2580 Bancroft Way Mixed-Use Project

2580 BANCROFT WAY MIXED-USE PROJECT

Response to Comments Document

State Clearinghouse No. 2017102015

JOHNSON LYMAN T h e S t a n d a r d ARCHITECTS 1375 Locust Street, #202, Walnut Creek, CA 94596 P1 925.930.9690 930.9039 fax Prepared for: 2 5 8 0 B a n c r o f t W a y 5.1.18 URBAN City of Berkeley PLANNING PARTNERS August 2018 INC.

2580 BANCROFT WAY MIXED-USE PROJECT Response to Comments Document

State Clearinghouse No. 2017102015

Prepared for: City of Berkeley Planning & Development Department 1947 Center Street Berkeley, CA 94704

URBAN By:

URBAN Urban Planning Partners, Inc. PLANNING PARTNERS 388 17th Street, Suite 230 INC. Oakland, CA 94612

With: BASELINE Environmental Consulting Fehr & Peers WSA, Inc. Architectural Resource Group

August 2018

TABLE OF CONTENTS

I. INTRODUCTION ...... 1 A. PURPOSE OF THE RESPONSES TO COMMENTS DOCUMENT ...... 1 B. ENVIRONMENTAL REVIEW PROCESS ...... 1 C. DOCUMENT ORGANIZATION...... 2

LIST OF COMMENTING AGENCIES, ORGANIZATIONS, AND INDIVIDUALS ...... 3 A. ORGANIZATION OF COMMENT LETTERS AND RESPONSES ...... 3

III. COMMENTS AND RESPONSES ...... 5 A. STATE, LOCAL, AND REGIONAL AGENCIES ...... 7 B. INDIVIDUALS AND ORGANIZATIONS ...... 17 C. PUBLIC HEARING COMMENTS ...... 31

IV. TEXT REVISIONS ...... 43

ATTACHMENTS Attachment A: Exhibit A-1 Mitigation and Monitoring and Reporting Program Attachment B: Supplemental Memorandum- Project Impacts Analysis of the Standard Project, 2580 Bancroft Way

i BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 TABLE OF CONTENTS RESPONSE TO COMMENTS

I. INTRODUCTION

A. PURPOSE OF THE RESPONSES TO COMMENTS DOCUMENT

This Response to Comments (RTC) document has been prepared to document responses to comments received on the Draft Environmental Impact Report (Draft EIR) prepared for the proposed 2580 Bancroft Way Mixed-Use Project (project) (State Clearinghouse #2017102015). The Draft EIR identifies the likely environmental consequences associated with the implementation of the project and recommends mitigation measures to reduce potentially significant impacts. This RTC document includes: a short description of the environmental review process, the comments received on the Draft EIR and responses to those comments, and text revisions to the Draft EIR in response to the comments received and/or to amplify or clarify material in the Draft EIR.

This RTC document, together with the Draft EIR, constitutes the Final EIR for the proposed 2580 Bancroft Way Mixed-Use Project.

B. ENVIRONMENTAL REVIEW PROCESS

According to CEQA, lead agencies are required to consult with public agencies having jurisdiction over a proposed project and to provide the general public with an opportunity to comment on the Draft EIR. The City of Berkeley (City) circulated a Notice of Preparation (NOP) that briefly described the project and the environmental topics that would be evaluated in the Draft EIR. The NOP was initially published on October 3, 2017. The 30-day public comment period for the scope of the EIR lasted from October 3, 2017 to November 3, 2017. The NOP was sent to the State Clearinghouse, responsible and trustee agencies, organizations, and interested individuals. A public scoping session for the project was held on October 26, 2017 in conjunction with a Zoning Adjustments Board (ZAB) meeting, as well as on November 2, 2017 in conjunction with a Landmarks Preservation Commission (LPC) meeting. Comments received by the City on the NOP either in writing or verbally at the public scoping sessions were considered during the preparation of the Draft EIR. Written NOP comments were received from East Bay Municipal Utility District, the Native American Heritage Commission, and one individual. The NOP and comment letters are included in Appendix B of the Draft EIR.

The Draft EIR was published on April 17, 2018 and distributed to applicable local and State agencies. Copies of the Notice of Availability of the Draft EIR (NOA) were mailed to all individuals previously requesting to be notified of the Draft EIR, in addition to those agencies and individuals who received a copy of the NOP.

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The 45-day public comment period for the Draft EIR began on April 17, 2018 and ended on June 1, 2018. Two public hearings were held regarding the Draft EIR during the 45-day public comment period: the LPC on May 3, 2018 and the ZAB on May 24, 2018. One member of the public and five LPC commissioners provided verbal comments during the May 3rd hearing. Two members of the ZAB provided verbal comments during the May 24th hearing. Written comments were received from two agencies and two individuals. Written responses to all the comments received regarding the adequacy of the Draft EIR are provided in Chapter III, Comments and Responses, of this document.

C. DOCUMENT ORGANIZATION

This RTC document consists of the following chapters:

Chapter I: Introduction. This chapter discusses the purpose and organization of this RTC document and the Final EIR, and summarizes the environmental review process for the project.

Chapter II: List of Commenting Agencies, Organizations, and Individuals. This chapter contains a list of agencies, organizations, and persons who submitted written comments or spoke at the public hearing on the Draft EIR during the public review period.

Chapter III: Comments and Responses. This chapter contains reproductions of all comment letters received on the Draft EIR as well as a summary of the verbal comments provided at the public hearing. A written response for each comment related to the adequacy of the Draft EIR received during the public review period is provided. Each response is keyed to the preceding comment.

Chapter IV: Text Revisions. Corrections to the Draft EIR necessary in light of the comments received and responses provided, or necessary to amplify or clarify material in the Draft EIR, are contained in this chapter. Text with double underline represents language that has been added to the Draft EIR; text with strikeout has been deleted from the Draft EIR. Revisions to figures are also provided, where appropriate.

LIST OF COMMENTING AGENCIES, ORGANIZATIONS, AND INDIVIDUALS

This chapter presents a list of letters and comments received during the public review period of the Draft EIR and describes the organization of the letters and comments that are included in Chapter III, Comments and Responses, of this document.

A. ORGANIZATION OF COMMENT LETTERS AND RESPONSES

During the 45-day comment period, which ended on June 1, 2018, the City received written comments from two agencies and two individuals and verbal comments from four LPC commissioners, two ZAB members, and one individual. This RTC document includes a reproduction of each written comment letter (or email) in its entirety received on the Draft EIR and a summary of comments made at the public hearing before the LPC and ZAB. Written responses to each comment are provided.

The comment letters are numbered consecutively following the A, B, and C designations. The letters are annotated in the margin according to the following code:

State, Local and Regional Agencies: A# Individuals and Organizations: B# Landmarks Preservation Commission and Zoning Adjustments Board: C#

The following agencies and individuals provided written or verbal comments. State, Local, and Regional Agencies A1 East Bay Municipal Utility District May 29, 2018 A2 Alameda County Transportation Commission June 1, 2018

Individuals and Organizations B1 Lozeau Drury LLC May 25, 2018 B2 Wendel Rosen Black and Dean LLC June 1, 2018

Landmarks Preservation Commission C1-1 Chairperson Steven Finacom May 3, 2018 C1-2 Commissioner Phil Allen May 3, 2018 C1-3 Commissioner Christopher Adams May 3, 2018 C1-4 Commissioner Becky O’Malley May 3, 2018 C1-5 John English May 3, 2018

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Zoning Adjustments Board C1-6 Board Member John Selawsky May 24, 2018 C1-7 Board Member Patrick Sheahan May 24, 2018

4 III. COMMENTS AND RESPONSES

Written responses to all comments on the Draft EIR are provided in this section. Letters received on the Draft EIR are provided in their entirety. Each letter is immediately followed by a response keyed to the specific comment.

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A. STATE, LOCAL, AND REGIONAL AGENCIES

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Letter A1

9 Bancroft Project – 2580 Bancroft EIR August 2018 III. Comments and Responses Response to Comments Letter A1 cont.

10 August 2018 Bancroft Project – 2580 Bancroft EIR Response to Comments III. Comments and Responses Letter A1 cont.

11 Bancroft Project – 2580 Bancroft EIR August 2018 III. Comments and Responses Response to Comments Letter A1 cont.

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LETTER A1 East Bay Municipal Utility District May 29, 2018

A1-1 The comment acknowledges receipt of the Draft EIR and does not address the adequacy of the Draft EIR; no further response is necessary.

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LETTER A2 Alameda County Transportation Commission June 1, 2018

A2-1 This introductory comment does not address the adequacy of the Draft EIR; no further response is necessary.

A2-2 The comment confirms the project is exempt from review under the Land Use Analysis Program. In addition, the comment acknowledges the receipt of the Draft EIR, and does not address the adequacy of the Draft EIR; no further response is necessary.

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B. INDIVIDUALS AND ORGANIZATIONS

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Letter B1

Via Email and Overnight Mail

May 25, 2018

Leslie Mendez, Senior Planner Timothy Burroughs, Acting Director Planning and Development Dept. Planning and Development Dept. Land Use Planning Division City of Berkeley 1947 Center St, 2nd Floor 1947 Center St, 3rd Floor Berkeley, CA 94704 Berkeley, CA 94704 [email protected] [email protected] [email protected] [email protected]

Re: 2580 Bancroft Way, aka SCH2017102015

Dear Ms. Mendez, and Mr. Burroughs:

I am writing on behalf of the Laborers International Union of North America, Local Union 304 and its members living in Alameda County and/or the City of Berkeley (“LiUNA”), regarding 2580 Bancroft Way, aka SCH2017102015, Use Permit #ZP2017-0083, and LMSAP #2017-0007, including all actions related or referring to demolition of the Bancroft Center and development of 122 dwelling units and 1 approximately 11,000 sq. ft. of ground-level retail on properties located at 2558-2588 Bancroft Way in the City of Berkeley(“Project”). We have reviewed the Draft Environmental Impact Report (“DEIR”) prepared for the Project and determine that it fails to comply with the California Environmental Quality Act (“CEQA”). We reserve the right to supplement these comments at later hearings on the Project.

Sincerely,

Richard Drury

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LETTER B1 Lozeau Drury LLC May 25, 2018

B1-1 The Draft EIR was prepared in compliance with the California Environmental Quality Act Guidelines Section 15183.3, Streamlining for Infill Projects. The comment does not state why the Draft EIR fails to comply with CEQA; as a result it is not possible to provide a response.

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Letter B2

21 Bancroft Project – 2580 Bancroft EIR August 2018 III. Comments and Responses Response to Comments Letter B2 cont.

3 cont.

22 August 2018 Bancroft Project – 2580 Bancroft EIR Response to Comments III. Comments and Responses Letter B2 cont.

7 cont.

23 Bancroft Project – 2580 Bancroft EIR August 2018 III. Comments and Responses Response to Comments Letter B2 cont.

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LETTER B2 Wendel Rosen Black and Dean LLC June 1, 2018

B2-1 These introductory comments do not address the adequacy of the Draft EIR; no further response is necessary.

B2-2 Mitigation Measure CULT-1c is revised as shown below.

Page IV-28, second paragraph of the Draft EIR, is revised as follows:

Mitigation Measure CULT-1c: A permanent, high-quality on-site plaque or interpretive display shall be installed within a publicly-accessible location at or near the Bancroft Way-facing facade of the retained portion of the Fred Turner Building (2546-2554 Bancroft Way). The primary goal of the exhibit wouldshall be to inform the public about the history of the building, including its landmark status and surrounding neighborhood; acknowledge the alterations madein the process of neighborhood development; and provide information regarding the City of Berkeley and Berkeley Landmarks Preservation Committee's efforts to record and preserve the city's architectural heritage. If deemed appropriate by staff and the Landmarks Preservation Commission Chair, the plaque may be designed consistent with the Berkeley Historical Plaque Project (berkeleyplaques.org). The placement, size, and appearance of the plaque shall be designed so as not to interfere with the ability of the building’s character- defining features to convey their significance consistent with the Secretary of the Interior Standards. A dDraft of the plaque or display shall be submitted with the building permit for review by staff in coordination with the Landmarks Preservation Commission Chair. The final plaque or display shall be in place prior to the issuance of a temporary certificate of occupancy.

B2-3 The Draft EIR has been revised to clarify that the project does not fully comply with General Plan Policy LU-2.A clarification has also been made between the significant impact due to removal (that the proposal does not meet the City’s definition of demolition) of a portion of the Fred Turner Building under the Secretary of Interior Standard for Impact CULT-1 and the conclusion of this impact statement for CULT-2.

Page IV-28, fifth paragraph of the Draft EIR, is revised as follows:

Impact CULT-2: The project would not fully comply be inconsistent with General Plan Policy LU-2: Preservation and Southside Plan Policy LU-F14. (S)

There are is two one policiesy that the proposed project may conflict with:

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. General Plan Policy LU-2 Preservation. Protect Berkeley’s character by identifying, restoring, and preserving historic buildings.

. Southside Plan Policy LU-F14: Employ Southside Design Guidelines to ensure that new buildings are compatible with existing buildings in the Telegraph Commercial (C-T) Subarea and do not detract from significance of existing landmark and historically significant buildings.

The General Plan contains many policies which may in some cases address different goals, policies, and objectives and thus some policies may conflict with each other through the decision-making process on particular development and land use decisions. It is not the intent of the General Plan to predetermine these decisions, but rather to help guide the decision-making process. In deciding whether to approve a proposed project, the City must decide whether, on balance, the project is consistent (i.e., in general harmony) with the General Plan. The fact that a specific project does not meet all General Plan goals, policies, and objectives does not inherently result in a General Plan insistency or significant effect on the environment. Given the project does not fully comply with General Plan LU-2 as it would only preserve approximately half of the Fred Turner Building this impact is conservatively identified as significant and unavoidable.

Since the proposed project would demolish the southern (rear) portion of the Fred Turner Building, and since the proposed rehabilitation to the northern (front) portion would not mitigate the project’s adverse effects on the Fred Turner Building, and would not adhere to the Secretary of Interior’s Standards, the proposed project would have a significant impact due to the inconsistency with General Plan Policy LU-2 Preservation, and Southside Plan Policy LU-F13. 9529170

B2-4 Revisions to the Draft EIR to address the distinction between the demolition of a portion of the Fred Turner Building and the adjacent new construction have been made both in Chapter IV.A, Cultural Resources, and Chapter V, Alternatives of the Draft EIR to better address the comment related to the Preservation Alternative.

