IS/MND Responses and Revisions

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7/12/13 (P:\EVU1201 ECCL\PRODUCTS\RTC\Admin\LSA CommunityCommentersResponseMemo.doc)

L S A A S S O C I A T E S , I N C .

2 2 1 5 F I F T H S T R E E T

B E R K E L E Y , C A L I F O R N I A 9 4 7 1 0

5 1 0 . 5 4 0 . 7 3 3 1 T E L

5 1 0 . 5 4 0 . 7 3 4 4 F A X

C A R L S B A D

F O R T C O L L I N S

F R E S N O

I R V I N E

P A L M S P R I N G S

P T . R I C H M O N D

R I V E R S I D E

R O C K L I N

S A N L U I S O B I S P O

M E M O R A N D U M

DATE:DATE:DATE:DATE: July 12, 2013

TO:TO:TO:TO: Emery Unified School Board of Trustees

FROM:FROM:FROM:FROM: Judith Malamut and Amy Paulsen, LSA

SUBJECT:SUBJECT:SUBJECT:SUBJECT: Response to Comment Letter Submitted by the Community Commenters on

Emeryville Center of Community Life Draft Initial Study Mitigated NegativeDeclaration

Attached please find responses to CEQA-related comments provided in the Community Commentersletter dated July 11, 2013, on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) on the

Emeryville Center of Community Life project . The following provides a response to the comments

received. These responses are provided at a level of detail commensurate with that of the comments.

These responses are in no way meant to limit the District's ability to reference any other portions ofthe draft Mitigated Negative Declaration in greater detail in the future for any reason. Upon review

and consideration of each comment, LSA finds that no new or more severe significant impacts have

been identified than those already identified and mitigated in the IS/MND, and that no new mitigation

measures or alternatives that would further substantially reduce impacts have been identified or

proposed beyond those already proposed in the IS/MND and incorporated into the project. Based on

this analysis, LSA confirms that the mitigation measures necessary to avoid or reduce project-related

impacts to a less-than-significant level are identified and incorporated and made a part of this

Mitigated Negative Declaration. These mitigation measures have been agreed to by the District, andtherefore, the project would not result in significant environmental impacts, and an MND is the

appropriate CEQA document to be adopted.

The responses in this memorandum are keyed to the comments numbered within the comment letter.

If text changes to the IS/MND Document or Mitigation Measures are proposed, they are shown

within this memorandum with new text shown in underline and deleted text shown in strikeout.

The following introductory comments are made to provide general clarification:

1. Should the School Board of Trustees adopt the Emeryville Center of Community Life(ECCL) IS/MND, the Board will also adopt a Mitigation Monitoring and Reporting Program

(MMRP). As noted in Section 15097 of the CEQA Guidelines:

In order to ensure that the mitigation measures and project revisions identified in the EIR or negative

declaration are implemented, the public agency shall adopt a program for monitoring or reporting on

the revisions which it has required in the project and the measures it has imposed to mitigate or avoid

significant environmental effects. A public agency may delegate reporting or monitoring

responsibilities to another public agency or to a private entity which accepts the delegation; however,

until mitigation measures have been completed the lead agency remains responsible for ensuring that

implementation of the mitigation measures occurs in accordance with the program.


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2. It should be noted that CEQA does not require mitigation measures to be prepared unless s asignificant environmental impact has been identified.

3. CEQA requires the evaluation of physical environmental impacts associated with a proposedproject. As set forth by CEQA Guidelines, inconsistencies between the project and applicable

General Plan and other policies do not constitute impacts in and of themselves. A policy

inconsistency is considered to be a significant adverse environmental impact only when it is

related to a policy adopted for the purpose of avoiding or mitigating an environmental effect,

and it is anticipated that the inconsistency would result in a significant adverse physical

impact based on an established significance criterion.

4. While it has been the Districts intent to comply with City regulations to the maximum extentfeasible, it should be noted that the District is a State institution, and therefore exempt from

local land use regulations when land use development is used to further its educational

mission.

5. Evaluation of project alternatives are not required as part of a Mitigated NegativeDeclaration.

Responses to Comments

Comment #1. The following text changes are proposed to the IS/MND to provide further clarification

that the Musco back visors will be installed on field lights as part of the project.

