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Exhibit B to Attachment 7 IKEA Retail Center Fi NORTH AMERICA | EUROPE | AFRICA | AUSTRALIA | ASIA WWW.FIRSTCARBONSOLUTIONS.COM FINAL Supplemental Environmental Impact Report IKEA Retail Center Project City of Dublin, Alameda County, California State Clearinghouse Number 2017082047 Prepared for: City of Dublin 100 Civic Plaza Dublin, CA 94568 925.833.6610 Contact: Amy Million, Principal Planner Prepared by: FirstCarbon Solutions 1350 Treat Boulevard, Suite 380 Walnut Creek, CA 94597 925.357.2562 Contact: Mary Bean, Project Director Grant Gruber, Project Manager Janna Waligorski, Project Manager Date: September 14, 2018 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Table of Contents FirstCarbon Solutions iii Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec00-01 TOC.docx Table of Contents Section 1: Introduction ............................................................................................................... 1-1 Section 2: Master Responses ....................................................................................................... 2-1 2.1 - Master Response ............................................................................................................ 2-1 Section 3: Responses to Written Comments ................................................................................ 3-1 3.1 - List of Authors ................................................................................................................ 3-1 3.2 - Responses to Comments ................................................................................................ 3-2 Section 4: Errata.......................................................................................................................... 4-1 4.1 - Changes to Draft EIR Text ............................................................................................... 4-1 Appendix I: Supplemental Air Quality Supporting Information THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Introduction FirstCarbon Solutions 1-1 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec01-00 Introduction.docx SECTION 1: INTRODUCTION In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of Dublin has evaluated the comments received on the IKEA Retail Center Project Draft Supplemental Environmental Impact Report (SEIR). The responses to the comments and errata, which are included in this document, together with the Mitigation Monitoring and Reporting Program, form the Final SEIR for use by the City of Dublin in its review. This document is organized into four sections: • Section 1—Introduction. • Section 2—Master Responses. Provides a single, comprehensive response to similar comments about a particular topic. • Section 3—Responses to Written Comments. Provides a list of the agencies, organizations, and individuals who commented on the Draft SEIR. Copies of all of the letters received regarding the Draft SEIR and responses thereto are included in this section. • Section 4—Errata. Includes an addendum listing refinements and clarifications on the Draft SEIR, which have been incorporated. The Final SEIR includes the following contents: • Draft SEIR (provided under separate cover) • Draft SEIR appendices (provided under separate cover) • Master Responses, Responses to Written Comments on the Draft SEIR, and Errata (Sections 2, 3, and 4 of this document) • Mitigation Monitoring and Reporting Program (provided under separate cover) THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Master Responses FirstCarbon Solutions 2-1 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec02-00 Master Responses.docx SECTION 2: MASTER RESPONSES Master responses address similar comments made by multiple public agencies, businesses, organizations, or individuals through written comments submitted to the City of Dublin. 2.1 - Master Response Master Response 1—Project Merits Summary of Relevant Comments The City of Dublin received numerous written comments about the merits of the IKEA Retail Center Project. The majority of these comments expressed opposition citing traffic congestion, sub-optimal use of the site, public safety, and community image. None of the comments raise questions about the sufficiency of the Draft SEIR’s analysis of environmental impacts. Response The comments primarily express a position on the merits of the proposed project—whether or not the City should approve the project. Several letters make reference to environmental impacts of the Project identified in the EIR as a reason for not approving the Project. Some of the environmental impacts of the project referenced in the comments include traffic and aesthetics. However, the comments recite the conclusions from the SEIR, and do not offer any comments on the adequacy of the analysis itself. With regard to comments referring to the EIR’s conclusions on traffic impacts, traffic is evaluated in detail in Section 3.6, Transportation. The evaluation assessed 31 intersections, 39 segments of I-580, 22 segments of I-680, 12 roadways, and three I-580 freeway ramps. The analysis found that the project would have a significant impact on certain intersection, freeway segment, and roadway segment operations. Mitigation was proposed for significant impacts; however, for certain intersections and roadways, the Draft SEIR concluded that traffic impacts would be significant and unavoidable because the mitigation measure is infeasible or its implementation is in the control of another agency. None of the comments challenge or dispute the analysis or conclusions in the SEIR on traffic impacts and mitigation. Because the letters do not specifically question the adequacy of the analysis of environmental impacts in the SEIR and only address the merits of the project, no responses to these comments are required under CEQA. These comments are provided at the end of Section 3, Responses to Written Comments. They will be part of the project record and presented to the City of Dublin decision- makers for consideration prior to acting on the proposed project. Master Response 2—Comments Raising Similar Issues Summary of Relevant Comments The City of Dublin received five letters that contained verbatim or near verbatim comments summarizing the SEIR’s conclusions regarding transportation and other environmental issues and expressing objection to the proposed project. City of Dublin—IKEA Retail Center Project Master Responses Administrative Final SEIR 2-2 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec02-00 Master Responses.docx Response To the extent these letters do not specifically address environmental issues and the adequacy of the SEIR’s analysis, no responses to these comments are required under CEQA. To the extent environmental issues are referenced in the comments, these issues are addressed in the response to individual comment letters. Also, see Master Response 1 for comments addressing the transportation analysis. City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-1 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx SECTION 3: RESPONSES TO WRITTEN COMMENTS 3.1 - List of Authors A list of public agencies, organizations, and individuals that provided comments on the Draft SEIR is presented below. Each comment has been assigned a code. Individual comments within each communication have been numbered so comments can be crossed-referenced with responses. Following this list, the text of the communication is reprinted and followed by the corresponding response. Additionally, the City of Dublin received 105 comments that commented on the project but did not provide comments on any aspect of the Draft SEIR’s analysis. In accordance with CEQA Guidelines Section 15003(g), which provides “The purpose of CEQA is not to generate paper, but to compel government at all levels to make decisions with environmental consequences in mind”, copies of these letters are provided at the end of this section; however, because these letters do not contain comments specific to the analysis contained within the SEIR or any environmental issue, individual responses to these comments are not provided, but instead are addressed in Section 2, Master Responses. Author Author Code State Agencies California Department of Transportation ................................................................................. CALTR ANS Local Agencies Alameda County Transportation Commission .................................................................................. ACTC City of Pleasanton ............................................................................................................... PLEASANTON Dublin San Ramon Services District ............................................................................................... DSRSD Organizations/Multiple Parties Adams Broadwell Joseph & Cardozo .................................................................................................... AB California Native Plant Society ......................................................................................................... CNPS Lozeau Drury ......................................................................................................................................... LD Individuals Tom Cignarella ...................................................................................................................... CIGNARELLA Liana deWit-Smith ............................................................................................................. DEWIT-SMITH Tammy Ficarra ............................................................................................................................ FICARRA Jeff Gebel ........................................................................................................................................ GEBEL Chenin Gonzales ...................................................................................................................... GONZALES John Heyer ...................................................................................................................................... HEYER Mike Kaube .................................................................................................................................... KAUBE Lianne Marshall ...................................................................................................................... MARSHALL City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-2 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Jegadheesa Murugesa ........................................................................................................... MURUGESA Chris Page ......................................................................................................................................... PAGE Feroza Solaiman ...................................................................................................................... SOLAIMAN Rupert Young ................................................................................................................................. YOUNG 3.2 - Responses to Comments 3.2.1 - Introduction In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of Dublin, as the lead agency, evaluated the comments received on the Draft SEIR (State Clearinghouse No. 2017082047) for the IKEA Retail Center Project, and has prepared the following responses to the comments received. This Response to Comments document becomes part of the Final SEIR for the project in accordance with CEQA Guidelines Section 15132. 3.2.2 - Comment Letters and Responses The comment letters reproduced in the following pages follow the same organization as used in the List of Authors. CALTRANS Page 1 of 3 1 2 2 CONT 3 4 5 CALTRANS Page 2 of 3 6 CALTRANS Page 3 of 3 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-7 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx State Agencies California Department of Transportation (CALTRANS) Response to CALTRANS-1 The agency provided introductory remarks to open the letter. No response is necessary. Response to CALTRANS-2 The agency summarized the project. No response is necessary. Response to CALTRANS-3 Mitigation measures were identified to mitigate the project’s impacts to the freeway system, including preparation and implementation of a transportation demand management program (MM TRANS-4a) to reduce the overall vehicle trip generation from the levels considered in the analysis, and payment of all local and regional transportation impact fees. Local fees include improvements to City of Dublin streets and intersections, and regional fees include regional roadway facilities as well as a number of Caltrans facilities. (Please see Response to ACTC Comment 7 for additional details related to the fee programs that apply to this project.) Many of the improvements noted in the SHOPP program, which is referenced in Caltrans letter, are upgrades of existing facilities that do not meet current design standards, or roadway rehabilitation, which would not mitigate the project’s impacts to the freeway system. Caltrans should coordinate with the Tri-Valley Transportation Council to identify additional regional projects that could be included in the regional fee program, as well as develop an Integrated Corridor Management Plan for Interstate 580 (I-580) in the Tri-Valley area such that corridor improvements can be identified and programmed into the regional fee program. Caltrans prepared the Interstate 580 East Corridor System Management Plan in May 2010, which identifies a number of corridor improvements from I-880 to I-205. In the study area, none of the identified improvements would mitigate project impacts, with the exception of some interchange improvements, which have been incorporated into the regional fee program and already considered in the Draft SEIR findings. Response to CALTRANS-4 Please refer to Response to ACTC-3 and Response to ACTC-10. Response to CALTRANS-5 The agency noted that the City of Dublin is responsible for all project mitigation. Implementation and monitoring of mitigations will be identified in the Mitigation Monitoring and Reporting Program adopted as part of the any Project approval. Response to CALTRANS-6 The agency provided closing remarks to conclude the letter. No response is necessary. THIS PAGE INTENTIONALLY LEFT BLANK ACTC Page 1 of 3 1 2 3 ACTC Page 2 of 3 3 CONT 4 5 6 7 8 9 10 ACTC Page 3 of 3 11 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-13 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Local Agencies Alameda County Transportation Commission (ACTC) Response to ACTC-1 The agency provided introductory remarks to open the letter. No response is necessary. Response to ACTC-2 The City of Dublin has updated ACTC’s contact information to its project notification list and the agency received the notice of the availability of the Final SEIR and public meetings. Note that the Draft SEIR evaluated ACTC regional roadways in Section 3.6 (Transportation) in Impact TRANS-5, and, therefore, the City’s intent from the outset was to ensure that ACTC’s area of jurisdiction was addressed in the document. Response to ACTC-3 As part of Mitigation Measure TRANS-4a, the project applicant is required to prepare and implement a transportation demand management (TDM) plan with measures targeted to site employees as well as patrons. This plan shall be reviewed and approved by the City of Dublin, and the project applicant shall be responsible for all costs associated with developing, implementing and monitoring the plan. The plan will identify TDM goals and strategies for employees as well as patrons, with provisions for monitoring. Response to ACTC-4 An evaluation of the operations of the I-580 Express Lanes were not conducted as these lanes are dynamically priced to maintain free-flow operations. Any increase in the demand for this facility by the Project would be counterbalanced by an increase in pricing to maintain the same demand before and after the Project is built. Since the demand for the Express Lanes would remain the same before and after the Project due to dynamic pricing, demand changes from the Project only affect the general purpose lanes and these impacts and mitigations are covered in the SEIR. The SEIR assesses potential project impacts on State Route 84 (SR-84) between Airway Boulevard and I-680. SR-84 is referred to as Isabel Avenue between Airway Boulevard and Vallecitos Road, and as Vallecitos Road between Isabel Avenue and I-680. A significant impact was identified on Isabel Avenue (SR-84) between Stanley Boulevard and Concannon Boulevard in the year 2040, as presented on Draft SEIR page 3.6-164, and mitigation measures were identified. No additional analysis is required. Response to ACTC-5 The comment accurately describes Table ES-2. No additional response necessary. Response to ACTC-6 The agency is referring to the freeway analysis, which correlates freeway density to LOS. The Highway Capacity Manual (2010) states on page 11-7 that “LOS F is identified when demand exceeds capacity because the analytic methodology does not allow the determination of density when demand exceeds capacity.” Therefore, the actual density numbers are not provided. For freeway locations that are projected to operate at LOS F, significant impacts were identified where the project added trips to the location. Since the impact is not directly tied to the increase in density, the density calculations would not change the overall findings presented in the Draft SEIR. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-14 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to ACTC-7 The Eastern Dublin Traffic Impact Fee (local) is calculated on a per average weekday vehicle trip basis. Funds deposited into the Eastern Dublin Traffic Impact Fee would be applied to improvements on local roads owned and maintained by the City of Dublin, including projects such as the Scarlett Drive Extension between Dougherty Road and Dublin Boulevard. Detailed information about the program can be found on the City’s website: http://www.dublin.ca.gov/1330/Fee-Schedule. The Tri-Valley Transportation Development Fund (regional) is calculated from average peak-hour vehicle trips. Funds deposited into the Tri-Valley Transportation Development Fund would be applied to planned improvements on the regional transportation system, such as improvements to SR-84, auxiliary lanes on I-680, and safety improvements on Vasco Road. Details regarding the program are provided on the Tri-Valley Transportation Council website: http://www.tvtc- jpa.com/getattachment/f2a953a0-7122-49de-8e69-d729654a5840/TVTC-Fee-Schedule.aspx. Mitigation Measure TRANS-4c is the fair share contribution towards the installation of an additional mixed-flow on-ramp lane from southbound Hacienda Drive to westbound I-580. The fair-share contribution will be calculated based on an estimate of the total project cost, the level of existing traffic (as the location is currently deficient), the projections of non-project added traffic, and the amount of project-added traffic. This improvement is not included in either the Eastern Dublin Traffic Impact Fee or the Tri-Valley Transportation Development Fund. Should the project be added to either fee program, payment of fees would constitute a fair share contribution. Response to ACTC-8 Trip generation estimates for the IKEA portion of the project were developed based on surveys of three existing IKEA stores over multiple days. Trip generation estimates for the other retail uses were developed using trip generation rates in the Transportation Engineers (ITE) Trip Generation Manual, (9th Edition). Information contained in the ITE Trip Generation Handbook and surveys of similar uses were used to estimate pass-by and diverted-link trips for the general retail portion of the project only. For general retail, the average pass-by rate is 34 percent, and the average diverted linked trip rate is 16 percent during PM peak hour (limited data is available for the AM peak hour). In other words, at a typical shopping center, approximately 50 percent of the traffic entering and exiting the site is already on the surrounding roadway system. Studies have also shown shopping centers with more than 50 percent pass-by/diverted trips. For this assessment, it was assumed that pass-by/diverted trips for the retail/restaurant portion of the project would comprise 50 percent of the trip generation on a daily basis and 30 percent on a peak-hour basis. Pass-by/diverted trips are fully captured in the analysis of project site access locations, as well as on the deviated route. IKEA is not a typical retail store, as it attracts trips as their primary destination from a larger catchment area than typical retail centers. This creates the potential that some patrons who come to the site primarily for IKEA would also patronize the other retail/restaurant establishments. Internal capture rates from ITE for general retail land-uses (information is not available specifically for restaurant land-uses, but they are considered similar to the retail uses) estimate that at least 20 percent of retail patrons would already be at the site. For the purpose of the trip generation City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-15 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx estimate, it is expected that up to 20 percent of the restaurant/retail patrons would be at the site already patronizing the IKEA store, or other retail/restaurant use. This reduction was based on data and procedures contained in the ITE Trip Generation Handbook, which yielded a higher than 20 percent internal reduction. To present a conservative assessment of potential project impacts, the internal reduction was capped at 20 percent. Since IKEA does not open until after the AM peak hour, internal capture reductions were not applied to the AM peak hour. As there is limited mid-day peak- hour trip generation information available, the weekday PM peak-hour trip generation was assumed for the midday time period. Response to ACTC-9 The City of Dublin has installed transit signal priority on Dublin Boulevard and plans to install transit signal priority at additional intersections along transit corridors to address bus delays for routes serving the project area. The City has constructed queue jump lanes on westbound Dublin Boulevard at Village Parkway, westbound Dublin Boulevard at Dougherty Road, eastbound Dublin Boulevard at Arnold Road, and on westbound Dublin Boulevard at Tassajara Road, providing an advantage to transit vehicles traveling through the corridor. The potential to construct queue jump lanes at other locations is also being evaluated by the City of Dublin along the corridor. All intersections along Dublin Boulevard (the Rapid Bus Route) are projected to operate at LOS E (the ACTC standard) or better with the incorporation of mitigation measures in the cumulative condition with the project, and most intersections are projected to operate at LOD D or better (the City of Dublin standard). With the availability of existing and planned queue jump lanes and existing transit signal priority, coupled with project mitigation measures which include installation of adaptive traffic signal control to provide better signal coordination along key corridors and intersection improvements, the project is not expected to add a significant amount of delay to transit vehicles on City streets. Express buses that use the freeway system are allowed to use the Express Lane that is dynamically priced to maintain free-flow travel. Although the mainline operation of express buses on I-580 would not be affected by the project, Route 580X does enter/exit the freeway at Hacienda Drive. There is a carpool bypass lane for bus vehicles entering the freeway, and the freeway ramp terminal intersections are projected to operate at acceptable service levels. Bus operations could be slowed in the freeway merge/diverge areas of I-580 westbound at Hacienda Drive during the morning peak hour (diverge area) and I-580 eastbound at the Hacienda Drive interchange in the weekday PM peak hour (merge area). These impacts were identified in the Draft SEIR and no additional analysis is required. The project impact on this segment of Hacienda Drive was identified as less than significant in the weekday AM peak hour. The 70X operates on I-680, north of I-580 where express lanes are provided. Similar to I-580, buses are permitted to use the Express Lanes where dynamic pricing maintains free-flow travel. Response to ACTC-10 The Draft SEIR addresses safety impacts to pedestrians and bicyclists on pages 3.6-168 to 3.6-170, which include mitigation measures that require the applicant to provide bicycle facilities connecting City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-16 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx to the project site, bicycle detection at intersections that provide primary access to the project site, safe and convenient pedestrian access to the project vicinity, even during construction, and contribute to pedestrian and bicycle improvements at the I-580/Hacienda Drive interchange. Additionally, mitigation measures that identified the need for roadway widening beyond the levels already contemplated and approved by the City of Dublin were reviewed for their secondary impact to pedestrians and cyclists. For example, potential secondary impacts to bicycles and pedestrians were identified with implementation of Mitigation Measure TRANS-4c, which would widen the Hacienda Drive on-ramp to provide additional mixed-flow vehicle storage for vehicles could result in secondary impacts to pedestrians and bicyclists by increasing pedestrian crossing distances through the interchange, and bicycle/vehicle conflicts. Mitigation Measure TRANS-8e was then identified to mitigate the secondary impact. Response to ACTC-11 The agency provided closing remarks to conclude the letter. No response is necessary. PLEASANTON Page 1 of 3 1 2 PLEASANTON Page 2 of 3 3 4 PLEASANTON Page 3 of 3 4 CONT 5 6 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-21 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx City of Pleasanton (PLEASANTON) Response to PLEASANTON-1 The agency provided introductory remarks to open the letter. No response is necessary. Response to PLEASANTON-2 The agency listed six roadway facilities within the Pleasanton city limits and identified deterioration of level of service and lengthy queues as its primary concerns with these facilities. The City’s specific concerns are addressed in Response to PLEASANTON-3 through Response to PLEASANTON-5. Response to PLEASANTON-3 The I-580 at Santa Rita Road intersection is projected to operate at a deficient LOS F during the PM peak hour in the near-term condition prior to the addition of project traffic. Based on the significance criteria identified in the Draft SEIR, a significant impact was identified. In instances where the addition of project traffic exacerbates an existing or projected deficiency, it is City of Dublin policy to require a fair-share contribution to the improvement rather than construction of said improvement. In the cumulative condition, the project worsens Saturday peak hour LOS F conditions. The text of the Draft SEIR correctly identifies that the intersection would operate at LOS D with implementation of the improvements; Table 3.6-19 of the SEIR incorrectly indicates that the improvement would result in LOS E operations during the Saturday peak hour. This correction is noted in Section 4, Errata. However, the range of mitigation required to return the intersection to LOS D should have also included the following: either modifying the northbound approach to construct a third eastbound left-turn lane or modifying the southbound approach to provide a third southbound through lane, in addition to re-timing the traffic signal. Section 4 Errata shows the proposed edits to Mitigation Measure TRANS-2c. The effectiveness of modifying Mitigation Measure TRANS-2c to include constructing a third eastbound left-turn lane and associated receiving lane, or a third southbound through lane, is presented in Table 3-1 for the cumulative Saturday peak hour. As shown, the addition of this broader range of improvements would ensure that the project and cumulative impact is reduced to a less than significant level. As indicated in the Draft SEIR, the City of Dublin and the project applicant shall work with the City of Pleasanton, Caltrans, and ACTC to identify feasible improvements at this interchange and contribute their fair share. Table 3-1: Cumulative With Mitigation—Peak Hour Intersection Levels of Service Intersection Control Peak Hour Cumulative Without Project Cumulative With Project Cumulative With Project With Draft SEIR Mitigation Cumulative With Project With Final SEIR Mitigation Delay LOS Delay LOS Delay LOS Delay LOS Santa Rita Road/I-580 Eastbound Off-Ramp Signal Saturday 94.5 F 97.4 F 63.6 E 39.5 D Notes: Bold indicates LOS E/F; Bold italics indicates impacts due to the proposed project Source: Fehr & Peers, 2018. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-22 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to PLEASANTON-4 Mitigation measures for freeway ramp meter impacts considered a tiered approach. The first tier determined whether increasing the ramp metering rates within the allowable range by Caltrans (180 to 900 vehicles per hour) would mitigate the impact. This mitigation is identified as Mitigation Measure TRANS-4b in the Draft SEIR and was found to mitigate the impact at the southbound Dougherty Road to I-580 westbound ramp and southbound Hacienda Drive to I-580 eastbound ramp. Mitigation Measure TRANS-4b would also mitigate the impact at the southbound Hacienda Drive to westbound I-580 in the existing and near-term condition. Caltrans has agreed to work with the City of Dublin to evaluate ramp meter rates along the I-580 corridor. To accommodate cumulative growth, an additional mitigation measure, Mitigation Measure TRANS- 4c, that identifies the provision of a second mixed-flow on-ramp lane was required in the Cumulative condition for the southbound Hacienda Drive to westbound I-580 ramp. Mitigation Measure TRANS-4c in the Draft SEIR identifies the fair-share contribution to the construction of a second mixed-flow on-ramp lane from southbound Hacienda Drive to westbound 580. As this is an existing deficiency, fair-share payment towards improvements will be required in accordance with City of Dublin policy. Response to PLEASANTON-5 As part of the conditions of approval, the project applicant shall be required to prepare a transportation demand management plan that also identifies parking management strategies (refer to Response to ACTC-3 for additional detail). As part of the parking management program, strategies to accommodate special events and peak holiday-season parking demand will be developed and are expected to include provision for off-site employee parking at near-by office campuses on weekends, or valet parking. The project applicant shall be responsible for developing, financing, and implementing the plan, and for securing overflow parking agreements with adjacent property owners, if needed. Although parking is not a CEQA issue, the City recognizes that periods of peak parking demand can create excess vehicle circulation, congestion and driver frustration. The requirement to prepare a parking management plan as part of the conditions of approval, as well as provisions for plan monitoring, allows the City and project applicant to better peak travel flow to and around the project site. Response to PLEASANTON-6 The agency provided closing remarks to conclude the letter. No response is necessary. DSRSD Page 1 of 2 1 2 3 4 5 DSRSD Page 2 of 2 City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-25 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Dublin San Ramon Services District (DSRSD) Response to DSRSD-1 The agency provided introductory remarks to open the letter. No response is necessary. Response to DSRSD-2 The agency noted that Draft SEIR’s page ES-4 identified “Utilities (water and wastewater)” as an Area of Controversy. The agency indicated that the proposed project is within the DSRSD service area and noted that the Draft SEIR concluded that impacts on water and wastewater would be less than significant. The agency concurred with this conclusion. The “Areas of Controversy” portion of the Executive Summary is required by CEQA Guidelines Section 15123(2) and is intended to identify issues raised by agencies and the public. In this case, the City received numerous comments during the scoping process about the adequacy of infrastructure, which is the basis for identifying “Utilities (water and wastewater)” in this context. However, the Draft SEIR’s analysis found that impacts on water and wastewater were less than significant and DSRSD agrees with that conclusion. Response to DSRSD-3 The agency referenced the Impact PSU-5 conclusion that water supply impacts would be less than significant and clarified that even if it does not have adequate recycled water supplies or infrastructure to serve the proposed project’s irrigation needs, these needs can still be met with potable water. No response is necessary. Response to DSRSD-4 The agency referenced a statement on Draft SEIR page 3.5-11 about an important potable water facility being present in the corner of the project site along Arnold Road. The agency noted that this facility serves as a turnout (or connection point) between Zone 7 and DSRSD and that the operation of this facility cannot be restricted or hindered by construction or operation of the proposed project. DSRSD staff advised Dublin city staff and the applicant team of the significance of this facility during the September 7, 2017 scoping meeting and it was noted in the Draft SEIR on pages 2-1, 3.5-11, and 3.5- 25. As stated on page 3.5-25, implementation of the proposed project would not alter this facility. Response to DSRSD-5 The agency provided closing remarks to conclude the letter. No response is necessary. THIS PAGE INTENTIONALLY LEFT BLANK AB Page 1 of 96 1 March 16, 2018 Page 2 4174-003acp printed on recycled paper each of these reasons, the City of Dublin (“City”) may not approve the Project until a revised document is prepared and recirculated for public review and comment. These comments were prepared with the assistance of biological resources expert Scott Cashen and air quality experts Matt Hagemann and Hadley Nolan of Soil Water Air Protection Enterprise (“SWAPE”). Mr. Cashen’s comments are attached to this letter as Exhibit A and his curriculum vitae is attached as Exhibit B. SWAPE’s comments are attached to this letter as Exhibit C, and Mr. Hagemann’s and Ms. Nolan’s curriculum vitae are attached as Exhibit D. Mr. Cashen’s and SWAPE’s are submitted to the City in addition to the comments contained herein. The City must respond to these comments separately and individually. I. Statement of Interest Dublin Residents for Responsible Development (“Dublin Residents”) is an unincorporated association of individuals and labor unions that may be adversely affected by the potential environmental impacts of the Project. The association includes: City of Dublin residents Kris Gallegos, Art Mayberry, Joe Steiner, and Francisco Rosa; the International Brotherhood of Electrical Workers Local 595, Plumbers & Steamfitters Local 342, Sheet Metal Workers Local 104, and their members and their families; and other individuals that live and/or work in the City of Dublin and Alameda County. Individual members of Dublin Residents and the affiliated unions live, work, recreate and raise their families in Alameda County, including in the City of Dublin. These members would be directly affected by the Project’s environmental and health and safety impacts. Members of Dublin Residents may also work on the Project itself. Accordingly, these individuals will be first in line to be exposed to any health and safety hazards created by the Project. Dublin Residents has an interest in enforcing environmental laws that encourage sustainable development and ensure a safe working environment for its members. Environmentally detrimental projects can jeopardize future jobs by making it more difficult and more expensive for business and industry to expand in the region, and by making it less desirable for businesses to locate and people to live there. AB Page 2 of 96 1 CONT 2 March 16, 2018 Page 3 4174-003acp printed on recycled paper II. CEQA REQUIRES THE DISCLOSURE OF ALL POTENTIALLY SIGNIFICANT PROJECT IMPACTS AND THE INCORPORATION OF ALL FEASIBLE MITIGATION MEASURES NECESSARY TO REDUCE SUCH IMPACTS TO BELOW A LEVEL OF SIGNIFICANCE CEQA has two basic purposes. First, CEQA is designed to inform decisionmakers and the public about the potential, significant environmental effects of a project.1 Except in certain limited circumstances, CEQA requires that an agency analyze the potential environmental impacts of its proposed actions in an environmental impact report (“EIR”).2 An EIR’s purpose is to inform the public and its responsible officials of the environmental consequences of their decisions before they are made. In this respect, an EIR “protects not only the environment but also informed self-government.”3 To fulfill this function, the discussion of impacts in an EIR must be detailed, complete, and “reflect a good faith effort at full disclosure.”4 CEQA requires an EIR to disclose all potential direct and indirect, significant environmental impacts of a project.5 In addition, an adequate EIR must contain the facts and analysis necessary to support its conclusions.6 The second purpose of CEQA is to require public agencies to avoid or reduce environmental damage when possible by requiring appropriate mitigation measures and through the consideration of environmentally superior alternatives.7 If an EIR identifies potentially significant impacts, it must then propose and evaluate mitigation measures to minimize these impacts.8 CEQA imposes an affirmative obligation on agencies to avoid or reduce environmental harm by adopting feasible 1 CEQA Guidelines § 15002, subd. (a)(1). 2 See, e.g., Pub. Resources Code § 21100. 3 Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564. 4 CEQA Guidelines § 15151; San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 721-722. 5 Pub. Resources Code § 21100, subd. (b)(1); CEQA Guidelines § 15126.2, subd. (a). 6 See Citizens of Goleta Valley 52 Cal.3d at 568. 7 CEQA Guidelines § 15002, subds. (a)(2)-(3); see also, Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners (2001) 91 Cal.App.4th 1344, 1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 564; Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 391, 400. 8 Pub. Resources Code §§ 21002.1, subd. (a), 21100, subd. (b)(3). AB Page 3 of 96 3 March 16, 2018 Page 4 4174-003acp printed on recycled paper project alternatives or mitigation measures.9 Without an adequate analysis and description of feasible mitigation measures, it would be impossible for agencies relying upon the EIR to meet this obligation. As discussed in detail below, the DSEIR fails to meet either of these two key goals of CEQA. The DSEIR fails to adequately and completely describe the Project and the Project setting and fails to disclose and evaluate all potentially significant environmental impacts of the Project. In addition, it proposes mitigation measures that are unenforceable, vague or so undefined that it is impossible to evaluate their effectiveness. A revised DSEIR must be prepared and recirculated to comply with CEQA’s most fundamental requirements. III. THE DSEIR FAILLS TO ESTABLISH THE ENVIRONMENTAL SETTING AND TO ADEQUATELY DISCLOSE, EVALUATE, AND MITIGATE ALL POTENTIALLY SIGNFICANT IMPACTS TO BIOLOGICAL RESOURCES A. The DSEIR Fails to Establish the Environmental Setting Resulting in an Inadequate Assessment of Potentially Significant Impacts to Biological Resources The DSEIR is legally inadequate because it fails to establish the environmental setting of the Project, resulting in inadequate disclosure and assessment of the Project’s potentially significant impacts on biological resources. The environmental setting, or baseline, refers to the conditions on the ground and is a starting point to measure whether a proposed project may cause a significant environmental impact.10 Describing the environmental setting is a prerequisite to an accurate and meaningful evaluation of the Project’s environmental impacts. Without this information, an appropriate analysis cannot be performed, effective mitigation cannot be designed, and alternatives cannot be developed. Furthermore, the failure to provide a proper baseline precludes the public from evaluating the scope of potential biological impacts that may result from Project-related activities. 9 Pub. Resources Code §§ 21002-21002.1. 10 Save Our Peninsula Com. v. Monterey Bd. of Supervisors (2001) 87 Cal.App.4th 99, 125. AB Page 4 of 96 3 CONT 4 March 16, 2018 Page 5 4174-003acp printed on recycled paper Here, the City’s biological resource analysis is based upon three “non- protocol” reconnaissance surveys of the project site. FirstCarbonSolution (“FCS”) biologists visited the Project site two times: once in spring 2016 and once and 2017.11 Additionally, the Biological Resources Assessment (“BRA”) attached to DSEIR was prepared by WRA, Inc. following a single site visit in August 2013.12 Neither the FCS nor the WRA visits included protocol-level surveys.13 As discussed in the attached expert comments of biologist Scott Cashen, these not protocol reconnaissance surveys were not adequate to establish the biological resources that may reside on or rely upon the habitat present on the Project site.14 As a result, the City lacks substantial evidence to support a determination that the proposed mitigation will be sufficient to reduce impacts to biological resources to a less than significant level. CEQA requires that the City collect sufficient facts to enable a complete and accurate description of the Project and its impacts.15 While a City has discretion to determine what surveys may be necessary to provide a complete and accurate description of the project setting, it must exercise that discretion such that its analysis and conclusions are supported by substantial evidence. In the case at hand, additional surveys are necessary to determine if the DSEIR’s findings regarding the Project’s biological impacts and the effectiveness of proposed mitigation are supported by substantial evidence. 1. The DSEIR Fails to Disclose the Potential Presence of Vernal Pool Fairy Shrimp The Project site lies within the Livermore Vernal Pool Region.16 Ephemeral pools in the Livermore Vernal Pool Region provide habitat for special-status branchiopods, including the vernal pool fairy shrimp and the California 11 DSEIR at p. 3.2-15. 12 DSEIR at Appendix C.1, p. iii (WRA, Inc. Biological Resources Assessment). 13 See DSEIR at pp. 3.2-15 – 3.2-16; Exhibit A, Scott Cashen, Comments on the Draft Supplemental Environmental Impact Report Prepared for the “IKEA Retail Center Project”(March 15,2018 ) (“S. Cashen Comments”), p. 2. 14 S. Cashen Comments at p. 2. 15 Sundstrom v. County of Mendocino (1988) 22 Cal.App.3d 296, 311; see also Laurel Heights Improvement Assn. v. Regents of the Univ. of Cal. (1988) 47 Cal.3d 376, 404-05. 16 S. Cashen Comments at p. 5. AB Page 5 of 96 4 CONT 5 March 16, 2018 Page 6 4174-003acp printed on recycled paper linderiella.17 The DSEIR notes that the Project site contains seasonal wetlands or vernal pools.18 Based upon the information provided in the Wetland Delineation data sheets provided, biologist Scott Cashen was able to determine that the wetlands at the project site hold water long enough to provide habitat for the federally threatened vernal pool fairy shrimp.19 The DSEIR does not evaluate, or even disclose, the potential presence of vernal pool fairy shrimp at the Project site. However, the Biological Resource Assessment notes that invertebrate shells from Ostracoda were detected in two of the wetlands in 2013.20 As Mr. Cashen explains, the presence of these ‘seed shrimp’ at the Project site provides substantial evidence that vernal pool fairy shrimp also may occur at the Project site.21 The failure to disclose the potential presence of vernal pool fairy shrimp thus amounts to a failure to establish the complete environmental setting for the Project, and prevents an evaluation of potential impacts to this special status species. Pursuant to mitigation incorporated into the Eastern Dublin General Plan Amendment and Specific Plan, species-specific surveys for special-status invertebrates in appropriate wetland habitats are required prior to approval of certain projects in the Reduced Planning Area.22 Here, the Project site is within the Reduced Planning Area subject to the survey requirements. However, the required surveys have not been performed. Instead, the BRA simply concluded that vernal pool fairy shrimp are “unlikely to occur in the Project Area due to the lack of vernal pool habitat and the area’s history of repeated discing, grading and leveling.”23 As a result, the DSEIR contains no discussion of vernal pool fairy shrimp. As Mr. Cashen explains, the BRA’s conclusion is not supported by evidence, and it is contradicted by scientific information on vernal pool fairy shrimp habitat.24 First, vernal pool fairy shrimp are not limited to “vernal pool” habitat; they also 17 Id. 18 DSEIR at p. 3.2-1. 19 S. Cashen Comments at p. 5. 20 DSEIR, Appendix C.1, Appendix B (Wetland Delineation Data Form for sampling date 11/5/2013). 21 S. Cashen Comments at p. 5. 22 City of Dublin. 1993. Addendum to Eastern Dublin General Plan Amendment and Specific Plan Environmental Impact Report. p. 22. 23 DSEIR, Appendix C.1 at p. 12. 24 S. Cashen Comments at pp. 5-6. AB Page 6 of 96 5 CONT March 16, 2018 Page 7 4174-003acp printed on recycled paper occur in vernal pool-like habitats.25 Indeed, vernal pool fairy shrimp occur in a wide range of habitats, including degraded or otherwise poor-quality habitats such as pools created by tire tracks and roadside ditches. In this case, the seasonal wetlands at the Project site provide potential habitat for vernal pool fairy shrimp.26 Second, according to the Wetland Delineation, the wetlands at the Project site have experienced “little disturbance” since 2008.27 This contradicts the statement in the BRA that the wetlands are unlikely to provide habitat because they have been subject to repeated disking, grading, and leveling.28 Moreover, even disking, grading, and leveling do not preclude the potential presence of vernal pool fairy shrimp.29 For example, in Contra Costa County, over 100 vernal pool fairy shrimp were documented occurring in a “non-vegetated depression in dirt road along tracks—partially scraped by bulldozer,” and that had “routine vehicle traffic through [the] area.”30 In sum, because substantial evidence shows that potential habitat for vernal pool fairy shrimp occurs on the Project site and no protocol-level surveys have been conducted to confirm or refute their presence, the DSEIR’s failure to include vernal pool fairy shrimp as among the special-status species at the Project site is not supported. This omission amounts to a failure to establish an accurate environmental setting in violation of CEQA, and prevents evaluation of a potentially significant impact to vernal pool fairy shrimp resulting from Project- related fill activities. 