Page IV-25, last paragraph is revised as follows:

Reason for non-compliance: The proposed new construction at the rear of above Fred Turner Building is incompatible with the historic resource in its massing, scale, size, and materials. Standard 9 references how proposed new construction must take into account how it will “protect the integrity of the property and its environment,” which implies consideration of indirect impacts as a result of adjacent or nearby construction. The Fred Turner Building’s significance is not derived from being located in an isolated setting. It is located along a busy street

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in a commercial setting and institutional setting adjacent to the campus of a major university. The size and scale of a proposed eight-story building adjacent to the east of the Fred Turner building would diminish its integrity of setting and feeling. However, these aspects of integrity are not as important to conveying the essential physical features that underpin its significance as an Arts and Crafts-styled boutique building. These features and the Fred Turner Building’s associations with the architect would remain if a proposed eight-story building were built adjacent to the east of the building. If assessed solely for impacts due to the adjacent eight-story building, the project would comply with the Secretary’s Standards. Despite the preceding discussion, however, the project as a whole would remain non-compliant with the Secretary’s Standards due to the proposed partial demolition of the Fred Turner Building and construction of a portion of the project behind the remaining portion of the Fred Turner Building.

Page V-7, first paragraph of the Draft EIR, is revised as follows:

Reason for compliance: The Preservation Alternative would not include demolition of the rear portion of the Fred Turner Building or would not building anything on top at the rear of the Fred Turner Building. The Preservation Alternative would construct a ten-story building adjacent to the east of the Fred Turner Building, a Berkeley City Landmark. As described in the discussion of Standard 9 relative to the proposed project, the Fred Turner Building was intentionally located in a commercial and institutional setting. The size and scale of a proposed ten-story building adjacent to the east of the Fred Turner Building would diminish its integrity of setting and the feeling of the property and its environment. However, these aspects of integrity are not as critical to conveying the building’s physical features of design, materials, and workmanship. These features and the location of the Fred Turner Building and its association with Ms. Morgan would remain if a proposed ten-story building were built next door. A ten-story building adjacent to the single-story Fred Turner Building would create a more imposing presence and striking contract in proportion and would further incrementally diminish its integrity of setting and feeling, generating potential indirect impacts.

Rehabilitation Standard 9 provides two instances where impacts to historic materials, features, size, scale, proportion and massing of a historic property from proposed adjacent construction are considered. The two instances include:

Introducing a new building or landscape feature that is out of character or otherwise inappropriate to the setting’s historic character, e.g., replacing picket fencing with chain link fencing.

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1) The ten-story Preservation Alternative would be four stories taller than the other buildings located within the same city block. However, located within one city block of the project site is the seven-story Durant Hotel at 2600 Durant Avenue; four nine-story buildings and two seven-story buildings at 2650 Durant Avenue (U.C. Berkeley Residence Hall Unit 1) and; four nine- story buildings at 2400 Durant Avenue (U.C. Berkeley Residence halls Unit 3). While, the proposed ten-story building would be the tallest building within the city block, it would not be uncharacteristic of other buildings within a one-block radius.1

Introducing new construction into historic districts that is visually incompatible or that destroys historic relationships within the setting.

2) The Fred Turner Building is not located within or adjacent to a historic district.2

Based on these explanations, the Preservation Alternative would be compliant with Rehabilitation Standard 9.

______1 Grimmer, Anne, and Kay D. Weeks, 2010, New Exterior Additions to Historic Buildings: Preservation Concerns. National Park Service Preservation Brief #14. https://www.nps.gov/tps/how-to-preserve/preservedocs/preservation-briefs/14Preserve-Brief- Additions.pdf, accessed various, accessed on July 30,2018. 2 Ibid.

B2-5 See response to comment B2-4 above for the Preservation Alternative’s compliance discussion with relationship to Rehabilitation Standard 9 of the Secretary’s Standards.

See response to comment B2-3 regarding Southside Plan Policy LU-F15. Southside Plan Policy LU-F14 was cited in error in the DEIR; rather, the discussion is around Southside Plan Policy LU-F15. After further review, the project would comply with Southside Plan Policy LU-F15.

Page V-7 fourth paragraph of the Draft EIR, is revised as follows:

Because tThe Preservation Alternative does not propose to modify the Fred Turner Building, it. The integrity of setting and feeling under Standard 9 would be diminished by the new development. However, as described above, the ten- story building would not be uncharacteristic in height of other buildings within a one-block radius. In addition, it is not located within or adjacent to a historic district. The Preservation Alternative would adhere to the Secretary of the Interior’s Standards and would have a less-than-significant impact related to

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cultural resources, unlike the proposed project, which would have a significant and unavoidable impact (see Impact CULT-1 and Impact CULT-2).

The specific objectives of Berkeley’s General Plan Policy LU-2 Preservation are to identify, restore, and preserve Berkeley’s historic building stock. The Fred Turner Building is a designated Berkeley Landmark, and under the Preservation Alternative, the Fred Turner Building would remain intact. The building’s use as commercial space would remain as currently configured. The Preservation Alternative would not rehabilitate or restore the Fred Turner Building and all existing features would remain in place. Although the Preservation Alternative would result in some impacts to integrity of setting and feeling to the Fred Turner Building, it is still compliant with Secretary Standard 9 and it more closely follows the intent of the General Plan Policy LU-2 to preserve Berkeley’s historic buildings. The Preservation Alternative, unlike the project, would avoid the significant and unavoidable impact related to Impact CULT-2.

B2-6 See response to comment B2-5.

B2-7 As the comment suggests, the conditions of approval are treated in the same way as City policies and regulations and will therefore be removed from the MMRP (Mitigation and Monitoring Reporting Program). As standard conditions of approval, they will be applicable to the project upon approval.

B2-8 The Infill Environmental Checklist text is revised to clarify that the project will remove all of the existing trees on the sidewalk fronting the project site in order to build the project and install underground utilities. The comment incorrectly states that there is a mitigation measure for Biological Resources, rather it is a Condition of Approval. The Condition of Approval is standard language that the City uses for many of its projects and will not be changed depending on the specifics of individual projects.

Draft EIR Appendix A, Infill Environmental Checklist, page 34, third paragraph, is revised as follows:

Street trees in front of the project site are Chinese Elms (ulmus parvifolia). The project would preserve or replace the existing street trees along Bancroft Way in order to build the project and install underground utilities. The project would also provide landscaping in the project’s courtyard, patio, and terraces.*

B2-9 While the project is intended as student housing, it is not a certainty that the entire population living in the project would be a population that already exists in the neighborhood and is living in other housing units, and it might induce new population growth; however, this potential new population growth would not exceed growth levels planned for the City in the Southside Area Plan, and

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impacts would be less than significant, which is consistent with the findings of the Southside Plan EIR.

B2-10 Pedestrian LOS is not an adopted CEQA analysis in the City of Berkeley. The pedestrian LOS information is provided for informational purposes only.

Draft EIR Appendix A, Infill Environmental Checklist, page 102, fifth paragraph of the Draft EIR, is revised as follows:

The City of Berkeley does not use pedestrian LOS to evaluate impacts on pedestrians for CEQA documents. However, this analysis uses the pedestrian LOS methodology to assess pedestrian conditions for informational purposes only. Pedestrian counts were conducted to evaluate pedestrian LOS on the sidewalk on the south side of Bancroft Way along the project site frontage. As detailed in Attachment I, the analysis was conducted using the 2010 Highway Capacity Manual (2010 HCM) LOS methodology, which measures pedestrian comfort on sidewalks based on available sidewalk space and pedestrian flow rate. Pedestrian traffic currently operates at LOS D, meaning that pedestrians have limited ability to pass slower pedestrians. With the addition of project pedestrian trips, the sidewalk would continue to operate at LOS D.

B2-11 As noted in response B2-10, pedestrian LOS is not an adopted threshold of significance in the City of Berkeley. Since the project would not cause a significant impact on pedestrians, there is no need to consider additional pedestrian improvements.

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C. PUBLIC HEARING COMMENTS

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Letter

C1 Landmarks Preservation Commission Comment Summary May 3, 2018

Commissioner Comments Commissioner Steven Finacom  In a table in IV-9, the list of historic resources and landmarks is missing many sites within the ¼ mile. Believes the actual list should be twice the size of the current one, although it does not affect conclusions.  Wants consistency of historical resources throughout various reports, since many reports utilize tables and information from preexisting reports. References to check out 1) City of Berkeley’s Landmark list, 2) Susan Cerny’s book Berkeley Landmarks, and 3) Anthony Bruce (Berkeley Architectural Heritage Association). 1A  Examples of items not included on the historical resources list: University of YWCA around the corner, Hearst Gym across the street, College Women’s Club a block to the east, old Berkeley Art Museum, and “a bunch more properties on the UC campus”.  A couple of designated landmarks on Bancroft/Durant are also missing from the list. The table appropriate identifies the Ellen Blood house that has been moved, but there are still two adjacent landmarks that are standing there not listed.  It is often the case that when older buildings are demolished that were built prior to the 1960s especially at a site that has had previous development, interesting subsurface remains occur that are from the historic period. Not sure if there was a mitigation 1B measure related to that, but it would be useful to have something to address that. For example, when the rear of Fred Turner Building or Bancroft Center is demolished you find an old well.  Wants the document to detail instructions on what constructors are to do if original building features (previously obscured) come to light in the event of the demolition. Ex. 1C Construction workers find a mural that may have been “sheetrocked” over during the tear down process.  Both the Design Review Committee and Landmarks Preservation Commission in their reviews of the project have focused on the design of the section behind the Fred Turner Building be somewhat different then the design of the other building next to it. So, from Bancroft as you are looking at the building, it appears to read as two similar but 1D separate buildings that are up against each other to break up the mass. It might be useful to have a cultural mitigation that would state that without being prescriptive; while the actual design is being worked out.

Commissioner Phil Allen  10-story alternative mitigation surprised him because the initial graphic only showed 8 stories. 2A  Is this 10 stories going just going to be in the part behind the Fred Turner Building or throughout the whole development?  Would appreciate adding a 10-story graphic of the alternative. 2B

Bancroft Project – 2580 Bancroft EIR August 2018 III. Comments and Responses Response to Comments Letter C1 cont.

Commissioner Christopher Adams If the scale on photo/graphics in the EIR are correct, many buildings were missed during the cataloging of historical resources. Such as St. Marks’ Episcopal Church (2300 Bancroft Way), Berkeley City Club (2315 Durant Avenue), Berkeley Architectural Heritage Association - BAHA 3A Building (2318 Durant Avenue).

Commissioner Becky O’Malley  Someone commented that they were surprised that there wasn’t a permanent set list of historical landmarks already established for the surrounding area and the entire city. 4A Perhaps as a layer in the city’s GIS database?

Public Comment John English  Personally, in support of the project, specifically the portions that do not include demolishing the Fred Turner building.  Glad to see EIR acknowledges that the project will have a significant environmental 5A impact, and that old drawings/photos of the courtyard and back of the building were used in the document.  More could have been done in detailing ways to design the south façade of the courtyard to be more evocative of the original historic look of the courtyard and backside of the building. Maybe this can be handled during the project review phase. 5B  The EIR did a reasonably adequate job, just wished more historic detailing/character 5C could have been preserved on the southern side of the courtyard.

Com August 2018 Bancroft Project – 2580 Bancroft EIR Response to Comments III. Comments and Responses Letter C1 cont.

Zoning Adjustment Board Comment Summary May 24, 2018

Board Member John Selawksy • Had a question about provisions of the Infill EIR Alternatives analysis. Wanted to know if 6A it includes Landmark Structures. • There should be a mandate for zip car, or other car share, 2-3 spaces as this is the wave 6B of the future, and many people are not buying their own cars.

Board Member Patrick Sheahan

• The density as proposed is not required to be reduced under an alternative, is that correct? Or the density as what is the base development standard F.A.R and height. 7A • Board member wants to include the base F.A.R and maximum height and argues that not having this information makes it difficult to evaluate the validity of the proposal or 7B the alternative. • Had a comment that there is not much information on what the building is, or what portion is being removed and what uses are being eliminated and this makes it very 7C difficult to evaluate the validity of the proposal of the alternative. • Wants the Bancroft Center to be included in the EIR because it is a structure worthy of 7D acknowledgment.

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LETTER C1 Public Hearing Comments May 3, 2018

Public Hearing Comments

Public Hearings were held on the Draft EIR at the City of Berkeley Landmarks Preservation Commission meeting held on May 3, 2018 and at the Zoning Adjustments Board meeting held on May 24, 2018. Comments were heard from Commissioners, Board members, and from members of the public at the Landmarks Preservation Commission meeting. In general, the issues that were verbally expressed at the public hearings were repeated in the written comments received, and thus the response presented in this document address verbal comments made by the Commissioners, Board Members, and the public.

Chairperson Steven Finacom (C1)

C1-1A Table IV-1 in Chapter IV-1 has been updated to include new resources within a ¼- mile. The additional resources added to the list do not change the conclusions of the Draft EIR.

Page IV-8, last paragraph is revised as follows:

The NWIC records search identified no previously recorded cultural resources within the project site and a total of 14 historic-period resources were identified within the ¼ mile records search buffer surrounding the project site. These are listed in Table IV-1. An additional 64 resources within a ¼-mile radius are also listed in Table IV-1 and were identified by WSA/Paleowest and LSA using An Illustrated Guide to the Berkeley California’s Architectural Heritage, the Berkeley Landmarks Website Directory of Properties in the Historic Property Data File, California State Office of Historic Preservation directory, which includes National Register of Historic Properties, California Register of Historic Resource listings, California Historical Landmarks, and California Points of Historical Interest, and the Southside Project Area’s Appendix H, Cultural Resource Table, which was independent of the NWIC records search.

C1-1B Mitigation Measure CULT-3 of the Infill Checklist, on page 38 of Appendix A, provides for the treatment of any prehistoric or historic-period archaeological materials encountered during construction.

C1-1C Such instructions should ideally be included not in the EIR itself, but in the historic preservation treatment plan to be prepared as part of implementation of Mitigation Measure CULT-1b of the Impact Analysis. However, text revisions to Mitigation Measure CULT-1b have been made to include previously unrecorded

36 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS III. COMMENTS AND RESPONSES

architectural features that may be uncovered during the demolition and rehabilitation activities.

Page IV-27, third paragraph of the Draft EIR, is revised as follows:

CULT-1b: A site-specific historic preservation treatment plan for the retained portion of the Fred Turner Building (2546-2554 Bancroft Way) shall be prepared and implemented by or under the direct supervision of a Preservation Architect who meets or exceeds the Secretary of the Interior's Professional Qualifications Standards for Historic Architecture and Architectural History. This treatment plan shall define conditions assessment and documentation, protection, and monitoring requirements and procedures to be implemented during demolition of the rear portion of the historic building, demolition on the adjacent property, and restoration of the retained northern portion of the building. The treatment plan shall describe procedures to be undertaken for the documentation, evaluation, and treatment of previously unrecorded architectural features that are uncovered during demolition and rehabilitation activities. Such features may include artwork, decorative plaster or metalwork, or other building elements currently obscured by post-1940 renovations or additions to the Fred Turner Building (2546-2554 Bancroft Way). Such All procedures should be defined to avoid inadvertent damage to portions of the Fred Turner Building (2546-2554 Bancroft Way) to be retained for incorporation into the proposed development during project construction and shall include consideration of site security and fencing; avoidance and physical protection of historic surfaces and materials; and storage of temporarily removed or salvaged historic materials and building components. The treatment plan shall be submitted to the City of Berkeley Planning and Development Department prior to construction for review and approval.

