographs No. 1:60-70. Available at:
<http://www.calenv.com/California_Environmental_Services/Publications_files/Townsend%20and%20Len
ihan_Burrowing%20Owl.pdf>. See also Alameda Creek Alliance. 2014 Mar 21. Lawsuit Challenges
Dublin Development That Will Evict Burrowing Owls [Press Release]. Available at:
<http://www.alamedacreek.org/newsroom/pdf/press%20releases/2014/Camp%20Parks%20PR%203-21-
14.pdf>.
41 Townsend SE, C Lenihan. 2003. Burrowing Owl Status in the Greater San Francisco Bay Area.
Proceedings of the California Burrowing Owl Syposium. Bird Populations Monographs No. 1:60-70.
42 Ibid.
43 Ibid.
44 BRA, p. 10.
AB
Page 45 of 96
A1
CONT
8
Burrowing owls can be difficult to detect due to their cryptic coloration, extensive use of
burrows, and tendency to flush (fly away) when approached.45 As a result, burrowing
owl researchers and the CDFW have concluded that four independent surveys are
necessary to provide reliable information on the presence of burrowing owls.46 Data
from the four surveys (termed “detection surveys” in CDFW’s Staff Report on Burrowing
Owl Mitigation) are essential to avoiding, minimizing, and properly mitigating the direct
and indirect effects of the Project on burrowing owls.
The DSEIR requires the Applicant to conduct two pre-construction surveys prior to
ground-disturbing activities at the Project site. Although CDFW guidelines recommend
“take avoidance” (i.e., pre-construction) surveys, the guidelines make it clear that those
surveys are not a substitute for the four “detection surveys” required to assess Project
impacts and formulate appropriate mitigation.47 Because FCS and WRA failed to
implement the CDFW survey protocol, the City lacks the information needed to fully
disclose and evaluate Project impacts to burrowing owls, and perhaps more importantly,
to ensure effective mitigation.
The need to establish the baseline population of burrowing owls on a site prior to
assessing impacts and mitigation measures is emphasized in CDFW’s 2012 Staff Report
on Burrowing Owl Mitigation (“Staff Report”), which states:
Adequate information about burrowing owls present in and adjacent to an area
that will be disturbed by a project or activity will enable the Department,
reviewing agencies and the public to effectively assess potential impacts and will
guide the development of avoidance, minimization, and mitigation measures.48
It is not possible to effectively assess the extent of Project impacts on burrowing owls
until surveys that adhere to CDFW guidelines have been conducted. As a result, the City
must require the Applicant to conduct the protocol surveys described in CDFW’s 2012
Staff Report, and the results of those surveys need to be released in a revised CEQA
document so that they can be thoroughly vetted by the public, resource agencies, and
decision makers during the CEQA review process.
Special-Status Bats
The DSEIR identified three special-status bat species (pallid bat, Townsend’s big-eared
bat, and Yuma myotis) that have a “moderate” potential of roosting in the building on the
Project site. As with the other special-status species, the Applicant did not conduct the
45 Klute DS, LW Ayers, MT Green, WH Howe, SL Jones, JA Shaffer, SR Sheffield, TS Zimmerman. 2003.
Status assessment and conservation plan for the western Burrowing Owl in the United States. Bio Tech Pub
FWS/BTP-R6001-2003. Washington: US Fish and Wildlife. Available at: <https://www.fws.gov/mountain-
prairie/migbirds/species/birds/wbo/Western%20Burrowing%20Owlrev73003a.pdf>.
46 See Appendix D In: California Department of Fish and Wildlife. 2012. Staff Report on Burrowing Owl
Mitigation.
47 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation.
48 Ibid, p. 6.
AB
Page 46 of 96
A1
CONT
9
survey(s) necessary to determine whether any bat species were indeed using the building
as a roost site. The City’s failure to establish baseline conditions precludes the public,
resource agencies, and scientific community from being able to submit informed
comments pertaining to Project impacts, and from having those comments vetted during
the environmental review process.
PROJECT IMPACT ISSUES
Special-Status Plants
The DSEIR provides no analysis of direct impacts to special-status plants other than the
statement that construction activities would directly impact Congdon’s tarplant if it is
found on the Project site, and that this would be a potentially significant impact.49 The
DSEIR fails to provide any analysis of impacts to other special-status plant species that
occur, or could occur, at the Project site.
Indirect impacts associated with the Project include trampling, pollution, altered
hydrology, shading, invasive plants, and pesticide drift. The DSEIR fails to provide any
analysis of, or mitigation for, these potentially significant indirect impacts to special-
status plants. As a result, the DSEIR lacks substantial evidence supporting its finding
that Project impacts on special-status plants would be less than significant.
Special-Status Branchiopods
The DSEIR fails to provide any analysis of, or mitigation for, potentially significant
impacts to special-status branchiopods (i.e., vernal pool fairy shrimp and California
linderiella).
Burrowing Owl
Habitat Loss
By 2003, only two “large” breeding colonies of burrowing owls remained in Alameda
County: one in the Altamont Hills, and one in the Camp Parks area. The Project site
provides habitat for burrowing owls in the “Camp Parks” population, which is the only
breeding population remaining in the Livermore-Amador Valley.50 The DSEIR fails to
disclose this information. It also fails to analyze how the loss of burrowing owl habitat
from the Project site may affect the Camp Parks burrowing owl population. Instead, it
jumps to the conclusion that Mitigation Measure BIO-1c would mitigate impacts to
burrowing owls to a less than significant level—even though Mitigation Measure BIO-1c
does not provide any specific information on how the mitigation measure would, or
could, mitigate significant impacts to the Camp Parks burrowing owl population.
49 DSEIR, p. 3.2-17.
50 Townsend SE, C Lenihan. 2003. Burrowing Owl Status in the Greater San Francisco Bay Area.
Proceedings of the California Burrowing Owl Syposium. Bird Populations Monographs No. 1:60-70.
AB
Page 47 of 96
A1
CONT
10
Habitat loss caused by development is the most immediate threat to burrowing owls that
reside in high growth areas of the San Francisco Bay Area.51 The further decline of
burrowing owls in the few remaining core population areas—such as the Camp Parks
area—will have a significant effect on the overall persistence of burrowing owls in the
region. This is exemplified by the extirpation of almost all burrowing owl colonies from
western Alameda and Contra Costa counties following build out in the 1980s and
1990s.52 The City is required to disclose this information, and provide robust mitigation
that reflects the severity of impacts to a core population area.
Eviction of Owls from Occupied Burrows
The Project may involve the eviction of burrowing owls from their burrows. The DSEIR,
however, fails to adequately evaluate potential impacts to burrowing owls from the
temporary or permanent closure of burrows, or to identify mitigation measures sufficient
to reduce such impacts below a level of significance. Consistent with CDFW guidelines,
passive relocation is a potentially significant impact under CEQA that must be
analyzed.53 Specifically, the temporary or permanent closure of burrows may result in:
(a) significant loss of burrows and habitat for reproduction and other life history
requirements; (b) increased stress on burrowing owls and reduced reproductive rates; (c)
increased depredation; (d) increased energetic costs; and (e) risks posed by having to find
and compete for available burrows.54 The City must disclose and thoroughly analyze the
impacts associated with evicting burrowing owls from the Project site.
The need for full analysis of potential impacts from passive relocation (i.e., eviction) is
further supported by research that indicates most translocation projects have resulted in
fewer breeding pairs of burrowing owls at the mitigation site than at the original site, and
that translocation projects generally have failed to produce self-sustaining populations.55
Investigators attribute the limited success of translocation to: (a) strong site tenacity
exhibited by burrowing owls, and (b) potential risks associated with forcing owls to move
into unfamiliar and perhaps less preferable habitats.56
The DSEIR fails to provide a burrowing owl exclusion plan, or fundamental details
associated with that plan (e.g., location of replacement burrows and compensation
habitat). This makes it impossible for the public, resource agencies, and decision makers
to evaluate the probability that there will be significant impacts to owls evicted from the
Project site.
51 Ibid.
52 Ibid. See also California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of
Fish and Wildlife. See also Glover SG. 2009. Breeding bird atlas of Contra Costa County. Mount Diablo
Audubon Society, Walnut Creek (CA). 260pp.
53 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation, p. 10.
54 Ibid.
55 Smith BW, JR Belthoff. 2001. Burrowing owls and development: short-distance nest burrow relocation
to minimize construction impacts. J. Raptor Research 35:385-391.
56 Ibid.
AB
Page 48 of 96
A1
CONT
11
Impacts to Foraging Habitat
The Project site provides suitable foraging habitat for special-status bats, the burrowing
owl, and other protected bird species.57 The DSEIR’s analysis of impacts to foraging
habitat for these species is limited to the statement that: “[i]t should be noted that
significant impacts associated with wildlife species are associated with their potential to
nest on-site; avian species can forage almost anywhere, and the loss of foraging habitat
by itself does not constitute a significant impact.”58 This statement is absurd and
indicates the author has minimal knowledge of the ecology associated with the special-
status species that occur in the Project region.
It is well established in scientific literature and mitigation guidance issued by the CDFW
that the loss or degradation of foraging habitat can have a significant impact on special-
status species. For example, burrowing owls depend on foraging habitat in close
proximity to burrows (nest sites).59 Indeed, CDFW’s Staff Report on Burrowing Owl
Mitigation reports: “burrows and the associated surrounding habitat are essential
ecological requisites for burrowing owls throughout the year and especially during the
breeding season.”60 As a result, burrowing owls will be eliminated from the Project site
even if their burrows are protected.
The loss of foraging habitat can also have a significant impact on bats. According to the
Western Bat Working Group: “[i]n general, the long term persistence of North American
bat species is threatened by the loss of clean, open water; modification or destruction of
roosting and foraging habitat; and, for hibernating species, disturbance or destruction of
hibernacula.”61 A considerable amount of foraging habitat in the region has already been
lost to urban development and other habitat conversion activities (e.g., agricultural
expansion and wind energy production). Much of the foraging habitat that remains in the
region is threatened by additional development. For these reasons, the loss of bat
foraging habitat at the Project site constitutes a potentially significant impact that must be
scientifically analyzed in a revised DSEIR.
The DSEIR’s assertion that “avian species can forage almost anywhere” contradicts
scientific facts. For example, burrowing owls only forage in areas that support a suitable
prey base and that have conditions that allow for effective hunting.62 As a result,
foraging is limited to areas with sufficient prey, and where vegetation is relatively short
and open.63 In addition, because burrowing owls exhibit high site fidelity, they do not
57 DSEIR, pp. 3.2-17 and -18.
58 DSEIR, p. 3.2-17.
59 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation.
60 Ibid, p. 21. [emphasis added].
61 Western Bat Working Group. 2005 (update). Species Accounts. p. 11. [emphasis added].
62 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. p. 24.
63 Klute DS, LW Ayers, MT Green, WH Howe, SL Jones, JA Shaffer, SR Sheffield, TS Zimmerman. 2003.
Status assessment and conservation plan for the western Burrowing Owl in the United States. Bio Tech Pub
FWS/BTP-R6001-2003. Washington: US Fish and Wildlife. See also Shuford WD, T Gardali, editors.
2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct
AB
Page 49 of 96
A2
12
readily colonize new habitats (including foraging habitats) if they are displaced from a
project site.64
The Project, in conjunction with other projects in the area (i.e., Boulevard and Zeiss
Innovation Center), would eliminate nearly all of the raptor foraging habitat remaining in
the region (Figure 1). As a result, raptor territories associated with that habitat will be
eliminated, even if the actual nest sites are not destroyed. This constitutes a significant
impact that must be disclosed, analyzed, and mitigated in a revised DSEIR.
Figure 1. Cumulative impacts to raptor foraging habitat in the Project area. Virtually all
remaining habitat would be eliminated by the proposed Project (yellow rectangle), Zeiss
Innovation Center Project (orange rectangle), and Boulevard Project (red polygon).
Cumulative Impacts
The DSEIR’s analysis of cumulative impacts to biological resources fails to satisfy the
requirements of CEQA.
First, the DSEIR fails to define the geographic scope of the City’s cumulative impacts
analysis other than it was “the region surrounding the project site.”65 This description is
populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western
Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento.
64 Rosenburg DK, KL Haley. 2004. The Ecology of Burrowing Owls in the Agroecosystem of the Imperial
Valley, California. Studies in Avian Biology 27:120-135. See also Wilkerson RL and RB Siegel. 2010.
Assessing changes in the distribution and abundance of burrowing owls in California, 1993-2007. Bird
Populations 10:1-36.
65 DSEIR, p. 4-3.
AB
Page 50 of 96
A2
CONT
A3
13
too vague to understand the geographic scope of the City’s analysis, and consequently,
any ability to validate the conclusions presented in the DSEIR.
Second, the list of cumulative projects provided in the DSEIR omits the Zeiss Innovation
Center Project, which is located approximately 700 feet north of the Project site. The
Zeiss Innovation Center Project would impact many of the same biological resources as
the proposed Project, including Congdon’s tarplant, seasonal wetlands, burrowing owl
(and other raptor) habitat, and potential habitat for the vernal pool fairy shrimp and
California linderiella.
Third, the DSEIR acknowledges the Project would (or could) impact wetlands, special-
status plants (Congdon’s tarplant), and special-status animals (nesting birds, burrowing
owl, bats).66 However, the DSEIR fails to provide any actual analysis of cumulative
impacts to these resources, nor does it provide the City’s conclusion on whether
cumulative impacts to these specific resources would be significant. Instead, the DSEIR
simply jumps to the conclusion that the proposed mitigation would make the Project’s
contribution to “any significant cumulative impact” less than cumulatively
considerable.67 There are two problems with the City’s rationale:
1. None of the biological resource mitigation measures are designed to alleviate the
cumulative impact; all three mitigation measures are specific to the Project site
and to Project activities. Therefore, they do not address the cumulative impact
posed by other projects in conjunction with the proposed Project.
2. Habitat loss, including the incremental loss of habitat from numerous small
projects, is the greatest threat to most special-status species. The DSEIR does not
require habitat compensation for all of the special-status species that would (or
could) be affected by the Project. As a result, the Project’s contribution to the
cumulatively significant loss of habitat would not be mitigated.
Fourth, the DSEIR concludes the Project’s contribution to any significant cumulative
impact on special-status plant species would be less than cumulatively considerable
because Congdon’s tarplant would be relocated if it is found on the Project site during
preconstruction surveys. The basis for this conclusion is confusing because the DSEIR
does not require (or propose) relocation of Congdon’s tarplant as mitigation.
Nevertheless, the DSEIR’s conclusion is not justified because the DSEIR fails to
incorporate mitigation for the numerous other special-status plant species that occur, or
could occur, at the Project site.
Based on my review of the scientific literature, and the City’s failure to demonstrate the
proposed mitigation would offset significant impacts, it is my professional opinion that
the Project’s incremental contribution to cumulative impacts to the burrowing owl and
Congdon’s tarplant would be cumulatively considerable. The Project may have
cumulatively considerable impacts to other species as well (e.g., vernal pool fairy shrimp,
special-status bats); however, I am unable to formulate a definitive opinion in this regard
66 DSEIR, p. 4-4.
67 DSEIR, p. 4-4.
AB
Page 51 of 96
A3
CONT
14
due to the DSEIR’s omission of baseline data pertaining to the presence of those species
on the Project site.
MITIGATION ISSUES
Special-Status Plants
The DSEIR requires the Applicant to conduct a focused survey to determine the presence
of Congdon’s tarplant prior to construction. If no special-status plant species
are found during the survey, then no additional mitigation measures will be implemented.
However, if Congdon’s tarplant is detected, additional mitigation measures shall be
required.68 There are several problems with the proposed mitigation:
First, the DSEIR does not require focused surveys or mitigation for the other special-
status plant species that occur, or could occur, at the Project site. As a result, potentially
significant impacts to all special-status plants besides Congdon’s tarplant remain
unmitigated.
Second, Congdon’s tarplant is known to occur at the Project site. Therefore, there is no
basis for making compensatory mitigation contingent on the results of a future survey of
unknown quality, and conducted by a biologist with uncertain qualifications. This is
especially true for annual plants such as Congdon’s tarplant because the presence and
abundance of annual plants can fluctuate dramatically from year to year due to climatic
conditions. Thus, the absence of Congdon’s tarplant from the Project site during a
preconstruction survey may be the result of adverse survey conditions rather than actual
absence of the species.
Third, the DSEIR indicates that compensatory mitigation would not be required if
activity exclusion zones can be installed around habitat occupied by Congdon’s tarplant
during construction of the Project. Based on the site plan, all existing plants will be
directly or indirectly affected by the Project.69 Therefore, even if activity exclusion zones
are feasible, the “protected” plant populations have no chance for long-term persistence
at the site once the Project is operational.
Compensatory Mitigation Strategy
The DSEIR requires the Applicant to prepare a mitigation plan if impacts to Congdon’s
tarplant cannot be avoided. According to the DSEIR: “[a] mitigation plan may include
but is not limited to the following: the acquisition of off-site mitigation areas presently
supporting the Congdon’s tarplant, purchase of credits in a mitigation bank that is
approved to sell credits for the Congdon’s tarplant, or payment of in-lieu fees to a public
agency or conservation organization (e.g., a local land trust) for the preservation and
68 DSEIR, p. 3.2-18.
69 Indirect impacts associated with the Project include trampling, pollution, altered hydrology, shading,
invasive plants, and pesticide drift.
AB
Page 52 of 96
A3
CONT
15
management of existing populations of Congdon’s tarplant.”70
The DSEIR cannot defer formulation of the mitigation plan unless it establishes
fundamental aspects of the plan in the DSEIR. These include: (a) the performance
standards (or success criteria) for the proposed mitigation, (b) a definitive enforcement
mechanism that ensures performance standards are met; (c) the contingency or remedial
action measures that would be triggered if success standards are not achieved; (d) the
measures that would be implemented to ensure the long-term protection and management
of sensitive biological resources at mitigation sites; and (e) the required monitoring
program, including the monitoring techniques, effort, and frequency. Because the DSEIR
lacks these fundamental details, the City has not ensured Project impacts to sensitive
botanical resources would be reduced to a less than significant level.
The DSEIR’s deferral of the mitigation plan is exacerbated by its failure to provide
evidence that the proposed mitigation is feasible. There do not appear to be any
mitigation banks that sell credits for impacts to Congdon’s tarplant.71 In addition, there
do not appear to be any in-lieu fee programs that cover impacts to Congdon’s tarplant.
Whereas the acquisition of off-site mitigation areas supporting Congdon’s tarplant is an
acceptable option, the DSEIR fails to provide evidence that sites suitable for acquisition
exist—especially given the demand generated by other projects requiring compensatory
mitigation for impacts to Congdon’s tarplant. As a result, the City needs to produce a
revised DSEIR that identifies the: (a) potential mitigation sites, and status of Congdon’s
tarplant at those sites; (b) actual mitigation ratio being proposed; (c) performance
standards for the mitigation sites; (d) required monitoring program; and, (e) measures that
will be implemented to ensure the long-term protection and management of Congdon’s
tarplant populations at the mitigation sites.
Compensatory Mitigation Ratio
According to the DSEIR, the mitigation plan should incorporate a compensatory
mitigation ratio of at least 1:1. The Eastern Alameda County Conservation Strategy
(“EACCS”) establishes the standard for mitigation needed to conserve species and habitat
in Eastern Alameda County. The mitigation proposed in the DSEIR does not adhere to
EACCS. Specifically, the EACCS establishes a standardized mitigation ratio of 5:1 for
impacts to focal plant species (e.g., Congdon’s tarplant).72 In addition, the 1:1 ratio
proposed in the DSEIR is not consistent with other projects in Dublin. For example, the
City is requiring a 5:1 ratio for impacts to Congdon’s tarplant at the Zeiss Innovation
70 DSEIR, p. 3.2-19.
71 California Department of Fish and Wildlife. 2018. Conservation and Mitigation Banks Established in
California by CDFW [website]. Available at:
<https://www.wildlife.ca.gov/Conservation/Planning/Banking/Approved-Banks#r3>.
72 ICF International. 2010. Final Draft East Alameda County Conservation Strategy.
Prepared for East Alameda County Conservation Strategy Steering Committee. October
2010. Table 3-12.
AB
Page 53 of 96
A3
CONT
16
Center Project site.73 The DSEIR fails to explain why a 5:1 ratio was needed to mitigate
impacts at the Zeiss project site, while the proposed Project only requires a 1:1 ratio—
even though the City analyzed both projects at approximately the same time.
Because the DSEIR lacks a detailed mitigation strategy, and because the measures listed
in the DSEIR do not comply with the EACCS, the City has not ensured Project impacts
to Congdon’s tarplant and other special-status plant species would be reduced to a less
than significant level.
Burrowing Owl
The DSEIR incorporates the following mitigation measures for Project impacts to
burrowing owls: (1) a Burrowing Owl Survey and Impact Assessment that would be
conducted immediately before ground-disturbing activities; (2) avoidance measures; (3)
burrow exclusion if avoidance is not possible; and, (4) preparation and implementation of
a Mitigation Plan if avoidance is not possible. I discuss each of these measures in the
subsections below.
Burrowing Owl Survey and Impact Assessment
The DSEIR requires a preconstruction survey no more than 14 days prior to ground-
disturbing activities, and a second survey within 48 hours of initial ground disturbance.
Two preconstruction surveys during an undetermined time of year do not provide reliable
information on burrowing owls that may be impacted by a project. As discussed above,
the two “take avoidance” (preconstruction) surveys described in CDFW’s Staff Report
are not intended to serve as a substitute for the four “detection” surveys needed to
identify presence, assess impacts, and formulate appropriate mitigation. Rather, the “take
avoidance” surveys are intended to confirm no new owls have colonized the site since
completion of the “detection” surveys. According to CDFW’s Staff Report: “[a]ny new
burrowing owl colonizing the project site after the CEQA document has been adopted
may constitute changed circumstances that should be addressed in a re-circulated CEQA
document.”74 Because the Applicant never made an attempt to establish burrowing owl
occupancy at the Project site, any burrowing owls occupying the site when the
preconstruction surveys are conducted would constitute changed circumstances that will
need to be addressed in a re-circulated CEQA document.
An additional problem with the City’s approach to obtaining the data needed to assess
occupancy and implement mitigation is that it is based on the Applicant’s timing, rather
than the timing needed to establish the ecological value of the site to burrowing owls.
Many burrowing owls migrate seasonally, at least at a local scale. As a result,
preconstruction surveys that are conducted during the non-breeding season would fail to
detect individuals that breed at the site. This would lead to the false conclusion that the
Project would have no impact on the species, and thus, compensatory mitigation is not
73 City of Dublin. 2017 Dec 8. Zeiss Innovation Center: Supplemental Mitigated Negative
Declaration/Initial Study. p. 29.
74 Ibid, p. 10. [emphasis added].
AB
Page 54 of 96
A3
CONT
17
required (per the conditions established in the DSEIR).
Avoidance Measures - Buffers
The DSEIR directs the Applicant to avoid disturbing or otherwise impacting burrows
occupied by burrowing owls. The DSEIR, however, fails to establish any standards for
the mitigation measure. For example, the DSEIR does not establish the minimum buffers
that need to be implemented around burrows, or the monitoring activities that should be
implemented to ensure burrowing owls are not being disturbed by construction activities.
The mitigation measure should be revised to reflect CDFW guidelines, which indicate the
need for buffers 50 to 500 meters, depending on the time of year and level of
disturbance.75
Exclusion and Relocation Plan
The DSEIR requires the Applicant, in consultation with the CDFW, to prepare a
Burrowing Owl Relocation Plan if avoidance of burrowing owls or their burrows is not
possible. This condition is appropriate if the final mitigation measure adopted by the
City clarifies that the Applicant’s Burrowing Owl Relocation Plan must be approved by
the CDFW prior to any ground-disturbing activities.
Mitigation Plan
The DSEIR defers critical analysis of the mitigation needed to mitigate the Project’s
potentially significant impacts to burrowing owls. Specifically, it defers identifying the
compensatory mitigation ratio; acceptable mitigation location and mechanism (e.g.,
habitat acquisition, purchase of credits at a mitigation bank, in-lieu fee, etc.); site
protection methods; financial assurances; performance standards; and monitoring
requirements. Instead, the DSEIR proposes to allow these critical mitigation components
to be established in a subsequent Burrowing Owl Mitigation Plan, which would be
reviewed and accepted by CDFW and the City prior to the first ground-disturbing
activities, but would not be presented to the public prior to Project approval. This
effectively robs the public from being able to submit comments on fundamental aspects
of the mitigation strategy. This is extremely important because neither the CDFW nor
the City has an effective oversight approach that ensures compensatory mitigation is
occurring.76
The DSEIR fails to identify a mitigation ratio, and instead proposes to allow CDFW to
approve a habitat compensation ratio following Project approval. CDFW’s Staff Report
on Burrowing Owl Mitigation indicates that a ratio of at least 1:1 is required to mitigate
impacts to burrowing owl habitat. However, a 1:1 ratio is not likely to be sufficient to
mitigate impacts below a level of significance in this case due to the rapid decline of the
Camp Parks population and the limited availability of compensation habitat to support
that population. Accordingly, mitigation imposed by the City should require adherence
75 California Department of Fish and Game. 2012 Mar 7. Staff Report on Burrowing Owl Mitigation. p. 9.
76 Burrowing Owl Preservation Society. 2017. Burrowing Owl Mitigation in California. 43 pp.
AB
Page 55 of 96
A3
CONT
18
to the regional-specific Eastern Alameda County Conservation Strategy (“EACCS”).