The following text revisions are made to page 45 of the IS/MND:

Musco back visors can will be installed on field lights to further reduce off-site lighttrespass where specific neighboring site conditions warrant.


Mitigation Measures AES-1: The District shall implement the following measures:

The District will identify three distinct lighting scenarios Scenario A: Competitive

Athletic Use (six poles in use); Scenario B: Recreation and Community Use (four poles

in use); and Scenario C: Clean-up Use (minimal lights on) to allow for field light

levels at the lowest acceptable setting for safety depending on the type of field use.

This includes flexibility of light level settings for practices where the full competitive

safety light levels may not be needed.

The light poles will have an additional 1/3 power reduction switch to further adjust andreduce lighting to provide the lowest safe lighting levels needed for any event.

UnlessIf a District game or City-sponsored event is occurring, all lighted use of the

field shall conclude at 8:30 p.m., with lighting turned off at 9:00 10:00 p.m. This 9:00

p.m. ending time coincides with the required time for end use of the PA system. For allother events, use of the field shall conclude at 8:30 p.m., with lighting turned off at

9:00 p.m.

Except for District games, no lighting of the field will occur on Saturdays and Sundays

exceeding the Scenario B lighting scheme.


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Musco back visors will be installed on field lights as part of the project.

Comment #2. All of the Musco fixtures that are proposed have external visors installed that shield the

light coming out of the front of the fixture. The use of back visors to reduce the amount of lightbehind the pole has been, and will be, applied on a light fixture by fixture basis in the proposed

lighting plan and during installation to help meet the need for basic safety on the field and to screen

spill light. Using back visors can degrade the performance on the field, so where these visors need to

be used to reduce light spill has been, and will continue to be, closely evaluated when the lights are

installed and are adjusted. The proposed lighting design balances the off-site spill and glare while

meeting IES light level and safe-play uniformity standards on the fields as well as being IDA (Dark

Skies) compliant. The District will adjust and install back visors where necessary to meet the light

levels identified and evaluated in the IS/MND such that spill light would be under the maximum 2.0

footcandle threshold on adjacent properties and safe play can take place on the fields. Therefore no

additional impacts associated with light and glare will occur as part of the project that would not be

mitigated by Mitigation Measure AES-1. The appropriate application of the fixture visors, as well as,

back visors will allow for controlled spill and glare while meeting safe and playable lightingstandards on the fields.

Comment #3. As stated in response to Comment #2, the proposed lighting design and adjustments

during installation will balance the off-site spill and glare while meeting IES light level and safe-play

uniformity standards on the fields. The District will adjust and install back visors where necessary to

meet the light levels identified and evaluated in the IS/MND such that spill light would be under the

maximum 2.0 footcandle threshold on adjacent properties and safe play can take place on the fields.

Comment #4.The section that the commenter is referring to is titled Localized CO Impacts. The

Bay Area Air Quality Management District (BAAQMD) has established a screening methodology

that provides a conservative indication of whether the implementation of a proposed project would

result in significant CO emissions. According to the BAAQMD CEQA Air Quality Guidelines, theproposed project results in less-than-significant impacts to localized CO concentrations because the

following screening criteria were met:

The project is consistent with an applicable congestion management program established by thecounty congestion management agency for designated roads or highways, regional transportationplan, and local congestion management agency plans;

The project would not increase traffic volumes at affected intersections to more than 44,000vehicles per hour; and

The project would not increase traffic volumes at affected intersections to more than 24,000vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel,

parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).

The proposed project would not conflict with an applicable congestion management program for

designated roads or highways, the regional transportation plan or other agency plans. Additionally,

traffic volumes on roadways in the project vicinity are less than 5,000 vehicles per hour (significantly

less than the 44,000 vehicle per hour threshold). While the commenter is correct in noting that the

incorrect peak hour trips are indicated in the text (the correct peak hour trips would be 686 AM peak

hour trips), this is still significantly below the 30,000+ peak hour trips that the project would need to


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generate to result in a localized CO impact. It should be noted that all air quality modeling assumed a

686 AM peak hour rate and accounted for all net new regional trips associated with the project.


The proposed project would not conflict with an applicable congestion management program

for designated roads or highways, the regional transportation plan or other agency plans.