Monitoring shall be designed to adequately ensure adherence to the procedures defined in the treatment plan. A monitoring report shall be prepared following completion of such activities documenting methods, observations, and inadvertent damage to historic materials and subsequent repairs. This report shall be provided to the applicant and appropriate agencies, including the City of Berkeley Planning and Development Department prior to a temporary certificate of occupancy.

C1-1D The suggested cultural mitigation measure is not necessary to address a potentially significant impact. The City may consider this as part of the project’s merits.

Commissioner Phil Allen (C2)

37 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 III. COMMENTS AND RESPONSES RESPONSE TO COMMENTS

C1-2A The part behind the Fred Turner Building will not be developed as the Preservation Alternative serves to preserve the back side of the Fred Turner Building.

The additional two stories of the Preservation Alternative (from eight stories to ten stories) are proposed for the building located on the east side of the Fred Turner Building. The Preservation Alternative would not reduce the density compared to that of the project. Rather, all of the residential units would be shifted to the east side of the site. According to Section 15183.3 of the CEQA Guidelines, the analysis of alternatives in an infill EIR need not address alternative locations, densities, or building intensities.

C1-2b The alternative graphic is included in the RTC document for reference (see Figure III-1).

38 (top edge varies)

Legend Placement

N 0 125 250 500 Feet

Johnson Lyman Architects, 2018 Figure III-1 The Standard - 2580 Bancroft Way Mixed-UseView lo Projectokin g south from Bancroft Way 2580 Bancroft Way Preservation Alternative

JOHNSON LYMAN T h e S t a n d a r d ARCHITECTS 1375 Locust Street, #202, Walnut Creek, CA 94596 E1 925.930.9690 930.9039 fax 2 5 8 0 B a n c r o f t W a y 6.18.18 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 III. COMMENTS AND RESPONSES RESPONSE TO COMMENTS

Commissioner Christopher Adams (C3)

C1-3A See response to comment C1-1A.

Commissioner Becky O’Malley (C4)

C1-4A The list of Berkeley landmarks is in tabular format on the Berkeley Architectural Association website available at https://www.berkeleyheritage.com/.

John English (C5)

C1-5A The support for the project is noted. The comment does not address the adequacy of the Draft EIR; no further response is necessary.

C1-5B The courtyard itself is identified in the Project Impacts Analysis, Appendix D on page 18, and Draft EIR, pages IV-20 and IV-21, as a Very Significant character- defining feature to be retained in the rehabilitated portion of the Fred Turner Building. In addition, Very Significant, Significant, and Contributing character- defining features to be retained include the steel sash multi-pane windows, the courtyard window hoods, molded archway header, and clay tile at the parapet above the courtyard. No extant Very Significant, Significant, or Contributing features will be removed from the courtyard during demolition, construction, and rehabilitation. Non-contributing features to be removed from the courtyard include the accessibility lift, staircase, platform, guardrail, roof, lighting fixtures, and doors and windows at the eastern and western courtyard walls.

The southern portion of the courtyard, including the stairs, lift, railings, platform, and entrance to the modern restaurant at the rear of the building, retains very little of the original character of the courtyard as it was built at the time of the building’s construction. The original building plan, a 1940 landscaping plan prepared by Leland and Adele Vaughan, and photographs from the mid-20th-century show the original character of the courtyard adjacent to the Black Sheep Restaurant. In the first decades of the building’s use, an angled staircase with decorative metal railings and bannister at the southwest corner of the paved courtyard accessed the restaurant’s entry. The large, central dining room had windows at the location of the current restaurant’s centered entrance, overlooking boxwood hedges framing a circular patio and ivy plantings, as well as a mature tree in the southeast corner of the courtyard. Awnings shaded the steel sash windows on the western and northern sides of the courtyard.

Little remains today of the original historic appearance of the south side of the Fred Turner Building’s courtyard, leaving few options for rehabilitation. Reconstruction of the southern portion of the courtyard as it was originally designed in 1940, in a manner consistent with the Secretary of the Interior’s

40 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS III. COMMENTS AND RESPONSES

Standards, would be undesirable as a mitigation to the proposed demolition and incompatible with the requirements of the current project. Instead, the current plan for the southern side of the courtyard (pictured on page P6 of the Standard Plans and Renderings prepared by Johnson Lyman Architects within the Project Impact Analysis, Appendix F, Project Plans and Perspective Views), provide an entrance into the new residential complex while incorporating elements reflecting and complementary to the extant historic features of the portion of the building to be retained. These include arched windows and framing mirroring the arches of the arcade and courtyard entrance to be retained from the historic building, as well as steel sash multi-pane windows, plastered wall finishes, and planters. In addition, removal of the existing roof, not original to the courtyard, will reopen the space as it was when originally built.

Potential recommendations, independent of the CEQA review, for further enhancing the proposed courtyard design’s compatibility with the retained historic courtyard space and evoking the building’s historic character would be to utilize light fixtures more complementary to the historic character of the retained portion of the building, and to install additional free-standing planter boxes with foliage and small shrubs within the courtyard after construction. The latter, while not requiring structural or design changes to the building itself, would provide a visible linkage in use and character to the courtyard enjoyed by patrons of the Black Sheep Restaurant during its tenure in the Fred Turner Building.

C1-5C See response to comment C1-5B.

Board Member John Selawsky (C6)

C1-6A As discussed on page V-1 of the Draft EIR, Section 15183.3 (e) of the CEQA Guidelines limits the range of alternatives that Infill EIRs must analyze. The analysis of the alternatives in an Infill EIR need not address alterative locations, densities, or building intensities. The fact that there is a landmark or historic resource does not change the narrower scope of the Infill EIR Alternatives.

C1-6B The provision of car share spaces is not necessary to address any of the project’s significant impacts; the City may consider this independently of the CEQA analysis.

Board Member Patrick Sheahan (C7)

C1-7A As stated above in Response C6-A, Infill EIRs do not need to consider alternative locations, densities or building intensities. The density of the proposed project is not required to be reduced under any alternative per the provisions of 15183.3 (e) of the CEQA Guidelines.

41 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 III. COMMENTS AND RESPONSES RESPONSE TO COMMENTS

C1-7B The range of Floor Area Ratios (FAR) for the General Plan are described on page III-6 of the Project Description of the Draft EIR. Building Intensities generally range from a Floor Area Ratio (FAR) of 3.0 to 3.5 in the Telegraph Avenue Commercial District (C-T). In addition, further discussion of FAR and height are provided on page III-7 of the Project Description. A description of how the project complies with the Berkeley Municipal Code with respect to FAR and height is discussed on page 75 of the Infill Environmental Checklist, Appendix A.

New main buildings in the C-T district must reach a minimum height of 35 feet and a maximum height of 65 feet, except for properties south of Dwight Way. Properties within the District shall not exceed a FAR of 5.0; however, the Zoning Adjustments Board may approve a Use Permit to increase a project’s maximum height to 75 feet and FAR to 6.0 if a at least 50 percent of the total building floor area is for residential use. The project proposes to exceed this conditionally permitted C-T height limit by one story through State Density Bonus provisions, which do not require discretionary approval. The provision of the base FAR does not relate to the adequacy of the EIR. The City may provide additional information independent of the CEQA analysis.

C1-7C Chapter IV, Impact Analysis of the Draft EIR, analyzes in detail the Fred Turner Building and discusses what portion is being removed, as well as a discussion of the Secretary’s Standards for Rehabilitation starting on page IV-25. In addition, Appendix D, Project Impact Analysis, also discusses the Fred Turner Building and Secretary’s Standards for Rehabilitation in Chapter 4 starting on page 12.

C1-7D The Bancroft Center is mentioned in the Draft EIR on pages IV-16- IV-21. As mentioned on page IV-19, “LSA evaluated the Bancroft Center according to the criteria for the CRHR and concluded that it does not appear eligible under any of the criteria. In addition, LSA evaluated the building according to the criteria for the Berkeley Landmarks Preservation Ordinance and recommends that it does not possess sufficient architectural merit, cultural value, educational value, or historic value for Landmark Status. LSA similarly recommends that the Bancroft Center (2558-2580 Bancroft Way) does not meet the Berkeley Landmarks Preservation Commission standard for Structures of Merit or contribute to an historic district. As such, it is not considered an historical resource for the purposes of CEQA.”

IV. TEXT REVISIONS

This RTC document presents specific revisions to the text of the Draft EIR that were initiated by City staff for the purpose of clarifying material in the Draft EIR. Where revisions to the main text are called for, the page and paragraph are noted, followed by the appropriate revision. Added text is indicated with double underlined text. Deletions to text in the Draft EIR are shown with strikeouts. Page numbers correspond to the page numbers of the Draft EIR. Revisions presented in this RTC Memo do not significantly alter the conclusions or findings of the Draft EIR.

Page II-5, Table II-1 is revised as follows:

CULT-1b: A site-specific historic preservation treatment plan for the retained portion of the Fred Turner Building (2546-2554 Bancroft Way) shall be prepared and implemented by or under the direct supervision of a Preservation Architect who meets or exceeds the Secretary of the Interior's Professional Qualifications Standards for Historic Architecture and Architectural History. This treatment plan shall define conditions assessment and documentation, protection, and monitoring requirements and procedures to be implemented during demolition of the rear portion of the historic building; demolition on the adjacent property, and restoration of the retained northern portion of the building. The treatment plan shall describe procedures to be undertaken for the documentation, evaluation, and treatment of previously unrecorded architectural features that are uncovered during demolition and rehabilitation activities. Such features may include artwork, decorative plaster or metalwork, or other building elements currently obscured by post-1940 renovations or additions to the Fred Turner Building (2546-2554 Bancroft Way). Such All procedures should be defined to avoid inadvertent damage to portions of the Fred Turner Building (2546-2554 Bancroft Way) to be retained for incorporation into the proposed development during project construction and shall include consideration of site security and fencing; avoidance and physical protection of historic surfaces and materials; and storage of temporarily removed or salvaged historic materials and building components. The treatment plan shall be submitted to the City of Berkeley Planning and Development Department prior to construction for review and approval.

43 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

CULT-1c: A permanent, high-quality on-site plaque or interpretive display shall be installed within a publicly-accessible location at or near the Bancroft Way-facing facade of the retained portion of the Fred Turner Building (2546-2554 Bancroft Way). The primary goal of the exhibit wouldshall be to inform the public about the history of the building, including its landmark status and surrounding neighborhood; acknowledge the alterations madein the process of neighborhood development; and provide information regarding the City of Berkeley and Berkeley Landmarks Preservation Committee's efforts to record and preserve the city's architectural heritage. If deemed appropriate by staff and the Landmarks Preservation Commission Chair, the plaque may be designed consistent with the Berkeley Historical Plaque Project (berkeleyplaques.org). The placement, size, and appearance of the plaque shall be designed so as not to interfere with the ability of the building’s character- defining features to convey their significance consistent with the Secretary of the Interior Standards. A dDraft of the plaque or display shall be submitted with the building permit for review by staff in coordination with the Landmarks Preservation Commission Chair. The final plaque or display shall be in place prior to the issuance of a temporary certificate of occupancy.

CULT-2: The project would not fully comply be inconsistent with General Plan Policy LU-2: Preservation. and Southside Plan Policy LU-F14.

Page IV-6, last paragraph is revised as follows:

Policy LU-F145: Employ Southside Design Guidelines to ensure that new buildings are compatible with existing buildings in the Telegraph Commercial (C-T) Subarea and do not detract from the significance of existing landmark and historically significant buildings.

Page IV-8, last paragraph is revised as follows:

The NWIC records search identified no previously recorded cultural resources within the project site and identified a total of 14 historic-period resources within the ¼ mile records search buffer surrounding the project site. These are listed in Table IV-1. An additional 64 resources within a ¼-mile radius are also listed in Table IV-1 and were identified by WSA/Paleowest and LSA using An Illustrated Guide to the Berkeley California’s Architectural Heritage, the Berkeley Landmarks Website Directory of Properties in the Historic Property Data File, California State Office of Historic Preservation directory, which includes National Register of Historic Properties, California Register of Historic Resource listings, California Historical Landmarks, and California Points of Historical Interest, and the Southside Project Area’s Appendix H, Cultural Resource Table, which was independent of the NWIC records search.