The EACCS requires compensatory mitigation for impacts to burrowing owl habitat that
is within 0.5 mile of a burrowing owl nest used within the previous three years. In
addition, the EACCS establishes a standardized mitigation ratio of 3:1 (3.5:1 if the
mitigation site is in a different core area).77 As a result, the City needs to establish the
mitigation ratio required for the Project, and it cannot assume that a ratio less than 3:1
would mitigate impacts to a less-than-significant level unless it provides scientific
analysis justifying that determination. Because the DSEIR does not contain mitigation
that adheres to the standards in the EACCS, and because the DSEIR fails to ensure that
mitigation would have any benefit to the Camp Parks burrowing owl population, the
Project’s impacts to the burrowing owl remain potentially significant.
Special-Status Bats
The DSEIR proposes the following mitigation for potentially significant impacts to
special-status bat species:
Pre-removal bat surveys of the existing on-site building shall occur no more than
30 days before its removal. If bats are found, then a qualified biologist shall
develop an appropriate relocation plan consistent with USFWS, CDFW, and East
Alameda County Conservation Strategy standards and policies.
These measures do not ensure Project impacts are mitigated to a less-than-significant
level.
The DSEIR fails to identify the survey techniques that should be implemented for the
pre-removal surveys. This is important for three reasons. First, bat detection often
requires specialized techniques, and a technique that is effective for one species may be
completely ineffective for other species.78 Second, pallid bats and Townsend’s big-eared
bats are known to be extremely sensitive to human disturbance.79 For example,
Townsend’s big-eared bats are so sensitive to human disturbance that simple entry into a
maternity roost can cause the colony to abandon the roost (which contributes to
population declines).80 As a result, pre-removal surveys may have a significant impact
on bats if appropriate techniques are not used. Third, the DSEIR fails to establish
minimum qualifications for the biologist conducting the pre-removal surveys. As a
result, the City has no basis for assuming the surveys would be effective and would avoid
disturbance to roost sites.
77 ICF International. 2010. Final Draft East Alameda County Conservation Strategy. Prepared for East
Alameda County Conservation Strategy Steering Committee. October 2010. p. 3-65 and Table 3-10.
78 Western Bat Working Group. 2005 (Update). Species Accounts. Available at: <http://wbwg.org/western-
bat-species/>.
79 Bureau of Land Management. 2005. Final environmental impact report and statement for the West
Mojave Plan: a habitat conservation plan and California desert conservation area plan amendment. Moreno
Valley (CA): U.S. Dept. of the Interior, Bureau of Land Management, California Desert District, Appendix
S: Species Accounts, Pallid Bat, p. 4 and Townsend’s Big-Eared Bat, p. 4.
80 Western Bat Working Group. 2005 (Update). Species Accounts. Available at: <http://wbwg.org/western-
bat-species/>.
AB
Page 56 of 96
A3
CONT
19
The mitigation measure requires a qualified biologist to develop an appropriate relocation
plan consistent with USFWS, CDFW, and East Alameda County Conservation Strategy
standards and policies. However, the DSEIR does not cite or otherwise identify those
standards and policies, nor am I aware that such standards and policies exist (the EACCS
does not include any for bat relocation).
Suitable roost sites are the limiting factor for most bat populations.81 The DSEIR does
not require the Applicant to provide replacement roosts as compensation for impacts to
potential roosts at the Project site. Therefore, even if the bats are properly excluded from
the existing on-site building, they may not have a suitable alternate roost in the vicinity,
and the local population may be extinguished.82 This constitutes a potentially significant
impact that remains unmitigated.
Wetlands
Mitigation Measure BIO-3a requires the Applicant to complete an updated wetland
delineation to determine if the wetlands at the Project are subject to jurisdiction under
Section 404 of the Clean Water Act. The DSEIR does not identify whether the
Applicant’s subsequent conclusions pertaining to the jurisdictional status of the wetlands
would be verified by the Army Corp of Engineers (“USACE”).
Mitigation Measure BIO-3b requires the Applicant to acquire appropriate permits under
Section 404 of the Clean Water Act from the USACE if the wetlands are determined to
be subject to USACE jurisdiction, and to obtain Section 401 certification from the
Regional Water Quality Control Board (“RWQCB”). It further requires the Applicant to
prepare a wetland mitigation plan that is approved by the USACE and RWQCB.
According to the DSEIR, the wetland mitigation plan shall meet the following
“standards”:
A mitigation plan shall be prepared that will establish suitable compensatory
mitigation based on the concept of no net loss of wetland habitat values or
acreages, to the satisfaction of the regulatory agencies. Specifically, a wetland
mitigation plan shall be developed and implemented that includes creation,
restoration, and/or enhancement of off-site wetlands prior to project ground
disturbance. Mitigation areas shall be established in perpetuity through
dedication of a conservation easement (or similar mechanism) to an approved
environmental organization and payment of an endowment for the long-term
management of the site.83
81 Ibid.
82 Bureau of Land Management. 2005. Final environmental impact report and statement for the West
Mojave Plan: a habitat conservation plan and California desert conservation area plan amendment. Moreno
Valley (CA): U.S. Dept. of the Interior, Bureau of Land Management, California Desert District, Appendix
S: Species Accounts, Pallid Bat, p. 4.
83 DSEIR, p. 3.2-22.
AB
Page 57 of 96
A3
CONT
20
The DSEIR concludes these actions would reduce Project impacts to wetlands to a less-
than-significant level. There are two crucial reasons why the City does not have the basis
for this conclusion.
First, the DSEIR impermissibly defers analysis and critical aspects of the wetlands
mitigation strategy. Under CEQA, the City is obligated to identify the specific mitigation
needed to mitigate Project impacts to less-than-significant levels. This includes the
specific mitigation strategy (e.g., creation, restoration, or enhancement), mitigation ratio,
monitoring program, and performance standards and that will be implemented to ensure
the Project would have less-than-significant impacts on the environment (i.e.,
independent of analysis conducted by the USACE and RWQCB designed to ensure
compliance with state and federal wetland regulations).
Contrary to what the DSEIR suggests, the City cannot rely on deferred mitigation and the
permitting requirements of other agencies to conclude impacts to wetlands would be
mitigated to less-than-significant levels. For example, in its comment letter to the lead
agency for another project, the RWQCB recently stated:
It is inappropriate to rely upon agency regulations for determining that impacts
will be at insignificant levels…Water Board staff strongly discourages the
County [of Kern] from attempting to defer to the later preparation of Waste
Discharge Requirements (WDRs) permits to address the above issues. Such an
approach would constitute deferment of mitigation. In the event that this occurs,
the Water Board may require substantial modifications to the Project during the
course of permitting review to ensure all water quality impacts [are] adequately
mitigated. Water Board staff encourages the Project proponents to initiate
detailed plans early in the process to allow for full and adequate review of the
Project to address the above issues. This planning should be concurrent with the
CEQA process as opposed to a sequential permitting approach.84
Second, compliance with regulatory permits provides no assurances that Project impacts
to jurisdictional wetlands would be less-than-significant. To the contrary, numerous
studies have demonstrated that many compensatory mitigation projects permitted under
Sections 401 and 404 of the Clean Water Act are not achieving the goal of “no overall net
loss” of wetland acres and functions.85 For example, Ambrose and Lee (2004)
concluded: “the Section 401 program has failed to achieve the goal of no net loss of
84 Kern County. 2011 Oct. Final Environmental Impact Report: RE Distributed Solar Projects, Chapter 7-4
(part 1), comment letter 8.
85 National Research Council. 2001. Compensating for wetland losses under the Clean Water Act. National
Research Committee on Mitigating Wetland Losses. National Academy Press, Washington DC, USA.
Available at: <https://www.nap.edu/catalog/10134/compensating-for-wetland-losses-under-the-clean-
water-act>. See also Society of Wetland Scientists (and references therein). 2000. Position Paper on
Performance Standards for Wetland Restoration and Creation. 4 pp. See also Environmental Law Institute.
2004. Measuring Mitigation: A Review of the Science for Compensatory Mitigation Performance
Standards. Report prepared for the US Environmental Protection Agency. 271 pp. Available at:
<http://www.forest-trends.org/documents/files/doc_609.pdf>. See also Kihslinger RL. 2008. Success of
Wetland Mitigation Projects. 2008. National Wetlands Newsletter 30(2):14-16. Available at:
<http://www.tetonwyo.org/DocumentCenter/View/3309>.
AB
Page 58 of 96
A3
CONT
21
habitat functions, values and services.”86 The National Academy of Sciences (2001)
conducted a comprehensive review of compensatory wetland mitigation projects in the
U.S. and found that the national “no net loss” goal is not being met because: (a) there is
little monitoring of permit compliance, and (b) the permit conditions commonly used to
establish mitigation success do not assure the establishment of wetland functions.87
Ambrose et al. (2007) derived similar results after examining 143 projects permitted by
the California State Water Resources Control Board. Specifically, they concluded: (a)
only 46% of the projects fully complied with all permit conditions, and (b) very few
wetland mitigation projects were successful, especially from the ecological perspective.88
Several other studies have shown that the regulatory agencies are not ensuring the
success of wetland mitigation projects.89 Most notably, a 2005 report issued by the
United States Government Accountability Office concluded that: “the Corps of Engineers
does not have an effective oversight approach to ensure that compensatory mitigation is
occurring.”90
In summary, the DSEIR improperly defers analysis and concludes future permits issued
by other agencies would ensure Project impacts to wetlands would be less-than-
significant. However, substantial evidence shows that those permits have been
ineffective in mitigating impacts to wetlands. Thus, the sole basis for the City’s
conclusion of insignificance is not supported by evidence.
86 Ambrose RF, SF Lee. 2004. Guidance Document for Compensatory Mitigation Projects Permitted Under
Clean Water Act Section 401 by the Los Angeles Regional Quality Control Board. p. 8. Available at:
<https://www.researchgate.net/publication/237587967_Guidance_Document_for_Compensatory_Mitigatio
n_Projects_Permitted_Under_Clean_Water_Act_Section_401_by_the_Los_Angeles_Regional_Quality_Co
ntrol_Board>.
87 National Research Council. 2001. Compensating for wetland losses under the Clean Water Act. National
Research Committee on Mitigating Wetland Losses. National Academy Press, Washington DC, USA.
88 Ambrose RF, JL Callaway, SF Lee. 2007. An Evaluation of Compensatory Mitigation Projects Permitted
Under Clean Water Act Section 401 by the California State Water Resources Control Board, 1991-2002.
xxiv + 396 pp. Available at:
<https://www.waterboards.ca.gov/water_issues/programs/cwa401/docs/mitigation_finalreport_full081307.
pdf>.
89 Kihslinger RL. 2008. Success of Wetland Mitigation Projects. 2008. National Wetlands Newsletter
30(2):14-16. See also Environmental Law Institute. 2004. Measuring Mitigation: A Review of the Science
for Compensatory Mitigation Performance Standards. Report prepared for the US Environmental
Protection Agency. 271 pp.
90 United States Government Accountability Office. 2005. Corps of Engineers Does Not Have an Effective
Oversight Approach to Ensure That Compensatory Mitigation Is Occurring. Report to the Ranking
Democratic Member, Committee on Transportation and Infrastructure, House of Representatives. GAO-05-
898 Wetlands Protection. Available at: <http://www.gao.gov/assets/250/247675.pdf>.
AB
Page 59 of 96
A3
CONT
22
This concludes my comments on the DSEIR. Please contact me if you would like to
discuss any issues raised by these comments.
Sincerely,
Scott Cashen, M.S.
Senior Biologist
AB
Page 60 of 96
A3
CONT
EXHIBIT B
AB
Page 61 of 96
Cashen, Curriculum Vitae 1
Scott Cashen, M.S.
Senior Wildlife Ecologist
Scott Cashen has 25 years of professional experience in natural resources
management. During that time he has worked as a field biologist, forester, environmental
consultant, and instructor of Wildlife Management. Mr. Cashen focuses on
CEQA/NEPA compliance issues, endangered species, scientific field studies, and other
topics that require a high level of scientific expertise.
Mr. Cashen has knowledge and experience with numerous taxa, ecoregions, biological
resource issues, and environmental regulations. As a biological resources expert, Mr.
Cashen is knowledgeable of the various agency-promulgated guidelines for field surveys,
impact assessments, and mitigation. Mr. Cashen has led field investigations on several
special-status species, including ones focusing on the yellow-legged frog, red-legged
frog, desert tortoise, steelhead, burrowing owl, California spotted owl, northern goshawk,
willow flycatcher, Peninsular bighorn sheep, red panda, and various forest carnivores.
Mr. Cashen is a recognized expert on the environmental impacts of renewable energy
development. He has been involved in the environmental review process of over 80
solar, wind, biomass, and geothermal energy projects. Mr. Cashen’s role in this capacity
has encompassed all stages of the environmental review process, from initial document
review through litigation support. Mr. Cashen has provided expert witness testimony on
several of the Department of the Interior’s “fast-tracked” renewable energy projects. His
testimony on those projects helped lead agencies develop project alternatives and
mitigation measures to reduce environmental impacts associated with the projects.
Mr. Cashen was a member of the independent scientific review panel for the Quincy
Library Group project, the largest community forestry project in the United States. As a
member of the panel, Mr. Cashen was responsible for advising the U.S. Forest Service on
its scientific monitoring program, and for preparing a final report to Congress describing
the effectiveness of the Herger-Feinstein Forest Recovery Act of 1998.
AREAS OF EXPERTISE
•CEQA, NEPA, and Endangered Species Act compliance issues
•Comprehensive biological resource assessments
•Endangered species management
•Renewable energy development
•Scientific field studies, grant writing and technical editing
EDUCATION
M.S. Wildlife and Fisheries Science - The Pennsylvania State University (1998)
Thesis: Avain Use of Restored Wetlands in Pennsylvania
B.S. Resource Management - The University of California, Berkeley (1992)
AB
Page 62 of 96
B1
Cashen, Curriculum Vitae 2
PROFESSIONAL EXPERIENCE
Litigation Support / Expert Witness
Mr. Cashen has served as a biological resources expert for over 100 projects subject to
environmental review under the California Environmental Quality Act (CEQA) and/or
the National Environmental Policy Act (NEPA). As a biological resources expert, Mr.
Cashen reviews CEQA/NEPA documents and provides his clients with an assessment of
biological resource issues. He then submits formal comments on the scientific and legal
adequacy of the project’s environmental documents (e.g., Environmental Impact
Statement). If needed, Mr. Cashen conducts field studies to generate evidence for legal
testimony, or he can obtain supplemental testimony from his deep network of species-
specific experts. Mr. Cashen has provided written and oral testimony to the California
Energy Commission, California Public Utilities Commission, and U.S. district courts.
His clients have included law firms, non-profit organizations, and citizen groups.
REPRESENTATIVE EXPERIENCE
Solar Energy Geothermal Energy
•Abengoa Mojave Solar Project •Casa Diablo IV Geothermal Project
•Avenal Energy Power Plant •East Brawley Geothermal
•Beacon Solar Energy Project •Mammoth Pacific 1 Replacement
•Blythe Solar Power Project •Orni 21 Geothermal Project
•Calico Solar Project •Western GeoPower Plant
•California Flats Solar Project Wind Energy
•Calipatria Solar Farm II •Catalina Renewable Energy Project
•Carrizo Energy Solar Farm •Ocotillo Wind Energy Project
•Catalina Renewable Energy Project •SD County Wind Energy Ordinance
•Fink Road Solar Farm •Searchlight Wind Project
•Genesis Solar Energy Project •Shu’luuk Wind Project
•Heber Solar Energy Facility •Tres Vaqueros Repowering Project
•Imperial Valley Solar Project •Tule Wind Project
•Ivanpah Solar Electric Generating •Vasco Winds Relicensing Project
•Maricopa Sun Solar Complex Biomass Facilities
•McCoy Solar Project •CA Ethanol Project
•Mt. Signal and Calexico Solar •Colusa Biomass Project
•Panoche Valley Solar •Tracy Green Energy Project
•San Joaquin Solar I & II Other
•San Luis Solar Project •DRECP
•Stateline Solar Project •Carnegie SVRA Expansion Project
•Solar Gen II Projects •Lakeview Substation Project
•SR Solis Oro Loma •Monterey Bay Shores Ecoresort
•Vestal Solar Facilities •Phillips 66 Rail Spur
•Victorville 2 Power Project •Valero Benecia Crude By Rail
•Willow Springs Solar •World Logistics Center
AB
Page 63 of 96
B1
CONT
Cashen, Curriculum Vitae 3
Project Management
Mr. Cashen has managed several large-scale wildlife, forestry, and natural resource
management projects. Many of the projects have required hiring and training field crews,
coordinating with other professionals, and communicating with project stakeholders. Mr.
Cashen’s experience in study design, data collection, and scientific writing make him an
effective project manager, and his background in several different natural resource
disciplines enable him to address the many facets of contemporary land management in a
cost-effective manner.
REPRESENTATIVE EXPERIENCE
Wildlife Studies
•Peninsular Bighorn Sheep Resource Use and Behavior Study: (CA State Parks)
•“KV” Spotted Owl and Northern Goshawk Inventory: (USFS, Plumas NF)
•Amphibian Inventory Project: (USFS, Plumas NF)
•San Mateo Creek Steelhead Restoration Project: (Trout Unlimited and CA Coastal
Conservancy, Orange County)
•Delta Meadows State Park Special-Status Species Inventory: (CA State Parks,
Locke)
Natural Resources Management
•Mather Lake Resource Management Study and Plan – (Sacramento County)
•Placer County Vernal Pool Study – (Placer County)
•Weidemann Ranch Mitigation Project – (Toll Brothers, Inc., San Ramon)
•Ion Communities Biological Resource Assessments – (Ion Communities,
Riverside and San Bernardino Counties)
•Del Rio Hills Biological Resource Assessment – (The Wyro Company, Rio Vista)
Forestry
•Forest Health Improvement Projects – (CalFire, SD and Riverside Counties)
•San Diego Bark Beetle Tree Removal Project – (SDG&E, San Diego Co.)
•San Diego Bark Beetle Tree Removal Project – (San Diego County/NRCS)
•Hillslope Monitoring Project – (CalFire, throughout California)
AB
Page 64 of 96
B1
CONT
Cashen, Curriculum Vitae 4
Biological Resources
Mr. Cashen has a diverse background with biological resources. He has conducted
comprehensive biological resource assessments, habitat evaluations, species inventories,
and scientific peer review. Mr. Cashen has led investigations on several special-status
species, including ones focusing on the foothill yellow-legged frog, mountain yellow-
legged frog, desert tortoise, steelhead, burrowing owl, California spotted owl, northern
goshawk, willow flycatcher, Peninsular bighorn sheep, red panda, and forest carnivores.
REPRESENTATIVE EXPERIENCE
Biological Assessments/Biological Evaluations (“BA/BE”)
•Aquatic Species BA/BE – Reliable Power Project (SF Public Utilities
Commission)
•Terrestrial Species BA/BE – Reliable Power Project (SF Public Utilities
Commission)
•Management Indicator Species Report – Reliable Power Project (SF Public Utilities
Commission)
•Migratory Bird Report – Reliable Power Project (SF Public Utilities Commission)
•Terrestrial and Aquatic Species BA – Lower Cherry Aqueduct (SF Public Utilities
Commission)
•Terrestrial and Aquatic Species BE – Lower Cherry Aqueduct (SF Public Utilities
Commission)
•Terrestrial and Aquatic Species BA/BE – Public Lands Lease Application
(Society for the Conservation of Bighorn Sheep)
•Terrestrial and Aquatic Species BA/BE – Simon Newman Ranch (The Nature
Conservancy)
Avian
•Study design and Lead Investigator - Delta Meadows State Park Special-Status
Species Inventory (CA State Parks: Locke)
•Study design and lead bird surveyor - Placer County Vernal Pool Study (Placer
County: throughout Placer County)
•Surveyor - Willow flycatcher habitat mapping (USFS: Plumas NF)
•Independent surveyor - Tolay Creek, Cullinan Ranch, and Guadacanal Village
restoration projects (Ducks Unlimited/USGS: San Pablo Bay)
•Study design and Lead Investigator - Bird use of restored wetlands research
(Pennsylvania Game Commission: throughout Pennsylvania)
•Study design and surveyor - Baseline inventory of bird species at a 400-acre site
in Napa County (HCV Associates: Napa)
AB
Page 65 of 96
B1
CONT
Cashen, Curriculum Vitae 5
•Surveyor - Baseline inventory of bird abundance following diesel spill (LFR
Levine-Fricke: Suisun Bay)
•Study design and lead bird surveyor - Green Valley Creek Riparian Restoration
Site (City of Fairfield: Fairfield, CA)
•Surveyor - Burrowing owl relocation and monitoring (US Navy: Dixon, CA)
•Surveyor - Pre-construction burrowing owl surveys (various clients: Livermore,
San Ramon, Rio Vista, Napa, Victorville, Imperial County, San Diego County)
•Surveyor - Backcountry bird inventory (National Park Service: Eagle, Alaska)
•Lead surveyor - Tidal salt marsh bird surveys (Point Reyes Bird Observatory:
throughout Bay Area)
•Surveyor – Pre-construction surveys for nesting birds (various clients and
locations)
Amphibian
•Crew Leader - Red-legged frog, foothill yellow-legged frog, and mountain
yellow-legged frog surveys (USFS: Plumas NF)
•Surveyor - Foothill yellow-legged frog surveys (PG&E: North Fork Feather
River)
•Surveyor - Mountain yellow-legged frog surveys (El Dorado Irrigation District:
Desolation Wilderness)
•Crew Leader - Bullfrog eradication (Trout Unlimited: Cleveland NF)
Fish and Aquatic Resources
•Surveyor - Hardhead minnow and other fish surveys (USFS: Plumas NF)
•Surveyor - Weber Creek aquatic habitat mapping (El Dorado Irrigation District:
Placerville, CA)
•Surveyor - Green Valley Creek aquatic habitat mapping (City of Fairfield:
Fairfield, CA)
•GPS Specialist - Salmonid spawning habitat mapping (CDFG: Sacramento River)
•Surveyor - Fish composition and abundance study (PG&E: Upper North Fork
Feather River and Lake Almanor)
•Crew Leader - Surveys of steelhead abundance and habitat use (CA Coastal
Conservancy: Gualala River estuary)
•Crew Leader - Exotic species identification and eradication (Trout Unlimited:
Cleveland NF)
AB
Page 66 of 96
B1
CONT
Cashen, Curriculum Vitae 6
Mammals
•Principal Investigator – Peninsular bighorn sheep resource use and behavior study
(California State Parks: Freeman Properties)
•Scientific Advisor –Study on red panda occupancy and abundance in eastern
Nepal (The Red Panda Network: CA and Nepal)
•Surveyor - Forest carnivore surveys (University of CA: Tahoe NF)
•Surveyor - Relocation and monitoring of salt marsh harvest mice and other small
mammals (US Navy: Skagg’s Island, CA)
•Surveyor – Surveys for Monterey dusky-footed woodrat. Relocation of woodrat
houses (Touré Associates: Prunedale)
Natural Resource Investigations / Multiple Species Studies
•Scientific Review Team Member – Member of the scientific review team
assessing the effectiveness of the US Forest Service’s implementation of the
Herger-Feinstein Quincy Library Group Act.
•Lead Consultant - Baseline biological resource assessments and habitat mapping
for CDF management units (CDF: San Diego, San Bernardino, and Riverside
Counties)
•Biological Resources Expert – Peer review of CEQA/NEPA documents (various
law firms, non-profit organizations, and citizen groups)
•Lead Consultant - Pre- and post-harvest biological resource assessments of tree
removal sites (SDG&E: San Diego County)
•Crew Leader - T&E species habitat evaluations for Biological Assessment in
support of a steelhead restoration plan (Trout Unlimited: Cleveland NF)
•Lead Investigator - Resource Management Study and Plan for Mather Lake
Regional Park (County of Sacramento: Sacramento, CA)
•Lead Investigator - Biological Resources Assessment for 1,070-acre Alfaro Ranch
property (Yuba County, CA)
•Lead Investigator - Wildlife Strike Hazard Management Plan (HCV Associates:
Napa)
•Lead Investigator - Del Rio Hills Biological Resource Assessment (The Wyro
Company: Rio Vista, CA)
•Lead Investigator – Ion Communities project sites (Ion Communities: Riverside
and San Bernardino Counties)
•Surveyor – Tahoe Pilot Project: Validation of California’s Wildlife Habitat
Relationships (CWHR) Model (University of California: Tahoe NF)
AB
Page 67 of 96
B1
CONT
Cashen, Curriculum Vitae 7
Forestry
Mr. Cashen has five years of experience working as a consulting forester on projects
throughout California. Mr. Cashen has consulted with landowners and timber operators
on forest management practices; and he has worked on a variety of forestry tasks
including selective tree marking, forest inventory, harvest layout, erosion control, and
supervision of logging operations. Mr. Cashen’s experience with many different natural
resources enable him to provide a holistic approach to forest management, rather than just
management of timber resources.
REPRESENTATIVE EXPERIENCE
•Lead Consultant - CalFire fuels treatment projects (SD and Riverside Counties)
•Lead Consultant and supervisor of harvest activities – San Diego Gas and Electric
Bark Beetle Tree Removal Project (San Diego)
•Crew Leader - Hillslope Monitoring Program (CalFire: throughout California)
•Consulting Forester – Forest inventories and timber harvest projects (various
clients throughout California)
Grant Writing and Technical Editing
Mr. Cashen has prepared and submitted over 50 proposals and grant applications.
Many of the projects listed herein were acquired through proposals he wrote. Mr.
Cashen’s clients and colleagues have recognized his strong scientific writing skills and
ability to generate technically superior proposal packages. Consequently, he routinely
prepares funding applications and conducts technical editing for various clients.