Additionally, traffic volumes on roadways in the project vicinity are less than 5,000 vehicles

per hour, and the project is expected to generate a maximum of 450 686 AM peak hour trips.

Emissions associated with the project are shown in Table 11. As noted in the IS/MND, the California

Emissions Estimator Model (CalEEMod) v.1.1 was used to generate the projected operational

emissions. Use of this air quality model is recommended by the BAAQMD, which is the agency

primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories)

and indirect sources (e.g., traffic associated with new development), as well as for monitoring

ambient pollutant concentrations. Additionally, the significance thresholds identified by theBAAQMD are also listed in the table, as well as the statement identifying that the project would notexceed any of the BAAQMD thresholds. Project assumptions used in the model are described in the

Project Description of the IS/MND (pages 5 to 32) as well as the modeling outputs from the traffic

analysis (pages 118 to 159 and Appendix E). Additional details on the specific calculations methods

of analysis incorporated into CalEEMod can be found in Appendix A of the CalEEMod Users Guide

found at www.caleemod.com. As noted in the IS/MND, there would be no significant operational air

quality impacts associated with the project so an operational air quality mitigation measure would notbe warranted.

Comment #5. The IS/MND agree that migratory birds are protected under the Migratory Bird Treaty

Act and CITES, and it is unlawful to pursue, hunt, take, capture or kill; attempt to take, capture or

kill; and possess them. The District has not in the past, and will not in the future undertake theseunlawful activities. However, The existing athletic fields are not considered critical habitat for the

Canada geese or hunting grounds for raptors such as Coopers Hawk, and construction of the project

and improvements such as turf fields will not cause a significant impact on Canada geese and raptors

in Emeryville.

Comment #6. Chemical compounds in artificial turf are regulated and are not be expected to affect

surface water quality. For the type of turf chosen, the District is required to provide proof of ISO

9001, ISO 14001 and OHSAS 18001 certifications. A study by the New York State Department of

Environmental Conservation did not identify significant chemical leaching from crumb-rubber

infilled synthetic turf fields.1

Laboratory testing of stormwater runoff from a synthetic turf fieldperformed in that study did not identify volatile organic compounds or semi-volatile organic

compounds above laboratory detection limits. Metals detected in the runoff were below establishedsurface water quality standards. Although leaching of certain compounds from artificial turf was

noted in one type of laboratory tests, the study concluded that under real world conditions no adverse

effects to aquatic life would result from use of this type of synthetic turf fields. The attached figure

showing the Stormwater Management Plan shows additional information regarding drainage on the

project site.

1 New York State Department of Environmental Conservation, 2009, An Assessment of Chemical

Leaching, Releases to Air and Temperature at Crumb-Rubber Infilled Synthetic Turf Fields, May.


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Comment #7.As described in the response to Comment #5, the existing sports fields are not critical

habitat for the Canada geese and other native and migratory birds that may occasionally use or rest on

the site. Replacement of the grass with turf would not interfere with the movement or migratorypatterns of native or migratory wildlife, and no significant impact would occur.

Comment #8. To provide further clarification that the District will perform all identified mitigation

measures, the following text revisions are made to pages 75-76 of the IS/MND:

Mitigation Measures CULT-1: Archaeological monitoring should shall be conducted for

construction-related ground disturbance below soil that is demonstrated to be fill in the project

site. The monitoring should shall be done in accordance with, and as guided by, an

Archaeological Monitoring and Evaluation Plan (AMEP) prepared and implemented for the

project. The purpose of the AMEP is to ensure that significant archaeological deposits

discovered during construction are identified, evaluated, and appropriately treated through the

use of a pre-established research design and field evaluation strategy, consistent with therequirements ofCEQA Guidelines 15126.4 (b)(3)(C). The AMEP should shall be approved bythe District well in advance of construction, and its implementation should shall be made a

condition of the issuance of a grading or building permit for the project. The AMEP should

shall be prepared by professionals who meet the Secretary of the Interiors Professional

Qualifications Standards in historical archaeology and prehistoric archaeology.