44 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

Page IV-9, Table IV-1 is revised as follows:

TABLE IV-1 HISTORICAL RESOURCES WITHIN ¼-MILE OF THE PROJECT SITE

Primary Berkeley Number/ Landmark Trinomial* Number Resource Name Recording Events Status** P-01-000230/ N/A Kroeber Hall Knapping 1993 (M. Steven Shackley, University of CA-ALA-000552H Area California, Berkeley) N/A P-01-005231 N/A45 Anna Head School for 1979 (Lesley Emmington, Berkeley Girls Architectural Heritage Association) ; 1979 (James P. Gibbon, Elaine Stone, [none]) #80000795, National Register of Historic Places (1980) P-01-005268 N/A Squire, (James A.) House 1979 (Anthony Buffington Bruce, Berkeley Architectural Heritage Association) CA Resource Status Code 2S2 P-01-005313 N/A 220 Blood (Mrs. Ellen) House 1979 (Anthony Buffington Bruce, Berkeley Architectural Heritage Association) CA Resource Status Code 3S P-01-005618 N/A The Granada 1978 (Anthony Buffington Bruce, Berkeley Apartments Architectural Heritage Assn.) CA Resource Status Code 2S2, 3S P-01-005619 N/A Hotel Carlton 2004 (Diana Painter, Painter Preservation & Planning) CA Resource Status Codes 2S2, 6Y, 3S P-01-005330 N/A 160 South Hall, Berkeley 2002 (Richard Schwartz, [none]) # P-01-010578 82004651, National Register of Historic Places (1982) P-01-010659 N/A 301 The Cambridge 2003 (Diana Painter, Painter Preservation P-01-005304 Apartments and Planning) CA Resource Status Code 6Y P-01-010669 N/A Wurster Hall 1977 (Gray Allan Brechin, Berkeley Architectural Heritage Association) ; 2003 (T.J. Kelley, [none]) ; 2016 (Alexandra Bevk, [none]) CA Resource Status Code 3S P-01-010988 N/A Barrows Hall, UC 2009 CA Resource Status Code 6Z Berkeley P-01-011258/ N/A 2245 College Ave 2011 (Paul Farnsworth & Aimee Arrigoni, CA-ALA-000639H William Self Associates Inc.) N/A P-01-011376 N/A Griffiths Hall Unit 2 2012 (Dana Supernowicz, Historic Resource Associates) CA Resource Status Code 6Y P-01-011577 N/A Trinity Methodist 2004 (Toni Webb, JRP Historical Episcopal Church Consulting); 2006 (Tim Stroshane, City of Berkeley Housing Department) CA Resource Status Codes 2S2, 6Y P-01-011602 N/A Zellerbach Hall 2015 (Alexander Bevk, [none]) CA Resource Status Code 3S 01-005155 N/A (Cerny St. Mark’s Episcopal CA Resource Status Code 3S 2001, pg. Church (2300 Bancroft 174) Way)

45 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

Primary Berkeley Number/ Landmark Trinomial* Number Resource Name Recording Events Status** 01-005156 N/A Gray Gables Canterbury CA Resource Status Code 2S2 Foundation (2346 Bancroft Way) 01-005158 48 First Unitarian Church/ NRHP #81000143 University Dance Studio (2401 Bancroft Way) 01-005160 314 University Art Museum NRHP #13001034 (2626/30 Bancroft Way) 01-005162 33 Bancroft Hotel/College NRHP #82002157 Women's Club (2680 Bancroft Way) 01-005163 229 Westminster CA Resource Status Code 3S House/Unitas House (2700 Bancroft Way) 01-005210 148 Doe Memorial Library CA Historic Landmark No. 946 (Campus Drive, UC NRHP #82004639 Campus) 01-005193 N/A Christian Science CA Resource Status Code 3S Building (2315 Bowditch Street) 01-005194 54 Site of Carrington House CA Resource Status Code 3s (2323 Bowditch Street) Berkeley LPC Structure of Merit N/A N/A Vedanta Society Temple State Historic Resources Inventory (Cerny (2455 Bowditch Street) 2001, pg. 194) 01-005230 N/A J. and C. Luttrell House CA Resource Status Code 3S (2328 Channing Way) 01-005232 79 Samuel G. Davis House CA Resource Status Code 3S (2547 Channing Way) 01-005233 216 Rose and William Berteaux Cottage/Fox CA Resource Status Code 3S Cottage (2612 Channing Way, relocated to 2530 Bowditch Street) 01-005257 320 Channing Apartments CA Resource Status Code 3S (2409 College Avenue) 01-005255 N/A Yummers/Espresso CA Resource Status Code 3S Experience (2300 College Avenue) 01-005256 N/A Alma A. Smith House CA Resource Status Code 3S (2310 College Avenue) 01-005258 N/A O.J. Bettis House (2530 CA Resource Status Code 3S College Avenue) 01-005234 N/A Channing House CA Resource Status Code 3S (2721 Channing Way) 01-005303 2 Berkeley Women’s City NRHP #77000282, Club CA Historic Landmark No. 908 (2315 Durant Avenue)

46 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

Primary Berkeley Number/ Landmark Trinomial* Number Resource Name Recording Events Status** 01-005312 109 McCreary/Greer House N/A (BAHA) (2318 Durant Avenue) 01-005235 N/A Dr. J, Knox House CA Resource Status Code 3S (2725 Channing Way) 01-005268 N/A James A. Squire House CA Resource Status Code 2S2 (2400 Dana Street) N/A N/A Berkeley Villa State Historic Resources Inventory Improvement Association/Speculative House (2421 Durant Avenue) 01-005305 219 Hotel for William K. CA Resource Status Code 3S Cashin/The Brasfield/ Beau Sky Hotel (2520 Durant Avenue) 01-005308 180 Hotel Durant (2600 Berkeley LPC Structure of Merit Durant Avenue) CA Resource Status Code 3S N/A N/A Christian Science State Historic Resources Inventory Student Organization )2601 Durant Avenue) 01-005309 201 Dr. Cornelius Beach CA Resource Status Code 3S Bradley House/Theta Xi House (2639 Durant Avenue) 01-005316 84 People's Park CA Resource Status Code 3S

01-005306 224 Alexander C. Stuart CA Resource Status Code 3S House (2524 Dwight Way) N/A 204 George Edwards House N/A (2530 Dwight Way) 01-005307 207 & 215 Baptist School of Divinity CA Resource Status Code 3S & Hobart Hall (2606 Dwight Way) 01-005323 5 First Church of Christ NRHP #86003361 Scientist (2619 Dwight National Landmark Way) 01-005329 158 Sather Tower CA Historic Landmark No. 946 /Campanile (Esplanade NRHP #82004650 Drive, UC Campus) 01-005341 156 Faculty Club and Glade CA Historic Landmark No. 946 (UC Campus) NRHP #82004641 01-005372 192 Haste Street building of Berkeley LPC Structure of Merit McKinley School CA Resource Status Code 3S (2419 Haste Street) 01-005373 N/A George D. Hutchinson CA Resource Status Code 3S Apartments (2436 Haste Street)

47 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

Primary Berkeley Number/ Landmark Trinomial* Number Resource Name Recording Events Status** 01-005374 N/A Sequoia Apartments CA Resource Status Code 3S (2441 Haste Street) (burned 2011, demolished 2012) 01-005367 127 John Woolley House CA Resource Status Code 3S (2509 Haste Street) 01-005372 115 Haste Street Annex, Berkeley LPC Structure of Merit McKinley School (built CA Resource Status Code 3S 2417 Haste Street, realigned to 2407 Dana Street, 2004) 01-005376 226 Casa Bonita Apartments CA Resource Status Code 3S (2605 Haste Street) 01-005642 154 Phoebe Apperson Hearst CA Historic Landmark No. 946 Memorial Gymnasium NRHP #82004645 for Women (Bancroft Way, UC Campus) 01-005646 151 Room 307, Gilman Hall NRHP #66000203 (Campus Drive, UC Campus) 01-005660 146 Durant Hall/Boalt Hall CA Historic Landmark No. 946 (Sather Road, UC NRHP #82004640 Campus) 01-005661 163 Wheeler Hall (Campanile CA Historic Landmark No. 946 Way, UC Campus) NRHP #82004654 01-005669 147 California Hall (Sather CA Historic Landmark No. 946, NRHP Road, UC Campus) #82004638 01-006824 141 Girton Hall / Senior CA Resource Status Code 1S Women’s Hall (UC Campus) 01-005670 N/A Women’s Faculty Club CA Resource Status Code 3S (Cerny 2001, pg. 153) 01-006732 142 Cowell Memorial NRHP #92001730; Hospital Site demolished in 1993 01-005252 87 Warren Cheney House CA Resource Status Code 3S (#1) 01-005253 87 Warren Cheney House CA Resource Status Code 3S (#2) 01·005718 157 Sather Gate and Bridge CA Historic Landmark No. 946 (UC Campus) NRHP #82004649 01-005620 N/A Public Food CA Resource Status Code 3S Store/Berkeley Market (2369 Telegraph Avenue) N/A N/A Sequoia Apartments/ CA Resource Status Code 3S Garden Spot Market (burned 2011, demolished 2012) (2432 Telegraph Avenue 01-005622 N/A Berkeley Food CA Resource Status Code 3S Center/Amoeba Music (2455 Telegraph

48 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

Primary Berkeley Number/ Landmark Trinomial* Number Resource Name Recording Events Status** Avenue)

01-005623 N/A Mrs. E. P. King House CA Resource Status Code 3S (2501 Telegraph Avenue) N/A 306 University YWCA (2600 Bancroft Way) N/A 17 Senior Hall (Senior Men’s NRHP #74000506 Hall; Golden Bear Lodge) N/A 193 Harmon Gymnasium Altered beyond recognition when reconstructed as Haas Pavilion in 1998. N/A 195 University of California, N/A Campus Landscape Features N/A 47 James Edgar House Berkeley LPC Structure of Merit (2437 Dwight Way) N/A 122 People's Bicentennial N/A Mural (2500 Haste Street) N/A 221 The Albra (2530-2534 Berkeley LPC Structure of Merit Durant Avenue) N/A 222 The Robcliff Apartment Berkeley LPC Structure of Merit House (2515 Channing Way) N/A 223 Epworth Hall (2521 Channing Way) * Primary Number Historic Resources that begin with a P-01, were part of a records search conducted by NWIC staff. **CA Resource Status Code 3S refers to a property that “Appears eligible for NR as an individual property through survey evaluation." Sources: NWIC File No. 17-0874 Directory of Properties in the Historic Property Data File. 2012. California State Office of Historic Preservation. On file at Northwest Information Center, Sonoma State University, Rohnert Park, California. The directory includes NRHP, CRHR listings, California Historical Landmarks, and California Points of Historical Interest. California State office of Historic Preservation. Cerny, Susan Dinkelspiel. 2001. Berkeley Landmarks: An Illustrated Guide to the Berkeley’s California’s Architectural Heritage. Berkeley Architectural Heritage Association, Berkeley. California. Berkeley Architectural Heritage Association 2018, Berkeley Landmarks. Electronic Resource at http://berkeleyheritage.com/berkeley_landmarks/all_landmarks.html. Southside Project Area, Appendix H, Cultural Resource Table

Starting on page IV-9, last paragraph is revised as follows:

Historic-period resources within ¼-mile of the project site include:

. UC Campus buildings: . South Hall (NRHP listed), . Wurster Hall (NRHP eligible),

49 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

. Barrows Hall, and . Zellerbach Hall

. Residential or institutional buildings near the campus’s southern extent, including: . Anna Head School for Girls (NRHP listed), . Griffiths Hall Unit 2, . James A. Squire house (NRHP eligible), . Ellen Blood House (NRHP eligible), . Granada Apartments (NRHP eligible), . Hotel Carlton (NRHP eligible), . Cambridge Apartments, and . Trinity Methodist Episcopal Church

In addition, There are…..

Page IV-25, last paragraph of the Draft EIR, is revised as follows:

Reason for non-compliance: The proposed new construction at the rear of above the Fred Turner Building is incompatible with the historic resource in its massing, scale, size, and materials. Standard 9 references how proposed new construction must take into account how it will “protect the integrity of the property and its environment,” which implies consideration of indirect impacts as a result of adjacent or nearby construction. The Fred Turner Building’s significance is not derived from being located in an isolated setting. It is located along a busy street in a commercial setting and institutional setting adjacent to the campus of a major university. The size and scale of a proposed eight-story building adjacent to and east of the Fred Turner building would diminish its integrity of setting and feeling. However, these aspects of integrity are not as important to conveying the essential physical features that underpin its significance as an Arts and Crafts-styled boutique building. These features and the Fred Turner Building’s associations with the architect would remain if a proposed eight-story building was built adjacent to the east of the building. If assessed solely for impacts due to the adjacent eight-story building, the project would comply with the Secretary’s Standards. Despite the preceding discussion, however, the project as a whole would remain non-compliant with the Secretary’s Standards due to the proposed partial demolition of the Fred Turner Building and construction of a portion of the project behind the remaining portion of the Fred Turner Building.

Page IV-27, third paragraph of the Draft EIR, is revised as follows:

Mitigation Measure CULT-1b: A site-specific historic preservation treatment plan for the retained portion of the Fred Turner Building (2546-2554 Bancroft Way) shall be prepared and implemented by or under the direct supervision of a Preservation Architect who meets or exceeds the Secretary of the Interior's Professional Qualifications Standards for Historic Architecture and Architectural History. This treatment plan shall define conditions

50 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

assessment and documentation, protection, and monitoring requirements and procedures to be implemented during demolition of the rear portion of the historic building; demolition on the adjacent property, and restoration of the retained northern portion of the building. The treatment plan shall describe procedures to be undertaken for the documentation, evaluation, and treatment of previously unrecorded architectural features that are uncovered during demolition and rehabilitation activities. Such features may include artwork, decorative plaster or metalwork, or other building elements currently obscured by post-1940 renovations or additions to the Fred Turner Building (2546-2554 Bancroft Way). Such All procedures should be defined to avoid inadvertent damage to portions of the Fred Turner Building (2546-2554 Bancroft Way) to be retained for incorporation into the proposed development during project construction and shall include consideration of site security and fencing; avoidance and physical protection of historic surfaces and materials; and storage of temporarily removed or salvaged historic materials and building components. The treatment plan shall be submitted to the City of Berkeley Planning and Development Department prior to construction for review and approval.

Page IV-28, second paragraph of the Draft EIR, is revised as follows:

Mitigation Measure CULT-1c: A permanent, high-quality on-site plaque or interpretive display shall be installed within a publicly-accessible location at or near the Bancroft Way- facing facade of the retained portion of the Fred Turner Building (2546-2554 Bancroft Way). The primary goal of the exhibit wouldshall be to inform the public about the history of the building, including its landmark status and surrounding neighborhood; acknowledge the alterations madein the process of neighborhood development; and provide information regarding the City of Berkeley and Berkeley Landmarks Preservation Committee's efforts to record and preserve the city's architectural heritage. If deemed appropriate by staff and the Landmarks Preservation Commission Chair, the plaque may be designed consistent with the Berkeley Historical Plaque Project (berkeleyplaques.org). The placement, size, and appearance of the plaque shall be designed so as not to interfere with the ability of the building’s character-defining features to convey their significance consistent with the Secretary of the Interior Standards. A dDraft of the plaque or display shall be submitted with the building permit for review by staff in coordination with the Landmarks Preservation Commission Chair. The final plaque or display shall be in place prior to the issuance of a temporary certificate of occupancy.

51 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

Page IV-28, fifth paragraph of the Draft EIR, is revised as follows:

Impact CULT-2: The project would not fully comply be inconsistent with General Plan Policy LU-2: Preservation and Southside Plan Policy LU-F14. (S)

There are is two one policiesy that the proposed project may conflict with:

. General Plan Policy LU-2 Preservation. Protect Berkeley’s character by identifying, restoring, and preserving historic buildings.

Page V-7, first paragraph of the Draft EIR, is revised as follows:

52 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

design, materials, and workmanship. These features and the location of the Fred Turner Building and its association with Ms. Morgan would remain if a proposed ten-story building were built next door. A ten-story building adjacent to the single-story Fred Turner Building would create a more imposing presence and striking contract in proportion and would further incrementally diminish its integrity of setting and feeling, generating potential indirect impacts.

Introducing a new building or landscape feature that is out of character or otherwise inappropriate to the setting’s historic character, e.g., replacing picket fencing with chain link fencing.

