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Home My WebLink AboutItem 6.3 Dublin Ranch Areas FGH CITY CLERK File # 0450-30 AGENDA STATEMENT CITY COUNCIL MEETING DATE: February 15, 2000 SUBJECT: PUBLIC HEARING PA 98-068, 98-069 and 98-070 Dublin Ranch Areas F, G and H (Previously known as the Pao Lin Property); General Plan / Eastern Dublin Specific Plan Amendment; Stage I Planned Development Rezone for Areas F (PA 98-068), and H (PA 98-070); Stage I and Stage II Planned Development Rezone for Area G (PA 98-069) and individual Mitigated Negative Declarations for Areas F, G and H. (Report Prepared by: Anne Kinney, Assistant Planner and Mike Porto, Consulting Planner) ATTACHMENTS: (Under Separate Cover) City Council ResolutiOn adopting individual Mitigated Negative Declarations and Mitigated Monitoring Programs as further clarified by the Response to Comments for Area F'(PA 98-068), Area G (PA 98-069) and Area H (PA 98-070) with the following Exhibits included: Exhibit A: The Mitigation Monitoring Programs for Areas F, G and H. (The Mitigated Negative Declarations are incorporated herein by reference) Exhibit B: Response to Mitigated Negative Declaration Comments, Areas F, G and H City Council Resolution approving a General Plan Amendment and an Amendment to the Eastern Dublin Specific Plan for Area F (PA 98-068), Area G (PA 98-069) and Area H (PA 98-070) with the following Exhibits 'included: Exhibit A: GP/EDSP Land Use Map Exhibit B: EDSP Planning Subareas Map Exhibit C: Proposed EDSP text amendments Exhibit D: GP text amendments Exhibit E: EDSP Appendix 4 update Exhibit F: EDSP Town Center Concept Plan. City Council Ordinance adopting a Planned Development (PD) Rezone/Development Plan Stage I for Area F (PA 98-068) and Area H (PA 98-070) and a Planned Development (PD) Rezone/Development Plan Stage I and II for Area G (PA 98-069) with the following Exhibits attached as: Exhibit A-1 & A-2: Area F: Development Plans Exhibit B-1 & B-2: Area G: Development Plans Exhibit C-1 & C-2: Area H: Development Plans g/pa\98-068\ccsrfeb 15.doc COPIES TO: Applicant Property Owner PA File ITEM NO. Fiscal Analysis for Areas F, G and H prepared by EDAW, Inc. Peer Review of EDAW's Fiscal Analysis prepared by ERA Applicants written statement regarding the requested General Plan / Eastern Dublin Specific Plan amendments. Letter from Martin Inderbitzen re: Mitigated Negative Declarations RECOMMENDATION: , 2. 3. 4. 5. 6. 7. o 10. Hear Staff Presentation Open Public Hearing Hear Applicant' s Presentation Question Staff, Applicant and the Public Close Public Hearing Deliberate Adopt Attachment 1, City Council Resolution approving individual Mitigated Negative Declarations for Area F (PA 98-068), Area G (PA 98-069), & Area H (PA 98- 070) of Dublin Ranch herein incorporated by reference with the Mitigated Monitoring Programs for Areas F, G and H included as Exhibit A and the Response to Comments included as Exhibit B, and Adopt Attachment 2, City Council Resolution approving the General Plan Amendment and Eastern Dublin Specific Plan Amendment for Areas F, G & H (PA 98-068, 069 and 070) of Dublin Ranch with Exhibits A, B, C, D, E and F included, and Waive reading and introduce the Ordinance Attachment 3 amending the Dublin Zoning Ordnance to approve a Planned Development (PD) Rezone/Development Plan Stage I for Area F (PA 98-068) and Area H (PA 98-070) and a Planned Development (PD) Rezone/Development Plan Stage I and II for Area G (PA 98- 069) with the Development Plans included as Exhibits A-1 & A-2, B-1 & B-2 and C-1 & C-2. Schedule the second reading of the Ordinance for the March 7, 2000 City Council meeting. BACKGROUND: The Eastern Dublin Specific Plan was adopted by the City of Dublin in January of 1994, and established land use designations for approximately 3,3.00 acres of land east of the Camp Parks Military Reserve. A large component of the plan (Dublin Ranch) was annexed to the City in 1995, including 1,037 acres owned by the Jennifer Lin Family and 304 acres owned by Pao Lin. Upon annexation, the Dublin Ranch properties were prezoned to a Planned Development overlay zone. The Pao Lin holdings were recently acquired by Jennifer Lin and are now the subject of this application. The land area was divided into three planning areas for ease of project processing: Areas F, G and H. Area F is the northern most portion of the project site and directly abuts Dublin Ranch Phase I to the north and Central Parkway to the south. Area G, the central portion of the site, is bounded by Dublin Boulevard to the south and Central Parkway to the north. Area H, the southern most planning area, is bounded by 1- 580 to the south and Dublin Boulevard to the north. All three Planning Areas are bounded on west by the DiManto Property (Dublin Land Company) and on the east by Areas B and C of Dublin Ranch. PROJECT DESCRIPTION: This application includes a General Plan and Eastern Dublin Specific Plan Amendment to relocate various land uses and acreages within Areas F, G and H (previously know as the Pao Lin property) of Dublin Ranch, on approximately 304 acres of land located north ofi-580 and east of Tassajara Road within the Eastern Dublin Specific Plan area. The project also consists of a Stage 1 Planned Development Rezone / Development Plan for Areas F and H and a Stage 1 & 2 Planned Development Rezone / Development Plan for Area G. Additional descriptions of the development concepts are contained in the proposed development plans for Areas F, G and H included as Exhibits A-1 & A-2, B-1 & B-2 and C-1 & C-2 of Attachment 3 to this staff report. ENVIRONMENTAL REVIEW Approval of the proposed General Plan / Eastern Dublin Specific Plan Amendments, Planned Development Rezoning / Development Plans, future Tentative Map and future amendment to the existing .Development Agreement for Areas F, G and H of Dublin Ranch are within the Dublin General Plan's Eastern Extended Planning Area and the Eastern Dublin Specific Plan Area, which was the subject of an Enviromnental Impact Report, certified by the City of Dublin in 1993 (Addenda to the EIR were also approved, dated May 4, 1993 and August 22, 1994). The General Plan/Specific Plan EIR is a program EIR, which anticipated several subsequent actions related to future development in Eastern Dublin. The EIR did identify some impacts from implementation of the General Plan/Specific Plan that were not able to be mitigated. Upon certification of the EIR, the City adopted a Statement of Overriding Considerations for several impacts, some of which relate to this project. The City also adopted a mitigation-monitoring program, which included measures intended to reduce impacts from the development of Eastern Dublin area. These mitigation measures apply to project approvals and actions at various stages in the development process, and will be applied to this project as applicable. The timing of these mitigation measures is indicated in the City's EIR mitigation monitoring matrix (City Council Resolution # 53-93). Through the Initial Study process, several issues presented themselves requiring additional analysis and ultimately mitigation measures which caused three separate Mitigated Negative Declarations to be prepared; one for Area F, one for Area G and one for Area H. The Mitigated Negative Declarations were published for review on November 9, 1999, for the mandatory 30-day review period and were sent to the City Council under separate cover on November 9, 1999. During the Public Comment period a number of comments letters were received from local, state and federal agencies, including East Bay Regional Parks District, Regional Water Quality Control Board, Department ofFish and Game and U. S. Fish and Wildlife Service. Staff has prepared responses to each of these letters, refer to the Response to Comments attached to the staff report as Exhibit B of Attachment 1. The agencies' comments focused on the biological resources of the project site which include special- status species and habitats regulated under the jurisdiction of the US Army Corps of Engineers, US Fish and Wildlife Service, and the California Department of Fish and Game. Based on discussions with the project applicants, measures to mitigate loss of on-site breeding and movement (estivation) habitat for both species within Planning Area F have been refined and included in the original Initial Study/Mitigated Negative Declaration. Mitigation for this impact would now consist of permanently creating suitable red-legged frog and California tiger salamander habitat and preserving a minimum 63-acre site in the northern drainage area of the Dublin Ranch property. Other mitigations have also been included. The amended mitigation measures will reduce impacts to biological resources to a less-than-significant level. PROJECT OVERVIEW General Plan/Eastern Dublin Specific Plan Amendments: The proposed General Plan and Eastern Dublin Specific Plan Amendments primarily consist of relocating various land uses and acreages within Areas F, G and H and eliminating portions of the document that are no longer applicable. Refer to Attachments B-2 to B-7 to this staff report. A summary chart of the proposed changes in land use designations, acreages and potential square footage is included below. EXISTING AND PROPOSED LAND USE AREAS F, G AND H Land Use Category Present General Plan Proposed General Difference Acres (units/sq.ft.) Plan Acres (units/sq.ft.) Single Family Residential 23.6 (94) 22.7 (91) -0.9 (-3) Medium Density Residential 77.3 (776) 68.9 (689) -8.4 (-87) Medium-High Density Residential 11.0 (220) 26.2 (528) +15.2 (+308) High Density Residential 23.4 (819) 25.0 (876) +1.6 (+57) Residential Total 1909 2184 +275 Public/Semi-Public (governmental & institutional uses) 7.8 7.0 -0.8 Neighborhood Commercial/Village Center 2.0 (426,388) 22.0 (230,000) -6.0 (-196,888) Neighborhood Park 11.6 12.3 +0.7 Neighborhood Square 6.0 4.5 - 1.5 General Commercial 35.9 (390,951) 16.4 (178,596) -19.5 (-212,355) Campus Office 36.7 (559,528) 43.9 (860,528) +7.2 (+301,000) Campus Office or General Commercial Uses allowed through Stage 2 PD 10.5 +10.5 approval. (205,821) (+205,821) Commercial Total 1,377,367 1,474,945 +97,578 Open Space 3.0 4.2 +1.2 Middle School 31.4 30.6 -0.8 Elementary School 10.0 10.0 0 Planned Development Rezoning: Chapter 8.32 of the Dublin Zoning Ordinance establishes the intent, purpose and requirements of the Planned Development District. The intent of the Planned Development Zoning District is to create a more desirable use of land, a more coherent and coordinated development and a better physical environment than would otherwise be possible under a single zoning district or combination of zoning districts. The Zoning Ordinance requires that a Development Plan shall be adopted to establish regulations for the use, development, improvement, and maintenance of the property within the requested Planned Development Zoning District. The Zoning Ordinance further requires the adoption of both a Stage 1 and Stage 2 Development Plan with the reclassification of the property in question to the Planned Development Zoning District. The applicant is applying for a Stage 1 Development Plan for Areas F and H and both a Stage 1 and 2 Development Plan for Area G. An individual Development Plan has been prepared for Areas F, G and H, depicting development concepts and addressing the requirements of the Zoning Ordinance. The proposed Development Plans are attached and consist of Attachment C-2 and C-3 for each area. Attachment C-2 contains all of the Zoning Ordinance requirements for a Stage 1 and 2 Development Plan. Attachment C-3 contains, site, circulation and other plans, the applicant's written statement and design guidelines. GENERAL PLAN AMENDMENT/EASTERN DUBLIN SPECIFIC PLAN AMENDMENTS: The basis for the General Plan and Eastern Dublin Specific Plan Amendments originate in revisions made to the Eastern Dublin Specific Plan several years ago. In 1997, the City approved revisions to the vehicular access and circulation patterns in the Circulation Element of the General Plan and the Eastern Dublin Specific Plan which affected the implementation of the planning concept for the "Town Center- Commercial" area which includes a portion of Area F and G. The primary circulation change was the redesignation of Central Parkway from a two-lane Transit Spine to a four-lane arterial. The applicant also identified economic aspects associated with the original Town Center commercial land acreage which is significantly in excess of what it is anticipated today's market would absorb. General Plan Amendment/Specific Plan Amendment Issues: Fiscal Analysis: EDAW, Inc has prepared a market assessment of the proposed plan as it relates to the existing Specific Plan. This was due in large part to the belief that the original Specific Plan over estimated the ability of the market place to absorb the total square footage of commercial uses originally planned. The City contracted with ERA (the firm that prepared the original fiscal analysis for the Eastern Dublin Specific Plan adopted in 1994) to provide a peer review of EDAW's analysis of this plan. Their basic determination was that the proposed plan appears to be consistent with the intent of the original Specific Plan. The methods used by EDAW are reasonable approximations of cost and revenue flows that can be expected from the development. The proposed project will result in revenues to the City that are slightly higher than the revenues proposed in the original Specific Plan. Included for review as Attachment D-1 and D-2 is the EDAW analysis and the ERA review of that document. Transit Spine: The Transit Spine as originally designated in the Eastern Dublin Specific Plan was to accommodate on- street parking serving a local business district with shops opening on to the street and with pedestrian access easily achievable between each side of the street. The Eastern Dublin Specific Plan made provisions for a tiering of land uses with high-density residential uses adjacent to the commercial and medium-density uses adjacent to the high-density uses, etc. When the Transit Spine (named Central Parkway) was designated a four-lane arterial, the ability to create a "Town Center" with on-street parking serving front loaded shops was impractical. In addition, having a commercial district fronting directly 5 onto Central phrkway would inhibit vehicular and pedestrian traffic flow on that arterial. The accessibility and economic viability of businesses located along Central Parkway would be seriously impacted. The applicant realized the difficulties in trying to make the "Town Center" concept work, as detailed in the Eastern Dublin Specific Plan with the amended street designation, and felt that a revised concept that kept the intent of the original plan was appropriate. The applicant is proposing to reorient the "Town Center" in a north/south configuration along 'Main Street' a new street to be constructed between Central Parkway and Dublin Boulevard (within Area G). Moving the Town Center south and orienting it between two arterials separates commercial users from through-traffic and will result in a safer downtown area for both pedestrians and vehicles and will create a more efficient circulation system. Direct access to either end of Main Street will be provided from Dublin Boulevard and Central Parkway with additional access available by a number of collector streets which cross the area. Relocating the neighborhood commercial uses to Area G also necessitated moving the high density and medium high-density residential designated areas within Area F to locations east and west of 'Main Street'. Locating high-density neighborhoods adjacent to 'Main Street" would create a pedestrian orientated Town Center as envisioned in the Specific Plan and would also serve to support a viable commercial district. With the applicant's submittal, Area G will encompass the entire Town Center land use including, neighborhood commercial, multi-family residential, parks, public and semi-public uses and Area F will become a more traditional residential village with associated parks and schools. Area H will remain similar to the prezoning and General Plan/Specific Plan land use designations (see discussion of Area H below). In addition to the applicant's request for a General Plan and Specific Plan Amendment, Staff is including revisions to Appendix 4 of the Eastern Dublin Specific Plan which depicts the land area and breakdown of land uses for the Pao Lin Property. Additionally, wording changes to delete all references to the "Transit Spine," wording changes relating to Land Use Categories, revisions to the Eastern Dublin Specific Plan Planning Subarea and Town Center Concept Maps and revisions to the General Plan/Eastern Dublin Specific Plan Land Use Map are also necessary. General Plan Amendment/Specific Plan Amendment Analysis: Area F Analysis: Area F is bordered by Area E and Phase 1 of Dublin Ranch on the north, Dublin Ranch Area B on the east, Central Parkway to the south and Dublin Ranch Area E and the property of the Dublin Land Company (DiManto) on the west. In the applicant's proposal, Area F has been decreased in size from 156.8 acres to 146.5 acres due primarily to the final alignment of Central Parkway from that illustrated in the Specific Plan. Because of this reduction, Area G has increased in size a comparable amount. The existing Specific Plan shows 14 acres of Neighborhood ~ommercial, 11 acres of High Density Residential, and 11 acres of Medium-High Density Residential designated lands north of Central Parkway. This GP/EDSP amendment proposes the relocation of neighborhood commercial, high and medium high density residential uses to Area G and their replacement by Medium Density Residential uses within Area F. Refer to Attachment C-3, Area F. The Dublin Unified School District, has indicated it will not require the full 50 acres designated for a "high school" on the Specific Plan, of which 30 acres fall within this Project Area. The school site will be redesignated as a future Middle School and sited as show on the Stage I Area F site plan. 6 The existing Specific Plan shows Public/Semi-Public land located in the middle of the Town Center. The Specific Plan proposed that this area contain some combination of community-serving uses such as a library, community center, post office, church, or other publicly oriented facility. This GP/EDSP amendment application proposes those types of uses to occur north of the intersection of Central Parkway and Devaney Drive in Area F. Within Area G, a 3.1-acre Governmental/Institution/Public/Semi-Public parcel is shown at the intersection of Central Parkway and Street E. It is planned that Area F will be a traditional residential village with 2 schools, a neighborhood park adjacent to the elementary school, a neighborhood square at the center of a residential neighborhood and public uses adjacent to Main Street and the Town Center. Area G Analysis: Area G of Dublin Ranch is 86.9 acres in size and is bounded by Dublin Ranch Area F on the north (separated by Central Parkway), Dublin Ranch Area B to the east, Dublin Ranch Area H on the south (separated by Dublin Blvd.) and property of the Dublin Land Company (DiManto) to the west. Area G has been increased in size from the 76.6 acres illustrated in the East Dublin Specific Plan to 86.9 acres in this Plan due primarily to the final realignments of Dublin Boulevard and Central Parkway. As mentioned previously, revised vehicular access and circulation patterns in the Circulation Element of the General Plan and East Dublin Specific Plan by the City of Dublin were one of the main reasons for the relocation and reorientation of the Town Center in a north-south orientation within Area G. The proposed 22 acre Town Center is the heart of Area G and is bordered by 11.9 acres of Medium-High and 11.5 acres of High Density Residential and a 2.7 acre Neighborhood Square on the west and 14.3 acres of Medium-High and 13.5 acres of High Density Residential and a 6.6 acre Neighborhood Park to the east. Higher density residential uses clustered around the commercial area will help strengthen it by concentrating significant numbers of potential customers within a short distance of the Town Center. To achieve this intensity of residential uses, the Medium-High Density Residential land use designation shown located between Central Parkway and Gleason Dr (Area F) in the Specific Plan was moved to Area G and replaced with Medium Density Residential in Area F. Additionally, the amount of Medium-High Density Residential shown in the Specific Plan was increased from 11.0 to 26.7 acres. Area H Analysis: Dublin Ranch Area H is bordered by the extension of Dublin Boulevard on the north, Area C of Dublin Ranch to the east, 1-580 on the south and property of the Dublin Land Company (DiManto) to the west. The project area is 70.8 acres in size. This area has two land use designations, being General Commercial and Campus Office. The Eastern Dublin Specific Plan shows 35.9 acres designated as General Commercial and 36.7 acres as Campus office. The applicant is proposing to modify the acreage to 43.9 acres of Campus office, 16.4 acres of General Commercial and the remaining 10.5 acres that could be developed as either all General Commercial or all Campus Office. The proposed GP/EDSP amendment will allow the flexibility to develop campus office uses on land designated for general commercial uses pursuant to a Planned Development Stage 2 Rezoning / Development Plan application. In addition, the requested amendment proposes that the midpoint of the density range of the floor area ratio (FAR) for Campus Office uses be increased from 0.35 in the Specific Plan to 0.45, with 0.60 FAR being the maximum of the range allowed in the General Plan. This will allow.the flexibility to exceed 7 0.45 FAR for Rome parcels; however, the amendment proposes average FAR for all CO parcels would not exceed 0.45 FAR. This increase in FAR coupled with the decrease in the amount of square footage for Neighborhood Commercial, with keeping the amount of commercial square footage relatively the same as originally designated. These minor modifications create the necessity for this General Plan/Specific Plan Amendment (GPA/SPA). The changes described above are the result of market assessment studies undertaken by EDAW, Inc. for Area H that concludes that the 1-580 corridor is "over-zoned" for regional/community-serving commercial uses. As mentioned in the GPA/EDSP amendment discussion above, the corridor is saturated with large format, specific market and full service retailers. Approximately 150 acres of land intended for such users are still available in the Specific Plan area, however, recent market studies show the buildout population of Eastern Dublin will not be at high enough levels to warrant a commercial area of this size. Additionally, the market assessment indicates a considerable demand at Present for regional and headquarters office land. That need is especially acute for large parcels of such land. It is for these reasons that the General Plan/Specific Plan Amendment for Area H is proposing the flexibility to develop 10.5 acres of land with either General Commercial or Campus Office uses. Because demand cannot be predicted with complete accuracy very far into the future, it shall be determined at the Stage 2 Planned Development Rezoning application whether the 10.5 acres will be developed with either General Commercial or Campus Office uses. PLANNED DEVELOPMENT REZONING (STAGE 1 & STAGE 2) The applicant is proposing a Planned Development Rezoning for Areas F, G and H to bring the zoning of these areas into consistency with the proposed General Plan/Eastern Dublin Specific Plan Amendment as required by State Law. In addition, the EDSP requires a "District PD Plan" for all property within plan area. The City of Dublin Zoning Ordinance requires a Stage 1 Development Plan (includes listing of permitted uses, densities, maximum numbers of residential uses and square footage of non-residential uses, preliminary site plan and a master landscape plan). As well as a Stage 2 Development Plan (which builds on the Stage 1 requirement and includes development regulations such as setbacks and building heights, architectural standards and specific landscape standards) in order to bring the applicant's property to a full Planned Development Zoning District. The applicant is proposing only a Stage 1 Planned Development Rezone for Areas F and H, as development plans for these two areas are not fully known at this time. Before development can proceed on these two areas an application for a Stage 2 Planned Development rezone will be necessary. However, both a Stage 1 and Stage 2 Planned Development Rezone for Area G is being proposed as very specific development plans are known for this area. Area F Planned Development Rezoning/Development Plan - Stage 1: The proposed zoning for the site is a combination of"Planned Development/R-l" (Single-Family, Medium Density Residential), "Planned Development/Schools" (Middle School, Elementary School), "Planned Development/Parks" (Neighborhood Square, Neighborhood Park) and "Planned Development/ P/SP" (Public and Semi-Public Uses) and "Planned Development/OS" (Open Space). These zoning categories are consistent with the purpose, intent and requirements of the City's Zoning Ordinance. The proposed project is consistent with the Dublin General Plan and Specific Plan policies by providing development of housing in the appropriate density range, preserving open space areas, and school and park sites adjacent to residential neighborhoods. The Planned Development proposes a linear open space area to preserve a stream corridor, and provides a continuous open space connection (multi-use trail) from 8 Dublin Ranch Phase 1, through Area F to Main Street (Area G). The multi-use trail also provides connections to on-street bike paths / pedestrian sidewalks linking to the school and park sites. Area "F" F MH 15.3 AC Gross 11.5 AC Gross PROPOSED PLANNED.DEVELOPMENT-. ..... ... ,~, :;':',. LAND USE PLAN ~,~ ~.~::;.'-..', ~.~:' ,. · .... · -..:;:: ~ i22.7 AC Gross-". :' ?\ .-' o .,. .r. '-,. , ..-', / . i.9 A( M'4'."__-:./:;' " .... 10.6 AC Gross "./ / · -., 10.0 Ac Gross ~ 16.4 AC Gross Acreage's are approximate. Refer-to Development Plan for specific acreage. Area H Planned Development Rezoning/Development Plan - Stage 1: The proposed zoning for the site is a combination of"Planned Development/C-2" (General Commercial) and "Planned Development/C-O" (Campus Office). The zoning category is consistent with the purpose, intent and requirements of the City's Zoning Ordinance. These uses and locations are consistent with and reinforce the General Plan and Specific Plan policies by providing land designated for employment and service uses in close proximity to residential development in Areas F and G. The Development Plan proposes development of between 16.4 acres of General Commercial Uses and 43.9 acres of Campus Office Uses, this includes 10.5 acres that could be developed with either all general commercial or campus office uses, pursuant to a Stage 2 PD application. The maximum development of Area H with both General Commercial and Campus Office would be capped at 1,244,945 square feet. The Eastern Dublin Specific Plan encourages mixed use developments including residential uses within areas designated for general commercial and campus office uses. The applicant is requesting that attached and detached dwellings at densities established for the Medium, Medium-High, and High Density Residential land use designations be considered for Area H. The Stage 1 Development Plan (refer to Attachment C-2) states that residential uses may be considered for this area at the Stage 2 Planned Development application process as long as certain policies of the Eastern Dublin Specific Plan are met. These policies are stated in the Area H Development Plan (Attachment C-2, Area H) attached to this staff report. · l, Area "H" Acreages are approximate. Refer to Development Plan for specific acreage. Area G Planned Development Rezoning/Development Plan - Stage 1 and 2: The Proposed zoning for the site is "Planned Development/RM" (Medium High Density and High Density Residential), "Planned Development/VC(NC)" (Neighborhood Commercial-Village Center*), "Planned Development/P/SP" (Public/Semi-Public), "Planned Development/Parks" (Neighborhood Park and Neighborhood Square) and "Planned Development/OS" (Open Space). This zoning category is consistent with the purpose, intent and requirements of the City's Zoning Ordinance. Area "G" ;' PROPOSED pLANNED DEVELOPMENT ' I,AND USE PLAN .~..:t..-.*.tar- ~ Nc .._ Acreages are approximate. Refer to Development Plan for specific acreage. The proposed project is consistent with the Dublin General Plan and Eastern Dublin Specific Plan policies by providing for the development of a pedestrian-orientated 'Main Street' with neighborhood retail uses serving the Village Center and surrounded by housing of the appropriate density range and by reserving land for public uses, parks and open space. The project also reflects Planned Development principles by providing pedestrian/bike trails/pathways which provide linear connections from 'Main Street' to the (Applicant's are proposing to call the Main Street commercial area [designated Neighborhood Commercial [within the "Town Center-Commercial" planning subarea] in the Eastern Dublin Specific Plan] Village Center. The uses and intent will not be effected For the purposes of this Ordinance NC Neighborhood Commercial and VC- Village Center shall be the same) 10 surrounding residential neighborhoods, north to Area F and east west to the neighborhood park and square. The trails, parkways, circulation and recreation facilities are consistent with the goals of the General Plan and Specific Plan. As the applicant has requested both a stage 1 and a Stage 2 Planned Development Rezone for Area G, very specific and detailed Development Standards, Architectural Guidelines and Landscape Guidelines will be adopted with the Planned Development Rezoning Development Plan. These items will dictate building styles, building materials, unique setbacks and various features which will create a diverse and interesting Town Center encompassing both commercial and residential uses. The most unique element would be the proposed "Main Street." Additionally, a Master Sign Program is also included which dictates the signage criteria for the individual buildings and uses within the Village Center Area. (Please See Attachment C-3 Area G). Main Street (Area G): The Village Center area as proposed by the applicant is envisioned in the traditional format with a series of buildings that give the impression that the area was developed over time. Buildings are to front onto the "Main Street" with parking areas behind the shops and stores. The Main Street will allow for one lane of traffic in each direction with on street parking. The parking areas behind the shops will have mid-block access through the shops to the Main Street with mid-block crosswalks allowing access to both sides of the street. The rear elevations of the buildings will have architecture that mirrors the front of the buildings to give the appearance of front doors. Commercial uses in the Village Center will focus on convenience retail such as comer grocery, drag store, and dry cleaners for local residents, and specialty retail uses such as food and clothing boutiques, florists, bookstores, stationers, antique shops, beauty salons, bars, cafes and restaurants for the larger community. Main Street will be developed with three blocks, each approximately 400 ft. in length with provisions for the development of both second story office uses and/or residential uses depending on the potential at the time of development. The addition of the residential uses is in keeping with the goals of Eastern Dublin Specific Plan which encourages the development of residential uses as an accessory use within the Town Center subarea. The applicant's plan details specifics for this development potential including parking requirements, and open space. One unique aspect of the Village Center Main Street will be the method of ownership of the sidewalk. Normally, the developer dedicates the right of way from the back of the sidewalk (in the case of a separated sidewalk) or Public Utility Easement (in the case of a monolithic sidewalk) to the City. In this instance, the sidewalks are proposed to be 12 feet in width to accommodate a higher volume of pedestrian traffic with the allowance of a 4-foot encroachment to accommodate outdoor seating for restaurants, etc. The Public Works Department proposes to allow the applicant to dedicate from the back of curb on one side of the street to the back of the curb on the other side (the vehicular travel surface only) with a 4 foot easement behind the curb for items such as fire hydrants, light standards and any other "public facility." The sidewalk area will then be maintained by an association which will make provisions for the maintenance and upkeep of the embellished paving, landscaping and other appurtenances envisioned for the streetscape. This will allow for a decorative streetscape usually not found on commercial thoroughfares. The streetscape for Main Street will be reviewed and approved by the Planning Commission as a part of the first SDR for the commercial portion of Village Center. 