2. The DSEIR Fails to Disclose the Potential Presence of California Linderiella Like vernal pool fairy shrimp, the DSEIR fails to disclose the potential presence of California linderiella at the Project site, despite substantial evidence of their potential to occur. California linderiella occupy the same type of habitat as the vernal pool fairy shrimp.31 They have also been detected in seasonal wetlands 25 Id. at p. 6. 26 Id. at p. 6. 27 Id. 28 See also DSEIR at p. 3.2-1; S. Cashen Comments at p. 6. 29 S. Cashen Comments at p. 6. 30 Id. 31 Id. at p. 7. AB Page 7 of 96 5 CONT 6 March 16, 2018 Page 8 4174-003acp printed on recycled paper similar to those at the Project site.32 Mr. Cashen’s comments explain that California linderiella have the potential to occur on the Project site and that their potential presence should be disclosed in DSEIR.33 The DSEIR’s failure to disclose the potential presence of California linderiella violates CEQA by failing to establish an accurate and complete environmental setting. The failure to disclose the potential presence of California linderiella also results in a failure to evaluate potentially significant impacts to this species resulting from Project-related fill activities. 3. The DSEIR Fails to Provide Critical Information Regarding Burrowing Owls at the Project Site The DSEIR states that there is moderate potential for burrowing owls to occur at the Project site.34 However, the DSEIR fails to establish the scope of the burrowing owl population on the Project site, and fails to disclose the status and demography of the local and regional burrowing owl populations that may be affected by loss of this potential breeding and foraging habitat. The DSEIR also fails to accurately disclose the amount of burrowing owl habitat on the Project site, preventing a contextual assessment of impacts due to potential habitat loss. CEQA requires a sufficient description of the Project setting to adequately inform the public and decisionmakers of the potential impacts of the Project. An accurate project setting is also necessary to permit meaningful assessment of the sufficiency of proposed mitigation measures. Here, the DSEIR acknowledges that the site provides potential burrowing owl habitat, but the surveys necessary to establish the scope of burrowing owl use of the site were never conducted.35 Instead, the DSEIR’s discussion is based on reconnaissance-level surveys by FCS and WRA.36 As Mr. Cashen’s comments explain, burrowing owls are difficult to detect due to their cryptic coloration, extensive use of burrows, and tendency to flush (i.e., fly 32 Id. 33 Id. 34 DSEIR at p. 3.2-6. 35 S. Cashen Comments at p. 8. 36 Id. AB Page 8 of 96 6 CONT 7a March 16, 2018 Page 9 4174-003acp printed on recycled paper away) when approached.37 Because of these characteristics, researchers and the California Department of Fish and Wildlife (“CDFW”) have concluded that four independent surveys are necessary to provide reliable information on the presence of burrowing owls, and that data from the four surveys is essential to avoiding, minimizing, and properly mitigating the impacts of a project.38 For the Project here, Mitigation Measure BIO-1c requires the Applicant to retain a biologist to conduct two pre-construction surveys for burrowing owls prior to the first ground disturbing activities.39 Although CDFW guidelines do recommend “take avoidance” (i.e., pre-construction) surveys, the guidelines make it clear that such surveys are no substitute for the four “detection surveys” that are required to fully assess a project’s impacts and formulate appropriate mitigation.40 Because both FCS and WRA failed to implement the CDFW survey protocol during their site visits, the City lacks the information needed to fully disclose and evaluate the Project’s impacts to burrowing owls and to ensure effective mitigation. The need to establish the baseline population of burrowing owls on a site prior to assessing impacts and mitigation measures is emphasized in CDFW’s 2012 Staff Report on Burrowing Owl Mitigation: Adequate information about burrowing owls present in and adjacent to an area that will be disturbed by a project or activity will enable the Department, reviewing agencies and the public to effectively assess potential impacts and will guide the development of avoidance, minimization, and mitigation measures. In short, it is not possible to fully and effectively assess the extent of the Project’s impacts on burrowing owls until surveys that adhere to CDFW guidelines have been conducted.41 Accordingly, the City must require the Applicant to conduct the protocol surveys described in CDFW’s 2012 Staff Report. The results of those surveys need to be released in a revised DSEIR so that they can be thoroughly 37 Id. 38 Id. 39 DSEIR at pp. 3.2-19 – 3.2-20. 40 S. Cashen Comments at p. 8 (citing California Department of Fish and Game (2012) Staff Report on Burrowing Owl Mitigation). 41 Id. AB Page 9 of 96 7a CONT March 16, 2018 Page 10 4174-003acp printed on recycled paper vetted by the public, resource agencies, and decisionmakers as a part of the CEQA review process. Furthermore, the DSEIR’s description of the environmental setting is inadequate because it fails to disclose the extent of burrowing owl habitat on the Project site, as well as the amount of habitat that would be eliminated by the Project.42 Significantly, the DSEIR also fails to disclose the Project’s proximity to the important Camp Parks burrowing owl population and its importance to the continuing viability of burrowing owls in the region.43 This information is an essential component for the DSEIR because it, along with the scope of the population on the Project site, will enable the public and decisionmakers to evaluate the relative significance of the Project’s impacts to the overall burrowing owl population and to evaluate the sufficiency of the proposed mitigation. As Mr. Cashen’s comments explain, burrowing owl populations have declined dramatically in the San Francisco Bay Area since the Eastern Dublin Specific Plan EIR was prepared.44 The species has been extirpated, or nearly extirpated, from six Bay Area counties (Napa, Marin, San Francisco, Santa Cruz, Sonoma, and San Mateo).45 Although burrowing owls were once abundant throughout Alameda and Contra Costa counties, they are now primarily limited to the eastern portions of those counties.46 Indeed, only two “large” breeding colonies of burrowing owls remain in Alameda County: one in the Altamont Hills, and the second in the Camp Parks area.47 The Project site is located at the periphery of the Camp Parks burrowing owl population, which is the last remaining large population of burrowing owls in the Livermore-Amador Valley.48 Because the Project would contribute to the further decline of burrowing owl habitat in the Camp Parks area – one of the few remaining core population areas in the region – the Project may have a significant effect on the overall persistence of burrowing owls in the region.49 42 See Id. at p. 9. 43 Id. at pp. 7, 9. 44 Id. at p. 7. 45 Id. 46 Id. 47 Id. 48 Id. 49 Id. at pp. 7-8. AB Page 10 of 96 7a CONT 7b March 16, 2018 Page 11 4174-003acp printed on recycled paper The City is required to disclose sufficient information to enable a complete assessment of whether additional mitigation is necessary due to the severity of impacts to a core population area. The DSEIR must be revised to establish and disclose the proximity and importance of the Camp Parks burrowing owl population so that the Project’s potential impacts to this core population area may be evaluated and appropriate mitigation identified. 4. The DSEIR Fails to Provide Information Regarding Special Status Plant Species That is Necessary to Assess Potential Impacts and the Effectiveness of Mitigation While the DSEIR acknowledges that Congdon’s Tarplant is known to occur on approximately 6.81 acres of the Project site,50 the document fails to disclose that other special status plant species may also occur. Because no protocol-level surveys were performed sufficient to determine whether other potentially-present special status plant species actually occur on the Project site, there is no basis to conclude that these other special status plants are not present.51 The failure to disclose the potential presence of these other species and the failure to perform surveys adequate to confirm the presence or non-presence of these species is a violation of CEQA. The DSEIR failures to inform the public and decisionmakers which plants may be impacted by the Project, the scope and significance of the plant population that may be impacted, and whether effective mitigation may be designed or alternatives should be considered. The DSEIR must be revised to adequately identify what special-status plant species may occur on the site, incorporate the results of protocol-level surveys for these plants, and identify appropriate mitigation requirements. In Mr. Cashen’s comments, he explains that at least two other special-status plant species are known occur at the Project site and neither are addressed in the DSEIR: (1) western dodder (Cuscuta occidentalis) and (2) Douglas' fiddleneck (Amsinckia douglasiana).52 These two plants are listed as plants observed at the Project site at the time of the WRA wetland delineation.53 Both of these species are locally rare (i.e., rank “A1” and “*A1x ” by the East Bay Chapter of the California 50 DSEIR at p. 2-1. 51 S. Cashen Comments at p. 3. 52 Id. at pp. 3-4. 53 DSEIR, Appendix C.1, Appendix A (BRA List of Observed Plant and Wildlife Species). AB Page 11 of 96 7b CONT 8a March 16, 2018 Page 12 4174-003acp printed on recycled paper Native Plant Society).54 Locally rare plant species with an “A” designation are considered special-status species under Sections 15380 and 15125(c) of the CEQA Guidelines. The presence of Douglas' fiddleneck at the Project site is especially significant because—until now—it was believed to be extirpated from Alameda and Contra Costa counties.55 Furthermore, the BRA dismissed the potential for saline clover (Trifolium hydrophilum) and hairless popcorn flower (Plagiobothrys glaber) to occur at the Project site, though its conclusions are unsupported.56 According to the BRA, saline clover is unlikely to occur at the site because “[t]he existing grassland and seasonally wet depression habitat in the Project Area is heavily disturbed and of low quality.”57 Additionally, the BRA states that hairless popcorn flower is unlikely to occur at the Project site because “[t]his species is presumed extinct and has not been found since 1954.”58 Contrary to the statements in the BRA, however, Mr. Cashen explains that Saline clover has been detected in disturbed areas and “low quality” habitats.59 Saline clover is also known to occur in the Tassajara Area.60 Additionally, the BRA’s statement that hairless popcorn flower has not been found since 1954 is simply incorrect, as the species was rediscovered near Tassajara Road in Dublin during surveys conducted in 2002 and 2006.61 Accordingly, the DSEIR’s assumption that these plant species have no potential to be present on the Project site is not supported by substantial evidence. Data from focused surveys is necessary to fully disclose the existing conditions at the Project site, analyze the Project’s impacts, formulate appropriate mitigation, and develop possible alternatives. Deferring the surveys until after completion of the CEQA review process fails to fully disclose potential Project impacts on special status plants and precludes the public, resource agencies, and 54 S. Cashen Comments at p. 3. 55 Id. at p. 4. 56 DSEIR, Appendix C.1, Appendix B at pp. B-15, B-16 (Potential for Special-Status Species to Occur in the Project Area); see also S. Cashen Comments at p. 4. 57 Id. at p. B-15. 58 Id. at p. B-16. 59 S. Cashen Comments at p. 4. 60 Id. at p. 5. 61 Id. at pp. 4-5. AB Page 12 of 96 8a 8b March 16, 2018 Page 13 4174-003acp printed on recycled paper scientific community from meaningful comment on these potential impacts, and precludes meaningful review of the Project’s impacts by decisionmakers exercising their discretion in approving entitlements and permits. 5. The DSEIR Fails to Establish Baseline Conditions for Special Status Bats at the Project Site The DSEIR identified three special-status bat species (pallid bat, Townsend’s big-eared bat, and Yuma myotis) that have a moderate potential of roosting in the existing building at the Project site.62 As with the other special-status species, the Applicant did not conduct the necessary surveys to determine whether any bat species were in fact using the building as a roost site.63 The failure to establish baseline conditions precludes the public, resource agencies, and scientific community from being able to review and submit informed comments pertaining to the Project’s impacts and the sufficiency of proposed mitigation. B. The DSEIR Fails to Disclose, Evaluate, and Mitigate All Potentially Significant Impacts to Biological Resources 1. The DSEIR Fails to Evaluate and Mitigate Potential Impacts to Special Status Branchiopods As discussed in subsection (a)(1) above, the DSEIR fails to disclose that special status branchiopods including vernal pool fairy shrimp and California linderiella may be present in the seasonal wetlands at the Project site.64 As a result, the DSEIR also fails to evaluate the potential impacts that the Project may have on these special-status species and fails to identify any measures to mitigate potentially significant impacts. Because substantial evidence shows that potential habitat for vernal pool fairy shrimp and California linderiella exists on the Project site, the DSEIR must be revised to disclose this information and evaluate potential impacts to these special status species.65 62 DSEIR at pp. 3.2-6, 3.2-11. 63 S. Cashen Comments at p. 8. 64 Id. at p. 9. 65 Id. AB Page 13 of 96 8b CONT 9 10 March 16, 2018 Page 14 4174-003acp printed on recycled paper 2. The DSEIR Fails to Evaluate and Mitigate All Potential Impacts to Burrowing Owls As discussed above, the DSEIR fails to adequately disclose the scope of burrowing owls and their habitat on the Project site. The DSEIR also fails to disclose the Project’s proximity to the critical Camp Parks burrowing owl population. As a result of these critical omissions, the DSEIR has failed to meaningfully evaluate and disclose the scope of potential impacts to burrowing owls from Project construction. Without such evaluation, it is impossible to fully assess the adequacy of the proposed mitigation measures. Furthermore, as Mr. Cashen’s comments demonstrate, the mitigation measures that are proposed are inadequate and do not support a finding that they would reduce Project impacts below a level of significance.66 i. The DSEIR Fails to Evaluate Impacts from Eviction The DSEIR fails to evaluate the potential impacts to burrowing owls from the proposed eviction of burrowing owls from their burrows. Additionally, the DSEIR fails to identify mitigation measures to reduce the potential impacts of eviction to a less than significant level. Under CDFW guidelines, passive relocation or eviction is a potentially significant impact under CEQA that must be analyzed.67 The temporary or permanent closure of burrows may result in a variety of impacts to the species, including: (1) significant loss of burrows and habitat for reproduction and other life history requirements; (2) increased stress and reduced reproductive rates; (3) increased depredation; (4) increased energetic costs; and (5) risks posed by having to find and compete for available burrows.68 Moreover, because the DSEIR fails to provide a burrowing owl exclusion plan, or fundamental details contained in such plans (e.g., location of replacement burrows and compensation habitat, whether exclusion permitted during breeding season), it is not possible for the public, resource agencies, and decisionmakers to 66 Id. at pp. 9-10. 67 Id. at p. 10. 68 Id. AB Page 14 of 96 11 12 March 16, 2018 Page 15 4174-003acp printed on recycled paper evaluate the potential impacts to owls evicted from the Project site and the adequacy of the mitigation.69 The DSEIR must be revised to provide sufficient detail on proposed eviction activities to enable meaningful evaluation of impacts from these activities. ii. Protective Buffer Requirements Are Vague and Unenforceable In order for mitigation measures to be effective, they must be specific, enforceable, and feasible actions that will improve environmental conditions. In this case, the DSEIR’s direction to avoid disturbing or otherwise impacting occupied burrows to mitigate impacts to burrowing owls is vague and unenforceable.70 As result, the requirement does not provide substantial evidence that impacts will be mitigated below a level of significance. The DSEIR does not establish the minimum buffers that need to be implemented around burrows. Nor does the DSEIR establish monitoring that should be implemented to ensure burrowing owls are not disturbed by construction activities. The DSEIR’s direction to avoid burrowing owls should be revised to reflect CDFW guidelines, which indicate buffers may need to be up to 500 meters, depending on the time of year and level of disturbance.71 In the absence of greater specificity, it is purely speculative to assume that the proposed mitigation will reduce impacts below a level of significance. iii. The DSEIR Improperly Defers Mitigation The DSEIR violates CEQA by deferring specification of critical elements of the mitigation measures needed to reduce the Project’s potentially significant impacts to burrowing owls below a level of significance. Specifically, the DSEIR defers identifying: (1) a compensatory mitigation ratio; (2) the acceptable mitigation location and mechanism (e.g., habitat acquisition, purchase of credits at a mitigation bank, in-lieu fee, etc.);(3) site protection methods;(4) financial 69 Id. 70 DSEIR at p. 3.2-20. 71 S. Cashen Comments at p. 17. AB Page 15 of 96 12 CONT 13 14 March 16, 2018 Page 16 4174-003acp printed on recycled paper assurances;(5) performance standards; and (6) monitoring requirements.72 Instead, the DSEIR relies on the establishment of mitigation requirements in a future Burrowing Owl Mitigation Plan, which is to be reviewed and accepted by CDFW and the City prior to the first ground-disturbing activities.73 Deferring formulation of mitigation measures to post-approval studies is generally impermissible.74 Mitigation measures adopted after Project approval deny the public the opportunity to comment on the Project as modified to mitigate impacts.75 Deferral of the specifics of mitigation is permissible only where the lead agency “commits itself to mitigation” and “lists the alternatives to be considered, analyzed and possibly incorporated in the mitigation plan.”76 If identification of specific mitigation measures is impractical until a later stage in the project, specific performance criteria must be articulated and further approvals must be made contingent upon meeting these performance criteria.77 The courts have held that simply requiring a project applicant to obtain a future report and then comply with any recommendations that may be based upon the report is insufficient to meet the standard for properly deferred mitigation.78 Here, the DSEIR’s proposed approach deprives the public of an opportunity to review and submit comments on fundamental aspects of the Project’s mitigation strategy prior to Project approval. Furthermore, neither the CDFW nor the City has an oversight approach to ensure compensatory mitigation is occurring.79 As Mr. Cashen’s comments explain, a 1:1 ratio is not likely to be sufficient to mitigate impacts below a level of significance in this case.80 This is due to the rapid decline of the Camp Parks population and the limited availability of compensation habitat to support that population.81 A project and region specific ratio is required 72 Id. 73 DSEIR at p. 3.2-20. 74 Sundstrom v. County of Mendocino (1988) 202 Cal.App.3d 296, 308-309; Pub. Resources Code § 21061. 75 Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359, 1393; Quail Botanical Gardens Foundation v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1604, n. 5 76 Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th 777, 793. 77 Id. 78 Id. 79 S. Cashen Comments at p. 17. 80 Id. at pp. 17-18. 81 Id. AB Page 16 of 96 14 CONT March 16, 2018 Page 17 4174-003acp printed on recycled paper in this case to support a finding that the mitigation ratio will reduce impacts below a significant level. In this case, a regional specific mitigation ratio for loss of burrowing owl habitat has already been established, yet was never disclosed or applied in the DSEIR. The Eastern Alameda County Conservation Strategy (“EACCS”) establishes the standard for mitigation needed to conserve species and habitat in Eastern Alameda County. The EACCS requires compensatory mitigation for impacts to burrowing owl habitat to be within one-half mile of a burrowing owl nest used within the previous three years.82 Additionally, the EACCS establishes a standardized mitigation ratio of 3:1 (3.5:1 if the mitigation site is in a different core area).83 Anything lower cannot be assumed to reduce regional impacts to a less than significant level.84 The EIR should be revised to include a provision that compensatory mitigation shall be required for Project impacts to burrowing owls and their habitat at a minimum of the EACCS compensatory mitigation ratio standard for burrowing owls of 3:1 (3.5:1 if the mitigation site is in a different core area). By failing to identify the applicability of the EACCS mitigation requirements and failing to establish a performance standard based on regional mitigation needs, the DSEIR’s deferral of the specific mitigation ratio requirement violates CEQA and is not support by substantial evidence. 3. The DSEIR Fails to Adequately Evaluate and Mitigate Potential Impacts to Special Status Plants The DSEIR requires the Applicant to conduct a focused survey to determine the presence of Congdon’s tarplant prior to construction.85 If no special-status plant species are found during this pre-construction survey, then no additional mitigation measures for special status plants will be implemented. If Congdon’s tarplant is detected during the survey, additional mitigation requirements are triggered. 82 Id. at p. 18. 83 Id. 84 Id. 85 DSEIR at p. 3.2-18. AB Page 17 of 96 14 15 March 16, 2018 Page 18 4174-003acp printed on recycled paper The DSEIR’s proposed mitigation strategy is not sufficient to ensure impacts to special status plants species will be less than significant.86 First, the DSEIR does not require focused surveys or specify mitigation for any other special-status plant species that occur, or could occur, at the Project site. As a result, potentially significant impacts to all special-status plants besides Congdon’s tarplant remain unmitigated.87 Second, Congdon’s tarplant is already known to occur at the Project site, thus compensatory mitigation should not be contingent on future surveys. This is especially true for annual plants such as Congdon’s tarplant because the presence and abundance of annual plants can fluctuate dramatically from year to year due to climatic conditions.88 The absence of Congdon’s tarplant from the Project site during a preconstruction survey may be the result of adverse survey conditions rather than actual absence of the species, which may in turn cause potentially significant impacts to go unmitigated. Third, the DSEIR indicates that compensatory mitigation would not be required if activity exclusion zones can be installed around habitat occupied by Congdon’s tarplant during construction of the Project.89 However, based on the site plan, Mr. Cashen states that all existing plants will be directly or indirectly affected by the Project.90 Therefore, even if activity exclusion zones are feasible, the plant populations have no chance for long-term persistence at the site once the Project is operational. The DSEIR must be revised to address these deficiencies in the proposed mitigation strategy and ensure all potentially significant impacts are mitigated to the extent feasible. i. The DSEIR Defers Mitigation for Congdon’s Tarplant Impacts The DSEIR requires that the Applicant prepare a mitigation plan if impacts to Congdon’s tarplant cannot be avoided. The DSEIR states: 86 See S. Cashen Comments at p. 14. 87 Id. 88 Id. 89 DSEIR at pp. 3.2-18 – 3.2-19. 90 S. Cashen Comments at p. 14. AB Page 18 of 96 15 CONT 16 March 16, 2018 Page 19 4174-003acp printed on recycled paper A mitigation plan may include but is not limited to the following: the acquisition of off-site mitigation areas presently supporting the Congdon’s tarplant, purchase of credits in a mitigation bank that is approved to sell credits for the Congdon’s tarplant, or payment of in-lieu fees to a public agency or conservation organization (e.g., a local land trust) for the preservation and management of existing populations of Congdon’s tarplant.91 As proposed, the DSEIR improperly defers formulation of the mitigation plan without establishing fundamental aspects needed to ensure effectiveness and enforceability. Such fundamental aspects include: (1) the performance standards (or success criteria) for the proposed mitigation, (2) a definitive enforcement mechanism that ensures performance standards are met; (3) the contingency or remedial action measures that would be triggered if success standards are not achieved; (4) the measures that would be implemented to ensure the long-term protection and management of sensitive biological resources at mitigation sites; and (5) the required monitoring program, including the monitoring techniques, effort, and frequency.92 Because the DSEIR lacks these fundamental details, the City has failed to ensure that Project impacts to sensitive botanical resources would be reduced to a less than significant level.93 Furthermore, the DSEIR’s deferral of the mitigation plan is exacerbated by its failure to provide evidence that the proposed mitigation is feasible. As Mr. Cashen’s comments note, there do not appear to be any mitigation banks that sell credits for impacts to Congdon’s tarplant.94 Additionally, there do not appear to be any in-lieu fee programs that cover impacts to Congdon’s tarplant, and the DSEIR fails to provide evidence that sites suitable for acquisition exist.95 The City must produce a revised DSEIR to establish that the proposed mitigation is feasible. Specifically, the DSEIR should identify: (1) the potential mitigation sites, and status of Congdon’s tarplant at those sites; (2) the actual mitigation ratio proposed; (3) performance standards for the mitigation sites; (4) the required monitoring program; and, (5) measures that will be implemented to ensure 91 DSEIR at p. 3.2-19. 92 S. Cashen Comments at pp. 14-15. 93 Id. 94 Id. at p. 15. 95 Id. AB Page 19 of 96 16 March 16, 2018 Page 20 4174-003acp printed on recycled paper the long-term protection and management of Congdon’s tarplant populations at the mitigation site(s).96 Without such details, the DSEIR lacks substantial evidence to support a finding that the proposed mitigation will reduce impacts below a level of significance. ii. The Proposed Compensatory Mitigation is Vague and Inconsistent with the EACCS According to the DSEIR, the Congdon’s tarplant mitigation plan should incorporate a compensatory mitigation ratio of at least 1:1.97 However, the Eastern Alameda County Conservation Strategy (“EACCS”) establishes the standard for mitigation needed to conserve species and habitat in Eastern Alameda County, and the proposed mitigation ratio does not adhere to EACCS standards.98 The EACCS establishes a standardized mitigation ratio of 5:1 for impacts to focal plant species (e.g., Congdon’s tarplant).99 Notably, the 1:1 ratio proposed in the DSEIR is not even consistent with other projects in the City of Dublin. For example, the City is requiring a 5:1 ratio for impacts to Congdon’s tarplant at the nearby Zeiss Innovation Center Project site.100 The DSEIR offers no explanation as to why a 5:1 ratio was needed to mitigate impacts at the Zeiss project site but the Project site here only requires a 1:1 ratio. Because the DSEIR fails to include a sufficiently detailed mitigation strategy, and because the measures listed in the DSEIR do not comply with the EACCS, the City has failed to provide substantial evidence that the Project’s impact to Congdon’s tarplant and other special-status plant species would be reduced to a less than significant level. 4. The DSEIR Fails to Adequately Evaluate and Mitigation Potential Impacts to Special Status Bats The DSEIR’s proposed mitigation measures fail to ensure that the Project’s impacts to special status bats are mitigated to a less than significant level. The 96 Id. 97 DSEIR at p. 3.2-19. 98 S. Cashen Comments at p. 15. 99 Id. 100 Id. AB Page 20 of 96 16 CONT 17 18 March 16, 2018 Page 21 4174-003acp printed on recycled paper DSEIR proposes the following mitigation for potentially significant impacts to special-status bat species: Pre-removal bat surveys of the existing on-site building shall occur no more than 30 days before its removal. If bats are found, then a qualified biologist shall develop an appropriate relocation plan consistent with USFWS, CDFW, and East Alameda County Conservation Strategy standards and policies.101 However, the DSEIR fails to identify the survey techniques that should be implemented for the pre-removal surveys, and it is unclear that the listed standards and policies even exist.102 As Mr. Cashen explains, establishing the required survey techniques for special status bat species is a necessary prerequisite to ensuring that potential impacts to bat species are identified and mitigated.103 First, bat detection often requires specialized techniques, and a technique that is effective for one species may be completely ineffective for other species.104 Second, pallid bats and Townsend’s big-eared bats are extremely sensitive to human disturbance, and human disturbance may cause the colony to abandon the roost (which contributes to population declines).105 Third, the establishment of minimum qualifications for the biologist conducting the pre-removal surveys fails is necessary to ensure the surveys will be effective and avoid additional impacts to the species.106 Because the DSEIR fails to establish critical performance standards for ensuring future surveys will be effective, the DSEIR’s conclusion that such surveys will reduce impacts below a level of significance is not supported by substantial evidence. Suitable roost sites are the limiting factor for most bat populations.107 The DSEIR does not require the Applicant to provide replacement roosts as compensation for impacts to potential roosts at the Project site. Therefore, even if the bats are properly excluded from the existing on-site building, they may not have a suitable alternate roost in the vicinity, and the local population may be 101 DSEIR at p. 3.2-20 – 3.2-21. 102 See S. Cashen Comments at p. 19. 103 Id. at pp. 18-19. 104 Id. at p. 18. 105 Id. 106 Id. 107 Id. at p. 19. AB Page 21 of 96 18 CONT March 16, 2018 Page 22 4174-003acp printed on recycled paper extinguished.108 This constitutes a potentially significant impact that remains unmitigated. Without ensuring that suitable replacement roosts will be available, the DSEIR lacks substantial evidence to support its finding that the proposed mitigation strategy will reduce impacts below a level of significance. 5. The DSEIR Fails to Adequately Evaluate Cumulative Impacts of the Project The DSEIR’s analysis of cumulative impacts to biological resources fails to satisfy the requirements of CEQA for several reasons. First, the DSEIR fails to define the geographic scope of the City’s cumulative impacts analysis beyond that it includes “the region surrounding the project site.” This description is too vague to understand the geographic scope of the analysis and prevents the public from assessing the conclusions presented in the DSEIR. Second, the list of cumulative projects provided in the DSEIR omits the Zeiss Innovation Center Project, which is located approximately 700 feet north of the Project site. The Zeiss Innovation Center Project would impact many of the same biological resources as the proposed Project, including Congdon’s tarplant, seasonal wetlands, burrowing owl (and other raptor) habitat, and potential habitat for the vernal pool fairy shrimp and California linderiella. Third, the DSEIR concludes the Project’s contribution to any significant cumulative impact on special-status plant species would be less than cumulatively considerable because Congdon’s tarplant would be relocated if it is found on the Project site during preconstruction surveys. However, there is no basis for this conclusion because the DSEIR does not require (or propose) relocation of Congdon’s tarplant as mitigation. Further, the DSEIR’s conclusion is not justified because the DSEIR fails to incorporate mitigation for the numerous other special-status plant species that occur, or could occur, at the Project site. Fourth, the DSEIR acknowledges the Project would (or could) impact wetlands, special-status plants (Congdon’s tarplant), and special-status animals (nesting birds, burrowing owl, bats). However, the DSEIR fails to provide any actual 108 Id. AB Page 22 of 96 18 CONT 19 March 16, 2018 Page 23 4174-003acp printed on recycled paper analysis of cumulative impacts to these resources, including whether cumulative impacts to these specific resources would be significant. As Mr. Cashen points out: 1. None of the biological resource mitigation measures are designed to alleviate the cumulative impact; all three mitigation measures are specific to the Project site and to Project activities and do not address the cumulative impact posed by other projects. 2. Habitat loss, including the incremental loss of habitat from numerous small projects, is the greatest threat to most special-status species. The DSEIR does not require habitat compensation for all of the special-status species that would (or could) be affected by the Project. As a result, the Project’s contribution to the cumulatively significant loss of habitat would not be mitigated.109 Mr. Cashen concludes that the Project’s incremental contribution to cumulative impacts to the burrowing owl and Congdon’s tarplant would be cumulatively considerable.110 Furthermore, the Project may have cumulatively considerable impacts to other species as well (e.g., vernal pool fairy shrimp, special- status bats), but DSEIR’s omission of baseline data pertaining to the presence of such species on the Project site prevents such a determination.111 C. The DSEIR Fails to Adequately Mitigate Potential Impacts to Wetlands and Improperly Defers Mitigation The DSEIR includes two measures to mitigate potential impacts to wetlands. First, Mitigation Measure BIO-3a requires the Applicant to complete an updated wetland delineation to determine if the wetlands at the Project are subject to jurisdiction under Section 404 of the Clean Water Act. Second, Mitigation Measure BIO-3b requires the Applicant to acquire appropriate permits under Section 404 of the Clean Water Act from the USACE if the wetlands are determined to be subject to USACE jurisdiction, and to obtain Section 401 certification from the Regional Water Quality Control Board 109 Id. at p. 13. 110 Id. at pp. 13-14. 111 Id. AB Page 23 of 96 19 CONT 20 March 16, 2018 Page 24 4174-003acp printed on recycled paper (“RWQCB”). BIO-3b further requires the Applicant to prepare a wetland mitigation plan to be approved by the USACE and RWQCB. Specifically: A mitigation plan shall be prepared that will establish suitable compensatory mitigation based on the concept of no net loss of wetland habitat values or acreages, to the satisfaction of the regulatory agencies. Specifically, a wetland mitigation plan shall be developed and implemented that includes creation, restoration, and/or enhancement of off-site wetlands prior to project ground disturbance. Mitigation areas shall be established in perpetuity through dedication of a conservation easement (or similar mechanism) to an approved environmental organization and payment of an endowment for the long-term management of the site.83 On the basis of these two mitigation measures, the DSEIR concludes the Project’s impacts to wetlands would be reduced to a less-than-significant level. The DSEIR’s conclusion that impacts would be mitigated to below a level of significance is not supported by substantial evidence for two reasons: First, the DSEIR impermissibly defers analysis and critical aspects of the wetlands mitigation strategy. Under CEQA, the City is obligated to identify the specific mitigation needed to mitigate Project impacts to less-than-significant levels. This includes the specific mitigation strategy, mitigation ratio, monitoring program, and performance standards and that will be implemented to ensure the Project would have less-than-significant impacts on the environment. Contrary to what the DSEIR suggests, the City cannot rely on deferred mitigation and the permitting requirements of other agencies to conclude impacts to wetlands would be mitigated to less-than-significant levels. Second, compliance with regulatory permits provides no assurances that Project impacts to jurisdictional wetlands would be less-than-significant.112 To the contrary, numerous studies have demonstrated that many compensatory mitigation projects permitted under Sections 401 and 404 of the Clean Water Act are not achieving the goal of “no overall net loss” of wetland acres and functions.113 112 Id. at pp. 20-21. 113 Id. AB Page 24 of 96 20 CONT March 16, 2018 Page 25 4174-003acp printed on recycled paper IV. THE DSEIR’S CONCLUSION THAT AIR QUALITY IMPACTS WOULD BE LESS THAN SIGNIFICANT IS NOT SUPPORTED BY SUBSTANTIAL EVIDENCE The DSEIR explains that Project emissions were quantified using the California Emissions Estimator Model Version CalEEMod.2016.3.2 (“CalEEMod”).114 When modeling a project’s emissions, CalEEMod provides the user with recommended default values based on information such as land use type, meteorological data, project type, and typical equipment associated with the project type.115 The user may replace default values when more site-specific information is available. However, CEQA requires that any changes to CalEEMod defaults must be supported by substantial evidence.116 CalEEMod generates “output files” for each model that reveal to the viewer the parameters used when creating a given model. We retained SWAPE to review the CalEEMod output files generated for the Project. In reviewing the CalEEMod output files, SWAPE found several of the input parameters used to be inconsistent with information disclosed in the DSEIR.117 As further explained in the attached SWAPE letter, these changes resulted in an underestimation of the Project’s construction and operational emissions.118 Because the DSEIR fails to accurately disclose and analyze the Project’s air quality impacts, the DSEIR’s conclusions that air quality impacts from Nitrogen Oxides (“NOx”) emissions during Project construction and operations will be less than significant are not supported by substantial evidence. A revised DSEIR must be prepared to include an air quality analysis that accurately discloses and evaluates the air quality impacts of the Project. 114 DSEIR at p. 3.1-1. 115 SWAPE Comments at p. 2 116 See CalEEMod 2012.2.2 User’s Guide, p. 9 (July 2013), available at http://www.aqmd.gov/docs/default-source/caleemod/usersguideSept2016.pdf?sfvrsn=6; SWAPE Comments at p. 2. 117 SWAPE Comments at p. 2. 118 Id. AB Page 25 of 96 21 March 16, 2018 Page 26 4174-003acp printed on recycled paper A. The DSEIR Emission Estimates Fail to Account for Materials Export Hauling Trips In reviewing the CalEEMod output files, SWAPE first found that the DSEIR’s emissions estimates do not account for emissions from materials hauling trips that the DSEIR states will occur during the grading phase.119 According to the DSEIR, the proposed project’s grading activities would involve 95,000 cubic yards of cut and 73,700 cubic yards of fill. Thus, 21,300 cubic yards would be exported off- site.” However, SWAPE’s review of the CalEEMod output files found that the Project’s construction-related emissions assume zero hauling truck trips will occur during the grading phase.120 In CalEEMod modeling, hauling truck trips are estimated based on the total amount of material that will be imported or exported and assuming that a single hauling truck can transport 16 cubic yards of material per trip.121 CalEEMod calculates the number of hauling truck trips assuming that each hauling truck will have 2 one-way trips (e.g., a hauling truck importing material will have a loaded arrival trip and an empty return trip, while a hauling truck exporting material will have an empty arrival trip but a loaded departure trip).122 Accordingly, the DSEIR should have modeled the Project’s emissions assuming that there would be a total of 2,662 (2 x 1,331 hauling trips) trips in order to account for the 2 one-way truck trips.123 As noted above, SWAPE’s review of the output files found that zero hauling truck trips are accounted for in the DSEIR’s CalEEMod model, and no explanation is provided as to why hauling trips would not occur for the off-site soil exports.124 Because the Project’s CalEEMod model assumes no hauling truck trips would occur during the grading phase of construction, SWAPE explains that that the DSEIR’s CalEEMod model underestimates the actual emissions that will be generated during construction activities.125 NOx and fugitive dust emissions are generated as a result of haul truck trips.126 In this case, the DSEIR’s air quality 119 Id. at pp. 2-3. 120 Id. at p. 2. 121 Id. at p. 3. 122 Id. 123 Id. 124 Id. at p. 2. 125 Id. at pp. 3-4. 126 Id. at p. 3. AB Page 26 of 96 22 March 16, 2018 Page 27 4174-003acp printed on recycled paper analysis shows that the Project’s construction NOx emissions are just below the BAAQMD threshold of significance (52.44 lbs/day compared to 54 lbs/day) after mitigation.127 SWAPE concludes that the inclusion of the omitted haul truck trips would very likely result in Project construction emissions exceeding the BAAQMD threshold of significance for NOx based on the total number of truck trips excluded.128 Because the DSEIR’s emission model fails to account for the haul truck trips disclosed in the DSEIR, the Project’s construction emissions are underestimated and the City’s conclusion that impacts will be mitigated to below a level of significance is not supported by substantial evidence. Moreover, substantial evidence supports a finding that the Project’s construction emissions will exceed the BAAQMD threshold of significance. A revised DSEIR should be prepared to accurately disclose, evaluate, and mitigate the Project’s construction emission impacts. B. The DSEIR Emission Estimates Fail to Account for All Daily Vehicle Trips In reviewing the CalEEMod output files, SWAPE found that the DSEIR’s emissions calculations underestimate the number of daily vehicle trips during Project operations.129 As a result of this miscalculation, the Project’s operational emissions are underestimated and not supported by substantial evidence, and therefore cannot be relied on to determine the significance of the Project’s air quality impacts.130 According to DSEIR Appendix B, the Project would generate a total of 16, 898 vehicle trips per day.131 However, Appendix B Table 10 erroneously represents that the total number of project vehicle trips would be 16,840 per day.132 The latter figure was used in the CalEEMod model to estimate emissions from Project operations.133 As a result of this miscalculation, SWAPE found that the emissions 127 DSEIR at pp. 3.1-44 – 3.1-45. 128 SWAPE Comments at p. 4. 129 Id. at pp. 6-7. 130 SWAPE Comments at p. 8. 131 DSEIR, Appendix B, p. 29, Table 10; see also SWAPE Comments at pp. 6-7. 132 Id. 133 SWAPE Comments at p. 7. AB Page 27 of 96 22 CONT 23 March 16, 2018 Page 28 4174-003acp printed on recycled paper model underestimates the number of daily trips by approximately 60 trips per day, or 21,900 vehicle trips per year.134 As SWAPE explains by underestimating the total number of vehicle trips expected to occur during Project operations, the DSEIR underestimates the Project’s operational mobile-source emissions.135 Moreover, this underestimation is important because the CalEEMod files demonstrate that the Project’s mitigated emissions are close to the BAAQMD’s significance threshold for operational NOx emissions.136 The DSEIR shows that the Project’s mitigated operational emissions would result in a maximum daily emission of approximately 51.54 lbs/day of NOx, or approximately 2.5 pounds below the BAAQMD’s NOx significance threshold of 54 lbs/day.137 However, because the DSEIR’s CalEEMod model underestimates the number of operational daily vehicle trips by 60 trips per day or 21,900 trips per year, SWAPE concludes it is possible that the Project’s NOx emissions would in fact exceed this threshold.138 By failing to include total number of vehicle trips expected to occur during Project operations, the DSEIR underestimates the Project’s operational mobile source emissions.139 For this reason, the DSEIR’s emissions estimates are inaccurate and not supported by substantial evidence. New modeling must be performed to accurately disclose and evaluate the Project’s operational emissions, and to evaluate compliance with the applicable thresholds of significance. V. THE DSEIR’S DETERMINATION THAT GLOBAL WARMING IMPACTS WOULD BE LESS THAN SIGNIFICANT IS NOT SUPPORTED BY SUBSTANTIAL EVIDENCE In an attempt to analyze the potential impacts of the Project’s operational greenhouse gas (“GHG”) emissions, the DSEIR employs two thresholds of significance – one for operational emissions in the year 2020, and another for operational emissions after the year 2020.140 For the Project’s anticipated opening 134 Id. 135 Id. 136 Id. 137 DSEIR at p. 3.1-46. 138 SWAPE Comments at p. 8. 139 Id. at p. 6. 