1) The ten-story Preservation Alternative would be four stories taller than the other buildings located within the same city block. However, located within one city block of the project site is the seven-story Durant Hotel at 2600 Durant Avenue; four nine-story buildings and two seven-story buildings at 2650 Durant Avenue (U.C. Berkeley Residence Hall Unit 1) and; four nine-story buildings at 2400 Durant Avenue (U.C. Berkeley Residence halls Unit 3). While the proposed ten-story building would be the tallest building within the city block, it would not be uncharacteristic of other buildings within a one-block radius.

Introducing new construction into historic districts that is visually incompatible or that destroys historic relationships within the setting.

2) The Fred Turner Building is not located within or adjacent to a historic district. Based on these explanations, the Preservation Alternative would be compliant with Rehabilitation Standard 9.

______1 Grimmer, Anne, and Kay D. Weeks, 2010, New Exterior Additions to Historic Buildings: Preservation Concerns. National Park Service Preservation Brief #14. https://www.nps.gov/tps/how-to-preserve/preservedocs/preservation- briefs/14Preserve-Brief-Additions.pdf, accessed various, accessed on July 30,2018. 2 Ibid.

Page V-7 fourth paragraph of the Draft EIR, is revised as follows:

Because tThe Preservation Alternative does not propose to modify the Fred Turner Building, it. The integrity of setting and feeling under Standard 9 would be diminished by the new development. However, as described above, the ten-story building would not be uncharacteristic in height of other buildings within a one-block radius. In addition, it is not located within or adjacent to a historic district. The Preservation Alternative would adhere to the Secretary of the Interior’s Standards and would have a less-than-significant impact

53 BANCROFT PROJECT – 2580 BANCROFT EIR AUGUST 2018 IV. TEXT REVISIONS RESPONSE TO COMMENTS

related to cultural resources, unlike the proposed project, which would have a significant and unavoidable impact (see Impact CULT-1 and Impact CULT-2).

The specific objectives of Berkeley’s General Plan Policy LU-2 Preservation are to identify, restore. and preserve Berkeley’s historic building stock. The Fred Turner Building is a designated Berkeley Landmark, and under the Preservation Alternative, the Fred Turner Building would remain intact. The building’s use as commercial space would remain as currently configured. The Preservation Alternative would not rehabilitate or restore the Fred Turner Building and all existing features would remain in place. Although the Preservation Alternative would result in some impacts to integrity of setting and feeling to the Fred Turner Building, it is still compliant with Secretary Standard 9 and it more closely follows the intent of the General Plan Policy LU-2 to preserve Berkeley’s historic buildings. The Preservation Alternative, unlike the project, would avoid the significant and unavoidable impact related to Impact CULT-2.

APPENDICES

Draft EIR Appendix A, Infill Environmental Checklist, page 34, third paragraph, is revised as follows:

Draft EIR Appendix A, Infill Environmental Checklist, page 102, fifth paragraph of the Draft EIR, is revised as follows:

Add a revised Mitigation Monitoring and Reporting Program prepared in April 2018.

ATTACHMENT A: Exhibit-A-1, Mitigation Monitoring and Reporting Program

54 AUGUST 2018 BANCROFT PROJECT – 2580 BANCROFT EIR RESPONSE TO COMMENTS IV. TEXT REVISIONS

Add a Supplemental Project Impact Report Memorandum.

ATTACHMENT B: Supplemental Memorandum- Project Impacts Analysis of the Standard Project, 2580 Bancroft Way

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56 ATTACHMENT A

Exhibit-A-1, Mitigation Monitoring and Reporting Program

EXHIBIT A-1

MITIGATION MONITORING AND REPORTING PROGRAM

This Mitigation Monitoring and Reporting Program (MMRP) was formulated based on the findings of the Environmental Impact Report (EIR) prepared for the 2580 Bancroft Way Mixed-Use project in the City of Berkeley. This MMRP is in compliance with §15097 of the CEQA Guidelines, which requires that the Lead Agency “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.” The MMRP lists mitigation measures recommended in the EIR and identifies mitigation monitoring requirements.

Table 1 presents the conditions of approval and/or mitigation measures identified in the 2580 Bancroft EIR necessary to mitigate potentially significant impacts. Each condition or mitigation measure is numbered according to the topical section to which it pertains in the EIR. The City’s Standard Conditions of Approval (SCAs) are identified in the EIR as measures that would minimize potential adverse effects that could result from implementation of the project and are also included in this MMRP to ensure the conditions are implemented and monitored. The Standard Conditions are identified with a SCA prefix (e.g., SCA NOISE-1).

The first column of Table 1 identifies the Standard Condition of Approval or Mitigation Measure. The second column identifies the monitoring schedule or timing, while the third column names the party responsible for monitoring the required action. The fourth column, “Monitoring Procedure,” outlines the steps for monitoring the action identified in the mitigation measure. The fifth and sixth columns deal with reporting and provide spaces for comments and dates and initials. These last columns will be used by the City to ensure that individual mitigation measures have been monitored.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials

A. AESTHETICS Aesthetics impacts are not considered significant impacts on the environment, per §21099(d) of the CEQA statute.

B. AGRICULTURE AND FORESTRY RESOURCES No significant agriculture and forestry resources impacts would occur.

C. AIR QUALITY No significant greenhouse gas emissions impacts were identified and no mitigation measures were identified in the EIR. MM AIR-1: Consistent with guidance from the BAAQMD, the Ongoing City of Berkeley Make regular following actions shall be required of construction throughout Planning & visits to the contracts and specifications for the project. demolition, Development project site to

Demolition. The following controls shall be implemented grading, Department ensure that all during demolition: and/or fugitive dust construction ▪ Water during demolition of structures and break-up of controls are being

pavement to control dust generation; implemented.

▪ Cover all trucks hauling demolition debris from the site;

and ▪ Use dust-proof chutes to load debris into trucks whenever feasible.

Construction. The following controls shall be implemented at all construction sites: ▪ Water all active construction areas at least twice daily and more often during windy periods; active areas adjacent to existing land uses shall be kept damp at all times, or shall be treated with non-toxic stabilizers to control dust. ▪ Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least 2 feet of freeboard; ▪ Pave, apply water three times daily, or apply (non-toxic) soil stabilizers on all unpaved access roads, parking

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials areas, and staging areas at construction sites; ▪ Sweep daily (with water sweepers) all paved access roads, parking areas, and staging areas, at construction sites; water sweepers shall vacuum up excess water to avoid runoff-related impacts to water quality; ▪ Sweep streets daily (with water sweepers) if visible soil material is carried onto adjacent public street; ▪ Apply non-toxic soil stabilizers to inactive construction areas; ▪ Enclose, cover, water twice daily; or apply non-toxic soil binders to exposed stockpiles (dirt, sand, etc.); ▪ Limit traffic speeds on unpaved roads to 15 mph; ▪ Install sandbags or other erosion control measures to prevent silt runoff to public roadways; ▪ Replant vegetation in disturbed areas as quickly as possible; ▪ Install baserock at entryways for exiting trucks, and wash off the tires and tracks of all trucks and equipment in designated areas before leaving the sites; and ▪ Suspend excavation and grading activity when winds (instantaneous gusts) exceed 25 mph.

Implementation of Mitigation Measure AIR-1 would reduce construction period air quality impacts to a less-than- significant level. SCA #36c, Toxics. Building Materials Survey: Prior to Prior to City of Berkeley Verify that the approving any permit for partial or complete demolition issuance of a Planning & Survey’s and renovation activities involving the removal of 20 square permit for Development procedures for or lineal feet of interior or exterior walls, a building demolition or Department the removal, materials survey shall be conducted by a qualified renovation reuse, or disposal professional. The survey shall include, but not be limited activities

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials to, identification of any lead-based paint, asbestos, of hazardous polychlorinated biphenyl (PBC) containing equipment, materials hydraulic fluids in elevators or lifts, refrigeration systems, complies with treated wood and mercury containing devices (including state fluorescent light bulbs and mercury switches). The Survey requirements. shall include plans on hazardous waste or hazardous Ensure Bay Area materials removal, reuse or disposal procedures to be Air Quality implemented that fully comply state hazardous waste Management generator requirements (22 California Code of Regulations District 66260 et seq). The Survey becomes a condition of any Regulation 11-2- building or demolition permit for the project. 401.3 is Documentation evidencing disposal of hazardous waste in understood. compliance with the survey shall be submitted to TMD within 30 days of the completion of the demolition. If asbestos is identified, Bay Area Air Quality Management District Regulation 11-2-401.3 a notification must be made and the J number must be made available to the City of Berkeley Permit Service Center. SCA #38, Air Quality – Diesel Particulate Matter during Compliance City of Berkeley Thoroughly Construction: All off-road construction equipment used for with this SCA Public Works review the health projects with construction lasting more than 2 months shall is required to Department risk assessment comply with one of the following measures: receive or Construction ▪ The project applicant shall prepare a health risk building Emissions assessment that demonstrates the project’s on-site permits. Minimization Plan emissions of diesel particulate matter during Monitoring is (Emission Plan) construction will not exceed health risk screening not needed. before the criteria after a screening-level health risk assessment is issuance of conducted in accordance with current guidance from building permits. BAAQMD and Office of Environmental Health Hazard Assessment (OEHHA). The health risk assessment shall be submitted to the Public Works Department for review

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials and approval prior to the issuance of building permits. ▪ All construction equipment shall be equipped with Tier 2 or higher engines and the most effective Verified Diesel Emission Control Strategies (VDECS) available for the engine type (Tier 4 engines automatically meet this requirement) as certified by the California Air Resources Board (CARB). The equipment shall be properly maintained and tuned in accordance with manufacturer specifications. In addition, a Construction Emissions Minimization Plan (Emissions Plan) shall be prepared that includes the following: ▪ An equipment inventory summarizing the type of off- road equipment required for each phase of construction, including the equipment manufacturer, equipment identification number, engine model year, engine certification (tier rating), horsepower, and engine serial number. For all VDECS, the equipment inventory shall also include the technology type, serial number, make, model, manufacturer, CARB verification number level, and installation date. ▪ A Certification Statement that the Contractor agrees to comply fully with the Emissions Plan and acknowledges that a significant violation of the Emissions Plan shall constitute a material breach of contract. The Emissions Plan shall be submitted to the Public Works Department for review and approval prior to the issuance of building permits. SCA #49, Public Works – Implement BAAQMD- Ongoing City of Berkeley Make regular Recommended Measures during Construction: For all throughout Public Works visits to the proposed projects, BAAQMD recommends implementing all demolition, Department project site to the Basic Construction Mitigation Measures, listed below to grading, ensure that all

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials meet the best management practices threshold for fugitive and/or BAAQMD- dust: construction recommended ▪ All exposed surfaces (e.g., parking areas, staging areas, measures are soil piles, graded areas, and unpaved access roads) shall being be watered two times per day. implemented.

▪ All haul trucks transporting soil, sand, or other loose material off-site shall be covered. ▪ All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. ▪ All vehicle speeds on unpaved roads shall be limited to 15 mph. ▪ All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. ▪ Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. ▪ All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified visible emissions evaluator. ▪ Post a publicly visible sign with the telephone number and person to contact at the lead agency regarding dust

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

D. BIOLOGICAL RESOURCES No significant biological resources impacts were identified and no mitigation measures were identified in the EIR. The following SCA is included to ensure no significant impacts occur.

E. CULTURAL RESOURCES MM CULT-1: The following mitigation measures shall be implemented:

MM CULT-1a: Documentation of the affected historical CULT-1a: Prior CULT-1a: City of CULT-1a: Staff will resource, the Fred Turner Building (2546-2554 Bancroft to project Berkeley Planning review and Way), shall be completed in accordance with the standards construction & Development archive the of Historical American Buildings Survey Level II, as Department gathered described in the Guidelines for Architectural and information Engineering Documentation (68 FR 43159), to include the following: ▪ Drawings: select existing drawings, where available, may be photographed with large-format negatives or photographically reproduced on Mylar in accordance with the U.S. Copyright Act, as amended ▪ Photographs: photographs with large-format negatives of exterior and interior views, or historic views where available and produced in accordance with the U.S. Copyright Act, as amended ▪ Written data: history and description. Upon completion, copies of all drawings, photographs, and the report shall be provided to the following repositories for archival information on Berkeley's historical resources

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials and Northern California architectural history: ▪ NWIC ▪ Berkeley Architectural Heritage Association ▪ Berkeley Historical Society ▪ Berkeley History Room of the Berkeley Public Library ▪ University of California, Berkeley Environmental Design Library ▪ The Julia Morgan Collections at the Robert E. Kennedy Library at California Polytechnic State University ▪ California State Library.

This mitigation would ensure that information regarding the building's history and condition at the time of documentation would be available to the public and future researchers.

MM CULT-1b: A site-specific historic preservation treatment plan for the retained portion of the Fred Turner Building CULT-1b: CULT-1b: City of CULT 1-b: Make (2546-2554 Bancroft Way) shall be prepared and Ongoing Berkeley Planning site visits and/or implemented by or under the direct supervision of a during & Development communicate with Preservation Architect who meets or exceeds the Secretary demolition Department construction staff of the Interior's Professional Qualifications Standards for and monthly during Historic Architecture and Architectural History. This renovation of demolition and treatment plan shall define conditions assessment and the Fred renovation of the documentation, protection, and monitoring requirements Turner Fred Turner and procedures to be implemented during demolition of Building Building. Update the rear portion of the historic building; demolition on the monitoring report adjacent property, and restoration of the retained northern with relevant portion of the building. The treatment plan shall describe updates after procedures to be undertaken for the documentation, each visit or evaluation, and treatment of previously unrecorded communication.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials architectural features that are uncovered during demolition and rehabilitation activities. Such features may include artwork, decorative plaster or metalwork, or other building elements currently obscured by post-1940 renovations or additions to the Fred Turner Building (2546-2554 Bancroft Way). Such All procedures should be defined to avoid inadvertent damage to portions of the Fred Turner Building (2546-2554 Bancroft Way) to be retained for incorporation into the proposed development during project construction and shall include consideration of site security and fencing; avoidance and physical protection of historic surfaces and materials; and storage of temporarily removed or salvaged historic materials and building components. The treatment plan shall be submitted to the City of Berkeley Planning and Development Department prior to construction for review and approval.

