FINAL ENVIRONMENTAL IMPACT REPORT
FOR THE
MARINA SHORES VILLAGE PROJECT
SCH Number: 2002022076
Prepared by the CITY OF REDWOOD CITY
and
WAGSTAFF AND ASSOCIATES Urban and Environmental Planners
in Association with Fehr & Peers Associates, Inc., Transportation Consultants Bottomley Design and Planning, Urban Designers Environmental Vision, Visual Simulation Consultants Wetlands Research Associates, Consulting Biologists Clearwater Hydrology, Drainage and Water Quality Consultants Illingworth & Rodkin, Inc., Noise Consultants Donald Ballanti, Air Quality Management Consultant Holman & Associates, Consulting Archaeologists EDR, Inc., Governmental Records Search Service (Haz Mat)
June 2003
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CONTENTS
Page
1. INTRODUCTION...... 1-1
1.1 Relationship Between DEIR and Final EIR...... 1-1 1.2 Proposed Project Summary...... 1-1
2. RESPONSES TO COMMENTS ON THE DRAFT EIR ...... 2-1
2.1 List of Draft EIR Commenters...... 2-2 2.2 Summary of Draft EIR Comments by Commenter...... 2-5 2.3 Master Responses...... 2-43 Master Response A: Project Compatibility with Existing Industrial Uses...... 2-45 Master Response B: Airport-Related Land Use, Public Health, and Safety Issues...... 2-53 Master Response C: Water Supply Issues ...... 2-55 Master Response D: Bayfront Study Discussion ...... 2-59 Master Response E: Project Compatibility with Aviation and Industrial Noise...... 2-63 Master Response F: Bird Collision...... 2-66 Master Response G: Project Consistency with "Smart Growth" Concepts...... 2-67 Master Response H: Loss of Peninsula Marina Slips Prior to EIR...... 2-69 Master Response I: Project-Related Affordable Housing Issues ...... 2-70 2.4 Responses to April 1, 2003 Redwood City Planning Commission Meeting Comments on the Draft EIR...... 2-73 2.5 Responses to Written Comments Received During and Immediately After the Draft EIR Public Review Period ...... 2-199
3. REVISIONS TO THE DRAFT EIR ...... 3-1
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1. INTRODUCTION
1.1 RELATIONSHIP BETWEEN DEIR AND FEIR
The final environmental impact report (Final EIR) for the proposed Marina Shores Village project has been prepared by the City of Redwood City in keeping with state environmental documentation requirements set forth in the California Environmental Quality Act (CEQA). The City has prepared the Final EIR pursuant to the CEQA Guidelines, including sections 15086 (Consultation Concerning Draft EIR), 15088 (Evaluation of and Response to Comments) and 15132 (Contents of Final Environmental Impact Report). In conformance with these guidelines, the Final EIR consists of the following two volumes:
(1) the Draft EIR, dated February 28, 2003, which was distributed for public review and comment on March 4, 2003; and
(2) this Final EIR document, which includes a summary listing of all comments submitted to the City in public testimony, letters, memoranda, and e-mails during and immediately after the public review period on the Draft EIR; minutes from the April 1, 2003 public hearing on the Draft EIR conducted by the Redwood City Planning Commission; verbatim versions of the letters, memoranda, and e-mails received during and immediately after the Draft EIR review period; the responses of the EIR authors to environmental issues raised in these oral and written comments; and associated revisions to the Draft EIR.
The summary listing of all comments received and the associated responses in this Final EIR document are correlated to the public hearing minutes and verbatim letters, memoranda, and e- mail by code numbers, which have been posted in the right hand margin of the public hearing minutes and verbatim letters, memoranda, and e-mails.
Both volumes of the Final EIR are available for public review at the City of Redwood City Planning Department, City Hall, 1017 Middlefield Road, First Floor, Redwood City, California; telephone: (650) 780-7241.
Certification of this Final EIR by the City must occur prior to any formal action by the City on the proposed project.
1.2 PROPOSED PROJECT SUMMARY
1.2.1 Proposed Project
This summary should not be relied upon for a thorough understanding of the details of the
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project, its individual impacts, and related mitigation needs. Please refer to chapter 3 (Project Description), chapters 4 through 15 (identified impacts and associated mitigation measures), and chapter 17 (alternatives to the project) of the February 2003 Draft EIR, and associated revisions in section 3 of this Final EIR document (Revisions to the Draft EIR), for a more complete description of the proposed project.
The project applicant, Glenborough-Pauls, LLC, has proposed the Marina Shores Village project on a site comprised of two non-contiguous properties known as Peninsula Marina (approximately 33.24 acres, including 14.10 acres of water) and Pete's Harbor (approximately 13.21 acres, including 2.90 acres of water) located in the Bair Island Road area of Redwood City, near the confluence of Redwood Creek and Smith Slough.
The proposed development program includes a mix of approximately 1,930 housing units, 300,000 square feet of office floor area, and 12,000 square feet of retail space, in an array of multi-story structures up to 21 stories, most atop 2- to 3-story above-grade parking podiums, plus support facilities, including parking, public open space, pedestrian plazas and paths, private recreational space, and other on-site amenities. The development program also includes the reduction and reconfiguration of the two marina areas from an existing total of approximately 17.00 acres to a future total of approximately 5.46 acres of water. It is anticipated that project development would be phased over approximately ten years.
Implementation of the project as currently proposed would require City approval of a General Plan Amendment (GPA) as well as a Precise Plan (see subsection 4.3.2.b in chapter 4, Land Use, for an explanation of the GPA and Precise Plan), among other entitlements, in order to permit the proposed residential use of the Peninsula Marina portion of the project site and to create a new residential designation allowing development of the residential portion of the project at an average density as high as 65 dwelling units per acre, which would exceed the current General Plan-permitted maximum density of 40 units per acre.
1.2.2 Required Approvals from the City of Redwood City
Implementation of the proposed Marina Shores Village project would require the following approvals from the City of Redwood City:
(a) Certification of the final environmental impact report (FEIR) for the proposed project;
(b) Approval of a General Plan Amendment (GPA) in order to permit residential uses on the Peninsula Marina portion of the project site and create a new high-density residential designation that would allow development of the residential portion of the project at an average density as high as 65 dwelling units per acre; (c) Approval of a Precise Plan;
(d) Possible approval of a Development Agreement (in addition to a Precise Plan);
(e) Design Review (Architectural) Permit approval;
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(f) Subdivision map review and approval;
(g) Improvement plan review and approval;
(h) Grading permit approval;
(i) Building permit approval; and
(j) Various water and sewer hook-up permit approvals.
1.2.3 Other Required Approvals and Consultations
The project is also expected to require approvals from the following trustee and responsible agencies:
(a) City/County Association of Governments of San Mateo County (C/CAG) (in both its designated role as the County's Congestion Management Agency and Airport Land Use Commission);
(b) San Francisco Bay Conservation and Development Commission (which is authorized to control Bay filling and dredging and Bay-related shoreline development on lands within its jurisdictional boundary, including a 100-foot band along the Uccelli Boulevard edge of the Pete's Harbor property--see Figure 8.1 in chapter 8 of this EIR);
(c) The San Francisco Regional Water Quality Control Board (certification responsibility under section 401 of the Clean Water Act);
(d) State Lands Commission (trustee agency) (possible permit authority for land at the outer edge of Pete's Harbor owned by the State and subject to a State Lands Commission land lease);
(e) State Department of Fish and Game (trustee agency) (including a possible stream alteration agreement for proposed modifications to the Smith Slough and Redwood Creek shorelines);
(f) Caltrans (encroachment permit approval for utility line extensions under U.S. 101);
(g) U.S. Army Corps of Engineers (wetlands fill permit under section 404 of Clean Water Act, and possibly a river/harbor modification permit under section 10 of the Rivers and Harbors Act);
(h) U.S. Fish and Wildlife Service (consultation with Army Corps of Engineers as part of the Section 404 permit process);
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(i) U.S. Environmental Protection Agency (possible review authority under section 404[b][1] of Clean Water Act);
(j) National Marine Fisheries Service (consultation with Army Corps of Engineers as part of the Section 404 permit process); and
(k) Federal Aviation Administration.
Other potentially required approvals, based on final project plans and operational characteristics, could include:
(l) State Department of Boating and Waterways;
(m) State Water Transportation Authority; and
(n) U.S. Coast Guard.
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2. RESPONSES TO COMMENTS ON THE DRAFT EIR
After completion of the Draft EIR, the Lead Agency (the City) is required under CEQA Guidelines sections 15086 (Consultation Concerning Draft EIR) and 15088 (Evaluation of and Response to Comments) to consult with and obtain comments from other public agencies having jurisdiction by law with respect to the project, and to provide the general public with an opportunity to comment on the Draft EIR. Under CEQA Guidelines section 15088, the Lead Agency is also required to respond in writing to substantive environmental points raised in this Draft EIR review and consultation process.
The Draft EIR, dated February 28, 2003, was distributed for public review and comment on March 4, 2003. The required 45-day public review period (for state review) on the Draft EIR also began on March 4, 2003. A public hearing to consider the adequacy of the Draft EIR was conducted by the City of Redwood City Planning Commission on April 1, 2003. The state- mandated 45-day public review period on the Draft EIR ended on April 17, 2003.
Comments on the Draft EIR were submitted in the form of public testimony received at the April 1, 2003 Planning Commission public hearing and letters, memoranda, and e-mails received by the City during and immediately after the Draft EIR public review period. Seven Planning Commissioners, 14 individuals from the public, and two applicant representatives commented at the April 1, 2003 Planning Commission meeting. Thirty-seven (37) letters, memoranda, and e-mails were received, including 28 received during, and nine received after the close of, the 45-day public review period.
CEQA Guidelines section 15132 (Contents of Final Environmental Impact Report), subsection (b), requires that the Final EIR include the full set of "comments and recommendations received on the Draft EIR either verbatim or in summary"; section 15132, subsection (c), requires that the Final EIR include "a list of persons, organizations, and public agencies commenting on the Draft EIR"; and section 15132, subsection (d), requires that the Final EIR include "the responses of the Lead Agency to significant environmental points raised in the review and consultation process." In keeping with these guidelines, this Responses to Comments chapter includes the following sections:
a list of commenters (section 2.1) which lists alphabetically each person, organization, and public agency that testified during the April 1, 2003 Planning Commission meeting or submitted written comments to the City during and immediately after the Draft EIR public review period;
a summary of the Draft EIR comments by commenter (section 2.2) that summarizes the environmental topics addressed by each Draft EIR commenter, and identifies the comment by a code number that is keyed to the City's response to the comment in
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sections 2.3 through 2.5 of this chapter;
a master responses section (section 2.3) that provides a consolidated response ("Master Response") to each of a number of key issues or areas of concern on which multiple comments were received during and immediately after the Draft EIR public review period; and
the responses to Draft EIR comments sections (sections 2.4 and 2.5), which: repeat the summary of each oral comment from the April 1, 2003 Planning Commission meeting on the Draft EIR, followed by the written response of the City to each oral comment (section 2.4); and repeat the summary of each written comment (letters, memos, and e- mails) received followed by the written response of the City to each written comment (section 2.5).