140 DSEIR, pp. 3.1-59 – 3.1-67. AB Page 28 of 96 23 CONT 24 March 16, 2018 Page 29 4174-003acp printed on recycled paper year, 2020, the DSEIR relies on an assessment of the Project’s consistency with the City of Dublin’s 2013 Climate Action Plan Update (“CAP”). Under this threshold, the DSEIR concludes that GHG emissions from operation of the project in the year 2020 will be less than significant because the Project complies with the applicable CAP measures for meeting 2020 GHG reduction goals. It is estimated that the Project will not commence operations until at least December 2020, however, meaning that the DSEIR’s CAP analysis only supports a determination for one month of operations and does not address operational emissions for the whole of the Project’s expected lifespan.141 Because the CAP does not provide a plan for meeting GHG reduction goals beyond 2020, the DSEIR uses a separate “business as usual” (“BAU”) GHG threshold for Project emissions after 2020 that is based on the Senate Bill (“SB”) 32 2030 statewide GHG reduction goal. This secondary threshold, however, is identical to the threshold of significance that was struck down by the California Supreme Court struck down in Center for Biological Diversity v. California Department of Fish and Wildlife (“Newhall”) and is not supported by substantial evidence.142 The DSEIR’s BAU threshold assumes that operational emissions after 2020 would not be significant if the Project’s 2030 emissions would be “40 percent below 1990 levels consistent with SB 32.”143 The DSEIR concludes that the Project’s 2030 operational GHG emissions would be more than 40 percent below 1990 business as usual emissions and thus operational emissions after 2020 would have a less than significant impact on global climate change.144 The DSEIR, however, offers no evidence to support its conclusion that impacts would be less than significant solely because the Project will reduce emissions from a business-as-usual scenario by a percentage that exceeds the statewide emissions targets in SB 32. Because the DSEIR’s use of the SB 32 2030 statewide GHG BAU reduction goal as a threshold of significance for project-level impacts is not supported by substantial evidence, its finding that the Project’s post 2020 operational emissions would be less than significant also is not supported by substantial evidence. 141 See CEQA Guidelines §15378(a) (requiring evaluation of all impacts that make up the “whole” of the project); see also Natural Resources Defense Council v. City of Los Angeles (“NRDC v. LA”) (2002) 103 Cal.App.4th 268. (CEQA requires examination of the environmental impacts of “the entire project, from start to finish”). 142 Center for Biological Diversity v. California Department of Fish and Wildlife (2015) 62 Cal.4th 204. 143 DSEIR, p. 3.1-61. 144 DSEIR, p. 3.1-63. AB Page 29 of 96 24 CONT March 16, 2018 Page 30 4174-003acp printed on recycled paper Rather than using inapplicable and disapproved thresholds of significance, the DSEIR should have applied the GHG thresholds set by the Bay Area Air Quality Management District (“BAAQMD”). As discussed below, the project’s operational emissions greatly exceed the BAAQMD threshold of significance for operational GHG emissions. Accordingly, the DSEIR must be revised to disclose this impact and to impose all feasible mitigation. A. The Determination that GHG Impacts Are Less Than Significant Because the Project Will Comply with the City of Dublin CAP Is Not Applicable to the Whole of the Project In Impact Air-7, the DSEIR considers whether the Project is consistent with the City of Dublin CAP to assess the significance of the Project’s GHG emissions for its opening year, 2020.145 This plan consistency approach is based on CEQA Guidelines sections 15064, 15130, and 15183.5, which together provide that public agencies may analyze and mitigate significant GHG emissions in a qualified reduction plan and later tier from that analysis when considering individual projects. Lead agencies may determine that an individual project’s contribution to global climate change is not cumulatively significant if the project complies with an adopted GHG reduction plan under specified circumstances.146 Guidelines section 15183.5 subdivision (b)(1) sets forth the recommended steps for agencies preparing such plans: (A)Quantify greenhouse gas emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area; (B)Establish a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by the plan would not be cumulatively considerable; (C)Identify and analyze the greenhouse gas emissions resulting from specific actions or categories of actions anticipated within the geographic area; 145 DSEIR, pp. 3.1-65-3.1-67. 146 Guidelines §15183.5(b) AB Page 30 of 96 24 CONT 25 March 16, 2018 Page 31 4174-003acp printed on recycled paper (D)Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level; (E)Establish a mechanism to monitor the plan's progress toward achieving the level and to require amendment if the plan is not achieving specified levels; (F) Be adopted in a public process following environmental review. BAAQMD’s CEQA Guidelines also endorse the use of a GHG reduction plan consistency analysis where appropriate and “recommend[] the Plan Elements in the state CEQA Guidelines as the minimum standards to meet the GHG Reduction Strategy Thresholds of Significance option.”147 Finally, Guidelines section 15064 subdivision (h)(3) specifies that such GHG reduction plans “must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process . . . .” As explained in the DSEIR, the City’s CAP satisfies the above requirements and constitutes a qualified GHG reduction plan for purposes of CEQA for activities through 2020.148 However, activities and GHG emissions after 2020 are not covered by the City’s CAP. Guidelines section 15183.5 subdivision (b)(1)(B) provides that consistency with GHG reduction plans may only be used as a threshold for “activities covered by the plan.” Because the plan does not establish GHG reduction goals for emissions after 2020, it does not cover activities or emissions after 2020 and is not applicable to the Project’s post-2020 operational emissions. The current CAP includes a total of 45 measures that the City determined would achieve its 2020 target of “15% below 2010 emissions levels by 2020.”149 The CAP explains that implementation of the plan’s measures and the reduction target will reduce the impact from covered activities to a less than significant level.150 147 BAAQMD CEQA Guidelines (May 2017) p. 4-8. 148 DSEIR at p. 3.1-65. 149 City of Dublin Climate Action Plan Update (July 2013), p. 24 (“CAP”). 150 CAP at p. 6. AB Page 31 of 96 25 CONT March 16, 2018 Page 32 4174-003acp printed on recycled paper However, because the current CAP was prepared to achieve the City’s 2020 reduction target only, it does not address activities, emission levels or reductions required beyond that year. More importantly, the CAP does not provide any evidence that compliance with the plan’s measures will reduce the impact from covered activities to a less than significant level beyond 2020. For that reason, the DSEIR correctly finds that the current CAP “does not contain adequate reduction measures to reduce California’s GHG emissions to the AB197 and SB32 targets of 40 percent below 1990 levels by 2030.”151 Reliance on a CAP consistency threshold for post-2020 emissions would also be flawed because the CAP no longer reflects prevailing scientific knowledge on climate change. CEQA requires a lead agency to evaluate effects based to the extent possible on scientific and factual data.152 As stated above, the DSEIR acknowledges that the current CAP does not include sufficient measures to ensure reductions consistent with SB 32.153 The targets of SB 32 were adopted in accordance with current scientific understanding of human contributions to climate change. , “They represent benchmarks, consistent with prevailing climate science, charting an appropriate trajectory forward that is in line with California’s role in stabilizing global warming below dangerous thresholds.”154 The “2030 target reflects the same science that informs the agreement reached in Paris by the 2015 Conference of Parties to the United Nations Framework Convention on Climate Change (UNFCCC), aimed at keeping the global temperature increase below 2 degrees Celsius (°C).”155 These targets are set to avoid California’s activities “contributing to an escalation of serious problems, including raging wildfires, coastal erosion, disruption of water supply, threats to agriculture, spread of insect-borne diseases, and continuing health threats from air pollution” that rising temperatures create. 156 151 DSEIR at p. 3.1-60. 152 See 14 C.C.R. § 15064.4; see also Cleveland National Forest Foundation v. San Diego Assoc. of Govts. (2017) 3 Cal. 5th 497, 518-519. 153 DSEIR, p. 3.1-60. 154 California’s 2017 Climate Change Scoping Plan, California Air Resources Board (Nov. 2017) p. ES3. 155 Id. at 2. 156 Id. at p. ES2. AB Page 32 of 96 25 CONT March 16, 2018 Page 33 4174-003acp printed on recycled paper Because the CAP is based on meeting pre-AB 32 2020 GHG reduction targets, the CAP fails to incorporate sufficient measures to ensure covered projects do not contribute to the significant effects the targets of SB 32 were adopted to prevent.157 For the above reasons, consistency with the CAP was not relied upon (and could not be relied upon) by the DSEIR to support a finding that the Project’s post- 2020 GHG operational emissions would be less than significant. The DSEIR states that the Project is scheduled to open in December 2020 – but this assumes no unexpected delays. Accordingly, the Project will only have one month of 2020 operational emissions at the most, and potentially no 2020 emissions at all. Practically all of the Projects emissions will, instead, occur from 2021 to 205 (assuming a 30 year lifespan).158 The Project will continue to operate and contribute to GHG emissions for decades to come. As a result, the determination that the Project’s operational GHG emissions in 2020 would be less than significant has no relevance to the significance of impacts from GHG emissions during the overwhelming majority of the Project’s operational life. CEQA requires that lead agencies consider long term impacts for projects with long term operations, particularly in the context of GHG emissions.159 Relying on a project’s emissions at one point in time does not meet CEQA’s requirement to assess all foreseeable impacts. Indeed, the California Supreme Court addressed this point in Newhall, noting that “over time consistency with the year 2020 goals will become a less definitive guide, especially for long term projects that will not begin operations for several years.” Here, the DSEIR’s conclusion that the Project will not result in significant impacts for the year 2020 on the grounds it is consistent with the City’s CAP does not support a determination that the Project will not result in significant greenhouse gas impacts over its operational lifespan. 157 Cleveland National Forest Foundation, 3 Cal. 5th at 519 (“CEQA requires public agencies . . . to ensure that [greenhouse gas impact] analysis stay in step with evolving scientific knowledge and state regulatory schemes.”) 158 The IKEA store in Emeryville, California, for example, is already in its 19th year of operation with no announced plans for closure anytime soon. Emeryville Today – 1990s to 2000s, City of Emeryville, https://www.ci.emeryville.ca.us/663/Emeryville-Today-1990s-to-2000s (Noting Emeryville IKEA opened in April 2000). 159 See CEQA Guidelines, § 15126.2 (discussing impacts both during the “initial and continued phases of the project”); see also Natural Resources Defense Council v. City of Los Angeles (“NRDC v. LA”) (2002) 103 Cal.App.4th 268 (CEQA requires examination of the environmental impacts of “the entire project, from start to finish”). AB Page 33 of 96 25 CONT March 16, 2018 Page 34 4174-003acp printed on recycled paper B. The Determination that Long-Term GHG Emissions Are Less Than Significant Is Not Supported By Substantial Evidence In recognition of the limits of a CAP consistency analysis is this case, the DSEIR uses a second threshold of significance for operational GHG emissions after 2020. While the DSEIR’s characterizes the analysis for 2030 as a “City of Dublin CAP Consistency Analysis,” the threshold it applies is a SB 32 2030 statewide GHG BAU reduction goal consistency threshold. The DSEIR bases this analysis on a direct comparison of the Project’s estimated reductions from a 2000 BAU scenario to the 2030 statewide emission reduction target set in SB 32.160 In this respect, the DSEIR employs the exact same methodology the California Supreme Court struck down in Center for Biological Diversity v. California Department of Fish and Wildlife (“Newhall”). Furthermore, like in that case, the DSEIR’s assumption that impacts would be less than significant based on consistency with a statewide (rather than a project-specific) goal is not supported by substantial evidence. In Newhall, the California Supreme Court squarely addressed the issue of using statewide GHG emission reduction targets as a threshold of significance for purposes of CEQA.161 In that case, the project at issue, Newhall Ranch, was a large development that included residential, community, and commercial uses to be developed on nearly 12,000 acres near the City of Santa Clarita. To assess the project’s GHG emissions the Newhall EIR considered whether the proposed Project’s emissions .would impede the State of California’s compliance with the statutory 2020 emissions reduction mandate established by AB 32.162 Relying on a similar “business-as-usual” or “BAU” methodology as the DSEIR uses here, the Newhall EIR concluded that: Because the EIR’s estimate of actual annual project emissions . . . is 31 percent below its business-as-usual estimate . . . , exceeding the Air Board’s determination of a 29 percent reduction from business as usual needed statewide, the . . . project’s likely greenhouse gas emissions will not impede 160 DSEIR, p. 3.1-63, Table 3.1-21: City of Dublin CAP Consistency Analysis – Operational Year 2030. The statewide targets of AB 197 and SB32 are not a climate action plan or a qualified greenhouse reduction plan and a direct comparison between anticipated project emissions and the reduction targets is not a “CAP Consistency Analysis.” See Guidelines § 15183.5. Furthermore, the City of Dublin CAP only addresses a 2020 reduction target. 161 Center for Biological Diversity v. California Dept. of Fish and Wildlife (2015) 62 Cal. 4th 204. 162 Id. at p. 218. AB Page 34 of 96 26 March 16, 2018 Page 35 4174-003acp printed on recycled paper achievement of A.B. 32’s goals and are therefore less than significant for CEQA purposes.163 In Newhall, the California Supreme Court concluded that assessing a project’s consistency with statewide GHG reduction goals is not per se prohibited under CEQA, but that such an assessment required substantial evidence and analysis demonstrating that such a consistency comparison was applicable. The Newhall decision held that, in that case, the EIR failed to provide substantial evidence “that Newhall Ranch’s project-level reduction of 31 percent in comparison to business as usual is consistent with achieving A.B. 32’s statewide goal of a 29 percent reduction from business as usual . . . .”164 The EIR provided no evidence to support finding that the “required percentage reduction from business as usual is the same for an individual project as for the entire state population and economy.”165 The Court held that a straight-line comparison between statewide reduction goals and project-specific reductions from BAU, without more, does not support a conclusion that project emission will result in a less than significant impact. Here, the DSEIR employs the exact same unsubstantiated methodology that the Court struck down in Newhall. The DSEIR states that “[t]he proposed project would meet the 40 percent reduction requirement over year 1990 by 2030, as required by AB 197 and SB 32.”166 Because of the Project’s estimated reduction over the BAU scenario, the DSEIR concludes that impacts from GHG emissions would be less than significant for the year 2030. The DSEIR’s analysis thus completely ignores the Supreme Court’s guidance in Newhall and employs the same flawed approach of directly comparing the Project’s anticipated reduction from BAU to the percentage of statewide reductions required under SB32. Furthermore, the DSEIR makes no attempt to determine the level of reduction an individual project must achieve to stay consistent with achieving statewide goals, as the Supreme 163 Id. The 2020 emission reduction target established by AB 32 has been superseded by the target in SB 32, which requires that statewide greenhouse gas emission are reduced to 40% below the 1990 level by 2030. 164 Id. at 225. 165 Id. at 225-226. 166 DSEIR, p. 3.1-63. AB Page 35 of 96 26 CONT March 16, 2018 Page 36 4174-003acp printed on recycled paper Court instructed would be required.167 The DSEIR simply assumes, without any evidence, that the Project must meet the same level of reduction set forth in statewide targets to avoid a significant impact. Both the California Air Resources Board and the California Supreme Court have recognized that the percent reduction required to be made by specific projects in order for the state to achieve statewide GHG reduction goal is not the same as the statewide GHG reduction goal. In Newhall, the Supreme Court noted that a greater degree of reduction is likely to be needed from new land use projects as compared to the economy as a whole because it is impractical and infeasible to require or obtain uniform reductions from all sources of GHG emissions, regardless of size or type. The Court also cited California Attorney General’s Office comments that “new development must be more GHG-efficient than [the statewide ‘business as usual’ reduction goals], given that past and current sources of emissions, which are substantially less efficient than this average, will continue to exist and emit.”168 New development, in particular, needs to be one of the primary sources of these greater reductions. This is because designing new buildings and infrastructure for maximum energy efficiency and renewable energy use is more feasible and more likely to occur than achieving the same savings by retrofitting older structures and systems. In sum, the DSEIR’s determination that impacts from the Project’s GHG emissions will be less than significant for operational emissions after 2020 is not supported by substantial evidence. The DSEIR employs the same approach and reasoning the Supreme Court considered in Newhall, yet it ignores the Court’s clear direction regarding the use of statewide targets as a threshold for project level analysis. The City cannot use statewide GHG emission goals in the absence of an analysis of how those targets translate to an individual project, and no such analysis is included in the DSEIR here. 167 See Newhall 62 Cal. 4th at 229 (explaining that a BAU comparison may be appropriate where the lead agency determines what level of reduction a particular project at the proposed location must contribute in order to comply with statewide goals.). 168 Id. at p. 226. AB Page 36 of 96 26 CONT March 16, 2018 Page 37 4174-003acp printed on recycled paper C. Substantial Evidence Shows That GHG Emissions from the Project Would Be Significant In order to properly evaluate the significance of the Project’s GHG emissions, SWAPE performed an analysis of the Project’s GHG emissions using BAAQMD’s threshold of 1,100 metric tons of carbon dioxide equivalents per year (“MTCO2e”).169 Relying on the City’s CalEEMod model, SWAPE explains that Project construction would generate 63 MTCO2e per year (amortized over 30 years).170 Additionally, Project operations would generate 13,634 MTCO23 per year after mitigation.171 Combined, the Project’s annual GHG emissions amount to 13,697 MTCO2e per year, which exceeds BAAQMD’s threshold of significance by approximately 12,597 MTCO2e per year.172 SWAPE’s analysis of the Project’s GHG emissions demonstrates that when using a legally valid threshold of significance, established by BAAQMD, substantial evidence shows that the Project would result in a cumulatively significant contribute to global climate change.173 Until an updated GHG analysis is prepared in a revised DSEIR that adequately evaluates the Project’s total GHG impact consistent with a legally valid threshold of significance, the DSEIR determination that the Project would not result in a significant GHG impact is not supported by substantial evidence. For each of these reasons, the City of Dublin (“City”) may not approve the Project until a revised document is prepared and recirculated for public review and comment. Sincerely, Collin S. McCarthy CSM:acp 169 SWAPE Comments at pp. 12-13. 170 Id. at p. 13. 171 Id. 172 Id. 173 Id. AB Page 37 of 96 27 28 EXHIBIT A AB Page 38 of 96 Scott Cashen, M.S.—Independent Biological Resources Consultant 3264 Hudson Avenue, Walnut Creek, CA 94597 1 March 15, 2018 Mr. Collin S. McCarthy Adams Broadwell Joseph & Cardozo 520 Capitol Mall, Suite 350 Sacramento, CA 95814 Subject: Comments on the Draft Supplemental Environmental Impact Report Prepared for the Ikea Retail Center Project Dear Mr. McCarthy: This letter contains my comments on the Draft Supplemental Environmental Impact Report (“DSEIR”) prepared by the City of Dublin (“City”) for the Ikea Retail Center Project (“Project”). Ikea Property, Inc. (“Applicant”) proposes the development of up to 432,099 square feet of commercial uses on 27.45 acres of mostly undeveloped land in Dublin, California. I am an environmental biologist with 25 years of professional experience in wildlife ecology and natural resources management. I have served as a biological resources expert for over 100 projects in California. My experience and scope of work in this regard has included assisting various clients with evaluations of biological resource issues, reviewing environmental compliance documents prepared pursuant to the California Environmental Quality Act (“CEQA”) and the National Environmental Policy Act (“NEPA”), and submitting written comments in response to CEQA and NEPA documents. My work has included the preparation of written and oral testimony for the California Energy Commission, California Public Utilities Commission, and Federal courts. My educational background includes a B.S. in Resource Management from the University of California at Berkeley, and a M.S. in Wildlife and Fisheries Science from the Pennsylvania State University. A true and correct copy of my current curriculum vitae is attached hereto. The comments herein are based on my review of the environmental documents prepared for the Project and other projects in the region, a review of scientific literature pertaining to biological resources known to occur in the Project area, consultations with other biological resource experts, and the knowledge and experience I have acquired during my 25-year career in the field of natural resources management. AB Page 39 of 96 A1 2 ENVIRONMENTAL SETTING FirstCarbon Solutions (“FCS”) biologists visited the Project site two times: once in the spring of 2016, and again on November 24, 2017.1 FCS did not conduct any focused (protocol-level) surveys for special-status plants or animals during these site visits. Instead, the primary purpose of the site visits was to obtain an overview of the existing habitat conditions within the Project site and the site’s potential to support sensitive biological resources so FCS could conduct a peer review of the Biological Resources Assessment (“BRA”) and Wetland Delineation (“WD”) conducted by WRA, Inc. in 2013.2 The BRA prepared by WRA was based on a single site visit (August 1, 2013) and did not include any protocol-level surveys.3 As a result, protocol-level surveys have never been conducted at the Project site. Data from protocol-level surveys are required to fully assess existing conditions, analyze Project impacts, and formulate appropriate mitigation. Deferring the surveys until after completion of the CEQA review process—as proposed in the DSEIR—prevents full disclosure of Project impacts. It also precludes the public, resource agencies, and scientific community from being able to submit informed comments pertaining to Project impacts, and from having those comments vetted during the environmental review process. These sentiments are reflected in the survey protocols prepared by the California Department of Fish and Wildlife (“CDFW”), California Burrowing Owl Consortium, and California Native Plant Society.4 Protocol-level survey data provide essential information on the presence, distribution, and abundance of sensitive biological resources at a project site. These data in turn facilitate proper understanding of the magnitude and severity of the project’s impacts to specific resources (e.g., various species), and thus, the feasibility of various mitigation options. Without protocol-level survey data, the City can only speculate on the presence of sensitive biological resources at the Project site. Similarly, without protocol-level data the City has no ability to assess the magnitude and severity of Project impacts to various resources, and subsequently, the ability of the proposed mitigation to reduce Project impacts to less-than-significant levels. As a result, the City has no basis for its conclusion that all potentially significant Project impacts would be mitigated to less-than- significant levels by the measures proposed in the DSEIR. 1 DSEIR, pp. 3.2-1 and -16. 2 DSEIR, p. 3.2-16. 3 BRA, p. 1. 4 California Department of Fish and Game. 2009. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities. Available at: <https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline>. See also California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. Available at: <https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83843>. See also California Native Plant Society. 2001 (Revised). CNPS Botanical Survey Guidelines. Available at: <http://www.cnps.org/cnps/rareplants/pdf/cnps_survey_guidelines.pdf>. See also California Burrowing Owl Consortium. 1993. Burrowing Owl Survey Protocol and Mitigation Guidelines. Available at: <https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=83842>. AB Page 40 of 96 A1 CONT 3 For example, the City has concluded that development of a mitigation plan, which would incorporate off-site habitat compensation, would effectively mitigate significant impacts to any special-status plant species that might be discovered on the Project site during preconstruction surveys.5 A conclusion of this nature relies on the presumption that all impacts can be mitigated to a less than significant level. Such a presumption is unrealistic. To illustrate this point, Douglas' fiddleneck (Amsinckia douglasiana) was detected at the Project site (although its presence was not disclosed in the DSEIR).6 The presence of Douglas' fiddleneck on the Project site represents the only known occurrence in Alameda and Contra Costa counties (it was previously believed to be extirpated from both counties). As a result, Project impacts to this locally rare species would be unmitigable because there are no off-site mitigation options (i.e., properties available for acquisition as replacement habitat). Due to the issues described above, the City needs to prepare a revised DSEIR once protocol-level surveys have been completed for the Project. Special-Status Plant Species Congdon’s tarplant (Centromadia parryi ssp. congdonii) is known to occur on approximately 6.81 acres of the Project site.7 However, the Applicant has not conducted protocol-level surveys to determine whether other special-status plant species occur on the Project site. Furthermore, because WRA did not conduct protocol-level surveys, and because its site visits were conducted after a period of below average rainfall (and during months that are generally not conducive to finding rare plants),8 it had no basis for concluding other special-status plants have “no potential” or are “unlikely” to occur at the Project site simply because those plants were not observed during its survey(s).9 Similarly, the City has no basis for its conclusion that Congdon’s tarplant is the only special-status plant species with a moderate to high potential of occurring at the Project site.10 Indeed, at least two other special-status plant species occur at the Project site: western dodder (Cuscuta occidentalis) and Douglas' fiddleneck (Amsinckia douglasiana).11 Both of these species are locally rare (i.e., rank “A1” and “*A1x ” by the East Bay Chapter of the California Native Plant Society).12 Locally rare plant species with an “A” 5 Although the DSEIR subsequently suggests the proposed mitigation would only be applied if Congdon’s tarplant is impacted by the Project. 6 BRA, Appendix D (Plant Species Observed on 5 Nov 2013) to Appendix C.2 (Wetland Delineation). 7 DSEIR, p. 3.2-5. 8 BRA, Appendix C.2 (Wetland Delineation), p. 9 and Appendix B (Wetland Delineation Data Sheets). 9 BRA, Appendix B. 10 DSEIR, p. 3.2-17. 11 BRA, Appendix A.1 (Plant Species Observed on 1 Aug 2013) and Appendix D (Plant Species Observed on 5 Nov 2013) to Appendix C.2 (Wetland Delineation). 12 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: < https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13). AB Page 41 of 96 A1 CONT 4 designations are considered special-status species under Sections 15380 and 15125(c) of CEQA.13 The presence of Douglas' fiddleneck at the Project site is especially significant because—until now—it was believed to have been extirpated from Alameda and Contra Costa counties.14 The DSEIR fails to disclose the presence of these two species at the Project site. The BRA dismissed the potential for saline clover (Trifolium hydrophilum) and hairless popcorn flower (Plagiobothrys glaber) to occur at the Project site.15 Saline clover has a Rare Plant Rank of 1B.2 and hairless popcorn flower is ranked 1A.16 Both species are associated with alkaline soils and vernal pools (and other mesic habitats),17 which are present at the Project site.18,19 According to the BRA, saline clover is unlikely to occur at the site because: “[t]he existing grassland and seasonally wet depression habitat in the Project Area is heavily disturbed and of low quality,” and hairless popcorn flower is unlikely to occur at the Project site because: “[t]his species is presumed extinct and has not been found since 1954.”20 Consequently, the BRA recommended no further actions (e.g., protocol-level surveys) for either species.21 Saline clover has been detected in disturbed areas and “low quality” habitats.22 In addition, the BRA’s statement that hairless popcorn flower has not been found since 1954 is incorrect; this species was rediscovered near Tassajara Road in Dublin during surveys 13 California Department of Fish and Game. 2009. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities. Available at: <https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=18959&inline>. See also California Native Plant Society. 2001 (Revised). CNPS Botanical Survey Guidelines. Available at: <http://www.cnps.org/cnps/rareplants/pdf/cnps_survey_guidelines.pdf>. 14 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13). 15 BRA, Appendix B. 16 Rank 1B plants are Rare, Threatened, or Endangered in California and elsewhere. Rank 1A plants are presumed extirpated in California and either rare or extinct elsewhere. Although hairless popcorn flower was believed to be extirpated, its presence in the Dublin area was verified in 2006. See Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. 17 California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and Wildlife. See also Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13). 18 BRA, Appendix C.2 (Wetland Delineation). 19 The presence of alkali mallow (Malvella leprosa) at the Project site indicates there is at least some alkaline soil. 20 Ibid. 21 Ibid. 22 California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and Wildlife. See also Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13). AB Page 42 of 96 A1 CONT 5 conducted in 2002 and 2006.23 Saline clover is also known to occur in the Tassajara Area. As a result, saline clover and hairless popcorn flower have the potential to occur at the Project site. Locally rare (i.e., A-rank) species that are known to occur in the East Dublin area (i.e., east of I-680 and north of I-580) and that have the potential to occur at the Project site include: Amaranthus palmeri, Cuscuta indecora var. indecora, Limosella acaulis, Stachys ajugoides, Trifolium barbigerum, Trifolium flavulum, Trifolium gambelii, and Triphysaria versicolor subsp. faucibarbata.24 Special-Status Branchiopods The Project site lies within the “Livermore Vernal Pool Region.”25 Ephemeral pools in the Livermore Vernal Pool Region provide habitat for special-status branchiopods, including the federally threatened vernal pool fairy shrimp, and the California linderiella, which has a NatureServe Rank of G2G3 S2S3.26 Vernal Pool Fairy Shrimp The Project site contains seasonal wetlands (vernal pools). Based on the information provided on the Wetland Delineation data sheets, the wetlands hold water longer enough to provide potential habitat for the vernal pool fairy shrimp.27 Indeed, aquatic invertebrate shells from Ostracoda were detected in two of the wetlands in 2013.28 The presence of these “seed shrimp” at the Project site provides substantial evidence that vernal pool fairy shrimp also may occur at the Project site. Mitigation incorporated into the Eastern Dublin General Plan Amendment and Specific Plan requires species-specific surveys for special-status invertebrates in appropriate wetland habitats prior to approval of specific projects in the Reduced Planning Area (which encompasses the Project site).29 Those surveys have not been conducted at the Project site.30 Instead, the BRA simply concluded: “[t]his species is unlikely to occur in the Project Area due to the lack of vernal pool habitat and the area’s history of repeated 23 Lake D. 2018. Rare, Unusual and Significant Plants of Alameda and Contra Costa Counties [web application]. Berkeley, California: East Bay Chapter of the California Native Plant Society. Available at: <https://ebcnps.fatcow.com/cgi-bin/ebrare/ebrare.cgi>. (Accessed 2018 Mar 13). 24 Personal communication with D. Lake, Unusual Plant Chair, East Bay California Native Plant Society, on 2018 Mar 14. 25 U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of California and Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. Figure III-6. 26 G2G3 = high to moderate risk of global extinction. S2S3 = high to moderate risk of statewide extinction. 27 BRA, Appendix C.2 (Wetland Delineation), Appendix B (Wetland Delineation Data Sheets). 28 Ibid. 29 City of Dublin. 1993. Addendum to Eastern Dublin General Plan Amendment and Specific Plan Environmental Impact Report. p. 22. 30 United States Fish and Wildlife Service. 1996. Interim survey guidelines to permittees for recovery permits under Section 10(a)(1)(A) of the Endangered Species Act for the listed vernal pool Branchiopods [internet]. Sacramento (CA): United States Fish and Wildlife Service, Sacramento Fish and Wildlife Office. Available at: <http://www.fws.gov/sacramento/es/Survey-Protocols- Guidelines/Documents/Interim_VP_Survey_Guidelines_to_Permittees_4-96.pdf>. AB Page 43 of 96 A1 CONT 6 discing, grading and leveling.”31 The BRA’s conclusion is not supported by evidence and it contradicts scientific information on vernal pool fairy shrimp habitat. Despite the moniker, vernal pool fairy shrimp are not limited to “vernal pools;” they also occur in vernal pool-like habitats such as seasonal wetlands and pools.32 Indeed, vernal pool fairy shrimp occur in a wide range of habitats, including degraded or otherwise poor-quality habitats such as pools created by tire tracks and roadside ditches.33 As a result, the seasonal wetlands at the Project site provide potential habitat for the vernal pool fairy shrimp. According to the Wetland Delineation, the wetlands have experienced “little disturbance” since 2008.34 This contradicts the BRA’s argument that the wetlands are unlikely to provide habitat because they have been subject to repeated disking, grading, and leveling. Nevertheless, disking, grading and leveling at the Project site do not preclude the potential for vernal pool fairy shrimp. For example, in Contra Costa County, over 100 vernal pool fairy shrimp were documented in a “non-vegetated depression in dirt road along tracks—partially scraped by bulldozer,” and that had “routine vehicle traffic through [the] area.”35 At a minimum, the wetlands at the Project site have remained undisturbed long enough to become dominated by wetland plants.36 This indicates they have also remained undisturbed long enough for vernal pool fairy shrimp colonization (or recolonization).37 Ultimately, the DSEIR provides no mention of the vernal pool fairy shrimp, and consequently, no analysis of potentially significant impacts to the species. Until protocol-level surveys have been conducted, filling of the site’s wetlands represents an unexamined, potentially significant impact to the vernal pool fairy shrimp. 31 BRA, p. 12. 32 California Natural Diversity Database. 2018 Jan 2. RareFind 5. California Department of Fish and Wildlife. 33 Ibid. See also U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of California and Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. p. II-197. 34 BRA, Appendix C.2 (Wetland Delineation), Appendix B (Wetland Delineation Data Sheets). See also p. 8. 35 California Natural Diversity Database. 2018 Jan 2. RareFind 5. California Department of Fish and Wildlife. Occurrence No. 212. 36 BRA, Appendix C.2 (Wetland Delineation). 37 United States Fish and Wildlife Service. 2007. Vernal pool fairy shrimp (Branchinecta lynchi), 5-year review: summary and evaluation. Sacramento Fish and Wildlife Office, Sacramento, CA, p. 5. Available at: <http://www.fws.gov/cno/es/images/Graphics/VPFS_5- yr%20review%20CNO%20FINAL%2027Sept07.pdf>. See also Incagnone G, F Marrone, R Barone, L Robba, L Naselli-Flores. 2015. How do freshwater organisms cross the ‘‘dry ocean’’?͒A review on passive dispersal and colonization processes with a special focus on temporary ponds. Hydrobiologia 750:103–123. See also Maquire B Jr. 1963. The Passive Dispersal of Small Aquatic Organisms and Their Colonization of Isolated Bodies of Water. Ecological Monographs 33(2):161-185. AB Page 44 of 96 A1 CONT 7 California Linderiella (formerly California fairy shrimp) Neither the DSEIR nor BRA mentions the California linderiella. California linderiella occupy the same types of habitat as the vernal pool fairy shrimp,38 and they have been detected in seasonal wetlands comparable to those found on the Project site.39 As a result, the California linderiella has the potential to occur at the Project site. Until protocol-level surveys have been conducted, filling of the site’s wetlands represents an unexamined, potentially significant impact to the California linderiella. Burrowing Owl The DSEIR fails to disclose the status and demography of the local and regional burrowing owl populations. This information is an essential component of the DSEIR because it enables the public and decision makers to evaluate the relative significance of Project impacts to the overall burrowing owl population. Burrowing owl populations have declined dramatically in the San Francisco Bay Area (“SFBA”) since the 1992 Eastern Dublin Specific Plan EIR was prepared.40 The species has been extirpated, or nearly extirpated, from six SFBA counties (Napa, Marin, San Francisco, Santa Cruz, Sonoma, and San Mateo).41 Although burrowing owls were once abundant throughout Alameda and Contra Costa counties, they are now primarily limited to the eastern portions of those counties.42 Two “large” breeding colonies of burrowing owls remain in Alameda County: one is in the Altamont Hills, and the second is in the Camp Parks area. The Project site is located at the periphery of the “Camp Parks” burrowing owl population. The Camp Parks population is the only “large” population of burrowing owls remaining in the Livermore- Amador Valley.43 Although the Project site provides good habitat for burrowing owls, neither WRA nor FCS conducted the surveys needed to determine presence of burrowing owls at the site.44 38 U.S. Fish and Wildlife Service. 2005. Recovery Plan for Vernal Pool Ecosystems of California and Southern Oregon. U.S. Fish and Wildlife Service, Portland, Oregon. pp. II-214 through II-220. 39 E.g., See EOndx #94421 in California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and Wildlife. 40 Wilkerson RL and RB Siegel. 2010. Assessing changes in the distribution and abundance of burrowing owls in California, 1993-2007. Bird Populations 10:1-36. See also Townsend SE, C Lenihan. 2003. Burrowing Owl Status in the Greater San Francisco Bay Area. Proceedings of the California Burrowing Owl Syposium. Bird Populations Monographs No. 1:60-70. Available at: <http://www.calenv.com/California_Environmental_Services/Publications_files/Townsend%20and%20Len ihan_Burrowing%20Owl.pdf>. See also Alameda Creek Alliance. 2014 Mar 21. Lawsuit Challenges Dublin Development That Will Evict Burrowing Owls [Press Release]. Available at: <http://www.alamedacreek.org/newsroom/pdf/press%20releases/2014/Camp%20Parks%20PR%203-21- 14.pdf>. 41 Townsend SE, C Lenihan. 2003. Burrowing Owl Status in the Greater San Francisco Bay Area. Proceedings of the California Burrowing Owl Syposium. Bird Populations Monographs No. 1:60-70. 42 Ibid. 43 Ibid. 44 BRA, p. 10. AB Page 45 of 96 A1 CONT 8 Burrowing owls can be difficult to detect due to their cryptic coloration, extensive use of burrows, and tendency to flush (fly away) when approached.45 As a result, burrowing owl researchers and the CDFW have concluded that four independent surveys are necessary to provide reliable information on the presence of burrowing owls.46 Data from the four surveys (termed “detection surveys” in CDFW’s Staff Report on Burrowing Owl Mitigation) are essential to avoiding, minimizing, and properly mitigating the direct and indirect effects of the Project on burrowing owls. The DSEIR requires the Applicant to conduct two pre-construction surveys prior to ground-disturbing activities at the Project site. Although CDFW guidelines recommend “take avoidance” (i.e., pre-construction) surveys, the guidelines make it clear that those surveys are not a substitute for the four “detection surveys” required to assess Project impacts and formulate appropriate mitigation.47 Because FCS and WRA failed to implement the CDFW survey protocol, the City lacks the information needed to fully disclose and evaluate Project impacts to burrowing owls, and perhaps more importantly, to ensure effective mitigation. The need to establish the baseline population of burrowing owls on a site prior to assessing impacts and mitigation measures is emphasized in CDFW’s 2012 Staff Report on Burrowing Owl Mitigation (“Staff Report”), which states: Adequate information about burrowing owls present in and adjacent to an area that will be disturbed by a project or activity will enable the Department, reviewing agencies and the public to effectively assess potential impacts and will guide the development of avoidance, minimization, and mitigation measures.48 It is not possible to effectively assess the extent of Project impacts on burrowing owls until surveys that adhere to CDFW guidelines have been conducted. As a result, the City must require the Applicant to conduct the protocol surveys described in CDFW’s 2012 Staff Report, and the results of those surveys need to be released in a revised CEQA document so that they can be thoroughly vetted by the public, resource agencies, and decision makers during the CEQA review process. Special-Status Bats The DSEIR identified three special-status bat species (pallid bat, Townsend’s big-eared bat, and Yuma myotis) that have a “moderate” potential of roosting in the building on the Project site. As with the other special-status species, the Applicant did not conduct the 45 Klute DS, LW Ayers, MT Green, WH Howe, SL Jones, JA Shaffer, SR Sheffield, TS Zimmerman. 2003. Status assessment and conservation plan for the western Burrowing Owl in the United States. Bio Tech Pub FWS/BTP-R6001-2003. Washington: US Fish and Wildlife. Available at: <https://www.fws.gov/mountain- prairie/migbirds/species/birds/wbo/Western%20Burrowing%20Owlrev73003a.pdf>. 46 See Appendix D In: California Department of Fish and Wildlife. 2012. Staff Report on Burrowing Owl Mitigation. 47 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. 48 Ibid, p. 6. AB Page 46 of 96 A1 CONT 9 survey(s) necessary to determine whether any bat species were indeed using the building as a roost site. The City’s failure to establish baseline conditions precludes the public, resource agencies, and scientific community from being able to submit informed comments pertaining to Project impacts, and from having those comments vetted during the environmental review process. PROJECT IMPACT ISSUES Special-Status Plants The DSEIR provides no analysis of direct impacts to special-status plants other than the statement that construction activities would directly impact Congdon’s tarplant if it is found on the Project site, and that this would be a potentially significant impact.49 The DSEIR fails to provide any analysis of impacts to other special-status plant species that occur, or could occur, at the Project site. Indirect impacts associated with the Project include trampling, pollution, altered hydrology, shading, invasive plants, and pesticide drift. The DSEIR fails to provide any analysis of, or mitigation for, these potentially significant indirect impacts to special- status plants. As a result, the DSEIR lacks substantial evidence supporting its finding that Project impacts on special-status plants would be less than significant. Special-Status Branchiopods The DSEIR fails to provide any analysis of, or mitigation for, potentially significant impacts to special-status branchiopods (i.e., vernal pool fairy shrimp and California linderiella). Burrowing Owl Habitat Loss By 2003, only two “large” breeding colonies of burrowing owls remained in Alameda County: one in the Altamont Hills, and one in the Camp Parks area. The Project site provides habitat for burrowing owls in the “Camp Parks” population, which is the only breeding population remaining in the Livermore-Amador Valley.50 The DSEIR fails to disclose this information. It also fails to analyze how the loss of burrowing owl habitat from the Project site may affect the Camp Parks burrowing owl population. Instead, it jumps to the conclusion that Mitigation Measure BIO-1c would mitigate impacts to burrowing owls to a less than significant level—even though Mitigation Measure BIO-1c does not provide any specific information on how the mitigation measure would, or could, mitigate significant impacts to the Camp Parks burrowing owl population. 