MM CULT-1c: A permanent, high-quality on-site plaque or CULT-1c: After CULT-1c: Berkeley CULT-1c: Review interpretive display shall be installed within a publicly- construction Landmarks and approve accessible location at or near the Bancroft Way-facing Preservation content produced facade of the retained portion of the Fred Turner Building Committee by exhibit (2546-2554 Bancroft Way). The primary goal of the exhibit designer and wouldshall be to inform the public about the history of the architectural building, including its landmark status and surrounding historian. Make neighborhood; acknowledge the alterations madein the site visit to process of neighborhood development; and provide ensure the plaque information regarding the City of Berkeley and Berkeley is tastefully Landmarks Preservation Committee's efforts to record and displayed after preserve the city's architectural heritage. If deemed construction is appropriate by staff and the Landmarks Preservation complete but Commission Chair, the plaque may be designed consistent before residents move in.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials with the Berkeley Historical Plaque Project (berkeleyplaques.org). The placement, size, and appearance of the plaque shall be designed so as not to interfere with the ability of the building’s character-defining features to convey their significance consistent with the Secretary of the Interior Standards. A dDraft of the plaque or display shall be submitted with the building permit for review by staff in coordination with the Landmarks Preservation Commission Chair. The final plaque or display shall be in place prior to the issuance of a temporary certificate of occupancy. Southside Plan EIR Impact CULT-1: Should fossils be During Qualified If fossils are encountered during construction or site preparation construction Paleontologist found work shall activities, such works shall be halted in the vicinity of the or site be halted until a find. A qualified paleontologist shall be contacted to preparation paleontologist evaluate the nature of the find and determine if mitigation determines if is necessary. All feasible recommendations of the mitigation is paleontologist shall be implemented. Mitigation may necessary. include, but is not limited to, in-field documentation and recovery of the specimen (s), laboratory analysis, the preparation of a report detailing the methods and findings of the investigation, and curation at an appropriate paleontological collections facility. Southside Plan EIR Impact CULT-2: During project-specific During City of Berkeley, environmental review for individual development projects project- Planning within the Southside area, the City shall apply the specific Department conditions of approval and the criteria for determining environmental archaeological impacts required by the City of Berkeley review General Plan. If such a system of review is not yet in place, the City shall, prior to the approval of any Draft Plan-related project involving ground disturbance, establish a

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials development process with comparable conditions of approval and safeguards against potential impacts to archaeological deposits. Such conditions and safeguards may include, but are not limited to, archaeological sensitivity assessments, site-specific investigations, intensive surface surveys, and/or subsurface archaeological testing prior to project clearance. Southside Plan EIR Impact CULT-3: If unanticipated During Qualified If deposits found deposits of prehistoric or historical archaeological materials construction archaeologist all work must be are encountered during construction activities, all work redirected within within 50 feet of the discovery shall be redirected until a 50 feet of the qualified archaeologist can be contacted to evaluate the discovery. If situation, determine if the deposit qualifies as a historical deposit does not or archaeological resource, and provide recommendations. qualify as a If the deposit does not qualify as a historical or historical or archaeological resource, then no further protection or study archaeological is necessary. If the deposit does qualify as a historical or resource no archaeological resource, then the impacts to the deposit further protection shall be avoided by project activities. If the deposits cannot is needed. If be avoided, adverse impacts to the deposit must be deposit qualifies, mitigated. Mitigation may include, but is not limited to, impacts to archaeological data recovery. Upon completion of the deposit shall be archaeological assessment, a report should be prepared avoided documenting methods, findings, and recommendations. The report should be submitted to the City, the project proponent, and the NWIC. Southside Plan EIR Impact CULT-4: If human remains are During County Coroner If human remains encountered during construction activities, all work within construction and Certified are found all work 50 feet of the remains should be redirected and the County Archaeologist within 50 feet of Coroner notified immediately. At the same time, an the remains archaeologist shall be contacted to assess the situation. If should be

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials the human remains are of Native American origin, the redirected and Coroner must notify the Native American Heritage the County Commission within 24 hours of this identification. The Coroner should Native American Heritage Commission will identify a Native be notified. American Most Likely Descendant (MLD) to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods. The archaeologist shall recover scientifically-valuable information, as appropriate and in accordance with the recommendations of the MLD. Upon completion of the archaeological assessment, a report should be prepared documenting methods and results, as well as recommendations regarding the treatment of the human remains and any associated archaeological materials. The report should be submitted to the City, the project proponent, and the NWIC.

F. GEOLOGY AND SOILS No significant geology and soils impacts were identified and no mitigation measures were identified in the EIR. The following SCAs are included to ensure no significant impacts occur. SCA #52, Public Works: The project sponsor shall maintain Ongoing City of Berkeley Make regular, sandbags or other devices around the site perimeter during during Public Works unannounced site the rainy season to prevent on-site soils from being washed construction Department visits to verify off-site and into the storm drain system. The project and grading perimeter sponsor shall comply with all City ordinances regarding activities protections construction and grading. SCA #53, Public Works: Prior to any excavation, grading, Ongoing City of Berkeley Make regular, clearing, or other activities involving soil disturbance during Public Works unannounced site during the rainy season the applicant shall obtain approval construction Department visits to verify of an erosion prevention plan by the Building and Safety and grading compliance with Division and the Public Works Department. The applicant activities the erosion shall be responsible for following these and any other prevention plan

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials measures required by the Building and Safety Division and the Public Works Department. SCA #54, Public Works: The removal or obstruction of any Ongoing City of Berkeley Check that all fire fire hydrant shall require the submission of a plan to the during Public Works hydrants are in City’s Public Works Department for the relocation of the fire construction Department their proper hydrant during construction. activities location during site visits SCA #55, Public Works: If underground utilities leading to Ongoing City of Berkeley adjacent properties are uncovered and/or broken, the during Public Works contractor involved shall immediately notify the Public construction Department Works Department and the Building & Safety Division, and activities carry out any necessary corrective action to their satisfaction.

G. GREENHOUSE GAS EMISSIONS No significant greenhouse gas emissions impacts were identified and no mitigation measures were identified in the EIR. The following SCAs are included to ensure no significant impacts occur. SCA #28, Savings by Design: The applicant shall submit During City of Berkeley N/A documentation to the project planner verifying that an application Planning & application to the Savings By Design program (either the approval Development Whole Building form or the Systems Approach form) was Department submitted to PG&E. This documentation shall include a copy of follow-up documentation between PG&E and the applicant, including a Savings By Design Energy Efficiency Form with a completed Preliminary Savings Estimate. SCA #29, Electric Vehicle (EV) Charging: At least 10% of the During City of Berkeley N/A project parking spaces for residential parking and 3% of the application Planning & parking spaces for non-residential parking shall be pre- approval Development wired to allow for future Level 2 (240 Volt/40 amp) plug-in Department electric vehicle (EV) charging system installation, as specified by the Office of Energy and Sustainable

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials Development. Any Level 2 EV charging systems installed at parking spaces will be counted toward the applicable pre- wiring requirement. Pre-wiring for EV charging and EV charging station installations shall be noted on site plans. SCA #30, Recycling and Organics Collection: Applicant shall During City of Berkeley N/A provide recycling and organics collection areas for application Planning & occupants, clearly marked on site plans, which comply with approval Development the Alameda County Mandatory Recycling Ordinance Department (ACWMA Ordinance 2012-01). SCA #31, Water Efficient Landscaping: Applicant shall During City of Berkeley N/A provide an updated Bay-Friendly Basics Landscape Checklist application Planning & that includes detailed notes of any measures that will not approval Development be fully met at the project. Landscape improvements shall Department be consistent with the current versions of the State’s Water Efficient Landscape Ordinance (WELO) and the East Bay Municipal Utility District’s Section 31: Water Efficiency Requirements. SCA #62, Exterior Lighting: All exterior lighting shall be During City of Berkeley N/A energy efficient where feasible; and shielded and directed application Planning & downward and away from property lines to prevent approval Development excessive glare beyond the subject property. Department SCA #71, Bike Parking: Secure and on-site bike parking for During City of Berkeley N/A bicycles shall be provided for the life of the building. application Planning & approval Development Department SCA #73, Transportation Demand Management: A Prior to City of Berkeley Establish annual Transportation Demand Management compliance report project Transportation reviews of the shall be submitted to the Transportation Division Manager, occupancy Division Manager Transportation on a form acceptable to the City, prior to occupancy, and and on an Demand on an annual basis thereafter, which demonstrates that the annual basis Management

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials project is in compliance with the applicable requirements thereafter compliance report and the following: during which ▪ Consistent with BMC 23E.68.080.H, and subject to the compliance for all review and oversight of the Transportation Division standards will be Manager, the cost equivalent to an unlimited local bus verified. pass shall be provided on a Clipper Card, or equivalent card that can be used by major Bay Area transit systems, shall be provided, at no cost, to every employee. ▪ A notice describing these transportation benefits shall be posted in a location or locations visible to all employees. ▪ Exceeding BMC23E.68.080.H, and subject to the review and oversight of the Transportation Division Manager, the cost equivalent to an unlimited local bus pass shall be provided on a Clipper Card, or equivalent card that can be used by major Bay Area transit systems, shall be provided, at no cost, two per residential unit. ▪ Transit information shall be provided in the residential lobby, updated at a minimum once a year. The information panels shall be shown in the construction drawings and shall be installed prior to occupancy. ▪ Transportation Information Officer will gather and provide information regarding transit and other alternative transportation to residents and commercial tenants and their employees. Information may pertain to the City, regional transit agencies, car sharing, Spare the Air, 511 and other relevant programs. This information package shall be provided to all residents/employees on arrival plus once a year. ▪ The food service operation, if qualifying for participation in the Alameda County Guaranteed Ride Home program

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials (or successor program), shall participate in the “Guarantee Ride Home” program to reduce employee single occupant vehicle trips by providing alternate means of leaving work in an emergency. Enrollment shall be encouraged by providing Guarantee Ride Home information to all employees. An affidavit/statement indicating number of participating employees shall be provided annually to the Transportation Division Manager.

H. HAZARDS AND HAZARDOUS MATERIALS No significant hazards and hazardous materials impacts were identified and no mitigation measures were identified in the EIR. The following SCAs are included to ensure no significant impacts occur. SCA #37d, Hazardous Materials Business Plan: A Ongoing City of Berkeley N/A Hazardous Materials Business Plan (HMBP) in compliance during Planning & with BMC Section 15.12.040 shall be submitted demolition, Development electronically at http://cers.calepa.ca.gov/ within 30 days grading, and Department if on-site hazardous materials exceed BMC 15.20.040. construction activities SCA #47a, Stormwater Requirements: The project plans Ongoing City of Berkeley Review project shall identify and show site-specific Best Management during Planning & plans for BMPs Practices (BMPs) appropriate to activities conducted on-site demolition, Development during application to limit to the maximum extent practicable the discharge of grading, and Department submittal. pollutants to the City's storm drainage system, regardless construction Confirm the BMPs of season or weather conditions. activities are implement during site visits. SCA #36c, Building Materials Survey: Prior to approving any Prior to City of Berkeley Verify that the permit for partial or complete demolition and renovation issuance of a Planning & Survey’s activities involving the removal of 20 square or lineal feet permit for Development procedures for of interior or exterior walls, a building materials survey demolition or Department the removal, shall be conducted by a qualified professional. The survey renovation reuse, or disposal shall include, but not be limited to, identification of any activities

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials lead-based paint, asbestos, polychlorinated biphenyl (PBC) of hazardous containing equipment, hydraulic fluids in elevators or lifts, materials refrigeration systems, treated wood and mercury containing complies with devices (including fluorescent light bulbs and mercury state switches). The Survey shall include plans on hazardous requirements. waste or hazardous materials removal, reuse or disposal Ensure Bay Area procedures to be implemented that fully comply state Air Quality hazardous waste generator requirements (22 California Management Code of Regulations 66260 et seq). The Survey becomes a District condition of any building or demolition permit for the Regulation 11-2- project. Documentation evidencing disposal of hazardous 401.3 is waste in compliance with the survey shall be submitted to understood. TMD within 30 days of the completion of the demolition. If asbestos is identified, Bay Area Air Quality Management District Regulation 11-2-401.3 a notification must be made and the J number must be made available to the City of Berkeley Permit Service Center. SCA #45, Transportation Construction Plan: The applicant Ongoing City of Berkeley Request to see and all persons associated with the project are hereby during Planning & TCP during site notified that a Transportation Construction Plan (TCP) is demolition, Development visits. Ensure that required for all phases of construction, particularly for the grading, and Department the project is following activities: construction complying with ▪ Alterations, closures, or blockages to sidewalks, activities the measures of pedestrian paths or vehicle travel lanes (including the TCP during bicycle lanes); site visits. ▪ Storage of building materials, dumpsters, debris anywhere in the public ROW; ▪ Provision of exclusive contractor parking on-street; or ▪ Significant truck activity. The applicant shall secure the City Traffic Engineer’s approval of a TCP. In addition to other requirements of the

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials Traffic Engineer, this plan shall include the locations of material and equipment storage, trailers, worker parking, a schedule of site operations that may block traffic, and provisions for traffic control. The TCP shall be consistent with any other requirements of the construction phase. A current copy of this Plan shall be available at all times at the construction site for review by City Staff.