11 Economic viability of the proposed 'Main Street'(Area G): The current East Dublin Specific Plan was overly optimistic in stating the amount of neighborhood retail uses to be split between Areas G and F. The yield was at least partially based on a 1988 market analysis report prepared by ERA in conjunction with the Eastern Dublin Specific Plan/General Plan Amendment. This analysis was done before the 1-580 corridor became highly competitive with large format, high-value retailers (Home Depot, Circuit City, Staples, etc.) and value-oriented, full service retailers (Costco, Wal- Mart, Super Kmart, etc.). Current market assessment work undertaken on behalf of the applicant by EDAW, Inc. for this GPA/SPA and the Development Plan for Areas F, G and H (and reviewed by ERA on the City's behalf) indicates that the Town Center could support up to 169,200 square feet of retail and service floor space at the buildout of the Specific Plan area. Refer to Attachment D-1 (EDAW's fiscal analysis) and D-2 (peer review by ERA) to this staff report. The full potential of retail space within the Town Center may be difficult to achieve without a supermarket/drug store anchor. According to EDAW's analysis there are more suitable sites in Eastern Dublin for such a facility (e.g., Tassajara or Fallon Roads near the 1-580 interchanges). If a large format supermarket/drug store is not captured in the Town Center, the food and liquor merchandise category would likely be represented by a mix of smaller specialty food stores which cater to specific market niches (e.g., bakery, ethnic foods, meat and fish markets, etc.). Normally these types of retail operations. do not generate the same high volumes of shopper traffic, as would one single supermarket. To enhance the economic viability of the Town Center, it is envisioned in the applicant's proposal as a high quality mixed-use district that provides a vibrant and pedestrian-friendly environment, presents a clear and complimentary set of neighborhood-oriented retail and services uses, and leverages the drawing power of other nearby commercial, community and civic uses (e.g., office, churches, lodging, etc.) in addition to the surrounding higher density residential and office components (within Area G and H) in order to attract and maintain a dedicated shopper and visitor base. As a result of the projected decreased demand, the Town Center is proposed to be reduced in size from the 28 acres indicated in the Specific Plan to 22 acres as depicted on the Area G Stage 1 & 2 Site Plan (Refer to Attachment C-3 Development Plan, Area G). Pedestrian/Bike Trails and Neighborhood Square (Area G): Another unique feature of the Town Center (Village Center) Plan is the proposed trail system and Neighborhood Square. This trail, which extends from Dublin Ranch, Phase 1 the north, through Area F, provides bicycle and pedestrian linkages to the Village Center Area and Dublin Boulevard. These trails provide delineation between the commercial uses of the Village Center and the Public/Semi-Public, Neighborhood Square and High-Density Residential uses on the west and the Medium High and High Density uses on the east. Connections from these trails to the adjacent residential communities are anticipated as well as connections from the trails, through the parking lots to the commercial uses on Main Street. Mid-block on Main Street, a strong pedestrian link has been provided connecting the medium-high density residential area on the east with the Neighborhood Square on the west. This pedestrian pathway traverses both the eastern and western parking areas, passes between the commercial buildings and crosses Main Street in a mid-block crosswalk. Both the easterly and westerly terminus of this pathway will be at focal points; in the medium-high density neighborhood in a "to be determined during SDR review" design element and in the Neighborhood Square at an appropriate design feature such as a gazebo, bandstand or similar structure. The pathway is envisioned as an embellished design to permit safe travel across the parking areas with raised planters and the crosswalk across Main Street having a unique paving pattern. 12 The pathway Could pass between buildings where an open courtyard with a design feature would be located such as that shown by the applicant on the westerly side of Main Street. On the easterly side of Main Street, the applicant envisions the pathway passing under the buildings through a neo-classical arched opening. The Neighborhood Square has been shown to address the urban nature of the Village Center; while the linkage to the commercial core is important, the provision of open space for the urban living environment is equally important. The applicant's depiction of the Neighborhood Square (which has been reviewed by the Parks and Recreation Commission in August of 1999) is as that of an urban meeting place; a location for art shows, band concerts, farmer's market, etc. An outdoor amphitheater is included in the applicant's proposed plan. The Parks and Community Services Department will have the final design review authority for the Neighborhood Square. The applicant's proposal for the Town Center commercial development as presented in the Specific Plan, is not being changed by this application. It remains the focus for convenient commercial and services for adjacent residential neighborhoods and the center for entertainment and specialty retail uses for the larger Eastern Dublin community. With the associated Development Regulations and Design Standards (Attachment C-2, Area G), Architectural Guidelines and Standards, Master Sign Program and Landscape Guidelines (Attachment C-3, Area G) a very exciting, unique and vibrant neighborhood commercial center to serve Eastern Dublin and Dublin Ranch in particular will be created. Residential Development in Area G: The density ranges of the residential uses are 14.0 to 25.0 units to the acre for the Medium High Density designation and 25.0+ units to the acre for the land designated for High Density residential land uses. The development of these residential properties would equate to townhouse condominiums or "stacked flats" for the Medium High sites and "stacked flat" apartments or condominiums over structured parking for the High-Density sites. The applicant has proposed a maximum total of 1,404 dwelling units for Area G. This number of units has been calculated to be approximately 528 Medium High Density units at approximately 20.2 dwelling units to the acre (slightly above the 19.5 mid-range target density) and 876 High Density units at a density range of 34.6 dwelling units to the acre (slightly less than the target density referenced in Appendix 4 of the existing Specific Plan). The overall density for the residential component of Area G is 27.3 dwelling units to the acre. The maximum number of dwelling units attributable to Dublin Ranch is 5,760. The overall project (Areas F & G combined) proposes more units than originally identified (1,909 vs. 2,184) in the Eastern Dublin Specific Plan for the properties in question. The applicant has proposed the additional units due to the loss of Village Center (Neighborhood Commercial) acreage with the replacement of higher density residential uses in keeping with the existing Specific Plan's "Town Center" concept. The increase in dwelling units for these areas will not increase the maximum allowable number of units for the entire Dublin Ranch land holdings beyond the 5,760 without a further General Plan Amendment requiring additional environmental review. PROJECT TIMING AND SEQUENCING It is the applicant's intention to move forward with the residential component of Area G as soon as possible. To facilitate this development, it will be necessary to construct Phase I roadway improvements for Central Parkway, the northerly boundary of Area G, Dublin Boulevard which is the southerly boundary of Area G and Collector "B" the easterly boundary of Area G. A Lot Line Adjustment is being processed to assimilate the "L" shaped portion of Phase 1 into Area F. The Tentative Tract Map for Areas 13 F, G and H has been submitted and will follow closely behind this project for Planning Commission consideration. OTHER AGENCY/DEPARTMENT REVIEW The application has been reviewed by the applicable City Departments and agencies. Extensive work with the applicant has taken Place to define the various points of the project and to provide the maximum direction and clarity to those individuals and departments who will utilize these documents and the amended General Plan and Specific Plan. PLANNING COMMISSION ACTION: On January 25, 2000, the Planning Commission adopted a Resolution recommending that the City Council adopt individual Mitigated Negative Declarations and Mitigated Monitoring Programs as further clarified by the Response to Comments for Areas F, G and H. At this Public Hearing, the Planning Commission also adopted a Resolution recommending that the City Council approve a General and Specific Plan Amendment and adopted a resolution recommending ~that the City Council approve a Planned Development (PD) Rezone/Development Plan Stage 1 for Area F and H and a Planned Development (PD) Rezone/Development Plan Stage 2 for Area G. CONCLUSIONS The GP/EDSP amendments proposed are necessary to implement the goals of the Specific Plan due to factors that have occurred since the approval of the original Eastern Dublin Specific Plan. The Stage 2 Development Plan for Area G will create an architecturally significant Village Center that will enhance and provide focus for Dublin'Ranch and eastern Dublin. The proposed project is consistent with the purpose, intent and requirements of the City's Zoning Ordinance, the approved Planned Development Rezone and the Development Plans, the Dublin General Plan and the Eastern Dublin Specific Plan. RECOMMENDATION: Staff recommends the City Council open the Public Hearing, deliberate and adopt the following resolutions: Adopt Attachment 1, City Council Resolution approving individual Mitigated Negative Declarations for Area F (PA 98-068), Area G (PA 98-069), & Area H (PA 98- 070) of Dublin Ranch herein incorporated by reference with the Mitigated Monitoring Programs for Areas F, G and H included as Exhibit A and the Response to Comments included as Exhibit B, and . Adopt Attachment 2, City Council Resolution approving the General Plan Amendment and Eastern Dublin Specific Plan Amendment for Areas F, G & H (PA 98-068, 069 and 070) of Dublin Ranch with Exhibits A, B, C, D, E and F included, and . Waive reading and introduce the Ordinance Attachment 3 amending the Dublin Zoning Ordnance to approve a Planned Development (PD) Rezone/Development Plan Stage I for Area F (PA 98-068) and Area H (PA 98-070) and a Planned Development (PD) Rezone/Development Plan Stage I and II for Area G (PA 98-069) with the Development Plans included as Exhibits A-1 & A-2, B-1 & B-2 and C-1 & C-2. 4. Schedule the second reading of the Ordinance for the March 7, 2000 City Council meeting. 14 RESOLUTION NO - 00 () A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DUBlLJIN ADOPTING INDIVIDUAL MITIGATED NEGATIVE DECLARATIONS AND MITIGATION MONITORJrNG PROGRAMS FOR EACH OF THE THREE DUBLIN RANCH PROJECT APPLICATIONS 'AREA F' (FA 98-068), 'AREA G' (PA 98-069) AND 'AREA H' (FA 98-070)- GENERAL PLAN I EASTERN DUBL][N SPECIFIC PLAN AMENDMENTS AND PLANNED DEVELOPMENT (PD) REZONINGS WHEREAS, Ted Farrfield, representmg property owner Jennifer LID et aI, has requested approval of a General Plan Amendment, an Amendment to the Eastern Dubhn Specific Plan to reVIse portIOns of the General Plan and Eastern Dublm SpeCIfic Plan Land Use dIagrams and text to allow the relocatIOn of VarIOUS land uses and acreages wrthm Areas F. G and H of Dublm Ranch and has requested approval of a Stage I Planned Development Rezone for Areas F and H and Stage 1 and 2 Planned Development Rezone for Area G to define land use desIgnatIOns and standards on land generally located east of Tassajara Road and north ofl-580 Wlthm the Eastern DublIn SpeCIfic Plan area (APN 985-0005-001,985-0005-002), and WHEREAS, the General Plan Amendment ("GP A") and Eastern Dublin Spectfic Plan ("EDSP' ) were adopted by the CIty In 1994, and WHEREAS, the EDSP proVIdes more speCIfic and detaIled goals, pohcles and actIOn programs ... for approxImately 3313 acres Wlthm the GP A area nearest to the CIty on Its Eastern SIde, and ~ WHEREAS, a Program EnVIronmental Impact Report ("Program EIR") was prepared for the EDSP and GPA (SCH No 91103604) and certified by the CIty Council on May 10, 1993, by ResolutIOn No 51-93, and two Addenda dated May 4, 1993, and August 22, 1994 ("Addenda") have been prepared and adopted by the Clty CounCIl and are hereby Incorporated by reference, and 'WHEREAS, on May 10, 1993, the CIty CouncIl also adopted ResolutIOn No 53-93, adoptIng the GPA and EDSP, makmg findmgs and adoptmg ovemdmg conSIderatIOns as to the envIronmental Impacts and mItIgatIon measures relatIng to the EDSP and GPA, and adoptmg a MItIgatIOn MomtorIng Program ("Program MMP") for the GP A and EDSP whIch resolutIOn IS hereby mcorporated by reference, and WHEREAS, mdlvldual Irutlal StudIes have been prepared for each of the three DublIn Ranch project applIcatIOns (Area F I P A 98.068 ~ SCH No 99112040, Area G I P A 98-069 - SCH No 9911204] and Area HIP A 98-070 - SCH No 99112042) to evaluate sIte-specIfic Impacts of the project, to a greater level of detail than m the Program EIR, pursuant to CEQA gUldelmes Sectlon 15168 Based on the three Imtlal StudIes, a. MItigated Negative DeclaratIOn and MItlga.tIOn Morutonng Program has been prepared for each area WIth the findmg that WIth the ImplementatIOn of MItIgatIOn Measures preVIOusly adopted for the Program EIR and 'WIth SIte speCIfic MItIgatIOn Measures contaIned In the ImtIaI StudIes, as further clanfied In the Response to Comments and agreed to by the developer, the potentIal site-specIfic Impacts ofthe projects would be reduced to a level of f) A 1'1' ACHMEN'f 1 mSIgmficance The Program EIR and ImtIal StudIes adequately descnbe the Impacts of the prOject, and there have been no substantIal changes or new InfOrmatIOn whIch would neceSSItate supplementmg the Program EIR pursuant to Pubhc Resources Code sectIOn 21166 and CEQA gUidelines SectIOn 15162, and WHEREAS, a complete applIcatIOn for the project IS avarlable and on file m the PlannIng Department, and . WHEREAS, a 30 day pubhc reVIew perIod was held for the Mmgated Negative DeclaratIOns, from November 10, 1999 through December 9, 1999, and WHEREAS, ten letters commentmg on the MItigated NegatIve Declarations were receIved dUrIng the comment perIod from local, state and federal agenCIes, WHEREAS, m response to comments receIved and as agreed to by the applIcant, mItigatIOn measures IdentIfied for two speCIal speCIes (red-legged frog and CalIfornia tiger salamander) have been further refined to be more speCIfic, and WHEREAS, In response to comments receIved new mformatlon has been added to the three MItIgated Negative DeclaratIOns which merely clanfies or makes mSIgmficant modIficatIOns to the documents, and WHEREAS, dIl pertment comments have been responded to and have become part of the Response to Comments attached as Attachment A - 3 to the staff report for P A 98-068, -069 and -070, and WHEREAS, the Planmng COmmISSIOn dId hold a properly notIced pubhc heanng on saId . applIcatIOn on December 14, 1999, January 11 2000 and January 25, 2000 and did adopt a ResolutIOn recommendIng that the CIty Council adopt IndIVIdual MItigated NegatIve DeclaratIOns and MItigatIOn MomtorIng Programs as further clanfied by the Responses to Comments for Area F (P A 98-068), Area G (P A 98-069) and Area H (P A 98-070), and WHEREAS, a properly noticed publIc heanng was held by the City CouncIl on February 15,2000, and WHEREAS, a Staff Report was submitted recommendmg that the City CouncIl adopt a MItigated NegatIve DeclaratIOn and MItigation Momtonng Program, as further clanfied by the Response to Comments for each of the three DublIn Ranch project applicatIOns (Area F I PA 98-068 - SCH No 99112040, Area G I P A 98-069 - SCH No 99112041 and Area HIP A 98-070 - SCH No 99112042), and '\VHEREAS, the CIty CouncIl did hear and use theIr mdependentjudgment and conSIdered all SaId reports, recommendatIOns and testImony heremabove set forth NOW, THEREFORE, BE IT RESOLVED 'IHA'f the Dublm CIty CounCil does hereby find that 1 The project IS wrthm the scope of the Program EnVIronmental Impact Report for the Eastern DublIn General Plan Amendment and SpeCIfic Plan (SCH 91103064) SIte-specIfic . envIronmental affects have been analyzed m the ImtIal StudIes prepared for each of the DublIn Ranch prOj ect apphcatl ons - Areas F, G and H, dated N ovem ber 8, 1999, and CIrculated for pubhc review The Dublm Ranch project applIcations - Areas F, G and H WIll not have a 2 e tJ sIgmficant effect on the enVironment With the applIcatIOn of MitIgation Measures IdentIfied In the Program EIR and m the IrntIal StudIes, as further clanfied In the Response to Comments 2 The SIte-speCIfic mItigatIOn measures contamed In the ImtIal Studles/MItIgated N egatlve DeclaratIOns for Areas F, G and H and as further clarIfied In the Response to Comments are eqUIvalent or more effectIve In reducmg the potential project Impacts to a level of Inslgrnficance and the refined SIte-specIfic mItigation measures will not In themselves cause an potentially sIgmficant effect on the enVIronment 3 In response to comments receIved on the three MItigated Negative DeclaratIOns, new mformatIon has been added to the documents whIch merely clanfies or makes mSIgmficant modIficatIOns to the documents and no new Impacts were IdentIfied In accordance WIth CEQA 4 The MItIgated Negative DeclaratlOns, MItigatIOn Momtonng Programs and the Response to Comments have been prepared m accordance WIth State and local envlfonmentallaws and gUIdelmes 5 The MItIgated Negative DeclaratIOns and MItigation Momtonng Programs, as further clanfied In the response to conunents are complete and adequate BE IT FURTHER RESOLVED THAT THE Dublm CIty CounCIl does hereby adopt a MItigated N egatI ve DeclaratIOn and MItigation Momtormg Program P A 98-068 for Area F, MItigated NegatIve DeclaratIOn and MItIgated Momtormg Program P A 98-069 for Area G and MItigated Negative Declaration and Mitigated Momtonng Program PA 98-070 for Area H, as clanfied by the Response to Comments (Attachment A-3 to the staff report), the MItigatIOn Momtonng Programs are attached as Attachment A-2 and With the ImtIal Studles/MltIgated NegatIve DeclaratIOns are mcorporated hereIn by reference PASSED, APPROVED AND ADOPTED thIS 15th day of February, 2000 AYES NOES ABSENT Mayor ATTEST CIty Clerk ~ g \98068\CCRESOmnd 3 (() () () oo~ I...O~ o~ I~ ooe O'\~ <~ ~eID -13 ~ ~"I!=l ~ ~ e <!J~ <~ OO=g ~El R ~ ~eID ~ 13 ~ ~ ~~ ~e I "I!=l J::~ uEl ~e ~~ ~El ~e R ~ ~"I!=l ~~ ~~ Q~ ~ ~ ~ ~ N ~ ~ ~ El ~ ~ = sa - C': c:.J !;: - '"' ~ > v=( ~ Z ~ ~ ~ U < ~ ~ < ~ Cd < I f=I ~ ~ ~ ~ ~ ~ CIl .... 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E ro L- C) o L- 0.. C) c -E I ~ ro ID IDO::: L- <(-g C)ro s: C) E S ro L- _ 0 o..-g .!:oc g:2:o ro c :::l 0:::00 c ~ 0 :cgb c5~0 . ~() ]D)un lbniinn JRann(C]h1 IPn~nnnniiilllg AIre~~ IF 9 G &, ]HI () JRe~}p)({])nn~e rr({]) Miirriig~rre((]l N egarriive ]D)etCn21Ir~rrii({])nn C({])mmennt~ JJ21illl1Ul21IrY 2~@@ ({) lEXHmIT B OF ATTACHMENT ]I. ~ & Introductnon Trus report compIles all letters receIved by the CIty of Dublin durmg the 30-day MItIgated NegatIve DeclaratIOn pubhc reVIew penod and Includes responses to each of the comments . ClarificatIOns to RmtlaB Studies ProJlect DescriptIOns The folloWing clanficatIOns are made 10 the Project DescnptIOn sectIOn for the IrutIal StudIes for Plannmg Areas F, G and H The follow1Og text should be deleted from each of the Imtlal Study documents o Plar.mng ..'-rea f The apphcant Ras also requested approval of a lot hne adjustment to separate Plaf'.RIng ..'-rea f from the remamGer of the Dublm Ranch property o PlanmFlg -'\.rea G The apphcant has also requested approyaJ of a master tentative tract map to subdI','Ide the Plar.Rmg ..\rea mto smaller parcels of land for sale to futl.He Bl:ulders l\fter the ma&ter tentatIve tract map IS finalIzed and recorded, It IS antICIpated that teFltatr/e subdrllsIOn maps would be filed to create 1OdI','Idual bl:lIldmf; lots for reSidential constructIOH The master tentatIve traet map IS be10g re','Iewed eoneurrently WIth the SpecIfic Plar./General Plan .'\rnendmeflt applicatIOn and PD rezone, howe','er, the master tOl'ltatIve map ma) Hot be acted upOH W'ltIl other applicatIOns ha','e been acted upon Plaf'~l:in; -,\rea H The apphc8:flt has also requested approval of a lot lIne adjustmem to separate Planru.n; :\rea H fr8m the remamder of the Dubl10 Ranoh preperty o . The followlDg text shall replace the above language In each of the IrutIal StudIes "The apphcant IS also requestIng approval of a Lot LIne Adjustment and VestIng Master TentatIve Map to encompass all three of the Planrung Areas The Lot LIDe Adjustment would modIfy a portIOn of the northerly boundary of Planrung Area F to encompass a portion of PlannIng Area E wItrun Plann10g Area F The 19 4 acres of land to be added has been deSIgnated as a school SIte Wlth10 Planrung Area E and enVIronmental reVIew for tins portIOn of the SIte was conducted by the CIty of Dubl10 10 1997 The Lot Lme Adjustment would also modIfy the east-west boundary hnes between Plann10g Areas G and H to be co-term1Ous WIth submitted Plannmg Area Plans The Vestmg Master Tentative Map proposes to estabhsh smaller parcels Wlthm PlannIng Area G for sale to future buIlders The smaller parcels to be create are conSIstent WIth related Stage 1 and Stage 2 development plan proposals After the vestIng master tentative map IS finalIzed and recorded, It IS anticIpated that future tentatIve subdiVIsIOn maps would be filed WithIn Plann10g Area G to create Indtvldual bUIldIng SItes for reSIdentIal and non-resIdential constructIOn The Vest10g Master Tentative Map does not propose to subdIVIde property wlthm Planrung Areas F or H It IS antIcipated that future tentatIve subdIVISIOn maps would be filed m cOnjunctIOn With or subsequent to Stage 2 Development Plans to dIVIde Planrung Areas F and H mto small lots for bUIldmg purposes" . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 2 January 2000 --- L __ () Summary of CommellU1l: lLetters Comment letters were receIved by the CIty of Dub lID from the followmg agencIes and organIzatIons o Comment Letter 1 Alameda County Flood Control Dlstnct Zone 7 o Comment Letter 2 Alameda County Pubhc Works Agency D Comment Letter 3 MartIn InderbItzen o Comment Letter 4 LID Plannmg Team D Comment Letter 5 East Bay RegIOnal Parks District D Comment Letter 6 Cahforma Department ofFish and Game D Comment Letter 7 US Fish and Wildlife Service D Comment Letter 8 Cahforma RegIOnal Water Quahty Control Board, San FranCISCo Bay RegIOn o Comment Letter 9 Cahforma Department of TransportatIOn o Comment Letter 10 Bruce Webb, Dubhn San Ramon Services District () Responses to CommeJlD.ts Tills IS a swnmary of each of the comments and the response of the CIty of Dublm Each letter has been revIewed and dIVIded Into smaller comments as noted by annotatIOns In the margm m each of the letters Each comment IS then summanzed and responded to below The full text of each letter WIth annotatIOns follows thIS sectIOn SInce many of the comments relate to potentIal bIOlogICal Impacts of the projects, a master response has been formulated for thIs tOpIC () Master Respmnse to Comments Reg31Jr(llmg BJOnogRC31n ResouJlll"ces The text of the three lrutIal StudIes summanze mformatIOn presented III the H T Harvey & ASSOCIates report for DublIn Ranch Plannmg Areas F, G and H (Pao Yeh LIn Property), EcologICal Impacts and MItigation (10/25/99) ("Report") TIns report presents InformatIOn on the status of senSItive speCIes on the property, the amount of survey work that was conducted to detenmne then status, the level of Impact H T Harvey & ASSOCiates IdentIfied regardmg each speCIes that would occur as a result of proposed development and proposed mItIgatIOn measures that would reduce the anticIpated Impacts to less-than-slgruficant levels Tills report was used as the background for the lrutIal StudIes and was also appended to each of the three ImtIal Study documents CIty staff and the consultmg bIOlogIst carefully revIewed the report dUrIng the Imtlal Study preparatIOn process CIty staff and the bIOlogIcal consultant also revIewed the BIOlogICal Resources analYSIS contarned In the Eastern Dublm SpeCIfic Plan/General Plan EIR ("EIR") Based on these reVIews staff and the bIOlogICal consultant belIeve that any potential for sIgrnficant Impacts to bIOlogIcal resources WIll be aVOIded or reduced to a level of mSlgruficance, In complIance WIth CEQA ThIS ImtlgatlOll Will occur through complIance WIth apphcable mItIgatIOn measures adopted In the EIR and Identified In the ImtIal StudIes for the projects, as further clar1fied III thIS master response CIty of Dublin Dublin Ranch PArs F, G & H Response to Comments Page 3 January 2000 Dunng the public reVIew penod the CIty of Dubhn receIved letters from the State Department of FISh and Game, UnIted States FIsh and WIldlIfe ServIce and other agencIes . These agencIes stated theIr OpInIOn that bIOlogICal Impacts had not been adequately analyzed or mItIgated under CEQA The CIty of DublIn respectfully dIsagrees Through thIs master response and later mdlvIdual responses, the CIty WIll descnbe the areas of dIsagreement and the eVIdence supportmg the CIty'S positIOn Red-Legged Frog BIOlogical surveys ofPlanmng Areas F, G and H conducted m 1998 and 1999 and descnbed m the Harvey report, resulted m the observatIOn of a smgle adult female red-legged frog m the PlannIng Area F stockpond dunng a July 1, 1999 SIte VlSlt ImtIal StudIes for PlannIng Areas F, G and H conclude only lrmlted use of the Plannmg Area F stockpond, upland grasslands and the seasonal wetlands by red-legged frogs occurs based on theIr low detectIOn rate on the property The Planrung Area F InItIal Study notes that red-legged frogs could breed m the stockpond However, the appearance of a smgle mdlvldual after a year and a half of survey work suggest overland movement to thIS pond from another mhabited SIte ThIS speCIes has been recorded from the dramage to the north (3/4 mIle) and from the Fallon Road VICInity to the east (112 mIle) As dIscussed m the Harvey report, red-legged frogs dlspersmg from off-SIte locatIOns or the Plannmg Area F pond currently are able to make unrestrIcted movement to other SUItable aquatic habItat to the north and east as descnbed above There lS no SUItable aquatic habitat between the stockpond and Interstate 580, and Interstate 580 forms a bamer to further movement to or from the south Development along Tassajara Road blocks movement to and from the west where red-legged frogs are present In TassaJara Creek The US FIsh and WildlIfe ServIce (ServIce) notes that red-legged frogs use upland areas to . forage or to move between areas of SUItable aquatic habitat The Project Impacts sectIOn of each IrutIal (Section IV "aU) are hereby reVIsed by reference to mclude the followmg text to clanfy that the Impact area Includes not only the stockpond In Planmng Area F, but may alsQ mclude upland areas around the stockpond "Clearmg and gradmg could result m the loss of IndiVIdual red-legged frogs and would result m the loss of any upland foragmg and dIspersal habitat" The Planrung Area F InItIal Study contams MitIgatIOn Measure 2(m) for red-legged frog Impacts ThIs IDltlgatIOn measure wIll be also reVIsed to mcIude the addItional cIanfymg language and mcorporated mto the Irutlal Study by reference to read as follows MlhgatlOD Measure 2 PrIor to the Issuance of a gradmg permIt, the prOject bUIlders/developers shall (m) Implement measures to mInImIZe dlrect Impacts to Cahforma red- legged frogs (IrutlatIOn of constructIOn durmg the dry season, May- October, selrung of the Impacted pond In Apnl and May and transportatIOn of any red-legged frogs or larvae to the Northern Dramage, preconstructIOD surveys, III SUItable habitat, removal of vegetatIOn by hand prIor to constructIOn, and, In SUItable habItat, mOnItorIng of constructIon by a herpetologIst), In consultatIOn With CDFG and the U S FIsh & WIldlIfe ServIce (USFWS) Enhance, restore, and preserve 45 acres of rIpanan habItat along a 3500-foot reach of the Northern DraInage . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 4 January 2000 () Removal of cattle and unnatural debns, replantmg of npanan vegetatIOn, InstallatIOn of Illstream weIrS, and creation of an m-stream or slightly off- channel pond Will sIgmficantly Improve condItIOns along thIS degraded stream for the red-legged frogs currently occuPYlDg the draInage and Vvlll mItigate the loss ofthe PlannIng Area F stock pond and adjommg dramages A minImum buffer of300 feet along the stream ID the Northern DraIDage WIll be preserved (new text to be added) MItigatIOn work at the proposed 0 10-acre pond III the northern draInage shall conSIst of remOVIDg sedIments from the bed of the former pond whIch eXisted at thIS SIte and fe-establishing the ongmaI stream channel configuration to flow adJacent to the pond SIte The pond shall proVIde open water and wetland habitat SUItable for use bv red- legged frogs and shall be buffered bv 300~foot WIde setbacks of preserved habitat " () Vernal Pool Invertebrates The ServIce comments on the presence of SUItable habItat for the conservancy faIry shnmp, the longhorn faIry shnmp, and the vernal pool tadpole shrImp In PlannIng Area H seasonal wetlands The Planntng Area H ImtIal Study summanzes the results of samplmg for vernal pool Invertebrates on and In the VICInity of Plannmg Area H, and the Harvey report prOVIdes addItional mformatIOn No speCial status vernal pool Invertebrates have been found on the project site or III the project VICInIty In the absence of any occurrences of these speCIes on or ID the VICInIty of the SIte, no Impacts to them are expected and no mitigatIOn measures are reqUIred , Califorma TIger Salamander The PlannIng Area F ImtIaI Study notes that tIger salamanders breed III the on-SIte stock pond and estivate In mammal burrows or other retreats In the upland portIons of the site The ImtIaI StudIes for Plannmg Areas G and H report on the lack of breedmg habItat wltlun theIr - respective areas and conclude that upland habitat use IS mlll1mal based on a lustory of agncultural operatIOns III these areas, but does recogmze the pOSSIbility that the speCIes could move across or estivate on them The Project Impacts sectIOn (IV "a") of the PlannIng Area F IrutIaI Study IdentIfies the loss of the stockpond and surroundIng upland habItat as a project Impact It does not speCIfy the amount of Impact SectIOn IV "a" of the ImtIaI Study for Planmng Area F IS hereby reVIsed by reference to note that all tiger salamander habItat on the site would be lost should the project be Implemented The estimated extent oftlus Impact IS shown on the attached FIgure () City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 5 January 2000 1350 /0 Il \ IT \ \ Il Il :z: n 0 CJ :11 Il "{ -::c ~ 1"1' "r- f ---- II ", - "~ \ ~ \\ " -=E-- 2 LANE: \\ :--....~ \, .....~ , - -l":!'~l " , :2 LANE ~ " Ii '\~ ;II iIII IQI.- ; :. :: '[ iI!I "11II If" . ! IIlII lit.... *' \ 'I J ! 1\ " 'U/ lJ ~~ II ..;;frsarta R, II --=--- Rehabillt ....L-.-- - ~ ~ "", A.nnex I ' ~~n a=:J rl " r ~4 rrouo 't =::I C EJ = CCI , Property Boundary 2000 I ~ H T HARVEY & ASSOCIATES ECOLOGICAL CONSULTANTS ApproXImate area of Esf.JvatJon HabItat = 20 4 acres 2000 0 I -'.--1' ",-,~~ ," " , .~. - approXlJ1late scale In feet Pao Yeh Lm Estunated Cahforma Tiger Salamander EstivatIOn Habitat File No 555 26 Date 1/14/00 - Figure 1 PAnp. F;. _IAn ?nnn - -< () Irutlal Studies for PlannIng Areas G and H state that tiger salamanders are unlIkely to estIvate m these plannIng areas and would rarely move across or otherwIse occur on them due to the regular dISkIng and other agncultural operatIOns whIch occur on them However, recogmzlDg the possIbIlIty that salamanders could e).lst wlthm these two areas, the Project Impact dIscussIOn of the BIOlogICal Resources sectIOn ImtIal StudIes for Planmng Areas G and H are hereby revIsed by reference to state that all potential upland tIger salamander habItat would be lost should the project be constructed The Planmng Area F Imtlal Study contarns MItIgatIOn Measure 2 (n), for Impacts to tIger salamanders TIus mItIgation measure IS hereby revIsed and mcorporated by reference mto the PlannIng Area F Imtlal Study to read as follows MItIgatIOn Measure 2 Pnor to the Issuance of a gradIng permIt, the project buIlders/developers shall (11) Create a new CalIfornIa tIger salamander breedmg pond III the Northern Dramage In the fall months pnor to gradIDg or other constructIOn activItIes the followmg Bono!!: or summer. and translocate mdlvldual tIger salamanders from the Impacted pond to the new pond The new pond Will be apprmamately 0 7 acres III Size, thereby mItIgatmg the loss of the Area F pond at a ratIO of approXImately 1 1 tv (new text) The acreage of estIvation habItat preserved around the created pond In the northern dramage shall be a mInimum of 63 acres The amount of estivatIOn habItat preserved around the eXIstIng off-SIte breedme pond to be preserved shall be a mInImum of 20 acres The opportumty for mterchange With other off-SIte breedIng locatIOns shall be mamtaIned on both SItes A qualIfied herpetologIst WIll conduct nocturnal surveys at the pond for emergIng adult salamanders dunng sIgmficant rarn events from December through February and transport mdlvlduals to the new pond The Impacted pond WIll then be thoroughly semed for any salamander larvae present 10 Apnl and May, any larvae captured WIll be transported to the new pond The new pond and adjacent estivatIOn habItat will be preserved In addItIOn, eXIstmg, occupIed breedrng and estivation habitat off-SIte the acrcage to be commcnSbH'nte vflth Impaeted habItat, WIll be preserved +fie acrea;e ef estI';atJElFl nal:l1tat prcserved frrsood both the crcated pond and the el.IstIng brccdm; pond to bc set asIde wIll be eommeflSW'ate WIth tn.e extent of Im.pacted estivatIon habItat on .'