PERMITS
U.S. Fish and Wildlife Service Section 10(a)(1)(A) Recovery Permit for the Peninsular
bighorn sheep
PROFESSIONAL ORGANIZATIONS / ASSOCIATIONS
The Wildlife Society
Cal Alumni Foresters
Mt. Diablo Audubon Society
OTHER AFFILIATIONS
Scientific Advisor and Grant Writer – The Red Panda Network
Scientific Advisor – Mt. Diablo Audubon Society
Grant Writer – American Conservation Experience
AB
Page 68 of 96
B1
CONT
Cashen, Curriculum Vitae 8
TEACHING EXPERIENCE
Instructor: Wildlife Management - The Pennsylvania State University, 1998
Teaching Assistant: Ornithology - The Pennsylvania State University, 1996-1997
PUBLICATIONS
Gutiérrez RJ, AS Cheng, DR Becker, S Cashen, et al. 2015. Legislated collaboration in a
conservation conflict: a case study of the Quincy Library group in California, USA.
Chapter 19 in: Redpath SR, et al. (eds). Conflicts in Conservation: Navigating Towards
Solutions. Cambridge Univ. Press, Cambridge, UK.
Cheng AS, RJ Gutiérrez RJ, S Cashen, et al. 2016. Is There a Place for Legislating Place-
Based Collaborative Forestry Proposals?: Examining the Herger-Feinstein Quincy
Library Group Forest Recovery Act Pilot Project. Journal of Forestry.
AB
Page 69 of 96
B1
CONT
EXHIBIT C
AB
Page 70 of 96
1
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swape.com
March 15, 2018
Collin McCarthy
Adams Broadwell Joseph & Cardozo
601 Gateway Boulevard, Suite 1000
South San Francisco, CA 94080
Subject: Comments on the IKEA Retail Center Project
Dear Mr. McCarthy,
We have reviewed the January 2018 Draft Supplemental Environmental Impact Report (DEIR) for the
IKEA Retail Center Project (“Project”) located in the City of Dublin (“City”). The Project proposes to
develop up to 432,099 square feet of commercial uses on 27.45 acres. The Project would be anchored
by an IKEA store of up to 339,099 square feet and would feature up to 93,000 square feet of lifestyle
retail-restaurant uses. The IKEA store would consist of a two-story building located over a two-level
parking structure with the lower level partially below grade. The building would stand approximately 61
feet above finished grade. A recycling and refuse collection area, trash compactor, and emergency diesel
generator would also be located at the rear of the store. A two-bay loading dock for home deliveries
would be located on the south side of the building facing I-580.
Our review concludes that DSEIR fails to adequately evaluate the Project’s Air Quality and Greenhouse
Gas (GHG) impacts. As a result, emissions associated with the construction and operation of the
proposed Project are inadequately addressed. An updated DSEIR should be prepared to adequately
assess and mitigate the potential air quality and GHG impacts the Project may have on the surrounding
environment.
AB
Page 71 of 96
C1
2
Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions
The DEIR relies on emissions calculated from the California Emissions Estimator Model Version
CalEEMod.2016.3.2 ("CalEEMod").1 CalEEMod provides recommended default values based on site
specific information, such as land use type, meteorological data, total lot acreage, project type and
typical equipment associated with project type. If more specific project information is known, the user
can change the default values and input project-specific values, but the California Environmental Quality
Act (CEQA) requires that such changes be justified by substantial evidence.2 Once all of the values are
inputted into the model, the Project's construction and operational emissions are calculated, and
"output files" are generated. These output files disclose to the reader what parameters were utilized in
calculating the Project's air pollutant emissions, and make known which default values were changed as
well as provide a justification for the values selected.3
When we reviewed the Project’s CalEEMod output files, we found that several of the values inputted
into the model were not consistent with information disclosed in the DSEIR. As a result, the Project’s
construction and operational emissions are greatly underestimated. An updated DSEIR should be
prepared to include an updated air quality analysis that adequately evaluates the impacts that
construction and operation of the Project will have on local and regional air quality.
Failure to Account for Material Export During Grading Phase
The Project’s CalEEMod model fails to include the total amount of material anticipated to be exported
during the Grading phase of construction, and as a result, the Project’s construction emissions are
underestimated.
According to the DSEIR, “the proposed project’s grading activities would involve 95,000 cubic yards of
cut and 73,700 cubic yards of fill. Thus, 21,300 cubic yards would be exported off-site” (p. 2-12). These
proposed material export activities will likely produce substantial pollutant emissions, and as a result,
these activities should be included in the Project’s CalEEMod model. However, review of the Project’s
CalEEMod output files demonstrates that none of the material to be exported during grading was
inputted into the model.
Review of the Trips and VMT table within the Project’s CalEEMod output files demonstrates that the
model estimates the Project’s construction-related emissions assuming zero hauling truck trips will
1 CalEEMod Model 2013.2.2 Website Archive, available at: http://www.aqmd.gov/caleemod/download-model-
2013
2 CalEEMod Model 2013.2.2 User’s Guide, pp. 2, 9, available at: http://www.aqmd.gov/docs/default-
source/caleemod/usersguideSept2016.pdf?sfvrsn=6
3 CalEEMod Model 2013.2.2 User’s Guide, pp. 7, 13, available at: http://www.aqmd.gov/docs/default-
source/caleemod/usersguideSept2016.pdf?sfvrsn=6 (A key feature of the CalEEMod program is the “remarks”
feature, where the user explains why a default setting was replaced by a “user defined” value. These remarks are
included in the report.)
AB
Page 72 of 96
C1
CONT
C2
3
occur during the grading phase of construction (Appendix B, pp. 63, pp. 96, pp. 130). Hauling truck trips
within CalEEMod are estimated based on the total amount of material that will be imported or exported
and assumes a single hauling truck can transport 16 cubic yards of material per trip.4 Therefore,
assuming the Project will use 16-cubic-yard hauling trucks, approximately 1,331 hauling truck trips
would be required to haul the soil off site. However, according to the CalEEMod User’s Guide, CalEEMod
calculates the number of hauling truck trips assuming that one hauling truck will have 2 one-way trips
(e.g., a hauling truck importing material will have a loaded arrival trip and an empty return trip, while a
hauling truck exporting material will have an empty arrival trip but a loaded departure trip). 5 Using this
logic, the DSEIR should have modeled the Project’s emissions assuming that there would be a total of
2,662 (2 x 1,331 hauling trips) in order to account for the 2 one-way truck trips. Thus, because the
Project’s CalEEMod model estimated emissions assuming no hauling truck trips would occur during the
grading phase of construction, it is extremely likely that the DSEIR’s CalEEMod model significantly
underestimates the actual emissions that will be generated during construction activities.
This underestimation presents a significant issue, as the inclusion of material export within the model is
necessary to calculate emissions produced from material movement, including truck loading and
unloading, and hauling truck trips.6 Specifically, NOx and fugitive dust emissions are generated as a
result of hauling truck trips. NOx emissions are caused by fuel combustion in mobile heavy-duty diesel
and gasoline-powered equipment and vehicles, while fugitive dust emissions are generated from loading
and unloading material into hauling trucks.7,8 The DSEIR’s failure to include these hauling trips,
therefore, underestimates the NOx and fugitive dust emissions that will be generated by the 2,662
hauling truck trips that will occur during Project construction. It is critical that the Project’s construction-
related emissions are remodeled and estimated with the inclusion of the 2,662 hauling truck trips, as
review of the Project’s CalEEMod output files demonstrates that the Project’s mitigated emissions,
without inclusion of any hauling truck trips, are close to the Bay Area Air Quality Management’s
(BAAQMD) significance threshold for NOx.
Review of the DSEIR’s air quality analysis demonstrates that the Project’s emissions, with
implementation of mitigation, will emit a maximum of approximately 52.44 pounds per day (lbs/day) of
NOx emissions during construction (see excerpt below) (p. 3.4-44 – 3.1-45).
4 “Appendix A: Calculation Details for CalEEMod.” CalEEMod User’s Guide, BREEZE Soft ware and SCAQMD. October
2017, available at: http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p.
17
5 “CalEEMod’s User’s Guide.” SCAQMD, September 2016, available at: http://www.aqmd.gov/docs/default-
source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p.34
6 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default-
source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p. 3, 26.
7 “Construction-Generated Criteria Air Pollutant and Precursor Emissions.” Sacramento Metropolitan Air Quality
Management District, May 2016, available at:
http://airquality.org/LandUseTransportation/Documents/Ch3Construction%20FINAL5-2016.pdf, p. 3-1
8 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default-source/caleemod/01_user-39-s-
guide2016-3-2_15november2017.pdf?sfvrsn=4 , p. 33
AB
Page 73 of 96
C2
CONT
4
As shown above, the Project’s mitigated emissions would result in a maximum daily emission of
approximately 52 lbs/day of NOx, which is approximately 2 pounds below the BAAQMD’s NOx
significance threshold of 54 lbs/day. Given the quantity of hauling truck trips that are needed to export
the 21,300 cubic yards of material from the Project site, it is highly likely that the Project’s NOx
emissions would exceed this threshold if emissions were modeled correctly. As such, we conclude that
the emissions generated during Project construction are underestimated, and as a result, the DSEIR’s air
pollution model should not be relied upon to determine Project significance.
Failure to Assess the Feasibility of Obtaining Tier 4 Interim Equipment
The DSEIR fails to assess the feasibility of obtaining an entire fleet of Tier 4I equipment during Project
construction. The DSEIR’s CalEEMod model proposes to equip all 30 pieces construction equipment with
Tier 4I engines (Appendix B, pp. 53, pp. 86, pp. 119). Due to the limited number of Tier 4I construction
equipment available, the Project should have assessed the feasibility in obtaining engines equipped with
Tier 4I engines for the entire construction fleet. By failing to demonstrate how the Project will actually
comply with this mitigation measure, this measure is unenforceable and thus, the DSEIR cannot claim
the emissions reductions from this measure.
The United States Environmental Protection Agency’s (USEPA) 1998 nonroad engine emission standards
were structured as a three-tiered progression. Tier 1 standards were phased-in from 1996 to 2000 and
Tier 2 emission standards were phased in from 2001 to 2006. Tier 3 standards, which applied to engines
from 37-560 kilowatts (kW) only, were phased in from 2006 to 2008. The Tier 4 emission standards
were introduced in 2004, and were phased in from 2008 to 2015. 9 These tiered emission standards,
however, are only applicable to newly manufactured nonroad equipment. According to the USEPA, “if
products were built before EPA emission standards started to apply, they are generally not affected by
9 Emission Standards, Nonroad Diesel Engines, available at:
https://www.dieselnet.com/standards/us/nonroad.php#tier3
AB
Page 74 of 96
C2
CONT
C3
5
the standards or other regulatory requirements.”10 Therefore, pieces of equipment manufactured prior
to 2000 are not required to adhere to Tier 2 emission standards, and pieces of equipment manufactured
prior to 2006 are not required to adhere to Tier 3 emission standards. Construction equipment often
lasts more than 30 years; as a result, Tier 1 equipment and non-certified equipment are currently still in
use.11 It is estimated that of the two million diesel engines currently used in construction, 31 percent
were manufactured before the introduction of emissions regulations.12
Although Tier 4I engines are currently being produced and installed in new off-road construction
equipment, the vast majority of existing diesel off-road construction equipment in California is not
equipped with either Tier 3 or Tier 4 Final engines.13 In a 2010 white paper, the California Industry Air
Quality Coalition estimated that approximately 7% and less than 1% of all off-road heavy duty diesel
equipment in California was equipped with Tier 2 and Tier 3 engines, respectively.14 Similarly, based on
information and data provided in the San Francisco Clean Construction Ordinance Implementation Guide
for San Francisco Public Projects, the availability of Tier 3 equipment is extremely limited. In 2014, 25%
of all off-road equipment in the state of California were equipped with Tier 2 engines, approximately
12% were equipped with Tier 3 engines, approximately 18% were equipped with Tier 4 Interim engines,
and only 4% were equipped with Tier 4 Final engines (see excerpt below).15
10 “Frequently Asked Questions from Owners and Operators of Nonroad Engines, Vehicles, and Equipment
Certified to EPA Standards.” United States Environmental Protection Agency, August 2012. Available at:
http://www.epa.gov/oms/highway-diesel/regs/420f12053.pdf
11 “Best Practices for Clean Diesel Construction.” Northeast Diesel Collaborative, August 2012. Available at:
http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf
12 Northeast Diesel Collaborative Clean Construction Workgroup, available at:
http://northeastdiesel.org/construction.html
13 California Industry Air Quality Coalition White Paper, p. 3, available at: http://www.agc-
ca.org/uploadedFiles/Member_Services/Regulatory-Advocacy-Page-PDFs/White_Paper_CARB_OffRoad.pdf
14 "White Paper: An Industry Perspective on the California Air Resources Board Proposed Off-Road Diesel
Regulations." Construction Industry Air Quality Coalition, available at: http://www.agc-
ca.org/uploadedFiles/Member_Services/Regulatory-Advocacy-Page-PDFs/White_Paper_CARB_OffRoad.pdf
15 “San Francisco Clean Construction Ordinance Implementation Guide for San Francisco Public Projects.” August
2015, available at:
https://www.sfdph.org/dph/files/EHSdocs/AirQuality/San_Francisco_Clean_Construction_Ordinance_2015.pdf , p.
6
AB
Page 75 of 96
C3
CONT
6
As demonstrated in the figure above, Tier 4I equipment only accounts for 18% of all off-road equipment
currently available in the state of California. Thus, by stating that the Project proposes to use Tier 4I
equipment during construction, the DSEIR is relying on obtaining an entire fleet of construction
equipment that only accounts for 18% of all off-road equipment currently available in the state of
California. Therefore, by failing to evaluate the feasibility of implementing Tier 4I mitigation into the
Project’s construction phases, the Project’s construction emissions are underestimated. Thus, we find
the conclusions made within the DSEIR to be incorrect and should not be relied upon to determine
Project significance.
Failure to Include All Daily Vehicle Trips
Review of the Project’s CalEEMod output files demonstrates that the model underestimated the number
of vehicle trips expected to occur during operation of the proposed Project. When we compare the total
number of vehicle trips estimated in the Project’s CalEEMod output files to the vehicle estimates found
in the Air Quality and Greenhouse Gas Supporting Document, we find that the model underestimated
the number of operational vehicle trips per day. As a result, the Project’s operational emissions are
underestimated and should not be relied upon to determine Project significance.
According to the Air Quality and Greenhouse Gas Supporting Document, which can be found in
Appendix B, the Project would generate a total of 16,898 vehicle trips per day (see excerpt below) (Table
10, Appendix B, p. 29).
As you can see in the table above, Table 10 claims that the Project would have a total of 16,840 trips per
day. This, however, this is incorrect. When the Total IKEA Trips, Retail Center Passenger Cars, Retail
Center Light-heavy Duty Trucks, and Retail Center Heavy-heavy Duty Trucks are added together, the
Project would actually generate a total of 16,898 trips per day (6,010 + 10,830 + 50 + 8 = 16,898). Table
AB
Page 76 of 96
C3
CONT
C4
7
10 fails to include the 58 truck trips generated by the retail center when calculating the total number of
vehicle trips. Therefore, to remain consistent with the daily vehicle trip estimates provided by the Air
Quality and Greenhouse Gas Supporting Document, the CalEEMod model should have estimated
emissions assuming that the IKEA building would generate a total of 6,010 trips per day and that the
proposed retail/restaurant land use would generate a total of 10,888 trips per day, for a total of 16,898
daily trips. Review of the DSEIR’s CalEEMod model, however, demonstrates that this was not the case
(see excerpt below) (Appendix B, pp. 77, pp. 110, pp. 144).
As you can see in the excerpt above, the DSEIR’s CalEEMod model underestimates the number of daily
trips the Project will generate by approximately 60 trips per day, or approximately 21,900 vehicle trips
per year.
By underestimating the total number of vehicle trips expected to occur during Project operation, the
DSEIR underestimates the Project’s operational mobile-source emissions. According to Appendix A of
the CalEEMod User’s Guide, CalEEMod uses the average daily trip rate when estimating a proposed
project’s annual air pollutant emissions.16 Therefore, if the DSEIR underestimates the number of daily
vehicle trips expected to occur throughout operation, then the proposed Project’s operational mobile-
source emissions are also underestimated. It is critical that the Project’s operational emissions are
modeled assuming a total of 16,898 daily trips, rather than a total of 16,840 daily trips will occur, as
review of the Project’s CalEEMod output files demonstrates that the Project’s mitigated emissions are
close to the BAAQMD’s significance threshold for operational NOx emissions (see excerpt below)
(Appendix A, pp. 61).
16 “CalEEMod User’s Guide Appendix A: Calculation Details for CalEEMod.” CAPCOA, September 2016, available at:
http://www.aqmd.gov/docs/default-source/caleemod/upgrades/2016.3/02_appendix-a2016-3-1.pdf?sfvrsn=2, p.
19
AB
Page 77 of 96
C4
CONT
8
As shown above, the Project’s mitigated emissions would result in a maximum daily emission of
approximately 46 lbs/day of NOx, which is approximately 8 pounds below the BAAQMD’s NOx
significance threshold of 54 lbs/day. Seeing as the DSEIR’s CalEEMod model underestimates the number
of operational daily vehicle trips by 60 trips per day or 21,900 trips per year, it is possible that the
Project’s NOx emissions would exceed this threshold if emissions were modeled correctly. As a result,
we find the DSEIR’s CalEEMod model to be unreliable and should not be relied upon to determine
Project significance. An updated air quality analysis must be prepared in an updated DSEIR that
adequately evaluates the Project’s air quality impact, and additional mitigation measures should be
implemented, if necessary.
Greenhouse Gas
Failure to Adequately Determine Significance of Greenhouse Gas Impacts
The DSEIR determines the significance of the Project’s GHG impact for the Project’s opening year in 2020
by demonstrating compliance with the City’s Climate Action Plan (CAP), which has a GHG reduction
target of 15 percent below 2010 levels by 2020 (p. 3.1-60). Additionally, the DSEIR states that because
the CAP was adopted prior to Assembly Bill 197 (AB 197) and Senate Bill 32 (SB 32) being codified into
law, the Project’s GHG impact was also evaluated by calculating the Project’s emissions in the year 2030
and comparing the emissions to year 2000 levels, in order to determine if the Project would achieve a
GHG reduction of 40 percent below 1990 levels by 2030, as mandated in AB 197 and SB 32 (p. 3.1-60 –
3.1-61). Review of the DSEIR’s GHG analysis demonstrates that: (1) the Project fails to demonstrate
compliance with the City’s CAP and; (2) the DSEIR’s method of using a statewide GHG reduction goal as a
CEQA threshold to determine whether the proposed Project has significant GHG emissions is incorrect.
As a result, we find the DSEIR’s conclusion that the Project would result in a less than significant GHG
impact to be unsubstantiated and incorrect.
AB
Page 78 of 96
C4
CONT
C5
9
Failure to Demonstrate Consistency with the City’s Climate Action Plan
As previously stated, the DSEIR determines the significance of the Project’s GHG impact in 2020 by
evaluating the Project’s consistency with the City’s CAP. The DSEIR states,
“To address this potential impact for 2020, project consistency with the City of Dublin CAP is
used for this analysis. The CAP is a qualified Greenhouse Gas Reduction Strategy under CEQA,
which can be used to determine the significance of GHG emissions from a project (CEQA
Guidelines section 15183.5). BAAQMD also recognizes the use of a CAP as a significance
threshold for a project’s GHG emissions. Therefore, if the project is consistent with the CAP,
then the project would result in a less than significant cumulative impact to global climate
change in 2020” (p. 3.1-65).
Therefore, in order to determine Project compliance, the DSEIR provides a consistency checklist, Table
3.1-23, which includes a list of proposed measures that the Project will implement at Project build out
(see table below) (Table 3.1-23, DSEIR, p. 3.1-66 – 3. 1-67).
AB
Page 79 of 96
C5
CONT
10
AB
Page 80 of 96
C5
CONT
11
According to the CAP, however, although a CEQA review for a proposed project must identify the
specific CAP measures applicable to the project, “if the measures are not otherwise binding and
enforceable, they must be incorporated as conditions of approval or as mitigation measures applicable
to the project”.17 Review of the Project Design Features (PDFs) and mitigation measures listed in the
DSEIR’s Executive Summary Matrix, however, demonstrates that the reduction measures outlined in
Table 3.1-23 were not included as PDFs, mitigation measures, or as mandatory conditions of approval
(Table ES-2, p. ES-7 – ES-8; p. 3.1-35). As a result, it is unclear what measures will actually be
implemented once the Project is approved, and it is unclear whether implementation of these measures
would satisfy requirements set forth by the CAP. Additionally, the City’s CAP states, “identification of
implementation steps and parties responsible for ensuring implementation of each action shall be
included in approval documents for each project”.18 Review of the DSEIR and associated appendices
demonstrates that this information has not been provided.
By failing to include the measures proposed in the checklist above as mitigation or mandatory
conditions of approval, these measures are not enforceable. Until the Project includes the checklist
items as mitigation or mandatory conditions of approval, the Project is not consistent with the CAP and
cannot claim that it is. Additionally, by failing to identify who will be responsible for implementing these
measures, the Project fails to comply with the requirements set forth in the CAP. An updated DSEIR
should be prepared to adequately demonstrate compliance with the CAP, must identify specific
measures the Project will implement within the CAP and who will implement these measures, and must
include these measures as conditions of Project approval or as mitigation.
17 “City of Dublin Climate Action Plan Update.” July 2013, available at:
http://dublinca.gov/DocumentCenter/View/5799, p. 53.
18 Ibid, p. 50
AB
Page 81 of 96
C5
CONT
12
Failure to Demonstrate Consistency with the City’s Climate Action Plan
As stated above, in an effort to comply with CEQA, AB 197, and SB 32 the DSEIR compares the Project’s
construction and operational GHG emissions to the emissions that would be generated by the Project in
the absence of any GHG reduction measures, also known as a Business As Usual scenario (BAU). Using
this method, the DSEIR concludes that if the Project achieves a minimum of a 40 percent reduction in
GHGs between the BAU and As Proposed scenarios for 2030, which is consistent with the AB 197 and SB
32 statewide reduction goals, then the Project would have a less than significant GHG impact (p. 3.1-63).
The use of this threshold to determine whether or not the Project would result in a significant GHG
impact, however, is flawed and should not be relied upon to determine impact significance, as a recent
law made by the California Supreme Court case Center for Biological Diversity et al. v. California
Department of Fish and Wildlife and the Newhall Land and Farming Company 2015 Cal. LEXIS 9478
(Newhall Case),19makes clear that this approach utilized in the DSEIR to achieve compliance with AB 197
and SB 32 is improper. The Newhall Case concludes that lead agencies cannot use the statewide GHG
emission reduction percentage as the CEQA threshold to determine whether a specific project-level
proposed Project has significant GHG emissions.20 As a result, this method of determining Project
significance is incorrect and should not be relied upon.
The DSEIR incorrectly relies on the BAU method to determine the Project’s GHG impacts. According to
the DSEIR, the Project would have to achieve a 40 percent reduction from BAU that is consistent with
the CARB Scoping Plan to result in a less than significant GHG impact. By modeling the Project’s
emissions within CalEEMod for the year 2000, the DSEIR takes the statewide reduction goal for 2030 and
calculates the percent reduction from BAU compared to the proposed Project, and subsequently
compares the total percent reduction to the statewide GHG reduction goal (p. 4.0-40). Using a straight-
line comparison between Project-specific and statewide GHG emission reductions, the Ikea Retail Center
Project would reduce its GHG emissions by 48 percent, which, according to the DSEIR, is consistent with
the statewide reduction goal (p. 3.1-63). As a result, the DSEIR concludes that the Project would have a
less than significant GHG impact (p. 3.1-63). The use of a “straight-line” comparison between Project-
specific and statewide GHG emissions, both by the Newhall Ranch EIR and the Ikea Retail Center Project
DSEIR, however, is flawed, because the percent reduction required by the proposed Project at the
project-level is not directly comparable to the percent reduction required to meet the statewide goal.
Since the Newhall Case prohibits this approach, the City cannot rely on this method for its GHG
assessment. The City must identify an acceptable method of compliance with CEQA, AB 197, and SB 32
for the Project’s GHG emissions, and must determine a Newhall-compliant alternative threshold for the
Project-specific GHG emissions.
Updated Greenhouse Gas Analysis Demonstrates Significant Impact
As previously discussed, the use of a BAU comparison method to determine the Project’s GHG impacts is
entirely flawed. Furthermore, the DSEIR fails to demonstrate compliance with the City’s CAP. In order to
evaluate the Project’s GHG impact, we prepared a simple analysis of the Project’s GHG emissions using
19http://www.courts.ca.gov/opinions/documents/S217763.PDF
20http://www.arb.ca.gov/cc/ab32/ab32.htm
AB
Page 82 of 96
C6
C7
13
the BAAQMD’s threshold of 1,100 metric tons of carbon dioxide equivalents per year (MTCO2e/year).
When we utilized this threshold, rather than the incorrect BAU method used in the DSEIR, we find that
the Project’s GHG emissions would result in a significant impact. As such, additional feasible mitigation
should be applied to the Project in an effort to mitigate the Project’s GHG emissions to the maximum
extent possible.
When the emissions estimated in the DSEIR’s model are compared to this threshold, we find that the
Project’s GHG emissions would exceed the BAAQMD’s 1,100 MTCO2e/year threshold. The DSEIR’s
model’s annual emissions demonstrate that construction of the Project would generate 63 MTCO2e per
year (when amortized over 30 years) with mitigation and operation of the Project would generate
13,634 MTCO2e per year with mitigation. When the Project’s amortized construction emissions and
operational emissions are combined, we find that the Project’s GHG emissions would exceed the
BAAQMD’s screening threshold of 1,100 MTCO2e per year (see table below).21
DSEIR's Annual Greenhouse Gas Emissions
Phase MT CO2e/year
Construction 63
Operation 13,634
Total 13,697
BAAQMD Significance Threshold 1,100
Threshold Exceeded? Yes
As you can see in the table above, when the proposed Project’s GHG emissions are compared to the
BAAQMD’s project-level threshold of 1,100 MT CO2e/year, we find that the Project would exceed this
threshold by approximately 12,597 CO2e/year, resulting in a significant impact. Until an updated GHG
analysis is prepared in a revised DSEIR that adequately evaluates the Project’s total GHG impact, the
conclusions made within the DSEIR’s Air Quality and Greenhouse Gas Analysis should not be relied upon
to determine Project significance.