I. HYDROLOGY AND WATER QUALITY No significant hydrology and water quality impacts were identified and no mitigation measures were identified in the EIR. The following SCAs are included to ensure no significant impacts occur. SCA #47, Stormwater Requirements: The applicant shall Ongoing City of Berkeley Make regular demonstrate compliance with the requirements of the City’s throughout Planning & visits to the National Pollution Discharge Elimination System (NPDES) demolition, Development project site to permit as described in BMC Section 17.20. The following grading, Department ensure that all conditions apply: construction, storm water and/or ▪ The project plans shall identify and show site-specific controls and BMP operations. Best Management Practices (BMPs) appropriate to measures are activities conducted on-site to limit to the maximum being extent practicable the discharge of pollutants to the implemented. City's storm drainage system, regardless of season or weather conditions. ▪ Trash enclosures and/or recycling area(s) shall be covered; no other area shall drain onto this area. Drains in any wash or process area shall not discharge to the storm drain system; these drains should connect to the sanitary sewer. Applicant shall contact the City of Berkeley and EBMUD for specific connection and discharge requirements. Discharges to the sanitary sewer are subject to the review, approval and conditions of the City of Berkeley and EBMUD.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials ▪ Landscaping shall be designed with efficient irrigation to reduce runoff, promote surface infiltration and minimize the use of fertilizers and pesticides that contribute to stormwater pollution. Where feasible, landscaping should be designed and operated to treat runoff. When and where possible, xeriscape and drought tolerant plants shall be incorporated into new development plans. ▪ Design, location and maintenance requirements and schedules for any stormwater quality treatment structural controls shall be submitted to the Department of Public Works for review with respect to reasonable adequacy of the controls. The review does not relieve the property owner of the responsibility for complying with BMC Chapter 17.20 and future revisions to the City's overall stormwater quality ordinances. This review shall be shall be conducted prior to the issuance of a Building Permit. ▪ All paved outdoor storage areas must be designed to reduce/limit the potential for runoff to contact pollutants. ▪ All on-site storm drain inlets/catch basins must be cleaned at least once a year immediately prior to the rainy season. The property owner shall be responsible for all costs associated with proper operation and maintenance of all storm drainage facilities (pipelines, inlets, catch basins, outlets, etc.) associated with the project, unless the City accepts such facilities by Council action. Additional cleaning may be required by City of Berkeley Public Works Engineering Dept. ▪ All private or public projects that create and/or replace

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials 10,000 square feet or more of impervious surface must comply with Provision C.3 of the Alameda County NPDES permit and must incorporate stormwater controls to enhance water quality. Permit submittals shall include a Stormwater Requirement Checklist and detailed information showing how the proposed project will meet Provision C.3 stormwater requirements, including a) Site design measures to reduce impervious surfaces, promote infiltration, and reduce water quality impacts; b) Source Control Measures to keep pollutants out of stormwater runoff; c) Stormwater treatment measures that are hydraulically sized to remove pollutants from stormwater; d) an O & M (Operations and Maintenance) agreement for all stormwater treatment devices and installations; and e) Engineering calculations for all stormwater devices (both mechanical and biological). ▪ All on-site storm drain inlets must be labeled “No Dumping – Drains to Bay” or equivalent using methods approved by the City. ▪ Most washing and/or steam cleaning must be done at an appropriately equipped facility that drains to the sanitary sewer. Any outdoor washing or pressure washing must be managed in such a way that there is no discharge or soaps or other pollutants to the storm drain. Sanitary connections are subject to the review, approval and conditions of the sanitary district with jurisdiction for receiving the discharge. ▪ All loading areas must be designated to minimize “run- on” or runoff from the area. Accumulated waste water that may contribute to the pollution of stormwater must be drained to the sanitary sewer or intercepted and

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials pretreated prior to discharge to the storm drain system. The property owner shall ensure that BMPs are implemented to prevent potential stormwater pollution. These BMPs shall include, but are not limited to, a regular program of sweeping, litter control and spill cleanup. ▪ Restaurants, where deemed appropriate, must be designed with a contained area for cleaning mats, equipment and containers. This contained wash area shall be covered or designed to prevent run-on or runoff from the area. The area shall not discharge to the storm drains; wash waters should drain to the sanitary sewer, or collected for ultimate disposal to the sanitary sewer. Employees shall be instructed and signs posted indicating that all washing activities shall be conducted in this area. Sanitary connections are subject to the review, approval and conditions of the waste water treatment plant receiving the discharge. ▪ Sidewalks and parking lots shall be swept regularly to prevent the accumulation of litter and debris. If pressure washed, debris must be trapped and collected to prevent entry to the storm drain system. If any cleaning agent or degreaser is used, wash water shall not discharge to the storm drains; wash waters should be collected and discharged to the sanitary sewer. Discharges to the sanitary sewer are subject to the review, approval and conditions of the sanitary district with jurisdiction for receiving the discharge. ▪ The applicant is responsible for ensuring that all contractors and sub-contractors are aware of and implement all stormwater quality control measures.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials Failure to comply with the approved construction BMPs shall result in the issuance of correction notices, citations, or a project stop work order. SCA #50, Public Works: All piles of debris, soil, sand, or Ongoing City of Berkeley Make regular, other loose materials shall be covered at night and during during Public Works unannounced site rainy weather with plastic at least one-eighth millimeter construction Department visits to verify thick and secured to the ground. and grading compliance with activities debris management SCA #51, Public Works: The applicant shall ensure that all Ongoing City of Berkeley Make regular, excavation takes into account surface and subsurface during Public Works unannounced site waters and underground streams so as not to adversely construction Department visits to verify affect adjacent properties and rights-of-way. and grading proper excavation activities methods are being used SCA #52, Public Works: The project sponsor shall Ongoing City of Berkeley Make regular, maintain sandbags or other devices around the site during Public Works unannounced site perimeter during the rainy season to prevent on-site soils construction Department visits to verify from being washed off-site and into the storm drain and grading perimeter system. activities protections SCA #53, Public Works: Prior to any excavation, grading, Ongoing City of Berkeley Make regular, clearing, or other activities involving soil disturbance during Public Works unannounced site during the rainy season the applicant shall obtain approval construction Department visits to verify of an erosion prevention plan by the Building and Safety and grading compliance with Division and the Public Works Department. The applicant activities the erosion shall be responsible for following these and any other prevention plan measures required by the Building and Safety Division and the Public Works Department.

J. LAND USE AND PLANNING No significant land use and planning impacts would occur.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials

K. MINERAL RESOURCES No significant mineral resource impacts would occur.

L. NOISE No significant noise impacts were identified and no mitigation measures were identified in the EIR. The following SCAs are included to ensure no significant impacts occur. SCA #16, Noise Reduction Program: The applicant shall Ongoing City of Berkeley Make regular develop a site-specific noise reduction program prepared by throughout Planning & visits to the a qualified acoustical consultant to reduce construction demolition, Development project site to noise impacts to the maximum extent feasible, subject to grading, Department ensure that all review and approval of the Zoning Officer. The noise and/or noise BMP control reduction program shall include the time limits for construction measures are construction listed above, as measures needed to ensure being that construction complies with BMC Section 13.40.070. implemented. The noise reduction program should include, but shall not be limited to, the following available controls to reduce construction noise levels as low as practical: ▪ Construction equipment should be well maintained and used judiciously to be as quiet as practical. ▪ Equip all internal combustion engine-driven equipment with mufflers, which are in good condition and appropriate for the equipment. ▪ Utilize “quiet” models of air compressors and other stationary noise sources where technology exists. Select hydraulically or electrically powered equipment and avoid pneumatically powered equipment where feasible. ▪ Locate stationary noise-generating equipment as far as possible from sensitive receptors when adjoining construction sites. Construct temporary noise barriers or partial enclosures to acoustically shield such equipment where feasible.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials ▪ Prohibit unnecessary idling of internal combustion engines. ▪ If impact pile driving is required, pre-drill foundation pile holes to minimize the number of impacts required to seat the pile. ▪ Construct solid plywood fences around construction sites adjacent to operational business, residences or other noise-sensitive land uses where the noise control plan analysis determines that a barrier would be effective at reducing noise. ▪ Erect temporary noise control blanket barriers, if necessary, along building facades facing construction sites. This mitigation would only be necessary if conflicts occurred which were irresolvable by proper scheduling. Noise control blanket barriers can be rented and quickly erected. ▪ Route construction related traffic along major roadways and away from sensitive receptors where feasible. SCA #15, Construction Noise Management Program – Public Ongoing City of Berkeley Make site visit Notice Required: At least two weeks prior to initiating any throughout Planning & two weeks prior construction activities at the site, the applicant shall demolition, Development to construction provide notice to businesses and residents within 500 feet grading, Department start to ensure of the project site. This notice shall at a minimum provide and/or that notices are the following: (1) project description, (2) description of construction correct and construction activities, (3) daily construction schedule (i.e., thoroughly time of day) and expected duration (number of months), (4) distributed. the name and phone number of the Project Liaison for the Periodically check project that is responsible for responding to any local in with the Project complaints, (5) commitment to notify neighbors at least Liaison to ensure four days in advance of authorized extended work hours complaints are being managed

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials and the reason for extended hours, and (6) that effectively. construction work is about to commence. The liaison would determine the cause of all construction-related complaints (e.g., starting too early, bad muffler, worker parking, etc.) and institute reasonable measures to correct the problem. A copy of such notice and methodology for distributing the notice shall be provided in advance to the City for review and approval. SCA #18, Construction Phases: The applicant shall provide Ongoing City of Berkeley Contact the the Zoning Officer with a schedule of major construction throughout Planning & applicant two phases with start dates and expected duration, a demolition, Development weeks prior to the description of the activities and anticipated noise levels of grading, Department start and end date each phase, and the name(s) and phone number(s) of the and/or of each individual(s) directly supervising each phase. The Zoning construction construction Officer or his/her designee shall have the authority to period to verify require an on-site meeting with these individuals as the correctness of necessary to ensure compliance with these conditions. The the phases. Post applicant shall notify the Zoning Officer of any changes to changes on all this schedule as soon as possible. materials accordingly. SCA #46, Project Construction Website: The applicant shall Ongoing City of Berkeley Check the project establish a project construction website with the following throughout Planning & construction information clearly accessible and updated monthly or demolition, Development website prior to more frequently as changes warrant: grading, Department the start date of and/or ▪ Contact information (i.e. “hotline” phone number, and each construction construction email address) for the project construction manager period to verify the website ▪ Calendar and schedule of daily/weekly/monthly contains correct construction activities information. ▪ The final Conditions of Approval, Mitigation Monitoring Compare website and Reporting Program, Transportation Construction information to Plan, Construction Noise Reduction Program, and any

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials other reports or programs related to construction noise, observations air quality, and traffic. gathered during site visits and request website updates if needed. SCA #19, Interior Noise Levels: Prior to issuance of a Compliance City of Berkeley Thoroughly building permit, the applicant shall submit a report to the with this SCA Planning & review the interior Building and Safety Division and the Zoning Officer by a is required to Development noise levels qualified acoustic engineer certifying that the interior receive Department before the residential portions of the project will achieve interior noise building issuance of levels of no more than 45 Ldn (Average Day-Night Levels). If permits. building permits. the adopted Building Code imposes a more restrictive Monitoring is standard for interior noise levels, the report shall certify not needed. compliance with this standard. SCA #14: The project is required to submit a screening During City of Berkeley Create a vibration level analysis on damage due to construction vibration. The construction Planning & impact project applicant would need to prepare a vibration impact Development assessment if assessment if the screening level analysis shows that the Department screening level project may create vibration to damage nearby structures. analysis shows The vibration impact assessment is required to take into that it will create account project specific information and the soil vibration characteristics in the area, as well as to recommend design means and methods of construction to avoid the potential damage, if feasible. The project sponsor is responsible for repair of any vibration damage to nearby structures resulting from the project construction.

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Mitigation Monitoring and Reporting Program Mitigation Monitoring Reporting Monitoring Monitoring Monitoring Date/ SCA/MM Schedule Responsibility Procedure Comments Initials

M. PARKS AND RECREATION No significant parks and recreation impacts would occur.

N. POPULATION AND HOUSING No significant population and housing impacts would occur.

O. PUBLIC SERVICES No significant public services impacts would occur.

P. TRANSPORTATION No significant transportation impacts would occur.

Q. UTILITIES AND SERVICE SYSTEMS No significant utilities and service systems impacts would occur.

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A-28 ATTACHMENT B

Supplemental Memorandum- Project Impacts Analysis of the Standard Project, 2580 Bancroft Way

CARLSBAD FRESNO IRVINE LOS ANGELES PALM SPRINGS POINT RICHMOND RIVERSIDE ROSEVILLE SAN LUIS OBISPO MEMORANDUM

DATE: July 31, 2018

TO: Emilie Wolfson, Associate Planner, Urban Planning Partners

FROM: Michael Hibma, M.A., Associate/Architectural Historian, LSA

SUBJECT: Supplemental Memorandum - Project Impacts Analysis of the Standard Project, 2580 Bancroft Way, Berkeley, Alameda County, California (LSA Project No.: TMK1501).

LSA prepared this supplemental memorandum (memo) to address two impacts scenarios not addressed in a Project Impacts Analysis (PIA) originally prepared in August 2016 by LSA cultural resource staff and a preservation architect at Interactive Resources Inc. (IR), for the Standard Project (Hibma and Butt 2018).1 Subsequently updated in March 2018, the PIA (2018 PIA) assessed whether the proposed 2580 Bancroft Way Mixed Use Project1 (Project) complies with the Secretary of the Interior’s Standards for the Treatment of Historic Properties (Secretary’s Standards) for Rehabilitation.

ELIGIBILITY AND IMPACT SUMMARY Based on background research and field observations, the 2018 PIA concluded:

• The Fred Turner Building at 2546-2554 Bancroft Way was designed by architect Julia Morgan and built in 1940. The building was designated Berkeley Landmark #49 in December 1981. Based on this designation, the Fred Turner Building qualifies as a “historical resource” under the California Environmental Quality Act (CEQA).

• Bancroft Center at 2558-2588 Bancroft Way was designed by Berkeley-based architect John Hans Ostwald and built in 1963. In 2015, LSA prepared an Historical Resource Evaluation of this building and found that it did not appear eligible for the National Register of Historic Places, the California Register of Historical Resources, or for listing as a City of Berkeley Landmark, Structure of Merit, or contributing element to a historic district. Accordingly, Bancroft Center does not qualify as a “historical resource” under CEQA. For details, please see LSA’s Historical Resource Evaluation of Bancroft Center in Appendix B of the 2018 PIA. The City of Berkeley Landmark Preservation Board (LPC) took no action to designate the Bancroft Center.

1 “The Standard Project” is also known as the 2580 Bancroft Way Mixed-Use Project.

157 Park Place, Pt. Richmond, California 94801 510.236.6810 www.lsa.net

2018 PIA Impacts Conclusion According to the Project description, the southern, or rear, portion of the Fred Turner Building would be demolished to accommodate construction of an approximately 86-foot-tall, eight-story addition with an approximate 60-foot setback from the edge of the main façade plane. The new construction would be differentiated in color, materials, and detailing from the Fred Turner Building. The project would retain, preserve and rehabilitate the historic character and distinctive features of the remaining, northern street-facing portion of the Fred Turner Building; deteriorated features would be preserved or replaced based on documentation of their original characteristics. The existing ground floor commercial space in the northern, street-facing portion of the building would remain in commercial use. The ground floor would also retain the Fred Turner Building’s historic arched entrance, arcaded walkway, and courtyard as the main entrance and lobby area for use by tenants and visitors. Please see 2018 PIA section 1.1.2, for a complete Project description.

The 2018 PIA found the Project would result in a net loss of approximately half of the Fred Turner Building, a Berkeley Landmark and a “historical resource” for the purposes of CEQA. The rear, southern portion of the building that would be removed has been altered. Please see Appendix A, pages 5-8, 2018 PIA for a description of alterations to the Fred Turner Building, as documented in building permits and observed in pedestrian surveys. Moreover, the 2018 PIA found that the exterior and interior features of the rear, southern portion of the Fred Turner Building as non- significant, while the primary character-defining feature of the Fred Turner Building’s architectural character remains its single-story massing; in fact, the building’s massing was rated as a “very significant” feature (2018 PIA, section 4.1.2).

However, the 2018 PIA concluded that the Project, as a whole, would result in “a substantial adverse change” in the historical significance of the Fred Turner Building, as defined at CEQA Guidelines §15064.5(b), due to the proposed partial demolition. Unless the LPC formally “delists” the Fred Turner Building, it would officially remain a Berkeley City Landmark following completion of the Project and the LPC would maintain design review jurisdiction of the property.