2.1 LIST OF DRAFT EIR COMMENTERS
The public agencies, organizations, individuals, and Planning Commission members who commented on the Draft EIR at the April 1, 2003 Planning Commission meeting, and in written form during and immediately after the Draft EIR public review period, are listed below alphabetically (each Planning Commission meeting commenter and each letter, memo, or e- mail received are identified by a code (e.g., PC 3, PC 7, 12, 18, etc.--in parentheses).
2.1.2 Individuals and Organizations
(Note: All street addresses are in Redwood City, unless otherwise noted.)
Marilyn Anderson, 2138 Hillcrest Road (3) Jack Castle (PC 6) Mike Claire, Vice President of Construction, Canada College (PC 9) The Cossins, 459 Marin Drive, Burlingame (6) Tom Cronin, Redwood City resident (PC 11) Patricia Dixon, Redwood Shores resident (PC 8, 12) Kay Eckhardt (PC 16) Claire Felong (1) Greg Greenway, Executive Director, Seaport Industrial Association (PC 10, 17) James Jonas, Docktown resident (PC 4) Linda Kresge, Chief Nurse, Sequoia Hospital (PC 12) Matt Leddy, 275 D Street (8, 9, 10, 11) Alison Mader, Director, Development, The Irvine Company Apartment Communities (36) Clem Maloney, Lyngso Garden Materials; Secretary, Seaport Industrial Association (PC 5) Whitman F. Manley and Sabrina V. Teller, Remy, Thomas, Moose and Manley, LLP, Attorneys, representing Sims-LMC (24) Christopher S. Mann, Director of Real Estates Services, Granite Rock Company (PC 7, 25) Kilicaslan Mertan, Marina Pointe homeowner, 305 Louis Lane (21)
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Nina Miller (30) Christopher Mohr, Executive Director, Housing Leadership Council of San Mateo County (27) Joe P. Morey, Jr., President, Peninsula Building Materials Co. (14) Nancy Oliver, 147 Belvedere Avenue, San Carlos (22) John and Nena Padley, 211 36th Avenue, Apt. B, San Mateo (32) Audrey C. Rust, President, Peninsula Open Space Trust (20) Neena Sessa (13) Paul Shepherd, Land Manager, Cargill Salt (16) Randall Smith, Vice President, Real Estate & Facilities, Oracle Corporation (4) Robin Smith, Sequoia Audubon Society for San Mateo County (PC 14, 23) Judy Sullivan, Redwood City resident and employee (PC 17) Vic Thomas, President, Lyngso Garden Materials (26; also see PC 5) Teri Tith, 236 Shorebird Circle (5) Ray Wang, Redwood City resident (PC 19) Jim Woolridge, President, San Carlos Airport Pilots Association (PC 18, 18) Leslie Young (29)
2.1.3 Responsible and Interested Agencies
California Department of Transportation (Caltrans); Timothy C. Sable, District Branch Chief (19) California Governor's Office of Planning and Research, State Clearinghouse; Terry Roberts, Director (31, 35) City/Council Association of Governments of San Mateo County (C/CAG); Garrett Dunwoody, C/CAG Consultant (2) City/Council Association of Governments of San Mateo County (C/CAG) Airport Land Use Commission (ALUC); Richard Newman, Chairperson (28) Redwood City School District; Ronald F. Crates, Ed.D., Superintendent (7) San Francisco Bay Conservation and Development Commission (BCDC); Andrea M. Gaut, Coastal Program Analyst (34), and Ellen Miramontes, Bay Design Analyst (37) San Mateo County Transit District (SamTrans); Erik Olafsson, Senior Planner, Strategic and Long Range Planning (15), and Ian B. McAvoy, Deputy Chief of Development (33)
2.1.4 City of Redwood City Planning Commission
Commissioner Rosanne Foust (PC 26) Commissioner Ralph A. Garcia, Jr. (PC 22) Commissioner Kenneth McCoy (PC 2, PC 25) Commissioner Hilary Paulson (PC 20) Commissioner Tamara Piulle (PC 21) Commissioner Nancy Radcliffe (PC 24) Commissioner John D. Seybert (PC 23)
2.1.5 Applicant
Tim Ridner, Director of Development, Glenborough-Pauls (PC 1) Paul Powers, Glenborough-Pauls (PC 15)
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2.2 SUMMARY OF DRAFT EIR COMMENTS BY COMMENTER
Planning Commission Regular Meeting of April 1, 2003:
A public hearing on the Draft EIR was held at the regular meeting of the Redwood City Planning Commission on April 1, 2003. All comments made at the meeting pertaining to the EIR are coded, listed, and summarized below.
Response Name/Agency Code Issues and Concerns
PC 1. Tim Ridner, Director of PC 1.01 General comment: EIR thoroughly analyzes impacts; Development, very conservative approach taken; various Glenborough-Pauls alternatives analyzed; not a marketing piece for the project.
PC 2. Commissioner PC 2.01 CEQA-Required Assessment Considerations--significant Kenneth McCoy unavoidable impacts: question regarding relationship between EIR-identified “significant unavoidable impacts,” certification of EIR, and potential approval of a project.
PC 2.02 Water Service--impacts and mitigation measures: question regarding timing of water supply verification and tentative subdivision map approval.
PC 2.03 Water Service--impacts and mitigation measures: can demolition or soil grading occur if water supply has not been verified?
PC 3. Commissioner John PC 3.01 Water Service--impacts and mitigation measures: D. Seybert questions regarding water supply and relationship between Senate Bill (SB) 610 and SB 211.
PC 4. James Jonas, PC 4.01 Noise--impacts and mitigation measures: for Docktown Docktown Resident residents, construction noise impacts will be substantial; if construction lasts months or years, substantial impact on Docktown property valuation could result; “much more detailed [noise] analysis” recommended.
PC 4.02 Noise--impacts and mitigation measures: EIR noise mitigation insufficient; “continuous [noise] monitoring” and “monitoring program” recommended.
PC 4.03 Air Quality, and PC 5.01 Land Use--impacts and mitigation measures: Transportation and compatibility of proposed project with existing nearby Circulation--impacts industrial uses “is definitely a significant impact”;
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and mitigation Bayfront Study acknowledges existing industry’s measures: concerns importance. regarding dust, southerly winds, PC 5.02 Transportation and Circulation--impacts and mitigation bicycle traffic measures: EIR does not include U.S. 101 (welcomed), and southbound on-ramp at Seaport Boulevard. Blomquist Extension.PC 5. PC 5.03 Transportation and Circulation--impacts and mitigation measures: expected back-up on Whipple at Veterans will result in drivers using Blomquist- Seaport route to U.S. 101 south; expanded left-turn pocket may be needed at Seaport on-ramp.
PC 5.04 Transportation and Circulation--impacts and mitigation measures: incompatibility between proposed commute vehicles and existing large delivery trucks on Blomquist Street is a significant impact.
PC 5.05 Project Consistency With Adopted Plans and Policies-- current Redwood City Bayfront Study: EIR refers to “Bayfront Study as an important planning document,” but study was not available when requested.
PC 5.06 Land Use--impacts and mitigation measures: “neighborhood compatibility is important”; tenants “need to be made fully aware of the neighborhood that they are moving into.”
PC 6. Jack Castle PC 6.01 Land Use and Visual Factors--impacts and mitigation measures: other cities have “benefited greatly” from infill projects with tall buildings. Hopefully, the EIR analysis and mitigation process can allow for tall buildings in Redwood City.
PC 7. Chris Mann, Director PC 7.01 General Comment: in the EIR, “everything around within of Real Estate, a mile radius didn’t seem to get addressed.” Granite Rock PC 7.02 Transportation and Circulation--impacts and mitigation measures: EIR traffic analysis should include future full occupancy of Pacific Shores offices.
PC 7.03 Land Use, Noise, Air Quality--impacts and mitigation measures: nearby industries operate 24 hours a day, and contribute noise and dust to area; project residents might complain about historical and ongoing industrial conditions; willing to work with developer on disclosure documents for future residents.
PC 8. Pat Dixon, Redwood PC 8.01 Noise--impacts and mitigation measures: noise analysis
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Shores Resident does not address noise “carry[ing] over the wetlands” or noise resulting from the airport landing pattern; “I have not seen a noise study done.”
PC 8.02 Soils and Geology--setting, impacts and mitigation measures: project area is all filled land; can something this size be built on that land?
PC 8.03 Transportation and Circulation--impacts and mitigation measures: will there be an additional 75-second wait at most of the intersections?
PC 8.04 Water Service, Sewer Service, and Parks and Recreation--impacts and mitigation measures: insufficient water, sanitary lines, and lack of bike trail not addressed in Draft EIR.
PC 8.05 Transportation and Circulation--setting, impacts and mitigation measures: existing rail lines along Seaport Boulevard “should be converted to light rail” that could run along Blomquist Street “to the far end of Pacific Shores,” which would alleviate traffic.
PC 8.06 General Comment: “It is a lovely project but just not for that particular location.”
PC 9. Mike Claire, Vice PC 9.01 Population, Housing, and Employment--impacts and President of mitigation measures: “on behalf of the college, Construction, Canada finding housing that is attractive is very difficult and is College a key obstacle in terms of attracting and retaining faculty and staff.”
PC 10. Greg Greenway, PC 10.01 Population, Housing, and Employment--impacts and Executive Director, mitigation measures: general support for project, Seaport Industrial particularly affordable housing component and Association proposed public space; following comments intended to “improve the EIR as a technical document that is part of a good planning process.”
PC 10.02 Land Use and Current Redwood City Bayfront Study--impacts and mitigation measures: Bayfront Study purpose is to address development areawide, rather than project-by-project; study not yet available; study should be part of significance criteria regarding potentially significant impacts; Bayfront Study process has stressed compatibility between heavy industry, light industry, and residential uses.
PC 10.03 Land Use, Visual Factors, and Noise--impacts and mitigation measures: “EIR does not take a realistic
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view of the compatibility issues between heavy industrial uses in the Seaport area and this new residential development”; distance between uses across open water and marshland “does not render those impacts insignificant.”
PC 10.04 Visual Factors and Noise--setting, impacts and mitigation measures: adequate existing baseline required to assess cumulative light, noise, and other environmental impacts.
PC 10.05 Land Use--impacts and mitigation measures: if potentially significant land use compatibility impacts are found, the EIR should include pertinent mitigation; Pacific Shores and West Point Marina mitigation requiring berms, extensive sound-proofing, and notification of tenants regarding nearby industry, should also be considered for Marina Shores Village project.
PC 10.06 Transportation and Circulation--impacts and mitigation measures: cumulative traffic impacts (e.g., with Pacific Shores project) and mitigation should be coordinated with Bayfront Study areawide traffic alternatives analysis and recommendations.