49 DSEIR, p. 3.2-17. 50 Townsend SE, C Lenihan. 2003. Burrowing Owl Status in the Greater San Francisco Bay Area. Proceedings of the California Burrowing Owl Syposium. Bird Populations Monographs No. 1:60-70. AB Page 47 of 96 A1 CONT 10 Habitat loss caused by development is the most immediate threat to burrowing owls that reside in high growth areas of the San Francisco Bay Area.51 The further decline of burrowing owls in the few remaining core population areas—such as the Camp Parks area—will have a significant effect on the overall persistence of burrowing owls in the region. This is exemplified by the extirpation of almost all burrowing owl colonies from western Alameda and Contra Costa counties following build out in the 1980s and 1990s.52 The City is required to disclose this information, and provide robust mitigation that reflects the severity of impacts to a core population area. Eviction of Owls from Occupied Burrows The Project may involve the eviction of burrowing owls from their burrows. The DSEIR, however, fails to adequately evaluate potential impacts to burrowing owls from the temporary or permanent closure of burrows, or to identify mitigation measures sufficient to reduce such impacts below a level of significance. Consistent with CDFW guidelines, passive relocation is a potentially significant impact under CEQA that must be analyzed.53 Specifically, the temporary or permanent closure of burrows may result in: (a) significant loss of burrows and habitat for reproduction and other life history requirements; (b) increased stress on burrowing owls and reduced reproductive rates; (c) increased depredation; (d) increased energetic costs; and (e) risks posed by having to find and compete for available burrows.54 The City must disclose and thoroughly analyze the impacts associated with evicting burrowing owls from the Project site. The need for full analysis of potential impacts from passive relocation (i.e., eviction) is further supported by research that indicates most translocation projects have resulted in fewer breeding pairs of burrowing owls at the mitigation site than at the original site, and that translocation projects generally have failed to produce self-sustaining populations.55 Investigators attribute the limited success of translocation to: (a) strong site tenacity exhibited by burrowing owls, and (b) potential risks associated with forcing owls to move into unfamiliar and perhaps less preferable habitats.56 The DSEIR fails to provide a burrowing owl exclusion plan, or fundamental details associated with that plan (e.g., location of replacement burrows and compensation habitat). This makes it impossible for the public, resource agencies, and decision makers to evaluate the probability that there will be significant impacts to owls evicted from the Project site. 51 Ibid. 52 Ibid. See also California Natural Diversity Database. 2018 Mar 6. RareFind 5. California Department of Fish and Wildlife. See also Glover SG. 2009. Breeding bird atlas of Contra Costa County. Mount Diablo Audubon Society, Walnut Creek (CA). 260pp. 53 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation, p. 10. 54 Ibid. 55 Smith BW, JR Belthoff. 2001. Burrowing owls and development: short-distance nest burrow relocation to minimize construction impacts. J. Raptor Research 35:385-391. 56 Ibid. AB Page 48 of 96 A1 CONT 11 Impacts to Foraging Habitat The Project site provides suitable foraging habitat for special-status bats, the burrowing owl, and other protected bird species.57 The DSEIR’s analysis of impacts to foraging habitat for these species is limited to the statement that: “[i]t should be noted that significant impacts associated with wildlife species are associated with their potential to nest on-site; avian species can forage almost anywhere, and the loss of foraging habitat by itself does not constitute a significant impact.”58 This statement is absurd and indicates the author has minimal knowledge of the ecology associated with the special- status species that occur in the Project region. It is well established in scientific literature and mitigation guidance issued by the CDFW that the loss or degradation of foraging habitat can have a significant impact on special- status species. For example, burrowing owls depend on foraging habitat in close proximity to burrows (nest sites).59 Indeed, CDFW’s Staff Report on Burrowing Owl Mitigation reports: “burrows and the associated surrounding habitat are essential ecological requisites for burrowing owls throughout the year and especially during the breeding season.”60 As a result, burrowing owls will be eliminated from the Project site even if their burrows are protected. The loss of foraging habitat can also have a significant impact on bats. According to the Western Bat Working Group: “[i]n general, the long term persistence of North American bat species is threatened by the loss of clean, open water; modification or destruction of roosting and foraging habitat; and, for hibernating species, disturbance or destruction of hibernacula.”61 A considerable amount of foraging habitat in the region has already been lost to urban development and other habitat conversion activities (e.g., agricultural expansion and wind energy production). Much of the foraging habitat that remains in the region is threatened by additional development. For these reasons, the loss of bat foraging habitat at the Project site constitutes a potentially significant impact that must be scientifically analyzed in a revised DSEIR. The DSEIR’s assertion that “avian species can forage almost anywhere” contradicts scientific facts. For example, burrowing owls only forage in areas that support a suitable prey base and that have conditions that allow for effective hunting.62 As a result, foraging is limited to areas with sufficient prey, and where vegetation is relatively short and open.63 In addition, because burrowing owls exhibit high site fidelity, they do not 57 DSEIR, pp. 3.2-17 and -18. 58 DSEIR, p. 3.2-17. 59 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. 60 Ibid, p. 21. [emphasis added]. 61 Western Bat Working Group. 2005 (update). Species Accounts. p. 11. [emphasis added]. 62 California Department of Fish and Game. 2012. Staff Report on Burrowing Owl Mitigation. p. 24. 63 Klute DS, LW Ayers, MT Green, WH Howe, SL Jones, JA Shaffer, SR Sheffield, TS Zimmerman. 2003. Status assessment and conservation plan for the western Burrowing Owl in the United States. Bio Tech Pub FWS/BTP-R6001-2003. Washington: US Fish and Wildlife. See also Shuford WD, T Gardali, editors. 2008. California Bird Species of Special Concern: A ranked assessment of species, subspecies, and distinct AB Page 49 of 96 A2 12 readily colonize new habitats (including foraging habitats) if they are displaced from a project site.64 The Project, in conjunction with other projects in the area (i.e., Boulevard and Zeiss Innovation Center), would eliminate nearly all of the raptor foraging habitat remaining in the region (Figure 1). As a result, raptor territories associated with that habitat will be eliminated, even if the actual nest sites are not destroyed. This constitutes a significant impact that must be disclosed, analyzed, and mitigated in a revised DSEIR. Figure 1. Cumulative impacts to raptor foraging habitat in the Project area. Virtually all remaining habitat would be eliminated by the proposed Project (yellow rectangle), Zeiss Innovation Center Project (orange rectangle), and Boulevard Project (red polygon). Cumulative Impacts The DSEIR’s analysis of cumulative impacts to biological resources fails to satisfy the requirements of CEQA. First, the DSEIR fails to define the geographic scope of the City’s cumulative impacts analysis other than it was “the region surrounding the project site.”65 This description is populations of birds of immediate conservation concern in California. Studies of Western Birds 1. Western Field Ornithologists, Camarillo, California, and California Department of Fish and Game, Sacramento. 64 Rosenburg DK, KL Haley. 2004. The Ecology of Burrowing Owls in the Agroecosystem of the Imperial Valley, California. Studies in Avian Biology 27:120-135. See also Wilkerson RL and RB Siegel. 2010. Assessing changes in the distribution and abundance of burrowing owls in California, 1993-2007. Bird Populations 10:1-36. 65 DSEIR, p. 4-3. AB Page 50 of 96 A2 CONT A3 13 too vague to understand the geographic scope of the City’s analysis, and consequently, any ability to validate the conclusions presented in the DSEIR. Second, the list of cumulative projects provided in the DSEIR omits the Zeiss Innovation Center Project, which is located approximately 700 feet north of the Project site. The Zeiss Innovation Center Project would impact many of the same biological resources as the proposed Project, including Congdon’s tarplant, seasonal wetlands, burrowing owl (and other raptor) habitat, and potential habitat for the vernal pool fairy shrimp and California linderiella. Third, the DSEIR acknowledges the Project would (or could) impact wetlands, special- status plants (Congdon’s tarplant), and special-status animals (nesting birds, burrowing owl, bats).66 However, the DSEIR fails to provide any actual analysis of cumulative impacts to these resources, nor does it provide the City’s conclusion on whether cumulative impacts to these specific resources would be significant. Instead, the DSEIR simply jumps to the conclusion that the proposed mitigation would make the Project’s contribution to “any significant cumulative impact” less than cumulatively considerable.67 There are two problems with the City’s rationale: 1. None of the biological resource mitigation measures are designed to alleviate the cumulative impact; all three mitigation measures are specific to the Project site and to Project activities. Therefore, they do not address the cumulative impact posed by other projects in conjunction with the proposed Project. 2. Habitat loss, including the incremental loss of habitat from numerous small projects, is the greatest threat to most special-status species. The DSEIR does not require habitat compensation for all of the special-status species that would (or could) be affected by the Project. As a result, the Project’s contribution to the cumulatively significant loss of habitat would not be mitigated. Fourth, the DSEIR concludes the Project’s contribution to any significant cumulative impact on special-status plant species would be less than cumulatively considerable because Congdon’s tarplant would be relocated if it is found on the Project site during preconstruction surveys. The basis for this conclusion is confusing because the DSEIR does not require (or propose) relocation of Congdon’s tarplant as mitigation. Nevertheless, the DSEIR’s conclusion is not justified because the DSEIR fails to incorporate mitigation for the numerous other special-status plant species that occur, or could occur, at the Project site. Based on my review of the scientific literature, and the City’s failure to demonstrate the proposed mitigation would offset significant impacts, it is my professional opinion that the Project’s incremental contribution to cumulative impacts to the burrowing owl and Congdon’s tarplant would be cumulatively considerable. The Project may have cumulatively considerable impacts to other species as well (e.g., vernal pool fairy shrimp, special-status bats); however, I am unable to formulate a definitive opinion in this regard 66 DSEIR, p. 4-4. 67 DSEIR, p. 4-4. AB Page 51 of 96 A3 CONT 14 due to the DSEIR’s omission of baseline data pertaining to the presence of those species on the Project site. MITIGATION ISSUES Special-Status Plants The DSEIR requires the Applicant to conduct a focused survey to determine the presence of Congdon’s tarplant prior to construction. If no special-status plant species are found during the survey, then no additional mitigation measures will be implemented. However, if Congdon’s tarplant is detected, additional mitigation measures shall be required.68 There are several problems with the proposed mitigation: First, the DSEIR does not require focused surveys or mitigation for the other special- status plant species that occur, or could occur, at the Project site. As a result, potentially significant impacts to all special-status plants besides Congdon’s tarplant remain unmitigated. Second, Congdon’s tarplant is known to occur at the Project site. Therefore, there is no basis for making compensatory mitigation contingent on the results of a future survey of unknown quality, and conducted by a biologist with uncertain qualifications. This is especially true for annual plants such as Congdon’s tarplant because the presence and abundance of annual plants can fluctuate dramatically from year to year due to climatic conditions. Thus, the absence of Congdon’s tarplant from the Project site during a preconstruction survey may be the result of adverse survey conditions rather than actual absence of the species. Third, the DSEIR indicates that compensatory mitigation would not be required if activity exclusion zones can be installed around habitat occupied by Congdon’s tarplant during construction of the Project. Based on the site plan, all existing plants will be directly or indirectly affected by the Project.69 Therefore, even if activity exclusion zones are feasible, the “protected” plant populations have no chance for long-term persistence at the site once the Project is operational. Compensatory Mitigation Strategy The DSEIR requires the Applicant to prepare a mitigation plan if impacts to Congdon’s tarplant cannot be avoided. According to the DSEIR: “[a] mitigation plan may include but is not limited to the following: the acquisition of off-site mitigation areas presently supporting the Congdon’s tarplant, purchase of credits in a mitigation bank that is approved to sell credits for the Congdon’s tarplant, or payment of in-lieu fees to a public agency or conservation organization (e.g., a local land trust) for the preservation and 68 DSEIR, p. 3.2-18. 69 Indirect impacts associated with the Project include trampling, pollution, altered hydrology, shading, invasive plants, and pesticide drift. AB Page 52 of 96 A3 CONT 15 management of existing populations of Congdon’s tarplant.”70 The DSEIR cannot defer formulation of the mitigation plan unless it establishes fundamental aspects of the plan in the DSEIR. These include: (a) the performance standards (or success criteria) for the proposed mitigation, (b) a definitive enforcement mechanism that ensures performance standards are met; (c) the contingency or remedial action measures that would be triggered if success standards are not achieved; (d) the measures that would be implemented to ensure the long-term protection and management of sensitive biological resources at mitigation sites; and (e) the required monitoring program, including the monitoring techniques, effort, and frequency. Because the DSEIR lacks these fundamental details, the City has not ensured Project impacts to sensitive botanical resources would be reduced to a less than significant level. The DSEIR’s deferral of the mitigation plan is exacerbated by its failure to provide evidence that the proposed mitigation is feasible. There do not appear to be any mitigation banks that sell credits for impacts to Congdon’s tarplant.71 In addition, there do not appear to be any in-lieu fee programs that cover impacts to Congdon’s tarplant. Whereas the acquisition of off-site mitigation areas supporting Congdon’s tarplant is an acceptable option, the DSEIR fails to provide evidence that sites suitable for acquisition exist—especially given the demand generated by other projects requiring compensatory mitigation for impacts to Congdon’s tarplant. As a result, the City needs to produce a revised DSEIR that identifies the: (a) potential mitigation sites, and status of Congdon’s tarplant at those sites; (b) actual mitigation ratio being proposed; (c) performance standards for the mitigation sites; (d) required monitoring program; and, (e) measures that will be implemented to ensure the long-term protection and management of Congdon’s tarplant populations at the mitigation sites. Compensatory Mitigation Ratio According to the DSEIR, the mitigation plan should incorporate a compensatory mitigation ratio of at least 1:1. The Eastern Alameda County Conservation Strategy (“EACCS”) establishes the standard for mitigation needed to conserve species and habitat in Eastern Alameda County. The mitigation proposed in the DSEIR does not adhere to EACCS. Specifically, the EACCS establishes a standardized mitigation ratio of 5:1 for impacts to focal plant species (e.g., Congdon’s tarplant).72 In addition, the 1:1 ratio proposed in the DSEIR is not consistent with other projects in Dublin. For example, the City is requiring a 5:1 ratio for impacts to Congdon’s tarplant at the Zeiss Innovation 70 DSEIR, p. 3.2-19. 71 California Department of Fish and Wildlife. 2018. Conservation and Mitigation Banks Established in California by CDFW [website]. Available at: <https://www.wildlife.ca.gov/Conservation/Planning/Banking/Approved-Banks#r3>. 72 ICF International. 2010. Final Draft East Alameda County Conservation Strategy. Prepared for East Alameda County Conservation Strategy Steering Committee. October 2010. Table 3-12. AB Page 53 of 96 A3 CONT 16 Center Project site.73 The DSEIR fails to explain why a 5:1 ratio was needed to mitigate impacts at the Zeiss project site, while the proposed Project only requires a 1:1 ratio— even though the City analyzed both projects at approximately the same time. Because the DSEIR lacks a detailed mitigation strategy, and because the measures listed in the DSEIR do not comply with the EACCS, the City has not ensured Project impacts to Congdon’s tarplant and other special-status plant species would be reduced to a less than significant level. Burrowing Owl The DSEIR incorporates the following mitigation measures for Project impacts to burrowing owls: (1) a Burrowing Owl Survey and Impact Assessment that would be conducted immediately before ground-disturbing activities; (2) avoidance measures; (3) burrow exclusion if avoidance is not possible; and, (4) preparation and implementation of a Mitigation Plan if avoidance is not possible. I discuss each of these measures in the subsections below. Burrowing Owl Survey and Impact Assessment The DSEIR requires a preconstruction survey no more than 14 days prior to ground- disturbing activities, and a second survey within 48 hours of initial ground disturbance. Two preconstruction surveys during an undetermined time of year do not provide reliable information on burrowing owls that may be impacted by a project. As discussed above, the two “take avoidance” (preconstruction) surveys described in CDFW’s Staff Report are not intended to serve as a substitute for the four “detection” surveys needed to identify presence, assess impacts, and formulate appropriate mitigation. Rather, the “take avoidance” surveys are intended to confirm no new owls have colonized the site since completion of the “detection” surveys. According to CDFW’s Staff Report: “[a]ny new burrowing owl colonizing the project site after the CEQA document has been adopted may constitute changed circumstances that should be addressed in a re-circulated CEQA document.”74 Because the Applicant never made an attempt to establish burrowing owl occupancy at the Project site, any burrowing owls occupying the site when the preconstruction surveys are conducted would constitute changed circumstances that will need to be addressed in a re-circulated CEQA document. An additional problem with the City’s approach to obtaining the data needed to assess occupancy and implement mitigation is that it is based on the Applicant’s timing, rather than the timing needed to establish the ecological value of the site to burrowing owls. Many burrowing owls migrate seasonally, at least at a local scale. As a result, preconstruction surveys that are conducted during the non-breeding season would fail to detect individuals that breed at the site. This would lead to the false conclusion that the Project would have no impact on the species, and thus, compensatory mitigation is not 73 City of Dublin. 2017 Dec 8. Zeiss Innovation Center: Supplemental Mitigated Negative Declaration/Initial Study. p. 29. 74 Ibid, p. 10. [emphasis added]. AB Page 54 of 96 A3 CONT 17 required (per the conditions established in the DSEIR). Avoidance Measures - Buffers The DSEIR directs the Applicant to avoid disturbing or otherwise impacting burrows occupied by burrowing owls. The DSEIR, however, fails to establish any standards for the mitigation measure. For example, the DSEIR does not establish the minimum buffers that need to be implemented around burrows, or the monitoring activities that should be implemented to ensure burrowing owls are not being disturbed by construction activities. The mitigation measure should be revised to reflect CDFW guidelines, which indicate the need for buffers 50 to 500 meters, depending on the time of year and level of disturbance.75 Exclusion and Relocation Plan The DSEIR requires the Applicant, in consultation with the CDFW, to prepare a Burrowing Owl Relocation Plan if avoidance of burrowing owls or their burrows is not possible. This condition is appropriate if the final mitigation measure adopted by the City clarifies that the Applicant’s Burrowing Owl Relocation Plan must be approved by the CDFW prior to any ground-disturbing activities. Mitigation Plan The DSEIR defers critical analysis of the mitigation needed to mitigate the Project’s potentially significant impacts to burrowing owls. Specifically, it defers identifying the compensatory mitigation ratio; acceptable mitigation location and mechanism (e.g., habitat acquisition, purchase of credits at a mitigation bank, in-lieu fee, etc.); site protection methods; financial assurances; performance standards; and monitoring requirements. Instead, the DSEIR proposes to allow these critical mitigation components to be established in a subsequent Burrowing Owl Mitigation Plan, which would be reviewed and accepted by CDFW and the City prior to the first ground-disturbing activities, but would not be presented to the public prior to Project approval. This effectively robs the public from being able to submit comments on fundamental aspects of the mitigation strategy. This is extremely important because neither the CDFW nor the City has an effective oversight approach that ensures compensatory mitigation is occurring.76 The DSEIR fails to identify a mitigation ratio, and instead proposes to allow CDFW to approve a habitat compensation ratio following Project approval. CDFW’s Staff Report on Burrowing Owl Mitigation indicates that a ratio of at least 1:1 is required to mitigate impacts to burrowing owl habitat. However, a 1:1 ratio is not likely to be sufficient to mitigate impacts below a level of significance in this case due to the rapid decline of the Camp Parks population and the limited availability of compensation habitat to support that population. Accordingly, mitigation imposed by the City should require adherence 75 California Department of Fish and Game. 2012 Mar 7. Staff Report on Burrowing Owl Mitigation. p. 9. 76 Burrowing Owl Preservation Society. 2017. Burrowing Owl Mitigation in California. 43 pp. AB Page 55 of 96 A3 CONT 18 to the regional-specific Eastern Alameda County Conservation Strategy (“EACCS”). The EACCS requires compensatory mitigation for impacts to burrowing owl habitat that is within 0.5 mile of a burrowing owl nest used within the previous three years. In addition, the EACCS establishes a standardized mitigation ratio of 3:1 (3.5:1 if the mitigation site is in a different core area).77 As a result, the City needs to establish the mitigation ratio required for the Project, and it cannot assume that a ratio less than 3:1 would mitigate impacts to a less-than-significant level unless it provides scientific analysis justifying that determination. Because the DSEIR does not contain mitigation that adheres to the standards in the EACCS, and because the DSEIR fails to ensure that mitigation would have any benefit to the Camp Parks burrowing owl population, the Project’s impacts to the burrowing owl remain potentially significant. Special-Status Bats The DSEIR proposes the following mitigation for potentially significant impacts to special-status bat species: Pre-removal bat surveys of the existing on-site building shall occur no more than 30 days before its removal. If bats are found, then a qualified biologist shall develop an appropriate relocation plan consistent with USFWS, CDFW, and East Alameda County Conservation Strategy standards and policies. These measures do not ensure Project impacts are mitigated to a less-than-significant level. The DSEIR fails to identify the survey techniques that should be implemented for the pre-removal surveys. This is important for three reasons. First, bat detection often requires specialized techniques, and a technique that is effective for one species may be completely ineffective for other species.78 Second, pallid bats and Townsend’s big-eared bats are known to be extremely sensitive to human disturbance.79 For example, Townsend’s big-eared bats are so sensitive to human disturbance that simple entry into a maternity roost can cause the colony to abandon the roost (which contributes to population declines).80 As a result, pre-removal surveys may have a significant impact on bats if appropriate techniques are not used. Third, the DSEIR fails to establish minimum qualifications for the biologist conducting the pre-removal surveys. As a result, the City has no basis for assuming the surveys would be effective and would avoid disturbance to roost sites. 77 ICF International. 2010. Final Draft East Alameda County Conservation Strategy. Prepared for East Alameda County Conservation Strategy Steering Committee. October 2010. p. 3-65 and Table 3-10. 78 Western Bat Working Group. 2005 (Update). Species Accounts. Available at: <http://wbwg.org/western- bat-species/>. 79 Bureau of Land Management. 2005. Final environmental impact report and statement for the West Mojave Plan: a habitat conservation plan and California desert conservation area plan amendment. Moreno Valley (CA): U.S. Dept. of the Interior, Bureau of Land Management, California Desert District, Appendix S: Species Accounts, Pallid Bat, p. 4 and Townsend’s Big-Eared Bat, p. 4. 80 Western Bat Working Group. 2005 (Update). Species Accounts. Available at: <http://wbwg.org/western- bat-species/>. AB Page 56 of 96 A3 CONT 19 The mitigation measure requires a qualified biologist to develop an appropriate relocation plan consistent with USFWS, CDFW, and East Alameda County Conservation Strategy standards and policies. However, the DSEIR does not cite or otherwise identify those standards and policies, nor am I aware that such standards and policies exist (the EACCS does not include any for bat relocation). Suitable roost sites are the limiting factor for most bat populations.81 The DSEIR does not require the Applicant to provide replacement roosts as compensation for impacts to potential roosts at the Project site. Therefore, even if the bats are properly excluded from the existing on-site building, they may not have a suitable alternate roost in the vicinity, and the local population may be extinguished.82 This constitutes a potentially significant impact that remains unmitigated. Wetlands Mitigation Measure BIO-3a requires the Applicant to complete an updated wetland delineation to determine if the wetlands at the Project are subject to jurisdiction under Section 404 of the Clean Water Act. The DSEIR does not identify whether the Applicant’s subsequent conclusions pertaining to the jurisdictional status of the wetlands would be verified by the Army Corp of Engineers (“USACE”). Mitigation Measure BIO-3b requires the Applicant to acquire appropriate permits under Section 404 of the Clean Water Act from the USACE if the wetlands are determined to be subject to USACE jurisdiction, and to obtain Section 401 certification from the Regional Water Quality Control Board (“RWQCB”). It further requires the Applicant to prepare a wetland mitigation plan that is approved by the USACE and RWQCB. According to the DSEIR, the wetland mitigation plan shall meet the following “standards”: A mitigation plan shall be prepared that will establish suitable compensatory mitigation based on the concept of no net loss of wetland habitat values or acreages, to the satisfaction of the regulatory agencies. Specifically, a wetland mitigation plan shall be developed and implemented that includes creation, restoration, and/or enhancement of off-site wetlands prior to project ground disturbance. Mitigation areas shall be established in perpetuity through dedication of a conservation easement (or similar mechanism) to an approved environmental organization and payment of an endowment for the long-term management of the site.83 81 Ibid. 82 Bureau of Land Management. 2005. Final environmental impact report and statement for the West Mojave Plan: a habitat conservation plan and California desert conservation area plan amendment. Moreno Valley (CA): U.S. Dept. of the Interior, Bureau of Land Management, California Desert District, Appendix S: Species Accounts, Pallid Bat, p. 4. 83 DSEIR, p. 3.2-22. AB Page 57 of 96 A3 CONT 20 The DSEIR concludes these actions would reduce Project impacts to wetlands to a less- than-significant level. There are two crucial reasons why the City does not have the basis for this conclusion. First, the DSEIR impermissibly defers analysis and critical aspects of the wetlands mitigation strategy. Under CEQA, the City is obligated to identify the specific mitigation needed to mitigate Project impacts to less-than-significant levels. This includes the specific mitigation strategy (e.g., creation, restoration, or enhancement), mitigation ratio, monitoring program, and performance standards and that will be implemented to ensure the Project would have less-than-significant impacts on the environment (i.e., independent of analysis conducted by the USACE and RWQCB designed to ensure compliance with state and federal wetland regulations). Contrary to what the DSEIR suggests, the City cannot rely on deferred mitigation and the permitting requirements of other agencies to conclude impacts to wetlands would be mitigated to less-than-significant levels. For example, in its comment letter to the lead agency for another project, the RWQCB recently stated: It is inappropriate to rely upon agency regulations for determining that impacts will be at insignificant levels…Water Board staff strongly discourages the County [of Kern] from attempting to defer to the later preparation of Waste Discharge Requirements (WDRs) permits to address the above issues. Such an approach would constitute deferment of mitigation. In the event that this occurs, the Water Board may require substantial modifications to the Project during the course of permitting review to ensure all water quality impacts [are] adequately mitigated. Water Board staff encourages the Project proponents to initiate detailed plans early in the process to allow for full and adequate review of the Project to address the above issues. This planning should be concurrent with the CEQA process as opposed to a sequential permitting approach.84 Second, compliance with regulatory permits provides no assurances that Project impacts to jurisdictional wetlands would be less-than-significant. To the contrary, numerous studies have demonstrated that many compensatory mitigation projects permitted under Sections 401 and 404 of the Clean Water Act are not achieving the goal of “no overall net loss” of wetland acres and functions.85 For example, Ambrose and Lee (2004) concluded: “the Section 401 program has failed to achieve the goal of no net loss of 84 Kern County. 2011 Oct. Final Environmental Impact Report: RE Distributed Solar Projects, Chapter 7-4 (part 1), comment letter 8. 85 National Research Council. 2001. Compensating for wetland losses under the Clean Water Act. National Research Committee on Mitigating Wetland Losses. National Academy Press, Washington DC, USA. Available at: <https://www.nap.edu/catalog/10134/compensating-for-wetland-losses-under-the-clean- water-act>. See also Society of Wetland Scientists (and references therein). 2000. Position Paper on Performance Standards for Wetland Restoration and Creation. 4 pp. See also Environmental Law Institute. 2004. Measuring Mitigation: A Review of the Science for Compensatory Mitigation Performance Standards. Report prepared for the US Environmental Protection Agency. 271 pp. Available at: <http://www.forest-trends.org/documents/files/doc_609.pdf>. See also Kihslinger RL. 2008. Success of Wetland Mitigation Projects. 2008. National Wetlands Newsletter 30(2):14-16. Available at: <http://www.tetonwyo.org/DocumentCenter/View/3309>. AB Page 58 of 96 A3 CONT 21 habitat functions, values and services.”86 The National Academy of Sciences (2001) conducted a comprehensive review of compensatory wetland mitigation projects in the U.S. and found that the national “no net loss” goal is not being met because: (a) there is little monitoring of permit compliance, and (b) the permit conditions commonly used to establish mitigation success do not assure the establishment of wetland functions.87 Ambrose et al. (2007) derived similar results after examining 143 projects permitted by the California State Water Resources Control Board. Specifically, they concluded: (a) only 46% of the projects fully complied with all permit conditions, and (b) very few wetland mitigation projects were successful, especially from the ecological perspective.88 Several other studies have shown that the regulatory agencies are not ensuring the success of wetland mitigation projects.89 Most notably, a 2005 report issued by the United States Government Accountability Office concluded that: “the Corps of Engineers does not have an effective oversight approach to ensure that compensatory mitigation is occurring.”90 In summary, the DSEIR improperly defers analysis and concludes future permits issued by other agencies would ensure Project impacts to wetlands would be less-than- significant. However, substantial evidence shows that those permits have been ineffective in mitigating impacts to wetlands. Thus, the sole basis for the City’s conclusion of insignificance is not supported by evidence. 86 Ambrose RF, SF Lee. 2004. Guidance Document for Compensatory Mitigation Projects Permitted Under Clean Water Act Section 401 by the Los Angeles Regional Quality Control Board. p. 8. Available at: <https://www.researchgate.net/publication/237587967_Guidance_Document_for_Compensatory_Mitigatio n_Projects_Permitted_Under_Clean_Water_Act_Section_401_by_the_Los_Angeles_Regional_Quality_Co ntrol_Board>. 87 National Research Council. 2001. Compensating for wetland losses under the Clean Water Act. National Research Committee on Mitigating Wetland Losses. National Academy Press, Washington DC, USA. 88 Ambrose RF, JL Callaway, SF Lee. 2007. An Evaluation of Compensatory Mitigation Projects Permitted Under Clean Water Act Section 401 by the California State Water Resources Control Board, 1991-2002. xxiv + 396 pp. Available at: <https://www.waterboards.ca.gov/water_issues/programs/cwa401/docs/mitigation_finalreport_full081307. pdf>. 89 Kihslinger RL. 2008. Success of Wetland Mitigation Projects. 2008. National Wetlands Newsletter 30(2):14-16. See also Environmental Law Institute. 2004. Measuring Mitigation: A Review of the Science for Compensatory Mitigation Performance Standards. Report prepared for the US Environmental Protection Agency. 271 pp. 90 United States Government Accountability Office. 2005. Corps of Engineers Does Not Have an Effective Oversight Approach to Ensure That Compensatory Mitigation Is Occurring. Report to the Ranking Democratic Member, Committee on Transportation and Infrastructure, House of Representatives. GAO-05- 898 Wetlands Protection. Available at: <http://www.gao.gov/assets/250/247675.pdf>. AB Page 59 of 96 A3 CONT 22 This concludes my comments on the DSEIR. Please contact me if you would like to discuss any issues raised by these comments. Sincerely, Scott Cashen, M.S. Senior Biologist AB Page 60 of 96 A3 CONT EXHIBIT B AB Page 61 of 96 Cashen, Curriculum Vitae 1 Scott Cashen, M.S. Senior Wildlife Ecologist Scott Cashen has 25 years of professional experience in natural resources management. During that time he has worked as a field biologist, forester, environmental consultant, and instructor of Wildlife Management. Mr. Cashen focuses on CEQA/NEPA compliance issues, endangered species, scientific field studies, and other topics that require a high level of scientific expertise. Mr. Cashen has knowledge and experience with numerous taxa, ecoregions, biological resource issues, and environmental regulations. As a biological resources expert, Mr. Cashen is knowledgeable of the various agency-promulgated guidelines for field surveys, impact assessments, and mitigation. Mr. Cashen has led field investigations on several special-status species, including ones focusing on the yellow-legged frog, red-legged frog, desert tortoise, steelhead, burrowing owl, California spotted owl, northern goshawk, willow flycatcher, Peninsular bighorn sheep, red panda, and various forest carnivores. Mr. Cashen is a recognized expert on the environmental impacts of renewable energy development. He has been involved in the environmental review process of over 80 solar, wind, biomass, and geothermal energy projects. Mr. Cashen’s role in this capacity has encompassed all stages of the environmental review process, from initial document review through litigation support. Mr. Cashen has provided expert witness testimony on several of the Department of the Interior’s “fast-tracked” renewable energy projects. His testimony on those projects helped lead agencies develop project alternatives and mitigation measures to reduce environmental impacts associated with the projects. Mr. Cashen was a member of the independent scientific review panel for the Quincy Library Group project, the largest community forestry project in the United States. As a member of the panel, Mr. Cashen was responsible for advising the U.S. Forest Service on its scientific monitoring program, and for preparing a final report to Congress describing the effectiveness of the Herger-Feinstein Forest Recovery Act of 1998. AREAS OF EXPERTISE •CEQA, NEPA, and Endangered Species Act compliance issues •Comprehensive biological resource assessments •Endangered species management •Renewable energy development •Scientific field studies, grant writing and technical editing EDUCATION M.S. Wildlife and Fisheries Science - The Pennsylvania State University (1998) Thesis: Avain Use of Restored Wetlands in Pennsylvania B.S. Resource Management - The University of California, Berkeley (1992) AB Page 62 of 96 B1 Cashen, Curriculum Vitae 2 PROFESSIONAL EXPERIENCE Litigation Support / Expert Witness Mr. Cashen has served as a biological resources expert for over 100 projects subject to environmental review under the California Environmental Quality Act (CEQA) and/or the National Environmental Policy Act (NEPA). As a biological resources expert, Mr. Cashen reviews CEQA/NEPA documents and provides his clients with an assessment of biological resource issues. He then submits formal comments on the scientific and legal adequacy of the project’s environmental documents (e.g., Environmental Impact Statement). If needed, Mr. Cashen conducts field studies to generate evidence for legal testimony, or he can obtain supplemental testimony from his deep network of species- specific experts. Mr. Cashen has provided written and oral testimony to the California Energy Commission, California Public Utilities Commission, and U.S. district courts. His clients have included law firms, non-profit organizations, and citizen groups. REPRESENTATIVE EXPERIENCE Solar Energy Geothermal Energy •Abengoa Mojave Solar Project •Casa Diablo IV Geothermal Project •Avenal Energy Power Plant •East Brawley Geothermal •Beacon Solar Energy Project •Mammoth Pacific 1 Replacement •Blythe Solar Power Project •Orni 21 Geothermal Project •Calico Solar Project •Western GeoPower Plant •California Flats Solar Project Wind Energy •Calipatria Solar Farm II •Catalina Renewable Energy Project •Carrizo Energy Solar Farm •Ocotillo Wind Energy Project •Catalina Renewable Energy Project •SD County Wind Energy Ordinance •Fink Road Solar Farm •Searchlight Wind Project •Genesis Solar Energy Project •Shu’luuk Wind Project •Heber Solar Energy Facility •Tres Vaqueros Repowering Project •Imperial Valley Solar Project •Tule Wind Project •Ivanpah Solar Electric Generating •Vasco Winds Relicensing Project •Maricopa Sun Solar Complex Biomass Facilities •McCoy Solar Project •CA Ethanol Project •Mt. Signal and Calexico Solar •Colusa Biomass Project •Panoche Valley Solar •Tracy Green Energy Project •San Joaquin Solar I & II Other •San Luis Solar Project •DRECP •Stateline Solar Project •Carnegie SVRA Expansion Project •Solar Gen II Projects •Lakeview Substation Project •SR Solis Oro Loma •Monterey Bay Shores Ecoresort •Vestal Solar Facilities •Phillips 66 Rail Spur •Victorville 2 Power Project •Valero Benecia Crude By Rail •Willow Springs Solar •World Logistics Center AB Page 63 of 96 B1 CONT Cashen, Curriculum Vitae 3 Project Management Mr. Cashen has managed several large-scale wildlife, forestry, and natural resource management projects. Many of the projects have required hiring and training field crews, coordinating with other professionals, and communicating with project stakeholders. Mr. Cashen’s experience in study design, data collection, and scientific writing make him an effective project manager, and his background in several different natural resource disciplines enable him to address the many facets of contemporary land management in a cost-effective manner. REPRESENTATIVE EXPERIENCE Wildlife Studies •Peninsular Bighorn Sheep Resource Use and Behavior Study: (CA State Parks) •“KV” Spotted Owl and Northern Goshawk Inventory: (USFS, Plumas NF) •Amphibian Inventory Project: (USFS, Plumas NF) •San Mateo Creek Steelhead Restoration Project: (Trout Unlimited and CA Coastal Conservancy, Orange County) •Delta Meadows State Park Special-Status Species Inventory: (CA State Parks, Locke) Natural Resources Management •Mather Lake Resource Management Study and Plan – (Sacramento County) •Placer County Vernal Pool Study – (Placer County) •Weidemann Ranch Mitigation Project – (Toll Brothers, Inc., San Ramon) •Ion Communities Biological Resource Assessments – (Ion Communities, Riverside and San Bernardino Counties) •Del Rio Hills Biological Resource Assessment – (The Wyro Company, Rio Vista) Forestry •Forest Health Improvement Projects – (CalFire, SD and Riverside Counties) •San Diego Bark Beetle Tree Removal Project – (SDG&E, San Diego Co.) •San Diego Bark Beetle Tree Removal Project – (San Diego County/NRCS) •Hillslope Monitoring Project – (CalFire, throughout California) AB Page 64 of 96 B1 CONT Cashen, Curriculum Vitae 4 Biological Resources Mr. Cashen has a diverse background with biological resources. He has conducted comprehensive biological resource assessments, habitat evaluations, species inventories, and scientific peer review. Mr. Cashen has led investigations on several special-status species, including ones focusing on the foothill yellow-legged frog, mountain yellow- legged frog, desert tortoise, steelhead, burrowing owl, California spotted owl, northern goshawk, willow flycatcher, Peninsular bighorn sheep, red panda, and forest carnivores. REPRESENTATIVE EXPERIENCE Biological Assessments/Biological Evaluations (“BA/BE”) •Aquatic Species BA/BE – Reliable Power Project (SF Public Utilities Commission) •Terrestrial Species BA/BE – Reliable Power Project (SF Public Utilities Commission) •Management Indicator Species Report – Reliable Power Project (SF Public Utilities Commission) •Migratory Bird Report – Reliable Power Project (SF Public Utilities Commission) •Terrestrial and Aquatic Species BA – Lower Cherry Aqueduct (SF Public Utilities Commission) •Terrestrial and Aquatic Species BE – Lower Cherry Aqueduct (SF Public Utilities Commission) •Terrestrial and Aquatic Species BA/BE – Public Lands Lease Application (Society for the Conservation of Bighorn Sheep) •Terrestrial and Aquatic Species BA/BE – Simon Newman Ranch (The Nature Conservancy) Avian •Study design and Lead Investigator - Delta Meadows State Park Special-Status Species Inventory (CA State Parks: Locke) •Study design and lead bird surveyor - Placer County Vernal Pool Study (Placer County: throughout Placer County) •Surveyor - Willow flycatcher habitat mapping (USFS: Plumas NF) •Independent surveyor - Tolay Creek, Cullinan Ranch, and Guadacanal Village restoration projects (Ducks Unlimited/USGS: San Pablo Bay) •Study design and Lead Investigator - Bird use of restored wetlands research (Pennsylvania Game Commission: throughout Pennsylvania) •Study design and surveyor - Baseline inventory of bird species at a 400-acre site in Napa County (HCV Associates: Napa) AB Page 65 of 96 B1 CONT Cashen, Curriculum Vitae 5 •Surveyor - Baseline inventory of bird abundance following diesel spill (LFR Levine-Fricke: Suisun Bay) •Study design and lead bird surveyor - Green Valley Creek Riparian Restoration Site (City of Fairfield: Fairfield, CA) •Surveyor - Burrowing owl relocation and monitoring (US Navy: Dixon, CA) •Surveyor - Pre-construction burrowing owl surveys (various clients: Livermore, San Ramon, Rio Vista, Napa, Victorville, Imperial County, San Diego County) •Surveyor - Backcountry bird inventory (National Park Service: Eagle, Alaska) •Lead surveyor - Tidal salt marsh bird surveys (Point Reyes Bird Observatory: throughout Bay Area) •Surveyor – Pre-construction surveys for nesting birds (various clients and locations) Amphibian •Crew Leader - Red-legged frog, foothill yellow-legged frog, and mountain yellow-legged frog surveys (USFS: Plumas NF) •Surveyor - Foothill yellow-legged frog surveys (PG&E: North Fork Feather River) •Surveyor - Mountain yellow-legged frog surveys (El Dorado Irrigation District: Desolation Wilderness) •Crew Leader - Bullfrog eradication (Trout Unlimited: Cleveland NF) Fish and Aquatic Resources •Surveyor - Hardhead minnow and other fish surveys (USFS: Plumas NF) •Surveyor - Weber Creek aquatic habitat mapping (El Dorado Irrigation District: Placerville, CA) •Surveyor - Green Valley Creek aquatic habitat mapping (City of Fairfield: Fairfield, CA) •GPS Specialist - Salmonid spawning habitat mapping (CDFG: Sacramento River) •Surveyor - Fish composition and