The AMEP should shall include a construction monitoring component and an evaluationcomponent. The monitoring component of the AMEP should shall refine the archaeological

sensitivity of the project site to: (1) identify areas that will be subject to monitoring; (2) define

the frequency of monitoring; and (3) identify those areas with little to no possibility of

containing intact deposits. This assessment should shall focus on the project sites land use

history based on historical maps and photographs, past site improvement/utilities constructionplans, historical documents, and soils/geotechnical information. The possibility for encountering

human remains during construction should shall also be addressed by consultation with the

appropriate descendant groups.

The evaluation component of the AMEP would guide fieldwork if archaeological resources orhuman remains are identified during monitoring. The purpose of this component is to establish

an evaluation process to shorten the time necessary to respond to and evaluate the significance

of discoveries made during archaeological monitoring. The evaluation component should shall

contain a field study and technical analysis work plan to guide the methods and procedures to

be used during the significance evaluation. The treatment of human remains during theevaluation process should shall be addressed, and procedures for the respectful treatment of

such remains should shall be developed through consultation with descendant communitiesprior to the final draft of the AMEP.


measures, the following text revisions are made to page 76 of the IS/MND:

Mitigation Measure CULT-2: Should paleontological resources be encountered during project

subsurface construction activities, all ground-disturbing activities within 25 feet should shall be

redirected and a qualified paleontologist contacted to assess the situation, consult with agencies


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as appropriate, and make recommendations for the treatment of the discovery. If found to be

significant, and project activities cannot avoid the paleontological resources, adverse effects to

paleontological resources should shall be mitigated. Mitigation may include monitoring,

recording the fossil locality, data recovery and analysis, a final report, and accessioning thefossil material and technical report to a paleontological repository. Public educational outreach

may also be appropriate. Upon completion of the assessment, a report documenting methods,

findings, and recommendations should shall be prepared and submitted to the District for

review, and (if paleontological materials are recovered) a paleontological repository, such as

the University of California Museum of Paleontology.

Comment #10. Please see Response to Comment #8.

Comment #11. No active or potentially active faults are known to be present in Emeryville. The

Guidelines for Evaluating Seismic Hazards in California cited in Mitigation Measure GEO-1a

requires the evaluation of risks from all known active and historic seismic source zones taking into

account all available historical seismicity data, including available paleoseismic data, the geologicrisk rate of regional active faults, and site-specific response characteristics. These guidelines addressall reasonably foreseeable seismic effects at the project site.

Comment #12. The following text revisions are made to page 80 of the IS/MND:

Therefore, the liquefaction hazard is potentially significant unless mitigation is incorporated.

Implementation of Mitigation Measures GEO-1a and GEO-1c would reduce the liquefactionhazard impact to a less-than-significant level.


measures, the following text revisions are made to page 81 of the IS/MND:

Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project

applicant to include analysis of the potential for unstable soils impacts as part of the design-

level geotechnical investigation to be prepared for the proposed project, would will reduce

the potential impacts related to unstable soils impacts to a less-than-significant level.

Comment #14.To provide further clarification that the District will perform all identified mitigation

measures, the following text revision is made to page 81 of the IS/MND:

Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project

applicant to include analysis of the potential for unstable soils impacts as part of the design-level geotechnical investigation to be prepared for the proposed project, would will reduce


Comment #15. As noted in the IS/MND, the California Emissions Estimator Model (CalEEMod)

v.2011.1.1 was used to estimate the greenhouse gas emissions associated with the project. Use of this

model is recommended by the BAAQMD, which is the agency primarily responsible for regulating

air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic

associated with new development), as well as for monitoring ambient pollutant concentrations.

Project assumptions used in the model are described in the Project Description of the IS/MND (pages


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5 to 32) as well as the modeling outputs from the traffic analysis (pages 118 to 159 and Appendix E).

Additional information about CalEEMod can be found at www.caleemod.com.

Comment #16. CEQA requires the evaluation of physical environmental impacts associated with aproposed project. As set forth by CEQA Guidelines, inconsistencies between the project and

applicable General Plan and other policies do not constitute impacts in and of themselves. A policy

inconsistency is considered to be a significant adverse environmental impact only when it is related to

a policy adopted for the purpose of avoiding or mitigating an environmental effect, and it is

anticipated that the inconsistency would result in a significant adverse physical impact based on an

established significance criterion. The commenters letter does not provide specific examples of how

an inconsistency results in a specific significant adverse physical impact based on the checklist

criteria.