PC 11. Tom Cronin, Redwood PC 11.01 Population, Housing, and Employment; and Parks City Resident and Recreation--impacts and mitigation measures: support for developer’s voluntary provision of 15 percent “affordable” residential units, and for public accessibility to currently underutilized waterfront.
PC 11.02 Water Service--impacts and mitigation measures: water supply “is the biggest single issue”; quotes from Draft EIR provided; City should consider mandatory use of recycled water.
PC 12. Linda Kresge, Chief PC 12.01 Population, Housing, and Employment; and Public Nurse, Sequoia Health and Safety--setting, impacts and mitigation Hospital measures: “Our recruitment efforts have been hampered by nurses’ inability to find affordable housing”; emergency departments need nurses in order to stay open; project could provide local housing for nurses who now commute long distances.
PC 12.02 Transportation and Circulation--impacts and mitigation measures: related to comment 12.01, if nurses lived closer to local work areas and had shorter commutes, wouldn’t traffic be impacted in a
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positive way?
PC 13. Tom Passanisi, PC 13.01 Project Consistency With Adopted Plans and Principal Planner, City Policies--Current Redwood City Bayfront Study: of Redwood City response to various comments tonight to clarify content and timing of Bayfront Study (no longer considered a Bayfront Plan); graphics being added to text, then staff review, then public review, then Planning Commission meeting; also may incorporate some of tonight’s comments; Planning Commission will review before EIR is certified.
PC 14. Robin Smith, Sequoia PC 14.01 Biological Resources--setting, impacts and Audubon Society for mitigation measures: Bair Island being restored for San Mateo County three endangered species--tern, California rail, and salt marsh harvest mouse; project on western flyway for migrating birds, which EIR does not address; EIR does not address other birds (e.g., swallows) currently using project area.
PC 14.02 Biological Resources--impacts and mitigation measures: “lighting pointing downward” is not enough mitigation to avoid bird strikes into project windows.
PC 14.03 CEQA-Required Assessment Considerations-- significant unavoidable impacts and cumulative impacts: cumulative effect of “significant unavoidable impacts” not reflected in the EIR.
PC 15. Paul Powers, PC 15.01 Transportation and Circulation--impacts and Glenborough-Pauls mitigation measures: project location is within three- to-four miles of approximately 93,000 jobs, so shorter commutes would result from potential Marina Shores Village residents who are employed within this radius.
PC 15.02 General PC 16.01 Population, Housing, and Employment--impacts and Comment: EIR mitigation measures: a larger project with 15 percent purpose is to “affordable” residential units will address the “measure very Peninsula’s affordable housing shortage more than conservatively all of would a smaller project with 15 percent affordable the negative impacts”; units. positive attributes of project will be PC 16.02 Introduction--EIR purpose and intended use: 1970 presented by California Environmental Quality Act (CEQA) developer at a later Guidelines “are inadequate and incomplete and date.PC 16. outdated.”
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PC 16.03 Hydrology and Water Quality--impacts and mitigation measures: if recycled water program is expanded, contaminants, microbes, and radioactivity in the bay will not be removed with chlorine; EIR has no medical expert; who will clean up the contamination--the developer, the taxpayer, or is there some other method?
PC 17. Judy Sullivan, PC 17.01 Population, Housing, and Employment--impacts and Redwood City mitigation measures: EIR adequately describes Resident and housing deficiency; in addition, “not only will Marina Employee Shores Village offer new housing stock, but those of us moving there will be freeing existing housing for families.”
PC 18. Jim Woolridge, PC 18.01 Noise--setting: Draft EIR noise analysis is deficient President, San Carlos (noise measurements made on weekdays, not Airport Pilots weekends; in winter, not summer; close to ground, Association not from air where planes are and project towers will be).
PC 18.02 Noise--impacts and mitigation measures: “Draft EIR does not analyze the noise effects of the [airplane] traffic pattern in general.”
PC 18.03 Noise--setting, impacts and mitigation measures: Draft EIR does not discuss single-event noise and early morning and late evening take-offs.
PC 18.04 Noise--setting, impacts and mitigation measures: existing noise measurement peaks assumed to be from aircraft; “not clear what mitigation measures will be effective at ground level or where residents sleep.”
PC 18.05 Public Health and Safety--impacts and mitigation measures: “Overflight[s] at 200-to-300 feet above the building[s] will have a significant safety, fear, and distress impact”; Draft EIR does not adequately document or mitigate.
PC 18.06 Public Health and Safety--impacts and mitigation measures: Federal Aviation Administration (FAA) determined that any project “height above 195 feet would warrant a hazard to air navigation”; Draft EIR “should have included the FAA’s required review and its determination and proposed mitigation.”
PC 19. Ray Wang, Redwood PC 19.01 Land Use--setting: comment regarding sustainable City Resident growth and City’s “compact with Bay Area Alliance.”
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PC 19.02 Land Use--setting, impacts and mitigation measures: comment regarding Redwood City’s overall philosophy related to “pro-growth” versus “sustainable growth.”
PC 19.03 CEQA-Required Assessment Considerations-- cumulative impacts: project should be considered “in a more holistic fashion” in context of other Redwood City projects (e.g., Sequoia, Kaiser, Abbott Labs, downtown cinema and housing units).
PC 20. Commissioner Hilary PC 20.01 Project Description--basic project objectives: EIR Paulson (p. 3-9) needs to state more clearly that project goals are applicant’s goals, not the City’s.
PC 20.02 Project Description--EIR (p. 3-10) needs to be consistent about tower heights (e.g., 21 stories over 2 stories parking versus 23 stories); also (p. 3-26), “why does Pete’s Harbor section not need a flushing channel like the other marina is getting?”
PC 20.03 Transportation and Circulation--impacts and mitigation measures: referring to Draft EIR p. 3-30, “does the number parking spaces to be provided meet the current Zoning Ordinance requirement for parking?”
PC 20.04 Visual Factors--setting, and impacts and mitigation measures: Figure 4.1 (Existing Land Use Context) should show existing building heights or number of stories.
PC 20.05 CEQA-Required Assessment Considerations-- significant unavoidable impacts: must City Council adopt a “statement of overriding considerations” for a significant unavoidable impact?; should read “may adopt”; also check for consistent use of “overriding considerations” text in each “significant unavoidable impact” box in EIR.
PC 20.06 Land Use--impacts and mitigation measures: “smart growth” discussion (p. 4-33) inconsistency regarding infill development near, next to, or within walking distance of a transportation hub.
PC 20.07 Land Use--impacts and mitigation measures: referring to Draft EIR p. 4-36 (cumulative land use impacts), “why is this [project] not a cumulative land use development...when you already are over your
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water allotment?”
PC 20.08 Visual Factors--impacts and mitigation measures: referring to Draft EIR p. 5-24, Mitigation 5-2, visual simulation or figure depicting 50-foot height limit requested.
PC 20.09 Visual Factors--impacts and mitigation measures: referring to Draft EIR p. 5-37, “don’t understand” architectural language; clarify or provide picture.
PC 20.10 Population, Housing, and Employment--impacts and mitigation measures: referring to Draft EIR p. 6-13, Mitigation 6-1 (regarding project-related resident population growth), list all specific mitigation measures referred to in mitigation box.
PC 20.11 Biological Resources--pertinent plans and policies: referring to Draft EIR p. 8-26, “why does BCDC [Bay Conservation and Development Commission] not have jurisdiction over the entire project?”
PC 20.12 Biological Resources--impacts and mitigation measures: Draft EIR does not adequately discuss cumulative effect on the bay; note that replacement open water/wetlands need not be located in Redwood City.
PC 20.13 Biological Resources--impacts and mitigation measures: referring to Draft EIR p. 8-37, disagreement with conclusion regarding “very small elimination of the available waterbird foraging habitat”; “any additional loss should be considered significant.”
PC 20.14 Biological Resources--impacts and mitigation measures: Mitigation 8-8 (regarding project-related bird collisions), which would result in a “significant unavoidable impact,” is used to create a “less-than- significant impact” for Impact 8-9 (Project-Related General Outdoor Lighting Impacts on Biological Resources); not sufficient mitigation.
PC 20.15 Biological Resources--impacts and mitigation measures: Mitigation 8-10 (regarding project-related introduction of invasive, non-native plants) needs to state more clearly what landscaping should be allowed.
PC 20.16 Water Service--impacts and mitigation measures:
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referring to Draft EIR p. 10-10, how big will the required water storage tank be and how will it be taken care of?
PC 20.17 Sewer Service--setting, impacts and mitigation measures: clarify differences between dry and wet weather sewage capacity.
PC 20.18 Police Service--impacts and mitigation measures: referring to Draft EIR p. 10-22, will new police officers be funded by general fund or project applicant?
PC 20.19 Fire Protection/Emergency Medical Services-- setting, impacts and mitigation measures: referring to Draft EIR p. 10-24, response time should be considered a significant impact, based on additional future traffic in area; additional mitigation required.
PC 20.20 Schools--setting, impacts and mitigation measures: “section needs to be updated in light of the current budget cuts.”
PC 20.21 Schools--setting, impacts and mitigation measures: Orion School, though nearest to project site, would not be project’s neighborhood school; EIR needs to identify appropriate school, distance from project site, and availability.
PC 20.22 Parks and Recreation--impacts and mitigation measures: referring to Draft EIR p. 10-35, definition of “usable open space” needs clarification; does this includes tree boxes, planters, and people’s patios?
PC 20.23 Parks and Recreation--impacts and mitigation measures: referring to Mitigation 10-8 (regarding project impacts on parks and recreation services), Draft EIR p. 10-37, parks and recreation commissioners should be included in Precise Plan formulation.
PC 20.24 Soils and Geology--impacts and mitigation measures: please define “redox potential” (p. 11-19); Mitigation 11-5 (regarding corrosive soils) does not say how materials will be protected from corrosive soil.
PC 20.25 Alternatives to the Proposed Project: more pictures requested, particularly for Alternative 8 (Residential/Commercial--Reduced Residential and Reduced Commercial to Permit No Marina Fill).
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PC 20.26 Alternatives to the Proposed Project: why is there no alternative for buildout under current zoning with no marina fill?
PC 21. Commissioner PC 21.01 Noise--impacts and mitigation measures: concern Tamara Piulle about “canyon effect” of noise at “Villas at Bair Island” residences; Marina Shores Village towers would surround those residences, and noise would not be able to escape.
PC 21.02 Water Service--impacts and mitigation measures: Mitigation 10-1 (regarding project-related and cumulative municipal water service demand) needs to specify where recycled water will be used (e.g., landscaping, toilets).
PC 21.03 Sewer Service--impacts and mitigation measures: referring to Draft EIR p. 10-17, would the City’s option to purchase 2.1 millions gallons per day (mgd) of sewage treatment capacity accommodate only the proposed project, or would it also cover other projects, such as Abbott Labs?