Mitigation Available to Reduce Operational Emissions
The results of our GHG analysis demonstrates that operation of the Project would result in significant
GHG emissions. Therefore, in an effort to reduce the Project’s operational emissions, we identified
several additional mitigation measures that are applicable to the Project, which can be found in
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures.22 Mitigation for criteria pollutant
emissions should include consideration of the following mobile mitigation measures in an effort to
reduce the Project’s emissions to below thresholds.
Reduce VMT by Increasing Transit Accessibility
21http://www.aguacaliente.org/downloads/Draft%20EIS/e5_6_GHG_110314.pdf, p. 5.6-14
22 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
AB
Page 83 of 96
C7
CONT
C8
14
Making transit more accessible encourages the use of other modes of transportation and therefore
reduces VMT. According to CAPCOA, implementation of this mitigation measure would reduce mobile
source emissions by 0.5 to 24.6 percent. The Project would need to include, at a minimum, the
following design features:
x A transit station/stop with high-quality, high-frequency bus service located within a five to ten-
minute walk, or roughly a quarter of a mile from stop to edge of development
x Or a rail station located within a 20-minute walk or roughly half a mile from station edge to
development
x Fast, frequent, and reliable transit service connecting to a high percentage of regional
destinations
x Neighborhood designed for walking and bicycling
Provide Electric Vehicle Parking
This mitigation measure implements accessible electric vehicle parking to reduce tailpipe emissions.
Design features include conductive/inductive electric vehicle charging stations and signage prohibiting
parking of non-electric vehicles.
Limit Parking Supply
This mitigation measure will change parking requirements and types of supply within the Project site to
encourage “smart growth” development and alternative transportation choices by Project residents and
employees, resulting in less VMTs. This will be accomplished in a multi-faceted strategy:
x Elimination (or reduction) of minimum parking requirements
x Creation of maximum parking requirements
x Provision of shared parking
Implement Commute Trip Reduction (CTR) Program
The Project could implement a voluntary Commute Trip Reduction (CTR) program with employers to
discourage single-occupancy vehicle trips and encourage alternative modes of transportation such as
carpooling, taking transit, walking, and biking. The main difference between a voluntary and a required
program is:
x Monitoring and reporting is not required
x No established performance standards (i.e. no trip reduction requirements)
The CTR program will provide workers with assistance in using alternative modes of travel. The CTR
program should include all of the following to apply the effectiveness reported by the literature:
x Carpooling encouragement
x Ride-matching assistance
x Preferential carpool parking
AB
Page 84 of 96
C8
CONT
15
x Flexible work schedules for carpools
x Half time transportation coordinator
x Vanpool assistance
x Bicycle end-trip facilities
Implement Subsidized or Discounted Transit Program
This Project could provide subsidized/discounted daily or monthly public transit passes. The Project may
also provide free transfers between all shuttles and transit to participants. These passes can be partially
or wholly subsidized by the employer or development. Many entities use revenue from parking to offset
the cost of such a Project.
Implement Commute Trip Reduction Marketing
The Project can implement marketing strategies to reduce commute trips. Information sharing and
marketing are important components to successful commute trip reduction strategies. Implementing
commute trip reduction strategies without a complementary marketing strategy will result in lower VMT
reductions. Marketing strategies may include:
x New employee orientation of trip reduction and alternative mode options
x Event promotions
x Publications
Implement Preferential Parking Permit Program
The Project can provide preferential parking in convenient locations (such as near public transportation
or building front doors) in terms of free or reduced parking fees, priority parking, or reserved parking for
commuters who carpool, vanpool, ride-share or use alternatively fueled vehicles. The Project should
provide wide parking spaces to accommodate vanpool vehicles.
Price Workplace Parking
The Project can implement workplace parking pricing at its employment centers. This may include:
explicitly charging for parking for its employees, implementing above market rate pricing, validating
parking only for invited guests, not providing employee parking and transportation allowances, and
educating employees about available alternatives.
Implement Employee Parking “Cash -Out”
The Project may require employers to offer employee parking “cash-out.” The term “cashout” is used to
describe the employer providing employees with a choice of forgoing their current subsidized/free
parking for a cash payment equivalent to the cost of the parking space to the employer.
Implement Transit Access Improvements
AB
Page 85 of 96
C8
CONT
16
This Project can improve access to transit facilities through sidewalk/ crosswalk safety enhancements
and bus shelter improvements.
When combined, these measures offer a cost-effective, feasible way to incorporate lower-emitting
design features into the proposed Project, which subsequently, reduces emissions released during
Project operation. A revised DSEIR must be prepared to include additional mitigation measures, as well
as include an updated air quality analysis to ensure that the necessary mitigation measures are
implemented to reduce Project emissions to below thresholds. Furthermore, the Project Applicant
needs to demonstrate commitment to the implementation of these measures prior to Project approval,
to ensure that the Project’s emissions are reduced to the maximum extent possible.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Hadley Nolan
AB
Page 86 of 96
C8
CONT
EXHIBIT D
AB
Page 87 of 96
Tel: (949) 887-9013
Email: mhagemann@swape.com
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A.Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 30 years of experience in environmental policy, contaminant assessment and remediation,
stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and
Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional
Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with
EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major
military facilities undergoing base closure. He led numerous enforcement actions under provisions of
the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic
characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE,
Matt has developed extensive client relationships and has managed complex projects that include
consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from
industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and
greenhouse gas emissions.
Positions Matt has held include:
x Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present);
x Geology Instructor, Golden West College, 2010 – 2104, 2017;
x Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);
AB
Page 88 of 96
D1
2
x Executive Director, Orange Coast Watch (2001 – 2004);
x Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989–
1998);
x Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000);
x Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 –
1998);
x Instructor, College of Marin, Department of Science (1990 – 1995);
x Geologist, U.S. Forest Service (1986 – 1998); and
x Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
x Lead analyst and testifying expert in the review of over 300 environmental impact reports
and negative declarations since 2003 under CEQA that identify significant issues with regard
to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions,
and geologic hazards. Make recommendations for additional mitigation measures to lead
agencies at the local and county level to include additional characterization of health risks
and implementation of protective measures to reduce worker exposure to hazards from
toxins and Valley Fever.
x Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial
facilities.
x Expert witness on numerous cases including, for example, MTBE litigation, air toxins at hazards at a
school, CERCLA compliance in assessment and remediation, and industrial stormwater
contamination.
x Technical assistance and litigation support for vapor intrusion concerns.
x Lead analyst and testifying expert in the review of environmental issues in license applications
for large solar power plants before the California Energy Commission.
x Manager of a project to evaluate numerous formerly used military sites in the western U.S.
x Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
x Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
With Komex H2O Science Inc., Matt’s duties included the following:
x Senior author of a report on the extent of perchlorate contamination that was used in testimony
by the former U.S. EPA Administrator and General Counsel.
x Senior researcher in the development of a comprehensive, electronically interactive chronology
of MTBE use, research, and regulation.
x Senior researcher in the development of a comprehensive, electronically interactive chronology
of perchlorate use, research, and regulation.
x Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
x Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
AB
Page 89 of 96
D1
CONT
3
x Expert witness testimony in a case of oil production-related contamination in Mississippi.
x Lead author for a multi-volume remedial investigation report for an operating school in Los
Angeles that met strict regulatory requirements and rigorous deadlines.
x Development of strategic approaches for cleanup of contaminated sites in consultation with
clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange
County beaches from multiple sources of contamination including urban runoff and the discharge of
wastewater. In reporting to a Board of Directors that included representatives from leading Orange
County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection
of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the
development of countywide water quality permits for the control of urban runoff and permits for the
discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including
Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business
institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to
characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point
Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army
Airfield, and Sacramento Army Depot. Specific activities were as follows:
x Led efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
x Initiated a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
x Identified emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of
groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to
show zones of vulnerability, and the results were adopted and published by the State of Hawaii and
County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the
Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included
the following:
x Received an EPA Bronze Medal for his contribution to the development of national guidance for
the protection of drinking water.
x Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted
AB
Page 90 of 96
D1
CONT
4
public hearings, and responded to public comments from residents who were very concerned
about the impact of designation.
x Reviewed a number of Environmental Impact Statements for planned major developments,
including large hazardous and solid waste disposal facilities, mine reclamation, and water
transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
x Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance
with Subtitle C requirements.
x Reviewed and wrote "part B" permits for the disposal of hazardous waste.
x Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed
the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
x Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service-wide investigations of contaminant sources to
prevent degradation of water quality, including the following tasks:
x Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the
Clean Water Act to control military, mining, and landfill contaminants.
x Conducted watershed-scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
x Identified high-levels of perchlorate in soil adjacent to a national park in New Mexico
and advised park superintendent on appropriate response actions under CERCLA.
x Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
x Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
x Co-authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation-
wide policy on the use of these vehicles in National Parks.
x Contributed to the Federal Multi-Agency Source Water Agreement under the Clean Water
Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9.
Activities included the following:
x Advised the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking
water supplies.
x Shaped EPA’s national response to these threats by serving on workgroups and by contributing
to guidance, including the Office of Research and Development publication, Oxygenates in
Water: Critical Information and Research Needs.
x Improved the technical training of EPA's scientific and engineering staff.
x Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific
AB
Page 91 of 96
D1
CONT
5
principles into the policy-making process.
x Established national protocol for the peer review of scientific documents.
Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for
timber harvest in the central Oregon Coast Range. Specific activities were as follows:
x Mapped geology in the field, and used aerial photographic interpretation and mathematical
models to determine slope stability.
x Coordinated his research with community members who were concerned with natural resource
protection.
x Characterized the geology of an aquifer that serves as the sole source of drinking water for the
city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later
listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern
Oregon. Duties included the following:
x Supervised year-long effort for soil and groundwater sampling.
x Conducted aquifer tests.
x Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university
levels:
x At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
x Served as a committee member for graduate and undergraduate students.
x Taught courses in environmental geology and oceanography at the College of Marin.
Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California
where he taught from 2010 to 2014 and in 2017.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and
Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las
Vegas, NV (served on conference organizing committee).
AB
Page 92 of 96
D1
CONT
6
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at
schools in Southern California, Los Angeles.
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE
Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater
Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust,
Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy
of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water
Supplies. Invited presentation to the Inter-Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of
the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a
meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address
Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental
Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater
(and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage
Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and
State Underground Storage Tank Program managers.
AB
Page 93 of 96
D1
CONT
7
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished
report.
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage
Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related
to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft
Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright
Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air
Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic
Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui,
October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air
and Waste Management Association Publication VIP-61.
Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases
in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater
Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of
Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL-
contaminated Groundwater. California Groundwater Resources Association Meeting.
AB
Page 94 of 96
D1
CONT
8
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examinations,
2009-2011.
AB
Page 95 of 96
D1
CONT
HADLEY KATHRYN NOLAN
SOIL WATER AIR PROTECTION ENTERPRISE
ʹͷʹͻǡʹͲͳ
ǡͻͲͶͲͷ
ǣȋͺȌͷͷͳǦͲͺ͵
ǣȋ͵ͳͲȌͶͷʹǦͷͷͷͷ
ǣȋ͵ͳͲȌͶͷʹǦͷͷͷͲ
ǣ̷Ǥ
EDUCATION
UNIVERSITY OF CALIFORNIA, LOS ANGELES B.S. ENVIRONMENTAL SCIENCES & ENVIRONMENTAL SYSTEMS AND SOCIETYJUNE 2016
PROJECT EXPERIENCE
SOIL WATER AIR PROTECTION ENTERPRISE SANTA MONICA, CA
SENIOR PROJECT ANALYST: CEQA ANALYSIS & MODELING
x
ȋ
ȌǤ
x Ǥ
x ǡǤǤ
Ǥ
x ǡǡ Ǥ
x
ǡǡǤ
SENIOR PROJECT ANALYST: GREENHOUSE GAS MODELING AND DETERMINATION OF SIGNIFICANCE
x
Ǥ
x
ǡǡ
Ǥ
x ͵ʹ
ǡ
ǡǤ
PROJECT ANALYST: ASSESSMENT OF AIR QUALITY IMPACTS FROM PROPOSED DIRECT TRANSFER FACILITY
x
ǡ ǡ Ǥ
x Ǥ
x
ǯȋȌ Ǥ
x ǡ
Ǥ
PROJECT ANALYST: EXPOSURE ASSESSMENT OF LEAD PRODUCTS FOR PROPOSITION 65 COMPLIANCE DETERMINATION
x ͵ͲͲ ͷ Ǥ
x ǡ ǡǤ
x ͷȋȌ Ǥ
x ȋȌ
ͷ Ǥ
ACCOMPLISHMENTS
x Academic Honoree, ǯǡǡ MAR 2013, MAR 2014, JAN 2015, JAN 2016
AB
Page 96 of 96
D1
CONT
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-123
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Organizations
Adams Broadwell Joseph & Cardozo (AB)
Note to reader: This law firm is representing Dublin Residents for Responsible Development,
International Brotherhood of Electrical Workers Local 595, Plumbers & Steamfitters Local 342, and
Sheet Metal Workers Local 104.
Response to AB-1
The organization provided introductory remarks and provided a summary of its comments.
The organization’s specific comments are addressed in detail in Response to AB-4 through Response
to AB-27.
Response to AB-2
The organization provided a statement of interest. No response is necessary.
Response to AB-3
The organization provided standard language about CEQA requirements and asserted that the Draft
SEIR fails to meet CEQA standards.
The organization’s specific comments are addressed in detail in Response to AB-4 through Response
to AB-27.
Response to AB-4
CEQA Guidelines Section 15384(b) indicates: “Substantial evidence shall include facts, reasonable
assumptions predicated on facts, and expert opinion supported by facts.”
The Draft SEIR’s biological analysis is based on multiple separate biological surveys of the project site
performed by two separate firms between 2013 and 2017. The first survey was conducted by WRA
on August 1, 2013 and the findings were summarized in the Biological Resources Assessment (Draft
SEIR Appendix C). The second survey was conducted in spring 2016 by FCS and served to confirm
the findings of the WRA assessment. The third survey was conducted by FCS on November 24,
2017—approximately 2 months prior to the release of the Draft SEIR—and also served to confirm
the findings of the WRA assessment. These surveys were the basis for the Draft SEIR’s description of
the baseline biological conditions of the project site and thus constitute substantial evidence.
Furthermore, CEQA Guidelines Section 15384(b) is silent regarding specific requirements for any
technical analyses that constitute substantial evidence; as such, there is no legal basis for the claims
that reconnaissance-level biological surveys are inadequate to constitute substantial evidence.
The Draft SEIR discloses that the project site is largely disturbed and lacks a diversity of native species.
The site is mostly composed of weedy plant species that are common and typically occur in developed
areas, and the site is extensively disturbed (including regular weed abatement). Thus, the project site’s
biological attributes could be fully characterized with a reconnaissance level survey. Protocol surveys
are neither required nor necessary to provide further insight into the baseline biological conditions.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-124 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to AB-5
The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that vernal pool fairy
shrimp are unlikely to occur on the project site because of the lack of vernal pool habitat and the
site’s history of repeated discing, grading, and leveling. FCS reconfirmed this finding during the 2016
and 2017 surveys. As such, the Draft SEIR appropriately did not identify the potential presence of
vernal pool fairy shrimp as a significant impact.
Furthermore, the WRA Biological Resources Assessment (Draft SEIR Appendix C) noted that all
seasonal depressions were man-made and formed by construction activities on the project site in
2008 and generally have limited biological value. The 12 Wetland Delineation Data Sheets provided
in Appendix B of the WRA Biological Resources Assessment document the conditions of the sampling
point with photographs. The photographs demonstrate that the project site has been disced and
graded and certain features may have been substantially disturbed by these activities. Furthermore,
the photographs show no evidence of vernal pools or vernal pool fairy shrimp.
Finally, an FCS biologist conducted an additional field survey on March 28, 2018 after several recent
rain events, and noted that there was no prolonged inundation present on the project site. Given
that prolonged inundation is an element necessary for vernal pool habitat, this reconfirms the Draft
SEIR’s findings.
In sum, substantial evidence supports the Draft SEIR’s conclusion that vernal pool fairy shrimp is
unlikely to occur on the project site.
Response to AB-6
California linderiella (or California fairy shrimp) occurs in the same habitat as vernal pool fairy shrimp
(refer to Response to AB-5, above). Thus, because vernal pool fairy shrimp is unlikely to occur,
California linderiella is also unlikely to occur. See Response to AB-5 above.
As previously noted, an FCS biologist conducted an additional field survey on March 28, 2018 after
several recent rain events, and noted that there was no prolonged inundation present on the project
site. Given that prolonged inundation is an element necessary for vernal pool habitat, this
reconfirms the Draft SEIR’s findings.
Response to AB-7a
The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that burrowing owl had
moderate potential to occur, although no indications of the species were observed. FCS reconfirmed
this finding during the 2016 and 2017 surveys. The Draft SEIR stated on page 3.2-6 that, “The site
exhibits good qualities for burrowing owl habitat, as it contains disturbed soils from discing and a
healthy ground squirrel population.” Because burrowing owl were determined to have the potential
to occur, Mitigation Measure BIO-1c was proposed, requiring a burrowing owl survey prior to ground
disturbing activities. Specifically, the mitigation measure requires compliance with CDFW-accepted
protocols and reduces this impact to less than significant if burrowing owls are found on-site.
Thus, the Draft EIR concluded that this species could occur on-site, which is a conservative finding.
Protocol-level surveys would not yield better information that could potentially change this finding.
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-125
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Finally, as a practical matter, FCS’s biological surveys indicate that the project site is covered with
weedy plant species and disturbed by regular weed abatement activities. The combination of
extensive groundcover and routine disturbance make the project site poorly suited to constitute
burrowing owl habitat. For these reasons, there is no basis to require protocol-level surveys.
Response to AB-7b
Camp Parks is located approximately 760 feet northwest of the IKEA project site, with Martinelli Way
(a four-lane divided roadway), Arnold Road (a four-lane divided roadway), Persimmon Place (a retail
center), and Dublin Boulevard (a six-lane divided roadway) located in between. The project site is
more than 700 feet away from the boundary of Camp Parks and is not contiguous to the property.
Additionally, the proposed project does not propose any development or land use activities within
Camp Parks. Given the urban character of the project vicinity, the project site is not part of the
burrowing owl breeding colony associated with Camp Parks. Thus, no project-related impacts would
occur to burrowing owl habitat within Camp Parks and there is no basis for the biological scope of
the Draft SEIR to encompass this area.
Refer to Response to AB-7a for discussion of the project site’s environmental setting.
Response to AB-8a
The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that the Congdon’s tar
plant was present on-site. FCS reconfirmed this finding during the 2016 and 2017 surveys. The Draft
SEIR concluded that the potential for occurrences of the Congdon’s tar plant was significant and set
forth Mitigation Measure BIO-1a, which requires a focused survey for this species and measures to
reduce this impact to a level of less than significant. Thus, the Draft EIR concluded that this species
occurs on-site, which is a conservative finding. Protocol-level surveys would not yield better
information that could potentially change this finding.
The field survey for the WRA Wetland Delineation was performed on November 5, 2013. Douglas’
fiddleneck was a plant species reported to be observed during the field survey. However, this
species blooms between March and May; it would be highly unlikely to observe this individual in
November. Moreover, FCS’s biologist observed the more common, non-native Rancher’s fiddleneck
throughout the project site during their biological surveys. These two plant species resemble each
other and can be mistaken for one another. Thus, FCS concluded that the reported occurrence of
the Douglas’ fiddleneck in November 2013 was in error. Thus, Draft SEIR did not identify this as a
special-status species that was present on the project site.
Finally, the WRA Wetland Delineation did not identify the western dodder as being present on the
project site. Thus, there are no statements in the Wetland Delineation or Draft SEIR that support the
organization’s claims.
Response to AB-8b
The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that saline clover is
unlikely to occur on the project site because the grassland and seasonally wet depression habitat is
heavily disturbed and of low quality. The WRA Biological Resources Assessment indicated that
hairless popcorn flower is unlikely to occur on the project site due to the lack of meadows and seeps
and the lack of coastal salt marshes and swamps. FCS reconfirmed these findings during the 2016
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-126 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
and 2017 surveys. As such, the Draft SEIR appropriately did not identify the potential presence of
saline clover and hairless popcorn flower as significant impacts.
Moreover, both saline clover and hairless popcorn flower occur on alkali soils. The project site lacks
these soils, which further supports the finding that these species are unlikely to occur on the project
site.
Finally, the statement about hairless popcorn flower having not been found in Dublin since 1954 was
based on a California Natural Diversity Database (CNDDB) query. The CNDDB is a screening tool
used by biologists to determine what special-status species have been previously recorded to be
present within a defined geographical area. Thus, it is entirely possible that amending the CNDDB
query parameters to encompass a broader area would yield different results, including more recent
occurrences of the hairless popcorn flower. However, a CNDDB query is not a substitute for a field
survey, and any findings from the field survey would take precedence over the database search. As
previously noted, the project site was surveyed on multiple occasions between 2013 and 2017 and
hairless popcorn flower was not observed. Thus, the findings of the field surveys are the basis for
the Draft SEIR’s conclusions about the hairless popcorn flower.
Response to AB-9
The Draft SEIR’s biological resources section discloses the potential presence of bats and assigns
appropriate mitigation measures to reduce impacts to less than significant levels. The Draft SEIR
states on page 3.2-11 that, “The marketing building on the project site may provide night roosting
habitat, and the bat may use the project site for foraging habitat.” This observation was based on
multiple surveys of the project site that occurred between 2013 and 2017. Because special-status
bats were determined to have the potential to occur, Mitigation Measure BIO-1d was proposed
requiring pre-removal bat surveys prior to demolition of the building. Mitigation Measures BIO-1d
indicates that if bats are found to be present, a relocation plan shall be developed in accordance
with USFWS, CDFW, and EACCS standards and policies. Referencing agency standards and policies
are clear and unequivocal performance standards. Thus, Mitigation Measure BIO-1d is adequate as
written and does not need to be revised. As such, the Draft SEIR did in fact disclose the baseline
conditions for special-status bats at the project site and provided appropriate mitigation.
Response to AB-10
Refer to Response to AB-5 and Response to AB-6.
Response to AB-11
Refer to Response to AB-7a and Response to 7b.
Response to AB-12
Mitigation Measure BIO-1c sets forth avoidance as the first option for burrowing owl impacts. Under
this scenario, burrowing owl nests would be protected with a buffer until the individuals have
departed. If avoidance is not possible, Mitigation Measure BIO-1c requires the applicant to develop
a detailed mitigation plan in consultation with CDFW. The mitigation plan must be developed in
accordance with the methodology set forth in CDFW’s Staff Report on Burrowing Owl Mitigation
Appendix A and must be reviewed and approved by CDFW.
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-127
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
In summary, Mitigation Measure BIO-1c includes performance standards that would reduce any
adverse impacts associated with burrowing owl eviction to less than significant.
Response to AB-13
Refer to Response to AB-14.
Response to AB-14
CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states
that mitigation measures “may specify performance standards,” “must be fully enforceable,” and
“must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure 1c
requires the applicant to retain a qualified biologist to conduct a burrowing owl survey and impact
assessment. There are clear and unequivocal performance standards within this mitigation measure
that are fully enforceable and roughly proportional to project impacts; for example:
“Prior to the first ground disturbing activities . . .”
“The surveys shall be conducted in accordance with the California Department of Wildlife (CDFW)
Staff Report on Burrowing Owl Mitigation”
“. . . the project applicant shall implement the following avoidance measures . . .”
“The mitigation plan shall be based on the requirements set forth in Appendix A of the CDFW 2012
Staff Report on Burrowing Owl Mitigation Appendix A and the Plan shall be reviewed and accepted
by CDFW . . .”
For these reasons, the Mitigation Measure BIO-1c meets the applicable requirements of CEQA
Guidelines Section 15126.4.
Regarding the claims that the mitigation measure is deferred because it does not include a
compensatory mitigation ratio, acceptable mitigation location and mechanism, site protection
mechanisms, financial assurances, or monitoring requirements, all of these items (to the extent that
they are applicable) would be determined as part of the consultation with CDFW required by the
mitigation measure. The performance standards are contained in CDFW 2012 Staff Report on
Burrowing Owl Mitigation. Because of the uncertainty associated with the outcome of the
burrowing owl survey, it would be premature to make any commitments regarding these items.
Requiring focused or pre-construction surveys prior to release of the Draft SEIR is contrary to sound
biological practice, as the purpose of these surveys is to identify impacted individuals immediately
prior to development and ensure that impacts are avoided, relocated, or otherwise mitigated.
Conducting these surveys months or years before development activities would occur would not
serve any meaningful purpose, particularly since these species have already been determined to
have the potential to occur on the project site. Thus, identifying focused or pre-construction surveys
as mitigation measures is consistent with CEQA Guidelines Section 15126.4 Mitigation Measure BIO-
1c appropriately cites the CDFW Staff Report on Burrowing Owl Mitigation as the basis for any
mitigation that may be necessary.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-128 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Additionally, Page 9 the CDFW Staff Report on Burrowing Owl Mitigation sets forth buffer setback
distances based on the time of year and level of disturbance of the project site. Because the exact
timing of ground disturbance is not known, referencing the CDFW Staff Report is sufficient and
affords the qualified biologist discretion in determining the appropriate distance.
As for the East Alameda County Conservation Strategy (EACCS), this applies only to public projects,
not private projects in the City of Dublin. Thus, City of Dublin has the discretion to apply different
mitigation ratios on a project-by-project basis. The City has modified Mitigation Measure BIO-1c to
include a minimum 1:1 ratio.