Additionally, it should be noted that whether or not the District has met the policies and goals of the

Emeryville General Plan or other plans is a subjective assessment. The District created a site plan

with pedestrian and bicycle amenities, encourages various forms of modes of transportation, and doesnot preclude any improvements noted by the comment letter at some point in the future. It should alsobe noted that the comment letter provided by the City of Emeryville did not raise any concerns about

the project not being consistent with the Emeryville General Plan.



Implementation of the following mitigation measures would will reduce potentially

significant impacts associated with potential hazardous materials in soil, soil vapor,

groundwater, and building materials at the project site to a less-than-significant level:

Comment #18. The school classrooms, services and facilities developed under the project are subjectto a number of State requirements for emergency safety and evacuation plans which, have, and would

protect future students and workers from an accident at or near the school. School Districts have a

legal responsibility to be prepared to meet emergencies (California Government Code Section 3100).

A comprehensive Safe School Plan is required under Education Code Section 35294.2. A civil

defense and disaster preparedness plan must be prepared and tested at least twice a year (EducationCode 33031). Therefore, the Safe School Plan anticipates emergency situations, such as the previous

hydrogen gas tank accident at the AC Transit bus yard, and has in place safety and evacuation plans

to which the District will continue to adhere.

Comment #19. Any improvements to the gym would not change the use of the site as a potentialevacuation site. The construction period associated with improvements would be limited in duration,

and would not result in a significant impact related to implementation of or physical interference withan adopted emergency response plan or emergency evacuation plan. As part of the update to the

Citys safety plan, the City and District will work together to identify a secondary location during

construction and improvement of the gym.

Comment #20. The artificial turf would be considered an impervious surface under stormwater

regulations and the project is required to comply with the Water Boards Municipal Regional Permit

(MRP), cited in Mitigation Measure HYD-2. Stormwater runoff from the field will be captured and

treated in accordance with Provision C.3 of the MRP. No flooding impacts would result.


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Comment #21. The text of the IS/MND reads Implementation of a required SWPPP indicating

that the District will implement the identified mitigation measures. Additionally, as noted previously,

the District will implement all mitigation measures within the IS/MND.

Please see Response to Comment #6 for a discussion of artificial turf.

Comment #22.Please see Response to Comment #16.

Comment #23. The City of Emeryville General Plan Policy T-P-3 states

"A Quality of Service standard that seeks to optimize travel by all transportation modes

shall be developed and used to measure transportation performance. The City does not

recognize Level of Service (LOS) as a valid measure of overall transportation operations,

and sets no maximum or minimum acceptable LOS levels, with the exception of streets that

are part of the regional Congestion Management Agency network. (These streets may change,but as of 2008 included San Pablo Avenue, Frontage Road, and Powell and Adeline streets).LOS shall not be used to measure transportation performance in environmental review

documents or for any other purpose unless it is mandated by another agency over which the

City has no jurisdiction (such as Caltrans, Berkeley, Oakland, and the Congestion

Management Agency), and then it shall only be used for the purposes mandated by that

agency."

The City is currently in the process of developing transportation impact study guidelines that will

specify the required analysis necessary to further the City's General Plan Goals. As guidelines have

not yet been established and adopted, the scope of work for the evaluation of the potential impacts of

the ECCL was reviewed by City staff and is similar to other recent analyses prepared for land use

developments within the City. Levels of service were calculated for vehicles, as well as transit,bicycle and pedestrians. Additionally, as the Project would increase traffic along San Pablo Avenue,

which is part of the Congestion Management Agency network, as well as a State Route, guidelines

from both Caltrans and Alameda County Transportation Commission were considered in the

assessment. Changes to the evaluation criteria or analysis methods would not likely result in the

disclosure of impacts previously unidentified.

Comment #24.The City of Emeryville Pedestrian and Bicycle Plan indicates that traffic volumes can

be higher than the threshold for small segments provided additional treatments are provided, which

includes the turn-about proposed as part of the project that would also serve as a traffic calming

device. The bulk of additional traffic from the project along the segment of 53rd Street betweenBoyer Avenue and San Pablo Avenue would occur during a 30 minute period in the morning and a 30

minute period in the afternoon on school days, approximately 180 days of the year. On weekends andnon-school days, traffic volumes would be similar to current conditions as access to the community

center would primarily be provided from 47th Street.