PC 21.04 Project Description--proposed circulation/shuttle bus system; and Transportation and Circulation--impacts and mitigation measures: referring to Draft EIR p. 3- 26, when would shuttle bus system be implemented (e.g., end of project buildout, or as housing is built over time)?
PC 21.05 Alternatives to the Proposed Project--Alternative 6 (residential/commercial--same residential, reduced commercial, with reduced building heights, reduced marina fill, added hotel, and increased retail, plus transit and transportation demand management provisions): regarding noise “canyon effect” (see comment 21.01), recommend that taller housing be located at Peninsula Marina, with scaled down Pete’s Harbor property.
PC 22. Commissioner Ralph PC 22.01 General Comment: still reading and gathering A. Garcia, Jr. information from fellow commissioners; no further comment.
PC 23. Commissioner John PC 23.01 Project Consistency With Adopted Plans and D. Seybert Policies--current Redwood City Bayfront Study: “how did the EIR consider...the Bayfront Study when it’s not been officially recognized?”; important to consider the Bayfront Study.
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PC 23.02 Visual Factors--impacts and mitigation measures: referring to Mitigation 5-4 (regarding potential light and glare impacts), request for additional discussion of project’s nighttime impacts, especially on views from hillside areas; any computer simulation to show that?
PC 23.03 General Comment: regarding disclosures in sales materials to prospective residents, “I am a little concerned that sales materials end with the person who first buys property”; sample areas pertinent to disclosure include nearby industries, noise, dust, and airport operations; disclosure process must be honest.
PC 23.04 Transportation and Circulation--impacts and mitigation measures: Mitigation 7-2 [regarding transportation demand management (TDM) program] should discuss further consequences or actions if TDM program is not effective.
PC 23.05 Parks and Recreation--impacts and mitigation measures: suggestion that water area of proposed project be considered part of parks and open space (see Impact 10-8); can a table show different types of project open space?
PC 23.06 CEQA-Required Assessment Considerations-- significant unavoidable impacts: referring to p. 18-2, Impact 4-2 (regarding project compatibility with adjacent residential land uses) is missing from the list of significant unavoidable impacts.
PC 23.07 Alternatives to the Proposed Project: Table 17.1 (Alternative 7 column) accidently reverses words “more” and “less” in description.PC 23.08 Introduction--EIR purpose and intended use: CEQA was created in 1970, but has been updated continuously since 1970.
PC 24. Commissioner Nancy PC 24.01 Project Description--proposed project Radcliffe characteristics: Outer Pete’s Harbor marina is subject to a State Lands Commission land lease that expires in June 2033; what would happen to the marina after 2033?
PC 24.02 Soils and Geology--setting, impacts and mitigation measures: if project site soil is very corrosive, should excavated soil be used for fill?
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PC 24.03 Visual Factors--impacts and mitigation measures: concerns over shadow effects on Bair Island, nearby residences, and Seaport businesses.
PC 25. Commissioner PC 25.01 Population, Housing, and Employment; and Kenneth McCoy Transportation and Circulation--impacts and mitigation measures: referring to Draft EIR p. 6-11, estimated 3,262 employed residents at proposed project may be understated, which would result in greater traffic generation than described on Draft EIR p. 7-41.
PC 25.02 Soils and Geology--impacts and mitigation measures: referring to p. 11-19, paragraph regarding corrosive soils is confusing; what would be form of corrosive protection?; would cathodic protection interfere with other infrastructure on-site (e.g., sewer lines, power distribution, overhead power lines)?; discussion “should be expanded on significantly.”
PC 26. Chairwoman Rosanne PC 26.01 Land Use--setting, impacts and mitigation Foust measures: Figure 4.1 (Existing Land Use Context) should include square footages and heights of existing development, to compare with future proposed development.
PC 26.02 Land Use--pertinent plans and policies: note that Strategic General Plan last adopted in 1990; portions of the General Plan, including zoning districts, have been updated over time; recommends “reflection on what has changed in specifically the land use categor[ies] of the General Plan.”
PC 26.03 Land Use--impacts and mitigation measures: regarding smart growth (see Draft EIR p. 4-23), clarify relationship between proposed project’s inconsistencies with smart growth and associated Mitigation 4-3.
PC 26.04 Transportation and Circulation--pertinent plans and policies: request to have traffic component of Bayfront Study available before end of public comment period.
Review Period Written Comments:
The 28 letters, memos, and e-mails received during the Draft EIR public review period are listed below, with all comments pertaining to the EIR coded and summarized.
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1. Claire Felong; undated 1.01 Population, Housing, and Employment--impacts and mitigation measures: desire for continued residential boat slips in marina[s].
1.02 Schools--impacts and mitigation measures: a shuttle between the project site and schools must be provided.
1.03 Schools--impacts and mitigation measures: representatives from the parent community and school districts must report to City Council on implications of the project.
1.04 Child Care--impacts and mitigation measures: on-site child care should be provided.
1.05 Population, Housing, and Employment--impacts and mitigation measures: some low-income housing should be provided by the project.
1.06 Transportation and Circulation--impacts and mitigation measures: “Where will the public be able to park?”
1.07 Project Description--proposed project characteristics, and Parks and Recreation--impacts and mitigation measures: “Where will the public be able to picnic, launch a boat, [and] use the shoreline which we own?”
1.08 Transportation and Circulation--impacts and mitigation measures: proposed project phasing must be coordinated with Blomquist Extension construction. 1.09 Transportation and Circulation--impacts and mitigation measures: project should include a pedestrian/bicycle bridge across the freeway.
2. Garrett Dunwoody, 2.01 Transportation and Circulation--impacts and mitigation C/CAG Consultant, measures: C/CAG needs more information to equate City/County Association transportation demand management (TDM) of Governments of San strategies included in EIR with number of trip Mateo County (C/CAG); reduction credits under the Congestion Management March 27, 2003 Plan (CMP).
3. Marilyn Anderson, 2138 3.01 Water Service--impacts and mitigation measures: concern Hillcrest Road, Redwood over water supply; “Redwood City is already over its City; March 28, 2003 allotment from Hetch Hetchy.”
3.02 Sewer Service--impacts and mitigation measures: “are current residents, once again, expected to foot the bill to add the needed additional [sewage] capacity?”
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3.03 Soils and Geology--impacts and mitigation measures: concern over liquefaction during earthquake.
3.04 Public Health and Safety--impacts and mitigation measures: will proximity of San Carlos Airport be a nuisance to future tenants of proposed project, who will then become opponents of an airport that has existed for many years?
3.05 Transportation and Circulation--impacts and mitigation measures: traffic concerns, “with at least 2 drivers (average) per household.”
4. Randall Smith, Vice 4.01 Biological Resources--impacts and mitigation measures: President, Real Estate & Oracle campus has experienced approximately one Facilities, Oracle bird collision mortality per year through 1998, all Corporation; April 4, pigeons; despite many herons, egrets, and other 2003 shore birds, no reports of mortalities of these birds.
4.02 Biological Resources--impacts and mitigation measures: since nesting pair of endangered peregrine falcons arrived at one Oracle rooftop, no incidence of bird collision mortality has occurred.
5. Term Tith, 236 Shorebird 5.01 Biological Resources--impacts and mitigation measures: Circle, Redwood City; concern that EIR does not address impacts on Bair April 8, 2003 Island refuge, including impacts on the endangered clapper rail, least tern, Western snowy plover, and salt harvest mouse, and impacts on migratory birds.
6. The Cossins, 459 Marin 6.01 Biological Resources--impacts and mitigation measures: Drive, Burlingame; April EIR does not address impacts on migratory birds and 11, 2003 local birds (e.g., endangered clapper rail, least tern, snowy plover), and cumulative impacts on local wildlife population.
7. Ronald F. Crates, Ed.D., 7.01 Schools--impacts and mitigation measures: EIR contains Superintendent, “no mitigation regarding a potential increase of the Redwood City School student population and how that will impact Redwood District; April 10, 2003 City School District’s facilities.”
7.02 Schools--impacts and mitigation measures: project applicant has agreed to fund “a student yield study to ascertain the potential number of students generated by the project.”
7.03 Schools--impacts and mitigation measures: school district will not be able to provide facilities in the project area.
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8. Matt Leddy, 275 D 8.01 Noise--impacts and mitigation measures: San Carlos Street, Redwood City; Airport Noise Abatement Procedures “should be an April 12, 2003 essential part of the EIR.”
8.02 Public Health and Safety, and Noise--impacts and mitigation measures: EIR Mitigation 12-1 (regarding safety impacts related to San Carlos Airport) needs to include abatement procedures noted in comment 8.01 and statement regarding permanency of current arrival-departure procedures.
8.03 Noise--impacts and mitigation measures: EIR should include noise contour map from San Carlos Airport Land Use Plan and explain how “shielding” from project structures would lower noise levels from aircraft.
8.04 Noise--impacts and mitigation measures: EIR needs information regarding airport noise levels during critical periods (i.e., people outside, airplanes taking off southward, warm weather, calm winds).
8.05 Noise--impacts and mitigation measures: EIR Mitigation 13- 1 (regarding State Title 24 requirements, including sound-rated windows) assumes that windows will never be open; not realistic.
9. Matt Leddy, 275 D 9.01 Biological Resources--impacts and mitigation measures: Street, Redwood City; concerns regarding shadow impacts on April 12, 2003 phytoplankton productivity in water; EIR conclusion of “no significant impact” should be changed to “potentially significant impact,” with corresponding mitigation.
10. Matt Leddy, 275 D 10.01 Transportation and Circulation--impacts and mitigation Street, Redwood City; measures: EIR does not consider impacts of April 12, 2003 motorists using neighborhood streets to avoid congested Whipple Avenue intersections.
10.02 Transportation and Circulation--impacts and mitigation measures: EIR should analyze following additional “intersections”: El Camino Real/Edgewood Road, Edgewood Road/Alameda de las Pulgas, Edgewood Road between El Camino Real and Alameda de las Pulgas, and Edgewood Road/Cordilleras Road.
10.03 Transportation and Circulation--impacts and mitigation measures: EIR transportation demand management (TDM) strategies are voluntary, and “there is no assurance that they will succeed in mitigating the
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significant traffic impacts.”
10.04 Alternatives to the Proposed Project--Alternative 8, and Transportation and Circulation--impacts and mitigation measures: EIR needs to generate traffic level of service (LOS) ratings for Alternative 8 (Residential/Commercial--Reduced Residential and Reduced Commercial to Permit No Marina Fill) to explain how significant traffic impacts could be mitigated with this alternative to the proposed project.
11. Matt Leddy, 275 D 11.01 Visual Factors--impacts and mitigation measures: “EIR Street, Redwood City; should include a visual simulation of the proposed April 12, 2003 development as viewed from the Bair Island levee trail at the closest point to the project (just across the tidal channel to the north)”
11.02 Biological Resources--impacts and mitigation measures: “EIR should include a reduction in building height as a mitigation measure to avoid bird collision mortality.” 11.03 Land Use--setting, impacts and mitigation measures: EIR omits November 2001 removal of Peninsula Marina boat slips as part of proposed project.