\rea f, whIch '.vIII bc determu'lcd based on surveys dunn; \\"1fltcr 1999/2000, (')f bascs en an a;reement WIth CDfG re,;:ardm,;: the lIkel) elITCnt Elf srntablc estI'/atlElfl habItat t) ThIs revIsed ffiltIgatIOn measure IS adequate to reduce Impacts to tIger salamanders to a less- than-sIgruficant level Wlthm Planrung Areas F, G and H City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 7 January 2000 KIf Fox The Service does not concur With the findIngs of the Irutml Studies that lIt fox are absent ., from the project site The Harvey report contams a descnptlOn of the results of kIt fox surveys eond ucted III the pro] ect VIClruty SInce 1989 and an analysIs of their results They conclude that kit fox are not present m the DublIn area and are absent from the Pao Yeh Lm SIte The Information reviewed IS the best avaIlable SCIentIfic InfOrmatIOn and It mdlcates that kIt fox are not present and the project SIte IS outsIde the species' range The surveys were conducted by professIOnal bIOlogISts and revIewed by the CIty'S consultIng bIOlogIst The City consultant's profeSSIOnal OpInIOn and the prevIOUS report conclude that there IS no potentIal for kit fox WithIn the three PlannIng Areas Burrowmg Owl All three of the Irutml Studies Identify the loss of mdlvldual burrOWing owls, theIr occupIed burrows and occupIed owl habItat as a potentIally sIgmficant llTIpact MItIgatIOn measures contamed In each of the ImtIal StudIes prOVIde mitigation for these Impacts The mItigatIOn measures are conSIstent With the reqUIrements contamed In the CalIfornIa Department ofFish and Game's Staff Report on BurrOWIng Owl mitIgatIOn dated October 17, 1995 and are conSIdered suffiCIent to reduce any project Impacts to thIS speCIes to a less-than-slgmficant level Other Species The project area contaInS one eucalyptus tree located on the border between Planmng Areas F and G, whIch could be used by tree nestmg raptors and loggerhead shnke The tree IS proposed for removal CDPG recommends preservmg the tree for use by these speCIes III the future However, With development of the proposed project, the tree would no longer be a SUItable nest SIte for these speCIes due to the loss of surroundIng foragmg habitat and the . greatly Increased level of dIsturbance Illtroduced to the area by the proposed project Therefore, the ImtJaI StudIes for Plannmg Areas F and G IDcorporates the mItIgation proposed by the CDFG In theIr comment letter by plantIng npanan-assoclated trees In the northern dramage III an area proposed to be dedicated for open space Tlus tree plantmgJS _ proposed for mltIgatmg Impacts to CDFG JunSdlctlOTI and would also mitigate for the loss of the eucalyptus tree A mItigatIOn and momtonng plan IS proposed to be prepared for tills work by the applIcant's con<;ultmg bIOlogISt The mformatIOn In the Harvey report notes the lIkely presence of homed lark on the SIte Loss of homed lark habItat was not IdentIfied as a sIgmficant Impact III the Imtml StudIes due to the large amount of SImilar habItat III the regIOn and theIr faIrly WIde dIstnbutIOn m thIs area The horned lake IllformatlOn III the Harvey report IS eVIdence that there IS no potential for slgmficant Impact The Imtml StudIes contaIn mItigatIOn measures for other grassland- assocIated speCIes, mcludmg the CalIfornIa tiger salamander and burrowmg owl San JoaquIn spearscale and Congdon's tarplant are Included on the CalIfornIa NatIve Plant SOCIety (CNPS) List IB ThIS lIst contams plants conSidered by the CNPS to be rare, threatened or endangered In Callforma and elsewhere They have no federal or state speCIal status The IrutIal StudIes, m the absence of the ablllty to conduct thorough field surveys due to dlsklng ofthe SIte, presume presence If SUItable habItat IS present and offers ImtlgatlOn standards for theIr removalD The CDFG bebeves pursuant to SectIOn 15380(d) of the CEQA GUJdelmes, that these species should be treated as If they were formally lIsted speCIes Tills sectIOn of the CEQA . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 8 January 2000 (() GUldelmes provIdes cntena by whIch a lead agency can determIne whether a speCies which IS not formally hsted should nevertheless be treated as such for purposes of CEQA review The cntena In the CEQA GUidelInes contam qualItatIve defimtlOns of "rare" and "endangered" speCIes CIty staff and the CIty'S bIOlogIcal consultant reviewed the cntena for these two plants Two plant speCIes referred to here, whIle not common In the regIOn, are known to be present at severallocahons m the LIvermore-Amador Valley area and thIS were determmed not to meet the cntena establIshed by 15380(d) of the GUIdelInes As noted m the comment from CDFG, the recreated stream channel proposed for Planmng Area F surrounded by development IS not expected to fully compensate for the fill of on-SIte dramages The on-SIte channel IS part of a mItIgatIOn proposal that mcludes an off-SIte component along the northern dram age that has larger buffers and greater protectlOn from development actIVIties The on-SIte component responds to concerns over the complete ehmmatlOn of natural dramages on the SIte Stream Improvements prOVided m MItIgatIOn Measure 3(ll) would compensate for loss of addItIOnal channel length The ImtIal Studies lIst the need for the project developer to obtaIn a Streambed AlteratIOn PermIt from the Department of FIsh and Game under the sectIOn tItled "Other Pubhc Agency ReqUired Approvals " Letter 1 Alameda County Zone 7 f) o Comment 1 On page 37, Item c "substantially alter draInage patterns, mcludIng streambed courses such that substantIal sIltatIon or eroSIOn would occur," the ImtmJ Study states that storm dram runoff would eventually flow mto the Zone 7 0-3 faclhty nnmedlateIy north of the 1-580 freeway TIns IS a planned faCility that currently does not eXist If constructed, the G-3 facIlity must meet Zone 7 standards Re<iponse The G-3 channel has been In operatlOnfor some tIme by Zone 7 As noted In prehmmary engmeenng studies for the G-3 and Arroyo Las Posltas channels and Dublm Ranch Master dramage area (prepared by Schaaf and Wheeler dated 12/3/98) and Dublm Ranch Master Drainage Study (5/99) document the peakjlows hydrauhcs and hydraulzc grade lines/or the new and eXIstlngjlows on the surroundIng streams and Improved channels The studIes document that the peakjlows from Planmng Areas F G and H development would occur slgmficantly sooner than the peak of the Arroyo Las PosItas channel drainage basm Therefore the eXlstmg channel could accommodate thzs small amount of storm water runoff from the proposed project and faulztIes have been adequately SIzed The dramage patterns and streambed cour5es of the development area would not be slgmjicantly changed and therefore, no further erOSIOn would result to streambed or channel courses Most of the mcreased jlows would be In Improved channels pIpes or structures so that streambed erosIOn would be kept to a mlmmum and would be zmproved .from eXIsting condltlOns Proper erOSIOn control measures wllI be undertaken m accordance with Zone 7 and RegIonal Water Qualzty Control Board crttena andpolzczes () City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 9 January 2000 Letter 2 Alameda County Public Works Department . o Comment 2 1 Dramage Impacts from the proposed development on downstream faclhtIes should be addressed In partIcular, the Arroyo de la Laguna has been expenenCIng numerous erosIOn Impacts and the effect of project runoff on the Arroyo should be addressed Response The drainage baSin that contributes storm water runoff to thiS sectIOn of the Arroyo IS approximately 425 square mzles In size The proposed project area constItutes approxImately one tenth of one percent (0 10) of the drainage area Ba~ed on thIS, any contnbutlOn to current or future Arroyo erosIOn would be consIdered less than slgmficant o Comment 2 2 The applIcant should be reqUIred to deslgnate haul routes to and from the SIte and repan any damage to County roads Response Comment acknowledged ThIS comment has been forwarded to the Dublm Publzc Works Departmentfor approprzate aOwn dunng the grading and excavatlOn phase of the project Prelzmmarzly It IS not beheved that County roadways would be used for wnstructlon vehIcles for the proposed project o Comment 2 3 It IS unclear about the Wldenmg and lmprovement of TassaJ ara Road, specIfically WIthIn County-mamtaIned roadway portIOns . Response Comment ac.Jmowledged The project IS not antIcIpated to reqUIre wldemng or Improvements to the umncorporated portIOns ofTassajara Road o Comment 24 All roadway and storm dram facIlItIes III County nght-of-way must conform to Alameda County SubdiVIsIon DeSIgn GUldehnes and hydrology cntena and standards Any nghts-of-way dedIcatIOn, road lIllprovements, relocatIons, etc shall be at no cost to the County Response Comment acknowledged No Improvements are proposed Within County nghts-of-way for the proposed project Letter 3 Martm InderbItzen o Comment 3 1 Concerns raIsed regardmg the presence of certam species wlthm the plannIng area that are not present on site Replacement language IS suggested III heu of a reqUIred 300-foot WIde buffer along the stream m the northern draInage area Please clanfy that If a preconstructlOil survey of the SIte finds no burrowmg owls no further mItIgatIon would be reqUIred . CIty of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 1 0 January 2000 f)J Response See Master Response Regardzng BiologIcal Resources regardzng the amount of land to be dedIcatedfor off-sIte mIllgatlOn m the northern dramage area for loss of on-sIle habItat for the red-leggedfrog and Califorma tiger 'iGlamander Regardmg burrowmg owl mll1gatlOn if the preconstructlOn surveys Identify no burrowing owl on the slle no further mlllgatlOn would be reqUired o Comment 3 2 CondItIOns and recommendatIOns contamed In the H T Harvey Report dated 10/25/99 should be used as part of the three ImtIal StudIes Concerns are raised regardmg the type and locatIOn of mItigatIOn reqUIred Response InformatIOn gathered and analyzed by H T Harvey & AssoclQtes was used as the baSI'; of the blOloglcalImpacts and mlllgatlOn measures sectIOn of all three Imtlal StudIes The full text of the Harvey report was mcluded In the AppendIx of each Imtzal Study A peer reVIew ofthlS report was conducted by LS4 Assoczates, the Cay's consultmg blOlogist Through the Master Response to Comments Regarding BlOloglcal Resources and other indIvIdual responses some of the Harvey repm t mlllgatIOn measures have been augmented for clarIficatIOn City staff and the CIty's consultzng bIOlogIst feel the mIllgatlOn measures contamed zn the Imtwl StudIes, as modified zn this Response to Comment document are generally consIstent wzth the Harvey report I) o Comment 33 MItIgatIOn Measure 5 reqUIres the project to make a faIr share contrIbutIOn to downstream draInage Improvements Zone 7 currently reqUlres payment of a fee to the DIStrIct and payment of the fee to the DIStrIct would satIsfy a fair share contrIbutIOn Therefore, the mitIgatIOn measure should be removed Response Payment of a fee by the project sponsors to Zone 7 would lzkely satisfy the Ml!lgatlOn Aleasure However the City prefers to mazntam the mlllgatlOn measure In the event there are dramage Improvements reqUired/or the project over and above that whIch would be covered by the fee o Comment 34 The MItIgatIOn Measure dealmg WIth flood protectIOn should read "Apphcant shall remove habItable portIOn of the project SIte from the 100-year FEMA floodplaIn pnor to occupancy permIts bemg Issued" Response The Imtwl Study IS hereby corrected by reference to replace appropnate MlllgatlOn Measures In the Imtzal Studies for Planmng Areas G and H 10 the follOWing language "The project developer(s) shall remove habItable portlOns of the project from the 1 OO-year FEMA flood plam prIOr to bUilding permlts bemg Issued" t) o Comment 3 5 Much of the text of the ImtIal StudIes appear to be wntten generally so as to cover all three Plannmg Areas, Because of tlns, clanficatlOns are needed to prevent maccuracles, such as cultural resources and the lack of TIger Salamander outSIde of Plannmg Area F - - - City of Dublm Dublm Ranch PA's F, G & H Response to Comments Page 11 January 2000 Response Based on the Harvey report the Calif 01 ma TIger Salamander has been . Identified m Planmng Area F Based upon an amplificatIOn of the Inltral Study mformatIOn contamed m the Master Response Regardmg BIOlogIcal Resources the movement and estIvation of tIger salamander speCIes IS noted wIthm Planning Area'l G and H However the presence of these speCIes IS anticIpated to be mInimal due to regular dIskmg and agrIcultural operatIOns on these two Planning Areas To ensure that full protectIOn IS prOVIded In the unlzkely event that unidentified archeologIcal or paleontologIcal resources are dl!Jcovered anywhere m the three planmng areas the CIty prefers to mazntam the language of these mlflgatlOn measures These mztlgatlOn measures respond to Impact 3 9B set fOl th m the Ea.l,tel n Dublm EIR and are conSIstent WIth the mztlgatlOn measures outlmed In thiS prevlOus FIR o Comment 3 6 The Imtlal StudIes mclude numerous traffic mItigatIOn measures that are speCIfic and that have been taken from the project traffic report The mltigatlon measures assume that a long lIst of development projects and related traffic Improvements would occur The lIstIng ofprojects IS hIghly speculatIve and may not be accurate Instead, the mitIgatIOn measure for the three planmng area projects should reqUIre that an acceptable level of servIce IS maIntaIned that may mclude the lIst attached Traffic mItIgatIOn measures apply to all three planmng areas, not each mdIvIdual area Response Cumulative traffic Impacts and mmgatlOn measures have been developed uszng the "bst" method ofknown and probable projects It IS beZzeved that these proJfcts wlll be developed before or sImultaneously With the three Dublm Ranch _ Plannmg Areas (F-H), although thI!J cannot be assured The CIty of Dublm prefers to lzst specific mItIgatIOn measure elements rather than a broad mItIgatIOn measure, 0'1 suggested by the commenter 1711S WIll aSSIst the City mfulfillmg Us legal reSpOn'llbllzty ofmztlgatlOn momtorIng and reportmg Changes to jpecific mltlgotlOn measures may be allowed by the City of Dublm at the tIme of subdIVIszon approval based on further traffic analYSIS at some po mt In the future . The traffic 'leetlOns of each of the three Imtwl StudIes are mfact, IdentIcal gIven the close mterconnectlVlty of the three planmng area!J In terms of traffic and tran\portatzon Impacts o Comment 3 7 The populatIOn figures and associated park requrrements for Plannmg Areas F and H have been mIscalculated The nwubers In the Imtlal Study represent dwelhng uruts rather than populatIOn AddItIOnally, the park acreage reqUIrement per capIta has been mIscalculated CIty reqUIrement Includes 1 5 acres for local parks and 3 5 acres for commumty parks, whereas the Imtlal StudIes use a 5-acre park requrrement all for local parks Respome Estlmates of park reqUIrements for the project mcluded In the ImtzaI Study are In error For the three Planmng Areas the CIty uses a neIghborhood park dedicatIOn reqUIrement of I :5 acres per 1000 reSIdents The amount of parkland . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 12 January 2000 f) proposed m Planmng Areas F and G exceed th1S standard The reqUlrement for commumty parks 1S calculated separately and accounts for the remamder portlOn of Dublm Ranch The Impact remams less-than-slgmficant wlth regard to the prOVISlOn of parkland o Comment 3 8 RegardIDg nOIse exposure, no resIdentIal development IS proposed III Planmng Area H, so It IS Inappropnate to apply extenor resldenhal nOIse standards to non~resldentlalland uses Also, only a portIOn ofPlannmg Area G IS proposed for resIdentIal land uses, so the ImpOSitIOn of resIdential nOIse exposure standards IS Inappropnate here too Response The Imtwl Study for Plannmg Area H Identifies the eXlstmg nOIse enVIronment for all three adjacent Plannmg Areas and zndIcates the range of eXIstmg nOise mltlgatlOn measures adopted as part of the Eastern DublIn Specific Plan No new nOIse mlt/gatlOn measures are reqwredfor thlS prOject The commenter IS correct that no reSldentlal development IS proposedfor Planmng Area H which lS confirmed by the ImtIal Study project descnptlOn ACOUS!lC mllIgatlOn measures for Plannmg Area H would only apply to resIdentwl development occurrzng wlthm the Planmng Area f) o Comment 39 No resIdential development IS proposed WIthIn Plannmg Area H, so all references to IDclusIOnary housmg reqmrements and resIdentIal zonIng should be removed Response The commenter IS correct, and the paragraph m the Project DescrzptlOn _ dealmg with mcIuslOnary housmg reqwrements lS hereby removed by reference from the Plannmg Area H Imtwl Study o Comment 3 10 The termInology "mtenmttent creeks," "creek" and/or "streams" should be removed SInce none of these eXIst on the property Instead, the terms "defined dramages" or "swales" should be used Response The Emtern Dublm Specific Plan ldentifies two "mtermIttent streams" wIthm Planmng Area F (Figure 3 7B) For all other natural dramagefeaturer; south of the stock pond m Area F the terms "defined dramage areas" are hereby mcorporated by reference Comment 4 LID PlanDlng Team o Comment 4 I Much of the text IS wntten generally to cover all three project areas whIch makes mformatlOn confuSIng and not appropnate to the speCIfic planmng area f) Response In many Instances the background and Impact InformatIOn for all th, ee Plannmg Areas are generally-the same smce a h1gh degree ofmterconnectlvIty eXists CIty of Dublin Page 13 Dublin Ranch PA's F, G & H January 2000 Response to Comments between the three areas Examples of thIS Include nOIse drainage and traffic Other . topUS have been specifically tallored for each plannmg area for example bIOlogical Impacts and populatlOn and housmg Impacts o Comment 42 Area H, page 3, second line, the use of the word vacant IS wrong, SInce agncultural and cattle grazIng occur on the Site Response The term "vacant" was mtended to convey that the site IS devOid of bwldmgs or structures, The Imtzal Study IS hereby corrected by reference 10 reflect the historical and on-going grazmg and agrIcultural uses of the property The property IS therefore not consIdered vacant o Comment 43 Area H, page 3, project descnptIOn, first paragraph, does not mentIOn that a master tentatIve tract map IS also proposed which should be mcluded In the ImtIaI Study Response See the ClarificatIOn to Imtlal Studies Project DeSCriptIOns dISCUSSIOn contamed m the Response to Comments o Comment 44 FIgure number should be 2 not 3 Response The wmmenter IS correct that the exhlblf IS mislabeled ThiS correctlOn IS . hereby mcluded by reference mto the Area H Imtlal Study o Comment 45 Area H, Project DescnptIOn, It IS not necessanly true that a Stage 2 PD rezone apphcatIOn Will be filed at the same time as the tentatIve tract map and Site - Development ReVIew ThIs applIcatIOn could be submItted pnor to or WIth a Tentative Tract Map and/or SIte Development ReView apphcatIOn Response The commenter IS correct the filing of such applzcatlOns would not need to be done sImultaneously The project descnptIOn IS thereby corrected by reference to Include the updated mformatIOn o Comment 4 6 Area H, Internal collector roads are only one mstance of provldmg a roadway system The final system may mclude a collector loop or other system The final system Will be determIned pnor to submIttal ofmdlvldual tentative tract maps The ImtIal Study ImplIes thIS IS the only solutIOn and the term "collector" should be deleted Respome The project descnptlOn contamed m the Initial Study was not meant to Imply that collector roads would be the only mterIOr means of CIrculatIOn It was meant to differentzate local facIZltIes such as local and collector roads whIch would be constructed by indIVIdual subdiViders from other major roadways which would be constructed wlfh asse.ument district financmg Therefore, there IS no need to delete the word "collector " . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 14 January 2000 f) " Comment 47 Area H, page 5, second paragraph, no housmg IS proposed for Plannmg Area H so language descnbmg City InclUsIOnary houslDg reqmrements should be deleted from the ImtIaI Study Response The commenter IS correct and all dIscussIOn related to mclu~IOnary housmg requIrements m Planmng Area H IS hereby deleted by reference " Comment 48 Area H, page 5, second paragraph under Assessment Dlstncts should be corrected to read "assessment dIstncts" rather than "mltlal study" Response The commenter IS correct and the Imtwl Study IS hereby corrected by reference as noted " Comment 49 Area H page 5, project descnptIon, first paragraph, although a lot hne adjustment has been requested a master tentatIve tract map IS also requested as part of the applIcatIOn and should be noted III the project descnptIOn sectIon of the ImtIal Study Response Refer to comment and response 4 3 Cf) " Comment 4 10 Area H, page 10, references to "permIts" should be changed to "authonzatIOn" or "401 CertIficatIOn" Response The 1m/wI Study IS hereby corrected by reference to note that "authOrlZatlOns" are requIredfrom the Regzonal Water Quahty Control Board "P ermIts" would stIll be requzred to be Issued by t he Corps of Engmeers and Califorma Department of FIsh and Game for streambed alteratzon " Comment 4 11 Area H, page 10, reference IS not made regardmg a master tentative tract map as part of the project Response Refer to Respome 4 3 " Comment 4 12 Area H, page 11, the sectIon headIDg on tills page I dentlfi es a category of "potentially sIgmficant Impacts" whIch IS not shown In the checklIst which follows Many of the Impacts are lIsted as "less than slgmficant WIth mItigatIOn measures n The ImtIal Study should state that Impacts are potentIally sIgruficant unless mltlgatIOn IS Incorporated () Response The changes Identified above are correct and are mcorporated by reference mto thIS Imtwl Study and the Imtwl Studies for Planmng Areas F and G as well The liThe Less Than SIgnificant WIth MItIgatzon" checkhst headmg corresponds to No 4 under EvaIuatlOn of EnVIronmental Impacts As reflected m the comment, City of Dublin Dublin Ranch PA's F G & H Response to Comments Page 15 January 2000 mItIgatIOn measures would reduce these Impacts from "potentially sIgnificant" to "less than sIgnificant" . o Comment 4 13 Area H, page 13, refer to Item 27 Response See respome to Comment 428 o Comment 4 14 Area H, checklist, questIOn the box checked off shouldn't the "less than slgmficant Impact" or "no Impact" box be checked Instead of "less than sIgmficant after mItigatIOn" for the Pubbc Servlces sectIOn? Respome The box In questIOn was checked off In error It should not have been checked Since thI,) box IS a tOpIC heading and checkmarks have been provldedfor IndlVldual components WIthm the Publlc Services sectIOn (1 e ,fire pollce !Jchools, etc) ThIS correctIOn to the InItzal Study IS hereby made by reference o Comment 4 15 Area H, checklIst, questIOn the "no Impact" box checked off regardIng the Mandatory FIndIng of SIgmficance "a" and "b " Shouldn't these be changed to "less than sIgmficant?" Response The ongmal response was based on full ImplementatIOn of mItIgatIOn measures, Uponfurther consIderatIOn, It may be more appropnate to check off the . "less than sIgmficant" boxes/or subsectIOns "a" and fib" In the Mandatory FmdIngs ofSlgmficance sectIOn These changes are hereby made and Incorporated by reference mto the text of the Imtral Study These reVlSlons also assume full ImplementatIOn of mItIgatIOn measures o Comment 4 16 Area H, page 23 the reference to Plannmg Area F should be revIsed to Planmng Area H Respome ThIS change IS hereby made and Incorporated by reference mto the text oj the ImtIaI Study o Comment 4 17 Refer to Comment 1 regardmg the term "vacant" Response Refer to Comment and Response 4 2 o Comment 4 18 Area H, page 24, AesthetICS, the use of the word "former" IS Inaccurate as the SIte IS still bemg used for agnculture Respome ThIS change, to delete the word '101 mer," IS hereby made and Incorporated by reference mto the text oJthe Imtwl Study . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 16 January 2000 ({) o Comment 4 19 Area H, page 24, AesthetIcs, when a Statement of Ovemdmg ConsideratIOns has been adopted, the Impact remams potentIally sIgmficant and unaVOIdable, It IS not reduced to a level of less than sIgruficant Response The comment IS correct The mtent of the referenced statement IS to indicate that since the Impact was prevIOusly addressed In a Statement of Overndmg Cons IderatlOns for the Eastern Dubhn SP/GP EIR no addlllOnal analysl!J IS requIred In regard to the last line In subparagraph "a" on page 24 the referenced statement IS hereby revIsed and Incorporated by reference to delete the words" less than slgmficant Impacts would result for thIS project and" ThIs project would have no Impact beyond that prevlOusly addressed In the Statement of Overndmg ConsIderatIOns" o Comment 4 20 Area H, page 24, Aesthetics, when a Statement of OvemdIng ConsideratIOns has been adopted, the Impact remams potentially sIgruficant and unaVOIdable, It IS not reduced to a level ofless than sIgOlficant Response See above response Accordmgly the lastfulllme of the referenced text IS hereby amended and mcorporated by reference mto the Imtwl Study to delete reference to reductIOn of the Impact to less than slgmficance () o Comment 421 Area H, page 25, Agncultural Resources, when a Statement of OverndIng ConsideratIOns has been adopted, the Impact remaInS potentIally sIgmficant and unaVOIdable, It IS not reduced to a level of less than slgmficance Response Refer to above responses to Comments 4 19 and 4 20 Although the comment IS correct, Impacts to AgrIcultural Resources were preVIOusly addressed In the Statement ofOverndmg ConsideratIOns adoptedfor the Eastern Dublm SP/GF EIR and no further analYSIS IS needed for thIS Imtwl Study However the reference to "less than sIgmficant" Impacts are hereby deleted and Incorporated by reference mto the Imtzal Study o Comment 4 22 Area H, page 25, refer to Item 19 (Comment 4 20) Response See response to Comment 4 19 and 4 20 References to "less than slgmficant" Impacts are hereby deleted and Incorporated by reference znto the Imtwl Study o Comment 4 23 Area H, page 26, BIOlogIcal Resources, EnVironmental SettIng, the word "one" should be replaced With "at least once" Response The imtzal Study IJ hereby corrected by reference to make the above change () City of Dublin DublIn Ranch PArs F, G & H Response to Comments Page 17 January 2000 o Comment 424 Area H, page 28, Wetlands, thIS sentence IS not accurate CDFG jUDsdlctIOnal habitat does not eXist ID Area H ThIS occurs m a dItch parallelIng the . frontage road WhICh extends from the elevated farm road to the G-3 channel Response The Initial Study IS hereby corrected to note that US Army Corps of EngIneers wetlands eXist WIthIn Planning Area H o Comment 425 Area H, page 28, Project Impacts, sectIOn Imphes that that certaIn plant and anImal speCIes are present on the site when eVidence has been presented to the contrary Refer to the H T Harvey report Response Refer to Master Response to BIOlogIcal Resources o Comment 426 ExhIbIt 5 title should be changed to "JurIsdIctIOnal area" and not "wetlands" The exhIbIt shows all water subject to Corps JurIsdIctIOn, not just wetlands Response The tale of ExhIbit 5 IS hereby changed by reference to read "}unsdlctlOnal Waters afthe US Includmg Wetlands" o Comment 427 Area H, Project Impacts and MItIgatIOn Measures "a," there are no tiger salamanders Wlthm Area G based on on-SIte surveys The reference needs to be . removed Also, there is confuSIOn regardIng the burrowmg owl If owls are not found on the SIte, then a habItat set-asIde IS not reqUIred Response See Master Response to BlOlogzeal Resources regarding the potentlGl presence of tiger mlamander habItat wIthIn Planning Area H RegardIng burrowmg owl wIthzn the Planning Areas if requIred preconstructlOn 5urveys fad to find burrowmg owl, no additIOnal mItIgatIOn would be reqUired o Comment 428 Area H, page 30, Cultural Resources, Based on the FInal EIR, no sIgmficant resources have been IdentIfied III Area H, only Area F Therefore, the Imtlal Study IS IDaccurate III mdlcatIng the pOSSIbIlIty of resources wIthm thIS Plannmg Area Response To ensure that full protectIOn IS prOVIded In the unlzkely event that umdentified archeological or paleontological resources are discovered anywhere In the three planmng areas, the Cay prefers to maintain the language of these mzl1gatlOn measures The~e mitIgatIOn measures re5pond to Impact 3 9B set forth In the Eastern Dub/zn EIR and are conSistent With the malgatwn mea5ures Olll/med In thiS prevIOus EIR o Comment 429 Area H, page)O, BIOlogIcal Resources, belIeve It IS mappropnate to . speCIfy a bIOlogIcal resources mItIgation SIte m North LIvermore The locatIOn of any CIty of Dublin Page 18 Dublin Ranch PA's F, G & H January 2000 Response to Comments () mItIgatIOn area WIll be dependent on dlscusSlOns Wlth the Corps of Engmeers and the Irutml Study text should be revIsed to "23 acres" Response The reference to the North LIvermore SIte has been takenfrom the Harvey report whlch has been used as the basls for bIOlogIcal Impacts and mll1gatlOn measures A site In North Livermore was Identified In the report as a potentwl off- sIte mltlgatlOnfor bIOlogIcal resource Impacts .. Comment 4 30 Area H, page 31 and throughout, why are Plannmg Areas F and G dIscussed here? ThIS IS the InItIal study only for Area H Response The topiC In questIOn IS hydrology and draznage, although thIS IS not specified In the comment Adjacent Planmng Areas have been mcluded to diSCUSS how the dramage of Plannmg Area HIS lznked to ad.Jacent areas Similarly, other references to adjacent Planmng Areas have been prOVIded where a logIcal lInkage to the adjacent areas eXIst such as traffic and transportatIOn .. Comment 4 31 Area H, page 32, first full paragraph, delete the phrase "mlmmlzmg gradmg on steep slopes " f) Response The phrase has been mcluded since a descnbes one of many mItIgatIOn measures mcluded In the Eastern Dublzn Specific Plan whIch apply to thiS and all other development proposals m the eastern Dublm area Only those mItIgatIOn measures wah applzcabIlIty would be enforced for Planmng Area H On page 31 of the Planmng Area H ImtIaI Study under the dISCUSSIOn of Landform and Topography, notes that the SIte IS relatIvely flat WI1h:- an - approximate grade change of approXimately 4 feet over the Planmng Area sIte .. Comment 432 Area H, page 33, hydrology, the follOWing sentence IS not accurate "The project SIte IS hIlly With several mtermlttent creeks flowmg through It " There are no hIlls or Intenmttent creeks III Planmng Area H, only defined dramages Response The ImtlOl Study IS hereby corrected by reference to delete the reference to mtermIttent streams and replace thIS language "WIth the term "defined dramages " .. Comment 433 Area H, page 33, mItIgatIOn measure, text regardmg NPDES permIts needs to be reVIsed to say "file a notIce of mtent WIth the state" rather than "obtaIn a notice of mtent from the state" Response The ImtlOl Study l~ hereby corrected by reference () .. Comment 434 Area H, page 35, MItIgatIOn Measure 6, tlns measure would reqmre the developer to pay a faIr share contnbutIOn for downstream dramage Improvements ACFC Zone 7 has an eXIstmg dramage program for tlns pmpose and the project WIll pay these fees Therefore, the need for further study IS not needed City of Dubhn Dublin Ranch PA's F, G & H Response to Comments Page 19 January 2000 Response Payment of afee by the project sponsors to Zone 7 would hkely satIsfy the . MItIgatIOn Measure However the Czty prefers to mamtaIn the mitigatIOn measure In the event there are drainage zmprovements requzred of the project over and above that whIch would be covered by the fee .. Comment 435 Area H, page 35, "g," "h" and "I," the project developer has already obtaIned a condItional letter of map reVlSlOn from FEMA where FEMA has agreed to take the portIOns of the sIte out of the flood plam The mItigatIOn measure should be re-wntten as follows "The apphcant shall remove habitable portIons of the project from the 100-year FEMA flood plam pnor to occupancy permIts bemg Issued" Response The Imtlal Study IS hereby corrected by reference to replace MlfzgatlOn Measure 7 wllh <;ubstantzally the above WOJ dmg MItIgatIOn Measure 7 now reads "The project developer(s) shall remove habItable pm twns of the project from the lOO-year FEMA flood plam prIOr to buzldmg permllS bemg zssued " .. Comment 436 Area H, page 35 "h" and "I," the ImtIal Study notes that there would be no hazards due to dam or levee break because the eXlstmg stock pond m Planrung Area F would be removed A comment.should probably be added that m the event the pond IS not removed, embankments WIll be remforced to elImmate dam faIlure as a (I potential hazard Response The lmtzal Study has been prepared based on the assumptIOn that the stock pond eXIstmg wlfhm Planmng Area F would be removed to accommodate proposed - land uses shown In the applzcant's request for development wIthm Planmng Area F If the stock pond were to remaIn a reVised applicatIOn would need to be filed wIth the Czty and addltlOnal envIronmental documentatIOn performed .. Comment 4 37 Area H, page 37, nOIse, EnVironmental SettIDg, The paragraph m the ImtIaI Study regardIDg nOIse should be re-wntten to reflect that no resIdential development IS proposed III Planmng Area H Secondly, use of soundwalls along 1- 580 are excluded (SIC) from occurrIng pursuant to the Eastern DublIn Sceruc Comdor PolICIes and Standards Response The envzronmental settIng portion of the Planmng Area H Imtzal Studv descnbes eXlstmg nozse condztlons In general terms for all three of the a4Jacent Planmng Areas based on the nOIse sectlOn contamed m the Eastern Dublm Specific Plan Although a brzefreference to resldentlal nOIse standards zs made m the NOIse sectIOn of the Checkhst explanatwn the Project DescnptlOnfor the Imtwl Study clearly Mates that no resldentzal development lS proposed wllhm Planmng Area H There zs no reqUlrement or mItIgatIOn measure contamed In the lnztzal Study to reqUire nOlse barner walls to be constructed ad;acent to thIS Planmng Area . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 20 January 2000 () o Comment 438 Area H, page 38, project Impacts and mItIgation measures "a," the ImtIaI Study lIsts fire spnnklers as an element of the project There may be portIOns of the project that may not reqwre spnnklers so that thIS comment should be removed Response The dZscusslOn contamed m the Imtwl Study is mtended as a general hstmg of.fire preventlOn measures which may be requzred by the Alameda County Fire Department as part of the reVlew of mdividual development projects IncluslOn of fire spnnklers IS not hsted as a specific mitlgatlOn measure There IS no need to remove this comment smce sprmklers could be requzredfor portlOns of the project o Comment 439 Area H, page 43, there IS no Table 2 on Page 43, ComparIson ofTnp GeneratIOn Why has thIS table not been Included In the document? Response Table 2 may have been madvertedly left out and IS attached to thiS memorandum It IS hereby mcorporated by reference mto the Imtlal Study for Planmng Area H The purpose ofmcludmg thiS table IS to show that the combmed peak hour traffic generatzonfrom the three Planmng Areas IS not significantly hlgher than and generally conSistent With the approved Eastern Dubhn Specific Plan and assoczated EIR () o Comment 440 Area H, page 44, traffic MItIgatIOn Measures 7 and 8, the ImtIal Study mcludes numerous traffic ffiltJgatlOn measures that are very speCIfic and are assumed to be taken dIrectly from the project traffic report MItIgatIOn measures contaIned m the traffic report are based on a number of other projects that may not occur Instead, the project should be condItIoned to mamtaIn acceptable levels of servIce and the hst of recommended Improvements may IDclude the lIst attached Response Cumulative traffic impacts and mltzgatlOn measures have been developed usmg the "/zst" method of known and probable projects It IS be/zeved that these projects Will be developed before or slmultaneously With the three Dublm Ranch Planmng Areas (F-H) although thiS cannot be assured The Czty of Dublm prefers to /zst specific mlflgatlOn measure elements rather than a broad mzt/gatlOn measures as suggested by the commenter ThiS Will assist the City mfulfillmg zts legal responslblhty of mitigatIOn momtormg and reportmg Changes to specific mztlgatlOn measures may be allowed by the City of Dublm at the time of subdzvzswn approval based on further traffic analYSIS at some pomt m the future o Comment 4 41 Area H, page 46, "d" and "g," SubstItute Plannmg Area H for PlannIng Area F Response The Imtzal Study IS hereby corrected by reference to replace references to Planmng Area Fwlfh Planmng Area H () ~ ~_......~ o Comment 442 City of Dublin Dublin Ranch PA's F, G & H Response to Comments Area H, page 46, "e," no new reSIdences are planned m Area H Page 21 January 2000 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ij I N Q,) .0 m i- = ~ - ,.. - t.J (.: - t.J c.J =- rFJ - - - - .=: - - ~ ...... 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'" '-' '-' '-' _ c c c:> Ol,l .., ~~~ COO . - = '0 Eo-< Q4i~ zzz !i z I~... ?nnn Response The Imllal Study 1S hereby corrected by reference to delete references to any new reszdentlQl development zn Plannmg Area H . o Comment 4 43 Area G, refer to comments on Area H Response The comment zs unclear Not all of the comments regarding Plannzng Area H also pertain to Planmng Area G To the extent that they do, however, refer to the appropnate responses to Planmng Area H o Comment 4 44 Area G, page 2, second hne, Refer to Area H concermng use of the word "vacant" Response Refer to Response to Comment 4 2 o Comment 4 45 Area G, page 3, SpecIfic Plan/General Plan Amendment descnptIOn, this paragraph IS Incorrect, sInce there are no MedIUm High DenSIty ReSIdential, Open Space, Middle School or Elementary School desIgnatIOns shown for Area GIll the current SpecIfic Plan Response The Inztzal Study 1S hereby corrected to delete references to these land uses m Plannmg Area G Land uses mcluded In the eXlstzng Specific Plan Includes . Medmm Density ReSIdentIal, High Dens1ty Reszdentzal, Pubbc/Seml-Publze NeIghborhood Commerczal/Vlllage Center, Neighborhood Park and NeIghborhood Square o Comment 4 46 Area G, page 4, SIXth paragraph, first sentence, the sentence IS not clear and It appears somethIng IS mlssmg Response The Imtzal Study IS hereby corrected by reference to complete the mcomplete sentence as follows " Gradmg actlvltzes would occur wzthzn Plannzng Area G to accommodate planned land use') roads and utllztles although the amount of gradzng IS not known at thzs llme " o Comment 447 Area G, Exlnblt 4, It IS unclear wInch area IS Area G Response The commenter IS correct, the exhzb1t IS Area H The corrected exhlblllS attached o Comment 4 48 Area G, page 10, zomng, tlus appears to be the zomng for Area F and not Area G . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 24 January 2000 (() Response EXIsting zonlngfor Planmng Area G IS hereby corrected to Include PD- NeIghborhood Commerczal HIgh Densay ResIdentIal and MedIum Densay ResIdentIal The ImtIal Study for Planmng Area G IS hereby corrected by reference 10 Include thIS informatIOn o Comment 4 49 Area G, page 11, no "potentIally sIgruficant Impacts" eXIsts on the IrutIal Study checklIst, even though this IS referenced m the text of the lrutIaI Study The checklIst should note that Impacts are potentIally sIgruficant unless mItIgatIOn IS mcorporated Response The changes Identified above are correct and are Incorporated by reference Into thIS Imtzal Study o Comment 450 Area G, page 24, where a Statement ofOvemdmg Concerns has been adopted, the rmpact remarns potentially slgruficant and unavOIdable The Impact Isn't reduced to "less than sIgruficant" In succeedmg environmental documents Response Refer to Responses to Comments 4 19 and 4 20 (() o Comment 451 Area G, page 26 "e," refer to above regardIng Statement of Ovemdmg ConsIderatIOns Response See response to above comment f) City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 25 January 2000 - ---- - = -~ u ~d ~~ ~~ ~< ~ Q :z ..( ~ ~ U ...... t:.. ......tI) UE- ~- ~e3 ztl):I: --~ ~z~ ~..(E- ;:J~z Clc..~ Z~~ ~..(Cl ~~z L...~ ~Zu.1 ..(u.1:;;S wo..( ~ c u ~iD ca _~~-; E ~a::u= u _ ~~ c -E uc_",u I) ~ E -=~ ~~"2.w:; '0 ~ ~ -g ~ C ~~ :; g. 0 E uc.." .::: c..U)_"5 E"gE e >.f.:;~"g"g g", 8.eo~~=c ~~.f~ 5'~ c;~~"",uEEa..oo~cC. ~.c Q ~C = =~~~_ uU'] c ~E:C.c"O-,:I P:DClO::o:g E e czu~~~i~~ii~o- uuo:;; =_ c.CI'J~U')'" OZU_=.c..c..JZZeIilO = Gl ... -< >. 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CI) o Comment 4 52 Area G, page 26, BIOlogICal Resources, EnvIronmental SettIng, the term "fallow" Imphes abandonment and It should be made clear that the land IS dlsked for weed control and grazed, etc Exchange the word "one" for "at lease once" Response The Inztlal Study IS hereby corrected by reference to Incorporate the fact that the SIte has been dlsked on an annual baSIS o Comment 4 53 Area G, page 26, BIOlogICal Resources, EnVIronmental SettIng, second paragraph, delete the word "draft " Response The InztIaI Study IS hereby corrected by reference to Incorporate the above change o Comment 454 Area G, page 27, second paragraph, fIrst lIne, add "ponded areas and" In front of "wetlands " Response The Inztlal Study for Plannzng Area G IS hereby corrected by reference to Incorporate the above change The corrected sentence would therefore read "Because Plannzng Area G lacks long-term ponded areas or wetlands ef em) h:1ml no sUltable habItat for western pond turtles and nestIng Trzcolored BlackbIrds IS present on Plannzng Area G "" () o Comment 455 Area G, page 27, first paragraph, second hne, after the second "Area G" add "contamed small Isolated areas of short term pondmg along the access road, bIsectIng Area G (and Area II) and these ponded areas " Response The InztIaI Study IS hereby corrected by reference to Incorporate the above change and to read as follows "Porhons of PlannIng Area G contaIn small. Isolated areas of short-term pondInf! along the acces'i road blsectInf! Planznf! Area G and Plannznf! Area Hand these ponded areas were sampledfor speCIal-status vernal pool Invertebrates but none were detected o Comment 4 56 Area G, page 31, DraInage, first paragraph, first and second lInes, there are no mtenmttent streams on the property These are gentle swales Streams are conSIdered to be jUrIsdIctIOnal Response The Inztlal Study IS hereby corrected by reference to Incorporate the above change o Comment 457 Area G, page 32, Hydrology and Water QualIty, EnVIronmental SettIng, first line, refer to above comment above concemmg the word "stream " (() Response See response to above .comment City of Dublin Dublin Ranch P A's F,G & H Response to Comments Page 27 January 2000 o Comment 458 Area G, page 33, project Impacts and mitigatIOn measures, "b," the text IS dIfficult to understand, SInce there IS httle, If any, recharge of groundwater The dense clay layer near the surface prevents downward movement of water . Response The Imtlal Study references back to the prevIOus EIR Based on the type of sod present on the SIte, groundwater recharge would be mImmal No change to the Imtlal Study IS therefore reqUired o Comment 459 Area G, page 33, project Impacts and rmtIgatIOn measures, "c," refer to earlier comment regardIng the absence of streams on the SIte Response See earlzer response regarding correctIOns to the ImtIal Study to Incorporate thIS change References to intermIttent streams WIthin Planmng Area G are hereby replaced wzth the term "defined drainages" o Comment 460 Area G, page 34, Item "c," fifth lIne, refer to prevIOUS comment concerrung streams Response See Response to Comment 4 59 o Comment 461 Area G, page 35, "h" and "I'" the dISCUSSIOn does not answer the questIOn . Response The checklzst questIOn IS "would the proposed project place hOUSing WithIn- an area that would Impede or redIrect floodwaters including flood water caused by a dam or levee fazlure " The response IS that a small portz on of Planmng Area G currently lzes wzthIn a 1 OO-year flood plain however project developers must adhel e to MItIgatIOn Measure 6 whIch would ensure that all habItable portIOns of the ~Ite be raIsed outSIde of the 1 OO-year flood plain It IS assumed that the CIty of Dublin and/or FEMA would not approve grading plans that would redIrect stormwater In such a manner as to place other structures WIthin a flood hazard area It has also been assumed based on submztted plans and Written deSCriptIOns submItted by the applzcant, that the stock pond wzthIn Planmng Area F would be removed as part of the project so that there would be no flooding hazardfrom a dam or levee break o Comment 462 Area G, page 35, Land Use and Planrung, last lme, 240 dwellmgs should be reVIsed to reflect 275 dwellings Response The ImtIal Study IS hereby corrected by reference to note that approval of the proposed Planmng Area G SP AlGP A would result In an Increase of 275 dwelling umts over the eXIsting Eastern Dublin Specific Plan not 240 dwelling umts as Identified In the Imtlal Study Based on successful mItIgatIon of all potentlalImpacts City of Dublin Dublin Ranch PAIs F, G & H Response to Comments Page 28 January 2000 . to levels of less than sIgnificance an mcrease of up to 275 dwellmg umts IS not f) be/zeved to result m any sIgnificant Impacts o Comment 4 63 Area G, page 36, NOise, EnVIronmental SettIng, second paragraph, refer to Area H, Item 36 (Comment 437) concernmg non-reSIdential nOise standards Response See response to Comment 4 37 o Comment 4 64 Area G, page 36, NOise, EnVIronmental Settmg, thud paragraph, thIs statement IS maccurate and should be revIsed The sentence does not separate nOise exposure levels by land use type and Infers that that the prOjected nOise level WIthIn all of Area G has an overlay of 65 dB With the rest of the Area havmg less than 65 dB AddItIOnally, does not add the dIsclaImer Included In Area H, beIng that foreground bUlldmgs, walls, etc Will attenuate and reduce much of the nOise before It reached Area G Tlus statement has more beanng on thIs Area as It has a greater dIstance from the freeway FInally, the text needs to be revIsed to clanfy that Areas G and F are not Impacted by nOise generated by TassaJara Road () Response The EnVIronmental Settmg sectIOn summarizes eXIstzng and future nOIse levels on the SIte based on mformatzon contamed m the EDSP EIR It clearly references other source documents that should be consulted for a full dISCUSSIOn of nOIse Impacts by land use type The EnVIronmental sectIOn also clearly notes that nOIse exposure wzthm the Planmng Area IS expected to be reduced to a level conSIstent WIth Czty standards m the future based on dIstances from roads and the planned constructIOn ofmtervenmg structures ThIS mcludes TassaJara Road There IS nothmg m the text that needs to be corrected or modified o Comment 465 Area G, page 37, Population and HOUSIng, Project Impacts and MItigatIon Measures, the total populatIOn number should be 2,808, not 1,404 as lIsted Two lines later a figure of2,084 IS listed for the approved Planmng Area G Plan If thIs IS the Eastern DublIn SpeCIfic Plan, thIs number IS m error The EDSP permIts 818 dwelling UOlts, whIch works out to 1,636 reSIdents If thIs 2,084 figure IS not the EDSP population for Area G, IS addItional explanatIOn needed? Area F populatIOn should be mcluded m thIs dIScussIon, as land uses and denSItIes have been re-allocated between the two areas Response The ImtIal Study mcorrectly reported the ultImate expected total populatIon of Planmng Area G Based on mformatzon supplzed by the applzcant the Planmng Area IS currently approvedfor an estImated populatIOn of 1,636 people (818 dwellmgs x 2 0 persons per dwellmg based on persons-per-unzt figures contamed m the EDSP) The proposed amendment would allow approxImately 2 808 persons (1,404 dwellmgs x 20 persons-per umt) All other Impacts such as traffic, utIlztIes and servIces have been based on the number of dwellmg umts mcluded m thIS response and no addItIOnal analYSIS IS warranted ({) As noted m the Project DeSCriptIOns m the ImtIal StudIes for Plannmg Areas F and G, the applzcant deSIres to relocate resIdentzal and commercIal land uses between these two Plannmg Areas so any ne~mcrease m populatIOn for the two Planmng - -- City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 29 January 2000 Areas over the eXIstmg Eastern Dublm Specific Plan/General Plan would be small and less than sIgnificant . o Comment 466 Area G, page 40, "b," tlurd lIne, the number of reSIdents for Area G should be revIsed to 2,808 resIdents The estImates for park dedIcatIOns are also mcorrect The IrntIal Study uses the Incorrect populatIOn and secondly It uses the standard of 5 acres of park for 1,000 resIdents Per CIty standard, local parks are only 1 5 acres of the total, With commuruty parks makIng up the remaIrnng 3 5 acres per 1,000 Hence, the 7 02 acre figure should be revised for local parks TIns Will also affect the overall Area F and G park acreage, wmch should be revIsed EnVIronmental Settmg, second paragraph, Refer to Area H, Item 36 (Comment 37) concemmg non- resIdential nOIse standards Response The commenter IS correct See response to Comment 4 65 regardmg the future estImated populatIOn for Planmng Area G Based on the corrected antICIpated corrected populatIOn for Planmng Area G, an antICIpated 4 2 acres of neIghborhood parks would be reqUlred based on a ratIO of 1 5 acres of neIghborhood parks per 1000 resIdents o Comment 467 Area G, page 45 and throughout, reVIse the four references to Area F to Area G Response The ImtIaI Study IS hereby corrected by reference to Incorporate the above . change o Comment 468 Area F, refer to comments on Areas G and H Response Refer to responses for Planmng Areas F and H o Comment 469 Area F, page 3, second lIne, refer to Area H regardIng the word "creek " Response The Eastern Dublm Specific Plan EIR notes the presence of "mtermlttent creeks" north of the eXIstmg stock pond m Planmng Area F South of the stock pond the ImtIal Study for Planmng Area F IS hereby changed to refer to such features as "defined dramage areas" Also refer to Comment 3 1 0 o Comment 470 Area F, page 3, Project DescnptIOn, SpeCIfic Plan/General Plan Amendment, second paragraph, the first line should be revIsed to read all of MedIum HIgh DensIty, not a portIOn, as noted Response The ImtIaI Study IS hereby corrected by reference to mcorporate the above change regardmg the descnptzon of MedIum Denslfy ResIdentIal land uses City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 30 January 2000 . I) () () o Comment 471 Area F, page 4, Table 1, land use acreages are not the most current, specIfically regardmg the MedIUm DensIty ReSIdentIal (689), Public/SemI-PublIc (39) and Open Space (28) and the unItS of MedIUm DenSIty ResIdentIal (689) Response The Imtlal Study IS hereby corrected by reference to zncorporate the above change o Comment 472 Area F, page 4, first paragraph, tlns paragraph IS not really true, only the north-south artenal street has been adjusted by the proposed applIcatIOn These streets (SIC) do not go through Area H as stated Response The Imtzal Study IS hereby corrected by reference to zncorporate the above change o Comment 473 Area F, page 5, Assessment DIStrICt dISCUSSIon, first paragraph, need to add Area F In addItIOn to or mstead of the Area G Response The Imtzal Study IS hereby corrected by reference that Phase 1 Assessment DIstrIct Improvements are encompassed wlthzn Planmng Area G WIth the exceptIOn of the southerly SIde of Dublzn Boulevard (wlthzn Plannzng Area H) and the northerly SIde of Central Parkway (Planmng Area F) Phase 2 of the Assessment Dlstnct proposes the constructIon of Gleason Road across the sIte wlthzn Plannzng Area F o Comment 474 Area F, page 6, second paragraph, there IS no dISCUSSIOn of a Master Tentative Tract Map beIng mcluded m tlns IrutIal Study In addItIOn, the lot lme adjustment noted m the document does not Include Parcel 0 (wlthtn Plannmg Area E of the Dublm Ranch) by reference Response See the ClarificatIons to Imtlal StudIes Project Descnptzons regardzng proposed subdIVISIOns of the three Plannzng Areas o Comment 475 Area F, Project DescnptIOn, see prevIOUS comment Response See the ClarificatIOns to Imtzal StudIes Project Descnptzons regardzng proposed subdIVISIOns of the three Planmng Areas o Comment 476 Area F, page 11, General Plan deSIgnatIOns, MIddle School, Elementary School, NeIghborhood Park, NeIghborhood Square, Pubhc and SemI- Public uses are not zOIDng dIstrICts If thts remams, the MIddle School should be reVIsed to be a HIgh School Response EXlstzng zomng dlstrlctsfor Planmng Area F mclude PD-Smgle Famlly Resldentlal, P D- MedIUm DenSIty ReSIdentIal P D- MedIum HIgh Denslty Resldentzal, PD-Hlgh DenSIty Resldentlal, PD-Hlgh DenSIty Resldentzal and PD- Nelghborhood Commerczal City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 31 January 2000 o Comment 477 Area F, page 12, first paragraph, no "potentIally sIgmficant Impacts" eXists on the ImtIal Study checklist, even though thIs IS referenced In the text of the . Imtlal Study The checklist should note that Impacts are potentially sIgmficant unless rrntIgatIOn IS mcorporated Response Refer to the responses to Comments 4 12 o Comment 4 78 Area F, page 25, fIrst paragraph, where a Statement of Overndmg Concerns has been adopted, the Impact remaIns potentIally sIgmficant and unavOidable The Impact Isn't reduced to "less than SIgnIficant" m succeedIng enVIronmental documents Response See responses to Comments 4 19 and 4 20 o Comment 479 Area F, page 27, "b," second paragraph, see above comment regardIng Statement of OvemdIng ConSIderatIOn Response See response to Comment 4 78 o Comment 480 Area F, page 27, "d and e," second paragraph, see above comment regardmg Statement of OvemdIng ConsideratIOn Response See response to Comment 4 78 . o Comment 481 Area F, page 27, BIOlogIcal Impacts, EnVIronmental Settmg, first paragraph, exchange the word "one" for "at least once" Response The changes zdentified above are zncorporated by reference znto thIS Imtzal Study o Comment 482 Area F, page 31, BIOlogICal Impacts "m," the reference to a nummum 300-foot buffer along the stream to the northern draInage should be replaced WIth "appropnate buffers along the draInage Will be preserved" ThiS IS because the speCIfic dImenSIOn WIll be dependent on outcomes of dISCUSSIons With other regulatory agencies The term "stream" should be replaced With the term "tnbutary draInage" Response See Master Response to BzologIcal Impacts MItIgatzon Measure 2 (Ill) has been modified as outlzned zn the Master Response . City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 32 January 2000 f) () (() o Comment 483 Area F, page 32, BIOlogICal Impacts, mItIgatIOn measure, this section descnbed the proposed mItigatIOn configuratIOn, yet says, "Will be filled and later recreated " Tlus lffiplIes that the proposed mItigatIOn IS the eXistIng condItion to be filled and recreated "Filled and later recreated near ItS former locatIOn" should be changed to "created" to clanfy that these are the measurements for the constructed feature and not the jUflsdlctIOnal area AddItIOnally, the third lIne refers to "m-land" mItIgatIOn "In-kmd" mItigatIOn IS not proposed, but mItigation has been proposed m terms of seasonally ponded wetlands Response The Imtzal Study zs hereby corrected by reference to reflect that the channel to be constructed wzll be "created" rather than "recreated " The ongmal text was taken from the H T Harvey & Assoczates report o Comment 484 Area F, page 32, BIOlogICal Impacts, MItigatIOn Measure 3 (11), unclear what this mItigatIOn measure IS callIng for Refer to Harvey Report Response MztzgatlOn Measure 3 (zz) whzch zs based on the Harvey report, would requzre the project developer(s) to provzde off-szte mztlgatzon for loss of the on-szte stockpond, whIch also serves as a breedzng pond for red-legged frogs and tzger salamander o Comment 485 Area F, page 35, first and fifth paragraphs, the ImtIal Study IndIcates a hIstory of landshdes, however, the geotechrucal report only IDdlcates that there IS eVIdence of preVIOUS landholdIng In some of the swales It does not IndIcate extensIve landslIdIng as noted m the ImtIal Study Response The changes zdentified above are mcorporated by reference mto thzs Imtzar Study to note that there has been a hzstory of landslzdmg m some of the swales and does not zmply WIdespread landslzdmg throughout the Plannzng Area o Comment 486 Area F, page 35, DraInage, "stream" should be revIsed to read "defmed dramage " Response Fzgure 3 7-B clearly shows the presence of zntermzttent streams wzthm Plannmg Area F north of the exzstzng stock pond The Planmng Area F Imtzal Study IS hereby modified to reflect the presence of defined draznages south of the exzstmg stock pond o Comment 487 Area F, page 37, and throughout, the ImtIal Study should be revIsed to reflect that there are no IntermIttent streams or creeks m the Planmng Area, only defmed dramages Response See response to Comment 4 86 ~ -- City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 33 January 2000 o Comment 488 Area F, page 39, Land Use and Plannmg, Project Impacts "b" second . paragraph, the last sentence doesn't make sense, please adVIse regardIng changes to the CIrCUlatIOn Element Response The lmtzal Study lS corrected by reference to delete references "to prevlOUS CzrculatlOn Element" changes o Comment 489 Area F, page 39, Land Use and PlannIng, Project Impacts "b" second paragraph, the number of dwellIng umts should be changed to mdlcate 275 dwellmgs mstead of 240 Response See response to Comment 4 62 o Comment 4 90 Area F, page 40, NOIse, EnVIronmental SettIng, the statement that mmor portIons of Area F would be subject to long term nOIse IS not correct, smce the 60 d hne parallels eXIstmg Central Parkway Secondly, Tassajara Road IS not a nOIse source affectmg Plannmg Area F Lastly, the sectIOn does not add a dtsclarmer that much of the nOIse reachIng Area F would be reduced by mtervenmg structures pnor to reachIng Area F Response The lmtzal Study lS corrected by reference to note that Plannmg Area F lS outszde of the future slgnificant nOlse exposure level as mdlcated m the Eastern . Dublm EIR However there remams a posszbllzty of future slgnificant nOlse based on vehzcle travel on local streets, MltlgatlOn Measures contamed m the Eastern Dublm EIR would stlll requzre mdzvzdual acoustzcal analyszs for mdzvldual subdlvzslOns wlthm Planmng Area F as they may be proposed for development o Comment 491 Area F, page 41, PopulatIOn and HOUSIng, Project Impacts "a," lInes 9 and 11, the ImtIal Study does not reflect the most recent dwellIng umt count Instead of 1,677 for an estImated populatIOn, a populatIOn of 1,669 should be used Instead of a populatIOn of 1,091 In the e~lstmg SP/GP, the number should be 1,092 Response The lmtzal Study lS corrected by reference to reflect the above populatlOn numbers o Comment 492 Area F, page 43, RecreatIOn, Project Impacts "a," fIrst paragraph, fIrst sentence, the ImtIal Study does not reflect that just for Area F, the amended plan proposes a lower population figure that the eXIstIng EDSP Only If both Areas F and G are taken together would the populatIOn estrmate exceed the eXlstmg EDSP population figures Response The comment zs correct The Czty stzll prefers to conslder cumulatlve zmpacts of all three SPIGP applzcatlOns m terms of populatlOn traffic recreatlOn and others -- City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 34 January 2000 . (() o Comment 493 Area F, page 43, RecreatIOn, Project Impacts "b," the populatIOn figure should be 1,669 and not 1 ,677 Response The Imtral Study IS corrected by reference to reflect the above populatIOn number o Comment 493 Area F, page 43, RecreatIOn, Project Impacts "b," the populatIOn figure should be 1,669 and not 1,677 Response The Imtral Study IS corrected by reference to reflect the above populatIOn number o Comment 494 Area F, page 44, RecreatIOn, Project Impacts, first paragraph, the paragraph IS supposed to be dlscllssmg neIghborhood park requIrements, however, the figures stated mcludes both neIghborhood and communIty park reqUlrements The last sentence should be rewntten to say that the overall Areas F and G neIghborhood park reqUlrement IS 6 7 acres whIle the two Area Plans propose 16 8 acres Tills results m an excess of 10 1 neIghborhood park acres than IS reqUlred to be dedIcated I) Response EstImates of park reqUirements for the project mcluded m the ImtIaI Study are In error For the three Planmng Areas the CIty uses a neighborhood park dedlcatzon reqUirement of 1 5 acres per 1000 resIdents The amount of parkland proposed In Planmng Areas F and G exceed thIs standard The requIrement fO/ commumty parks IS calculated separately and accounts for the remamder portIOn of - Dublm Ranch The Impact remams le<;s-than-slgmficant wIth regard to the provlSlon of parkland o Comment 4 95 Area F, page 51, "e," wastewater dIsposal IS not dIscussed Response Wastewater dIsposal IS dIscussed In the Eastern Dublm EIR (Impact 35/G), whIch ha<; been Incorporated by reference as part of the ImtIaI Study WIth adherence to MltlgatlOn Measures 3 5/11-14, Impacts related to wastewater dIsposal would be reduced to an mSlgmficant level Comment 5 lEast Bay RegIOnal Parks DIstrIct o Comment 5 1 The subject MItigated Negative DeclaratIOn Identifies Tassajara Creek as the proposed locatIOn for bIOlogICal mItIgation for the Dublm Ranch projects by preservmg, enhancmg and restormg a 5,200 foot sectIOn of Tassajara Creek north of the proposed Greenbnar development The Dlstnct IS concerned that a large portIOn of the proposed nutlgatIOn SIte IS owned by the DIStrIct and would therefore not be aVaIlable for mitIgation for the Dublm Ranch project (f) City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 35 January 2000 Response The MrflgatlOn Measure referenced m thIs comment proposes the enhancement and restoratlOn of habItat along a porllon ofTassajara Creek as . contamed m the Harvey report ThIs and other mltlgatlOn measures presented m thIS report are Identified as optlOns for mztzgatlOn of rzparzan/wetland Impacts to Plannmg Areas F and H Impacts to rzpanan resources occur only m Planmng Area F, and that Imtzal Study mcludes mltlgatlOnfor the loss ofrzparzan habitat The mltlgatwn for Plannmg Area F nparzan 1S the creatlOn of an 810-foot long dramage on the sIte and restoratIOn and enhancement of a portlOn of the Northern Dramage RestoratlOn and enhancement of nparzan habltat along Tassajara Creek may be a proposal assoc1ated with development of the remamder of Dublm Ranch A record of survey performed by the applzcant's surveyor has determmed that the proposed mltlgatzon area along Tassajara Creek IS wIthm the Dublm Ranch property Ajigure has been attached, provlded by the project applzcant, that presents known property boundanes m the area - City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 36 January 2000 . -- "., ..... < ~ !:: S !: { - { :.Il { t'.o'J !:: ~ i: Q ( .8 e ~ ~ \,) 2: - ~ 0 -- :;; - ::... ...... "::l.:.t: 2S a> ~ !:: t rn ":I ... 0 ..... :;:U Q:: I.:l <; C":l - ... ~ c -::; ":I ~ ~-. - = \C - ." ~ - ." N ::t: u ~.; ll) ~ ~ ll) ( ll) < c: :; ~ o o ..". :; '" ~ "'iJ '" ~ 3~ '" ~ '" !:: ~ ::: ::: e = i3 .. ~ - ~ 0:::.;:: E~ .., '" '" .2 (f) o Comment 5 2 The MItIgated NegatIve DeclaratIOns IdentIfies potentially sIgmficant Impacts to two specIal-status speCIes of plants, CahfornIa TIger Salamander, red- legged frogs, burrowmg owls, badgers and nestIng sparrows Many of these Impacts were not properly addressed In the Eastern Dublm SpeCIfic Plan/General Plan (EDSP) ErR The CIty may wIsh to postpone consideratIOn of the subject Dublm Ranch applications untIl such time as conflIcts between development and specIes conservatIOn have been resolved The DIStriCt recommends revISIons to the EDSP and EIR as recommended by USFWS, the preparatIOn of a multi-specIes habItat conservation plan and other studies to examme cumulatIve Impacts to speCIal-status speCies Response The CIty of Dublin IS satIsfied that the Eastern Dublin Specific Plan/General Plan EIR, supplemented by addltlOnal blOloglcal analyses, con tamed In the Harvey report for the proposed Dublin Ranch Planmng Area F G and H developments, are adequate to meet the reqUlrements ofCEQA The Harvey report analysIs revIews potentzallmpacts to speCIes IdentIfied In the Eastern Dublin Specific Plan/General Plan EIR a'l well as speCIeS Identified smce certificatIOn of that EIR MItIgatIOn measures adopted as part of the Eastern Dubhn Specific Plan/General Plan EIR have been apphed by reference to the three proposed Dubhn Ranch projects AddItIOnal refined mItIgatIOn measures are set forth In the Harvey report as modified by the Response to Comments Also refer to the response to Comment 6 J on thIS tOpiC C() Comment Letter 6 CalifornIa Department of Fish and Game o Comment 6 I The Department does not beheve that the FEIR for the Eastern DublID - SpeCIfic Plan/General Plan fully dIscusses speCIes occurrences, IncludIng Impacts to speCIes not covered or adequately addressed III the ongInal FEIR ThIs FEIR should therefore not be referenced as adequate under CEQA for dIsclosure or provldmg mitIgatIOn for these specles () Response The CIty of Dublm IS satIsfied that the EDSP EIR, supplemented by addItIOnal bIOlogIcal analyses such as have been recently prepared by H T Harvey for the proposed Dublm Ranch Planning Area F G and H developments are adequate to meet the reqUlrements of CEQA The Harvey report analYSIS revIews potentzallmpacts to speCIes Identified m the Eastern Dublm Specific Plan/General Plan EIR as well as speCIe 'I Identified Since certificatIOn of that EIR The prevIOUS EIR contamed extenSIve dISCUSSIOn of potentzallmpacts to numerous specIes It antIcIpated potentzal effects to all o/the speCIes mentIOned m the CDFG comment letter and Identifies mItigatIOn measures as necessary to reduce Identified Impacts to less-than-slgnificant levels (se SectIOn 3 7 of the EDSP EIR) For example Impact 3 7 IF addresses destructIOn of small water features whIch prOVIde habItat for red- leggedfrogs ThIS Impact was reVIewed and refined as part of the DublIn Ranch project by Harvey & ASSOCIates, as the SIte moves closer to potentzal development MmgatIOn measures set forth In the certified EIR contInue to be apphed to Implementing prOjects, such as Planmng Areas F, G and H MItIgatIOn measures City of Dublin Page 38 Dublin Ranch PA's F, G & H January 2000 Response to Comments znclude reqUlrements such as vegetatlOn enhancement/management plans for open space areas (MM 3 7/2 0) and pre constructIOn surveys for certam speCIes (MM . 