abundance study (PG&E: Upper North Fork Feather River and Lake Almanor) •Crew Leader - Surveys of steelhead abundance and habitat use (CA Coastal Conservancy: Gualala River estuary) •Crew Leader - Exotic species identification and eradication (Trout Unlimited: Cleveland NF) AB Page 66 of 96 B1 CONT Cashen, Curriculum Vitae 6 Mammals •Principal Investigator – Peninsular bighorn sheep resource use and behavior study (California State Parks: Freeman Properties) •Scientific Advisor –Study on red panda occupancy and abundance in eastern Nepal (The Red Panda Network: CA and Nepal) •Surveyor - Forest carnivore surveys (University of CA: Tahoe NF) •Surveyor - Relocation and monitoring of salt marsh harvest mice and other small mammals (US Navy: Skagg’s Island, CA) •Surveyor – Surveys for Monterey dusky-footed woodrat. Relocation of woodrat houses (Touré Associates: Prunedale) Natural Resource Investigations / Multiple Species Studies •Scientific Review Team Member – Member of the scientific review team assessing the effectiveness of the US Forest Service’s implementation of the Herger-Feinstein Quincy Library Group Act. •Lead Consultant - Baseline biological resource assessments and habitat mapping for CDF management units (CDF: San Diego, San Bernardino, and Riverside Counties) •Biological Resources Expert – Peer review of CEQA/NEPA documents (various law firms, non-profit organizations, and citizen groups) •Lead Consultant - Pre- and post-harvest biological resource assessments of tree removal sites (SDG&E: San Diego County) •Crew Leader - T&E species habitat evaluations for Biological Assessment in support of a steelhead restoration plan (Trout Unlimited: Cleveland NF) •Lead Investigator - Resource Management Study and Plan for Mather Lake Regional Park (County of Sacramento: Sacramento, CA) •Lead Investigator - Biological Resources Assessment for 1,070-acre Alfaro Ranch property (Yuba County, CA) •Lead Investigator - Wildlife Strike Hazard Management Plan (HCV Associates: Napa) •Lead Investigator - Del Rio Hills Biological Resource Assessment (The Wyro Company: Rio Vista, CA) •Lead Investigator – Ion Communities project sites (Ion Communities: Riverside and San Bernardino Counties) •Surveyor – Tahoe Pilot Project: Validation of California’s Wildlife Habitat Relationships (CWHR) Model (University of California: Tahoe NF) AB Page 67 of 96 B1 CONT Cashen, Curriculum Vitae 7 Forestry Mr. Cashen has five years of experience working as a consulting forester on projects throughout California. Mr. Cashen has consulted with landowners and timber operators on forest management practices; and he has worked on a variety of forestry tasks including selective tree marking, forest inventory, harvest layout, erosion control, and supervision of logging operations. Mr. Cashen’s experience with many different natural resources enable him to provide a holistic approach to forest management, rather than just management of timber resources. REPRESENTATIVE EXPERIENCE •Lead Consultant - CalFire fuels treatment projects (SD and Riverside Counties) •Lead Consultant and supervisor of harvest activities – San Diego Gas and Electric Bark Beetle Tree Removal Project (San Diego) •Crew Leader - Hillslope Monitoring Program (CalFire: throughout California) •Consulting Forester – Forest inventories and timber harvest projects (various clients throughout California) Grant Writing and Technical Editing Mr. Cashen has prepared and submitted over 50 proposals and grant applications. Many of the projects listed herein were acquired through proposals he wrote. Mr. Cashen’s clients and colleagues have recognized his strong scientific writing skills and ability to generate technically superior proposal packages. Consequently, he routinely prepares funding applications and conducts technical editing for various clients. PERMITS U.S. Fish and Wildlife Service Section 10(a)(1)(A) Recovery Permit for the Peninsular bighorn sheep PROFESSIONAL ORGANIZATIONS / ASSOCIATIONS The Wildlife Society Cal Alumni Foresters Mt. Diablo Audubon Society OTHER AFFILIATIONS Scientific Advisor and Grant Writer – The Red Panda Network Scientific Advisor – Mt. Diablo Audubon Society Grant Writer – American Conservation Experience AB Page 68 of 96 B1 CONT Cashen, Curriculum Vitae 8 TEACHING EXPERIENCE Instructor: Wildlife Management - The Pennsylvania State University, 1998 Teaching Assistant: Ornithology - The Pennsylvania State University, 1996-1997 PUBLICATIONS Gutiérrez RJ, AS Cheng, DR Becker, S Cashen, et al. 2015. Legislated collaboration in a conservation conflict: a case study of the Quincy Library group in California, USA. Chapter 19 in: Redpath SR, et al. (eds). Conflicts in Conservation: Navigating Towards Solutions. Cambridge Univ. Press, Cambridge, UK. Cheng AS, RJ Gutiérrez RJ, S Cashen, et al. 2016. Is There a Place for Legislating Place- Based Collaborative Forestry Proposals?: Examining the Herger-Feinstein Quincy Library Group Forest Recovery Act Pilot Project. Journal of Forestry. AB Page 69 of 96 B1 CONT EXHIBIT C AB Page 70 of 96 1 2656 29th Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mhagemann@swape.com March 15, 2018 Collin McCarthy Adams Broadwell Joseph & Cardozo 601 Gateway Boulevard, Suite 1000 South San Francisco, CA 94080 Subject: Comments on the IKEA Retail Center Project Dear Mr. McCarthy, We have reviewed the January 2018 Draft Supplemental Environmental Impact Report (DEIR) for the IKEA Retail Center Project (“Project”) located in the City of Dublin (“City”). The Project proposes to develop up to 432,099 square feet of commercial uses on 27.45 acres. The Project would be anchored by an IKEA store of up to 339,099 square feet and would feature up to 93,000 square feet of lifestyle retail-restaurant uses. The IKEA store would consist of a two-story building located over a two-level parking structure with the lower level partially below grade. The building would stand approximately 61 feet above finished grade. A recycling and refuse collection area, trash compactor, and emergency diesel generator would also be located at the rear of the store. A two-bay loading dock for home deliveries would be located on the south side of the building facing I-580. Our review concludes that DSEIR fails to adequately evaluate the Project’s Air Quality and Greenhouse Gas (GHG) impacts. As a result, emissions associated with the construction and operation of the proposed Project are inadequately addressed. An updated DSEIR should be prepared to adequately assess and mitigate the potential air quality and GHG impacts the Project may have on the surrounding environment. AB Page 71 of 96 C1 2 Air Quality Unsubstantiated Input Parameters Used to Estimate Project Emissions The DEIR relies on emissions calculated from the California Emissions Estimator Model Version CalEEMod.2016.3.2 ("CalEEMod").1 CalEEMod provides recommended default values based on site specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but the California Environmental Quality Act (CEQA) requires that such changes be justified by substantial evidence.2 Once all of the values are inputted into the model, the Project's construction and operational emissions are calculated, and "output files" are generated. These output files disclose to the reader what parameters were utilized in calculating the Project's air pollutant emissions, and make known which default values were changed as well as provide a justification for the values selected.3 When we reviewed the Project’s CalEEMod output files, we found that several of the values inputted into the model were not consistent with information disclosed in the DSEIR. As a result, the Project’s construction and operational emissions are greatly underestimated. An updated DSEIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality. Failure to Account for Material Export During Grading Phase The Project’s CalEEMod model fails to include the total amount of material anticipated to be exported during the Grading phase of construction, and as a result, the Project’s construction emissions are underestimated. According to the DSEIR, “the proposed project’s grading activities would involve 95,000 cubic yards of cut and 73,700 cubic yards of fill. Thus, 21,300 cubic yards would be exported off-site” (p. 2-12). These proposed material export activities will likely produce substantial pollutant emissions, and as a result, these activities should be included in the Project’s CalEEMod model. However, review of the Project’s CalEEMod output files demonstrates that none of the material to be exported during grading was inputted into the model. Review of the Trips and VMT table within the Project’s CalEEMod output files demonstrates that the model estimates the Project’s construction-related emissions assuming zero hauling truck trips will 1 CalEEMod Model 2013.2.2 Website Archive, available at: http://www.aqmd.gov/caleemod/download-model- 2013 2 CalEEMod Model 2013.2.2 User’s Guide, pp. 2, 9, available at: http://www.aqmd.gov/docs/default- source/caleemod/usersguideSept2016.pdf?sfvrsn=6 3 CalEEMod Model 2013.2.2 User’s Guide, pp. 7, 13, available at: http://www.aqmd.gov/docs/default- source/caleemod/usersguideSept2016.pdf?sfvrsn=6 (A key feature of the CalEEMod program is the “remarks” feature, where the user explains why a default setting was replaced by a “user defined” value. These remarks are included in the report.) AB Page 72 of 96 C1 CONT C2 3 occur during the grading phase of construction (Appendix B, pp. 63, pp. 96, pp. 130). Hauling truck trips within CalEEMod are estimated based on the total amount of material that will be imported or exported and assumes a single hauling truck can transport 16 cubic yards of material per trip.4 Therefore, assuming the Project will use 16-cubic-yard hauling trucks, approximately 1,331 hauling truck trips would be required to haul the soil off site. However, according to the CalEEMod User’s Guide, CalEEMod calculates the number of hauling truck trips assuming that one hauling truck will have 2 one-way trips (e.g., a hauling truck importing material will have a loaded arrival trip and an empty return trip, while a hauling truck exporting material will have an empty arrival trip but a loaded departure trip). 5 Using this logic, the DSEIR should have modeled the Project’s emissions assuming that there would be a total of 2,662 (2 x 1,331 hauling trips) in order to account for the 2 one-way truck trips. Thus, because the Project’s CalEEMod model estimated emissions assuming no hauling truck trips would occur during the grading phase of construction, it is extremely likely that the DSEIR’s CalEEMod model significantly underestimates the actual emissions that will be generated during construction activities. This underestimation presents a significant issue, as the inclusion of material export within the model is necessary to calculate emissions produced from material movement, including truck loading and unloading, and hauling truck trips.6 Specifically, NOx and fugitive dust emissions are generated as a result of hauling truck trips. NOx emissions are caused by fuel combustion in mobile heavy-duty diesel and gasoline-powered equipment and vehicles, while fugitive dust emissions are generated from loading and unloading material into hauling trucks.7,8 The DSEIR’s failure to include these hauling trips, therefore, underestimates the NOx and fugitive dust emissions that will be generated by the 2,662 hauling truck trips that will occur during Project construction. It is critical that the Project’s construction- related emissions are remodeled and estimated with the inclusion of the 2,662 hauling truck trips, as review of the Project’s CalEEMod output files demonstrates that the Project’s mitigated emissions, without inclusion of any hauling truck trips, are close to the Bay Area Air Quality Management’s (BAAQMD) significance threshold for NOx. Review of the DSEIR’s air quality analysis demonstrates that the Project’s emissions, with implementation of mitigation, will emit a maximum of approximately 52.44 pounds per day (lbs/day) of NOx emissions during construction (see excerpt below) (p. 3.4-44 – 3.1-45). 4 “Appendix A: Calculation Details for CalEEMod.” CalEEMod User’s Guide, BREEZE Soft ware and SCAQMD. October 2017, available at: http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 17 5 “CalEEMod’s User’s Guide.” SCAQMD, September 2016, available at: http://www.aqmd.gov/docs/default- source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p.34 6 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default- source/caleemod/upgrades/2016.3/01_user-39-s-guide2016-3-1.pdf?sfvrsn=2, p. 3, 26. 7 “Construction-Generated Criteria Air Pollutant and Precursor Emissions.” Sacramento Metropolitan Air Quality Management District, May 2016, available at: http://airquality.org/LandUseTransportation/Documents/Ch3Construction%20FINAL5-2016.pdf, p. 3-1 8 CalEEMod User’s Guide, available at: http://www.aqmd.gov/docs/default-source/caleemod/01_user-39-s- guide2016-3-2_15november2017.pdf?sfvrsn=4 , p. 33 AB Page 73 of 96 C2 CONT 4 As shown above, the Project’s mitigated emissions would result in a maximum daily emission of approximately 52 lbs/day of NOx, which is approximately 2 pounds below the BAAQMD’s NOx significance threshold of 54 lbs/day. Given the quantity of hauling truck trips that are needed to export the 21,300 cubic yards of material from the Project site, it is highly likely that the Project’s NOx emissions would exceed this threshold if emissions were modeled correctly. As such, we conclude that the emissions generated during Project construction are underestimated, and as a result, the DSEIR’s air pollution model should not be relied upon to determine Project significance. Failure to Assess the Feasibility of Obtaining Tier 4 Interim Equipment The DSEIR fails to assess the feasibility of obtaining an entire fleet of Tier 4I equipment during Project construction. The DSEIR’s CalEEMod model proposes to equip all 30 pieces construction equipment with Tier 4I engines (Appendix B, pp. 53, pp. 86, pp. 119). Due to the limited number of Tier 4I construction equipment available, the Project should have assessed the feasibility in obtaining engines equipped with Tier 4I engines for the entire construction fleet. By failing to demonstrate how the Project will actually comply with this mitigation measure, this measure is unenforceable and thus, the DSEIR cannot claim the emissions reductions from this measure. The United States Environmental Protection Agency’s (USEPA) 1998 nonroad engine emission standards were structured as a three-tiered progression. Tier 1 standards were phased-in from 1996 to 2000 and Tier 2 emission standards were phased in from 2001 to 2006. Tier 3 standards, which applied to engines from 37-560 kilowatts (kW) only, were phased in from 2006 to 2008. The Tier 4 emission standards were introduced in 2004, and were phased in from 2008 to 2015. 9 These tiered emission standards, however, are only applicable to newly manufactured nonroad equipment. According to the USEPA, “if products were built before EPA emission standards started to apply, they are generally not affected by 9 Emission Standards, Nonroad Diesel Engines, available at: https://www.dieselnet.com/standards/us/nonroad.php#tier3 AB Page 74 of 96 C2 CONT C3 5 the standards or other regulatory requirements.”10 Therefore, pieces of equipment manufactured prior to 2000 are not required to adhere to Tier 2 emission standards, and pieces of equipment manufactured prior to 2006 are not required to adhere to Tier 3 emission standards. Construction equipment often lasts more than 30 years; as a result, Tier 1 equipment and non-certified equipment are currently still in use.11 It is estimated that of the two million diesel engines currently used in construction, 31 percent were manufactured before the introduction of emissions regulations.12 Although Tier 4I engines are currently being produced and installed in new off-road construction equipment, the vast majority of existing diesel off-road construction equipment in California is not equipped with either Tier 3 or Tier 4 Final engines.13 In a 2010 white paper, the California Industry Air Quality Coalition estimated that approximately 7% and less than 1% of all off-road heavy duty diesel equipment in California was equipped with Tier 2 and Tier 3 engines, respectively.14 Similarly, based on information and data provided in the San Francisco Clean Construction Ordinance Implementation Guide for San Francisco Public Projects, the availability of Tier 3 equipment is extremely limited. In 2014, 25% of all off-road equipment in the state of California were equipped with Tier 2 engines, approximately 12% were equipped with Tier 3 engines, approximately 18% were equipped with Tier 4 Interim engines, and only 4% were equipped with Tier 4 Final engines (see excerpt below).15 10 “Frequently Asked Questions from Owners and Operators of Nonroad Engines, Vehicles, and Equipment Certified to EPA Standards.” United States Environmental Protection Agency, August 2012. Available at: http://www.epa.gov/oms/highway-diesel/regs/420f12053.pdf 11 “Best Practices for Clean Diesel Construction.” Northeast Diesel Collaborative, August 2012. Available at: http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf 12 Northeast Diesel Collaborative Clean Construction Workgroup, available at: http://northeastdiesel.org/construction.html 13 California Industry Air Quality Coalition White Paper, p. 3, available at: http://www.agc- ca.org/uploadedFiles/Member_Services/Regulatory-Advocacy-Page-PDFs/White_Paper_CARB_OffRoad.pdf 14 "White Paper: An Industry Perspective on the California Air Resources Board Proposed Off-Road Diesel Regulations." Construction Industry Air Quality Coalition, available at: http://www.agc- ca.org/uploadedFiles/Member_Services/Regulatory-Advocacy-Page-PDFs/White_Paper_CARB_OffRoad.pdf 15 “San Francisco Clean Construction Ordinance Implementation Guide for San Francisco Public Projects.” August 2015, available at: https://www.sfdph.org/dph/files/EHSdocs/AirQuality/San_Francisco_Clean_Construction_Ordinance_2015.pdf , p. 6 AB Page 75 of 96 C3 CONT 6 As demonstrated in the figure above, Tier 4I equipment only accounts for 18% of all off-road equipment currently available in the state of California. Thus, by stating that the Project proposes to use Tier 4I equipment during construction, the DSEIR is relying on obtaining an entire fleet of construction equipment that only accounts for 18% of all off-road equipment currently available in the state of California. Therefore, by failing to evaluate the feasibility of implementing Tier 4I mitigation into the Project’s construction phases, the Project’s construction emissions are underestimated. Thus, we find the conclusions made within the DSEIR to be incorrect and should not be relied upon to determine Project significance. Failure to Include All Daily Vehicle Trips Review of the Project’s CalEEMod output files demonstrates that the model underestimated the number of vehicle trips expected to occur during operation of the proposed Project. When we compare the total number of vehicle trips estimated in the Project’s CalEEMod output files to the vehicle estimates found in the Air Quality and Greenhouse Gas Supporting Document, we find that the model underestimated the number of operational vehicle trips per day. As a result, the Project’s operational emissions are underestimated and should not be relied upon to determine Project significance. According to the Air Quality and Greenhouse Gas Supporting Document, which can be found in Appendix B, the Project would generate a total of 16,898 vehicle trips per day (see excerpt below) (Table 10, Appendix B, p. 29). As you can see in the table above, Table 10 claims that the Project would have a total of 16,840 trips per day. This, however, this is incorrect. When the Total IKEA Trips, Retail Center Passenger Cars, Retail Center Light-heavy Duty Trucks, and Retail Center Heavy-heavy Duty Trucks are added together, the Project would actually generate a total of 16,898 trips per day (6,010 + 10,830 + 50 + 8 = 16,898). Table AB Page 76 of 96 C3 CONT C4 7 10 fails to include the 58 truck trips generated by the retail center when calculating the total number of vehicle trips. Therefore, to remain consistent with the daily vehicle trip estimates provided by the Air Quality and Greenhouse Gas Supporting Document, the CalEEMod model should have estimated emissions assuming that the IKEA building would generate a total of 6,010 trips per day and that the proposed retail/restaurant land use would generate a total of 10,888 trips per day, for a total of 16,898 daily trips. Review of the DSEIR’s CalEEMod model, however, demonstrates that this was not the case (see excerpt below) (Appendix B, pp. 77, pp. 110, pp. 144). As you can see in the excerpt above, the DSEIR’s CalEEMod model underestimates the number of daily trips the Project will generate by approximately 60 trips per day, or approximately 21,900 vehicle trips per year. By underestimating the total number of vehicle trips expected to occur during Project operation, the DSEIR underestimates the Project’s operational mobile-source emissions. According to Appendix A of the CalEEMod User’s Guide, CalEEMod uses the average daily trip rate when estimating a proposed project’s annual air pollutant emissions.16 Therefore, if the DSEIR underestimates the number of daily vehicle trips expected to occur throughout operation, then the proposed Project’s operational mobile- source emissions are also underestimated. It is critical that the Project’s operational emissions are modeled assuming a total of 16,898 daily trips, rather than a total of 16,840 daily trips will occur, as review of the Project’s CalEEMod output files demonstrates that the Project’s mitigated emissions are close to the BAAQMD’s significance threshold for operational NOx emissions (see excerpt below) (Appendix A, pp. 61). 16 “CalEEMod User’s Guide Appendix A: Calculation Details for CalEEMod.” CAPCOA, September 2016, available at: http://www.aqmd.gov/docs/default-source/caleemod/upgrades/2016.3/02_appendix-a2016-3-1.pdf?sfvrsn=2, p. 19 AB Page 77 of 96 C4 CONT 8 As shown above, the Project’s mitigated emissions would result in a maximum daily emission of approximately 46 lbs/day of NOx, which is approximately 8 pounds below the BAAQMD’s NOx significance threshold of 54 lbs/day. Seeing as the DSEIR’s CalEEMod model underestimates the number of operational daily vehicle trips by 60 trips per day or 21,900 trips per year, it is possible that the Project’s NOx emissions would exceed this threshold if emissions were modeled correctly. As a result, we find the DSEIR’s CalEEMod model to be unreliable and should not be relied upon to determine Project significance. An updated air quality analysis must be prepared in an updated DSEIR that adequately evaluates the Project’s air quality impact, and additional mitigation measures should be implemented, if necessary. Greenhouse Gas Failure to Adequately Determine Significance of Greenhouse Gas Impacts The DSEIR determines the significance of the Project’s GHG impact for the Project’s opening year in 2020 by demonstrating compliance with the City’s Climate Action Plan (CAP), which has a GHG reduction target of 15 percent below 2010 levels by 2020 (p. 3.1-60). Additionally, the DSEIR states that because the CAP was adopted prior to Assembly Bill 197 (AB 197) and Senate Bill 32 (SB 32) being codified into law, the Project’s GHG impact was also evaluated by calculating the Project’s emissions in the year 2030 and comparing the emissions to year 2000 levels, in order to determine if the Project would achieve a GHG reduction of 40 percent below 1990 levels by 2030, as mandated in AB 197 and SB 32 (p. 3.1-60 – 3.1-61). Review of the DSEIR’s GHG analysis demonstrates that: (1) the Project fails to demonstrate compliance with the City’s CAP and; (2) the DSEIR’s method of using a statewide GHG reduction goal as a CEQA threshold to determine whether the proposed Project has significant GHG emissions is incorrect. As a result, we find the DSEIR’s conclusion that the Project would result in a less than significant GHG impact to be unsubstantiated and incorrect. AB Page 78 of 96 C4 CONT C5 9 Failure to Demonstrate Consistency with the City’s Climate Action Plan As previously stated, the DSEIR determines the significance of the Project’s GHG impact in 2020 by evaluating the Project’s consistency with the City’s CAP. The DSEIR states, “To address this potential impact for 2020, project consistency with the City of Dublin CAP is used for this analysis. The CAP is a qualified Greenhouse Gas Reduction Strategy under CEQA, which can be used to determine the significance of GHG emissions from a project (CEQA Guidelines section 15183.5). BAAQMD also recognizes the use of a CAP as a significance threshold for a project’s GHG emissions. Therefore, if the project is consistent with the CAP, then the project would result in a less than significant cumulative impact to global climate change in 2020” (p. 3.1-65). Therefore, in order to determine Project compliance, the DSEIR provides a consistency checklist, Table 3.1-23, which includes a list of proposed measures that the Project will implement at Project build out (see table below) (Table 3.1-23, DSEIR, p. 3.1-66 – 3. 1-67). AB Page 79 of 96 C5 CONT 10 AB Page 80 of 96 C5 CONT 11 According to the CAP, however, although a CEQA review for a proposed project must identify the specific CAP measures applicable to the project, “if the measures are not otherwise binding and enforceable, they must be incorporated as conditions of approval or as mitigation measures applicable to the project”.17 Review of the Project Design Features (PDFs) and mitigation measures listed in the DSEIR’s Executive Summary Matrix, however, demonstrates that the reduction measures outlined in Table 3.1-23 were not included as PDFs, mitigation measures, or as mandatory conditions of approval (Table ES-2, p. ES-7 – ES-8; p. 3.1-35). As a result, it is unclear what measures will actually be implemented once the Project is approved, and it is unclear whether implementation of these measures would satisfy requirements set forth by the CAP. Additionally, the City’s CAP states, “identification of implementation steps and parties responsible for ensuring implementation of each action shall be included in approval documents for each project”.18 Review of the DSEIR and associated appendices demonstrates that this information has not been provided. By failing to include the measures proposed in the checklist above as mitigation or mandatory conditions of approval, these measures are not enforceable. Until the Project includes the checklist items as mitigation or mandatory conditions of approval, the Project is not consistent with the CAP and cannot claim that it is. Additionally, by failing to identify who will be responsible for implementing these measures, the Project fails to comply with the requirements set forth in the CAP. An updated DSEIR should be prepared to adequately demonstrate compliance with the CAP, must identify specific measures the Project will implement within the CAP and who will implement these measures, and must include these measures as conditions of Project approval or as mitigation. 17 “City of Dublin Climate Action Plan Update.” July 2013, available at: http://dublinca.gov/DocumentCenter/View/5799, p. 53. 18 Ibid, p. 50 AB Page 81 of 96 C5 CONT 12 Failure to Demonstrate Consistency with the City’s Climate Action Plan As stated above, in an effort to comply with CEQA, AB 197, and SB 32 the DSEIR compares the Project’s construction and operational GHG emissions to the emissions that would be generated by the Project in the absence of any GHG reduction measures, also known as a Business As Usual scenario (BAU). Using this method, the DSEIR concludes that if the Project achieves a minimum of a 40 percent reduction in GHGs between the BAU and As Proposed scenarios for 2030, which is consistent with the AB 197 and SB 32 statewide reduction goals, then the Project would have a less than significant GHG impact (p. 3.1-63). The use of this threshold to determine whether or not the Project would result in a significant GHG impact, however, is flawed and should not be relied upon to determine impact significance, as a recent law made by the California Supreme Court case Center for Biological Diversity et al. v. California Department of Fish and Wildlife and the Newhall Land and Farming Company 2015 Cal. LEXIS 9478 (Newhall Case),19makes clear that this approach utilized in the DSEIR to achieve compliance with AB 197 and SB 32 is improper. The Newhall Case concludes that lead agencies cannot use the statewide GHG emission reduction percentage as the CEQA threshold to determine whether a specific project-level proposed Project has significant GHG emissions.20 As a result, this method of determining Project significance is incorrect and should not be relied upon. The DSEIR incorrectly relies on the BAU method to determine the Project’s GHG impacts. According to the DSEIR, the Project would have to achieve a 40 percent reduction from BAU that is consistent with the CARB Scoping Plan to result in a less than significant GHG impact. By modeling the Project’s emissions within CalEEMod for the year 2000, the DSEIR takes the statewide reduction goal for 2030 and calculates the percent reduction from BAU compared to the proposed Project, and subsequently compares the total percent reduction to the statewide GHG reduction goal (p. 4.0-40). Using a straight- line comparison between Project-specific and statewide GHG emission reductions, the Ikea Retail Center Project would reduce its GHG emissions by 48 percent, which, according to the DSEIR, is consistent with the statewide reduction goal (p. 3.1-63). As a result, the DSEIR concludes that the Project would have a less than significant GHG impact (p. 3.1-63). The use of a “straight-line” comparison between Project- specific and statewide GHG emissions, both by the Newhall Ranch EIR and the Ikea Retail Center Project DSEIR, however, is flawed, because the percent reduction required by the proposed Project at the project-level is not directly comparable to the percent reduction required to meet the statewide goal. Since the Newhall Case prohibits this approach, the City cannot rely on this method for its GHG assessment. The City must identify an acceptable method of compliance with CEQA, AB 197, and SB 32 for the Project’s GHG emissions, and must determine a Newhall-compliant alternative threshold for the Project-specific GHG emissions. Updated Greenhouse Gas Analysis Demonstrates Significant Impact As previously discussed, the use of a BAU comparison method to determine the Project’s GHG impacts is entirely flawed. Furthermore, the DSEIR fails to demonstrate compliance with the City’s CAP. In order to evaluate the Project’s GHG impact, we prepared a simple analysis of the Project’s GHG emissions using 19http://www.courts.ca.gov/opinions/documents/S217763.PDF 20http://www.arb.ca.gov/cc/ab32/ab32.htm AB Page 82 of 96 C6 C7 13 the BAAQMD’s threshold of 1,100 metric tons of carbon dioxide equivalents per year (MTCO2e/year). When we utilized this threshold, rather than the incorrect BAU method used in the DSEIR, we find that the Project’s GHG emissions would result in a significant impact. As such, additional feasible mitigation should be applied to the Project in an effort to mitigate the Project’s GHG emissions to the maximum extent possible. When the emissions estimated in the DSEIR’s model are compared to this threshold, we find that the Project’s GHG emissions would exceed the BAAQMD’s 1,100 MTCO2e/year threshold. The DSEIR’s model’s annual emissions demonstrate that construction of the Project would generate 63 MTCO2e per year (when amortized over 30 years) with mitigation and operation of the Project would generate 13,634 MTCO2e per year with mitigation. When the Project’s amortized construction emissions and operational emissions are combined, we find that the Project’s GHG emissions would exceed the BAAQMD’s screening threshold of 1,100 MTCO2e per year (see table below).21 DSEIR's Annual Greenhouse Gas Emissions Phase MT CO2e/year Construction 63 Operation 13,634 Total 13,697 BAAQMD Significance Threshold 1,100 Threshold Exceeded? Yes As you can see in the table above, when the proposed Project’s GHG emissions are compared to the BAAQMD’s project-level threshold of 1,100 MT CO2e/year, we find that the Project would exceed this threshold by approximately 12,597 CO2e/year, resulting in a significant impact. Until an updated GHG analysis is prepared in a revised DSEIR that adequately evaluates the Project’s total GHG impact, the conclusions made within the DSEIR’s Air Quality and Greenhouse Gas Analysis should not be relied upon to determine Project significance. Mitigation Available to Reduce Operational Emissions The results of our GHG analysis demonstrates that operation of the Project would result in significant GHG emissions. Therefore, in an effort to reduce the Project’s operational emissions, we identified several additional mitigation measures that are applicable to the Project, which can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures.22 Mitigation for criteria pollutant emissions should include consideration of the following mobile mitigation measures in an effort to reduce the Project’s emissions to below thresholds. Reduce VMT by Increasing Transit Accessibility 21http://www.aguacaliente.org/downloads/Draft%20EIS/e5_6_GHG_110314.pdf, p. 5.6-14 22 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf AB Page 83 of 96 C7 CONT C8 14 Making transit more accessible encourages the use of other modes of transportation and therefore reduces VMT. According to CAPCOA, implementation of this mitigation measure would reduce mobile source emissions by 0.5 to 24.6 percent. The Project would need to include, at a minimum, the following design features: x A transit station/stop with high-quality, high-frequency bus service located within a five to ten- minute walk, or roughly a quarter of a mile from stop to edge of development x Or a rail station located within a 20-minute walk or roughly half a mile from station edge to development x Fast, frequent, and reliable transit service connecting to a high percentage of regional destinations x Neighborhood designed for walking and bicycling Provide Electric Vehicle Parking This mitigation measure implements accessible electric vehicle parking to reduce tailpipe emissions. Design features include conductive/inductive electric vehicle charging stations and signage prohibiting parking of non-electric vehicles. Limit Parking Supply This mitigation measure will change parking requirements and types of supply within the Project site to encourage “smart growth” development and alternative transportation choices by Project residents and employees, resulting in less VMTs. This will be accomplished in a multi-faceted strategy: x Elimination (or reduction) of minimum parking requirements x Creation of maximum parking requirements x Provision of shared parking Implement Commute Trip Reduction (CTR) Program The Project could implement a voluntary Commute Trip Reduction (CTR) program with employers to discourage single-occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking. The main difference between a voluntary and a required program is: x Monitoring and reporting is not required x No established performance standards (i.e. no trip reduction requirements) The CTR program will provide workers with assistance in using alternative modes of travel. The CTR program should include all of the following to apply the effectiveness reported by the literature: x Carpooling encouragement x Ride-matching assistance x Preferential carpool parking AB Page 84 of 96 C8 CONT 15 x Flexible work schedules for carpools x Half time transportation coordinator x Vanpool assistance x Bicycle end-trip facilities Implement Subsidized or Discounted Transit Program This Project could provide subsidized/discounted daily or monthly public transit passes. The Project may also provide free transfers between all shuttles and transit to participants. These passes can be partially or wholly subsidized by the employer or development. Many entities use revenue from parking to offset the cost of such a Project. Implement Commute Trip Reduction Marketing The Project can implement marketing strategies to reduce commute trips. Information sharing and marketing are important components to successful commute trip reduction strategies. Implementing commute trip reduction strategies without a complementary marketing strategy will result in lower VMT reductions. Marketing strategies may include: x New employee orientation of trip reduction and alternative mode options x Event promotions x Publications Implement Preferential Parking Permit Program The Project can provide preferential parking in convenient locations (such as near public transportation or building front doors) in terms of free or reduced parking fees, priority parking, or reserved parking for commuters who carpool, vanpool, ride-share or use alternatively fueled vehicles. The Project should provide wide parking spaces to accommodate vanpool vehicles. Price Workplace Parking The Project can implement workplace parking pricing at its employment centers. This may include: explicitly charging for parking for its employees, implementing above market rate pricing, validating parking only for invited guests, not providing employee parking and transportation allowances, and educating employees about available alternatives. Implement Employee Parking “Cash -Out” The Project may require employers to offer employee parking “cash-out.” The term “cashout” is used to describe the employer providing employees with a choice of forgoing their current subsidized/free parking for a cash payment equivalent to the cost of the parking space to the employer. Implement Transit Access Improvements AB Page 85 of 96 C8 CONT 16 This Project can improve access to transit facilities through sidewalk/ crosswalk safety enhancements and bus shelter improvements. When combined, these measures offer a cost-effective, feasible way to incorporate lower-emitting design features into the proposed Project, which subsequently, reduces emissions released during Project operation. A revised DSEIR must be prepared to include additional mitigation measures, as well as include an updated air quality analysis to ensure that the necessary mitigation measures are implemented to reduce Project emissions to below thresholds. Furthermore, the Project Applicant needs to demonstrate commitment to the implementation of these measures prior to Project approval, to ensure that the Project’s emissions are reduced to the maximum extent possible. Sincerely, Matt Hagemann, P.G., C.Hg. Hadley Nolan AB Page 86 of 96 C8 CONT EXHIBIT D AB Page 87 of 96 Tel: (949) 887-9013 Email: mhagemann@swape.com Matthew F. Hagemann, P.G., C.Hg., QSD, QSP Geologic and Hydrogeologic Characterization Investigation and Remediation Strategies Litigation Support and Testifying Expert Industrial Stormwater Compliance CEQA Review Education: M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984. B.A.Degree, Geology, Humboldt State University, Arcata, CA, 1982. Professional Certifications: California Professional Geologist California Certified Hydrogeologist Qualified SWPPP Developer and Practitioner Professional Experience: Matt has 30 years of experience in environmental policy, contaminant assessment and remediation, stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE, Matt has developed extensive client relationships and has managed complex projects that include consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and greenhouse gas emissions. Positions Matt has held include: x Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); x Geology Instructor, Golden West College, 2010 – 2104, 2017; x Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003); AB Page 88 of 96 D1 2 x Executive Director, Orange Coast Watch (2001 – 2004); x Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998); x Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); x Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998); x Instructor, College of Marin, Department of Science (1990 – 1995); x Geologist, U.S. Forest Service (1986 – 1998); and x Geologist, Dames & Moore (1984 – 1986). Senior Regulatory and Litigation Support Analyst: With SWAPE, Matt’s responsibilities have included: x Lead analyst and testifying expert in the review of over 300 environmental impact reports and negative declarations since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever. x Stormwater analysis, sampling and best management practice evaluation at more than 100 industrial facilities. x Expert witness on numerous cases including, for example, MTBE litigation, air toxins at hazards at a school, CERCLA compliance in assessment and remediation, and industrial stormwater contamination. x Technical assistance and litigation support for vapor intrusion concerns. x Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. x Manager of a project to evaluate numerous formerly used military sites in the western U.S. x Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells. x Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California. With Komex H2O Science Inc., Matt’s duties included the following: x Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. x Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation. x Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation. x Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. x Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York. AB Page 89 of 96 D1 CONT 3 x Expert witness testimony in a case of oil production-related contamination in Mississippi. x Lead author for a multi-volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. x Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators. Executive Director: As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council. Hydrogeology: As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows: x Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater. x Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases. x Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum. At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui. As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following: x Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water. x Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted AB Page 90 of 96 D1 CONT 4 public hearings, and responded to public comments from residents who were very concerned about the impact of designation. x Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer. Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows: x Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements. x Reviewed and wrote "part B" permits for the disposal of hazardous waste. x Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S. EPA legal counsel. x Wrote contract specifications and supervised contractor’s investigations of waste sites. With the National Park Service, Matt directed service-wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks: x Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. x Conducted watershed-scale investigations of contaminants at parks, including Yellowstone and Olympic National Park. x Identified high-levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. x Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup. x Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup. x Co-authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation- wide policy on the use of these vehicles in National Parks. x Contributed to the Federal Multi-Agency Source Water Agreement under the Clean Water Action Plan. Policy: Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following: x Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies. x Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs. x Improved the technical training of EPA's scientific and engineering staff. x Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific AB Page 91 of 96 D1 CONT 5 principles into the policy-making process. x Established national protocol for the peer review of scientific documents. Geology: With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows: x Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability. x Coordinated his research with community members who were concerned with natural resource protection. x Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon. As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following: x Supervised year-long effort for soil and groundwater sampling. x Conducted aquifer tests. x Investigated active faults beneath sites proposed for hazardous waste disposal. Teaching: From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels: x At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination. x Served as a committee member for graduate and undergraduate students. x Taught courses in environmental geology and oceanography at the College of Marin. Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California where he taught from 2010 to 2014 and in 2017. Invited Testimony, Reports, Papers and Presentations: Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon. Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S. EPA Region 9, San Francisco, California. Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao. Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee). AB Page 92 of 96 D1 CONT 6 Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles. Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association. Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee). Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA. Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA. Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ. Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter-Tribal Meeting, Torres Martinez Tribe. Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant. Invited presentation to the U.S. EPA Region 9. Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee. Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists. Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association. Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers. AB Page 93 of 96 D1 CONT 7 Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report. Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water. Unpublished report. Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report. Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report. VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report. Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina. Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada. Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City. Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996. Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP-61. Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting. Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater. Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL- contaminated Groundwater. California Groundwater Resources Association Meeting. AB Page 94 of 96 D1 CONT 8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35. Other Experience: Selected as subject matter expert for the California Professional Geologist licensing examinations, 2009-2011. AB Page 95 of 96 D1 CONT HADLEY KATHRYN NOLAN SOIL WATER AIR PROTECTION ENTERPRISE ʹ͸ͷ͸ʹͻ–Š–”‡‡–ǡ—‹–‡ʹͲͳ ƒ–ƒ‘‹…ƒǡƒŽ‹ˆ‘”‹ƒͻͲͶͲͷ ‘„‹Ž‡ǣȋ͸͹ͺȌͷͷͳǦͲͺ͵͸ ˆˆ‹…‡ǣȋ͵ͳͲȌͶͷʹǦͷͷͷͷ  ƒšǣȋ͵ͳͲȌͶͷʹǦͷͷͷͲ ƒ‹ŽǣŠƒ†Ž‡›̷•™ƒ’‡Ǥ…‘ EDUCATION UNIVERSITY OF CALIFORNIA, LOS ANGELES B.S. ENVIRONMENTAL SCIENCES & ENVIRONMENTAL SYSTEMS AND SOCIETYJUNE 2016 PROJECT EXPERIENCE SOIL WATER AIR PROTECTION ENTERPRISE SANTA MONICA, CA           SENIOR PROJECT ANALYST: CEQA ANALYSIS & MODELING x ‘†‡Ž‡†…‘•–”—…–‹‘ƒ†‘’‡”ƒ–‹‘ƒŽƒ…–‹˜‹–‹‡•ˆ‘”’”‘’‘•‡†Žƒ†—•‡’”‘Œ‡…–•—•‹‰ƒŽ‘†–‘“—ƒ–‹ˆ›…”‹–‡”‹ƒƒ‹”’‘ŽŽ—–ƒ– ƒ†‰”‡‡Š‘—•‡‰ƒ•ȋ Ȍ‡‹••‹‘•Ǥ x ”‰ƒ‹œ‡†’”‡•‡–ƒ–‹‘•…‘–ƒ‹‹‰ˆ‹‰—”‡•ƒ†–ƒ„Ž‡•–Šƒ–…‘’ƒ”‡”‡•—Ž–•‘ˆ…”‹–‡”‹ƒƒ‹”’‘ŽŽ—–ƒ–ƒƒŽ›•‡•–‘–Š”‡•Š‘Ž†•Ǥ x —ƒ–‹ˆ‹‡†ƒ„‹‡–ƒ‹”…‘…‡–”ƒ–‹‘•ƒ–•‡•‹–‹˜‡”‡…‡’–‘”Ž‘…ƒ–‹‘•—•‹‰ǡƒǤǤ”‡…‘‡†‡†•…”‡‡‹‰Ž‡˜‡Ž †‹•’‡”•‹‘‘†‡ŽǤ x ‘†—…–‡†…‘•–”—…–‹‘ƒ†‘’‡”ƒ–‹‘ƒŽŠ‡ƒŽ–Š”‹•ƒ••‡••‡–•ˆ‘””‡•‹†‡–‹ƒŽǡ™‘”‡”ǡƒ†•…Š‘‘Ž…Š‹Ž†”‡•‡•‹–‹˜‡”‡…‡’–‘”•Ǥ x ”‡’ƒ”‡†”‡’‘”–•–Šƒ–†‹•…—••ƒ†‡“—ƒ…›‘ˆƒ‹”“—ƒŽ‹–›ƒ†Š‡ƒŽ–Š”‹•ƒƒŽ›•‡•…‘†—…–‡†ˆ‘”’”‘’‘•‡†Žƒ†—•‡†‡˜‡Ž‘’‡–• •—„Œ‡…––‘”‡˜‹‡™„›˜‡”‹ˆ›‹‰…‘’Ž‹ƒ…‡™‹–ŠŽ‘…ƒŽǡ•–ƒ–‡ǡƒ†”‡‰‹‘ƒŽ”‡‰—Žƒ–‹‘•Ǥ SENIOR PROJECT ANALYST: GREENHOUSE GAS MODELING AND DETERMINATION OF SIGNIFICANCE x ˜ƒŽ—ƒ–‡†‡˜‹”‘‡–ƒŽ‹’ƒ…–”‡’‘”–•ˆ‘”’”‘’‘•‡†’”‘Œ‡…–•–‘‹†‡–‹ˆ›†‹•…”‡’ƒ…‹‡•™‹–Š–Š‡‡–Š‘†•—•‡†–‘“—ƒ–‹ˆ›ƒ† ƒ••‡•• ‹’ƒ…–•Ǥ x —ƒ–‹ˆ‹‡† ‡‹••‹‘•ˆ‘”’”‘’‘•‡†’”‘Œ‡…–•—•‹‰ƒŽ‘†–‘’”‘†—…‡”‡’‘”–•ǡ–ƒ„Ž‡•ǡƒ†ˆ‹‰—”‡•–Šƒ–…‘’ƒ”‡‡‹••‹‘• –‘ƒ’’Ž‹…ƒ„Ž‡–Š”‡•Š‘Ž†•ƒ†”‡†—…–‹‘–ƒ”‰‡–•Ǥ x ‡–‡”‹‡†…‘’Ž‹ƒ…‡‘ˆ’”‘’‘•‡†Žƒ†—•‡†‡˜‡Ž‘’‡–•™‹–Š͵ʹ ”‡†—…–‹‘–ƒ”‰‡–•ǡ™‹–Š •‹‰‹ˆ‹…ƒ…‡–Š”‡•Š‘Ž†• ”‡…‘‡†‡†„›‹”—ƒŽ‹–›ƒƒ‰‡‡–‹•–”‹…–•‹ƒŽ‹ˆ‘”‹ƒǡƒ†™‹–Š‰—‹†‡Ž‹‡••‡–ˆ‘”–Š„›Ǥ PROJECT ANALYST: ASSESSMENT OF AIR QUALITY IMPACTS FROM PROPOSED DIRECT TRANSFER FACILITY x ••‡••‡†ƒ‹”“—ƒŽ‹–›‹’ƒ…–•”‡•—Ž–‹‰ˆ”‘‹’Ž‡‡–ƒ–‹‘‘ˆƒ’”‘’‘•‡†‘ŽŽ‡…–‹‘‡”˜‹…‡‰”‡‡‡–ˆ‘”š…Ž—•‹˜‡‡•‹†‡–‹ƒŽ ƒ†‘‡”…‹ƒŽ ƒ”„ƒ‰‡ǡ‡…›…Žƒ„Ž‡ƒ–‡”‹ƒŽ•ǡƒ†”‰ƒ‹…ƒ•–‡‘ŽŽ‡…–‹‘‡”˜‹…‡•ˆ‘”ƒ…‘—‹–›Ǥ x ”‰ƒ‹œ‡†–ƒ„Ž‡•ƒ†ƒ’•–‘†‡‘•–”ƒ–‡’‘–‡–‹ƒŽƒ‹”“—ƒŽ‹–›‹’ƒ…–•”‡•—Ž–‹‰ˆ”‘’”‘’‘•‡†Šƒ—Ž‹‰–”‹’”‘—–‡•Ǥ x ‘†—…–‡†ƒ‹”“—ƒŽ‹–›ƒƒŽ›•‡•–Šƒ–…‘’ƒ”‡†“—ƒ–‹ˆ‹‡†…”‹–‡”‹ƒƒ‹”’‘ŽŽ—–ƒ–‡‹••‹‘•”‡Ž‡ƒ•‡††—”‹‰…‘•–”—…–‹‘‘ˆ†‹”‡…– –”ƒ•ˆ‡”ˆƒ…‹Ž‹–›–‘–Š‡ƒ›”‡ƒ‹”—ƒŽ‹–›ƒƒ‰‡‡–‹•–”‹…–ǯ•ȋȌ•‹‰‹ˆ‹…ƒ…‡–Š”‡•Š‘Ž†•Ǥ x ”‡’ƒ”‡†ˆ‹ƒŽƒƒŽ›–‹…ƒŽ”‡’‘”––‘†‡‘•–”ƒ–‡Ž‘…ƒŽƒ†”‡‰‹‘ƒŽƒ‹”“—ƒŽ‹–›‹’ƒ…–•ǡƒ•™‡ŽŽƒ• ‹’ƒ…–•Ǥ PROJECT ANALYST: EXPOSURE ASSESSMENT OF LEAD PRODUCTS FOR PROPOSITION 65 COMPLIANCE DETERMINATION x ƒŽ…—Žƒ–‡†Š—ƒ‡š’‘•—”‡ƒ†Ž‹ˆ‡–‹‡Š‡ƒŽ–Š”‹•ˆ‘”‘˜‡”͵ͲͲŽ‡ƒ†’”‘†—…–•—†‡”‰‘‹‰”‘’‘•‹–‹‘͸ͷ…‘’Ž‹ƒ…‡”‡˜‹‡™Ǥ x ‘’‹Ž‡†ƒ†ƒƒŽ›œ‡†Žƒ„‘”ƒ–‘”›–‡•–‹‰†ƒ–ƒƒ†’”‘†—…‡†–ƒ„Ž‡•ǡ…Šƒ”–•ǡƒ†‰”ƒ’Š•–‘‡šŠ‹„‹–‡‹••‹‘Ž‡˜‡Ž•Ǥ x ‘’ƒ”‡†ˆ‹ƒŽ‹œ‡†–‡•–‹‰†ƒ–ƒ–‘”‘’‘•‹–‹‘͸ͷƒš‹—ŽŽ‘™ƒ„Ž‡‘•‡‡˜‡Ž•ȋ•Ȍ–‘†‡–‡”‹‡Ž‡˜‡Ž‘ˆ…‘’Ž‹ƒ…‡Ǥ x ”‡’ƒ”‡†ˆ‹ƒŽƒƒŽ›–‹…ƒŽŽ‡ƒ†‡š’‘•—”‡‡”–‹ˆ‹…ƒ–‡‘ˆ‡”‹–ȋȌ”‡’‘”–•ƒ†‘”‰ƒ‹œ‡†•—’’‘”–‹‰†ƒ–ƒˆ‘”—•‡‹‡˜‹”‘‡–ƒŽ ‡ˆ‘”…‡‡–•–ƒ–—–‡”‘’‘•‹–‹‘͸ͷ…ƒ•‡•Ǥ ACCOMPLISHMENTS x Academic Honoree, ‡ƒǯ•‹•–ǡ‹˜‡”•‹–›‘ˆƒŽ‹ˆ‘”‹ƒǡ‘•‰‡Ž‡• MAR 2013, MAR 2014, JAN 2015, JAN 2016 AB Page 96 of 96 D1 CONT City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-123 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Organizations Adams Broadwell Joseph & Cardozo (AB) Note to reader: This law firm is representing Dublin Residents for Responsible Development, International Brotherhood of Electrical Workers Local 595, Plumbers & Steamfitters Local 342, and Sheet Metal Workers Local 104. Response to AB-1 The organization provided introductory remarks and provided a summary of its comments. The organization’s specific comments are addressed in detail in Response to AB-4 through Response to AB-27. Response to AB-2 The organization provided a statement of interest. No response is necessary. Response to AB-3 The organization provided standard language about CEQA requirements and asserted that the Draft SEIR fails to meet CEQA standards. The organization’s specific comments are addressed in detail in Response to AB-4 through Response to AB-27. Response to AB-4 CEQA Guidelines Section 15384(b) indicates: “Substantial evidence shall include facts, reasonable assumptions predicated on facts, and expert opinion supported by facts.” The Draft SEIR’s biological analysis is based on multiple separate biological surveys of the project site performed by two separate firms between 2013 and 2017. The first survey was conducted by WRA on August 1, 2013 and the findings were summarized in the Biological Resources Assessment (Draft SEIR Appendix C). The second survey was conducted in spring 2016 by FCS and served to confirm the findings of the WRA assessment. The third survey was conducted by FCS on November 24, 2017—approximately 2 months prior to the release of the Draft SEIR—and also served to confirm the findings of the WRA assessment. These surveys were the basis for the Draft SEIR’s description of the baseline biological conditions of the project site and thus constitute substantial evidence. Furthermore, CEQA Guidelines Section 15384(b) is silent regarding specific requirements for any technical analyses that constitute substantial evidence; as such, there is no legal basis for the claims that reconnaissance-level biological surveys are inadequate to constitute substantial evidence. The Draft SEIR discloses that the project site is largely disturbed and lacks a diversity of native species. The site is mostly composed of weedy plant species that are common and typically occur in developed areas, and the site is extensively disturbed (including regular weed abatement). Thus, the project site’s biological attributes could be fully characterized with a reconnaissance level survey. Protocol surveys are neither required nor necessary to provide further insight into the baseline biological conditions. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-124 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to AB-5 The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that vernal pool fairy shrimp are unlikely to occur on the project site because of the lack of vernal pool habitat and the site’s history of repeated discing, grading, and leveling. FCS reconfirmed this finding during the 2016 and 2017 surveys. As such, the Draft SEIR appropriately did not identify the potential presence of vernal pool fairy shrimp as a significant impact. Furthermore, the WRA Biological Resources Assessment (Draft SEIR Appendix C) noted that all seasonal depressions were man-made and formed by construction activities on the project site in 2008 and generally have limited biological value. The 12 Wetland Delineation Data Sheets provided in Appendix B of the WRA Biological Resources Assessment document the conditions of the sampling point with photographs. The photographs demonstrate that the project site has been disced and graded and certain features may have been substantially disturbed by these activities. Furthermore, the photographs show no evidence of vernal pools or vernal pool fairy shrimp. Finally, an FCS biologist conducted an additional field survey on March 28, 2018 after several recent rain events, and noted that there was no prolonged inundation present on the project site. Given that prolonged inundation is an element necessary for vernal pool habitat, this reconfirms the Draft SEIR’s findings. In sum, substantial evidence supports the Draft SEIR’s conclusion that vernal pool fairy shrimp is unlikely to occur on the project site. Response to AB-6 California linderiella (or California fairy shrimp) occurs in the same habitat as vernal pool fairy shrimp (refer to Response to AB-5, above). Thus, because vernal pool fairy shrimp is unlikely to occur, California linderiella is also unlikely to occur. See Response to AB-5 above. As previously noted, an FCS biologist conducted an additional field survey on March 28, 2018 after several recent rain events, and noted that there was no prolonged inundation present on the project site. Given that prolonged inundation is an element necessary for vernal pool habitat, this reconfirms the Draft SEIR’s findings. Response to AB-7a The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that burrowing owl had moderate potential to occur, although no indications of the species were observed. FCS reconfirmed this finding during the 2016 and 2017 surveys. The Draft SEIR stated on page 3.2-6 that, “The site exhibits good qualities for burrowing owl habitat, as it contains disturbed soils from discing and a healthy ground squirrel population.” Because burrowing owl were determined to have the potential to occur, Mitigation Measure BIO-1c was proposed, requiring a burrowing owl survey prior to ground disturbing activities. Specifically, the mitigation measure requires compliance with CDFW-accepted protocols and reduces this impact to less than significant if burrowing owls are found on-site. Thus, the Draft EIR concluded that this species could occur on-site, which is a conservative finding. Protocol-level surveys would not yield better information that could potentially change this finding. City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-125 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Finally, as a practical matter, FCS’s biological surveys indicate that the project site is covered with weedy plant species and disturbed by regular weed abatement activities. The combination of extensive groundcover and routine disturbance make the project site poorly suited to constitute burrowing owl habitat. For these reasons, there is no basis to require protocol-level surveys. Response to AB-7b Camp Parks is located approximately 760 feet northwest of the IKEA project site, with Martinelli Way (a four-lane divided roadway), Arnold Road (a four-lane divided roadway), Persimmon Place (a retail center), and Dublin Boulevard (a six-lane divided roadway) located in between. The project site is more than 700 feet away from the boundary of Camp Parks and is not contiguous to the property. Additionally, the proposed project does not propose any development or land use activities within Camp Parks. Given the urban character of the project vicinity, the project site is not part of the burrowing owl breeding colony associated with Camp Parks. Thus, no project-related impacts would occur to burrowing owl habitat within Camp Parks and there is no basis for the biological scope of the Draft SEIR to encompass this area. Refer to Response to AB-7a for discussion of the project site’s environmental setting. Response to AB-8a The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that the Congdon’s tar plant was present on-site. FCS reconfirmed this finding during the 2016 and 2017 surveys. The Draft SEIR concluded that the potential for occurrences of the Congdon’s tar plant was significant and set forth Mitigation Measure BIO-1a, which requires a focused survey for this species and measures to reduce this impact to a level of less than significant. Thus, the Draft EIR concluded that this species occurs on-site, which is a conservative finding. Protocol-level surveys would not yield better information that could potentially change this finding. The field survey for the WRA Wetland Delineation was performed on November 5, 2013. Douglas’ fiddleneck was a plant species reported to be observed during the field survey. However, this species blooms between March and May; it would be highly unlikely to observe this individual in November. Moreover, FCS’s biologist observed the more common, non-native Rancher’s fiddleneck throughout the project site during their biological surveys. These two plant species resemble each other and can be mistaken for one another. Thus, FCS concluded that the reported occurrence of the Douglas’ fiddleneck in November 2013 was in error. Thus, Draft SEIR did not identify this as a special-status species that was present on the project site. Finally, the WRA Wetland Delineation did not identify the western dodder as being present on the project site. Thus, there are no statements in the Wetland Delineation or Draft SEIR that support the organization’s claims. Response to AB-8b The WRA Biological Resources Assessment (Draft SEIR Appendix C) indicated that saline clover is unlikely to occur on the project site because the grassland and seasonally wet depression habitat is heavily disturbed and of low quality. The WRA Biological Resources Assessment indicated that hairless popcorn flower is unlikely to occur on the project site due to the lack of meadows and seeps and the lack of coastal salt marshes and swamps. FCS reconfirmed these findings during the 2016 City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-126 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx and 2017 surveys. As such, the Draft SEIR appropriately did not identify the potential presence of saline clover and hairless popcorn flower as significant impacts. Moreover, both saline clover and hairless popcorn flower occur on alkali soils. The project site lacks these soils, which further supports the finding that these species are unlikely to occur on the project site. Finally, the statement about hairless popcorn flower having not been found in Dublin since 1954 was based on a California Natural Diversity Database (CNDDB) query. The CNDDB is a screening tool used by biologists to determine what special-status species have been previously recorded to be present within a defined geographical area. Thus, it is entirely possible that amending the CNDDB query parameters to encompass a broader area would yield different results, including more recent occurrences of the hairless popcorn flower. However, a CNDDB query is not a substitute for a field survey, and any findings from the field survey would take precedence over the database search. As previously noted, the project site was surveyed on multiple occasions between 2013 and 2017 and hairless popcorn flower was not observed. Thus, the findings of the field surveys are the basis for the Draft SEIR’s conclusions about the hairless popcorn flower. Response to AB-9 The Draft SEIR’s biological resources section discloses the potential presence of bats and assigns appropriate mitigation measures to reduce impacts to less than significant levels. The Draft SEIR states on page 3.2-11 that, “The marketing building on the project site may provide night roosting habitat, and the bat may use the project site for foraging habitat.” This observation was based on multiple surveys of the project site that occurred between 2013 and 2017. Because special-status bats were determined to have the potential to occur, Mitigation Measure BIO-1d was proposed requiring pre-removal bat surveys prior to demolition of the building. Mitigation Measures BIO-1d indicates that if bats are found to be present, a relocation plan shall be developed in accordance with USFWS, CDFW, and EACCS standards and policies. Referencing agency standards and policies are clear and unequivocal performance standards. Thus, Mitigation Measure BIO-1d is adequate as written and does not need to be revised. As such, the Draft SEIR did in fact disclose the baseline conditions for special-status bats at the project site and provided appropriate mitigation. Response to AB-10 Refer to Response to AB-5 and Response to AB-6. Response to AB-11 Refer to Response to AB-7a and Response to 7b. Response to AB-12 Mitigation Measure BIO-1c sets forth avoidance as the first option for burrowing owl impacts. Under this scenario, burrowing owl nests would be protected with a buffer until the individuals have departed. If avoidance is not possible, Mitigation Measure BIO-1c requires the applicant to develop a detailed mitigation plan in consultation with CDFW. The mitigation plan must be developed in accordance with the methodology set forth in CDFW’s Staff Report on Burrowing Owl Mitigation Appendix A and must be reviewed and approved by CDFW. City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-127 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx In summary, Mitigation Measure BIO-1c includes performance standards that would reduce any adverse impacts associated with burrowing owl eviction to less than significant. Response to AB-13 Refer to Response to AB-14. Response to AB-14 CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states that mitigation measures “may specify performance standards,” “must be fully enforceable,” and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure 1c requires the applicant to retain a qualified biologist to conduct a burrowing owl survey and impact assessment. There are clear and unequivocal performance standards within this mitigation measure that are fully enforceable and roughly proportional to project impacts; for example: “Prior to the first ground disturbing activities . . .” “The surveys shall be conducted in accordance with the California Department of Wildlife (CDFW) Staff Report on Burrowing Owl Mitigation” “. . . the project applicant shall implement the following avoidance measures . . .” “The mitigation plan shall be based on the requirements set forth in Appendix A of the CDFW 2012 Staff Report on Burrowing Owl Mitigation Appendix A and the Plan shall be reviewed and accepted by CDFW . . .” For these reasons, the Mitigation Measure BIO-1c meets the applicable requirements of CEQA Guidelines Section 15126.4. Regarding the claims that the mitigation measure is deferred because it does not include a compensatory mitigation ratio, acceptable mitigation location and mechanism, site protection mechanisms, financial assurances, or monitoring requirements, all of these items (to the extent that they are applicable) would be determined as part of the consultation with CDFW required by the mitigation measure. The performance standards are contained in CDFW 2012 Staff Report on Burrowing Owl Mitigation. Because of the uncertainty associated with the outcome of the burrowing owl survey, it would be premature to make any commitments regarding these items. Requiring focused or pre-construction surveys prior to release of the Draft SEIR is contrary to sound biological practice, as the purpose of these surveys is to identify impacted individuals immediately prior to development and ensure that impacts are avoided, relocated, or otherwise mitigated. Conducting these surveys months or years before development activities would occur would not serve any meaningful purpose, particularly since these species have already been determined to have the potential to occur on the project site. Thus, identifying focused or pre-construction surveys as mitigation measures is consistent with CEQA Guidelines Section 15126.4 Mitigation Measure BIO- 1c appropriately cites the CDFW Staff Report on Burrowing Owl Mitigation as the basis for any mitigation that may be necessary. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-128 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Additionally, Page 9 the CDFW Staff Report on Burrowing Owl Mitigation sets forth buffer setback distances based on the time of year and level of disturbance of the project site. Because the exact timing of ground disturbance is not known, referencing the CDFW Staff Report is sufficient and affords the qualified biologist discretion in determining the appropriate distance. As for the East Alameda County Conservation Strategy (EACCS), this applies only to public projects, not private projects in the City of Dublin. Thus, City of Dublin has the discretion to apply different mitigation ratios on a project-by-project basis. The City has modified Mitigation Measure BIO-1c to include a minimum 1:1 ratio. Response to AB-15 This project site has been surveyed for special-status plants multiple times between 2013 and 2017. Only Congdon’s tar plant was found to be present; no other special-status plants have been documented to occur. Thus, the Draft SEIR appropriately set forth Mitigation Measure BIO-1a, requiring focused surveys for the Congdon’s tarplant. If found to be present, Mitigation Measure BIO-1a outlines multiple options for mitigating impacts including exclusion/avoidance and purchase of credits at a mitigation bank. It is appropriate to identify multiple options for mitigation, particularly when none have been officially eliminated. Furthermore, if in fact the project characteristics preclude exclusion/avoidance, purchasing credits at a mitigation bank is feasible. For these reasons, the analysis and mitigation in the Draft SEIR complies with CEQA standards and there is no legal basis to revise the Draft SEIR. Response to AB-16 CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states that mitigation measures “may specify performance standards,” “must be fully enforceable,” and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure BIO-1a requires the applicant to retain a qualified biologist to conduct a focused survey for the Congdon’s tarplant and, if found to be present, implement one of two mitigation options (avoidance/exclusion or purchase of credits at a mitigation bank). There are clear and unequivocal performance standards within this mitigation measure that are fully enforceable and roughly proportional to project impacts. For these reasons, Mitigation Measure BIO-1a meets the applicable requirements of CEQA Guidelines Section 15126.4. Regarding the claims that there are no existing mitigation banks that sell credits for the Congdon’s tarplant, the Kaiser Dublin Medical Center entered into an agreement to purchase credits for this species at a mitigation bank. Thus, if the Congdon’s tarplant is found on the project site, it would be expected that the applicant could also purchase credits at this mitigation bank. Regardless of this specific mitigation bank’s availability, the mitigation measure includes other mitigation options and requires consultation with, and approval by, the CDFW and the City of the mitigation plan prior to the commencement of any activities that would impact Congdon’s tar plant. Response to AB-17 Mitigation Measure BIO-1a employs a standard of “a minimum ratio of 1:1,” which does not preclude a higher ratio and as stated, the mitigation ratio shall be development in consultation with, and approved by, the CDFW and the City. Moreover, as previously noted, EACCS is advisory for private City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-129 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx development projects, and the City of Dublin has the discretion to apply different mitigation ratios on a project-by-project basis. Response to AB-18 Refer to Response to AB-9. Response to AB-19 There are several species that have been determined to potentially occur and have appropriate corresponding mitigation to reduce impacts to less than significant. Furthermore, the site mostly represents an island of ruderal vegetation in the midst of extensive commercial development. For these reasons with the implementation of required mitigation, cumulative impacts to biological resources would be less than significant. The Zeiss Innovation Center Project has been added to the list of cumulative projects in Table 4-1. This change is noted in Section 5, Errata. However, it should be noted that the Draft SEIR is a supplement to the Eastern Dublin Specific Plan EIR, which encompassed both the IKEA and Zeiss project sites. The Eastern Dublin Specific Plan EIR contemplated development on both sites, and, thus, development at the Zeiss site was contemplated in a prior round of environmental review. This renders the omission of the Zeiss Innovation Center Project immaterial. Response to AB-20 The site has 1.92 acres of wetlands under State law subject to RWCQB jurisdiction. Since the site design will impact these areas, the impacts and mitigation measures identify a detailed permitting process under Section 401 that identifies mitigation to ensure no net loss of wetland resources. If delineation finds that wetlands are subject to federal jurisdiction, the mitigation measure also requires that the project obtain a 404 permit. Response to AB-21 The organization’s specific comments will be addressed in Response to AB-22 through Response to AB-27. Response to AB-22 The preliminary information provided by the applicant and utilized in the CalEEMod model runs was that the project site would be balanced with no export or import of dirt during grading of the proposed project. However, during development of the Draft SEIR, more refined grading assumptions were developed, which found that 21,300 cubic yards of dirt would need to be exported during grading of the project. The required export of 21,300 cubic yards during grading was included in Section 2.3, Project Characteristics of the Draft SEIR but was not included in the Air Quality modeling assumptions provided in Appendix B or in the CalEEMod model runs performed for the proposed project. For the air modeling in the Final SEIR to be consistent with the most current version of the project description that includes the export of 21,300 cubic yards of dirt during grading of the project, the CalEEMod Model was re-run and the CalEEMod output files are included as Appendix I to the Final SEIR. In addition, the revised Table 3.1-7 and revised Table 3.1-8 are provided in Section 4, Errata. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-130 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx As shown the revised Tables 3.1-7 and 3.1-8, the addition of the export of 21,300 cubic yards to the grading phase in the CalEEMod model does not result in any new impacts not previously discussed in the Draft SEIR and no new mitigation measures are required. The entire project site is proposed to be graded in one phase. Although building construction activities may be staggered, the SEIR’s air quality analysis assumed a worst-case scenario of all buildings being constructed simultaneously. Thus, staggered building construction would result in a lower amount of emissions being spread over a longer period, which would be less severe than what was modeled in the SEIR. The claim that the additional emissions created from the export of dirt during grading activities may result in an exceedance of the BAAQMD thresholds does not have factual basis since grading (and soil export) would not overlap with building construction, paving and architectural coating activities, which are well below the BAAQMD thresholds for the mitigated conditions. Response to AB-23 Table 10 from Appendix B included a typo for the Retail Center Passenger Cars of 10,830 daily trips. The 10,830 daily trips came from Table 3.6-10 of the DSEIR and represents the total gross daily trips generated from the Non-IKEA land uses. The 10,830 daily trips should have been entered on the row for Total Retail Center Trips and the Passenger Cars should have been 10,772 daily trips, which is calculated by subtracting the truck trips from the total daily trips. The Total Project Trips shown in Table 10 of 16,840 daily trips is the correct amount for the project and is what was analyzed in the CalEEMod model runs. The corrected version of Table 10 is provided in Section 4, Errata. This does not change any impact conclusion or result in any new impacts not previously discussed in the Draft SEIR. Response to AB-24 The organization claimed that the Draft SEIR’s determination that global warming impacts would be less than significant is not supported by substantial evidence. Although the DSEIR does not reference the California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan), prepared by the California Air Resource Board (CARB) in November 2017 (which was prepared two months before publication of the DSEIR), the 2017 Scoping Plan was prepared by CARB in order to provide a pathway for the State to meet the GHG emission reduction goals provided in AB 197 and SB 32, and provides substantial evidence for the threshold utilized in the DSEIR for the year 2030 GHG emissions analysis. The 2017 Scoping Plan provides guidance for local agencies in California to meet the AB 197 and SB 32 climate goal of 40 percent below 1990 levels by year 2030, and provides the following text of how local agency climate action plans should be updated to meet the new 2030 and 2050 climate goals: Numerous local governments in California have already adopted GHG emissions reduction goals for year 2020 consistent with AB 32. CARB advises that local governments also develop community-wide GHG emissions reduction goals necessary to reach 2030 and 2050 climate goals. Emissions inventories and reduction goals should be expressed in mass emissions, per capita emissions, and service population emissions. To do this, local governments can start by developing a community-wide GHG emissions target consistent with the accepted protocols as City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-131 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx outlined in OPR’s General Plan Guidelines Chapter 8: Climate Change. They can then calculate GHG emissions thresholds by applying the percent reductions necessary to reach 2030 and 2050 climate goals (i.e., 40 percent and 80 percent, respectively) to their community-wide GHG emissions target. Since the statewide per capita targets are based on the statewide GHG emissions inventory that includes all emissions sectors in the State, it is appropriate for local jurisdictions to derive evidence-based local per capita goals based on local emissions sectors and population projections that are consistent with the framework used to develop the statewide per capita targets. The resulting GHG emissions trajectory should show a downward trend consistent with the statewide objectives. The recommendation for a community- wide goal expands upon the reduction of 15 percent from “current” (2005–2008) levels by 2020 as recommended in the 2008 Scoping Plan. (Emphasis added). As stated above in the 2017 Scoping Plan, local agencies can “calculate GHG emissions thresholds by applying the percent reductions necessary to reach 2030 and 2050 climate goals (i.e., 40 percent and 80 percent, respectively to their community-wide GHG emissions target.” As such, the year 2030 GHG emissions threshold of 40 percent below 1990 levels by year 2030 that was utilized in the DSEIR is substantiated by evidence provided in the 2017 Scoping Plan. In addition, the project contains many differences from the “Newhall” project that consisted of a mostly residential project located in an undeveloped area and would be considered a “leapfrog” development. First, the project consists of an infill commercial retail project with residential uses located within walking distance and existing transit (both bus and light rail stations) within walking distance to the project site. The proposed project has also committed to implementation of: • Project Design Feature 1, which requires development of an on-site walkway/bikeway system to promote non-vehicular transportation; • Project Design Feature 2, which requires the IKEA store to be designed to achieve a LEED Silver or higher rating; and • Project Design Feature 3, which requires the installation of a minimum 1,200-kilowatt PV solar panel system on the IKEA store building. With implementation of Project Design Features 1, 2, and 3 and consideration of the placement of the proposed project as an in-fill development that is transit accessible, the proposed project currently complies with the City’s CAP and meets the GHG emissions reduction targets provided in 2017 Scoping Plan implementing SB 32. Response to AB-25 The commenter claims that a typical project should be analyzed for a 30-year lifespan (2020 to 2050). However, as explained above in Response to AB-24, the project’s 2020 emissions were analyzed in accordance with the CAP. The Project’s post-2020 emissions were analyzed in accordance with standards under SB 32 and the 2017 Scoping Plan. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-132 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to AB-26 Refer to Responses to AB-24 and AB-25. Response to AB-27 The organization asserted that substantial evidence exists demonstrating that greenhouse gas emissions from the project would be significant. The organization referenced modeling performed by it consultant indicating that the project would generate 63 metric tons of carbon dioxide equivalents (MTCO2e) during construction and 13,634 MTCO2e during operation annually, which exceed the BAAQMD’s threshold of 1,100 MTCO2e annually. The organization stated that the greenhouse gas emissions analysis must be revised and recirculated with a legally valid threshold of significance. The BAAQMD’s CEQA Air Quality Guidelines, prepared May 2017, details a few different thresholds that may be utilized in the analysis of a project’s GHG emissions. The BAAQMD’s thresholds are detailed on page 3.1-60 of the DSEIR. It is important to note that in the CEQQ Air Quality Guidelines, the BAAQMD utilizes the word “or” in detailing the different thresholds, which means that a project only needs to be found less than significant for one of the thresholds in order to provide a determination of less than significant in the DSEIR. Since the City has adopted a CAP, the DSEIR determined that compliance with the CAP is the most applicable threshold for the proposed project, and it is the threshold that was utilized in the DSEIR. See Responses to AB-24 and AB-25 for the discussion of post-2020 thresholds of significance for GHG emissions used in the DSEIR. Response to AB-28 For the reasons provided in Response to AB-1 through Response to AB-27, there is no legal basis to revise and recirculate the Draft SEIR. Response to AB-A-1 The following comment consists of a letter prepared by Scott Cashen, an independent biological resources consultant, that is referenced by the preceding comments. Topics addressed include baseline biological setting, Congdon’s tarplant, saline clover, hairless popcorn flower, vernal pool fairy shrimp, California Linderiella, the burrowing owl, and special-status bats. Refer to Response to AB-4 through Response to AB-20. Response to AB-A-2 The author disputed a statement in the Draft SEIR that the loss of foraging habitat does not constitute a significant impact, and asserted that the development of the proposed project would result in significant impacts on the burrowing owl and bats. The Draft SEIR’s statement regarding the wide availability of foraging habitat on page 3.2-17 was provided in the context of raptors such as the white-tailed kite. The purpose was to illustrate the difference between nesting and foraging habitat, and note that mitigation for loss of foraging habitat is typically not required because of its ubiquity and, therefore, is less than significant under CEQA. Refer to Response to AB-11 through Response to AB-7a, AB-7b, and AB-9 for discussion of the burrowing owl and bats. City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-133 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to AB-A-3 The following comments were referenced in the preceding comments. Topics addressed include cumulative impacts, special-status plants, compensatory mitigation, the burrowing owl, special- status bats, and wetlands. Refer to Response to AB-4 through Response to AB-20. Response to AB-B-1 This comment consists of Scott Cashen’s resume. No response is necessary. Response to AB-C-1 This comment consists of general statements describing what the remainder of the letter will analyze without providing any specific claims. The commenter’s specific comments are addressed in detail in Response to AB-C-2 through Response to AB-C-8. Response to AB-C-2 Refer to Response to AB-22. Response to AB-C-3 Refer to Response to LD-3 Response to AB-C-4 Refer to Response to AB-23. Response to AB-C-5 This commenter incorrectly claims that in order for the project to be consistent with the CAP that the DSEIR needs to include mitigation measures or mandatory conditions of approval; however, the DSEIR was able to demonstrate consistency with the CAP through Project compliance with city and state regulations. Response to AB-C-6 This comment was addressed above in Response to AB-24. Response to AB-C-7 This comment was addressed above in Response to AB-27. Response to AB-C-8 The Draft SEIR found through implementation of Mitigation Measures AIR-3a, AIR-3b, AIR-3c, TRANS-1a, TRANS-1b, TRANS-1c, TRANS-1d, TRANS-1e, TRANS-1f, TRANS-4a, TRANS-7a, TRANS-7b, and TRANS-7c, and implementation of Project Design Features 1, 2 and 3, that the air quality and greenhouse gas emissions would be reduced to less than significant levels. As such, no additional mitigation is required for the proposed project. Response to AB-D-1 This comment consists of Matthew Hagemann’s and Hadley Nolan’s resumes. No response is necessary. THIS PAGE INTENTIONALLY LEFT BLANK CNPS Page 1 of 4 1 2 CNPS Page 2 of 4 3 4 5 6 CNPS Page 3 of 4 7 8 CNPS Page 4 of 4 8 CONT 9 City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-139 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx California Native Plant Society (CNPS) Response to CNPS-1 The organization provided introductory remarks to open the letter. No response is necessary. Response to CNPS-2 The organization summarized its comments regarding the Draft SEIR’s evaluation of special-status plant species impacts. The agency’s specific comments are addressed in Response to CNPS-3 through Response to CNPS-8. Response to CNPS-3 Refer to Response to AB-4 and AB-5. A detailed plant inventory was prepared as part of the WRA Wetland Delineation (Draft SEIR Appendix C). The only special-status plant species observed was Congdon’s tarplant. FCS confirmed the findings of WRA’s 2013 surveys in 2016 and 2017. Given that the project site is isolated and in a highly disturbed state, additional protocol-level surveys would not yield any further insights into the potential presence of plants on the project site. Response to CNPS-4 The EIR and supporting documentation does include identification of species to the taxonomic level. Regarding the one unidentified species of Amsinckia, reported in the WRA August and November 2013 reports, FCS biologists conducted a field survey in Spring 2016, which is the appropriate blooming period for the species. FCS biologists observed Rancher’s fiddleneck (Amsinckia intermedia), a common non-native weedy species, throughout the project site during our biological survey. FCS biologists did not observe any Douglas’ fiddleneck (Amsinckia douglasiana). The commenter is correct that WRA reported that Douglas’ fiddleneck (Amsinckia douglasiana) was reported during the field survey performed by WRA on November 5, 2013. However, this species blooms between March and May; it would be highly unlikely to observe this individual in November. Moreover, these two plant species resemble each other and can be mistaken for one another. Thus, FCS concluded that the reported occurrence of the Douglas’ fiddleneck in November 2013 was in error, and therefore the Draft SEIR did not identify this as a special-status species that was present on the project site. Response to CNPS-5 Refer to Response to AB-4. A detailed plant inventory was prepared as part of the WRA Wetland Delineation and is provided in Appendix C of the Draft SEIR. The project site was surveyed on multiple occasions by qualified biologists between 2013 and 2017. The only special-status plant species observed during the surveys was Congdon’s tarplant. The other species cited by the organization (California dodder, Palmer’s amaranth, large-seeded dodder, broad leaved mudwort, hedge nettle, bearded clover, and yellow owl’s clover) were not observed during any of the biological surveys. Thus, it is not necessary to perform another survey for these species. Refer to Response to AB-8b. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-140 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to CNPS-6 All CNPS rankings were considered under the combined habitat assessment and wetland delineation efforts that constitute an exhaustive assessment for special-status plants. Response to CNPS-7 As discussed in Responses to AB-4 and AB-5, the project site was surveyed on multiple occasions by qualified biologists between 2013 and 2017. The Draft SEIR disclosed the potential impact of up to 6.81 acres of Congdon’s tarplant and requires protocol-level surveys to determine the current extent of this species on the site prior to disturbance. The project site is isolated, disturbed, and currently supports a large monoculture of field mustard, a weedy species. Given these site characteristics, the avoidance or compensatory mitigation requirements set forth in Mitigation Measure BIO-1a would fully mitigate all direct and indirect impacts on the Congdon’s tarplant associated with the proposed project. Thus, there are assurances that all potential impacts on Congdon’s tarplant would be fully mitigated. Response to CNPS-8 Mitigation Measure BIO-1a requires either avoidance or compensatory mitigation for this species in accordance with CDFW-guidance. In the outlined mitigation strategy, the measures clearly require preservation of the species on the site if found in their original, less than, or greater than states. Furthermore, EACCS guidance is advisory for private-sector projects and the City of Dublin has the discretion to determine the appropriate mitigation ratio. In this case, Mitigation Measure BIO-1a establishes a floor of minimum 1:1, which for a disturbed, infill site, is appropriate. Response to CNPS-9 The organization provided closing remarks to conclude the letter. No response is necessary. LD Page 1 of 23 1 2 LD Page 2 of 23 3 4 LD Page 3 of 23 4 CONT 5 LD Page 4 of 23 5 CONT 6 LD Page 5 of 23 6 CONT LD Page 6 of 23 7 LD Page 7 of 23 7 CONT 8 9 LD Page 8 of 23 9 CONT LD Page 9 of 23 10 LD Page 10 of 23 10 CONT 11 12 LD Page 11 of 23 12 CONT 13 LD Page 12 of 23 LD Page 13 of 23 14 LD Page 14 of 23 14 CONT LD Page 15 of 23 14 CONT LD Page 16 of 23 14 CONT LD Page 17 of 23 14 CONT LD Page 18 of 23 14 CONT LD Page 19 of 23 14 CONT LD Page 20 of 23 14 CONT LD Page 21 of 23 14 CONT LD Page 22 of 23 14 CONT LD Page 23 of 23 14 CONT THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-165 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Lozeau Drury (LD) Note to reader: This law firm is representing Laborer’s International Union of North America Local Union No. 304. Response to LD-1 The organization provided introductory remarks and stated that the Draft SEIR fails CEQA requirements and should be revised and recirculated. The organization’s specific comments are addressed in Response LD-7 through Response to LD-14. Response to LD-2 The organization summarized the Draft SEIR’s project description. No response is necessary. Response to LD-3 Regarding impacts to construction workers, the Draft SEIR Mitigation Measure AIR-3a limits idling to no more than 5 minutes and requires that construction equipment be properly tuned and maintained in accordance with the manufacturer’s specifications. Additionally, Mitigation Measure AIR-3b requires that all construction equipment greater than 50 horsepower meet United States Environmental Protection Agency Tier 4 interim off-road emissions standards. These mitigation measures would protect the health of construction workers and others from air pollution. Thus, there is no basis for the claim that construction workers would suffer adverse health effects from poorly maintained or controlled construction equipment. As for hazardous materials, the Draft SEIR disclosed that the project site contains two soil stockpiles with detectable concentrations of petroleum hydrocarbons, poly aromatic hydrocarbons (PAHs), and polychlorinated biphenyls (PCBs). Draft SEIR Mitigation Measure HAZ-2 requires the applicant to retain a qualified hazardous materials contactor to sample these soil stockpiles for these substances prior to grading activities and properly remove them if detectable concentrations of these hazardous materials are found to be present. Thus, any hazardous materials in soil would be abated prior to grading; thus, there is no basis for the claim that construction workers would suffer adverse health effects from hazardous materials on the project site. Response to LD-4 The organization provided standard language about CEQA requirements. The Draft SEIR complies with the requirements of CEQA in every respect. No response is necessary. Response to LD-5 The organization provided standard language about CEQA requirements for Supplemental EIRs and asserted that the Draft SEIR fails to analyze significant environmental impacts pertaining to the project and fully consider available mitigation measures. The organization reiterated its previous comments that the Draft SEIR should be revised and recirculated. The organization’s specific comments about the Draft SEIR’s alleged deficiencies are addressed in Response LD-7 through Response to LD-14. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-166 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Response to LD-6 The organization provided standard language about CEQA requirements for analyzing and disclosing all potentially significant impacts. No response is necessary. Response to LD-7 The Draft SEIR identifies impacts to intersections, local and regional roadway segments, and freeway facilities. Mitigation measures were identified for all impacts. Implementation of many mitigation measures can be assured as the improvements are already planned by the City of Dublin, or would be constructed as part of the project. For other impacts, feasible improvements have been identified but coordination with and approval from other agencies is required and neither the City of Dublin nor the project applicant can ensure their implementation. For other impacts, such as to the regional freeway system, other parallel improvements would provide other travel routes, and alternative travel modes for travel through the corridor. However, the effectiveness of these measures cannot be fully quantified. For some impacts, such as at the Dougherty Road at Dublin Boulevard Intersection, insufficient right-of-way is available to construct identified improvements. Therefore, the Draft SEIR concludes that some impacts could be significant and unavoidable as there are no assurances regarding the timing of implementation, nor the effectiveness of such measures. As part of the project approval process, a Statement of Overriding considerations must be prepared when there are significant and unavoidable impacts. This statement acknowledges the balancing of competing public objectives (including environmental, legal, technical, social, and economic factors), and allows for a project that could have significant and unavoidable environmental impacts to be approved. Response to LD-8 CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states that mitigation measures “may specify performance standards,” “must be fully enforceable,” and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure AIR-3b requires that all construction equipment greater than 50 horsepower meet United States Environmental Protection Agency Tier 4 interim off-road emissions standards and obligates the applicant to provide the City of Dublin with documentation verifying this at the time of issuance of grading permits. The mitigation measure identifies a clear and unequivocal performance standard that is fully enforceable and roughly proportional to project impacts. As such, Mitigation Measure AIR-3b meets the applicable requirements of CEQA Guidelines Section 15126.4. Regarding cumulative construction criteria pollutant emissions from the simultaneous construction of the IKEA Retail Center, Boulevard, and the Zeiss Innovation Center projects, this is unlikely to occur. As of June 2018, the Boulevard Project site is 1,500 feet northwest of the IKEA Retail Center project site and is currently under construction; the Zeiss Innovation Center Project site is approximately 760 feet north of the IKEA site and is approved and expected to commence construction in the second half of 2018. Since the IKEA Retail Center project has not yet been considered for approval and cannot begun any construction until after approval and issuance of permits, the IKEA construction is unlikely to overlap with these other projects. In addition, none of the three sites are contiguous to each other. Criteria pollutant air emissions constitute a very short- term, localized phenomenon and are heavily influenced by factors such as weather. Moreover, City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-167 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx construction activities are temporary and cease when the project is completed. Thus, for a worst- case cumulative criteria pollutant impact to occur in the context of construction, all three projects would have to be under construction simultaneously on a hot, sunny day with little to no wind. Given the staggered schedules of the three projects and the distance between each one, this is remote and unlikely to occur. Therefore, it is too speculative to evaluate. Response to LD-9 As discussed in Response to LD-8, there is no basis for assuming that Mitigation Measure AIR-3b will not be effective at mitigating impacts from the IKEA construction or assuming that the IKEA Retail Center, Boulevard, and Zeiss Innovation Center projects will be implemented on similar constriction schedules. The mitigation measure will ensure that the construction impacts from the IKEA project will be less than cumulatively considerable. Response to LD-10 Draft SEIR page 3.2-2 indicated that the on-site seasonal features may be exempt from jurisdiction under Section 404 of the Clean Water Act because they appear to be isolated and do not drain to a navigable waterway. Moreover, the Draft SEIR consistently indicates that the seasonal features are 1.92 acres in area; the statement on page 3.2-16 about the seasonal wetland acreage increasing from 1.17 to 1.92 reflected the values contained in the WRA Biological Resources Assessment dated August 2013 (1.17 acres) and the WRA Delineation of Waters of the U.S. dated November 2013 (1.92 acres); they do not reflect 2016 versus 2017 values. In all cases, the Draft SEIR referenced the higher value of 1.92 acres when discussing existing conditions and impacts. CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states that mitigation measures “may specify performance standards,” “must be fully enforceable,” and “must be ‘roughly proportional’ to the impacts of the project.” In this case, the mitigation measures for Congdon’s tarplant (Mitigation Measure BIO-1a), nesting birds (Mitigation Measure BIO-1b), burrowing owl (Mitigation Measure BIO-1c), bats (Mitigation Measure BIO-1d), and wetlands (Mitigation Measures BIO-3a and BIO-3b) all identify clear and unequivocal performance standards that are fully enforceable and roughly proportional to project impacts. As an example, Mitigation Measure BIO-1a indicates that (1) a focused survey for the Congdon’s tar plant must be completed prior to vegetation removal or ground disturbing activities; (2) must be conducted in accordance with the CDFW’s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities; and (3) specific avoidance or compensatory mitigation must be implemented if individuals are found to be present. In regard to requiring focused or pre-construction surveys prior approval of a project, please refer to Response AB-14. Response to LD-11 The Smallwood inspection is addressed in Response to LD-14. Response to LD-12 CEQA Guidelines Section 15126.4 sets forth considerations for mitigation measures. The section states that mitigation measures “may specify performance standards,” “must be fully enforceable,” and “must be ‘roughly proportional’ to the impacts of the project.” In this case, Mitigation Measure HAZ-2 City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-168 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx requires the applicant to retain a qualified hazardous materials contactor to sample these soil stockpiles for these substances prior to grading activities and properly remove them if detectable concentrations of these hazardous materials are found to be present. There are clear and unequivocal performance standards within this mitigation measure that are fully enforceable and roughly proportional to project impacts, such as: “Prior to issuance of the first grading permit . . .” “If sampling determines that concentrations of these substances exceed acceptable human health exposure levels . . .” “. . . the applicant shall retain a qualified hazardous materials contractor to properly remove and dispose if impacted soil . . .” For these reasons, Mitigation Measure HAZ-2 meets the applicable requirements of CEQA Guidelines Section 15126.4 and the claims that construction workers would be exposed to hazardous materials are not supported by substantial evidence. Response to LD-13 As discussed in these responses, the Draft SEIR meets all applicable CEQA requirements and there is no legal basis to revise and recirculate the Draft SEIR. Response to LD-14 This comment consists of a letter authored by Shawn Smallwood, Ph.D., dated March 5, 2018 regarding the Zeiss Innovation Center Project site located east of Arnold Road and north of Dublin Boulevard. Dr. Smallwood indicated that he performed a 15-minute site visit on February 8, 2018 and a 94-minute visit on March 2, 2018. He indicated that both visits were restricted to the outer perimeter of the Zeiss Innovation Center Project site and that he did not actually walk the site. He reported observing a red-tailed hawk and a white-tailed kite and suggested that their behavior was indicative of nesting. He also inferred burrowing owls may be present because of the presence of ground squirrels. His letter then delves into topics specific to the Zeiss Innovation Center Project that have no relevance to the IKEA Retail Center project. As should be clear, Dr. Smallwood did not survey the IKEA Retail Center project site. The Zeiss Innovation Center Project site is located approximately 760 feet north of the IKEA Retail Center project site, with Martinelli Way (a four-lane divided roadway), Persimmon Place (a retail center), and Dublin Boulevard (a six-lane divided roadway) located in between. The two sites are non- contiguous. Unlike the Zeiss Innovation Center Project site, the IKEA Retail Center project site supports paved areas and buildings. Moreover, Dr. Smallwood’s methods would not be consistent with those for a reconnaissance level biological survey, or for that matter, CEQA-level evaluation of biological resources. Moreover, his initial February 8, 2018 survey of the approximately 10-acre site Zeiss Innovation Center Project site consisted of a 15-minute visit, which seems to be a bit abbreviated for a site of this size. His suggestion that that red-tailed hawks, white-tailed kites, or burrowing owls are nesting on-site are completely unsupported by any actual direct evidence that such nests are present. Lastly, using a City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-169 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx biologist’s observations for one project site as a proxy for a completely separate site would not meet any widely accepted standard for biological assessments. Overall, Dr. Smallwood’s letter provides limited biological insight into the Zeiss Innovation Center Project site and absolutely no biological insight into the IKEA Retail Center site. Regardless, the IKEA Retail Center project site was surveyed on multiple occasions between 2013 and 2017 by several biologists from separate firms and was determined to provide suitable habitat for nesting birds (including raptors such as the red-tailed hawks and white-tailed kites) and the burrowing owl. Accordingly, the Draft SEIR set forth Mitigation Measures BIO-1b and BIO-1c to address impacts to these species. As such, there is no basis to revise and recirculate the Draft SEIR based on Dr. Smallwood’s letter. THIS PAGE INTENTIONALLY LEFT BLANK CIGNARELLA Page 1 of 2 1 2 CIGNARELLA Page 2 of 2 2 CONT City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-173 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Individuals Tom Cignarella (CIGNARELLA) Response to CIGNARELLA-1 The author expressed objection to the project because of traffic congestion. Refer to Master Response 1. Response to CIGNARELLA-2 The author provided a summary of the SEIR’s conclusions regarding traffic. Refer to Master Response 2. THIS PAGE INTENTIONALLY LEFT BLANK DE WIT-SMITH Page 1 of 2 1 DE WIT-SMITH Page 2 of 2 1 CONT City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-177 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Liana deWit-Smith (DEWIT-SMITH) Response to DEWIT-SMITH-1 The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection to the project. Refer to Master Responses 1 and 2. THIS PAGE INTENTIONALLY LEFT BLANK FICARRA Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-181 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Tammy Ficarra (FICARRA) Response to FICARRA-1 The author expressed objection to the project because of traffic congestion. Refer to Master Response 1. THIS PAGE INTENTIONALLY LEFT BLANK GEBEL Page 1 of 1 1 2 3 4 5 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-185 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Jeff Gebel (GEBEL) Response to GEBEL-1 The author does not provide any evidence in support of his claim that traffic impacts on I-580, I-680, Hacienda Drive, and Dublin Boulevard have not been properly mitigated. Refer to CALTRANS-3 for further discussion of traffic analysis and mitigation, particularly with regard to freeway impacts. Response to GEBEL-2 Both Livermore and Pleasanton have established retail nodes1 that are within close driving distance of Dublin and, thus, Dublin residents are making existing trips to these outlets. As such, these traffic patterns are captured in the Draft SEIR’s existing and Existing Plus Project traffic analyses (Impacts TRANS-1) in Section 3.6, Transportation. To the extent that these residents would continue to make these shopping trips in the future, this would represent the continuation of an existing condition. IKEA primarily retails furniture and housewares and, thus, only competes with outlets in these categories. Thus, the development of an IKEA would not eliminate the need for Dublin residents to shop at outlets that serve other retail categories. Although the Draft SEIR indicates that traffic conditions would deteriorate on local and regional roadways under Near-Term with Project and Cumulative with Project conditions, attempting to predict how this would influence non-IKEA retail traffic pattern trips is too speculative to predict because it would require information that is not currently available (the types of outlets that would exist in the future, shopping preferences of residents in the future, etc.). CEQA Guidelines Section 15145 indicates that if a lead agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact. Response to GEBEL-3 Impacts on the existing visual character of the project site were adequately addressed in the Eastern Dublin EIR and no further analysis is required. Thus, the project would not represent a substantial visual impact under CEQA standards. However, the design and coloring of the building is subject to City zoning regulations, including site development review standards, which will be considered by decision-makers. Response to GEBEL-4 The Draft SEIR’s noise analysis in Section 3.4 Noise specifically accounted for truck noise in terms of roadway noise and delivery loading and unloading noise; refer to pages 3.4-18; 3.4-20 through 3.4-27; and 3.4-29 through 3.4-30. As discussed on those pages, all operational noise impacts (including truck noise) were found to be less than significant. Response to GEBEL-5 Project-related greenhouse gas emissions impacts were evaluated in Section 3.1, Air Quality/ Greenhouse Gas Emissions on pages 3.1-59 through 3.1-67. Although the proposed project would result in a net increase in daily vehicle trips, the State’s adopted greenhouse gas reduction policies (e.g., Pavley I motor vehicle emission standards, Low Carbon Fuel Standard, Pavley II Advanced Clear 1 Livermore nodes include the San Francisco Premium Outlets and Costco. Pleasanton nodes include Pacific Pearl, CarMax/Stoneridge Chrysler/Jeep/Dodge, Rose Pavilion, Metro 580, etc. City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-186 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Cars Program) would apply to the vehicle fleet and serve to reduce greenhouse gas emissions over time. The proposed project also includes features that would reduce greenhouse gas emissions such as being designed to meet the United States Green Building Council’s Leadership in Energy and Environmental Design Silver standard, being accessible to bicycles and transit, and the use of a photovoltaic solar system for electricity production. The Draft SEIR found that the proposed project would achieve the State’s 40 percent emissions reduction target set forth in SB 32 and, thus, impacts would be less than significant. Because the proposed project would be consistent with the State’s greenhouse gas reduction objectives, it would not be considered to increase Dublin’s carbon footprint. GONZALES Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-189 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Chenin Gonzales (GONZALES) Response to GONZALES-1 The Draft SEIR referenced the applicable federal and state statutes that pertain to avian species on pages 3.2-11 through 3.2-14, including the white-tailed hawk and western burrowing owl. Section 3.2, Biological Resources Impact BIO-1 evaluated impacts on special-status bird species and noted that the project site provides suitable habitat for nesting birds, the western burrowing owl, and bat species; as such, Mitigation Measures BIO-1b, BIO-1c, and BIO-1d were set forth to mitigate impacts on these species. In summary, the Draft SEIR did evaluate the potential presence of special-status aviation species and set forth mitigation to reduce impacts to a level of less than significant. THIS PAGE INTENTIONALLY LEFT BLANK HEYER Page 1 of 2 1 HEYER Page 2 of 2 1 CONT City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-193 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx John Heyer (HEYER) Response to HEYER-1 The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection to the project. Refer to Master Responses 1 and 2. THIS PAGE INTENTIONALLY LEFT BLANK KAUBE Page 1 of 2 1 2 3 4 KAUBE Page 2 of 25 City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-197 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Michael Kaube (KAUBE) Response to KAUBE-1 The Initial Study in Appendix A served as a preliminary assessment of impacts on public transit, bicycles and pedestrians. A more detailed assessment of bicycle circulation is provided in Draft SEIR Section 3.6, Transportation, Impact TRANS-8, and identified several improvements to enhance the convenience and safety of cycling in the project vicinity (Mitigation Measures TRANS-8a, TRANS-8b, and TRANS-8c). After implementation of these mitigation measures, the Draft SEIR concluded that impacts on bicycles were less than significant. The author did not provide any specific comments on the Draft SEIR’s analysis or mitigation measures. Response to KAUBE-2 As noted in Response to KAUBE-1, the Draft SEIR provided a detailed assessment of bicycle and pedestrian circulation and set forth improvements as mitigation measures. Regarding the poor condition of the Class I bicycle/pedestrian path along the north side of Dublin Boulevard, this is a result of the development of the Boulevard Project that restricted access to portions of this facility. That project will be required to restore the Class I bicycle/pedestrian path to satisfactory condition. Note that the IKEA Retail Center project does not propose any changes to this facility. Response to KAUBE-3 Refer to Response to KAUBE-1 and -2. Response to KAUBE-4 The author stated that he will be opposed to any further development in the project vicinity until the traffic situation is improved. This comment is noted and will be provided to City decision-makers. No response is necessary. Response to KAUBE-5 This comment consists of a diagram referenced by the author in his comments. No response is necessary. THIS PAGE INTENTIONALLY LEFT BLANK MARSHALL Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-201 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Lianne Marshall (MARSHALL) Response to MARSHALL-1 The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection to the project. Refer to Master Response 1. The author also expressed objection to the design and appearance of the proposed project. Impacts on the existing visual character of the project site were adequately addressed in the Eastern Dublin EIR and no further analysis is required. Thus, the project would not represent a substantial visual impact under CEQA standards. However, the design and coloring of the building is subject to City zoning regulations, including site development review standards, which will be considered by decision-makers. THIS PAGE INTENTIONALLY LEFT BLANK MURUGESAN Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-205 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Jegadheesa Murugesan (MURUGESAN) Response to MURUGESAN-1 The author provided a summary of the SEIR’s conclusions regarding vehicle miles traveled and expressed objection to the project. Refer to Master Response 1. The author stated that the SEIR in Table Page 6-6 underreported the City’s population as 50,000 and asserted that this should be corrected in order to get an accurate picture of traffic impacts. Table 6-6 indicates that the City’s “existing population” is 50,970. That number represents a calculation of residential population based on the number of households in the base year model with different housing types having different household sizes. The model base year is 2015, so this numbers reflects the population for that year. It should be noted that the population for the City of Dublin for modeling purposes does not include the Santa Rita Jail facility, which has a capacity of 4,000 people or Federal Correctional Institution Dublin, which has a capacity of 990. THIS PAGE INTENTIONALLY LEFT BLANK PAGE Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-209 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Chris Page (PAGE) Response to PAGE-1 The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection to the project. Refer to Master Responses 1 and 2. THIS PAGE INTENTIONALLY LEFT BLANK SOLAIMAN Page 1 of 2 1 SOLAIMAN Page 2 of 2 1 CONT City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-213 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Feroza Solaiman (SOLAIMAN) Response to SOLAIMAN-1 The author provided a summary of the SEIR’s conclusions regarding traffic and expressed objection to the project. Refer to Master Responses 1 and 2. THIS PAGE INTENTIONALLY LEFT BLANK YOUNG Page 1 of 1 1 THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-217 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Rupert Young (YOUNG) Response to YOUNG-1 The author expressed objection to the project because of traffic congestion and land use compatibility. Refer to Master Response 1. Impacts on land use were addressed in the initial study, which was included as Appendix A of the EIR. As discussed, the proposed project consists of the development of commercial-retail center. The City of Dublin General Plan designates the project site as “General Commercial,” while the Eastern Dublin Specific Plan zones the site as “General Commercial,” which permits the construction of retail-commercial uses. Development on-site would be required to comply with all applicable General Plan policies and Specific Plan regulations, and would be reviewed by the City prior to approval of the necessary permits. As such, impacts would be less than significant and no further analysis is required. Thus, the project would not result in a significant impact in terms of land use. The design and coloring of the building is subject to City zoning regulations, including site development review standards, which will be considered by decision-makers. THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Responses to Written Comments FirstCarbon Solutions 3-219 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Non-Draft SEIR Comments Table 3-2 summarizes the individuals that submitted comments that pertained to the proposed project, but did not specifically address any aspect of the Draft SEIR’s analysis. The letters are reproduced following the table. Please refer to Section 2, Master Responses for a response to these comments. Table 3-2: Non-Draft SEIR Comments Signatory Signatory Signatory J. Alexander Melissa Alexander Angie [Full Name Not provided] Sandi Arajs and Tom Rogers Joe Banchero Dean Barnes Lisa Burks Maijargal Burrows Catherine Byron Brian Cardella Marlon Cardenas Kerrie Chabot Jenny Chang Daniel Chen Young Cho Tom Cignarella Sean Cohen Danielle Cooper Ewa David Lianna de Wit-Smith Vanessa Dellon Diana DeMeo Mindy Destro Satpal Dhillon Susan Dunnegan Ernesto Eugenio Jennifer Farber and John Hanson Tammy Ficarra (3 letters) Susanne Frey Vasantha Ganesan Michelle Gebel Jay Gill Sumeet Gore Patrick Graham Perrin Guess Roger Gupta Akansha Gupta Rajesh Gupta Roger and Nancy Haddad (2 letters) Patty Hansen Sunil Hariani Pam Harvey Heidi [Full Name Not Provided] Gretchen Hellmann Jennet Herdman John Heyer Wendy Jemo Jim R. and Elena G. (Full Names Not Provided) Teresa Johnson Gerry Judd Nina Kamatani Kamlesh Kamdar Alex Kao Sepi Katz Stefani Katz Pearl Ko Vaidy Krishnamurthy Pawan Kumar William and Katherine Kuo Eric Lam Linda Leonard Cheryl LeValley James Lin Gina Lindauer Weifeng Liu John Lumm Mahesh [Full Name Not Provided] Ravinder Mangat Lianne Marshall Kiran Maskey Marlene Massetti Leonie Meima Rowena Morgan Kazuko and Masahiro Morimoto Gargi Mukherjee Jegadheesa Murugesan Hilary Nindorf Chris Page City of Dublin—IKEA Retail Center Project Responses to Written Comments Final SEIR 3-220 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec03-00 Responses to Written Comments.docx Table 3-2(cont.): Non-Draft SEIR Comments Signatory Signatory Signatory Katie Palomares Carmen Pappas Ashish Paralkar Annissa Park Ivan Pysarevskyy Ramya Ramakrishnan Brian Roudabush Johan Rydell Nithya Sakthirajan Edlyn Sammanasu (2 letters) Lucretia Samuels Satar [Full Name Not Provided] (2 letters) Jenny Scheinpflug Thomas Schindler Allen Shaw Monica Silva Jennifer Situ and Vick Tran (2 letters) Feroza Solaiman Vanessa Sotelo Suico [Full Name Not Provided] (2 letters) Diane Tarin Nhuly Tran Debbie Wagner (2 letters) Janeen Wheeler Heather Whiting Barbara Wilson Rupert Young Source: City of Dublin, 2018. THIS PAGE INTENTIONALLY LEFT BLANK City of Dublin—IKEA Retail Center Project Final SEIR Errata FirstCarbon Solutions 4-1 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx SECTION 4: ERRATA The following are revisions to the Draft SEIR for the IKEA Retail Center Project. These revisions are minor modifications and clarifications to the document, and do not change the significance of any of the environmental issue conclusions within the Draft SEIR. The revisions are listed by page number. All additions to the text are underlined (underlined) and all deletions from the text are stricken (stricken). 4.1 - Changes to Draft EIR Text Section ES, Executive Summary Page ES-1, Project Location The project address has been corrected. The project site is located at 5344 and 5144 5411 Martinelli Way in the City of Dublin, Alameda County, California. Page ES-2, Table ES-1 Table ES-1 has been revised to eliminate a redundant entry for 8,000 square feet of restaurant uses. These uses are captured in the 58,440 square-foot value. Table ES-1: IKEA Retail Center Project Summary Use Acreage Square Feet Characteristics Major 1 (IKEA) 13.65 339,099 2 stories above two-story parking structure Lifestyle retail-restaurant 13.66 8,000 Freestanding restaurant 34,560 Multiple buildings, retail use 58,440 Multiple buildings, restaurant/food use Subtotal 27.45 — ― Proposed/anticipated dedication for BART1 (0.16) ― ― Total 27.31 432,099 ― Note: 1 Based on Express Bus/Bus Rapid Transit (BRT) Alternative. Source: GreenbergFarrow, 2017. Section 2, Project Description Page 2-1, Project Location The project address has been corrected. The project site is located at 5344 and 5144 5411 Martinelli Way in the City of Dublin, Alameda County, California. City of Dublin—IKEA Retail Center Project Errata Final SEIR 4-2 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Page 2-10, Table 2-1 Table 2-1 has been revised to eliminate a redundant entry for 8,000 square feet of restaurant uses. These uses are captured in the 58,440 square-foot value. Table 2-1: IKEA Retail Center Project Summary Use Acreage Square Feet Characteristics Major 1 (IKEA) 13.65 339,099 2 stories above two-story parking structure Lifestyle retail-restaurant 13.66 8,000 Freestanding restaurant 34,560 Multiple buildings, retail use 58,440 Multiple buildings, restaurant/food use Subtotal 27.45 — ― Proposed/anticipated dedication for BART1 (0.16) ― ― Total 27.31 432,099 ― Note: 1 Based on Express Bus/Bus Rapid Transit (BRT) Alternative. Source: GreenbergFarrow, 2017. Page 2-10 Text is added to clarify the proposed building height of the structure Major 1—IKEA The IKEA store would consist of a two-story building located over a two-level parking structure with the lower level partially below grade. The building would be set against the Arnold Road frontage and face Hacienda Drive. The building would stand approximately 61 feet above finished grade. The majority of the building would be at 58 feet 6 inches, while the yellow Ikea Panels would project up to 65 feet in height. The principal loading docks would be located in the rear of the building facing Arnold Road. A recycling and refuse collection area, trash compactor, and emergency diesel generator would also be located at the rear of the store. A two-bay loading dock for home deliveries would be located on the south side of the building facing I-580. Section 3.1, Air Quality/Greenhouse Gas Emissions Pages 3.1-43 and 3.1-44, Table 3.1-7 Table 3.1-7 has been revised to include emissions from export haul trips, which would only occur during the grading phase of construction. City of Dublin—IKEA Retail Center Project Final SEIR Errata FirstCarbon Solutions 4-3 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Table 3.1 —7: Construction-Related Criteria Air Pollutant Emissions Prior to Mitigation Construction Activity Air Pollutants (pounds per day) ROG NOX PM10 1 PM2.5 1 Demolition 3.83 39.78 1.95 1.81 Grading 5.185.76 59.5979.00 2.633.90 2.422.82 Combined Building Construction, Paving, and Architectural Coatings 146.06 73.35 3.01 2.83 - Building Construction 6.29 57.32 2.16 2.03 - Paving 2.21 14.11 0.75 0.69 - Architectural Coating 137.56 1.92 0.11 0.11 CEQA Significance Thresholds 54 54 82 54 Exceeds Significance Threshold? Yes Yes No No Notes: 1 Exhaust only ROG = reactive organic gases NOX = oxides of nitrogen PM10 = particulate matter 10 microns in diameter PM2.5 = particulate matter 2.5 microns in diameter Source: FirstCarbon Solutions, CalEEMod Version 2016.3.2, Appendix B. Pages 3.1-44 and 3.1-45, Table 3.1-8 Table 3.1-8 has been revised to include emissions from export haul trips. Table 3.1-8: Mitigated Construction-Related Criteria Air Pollutant Emissions Construction Activity Air Pollutants (pounds per day) ROG NOX PM10 1 PM2.5 1 Demolition 0.69 14.98 0.07 0.07 Grading 1.101.68 19.3438.75 0.111.38 0.110.51 Combined Building Construction, Paving, and Architectural Coatings 51.41 52.44 0.34 0.34 - Building Construction 3.37 41.06 0.30 0.30 - Paving 1.19 10.08 0.04 0.04 - Architectural Coating 46.85 1.30 0.00 0.00 CEQA Significance Thresholds 54 54 82 54 Exceeds Significance Threshold? No No No No Notes: 1 Exhaust only ROG = reactive organic gases NOX = oxides of nitrogen PM10 = particulate matter 10 microns in diameter PM2.5 = particulate matter 2.5 microns in diameter Source: FirstCarbon Solutions, CalEEMod Version 2016.3.2, Appendix B. City of Dublin—IKEA Retail Center Project Errata Final SEIR 4-4 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Section 3.3, Biological Resources Pages 3.2-19 and 3.2-20, Mitigation Measure BIO-1c Mitigation Measure BIO-1c has been modified to include a requirement for minimum 1:1 replacement. MM BIO-1c Prior to the first ground-disturbing activities, the project applicant shall implement the following measures that pertain to burrowing owl, as applicable: 1. Conduct a Burrowing Owl Survey and Impact Assessment. Prior to the first ground-disturbing activities, the project applicant shall retain a qualified biologist to conduct two pre-construction surveys for the burrowing owl for the entire site. The first survey shall be conducted no more than 14 days prior to ground- disturbing activities and the second survey shall be conducted within 48 hours of initial ground disturbance. The surveys shall be conducted in accordance with the California Department of Fish and Wildlife (CDFW) Staff Report on Burrowing Owl Mitigation. If the surveys determine owls are present, then the measures set forth in this mitigation shall be followed. 2. Implement Avoidance Measures. If direct impacts to owls can be avoided, prior to the first ground-disturbing activities, the project applicant shall implement the following avoidance measures during all phases of construction to reduce or eliminate potential impacts to California burrowing owls. • Avoid disturbing occupied burrows during the nesting period, from February 1 through 31 August. • Avoid impacting burrows occupied during the non-breeding season by migratory or non-migratory resident burrowing owls. • Avoid direct destruction of burrows through chaining (dragging a heavy chain over an area to remove shrubs), disking, cultivation, and urban, industrial, or agricultural development. • Develop and implement a worker awareness program to increase the on-site worker’s recognition of and commitment to burrowing owl protection. • Place visible markers near burrows to ensure that equipment and other machinery does not collapse burrows. • Do not fumigate or use treated bait or other means of poisoning nuisance animals in areas where burrowing owls are known or suspected to occur (e.g., sites observed with nesting owls, designated use areas). 3. Conduct Burrow Exclusion. If avoidance of burrowing owl or their burrows is not possible, prior to the first ground-disturbing activities, the project applicant, in consultation with the CDFW, shall prepare a Burrowing Owl Relocation Plan as indicated and following the CDFW 2012 Staff Report. Monitoring of the excluded owls shall be carried out pursuant to the California Department of Fish and Game 2012 Staff Report. 4. Prepare and Implement a Mitigation Plan. If avoidance of burrowing owl or their burrows is not possible, and project activities may result in impacts to nesting, City of Dublin—IKEA Retail Center Project Final SEIR Errata FirstCarbon Solutions 4-5 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx occupied, and satellite burrows and/or burrowing owl habitat, the project applicant shall consult with the CDFW and develop a detailed mitigation plan that shall include replacement of impacted habitat at no less than a 1:1 ratio, number of burrows, and burrowing owl in a ratio approved by CDFW. The mitigation plan shall be based on the requirements set forth in Appendix A of the CDFW 2012 Staff Report on Burrowing Owl Mitigation and the Plan shall be reviewed and accepted by CDFW and the City prior to the first ground-disturbing activities. Section 3.6, Transportation Page 3.6-70, After Third Paragraph The discussion of Hacienda Drive/Martinelli Way improvements has been amended to acknowledge that Caltrans has jurisdictional control. Note that the 100-foot extension of the turn pocket would encroach into the Caltrans jurisdiction. The City of Dublin has no control over Caltrans facilities and therefore, the residual significance of this impact is significant and unavoidable. Page 3.6-125, Table 3.6-19 A typographical error associated with the identification of LOS following the implementation of mitigation is corrected, as shown in Table 3.6-19. Table 3.6-19: Cumulative with Mitigation Peak-Hour Intersection Levels of Service Intersection Control Peak Hour Cumulative without Project Cumulative with Project Cumulative with Project With Mitigation Delay LOS Delay LOS Delay LOS 6. Hopyard Road & Owens Drive Signal AM PM SAT 50.8 95.1 63.7 D F E 50.9 96.6 65.6 D F E 35.9 54.2 53.8 C D D 11. Dublin Boulevard & Arnold Road Signal AM AFT PM SAT 35.3 44.3 60.3 (141.5) 47.7 D D E D 38.2 52.4 60.7 (170.8) 47.8 D D E D 35.4 48.8 43.6 42.3 D D D D 17. Dublin Boulevard & Hacienda Drive Signal AM AFT PM SAT 36.8 45.5 72.2 (275.0) 64.4 (235.0) D D E E 37.9 52.6 80.8 (345.2) 77.0 (318.8) D D F E 36.7 36.0 52.2 47.0 D D D D 18. Hacienda Drive & Martinelli Way Signal AM AFT PM SAT 38.7 37.1 0.82 (1.86) 41.9 D D F D 41.2 49.9 1.01 (2.42) 70.4 D D F E 50.0 41.0 47.6 53.9 D D D D 21. Owens Drive & Hacienda Drive Signal AM PM SAT 21.0 99.1 24.0 C F C 21.1 100.9 24.3 C F C 20.4 54.5 21.0 C D C City of Dublin—IKEA Retail Center Project Errata Final SEIR 4-6 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Table 3.6-19 (cont.): Cumulative with Mitigation Peak-Hour Intersection Levels of Service Intersection Control Peak Hour Cumulative without Project Cumulative with Project Cumulative with Project With Mitigation Delay LOS Delay LOS Delay LOS 26. Dublin Boulevard & Tassajara Road Signal AM PM SAT 49.0 1.53 (1.93) 1.38 (1.98) D F F 49.5 1.54 (1.93) 1.40 (2.06) D F F 49.1 70.3 54.9 D E D 28. Santa Rita Road & I-580 Eastbound Off- Ramp Signal AM PM SAT 35.0 53.0 94.5 C D F 35.1 54.0 97.4 D D F 29.4 47.8 36.6 47.4 39.5 63.6 CD D DE Notes: Bold text indicates LOS E/F; Bold Italics text indicates impacts due to the proposed project. 1 Signal = signalized. 2 Average intersection delay calculated using the HCM 2000 methodology. For LOS E signalized intersections in the City of Dublin, average delay is followed by the delay for the worst movement in parentheses. For LOS F signalized intersections in the City of Dublin, overall intersection volume-to-capacity (v/c) ratio is followed by the v/c ratio for the worst movement. Source: Fehr and Peers, 2018. Page 3.6-100, Mitigation Measure TRANS-2c The improvements listed in Mitigation Measure TRANS-2c are amended to include an additional eastbound left turn or through lane. MM TRANS-2c Prior to issuance of the first building permit, the project applicant shall provide the City of Dublin documentation that they have worked with the City of Pleasanton and Caltrans to identify and pay the project’s proportionate share for improvements to the intersection of Santa Rita Road/I-580 Eastbound in the City of Pleasanton. The improvements shall consist of modifying the southbound approach to construct a second southbound left-turn lane, and either modifying the northbound approach to construct a third eastbound left-turn lane or modifying the southbound approach to provide a third southbound through lane, in addition to re-timing the traffic signal. Section 4, Cumulative Effects Table 4-1 An entry has been added to Table 4-1 for the Zeiss Innovation Center Project. The addition of this project to Table 4-1 does not materially change any conclusions in Section 4, Cumulative Effects. City of Dublin—IKEA Retail Center Project Final SEIR Errata FirstCarbon Solutions 4-7 Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Table 4-1: Cumulative Projects Jurisdiction Project Characteristics Location Status City of Dublin Kaiser Dublin Medical Center 950,000 square feet Kaiser Medical Campus; 250,000 square feet commercial Dublin Boulevard/ Keegan Street Approved; under construction Dublin Crossing/ Boulevard Up to 1,995 dwelling units; 200,000 square feet commercial; 35 acres parks; 12-acre elementary school Dublin Boulevard/ DeMarcus Approved; under construction Zeiss Innovation Center Phase 1: 208,650 square feet research and development Phase 2: 224,440 square feet research and development Dublin Boulevard/ Arnold Road Proposed Grafton Plaza Mixed Use 115 dwelling units, 50,000 square feet retail commercial, and 130 room hotel Dublin Boulevard/ Grafton Drive Proposed; not yet approved or built Grafton Station Phase III 133,446 square feet commercial Dublin Boulevard/ Tassajara Road Approved; unbuilt City of Pleasanton Stoneridge Drive Specific Plan 800 dwelling units (senior); 120,000–200,000 square feet commercial; 331,000 square feet auto mall El Charro Road/Stoneridge Drive Approved; under construction Johnson Drive Economic Zone 40-acre area envisioned to support up to 535,490 square feet of warehouse club retail (Costco), hotel, general retail, and recreational facilities 7106–7315 Johnson Drive Proposed City of Livermore El Charro Specific Plan 1.5 million square feet retail; 250 acres El Charro Road/Jack London Boulevard Adopted; under construction Isabel Neighborhood Plan 1,132-acre area envisioned to support up to 4,300 dwelling units and up to 9,000 jobs I-580/Isabel Avenue (north side of freeway) Proposed Sage Residential Project 476 dwelling units Portola Drive/ Isabel Avenue Approved; under construction City of San Ramon San Ramon City Center Phase 1: 279159 square feet retail; 46,086 square feet cinema Phase 2: 65,679 square feet retail; 169-room hotel; 487 dwelling units Bollinger Canyon Road/Camino Ramon Approved; under construction Multiple Bay Area Rapid Transit District (BART) Livermore Extension 4.8-mile BART extension from Dublin/Pleasanton Station to I-580/Isabel Avenue I-580 Median (Dublin to Livermore) Planned Source: City of Dublin, 2017; City of Pleasanton, 2017; City of Livermore, 2017. City of Dublin—IKEA Retail Center Project Errata Final SEIR 4-8 FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\6 - Draft Final SEIR\37660005 Sec04-00 Errata.docx Appendix B, Air Quality/Greenhouse Gas Emissions Supporting Information Table 10 The fleet mix in Table 10 has been revised to correct an erroneous entry. Table 10: Project Vehicle Fleet Mix Building Vehicle Type Number of Vehicle Trips IKEA Passenger Cars 5,980 Light-heavy Duty Trucks (2-axles) 20 Heavy-heavy Duty Trucks (4+axles) 10 Total IKEA Trips 6010 Retail Center Passenger Cars(2) 10,83010,772 Light-heavy Duty Trucks (2-axles) 50 Heavy-heavy Duty Trucks (4+axles) 8 Total Retail Center Trips 10,80110,830 Total Project Trips 16,840 Source: Fehr & Peers, 2017. City of Dublin—IKEA Retail Center Project Final SEIR FirstCarbon Solutions Y:\Publications\Client (PN-JN)\3766\37660005\SEIR\5 - Screencheck Final SEIR\37660005 Sec99-00 App div pg.docx Appendix I: Supplemental Air Quality Supporting Information THIS PAGE INTENTIONALLY LEFT BLANK 1.1 Land Usage Land Uses Size Metric Lot Acreage Floor Surface Area Population Enclosed Parking with Elevator 1,026.00 Space 4.00 464,212.00 0 Parking Lot 568.00 Space 10.57 227,200.00 0 High Turnover (Sit Down Restaurant)58.44 1000sqft 1.55 58,440.00 0 Free-Standing Discount Superstore 339.10 1000sqft 9.65 339,099.00 0 Strip Mall 34.56 1000sqft 1.55 34,560.00 0 1.2 Other Project Characteristics Urbanization Climate Zone Urban 4 Wind Speed (m/s)Precipitation Freq (Days)2.2 63 1.3 User Entered Comments & Non-Default Data 1.0 Project Characteristics Utility Company Pacific Gas & Electric Company 2020Operational Year CO2 Intensity (lb/MWhr) 519.21 0.023CH4 Intensity (lb/MWhr) 0.005N2O Intensity (lb/MWhr) Dublin IKEA Retail Center Mitigated Alameda County, Winter CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 1 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter Project Characteristics - PG&E Intensity Factors reduced by 19%. Land Use - Land uses provided by applicant. Construction Phase - 10 days Demo, 45 days Grading, 290 days Building Construction, 35 days Paving, and 45 days Painting. Off-road Equipment - Off-road Equipment - Building Construction equipment hours = 1.5 x default hours to account for the shortened Building Construction period. Off-road Equipment - Demolition - 147 tons builidng material + 290 tons of paving debris = 437.20 total tons of demolition debris Architectural Coating - Non-Residential Interior and Exterior VOC set to 45 g/L. Vehicle Trips - Trip Rates and Trip Length adjusted to match TIA. Energy Use - Electricty usage for IKEA reduced by 29%. Construction Off-road Equipment Mitigation - All equipment Tier 4 Interim. Water exposed area. Mobile Land Use Mitigation - Mit TRANS-7A - Busstop 0.05 miles (Martinelli Wy); Project Design Feature 1 - Improve pedestrian network on project site and connecting off-site; Area Mitigation - Use low VOC Paint on non-res interior, 45 g/L. Energy Mitigation - 42 percent renewable energy generated Water Mitigation - Install low-flow fixtures and water-efficient irrigation systems. Waste Mitigation - 50 percent waste diverted. Operational Off-Road Equipment - . Fleet Mix - Fleet mix updated to account for 70 2-axle trucks and 18 4-axle. Stationary Sources - Emergency Generators and Fire Pumps - 1 backup generator at IKEA, run 0.5 hours, 6 hour/year, 2,923 HP; load factor 0.5. Grading - 95,000 cy cut and 73,700 cy fill = 21,300 cy exported offsite Table Name Column Name Default Value New Value tblArchitecturalCoating EF_Nonresidential_Exterior 150.00 45.00 tblArchitecturalCoating EF_Nonresidential_Interior 100.00 45.00 tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV alue 100 45 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 2 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstructionPhase NumDays 30.00 10.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 3 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter tblConstructionPhase NumDays 440.00 290.00 tblConstructionPhase NumDays 35.00 45.00 tblEnergyUse LightingElect 1.75 1.24 tblEnergyUse LightingElect 5.25 3.72 tblEnergyUse NT24E 0.19 0.13 tblEnergyUse NT24E 2.68 1.91 tblEnergyUse T24E 3.92 2.78 tblEnergyUse T24E 2.76 1.96 tblFleetMix HHD 0.04 0.33 tblFleetMix HHD 0.04 0.00 tblFleetMix HHD 0.04 0.00 tblFleetMix HHD 0.04 0.33 tblFleetMix HHD 0.04 0.00 tblFleetMix LDA 0.56 0.00 tblFleetMix LDA 0.56 0.62 tblFleetMix LDA 0.56 0.62 tblFleetMix LDA 0.56 0.00 tblFleetMix LDA 0.56 0.62 tblFleetMix LDT1 0.04 0.00 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT1 0.04 0.00 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT2 0.19 0.00 tblFleetMix LDT2 0.19 0.21 tblFleetMix LDT2 0.19 0.21 tblFleetMix LDT2 0.19 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 4 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter tblFleetMix LDT2 0.19 0.21 tblFleetMix LHD1 0.02 0.67 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD1 0.02 0.67 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix MCY 5.5690e-003 0.00 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MCY 5.5690e-003 0.00 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MDV 0.11 0.00 tblFleetMix MDV 0.11 0.12 tblFleetMix MDV 0.11 0.12 tblFleetMix MDV 0.11 0.00 tblFleetMix MDV 0.11 0.12 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MHD 0.02 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 5 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblGrading MaterialExported 0.00 21,300.00 tblLandUse LandUseSquareFeet 410,400.00 464,212.00 tblLandUse LandUseSquareFeet 339,100.00 339,099.00 tblLandUse LotAcreage 9.23 4.00 tblLandUse LotAcreage 5.11 10.57 tblLandUse LotAcreage 1.34 1.55 tblLandUse LotAcreage 7.78 9.65 tblLandUse LotAcreage 0.79 1.55 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 6 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter tblOffRoadEquipment UsageHours 7.00 11.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblOffRoadEquipment UsageHours 7.00 11.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblProjectCharacteristics CH4IntensityFactor 0.029 0.023 tblProjectCharacteristics CO2IntensityFactor 641.35 519.21 tblProjectCharacteristics N2OIntensityFactor 0.006 0.005 tblVehicleTrips CC_TL 7.30 31.00 tblVehicleTrips CC_TL 7.30 15.00 tblVehicleTrips CC_TL 7.30 9.00 tblVehicleTrips CC_TL 7.30 24.00 tblVehicleTrips CC_TL 7.30 9.00 tblVehicleTrips CC_TTP 0.00 100.00 tblVehicleTrips CC_TTP 0.00 100.00 tblVehicleTrips CNW_TL 7.30 31.00 tblVehicleTrips CNW_TL 7.30 15.00 tblVehicleTrips CNW_TL 7.30 9.00 tblVehicleTrips CNW_TL 7.30 24.00 tblVehicleTrips CNW_TL 7.30 9.00 tblVehicleTrips CW_TL 9.50 31.00 tblVehicleTrips CW_TL 9.50 15.00 tblVehicleTrips CW_TL 9.50 9.00 tblVehicleTrips CW_TL 9.50 24.00 tblVehicleTrips CW_TL 9.50 9.00 tblVehicleTrips PR_TP 0.00 100.00 tblVehicleTrips PR_TP 0.00 100.