11.04 Population, Housing, and Employment; and Parks and Recreation--setting, impacts and mitigation measures: EIR must thoroughly analyze regional demand for public marina slips; “conclusion of ‘no significant impact’ [EIR p. 4-27] has not been substantiated.”
11.05 Population, Housing, and Employment--impacts and mitigation measures: regarding housing affordability, EIR should define “above moderate-income” and “moderate-income”; EIR should compare current salaries for entry-level “workforce” jobs with moderate-income housing affordability; will moderately priced units remain so in perpetuity?
11.06 Alternatives to the Proposed Project--Alternative 8: EIR should include an alternative similar to #8, but with allowable building heights reduced to 75 feet.
12. Patricia Dixon; April 13, 12.01 Noise--impacts and mitigation measures: concerns 2003 regarding “airport noise bouncing off the buildings”; “Water being both a carrier and magnetizer will send all noise west across [U.S.] 101 and also north over the wetlands (with interference to the wildlife).”
12.02 Transportation and Circulation--impacts and mitigation
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measures: “Listing some [intersections] at level [of service] C or D is ridiculous since most have been at level F since I was on TAC!”
12.03 Air Quality--impacts and mitigation measures: could not find carbon monoxide analysis in EIR; carbon monoxide effects should address wildlife and humans, summer and winter.
12.04 Noise--setting, impacts and mitigation measures: EIR should analyze noise in summer, weekdays and weekends, and at level of approach--not 15 feet above ground.
12.05 Population, Housing, and Employment--housing affordability: applicant’s affordable housing program needs to be thoroughly discussed prior to granting any permits. 12.06 Soils and Geology--impacts and mitigation measures: concerns regarding locating project on “shaky ground.”
13. Neena Sessa; April 13, 13.01 Biological Resources--impacts and mitigation measures: 2003 EIR does not address impacts on migratory birds and local birds (e.g., endangered clapper rail, least tern, snowy plover), and cumulative impacts on local wildlife population.
14. Joe P. Morey, Jr., 14.01 Land Use and Transportation and Circulation--impacts President, Peninsula and mitigation measures: significance criteria should Building Materials Co.; address Bayfront Study, which is an “applicable land April 15, 2003 use plan,” in order to assure compatibility between existing uses and proposed new uses, and to utilize study’s “transportation alternatives” analysis to help mitigate impacts.
14.02 Land Use, Visual Factors, Noise--setting, impacts and mitigation measures: “we are certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “EIR fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light across open water and wetlands; “mitigations might include extensive soundproofing, landscaping and design features to create buffers, and disclosures in leases and to homeowners.”
14.03 Transportation and Circulation--impacts and mitigation measures: “U.S. 101 southbound on-ramp from
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Seaport Boulevard is omitted from the impacted intersections”; “project will have a significant negative impact on this intersection”; an expanded left-turn pocket might mitigate this impact.
14.04 Transportation and 15.01 Transportation and Circulation--impacts and mitigation Circulation--impacts and measures: EIR transportation demand management mitigation measures: an (TDM) measures should be quantified to estimate trip incompatibility will exist reductions. between commute vehicles and large 15.02 Transportation and Circulation--impacts and mitigation delivery trucks on measures: have Abbott Laboratories and Kaiser Blomquist Street; “Such Permanente projects been included in cumulative incompatibility directly traffic analysis, along with “all existing, recently meets the definition of a approved and future developments that would affect significant impact as the [transportation] facilities being evaluated”? defined by this EIR section [Transportation 15.03 Transportation and Circulation--impacts and mitigation and Circulation]”; measures: mitigation measures should discuss mitigations might include financing, scheduling, implementation, and developer monitoring. implementation of “transportation 15.04 Transportation and Circulation--setting: “SamTrans no alternatives” longer offers the RX route to the [project] area” (EIR recommendations from p. 7-18). Bayfront Study. 15. 15.05 Transportation and Circulation--impacts and mitigation measures: “Mitigation 7-2 seems to assume SamTrans financial ability to supply a shuttle to the proposed project.”
15.06 Transportation and Circulation--impacts and mitigation measures: Mitigation 7-7 implies that SamTrans would implement a bus route to the Marina Shores Village site, but “SamTrans is currently in a non- expansion period and may be for a number of years.”
15.07 Transportation and Circulation--impacts and mitigation measures: SamTrans notes significant impacts on U.S. 101 and State Route 84 which would not be fully mitigated by the project sponsor (as listed in chapter 18--CEQA-Required Assessment Considerations, section 18.2--Significant Unavoidable Impacts).
16. Paul Shepherd, Land 16.01 Land Use--setting: correction and clarification to text Manager, Cargill Salt; regarding existing “salt crystallizers” east of Seaport April 15, 2003 Boulevard.
16.02 Land Use--setting: correction to Figure 4.1 (Existing
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Land Use Context) regarding existing “salt crystallizers.” 16.03 Land use--setting: correction and clarification to text regarding existing Cargill Salt lands at the northern terminus of Seaport Boulevard.
17. Greg Greenway, 17.01 Land Use and Transportation and Circulation--impacts Executive Director, and mitigation measures: significance criteria should Seaport Industrial address Bayfront Study, which is an “applicable land Association; April 15, use plan,” in order to assure compatibility between 2003 existing uses and proposed new uses, and to utilize study’s “transportation options” analysis to help mitigate impacts.
17.02 Land Use, Visual Factors, Noise--setting, impacts and mitigation measures: “we are certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “EIR fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light across open water and wetlands; “mitigations might include extensive soundproofing, landscaping and design features to create buffers, and disclosures in leases and to homeowners.”
17.03 Transportation and Circulation--impacts and mitigation measures: “U.S. 101 southbound on-ramp from Seaport Boulevard is omitted from the impacted intersections”; “project will have a significant negative impact on this intersection”; an expanded left-turn pocket might mitigate this impact.
17.04 Transportation and Circulation--impacts and mitigation measures: an incompatibility will exist between commute vehicles and large delivery trucks on Blomquist Street; “Such incompatibility directly meets the definition of a significant impact as defined by this EIR section [Transportation and Circulation]”; mitigations might include developer implementation of “transportation options” recommendations from Bayfront Study.
17.05 Land Use--pertinent plans and policies, and impacts and mitigation measures: Bayfront Study should be referenced in the significance criteria as an “applicable land use plan”; the study has not been available for review.
17.06 Land Use--pertinent plans and policies: according to
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“smart growth” criteria, proposed project is not “transit-oriented development” because it is not within walking distance of a major transit hub.
17.07 Land Use, Visual Factors, and Noise--impacts and mitigation measures: Table 4.3 (Existing Industries in Project Vicinity with Potential Nuisance Conflicts with Proposed Project) should include Port of Redwood City businesses; all incompatibilities listed in the table are “potentially significant.”
17.08 Land Use--impacts and mitigation measures: incompatibilities between proposed residences and neighboring industries might result in future perceived impacts and nuisance complaints “precisely analogous” to those identified in Impact 4- 1 resulting from the existing overhead electrical transmission lines adjacent to the project site.
17.09 Land Use--impacts and mitigation measures: “future nuisance complaints always result when residences are built nearby existing industry.”
17.10 Land Use--pertinent plans and policies: Redwood City Strategic General Plan Land Use Element identifies industry and nearby residential development as incompatible uses.
17.11 Land Use--impacts and mitigation measures: Bayfront Study hearings and Planning Commission comments “clearly favored” compatibility between industry and new projects; any incompatibility should be mitigated.
17.12 Transportation and Circulation--impacts and mitigation measures: interaction of project-generated commuter vehicles and ongoing commercial trucks, and proposed Blomquist bridge to Seaport area, raises safety issues.
17.13 Transportation and Circulation--impacts and mitigation measures: regarding chapter 7 (Transportation and Circulation) appendix, “Moderate Innovation Strategies,” purchase of the Union Pacific right-of- way (for potential alternative transportation solutions) would present potential incompatibilities with industries that use this railroad.
17.14 Transportation and Circulation--impacts and mitigation measures: regarding chapter 7 (Transportation and Circulation) appendix, Exhibit 6 (Trip Reduction
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Toolbox for Employment Centers), adding high occupancy vehicle (HOV) lanes to Seaport Boulevard would present potential incompatibilities, particularly during construction.
17.15 Land Use--impacts and mitigation measures: compatibility issues with Pacific Shores Center (PSC), as described in EIR, are not the same as with Marina Shores Village project (e.g., office vs. residential, mitigation required at PSC, all tenants at PSC notified of nearby industry).
17.16 Land Use--impacts and mitigation measures: City required written notification regarding nearby industry to all tenants and live-aboards at approved West Point Marina.
17.17 Visual Factors and Noise--impacts and mitigation measures: light and noise impacts of nearby industry, particularly at nighttime, “need to be studied empirically.”
17.18 Visual Factors and Noise--setting, impacts and mitigation measures: cumulative light and noise impacts on existing residents during project construction cannot be estimated without an accurate study of existing light and noise.
17.19 Visual Factors and Noise--impacts and mitigation measures: proposed project heights will result in residents having a direct view into industrial yards; light and sound “carry well” across the open water and marshland separating the project site from industry.
17.20 Land Use, Visual Factors, and Noise--impacts and mitigation measures: significant compatibility issues should be mitigated (e.g., with soundproofing, design features, landscaping, written disclosure); EIR already suggests such mitigations for other significant impacts.
17.21 Land Use--impacts and mitigation measures: regarding “smart growth,” “an ‘effective transit link’ [see Mitigation 4-3] might include designated shuttles beyond additional SamTrans buses.”
17.22 Land Use--impacts and mitigation measures: regarding “smart growth” Mitigation 4-3, “an effective link to nearby job centers would provide increased
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mitigation”; a water taxi, first proposed by the project applicant, could provide such a link between the project and Pacific Shores Center.
17.23 Population, Housing, and Employment--impacts and mitigation measures: regarding housing affordability, the Seaport Industrial Association “supports the developer’s commitment to provide at least 15 percent of the project units at below market rates.”
17.24 Transportation and Circulation--impacts and mitigation measures: EIR identifies 14 significant unavoidable traffic impacts; “City should be aggressive in identifying mitigations beyond those listed in the EIR”; traffic impacts should be examined regionally; Bayfront Study “Transportation Options Study” has not been fully incorporated into traffic mitigations.
17.25 Transportation and Circulation--impacts and mitigation measures: regarding Exhibit 5 from the Bayfront Study “Transportation Options Study” (reproduced in EIR chapter 7 appendix), the “Strategy Areas” have not been fully integrated into the EIR as traffic mitigations.
17.26 Transportation and Circulation--impacts and mitigation measures: impacts of the U.S. 101 northbound- Seaport Boulevard east (north)-Seaport/Blomquist intersection route to the proposed project have not been examined.