3 7/20 0) and numerous other measures Impacts and mItIgatIOns to other species such as the Califorma TIger Salamander, burrowing owl AmerIcan badger and others, are also addressed In the EDSP EIR Further mItIgatIOn measures requIred as part of the Imtzal Studlesfor Planmng Areas F, G and H buzld on the EIRfoundatzon to clarify and provide more proJect-specific detazl The CIty's consulting bIOlogIst has reviewed the orIginal EDSP mItIgatIOn measures, the currently proposed mItigatIOn measures and the comment by CDFG In the profeSSIOnal OpinIOn of the consultzng bIOlogIst, the prevIous mItIgatIOn measures set forth In the EDSP EIR together WIth the mItigatIOn measures proposed In the three Imtzal Studzes WIll reduce potentwl bIOlogical Impacts to less than SIgnificant levels .. Comment 6 2 The Department does not beheve mItigatIOn measures set forth In the MItigated Negative DeclaratIOns would reduce potentIal Impacts to a pOInt of less- than-slgmficance as reqUITed by CEQA A mandatory findIng of sIgmficance must be made Response The City of Dubhn IS satisfied that complzance wIth CEQA has been achIeved through the three proposed Inztwl StudIes and proposed Issuance of MItIgated NegatIve Declaratzons Full d,sclosure of Impacts to bIOlogical resources have been made In the Imtzal Stud,es !'upplemented by addllIOnal mformatlOn contamed In the Master Response to BIOlogIcal resources contamed In th,s Response to Comments MItIgatlOn has also been proposed so that Impacts to blOlogIcal resources WIll be reduced to a level of less than SIgnificance . .. Comment 63 It IS the oplmon of the Department that constructIOn of the project would result In fragmentatlOn of habitat and blockIng of movement corndors of the red-legged frog and that the ffiltlgatlOn proposed IS not adequate to reduce this Impact to a less-than-slgmficant level Response Refer to Master Response to BIOlogIcal Resources whIch addresses blockage of movement corrzdors .. Comment 6 4 The Department does not agree WIth the findmg contamed m the Imual Study regardmg the mlgratIOn pattern of the red-legged frog and that the Impact to thIS speCIes has been underestImated Response Refer to Master Response to BzologIcal Resources .. Comment 6 5 Areas along Tassajara Creek are Identdied as the proposed mItigatIOn area for red-legged frog Impacts The Department beheves the proposed mItigatIOn area IS owned by the East Bay RegIOnal Parks Dlstnct and may not oe avarlable for mitigatIOn City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 39 January 2000i €I (() Response See the response for Comment 5 1 o Comment 6 6 Surveys and mItIgatIOn measures for red-legged frogs should follow established USFWS and Department gUIdelInes Response Surveys for sensItIve bIOlogIcal specIes comply wIth the prevIOusly adopted Eastern Dublzn EIR AddItIOnal surveys WIll follow applzcable Agency and Department guldelznes o Comment 6 7 The Department does not agree With the findmg contaIned In the IrutIal Study that mItigatIOn measures related to estivatIOn habItat for the Callforrua TIger Salamander WIll be commensurate With Area F only The Department beheves all of Areas F, G and H to be potential habItat for red-legged frogs and measures need to be Identified to mInlmlze Impacts to all of thIS area Response Refer to Master Response to BIOlogIcal Resources contazned zn thIS document regardzng the range of tIger salamander upland habItat (() o Comment 6 8 The Department does not concur With the fIndmg contarned m the IrntIal Studies that lot fox speCIes are presumed absent from the project SIte The area lIes WIthIn the western range of the kIt fox and SUItable denrung and foragIng habItat eXIsts on the project SIte PermIts are reqUITed for talong of habItat area and adequate mItIgatIOn reqUITe compensatory preservatIOn of habItat at a 3 1 ratio Response Refer to Master Response to BIOlogIcal Resources o Comment 6 9 The Department consIders the proposed mItigatIOn for Impacts to burrOWing owl to be Inadequate AddItIOnal mItIgation IS needed Response Refer to Master Response to BIOlogIcal Resources o Comment 6 10 The Department IS opposed to the removal of eucalyptus trees (SIC) along the southern edge the SIte These trees proVIde SUItable habItat for varIOUS species of tree-nestIng raptors Removal of the trees (SIC) WIll result m a sIgruficant temporal loss of potentIal nestIng habItats well as a permanent loss If mItIgatIOn IS not Incorporated Any tree removal and replantIng program should be deSCrIbed In a MItIgatIOn Morntormg Plan Response Refer to Master Response to BIOlogIcal Resounes () o Comment 6 11 The Department recommends that a thorough field survey be completed for San Joaqum spearscale and Congdon's tarplant and approprIate mItIgatIon proposed If pOSSIble, the D_epartment recommends that rmpacts be aVOIded City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 40 January 2000 where such speCIes occur along With an appropnate buffer area TranslocatIOn IS not approved by the Department as an acceptable mItIgatIon measure, smce It IS . expenmental and does not meet the standards of CEQA The dISCUSSIon found In the InItIal Study IS not consIdered adequate Response Refer to Master Response to BIOlogIcal Resources o Comment 6 12 The Department recommends a mInImum buffer of 100 feet adjacent to wetlands A Streambed AlteratIOn PermIt must also be obtamed from the Department pnor to any work m a creek or stream comdor Response The prelzmznary cross-sectIOn of the re-created on-szte wetland submItted by the applzcant zndIcates that approxImately 30 feet of buffer area would be reserved on eIther SIde of the wetlandldraznage channel The Department of FIsh and Game comment and recommendatIOn IS acknowledged It IS further noted that thIS feature IS not zntended to be full mItIgatzon for loss of on-SIte wetlands extenSIve off-SIte wetlands are also proposed to be preserved as part of the project mItIgatIOn program The applzcant acknowledges that the final deSIgn of thIS feature may change as development plans are finalzzed and necessary Streambed AlteratIon PermIts obtazned from the Department of FIsh and Game Comment Letter 7 U S FISh and WIldlIfe Service o Comment 7 1 The ServIce IS concerned With the segmentatIOn of the proposed . Dublm Ranch planrung areas The pIecemeal approach reduces the likelIhood of the hsted speCIes to perSIst on-SIte (WlthJ.n DublIn Ranch), much less WlthJ.n the entIre Eastern DublIn SpeCIfic Plan The ServIce requests that the CIty of Dublm reevaluate- these three plannmg documents and the remarmng undeveloped portIOn of the Dublm Ranch under one plannIng document Response Although the envIronmental Impacts of the three adjacent plannzng areas have been presented zn three separate InztIal StudIes, potentIal Impacts have been addressed as though one project eXIsts ThIS was specifically done for potentIal bIOlogIcal resources where a szngle report (the Harvey report) was prepared to evaluate potentIal Impacts and recommend approprzate mItIgatIOn measures In terms of zncludzng other portIOns of Dublzn Ranch no other development proposal S" had been receIved by the CIty of Dublzn at the tIme the envIronmental documents for the three plannzng areas were commenced Therefore an accurate evaluatIOn of potentzal development Impacts to the remazndel of Dublzn Ranch (a portIon of whIch has been approved for development) could not be made The three projects under conSIderatIOn total approxImately 300 acres of land andjlexIbIlzty eXIsts to accommodate mItIgatIOn on and off of the project SIte o Comment 7 2 The ServIce does not concur With the findmgs of the InItial StudIes WIth regard to red-legged frogs and salamangers Other speCIes may eXIst WlthJ.n City of Dublin Dublin Ranch PA's F, G & H Response to CommentsI Page 41 January 2000 . I) seasonal wetlands, mcludmg the conservancy farry shnmp, the longhorn fau)' shnmp, and the vernal pool tadpole shnmp Response Refer to Master Response to BIOlogical Resources o Comment 7 3 The ServIce does not concur with the presumed absence of kit fox from the SIte Slghtmgs have been made of at least two kit fox sltmgs wltmn ten mIles of the SIte The planmng areas contam swtable habitat for thiS speCIes and no barTlers eXIst to prevent lot fox from reachmg the SIte Response Refer to Master Response to BIOlogical Resources o Comment 7 4 The ServIce does not concur With the presumed absence of the conservancy farry shnmp, the longhorn fatry shnmp or the vernal pool tadpole shnmp from the SIte Response Refer to Master Response to BlOloglcal Resources I) o Comment 7 5 The ServIce contmues to be concerned over lack of appropnate rmtlganon for federally lIsted speCIes Wltlnn the East DublIn Plannmg Area Specifically, measures fml to aVOId Impacts to lot foxes, red-legged frogs, salamanders and vernal pool mvertebrates The documents fall to descnbe Impacts to upland portIons of the planmng areas or the mdrrect Impacts associated WIth gradillg the upland portIOns of the seasonal wetland Response Refer to Master Response to BIOlogical Resources o Comment 76 The proposed projects are lIkely to result ill a take of lot foxes and red- legged frogs and possIble the farry shnmp, the longhorn falI shnmp, or the vernal pool tadpole shnmp A formal SectIOn 7 consultatIon may be needed Response Refer to Master Response to BIOlogIcal Resources regardmg potentzal Impacts to the species hsted In the comment It IS hkely that Planmng Areas F and H would requzre SectlOn 7 consultatIOns pnor to Issuance of necessary perm lis or other authOrIzatIOns o Comment 7 7 In conclUSIOn, the proposed projects Will further Isolate and fragment populatIOns of red-legged frogs wlthm the TassaJara Creek watershed and areas to the east of TassaJara Creek A mmnnum buffer of300 feet between all wetlands and upland dIspersal corndors are necessary to ensure the project does not Isolate the red- legged frog, The development of these comdors would also ffilmmIze Impacts to other speCIes, mcludmg the lot fox (f) City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 42 January 2000 Response Refer to Master Response to BIOlogIcal Resources regardmg the fragmentatIOn ofred-Ieggedfrog populatlOn The Master Response a/so recommends . the dedlcatlOn of a mmlmum 63-acre off-sIte mItIgatIOn area that would very lzke/y mclude a mtmmum 300-foot wide buffer Comment Letter 8 CahforDla RegIOnal Water QualIty Control Board, San FrancIsco Bay ReglOD o Comment 8 1 Board staff are concerned that the NegatIve DeclaratIOn may not adequately address the proJect's potentIal Impacts to wetlands, nparlan waters and assocIated endangered speCies, mcludmg the red-legged frog and CalIfornIa tIger salamander Response Refer to Master Response to BIOlogical Resources o Comment 8 2 Board staff are further concerned that project would Increase the levels of pollutants dIscharged from the SIte and could alter the SIte's runoffhydrograph, potentIally Impactmg downstream bed and bank stabIlIty Response The three Inztzal StudIes acknowledge the potentwl mcrease of stormwater runoff from the Hte as a result of proposed urban development DIscussIOn of such Impacts are found m the Hydrology and Water Qualzty sectlOns of the three documents Each of the three Inztwl Studles contam a mltlgatlOn measure that requires project developers to prepare an updated project specific stormwater study . to show the Impacts of mdlvldual developments agamst the master dramage study In terms oflmpacts of downstream bank and bed stabIlity ThIS mltlgatlOn IS consistent wllh Mltlgatzon Measures 3 5/44 -48 contamed m the Eastern Dublzn EIR, which reqUlre the preparatlOn of master storm dram master plans Follow-on studles would also mclude revlewmg potentzallmpacts to downstream bank stabllzty Each project Will be reqUlred to Implement Best Management PractIces for constructlOn and post- constructIOn actlvlfzes to mlnzmlze polluted Morm water runofffrom leavmg the sIte · Comment 83 It appears that the project Will Impact the number and range of eXlstmg rare, threatened and/or endangered speCIes that are known to be present or could be present on the SIte Under CEQA, such Impacts reqUlre a mandatory findmg of sIgmficance and It does not appear that the proposed NegatIve DeclaratIOn complIes With CEQA An EIR or appropnate subsequent or addendum IS reqUlred Although an EIR was prepared m 1992, substantIal new mformatIOn has been developed smce that tIme Therefore, the Board belIeves a NegatIve DeclaratIOn IS not appropnate and an EIR or SImIlar document should be prepared Response The CIty of Dublm IS satisfied that the Eastern Dublm Specific Plan/General Plan EIR supplemented by addltzonal blOloglca/ analyses contamed m the Harvey report for the proposed Dublm Ranch Plannmg Area F, G and H developments are adequate to meet the reqUlrements ofCEQA The Harvey report analYSIS revIews potentwZl1r!P-acts to speCles Identified m the Eastern Dublzn Specific City of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 43 January 2000 . f) I) ~ Plan/General Plan EIR as well as species Identified since certificatIOn of that EIR MItIgatIOn measures adopted as part of the Eastern Dublin Specific Plan/General Plan EIR have been apphed by reference to the three proposed Dublin Ranch projects AddztlOnal refined mztlgatIOn measures are set forth m the Harvey report as modified by the Response to Comments Also refer to the response to Comment 6 1 on thIs tOpiC o Comment 8 4 The proposed development would dIsturb more than five acres of land dunng constructIOn and must be covered under the State NPDES General PermIt Response Each of the three Imtzal StudIes clearly Identifies that a NotIce of Intent IS requzred to be filed WIth the State Water Resources Control Board ThIs reference IS contained In the sectlOn entztled Other Pubhc Agency Requzred Approvals o Comment 8 5 ApproXImately 6 8 acres of U S Army Corps of Engmeers JurIsdIctIOnal wetlands and 1 02 other waters of the Umted States would be Impacted With the proposed development Because the project mvolves potential dIsturbance to all or some ofthts area, a SectIOn 401 Water QUalIty CertIficatIOn or other approval from the State would be needed and should be references m the CEQA document Response Each of the three Imtzal StudIes clearly Identifies that permzts are necessary from the San FranCISco Bay RegIOnal Water Quahty Control Board o Comment 8 6 SectIon 404 (b) (1) of the Clean Water Act IdentIfies the sequence In wmch wetlands and other waters of the Umted States should be treated ThIS mcludes aVOIdance, ffilmrnIZmg Impacts and mItIgatIOn MItIgatIOn should be m-lond and Qn- - sIte, With no net destructIOn of habItat value Response The project IS proposmg to mItigate for the fill of wetland areas at a 2 1 ratlO mItIgate for the fill of non- wetland waters at all ratIO and to restore and enhance an off-sIte drainage area There WIll be no net loss of wetland acreage or habItat value o Comment 8 7 Although the proJect deSIgn would fill certatn areas of creeks and wetlands, It has not yet received reqwred approvals from state and federal agenCIes The deSIgn of the proJect may change dunng agency reVIew and tlns uncertamty should be reflected m the CEQA documentatIOn For ehample, the CIty could commIt to complete any additIonally reqwred CEQA documentatIOn necessary for the proJect to be m complIance followmg any deSIgn changes Response The CIty of Dublin has revIewed the proposed project as submItted by the apphcant The CIty beheves that there IS some degree offlexlblhty to allow mmor changes to the project should changes be requzred as the three projects are revIewed by state and federal regulatory agencIes However, should the project change CIty of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 44 January 2000 slgmficantly the Cay wIll undertake addItIonal CEQA reVIews as necessary and appropnate based on the modified project deSCrIptIon . o Comment 8 8 The proposed proJect must comply WIth NPDES permIt CAS002831 SpecIfic measures mcorporated In the permIt to mIrumIze stormwater runoff pollutIOn Includes numnuzmg land dIsturbance, mInImlzmg ImpervIous surfaces, use of clusterIng and other measures Response Each of the lmtzal StudIes requzre the project developer(s) to prepare and Implement Storm water PollutIOn PreventIOn Plans (SWPPPs) przor to Issuance of gradmg permIts m accordance wah the 1999 edlfzon of the DeSIgn Guzdelme Manual for Storm water Qualzty ProtectIOn These Plans would requzre the developer to mstlfute constructIOn and post-constructIOn pollutIOn preventIOn plans SWP P Ps must be approved by the City of Dublm, the San FranCISco Bay RegIOnal Water Qualzty Control Board and the State Water Resources Control Board Included wlthm the Specific Plan document are stormwater qualzty guzdelmes WhICh reference specific crzterzon for the above-referenced manual o Comment 8 9 The proJect could substantIally alter the eXIstmg runoff hydrograph and flow Into streams Such alteratIOns could result In Impacts to downstream bed and bank stabIhty and assocIated Impacts to loss of habItat and threats to eXIstIng structures adjacent to the streams The present hydrograpmc analysIS IS hmIted to ensUTIng that peak flows Will not create a floodmg hazard and should be expanded Response See Response to Comment 1 . Comment Letter 9 Cahforma Department of TransportatIon o Comment 9 1 Traffic Impacts dIscussed In the document are dependent on the accuracy of forecastIng used As the office, commerCIal, retaIl and reSIdentIal development occurs, a more speCIfic and detaIled traffic analYSIS should be carned out for all proJects WItlnn the Dubhn Ranch area, all ofwmch are close to I-580 Response For the traffic analYSIS contamed m the Imtlal StudIes for the three Planmng Areas, the City has attempted to be as accurate as pOSSIble m terms of mcludmg the Impacts of all known or reasonably fore'ieeable projects m the vlcmlty As addItIOnal development IS proposed m the Eastern Dublm area, mcludmg Dublm Ranch addltlOnal specific traffic analyses WIll be completed Comment Letter 10 Bruce Webb, Dubhn San Ramon ServIces DIstrIct o Comment 10 1 The DIStnCt has made sIgmficant progress In proVIdIng recycled water to the Eastern DublIn area and It IS fully antIcIpated that recycled water wIll be avaIlable to the project at th.:Eme of development City of Dublin Dublin Ranch PAIs F, G & H Response to Comments Page 45 January 2000 . f) Response Comment acknowledged As stated zn the three Imtwl StudIes connectzons to the Dzstnct's recycled water system would be made at the tIme of development if avazlable Project developer(s) would be requzred to obtam permits from DSRSD and znstall reclazmed water faczhtIes zn accordance wzth DSRSD standards durmg project Impl ementatlOn o Comment 102 Planmng Area G, page 47 "b," the statement IS made that sewer lines Will be extended from the east In fact, all sewer lmes and potable water lInes wIll be extended from the west Response The Imtwl Study IS hereby corrected by reference to reflect the above change o Comment 103 Plannmg Area G, page 47 "e," the statement IS made that the local wastewater treatment plant contatns adequate capaCIty for the project, the DIStrIct IS currently expandmg wastewater treatment capaCIty through ImplementatIOn of "Stage IV" Improvements, antIcIpated for completIOn on 2001 Also, LA VWMA wastewater dIscharge facIlIties are bemg expanded at tlns time Response The comment IS acknowledged and the Imtwl Study IS hereby corrected by reference to reflect the above change r I) f) CIty of Dublin Dublin Ranch PA's F, G & H Response to Comments Page 46 January 2000 C([])mmennlt ILeltteIrs City of Dublin Dublin Ranch PA's F G & H Response to Comments Page 47 January 2000 . . . I) ALAMEDA COUNTY FLOOD CONTROL AND WA.TER CONSERVATION DISTRICT 509~ PARVSIDE DRIVE d PLEASANTON CALIFORNIA 9~5"" :: 27 6 P.;or E (920) ..84 2600 I..X \920) 402 39 ~ December 6, ] 999 Mr DennIS H Carnngton, SenIor Planner CIty of DublIn ] 00 CIVIC Plaza Dubl1O, CA 94568 letter 1 RECEIVED DEe 7 1999 DUBl'N PLANNING Re MItIgated NegatIve DeclaratIOn DublIn Ranch Areas F, G and H Dear Mr Carrmgton Zone 7 has revIewed the above-referenced NegatIve DeclaratIon Comments have been made 10 the follow1Og areas and are descrIbed below ]) Flood Control Flood Control ~ Page 37, Item c, substantIally alter dramage patterns, mcludmg streambed courses such that substantial siltatIon or erosIOn would occur? The paragraph states that storm dram runoff would eventually flow to the Alameda County Flood Control and Water ConservatIon DIstrIct G-3 faCIlIty ImmedIately north of the 1-580 freeway It should be known thIS IS a master planned dramage facIlIty that currently does not eAlst ThIs faclhty (Lme G-3) would have to meet Zone 7 standards If Zone 7 IS to take ownershIp of the faCIlItIes Thank you for the opportunIty to comment on your envIronmental document If you have any questIons regardmg our response, please call me at eAt 231 ~~7ljAr~ Sal Segura / Water Supply Advance Plannmg EnVIronmental Document Coord1Oator SS ss () cc Ed Cummmgs, Zone 7 DennIS Gambs, Zone 7 Dave Lunn, Zone 7 John Koltz, Zone 7 ~\~ j#' \ COUNTY OF ALAMEDA PUBLIC'VORKS .\GENCY DEVELOPMENT SERVICES DEPARTMENT 95] Turner Court Room ] 00 Hay\\ ard CA 94)45 2698 (5]0) 670 660] FAX (5] 0) 670 5269 November 30 1999 , . Anne Kmney, ASSIstant Planner CIty of DublIn, Plannmg Department PO Box 2340 Dubhn, CA 94568 RECEiVED DE~ - ?, 1999 O\J6L\N pLANN\NG Letter 2 Dear Ms KInney Reference IS made to your correspondence dated November 8, 1999 transmItting a copy of the L111Ml 'StudylMItlgated NegatIve Dec1aratlOns for Dublm Ranch Planning Areas F, G and H P 1\ 98-068 .\rea F, PA 98-069 "Area G' and PA 98-070 Area H We thanK you tor the opportunIty to Ie\ lew these documents Please consIder the follOWing m estabhshmg the conditIons of approval 2 1 It IS our understandmg that all Flood Control Issues are being addressed by Zone 7, I\lameda County Flood Control and Water ConservatIon DIStrIct and the CIty of Dublm However, dramage Impacts from thiS proposed development on downstream facIhtles should be addressed In partIcular the Arroyo de la Laguna has been e>..penencmg numerous eroslOn problems m recent years The effect that runoff from thIS new development WIll have on the Arroyo should be addressed 2 ReqUIre the apphcant to deSIgnate proposed haul routes, and to reparr damage to County roads used as a haul route, or damaged by constructIon actIvIty TypIcally, we work out a letter agreement WIth the developer, and Issue a permIt 11us guarantees repaIr of any damaged portIons of the road\\ ay and/or contrIbutIon to future overlay projects . 2 2 3 It was unclear where the lUnIts of wldenmg of TassaJara Road are proposed Are Improvements 2 3 proposed along the County of Alameda maIntamed portIon of the roadway? The report should adequately address thIS Issue 4 2 4 All roadway and storm dram faCIlItIes m the County nght-of-way are to conform to Alameda County s SubdIvIsIon DeSIgn GUIdelines and Hydrology and Hydrauhcs Cntena Summary All \Vorh. must be m comphance WIth Alameda County ordmances, gUIdelines, and permIt reqUIrements tvly nght-oi-way uedJ(,auon Judd lillplu\;:;nleULS, au) ne",c:;~a...) r.::loc:lt.o"" of ~~ Lj f':lCl1,1-,,::: :n~l1 'Ie :3t no cost to the County If you have any questIons please feel free to contact me at 510-670 5260 Very truly yours, o/J/~~ ~ WIlham Lepere Development Services (I T() "ERVF A.ND PRESERVE OUR COMMUNITY Attorney at Law RECEIVED UtL 0 1999 MARi~N Wo ~N[DlERB~iZIEN I) DUBLIN PLANNING December 6, 1999 Mr Eddte Peabody, ]r Drrector of Commumty Development CIty of Dub 1m 100 CIVIC Plaza Dublm, CalIfornIa 94568 Letter 3 Re Mitigated NegatIve DeclaratLOn and Inztlal Studies Areas F, G, and H Dear Mr Peabody Thank you for the opporturnty to reVIew the MItIgated NegatIve DeclaratIOn and Imnal Study documents for Dublm Ranch Areas F, G, and H We offer our comments on the attached sheets, however, Issues of speCIfic concern are dIscussed below f) 3 1 We have many concerns regardmg the blOlogy sectIons FIrst, the recomrnendatlODs mcluded 10 the EcologIcal Impacts and MltlgatIOD report prepared by H T Harvey, dated October 25, 1999, should be used and mcluded 1D these ImtIal Studies Wltlnn the studIes there IS certam verbIage that ImplIes certam plant and ammal speCIes are present on SIte, when eVIdence subITIltted IS to the contrary AddItIOnally, there IS a statement that "a nummurn buffer of 300 feet along the stream 1D the northern dramage" Will be preserved for red-legged frogs We dtsagree With tlns and belIeve that It should be replaced WIth "appropnate buffers along the dramage WIll be preserved" because the speCIfic dImenSIOn v.'1ll be dependent upon the outcome of our dISCUSSIOns With the Corps and other agencIes Fmally, we are confused WIth the burrOWIng owl nutIgatIOn plan for habItat 1t should be made clear that If owls are not found on the SIte, then a habItat set-asIde IS not reqUIred 3 2 Many concerns eAlst regardmg wetlands and JUflsdlctIOnal areas Generally, condItIOns and recommendatIons mcluded m the Ecological Impacts and MItIgatIon report prepared by H T Harvey, dated October 25, 1999, should be used and mcluded m these Imtml Studles SpeCIfic Issues mclude Area F text descnbmg the proposed lllil1gatIOn feature as the eXIstmg COndITIOn AddITIonally, we are concerned about how the text ImplIes, m error, certam types, locatIOns and amounts of mItIgatIOn that vnIl be proVided by us TIns needs to be remedied by refemng to the JUTlsdIcl10nal mItlganon sectIons of the H T Harvey report I) A \WINDo~~Uih$.u~~oulevard Suite A Pleasanton California 94566 Phone 925 485 1060 Fax 925 485 1065 Mr EddIe Peabody, Jr December 6, ] 999 Page Two . 3 3 MItIgatIon Measure 5 of the Imtlal Study requrres that the project's "faIT share contnbutIOn" for downstream rmprovements be documented It should be noted that A CF C Zone 7 has a dramage pro gram for tlns purpose and that the proJ ect Will pay Zone 7 fees and the need to study or · docwnent' tlus should removed from the IrutIal Study 3 4 There IS a concern regardmg the floodplam dIscussIOn The mItIgatIOn measure callmg for certIficatIOn pnor to approval of gradmg permIts IS unclear and we sllspect that the mtentIOn IS not consIstent WIth flood platn processIng We belIeve the "certIficatIOn" whIch the lrutJal Study IS refemng to IS a certIficatIOn that the property IS filled that FEMA reqillres pnor to takmg the property out of the floodplatn The mItIgatIOn measure should reflect FEJv1A reqUirements and read ., Apphcant shall remove habItable portIOns of the proJ ect from the 100 year FEMA floodplam pnor to occupancy penmts bemg Issued" The applIcant has already obtatned a condItIonal letter of map reVISIOn 3__~ Much of the te:h."t m these documents appear to be wntten generally so as to cover all three Areas Because of tlus, addltlonal clanficatIOn of certam Issues IS needed to prevent confuSIOn and maccuracles such as the Iruual Study te:h.t concernmg cultural resources and tIger salamanders IS pertment only to Area F . !3 ~_ The InItIal StudIes mclude numerous traffic mitIgatIOns that are very speCIfic and were taken dIrectly from the traffic report It should be pomted out that these mIugatIOn measures assume a long lIst of developments and Improvements havmg occurred 10 the area before tlus project comes on lme TIus long lIst of asswnptlons 15 mghly speculatIve and mayor may not be accurate Rather than reqUlfe a speCIfic lIst of Improvements, the mItIgatIOn measures should requIre that the proJect be condItIoned to mamtam acceptable levels of serVIce and that the rmprovements necessary may mclude the lIst attached We suspect that some of the Improvements lIsted may not be able to be done today smce the mtersectIOn configuratIOns assumed ill the traffic reports do not even e)Jst today Also, It should be pomted out that the mItIgatIOn measures lIsted apply to all three areas, not Just each mdlvIdual area 3 7 In regards to park acreage requrrements for both Areas F and G, the populatIOn figures to deterrmne park need have been mIscalculated The numbers mcluded ill the ImtIal Study represent dwellmg umts rather than populatIOn Tlus error then affects the quantIty of park acreage reqUIred to servIce the proJected populatIon AddItIonally, for both Areas F and G, the park acreage reqUIrement per capIta has been mIscalculated The ImtIal Study uses the full 5 acres of reqwred park land to proJect local park acreage, whereas 1 5 acres should be used (The other 3 5 acres IS the commumty parks reqUIrement) . A IWlNDOW-l\160l4-1 DOC () () (f) I 3 8 Mr Eddie Peabody, Jr December 6, 1999 Page Thee We have a couple of different concerns regardIng the nOIse sectIOns FIrst, for Area H and G, It IS noted that the plannIng area would be subject to sIgruficant long-term nOIse eAposure, defined as a CNEL of 60 dB fot extenor nOIse However, thIS CNEL standard apphes only to reSIdential development, none of wh.Ich IS proposed to occur In Area H and 10 Area G, only a portion of the overall land plan There are addItIOnal maccurate statements concernmg the extent and level of eXIstmg nOIse Impacts to the proposed projects 3 9 There are no reSIdentIal uses proposed for Area H Hence, all references to InclUsIOnary zonmg and resldenual uses should be eltmmated from thIs document 3 loIn all three Areas, the words "IntermIttent creeks", "creeks" and/or "streams" are used - - There are no "creeks" or "streams," mtermIttent or not, on the property These features are should be referred to as "defmed draInages" or "sv.ales", dependmg upon theu phYSIOlogy Thank you for permIttmg us to reVIew and cormnent upon these documents Our lIst of comments for the three Areas IS attached We beheve that our concerns should be addressed and corrected pnor to the Planmng ComrmsslOn heanng Please contact me If you have any questIOns or comments Very truly yours, C/770/~ MARTIN W INDERBITZEN cc M Porto and A KInney Enclosure A IWINDOV.-1\1603..-1 DOC Letter 4 RECEIVED Ut.L b 1999 DUBLIN PLANNING Below are comments provided by the Lm Team 10 response to theIr review of the DublIn Rancb Areas F, G, and H MItIgated NegatIve DeclaratIOn and ImtIal Study documents . Overall _4 1 1 Much of text IS wntten generally to cover all three proJect areas, but makes mformatIOn confusmg and m many mstances, not appropnate to a specIfic Area Area H 1 Page 3 first paragJ aph second lme The use of the word "vacant' IS wrong WhIle 4 2 It IS true the land IS not developed, agncultural and cattle graz.mg uses contmue on the SIte 2 Page 3 Project DescllptlOn first paragraph Does not mentIOn that a Master 4 3 TentatIve Map IS also mtended to be addressed by thIS ImtIal Study or that of Area F, only a "lot lme adJustment to separate Planmng Area from the balance of Dub 1m Ranch ' 4 4 3 ExhIbIt 3- SIte LocatIOn FIgure number should be 2, not 3 4 5 4 Page 4 Stage 1 Development Plan fil st paragJ aph It IS not necessanly true that that a Stage 2 PD Rezone applIcatIOn Will be filed at the same tIme as the Tentauve Map and SIte Development ReVIew A Stage 2 PD Rezone could be submItted pnor to or With a TentatIve Map and/or Site Development ReVIew applIcatIOn . 5 Page 4 Stage 1 Development Plan foUl th paragraph Internal collector roads are 4 6 only one mstance of provIdmg a roadway system Other potential systems may be proVIded VIa a collector loop, or some other system The final system Will be deterrnmed pnor to the subnuttal oithe mdlvIdual tentatIve map and created only as speCIfic users are found TIns Imtlal Study comment ImplIes that thIs IS the final and only soluuon The word "collector" should be elIrnmated from the te).,1: 6 Page 5 second paragJ aph No housmg IS proposed for Area H, therefore, there 4 7 should be no dISCUSSIOn of mc1usIOnary zomng here TIns paragraph should be deleted 7 Page 5, Assessment DZStllCts second pal agraph, second lme We belIeve "mItIal 4 8 study" should be "assessment dIStnCt" 8 Page 5, Other Entztlements fil st paragraph Although a lot lme adJustment IS noted, 4 9 Master TentatIve Map has not been mcluded as an entItlement as part of thiS applJcatIon/Imtlal Study 9 Page 10, Other publzc agency reqUIred appl ovals last lme We tlnnk "PermIts" 4 10 should be "AuthonzatIOn" or "40 I CertIficatIOn" mstead -- ..- --- . Pa~ 1 A \WINDO\\-J\lSREVE-l DOC f) I) f) 10 Page 10, Project DescnptlOn Agam, Master TentatIve Map IS not noted as bemg part _.:tl! oftlus appbcauon/IrutIal Study 11 Page 11 EnVironmental Facto! s Potentially Affected It IS noted that 'The ~ 4 12 envIronmental factors checked below would be potentIally affected by tius proJ ect, ~ ---- mvolvzng at least one Impact that IS a potentzally sIgnificant rmpact as mdrcated by the checklzst on the followzng pages ' However, no 'potentzally slgnzjicant Impact eXists on tlus checklIst All enVIronmental Impacts are "less than sIgmficant 'Vlth mItIgatIon" or less ThIS statement IS not accurate Rather, It should state that Impacts are potenTIally sIgmficant unless mItIgatIOn IS mcorporated AddItIOnally, tlns page contams no sIgnature or date 4 13 12 Page 15, V Cultural ResoUl ces Refer to Item 27 13 Page 19, XIII PublIc ServIces a) We don t understand the baslS for whIch tillS IS 4 14 checked as "less than sIgmficant WIth mItIgatIOn" ThIs should be "less than - - - sIgmficant Impact" or "no Impact' 14 Page 21 and 22, J..rvI Mandatory Fmdmgs of SIgnificance, a) and b) We questIOn the ' No Impact" ThIs depends on how the Item IS rnterpreted If the Item IS refemng 4 15 to the regIOn, the assessment IS valId If It IS referrmg to Just the proJect sIte the assessment conclUSIOn IS not vahd smce the project proposes to WIpe out everythmg mcludmg JUrIsdICTIOnal wetlands ~ 16_15 Page 23, last paragraph, second lme .A.rea F should be reVIsed to Area H 4 1 7 16 Page 24 ] Aesthetrcs EnvlJ onmental Settmg Refer to Item 1 regardmg 'vacant' 17 Page 24 I AesthetICS, PrOject Impacts and Mltlgatwn Measures a) second lme 4 1 8 The use of the word "former" IS lDaccUfate as the fields are stIll bemg used for agncultural use Refer to Item 1 regardmg "vacant" ] 8 Page 24 I AesthetiCS, Project Impacts and MltzgatlOn MeasUJ es, b), second 4 19 paragraph Where there IS a Statement of Ovemdmg ConSIderatIons, the Impact - remams potentlally sIgruficant and unaVOIdable It Isn't reduced to' less than slgruficant' III succeedmg envlIonmental documents as stated by thIS Item 19 Page 24 ] Aesthetlcs, ProJect Impacts and MztzgatlOn MeasUl es c) 'Where there IS a 4 20 Statement of Overndmg ConSIderatIOns, the Impact remaIns potentIally sIgmficant and unaVOIdable It Isn't reduced to "less than sIgmficant" m succeedmg envlTonrnental documents as stated by thts-Item ~ I> Page :2 1\ \Wl}IDOW~J\ISREVE-l DOC 20 Page 25 ]] AgJ lcultural Resources Envll onmental SellIng, thIrd lIne Same as -..4 ~~J_ above . 4 2221 Page 26 PJ ojec! Impacts and MlllgatLOn Measures, b) Refer to Item 19 above 22 Page 26 flI BlOloglcal Resources EnvIronmental Set/mg, thIrd lme The word _4_1...J. "one" should be replaced With "at lea::rt once" 23 Page 28 Wetlands last sentence Tlus sentence IS not accurate CDFO JurIsdIctIOnal 4 24 habItat does eAlst m Area H Tills occurs m a dJtch, parallelmg the frontage road whIch e),.