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 7 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 2.0 Emissions Summary tblVehicleTrips ST_TR 0.00 0.03 tblVehicleTrips ST_TR 64.07 17.63 tblVehicleTrips ST_TR 158.37 126.64 tblVehicleTrips ST_TR 0.00 0.10 tblVehicleTrips ST_TR 42.04 97.54 tblVehicleTrips SU_TR 0.00 0.03 tblVehicleTrips SU_TR 56.12 17.63 tblVehicleTrips SU_TR 131.84 126.64 tblVehicleTrips SU_TR 0.00 0.10 tblVehicleTrips SU_TR 20.43 97.54 tblVehicleTrips WD_TR 0.00 0.03 tblVehicleTrips WD_TR 50.75 17.63 tblVehicleTrips WD_TR 127.15 126.64 tblVehicleTrips WD_TR 0.00 0.10 tblVehicleTrips WD_TR 44.32 97.54 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 8 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 2.1 Overall Construction (Maximum Daily Emission) ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Year lb/day lb/day 2018 5.7553 79.0019 39.1489 0.1112 9.9267 2.7087 12.6354 3.9322 2.4947 6.4268 0.0000 11,450.847 1 11,450.847 1 2.2295 0.0000 11,506.584 1 2019 6.2866 57.3195 45.0115 0.1264 4.8201 2.1561 6.9763 1.3068 2.0283 3.3351 0.0000 12,748.12 86 12,748.12 86 1.4275 0.0000 12,783.81 55 2020 47.0392 52.3209 42.5768 0.1249 4.8201 1.8395 6.6597 1.3068 1.7301 3.0369 0.0000 12,543.25 21 12,543.25 21 1.3765 0.0000 12,577.66 55 Maximum 47.0392 79.0019 45.0115 0.1264 9.9267 2.7087 12.6354 3.9322 2.4947 6.4268 0.0000 12,748.12 86 12,748.12 86 2.2295 0.0000 12,783.81 55 Unmitigated Construction ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Year lb/day lb/day 2018 1.6762 38.7508 40.7821 0.1112 4.6034 0.1765 4.7798 1.7333 0.1732 1.9065 0.0000 11,450.847 1 11,450.847 1 2.2295 0.0000 11,506.584 1 2019 3.4889 41.6052 46.1326 0.1264 4.8201 0.3046 5.1247 1.3068 0.2961 1.6029 0.0000 12,748.12 86 12,748.12 86 1.4275 0.0000 12,783.81 55 2020 46.8515 39.5277 44.1862 0.1249 4.8201 0.2535 5.0737 1.3068 0.2473 1.5541 0.0000 12,543.25 21 12,543.25 21 1.3765 0.0000 12,577.66 55 Maximum 46.8515 41.6052 46.1326 0.1264 4.8201 0.3046 5.1247 1.7333 0.2961 1.9065 0.0000 12,748.12 86 12,748.12 86 2.2295 0.0000 12,783.81 55 Mitigated Construction CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 9 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 2.2 Overall Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Area 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 Mobile 25.1668 44.8840 304.9522 0.7693 74.6479 0.5878 75.2357 19.8113 0.5451 20.3564 76,794.61 41 76,794.61 41 2.7574 76,863.54 78 Stationary 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 38.0197 55.7332 312.2899 0.7983 74.6479 1.0962 75.7441 19.8113 1.0535 20.8649 81,836.58 78 81,836.58 78 2.9569 0.0770 81,933.46 21 Unmitigated Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Percent Reduction 11.96 36.45 -3.44 0.00 27.21 89.04 42.99 33.59 88.54 60.44 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 10 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 2.2 Overall Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Area 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 Mobile 24.2612 40.6929 280.3369 0.6823 65.8395 0.5293 66.3687 17.4736 0.4908 17.9643 68,090.22 29 68,090.22 29 2.5011 68,152.75 07 Stationary 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 36.6614 51.5420 287.6746 0.7112 65.8395 1.0377 66.8772 17.4736 0.9992 18.4728 73,132.19 66 73,132.19 66 2.7006 0.0770 73,222.66 50 Mitigated Operational 3.0 Construction Detail Construction Phase ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Percent Reduction 3.57 7.52 7.88 10.90 11.80 5.34 11.71 11.80 5.16 11.46 0.00 10.64 10.64 8.67 0.00 10.63 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 11 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter Phase Number Phase Name Phase Type Start Date End Date Num Days Week Num Days Phase Description 1 Demolition Demolition 10/15/2018 10/26/2018 5 10 2 Grading Grading 10/27/2018 12/30/2018 5 45 3 Building Construction Building Construction 1/1/2019 2/10/2020 5 290 4 Paving Paving 2/11/2020 3/30/2020 5 35 5 Architectural Coating Architectural Coating 4/1/2020 6/2/2020 5 45 OffRoad Equipment Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 648,149; Non-Residential Outdoor: 216,050; Striped Parking Area: 41,485 (Architectural Coating ±sqft) Acres of Grading (Site Preparation Phase): 0 Acres of Grading (Grading Phase): 112.5 Acres of Paving: 14.57 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 12 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73 Demolition Excavators 3 8.00 158 0.38 Demolition Rubber Tired Dozers 2 8.00 247 0.40 Grading Excavators 2 8.00 158 0.38 Grading Graders 1 8.00 187 0.41 Grading Rubber Tired Dozers 1 8.00 247 0.40 Grading Scrapers 2 8.00 367 0.48 Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37 Building Construction Cranes 1 11.00 231 0.29 Building Construction Forklifts 3 12.00 89 0.20 Building Construction Generator Sets 1 12.00 84 0.74 Building Construction Tractors/Loaders/Backhoes 3 11.00 97 0.37 Building Construction Welders 1 12.00 46 0.45 Paving Pavers 2 8.00 130 0.42 Paving Paving Equipment 2 8.00 132 0.36 Paving Rollers 2 8.00 80 0.38 Architectural Coating Air Compressors 1 6.00 78 0.48 Trips and VMT Phase Name Offroad Equipment Count Worker Trip Number Vendor Trip Number Hauling Trip Number Worker Trip Length Vendor Trip Length Hauling Trip Length Worker Vehicle Class Vendor Vehicle Class Hauling Vehicle Class Demolition 6 15.00 0.00 43.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 2,662.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 435.00 184.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 87.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 13 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 0.9356 0.0000 0.9356 0.1417 0.0000 0.1417 0.0000 0.0000 Off-Road 3.7190 38.3225 22.3040 0.0388 1.9386 1.9386 1.8048 1.8048 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Total 3.7190 38.3225 22.3040 0.0388 0.9356 1.9386 2.8741 0.1417 1.8048 1.9465 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Unmitigated Construction On-Site 3.1 Mitigation Measures Construction Use Cleaner Engines for Construction Equipment Water Exposed Area CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 14 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0416 1.4108 0.2458 3.4600e- 003 0.0753 5.3600e- 003 0.0806 0.0206 5.1300e- 003 0.0258 366.5733 366.5733 0.0204 367.0827 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0694 0.0541 0.5090 1.2300e- 003 0.1232 8.7000e- 004 0.1241 0.0327 8.0000e- 004 0.0335 122.5729 122.5729 3.9000e- 003 122.6704 Total 0.1111 1.4649 0.7547 4.6900e- 003 0.1985 6.2300e- 003 0.2047 0.0533 5.9300e- 003 0.0593 489.1462 489.1462 0.0243 489.7531 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 0.3649 0.0000 0.3649 0.0552 0.0000 0.0552 0.0000 0.0000 Off-Road 0.5841 13.5576 24.6739 0.0388 0.0616 0.0616 0.0616 0.0616 0.0000 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Total 0.5841 13.5576 24.6739 0.0388 0.3649 0.0616 0.4265 0.0552 0.0616 0.1169 0.0000 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 15 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0416 1.4108 0.2458 3.4600e- 003 0.0753 5.3600e- 003 0.0806 0.0206 5.1300e- 003 0.0258 366.5733 366.5733 0.0204 367.0827 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0694 0.0541 0.5090 1.2300e- 003 0.1232 8.7000e- 004 0.1241 0.0327 8.0000e- 004 0.0335 122.5729 122.5729 3.9000e- 003 122.6704 Total 0.1111 1.4649 0.7547 4.6900e- 003 0.1985 6.2300e- 003 0.2047 0.0533 5.9300e- 003 0.0593 489.1462 489.1462 0.0243 489.7531 Mitigated Construction Off-Site 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 8.7269 0.0000 8.7269 3.6046 0.0000 3.6046 0.0000 0.0000 Off-Road 5.0901 59.5218 35.0894 0.0620 2.6337 2.6337 2.4230 2.4230 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Total 5.0901 59.5218 35.0894 0.0620 8.7269 2.6337 11.3606 3.6046 2.4230 6.0277 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 16 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.5726 19.4079 3.3809 0.0475 1.0356 0.0738 1.1093 0.2840 0.0706 0.3545 5,042.988 2 5,042.988 2 0.2803 5,049.995 7 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0926 0.0722 0.6786 1.6400e- 003 0.1643 1.1500e- 003 0.1655 0.0436 1.0600e- 003 0.0446 163.4305 163.4305 5.2000e- 003 163.5606 Total 0.6652 19.4801 4.0595 0.0492 1.1999 0.0749 1.2748 0.3275 0.0716 0.3992 5,206.418 7 5,206.418 7 0.2855 5,213.556 3 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 3.4035 0.0000 3.4035 1.4058 0.0000 1.4058 0.0000 0.0000 Off-Road 1.0110 19.2707 36.7226 0.0620 0.1015 0.1015 0.1015 0.1015 0.0000 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Total 1.0110 19.2707 36.7226 0.0620 3.4035 0.1015 3.5050 1.4058 0.1015 1.5073 0.0000 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 17 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.5726 19.4079 3.3809 0.0475 1.0356 0.0738 1.1093 0.2840 0.0706 0.3545 5,042.988 2 5,042.988 2 0.2803 5,049.995 7 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0926 0.0722 0.6786 1.6400e- 003 0.1643 1.1500e- 003 0.1655 0.0436 1.0600e- 003 0.0446 163.4305 163.4305 5.2000e- 003 163.5606 Total 0.6652 19.4801 4.0595 0.0492 1.1999 0.0749 1.2748 0.3275 0.0716 0.3992 5,206.418 7 5,206.418 7 0.2855 5,213.556 3 Mitigated Construction Off-Site 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Total 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 18 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.8522 23.5096 5.6090 0.0504 1.2467 0.1517 1.3984 0.3590 0.1451 0.5041 5,316.751 3 5,316.751 3 0.3512 5,325.531 2 Worker 1.8176 1.3780 13.0818 0.0347 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,450.642 3 3,450.642 3 0.0997 3,453.135 8 Total 2.6697 24.8876 18.6908 0.0851 4.8201 0.1762 4.9963 1.3068 0.1677 1.4745 8,767.393 6 8,767.393 6 0.4509 8,778.667 0 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 19 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.8522 23.5096 5.6090 0.0504 1.2467 0.1517 1.3984 0.3590 0.1451 0.5041 5,316.751 3 5,316.751 3 0.3512 5,325.531 2 Worker 1.8176 1.3780 13.0818 0.0347 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,450.642 3 3,450.642 3 0.0997 3,453.135 8 Total 2.6697 24.8876 18.6908 0.0851 4.8201 0.1762 4.9963 1.3068 0.1677 1.4745 8,767.393 6 8,767.393 6 0.4509 8,778.667 0 Mitigated Construction Off-Site 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Total 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 20 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.7115 21.5923 5.0273 0.0500 1.2467 0.1012 1.3480 0.3590 0.0968 0.4558 5,278.457 2 5,278.457 2 0.3254 5,286.593 1 Worker 1.6600 1.2179 11.7171 0.0336 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,343.881 9 3,343.881 9 0.0873 3,346.063 9 Total 2.3715 22.8101 16.7444 0.0836 4.8201 0.1251 4.9452 1.3068 0.1188 1.4256 8,622.339 1 8,622.339 1 0.4127 8,632.657 0 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 21 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.7115 21.5923 5.0273 0.0500 1.2467 0.1012 1.3480 0.3590 0.0968 0.4558 5,278.457 2 5,278.457 2 0.3254 5,286.593 1 Worker 1.6600 1.2179 11.7171 0.0336 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,343.881 9 3,343.881 9 0.0873 3,346.063 9 Total 2.3715 22.8101 16.7444 0.0836 4.8201 0.1251 4.9452 1.3068 0.1188 1.4256 8,622.339 1 8,622.339 1 0.4127 8,632.657 0 Mitigated Construction Off-Site 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 1.3566 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1478 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 22 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0572 0.0420 0.4040 1.1600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 115.3063 115.3063 3.0100e- 003 115.3815 Total 0.0572 0.0420 0.4040 1.1600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 115.3063 115.3063 3.0100e- 003 115.3815 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.3341 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.1253 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 23 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0572 0.0420 0.4040 1.1600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 115.3063 115.3063 3.0100e- 003 115.3815 Total 0.0572 0.0420 0.4040 1.1600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 115.3063 115.3063 3.0100e- 003 115.3815 Mitigated Construction Off-Site 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2422 1.6838 1.8314 2.9700e- 003 0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928 Total 46.7072 1.6838 1.8314 2.9700e- 003 0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 24 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.3320 0.2436 2.3434 6.7100e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 668.7764 668.7764 0.0175 669.2128 Total 0.3320 0.2436 2.3434 6.7100e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 668.7764 668.7764 0.0175 669.2128 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0545 1.0598 1.8324 2.9700e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 0.0000 281.4481 281.4481 0.0218 281.9928 Total 46.5195 1.0598 1.8324 2.9700e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 0.0000 281.4481 281.4481 0.0218 281.9928 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 25 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile Increase Transit Accessibility Improve Pedestrian Network 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.3320 0.2436 2.3434 6.7100e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 668.7764 668.7764 0.0175 669.2128 Total 0.3320 0.2436 2.3434 6.7100e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 668.7764 668.7764 0.0175 669.2128 Mitigated Construction Off-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 26 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Mitigated 24.2612 40.6929 280.3369 0.6823 65.8395 0.5293 66.3687 17.4736 0.4908 17.9643 68,090.22 29 68,090.22 29 2.5011 68,152.75 07 Unmitigated 25.1668 44.8840 304.9522 0.7693 74.6479 0.5878 75.2357 19.8113 0.5451 20.3564 76,794.61 41 76,794.61 41 2.7574 76,863.54 78 4.2 Trip Summary Information 4.3 Trip Type Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual VMT Enclosed Parking with Elevator 30.78 30.78 30.78 347,322 306,338 Free-Standing Discount Superstore 5,978.33 5,978.33 5978.33 18,438,751 16,262,979 High Turnover (Sit Down Restaurant)7,400.84 7,400.84 7400.84 10,298,804 9,083,545 Parking Lot 56.80 56.80 56.80 496,205 437,653 Strip Mall 3,370.98 3,370.98 3370.98 6,092,242 5,373,357 Total 16,837.74 16,837.74 16,837.74 35,673,323 31,463,871 Miles Trip %Trip Purpose % Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Enclosed Parking with Elevator 31.00 31.00 31.00 0.00 100.00 0.00 100 0 0 Free-Standing Discount Superstore 15.00 15.00 15.00 13.20 67.80 19.00 47.5 35.5 17 High Turnover (Sit Down Restaurant) 9.00 9.00 9.00 8.50 72.50 19.00 37 20 43 Parking Lot 24.00 24.00 24.00 0.00 100.00 0.00 100 0 0 Strip Mall 9.00 9.00 9.00 16.60 64.40 19.00 45 40 15 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 27 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 5.0 Energy Detail ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day NaturalGas Mitigated 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 NaturalGas Unmitigated 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 5.1 Mitigation Measures Energy Percent of Electricity Use Generated with Renewable Energy 4.4 Fleet Mix Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000 Free-Standing Discount Superstore 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 High Turnover (Sit Down Restaurant) 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 Parking Lot 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000 Strip Mall 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 Historical Energy Use: N CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 28 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 5.2 Energy by Land Use - NaturalGas NaturalGa s Use ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Land Use kBTU/yr lb/day lb/day Enclosed Parking with Elevator 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Free-Standing Discount Superstore 2201.82 0.0238 0.2159 0.1813 1.3000e- 003 0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e- 003 4.7500e- 003 260.5771 High Turnover (Sit Down Restaurant) 33283.6 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715 5 3,915.715 5 0.0751 0.0718 3,938.984 6 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Strip Mall 224.403 2.4200e- 003 0.0220 0.0185 1.3000e- 004 1.6700e- 003 1.6700e- 003 1.6700e- 003 1.6700e- 003 26.4004 26.4004 5.1000e- 004 4.8000e- 004 26.5573 Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 Unmitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 29 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter Use Low VOC Paint - Non-Residential Interior 6.1 Mitigation Measures Area 6.0 Area Detail 5.2 Energy by Land Use - NaturalGas NaturalGa s Use ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Land Use kBTU/yr lb/day lb/day Enclosed Parking with Elevator 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Free-Standing Discount Superstore 2.20182 0.0238 0.2159 0.1813 1.3000e- 003 0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e- 003 4.7500e- 003 260.5771 High Turnover (Sit Down Restaurant) 33.2836 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715 5 3,915.715 5 0.0751 0.0718 3,938.984 6 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Strip Mall 0.224403 2.4200e- 003 0.0220 0.0185 1.3000e- 004 1.6700e- 003 1.6700e- 003 1.6700e- 003 1.6700e- 003 26.4004 26.4004 5.1000e- 004 4.8000e- 004 26.5573 Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 Mitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 30 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Mitigated 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Unmitigated 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 6.2 Area by SubCategory ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e SubCategory lb/day lb/day Architectural Coating 1.3136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer Products 9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0196 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Total 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Unmitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 31 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 8.1 Mitigation Measures Waste Institute Recycling and Composting Services Install Low Flow Bathroom Faucet Install Low Flow Kitchen Faucet Install Low Flow Toilet Use Water Efficient Irrigation System 7.1 Mitigation Measures Water 7.0 Water Detail 8.0 Waste Detail 6.2 Area by SubCategory ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e SubCategory lb/day lb/day Architectural Coating 0.8609 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer Products 9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0196 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Total 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Mitigated 9.0 Operational Offroad CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 32 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 11.0 Vegetation Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Stationary Equipment Fire Pumps and Emergency Generators Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Emergency Generator 1 0.5 6 2923 0.5 Diesel Boilers Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment Equipment Type Number 10.1 Stationary Sources ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Equipment Type lb/day lb/day Emergency Generator - Diesel (750 - 9999 HP) 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Unmitigated/Mitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:19 AMPage 33 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Winter 1.1 Land Usage Land Uses Size Metric Lot Acreage Floor Surface Area Population Enclosed Parking with Elevator 1,026.00 Space 4.00 464,212.00 0 Parking Lot 568.00 Space 10.57 227,200.00 0 High Turnover (Sit Down Restaurant)58.44 1000sqft 1.55 58,440.00 0 Free-Standing Discount Superstore 339.10 1000sqft 9.65 339,099.00 0 Strip Mall 34.56 1000sqft 1.55 34,560.00 0 1.2 Other Project Characteristics Urbanization Climate Zone Urban 4 Wind Speed (m/s)Precipitation Freq (Days)2.2 63 1.3 User Entered Comments & Non-Default Data 1.0 Project Characteristics Utility Company Pacific Gas & Electric Company 2020Operational Year CO2 Intensity (lb/MWhr) 519.21 0.023CH4 Intensity (lb/MWhr) 0.005N2O Intensity (lb/MWhr) Dublin IKEA Retail Center Mitigated Alameda County, Summer CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 1 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer Project Characteristics - PG&E Intensity Factors reduced by 19%. Land Use - Land uses provided by applicant. Construction Phase - 10 days Demo, 45 days Grading, 290 days Building Construction, 35 days Paving, and 45 days Painting. Off-road Equipment - Off-road Equipment - Building Construction equipment hours = 1.5 x default hours to account for the shortened Building Construction period. Off-road Equipment - Demolition - 147 tons builidng material + 290 tons of paving debris = 437.20 total tons of demolition debris Architectural Coating - Non-Residential Interior and Exterior VOC set to 45 g/L. Vehicle Trips - Trip Rates and Trip Length adjusted to match TIA. Energy Use - Electricty usage for IKEA reduced by 29%. Construction Off-road Equipment Mitigation - All equipment Tier 4 Interim. Water exposed area. Mobile Land Use Mitigation - Mit TRANS-7A - Busstop 0.05 miles (Martinelli Wy); Project Design Feature 1 - Improve pedestrian network on project site and connecting off-site; Area Mitigation - Use low VOC Paint on non-res interior, 45 g/L. Energy Mitigation - 42 percent renewable energy generated Water Mitigation - Install low-flow fixtures and water-efficient irrigation systems. Waste Mitigation - 50 percent waste diverted. Operational Off-Road Equipment - . Fleet Mix - Fleet mix updated to account for 70 2-axle trucks and 18 4-axle. Stationary Sources - Emergency Generators and Fire Pumps - 1 backup generator at IKEA, run 0.5 hours, 6 hour/year, 2,923 HP; load factor 0.5. Grading - 95,000 cy cut and 73,700 cy fill = 21,300 cy exported offsite Table Name Column Name Default Value New Value tblArchitecturalCoating EF_Nonresidential_Exterior 150.00 45.00 tblArchitecturalCoating EF_Nonresidential_Interior 100.00 45.00 tblAreaMitigation UseLowVOCPaintNonresidentialInteriorV alue 100 45 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 2 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 3.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 5.00 tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00 tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstEquipMitigation Tier No Change Tier 4 Interim tblConstructionPhase NumDays 30.00 10.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 3 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer tblConstructionPhase NumDays 440.00 290.00 tblConstructionPhase NumDays 35.00 45.00 tblEnergyUse LightingElect 1.75 1.24 tblEnergyUse LightingElect 5.25 3.72 tblEnergyUse NT24E 0.19 0.13 tblEnergyUse NT24E 2.68 1.91 tblEnergyUse T24E 3.92 2.78 tblEnergyUse T24E 2.76 1.96 tblFleetMix HHD 0.04 0.33 tblFleetMix HHD 0.04 0.00 tblFleetMix HHD 0.04 0.00 tblFleetMix HHD 0.04 0.33 tblFleetMix HHD 0.04 0.00 tblFleetMix LDA 0.56 0.00 tblFleetMix LDA 0.56 0.62 tblFleetMix LDA 0.56 0.62 tblFleetMix LDA 0.56 0.00 tblFleetMix LDA 0.56 0.62 tblFleetMix LDT1 0.04 0.00 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT1 0.04 0.00 tblFleetMix LDT1 0.04 0.05 tblFleetMix LDT2 0.19 0.00 tblFleetMix LDT2 0.19 0.21 tblFleetMix LDT2 0.19 0.21 tblFleetMix LDT2 0.19 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 4 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer tblFleetMix LDT2 0.19 0.21 tblFleetMix LHD1 0.02 0.67 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD1 0.02 0.67 tblFleetMix LHD1 0.02 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix LHD2 5.2280e-003 0.00 tblFleetMix MCY 5.5690e-003 0.00 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MCY 5.5690e-003 0.00 tblFleetMix MCY 5.5690e-003 6.0000e-003 tblFleetMix MDV 0.11 0.00 tblFleetMix MDV 0.11 0.12 tblFleetMix MDV 0.11 0.12 tblFleetMix MDV 0.11 0.00 tblFleetMix MDV 0.11 0.12 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MH 7.5900e-004 0.00 tblFleetMix MHD 0.02 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 5 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix MHD 0.02 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix OBUS 2.1180e-003 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix SBUS 3.0800e-004 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblFleetMix UBUS 2.8050e-003 0.00 tblGrading MaterialExported 0.00 21,300.00 tblLandUse LandUseSquareFeet 410,400.00 464,212.00 tblLandUse LandUseSquareFeet 339,100.00 339,099.00 tblLandUse LotAcreage 9.23 4.00 tblLandUse LotAcreage 5.11 10.57 tblLandUse LotAcreage 1.34 1.55 tblLandUse LotAcreage 7.78 9.65 tblLandUse LotAcreage 0.79 1.55 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 6 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer tblOffRoadEquipment UsageHours 7.00 11.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblOffRoadEquipment UsageHours 7.00 11.00 tblOffRoadEquipment UsageHours 8.00 12.00 tblProjectCharacteristics CH4IntensityFactor 0.029 0.023 tblProjectCharacteristics CO2IntensityFactor 641.35 519.21 tblProjectCharacteristics N2OIntensityFactor 0.006 0.005 tblVehicleTrips CC_TL 7.30 31.00 tblVehicleTrips CC_TL 7.30 15.00 tblVehicleTrips CC_TL 7.30 9.00 tblVehicleTrips CC_TL 7.30 24.00 tblVehicleTrips CC_TL 7.30 9.00 tblVehicleTrips CC_TTP 0.00 100.00 tblVehicleTrips CC_TTP 0.00 100.00 tblVehicleTrips CNW_TL 7.30 31.00 tblVehicleTrips CNW_TL 7.30 15.00 tblVehicleTrips CNW_TL 7.30 9.00 tblVehicleTrips CNW_TL 7.30 24.00 tblVehicleTrips CNW_TL 7.30 9.00 tblVehicleTrips CW_TL 9.50 31.00 tblVehicleTrips CW_TL 9.50 15.00 tblVehicleTrips CW_TL 9.50 9.00 tblVehicleTrips CW_TL 9.50 24.00 tblVehicleTrips CW_TL 9.50 9.00 tblVehicleTrips PR_TP 0.00 100.00 tblVehicleTrips PR_TP 0.00 100.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 7 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 2.0 Emissions Summary tblVehicleTrips ST_TR 0.00 0.03 tblVehicleTrips ST_TR 64.07 17.63 tblVehicleTrips ST_TR 158.37 126.64 tblVehicleTrips ST_TR 0.00 0.10 tblVehicleTrips ST_TR 42.04 97.54 tblVehicleTrips SU_TR 0.00 0.03 tblVehicleTrips SU_TR 56.12 17.63 tblVehicleTrips SU_TR 131.84 126.64 tblVehicleTrips SU_TR 0.00 0.10 tblVehicleTrips SU_TR 20.43 97.54 tblVehicleTrips WD_TR 0.00 0.03 tblVehicleTrips WD_TR 50.75 17.63 tblVehicleTrips WD_TR 127.15 126.64 tblVehicleTrips WD_TR 0.00 0.10 tblVehicleTrips WD_TR 44.32 97.54 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 8 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 2.1 Overall Construction (Maximum Daily Emission) ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Year lb/day lb/day 2018 5.7349 78.5213 38.8747 0.1122 9.9267 2.7074 12.6341 3.9322 2.4934 6.4256 0.0000 11,556.913 9 11,556.913 9 2.2092 0.0000 11,612.143 3 2019 6.1714 56.7724 44.9687 0.1308 4.8201 2.1539 6.9740 1.3068 2.0262 3.3330 0.0000 13,195.46 96 13,195.46 96 1.4009 0.0000 13,230.49 31 2020 47.0255 51.8731 42.5837 0.1292 4.8201 1.8380 6.6581 1.3068 1.7286 3.0354 0.0000 12,982.34 33 12,982.34 33 1.3522 0.0000 13,016.14 86 Maximum 47.0255 78.5213 44.9687 0.1308 9.9267 2.7074 12.6341 3.9322 2.4934 6.4256 0.0000 13,195.46 96 13,195.46 96 2.2092 0.0000 13,230.49 31 Unmitigated Construction ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Year lb/day lb/day 2018 1.6558 38.2703 40.5079 0.1122 4.6034 0.1752 4.7785 1.7333 0.1719 1.9053 0.0000 11,556.913 9 11,556.913 9 2.2092 0.0000 11,612.143 3 2019 3.3737 41.0580 46.0898 0.1308 4.8201 0.3024 5.1225 1.3068 0.2940 1.6008 0.0000 13,195.46 96 13,195.46 96 1.4009 0.0000 13,230.49 31 2020 46.8378 39.0799 44.1931 0.1292 4.8201 0.2520 5.0721 1.3068 0.2458 1.5526 0.0000 12,982.34 33 12,982.34 33 1.3522 0.0000 13,016.14 86 Maximum 46.8378 41.0580 46.0898 0.1308 4.8201 0.3024 5.1225 1.7333 0.2940 1.9053 0.0000 13,195.46 96 13,195.46 96 2.2092 0.0000 13,230.49 31 Mitigated Construction CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 9 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 2.2 Overall Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Area 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 Mobile 30.0564 38.6111 298.8805 0.8301 74.6479 0.5873 75.2352 19.8113 0.5447 20.3560 82,895.07 31 82,895.07 31 2.7478 82,963.76 79 Stationary 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 42.9093 49.4603 306.2182 0.8590 74.6479 1.0958 75.7437 19.8113 1.0531 20.8645 87,937.04 68 87,937.04 68 2.9473 0.0770 88,033.68 22 Unmitigated Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Percent Reduction 11.99 36.74 -3.45 0.00 27.21 89.11 42.99 33.59 88.61 60.46 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 10 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 2.2 Overall Operational ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Area 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Energy 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 Mobile 29.1340 35.0229 271.1314 0.7359 65.8395 0.5288 66.3683 17.4736 0.4904 17.9639 73,476.22 62 73,476.22 62 2.4745 73,538.08 78 Stationary 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 41.5341 45.8721 278.4691 0.7648 65.8395 1.0373 66.8768 17.4736 0.9988 18.4724 78,518.19 99 78,518.19 99 2.6740 0.0770 78,608.00 21 Mitigated Operational 3.0 Construction Detail Construction Phase ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e Percent Reduction 3.20 7.25 9.06 10.97 11.80 5.34 11.71 11.80 5.16 11.46 0.00 10.71 10.71 9.27 0.00 10.71 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 11 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer Phase Number Phase Name Phase Type Start Date End Date Num Days Week Num Days Phase Description 1 Demolition Demolition 10/15/2018 10/26/2018 5 10 2 Grading Grading 10/27/2018 12/30/2018 5 45 3 Building Construction Building Construction 1/1/2019 2/10/2020 5 290 4 Paving Paving 2/11/2020 3/30/2020 5 35 5 Architectural Coating Architectural Coating 4/1/2020 6/2/2020 5 45 OffRoad Equipment Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 648,149; Non-Residential Outdoor: 216,050; Striped Parking Area: 41,485 (Architectural Coating ±sqft) Acres of Grading (Site Preparation Phase): 0 Acres of Grading (Grading Phase): 112.5 Acres of Paving: 14.57 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 12 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73 Demolition Excavators 3 8.00 158 0.38 Demolition Rubber Tired Dozers 2 8.00 247 0.40 Grading Excavators 2 8.00 158 0.38 Grading Graders 1 8.00 187 0.41 Grading Rubber Tired Dozers 1 8.00 247 0.40 Grading Scrapers 2 8.00 367 0.48 Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37 Building Construction Cranes 1 11.00 231 0.29 Building Construction Forklifts 3 12.00 89 0.20 Building Construction Generator Sets 1 12.00 84 0.74 Building Construction Tractors/Loaders/Backhoes 3 11.00 97 0.37 Building Construction Welders 1 12.00 46 0.45 Paving Pavers 2 8.00 130 0.42 Paving Paving Equipment 2 8.00 132 0.36 Paving Rollers 2 8.00 80 0.38 Architectural Coating Air Compressors 1 6.00 78 0.48 Trips and VMT Phase Name Offroad Equipment Count Worker Trip Number Vendor Trip Number Hauling Trip Number Worker Trip Length Vendor Trip Length Hauling Trip Length Worker Vehicle Class Vendor Vehicle Class Hauling Vehicle Class Demolition 6 15.00 0.00 43.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 2,662.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 435.00 184.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 87.00 0.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 13 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 0.9356 0.0000 0.9356 0.1417 0.0000 0.1417 0.0000 0.0000 Off-Road 3.7190 38.3225 22.3040 0.0388 1.9386 1.9386 1.8048 1.8048 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Total 3.7190 38.3225 22.3040 0.0388 0.9356 1.9386 2.8741 0.1417 1.8048 1.9465 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Unmitigated Construction On-Site 3.1 Mitigation Measures Construction Use Cleaner Engines for Construction Equipment Water Exposed Area CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 14 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0404 1.3769 0.2235 3.5200e- 003 0.0753 5.2700e- 003 0.0805 0.0206 5.0400e- 003 0.0257 373.2552 373.2552 0.0189 373.7271 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0664 0.0435 0.5334 1.3400e- 003 0.1232 8.7000e- 004 0.1241 0.0327 8.0000e- 004 0.0335 133.1811 133.1811 4.1200e- 003 133.2842 Total 0.1068 1.4204 0.7568 4.8600e- 003 0.1985 6.1400e- 003 0.2046 0.0533 5.8400e- 003 0.0592 506.4362 506.4362 0.0230 507.0113 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 0.3649 0.0000 0.3649 0.0552 0.0000 0.0552 0.0000 0.0000 Off-Road 0.5841 13.5576 24.6739 0.0388 0.0616 0.0616 0.0616 0.0616 0.0000 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Total 0.5841 13.5576 24.6739 0.0388 0.3649 0.0616 0.4265 0.0552 0.0616 0.1169 0.0000 3,871.766 5 3,871.766 5 1.0667 3,898.434 4 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 15 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.2 Demolition - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0404 1.3769 0.2235 3.5200e- 003 0.0753 5.2700e- 003 0.0805 0.0206 5.0400e- 003 0.0257 373.2552 373.2552 0.0189 373.7271 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0664 0.0435 0.5334 1.3400e- 003 0.1232 8.7000e- 004 0.1241 0.0327 8.0000e- 004 0.0335 133.1811 133.1811 4.1200e- 003 133.2842 Total 0.1068 1.4204 0.7568 4.8600e- 003 0.1985 6.1400e- 003 0.2046 0.0533 5.8400e- 003 0.0592 506.4362 506.4362 0.0230 507.0113 Mitigated Construction Off-Site 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 8.7269 0.0000 8.7269 3.6046 0.0000 3.6046 0.0000 0.0000 Off-Road 5.0901 59.5218 35.0894 0.0620 2.6337 2.6337 2.4230 2.4230 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Total 5.0901 59.5218 35.0894 0.0620 8.7269 2.6337 11.3606 3.6046 2.4230 6.0277 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 16 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.5563 18.9415 3.0741 0.0484 1.0356 0.0725 1.1080 0.2840 0.0693 0.3533 5,134.910 7 5,134.910 7 0.2597 5,141.403 3 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0885 0.0580 0.7112 1.7800e- 003 0.1643 1.1500e- 003 0.1655 0.0436 1.0600e- 003 0.0446 177.5748 177.5748 5.5000e- 003 177.7122 Total 0.6448 18.9996 3.7853 0.0502 1.1999 0.0736 1.2735 0.3275 0.0704 0.3979 5,312.485 5 5,312.485 5 0.2652 5,319.115 5 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Fugitive Dust 3.4035 0.0000 3.4035 1.4058 0.0000 1.4058 0.0000 0.0000 Off-Road 1.0110 19.2707 36.7226 0.0620 0.1015 0.1015 0.1015 0.1015 0.0000 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Total 1.0110 19.2707 36.7226 0.0620 3.4035 0.1015 3.5050 1.4058 0.1015 1.5073 0.0000 6,244.428 4 6,244.428 4 1.9440 6,293.027 8 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 17 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.3 Grading - 2018 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.5563 18.9415 3.0741 0.0484 1.0356 0.0725 1.1080 0.2840 0.0693 0.3533 5,134.910 7 5,134.910 7 0.2597 5,141.403 3 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0885 0.0580 0.7112 1.7800e- 003 0.1643 1.1500e- 003 0.1655 0.0436 1.0600e- 003 0.0446 177.5748 177.5748 5.5000e- 003 177.7122 Total 0.6448 18.9996 3.7853 0.0502 1.1999 0.0736 1.2735 0.3275 0.0704 0.3979 5,312.485 5 5,312.485 5 0.2652 5,319.115 5 Mitigated Construction Off-Site 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Total 3.6169 32.4319 26.3207 0.0413 1.9800 1.9800 1.8606 1.8606 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 18 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.8138 23.2328 4.8588 0.0518 1.2467 0.1494 1.3962 0.3590 0.1430 0.5019 5,465.082 2 5,465.082 2 0.3186 5,473.046 9 Worker 1.7407 1.1077 13.7892 0.0377 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,749.652 4 3,749.652 4 0.1058 3,752.297 7 Total 2.5545 24.3405 18.6480 0.0895 4.8201 0.1739 4.9941 1.3068 0.1656 1.4724 9,214.734 6 9,214.734 6 0.4244 9,225.344 6 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,980.735 0 3,980.735 0 0.9765 4,005.148 5 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 19 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.4 Building Construction - 2019 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.8138 23.2328 4.8588 0.0518 1.2467 0.1494 1.3962 0.3590 0.1430 0.5019 5,465.082 2 5,465.082 2 0.3186 5,473.046 9 Worker 1.7407 1.1077 13.7892 0.0377 3.5734 0.0245 3.5979 0.9478 0.0226 0.9704 3,749.652 4 3,749.652 4 0.1058 3,752.297 7 Total 2.5545 24.3405 18.6480 0.0895 4.8201 0.1739 4.9941 1.3068 0.1656 1.4724 9,214.734 6 9,214.734 6 0.4244 9,225.344 6 Mitigated Construction Off-Site 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Total 3.2474 29.5107 25.8324 0.0413 1.7144 1.7144 1.6113 1.6113 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 20 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.6769 21.3830 4.3424 0.0514 1.2467 0.0997 1.3464 0.3590 0.0954 0.4543 5,427.606 9 5,427.606 9 0.2953 5,434.988 6 Worker 1.5914 0.9793 12.4089 0.0365 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,633.823 4 3,633.823 4 0.0931 3,636.151 5 Total 2.2683 22.3623 16.7513 0.0879 4.8201 0.1235 4.9437 1.3068 0.1173 1.4241 9,061.430 3 9,061.430 3 0.3884 9,071.140 1 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Total 0.8192 16.7175 27.4418 0.0413 0.1284 0.1284 0.1284 0.1284 0.0000 3,920.913 0 3,920.913 0 0.9638 3,945.008 5 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 21 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.4 Building Construction - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.6769 21.3830 4.3424 0.0514 1.2467 0.0997 1.3464 0.3590 0.0954 0.4543 5,427.606 9 5,427.606 9 0.2953 5,434.988 6 Worker 1.5914 0.9793 12.4089 0.0365 3.5734 0.0239 3.5973 0.9478 0.0220 0.9698 3,633.823 4 3,633.823 4 0.0931 3,636.151 5 Total 2.2683 22.3623 16.7513 0.0879 4.8201 0.1235 4.9437 1.3068 0.1173 1.4241 9,061.430 3 9,061.430 3 0.3884 9,071.140 1 Mitigated Construction Off-Site 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 1.3566 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 2.1478 14.0656 14.6521 0.0228 0.7528 0.7528 0.6926 0.6926 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 22 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0549 0.0338 0.4279 1.2600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 125.3043 125.3043 3.2100e- 003 125.3845 Total 0.0549 0.0338 0.4279 1.2600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 125.3043 125.3043 3.2100e- 003 125.3845 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Off-Road 0.3341 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Paving 0.7912 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 1.1253 10.0395 17.2957 0.0228 0.0374 0.0374 0.0374 0.0374 0.0000 2,207.733 4 2,207.733 4 0.7140 2,225.584 1 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 23 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.5 Paving - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0549 0.0338 0.4279 1.2600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 125.3043 125.3043 3.2100e- 003 125.3845 Total 0.0549 0.0338 0.4279 1.2600e- 003 0.1232 8.2000e- 004 0.1240 0.0327 7.6000e- 004 0.0334 125.3043 125.3043 3.2100e- 003 125.3845 Mitigated Construction Off-Site 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2422 1.6838 1.8314 2.9700e- 003 0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928 Total 46.7072 1.6838 1.8314 2.9700e- 003 0.1109 0.1109 0.1109 0.1109 281.4481 281.4481 0.0218 281.9928 Unmitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 24 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.3183 0.1959 2.4818 7.2900e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 726.7647 726.7647 0.0186 727.2303 Total 0.3183 0.1959 2.4818 7.2900e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 726.7647 726.7647 0.0186 727.2303 Unmitigated Construction Off-Site ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Archit. Coating 46.4651 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0545 1.0598 1.8324 2.9700e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 0.0000 281.4481 281.4481 0.0218 281.9928 Total 46.5195 1.0598 1.8324 2.9700e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 3.9600e- 003 0.0000 281.4481 281.4481 0.0218 281.9928 Mitigated Construction On-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 25 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 4.0 Operational Detail - Mobile 4.1 Mitigation Measures Mobile Increase Transit Accessibility Improve Pedestrian Network 3.6 Architectural Coating - 2020 ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.3183 0.1959 2.4818 7.2900e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 726.7647 726.7647 0.0186 727.2303 Total 0.3183 0.1959 2.4818 7.2900e- 003 0.7147 4.7700e- 003 0.7195 0.1896 4.4000e- 003 0.1940 726.7647 726.7647 0.0186 727.2303 Mitigated Construction Off-Site CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 26 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Mitigated 29.1340 35.0229 271.1314 0.7359 65.8395 0.5288 66.3683 17.4736 0.4904 17.9639 73,476.22 62 73,476.22 62 2.4745 73,538.08 78 Unmitigated 30.0564 38.6111 298.8805 0.8301 74.6479 0.5873 75.2352 19.8113 0.5447 20.3560 82,895.07 31 82,895.07 31 2.7478 82,963.76 79 4.2 Trip Summary Information 4.3 Trip Type Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday Sunday Annual VMT Annual VMT Enclosed Parking with Elevator 30.78 30.78 30.78 347,322 306,338 Free-Standing Discount Superstore 5,978.33 5,978.33 5978.33 18,438,751 16,262,979 High Turnover (Sit Down Restaurant)7,400.84 7,400.84 7400.84 10,298,804 9,083,545 Parking Lot 56.80 56.80 56.80 496,205 437,653 Strip Mall 3,370.98 3,370.98 3370.98 6,092,242 5,373,357 Total 16,837.74 16,837.74 16,837.74 35,673,323 31,463,871 Miles Trip %Trip Purpose % Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Enclosed Parking with Elevator 31.00 31.00 31.00 0.00 100.00 0.00 100 0 0 Free-Standing Discount Superstore 15.00 15.00 15.00 13.20 67.80 19.00 47.5 35.5 17 High Turnover (Sit Down Restaurant) 9.00 9.00 9.00 8.50 72.50 19.00 37 20 43 Parking Lot 24.00 24.00 24.00 0.00 100.00 0.00 100 0 0 Strip Mall 9.00 9.00 9.00 16.60 64.40 19.00 45 40 15 CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 27 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 5.0 Energy Detail ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day NaturalGas Mitigated 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 NaturalGas Unmitigated 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.1190 5.1 Mitigation Measures Energy Percent of Electricity Use Generated with Renewable Energy 4.4 Fleet Mix Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Enclosed Parking with Elevator 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000 Free-Standing Discount Superstore 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 High Turnover (Sit Down Restaurant) 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 Parking Lot 0.000000 0.000000 0.000000 0.000000 0.667000 0.000000 0.000000 0.333000 0.000000 0.000000 0.000000 0.000000 0.000000 Strip Mall 0.616000 0.045000 0.211000 0.122000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.006000 0.000000 0.000000 Historical Energy Use: N CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 28 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 5.2 Energy by Land Use - NaturalGas NaturalGa s Use ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Land Use kBTU/yr lb/day lb/day Enclosed Parking with Elevator 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Free-Standing Discount Superstore 2201.82 0.0238 0.2159 0.1813 1.3000e- 003 0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e- 003 4.7500e- 003 260.5771 High Turnover (Sit Down Restaurant) 33283.6 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715 5 3,915.715 5 0.0751 0.0718 3,938.984 6 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Strip Mall 224.403 2.4200e- 003 0.0220 0.0185 1.3000e- 004 1.6700e- 003 1.6700e- 003 1.6700e- 003 1.6700e- 003 26.4004 26.4004 5.1000e- 004 4.8000e- 004 26.5573 Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 Unmitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 29 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer Use Low VOC Paint - Non-Residential Interior 6.1 Mitigation Measures Area 6.0 Area Detail 5.2 Energy by Land Use - NaturalGas NaturalGa s Use ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Land Use kBTU/yr lb/day lb/day Enclosed Parking with Elevator 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Free-Standing Discount Superstore 2.20182 0.0238 0.2159 0.1813 1.3000e- 003 0.0164 0.0164 0.0164 0.0164 259.0378 259.0378 4.9600e- 003 4.7500e- 003 260.5771 High Turnover (Sit Down Restaurant) 33.2836 0.3589 3.2631 2.7410 0.0196 0.2480 0.2480 0.2480 0.2480 3,915.715 5 3,915.715 5 0.0751 0.0718 3,938.984 6 Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Strip Mall 0.224403 2.4200e- 003 0.0220 0.0185 1.3000e- 004 1.6700e- 003 1.6700e- 003 1.6700e- 003 1.6700e- 003 26.4004 26.4004 5.1000e- 004 4.8000e- 004 26.5573 Total 0.3851 3.5010 2.9408 0.0210 0.2661 0.2661 0.2661 0.2661 4,201.153 6 4,201.153 6 0.0805 0.0770 4,226.119 0 Mitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 30 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Category lb/day lb/day Mitigated 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Unmitigated 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 6.2 Area by SubCategory ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e SubCategory lb/day lb/day Architectural Coating 1.3136 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer Products 9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0196 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Total 10.8250 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Unmitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 31 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 8.1 Mitigation Measures Waste Institute Recycling and Composting Services Install Low Flow Bathroom Faucet Install Low Flow Kitchen Faucet Install Low Flow Toilet Use Water Efficient Irrigation System 7.1 Mitigation Measures Water 7.0 Water Detail 8.0 Waste Detail 6.2 Area by SubCategory ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e SubCategory lb/day lb/day Architectural Coating 0.8609 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer Products 9.4918 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 0.0196 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Total 10.3723 1.9200e- 003 0.2082 2.0000e- 005 7.5000e- 004 7.5000e- 004 7.5000e- 004 7.5000e- 004 0.4434 0.4434 1.1900e- 003 0.4731 Mitigated 9.0 Operational Offroad CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 32 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer 11.0 Vegetation Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type 10.0 Stationary Equipment Fire Pumps and Emergency Generators Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Emergency Generator 1 0.5 6 2923 0.5 Diesel Boilers Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment Equipment Type Number 10.1 Stationary Sources ROG NOx CO SO2 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e Equipment Type lb/day lb/day Emergency Generator - Diesel (750 - 9999 HP) 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Total 1.6428 7.3463 4.1887 7.8900e- 003 0.2417 0.2417 0.2417 0.2417 840.3766 840.3766 0.1178 843.3222 Unmitigated/Mitigated CalEEMod Version: CalEEMod.2016.3.2 Date: 4/6/2018 10:18 AMPage 33 of 33 Dublin IKEA Retail Center Mitigated - Alameda County, Summer