17.27 Transportation and Circulation--setting: regarding U.S. 101 southbound, Whipple Avenue to Woodside Road, AM peak hour: “level of service under ‘existing conditions’ will worsen when the economy improves, and existing offices are closer to capacity.”
17.28 Transportation and Circulation--impacts and mitigation measures: transportation demand management (TDM) measures will not solve congestion at U.S. 101 southbound exit at Woodside/Seaport.
17.29 Transportation and Circulation--impacts and mitigation measures: cumulative unavoidable traffic impacts should be mitigated by having “all developers within the area contribute [funds] to solutions.”
17.30 Transportation and Circulation--impacts and mitigation measures: regarding emergency access impact (Impact 7-10), does traffic analysis account for
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proposed 600 apartments on Syufy (Century Cinema) property?
17.31 Transportation and Circulation--impacts and mitigation measures: regarding the Blomquist Extension, EIR Secondary Impact 7-10A should extend to Seaport Boulevard.
17.32 Transportation and Circulation--impacts and mitigation measures: same recommendation as comment 17.31.
17.33 Transportation and Circulation--impacts and mitigation measures: some southbound AM commuters from project are likely to use Woodside to access U.S. 101; what are traffic assumptions?
17.34 Transportation and Circulation--impacts and mitigation measures: some northbound PM commuters to project are likely to use Woodside to exit U.S. 101; what are traffic assumptions?
17.35 Transportation and Circulation--impacts and mitigation measures: mitigation should account for trucks leaving driveways and heading south on Blomquist.
17.36 Transportation and Circulation--impacts and mitigation measures: “Will trucks be allowed to cross Blomquist bridge and travel to Whipple?”; will roadway accommodate trucks?”
17.37 Transportation and Circulation--impacts and mitigation measures: same as comments 17.32 through 17.35.
17.38 Transportation and Circulation--impacts and mitigation measures: do cumulative (2020) conditions include the Abbott Labs and Syufy projects (Draft EIR p. 7- 19)?
17.39 Transportation and Circulation--impacts and mitigation measures: ”Woodside freeway interchange is extremely dangerous, and mitigations are required for additional impacts”; statistics from EIR regarding traffic volumes provided; developers should fund extended left turn pocket at freeway interchange.
17.40 Transportation and Circulation--impacts and mitigation measures: EIR-identified additional receiving lane on U.S. 101 southbound on-ramp at Woodside Road “does not by itself address the backup under the
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freeway.”
17.41 Transportation and Circulation--impacts and mitigation measures: “EIR should study the interaction between commuter cars and commercial trucks.”
17.42 Transportation and Circulation--impacts and mitigation measures: “EIR should study the issue of truck access to Blomquist from business driveways on that street.”
17.43 Transportation and Circulation--impacts and mitigation measures: same as comments 17.27 through 17.29.
17.44 Water Service--setting, impacts and mitigation measures: “Given the seriousness of the [water supply] situation,...it would not be prudent for the City to adopt a statement of overriding consideration[s] for this significant unavoidable impact if new sources of water are not generated.”
17.45 Transportation and Circulation, and Fire Protection/Emergency Medical Services--impacts and mitigation measures: regarding emergency response and evacuation impacts, what analysis supports “less-than-significant” impacts if 14 significant unavoidable traffic impacts are identified in the EIR?; emergency response and evacuation analysis must include Seaport Boulevard area.
17.46 Fire Protection/Emergency Medical Services--impacts and mitigation measures: “Impacts on access to Seaport Boulevard in the event of a fire or disaster should be included”; mitigations might include contributions toward a firefighting boat.
17.47 Solid Waste Service--impacts and mitigation measures: "[Seaport Industrial Association] supports the developer’s commitment to recycling.”
17.48 Child Care--impacts and mitigation measures: Seaport Industrial Association “encourages the City to consider giving incentives to the developer to provide adequate child care space or facilities on the project site.”
17.49 Noise--setting, impacts and mitigation measures: existing noise measurements are limited because: (1) “they were not designed to measure noise from industrial uses,” (2) “they were conducted for only
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two days (Wednesday and Thursday nights)”, and (3) “they were conducted at 10 to 12 feet above surrounding ground.”
17.50 Noise--impacts and mitigation measures: additional noise mitigation might include adequate noise buffers, written notification to all tenants regarding nearby noise sources, and relocation of towers away from noise sources.
17.51 Noise--impacts and mitigation measures: regarding cumulative noise impacts from project construction, “reliable data on existing noise conditions” must be presented.
18. Jim Woolridge, 18.01 Noise--setting, impacts and mitigation measures: EIR President, San Carlos noise analysis is deficient for reasons related to: (1) Airport Pilots time that noise measurements were taken Association; April 16, (weekdays, not weekends; winter, not summer; 2003 recently post-9/11); and (2) proximity of proposed residential towers to runway 12 takeoff path.
18.02 Noise--impacts and mitigation measures: Draft EIR does not analyze aircraft noise effects in general.
18.03 Noise--impacts and mitigation measures: no discussion of single-event aircraft noise impacts, especially related to runway 12.
18.04 Noise--setting: EIR existing noise measurements show peaks as high as 73 and 83 dBA, “that we can only assume are aircraft noise”; source of the noise needs to be documented, with associated effective mitigation measures identified.
18.05 Noise--impacts and mitigation measures: “Without adequate disclosure and appropriate easements, there will be many noise complaints from the new development and very unhappy residents.” 18.06 Public Health and Safety--impacts and mitigation measures: “Overflights at 200-300 feet above the building[s] will have a significant safety and fear and distress impact”; EIR needs to document and mitigate; avigation easement (part of Mitigation Measure 12-1) is not a safety measure.
18.07 Public Health and Safety--impacts and mitigation measures: required Federal Aviation Administration (FAA) review of project should be included in EIR.
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19. Timothy C. Sable, District 19.01 Transportation and Circulation--impacts and mitigation Branch Chief, measures: apparent discrepancy between IGR/CEQA, California summation of project trips for U.S. 101 off- Department of ramp/Whipple Avenue intersection with and without Transportation project in year 2020. (Caltrans); April 16, 2003 19.02 Transportation and Circulation--impacts and mitigation measures: recommendations for mitigation measures for northbound U.S. 101 off-ramp with Whipple Avenue, including “converting the existing shared off-ramp lane into a left-turn-only lane and adding a dedicated right-turn-only lane,” and adding a second through lane to eastbound Whipple Avenue at this intersection.
19.03 Transportation and Circulation--setting, impacts and mitigation measures: “Please provide a complete freeway interchange analysis for the three U.S. 101 intersections at Whipple Avenue, State Route 84 (SR 84), and Marsh Road, and for the SR 84 intersection at SR 82. In addition, please provide us with the transportation and circulation technical appendices with the trip generation surveys for the proposed project.”
19.04 Transportation and Circulation--impacts and mitigation measures: disagreement that level of service impacts to State Routes are “significant and unavoidable”; “project applicant should provide fair- share fee for current and future improvements”; please provide more details regarding anticipated effectiveness and timing of transportation demand management (TDM) measures.
19.05 Transportation and Circulation--setting: study intersection #9 (Veterans at Maple) on Figure 7.2 is depicted as a four-way intersection, but Thomas Bros. map shows it as a “T” intersection; clarify. 19.06 Transportation and Circulation--impacts and mitigation measures: does the Draft EIR consider the impacts of the reconstruction project for the U.S. 101/SR 84 interchange?
19.07 Public Health and Safety--setting: more extensive hazardous waste database review recommended, to include National Priority List , Corrective Action Reports, etc.
19.08 Public Health and Safety--setting: evaluation of leaking underground storage tank (LUST) at Docktown
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Marina, 13 LUST sites within half-mile of project site, and all other relevant listed sites recommended.
19.09 Noise--setting, impacts and mitigation measures: noise monitoring site ST-3 (near U.S. 101) has existing noise level of Leq 69 dBA, which exceeds federal criterion; how will this be mitigated?; please provide noise measurement data in Leq format.
19.10 Transportation and Circulation--impacts and mitigation measures: encroachment permit required for any work that encroaches onto a State right-of-way.
20. Audrey C. Rust, 20.01 Biological Resources--impacts and mitigation measures: President, Peninsula Peninsula Open Space Trust (POST) “urges the City Open Space Trust; April to safeguard the integrity of this natural area” [Bair 16, 2003 Island].
21. Kilicaslan Mertan, Marina 21.01 Infrastructure and Public Services--satellite dishes: EIR Pointe Homeowner, 305 does not address loss of satellite broadcast reception Louis Lane, Redwood due to proposed high-rise buildings near Marina City; April 16, 2003 Pointe townhouses.
22. Nancy Oliver, 147 22.01 Visual Factors and Biological Resources--impacts and Belvedere Avenue, San mitigation measures: housing already built near Carlos; April 17, 2003 Peninsula Marina replaced natural shoreline and wildlife habitat with “ugly cement bulkhead” visible from Diving Pelican restaurant.
22.02 Visual Factors, Parks and Recreation, and Biological Resources--impacts and mitigation measures: proposed buildings should be set back from the shore, with pathways for walking, bike riding, skating; shoreline should be kept natural to protect wildlife habitat. 22.03 Transportation and Circulation--impacts and mitigation measures: with only one access road, project impact could be “devastating” during commute times, emergency, or disaster.
22.04 Visual Factors--impacts and mitigation measures: to allow for better views out to the bay and up to the hills, tall buildings should “separated by a vast area of open space.”
22.05 Visual Factors, Parks and Recreation, and Biological Resources--impacts and mitigation measures: shoreline should be available for everyone, buildings should be surrounded with open space, wildlife habitat should remain intact, shoreline restaurants
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should be retained and encouraged, and houseboats should continue to have berths.
23. Robin Smith, Sequoia 23.01 Biological Resources--impacts and mitigation measures: Audubon Society; April proposed towers will have an impact on migratory 17, 2003 birds; nighttime migration may be affected by illuminated tower windows; daytime bird strikes may result from proposed towers, existing high-tension electrical towers, and San Carlos Airport planes; “more study needs to be done.”
23.02 Biological Resources--impacts and mitigation measures: EIR does not address pet cats and dogs that may enter the wildlife refuge and harm endangered species.
23.03 Water service--impacts and mitigation measures: “Where will the water come from [and] will there be mandatory water rationing in Redwood City?”; “this issue needs greater study.”
23.04 CEQA-Required Assessment Considerations--significant unavoidable impacts: “a third of the studied impacts are significantly or cumulatively unavoidable”; “the EIR needs to reflect on the totality of the impacts.”
23.05 “Cost-Benefit Ratio”: EIR should consider “cost-benefit ratio” of this project for Redwood City.
24. Whitman F. Manley and 24.01 Land Use, Visual Factors, Transportation and Circulation, Sabrina V. Teller; Remy, and Noise--impacts and mitigation measures: Sims Thomas, Moose and Metal and other existing industry in the project Manley, LLP, Attorneys vicinity (the Port of Redwood City) may inherently at Law; April 17, 2003 contribute loud noises, vibrations, traffic (heavy truck, rail, marine), and visual (including night lighting) and aesthetic impacts to the project vicinity, which may be offensive to residents of the proposed residential towers; Sims is concerned about the EIR’s lack of mitigation for these potential impacts.