Response to AB-15
This project site has been surveyed for special-status plants multiple times between 2013 and 2017.
Only Congdon’s tar plant was found to be present; no other special-status plants have been
documented to occur. Thus, the Draft SEIR appropriately set forth Mitigation Measure BIO-1a,
requiring focused surveys for the Congdon’s tarplant. If found to be present, Mitigation Measure
BIO-1a outlines multiple options for mitigating impacts including exclusion/avoidance and purchase
of credits at a mitigation bank. It is appropriate to identify multiple options for mitigation,
particularly when none have been officially eliminated. Furthermore, if in fact the project
characteristics preclude exclusion/avoidance, purchasing credits at a mitigation bank is feasible. For
these reasons, the analysis and mitigation in the Draft SEIR complies with CEQA standards and there
is no legal basis to revise the Draft SEIR.
Response to AB-16
CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section
states that mitigation measures “may specify performance standards,” “must be fully enforceable,”
and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure
BIO-1a requires the applicant to retain a qualified biologist to conduct a focused survey for the
Congdon’s tarplant and, if found to be present, implement one of two mitigation options
(avoidance/exclusion or purchase of credits at a mitigation bank). There are clear and unequivocal
performance standards within this mitigation measure that are fully enforceable and roughly
proportional to project impacts. For these reasons, Mitigation Measure BIO-1a meets the applicable
requirements of CEQA Guidelines Section 15126.4.
Regarding the claims that there are no existing mitigation banks that sell credits for the Congdon’s
tarplant, the Kaiser Dublin Medical Center entered into an agreement to purchase credits for this
species at a mitigation bank. Thus, if the Congdon’s tarplant is found on the project site, it would be
expected that the applicant could also purchase credits at this mitigation bank. Regardless of this
specific mitigation bank’s availability, the mitigation measure includes other mitigation options and
requires consultation with, and approval by, the CDFW and the City of the mitigation plan prior to
the commencement of any activities that would impact Congdon’s tar plant.
Response to AB-17
Mitigation Measure BIO-1a employs a standard of “a minimum ratio of 1:1,” which does not preclude a
higher ratio and as stated, the mitigation ratio shall be development in consultation with, and
approved by, the CDFW and the City. Moreover, as previously noted, EACCS is advisory for private
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-129
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
development projects, and the City of Dublin has the discretion to apply different mitigation ratios on a
project-by-project basis.
Response to AB-18
Refer to Response to AB-9.
Response to AB-19
There are several species that have been determined to potentially occur and have appropriate
corresponding mitigation to reduce impacts to less than significant. Furthermore, the site mostly
represents an island of ruderal vegetation in the midst of extensive commercial development. For
these reasons with the implementation of required mitigation, cumulative impacts to biological
resources would be less than significant.
The Zeiss Innovation Center Project has been added to the list of cumulative projects in Table 4-1.
This change is noted in Section 5, Errata. However, it should be noted that the Draft SEIR is a
supplement to the Eastern Dublin Specific Plan EIR, which encompassed both the IKEA and Zeiss
project sites. The Eastern Dublin Specific Plan EIR contemplated development on both sites, and,
thus, development at the Zeiss site was contemplated in a prior round of environmental review. This
renders the omission of the Zeiss Innovation Center Project immaterial.
Response to AB-20
The site has 1.92 acres of wetlands under State law subject to RWCQB jurisdiction. Since the site
design will impact these areas, the impacts and mitigation measures identify a detailed permitting
process under Section 401 that identifies mitigation to ensure no net loss of wetland resources. If
delineation finds that wetlands are subject to federal jurisdiction, the mitigation measure also
requires that the project obtain a 404 permit.
Response to AB-21
The organization’s specific comments will be addressed in Response to AB-22 through Response to
AB-27.
Response to AB-22
The preliminary information provided by the applicant and utilized in the CalEEMod model runs was
that the project site would be balanced with no export or import of dirt during grading of the
proposed project. However, during development of the Draft SEIR, more refined grading
assumptions were developed, which found that 21,300 cubic yards of dirt would need to be
exported during grading of the project. The required export of 21,300 cubic yards during grading
was included in Section 2.3, Project Characteristics of the Draft SEIR but was not included in the Air
Quality modeling assumptions provided in Appendix B or in the CalEEMod model runs performed for
the proposed project.
For the air modeling in the Final SEIR to be consistent with the most current version of the project
description that includes the export of 21,300 cubic yards of dirt during grading of the project, the
CalEEMod Model was re-run and the CalEEMod output files are included as Appendix I to the Final
SEIR. In addition, the revised Table 3.1-7 and revised Table 3.1-8 are provided in Section 4, Errata.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-130 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
As shown the revised Tables 3.1-7 and 3.1-8, the addition of the export of 21,300 cubic yards to the
grading phase in the CalEEMod model does not result in any new impacts not previously discussed in
the Draft SEIR and no new mitigation measures are required. The entire project site is proposed to be
graded in one phase. Although building construction activities may be staggered, the SEIR’s air quality
analysis assumed a worst-case scenario of all buildings being constructed simultaneously. Thus,
staggered building construction would result in a lower amount of emissions being spread over a
longer period, which would be less severe than what was modeled in the SEIR.
The claim that the additional emissions created from the export of dirt during grading activities may
result in an exceedance of the BAAQMD thresholds does not have factual basis since grading (and soil
export) would not overlap with building construction, paving and architectural coating activities, which
are well below the BAAQMD thresholds for the mitigated conditions.
Response to AB-23
Table 10 from Appendix B included a typo for the Retail Center Passenger Cars of 10,830 daily trips.
The 10,830 daily trips came from Table 3.6-10 of the DSEIR and represents the total gross daily trips
generated from the Non-IKEA land uses. The 10,830 daily trips should have been entered on the row
for Total Retail Center Trips and the Passenger Cars should have been 10,772 daily trips, which is
calculated by subtracting the truck trips from the total daily trips. The Total Project Trips shown in
Table 10 of 16,840 daily trips is the correct amount for the project and is what was analyzed in the
CalEEMod model runs. The corrected version of Table 10 is provided in Section 4, Errata. This does not
change any impact conclusion or result in any new impacts not previously discussed in the Draft SEIR.
Response to AB-24
The organization claimed that the Draft SEIR’s determination that global warming impacts would be
less than significant is not supported by substantial evidence.
Although the DSEIR does not reference the California’s 2017 Climate Change Scoping Plan (2017
Scoping Plan), prepared by the California Air Resource Board (CARB) in November 2017 (which was
prepared two months before publication of the DSEIR), the 2017 Scoping Plan was prepared by CARB
in order to provide a pathway for the State to meet the GHG emission reduction goals provided in AB
197 and SB 32, and provides substantial evidence for the threshold utilized in the DSEIR for the year
2030 GHG emissions analysis.
The 2017 Scoping Plan provides guidance for local agencies in California to meet the AB 197 and SB 32
climate goal of 40 percent below 1990 levels by year 2030, and provides the following text of how local
agency climate action plans should be updated to meet the new 2030 and 2050 climate goals:
Numerous local governments in California have already adopted GHG emissions
reduction goals for year 2020 consistent with AB 32. CARB advises that local
governments also develop community-wide GHG emissions reduction goals
necessary to reach 2030 and 2050 climate goals. Emissions inventories and
reduction goals should be expressed in mass emissions, per capita emissions, and
service population emissions. To do this, local governments can start by developing
a community-wide GHG emissions target consistent with the accepted protocols as
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-131
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
outlined in OPR’s General Plan Guidelines Chapter 8: Climate Change. They can then
calculate GHG emissions thresholds by applying the percent reductions necessary to
reach 2030 and 2050 climate goals (i.e., 40 percent and 80 percent, respectively) to
their community-wide GHG emissions target. Since the statewide per capita targets
are based on the statewide GHG emissions inventory that includes all emissions
sectors in the State, it is appropriate for local jurisdictions to derive evidence-based
local per capita goals based on local emissions sectors and population projections
that are consistent with the framework used to develop the statewide per capita
targets. The resulting GHG emissions trajectory should show a downward trend
consistent with the statewide objectives. The recommendation for a community-
wide goal expands upon the reduction of 15 percent from “current” (2005–2008)
levels by 2020 as recommended in the 2008 Scoping Plan. (Emphasis added).
As stated above in the 2017 Scoping Plan, local agencies can “calculate GHG emissions thresholds by
applying the percent reductions necessary to reach 2030 and 2050 climate goals (i.e., 40 percent and
80 percent, respectively to their community-wide GHG emissions target.” As such, the year 2030
GHG emissions threshold of 40 percent below 1990 levels by year 2030 that was utilized in the DSEIR
is substantiated by evidence provided in the 2017 Scoping Plan.
In addition, the project contains many differences from the “Newhall” project that consisted of a
mostly residential project located in an undeveloped area and would be considered a “leapfrog”
development. First, the project consists of an infill commercial retail project with residential uses
located within walking distance and existing transit (both bus and light rail stations) within walking
distance to the project site. The proposed project has also committed to implementation of:
• Project Design Feature 1, which requires development of an on-site walkway/bikeway system
to promote non-vehicular transportation;
• Project Design Feature 2, which requires the IKEA store to be designed to achieve a LEED Silver
or higher rating; and
• Project Design Feature 3, which requires the installation of a minimum 1,200-kilowatt PV solar
panel system on the IKEA store building.
With implementation of Project Design Features 1, 2, and 3 and consideration of the placement of
the proposed project as an in-fill development that is transit accessible, the proposed project
currently complies with the City’s CAP and meets the GHG emissions reduction targets provided in
2017 Scoping Plan implementing SB 32.
Response to AB-25
The commenter claims that a typical project should be analyzed for a 30-year lifespan (2020 to
2050). However, as explained above in Response to AB-24, the project’s 2020 emissions were
analyzed in accordance with the CAP. The Project’s post-2020 emissions were analyzed in
accordance with standards under SB 32 and the 2017 Scoping Plan.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-132 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to AB-26
Refer to Responses to AB-24 and AB-25.
Response to AB-27
The organization asserted that substantial evidence exists demonstrating that greenhouse gas
emissions from the project would be significant. The organization referenced modeling performed
by it consultant indicating that the project would generate 63 metric tons of carbon dioxide
equivalents (MTCO2e) during construction and 13,634 MTCO2e during operation annually, which
exceed the BAAQMD’s threshold of 1,100 MTCO2e annually. The organization stated that the
greenhouse gas emissions analysis must be revised and recirculated with a legally valid threshold of
significance.
The BAAQMD’s CEQA Air Quality Guidelines, prepared May 2017, details a few different thresholds that
may be utilized in the analysis of a project’s GHG emissions. The BAAQMD’s thresholds are detailed on
page 3.1-60 of the DSEIR. It is important to note that in the CEQQ Air Quality Guidelines, the BAAQMD
utilizes the word “or” in detailing the different thresholds, which means that a project only needs to be
found less than significant for one of the thresholds in order to provide a determination of less than
significant in the DSEIR. Since the City has adopted a CAP, the DSEIR determined that compliance with
the CAP is the most applicable threshold for the proposed project, and it is the threshold that was
utilized in the DSEIR. See Responses to AB-24 and AB-25 for the discussion of post-2020 thresholds of
significance for GHG emissions used in the DSEIR.
Response to AB-28
For the reasons provided in Response to AB-1 through Response to AB-27, there is no legal basis to
revise and recirculate the Draft SEIR.
Response to AB-A-1
The following comment consists of a letter prepared by Scott Cashen, an independent biological
resources consultant, that is referenced by the preceding comments. Topics addressed include
baseline biological setting, Congdon’s tarplant, saline clover, hairless popcorn flower, vernal pool
fairy shrimp, California Linderiella, the burrowing owl, and special-status bats.
Refer to Response to AB-4 through Response to AB-20.
Response to AB-A-2
The author disputed a statement in the Draft SEIR that the loss of foraging habitat does not
constitute a significant impact, and asserted that the development of the proposed project would
result in significant impacts on the burrowing owl and bats.
The Draft SEIR’s statement regarding the wide availability of foraging habitat on page 3.2-17 was
provided in the context of raptors such as the white-tailed kite. The purpose was to illustrate the
difference between nesting and foraging habitat, and note that mitigation for loss of foraging habitat
is typically not required because of its ubiquity and, therefore, is less than significant under CEQA.
Refer to Response to AB-11 through Response to AB-7a, AB-7b, and AB-9 for discussion of the
burrowing owl and bats.
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-133
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to AB-A-3
The following comments were referenced in the preceding comments. Topics addressed include
cumulative impacts, special-status plants, compensatory mitigation, the burrowing owl, special-
status bats, and wetlands.
Refer to Response to AB-4 through Response to AB-20.
Response to AB-B-1
This comment consists of Scott Cashen’s resume. No response is necessary.
Response to AB-C-1
This comment consists of general statements describing what the remainder of the letter will analyze
without providing any specific claims.
The commenter’s specific comments are addressed in detail in Response to AB-C-2 through
Response to AB-C-8.
Response to AB-C-2
Refer to Response to AB-22.
Response to AB-C-3
Refer to Response to LD-3
Response to AB-C-4
Refer to Response to AB-23.
Response to AB-C-5
This commenter incorrectly claims that in order for the project to be consistent with the CAP that the
DSEIR needs to include mitigation measures or mandatory conditions of approval; however, the DSEIR
was able to demonstrate consistency with the CAP through Project compliance with city and state
regulations.
Response to AB-C-6
This comment was addressed above in Response to AB-24.
Response to AB-C-7
This comment was addressed above in Response to AB-27.
Response to AB-C-8
The Draft SEIR found through implementation of Mitigation Measures AIR-3a, AIR-3b, AIR-3c,
TRANS-1a, TRANS-1b, TRANS-1c, TRANS-1d, TRANS-1e, TRANS-1f, TRANS-4a, TRANS-7a, TRANS-7b,
and TRANS-7c, and implementation of Project Design Features 1, 2 and 3, that the air quality and
greenhouse gas emissions would be reduced to less than significant levels. As such, no additional
mitigation is required for the proposed project.
Response to AB-D-1
This comment consists of Matthew Hagemann’s and Hadley Nolan’s resumes. No response is
necessary.
THIS PAGE INTENTIONALLY LEFT BLANK
CNPS
Page 1 of 4
1
2
CNPS
Page 2 of 4
3
4
5
6
CNPS
Page 3 of 4
7
8
CNPS
Page 4 of 4
8
CONT
9
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-139
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
California Native Plant Society (CNPS)
Response to CNPS-1
The organization provided introductory remarks to open the letter. No response is necessary.
Response to CNPS-2
The organization summarized its comments regarding the Draft SEIR’s evaluation of special-status
plant species impacts. The agency’s specific comments are addressed in Response to CNPS-3
through Response to CNPS-8.
Response to CNPS-3
Refer to Response to AB-4 and AB-5.
A detailed plant inventory was prepared as part of the WRA Wetland Delineation (Draft SEIR
Appendix C). The only special-status plant species observed was Congdon’s tarplant. FCS confirmed
the findings of WRA’s 2013 surveys in 2016 and 2017. Given that the project site is isolated and in a
highly disturbed state, additional protocol-level surveys would not yield any further insights into the
potential presence of plants on the project site.
Response to CNPS-4
The EIR and supporting documentation does include identification of species to the taxonomic level.
Regarding the one unidentified species of Amsinckia, reported in the WRA August and November
2013 reports, FCS biologists conducted a field survey in Spring 2016, which is the appropriate
blooming period for the species. FCS biologists observed Rancher’s fiddleneck (Amsinckia
intermedia), a common non-native weedy species, throughout the project site during our biological
survey. FCS biologists did not observe any Douglas’ fiddleneck (Amsinckia douglasiana).
The commenter is correct that WRA reported that Douglas’ fiddleneck (Amsinckia douglasiana) was
reported during the field survey performed by WRA on November 5, 2013. However, this species
blooms between March and May; it would be highly unlikely to observe this individual in November.
Moreover, these two plant species resemble each other and can be mistaken for one another. Thus,
FCS concluded that the reported occurrence of the Douglas’ fiddleneck in November 2013 was in
error, and therefore the Draft SEIR did not identify this as a special-status species that was present
on the project site.
Response to CNPS-5
Refer to Response to AB-4.
A detailed plant inventory was prepared as part of the WRA Wetland Delineation and is provided in
Appendix C of the Draft SEIR.
The project site was surveyed on multiple occasions by qualified biologists between 2013 and 2017.
The only special-status plant species observed during the surveys was Congdon’s tarplant. The other
species cited by the organization (California dodder, Palmer’s amaranth, large-seeded dodder, broad
leaved mudwort, hedge nettle, bearded clover, and yellow owl’s clover) were not observed during
any of the biological surveys. Thus, it is not necessary to perform another survey for these species.
Refer to Response to AB-8b.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-140 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to CNPS-6
All CNPS rankings were considered under the combined habitat assessment and wetland delineation
efforts that constitute an exhaustive assessment for special-status plants.
Response to CNPS-7
As discussed in Responses to AB-4 and AB-5, the project site was surveyed on multiple occasions by
qualified biologists between 2013 and 2017. The Draft SEIR disclosed the potential impact of up to
6.81 acres of Congdon’s tarplant and requires protocol-level surveys to determine the current
extent of this species on the site prior to disturbance. The project site is isolated, disturbed, and
currently supports a large monoculture of field mustard, a weedy species. Given these site
characteristics, the avoidance or compensatory mitigation requirements set forth in Mitigation
Measure BIO-1a would fully mitigate all direct and indirect impacts on the Congdon’s tarplant
associated with the proposed project. Thus, there are assurances that all potential impacts on
Congdon’s tarplant would be fully mitigated.
Response to CNPS-8
Mitigation Measure BIO-1a requires either avoidance or compensatory mitigation for this species in
accordance with CDFW-guidance. In the outlined mitigation strategy, the measures clearly require
preservation of the species on the site if found in their original, less than, or greater than states.
Furthermore, EACCS guidance is advisory for private-sector projects and the City of Dublin has the
discretion to determine the appropriate mitigation ratio. In this case, Mitigation Measure BIO-1a
establishes a floor of minimum 1:1, which for a disturbed, infill site, is appropriate.
Response to CNPS-9
The organization provided closing remarks to conclude the letter. No response is necessary.
LD
Page 1 of 23
1
2
LD
Page 2 of 23
3
4
LD
Page 3 of 23
4
CONT
5
LD
Page 4 of 23
5
CONT
6
LD
Page 5 of 23
6
CONT
LD
Page 6 of 23
7
LD
Page 7 of 23
7
CONT
8
9
LD
Page 8 of 23
9
CONT
LD
Page 9 of 23
10
LD
Page 10 of 23
10
CONT
11
12
LD
Page 11 of 23
12
CONT
13
LD
Page 12 of 23
LD
Page 13 of 23
14
LD
Page 14 of 23
14
CONT
LD
Page 15 of 23
14
CONT
LD
Page 16 of 23
14
CONT
LD
Page 17 of 23
14
CONT
LD
Page 18 of 23
14
CONT
LD
Page 19 of 23
14
CONT
LD
Page 20 of 23
14
CONT
LD
Page 21 of 23
14
CONT
LD
Page 22 of 23
14
CONT
LD
Page 23 of 23
14
CONT
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-165
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Lozeau Drury (LD)
Note to reader: This law firm is representing Laborer’s International Union of North America Local
Union No. 304.
Response to LD-1
The organization provided introductory remarks and stated that the Draft SEIR fails CEQA
requirements and should be revised and recirculated.
The organization’s specific comments are addressed in Response LD-7 through Response to LD-14.
Response to LD-2
The organization summarized the Draft SEIR’s project description. No response is necessary.
Response to LD-3
Regarding impacts to construction workers, the Draft SEIR Mitigation Measure AIR-3a limits idling to
no more than 5 minutes and requires that construction equipment be properly tuned and
maintained in accordance with the manufacturer’s specifications. Additionally, Mitigation Measure
AIR-3b requires that all construction equipment greater than 50 horsepower meet United States
Environmental Protection Agency Tier 4 interim off-road emissions standards. These mitigation
measures would protect the health of construction workers and others from air pollution. Thus,
there is no basis for the claim that construction workers would suffer adverse health effects from
poorly maintained or controlled construction equipment.
As for hazardous materials, the Draft SEIR disclosed that the project site contains two soil stockpiles
with detectable concentrations of petroleum hydrocarbons, poly aromatic hydrocarbons (PAHs), and
polychlorinated biphenyls (PCBs). Draft SEIR Mitigation Measure HAZ-2 requires the applicant to
retain a qualified hazardous materials contactor to sample these soil stockpiles for these substances
prior to grading activities and properly remove them if detectable concentrations of these hazardous
materials are found to be present. Thus, any hazardous materials in soil would be abated prior to
grading; thus, there is no basis for the claim that construction workers would suffer adverse health
effects from hazardous materials on the project site.
Response to LD-4
The organization provided standard language about CEQA requirements. The Draft SEIR complies
with the requirements of CEQA in every respect. No response is necessary.
Response to LD-5
The organization provided standard language about CEQA requirements for Supplemental EIRs and
asserted that the Draft SEIR fails to analyze significant environmental impacts pertaining to the
project and fully consider available mitigation measures. The organization reiterated its previous
comments that the Draft SEIR should be revised and recirculated.
The organization’s specific comments about the Draft SEIR’s alleged deficiencies are addressed in
Response LD-7 through Response to LD-14.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-166 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Response to LD-6
The organization provided standard language about CEQA requirements for analyzing and disclosing
all potentially significant impacts. No response is necessary.
Response to LD-7
The Draft SEIR identifies impacts to intersections, local and regional roadway segments, and freeway
facilities. Mitigation measures were identified for all impacts. Implementation of many mitigation
measures can be assured as the improvements are already planned by the City of Dublin, or would
be constructed as part of the project. For other impacts, feasible improvements have been
identified but coordination with and approval from other agencies is required and neither the City of
Dublin nor the project applicant can ensure their implementation. For other impacts, such as to the
regional freeway system, other parallel improvements would provide other travel routes, and
alternative travel modes for travel through the corridor. However, the effectiveness of these
measures cannot be fully quantified. For some impacts, such as at the Dougherty Road at Dublin
Boulevard Intersection, insufficient right-of-way is available to construct identified improvements.
Therefore, the Draft SEIR concludes that some impacts could be significant and unavoidable as there
are no assurances regarding the timing of implementation, nor the effectiveness of such measures.
As part of the project approval process, a Statement of Overriding considerations must be prepared
when there are significant and unavoidable impacts. This statement acknowledges the balancing of
competing public objectives (including environmental, legal, technical, social, and economic factors),
and allows for a project that could have significant and unavoidable environmental impacts to be
approved.
Response to LD-8
CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section
states that mitigation measures “may specify performance standards,” “must be fully enforceable,”
and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure
AIR-3b requires that all construction equipment greater than 50 horsepower meet United States
Environmental Protection Agency Tier 4 interim off-road emissions standards and obligates the
applicant to provide the City of Dublin with documentation verifying this at the time of issuance of
grading permits. The mitigation measure identifies a clear and unequivocal performance standard
that is fully enforceable and roughly proportional to project impacts. As such, Mitigation Measure
AIR-3b meets the applicable requirements of CEQA Guidelines Section 15126.4.
Regarding cumulative construction criteria pollutant emissions from the simultaneous construction
of the IKEA Retail Center, Boulevard, and the Zeiss Innovation Center projects, this is unlikely to
occur. As of June 2018, the Boulevard Project site is 1,500 feet northwest of the IKEA Retail Center
project site and is currently under construction; the Zeiss Innovation Center Project site is
approximately 760 feet north of the IKEA site and is approved and expected to commence
construction in the second half of 2018. Since the IKEA Retail Center project has not yet been
considered for approval and cannot begun any construction until after approval and issuance of
permits, the IKEA construction is unlikely to overlap with these other projects. In addition, none of
the three sites are contiguous to each other. Criteria pollutant air emissions constitute a very short-
term, localized phenomenon and are heavily influenced by factors such as weather. Moreover,
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-167
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
construction activities are temporary and cease when the project is completed. Thus, for a worst-
case cumulative criteria pollutant impact to occur in the context of construction, all three projects
would have to be under construction simultaneously on a hot, sunny day with little to no wind.
Given the staggered schedules of the three projects and the distance between each one, this is
remote and unlikely to occur. Therefore, it is too speculative to evaluate.
Response to LD-9
As discussed in Response to LD-8, there is no basis for assuming that Mitigation Measure AIR-3b will
not be effective at mitigating impacts from the IKEA construction or assuming that the IKEA Retail
Center, Boulevard, and Zeiss Innovation Center projects will be implemented on similar constriction
schedules. The mitigation measure will ensure that the construction impacts from the IKEA project
will be less than cumulatively considerable.
Response to LD-10
Draft SEIR page 3.2-2 indicated that the on-site seasonal features may be exempt from jurisdiction
under Section 404 of the Clean Water Act because they appear to be isolated and do not drain to a
navigable waterway. Moreover, the Draft SEIR consistently indicates that the seasonal features are
1.92 acres in area; the statement on page 3.2-16 about the seasonal wetland acreage increasing
from 1.17 to 1.92 reflected the values contained in the WRA Biological Resources Assessment dated
August 2013 (1.17 acres) and the WRA Delineation of Waters of the U.S. dated November 2013 (1.92
acres); they do not reflect 2016 versus 2017 values. In all cases, the Draft SEIR referenced the higher
value of 1.92 acres when discussing existing conditions and impacts.
CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section
states that mitigation measures “may specify performance standards,” “must be fully enforceable,”
and “must be ‘roughly proportional’ to the impacts of the project.” In this case, the mitigation
measures for Congdon’s tarplant (Mitigation Measure BIO-1a), nesting birds (Mitigation Measure
BIO-1b), burrowing owl (Mitigation Measure BIO-1c), bats (Mitigation Measure BIO-1d), and
wetlands (Mitigation Measures BIO-3a and BIO-3b) all identify clear and unequivocal performance
standards that are fully enforceable and roughly proportional to project impacts. As an example,
Mitigation Measure BIO-1a indicates that (1) a focused survey for the Congdon’s tar plant must be
completed prior to vegetation removal or ground disturbing activities; (2) must be conducted in
accordance with the CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native
Plant Populations and Natural Communities; and (3) specific avoidance or compensatory mitigation
must be implemented if individuals are found to be present.