-tends from the elevated farm TOad to the G-3 channel As a SIde note, we have receIved a venficatlOn letter from the Corps that they have accepted our JUTIsdlctlOnal delIneatIOn for Areas H and F We WIll forward you a courtesy copy shortly 24 Page 28, PI oject Impacts and mItIgatIOn mea5W es ThiS sectIOn Imphes that certam _4 _25_ plant and ammal speCIes are present on SIte when eVIdence has been submJtted to the contraI) Refer to the H T Harvey report 25 Exhlbl/ 5 TItle should be <'JnnsdIctlOnal Areas", not "wetlands" as the map ,>hows aU 4 29_ waters subject to CorpsJUDsdlctIon, not Just wetlands . 26 Page 28, Project Impacts and MltlgatlOn Measures a) There are no CalIfomm nger 4 27 salamanders WItlnn Area G based on all onNsIte surveys underta1..en to date The - --- reference to them needs to be removed AdditIOnally, we are confused about the borrOWIng owl It should be made clear that If owls are not found on the SIte, then a habitat set-asIde IS not reqwred 27 Page 30 Cultural Resources, Enwronmental SettIng, first paragJ aph Based upon 4 28 the FEIR, no potentIaUy sIgmficant archaeologIcal resources have been IdentIfied WItlun !>uea H The IrntIal Study statement IS not accurate here and IS only true for Area F The second paragraph should be deleted completely as tins resurvey dId not occur ill Area H Because oftlns error, ProJect Impacts and MItIgatIOn Measures and the Chec1...hst should be reVIewed and reVised as necessary 28 Page 30 Project Impacts and MmgatlOn Measures, MltlgatlOn MeasUJ e 2 We are 4 2 9 concerned that the verbiage specIfies a 23 acre mItIgatIon SIte In LIvermore We do not belIeve It IS appropnate at tlns tIme to refer to a specIfic SIZe as mItIgatIon amounts Will be dependent upon the outcome of our dISCUSSIons WIth the Corps and other agenCIes The text should be reVIsed to delete the words '<23 acres" 29 Page 31, thl oughout- Why are Areas F and G bemg dlscussed here? Tlus IS the 4 30 IrntIal Study only for Area H _ . Page3 A IW1NDOV,-I\l5REVE-1 DOC (f) 4 31 30 Page 32 jirstfull paragraph second to last lme Delete" rmrumIzmg gradmg on steep slopes" there are no steep slopes WithIn Area H 31 Page 33 VIII Hydrology and Water Quahty EnVIronmental Settmg The followmg 4 32 sentence IS not accurate- "The proJect SIte IS mlly With several mterrmttent creeks flOWing through It" There are no rulls or IntermIttent creeks ill Area H In addIoon, there are no creeks WItlun Areas F or 6 eIther These elements are properly referred to as defmed dramages 32 Page 33, MItIgatIOn Measure 4, secondpwagraph The NPDES verblage needs to 4 33 be revIsed It should say "file a notIce of Intent With the state", not "obtam a notlce from the state' 33 Page 34, e) MztlgatlOn Measure 5 TIns measure requITes that the proJect's "faIr _ 4 34_ share contnbutlOn" for downstream Improvements be documented It should be noted that ACFC Zone 7 has an eAlstmg dramage program for thts purpose and that the project Will pay Zone 7 fees The need to further study or "document" thts Item should removed from the IrutIal Study () 34 Page 34 g) and Page 35, hI) The mItIgatIOn measures and probably the dISCUSSIOn of the flood plam Issues need to be rewntten We have already obtatned a condltIOnal 4 35 letter of map reVISIOn from FEMA m wmch they agree to take the property out of the flood plam once It IS filled to speCIfic elevatIOns Once the fillls done, FEMA WIll take the area out of the flood plam The rmtIgatIOn measure callmg for certIficatIOn pnor to approval of gradmg perrmts IS unclear and we suspect that the IntentIon IS not conSIstent With flood platn processmg We belIeve the "certmcatIon" the ImtJal Study IS refernng to IS a certIficatIOn that the property IS filled wmch FEMA requITes pnor to takmg the property out of the flood plam The rmtIgatlOn measure should reflect FEMA reqwrements and read "ApplIcant shall remove habltable portIOns of the project from the 100 year FEMA flood plam pnor to occupancy perrmts bemg Issued" For your reference, the applIcant has already obtamed a condItIOnal letter of map reVISIOn 35 Page 35, h z) The study concludes that there are no hazards due to dam or levee 4 36 break because the upstream stock pond Will be removed However, there should probably be a comment that ill the event the pond IS not removed, embankments WIll be remforced to elImmate dam fatlure as a potentIal hazard () 36 Page 37, XI NOIse EnVironmental Settmg, second paragraph There are a couple of Issues here One, the Eastern Dublm EIR notes that a "CNEL of 60 dB or less IS 4 37 consIdered normally acceptable for resldentzal d~velopment The paragraph ill the IrutJal Study should be rewntten tOJeflecrtlus as no reSIdentIal uses are proposed m Area H Secondly, the use of sound walls along 1-580 are excluded from occurnng by Page 4 A IWINDO\\-JUSREVE-l DOC the City s Eastern Dublm Scemc Comdor PolICIes and Standards TIus sentence should also be revIsed . 37 Page 38, Project Impacts and MItIgatIon Measures a) The study lIsts fire spnnklers 4 38 as an element of the project We suspect that there are portIOns of the project that - may not be requrred to have spnnklers and, If so, tlns comment should be removed 38 Page 43 There IS no table present on Page 43, Table 2 Companson ofTnp 4 39 GeneratIOn We assume tlns was for the table on Page 47 and 47 5 'Why are Area F and G compansons Included here? 39 Page 44, MltlgatlOn Measw e 7 and Page 46 MltlgatlOn Measw e 8 The study mcludes numerous traffic rmtIgatIOns that are very specIfic and we assume are taken 4 40 from the Areas F, G, and H traffic report dIrectly It should be pOInted out that mItIgatIOn measures taken from the traffic report assume a long lIst of developments and Improvements havmg occurred m the area before thIS proJect comes on lme TIus long lIst of assumptIOns IS hIghly speculatIve and mayor may not be accurate Rather than reqUITe a specIfic lIst of Improvements, the mItIgatIOn measure should requITe that the proJect be conditIOned to mamtmn acceptable levels of serVIce and that the lIst of Improvements mav mclude the lIst attached We suspect that some of the Improvements necessary may not be able to be done today smce the mtersectIOn configuratIons assumed m the traffic reports do not even eXIst today . Also, It should be noted that the mItIgatIOn measures lIsted apply to all of Dublm Ranch Areas F, G, and H, not JUst each mdIvIdual Area TIus should be pomted out m the IrntIal Study 4 41 40 Page 46, d) second lme and g) first lme SubstItute Area H for Area F 4 42 41 Page 46 e) No new reSidences are planned m Area H Area G 4 43 1 Refer to comments on Area H 4 44 2 Page 2, second to last lme Refer to Area H concermng use of the word 'vacant" 4 45 3 Page 3, Specific Plan/General Plan Amendment first paragJ aph TIus paragraph IS mcorrect, smce there are no MedIum HIgh DenSIty ReSIdentIal, Open Space, MIddle School and Elementary School deSIgnatIOns sho\YD for the Area G m the current SpeCIfic Plan Table 1 pomts tlns out . Page ~ A \WINDOV.-IIlSREVE-IDOC f) A.-A ~ 4 Page 4 sIxth paragraph first sentence ThIs sentence IS not clear and It appears somethmg IS rmssmg 4 47 5 Page 9 ExhibIt 4 It IS unclear wIDch area IS Area G 4__48 6 Page 10 7 Zomng TIns appears to be the zonmg for Area F not Area G 4 49 7 Page II, EnVIronmental Factors Potentzally Affected It IS noted that 'The envlfonmental factors checked below would be potentIally affected by tlns proJect, mvolvmg at least one Impact that IS a potentzally szgmficant mlpact as mdlcated by the checkhst on the followmg pages" However, no potentzally szgmficant zmpact" eXIsts on tlns checklIst All environmental Impacts are less than sIgrnficant WIth mItIgatIOn" or less TIns statement IS not accurate Rather, It should state that Impacts are potentIally sIgrnficant unless rmtIgatIOn IS mcorporated 8 4 50 Page 24 P, oJect Impacts and Mztzgallon c) Where there IS a Statement of Ovemdmg ConsIderatIOns, the Impact remams potentIally sIgmficant and unaVOIdable It Isn't reduced to "less than slgmficant" In succeedrng enVIronmental documents as stated by tlns Item 4 51 9 Page 26 e) Refer to above concernmg Statement of Ovemdmg Consl.deratIOns f) 10 Page 26, IV BIOlogIcal Resources Envzronmental Settmg fil st pal agJ aph, second to 4 52 last lme "fallow" ImplIes abandonment It should be made clear that tlns land IS dIsced for weed control, grazed, etc E:x.change the word" one" for" at least once" 4 5 3 II Page 26 IV BlOlogzcal Resources, EnVIronmental Settmg second paragJ aph second lme Delete the word "draft" 4 54 12 Page 27, second paragraph, first lme Add "ponded areas and" ill front of "wetlands" 13 Page 27 second paragJ aph second lme After the second "Area G" add "contamed 4 5 5 small Isolated areas of short term pondmg along the access road, bIsectmg Area G (and t\.rea H) and these ponded areas" 14 Page 31, Dramage fil st paragraph, fil st and second lme There are no mtermlttent 4 56 streams on the property These are gentle swales Streams are conSIdered to be jUTIsdIctIOnal 15 Page 32 VIII Hydrology and Water Quahty Envzronmental Settmg fil st lme Refer · 4 57 to Item 14 above concermng the word "stream" ([) - - 16 Page 33 Project Impacts and Mmgatzon Measures b) We don't understand tlns 4 58 ratIOnale As noted ill our vanous hydrology and Corps permIt reports that because of Page-6 A.\WINDOW-l\lSREVE-l DOC the clay sOli type found on SIte there IS lIttle, If any recharge of groundwater The dense clay layer near the surface prevents downward movement of water . 4 59 17 Page 33, PI oject Impacts and MltzgatlOn Measures c) first pm agraph Refer to - --- Item 14 above concernmg streams i ~O 18 Page 34, c) fzflh lzne Refer to Item 14 above concermng streams I 4 61 19 Page 35 h z) The diSCUSSIOn does not answer the questIOn 4 62 20 Page 35, IX Land Use Planml1g last lzne of page 240 dwellillgs should be revIsed to 275 dwellillgs 21 Page 36 XI NOIse, Envll onmental Settzng second paragraph Refer to Area H, Item 4 63 36 concermng non-resIdentIal nOIse standards - 4 64 22 Page 36, XI NOIse EnVIronmental Settzng thl1dpaJaglGph Tlns statement IS maccurate and should be revIsed FIrst, It does not separate nOIse eAposure/levels by land use type and secondly, It mfers that the proJected nOIse level WIthm all of Area G IS at 65 dB Tlns IS not true, only a very small portlOn of Area G has an overlay dB of 65 WIth the rest of the Area beIng less than 65 dB AddItIOnally, thts paragraph does not add the illsclanner mcluded m Area H, bemg that foreground bUlldrngs, walls, etc Will attenuate and reduce much of the ex1:enor nOIse before It reaches Area G Tlus statement has more beaTIng on thts Area than ill Area H as It IS a greater dtstance from the freeway Fmally, the text needs to be revIsed to cIani)' that Areas G and F are not Impacted by nOIse generated by TassaJara Road . 23 Page 37, XlI PopulatIOn and Houszng Project Impacts and MltzgatlOn Measures a) 4 65 mnth lzne The total populatIOn number of Area G should be 2,808, not the 1,404 number lIsted, wInch IS the dwellmg count Two lrnes later a figure of 2,084 IS lIsted for the approved Planrnng Area G plan Ifthts IS the East Dublm SpeCIfic Plan (EDSP) populatIOn, thts number IS an error The EDSP permIts 818 dwellmgs wluch works out to 1636 reSIdents Iftlns 2,084 figure IS not the EDSP populatlOn for Area G, addItIonal eAplanatIOn needs to be proVIded? The subsequent analYSIS WIll need to be revIsed Area F populatIOn should be mcluded m thts dISCUSSIon as land uses and denSItIes have been re-allocated between the two areas and would help to present a clearer pIcture of the overall unItS and populatlOn antICIpated between the EDSP and our proposal - 4 66 l 24 Page 40 paragraph b) thIrd lzne The number 1,404 should be reVIsed to 2 808 (refer to Item 19 above) The total park. acreage of 702 acres noted on Lme 5, whIch calculates the acreage requlIed for local parks, IS rncorrect FITst, It uses the wrong populatIOn figure Second, It usesjhe standard of 5 acres per 1000 reSIdents Per current CIty standards, local parks are only 1 5 acres of the total, With commuruty . Page,1 A IWINDOV,-l\lSREVE-1 DOC t) parks making up the remamIng 3 5 acres per 1,000 populatIOn Hence, the 7 02 acre figure should be revIsed to 4 2 acres for local parks AddItIOnally, tlns Will affect the overall Area F and G park acreage total, wruch should be reVIsed to 6 7 acres mstead of the eXlstmg 15 3 acres Because of thIS acreage dIfference, the findmgs of thIs paragraph need to be reVIsed to state that the amended Area G plan prOVIdes an addITIonal 5 0 acres of local park. land than IS reqmred and when, combmed WIth Area F, an excess of 10 I local park acres are prOVided 4 ~_7 25 Page 46 throughout ReVIse the four "Area F" to "Area G' :\.rea F 4 68 I Refer to comments on Areas H and G 14 69 2 --- ., .J 4 70 I () -I 4 71 Page 3, second lme Refer to Area H concermng the word "creek" Page 3 p, oject Descnpnon, Specific Plan/Genel al Plan Amendment second paragraph The first lIne should be reVIsed to read all of the MedIUm HIgh DenSIty, not a pOl tlOn as noted Page 4 Table 1 Land Use acreages where not updated as submItted on EDGP/SPA ExhIbIt as proVIded by MacKay & Somps and mcluded m the ImtIal Study Acreages that are not correct are Medtum DenSIty ReSIdentIal (68 9), PublIc/Serm-PublIc (3 9), and Open Space (28) and the umts of Medtum DenSIty ReSIdentIal (689) 5 Page 4, first parag1 aph of page ThIs paragraph IS not really true All north-south 4 72 streets shown m our land plans are Illustrated In the EDSP Land Use Map It IS only the mtent of the central north-south street that has been adJusted by our proposal AddItIOnally, these streets do not go through Area H as stated 4 73 6 Page 5 Assessment DIStllcts first paragraph Need to add Area F m additIOn to or mstead of the Area Gs 4 74 7 Page 6 second parag1 aph Agam, there IS no dISCUSSion of a Master TentatIve Map beIng mcluded under tlns IrutIal Study AdditIonally, the lot lme adJustment that IS noted does not mclude Parcel 0 by reference 4 75 8 Page 11, 1 Project DescnptIOn See above (f) 9 Page 11 6 General Plan deslgnatlOns Middle School, Elementary School, 4 76 NeIghborhood Park, NeIghborhood Square, PublIc and SemI-PublIc are not zomng Page g A IWINDOW-IIISREVE-I DOC dIStncts If tlus remmns, the MIddle School should be revIsed to HIgh School as thIS IS what IS Illustrated ill the GP and EDSP . 10 Page 12 first paragraph It IS noted that "The envlfonmental factors checked below would be potentIally affected by tlus proJect, mvolvmg at least one Impact that IS a - 4 77_ "potentzally szgnificant Impact as mdlcated by the checklzst on the followmg pages ' However, no "potentzally significant Impact' e:>"lsts on tlus checklIst All enVIronmental Impacts are ' less than slgmficant WIth rmtIgatlOn" or less ThIs statement IS mIsleadIng and erroneous Rather, It should state that Impacts are potentIally sIgmficant unless mItIgatIOn IS mcorporated 4 78 11 Page 25 Project Impacts and Mltzgatlon A1easw es, c) Where there IS a Statement of Overndmg ConSIderatIOns, the Impact remams potentIally sIgmficant and unavOIdable It Isn't reduced to "less than sIgmficant" ill succeedIng envlIonmental documents as stated by tlus Item 4 79 12 Page 27 b) second paragraph Refer to Item 11 above concerrung Statement of Ovemdmg ConSIderatIOns 4 80 13 Page 27, d e) Refer to Item 11 above concerrung Statement of Ovemdmg ConSIderaTIons 14 Page 27 fl/ BIOlogIcal Resow ces EnVIronmental Settmg fi! st paragraph second to I 4 81 last lme Exchange the word" one" for" at least once" . 15 Page 31 (lll) last sentence The reference to "a IDlllimum buffer of 300 feet along 4 82 the stream m the northern dramage" to be preserved for red-legged frogs should be - replaced With "appropnate buffers along the dramage wIll be preserved" ThIs IS because the speCIfic dImenSIOn \\'111 be dependent upon the outcome of our dISCUSSIOns With the Corps and other agenCIes and It has not been set at tlus tIme "Stream" should be replaced WIth "tnbutary dramage" to accurately descnbe thIS feature 4 83 16 Page 32 MItigatIOn Measwe 3 (1) sentence begmnmg at end oflmefour Tills sentence descnbes the proposed rmtIgatlOn configuratIOn, yet says" Will be filled and later recreated " (specIfic te>..1 m lIne SI:>") TIns ImplIes that our proposed mItIgatIOn IS the eXIstIng condItIOn to be filled and recreated 'FIlled and later recreated near ItS former locatIOn" should be changed to "created" to clarIfy that these are the measurements for the constructed feature, and not the JUrISdIctIOnal area AddItIOnally, m the tlnrd to last lme of the paragraph, the word "m-kInd" IS used We have not proposed rrntIgatIOn to be "m-lond," but have proposed mItIgatIOn to be proVIded by seasonally ponded areas . Page-.9 A \WINDOW-l\JSREVE-1 DOC t) 4 84 17 Page 32 MItIgatIOn Measure 3 (ll) second and thIrd line See above AddltlOnaIly, we are confused as to what thIS IS saymg we are offenng for mItIgatIOn Refer to the H T Harvey report 4 85 18 Page 35, first and fifth parag1 aph of page The IrutIal Study text reads "The prelImmary geotechrucal report mdIcates a Instory of landslIdes on the SIte" However, the Berlogar report teA1 referenced by tills statement reads "Some of the swales on the SIte show eVIdence ofprevlOus landslIdIng" TIns IS doesn't mdIcate an extensIve Instory of landslIdes across the SIte The ImtIal Study text should be rewntten to more accurately reflect the eXlstmg COndITIOnS 4 86 19 Page 35, Drainage, second line "Stream" should be reVIsed to "defined drmnage" 20 Page 3 7 throughout As noted prevlOusly In tills Area and other Areas, no 4 87 IntermIttent creeks or streams are located on SIte, only defined dramages ImtIal Study teAt should be reVIsed accordmgly 21 Page 39 IX Land Use and Planmng, P, oJect Impacts and MItIgatIOn MeasUl es, (b) 4 88 first paragraph The last sentence doesn't make sense Please adVIse the meamng of -- - " changes to CrrculatIon Element " () 22 Page 39 IX Land Use and Planmng Project Impacts and MltlgatlOn Measures (b) 4 89 second pal ag1 aph As m Area G, the 240 dwellIngs should be changed to 275 23 Page 40 Xl NOIse EnVIronmental Settmg second paragraph There are a few Issues of concern here One, the EIR Future NOIse Contours Map shows the 60 dB lIne as 4 90 bordenng Area F (I e the lIne parallels Central Parkway) The sentence m the ImtIal Study IS In error by stanng that "mmor portIOns of Area F would be subJect to sIgmficant long-term nOIse eAposure when m fact It IS not Secondly, TassaJara Road IS not a nOIse source affectIng Area F per the EIR Future NOIse Contours Map smce the nOIse contours are not even close to Area F Lastly, thIs paragraph does not add the dIsclarrner mcluded m Area H, that foreground bwldmgs, walls, etc wIll attenuate and reduce much of the extenor nOIse before It reaches Area F TIns statement has more beanng m thIs Area as It IS a greater dIstance from nOIse generators TIns entIre paragraph should be rewntten to mcorporate these Items 24 Page 41 XlI PopulatIOn and HOUSing Project Impacts and MItIgatIon MeasUl es a) 4 91 lines 9 and 11 Because the most current dwellmg urut totals were not used m Table 1, these populatlOn figures are slIghtly off Instead of 1 677 for an amended populanon, the figure should be 1,669 Instead of 1,091 for the e:>..1snng GP/SP A, the number should be 1,092 (() 25 Page 43, XIV RecreatIOn P, oJect jmpacts and MItIgatIOn Measures a) first _ - paragraph first sentence TIus sentence does not take mto account that for Just Area 4 92 F, our amended plan proposes a lower populatlOn figure than the e:>..1stmg EDSP plan Page 10 A.\WINDOW-l\lSREVE-l DOC does (1 e 1,669 people vs 2297 people) Only If both Area F and Area G are 10oI-.ed . at together does the amended populatIOn figure exceed the eXlstmg GPIEDSP populatIOn figure 26 Page 43, XIV RecreatIOn P, oJect Impacts and MmgaflOn Measures b), second lme 4 93 Agam, the populatIOn figure should be 1,669 and not 1,677 26 Page 44 first paragraph ThIS paragraph IS supposed to be dISCUSSIng the Area F neIghborhood park dedIcatIOn requuements However, the figure noted IS for all 4 94 (cornrnuruty and local) park acreage Neighborhood park acreage reqwrements for Area F are 2 5 acres, not the 8 3 noted Because of tlns error and the problems already noted m Area G, the second to the last sentence needs to be rewrItten to say that the overall Area F and G nelghborhood/local park reqUIrement IS 6 7 acres whIle the Area plans proVide a total of 16 8 acres TIns creates an excess of 10 1 acres of neIghborhood/local parI-. proVided by the amended plan than IS reqUIred to be dedIcated 4 95 27 Page 51, e) Wastewater disposal IS not dIscussed here ~ . ~ Page 11 A \WlNDOW-I\lSREVE-J.DOC () f) () REGIONAL JPARKS Iii ~~ EAST BAY REGDOINlAIL PAIRI:( DBS1'IRBCT December 7, 1999 BO~RD OF DIR CTORS Be' erl} Lane Prec:.loent Ware 0 C~ "I Se, f'fln VICP Preslden \\arc 3 JOl'1 SU e Treac;urer \'\ara? Letter 5 RECEIVED DEe 1 3 1999 DUBLIN PLANNING Mr Jerry Haag Commumty Development Department CIty of Dub 1m POBox 2340 Dublm, CA 94568 ..hn IVIes a-a Se re arl \\a 0 5 Subject Comments on MItigated NegatIve Declarations for Dublm Ranch Areas F, G 8.. H PA-98-068, -069 and -070, TassaJara Creek RegIOnal TraIl iec rladl.e \\ard I Daua SlOan \\~rd Je31 Sill '" aro 1 The East Bay RegIOnal Park DIStrIct (DIStrIct) has reVIewed the proposed MItigated Negative Declarations (MND) for the proposed Dubhn Ranch Developments, Areas F, G and H m Dublm ~~T~IB:~e:Ooe' are submIttIng wntten comments on the subJect proposal as part of our on-gomg mterest m completmg the TassaJara Creek RegIOnal TraIl, and m protecting TassaJara Creek and the unportant natural resources of the East Dublm area Dear Mr Haag The DIStrIct has for the past 65 years promoted the conservanon of open space and~ protectIon of unportant natural resources In the East Bay DIStrIct staff have partICIpated m a vanety ofpubhc plannmg Issues m the CIty of DublIn where we have promoted these mterests, mcludmg the CIty s East Dublm General Plan and SpecIfic Plan, and subsequent development proposals along TassaJara Creek, mcludmg the Casters on and Greenbnar Homes developments In our comments on the Greenbnar Homes development proposal, we raIsed several concerns about the adequacy of the East Dublm SpecIfic Plan (EDSP) EnVIronmental Impact Report (EIR) to address project unpacts to TassaJara Creek and the Federally-threatened CahfoIDIa red-legged frog m hght of SIgnIficant new mformatlOn that has been documented smce the EDSP ErR was CertIfied m 1993 We also stated that the proposed MND for Greenbnar Homes would be madequate for our CEQA complIance purposes (as a responSIble agency) should the DIstnct assume management responSIbIlIty for portIons of the TassaJara Creek RegIOnal TraIl whIch are constructed as a reqUIred element of the Greenbnar Homes development To the extent that development proJects m the East Dubhn area eIther dIrectly affect the TassaJara Creek. Corndor m whIch the regIOnal traIl IS located, or propose off-SIte mItigation wIthm that corndor, It IS a concern of the DIStrICt that unpacts on the corndor are envIronmentally acceptable to the State and federal resource agenCIes, and to the Distnct 5 1 Impacts to DIStrICt Propertv 'The subJect MND contams a report prepared by H T Harvey 8.. ASSOCIates entItled 'Dublm Ranch Areas F, G and H EcolOgIcal Impacts and MItIgation' Page 33 oftlns report IdentIfies TassaJara Creek. as the proposed location to mItIgate for Dublm Ranch proJect unpacts to 'CDFG JunsdIctIonal areas and red-legged frog habItat" by preservmg, eEhancmg and restonng a 5200 foot sectIon of TassaJara Creek to the north of the proposed Greenbnar Homes Development We are concerned because a large portIon of thIS proposed mItIgatIon SIte IS already owned by the DIStrIct and consequently would not be avaIlable for use as a mItigation SIte for the Dublm Ranch Development 2950 Peralta Oaks Court PO Sox 5381 Oakland CA 94605 0381 www ebparks Drg IC'il T l 510635 0135 TDD 510633 0460 ~ FAX 5105694319 FIgure 5 of the H T Harvey Report depIcts the proposed locatIOns for these mItIgatIOn measures along TassJara Creek, yet It does not contam any property boundanes whIch would show precIsely where . these mItIgatIOn SItes are located or who owns the underlymg land Usmg thIS eXIStIng figure, we have attempted to overlay eXIstIng DIStnCt land ownershIp mformatIOn m thIS map and have dIscovered that approXImately one-half of the west bam. of the TassaJara Creek mItIgatIon SIte may already be owned by the DIStnCt as pubhc open space and as a regIOnal traIl Furthermore, at least one entIre and two partIal proposed restoratIOn SItes may be contamed wlthm DIStrIct lands Smce thIs proJect WIll result m sIgmficant Impacts to wetlands and red-legged frog habItat and because the MND proposes use of TassaJara Creek as the mItIgation SIte, It IS ImperatIve that the MND contam adequate mformatIon on property ownershIp and assurances that the proposed mItIgatIon SItes are actually avaIlable for use by the apphcant to mItIgate for proJect Impacts Absent such mformatIon, the MND cannot adequately demonstrate that potentIally sIgmficant Impacts can and WIll be mItigated to a less-than-sIgnIficant level I have enclosed two maps showmg our property ownershIp m thIS area CumulatIve Impacts to Tassalara Creek and SpeCIal-Status SpeCIes The DIStnCt, CIty of Dub 1m, Greenbnar Homes, US FIsh and WIldhfe SerVIce (USFWS) and 5 2 CalIfornIa Department ofFIsh and Game (CDFG) are currently seekIng to resolve confhcts between the proposed Greenbnar Homes Development, mcludmg a segment of the TassaJara Creek RegIOnal TraIl, and the speCIes conservation and mItigatIon reqUIrements for proJect unpacts to red-legged frog and TassaJara Creek It IS hkely that resolutIon of thIS complex Issue WIll take several months and WIll reqUIre maJor reVISIOns to Greenbnar Homes Development proposals and to subsequent development proposals that affect TassaJara Creek or speCIal-status speCIes m the East Dublm area The proposed DublIn Ranch MND IdentIfies potentIally sIgmficant Impacts to two speCIal-status plants, CahfoTIlla tIger salamander, red-legged frogs, burrowmg owls, badgers and nestIng raptors . Many of these potentIal Impacts were not properly addressed m the EDSP Fmal EIR or the speCIes were not known to be present m the proJect area at the time the Fmal EIR was certIfied The CIty may WIsh to postpone conSIderatIon of new developments m the East DublIn area that unpact speCIal-status _ speCIes untIl such tIme as confhcts between development and speCIes conservatIOn have been resolved m some regIOnal fasmon ThIS would lIkely reqUIre reVlSlons to the East Dubhn SpeCIfic Plan and Fmal EIR, and as recommended by USFWS, the preparatIon of a muln-specles habItat conservanon plan that addresses the mdn ldual and cumulanve effects to speCIal-status speCIes ThIS approach IS bemg conSIdered by the CIties of LIvermore, Clayton, Plttsburg, AntIoch and Brentwood through mdlvldual and regIOnal habItat conservatIon plannmg efforts Please call me at (510) 544-2622 should you have any questIons about thIS comment letter or Steve FIala at (510) 544-2602 for any speCIfic questIons about TassaJara Creek RegIOnal TraIl Smcerely, ;kf ril!t~'\ Brad Olson EnvlTonmental SpecIahst attachments (2) Denms Camngton, CIty of Dublm Planmng-Department Jamce Gan/Scott WIlson, CalIfornIa Department ofFIsh and Game Curt McCasland, US FIsh and WIldlIfe ServIce cc . 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OJ in ><~ aIDID ~~ <(0 W n.~ > L.- w.... r ~ ~ ~ 0 - -I I I o 4 )'" , , ~ I I I I I n ~ -0 G 5J .(J a /~ (() (() 6 1 C() State of California The Resources Agency DEPARTMENT OF FISH AND GAME http / /wwwdfg ca gov POST OFFICE BOX 47 YOUNTVILLE CALIFORNIA 94599 (707) 944-5500 GRA) DAVIS Governor December 8,1999 ~ RECEIVED DEG 1 3 19991 DUBL.IN pbA,NNlNQi Mr Denn1S Carr1ngton C1ty of Dubl1n Plann1ng Department Post Off1ce Box 2340 Dubl1n, Cal1forn1a 94568 lLetter 6 Dear Mr Carr1ngton Dubl1n Ranch Res1dent1al Development Plann1ng Appl1cat1on Numbers, Area F PA 98-068, Area G PA 98-069, Area H PA 98-070 M1t1gated Negat1ve Declarat10n C1ty of Dubl1n, Alameda County Department of F1Sh and Game personnel have rev1ewed the subJect documents Th1S proJect 1S part of a four-phase development known as Dubl1n Ranch Phase One has already been perm1tted and 1S under construct1on Negat1ve Declarat10ns have been subm1tted for the rema1n1ng 305 acres Wh1Ch have been d1v1ded 1nto three Plann1ng Areas,- F, G, and H Area F 1S 147 acres It 11es south of Phase One and 1mmed1ately north of ~reas G (87 acres), and H (71 acres) These comments address development of these three plann1ng areas of the Dubl1n Ranch The proposed proJect lles w1th1D the Eastern Dubl1n Spec1f1c Plan Area A program-level Env1ronmental Impact Report (EIR) was prepared for th1S plann1ng area 1n 1992 and a F1nal EIR (FEIR) was adopted 1n 1993 Tne In1t1a1 Study Checkl1st was prepared to determ1ne whether there are potent1al slgn1f1cant slte-spec1f1c env1ronmental lmpacts not examlned In the FEIR and whether proJect-spec1f1c m1t1gat1on measures would reduce the level of lmpacts to a p01nt where a M1t1gated Negat1ve Declarat10n would be adequate to meet Cal1forn1a Env1ronmental Qual1ty Act (CEQA) requ1rements Based on substantlal new 1nformatlon, 1nclud1ng spec1es 11st1ng and cumulat1ve 1mpacts, the Department does not bel1eve that the FEIR for the Dubl1n Spec1f1c ~rea Plan fully d1scussed speCles occurrences or establ1shed appropr1ate m1t1gat1on for these spec1es The DUDl1n Ranch proJects 1nvolve 1mpacts to spec1es not covered or not adequately addressed 1n the FEIR The FEIR, therefore, should not be referenced as adequate under CEQA for d1sclosure or prov1d1ng m1t1gat1on for these spec1es C/.)