24.02 Noise and Visual Factors--impacts and mitigation measures: “Please explain how the DEIR authors arrived at the conclusion that the future residents of such tall buildings would not be adversely affected by the unobstructed view of, and exposure to sounds and night lighting from, the industrial Port area, which includes the Sims’ facility.”
24.03 Land Use, Visual Factors, and Noise--impacts and mitigation measures: Draft EIR proposes no
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mitigation for potential nuisance conflicts with existing industrial uses; the following mitigation measures should be adopted for the project: (1) deed disclosures and restrictions informing potential buyers of possible impacts arising from the Port’s industrial facilities; (2) appropriate soundproofing, light shielding, landscaping, and other design features to create buffers; (3) and a reduction in maximum heights of the project towers so that potential visual and noise impacts arising from the Port’s industrial operations might be less noticeable.
24.04 Visual Factors--impacts and mitigation measures: views outward from the project towers will include the Port and its associated facilities; EIR should analyze related potential visual impacts, and identify appropriate mitigation.
24.05 Noise--impacts and mitigation measures: EIR “noise impact analysis does not acknowledge the potential noise impact to the residents of the proposed [p]roject’s towers that may result from intermittent, loud noises from the Port’s industrial operations.... Because noise events at the Port are episodic, the limited ambient noise data in the [Draft EIR] is insufficient.”
24.06 Project Consistency With Adopted Plans and Policies-- City of Redwood City Strategic General Plan and Zoning Ordinance: “Sims [Metal] disputes the [Draft EIR’s] statement that the [p]roject has been fully analyzed with respect to all of the applicable General Plan policies”; Draft EIR “does not mention the General Plan’s policy regarding the desirability of isolating heavy industrial uses from residences.”
24.07 Project Consistency With Adopted Plans and Policies-- current Redwood City Bayfront Study: as part of the Bayfront Study process, the Redwood City Planning Commission has recommended that existing land uses and proposed new uses be compatible; Draft EIR does not address how such compatibility will be assured, “in light of the issues set out above.”
24.08 Transportation and Circulation--impacts and mitigation measures: Draft EIR appears to omit the U.S. 101 southbound on-ramp from Seaport Boulevard from the intersections evaluated under the proposed project.
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25. Christopher S. Mann, 25.01 Land Use, Visual Factors, Transportation and Circulation, Director of Real Estate Noise, and Air Quality--setting, impacts and Services, Granite Rock mitigation measures: “Draft EIR must discuss and Company; April 17, 2003 analyze the effect of existing heavy industrial operations near the [p]roposed [p]roject as they are relevant physical conditions already in place in the area”; some of these operations include an asphalt batch plant, concrete ready mix batch plant, heavy equipment yard, concrete and asphaltic rubble recycling operation, building material production, and metal recycling operations; such 24-hour operations inherently produce noise, dust, traffic, light, and glare--all of which should be given “full and fair assessment” in relation to the proposed project.
25.02 Noise--setting, impacts and mitigation measures: noise analysis does not discuss noise from nearby industrial operations.
25.03 Land Use, Visual Factors, Transportation and Circulation, Noise, and Air Quality--setting: EIR needs to adequately describe the existing heavy industrial conditions in the neighborhood.
25.04 Project Consistency With Adopted Plans and Policies-- current Redwood City Bayfront Study: “EIR needs to incorporate the Bayfront Study more often and more completely as it is a relevant regional land use and planning document.” 25.05 Transportation and Circulation--impacts and mitigation measures: future construction of the Blomquist Extension is not certain; also, EIR includes “apparently conflicting positions” regarding Blomquist--as a road to accommodate emergency vehicles and relieve congestion, as well as “enjoy[ing] the relative seclusion of the [p]roposed [p]roject’s roadway access.”
25.06 Transportation and Circulation, Water Service, Soils and Geology, and Noise--impacts and mitigation measures: future studies identified in the EIR “should not be delayed as their outcomes need to be considered in the EIR process.”
25.07 Land Use--setting: EIR must accurately describe the existing industrial conditions around the project area.
26. Vic Thomas, President, 26.01 Land Use and Transportation and Circulation--impacts Lyngso Garden and mitigation measures: significance criteria should Materials, Inc.; April 17, address Bayfront Study, which is an “applicable land
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2003 use plan,” in order to assure compatibility between existing uses and proposed new uses, and to utilize study’s “transportation alternatives” analysis to help mitigate impacts.
26.02 Land Use, Visual Factors, and Noise--setting, impacts and mitigation measures: “we are absolutely certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “industrial owners on Blomquist Street plan to be here permanently”; “EIR also fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light on proposed homes.
26.03 Land Use, Visual Factors, and Noise--impacts and mitigation measures: mitigation for impacts identified in comment 26.02 should include extraordinary soundproofing and disclosures in leases and to home buyers.
26.04 Transportation and Circulation--impacts and mitigation measures: “U.S. 101 southbound on-ramp from Seaport Boulevard will be a significantly impacted intersection”; an expanded left-turn pocket is needed to mitigate this impact. 26.05 Transportation and Circulation--impacts and mitigation measures: an incompatibility will exist between commute vehicles and large delivery trucks on Blomquist Street; “Such incompatibility directly meets the definition of a significant impact, as defined by this EIR section [Transportation and Circulation].”
27. Christopher Mohr, 27.01 Population, Housing, and Employment--impacts and Executive Director, mitigation measures: proposed project will provide Housing Leadership housing that is critically needed on the Peninsula, Council of San Mateo while preserving open space. County; April 17, 2003 27.02 Transportation and Circulation--impacts and mitigation measures: local traffic impacts of the project may be substantial, but the following will lessen the impacts: project’s location near jobs (which will also reduce regional commuter traffic), likely number of older residents, and planned mitigations.
27.03 Population, Housing, and Employment--impacts and mitigation measures: proposed project will offer Redwood City “a variety of new housing types.”
27.04 Population, Housing, and Employment--impacts and
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mitigation measures: proposed architecture and construction of the project will provide housing “for a long time to come.”
27.05 Population, Housing, and Employment--impacts and mitigation measures: developer has proposed to make 15 percent of the units affordable, which, “if achieved, would help Redwood City further its housing goals.”
28. Richard Newman, 28.01 Project Description--required jurisdictional approvals: Chairperson, City/County C/CAG ALUC staff will coordinate review process Association of with City staff, as needed, regarding required Governments of San approvals (e.g., General Plan Amendment, Precise Mateo County (C/CAG) Plan, Design Review [Architectural] Permit). Airport Land Use Commission (ALUC); 28.02 Land Use, Public Health and Safety, Noise, and Air April 17, 2003 Quality--setting, impacts and mitigation measures: “Draft EIR does address key airport/land use compatibility issues related to aircraft operations” as identified in February 22, 2001 letter to former Marina Shores Village Project Manager (Attachment No. 1 to comment letter), including noise, vibration, electromagnetic interference, fuel particles, dust, fear, and “complicated airspace” issues.28.03 Land Use, Public Health and Safety, Noise, and Air Quality--setting, impacts and mitigation measures: two subsequent letters from the ALUC, as well as an ALUC regular meeting in 2001, identified the same and similar issues.
28.04 Land Use, Public Health and Safety, Noise, and Air Quality--impacts and mitigation measures: Draft EIR page 12-12 “explains the land use compatibility issues the ALUC and C/CAG would address as part of their formal reviews, but it does not include any text to explain how the proposed project relates to those same issues....This is a significant omission that must be corrected before final action is taken on the adequacy of the EIR, per the relevant CEQA requirements.”
28.05 Public Health and Safety--impacts and mitigation measures: due to the project site’s proximity to San Carlos Airport and the proposed heights of project buildings, review by the Federal Aviation Administration (FAA) will be required; Draft EIR addresses the airspace/height issues, beginning on page 12-11 (Public Health and Safety, Impact 12-1: Safety Impacts Related to San Carlos Airport); after
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applicant’s submittal of project plans, the FAA concluded, in a February 5, 2003 letter to the applicant (Attachment No. 3 to comment letter), that the proposed project “is presumed to be a hazard to air navigation”; Draft EIR omits FAA findings and does not identify necessary mitigation (i.e., reductions in tower heights).
28.06 Public Health and Safety--impacts and mitigation measures: Mitigation Measure 12-1 should be rewritten to address issues noted in comment 28.05.
28.07 Noise--pertinent plans and policies: identified 45 dB CNEL interior noise standard (EIR page 13-11) is consistent with the FAA interior standard for residential uses; the identified requirement for an acoustical study (Mitigation 13-1, page 13-16) is consistent with the 1996 San Carlos Airport Land Use Plan, as amended.
28.08 Noise--impacts and mitigation measures: Draft EIR noise analysis is inadequate regarding aircraft and overflight noise; noise study period (winter weekdays) was not representative of typical aircraft operations. 28.09 Noise--impacts and mitigation measures: Draft EIR “does not address impacts from periods of high aircraft activity and related single-event noise levels.”
28.10 Noise--impacts and mitigation measures: Draft EIR noise analysis was “conducted at or near ground level and fails to account for the height of the buildings” (i.e., residences at higher floors will experience more aircraft noise).
28.11 Noise--impacts and mitigation measures: Draft EIR “further fails to address the impacts of single-event and cumulative noise on outdoor activities at the project site.”
28.12 Noise--impacts and mitigation: project site is “well outside of the 55 dB CNEL aircraft noise contour,” as indicated in the Airport Master Plan Update Draft EIR (June 2002); however, the “site is subject to single- event noise impacts from: (1) aircraft arrivals and departures at San Carlos Airport, (2) commercial jet arrivals to San Francisco International Airport, and (3) transient aircraft traversing the area. Aircraft can be as low as 300-400 feet in the project vicinity....This is another significant omission of
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critical information in the [Draft EIR] that must be rectified before the [Draft EIR] is certified under CEQA.”
28.13 Public Health and Safety--impacts and mitigation measures: Draft EIR does not address the safety guidelines contained in the Airport Land Use Plan; potential project design issues--including reflective glass; site lighting; size, type, and location of communication equipment; size and location of HVAC exhaust vents; and water features that may attract birds--will be evaluated by the C/CAG ALUC and C/CAG as part of their formal project reviews; EIR should discuss these issues.
28.14 Public Health and Safety--impacts and mitigation measures: Draft EIR “correctly states that the project site is located outside of the current San Carlos Airport Avigation Easement Review Area (AERA) boundary”; ALUC has determined that “it would be very appropriate for the project sponsor to grant an avigation easement to the County of San Mateo, as the proprietor of San Carlos Airport, either voluntarily, or as a condition of approval of the project by the City of Redwood City.”