In regard to requiring focused or pre-construction surveys prior approval of a project, please refer to
Response AB-14.
Response to LD-11
The Smallwood inspection is addressed in Response to LD-14.
Response to LD-12
CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states
that mitigation measures “may specify performance standards,” “must be fully enforceable,” and
“must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure HAZ-2
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-168 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
requires the applicant to retain a qualified hazardous materials contactor to sample these soil
stockpiles for these substances prior to grading activities and properly remove them if detectable
concentrations of these hazardous materials are found to be present. There are clear and unequivocal
performance standards within this mitigation measure that are fully enforceable and roughly
proportional to project impacts, such as:
“Prior to issuance of the first grading permit . . .”
“If sampling determines that concentrations of these substances exceed acceptable human health
exposure levels . . .”
“. . . the applicant shall retain a qualified hazardous materials contractor to properly remove and
dispose if impacted soil . . .”
For these reasons, Mitigation Measure HAZ-2 meets the applicable requirements of CEQA Guidelines
Section 15126.4 and the claims that construction workers would be exposed to hazardous materials
are not supported by substantial evidence.
Response to LD-13
As discussed in these responses, the Draft SEIR meets all applicable CEQA requirements and there is
no legal basis to revise and recirculate the Draft SEIR.
Response to LD-14
This comment consists of a letter authored by Shawn Smallwood, Ph.D., dated March 5, 2018
regarding the Zeiss Innovation Center Project site located east of Arnold Road and north of Dublin
Boulevard. Dr. Smallwood indicated that he performed a 15-minute site visit on February 8, 2018
and a 94-minute visit on March 2, 2018. He indicated that both visits were restricted to the outer
perimeter of the Zeiss Innovation Center Project site and that he did not actually walk the site. He
reported observing a red-tailed hawk and a white-tailed kite and suggested that their behavior was
indicative of nesting. He also inferred burrowing owls may be present because of the presence of
ground squirrels. His letter then delves into topics specific to the Zeiss Innovation Center Project
that have no relevance to the IKEA Retail Center project.
As should be clear, Dr. Smallwood did not survey the IKEA Retail Center project site. The Zeiss
Innovation Center Project site is located approximately 760 feet north of the IKEA Retail Center
project site, with Martinelli Way (a four-lane divided roadway), Persimmon Place (a retail center),
and Dublin Boulevard (a six-lane divided roadway) located in between. The two sites are non-
contiguous. Unlike the Zeiss Innovation Center Project site, the IKEA Retail Center project site
supports paved areas and buildings.
Moreover, Dr. Smallwood’s methods would not be consistent with those for a reconnaissance level
biological survey, or for that matter, CEQA-level evaluation of biological resources. Moreover, his
initial February 8, 2018 survey of the approximately 10-acre site Zeiss Innovation Center Project site
consisted of a 15-minute visit, which seems to be a bit abbreviated for a site of this size. His
suggestion that that red-tailed hawks, white-tailed kites, or burrowing owls are nesting on-site are
completely unsupported by any actual direct evidence that such nests are present. Lastly, using a
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-169
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
biologist’s observations for one project site as a proxy for a completely separate site would not meet
any widely accepted standard for biological assessments. Overall, Dr. Smallwood’s letter provides
limited biological insight into the Zeiss Innovation Center Project site and absolutely no biological
insight into the IKEA Retail Center site.
Regardless, the IKEA Retail Center project site was surveyed on multiple occasions between 2013
and 2017 by several biologists from separate firms and was determined to provide suitable habitat
for nesting birds (including raptors such as the red-tailed hawks and white-tailed kites) and the
burrowing owl. Accordingly, the Draft SEIR set forth Mitigation Measures BIO-1b and BIO-1c to
address impacts to these species. As such, there is no basis to revise and recirculate the Draft SEIR
based on Dr. Smallwood’s letter.
THIS PAGE INTENTIONALLY LEFT BLANK
CIGNARELLA
Page 1 of 2
1
2
CIGNARELLA
Page 2 of 2
2
CONT
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-173
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Individuals
Tom Cignarella (CIGNARELLA)
Response to CIGNARELLA-1
The author expressed objection to the project because of traffic congestion. Refer to Master
Response 1.
Response to CIGNARELLA-2
The author provided a summary of the SEIR’s conclusions regarding traffic. Refer to Master Response 2.
THIS PAGE INTENTIONALLY LEFT BLANK
DE WIT-SMITH
Page 1 of 2
1
DE WIT-SMITH
Page 2 of 2
1
CONT
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-177
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Liana deWit-Smith (DEWIT-SMITH)
Response to DEWIT-SMITH-1
The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection
to the project. Refer to Master Responses 1 and 2.
THIS PAGE INTENTIONALLY LEFT BLANK
FICARRA
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-181
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Tammy Ficarra (FICARRA)
Response to FICARRA-1
The author expressed objection to the project because of traffic congestion. Refer to Master
Response 1.
THIS PAGE INTENTIONALLY LEFT BLANK
GEBEL
Page 1 of 1
1
2
3
4
5
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-185
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Jeff Gebel (GEBEL)
Response to GEBEL-1
The author does not provide any evidence in support of his claim that traffic impacts on I-580, I-680,
Hacienda Drive, and Dublin Boulevard have not been properly mitigated. Refer to CALTRANS-3 for
further discussion of traffic analysis and mitigation, particularly with regard to freeway impacts.
Response to GEBEL-2
Both Livermore and Pleasanton have established retail nodes1 that are within close driving distance
of Dublin and, thus, Dublin residents are making existing trips to these outlets. As such, these traffic
patterns are captured in the Draft SEIR’s existing and Existing Plus Project traffic analyses (Impacts
TRANS-1) in Section 3.6, Transportation. To the extent that these residents would continue to make
these shopping trips in the future, this would represent the continuation of an existing condition.
IKEA primarily retails furniture and housewares and, thus, only competes with outlets in these
categories. Thus, the development of an IKEA would not eliminate the need for Dublin residents to
shop at outlets that serve other retail categories.
Although the Draft SEIR indicates that traffic conditions would deteriorate on local and regional
roadways under Near-Term with Project and Cumulative with Project conditions, attempting to
predict how this would influence non-IKEA retail traffic pattern trips is too speculative to predict
because it would require information that is not currently available (the types of outlets that would
exist in the future, shopping preferences of residents in the future, etc.). CEQA Guidelines Section
15145 indicates that if a lead agency finds that a particular impact is too speculative for evaluation,
the agency should note its conclusion and terminate discussion of the impact.
Response to GEBEL-3
Impacts on the existing visual character of the project site were adequately addressed in the Eastern
Dublin EIR and no further analysis is required. Thus, the project would not represent a substantial
visual impact under CEQA standards. However, the design and coloring of the building is subject to
City zoning regulations, including site development review standards, which will be considered by
decision-makers.
Response to GEBEL-4
The Draft SEIR’s noise analysis in Section 3.4 Noise specifically accounted for truck noise in terms of
roadway noise and delivery loading and unloading noise; refer to pages 3.4-18; 3.4-20 through
3.4-27; and 3.4-29 through 3.4-30. As discussed on those pages, all operational noise impacts
(including truck noise) were found to be less than significant.
Response to GEBEL-5
Project-related greenhouse gas emissions impacts were evaluated in Section 3.1, Air Quality/
Greenhouse Gas Emissions on pages 3.1-59 through 3.1-67. Although the proposed project would
result in a net increase in daily vehicle trips, the State’s adopted greenhouse gas reduction policies
(e.g., Pavley I motor vehicle emission standards, Low Carbon Fuel Standard, Pavley II Advanced Clear
1 Livermore nodes include the San Francisco Premium Outlets and Costco. Pleasanton nodes include Pacific Pearl,
CarMax/Stoneridge Chrysler/Jeep/Dodge, Rose Pavilion, Metro 580, etc.
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-186 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Cars Program) would apply to the vehicle fleet and serve to reduce greenhouse gas emissions over
time. The proposed project also includes features that would reduce greenhouse gas emissions such
as being designed to meet the United States Green Building Council’s Leadership in Energy and
Environmental Design Silver standard, being accessible to bicycles and transit, and the use of a
photovoltaic solar system for electricity production. The Draft SEIR found that the proposed project
would achieve the State’s 40 percent emissions reduction target set forth in SB 32 and, thus, impacts
would be less than significant. Because the proposed project would be consistent with the State’s
greenhouse gas reduction objectives, it would not be considered to increase Dublin’s carbon footprint.
GONZALES
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-189
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Chenin Gonzales (GONZALES)
Response to GONZALES-1
The Draft SEIR referenced the applicable federal and state statutes that pertain to avian species on
pages 3.2-11 through 3.2-14, including the white-tailed hawk and western burrowing owl. Section
3.2, Biological Resources Impact BIO-1 evaluated impacts on special-status bird species and noted
that the project site provides suitable habitat for nesting birds, the western burrowing owl, and bat
species; as such, Mitigation Measures BIO-1b, BIO-1c, and BIO-1d were set forth to mitigate impacts
on these species. In summary, the Draft SEIR did evaluate the potential presence of special-status
aviation species and set forth mitigation to reduce impacts to a level of less than significant.
THIS PAGE INTENTIONALLY LEFT BLANK
HEYER
Page 1 of 2
1
HEYER
Page 2 of 2
1
CONT
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-193
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
John Heyer (HEYER)
Response to HEYER-1
The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection
to the project. Refer to Master Responses 1 and 2.
THIS PAGE INTENTIONALLY LEFT BLANK
KAUBE
Page 1 of 2
1
2
3
4
KAUBE Page 2 of 25
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-197
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Michael Kaube (KAUBE)
Response to KAUBE-1
The Initial Study in Appendix A served as a preliminary assessment of impacts on public transit,
bicycles and pedestrians. A more detailed assessment of bicycle circulation is provided in Draft SEIR
Section 3.6, Transportation, Impact TRANS-8, and identified several improvements to enhance the
convenience and safety of cycling in the project vicinity (Mitigation Measures TRANS-8a, TRANS-8b,
and TRANS-8c). After implementation of these mitigation measures, the Draft SEIR concluded that
impacts on bicycles were less than significant. The author did not provide any specific comments on
the Draft SEIR’s analysis or mitigation measures.
Response to KAUBE-2
As noted in Response to KAUBE-1, the Draft SEIR provided a detailed assessment of bicycle and
pedestrian circulation and set forth improvements as mitigation measures.
Regarding the poor condition of the Class I bicycle/pedestrian path along the north side of Dublin
Boulevard, this is a result of the development of the Boulevard Project that restricted access to
portions of this facility. That project will be required to restore the Class I bicycle/pedestrian path to
satisfactory condition. Note that the IKEA Retail Center project does not propose any changes to this
facility.
Response to KAUBE-3
Refer to Response to KAUBE-1 and -2.
Response to KAUBE-4
The author stated that he will be opposed to any further development in the project vicinity until the
traffic situation is improved. This comment is noted and will be provided to City decision-makers.
No response is necessary.
Response to KAUBE-5
This comment consists of a diagram referenced by the author in his comments. No response is
necessary.
THIS PAGE INTENTIONALLY LEFT BLANK
MARSHALL
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-201
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Lianne Marshall (MARSHALL)
Response to MARSHALL-1
The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection
to the project. Refer to Master Response 1.
The author also expressed objection to the design and appearance of the proposed project. Impacts
on the existing visual character of the project site were adequately addressed in the Eastern Dublin
EIR and no further analysis is required. Thus, the project would not represent a substantial visual
impact under CEQA standards. However, the design and coloring of the building is subject to City
zoning regulations, including site development review standards, which will be considered by
decision-makers.
THIS PAGE INTENTIONALLY LEFT BLANK
MURUGESAN
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-205
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Jegadheesa Murugesan (MURUGESAN)
Response to MURUGESAN-1
The author provided a summary of the SEIR’s conclusions regarding vehicle miles traveled and
expressed objection to the project. Refer to Master Response 1.
The author stated that the SEIR in Table Page 6-6 underreported the City’s population as 50,000 and
asserted that this should be corrected in order to get an accurate picture of traffic impacts.
Table 6-6 indicates that the City’s “existing population” is 50,970. That number represents a
calculation of residential population based on the number of households in the base year model
with different housing types having different household sizes. The model base year is 2015, so this
numbers reflects the population for that year. It should be noted that the population for the City of
Dublin for modeling purposes does not include the Santa Rita Jail facility, which has a capacity of
4,000 people or Federal Correctional Institution Dublin, which has a capacity of 990.
THIS PAGE INTENTIONALLY LEFT BLANK
PAGE
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-209
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Chris Page (PAGE)
Response to PAGE-1
The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection
to the project. Refer to Master Responses 1 and 2.
THIS PAGE INTENTIONALLY LEFT BLANK
SOLAIMAN
Page 1 of 2
1
SOLAIMAN
Page 2 of 2
1
CONT
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-213
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Feroza Solaiman (SOLAIMAN)
Response to SOLAIMAN-1
The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection
to the project. Refer to Master Responses 1 and 2.
THIS PAGE INTENTIONALLY LEFT BLANK
YOUNG
Page 1 of 1
1
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-217
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Rupert Young (YOUNG)
Response to YOUNG-1
The author expressed objection to the project because of traffic congestion and land use
compatibility. Refer to Master Response 1.
Impacts on land use were addressed in the initial study, which was included as Appendix A of the
EIR. As discussed, the proposed project consists of the development of commercial-retail center.
The City of Dublin General Plan designates the project site as “General Commercial,” while the
Eastern Dublin Specific Plan zones the site as “General Commercial,” which permits the construction
of retail-commercial uses. Development on-site would be required to comply with all applicable
General Plan policies and Specific Plan regulations, and would be reviewed by the City prior to
approval of the necessary permits. As such, impacts would be less than significant and no further
analysis is required. Thus, the project would not result in a significant impact in terms of land use.
The design and coloring of the building is subject to City zoning regulations, including site
development review standards, which will be considered by decision-makers.
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Responses to Written Comments
FirstCarbon Solutions 3-219
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Non-Draft SEIR Comments
Table 3-2 summarizes the individuals that submitted comments that pertained to the proposed
project, but did not specifically address any aspect of the Draft SEIR’s analysis. The letters are
reproduced following the table. Please refer to Section 2, Master Responses for a response to these
comments.
Table 3-2: Non-Draft SEIR Comments
Signatory Signatory Signatory
J. Alexander Melissa Alexander Angie [Full Name Not provided]
Sandi Arajs and Tom Rogers Joe Banchero Dean Barnes
Lisa Burks Maijargal Burrows Catherine Byron
Brian Cardella Marlon Cardenas Kerrie Chabot
Jenny Chang Daniel Chen Young Cho
Tom Cignarella Sean Cohen Danielle Cooper
Ewa David Lianna de Wit-Smith Vanessa Dellon
Diana DeMeo Mindy Destro Satpal Dhillon
Susan Dunnegan Ernesto Eugenio Jennifer Farber and John Hanson
Tammy Ficarra (3 letters) Susanne Frey Vasantha Ganesan
Michelle Gebel Jay Gill Sumeet Gore
Patrick Graham Perrin Guess Roger Gupta
Akansha Gupta Rajesh Gupta Roger and Nancy Haddad (2
letters)
Patty Hansen Sunil Hariani Pam Harvey
Heidi [Full Name Not Provided] Gretchen Hellmann Jennet Herdman
John Heyer Wendy Jemo Jim R. and Elena G. (Full Names
Not Provided)
Teresa Johnson Gerry Judd Nina Kamatani
Kamlesh Kamdar Alex Kao Sepi Katz
Stefani Katz Pearl Ko Vaidy Krishnamurthy
Pawan Kumar William and Katherine Kuo Eric Lam
Linda Leonard Cheryl LeValley James Lin
Gina Lindauer Weifeng Liu John Lumm
Mahesh [Full Name Not Provided] Ravinder Mangat Lianne Marshall
Kiran Maskey Marlene Massetti Leonie Meima
Rowena Morgan Kazuko and Masahiro Morimoto Gargi Mukherjee
Jegadheesa Murugesan Hilary Nindorf Chris Page
City of Dublin—IKEA Retail Center Project
Responses to Written Comments Final SEIR
3-220 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx
Table 3-2(cont.): Non-Draft SEIR Comments
Signatory Signatory Signatory
Katie Palomares Carmen Pappas Ashish Paralkar
Annissa Park Ivan Pysarevskyy Ramya Ramakrishnan
Brian Roudabush Johan Rydell Nithya Sakthirajan
Edlyn Sammanasu (2 letters) Lucretia Samuels Satar [Full Name Not Provided] (2
letters)
Jenny Scheinpflug Thomas Schindler Allen Shaw
Monica Silva Jennifer Situ and Vick Tran (2
letters)
Feroza Solaiman
Vanessa Sotelo Suico [Full Name Not Provided] (2
letters)
Diane Tarin
Nhuly Tran Debbie Wagner (2 letters) Janeen Wheeler
Heather Whiting Barbara Wilson Rupert Young
Source: City of Dublin, 2018.
THIS PAGE INTENTIONALLY LEFT BLANK
City of Dublin—IKEA Retail Center Project
Final SEIR Errata
FirstCarbon Solutions 4-1
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
SECTION 4: ERRATA
The following are revisions to the Draft SEIR for the IKEA Retail 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 SEIR. The revisions are listed by page number. All
additions to the text are underlined (underlined) and all deletions from the text are stricken (stricken).
4.1 - Changes to Draft EIR Text
Section ES, Executive Summary
Page ES-1, Project Location
The project address has been corrected.
The project site is located at 5344 and 5144 5411 Martinelli Way in the City of Dublin,
Alameda County, California.
Page ES-2, Table ES-1
Table ES-1 has been revised to eliminate a redundant entry for 8,000 square feet of restaurant uses.
These uses are captured in the 58,440 square-foot value.
Table ES-1: IKEA Retail Center Project Summary
Use Acreage Square Feet Characteristics
Major 1 (IKEA) 13.65 339,099 2 stories above two-story parking structure
Lifestyle retail-restaurant
13.66
8,000 Freestanding restaurant
34,560 Multiple buildings, retail use
58,440 Multiple buildings, restaurant/food use
Subtotal 27.45 — ―
Proposed/anticipated dedication
for BART1 (0.16) ― ―
Total 27.31 432,099 ―
Note:
1 Based on Express Bus/Bus Rapid Transit (BRT) Alternative.
Source: GreenbergFarrow, 2017.
Section 2, Project Description
Page 2-1, Project Location
The project address has been corrected.
The project site is located at 5344 and 5144 5411 Martinelli Way in the City of Dublin,
Alameda County, California.
City of Dublin—IKEA Retail Center Project
Errata Final SEIR
4-2 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Page 2-10, Table 2-1
Table 2-1 has been revised to eliminate a redundant entry for 8,000 square feet of restaurant uses.
These uses are captured in the 58,440 square-foot value.
Table 2-1: IKEA Retail Center Project Summary
Use Acreage Square Feet Characteristics
Major 1 (IKEA) 13.65 339,099 2 stories above two-story parking structure
Lifestyle retail-restaurant
13.66
8,000 Freestanding restaurant
34,560 Multiple buildings, retail use
58,440 Multiple buildings, restaurant/food use
Subtotal 27.45 — ―
Proposed/anticipated dedication
for BART1 (0.16) ― ―
Total 27.31 432,099 ―
Note:
1 Based on Express Bus/Bus Rapid Transit (BRT) Alternative.
Source: GreenbergFarrow, 2017.
Page 2-10
Text is added to clarify the proposed building height of the structure
Major 1—IKEA
The IKEA store would consist of a two-story building located over a two-level parking structure with
the lower level partially below grade. The building would be set against the Arnold Road frontage
and face Hacienda Drive. The building would stand approximately 61 feet above finished grade. The
majority of the building would be at 58 feet 6 inches, while the yellow Ikea Panels would project up
to 65 feet in height. The principal loading docks would be located in the rear of the building facing
Arnold Road. A recycling and refuse collection area, trash compactor, and emergency diesel
generator would also be located at the rear of the store. A two-bay loading dock for home deliveries
would be located on the south side of the building facing I-580.
Section 3.1, Air Quality/Greenhouse Gas Emissions
Pages 3.1-43 and 3.1-44, Table 3.1-7
Table 3.1-7 has been revised to include emissions from export haul trips, which would only occur
during the grading phase of construction.
City of Dublin—IKEA Retail Center Project
Final SEIR Errata
FirstCarbon Solutions 4-3
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Table 3.1 —7: Construction-Related Criteria Air Pollutant Emissions Prior to Mitigation
Construction Activity
Air Pollutants (pounds per day)
ROG NOX PM10
1 PM2.5
1
Demolition 3.83 39.78 1.95 1.81
Grading 5.185.76 59.5979.00 2.633.90 2.422.82
Combined Building Construction,
Paving, and Architectural Coatings 146.06 73.35 3.01 2.83
- Building Construction 6.29 57.32 2.16 2.03
- Paving 2.21 14.11 0.75 0.69
- Architectural Coating 137.56 1.92 0.11 0.11
CEQA Significance Thresholds 54 54 82 54
Exceeds Significance Threshold? Yes Yes No No
Notes:
1 Exhaust only
ROG = reactive organic gases NOX = oxides of nitrogen
PM10 = particulate matter 10 microns in diameter
PM2.5 = particulate matter 2.5 microns in diameter
Source: FirstCarbon Solutions, CalEEMod Version 2016.3.2, Appendix B.
Pages 3.1-44 and 3.1-45, Table 3.1-8
Table 3.1-8 has been revised to include emissions from export haul trips.
Table 3.1-8: Mitigated Construction-Related Criteria Air Pollutant Emissions
Construction Activity
Air Pollutants (pounds per day)
ROG NOX PM10
1 PM2.5
1
Demolition 0.69 14.98 0.07 0.07
Grading 1.101.68 19.3438.75 0.111.38 0.110.51
Combined Building Construction,
Paving, and Architectural Coatings 51.41 52.44 0.34 0.34
- Building Construction 3.37 41.06 0.30 0.30
- Paving 1.19 10.08 0.04 0.04
- Architectural Coating 46.85 1.30 0.00 0.00
CEQA Significance Thresholds 54 54 82 54
Exceeds Significance Threshold? No No No No
Notes:
1 Exhaust only
ROG = reactive organic gases NOX = oxides of nitrogen
PM10 = particulate matter 10 microns in diameter
PM2.5 = particulate matter 2.5 microns in diameter
Source: FirstCarbon Solutions, CalEEMod Version 2016.3.2, Appendix B.
City of Dublin—IKEA Retail Center Project
Errata Final SEIR
4-4 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Section 3.3, Biological Resources
Pages 3.2-19 and 3.2-20, Mitigation Measure BIO-1c
Mitigation Measure BIO-1c has been modified to include a requirement for minimum 1:1
replacement.
MM BIO-1c Prior to the first ground-disturbing activities, the project applicant shall implement
the following measures that pertain to 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 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 does not collapse burrows.
• Do not fumigate or 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, prior to the first ground-disturbing activities, the project applicant, in
consultation with the CDFW, 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 pursuant to 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,
City of Dublin—IKEA Retail Center Project
Final SEIR Errata
FirstCarbon Solutions 4-5
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
occupied, and satellite burrows and/or burrowing owl habitat, the project
applicant shall consult with the CDFW and develop a detailed mitigation plan that
shall include replacement of impacted habitat at no less than a 1:1 ratio, number
of burrows, and burrowing owl in a ratio approved by CDFW. The mitigation plan
shall be based on the requirements set forth in Appendix A of the CDFW 2012
Staff Report on Burrowing Owl Mitigation and the Plan shall be reviewed and
accepted by CDFW and the City prior to the first ground-disturbing activities.
Section 3.6, Transportation
Page 3.6-70, After Third Paragraph
The discussion of Hacienda Drive/Martinelli Way improvements has been amended to acknowledge
that Caltrans has jurisdictional control.
Note that the 100-foot extension of the turn pocket would encroach into the Caltrans
jurisdiction. The City of Dublin has no control over Caltrans facilities and therefore, the
residual significance of this impact is significant and unavoidable.
Page 3.6-125, Table 3.6-19
A typographical error associated with the identification of LOS following the implementation of
mitigation is corrected, as shown in Table 3.6-19.