~~ C~'()~1~1, W>>~1;, ~ 1~/O Mr Dennls Carrlngton December 8, 1999 Page Two ~ The determlnatlon In the Inltlal Study page 12 states 6 2 "although the proposed proJect could have slgnlflcant effect on -----the envlronment there wlII not be a slgnlflcant effect In thls case because the mltlgatlon measure have been added to the proJect" It lS the Department's oplnlon that mltlgatlon measures proposed for thls proJect wlII not reduce the effects or mltlgate the effects to a pOlnt where clearly no slgnlflcant effect on the enVlronment would occur as requlred by CEQA Page 52 of the Inltlal Study for PA F states that the proJect wlll not "reduce the number or restrlct the range of a rare, endangered plant or anlmal" However, page 29 states that lmpacts to Callfornla red-legged frog (Rana aurora drayton~~) and Callfornla tlger salamander (Ambystoma cal~forn~ense) wlII result from the proJect In addltlon, the Department dlsagrees wlth thls determlnatlon due to potentlal lmpacts to klt fox Therefore, due to the fact that the constructlon of thls proJect wlII reduce the number and restrlct the range of an endangered, rare, or threatened specles, a mandatory flndlng of slgnlflcarrce must be made . Callfornla Red-legged Frog 6 3 It lS the oplnlon of the Department that constructlon of thlS proJect wlll result In fragmentatlon of habltat and blocklng of movement corrldors of the Callfornla red-legged frog and that the mltlgatlDn as proposed lS not adequate to reduce the lmpacts to a level that lS less than slgnlflcant Accordlng to the Inltlal Study PA F, red-legged frogs have been documented In the pond on Area F of the slte, wlthln 3/4 mlle to the north, and wlthln 1/2 mlle to the east The appllcant states no frogs were detected to the south or west of the slte and, therefore, the development of the slte lS not expected to provlde a barrler to dlspersal of Callfornla red- legged frogs The appllcant also states that areas of the slte other than the stock pond are llkely not of substantlal lmportance to thls specles 6 4 The Department does not agree wlth thls flndlng and belleves that lmpacts to red-legged frogs have been underestlmated Recent research has shown that red-legged frogs frequently utlllze upland habltat adJacent !o water fea~ures Regular movement of red-legged frogs have-been documented between 200-300 feet from the edge of the creek, however, several frogs In one . ~ ~ ~~ I ~ Mr Denn1s Carr1ngton December 8, 1999 Page Three study were documented mov1ng over one and one-half m1les dur1ng d1spersal In add1t10n, the February 1999 observat10n of a red- legged frog 1n TassaJara Creek to the west of the proJect s1te conf1rms red-legged frogs OccupY1ng hab1tats to the west, north, and east of the proJect s1te Therefore, the proposed development w111 1mpact d1spersal, breed1ng, and forag1ng hab1tat of the red-legged frog 6 5 Areas along TassaJara Creek are 1dent1f1ed as the proposed locat10n to m1t1gate for Dub11n Ranch proJect 1mpact to the Department's Jur1sd1ct10nal areas and red-legged frog hab1tat The preservat10n, enhancement, and restorat10n of a 5200-foot sect10n of TassaJara Creek to the north of the proposed Greenbr1ar Homes Development 1S d1scussed The Department bel1eves that some of th1s area 1S owned by the East Bay Reg10nal Park D1str1ct The ava1lab111ty of th1s area as a m1t1gat10n s1te 1S quest10nable and therefore 1S not 11kely to prov1de adequate ffilt1gat10n for 1mpacts to red-legged frogs The Department recommends that the Un1ted States F1sh and~W1ldl1fe SerV1ce (USFWS) be consulted regard1ng the adequacy of the proposed m1t1gat10n Surveys and m1t1gat10n measures for red legged-frogs should _ follow establ1shed USFWS and Department gU1del1nes The Department recommends that measures be lmplemented to av01d rea- legged frog hab1tat w1th1n the proJect area Cal1forn1a T1ger Salamander 6 7 In the October 25, 1999, report by H T Harvey, Ecolog1cal Impacts and M1t1gat10n, page 18, 1t states that the maJor1ty 0= Cal1forn1a t1ger salamander (CTS) (Ambystoma cal~forn~ense) use occurred 1n Area F M1t1gat10n Measure 2(11} states that m1t1gat10n for 1mpacts to est1vat10n hab1tat w1ll be commensurate w1th 1mpacts on Area F only The Department does not agree w1th th1s f1nd1ng Because there 1S documentat10n that CTS move long d1stances between breed1ng hab1tats and est1vat10n s1tes, effects of development should be cons1dered from the perspect1ve of fragmentat10n of hab1tat and block1ng of movement corr1dors Recent research conducted by Peter Trenham for complet10n of h1s doctorate requ1rements at U C DaV1S document CTS movements up to 670 meters from breed1ng ponds --In add1t10n, data-collected at the Byron a1rport showed between 5 percent to 10 percent of the Mr Denn1s Carr1ngton December 8, 1999 Page Four . populat1on was mov1ng up to 500 meters Based on th1S data, the Department cons1ders Areas F, G, and H to be potent1al hab1tat and recommends that measures be 1mplemented to avo1d and m1n1m1ze 1mpacts to CTS that result through loss and mod1f1cat1on of est1vat1ng hab1tat 1n these areas Unavo1dable 1mpacts may be m1t1gated both by 1) 1mplement1ng a relocat1on program approved by the Department to m1n1m1ze "take" and, 2) develop1ng and 1mplement1ng a Mltlgatlon Agreement acceptable to the Department to compensate for the loss of CTS habltat Compensat1on for the loss of hab1tat must address the loss of the ent1re breed1ng and est1vat1ng hab1tat of the CTS populat1on, Slnce slgn1f1cant d1srupt1on of the aest1vat1ng hab1tat w1ll llkely result 1n the 1nab1l1ty to susta1n the ent1re populat1on locally The M1t1gat1on ~greement must preserve eX1st1ng occup1ed hab1tat of CTS at a slte acceptable to the Department M1t1gat1on hab1tat should be prov1ded at a m1n1mum 1 1 compensat1on rat10 for both est1vat1on and breed~ng hab1tat Implementat10n of a relocat1on program for CTS cannot be conducted unt1l a M1t1gat1on Agreement 1S slgned by the Department Due to the potent1al that th1S spec1es w1ll be Ilsted by the USFWS pr10r to the construct1on of the proJect, we recommend that the USFWS be consulted regardlng potent1al perm1t requ1rements . San Joaquln Klt Fox The In1t1al Study PA F states on pages 15 and 28 that the 6 8 San Joaquln k1t fox (Vulpes macrot~s mut~ca) 1S presumed absent from the slte The Department does not concur wlth these f1nd1ngs The area 1S In the western range of the k1t fox and sUltable dennlng and foraglng hab1tat eXlsts on the proJect slte The document states that only the f1rst phase of surveys were conducted 1n 1997 followed by reconna1ssance level surveys In th1S area, because k1t foxes occur 1n low numbers and the detect10n rate 1S low even 1n areas where they are known to be denn1ng, negat1ve f1nd1ngs based on the survey methods employed are not acceptable Close consultat1on w1th the Department and the USFWS w1ll be needed to assure compl1ance w1th the State and Federal Endangered Spec1es Acts Loss of hab1tat ~s con~ldered a tak1ng under these Acts and w1ll requ1re permlts from both agenc1es Currently, . ID1tlgat1on standards for permanent loss of hab1tat requ1re ~ Mr Denn1s Carr1ngton December 8, 1999 Page F1ve ,6 9 t) 6 10 f) compensatory preservat10n of hab1tat at a 3 1 rat10 Informat1on on what lands would be acqu1red or otherw1se preserved as m1t1gat1on should be prov1ded Lands Wh1Ch are ded1cated to a publ1C agency should 1nclude a permanent fund to cover the costs of ma1ntenance for the Ilfe of the proJect The Department recommends focus1ng m1t1gat1on to create a small number of larger preserves 1n h1gh value hab1tat w1th 1nterconnect1ng corr1dors for the k1t fox Burrow1ng Owl M1t1gat1on Measure 2 (lV), page 31, descr1bes proposed m1t1gat1on for 1mpacts to burrow1ng owl (Athene cun~cular~a) The Department cons1ders the proposed m1t1gat1on to be 1nadequate Surveys accord1ng to establ1shed Department protocol should be conducted on the ent1re proJect slte and w1th1n a SOD-foot zone around the proJect slte dur1ng the nest1ng and non-nest1ng seasons Buffers should be establ1shed around occup1ed burrows at all t1mes of the year, not only dur1ng the breed1ng season D1sturbance of burrows used by owl pa1rs or slngle b1rds dur1ng the nest1ng or non-nest1ng season should be m1t1gated by the complet1on of a M1t1gat1on Agreement w1th the Department and the acqu1s1t1on and conservat1on of 6 S acres of sU1table owl hab1ta! per owl pa1r or slngle b1rd 1n a 10cat1on acceptable to the Department Eucalyptus Trees The Department lS opposed to the removal of the eucalyptus trees along the southern edge of the slte As stated on page 28 of the In1t1al Study PA F, these trees prov1de potent1ally sU1table nest1ng sltes for loggerhead shr1ke (Lan~us ludov~c~anus), wh1te-ta1led k1te (Elanus caeruleus), and other tree-nest1ng raptors Wh1Ch are protected under the M1gratory B1rd Treaty Act and have been observed on the proJect slte Golden Eagles (Aqu~la chrysaetos) are also known to breed locally Due to the scarc1ty of nest1ng sltes 1n the area, the proposed act10n lS cons1dered by the Department to be slgn1f1cant 1f not m1t1gated Removal of these trees w1ll result 1n a slgn1f1cant temporal loss of potent1al nest1ng hab1tat and permanent loss 1f m1t1gat1on lS not 1ncorporated If 1t lS not poss1ble to avo1d tree removal, the Department recommends plant1ng of large trees 1n an area preserved 1n perpetu1ty as-open-space and otherw1se sU1table for nest1ng Any-free removal and replant1ng program should be fully descr1bed 1n a M1t1ga~10n and Mon1tor1ng Plan Mr Denn1s Carr1ngton December 8, 1999 Page SlX . that would d1SCUSS the spec1es to be planted, locat1on, ma1ntenance, mon1tor1ng, success cr1ter1a and secur1ty lssues The plan would need to be acceptable to the Department Based on locat1on and the abundance of grassland hab1tat, 1t lS 11kely the slte prov1des nest1ng and forag1ng hab1tat for a number of spec1es The Cal1forn1a horned lark (Eremoph~la alpestr~s act~a), a State Spec1es of Spec1al Concern, 11kely breeds 1n the grassland on slte SUltaele grassland/open space area should be preserved to m1t1gate 1mpacts to these speC1es San Joaqu1n spearscale (Atr~plex Joaqu~n~ana)and Congdon's 6 11 tarplant (Hem~zon~a parry~ sp congdon~~) were oeserved on the slte A thorough f1eld survey, conducted accordlng to the Department's Rare Plant Survey GU1del1nes by a qual1f1ed botan1st dur1ng the appropr1ate months, lS needed to determ1ne the extent of these spec1es on the proJect slte CEQA GU1del1nes Sect10n l5380(d) states that these spec1es be addressed as other threatened and endangered spec1es and adequate m1t1gat1on be ~ prov1ded for any 1mpacts The Department recommends that 1mpacts be avo1ded 1n areas where these spec1es occur on the proJect slte Conservat1on areas should also 1nclude an appropr1ate buffer The Department does not approve of translocat1on as an acceptable m1t1gat1on measure There lS no eV1dence to support that translocat1on lS a successful techn1que to perpetuate populat1ons of these plant speC1es and, therefore, the proposed m1t1gat1on lS v1ewed as exper1mental and does not meet the m1t1gat1on standards of CEQA If avo1dance of 1mpacts to these spec1es lS not poss1ble, a M1tlgat1on and Mon1tor1ng Plan should be developed that w1II prov1de for off-s1te conservat1on of populatlons of these spec1es The plan should be rev1ewed and approved by the Department Surveys to be conducted at a later t1me, or m1t1gat1on measures to be 1dent1f1ed at some future t1me, are not acceptable It has been deterffilned by court rul1ng that such studles and ffilt1gat1on measures would be 1mproperly exempted from the process of publ1C and governmental scrut1ny Wh1Ch lS requ1red under the CEQA The In1t1al Study requests future stud1es and future 1dent1f1cat1on of m1t1gat1on and, therefore, lS cons1dered 1nadequate . ~ Mr Dennls Carrlngton December 8, 1999 Page Seven Wetlands 6 12 The proJect wlll lmpact 1 6 acres of wetlands ln the --Department's Jurlsdlctlon lncludlng 2970 Ilnear feet of lmpacts along two seasonal dralnages Mltlgatlon proposed lS 0 48 acre ln the northern dralnage and creatlon on-slte of an 810-foot long dralnage wlth a 33-foot buffer on each slde The Department recommends a mlnlmum 100-foot buffer be establlshed to protect wetlands The buffer should be measured outward from the edge of any wetland A recreated channel surrounded by development lS not expected to fully compensate for the functlons and values of the lmpacted channel Enhancement of addltlonal Ilnear feet of channel, at least equlvalent to that belng lmpacted, should be requlred f) A Streambed Alteratlon Agreement must be obtalned from the Department prlor to any work ln a lake or stream corrldor Slnce the lssuance of such an Agreement lS subJect to CEQA reVlew, dlsclosure and lncorporatlon of mltlgatlon measures requested by the Department lS needed to meet the requlrements of CEQA The proJect wlll lmpact approxlmately 6 80 acres of wetlands and waters ln U S Army Corps of Englneers Jurlsdlctlon It lS the POllCY of thlS Department that a proJect should cause no net loss of elther wetland acreage or wetland habltat value Department personnel are avallable to address these concerns ln more detall To arrange a meetlng please contact Ms Janlce Gan, Assoclate B10loglSt, at (209) 835-6910, Mr Scott Wllson, Envlrorumental Speclallst, at (707) 944-5529, or Mr Carl Wllcox, Envlrorumental Program Manager, at (707) 944-5525 Slncerely, //:~~ Reglonal Manager Central Coast Reglon f) cc See next page -~ - Mr Dennls Carrlngton December 8, 1999 Page Elght . cc Mr Curt McCasland U S F1Sh and Wlldllfe Servlce 3310 El Camlno Avenue, SUlte 130 Sacramento, Callfornla 97232-6340 Ms Shella Larsen U S F1Sh and Wlldllfe Servlce 3310 El Camlno Avenue, SUlte 130 Sacramento, Callfornla 97232-6340 Mr Kelth Llchten State Water Resource 2101 Webster Street, Oakland, Callfornla Control Board SUlte 500 94612 Mr Ed Wylle U S Army Corps of Englneers 333 Market Street San Franclsco, Callfornla 94105-2197 ;' c . . f) f) ~ UnIted States Department of the Intenor FISH AND WILDLIFE SERVICE Sacramento Fish and Wtldhfe Office 2800 Cottage Wav, Room W-260S Sacramento, California 95825-1846 RECEIV~D 1 3 1999 DUBLIN PUY\\NINGi IN REPLY REFER TO- 1-1-00-TA-37I December 9, 1999 Ms Anne Kmney City ofDublm Planrung Department POBox 2340 DublIn, CalIforrua 94568 lLetter 7 Subject Irutlal Study/.Mitlgated Negative Declarations for DublIn Ranch Planmng Areas F, G, and H Dear Ms Kmney Trus IS m response to the City ofDubhn's Mitigated Negative DeclaratIOns and Imtlal Studies dated November 8, 1999, for each of the three Dubfm Ranch Planrung Areas (F, G, and H) m the CIty of Dub 1m, Alameda County At Issue are Impacts to the San Joaqum lat fox (Vulpes macrons mutrca) (lut fox), conservancy faIrY shnmp (Branchmecta conservatlO), longhorn fwry shnmp (B longzantenna), vernal pool tadpole shrunp (Lepldurus packard!), the CalIforrua red-legged frog (Rana aurora draytonu) (red-legged frog), and CalIforrua tiger salamander (Ambystoma califomlense) (salamander) The lat fox and vernal pool Invertebrates are federally lIsted as endangered and the red-legged frog IS federally lIsted as threatened pursuant to the Endangered SpecIes Act of 1973, as amended (Act) The salamander IS a candIdate species The ServIce has Judged the salamander to be warranted but precluded from hstIng actIOn at present by hIgher lIstmg pnontles Planmng Areas F, G, and H contaIn approAlmately 147, 87, and 71 acres, respectIvely, and are all part of the larger Dubhn Ranch planned development, wIuch contaInS 1,310 acres Tills letter proVIdes the US FISh and WIldhfe ServIce's (ServIce) COiilments on the proposed modmcatlOns pursuant to tne ACt 7 1 The ServIce IS concerned With the segmentatIOn of the proposed Dublm Ranch planrung area The ServIce has preVIously met WIth the consultants for DublIn Ranch and discussed proJect unpacts assocIated With the entIre Dubhn Ranch project area, mcIudmg the three parcels willch make up Planmng Areas F, G, and H ThIs piecemeal approach proposed WithIn these three planrung documents reduces the hkehhood of the hsted species to persist on site (1 e , DublIn Ranch), much less WithIn the entIre Eastern Dubhn Specific Plan area The ServIce requests that the City of DublIn reevaluate these three planmng documents and the remaImng undeveloped portions of the Dublm Ranch Project under one planmng document ThIs coordmated evaluation Will allow a more practicable and realIstIc approach to conservIng lIsted species WIthIn your JunsdICTIOn --- Beyond the SefVlce's concerns over the segmentation of the overall project, the SefVlce does not 7 2 concur WIth the findIngs ofthe Irutlal StudIes Red-legged frogs and salamanders have been -- found WithIn Planrung Area F and to the west, east, and north of the project areas The remamrng portIons of the project areas consist pnmanly of nonnative annual grassland that were lustoncally farmed but are currently fallow The ServIce believes that the seasonal wetland found Wltlun PlanDlng Area H contams sUItable habItat for the conservancy fairy shnmp, the longhorn fairy sbnmp, the vernal pool tadpole shnmp, the red-legged frog, and the salamander, the surroundmg grasslands m all three planrung areas, as well as the rest ofDubhn Ranch, contatn SUItable habItat 7 _~_ for red-legged frogs and salamanders Furthermore, the SefVlce does not concur WIth the r presumed absence of lot foxes from the sIte, there have been at least two lut fox slghtmgs Wlthm ten mIles of the project sIte The planmng areas con tam habItat sUItable for kIt foxes and there are no current unpedunents or bamers that would prevent lot foxes from reachrng the planrung areas 7 4 Furthermore complete protocol surveys have not been completed and the SefVlce does not concur --r With the presumed absence of the conservancy fauy shnmp, the longhorn fairy shnmp, or the vernal pool tadpole shnrnp 7 5 The SefVlce contmues to be concerned over the lack of appropnate measures to mmUllize Impacts to federally lIsted species WIthrn the East Dublm Planrung Area The measures rncluded Wltlun all three planrung documents fad to adequately aVOId slgmficant Impacts to lut foxes, red-legged frogs, salamanders, or the vernal pool Invertebrates Your plannIng document~ fad to 10clude the upland portion of the planrung areas as habItat for lut foxes red-legged frogs, or salamanders, or the IndIrect Impacts assocIated WIth gradIng the upland portIons of the seasonal wetland found 10 area H Red-legged frogs have been documented to forage beyond 200 feet of aquatic habItat In uplands With lIttle to no avaIlable cover In addItIOn, red-legged frogs have been observed travelIng dIstanceS ofapproxunately 1-3 kIlometers (0 6-1 8 mIles) between breedIng and nonbreedmg habitat These dIsperSIng frogs were observed to make both straIght hne movements over upland habItat as well as mOVIng along npanan comdors Salamanders also requrre upland habItat Adult salamanders spend the maJonty of theIr hves mhabltIng burrows Wltlun upland areas GlVen these observatIOns, It IS Important to preserve upland areas for adequate dispersal comdors and nonbreedmg habItat for both red-legged frogs and salamanders, not to mentIon the use of grasslands by foragIng kIt foxes 2 . . 7 6 The proposed proJects are lIkely to result In take of lut foxes and red-legged frogs and pOSSIbly the conservancy fany shnmp, the longhorn faIry shnmp, or the vernal pool tadpole shnmp The SefVlce recommends that the project applIcant dISCUSS the entire project With the SefVlce to ensure that proper measures are Implemented to mInnlliZe Impacts to federally lIsted species If a Federal agency IS mvolved WIth the permIttmg, fundmg, or carrymg out oftlus proJect, then lDltIatIon offormal consultatIon between that agency and the SefVlce pursuant to sectIOn 7 of the Act, IS requrred Such consultatIOn would result In a bIOlogIcal op1OJon addressmg antICIpated effects oftbe project to lIsted and proposed specIes and may authonze a lIffilted level of IncIdental take Ifa Federal agency IS not Involved With the proJect, and federally-lIsted specJes may be taken as part of the proJect, then an "InCIdental take" permit pursuant to sectJon ID( a)(1 )(B) of the Act should be obtamed The SeIVlce may Jssue such a permIt upon completion by the penrut . () () f) 3 applIcant of a satisfactory conservation plan for the lIsted species that would be affected by the project I 7 7 In conclusIon, the proposed projects wlll further Isolate and fragment populations of red-legged -- frogs WithIn the TassaJarra Creek Watershed and areas to the east ofTassaJarra Creek The eastern portIons of Alameda and Contra Costa Counties possess the largest populations of red- legged frogs m the East Bay area, and these areas are currently undergomg rapid growth The ServIce belIeves tros area IS llTIportant for the long-term SUrvIval and recovery of the species To prevent take of red-legged frogs, the Service belIeves a lTIlnImum buffer distance of300 feet between all wetlands and adequate upland dispersal comdors are necessary to ensure the project does not Isolate red-legged frogs The development of these comdors, In conjunction with preSerVI'1g su.t"ble salaMander UDla!1~ h?bltat would also 'l1In.""11ze 'f'1pactc: to I...lt fO'l>..es Furthermore, the project should be deSIgned to aVOId nUisance summer flows entenng mto TassaJarra Creek or any other water course These actions are necessary to allow lIt foxes, red- legged frogs, the conservancy fauy shnmp, the longhorn faIry shnmp, the vernal pool tadpole shnmp, and salamanders to persist m the proJect VICInity Your contInued coordmatIon With the Service Will be essentIal to ensure that these lIsted species persist WithIn the East Dublm PlannIng area We look forward to worlIng With you on this proJect If you have any questIOns, please contact Curt McCasland or Ken Sanchez at (916) 414-6625 SIncerely %'-MA^- (\ V\vt.~ If) Karen J~lIer Chief: Endangered SpecIes DIVISIon cc Scott Wdso'1, CDFG, Y ountvIlle, C A Jaruce Gan, CDFG, Y ountvIl1e, CA Keith LIchten, RWQCB, Oakland, CA Brad Olson, EBRPD, Oakland, CA Malcolm Sproul, LSA, Pt RIchmond, CA Ron Duke, H T Harvey, Milpltas, CA Jeff Miller, Alameda Creek AllIance, Canyon, CA Jaruce Delfino, Ohlone Audobon Society, Castro Valley, CA Karen High, CItizens Comnuttee to Complete the Refuge, ~ Califormdia Regional Water Q1Ulabty Control Board San FrancIsco Bay RegIOn ~ 'WlOston H Hickox Secretary for EnvIronmental ProtectIon Internet Address hnp II....'VI'VI swrcb ca gOY 1515 Cia} Street, SUite 1400 Oakland California 94612 Phone (5 I 0) 622 2300 3 FAX (5] 0) 622 2460 Gray DavIs Govemo. December 9, 1999 FIle No 219809 (KHL) Letter 8 RECEIVED D l: L I ~ 19S9 DUBLIN PLANNING Ms Anne KInney CIty of Dublm 100 CIVIC Par1.rway DublIn, CA Re SCH Nos Dublm Ranch Planmng Areas "F", "G", and "H" 99112040,99112041, and 99112042 Dear Ms Kmney We have receIved the above-referenced MIugated Negauve DeclaratIOns and offer the followmg comments on areas Wlth whtch the RegIOnal Water QualIty Control Board (R WQCB) IS concerned . The NegatIve Declarauons address the portIOn of the phased DublIn Ranch proJect that would be located on Areas F, G, and H Areas F, G, and H are located 'wItlnn the 3,302 acre Eastern DublIn SpecIfic Plan area, and are compnsed of 147 acres, 87 acres, and 71 acres, respecuvely The proposed project on these areas would result ill the constructIOn of 2,188 resIdenual uruts, publIc or semI-publIc uses on 7 1 acres, neIghborhood and general commerCIal use on 382 acres, campus office and/or campus office/commercIal uses on 55 1 acres, and a varIety of other uses, mcludrng schools, parks and open space 8 1 Board staff are concerned that the NegatIve DeclaratIOn may not adequately address the proJect's potenTIal rmpacts to wetlands, nparIan waters, and assocIated endangered speCIes, mcludmg the CalIforma red-legged frog (CRLF) and CalIforma uger salamander (CTS) Further, 8 2 staff are concerned that the project, as proposed, would Increase the levels of pollutants dIscharged from the site and could alter the site's runoff hydro graph, potentIally Impactmg downstream bed and bank StabIlIty 8 3 It appears that the proJect Will Impact the number or range of eAlstrng rare, threatened, and/or endangered speCIes that are known to be present or could be present on the proJect SIte For example, page 29 of the Imual Study for Planrung Area F states that "[c]learmg and gradrng could result m the loss of mdIvIdual tIger salamCID.ders and theIr estIvauon habItat, and fillmg of the stock pond would result m the loss of 0 7 acres-of red-legged frog-and-tlger salamander . California EnVironmental Protectzon Agency Q~ Recycled Paper (f) - 2 - breedmg habitat and could potentIally result m the loss of mdIvlduals" The ImtIal Study subsequently Identifies Impacts to other rare, threatened, and/or endangered speCIes I) Under CEQA, Impacts or potentIal Impacts to the number or range of a rare, threatened, or endangered speCIes reqUIre a mandatory findmg of slgmficant Impact Because the subject CEQA documents IdentIfy such Impacts, It appears that a negatIve declaratIOn does not adequately comply With CEQA SectIOn 15065 of the CEQA GUIdelInes states that "[a] lead agency shall find that a project may bave a SIgnIficant effect on the enVIronment [when the] project has the potenTIal to reduce the number or restrIct the range of an endangered, rare or threatened speCIes "Under tlns relatively StrICt sectIon of the CEQA GUIdelmes, an EIR or appropnate subsequent EIR or addendum IS reqUITed for proJects With such Impacts It appears that the subJect project, as presently proposed, has the potentIal to have such Impacts WhIle an FEIR was prepared for the DublIn Area SpecIfic Plan m 1992, we concur With the State Department ofFIsh and Game (CDFG) that substantIal new mformatIOn that has developed smce the FEIR' s certIficatIOn m 1993 Therefore, staff belIeves that these negatIve declaratIOns are mappropnate for the present proJect, and an EIR or other appropnate subsequent document should be prepared However, we understand that the CIty may not male the same findmg Therefore, tins letter also proVIdes more detaIled comment on other areas of the NegatIve DeclaratIons With wInch the Board IS mterested 8 4 The proposed development would dISturb more than five acres of land durmg. construCTIon It must be covered under the State NPDES General PermIt for Discharges of Storm Water ASSOCiated With ConstructIOn ACtIVIty (General PermIt) TIns can be accomplIshed by filmg a NotIce of Intent (NOI) WIth the State Water Resources Control Board, DIVISIOn of Water QualIty CopIes of the General PermIt and- NOI can be obtatned from the State Board's web page, www swrcb ca QOV, or by contactmg the Board at (510) 622-2494 The project sponsor must propose and rmplement control measures that are conSIstent WIth the General PermIt and With the recommendatIOns and polICIes of the local agency and the R WQCB 8 5 Appro>illIlately 68 acres of U S Army Corps of Engmeers (Corps) JurIsdIctIOnal area (578 acres of wetlands and 1 02 acres of Waters of the US) would be Impacted WIth the development of Areas F, G, and H These mclude approXImately 3000 lmear feet of seasonal creeks on the SIte Because the proJect Involves the dIsturbance of JUTIsdIctIonal wetlands and Waters of the State, a SectIOn 401 Water QualIty CertIficatIOn or other appropnate approval from the State WIll be necessary, and should be referenced ill appropnate sectIOns of the proJect's CEQA documentatIOn (e g, paragraph 2 of the BIOlogICal Resources SectIon m the Auea F mItIgated Negauve DeclaratIon, wruch presently refers only to the Corps and CDFG) - ~ 8 6 SectIon 404 (b)(l) of the Clean Water Act sequences the order In wInch proposals should ~ I be approached FIrst Impacts to wetlands or Waters of the state must be aVOIded to the maxunum extent praCTIcable Second, the remmmng Impacts must be mInImIzed Fmally, the remamillg Califorma EnvlrOlzmental ProtectIon Agency ~ ReC)cled Paper ... - .) - . unavOIdable adverse Impacts to wetlands or Waters of the State must be mItigated MItigatIOn wIll preferably be ill-land and on-site, WIth no net destructIOn of habItat value If the applIcant IS unable to demonstrate that the proJect was unable to aVOld adverse Impacts to wetlands or Waters of the State, water qUalIty certIficatIOn wIll be demed 401 certIficatIOn may also be demed based on sIgmficant adverse Impacts to wetlands or other Waters of the State 8 7 Although the project deSIgn, as proposed, would fill certatn areas of creeks and wetlands - on the project SIte, It has not yet received the reqUired approvals from state and federal agencIes The deSIgn may change substantIally dunng agency reVIew of the proJect applIcatIOn for wetland fill, and tlns uncertaInty should be reflected m the project's CEQA document For eAample, to address thIS, the City could COmmIt to completmg any addItIonally reqUIred CEQA documentatIOn necessary for the proJect to come Into complIance WIth CEQA folloWing such deSIgn changes 8~ The City of Dublm IS permItted under and complIes With NPDES permIt CAS0029831, the mumcIpal storm water permIt and assOCIated Storm Water Management Plan (SWMP), as a part of approvmg and condItIOmng new and redevelopment proJects As of February 19, 1998, the SWMP mcludes the follovvillg reqUirements . 1 AgencIes Will requITe publIc and pnvate development proJects to illclude site planmng and deSIgn technIques to prevent and rmmrmze Impacts to water qUalIty These m~ mclude the followlDg a MmImIze land dIsturbance, b MmllTIlze ImpervIOUS surfaces (e g, roadway WIdth), espeCIally dIrectly connected ImpervIOUS areas (DCIA), c Use of clustenng, d PreservatIOn of qualIty open space, and e Matntam (and/or restore, If possIble) npanan areas and wetlands as proJect amemtIes, establIshmg vegetatIOn buffer zones to reduce runoff mto waterways 2 Each Agency WIll reqUire publIc and pnvate development proJects to mclude permanent stormwater quality controls, as appropnate, If suffiCIent site plannIng measures are not Implemented or feasIble Therefore, tlns proJect, wrnch IS located m the City of Dub1m, must mclude both deSIgn measures and permanent treatment controls, as appropnate f..s proposed III the NegatlVe DeclaratIOns, the proJect applIcant would not be-reqUITed to address tlns Issue untIl It obtamed a . gradIng pemut TypIcally at that stage, the proJect has already undergone substantial deSIgn and It IS much more dIfficult to mcorporate mto It acceptable and effectIve storm water deSIgn Californza EnVIronmental ProtectlOn Agency ~~ Recvc/ed PaDer CI) () t) -4- measures and treatment controls Post-constructIon storm water deSIgn measures and treatment controls are most easIly and effectIvely mcorporated mto a proJect at Its planmng stages Therefore, the project applIcant should be reqwred to submIt a detaIled conceptual post- constructIOn SWPPP as soon m the process as appropnate, and a final post-constructIOn SVlPPP pnor to obtammg a gradmg permIt for the proJect The conceptual post-constructIOn SWPPP should be as detaIled and site-specIfic as possIble, and CIty approval of such a SWPPP should be reqwred pnor to any other approval that would fix substantIal portIOns of the proJect, and deSIgn measures for those areas, m place 8 9 AddItIonally, by substantIally mcreasmg the amount of ImpervIOus surface present on the SIte and by mtroducmg constructed storm dratns, rather than the present overland flow, the project could substantIally alter the eXlstmg runoff hydrograph for the Site, and flows m the streams mto wluch It would dram Such alteratIOns could result m Impacts to downstream stream bed and bank stabIlIty, and asSOCIated Impacts mcludmg loss of habItat and threats to eAIstmg structures adJacent to the streams At present, the hydrologIC analYSIS of downstream Impacts IS lImIted to ensutmg that peak flows Will not create a floodmg hazard The analYSIS should be eApanded to address the Issues dIscussed above ~ RegIOnal Board staff are unable to offer more speCIfic comment at tlns time However, I have attached a copy of our General Comments, wluch dISCUSS the RegIOnal Board's area of responsIbilIty, and wInch should help gwde m the preparatIOn of further CEQA documentatIOn - RegIOnal Board staff also encourage the lead agency to obtaIn a copy of "Start at the Source," a deSIgn gwdance manual for storm water qUalIty protectIOn, wluch prOVIdes mnovatlve ways of desIgnmg structures, parkmg lots, dramage systems, and landscapmg TIns manual may be obtamed at most CIties' planmng departments or by callmg Forbes Press, wluch IS dIstnbutmg the manual for the Bay Area Stormwater Management AgenCIes ASSOCIatIOn, at 1-800-773-7247 If you have any questIOns, please contact me at (510) 622-2380, or VIa e-mail to khl(a)rb2 swrcb ca !!oy Smcerely, ~~ KeIth H LIchten Water Resource Control Engmeer Enclosures General Comments Start at the Source mformatIon page - cc (w/out attachments) State Clearmghouse Califorma Envzronmental ProtectIOn Agency ,,~ Reevcled Paver t f :: -<~- ~~~ ~Lt Lillncci ~(Q)mCc~ ..- ~, , '- ,. _"'t. ~-'" "1' ....:r"f. __--~- )-_ -.~_.?=_-;:;__ ('" ~- - .,.;::' "'( - __ ~ ....-w "" .-'" ~~ .....::= - ~ {, -=- I ~ _..,..... r _ ... - .... -.::-.- ~ - ~ -~- r -.$ l>-.. ,J.