Please see Response to Comment #16 for a discussion regarding policy consistency and physical

environmental impacts.

Comment #25. The proposed addition of a new outfall into the on-site culvert would be within the

project site. The inflow (onto the site) and outflow (away from the site) locations would not change


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from the existing conditions, and the addition of a new outfall into the culvert would not significantly

change existing conditions. Mitigation Measure HYD-1 and HYD-2 would mitigate stormwater

pollutants generated by the project during construction and operation, respectively.



Implementation of the proposed project could degrade the quality of the environment; however,

implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, CULT-1, and CULT-2 would

will ensure that potential impacts related to biological and cultural resources would be reduced

to less-than-significant levels. With mitigation, the proposed project would not: 1) substantially

degrade the quality of the environment; 2) substantially reduce the habitat of a fish or wildlife

species; 3) cause a fish or wildlife species population to drop below self-sustaining levels; 4)

threaten to eliminate a plant or animal community; 5) reduce the number or restrict the range of

a rare or endangered plant or animal; or 6) eliminate important examples of the major period of

California history.

Comment #27. The comment letter does not identify any information or cite specific cumulative

impacts that were not evaluated in the IS/MND. No further response can be provided.

Comment #29. The comment letter does not identify any information or cite specific environmental

effects that were not evaluated in the IS/MND. No further response can be provided.


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2 2 1 5 F I F T H S T R E E T

B E R K E L E Y , C A L I F O R N I A 9 4 7 1 0

5 1 0 . 5 4 0 . 7 3 3 1 T E L

5 1 0 . 5 4 0 . 7 3 4 4 F A X

C A R L S B A D

F O R T C O L L I N S

F R E S N O

I R V I N E

P A L M S P R I N G S

P T . R I C H M O N D

R I V E R S I D E

R O C K L I N

S A N L U I S O B I S P O

M E M O R A N D U M

DATE:DATE:DATE:DATE: July 12, 2013

TO:TO:TO:TO: Emery Unified School Board of Trustees

FROM:FROM:FROM:FROM: Judith Malamut and Amy Paulsen, LSA

SUBJECT:SUBJECT:SUBJECT:SUBJECT: Recommended Text Changes tp the Emeryville Center of Community Life Initial

Study Mitigated Negative Declaration

Following are recommended text changes to the Draft Initial Study/Mitigated Negative Declaration

(IS/MND) on the Emeryville Center of Community Life (ECCL) project, response to comments madeon the IS/MND, for consideration by the District Board prior to adoption. The text changes to the

IS/MND Document are identified with new text shown in underline and deleted text shown in

strikeout.


Musco back visors can will be installed on field lights to further reduce off-site light

trespass where specific neighboring site conditions warrant.


Mitigation Measures AES-1: The District shall implement the following measures: The District will identify three distinct lighting scenarios Scenario A: Competitive

Athletic Use (six poles in use); Scenario B: Recreation and Community Use (four poles

in use); and Scenario C: Clean-up Use (minimal lights on) to allow for field light

levels at the lowest acceptable setting for safety depending on the type of field use.

This includes flexibility of light level settings for practices where the full competitive

safety light levels may not be needed.

The light poles will have an additional 1/3 power reduction switch to further adjust and

reduce lighting to provide the lowest safe lighting levels needed for any event.

UnlessIf a District game or City-sponsored event is occurring, all lighted use of the

field shall conclude at 8:30 p.m., with lighting turned off at 9:00 10:00 p.m. This 9:00

p.m. ending time coincides with the required time for end use of the PA system. For all

other events, use of the field shall conclude at 8:30 p.m., with lighting turned off at9:00 p.m.

Except for District games, no lighting of the field will occur on Saturdays and Sundays

exceeding the Scenario B lighting scheme.

Musco back visors will be installed on field lights as part of the project.



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The proposed project would not conflict with an applicable congestion management program

for designated roads or highways, the regional transportation plan or other agency plans.

Additionally, traffic volumes on roadways in the project vicinity are less than 5,000 vehicles

per hour, and the project is expected to generate a maximum of 450 686 AM peak hour trips.

