Section 3.0 Environmental Setting, Impacts, and Mitigation
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SECTION 3.0 ENVIRONMENTAL SETTING, IMPACTS, AND MITIGATION INTRODUCTION This introduction explains why the analysis in a General Plan PEIR may be different than a similar discussion in an EIR prepared for a development project. It also discusses how the “existing conditions” were determined for this PEIR and how impacts and mitigations are described. Why Long-term Comprehensive Plan-level Impacts Are Not Described as Existing + Project This PEIR includes a description of existing conditions in the City of San José, currently an urban city of almost one million people encompassing 143 square miles and over 500 miles of roadway. In each of the impact discussions where it is possible to do so, the impact of the project (under future conditions) is compared to existing conditions. CEQA BASELINE The transportation section, for example, identifies the There has been substantial discussion conditions that are anticipated to exist in 2035, when the recently among planning and proposed General Plan (the “project”) is assumed to be transportation professionals about the implications of a 2010 court case fully implemented. Wherever possible, the future involving the baseline for CEQA conditions are analyzed using typical professional analyses of transportation criteria (such as screenlines or average speeds) at improvements. The case in question strategic locations, and the findings are compared to [Sunnyvale West Neighborhood Association v. Sunnyvale Council existing conditions in order to put the plan into a current th [(2010) Cal. App. 4 ,1351] involved perspective. The differences between those two a transportation improvement that conditions are not always due to the impacts of the would not be built right away; the proposed project; that is, the proposed General Plan is EIR was not about adoption of a not the only factor acting on traffic conditions between General Plan or other long term plan, but the analysis did include future now and the year 2035, and (as discussed below) it may traffic projections for the estimated not even be the primary factor when compared to the imple- mentation period. As a result, effects of factors such as regional growth and recent discussion involves the demographics changes. Nevertheless, where possible the question of whether an environmental “project” condition is compared to the existing impact must be determined by comparing the “project” conditions condition. (the conditions that will exist when the proposed project is completed, no The existing environmental setting includes the land uses matter how far in the future that and transportation network within the city and the might be) to existing conditions. The surrounding region. Roadway volumes, vehicular argument revolves, in part, around the difficulty the public would have emissions, and roadway noise levels are quantified understanding a discussion of future elements of the existing conditions and reflect the city’s conditions that is not compared to existence within a regional urban environment and ground level current conditions. economy. Existing traffic conditions, associated air quality, and noise levels especially reflect this interconnected regional relationship between jurisdictions. Some of the existing traffic, air pollution, and noise in the City of San José and adjacent jurisdictions are generated by workers who routinely travel to jobs, students who travel to schools, and shoppers who travel to stores located in cities and counties other than where they reside, Envision San José 2040 General Plan 131 Draft Program EIR City of San José June 2011 Section 3.0 Environmental Setting, Impacts, and Mitigation and some are generated by the transport of goods and materials from origin to destination across jurisdictional lines. The regional modeling methodology, which identifies trip origins and destinations based on planned land uses, makes this long-range analysis quite different from a standard near-term analysis for a single development project, where the ‘environment’ is much more locally focused on the project site (whatever the “project” might be), and the other trip end is neither known nor assumed. In a regional transportation model, every trip must have a starting point and ending point, however, the long-term land use and behavioral assumptions that support that information can be adjusted. The proposed General Plan was modeled for build out in horizon year 2035, including planned land uses and land use intensities, and physical and operational modifications to the transportation system within the City’s boundaries (as described in the Project Description) as well as within the region. The model does not assume that the rest of the region will remain in stasis (i.e., maintain “existing conditions”) as San José grows. The City’s transportation model is nested in regional and subregional models that were developed by MTC and VTA, and it reflects anticipated conditions outside the City’s General Plan boundaries that are based on ABAG forecasts and/or individual jurisdictions’ plans through horizon year 2035. The analysis in this PEIR compares specific aspects of the future project conditions to existing conditions, but the differences between the two conditions represent the combined impacts of the proposed General Plan and various other forces, many of which are not within the control of the City of San José. Specifically, the region is expected to experience significant growth and demographic changes independent of actions taken by the City of San José. The future conditions reflected in 2035 projections analyzed in this PEIR therefore represent regional projections based upon the professional judgment of staff of the relevant regional planning agencies (ABAG, MTC, VTA, etc.), as well as neighboring jurisdictions. The CEQA Guidelines advise only that the impacts of a project are to be compared to either (a) the conditions that exist at the time a Notice of Preparation (NOP) is circulated or, (b) if no NOP is circulated, at the time environmental analysis begins. This is a reasonable requirement for specific development projects, where EIRs are completed in a one- to two-year timeframe and a snapshot of existing conditions can generally capture conditions that existed on a particular day or at least during a month. For a General Plan update for a major city, the situation is quite different. The City of San José discovered, in compiling the substantial quantity of information necessary to prepare this PEIR, that it was impossible to compile a complete and accurate picture of existing conditions on a single day, month, or year. In this case, the City’s transportation model was updated well in advance of the General Plan update process making use of the best available data to provide adequate time to complete the analysis; the model was updated and validated as a first step in the environmental assessment, using traffic counts, land use data, and the roadway network from April and May, 2008. The process of developing the transportation model began before the proposed Envision San José 2040 General Plan had been drafted – in 2008, it was still in initial formulation stages. Once the major elements of the proposed General Plan were identified, the rest of the CEQA process began and an NOP was prepared and circulated in July, 2009. The CEQA Guidelines specifically refer to only two conditions – circulation of an NOP or the commencement of the environmental analysis – which implies that if an NOP is circulated then that date must benchmark the “existing condition.” For San José’s General Plan, it was not possible to circulate an NOP at the time work began on Envision San José 2040 General Plan 132 Draft Program EIR City of San José June 2011 Section 3.0 Environmental Setting, Impacts, and Mitigation updating the transportation model because the project description had not yet been formulated. If the City had delayed validation of the model until after the Draft General Plan was further developed, it would have delayed the analytic process by at least another year, undermining the City’s ability to complete the General Plan update process without providing any real benefit to the quality of analysis in this PEIR. There are many other complications in setting a baseline for a General Plan EIR for a major city at an arbitrary point in time. The air quality of the region is tracked by the Bay Area Air Quality Management District (BAAQMD), which publishes the results of the District’s monitoring programs. The most recent data available at the time the air quality analysis was prepared for this PEIR (using the information produced by the Transportation Impact Analysis from the transportation model) was for the year 2009. It is accepted practice in the Bay Area to use the most current information available in preparing air quality impact analyses, so air quality data from 2009 is the information used to identify “existing conditions” in this PEIR. The conditions identified in Table 3.4-4 of this PEIR indicate that air quality improved slightly from 2008 to 2009, with conditions in 2009 being very similar in many respects to those that prevailed in 2007. Identifying “existing conditions” for the biology discussion was more difficult. San José includes 280 square miles in its sphere of influence, which range from the Santa Cruz Mountains and the Diablo Range to the shores of San Francisco Bay. The habitat mapping reflected in this PEIR was based primarily on mapping from the Draft Santa Clara Valley Habitat Plan, obtained in 2008 but generally completed prior to that time (2006, 2007, and/or 2008, primarily). This mapping work was used because it was the most comprehensive dataset on existing habitats that has ever been available to the City of San José and was the most complete compilation of this type of information available in 2010 when the biological resources report was completed. Information on those few areas that were outside those covered by the Draft Habitat Plan was based on the biological consultant’s own year 2008 mapping field work and aerial photo interpretation.