- -r _ _ _ u'" _ <po _ #- ~ ~ A ll)l 0 <G 0 &aum ~ Miurll1maill - 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(~I 0) 612 2460 @ ~ Gn" Da\ 15 Gm-.:mur General Comments The San FrancIsco RegIOnal Water Quahty Control Board (Regtonal Board or RWQCB) IS charged wIth the protectIOn of the Waters of the State of Cahforma m the San FrancISco Bay ReglOn" mcJudmg wetlands and storm water qualIty The RegIOnal Board IS responsIble for admlDlstenng the regulations estabhshed by the Federal Clean Water Act AddItIonally, the Cahfomla Water Code estabhshes broad state authonty for regulation of water qualIty The San FranCISCO Bay Basm Water Quahty Control Plan (Basm Plan) explams the RegIOnal Board's strategy for regulatmg water qualIty The Basm Plan also descnbes the range of responses aVaIlable to the RegIOnal Board WIth regard to actIons and proposed actIons that degrade or potentIally degrade the benefiCIal uses of the Waters of the State of CalUOInIa. NPDES () Water quality degradatJOD IS regulated by the Federal NatIonal Pollutant Discharge Eltmmabon System (NPDES) Program, estabhshed by the Clean Water Act, which controls and reduces pollutants to water bodIes from pornt and nonpomt dIscharges In CahfornIa, the program IS admmlstered by the CaluomIa RegIOnal Water Quahty Control Boards The Regtonal Board Issues NPDES penmts for dIScharges to water bodIes m the San FranCISCO Bay Area, mcludmg MUDlCIpal (area- or county-Wlde) Storm water DIscharge PermIts Projects dISturbrng more than five acres of land dunng constructIon must be covered under th~ State NPDES General Permit for Discharges of Storm Water AsSOCiated WIth ConstructIon ActIVity (General PermIt) Thts can be accomphshed by filmg a NotIce of Intent An NOr and the General PermIt can be obtamed from the Board at (510) 286-0968 The project sponsor must propose and Implement control measures that are consIstent With the General PermIt and With the recommendatIons and pohcles of the local agency and the RWQCB Projects that mclude faclhtles WIth dIscharges of Storm Water AsSOCiated With Industnal ActIvIty must be covered under the State NPDES General Permit for DIscharges of Storm Water ASSOCiated WIth IndustrIal ActIvJty Thts may be accompltshed by filIng a Notice of Intent The project sponsor must propose control measures that are consIStent WIth tIus, and WIth recommendatIons and ~ pohcles of the local agency and the RWQCB In a few cases, the project sponsor may apply for (or the RWQCB may requIre) Issuance ofao mdlVldual (mdustry- or faCIlIty-specIfic) permit The RWQCB's Urban Runoff Management Program requIres Bay Area mUDlcIpalItIeS to develop and IIDplement storm water management plans (SWMPs) The SWMPs must rnclude a program for ImplementIng new development and constructIOn SIte storm water quality controls The objectIve of 1hts component 15 to ensure that appropnate measures to control pollutants from new development are considered dunng the plannmg phase, before constructIon begms, unplemented dunng the constructIon phase, and mamtamed after constructIon, throughout the lIfe of the p.!oJect () California Envlronme,bal Protectloll AgenCl Q";) D~ _ _I_~ J'J___ _ Impacts and MltI!!atIon Measures . Wetlands Wetlands enhance water quality through such natural functIons as flood and eroSIOn control, stream bank: stabIlIZatIon, and filtratIon and punficatlOn of contammants Wetlands also provIde cntIcal babItats for hundreds of speCIes of fish, bIrds. and other wIldlife. offer open space, and proVide many recreatIonal opportunItIes Water quality lDlpacts occur m wetlands from constroctlOn of structures m waterways. dredgmg, fillmg, and altenng dramage to wetlands The RegIOnal Board must certJ.fy that any permit ISSUed by the U S Army Corps of Engmeers pursuant to Sectton 404 of the Clean Water Act (covenng, dredgmg, or fillmg of Waters of the UnIted States. mcludmg wetlands) comphes With state water quality standards. or waIve such certrlicatIon SectIon 401 Water QualIty CertrlicatlOn IS necessary for all 404 NattonWIde permIts, reportIng and non- reportIng, as well as mdIvIdual permIts All projects must be evaluated for the presence ofJunsdlchonal wetlands and other Waters of the State DestructIon of or Impact to these waters should be aVOided If the proposed proJect lIDpacts wetlands or other Waters of the State and the project applIcant 15 unable to demonstrate that the project was unable to aVOid those adverse mIpacts, water qualIty certrlicatIon WIll most lIkely be dewed 401 Certrlicat:J.on may also be demed based on SI~cant adverse rmpacts to wetlands or other Waters of the State In coosIdenng proposals to fill wetlands, the RegIOnal Board has adopted the CalIfOrnIa Wetlands Conservation Pohcy (ExecutIVe Order W-59-93, SIgned August 23, 1993) The goals of the Policy mclude ensunng "no overall net loss and achlevmg a long-term net gam m the quantIty, qualIty, and . permanence ofwetIands acreage and values" Under thiS Pohcy, the RegIOnal Board also considers the potential post-constructIon lIDpacts to wetlands and Waters of the State and evaluates the measures proposed to mitIgate those rmpacts (see Storm Water Quabty Control, below) The RegIonal Board has adopted U S EPA's Clean Water Act SectIon 404(b)(1) "GUIdelmes for SpeCification of DJsposal Sites for Dredge or Fill Matenal." dated December 24, 1980, m the Board's Basm Plan for determmmg the CIrcumstances under which fill may be pemlltted SectIon 404(b)(1) GUIdelmes prohIbIt all dIscharges offill matenaI mto regulated waters of the UUlled States, unless a discharge, as proposed, constItutes the least envrronmentally damagmg practIcable alternative that Will achIeve the basiC project purpose For non-water dependent projects, the gwdelmes assume that there are less damagmg alternatIves, and the apphcant must rebut that assumptIon The SectIon 404(b)(1) GUldelmes sequence the order In which proposals should be approached FIrSt, Impacts to wetlands or Waters of the State must be aVOIded to the m8X1IDUID extent practIcable Second, the remammg lDlpacts must be mmlIllIzed FmaIly. the remammg unaVOIdable adverse nnpacts to wetlands or Waters of the State must be mitIgated MItIgatIon WIll be preferably m-kmd and on-Site, Wltb no net destructIOn of habItat value A proportIonately greater amount of mITIgatIon IS reqwred for projects that are out-of-kmd and/or off-Site MitIgatIon WlII preferably be completed pnor to. or at least slIDultaneous to, the fillmg or other loss of eXlstmg wetlands Successful mltIga'bon projects are complextasks and dIfficult to achieve This Issue Will be . strongly consIdered dunng agency revIew of any proposed wetland fill Wetland features or ponds ., ... f) f) () created as mitIgatIOn for the loss of eXistIng JunsdlctIonal wetlands or Waters of the Umted States cannot be used as storm \\oater treatment controls In general, If a proposed project Impacts wetlands or Waters of the State and the project apphcant IS unable to demonstrate that the project was unable to aVOid adverse Impacts to wetlands or Waters of the State, water quahty certIficatIon w1l1 be demed 401 CertIficatIon may also be deDJed based OD signIficant adverse lDlpacts to wetlands or other Waters oftbe State Storm Water QUality Control Storm water IS the major source of fresh water to creeks and waterways Storm water qualIty IS affected by a vanety of land uses and the pollutants generated by these actIvItIes Development and construction actIvItIes cause both slte.spectfic and cumulattve water quahty mlpacts Water qualIty degradatIon may occur dunng constructIon due to dIscharges of sedIment, chemicals, and wastes to nearby stonn drams or creeks Water qualIty degradation may occur after constructIon IS complete, due to dIscharges of petroleum hydrocarbons, 011, grease, and metals from vehtcles, pesticides and fertilIzers from Jandscapmg, and bactena from pets and people Runoff may be concentrated and storm water flow mcreased by newly developed unpervlOUS surfaces. which wIll mobIlIZe and transport pol1utants deposIted on these surfaces to storm drams and creeks Changes In runoff quantity or velocIty may cause erosion or sIltatIon m streams Cumulatively, these discharges wIll mcrease pollutant loads m creeks and wetlands WIthm the local watershed, and ultImately m San FranCISCO Bay To asSIst munlclpahtIes In the Bay Area WIth complymg WIth an area-WIde NPDES MumcIpal Storm Water PermIt or to develop a Baselme Urban Runoff Program (If they are not yet a co-permrttee WIth a MunICIpal Storm Water Permit), the RegIOnal Board dIstnbuted the Staff RecommendatJOns for New and Redevelopment Control for Storm Water Programs (RecommendatIons) m Apnl 1994 The Recommendations descnbe the RegIOnal Board's expectations of mUDlclpalltIes m protectIng stom water qualIty from Impacts due to new and redevelopment proJects. mcludmg estabhshmg polICies and requIrements to apply to development areas and proJects, mlbatmg appropnate plannmg, reView, approval, and mspectIon procedures, and llsmg best management practIces (BMPs) dunng construction and post-constructIon Project nnpacts should be mmUDlzed by developmg and rmplementmg a Storm Water Polhmon Prevention Plan (SWPPP) A SWPPP 15 requrred by the State ConstructIon Storm Water General PermIt (General Permit) The SWPPP should be consistent With the terms oftbe General PermIt, the Manual of Standards for Erosion & SechmentatJon Control Measures by the AsSOCIation of Bay Area Governments (ABAG), poliCies and recommendations of the local urban runoff program (CIty and/or county). and the Recommendations of the RWQCB SWPPPs should also be requrred for projects that may have rmpacts, but which are not reqUIred to obtam an NPDES penmt Preparation of a SWPPP should be a conditIon of development ImplementatIOn of the SWPPP should be enforced dunng the constructIon penod via appropnate optIons such as CItatiOns, stop work orders. or Wlthholdmg occupancy permIts Impacts Jdenbfied should be aVOIded and milllDltzed by developIng and lDlplementmg the types of controls lIsted below Explanations of the controls are avaIlable m the RegIOnal Board's constructIon Field Manual, available from Fnends of the San FranCISCO EstuaJy at (510) 286-0924, m BASMAA's Start at the Source, and In the Califorma ~o!."' Water Best Management Practice Handbooks 3 Site PlannlDg . The project should mmumze Impacts from project development by mcorporatmg appropnate Site plannmg concepts 1111S should be accomplIshed by deslgnmg and proposmg SIte plannmg options as early ill the project plannmg phases as poSSible Appropnate SIte plannmg concepts to mclude, but are not lumted to the followmg o Phase constructlOn to hmrt areas and penods of IDlpact. o MmuDIze dIrectly connected ImpervIOus areas o Preserve natural topography, eXistIng dramage courses and eXistIng vegetation o Locate constructIOn and structures as far as poSSIble from streams. wetlands, dramage areas, etc o ProVIde undeveloped. vegetated buffer zones between development and streams, wetlands, dramage areas, etc o Reduce paved area through cluster development, narrower streets, use of porous pavement and/or retammg natural surfaces o Mmmuze the use of gutters and curbs which concentrate and drrect runoff to Impermeable surfaces o Use eXIstIng vegetatIon and create new vegetated areas to promote mfiltrallon o DeSign and layout commumtIes to reduce rehance on cars o Include green areas for people to walk therr pets, thereby reducmg bUIld-up of bactena, worms, VlIUSes, nutnents, etc ill unpermeable areas, or mstltute ordmances requmng ovroers to collect pets' excrement. o Incorporate low-mamtenance landscapmg o DeSign and layout streets and storm dram systems to faclhtate easy mamtenance and cleamng o ConSider the need for runoff collectIOn and treatment systems . o Label storm drams to dIScourage dumpmg of pollutants mto them EroSIOD The proJect should mmumze erOSIOn and control sedunent dormg and after constructIon This should be done by developmg and unplementmg an erOSlOn control plan, or equivalent plan TIus plan should be mcluded m the SWPPP The plan should specify all control measures that Will be used or whlch are annClpated to be used, mcludmg, but not huuted to, the follOWIng o Lunlt access routes and stablhze access pomts o Stablhze denuded areas as soon as pOSSible WIth seedmg, mulchmg, or other effectIve methods o Protect adjacent propertIes With vegetatIve buffer stnps, sedtm.ent barners, or other effectIve methods o Delmeate cleanng lIDllts, easements, setbacks, senSItIve areas, vegetatIOn and dramage courses by markmg them m the field. o StabllIze and prevent eroSIOn from temporary conveyance channels and outlets o Use sedtm.ent controls and filtrabon to remove sedunent from water generated by dewatenng or collected on-site dormg constructIon For large Sites, storm water settlmg basms wIll often be necessary . 4 (f) Chemu:al allld Waste Managem.ent The project should mmlIDIZe unpacts from chemicals and wastes used or generated dunng constructIon This should be done by developmg and rmplementmg a plan or set of control measures The plan or control measures should be mcluded m the SWPPP The plan should SpecIfy ail control measures that wIll be used or whtch are antIcipated to be used, mcludmg, but not lumted to. the foHoWIng () o DeSIgnate specIfic areas of the Site, away from streams or storm dram mlets, for storage, preparation, and dIsposal ofbuIldtng matenals, chemical products, and wastes o Store stockpJled matenals and wastes under a roof or plasttc sheetmg o Store contamers of pamt, chemJcals, solvents, and other hazardous matenals stored m contaIners under cover dunng ramy penods o Berm arOlmd storage areas to prevent contact WIth runoff o Cover open Dumpsters securely WIth plasbc sheetmg. a tarp, or other cover dunng ramy penods o DesJgnate specIfic areas of the Site, away from streams or storm dram mlets, for auto and eqUIpment parkIng and for routIne vehIcle and equipment mamtenance o Routmely mamtam all vehIcles and heavy eqUIpment to aVOid leaks o Perfonn major mamtenance, reparr, and vemcle and eqwpment washmg off.slte, or m deSIgnated and controlled areas on-sIte o Collect used motor 011, rachator coolant or other flUids WIth dnp pans or drop cloths o Store and label spent flUids carefully pncr to recyclmg or proper dtsposal o Sweep up spilled dry matenals (cement, mortar, fertIlIZers, etc) rmmedlately-do not use water to wash them away o Clean up hqUId spIlls on paved or unpermeable surfaces usmg "dry" cleanup methods (e g , absorbent matenals, cat htter. rags) and dIspose of cleanup matenals properly o Clean up spills on dut areas by dlggmg up and properly dlsposmg of the SOli o Keep pamt removal wastes, fresh concrete, cement mortars, cleared vegetatIon, and demolition wastes out of gutters, streams, and storm drams by usmg proper contaInment and dISposal Post-Constmcbon The project should mmmuze unpacts from pollutants that may be generated by the project follOWIng constructIon, when the project IS complete and occupJed or m operal1on These pollutants may mclude sedunent, bactena, metals, solvents, 011, grease, and pestIcIdes, all of which are typically generated dunng the hfe of a reSIdentIal. commercIal, or mdustnaI project after constructIon has ceased TIus should be done by developmg and unplementmg a plan and set of control measures The plan or control measures should be mcluded m the SWPPP The plan should Specify ail control measures that will be used or which are antIcipated to be used, mcludmg, but not lunrted to, the source controls and treatment controls hsted m the Recommenda.tlODS Appropnate control measures are dIscussed m the Recommendattons, m () o Table 2 Summary ofresldenttal post-constructIon BMP selectIon o Table 3 Summary of mdustnal post-constructton BMP selectIOn o Table 4 Summary of~cammerclal post-constructIon BMP selection 5 AddItional sources of ullonnatlOD that should be consulted for B:MP selectJon mclude the California . Storm Water Best Management Practice Handbooks, the Bay Area Preamble to the California Storm Water Best Management PractIce Handbooks and New Development RecommendatIons, the BASMAA New Development Subcommittee meebngs, mmutes, and dlstnbuted mfonnatlon, and RegIOnal Board staff RegIOnal Board staff also have fact sheets and other mformatIon avaIlable for a vanety of structural storm water treatment controls, sllch as grassy swales, porous pavement and extended detention ponds . . 6 () () () STATE OF CALIFORNIA BUSINESS TRANSPORTATION AND HOUSING AGENCY RECEIVED GRAYDJlVIS Governor DEPARTMENT OF TRANSPORTATION POBOX 23660 OAKLAND CA 94623-0660 r,,1 (510) 286-4444 Fax; (510) 28&-5513 TOO (S10) 266-4454 ~ 131999 ~ DUBLIN PtANNING ~ December 9, 1999 ALA580609 ALA-580-1794 SCH#99l 12040-42 Ms Anne Kmney Planmng Department CIty of Dublm 100 CIVIC Parkway Dubhn, CA 94588 Letter 9 Dear Ms Kmney DublIn Ranch - Plannmg Areas "F" "G"and "H" (Fde No P A 98-068) Thank you for mcludmg the CalIforrua Department of TransportatIon (Caltrans) m the envrronmental reVIew process for the above-referenced proJect We have reVIewed the IrutIal Study and MItIgated NegatIve DeclaratIOn and have the followmg comments to offer The traffic llTIpacts dIscussed m the document are dependent on the accuracy of the forecastmg used. such as trIp generatIon and dIstrIbutIOn WhIle we are pleased to see the mclusIOn of IIDtIganon measures for known nnpacts at thIS tIme, we would hke to keep watch over traffic and congestIOn problems as development contmues As the office, commerCIal, retaIl, and reSidentIal development occurs, a more speCIfic and detailed traffic llTIpact analYSIS should be carned out for projects Wltlun the DublIn Ranch areas, all of WhICh are close to 1-580 Please contmue to keep us Informed of the progress on these proJects Should you requITe further mformahon or have any questIons regardmg thIS letter, please call Paul Svedersky of my staff at (510) 622-1639 Smcerely, HARRY Y YAHA. T A DIstnct DIrector By~a~ JEAN C R FThINEY Dlstnct Branch ChIef IGR/CEQA ..... -........ - c State Cleannghouse DUBLIN S.~ RAMON SERVICES DISTRICT 70" 1 Dublm 13o...1ltl dfd Dubhn Cd.Ufoml.o. G..j5GS F J0... 925 b29 1180 . 9258260515 December 13, 1999 A.nne Kmney, Assistant Planner CIty of Dublm ] 00 CIVIC PJaza DublIn, CA. 94568 SubJ ect Letter 10 Imtlal Studles/Mlllgated NegatIve DeclaratIOns SpecIfic Plan Amendments and Stage I and 2 Development Plans for Eastern Dublm Plannmg Areas "F, G and H" Dear Ms KUU1ey . We have reviewed the Irutlal Studlesllv1rllgated Negative DeclaratIOns for these projects and would lIke to offer the followmg comments Although our comments do not appear to reqUlre slgmficant reVISIOns of the documents and do not change any of the conclUSIOns regardmg Impacts nor mItIgatIOns, we feel the publIc record must be made complete by the submIssIOn of these comments 10 1 1 10 2 2 Page 4 states that "\Vhen and where avaIlable recycled water \Nlll be provlded for lITlgatlon purposes Please note that the DIStnCt has made sIgruficant progress m provIdmg recvcled water to the Eastern Dublm plan area smce the tIme of certIficatIOn of the EIR Potable water systems have been master planned for the proJect area contmgent on supplymg recycled water to approved landscape demands such as common areas, parls and medIans Use of recycled ""ater sIgruficantly reduces the sIzmg reqmrements for potable \\ ater facIhlles and the DIstnct does not conSIder recycled \\ater servIce an optlonal uhlrtv dependent on further study Recycled \\ater WIll be an mtegral element of the Vlater supply for the project area It IS fully antlcIpated that recycled Vlater w1l1 be prOVIded to the proJect area at the trme of development Paragraph "b ' 10 the Attachment sectIOn (page 47 m the Area "Q" IS) states lInes Will be e>..'tended from the ~ast In fact all sewer lInes WIll be e>..ten~~e-EfV~ . u c. "" .-:: 1 1999 OL3dN PLANNING The DubllrL San karnlJf1 St:r.....L~es DtS'\..ilC"L 1S.oJ P'Ublll;; Enll1y c() () (f) Ms Anne Kmney CIty ofDubhn December 13, 1999 Page 2 west, and potable water lInes wIll also be e>.1ended from the south _1 0_ 3 3 Paragraph "e" (Page 4 7 m the Area "G" IS) states that wastewater treatment capaCIty ofthe wastewater treatment plant (WWTP) IS adequate for the project Although thIS IS m fact true, the DIstnCt IS currently e>.pandmg wastewater treatment capaCIty through ImplementatIOn of the "Stage IV" Improvements plan at the WWTP FaCIlIties Will be completed m year 2001 Also, the L.<\ VWM.<\ wastewater dIscharge faCIlItIes are bemg expanded, deSign IS underway and a financmg plan has been approved by the member agenCIes Thank you for provIdmg these documents to us for review and comment If you have any questIOns please contact me at 551-7230, ext 110 Smcerely, ~~ ~~ (~~ {/7- --- Bruce W Webb, Engmeenng Planner Cc JIm Templeton Bob Gresens Rhodora BIagtan FIle 806-02 DP98-068 Area F G H Cbron H \ENGDEPT\DEPTSTUF\PLANNER\CEQA "'mneyltr doc () f3) . RESOLUTION NO 00- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DUBLIN APPROVING A GENERAL PLAN AMENDMENT AND AN AMENDMENT TO THE EASTERN DUBLIN SPECIFIC PLAN FOR DUBLIN RANCH 'AREA If' (pA 98-068), 'AREA G' (pA 98-069) AND 'AREA H' (p A 98-070) WHEREAS, Ted FaIrfield, representmg property owner JennIfer Lm et ai, has requested approval to amend portIOns of the General Plan and the Eastern Dublm Specific Plan, whIch would I Relocate vanous land uses and acreages WItlnn Areas F, G and H of DublIn Ranch on land generally located east of TassaJara Road and North ofI-580 WItlnn the Eastern DublIn SpecIfic Plan area (APN 985-0005-001,985-0005-002) as shown on ExhIbIts A and B General Plan and Eastern DublIn SpecIfic Plan Land Use Map and Eastern DublIn SpecIfic Plan Planmng Subareas Map Land use changes Include relocatmg all of the MedIUm HIgh DenSIty ReSldentlal, HIgh DenSIty Resldentlal, and NeIghborhood CommercIal uses WithIn Area F to Area G These three land uses would be replaced With MedIum DenSIty ReSidentIal uses WithIn Area F The NeIghborhood CommercIal uses wInch are currently shown along both Sides of Central Parkway (prevIOusly the "TranSIt Spme") would be relocated to Area G and reorIented m a north-south dIrectIOn between DublIn Boulevard and Central Parkway along MaIn Street 2 Amend text m the Land Use element of the General Plan and Eastern DublIn SpeCIfic Plan to delete references to the "TranSIt Spme" and replace It With eIther "Central Parkway" or "Mam Street" as approprIate, m accordance With Resolution No 77-97 TIns Resolution was approved by the CIty Council on June 17, 1997 to amend the CIrculatIOn element of the General Plan and Eastern Dublm SpeCIfic Plan TIns Amendment reclassIfied the "TranSIt Spme" from a transIt- onented comdor to an east-west artenal and renamed It "Central Parkway" (EililbIt C EDSP Text Amendments) 3 Amend text m the General Plan and Eastern Dublm SpeCific Plan, to allow Campus Office uses be developed on 10 5 acres of land deSignated for General CommercIal uses WithIn the south- west quadrant of Area H, pursuant to a Stage 2 Planned Development (PD) Rezone (Eililblts C and D EDSP and GP Text Amendments) 4 Update AppendIX 4 "Eastern DublIn SpeCific Plan Land Use Summary By Land Owner", #19 Pao-Lm (also know as Areas F, G and H, now owned by Jennifer Lm et al) (ExhIbit E) WHEREAS, a complete appllcatIOn for thIS proJect IS on file WIth the Dubhn Planmng Department, and WHEREAS, the potentIal envIronmental effects of the proposed project have been prevIOusly addressed m the Eastern Dubhn SpeCific Plan EIR (SCH No 91-103064), and WHERES, mdIvIdual Imtlal StudIes have been prepared for each of the three Dublm Ranch Areas (Area F - SCH No 99112040, Area G - SCH No 99112041 and Area H - SCH No 99112042) to evaluate site-specIfic Impacts of the proJect (to a greater level of detatl than m the Program EIR) pursuant to CEQA ATfACHMENT 2 gUIdelInes SectIon 15168 Based on the three ImtIal StudIes, a MItIgated NegatIve DeclaratIon and MItIgated MomtoTlng Program has been prepared for each area WIth the findmg that WIth the ImplementatIOn of MItIgatIon Measures prevIOusly adopted for the Program EIR and WIth SIte specIfic MItIgatIOn Measures contamed m the ImtIal StudIes, as further clarIfied by the Response to Comments, the potentIal SIte-specific Impacts of the proJects would be reduced to a level of mSlgmficance The . Program EIR and ImtIal StudIes adequately descnbe the Impacts of the proJect, and there have been no substantIal changes or new mformatIon that would be outside the scope of the Program EIR, and WHEREAS, the PlannIng CommISSIOn did hold a properly noticed publIc heanng on SaId applIcatIOn on December 14, 1999, January 11,2000 and January 25, 2000 and dId adopt a ResolutIOn recommendmg that the CIty CouncIl approve a General Plan Amendment and an Amendment to the Eastern Dublm SpecIfic Plan for Area F (P A 98-068), Area G (P A 98-069) and Area H (P A 98-070), and WHEREAS, a properly notIced publIc heanng was held by the CIty CouncIl on February] 5, 2000, and WHEREAS, a Staff Report was submItted recommendmg that the CIty CounCil approve the proposed General Plan Amendment and Amendment to the Eastern DublIn SpeCIfic Plan, and WHEREAS, the City CounCIl dId hear and use theIr mdependent Judgment and conSIdered all SaId reports, recommendatIOns and testImony heremabove set forth NOW, THEREFORE, BE IT RESOLVED THAT the DublIn CIty CounCIl does hereby find that ] The proposed Amendments are conSIstent WIth the goals, general provlSlons and purpose of the . Dublm General Plan and the Eastern DublIn SpeCIfic Plan as proposed to be amended herem, and 2 The relocatIOn of land uses and acreages WIthm Areas F, G and H of Dublm Ranch are appropnate for the subject property m terms ofland use compatibilIty and configuratIOn and wIll prOVIde a comprehensIve plan for the development of Areas F, G and H, and 3 The amended land uses and text would allow the development of Mam Street, a pedestnan onentated retatl and servIce center WItlnn walkmg dIstance ofIngh and medIum hIgh denSIty reSIdences as reflected on the Development Plan mcluded as a part of ExhIbIt B to the Staff Report These changes are appropnate based on analYSIS m the staff report, WIll proVide a development pattern conSIstent With the SpecIfic Plan goals, and Will help Implement polICIes of the General Plan and EDSP regardmg development m Eastern Dublm, and 4 The amended text would allow Campus Office uses be developed on 10 5 acres of land deSIgnated for General CommerCIal uses wItlnn the south-west quadrant of Area H, pursuant to a Stage 2 Planned Development (PD) Rezone The change to thIS land use IS appropnate based upon analYSIS 10 the staff report, WIll result m more effiCIent use of land mime WIth mark.et condItIons, WIll prOVide a development pattern conSIstent WIth the SpeCIfic Plan goals, and wIll help Implement polICIes of the General Plan and EDSP regardmg development m Eastern Dublm, and . 5 The reVIsed AppendIX 4 "Eastern DublIn SpeCific Plan Land Use Summary By Land Owner", #19 Pao-Lm represents updated mformatIOn regardmg land uses and acreages wlthm the Pao-Lm 2 ~ () I) property (also know as Areas F, G and H, now owned by JennIfer Lm et al) of the Eastern Dublm SpecIfic Plan area BE IT FURTHER RESOL VED THAT THE Dublm CIty CouncIl does hereby approve a General Plan Amendment and an Amendment to the Eastern Dubhn SpecIfic Plan, as shown on ExhIbIts A, B, C, D, E and F to the Staff Report for the February 15,2000 CIty CouncIl meetmg for PA 98-068, P A 98-069 and P A 98-070 PASSED, APPROVED AND ADOPTED thIS 15th day of February, 2000 AYES NOES ABSENT Mayor ATTEST City Clerk. g \98068\CCRESOGP 3 c cO .....-< ~ U r.;:::: ...... u (l.) 0.. 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OJ> ~ ~ ~ ~~s::~ (3 a ~ "'" 8. < c u !il 13 ~ UJ]~.:g < ~ 1 ~ ~ '8 al::I: en o::l a'd~~~ 15 ~ ~ z ~ ~~ U-l o ~ :5 N ~ o (]ti o u ~ :I: u Cj I I I I I I I 0 I I U I I I ) 0 I aJ I l\.) I I I ...... I I I 0 I I U --- U , Cj , , , , '" u ;: ~ e, ~ 0 ::c 7 <> ~ ~ ~ ~ ~ ~ C:LJ ~ M '" '" ~ ~ ~ <L ~ ~ ~ . . . () Eastern Dublm Specific Plan Amendmen.t- Dublm Ranch Project Applncall:lOHls Area IF - P A 98-068, Area G - P A 98-069 &. Area H - P A 98-070 The followmg are proposed amendments to the Eastern Dublm SpecIfic Plan as part ofPA 98-068, PA 98~069 and P A 98-070 I A reVISion to the Eastern Dublm SpecIfic Plan Land Use Map (FIgure 4 I) of the EDSP dated January 7, 1994 to rearrange land uses The revIsed portIon of the map IS attached as Exhlblt A 2 A reVlSlOn to the Eastern Dublm SpecIfic Plan Planmng Subareas Map (FIgure 4 2) of the EDSP dated January 7, 1994 to rearrange the boundanes of the subareas The revIsed portIOn of the map IS attached as ExhIbIt B ..., .) A Text Amendment to Chapter 3 of the Eastern Dublm SpeCIfic Plan relatmg to land use categones, the TranSit Spme and east-west vehIcular connectIOns () 333 Land Use Categones, Commercial Second Paragraph, RIght Column Note There are several areas mdIcated on the land use map that could develop as eIther general commerCIal or campus office uses This fleXIbIlIty has been proVIded m these key areas to respond to changmg market condItIOns that may occur m the future The sInft from eIther campus office or general commerCIal (the underlymg land use deSIgnatIOn) to general commerCIal or campus office would be permitted If the establIshed traffic levels of servIce are not exceeded Appropnate traffic studIes may need to be conducted m order for the City to make the proper determmatIon regardmg traffic levels of service <II' 34 1 Streets and HIghways Thud Paragraph The major east-west roads are Dublm Boulevard, provldmg a connectIOn to central Dublm and North Canyons Parkway III Livermore, afl:4 Gleason Road, and Central Parkwav whIch WIll accommodate predommantly local tnps () 3 4 2 Public TranSIt PublIc tranSIt opporturutIes Will be maxImIzed for eastern Dubhn reSIdents Local tranSIt service IS to be proVIded to all land uses With connectIons to regIOnal tranSIt, such as BART Tho Plan deSignates the cast VlcSt Clomdor... mIdway set'.vecn Dubhn BOllleyard.....and Gleason Dr!'. 0 as a "tranSIt S}3IFl~" nus eorns0r, which cJ[teFlds acro 5S the WIdth of the plar..B.lflg area, \\ IlllmL the IOWA Center to the futHrc East Dublm R".RT sta-tlElFl and downtO\Vf1 D1:tBhFl The tranSIt spme IS It IS also planned to construct '''Mam Street" m a north-south onentatIOn through fef the Town Center (nlld '1. ay to run between Dublm Boulevard and Central Parkway) f.tftEl. fResldentIaI and CommerCIal employment use~ ~ Will beefi concentrated along the COrrIdor "Mam Street' to encourage tranSIt use for local and regIOnal travel 'MalD Street" The COrrIdor also lIes wIthm easy walkmg EXHIBIT C OF ATTACHMENT 2 distance of over half the resIdences m eastern Dublm AdvIsory desIgn gUldelmes which . encourage tranSIt use are proposed for bus shelters and tranSIt stops 36 Commumty DesIgn SIXth paragraph, left Column, page 19 The gUldehnes for the ClIcuJatlOn System (pedestrIan and bIke paths, and streets, and TranSIt ~) focus on creatmg commuruty and subarea IdentIty, encouragIng pedestrIan use, and protectmg senSItIVe natural and visual resources 4 A Text Amendment to Chapter 4 of the Eastern Dublm SpecIfic Plan relatmg to the arrangement of land uses and the character of commercIal areas 45 1 LocatIOn Policy 4-11 Concentrate reglOnally-onented commerCIal uses south of Dublm Boulevard and near freeway mterchanges where convenIent vehIcular access wIll lImIt traffic Impacts on the rest of eastern Dublm Note There are several areas mdIcated on the land use map that could develop as eIther general commerCIal or campus office uses ThIS fleXibIlIty has been prOVided In these key areas to respond to changIng market condItIOns that may occur m the future The shIft from eIther campus office or general commercIal (the underlymg land use deSIgnatIOn) to general commerCIal or campus office would be permItted If the establIshed traffic levels of service are not exceeded ApproprIate traffic studies may need to be conducted m order for the CIty to make the proper determmatlOn regardmg traffic levels of servIce . Third paragraph left column, page 28 CommuDlty --Qnentated commerCIal development IS planned for three mIxed-use commerCial centers, each of WhICh IS centrally located to a reSIdentIal area These centers are the Tov.m Center (along TassJara Road between DublIn Boulevard and Gleason Dnve and alone' Malll Street" between Dublm Boulevard and lust north of Central Parkway), and the VIllage Centers (located at the north and south ends of Fallon Road Pohcy 4-15 Concentrate pedestnan-onented commerCIal uses along , Mam Street' the trJUSl! 5j*fte and at key tranSIt transfer pomts 4 8 2 CommerCIal General CommerCial After FIrst Paragraph Note There IS one area mdIcated on the amended land use map located on the south-west quadrant of Area H of Dublm Ranch that could develop as eIther eeneral commerCial or campus office uses ThIS fleXibIlIty has been proVided m thIS area to respond to chanemg market conditions that mav occur m the future The ShIft from general commerCial (the underlvmg land use deSIgnatIOn) to campus office would be penmtted lithe estabh<;hed traffic levels of service are not exceeded Appropnate traffic studIes may need to be conducted m order for the CIty to make the proper determmatlOn reeardmg traffic levels of service The development of eIther general commerCIal or campus office uses WIll be establIshed at the Stage 2 Planned . Development applIcatIOn process 484 Parks and Open Space Second Paragraph, RIght Column, third lme Replace "TranSIt Spme" With "Central Parkway" 2 C{) 4 9 2 Town Center - Commercial LocatlOn The Town Center-CommercIal subarea conSIsts of two lInear t5-a4-shaped area~ located adJacent 3J1d perpendIculm- to TassaJara Road and "MaIn Street" The subarea extends north-south along TassaJara Road from Dublm Boulevard to Just north of Gleason Drive and north-south along "MaIn Street" from Dublm Boulevard to lUst north of Central Parkway \1Idv.a) between thcse tv,o roadwa-ys the subarea e](tends approumately % mIle eastward along J street desl;:;natcd as the tranSIt spmc (see figure 4 1) Second Paragraph, rIght column, page 36 The Neighborhood CommerCIal area, which extends along both sIdes of the tranSit spme' Mam Street", In Intended as a more pedestrIan-onented <:;ervIce, retaIl, commerCial and entertamment center servmg the dally needs of the reSIdentIal neIghborhood surroundmg It and the more mtenmttent shoppmg, entertatnment and servIce needs of the larger communIty CI) Fourth Paragraph, nght column, page 36 The subarea has an area north of the mtersectlOn of"Mam Street" and Central Parkway and an area west of the mld-pomt of "Mam Street" near the mIdpomt of the transit sfHnl'l whIch IS deSIgnated for PublIc/SemI-Public uses The mtent IS that tlHs these area~ be developed WIth some combmatlOn of commumty-servmg uses that WIll provIde a publIc focus at the heart of the Town-Center Such uses mIght mclude a performmg arts center, lIbrary, commuruty center, post office or some other commumty faCIlIty It IS antICIpated that the uses m t}:llS area the Town Center would adJom a pubhc plaza that could accommodate publIc ceremorues, events, and less formal gathenngs WIthm the Town Center 5 A Text Amendment to Chapter 5 of the Eastern Dublm SpecIfic Plan relatmg to the transportatIOn and cIrculatIOn systems wIthm Eastern Dublm Second Paragraph, left Column, page 53 It is also planned to construct Mam Street (two lanes) m a north-south onentatIon through the future Eastern Dublm Town Center (mId1,\uy runnIng between Dublm Boulevard and Central Parkway) The Mam Street mIrumum nght-or-way shall be ':/id 64 feet wIDch mcludes ~ lan8sElupe area and +4 12 foot pnvate SIdewalks on both Sides WIth 4' public utlhtv easements behmd the curb face for street lights fire hvdrants, etc ,A~ddltIOnal n;:;ht ef \Va) 'n'lll bc needed for addItIonal turn lanes 6 A reViSIOn to the Eastern Dublm Specdic Plan Town Center Concept Plan (FIgure 7 1) of the EDSP dated January 7, 1994 to rearrange land uses (refer to ExhIbit F) The reVIsed portlOn of the map IS attached Chapter 7 of the EDSP dISCUSS "GUldelmes" for Town Center CommunIty DeSIgn WIDch are adVISOry only The SpeCIfic Plan makes prOVISIon for the CIty to consJder "eqUIvalent or superior methods of deSIgn to achieve the obJectIves of the plan" As these Items are GUIdelmes only and the project meets the SpIrIt and mtent of the SpeCific Plan, no teAt amendment is proposed 7 A Text Amendment to AppendIX 4, Eastern DublIn SpeCIfic Plan Land Use Summary by Landowner, #19 Pao-Lm (also Know as Areas F, G and H, now owned by JennIfer Lm) IS attached as E>JubIt E CID G \pa\98068\EDSP Amendments 3 IJ tD ~ GENERAL PLAN AMENDMENT IDllllbhlrn Ranch Project AplPhcatnons Area IF - lP A 98-068, Area G - P A 98-069 & Area JH[ - P A 98-070 The followmg are proposed amendments to the General Plan as part ofPA 98-068, PA 98~069 and P A 98-070 1 A reVISIOn to the General Plan - Eastern Extended Planmng Area Land Use Map (FIgure 2 B) of the General Plan dated May 10, 1993 to rearrange land uses The reVised portlOn of the map IS attached (ExhIbIt A) 1 8 1 Land Use ClaSSIficatIOn Eastern Extended Plannmg Area CommercIal! IndustrIal Page 8, msert after first paragraph Note There IS one area mdIcated on the amended land use map located on the south- west quadrant of Area H of Dublm Ranch that could develop as eIther general commerCIal or campus office uses ThIS fleXIbIlItv has been provIded m thIS area to respond to changmg market condItlOns that mav occur m the future The ShIft from Qeneral commerCIal (the underlvmQ land use deSIgnatIOn) to campu<; office would be permItted If the estabhshed traffic levels of service are not exceeded ApprOPrIate traffic studIes may need to be conducted In order for the CIty to make the proper determmatlOn reQardmg traffic levels of servIce The development of eIther general commerCial or campus office uses Will be establIshed at the Stage 2 Planned Development apphcatlon process G \pa\98068\GPA EXHmiT D OlF ATfACHMEN'f 2 C{) APPENDIX 4 EASTERN DUBLIN SPECIFIC PLAN LAND USE SUMMARY BY LAND OWNER ({) #19 P AO-LIN (AREAS F, G & H) Acres DensIty Sq Ft DOlts General CommercIal * 269 25 292,941 NeIghborhood CommerCIal 220 35 230000 Campus Office 439 45 860,528 PublIc/SemI-PublIc 70 25 76,230 High DensIty ReSIdentIal 250 35 876 MedIUm HIgh DensIty ResidentIal 262 20 528 Medium Density ReSIdentIal 689 10 689 Smgle FamIly ResidentIal 227 4 91 NeIghborhood Park 123 Neighborhood Square 45 Elementary School 100 HIgh / MIddle School 306 Open Space 42 Total 3042 1,459,699 2,184 * 10 5 acres of General Commercial located In the south-west quadrant of Area H (refer to amended Land Use Map) may be used for Campus Office Uses pursuant to a Stage 2 Planned Development (PD) ApplIcatIOn Process If Campus Uses are constructed on the 10 5 acres, the maximum square footage would be 205,821 sq ft g planmng\pa98 068\APPENDIX 4 co lEXH][B][T lE OF ATTACHMENT 2 ~ N j ~ s: = E-< !r jf ii ,e d Z 00 w ~& I Jl5 · d fS t ::;E I! 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