The following text revisions are made to pages 75-76 of the IS/MND:

Mitigation Measures CULT-1: Archaeological monitoring should shall be conducted for

construction-related ground disturbance below soil that is demonstrated to be fill in the project

site. The monitoring should shall be done in accordance with, and as guided by, an

Archaeological Monitoring and Evaluation Plan (AMEP) prepared and implemented for the

project. The purpose of the AMEP is to ensure that significant archaeological deposits

discovered during construction are identified, evaluated, and appropriately treated through the

use of a pre-established research design and field evaluation strategy, consistent with the

requirements ofCEQA Guidelines 15126.4 (b)(3)(C). The AMEP should shall be approved by

the District well in advance of construction, and its implementation should shall be made acondition of the issuance of a grading or building permit for the project. The AMEP shouldshall be prepared by professionals who meet the Secretary of the Interiors Professional

Qualifications Standards in historical archaeology and prehistoric archaeology.

The AMEP should shall include a construction monitoring component and an evaluation

component. The monitoring component of the AMEP should shall refine the archaeological

sensitivity of the project site to: (1) identify areas that will be subject to monitoring; (2) definethe frequency of monitoring; and (3) identify those areas with little to no possibility of

containing intact deposits. This assessment should shall focus on the project sites land use

history based on historical maps and photographs, past site improvement/utilities construction

plans, historical documents, and soils/geotechnical information. The possibility for encountering

human remains during construction should shall also be addressed by consultation with theappropriate descendant groups.

The evaluation component of the AMEP would guide fieldwork if archaeological resources or

human remains are identified during monitoring. The purpose of this component is to establish

an evaluation process to shorten the time necessary to respond to and evaluate the significanceof discoveries made during archaeological monitoring. The evaluation component should shall

contain a field study and technical analysis work plan to guide the methods and procedures to

be used during the significance evaluation. The treatment of human remains during the

evaluation process should shall be addressed, and procedures for the respectful treatment of

such remains should shall be developed through consultation with descendant communitiesprior to the final draft of the AMEP.


Mitigation Measure CULT-2: Should paleontological resources be encountered during project

subsurface construction activities, all ground-disturbing activities within 25 feet should shall be

redirected and a qualified paleontologist contacted to assess the situation, consult with agencies

as appropriate, and make recommendations for the treatment of the discovery. If found to be

significant, and project activities cannot avoid the paleontological resources, adverse effects to

paleontological resources should shall be mitigated. Mitigation may include monitoring,


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recording the fossil locality, data recovery and analysis, a final report, and accessioning the

fossil material and technical report to a paleontological repository. Public educational outreach

may also be appropriate. Upon completion of the assessment, a report documenting methods,

findings, and recommendations should shall be prepared and submitted to the District forreview, and (if paleontological materials are recovered) a paleontological repository, such as

the University of California Museum of Paleontology.


Therefore, the liquefaction hazard is potentially significant unless mitigation is incorporated.

Implementation of Mitigation Measures GEO-1a and GEO-1c would reduce the liquefaction

hazard impact to a less-than-significant level.


Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the projectapplicant to include analysis of the potential for unstable soils impacts as part of the design-level geotechnical investigation to be prepared for the proposed project, would will reduce


The following text revision is made to page 81 of the IS/MND:

Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the projectapplicant to include analysis of the potential for unstable soils impacts as part of the design-

level geotechnical investigation to be prepared for the proposed project, would will reduce



Implementation of the following mitigation measures would will reduce potentially

significant impacts associated with potential hazardous materials in soil, soil vapor,

groundwater, and building materials at the project site to a less-than-significant level:


Implementation of the proposed project could degrade the quality of the environment; however,

implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, CULT-1, and CULT-2 would

will ensure that potential impacts related to biological and cultural resources would be reducedto less-than-significant levels. With mitigation, the proposed project would not: 1) substantially

degrade the quality of the environment; 2) substantially reduce the habitat of a fish or wildlifespecies; 3) cause a fish or wildlife species population to drop below self-sustaining levels; 4)

threaten to eliminate a plant or animal community; 5) reduce the number or restrict the range of

a rare or endangered plant or animal; or 6) eliminate important examples of the major period of

California history.

IS/MND Responses and Revisions

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Transcript of IS/MND Responses and Revisions