Table 3.6-19: Cumulative with Mitigation Peak-Hour Intersection Levels of Service
Intersection Control
Peak
Hour
Cumulative without
Project Cumulative with Project
Cumulative with Project
With Mitigation
Delay LOS Delay LOS Delay LOS
6. Hopyard Road
& Owens Drive Signal
AM
PM
SAT
50.8
95.1
63.7
D
F
E
50.9
96.6
65.6
D
F
E
35.9
54.2
53.8
C
D
D
11. Dublin
Boulevard &
Arnold Road
Signal
AM
AFT
PM
SAT
35.3
44.3
60.3 (141.5)
47.7
D
D
E
D
38.2
52.4
60.7 (170.8)
47.8
D
D
E
D
35.4
48.8
43.6
42.3
D
D
D
D
17. Dublin
Boulevard &
Hacienda Drive
Signal
AM
AFT
PM
SAT
36.8
45.5
72.2 (275.0)
64.4 (235.0)
D
D
E
E
37.9
52.6
80.8 (345.2)
77.0 (318.8)
D
D
F
E
36.7
36.0
52.2
47.0
D
D
D
D
18. Hacienda Drive
& Martinelli
Way
Signal
AM
AFT
PM
SAT
38.7
37.1
0.82 (1.86)
41.9
D
D
F
D
41.2
49.9
1.01 (2.42)
70.4
D
D
F
E
50.0
41.0
47.6
53.9
D
D
D
D
21. Owens Drive &
Hacienda Drive Signal
AM
PM
SAT
21.0
99.1
24.0
C
F
C
21.1
100.9
24.3
C
F
C
20.4
54.5
21.0
C
D
C
City of Dublin—IKEA Retail Center Project
Errata Final SEIR
4-6 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Table 3.6-19 (cont.): Cumulative with Mitigation Peak-Hour Intersection Levels of Service
Intersection Control
Peak
Hour
Cumulative without
Project Cumulative with Project
Cumulative with Project
With Mitigation
Delay LOS Delay LOS Delay LOS
26. Dublin
Boulevard &
Tassajara Road
Signal
AM
PM
SAT
49.0
1.53 (1.93)
1.38 (1.98)
D
F
F
49.5
1.54 (1.93)
1.40 (2.06)
D
F
F
49.1
70.3
54.9
D
E
D
28. Santa Rita
Road & I-580
Eastbound Off-
Ramp
Signal
AM
PM
SAT
35.0
53.0
94.5
C
D
F
35.1
54.0
97.4
D
D
F
29.4 47.8
36.6 47.4
39.5 63.6
CD
D
DE
Notes:
Bold text indicates LOS E/F; Bold Italics text indicates impacts due to the proposed project.
1 Signal = signalized.
2 Average intersection delay calculated using the HCM 2000 methodology.
For LOS E signalized intersections in the City of Dublin, average delay is followed by the delay for the worst movement
in parentheses.
For LOS F signalized intersections in the City of Dublin, overall intersection volume-to-capacity (v/c) ratio is followed by
the v/c ratio for the worst movement.
Source: Fehr and Peers, 2018.
Page 3.6-100, Mitigation Measure TRANS-2c
The improvements listed in Mitigation Measure TRANS-2c are amended to include an additional
eastbound left turn or through lane.
MM TRANS-2c Prior to issuance of the first building permit, the project applicant shall provide the
City of Dublin documentation that they have worked with the City of Pleasanton and
Caltrans to identify and pay the project’s proportionate share for improvements to
the intersection of Santa Rita Road/I-580 Eastbound in the City of Pleasanton. The
improvements shall consist of modifying the southbound approach to construct a
second southbound left-turn lane, and either modifying the northbound approach
to construct a third eastbound left-turn lane or modifying the southbound approach
to provide a third southbound through lane, in addition to re-timing the traffic
signal.
Section 4, Cumulative Effects
Table 4-1
An entry has been added to Table 4-1 for the Zeiss Innovation Center Project. The addition of this
project to Table 4-1 does not materially change any conclusions in Section 4, Cumulative Effects.
City of Dublin—IKEA Retail Center Project
Final SEIR Errata
FirstCarbon Solutions 4-7
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Table 4-1: Cumulative Projects
Jurisdiction Project Characteristics Location Status
City of
Dublin
Kaiser Dublin
Medical Center
950,000 square feet Kaiser
Medical Campus; 250,000 square
feet commercial
Dublin
Boulevard/
Keegan Street
Approved; under
construction
Dublin Crossing/
Boulevard
Up to 1,995 dwelling units;
200,000 square feet commercial;
35 acres parks; 12-acre
elementary school
Dublin
Boulevard/
DeMarcus
Approved; under
construction
Zeiss Innovation
Center
Phase 1: 208,650 square feet
research and development
Phase 2: 224,440 square feet
research and development
Dublin
Boulevard/
Arnold Road
Proposed
Grafton Plaza Mixed
Use
115 dwelling units, 50,000 square
feet retail commercial, and 130
room hotel
Dublin
Boulevard/
Grafton Drive
Proposed; not
yet approved or
built
Grafton Station
Phase III
133,446 square feet commercial Dublin
Boulevard/
Tassajara Road
Approved;
unbuilt
City of
Pleasanton
Stoneridge Drive
Specific Plan
800 dwelling units (senior);
120,000–200,000 square feet
commercial; 331,000 square feet
auto mall
El Charro
Road/Stoneridge
Drive
Approved; under
construction
Johnson Drive
Economic Zone
40-acre area envisioned to
support up to 535,490 square feet
of warehouse club retail (Costco),
hotel, general retail, and
recreational facilities
7106–7315
Johnson Drive
Proposed
City of
Livermore
El Charro Specific
Plan
1.5 million square feet retail; 250
acres
El Charro
Road/Jack
London
Boulevard
Adopted; under
construction
Isabel Neighborhood
Plan
1,132-acre area envisioned to
support up to 4,300 dwelling units
and up to 9,000 jobs
I-580/Isabel
Avenue (north
side of freeway)
Proposed
Sage Residential
Project
476 dwelling units Portola Drive/
Isabel Avenue
Approved; under
construction
City of San
Ramon
San Ramon City
Center
Phase 1: 279159 square feet
retail; 46,086 square feet cinema
Phase 2: 65,679 square feet retail;
169-room hotel; 487 dwelling units
Bollinger Canyon
Road/Camino
Ramon
Approved; under
construction
Multiple Bay Area Rapid
Transit District
(BART) Livermore
Extension
4.8-mile BART extension from
Dublin/Pleasanton Station to
I-580/Isabel Avenue
I-580 Median
(Dublin to
Livermore)
Planned
Source: City of Dublin, 2017; City of Pleasanton, 2017; City of Livermore, 2017.
City of Dublin—IKEA Retail Center Project
Errata Final SEIR
4-8 FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx
Appendix B, Air Quality/Greenhouse Gas Emissions Supporting Information
Table 10
The fleet mix in Table 10 has been revised to correct an erroneous entry.
Table 10: Project Vehicle Fleet Mix
Building Vehicle Type Number of Vehicle Trips
IKEA
Passenger Cars 5,980
Light-heavy Duty Trucks (2-axles) 20
Heavy-heavy Duty Trucks (4+axles) 10
Total IKEA Trips 6010
Retail Center
Passenger Cars(2) 10,83010,772
Light-heavy Duty Trucks (2-axles) 50
Heavy-heavy Duty Trucks (4+axles) 8
Total Retail Center Trips 10,80110,830
Total Project Trips 16,840
Source: Fehr & Peers, 2017.
City of Dublin—IKEA Retail Center Project
Final SEIR
FirstCarbon Solutions
Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\5 - Screencheck Final SEIR\37660005 Sec99-00 App div pg.docx
Appendix I:
Supplemental Air Quality Supporting Information
THIS PAGE INTENTIONALLY LEFT BLANK
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 1,026.00 Space 4.00 464,212.00 0
Parking Lot 568.00 Space 10.57 227,200.00 0
High Turnover (Sit Down Restaurant)58.44 1000sqft 1.55 58,440.00 0
Free-Standing Discount Superstore 339.10 1000sqft 9.65 339,099.00 0
Strip Mall 34.56 1000sqft 1.55 34,560.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
4
Wind Speed (m/s)Precipitation Freq (Days)2.2 63
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Pacific Gas & Electric Company
2020Operational Year
CO2 Intensity
(lb/MWhr)
519.21 0.023CH4 Intensity
(lb/MWhr)
0.005N2O Intensity
(lb/MWhr)
Dublin IKEA Retail Center Mitigated
Alameda County, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 1 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
Project Characteristics - PG&E Intensity Factors reduced by 19%.
Land Use - Land uses provided by applicant.
Construction Phase - 10 days Demo, 45 days Grading, 290 days Building Construction, 35 days Paving, and 45 days Painting.
Off-road Equipment -
Off-road Equipment - Building Construction equipment hours = 1.5 x default hours to account for the shortened Building Construction period.
Off-road Equipment -
Demolition - 147 tons builidng material + 290 tons of paving debris = 437.20 total tons of demolition debris
Architectural Coating - Non-Residential Interior and Exterior VOC set to 45 g/L.
Vehicle Trips - Trip Rates and Trip Length adjusted to match TIA.
Energy Use - Electricty usage for IKEA reduced by 29%.
Construction Off-road Equipment Mitigation - All equipment Tier 4 Interim. Water exposed area.
Mobile Land Use Mitigation - Mit TRANS-7A - Busstop 0.05 miles (Martinelli Wy); Project Design Feature 1 - Improve pedestrian network on project site and
connecting off-site;
Area Mitigation - Use low VOC Paint on non-res interior, 45 g/L.
Energy Mitigation - 42 percent renewable energy generated
Water Mitigation - Install low-flow fixtures and water-efficient irrigation systems.
Waste Mitigation - 50 percent waste diverted.
Operational Off-Road Equipment - .
Fleet Mix - Fleet mix updated to account for 70 2-axle trucks and 18 4-axle.
Stationary Sources - Emergency Generators and Fire Pumps - 1 backup generator at IKEA, run 0.5 hours, 6 hour/year, 2,923 HP; load factor 0.5.
Grading - 95,000 cy cut and 73,700 cy fill = 21,300 cy exported offsite
Table Name Column Name Default Value New Value
tblArchitecturalCoating EF_Nonresidential_Exterior 150.00 45.00
tblArchitecturalCoating EF_Nonresidential_Interior 100.00 45.00
tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV
alue
100 45
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 2 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstructionPhase NumDays 30.00 10.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 3 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
tblConstructionPhase NumDays 440.00 290.00
tblConstructionPhase NumDays 35.00 45.00
tblEnergyUse LightingElect 1.75 1.24
tblEnergyUse LightingElect 5.25 3.72
tblEnergyUse NT24E 0.19 0.13
tblEnergyUse NT24E 2.68 1.91
tblEnergyUse T24E 3.92 2.78
tblEnergyUse T24E 2.76 1.96
tblFleetMix HHD 0.04 0.33
tblFleetMix HHD 0.04 0.00
tblFleetMix HHD 0.04 0.00
tblFleetMix HHD 0.04 0.33
tblFleetMix HHD 0.04 0.00
tblFleetMix LDA 0.56 0.00
tblFleetMix LDA 0.56 0.62
tblFleetMix LDA 0.56 0.62
tblFleetMix LDA 0.56 0.00
tblFleetMix LDA 0.56 0.62
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT2 0.19 0.00
tblFleetMix LDT2 0.19 0.21
tblFleetMix LDT2 0.19 0.21
tblFleetMix LDT2 0.19 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 4 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
tblFleetMix LDT2 0.19 0.21
tblFleetMix LHD1 0.02 0.67
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.67
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix MCY 5.5690e-003 0.00
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MCY 5.5690e-003 0.00
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MDV 0.11 0.00
tblFleetMix MDV 0.11 0.12
tblFleetMix MDV 0.11 0.12
tblFleetMix MDV 0.11 0.00
tblFleetMix MDV 0.11 0.12
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MHD 0.02 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 5 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblGrading MaterialExported 0.00 21,300.00
tblLandUse LandUseSquareFeet 410,400.00 464,212.00
tblLandUse LandUseSquareFeet 339,100.00 339,099.00
tblLandUse LotAcreage 9.23 4.00
tblLandUse LotAcreage 5.11 10.57
tblLandUse LotAcreage 1.34 1.55
tblLandUse LotAcreage 7.78 9.65
tblLandUse LotAcreage 0.79 1.55
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 6 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
tblOffRoadEquipment UsageHours 7.00 11.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblOffRoadEquipment UsageHours 7.00 11.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblProjectCharacteristics CH4IntensityFactor 0.029 0.023
tblProjectCharacteristics CO2IntensityFactor 641.35 519.21
tblProjectCharacteristics N2OIntensityFactor 0.006 0.005
tblVehicleTrips CC_TL 7.30 31.00
tblVehicleTrips CC_TL 7.30 15.00
tblVehicleTrips CC_TL 7.30 9.00
tblVehicleTrips CC_TL 7.30 24.00
tblVehicleTrips CC_TL 7.30 9.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CNW_TL 7.30 31.00
tblVehicleTrips CNW_TL 7.30 15.00
tblVehicleTrips CNW_TL 7.30 9.00
tblVehicleTrips CNW_TL 7.30 24.00
tblVehicleTrips CNW_TL 7.30 9.00
tblVehicleTrips CW_TL 9.50 31.00
tblVehicleTrips CW_TL 9.50 15.00
tblVehicleTrips CW_TL 9.50 9.00
tblVehicleTrips CW_TL 9.50 24.00
tblVehicleTrips CW_TL 9.50 9.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips PR_TP 0.00 100.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 7 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
2.0 Emissions Summary
tblVehicleTrips ST_TR 0.00 0.03
tblVehicleTrips ST_TR 64.07 17.63
tblVehicleTrips ST_TR 158.37 126.64
tblVehicleTrips ST_TR 0.00 0.10
tblVehicleTrips ST_TR 42.04 97.54
tblVehicleTrips SU_TR 0.00 0.03
tblVehicleTrips SU_TR 56.12 17.63
tblVehicleTrips SU_TR 131.84 126.64
tblVehicleTrips SU_TR 0.00 0.10
tblVehicleTrips SU_TR 20.43 97.54
tblVehicleTrips WD_TR 0.00 0.03
tblVehicleTrips WD_TR 50.75 17.63
tblVehicleTrips WD_TR 127.15 126.64
tblVehicleTrips WD_TR 0.00 0.10
tblVehicleTrips WD_TR 44.32 97.54
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 8 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2018 5.7553 79.0019 39.1489 0.1112 9.9267 2.7087 12.6354 3.9322 2.4947 6.4268 0.0000 11,450.847
1
11,450.847
1
2.2295 0.0000 11,506.584
1
2019 6.2866 57.3195 45.0115 0.1264 4.8201 2.1561 6.9763 1.3068 2.0283 3.3351 0.0000 12,748.12
86
12,748.12
86
1.4275 0.0000 12,783.81
55
2020 47.0392 52.3209 42.5768 0.1249 4.8201 1.8395 6.6597 1.3068 1.7301 3.0369 0.0000 12,543.25
21
12,543.25
21
1.3765 0.0000 12,577.66
55
Maximum 47.0392 79.0019 45.0115 0.1264 9.9267 2.7087 12.6354 3.9322 2.4947 6.4268 0.0000 12,748.12
86
12,748.12
86
2.2295 0.0000 12,783.81
55
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2018 1.6762 38.7508 40.7821 0.1112 4.6034 0.1765 4.7798 1.7333 0.1732 1.9065 0.0000 11,450.847
1
11,450.847
1
2.2295 0.0000 11,506.584
1
2019 3.4889 41.6052 46.1326 0.1264 4.8201 0.3046 5.1247 1.3068 0.2961 1.6029 0.0000 12,748.12
86
12,748.12
86
1.4275 0.0000 12,783.81
55
2020 46.8515 39.5277 44.1862 0.1249 4.8201 0.2535 5.0737 1.3068 0.2473 1.5541 0.0000 12,543.25
21
12,543.25
21
1.3765 0.0000 12,577.66
55
Maximum 46.8515 41.6052 46.1326 0.1264 4.8201 0.3046 5.1247 1.7333 0.2961 1.9065 0.0000 12,748.12
86
12,748.12
86
2.2295 0.0000 12,783.81
55
Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 9 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
Mobile 25.1668 44.8840 304.9522 0.7693 74.6479 0.5878 75.2357 19.8113 0.5451 20.3564 76,794.61
41
76,794.61
41
2.7574 76,863.54
78
Stationary 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 38.0197 55.7332 312.2899 0.7983 74.6479 1.0962 75.7441 19.8113 1.0535 20.8649 81,836.58
78
81,836.58
78
2.9569 0.0770 81,933.46
21
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
11.96 36.45 -3.44 0.00 27.21 89.04 42.99 33.59 88.54 60.44 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 10 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
Mobile 24.2612 40.6929 280.3369 0.6823 65.8395 0.5293 66.3687 17.4736 0.4908 17.9643 68,090.22
29
68,090.22
29
2.5011 68,152.75
07
Stationary 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 36.6614 51.5420 287.6746 0.7112 65.8395 1.0377 66.8772 17.4736 0.9992 18.4728 73,132.19
66
73,132.19
66
2.7006 0.0770 73,222.66
50
Mitigated Operational
3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
3.57 7.52 7.88 10.90 11.80 5.34 11.71 11.80 5.16 11.46 0.00 10.64 10.64 8.67 0.00 10.63
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 11 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 10/15/2018 10/26/2018 5 10
2 Grading Grading 10/27/2018 12/30/2018 5 45
3 Building Construction Building Construction 1/1/2019 2/10/2020 5 290
4 Paving Paving 2/11/2020 3/30/2020 5 35
5 Architectural Coating Architectural Coating 4/1/2020 6/2/2020 5 45
OffRoad Equipment
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 648,149; Non-Residential Outdoor: 216,050; Striped Parking Area:
41,485 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 14.57
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 12 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 11.00 231 0.29
Building Construction Forklifts 3 12.00 89 0.20
Building Construction Generator Sets 1 12.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 11.00 97 0.37
Building Construction Welders 1 12.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 43.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Grading 8 20.00 0.00 2,662.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Building Construction 9 435.00 184.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Architectural Coating 1 87.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 13 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.9356 0.0000 0.9356 0.1417 0.0000 0.1417 0.0000 0.0000
Off-Road 3.7190 38.3225 22.3040 0.0388 1.9386 1.9386 1.8048 1.8048 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Total 3.7190 38.3225 22.3040 0.0388 0.9356 1.9386 2.8741 0.1417 1.8048 1.9465 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Water Exposed Area
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 14 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0416 1.4108 0.2458 3.4600e-
003
0.0753 5.3600e-
003
0.0806 0.0206 5.1300e-
003
0.0258 366.5733 366.5733 0.0204 367.0827
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0694 0.0541 0.5090 1.2300e-
003
0.1232 8.7000e-
004
0.1241 0.0327 8.0000e-
004
0.0335 122.5729 122.5729 3.9000e-
003
122.6704
Total 0.1111 1.4649 0.7547 4.6900e-
003
0.1985 6.2300e-
003
0.2047 0.0533 5.9300e-
003
0.0593 489.1462 489.1462 0.0243 489.7531
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.3649 0.0000 0.3649 0.0552 0.0000 0.0552 0.0000 0.0000
Off-Road 0.5841 13.5576 24.6739 0.0388 0.0616 0.0616 0.0616 0.0616 0.0000 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Total 0.5841 13.5576 24.6739 0.0388 0.3649 0.0616 0.4265 0.0552 0.0616 0.1169 0.0000 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 15 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0416 1.4108 0.2458 3.4600e-
003
0.0753 5.3600e-
003
0.0806 0.0206 5.1300e-
003
0.0258 366.5733 366.5733 0.0204 367.0827
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0694 0.0541 0.5090 1.2300e-
003
0.1232 8.7000e-
004
0.1241 0.0327 8.0000e-
004
0.0335 122.5729 122.5729 3.9000e-
003
122.6704
Total 0.1111 1.4649 0.7547 4.6900e-
003
0.1985 6.2300e-
003
0.2047 0.0533 5.9300e-
003
0.0593 489.1462 489.1462 0.0243 489.7531
Mitigated Construction Off-Site
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.7269 0.0000 8.7269 3.6046 0.0000 3.6046 0.0000 0.0000
Off-Road 5.0901 59.5218 35.0894 0.0620 2.6337 2.6337 2.4230 2.4230 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Total 5.0901 59.5218 35.0894 0.0620 8.7269 2.6337 11.3606 3.6046 2.4230 6.0277 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 16 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.5726 19.4079 3.3809 0.0475 1.0356 0.0738 1.1093 0.2840 0.0706 0.3545 5,042.988
2
5,042.988
2
0.2803 5,049.995
7
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0926 0.0722 0.6786 1.6400e-
003
0.1643 1.1500e-
003
0.1655 0.0436 1.0600e-
003
0.0446 163.4305 163.4305 5.2000e-
003
163.5606
Total 0.6652 19.4801 4.0595 0.0492 1.1999 0.0749 1.2748 0.3275 0.0716 0.3992 5,206.418
7
5,206.418
7
0.2855 5,213.556
3
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.4035 0.0000 3.4035 1.4058 0.0000 1.4058 0.0000 0.0000
Off-Road 1.0110 19.2707 36.7226 0.0620 0.1015 0.1015 0.1015 0.1015 0.0000 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Total 1.0110 19.2707 36.7226 0.0620 3.4035 0.1015 3.5050 1.4058 0.1015 1.5073 0.0000 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 17 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.5726 19.4079 3.3809 0.0475 1.0356 0.0738 1.1093 0.2840 0.0706 0.3545 5,042.988
2
5,042.988
2
0.2803 5,049.995
7
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0926 0.0722 0.6786 1.6400e-
003
0.1643 1.1500e-
003
0.1655 0.0436 1.0600e-
003
0.0446 163.4305 163.4305 5.2000e-
003
163.5606
Total 0.6652 19.4801 4.0595 0.0492 1.1999 0.0749 1.2748 0.3275 0.0716 0.3992 5,206.418
7
5,206.418
7
0.2855 5,213.556
3
Mitigated Construction Off-Site
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Total 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 18 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.8522 23.5096 5.6090 0.0504 1.2467 0.1517 1.3984 0.3590 0.1451 0.5041 5,316.751
3
5,316.751
3
0.3512 5,325.531
2
Worker 1.8176 1.3780 13.0818 0.0347 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,450.642
3
3,450.642
3
0.0997 3,453.135
8
Total 2.6697 24.8876 18.6908 0.0851 4.8201 0.1762 4.9963 1.3068 0.1677 1.4745 8,767.393
6
8,767.393
6
0.4509 8,778.667
0
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 19 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.8522 23.5096 5.6090 0.0504 1.2467 0.1517 1.3984 0.3590 0.1451 0.5041 5,316.751
3
5,316.751
3
0.3512 5,325.531
2
Worker 1.8176 1.3780 13.0818 0.0347 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,450.642
3
3,450.642
3
0.0997 3,453.135
8
Total 2.6697 24.8876 18.6908 0.0851 4.8201 0.1762 4.9963 1.3068 0.1677 1.4745 8,767.393
6
8,767.393
6
0.4509 8,778.667
0
Mitigated Construction Off-Site
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Total 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 20 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.7115 21.5923 5.0273 0.0500 1.2467 0.1012 1.3480 0.3590 0.0968 0.4558 5,278.457
2
5,278.457
2
0.3254 5,286.593
1
Worker 1.6600 1.2179 11.7171 0.0336 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,343.881
9
3,343.881
9
0.0873 3,346.063
9
Total 2.3715 22.8101 16.7444 0.0836 4.8201 0.1251 4.9452 1.3068 0.1188 1.4256 8,622.339
1
8,622.339
1
0.4127 8,632.657
0
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 21 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.7115 21.5923 5.0273 0.0500 1.2467 0.1012 1.3480 0.3590 0.0968 0.4558 5,278.457
2
5,278.457
2
0.3254 5,286.593
1
Worker 1.6600 1.2179 11.7171 0.0336 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,343.881
9
3,343.881
9
0.0873 3,346.063
9
Total 2.3715 22.8101 16.7444 0.0836 4.8201 0.1251 4.9452 1.3068 0.1188 1.4256 8,622.339
1
8,622.339
1
0.4127 8,632.657
0
Mitigated Construction Off-Site
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3566 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 2.1478 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 22 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0572 0.0420 0.4040 1.1600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 115.3063 115.3063 3.0100e-
003
115.3815
Total 0.0572 0.0420 0.4040 1.1600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 115.3063 115.3063 3.0100e-
003
115.3815
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.3341 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.1253 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 23 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0572 0.0420 0.4040 1.1600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 115.3063 115.3063 3.0100e-
003
115.3815
Total 0.0572 0.0420 0.4040 1.1600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 115.3063 115.3063 3.0100e-
003
115.3815
Mitigated Construction Off-Site
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.2422 1.6838 1.8314 2.9700e-
003
0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928
Total 46.7072 1.6838 1.8314 2.9700e-
003
0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 24 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.3320 0.2436 2.3434 6.7100e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 668.7764 668.7764 0.0175 669.2128
Total 0.3320 0.2436 2.3434 6.7100e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 668.7764 668.7764 0.0175 669.2128
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0545 1.0598 1.8324 2.9700e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
0.0000 281.4481 281.4481 0.0218 281.9928
Total 46.5195 1.0598 1.8324 2.9700e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
0.0000 281.4481 281.4481 0.0218 281.9928
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 25 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
Increase Transit Accessibility
Improve Pedestrian Network
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.3320 0.2436 2.3434 6.7100e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 668.7764 668.7764 0.0175 669.2128
Total 0.3320 0.2436 2.3434 6.7100e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 668.7764 668.7764 0.0175 669.2128
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 26 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 24.2612 40.6929 280.3369 0.6823 65.8395 0.5293 66.3687 17.4736 0.4908 17.9643 68,090.22
29
68,090.22
29
2.5011 68,152.75
07
Unmitigated 25.1668 44.8840 304.9522 0.7693 74.6479 0.5878 75.2357 19.8113 0.5451 20.3564 76,794.61
41
76,794.61
41
2.7574 76,863.54
78
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Enclosed Parking with Elevator 30.78 30.78 30.78 347,322 306,338
Free-Standing Discount Superstore 5,978.33 5,978.33 5978.33 18,438,751 16,262,979
High Turnover (Sit Down Restaurant)7,400.84 7,400.84 7400.84 10,298,804 9,083,545
Parking Lot 56.80 56.80 56.80 496,205 437,653
Strip Mall 3,370.98 3,370.98 3370.98 6,092,242 5,373,357
Total 16,837.74 16,837.74 16,837.74 35,673,323 31,463,871
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Enclosed Parking with Elevator 31.00 31.00 31.00 0.00 100.00 0.00 100 0 0
Free-Standing Discount
Superstore
15.00 15.00 15.00 13.20 67.80 19.00 47.5 35.5 17
High Turnover (Sit Down
Restaurant)
9.00 9.00 9.00 8.50 72.50 19.00 37 20 43
Parking Lot 24.00 24.00 24.00 0.00 100.00 0.00 100 0 0
Strip Mall 9.00 9.00 9.00 16.60 64.40 19.00 45 40 15
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 27 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
NaturalGas
Unmitigated
0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
5.1 Mitigation Measures Energy
Percent of Electricity Use Generated with Renewable Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Enclosed Parking with Elevator 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000
Free-Standing Discount
Superstore
0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
High Turnover (Sit Down
Restaurant)
0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
Parking Lot 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000
Strip Mall 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 28 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Free-Standing
Discount
Superstore
2201.82 0.0238 0.2159 0.1813 1.3000e-
003
0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e-
003
4.7500e-
003
260.5771
High Turnover (Sit
Down Restaurant)
33283.6 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715
5
3,915.715
5
0.0751 0.0718 3,938.984
6
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Strip Mall 224.403 2.4200e-
003
0.0220 0.0185 1.3000e-
004
1.6700e-
003
1.6700e-
003
1.6700e-
003
1.6700e-
003
26.4004 26.4004 5.1000e-
004
4.8000e-
004
26.5573
Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 29 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
Use Low VOC Paint - Non-Residential Interior
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Free-Standing
Discount
Superstore
2.20182 0.0238 0.2159 0.1813 1.3000e-
003
0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e-
003
4.7500e-
003
260.5771
High Turnover (Sit
Down Restaurant)
33.2836 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715
5
3,915.715
5
0.0751 0.0718 3,938.984
6
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Strip Mall 0.224403 2.4200e-
003
0.0220 0.0185 1.3000e-
004
1.6700e-
003
1.6700e-
003
1.6700e-
003
1.6700e-
003
26.4004 26.4004 5.1000e-
004
4.8000e-
004
26.5573
Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 30 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Unmitigated 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
1.3136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0196 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Total 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 31 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
8.1 Mitigation Measures Waste
Institute Recycling and Composting Services
Install Low Flow Bathroom Faucet
Install Low Flow Kitchen Faucet
Install Low Flow Toilet
Use Water Efficient Irrigation System
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.8609 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0196 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Total 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Mitigated
9.0 Operational Offroad
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 32 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
11.0 Vegetation
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Emergency Generator 1 0.5 6 2923 0.5 Diesel
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
10.1 Stationary Sources
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Equipment Type lb/day lb/day
Emergency
Generator -
Diesel (750 -
9999 HP)
1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Unmitigated/Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 33 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Winter
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 1,026.00 Space 4.00 464,212.00 0
Parking Lot 568.00 Space 10.57 227,200.00 0
High Turnover (Sit Down Restaurant)58.44 1000sqft 1.55 58,440.00 0
Free-Standing Discount Superstore 339.10 1000sqft 9.65 339,099.00 0
Strip Mall 34.56 1000sqft 1.55 34,560.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
4
Wind Speed (m/s)Precipitation Freq (Days)2.2 63
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Pacific Gas & Electric Company
2020Operational Year
CO2 Intensity
(lb/MWhr)
519.21 0.023CH4 Intensity
(lb/MWhr)
0.005N2O Intensity
(lb/MWhr)
Dublin IKEA Retail Center Mitigated
Alameda County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 1 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
Project Characteristics - PG&E Intensity Factors reduced by 19%.