PRESERVATION ALTERNATIVE The PIA was last updated in March 2018 in support of the Draft Infill Environmental Impact Report (2018 DEIR) for the Project. Subsequently, a Preservation Alternative was developed and analyzed by the City of Berkeley and Urban Planning Partners. According to the 2018 DEIR, the Preservation Alternative “…includes the same intensity and density of development as the project. However, it would not include any work on the Fred Turner Building (2546-2554 Bancroft Way): no demolition nor any improvements. All development for the proposed project would take place on the east side of the project site, which would increase the height of the project by two stories to bring the total number of stories to ten. No residential entrances would be located through the Fred Turner Building and instead would only be on the north and east side of the new building” (2018 DEIR: II-3).

The 2018 DEIR goes on to state that all development for the Preservation Alternative “would take place on the east side of the project, which includes the 20 units above the Fred Turner Building in the proposed project. These 20 units would be added to the east side of the project which would increase the height by two stories to bring the total number of stories to ten. No residential

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entrances would be located through the Fred Turner Building and instead would only be on the north and east side of the new building under the Preservation Alternative” (2018 DEIR: V-5). See the attached figure for a rendering of the proposed ten-story building massing under the Preservation Alternative. Relatedly, a review of online information from the City of Berkeley indicated that no Landmarks or Structures of Merit properties are located on any parcels adjacent to the project site (City of Berkeley 2018).

SUPPLEMENTAL ANALYSIS The 2018 PIA did not analyze any additional or standalone impacts solely derived from constructing an eight-story building east of and adjacent to the Fred Turner Building or from impacts derived from the Preservation Alternative. This memo provides the additional analysis to assess this impact. This memo was prepared by LSA Associate/Architectural Historian Michael Hibma, who co-authored the 2018 PIA and meets the Secretary of the Interior's Professional Qualifications Standards for architectural history and history (36 CFR Part 61). The supplemental analysis addresses the following impacts scenarios:

A) Potential impacts to the Fred Turner Building, a Berkeley City Landmark (#49), resulting from a proposed eight-story building constructed east of and adjacent to the Fred Turner Building. This aspect of the Project was not addressed in the 2018 PIA; and

B) Potential impacts to the Fred Turner Building from a proposed ten-story building constructed east of and adjacent to the Fred Turner Building.

Assessing impacts under either scenarios was completed with respect to the ten Rehabilitation Standards of the Secretary’s Standards.

Scenario A1 To determine the applicability of the Rehabilitation Standards of the Secretary’s Standards to the Fred Turner Building, or any historical resource, consideration of potential impacts must be “grounded in an understanding of a property’s physical features and how they relate to its significance” (National Park Service 1997:18). Rehabilitation Standard 9 references how proposed new construction must take into account how it will “protect the integrity of the property and its environment,” which implies consideration of indirect impacts because of adjacent or nearby construction. However, for the reasons outlined below, this stipulation is not as germane for a resource like the Fred Turner Building, significant solely for its architectural qualities.

The National Park Service’s National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation (Bulletin 15) provides guidance on how to define a resource’s essential physical features that convey its historic identity and significance. A resource’s historical integrity or authenticity conveys this significance. There are seven aspects of integrity: location, design, setting, materials, workmanship, feeling, and association. As stated in Bulletin 15, “determining which of

1 See section 5.4 of the 2018 PIA for the full impacts analysis utilizing all ten Rehabilitation Standards.

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these aspects are most important to a particular property requires knowing why, where, and when the property is significant” (National Park Service 1997:44).

LSA’s background research found that the Fred Turner Building’s significance as a Berkeley Landmark is derived from its associations with the Arts and Crafts architectural style and with architect Julia Morgan (see 2018 PIA, section 4.1.1). The 2018 PIA affirms that the Fred Turner Building retains these essential physical qualities (see 2018 PIA section 4.1.2.1 for a complete list). As stated in Bulletin 15, a “property important for illustrating a particular architectural style or construction technique [i.e., National Register Criterion C and California Register Criterion 3] must retain most of the physical features that constitute that style or technique. A property that has lost some historic materials or details can be eligible if it retains the majority of the features that illustrate its style in terms of massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation” (National Park Service 1997:46).

The Fred Turner Building’s significance is not derived from being located in an isolated setting. It was intentionally sited along a busy street in a bustling commercial and institutional setting adjacent to the campus of a major university. The size and scale of a proposed eight-story building, east of and adjacent to the Fred Turner Building, would diminish its integrity of setting and feeling. However, these aspects of integrity are not as important to conveying the essential physical features that underpin its significance as an Arts and Crafts-styled boutique building designed by Julia Morgan as integrity of design, materials, and workmanship.

Moreover, the Fred Turner Building was designated a Berkeley Landmark with several alterations in place, and has since retained its Landmark status while sustaining later post-designation alterations. See Appendix A, pages 5-8, 2018 PIA for a description of alterations to the Fred Turner Building as documented in building permits and observed in pedestrian surveys. These features and the location of the Fred Turner Building and its association with Ms. Morgan would remain if a proposed eight-story building was built east of and adjacent to the building. If assessed solely for impacts due to the adjacent eight-story building, the project would comply with the Secretary’s Standards.

Despite the preceding discussion, however, the proposed Project as a whole would remain non- compliant with the Secretary’s Standards due to the proposed partial demolition of the Fred Turner Building and construction of the Project.

Scenario B The following discussion assesses the compatibility of the proposed Preservation Alternative design with respect to the existing visual aspects of the neighboring Fred Turner Building and the larger built environmental setting. The assessment is based on the conceptual guidance provided in the Secretary’s Standards, especially as it pertains to the proposed new construction.

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Rehabilitation Standard 1

A property would be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces and spatial relationships.

The Fred Turner Building is a single-story commercial building constructed in 1940 that was intentionally sited along Bancroft Way to capitalize on commercial opportunities near the University of California, Berkeley campus. The building’s location has remained the same since construction. The Fred Turner Building would remain within the project site and retain its current commercial uses. The proposed ten-story building would be constructed east of and adjacent to the Fred Turner Building. The Fred Turner Building would maintain all of its character-defining features identified in section 4.1.2 of the 2018 PIA. However, the Preservation Alternative would not implement a program of rehabilitation and restoration to the northern, front half of the Fred Turner Building. No changes would occur to the materials, features, and spaces of the building’s front half; the altered southern, rear half of the building, which retains little of the original significant fabric, would also remain.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 1.

Rehabilitation Standard 2

The historic character of a property would be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize the property would be avoided.

This historic character of the Fred Turner Building is conveyed by its architectural qualities as a single-story, multi-unit Arts and Crafts-inspired commercial boutique building. The proposed project would not impact the building’s existing features, spaces, and spatial relationships. Although the Preservation Alternative would construct a ten-story building east of and adjacent to the Fred Turner Building, the Preservation Alternative would not alter or remove any of the very significant, significant, or contributing character-defining façade elements, fenestration pattern or materials, or ornamentation on the main, street-facing façade. The Preservation Alternative would maintain the Fred Turner Building in its current location and retain its historical use as a commercial property.

Therefore, as designed, the Preservation Alternative would be compliant with Rehabilitation Standard 2.

Rehabilitation Standard 3

Each property would be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historical properties, would not be undertaken.

The Preservation Alternative would construct a ten-story building east of and adjacent to the Fred Turner Building, a Berkeley City Landmark. No project-related activity would impinge the City

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Landmark boundary. By the same token, the Preservation Alternative would not remove the non- character defining features of, and modifications to, the Fred Turner Building. As described in section 3.1.2 and in Appendix A of the 2018 PIA, these alterations are concentrated in the rear, southern half of the building. The building will remain in use as a multi-unit commercial boutique in its historical location, along with its altered and reconfigured spaces, and would not undergo a program of restoration and rehabilitation as proposed by the Project.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 3.

Rehabilitation Standard 4

Changes to a property that have acquired significance in their own right would be retained and preserved.

The Preservation Alternative would construct a ten-story building east of and adjacent to the Fred Turner Building, a Berkeley City Landmark. No project-related activity would impinge on the City Landmark boundary.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 4.

Rehabilitation Standard 5

Distinctive materials, features, finishes and construction techniques or examples of craftsmanship that characterize a property would be preserved.

The Preservation Alternative does not propose altering or removing any of the distinctive materials, features, finishes, and construction techniques or examples of craftsmanship found on Fred Turner Building. Under the Preservation Alternative, the Fred Turner Building’s Arts and Crafts architectural qualities and its association with architect Julia Morgan will remain as key pillars of its significance, despite alterations to the building both before and after its landmark designation in 1981. The building will remain in use as a multi-unit commercial boutique in its historical location, along with its altered and reconfigured spaces. The Preservation Alternative would not remove any of the remaining historic fabric of the Fred Turner Building, whereas the proposed Project would implement a program of restoration and rehabilitation to the northern street-facing half of the Fred Turner Building while demolishing the rear, southern portion of the building to accommodate an eight-story addition. No rehabilitation or repair would occur on the Fred Turner Building under the Preservation Alternative. The Fred Turner building will remain in its current state.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 5.

Rehabilitation Standard 6

Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

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The very significant, significant, or contributing character-defining features of the Fred Turner Building’s main, street-facing façade, such as its stucco siding, decorative copper-clad window hoods and ornamentation, arched arcade entrance, fenestration pattern, and materials, would be retained in their current condition under the Preservation Alternative. Deteriorated features would remain in place and not restored or replaced. The rear of the building, which was altered in the 76 years following construction, would remain in its current condition and retain its current use.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 6.

Rehabilitation Standard 7

Chemical or physical treatments, if appropriate, would be undertaken using the gentlest means possible. Treatments that cause damage to historic materials would not be used.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 7.

Rehabilitation Standard 8

Archaeological resources would be protected and preserved in place. If such resources must be disturbed, mitigation measures would be undertaken.

Archaeological resources are not expected to be found on the project site, as the area for proposed construction has been disturbed by prior development, including excavation of an underground parking facility under Bancroft Center, and other development-related activities. However, the proposed project does include excavation work under the rear portion of the Fred Turner Building. If any archaeological material should be encountered during this project, construction should be halted and appropriate mitigation measures taken to identify and avoid, or substantially lessen, potential impacts.

The Preservation Alternative would be compliant with Rehabilitation Standard 8.

Rehabilitation Standard 9

New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale, proportion, and massing to protect the integrity of the property and its environment.

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As described above in Scenario A, the Fred Turner Building was intentionally sited in a bustling commercial and institutional setting. The size and scale of a proposed ten-story building, east of and adjacent to the Fred Turner Building, would diminish its integrity of setting and feeling of the property and its environment. However, these aspects of integrity are not as critical to conveying the building’s essential physical features as integrity of design, materials, and workmanship. These features and the location of the Fred Turner Building and its association with Ms. Morgan would remain if a proposed ten-story building were built next door. Based on a review of the proposed massing of the new building under the Preservation Alternative, the potential indirect impacts of an adjacent ten-story building next door to the single-story Fred Turner Building would create a more imposing presence and striking contrast in proportion and would further incrementally diminish its integrity of setting and feeling.

Rehabilitation Standard 9 provides two instances where impacts to historic materials, features, size, scale, proportion, and massing of a historic property from proposed adjacent construction are considered. These two instances are discussed below:

1. “Introducing a new building or landscape feature that is out of character or otherwise inappropriate to the setting’s historic character, e.g., replacing picket fencing with chain link fencing (Weeks and Grimmer 1995:108).”

The proposed ten-story building would be, at a minimum, four stories taller than the other buildings located within the same city block. However, located within a one-city block of the project site is the seven-story Durant Hotel at 2600 Durant Avenue; four, nine-story buildings and two, seven-story buildings at 2650 Durant Avenue (U.C. Berkeley Residence Halls Unit 1); and four, nine story buildings at 2400 Durant Avenue (U.C. Berkeley Residence Halls Unit 3).

Therefore, while the proposed ten-story building would be the tallest building within its host city block, it would be the twelfth building taller than seven stories within a one-block radius.

2. “Introducing new construction into historic districts that is visually incompatible or that destroys historic relationships within the setting (Weeks and Grimmer 1995:108).”

The Fred Turner Building is not located within or adjacent to a historic district.

The Preservation Alternative as designed would be compliant with Rehabilitation Standard 9.

7/31/18 8 Rehabilitation Standard 10

New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired. If the proposed ten-story building were constructed east of and adjacent to the Fred Turner Building was later removed, the Fred Turner Building would retain its essential form and integrity of the historic property and its environment would be unimpaired.

As designed, the Preservation Alternative would be compliant with Rehabilitation Standard 10.

CONCLUSION As demonstrated in the 2018 PIA, Scenario A would both “destroy historic materials and features” that characterize the Fred Turner Building through demolition of the rear, southern portion of the building and construct a new eight-story addition in its place and on a parcel east of and adjacent to the Fred Turner Building. The new, eight-story construction behind the remaining front half of the Fred Turner Building would be out of “size, scale, proportion and massing” with the original design of the single-story commercial boutique.

Under Scenario B, the Preservation Alternative will not “destroy historic materials, features” that characterize the Fred Turner Building. The Fred Turner Building will remain in its historical location, altered configuration, and build a taller, ten-story building east of and adjacent to the Fred Turner Building. However, the Preservation Alternative will not rehabilitate or restore the Fred Turner Building and all existing alterations would remain in place.

The proposed ten-story building under the Preservation Alternative would diminish integrity of setting and feeling. However, the incremental degree of diminishment of integrity of setting and feeling by an additional two stories could be perceived as minor when compared to the level of diminishment of integrity of setting and feeling that would result of an imposing eight-story rear addition to the Fred Turner Building and an eight story building next door as proposed by the Project, which the 2018 PIA found not in compliance with the Secretary’s Standards.

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REFERENCES CITED City of Berkeley 2018 Parcel Conditions and Permit History. Electronic document, https://www.cityofberkeley.info/ppop/home, accessed various.

Grimmer, Anne E., and Kay D. Weeks 2010 New Exterior Additions to Historic Buildings: Preservation Concerns. National Park Service Preservation Brief #14. Washington, D.C. Electronic document, https://www.nps.gov/tps/how-to-preserve/preservedocs/preservation-briefs/14Preserve- Brief-Additions.pdf, accessed various.

Hibma, Michael and Kimberley Butt 2018 Project Impacts Analysis of the Standard Project. LSA and Interactive Resources, Point Richmond, California. Electronic document, https://www.cityofberkeley.info/uploadedFiles/Planning_and_Development/Level_3_- _LPC/2018-05-03_LPC_ATT1-B_2580%20Bancroft_CEQA_DEAIR_Appendix%20D%20PIA.pdf, accessed various.

National Park Service 1997 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. U.S. Department of the Interior, Washington, D.C. Electron in version here: https://www.nps.gov/nr/publications/bulletins/pdfs/nrb15.pdf.

Attachment: Figure III-1, 2580 Bancroft Way, Preservation Alternative

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