Land Use - Land uses provided by applicant.
Construction Phase - 10 days Demo, 45 days Grading, 290 days Building Construction, 35 days Paving, and 45 days Painting.
Off-road Equipment -
Off-road Equipment - Building Construction equipment hours = 1.5 x default hours to account for the shortened Building Construction period.
Off-road Equipment -
Demolition - 147 tons builidng material + 290 tons of paving debris = 437.20 total tons of demolition debris
Architectural Coating - Non-Residential Interior and Exterior VOC set to 45 g/L.
Vehicle Trips - Trip Rates and Trip Length adjusted to match TIA.
Energy Use - Electricty usage for IKEA reduced by 29%.
Construction Off-road Equipment Mitigation - All equipment Tier 4 Interim. Water exposed area.
Mobile Land Use Mitigation - Mit TRANS-7A - Busstop 0.05 miles (Martinelli Wy); Project Design Feature 1 - Improve pedestrian network on project site and
connecting off-site;
Area Mitigation - Use low VOC Paint on non-res interior, 45 g/L.
Energy Mitigation - 42 percent renewable energy generated
Water Mitigation - Install low-flow fixtures and water-efficient irrigation systems.
Waste Mitigation - 50 percent waste diverted.
Operational Off-Road Equipment - .
Fleet Mix - Fleet mix updated to account for 70 2-axle trucks and 18 4-axle.
Stationary Sources - Emergency Generators and Fire Pumps - 1 backup generator at IKEA, run 0.5 hours, 6 hour/year, 2,923 HP; load factor 0.5.
Grading - 95,000 cy cut and 73,700 cy fill = 21,300 cy exported offsite
Table Name Column Name Default Value New Value
tblArchitecturalCoating EF_Nonresidential_Exterior 150.00 45.00
tblArchitecturalCoating EF_Nonresidential_Interior 100.00 45.00
tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV
alue
100 45
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 2 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstEquipMitigation Tier No Change Tier 4 Interim
tblConstructionPhase NumDays 30.00 10.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 3 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
tblConstructionPhase NumDays 440.00 290.00
tblConstructionPhase NumDays 35.00 45.00
tblEnergyUse LightingElect 1.75 1.24
tblEnergyUse LightingElect 5.25 3.72
tblEnergyUse NT24E 0.19 0.13
tblEnergyUse NT24E 2.68 1.91
tblEnergyUse T24E 3.92 2.78
tblEnergyUse T24E 2.76 1.96
tblFleetMix HHD 0.04 0.33
tblFleetMix HHD 0.04 0.00
tblFleetMix HHD 0.04 0.00
tblFleetMix HHD 0.04 0.33
tblFleetMix HHD 0.04 0.00
tblFleetMix LDA 0.56 0.00
tblFleetMix LDA 0.56 0.62
tblFleetMix LDA 0.56 0.62
tblFleetMix LDA 0.56 0.00
tblFleetMix LDA 0.56 0.62
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT2 0.19 0.00
tblFleetMix LDT2 0.19 0.21
tblFleetMix LDT2 0.19 0.21
tblFleetMix LDT2 0.19 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 4 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
tblFleetMix LDT2 0.19 0.21
tblFleetMix LHD1 0.02 0.67
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD1 0.02 0.67
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix LHD2 5.2280e-003 0.00
tblFleetMix MCY 5.5690e-003 0.00
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MCY 5.5690e-003 0.00
tblFleetMix MCY 5.5690e-003 6.0000e-003
tblFleetMix MDV 0.11 0.00
tblFleetMix MDV 0.11 0.12
tblFleetMix MDV 0.11 0.12
tblFleetMix MDV 0.11 0.00
tblFleetMix MDV 0.11 0.12
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MH 7.5900e-004 0.00
tblFleetMix MHD 0.02 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 5 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix OBUS 2.1180e-003 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix SBUS 3.0800e-004 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblFleetMix UBUS 2.8050e-003 0.00
tblGrading MaterialExported 0.00 21,300.00
tblLandUse LandUseSquareFeet 410,400.00 464,212.00
tblLandUse LandUseSquareFeet 339,100.00 339,099.00
tblLandUse LotAcreage 9.23 4.00
tblLandUse LotAcreage 5.11 10.57
tblLandUse LotAcreage 1.34 1.55
tblLandUse LotAcreage 7.78 9.65
tblLandUse LotAcreage 0.79 1.55
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 6 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
tblOffRoadEquipment UsageHours 7.00 11.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblOffRoadEquipment UsageHours 7.00 11.00
tblOffRoadEquipment UsageHours 8.00 12.00
tblProjectCharacteristics CH4IntensityFactor 0.029 0.023
tblProjectCharacteristics CO2IntensityFactor 641.35 519.21
tblProjectCharacteristics N2OIntensityFactor 0.006 0.005
tblVehicleTrips CC_TL 7.30 31.00
tblVehicleTrips CC_TL 7.30 15.00
tblVehicleTrips CC_TL 7.30 9.00
tblVehicleTrips CC_TL 7.30 24.00
tblVehicleTrips CC_TL 7.30 9.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CC_TTP 0.00 100.00
tblVehicleTrips CNW_TL 7.30 31.00
tblVehicleTrips CNW_TL 7.30 15.00
tblVehicleTrips CNW_TL 7.30 9.00
tblVehicleTrips CNW_TL 7.30 24.00
tblVehicleTrips CNW_TL 7.30 9.00
tblVehicleTrips CW_TL 9.50 31.00
tblVehicleTrips CW_TL 9.50 15.00
tblVehicleTrips CW_TL 9.50 9.00
tblVehicleTrips CW_TL 9.50 24.00
tblVehicleTrips CW_TL 9.50 9.00
tblVehicleTrips PR_TP 0.00 100.00
tblVehicleTrips PR_TP 0.00 100.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 7 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
2.0 Emissions Summary
tblVehicleTrips ST_TR 0.00 0.03
tblVehicleTrips ST_TR 64.07 17.63
tblVehicleTrips ST_TR 158.37 126.64
tblVehicleTrips ST_TR 0.00 0.10
tblVehicleTrips ST_TR 42.04 97.54
tblVehicleTrips SU_TR 0.00 0.03
tblVehicleTrips SU_TR 56.12 17.63
tblVehicleTrips SU_TR 131.84 126.64
tblVehicleTrips SU_TR 0.00 0.10
tblVehicleTrips SU_TR 20.43 97.54
tblVehicleTrips WD_TR 0.00 0.03
tblVehicleTrips WD_TR 50.75 17.63
tblVehicleTrips WD_TR 127.15 126.64
tblVehicleTrips WD_TR 0.00 0.10
tblVehicleTrips WD_TR 44.32 97.54
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 8 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2018 5.7349 78.5213 38.8747 0.1122 9.9267 2.7074 12.6341 3.9322 2.4934 6.4256 0.0000 11,556.913
9
11,556.913
9
2.2092 0.0000 11,612.143
3
2019 6.1714 56.7724 44.9687 0.1308 4.8201 2.1539 6.9740 1.3068 2.0262 3.3330 0.0000 13,195.46
96
13,195.46
96
1.4009 0.0000 13,230.49
31
2020 47.0255 51.8731 42.5837 0.1292 4.8201 1.8380 6.6581 1.3068 1.7286 3.0354 0.0000 12,982.34
33
12,982.34
33
1.3522 0.0000 13,016.14
86
Maximum 47.0255 78.5213 44.9687 0.1308 9.9267 2.7074 12.6341 3.9322 2.4934 6.4256 0.0000 13,195.46
96
13,195.46
96
2.2092 0.0000 13,230.49
31
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2018 1.6558 38.2703 40.5079 0.1122 4.6034 0.1752 4.7785 1.7333 0.1719 1.9053 0.0000 11,556.913
9
11,556.913
9
2.2092 0.0000 11,612.143
3
2019 3.3737 41.0580 46.0898 0.1308 4.8201 0.3024 5.1225 1.3068 0.2940 1.6008 0.0000 13,195.46
96
13,195.46
96
1.4009 0.0000 13,230.49
31
2020 46.8378 39.0799 44.1931 0.1292 4.8201 0.2520 5.0721 1.3068 0.2458 1.5526 0.0000 12,982.34
33
12,982.34
33
1.3522 0.0000 13,016.14
86
Maximum 46.8378 41.0580 46.0898 0.1308 4.8201 0.3024 5.1225 1.7333 0.2940 1.9053 0.0000 13,195.46
96
13,195.46
96
2.2092 0.0000 13,230.49
31
Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 9 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
Mobile 30.0564 38.6111 298.8805 0.8301 74.6479 0.5873 75.2352 19.8113 0.5447 20.3560 82,895.07
31
82,895.07
31
2.7478 82,963.76
79
Stationary 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 42.9093 49.4603 306.2182 0.8590 74.6479 1.0958 75.7437 19.8113 1.0531 20.8645 87,937.04
68
87,937.04
68
2.9473 0.0770 88,033.68
22
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
11.99 36.74 -3.45 0.00 27.21 89.11 42.99 33.59 88.61 60.46 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 10 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
Mobile 29.1340 35.0229 271.1314 0.7359 65.8395 0.5288 66.3683 17.4736 0.4904 17.9639 73,476.22
62
73,476.22
62
2.4745 73,538.08
78
Stationary 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 41.5341 45.8721 278.4691 0.7648 65.8395 1.0373 66.8768 17.4736 0.9988 18.4724 78,518.19
99
78,518.19
99
2.6740 0.0770 78,608.00
21
Mitigated Operational
3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
3.20 7.25 9.06 10.97 11.80 5.34 11.71 11.80 5.16 11.46 0.00 10.71 10.71 9.27 0.00 10.71
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 11 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 10/15/2018 10/26/2018 5 10
2 Grading Grading 10/27/2018 12/30/2018 5 45
3 Building Construction Building Construction 1/1/2019 2/10/2020 5 290
4 Paving Paving 2/11/2020 3/30/2020 5 35
5 Architectural Coating Architectural Coating 4/1/2020 6/2/2020 5 45
OffRoad Equipment
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 648,149; Non-Residential Outdoor: 216,050; Striped Parking Area:
41,485 (Architectural Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 14.57
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 12 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 11.00 231 0.29
Building Construction Forklifts 3 12.00 89 0.20
Building Construction Generator Sets 1 12.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 11.00 97 0.37
Building Construction Welders 1 12.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 43.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Grading 8 20.00 0.00 2,662.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Building Construction 9 435.00 184.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
Architectural Coating 1 87.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 13 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.9356 0.0000 0.9356 0.1417 0.0000 0.1417 0.0000 0.0000
Off-Road 3.7190 38.3225 22.3040 0.0388 1.9386 1.9386 1.8048 1.8048 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Total 3.7190 38.3225 22.3040 0.0388 0.9356 1.9386 2.8741 0.1417 1.8048 1.9465 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Water Exposed Area
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 14 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0404 1.3769 0.2235 3.5200e-
003
0.0753 5.2700e-
003
0.0805 0.0206 5.0400e-
003
0.0257 373.2552 373.2552 0.0189 373.7271
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0664 0.0435 0.5334 1.3400e-
003
0.1232 8.7000e-
004
0.1241 0.0327 8.0000e-
004
0.0335 133.1811 133.1811 4.1200e-
003
133.2842
Total 0.1068 1.4204 0.7568 4.8600e-
003
0.1985 6.1400e-
003
0.2046 0.0533 5.8400e-
003
0.0592 506.4362 506.4362 0.0230 507.0113
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.3649 0.0000 0.3649 0.0552 0.0000 0.0552 0.0000 0.0000
Off-Road 0.5841 13.5576 24.6739 0.0388 0.0616 0.0616 0.0616 0.0616 0.0000 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Total 0.5841 13.5576 24.6739 0.0388 0.3649 0.0616 0.4265 0.0552 0.0616 0.1169 0.0000 3,871.766
5
3,871.766
5
1.0667 3,898.434
4
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 15 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.2 Demolition - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0404 1.3769 0.2235 3.5200e-
003
0.0753 5.2700e-
003
0.0805 0.0206 5.0400e-
003
0.0257 373.2552 373.2552 0.0189 373.7271
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0664 0.0435 0.5334 1.3400e-
003
0.1232 8.7000e-
004
0.1241 0.0327 8.0000e-
004
0.0335 133.1811 133.1811 4.1200e-
003
133.2842
Total 0.1068 1.4204 0.7568 4.8600e-
003
0.1985 6.1400e-
003
0.2046 0.0533 5.8400e-
003
0.0592 506.4362 506.4362 0.0230 507.0113
Mitigated Construction Off-Site
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 8.7269 0.0000 8.7269 3.6046 0.0000 3.6046 0.0000 0.0000
Off-Road 5.0901 59.5218 35.0894 0.0620 2.6337 2.6337 2.4230 2.4230 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Total 5.0901 59.5218 35.0894 0.0620 8.7269 2.6337 11.3606 3.6046 2.4230 6.0277 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 16 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.5563 18.9415 3.0741 0.0484 1.0356 0.0725 1.1080 0.2840 0.0693 0.3533 5,134.910
7
5,134.910
7
0.2597 5,141.403
3
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0885 0.0580 0.7112 1.7800e-
003
0.1643 1.1500e-
003
0.1655 0.0436 1.0600e-
003
0.0446 177.5748 177.5748 5.5000e-
003
177.7122
Total 0.6448 18.9996 3.7853 0.0502 1.1999 0.0736 1.2735 0.3275 0.0704 0.3979 5,312.485
5
5,312.485
5
0.2652 5,319.115
5
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 3.4035 0.0000 3.4035 1.4058 0.0000 1.4058 0.0000 0.0000
Off-Road 1.0110 19.2707 36.7226 0.0620 0.1015 0.1015 0.1015 0.1015 0.0000 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Total 1.0110 19.2707 36.7226 0.0620 3.4035 0.1015 3.5050 1.4058 0.1015 1.5073 0.0000 6,244.428
4
6,244.428
4
1.9440 6,293.027
8
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 17 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.3 Grading - 2018
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.5563 18.9415 3.0741 0.0484 1.0356 0.0725 1.1080 0.2840 0.0693 0.3533 5,134.910
7
5,134.910
7
0.2597 5,141.403
3
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0885 0.0580 0.7112 1.7800e-
003
0.1643 1.1500e-
003
0.1655 0.0436 1.0600e-
003
0.0446 177.5748 177.5748 5.5000e-
003
177.7122
Total 0.6448 18.9996 3.7853 0.0502 1.1999 0.0736 1.2735 0.3275 0.0704 0.3979 5,312.485
5
5,312.485
5
0.2652 5,319.115
5
Mitigated Construction Off-Site
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Total 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 18 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.8138 23.2328 4.8588 0.0518 1.2467 0.1494 1.3962 0.3590 0.1430 0.5019 5,465.082
2
5,465.082
2
0.3186 5,473.046
9
Worker 1.7407 1.1077 13.7892 0.0377 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,749.652
4
3,749.652
4
0.1058 3,752.297
7
Total 2.5545 24.3405 18.6480 0.0895 4.8201 0.1739 4.9941 1.3068 0.1656 1.4724 9,214.734
6
9,214.734
6
0.4244 9,225.344
6
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735
0
3,980.735
0
0.9765 4,005.148
5
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 19 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.4 Building Construction - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.8138 23.2328 4.8588 0.0518 1.2467 0.1494 1.3962 0.3590 0.1430 0.5019 5,465.082
2
5,465.082
2
0.3186 5,473.046
9
Worker 1.7407 1.1077 13.7892 0.0377 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,749.652
4
3,749.652
4
0.1058 3,752.297
7
Total 2.5545 24.3405 18.6480 0.0895 4.8201 0.1739 4.9941 1.3068 0.1656 1.4724 9,214.734
6
9,214.734
6
0.4244 9,225.344
6
Mitigated Construction Off-Site
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Total 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 20 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.6769 21.3830 4.3424 0.0514 1.2467 0.0997 1.3464 0.3590 0.0954 0.4543 5,427.606
9
5,427.606
9
0.2953 5,434.988
6
Worker 1.5914 0.9793 12.4089 0.0365 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,633.823
4
3,633.823
4
0.0931 3,636.151
5
Total 2.2683 22.3623 16.7513 0.0879 4.8201 0.1235 4.9437 1.3068 0.1173 1.4241 9,061.430
3
9,061.430
3
0.3884 9,071.140
1
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913
0
3,920.913
0
0.9638 3,945.008
5
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 21 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.4 Building Construction - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.6769 21.3830 4.3424 0.0514 1.2467 0.0997 1.3464 0.3590 0.0954 0.4543 5,427.606
9
5,427.606
9
0.2953 5,434.988
6
Worker 1.5914 0.9793 12.4089 0.0365 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,633.823
4
3,633.823
4
0.0931 3,636.151
5
Total 2.2683 22.3623 16.7513 0.0879 4.8201 0.1235 4.9437 1.3068 0.1173 1.4241 9,061.430
3
9,061.430
3
0.3884 9,071.140
1
Mitigated Construction Off-Site
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 1.3566 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 2.1478 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 22 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0549 0.0338 0.4279 1.2600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 125.3043 125.3043 3.2100e-
003
125.3845
Total 0.0549 0.0338 0.4279 1.2600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 125.3043 125.3043 3.2100e-
003
125.3845
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.3341 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 1.1253 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733
4
2,207.733
4
0.7140 2,225.584
1
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 23 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.5 Paving - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0549 0.0338 0.4279 1.2600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 125.3043 125.3043 3.2100e-
003
125.3845
Total 0.0549 0.0338 0.4279 1.2600e-
003
0.1232 8.2000e-
004
0.1240 0.0327 7.6000e-
004
0.0334 125.3043 125.3043 3.2100e-
003
125.3845
Mitigated Construction Off-Site
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.2422 1.6838 1.8314 2.9700e-
003
0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928
Total 46.7072 1.6838 1.8314 2.9700e-
003
0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 24 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.3183 0.1959 2.4818 7.2900e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 726.7647 726.7647 0.0186 727.2303
Total 0.3183 0.1959 2.4818 7.2900e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 726.7647 726.7647 0.0186 727.2303
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0545 1.0598 1.8324 2.9700e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
0.0000 281.4481 281.4481 0.0218 281.9928
Total 46.5195 1.0598 1.8324 2.9700e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
3.9600e-
003
0.0000 281.4481 281.4481 0.0218 281.9928
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 25 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
Increase Transit Accessibility
Improve Pedestrian Network
3.6 Architectural Coating - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.3183 0.1959 2.4818 7.2900e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 726.7647 726.7647 0.0186 727.2303
Total 0.3183 0.1959 2.4818 7.2900e-
003
0.7147 4.7700e-
003
0.7195 0.1896 4.4000e-
003
0.1940 726.7647 726.7647 0.0186 727.2303
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 26 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 29.1340 35.0229 271.1314 0.7359 65.8395 0.5288 66.3683 17.4736 0.4904 17.9639 73,476.22
62
73,476.22
62
2.4745 73,538.08
78
Unmitigated 30.0564 38.6111 298.8805 0.8301 74.6479 0.5873 75.2352 19.8113 0.5447 20.3560 82,895.07
31
82,895.07
31
2.7478 82,963.76
79
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Enclosed Parking with Elevator 30.78 30.78 30.78 347,322 306,338
Free-Standing Discount Superstore 5,978.33 5,978.33 5978.33 18,438,751 16,262,979
High Turnover (Sit Down Restaurant)7,400.84 7,400.84 7400.84 10,298,804 9,083,545
Parking Lot 56.80 56.80 56.80 496,205 437,653
Strip Mall 3,370.98 3,370.98 3370.98 6,092,242 5,373,357
Total 16,837.74 16,837.74 16,837.74 35,673,323 31,463,871
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Enclosed Parking with Elevator 31.00 31.00 31.00 0.00 100.00 0.00 100 0 0
Free-Standing Discount
Superstore
15.00 15.00 15.00 13.20 67.80 19.00 47.5 35.5 17
High Turnover (Sit Down
Restaurant)
9.00 9.00 9.00 8.50 72.50 19.00 37 20 43
Parking Lot 24.00 24.00 24.00 0.00 100.00 0.00 100 0 0
Strip Mall 9.00 9.00 9.00 16.60 64.40 19.00 45 40 15
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 27 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
NaturalGas
Unmitigated
0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.1190
5.1 Mitigation Measures Energy
Percent of Electricity Use Generated with Renewable Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Enclosed Parking with Elevator 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000
Free-Standing Discount
Superstore
0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
High Turnover (Sit Down
Restaurant)
0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
Parking Lot 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000
Strip Mall 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 28 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Free-Standing
Discount
Superstore
2201.82 0.0238 0.2159 0.1813 1.3000e-
003
0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e-
003
4.7500e-
003
260.5771
High Turnover (Sit
Down Restaurant)
33283.6 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715
5
3,915.715
5
0.0751 0.0718 3,938.984
6
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Strip Mall 224.403 2.4200e-
003
0.0220 0.0185 1.3000e-
004
1.6700e-
003
1.6700e-
003
1.6700e-
003
1.6700e-
003
26.4004 26.4004 5.1000e-
004
4.8000e-
004
26.5573
Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 29 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
Use Low VOC Paint - Non-Residential Interior
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Free-Standing
Discount
Superstore
2.20182 0.0238 0.2159 0.1813 1.3000e-
003
0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e-
003
4.7500e-
003
260.5771
High Turnover (Sit
Down Restaurant)
33.2836 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715
5
3,915.715
5
0.0751 0.0718 3,938.984
6
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Strip Mall 0.224403 2.4200e-
003
0.0220 0.0185 1.3000e-
004
1.6700e-
003
1.6700e-
003
1.6700e-
003
1.6700e-
003
26.4004 26.4004 5.1000e-
004
4.8000e-
004
26.5573
Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153
6
4,201.153
6
0.0805 0.0770 4,226.119
0
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 30 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Unmitigated 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
1.3136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0196 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Total 10.8250 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 31 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
8.1 Mitigation Measures Waste
Institute Recycling and Composting Services
Install Low Flow Bathroom Faucet
Install Low Flow Kitchen Faucet
Install Low Flow Toilet
Use Water Efficient Irrigation System
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.8609 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0196 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Total 10.3723 1.9200e-
003
0.2082 2.0000e-
005
7.5000e-
004
7.5000e-
004
7.5000e-
004
7.5000e-
004
0.4434 0.4434 1.1900e-
003
0.4731
Mitigated
9.0 Operational Offroad
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 32 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer
11.0 Vegetation
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Emergency Generator 1 0.5 6 2923 0.5 Diesel
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
10.1 Stationary Sources
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Equipment Type lb/day lb/day
Emergency
Generator -
Diesel (750 -
9999 HP)
1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Total 1.6428 7.3463 4.1887 7.8900e-
003
0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222
Unmitigated/Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 33 of 33
Dublin IKEA Retail Center Mitigated - Alameda County, Summer