28.15 Public Health and Safety--impacts and mitigation measures: ALUC has “also determined that it would be appropriate for the project sponsor to grant an avigation easement to the City and County of San Francisco, as the proprietor of San Francisco International Airport, either voluntarily, or as a condition of approval of the project by the City of Redwood City.”
28.16 Land Use, Public Health and Safety, Noise, and Air Quality--impacts and mitigation measures: “content of the [Draft EIR] is weak and incomplete, regarding the relationship of the proposed project to airport/aircraft operations at San Carlos Airport and other aircraft operations in the vicinity of the project site.”
Written Comments Received After End of Review Period (April 17, 2003):
The nine letters, memos, and e-mails received after the Draft EIR public review period are listed below, with all comments pertaining to the EIR coded and summarized.
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29. Leslie Young; April 18, 29.01 Land Use, and Parks and Recreation--impacts and 2003 mitigation measures: proposed project is not integrated with the Bayfront Study; Bayfront Trail path on project site needs to be defined; only open space appears to be under PG&E power lines.
29.02 Project Consistency With Adopted Plans and Policies-- City of Redwood City Strategic General Plan and Zoning Ordinance: project is not integrated into an overall plan for Redwood City, including the redevelopment of downtown; if located in downtown Redwood City, the project could take advantage of existing transportation infrastructure and help fuel redevelopment of downtown.
29.03 Project Consistency With Adopted Plans and Policies-- pertinent regional plans: project “is not integrated into a plan considering surrounding cities.”
29.04 Economic Factors, Visual Factors, Transportation and Circulation, Police Service, Parks and Recreation-- impacts and mitigation measures: “a whole is missing from the EIR regarding economic impact”; concerns regarding unsafe traffic, crime, and shadows, resulting in decreased home values in area; green space needed. 29.05 Transportation and Circulation--impacts and mitigation measures: intersection of Whipple Avenue and U.S. 101 dangerous for bicyclists, will worsen with project; photos provided to show possible striping of roadway for mitigation.
29.06 Economic Factors, Visual Impacts, Transportation and Circulation, Police Service, Parks and Recreation, Project Consistency With Adopted Plans and Policies: summary of comments 29.01 through 29.05.
30. Nina Miller, forwarded by 30.01 Population, Housing, and Employment--impacts and Irene Barragan, City mitigation measures: ample vacant space available Manager’s Office, City of for housing in other areas of Redwood City. Redwood City; April 18, 2003 30.02 Biological Resources, and Parks and Recreation-- impacts and mitigation measures: shoreline should be preserved as much as possible; “low-profile recreation” acceptable use.
31. Terry Roberts, Director, 31.01 Introduction--EIR purpose and intended use: “This letter State Clearinghouse; acknowledges that you [City of Redwood City] have April 18, 2003 complied with the State Clearinghouse review
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requirements for draft environmental documents, pursuant to the California Environmental Quality Act.”
32. John and Nena Padley, 32.01 Biological Resources--impacts and mitigation measures: 211 36th Avenue, Apt. B, concern about project impacts on wildlife and San Mateo; undated endangered species.
33. Ian B. McAvoy, Deputy 33.01 Transportation and Circulation--impacts and mitigation Chief of Development, measures: proposed “project is a positive effort to San Mateo County provide high-density housing near our suite of Transit District existing and future transit services”; project “will (SamTrans); April 25, afford us significant growth in all modes of transit 2003 ridership.”
34. Andrea M. Gaut, Coastal 34.01 Project Description--proposed project characteristics, and Program Analyst, San Parks and Recreation--impacts and mitigation Francisco Bay measures: public access should average at least Conservation and 100 feet in width from top of [shoreline] bank Development landward; current project plans show very narrow Commission (BCDC); public access without consideration of open spaces April 25, 2003 directly adjacent to the site; open spaces should be useable by the general public and residents alike. 34.02 Hydrology and Water Quality--impacts and mitigation measures: relocation of displaced live-aboard boats could result in uncontrolled discharges and a significant water quality impact.
34.03 Visual Factors--impacts and mitigation measures: berthing layout should promote unobstructed views of wildlife refuge from public access areas.
34.04 Land Use--pertinent plans and policies (BCDC’s San Francisco Bay Plan): previously submitted (March 28, 2002) Notice of Preparation (NOP) letter attached, regarding BCDC jurisdiction and related issues of concern.
35. Terry Roberts, Senior 35.01 Introduction--EIR purpose and intended use: attached Planner, State BCDC comment letter received at State Clearinghouse; April 30, Clearinghouse after end of state review period, which 2003 closed April 17, 2003.
36. Alison Mader, 36.01 Transportation and Circulation, and Infrastructure and Director, Development, Public Services--impacts and mitigation measures: The Irvine Company project should be required to pay "fair share" of Apartment Communities; mitigation costs. May 23, 2003 36.02 Visual Factors--impacts and mitigation measures: "Villas at Bair Island" and Bair Island Marina will be impacted by shadows and glare.
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36.03 Transportation and Circulation--impacts and mitigation measures: project does not meet City parking requirements; overflow parking at "Villas at Bair Island" may result.
36.04 Hydrology and Water Quality--impacts and mitigation measures: concern that project dredging and filling may impact Bair Island Marina access.
37. Ellen Miramontes, Bay 37.01 Project Description--required jurisdictional approvals: Design Analyst, San public access issues related to BCDC area of Francisco Bay jurisdiction on Pete's Harbor property. Conservation and Development Commission (BCDC); May 1, 2003
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Many of the comments received during and immediately after the Draft EIR public review period address the same issues. Nine specific areas of concern fall into this category. Each of these nine issues and an associated "Master Response" of the EIR authors to the various comments received pertaining to the issue are provided in this section (Master Responses A through I). These various master responses are then referenced where applicable throughout sections 2.4 (Responses to Planning Commission Meeting Comments) and 2.5 (Responses to Written Comments) of this document.
2.3 MASTER RESPONSES
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Master Response A: Project Compatibility with Existing Industrial Uses. Many comments were received regarding the Draft EIR evaluation of project compatibility with the numerous existing heavy commercial and industrial activities within a one-mile radius of the project site, suggesting that the existence of these activities in the Bair Island Road/Seaport Boulevard/Port of Redwood City area, and associated visual, traffic, noise and air quality impacts, have not been adequately acknowledged and addressed in the Draft EIR. The commenters have pointed out that these existing heavy commercial and industrial activities within a one-mile radius of the proposed project site include such nuisance prone activities as an asphalt batch plant, a concrete ready mix batch plant, heavy equipment yards, concrete and asphaltic rubber recycling operations, building material production operations, and metal recycling operations. The commenters have also pointed out that many of these business owners plan on long-term occupancy and operation at these locations and some of these businesses operate 24 hours per day, seven days per week. Comments were made that the Draft EIR does not present a realistic depiction of associated land use compatibility issues and mitigation needs. In particular, comments were submitted questioning the adequacy of the Draft EIR with respect to the following:
associated visual impacts, including general aesthetic incompatibilities, effects on elevated (unobstructed) views from the project residential towers towards unsightly industrial activities, associated extended-hour (“24/7") night-time lighting light intrusion and glare impacts, and the concern that, contrary to the Draft EIR findings, the distances across the water between the proposed project and these activities would not render associated visual impacts insignificant;
associated traffic conflicts between project-introduced vehicular and pedestrian activity and heavy truck and rail activity generated by these existing heavy commercial and industrial uses;
associated noise and vibration effects and whether the monitoring data and associated Draft EIR descriptions of existing (baseline) ambient noise conditions in the area are accurate, given the potential for unobstructed noise transmission over intervening open water and marsh areas, including occasional loud and intermittent noises, particularly at nighttime;
associated air quality impact concerns, including potential dust and other industrial pollutant emissions impacts on the proposed project;
the need to study these visual, traffic, noise and air quality issues more empirically;
inadequate consideration of associated existing City land use policies (Redwood City General Plan) and evolving policies (Bayfront Study) intended to ensure compatibility between new uses and existing heavy commercial and industrial uses in this area; and
a lack of sufficient mitigation for these potential compatibility impacts, and a suggested need for such additional measures as disclosure requirements, visual and noise buffering
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(berms, landscaping, etc.) requirements, light shielding requirements, “extensive sound proofing” requirements, restrictions on building heights to reduce associated visual and noise impacts, and City adoption of a “right-to-operate” ordinance for existing heavy commercial and industrial uses.
Response: The EIR authors believe that the Draft EIR includes sufficient consideration of the existing heavy commercial and industrial activities in the project site’s Bair Island Road/Seaport Boulevard/Port of Redwood City vicinity and associated impacts and mitigation needs that is complete and in full compliance with CEQA, as further explained below.
Draft EIR Land Use Setting and Impact Discussion. Page 4-5 of the Draft EIR includes a description of the adjacent Seaport Center east of the project site. Page 4-6 includes a description of the adjacent Baypoint Marina heavy commercial and light industrial uses, plus the Alan Steel and Supply Company operation, to the west of the project site. Page 4-7 describes the Central Concrete operation and active Cargill evaporation ponds to the east of the project site, and the Port of Redwood City complex to the northeast, explaining that the port “contains a variety of maritime and industrial uses including Romic Environmental Technologies (a hazardous waste transfer operation), Kaiser Cement (concrete manufacturers and distributors), RMC Lonestar (a concrete materials transfer operation), Bell Marine (a concrete and asphalt recycling operation), Kaiser Cement Corporation (concrete manufacturers and distributors), BCBM (concrete and cement distributors), and Sims-LMC (a metal recycling operation),” all to the northeast of the project site; plus “a variety of heavy industrial uses” southeast of the site, “anchored by the Granite Rock operations and including Frey Trucking and Supply, General Hardware and Supply, Continental Tool, Pavex, Peninsula Building Materials, T&H Lumber, a PG&E substation, and Lyngso Construction Materials,” as well as the “Malibu Grand Prix...located...on land owned by Granite Rock.” Here, the Draft EIR also describes its finding that “incompatibilities and related nuisance complaints associated with”...the proposed...”introduction of a new, high-intensity, large-scale residential development in proximity to existing industrial land uses east of Redwood Creek would be “less-than-significant” due to “distances of separation, intervening uses,” project access characteristics, local wind patterns, and other factors...”. The DEIR states the following on page 4-31 in support of this finding:
Unlike the Pacific Shores development, which is contiguous to or opposite the two largest industrial designations in the area (see Figure 4.1) and is served exclusively by Seaport Boulevard, the proposed Marina Shores project is separated from existing HI: Heavy Industrial designated properties by intervening properties and Redwood Creek, and would not be served by Seaport Boulevard (the principal industrial access route in the area). Due to its separation from these existing industrial properties and from Seaport Boulevard, the project would not result in significant land use compatibility impacts with nearby industrial uses (e.g., visual, public health and safety, noise, air quality, odor, etc.). The findings in the Public Health and Safety, Noise, and Air Quality chapters of this EIR (chapters 12, 13, and 15, respectively) indicate that, due to the degree of existing buffering (intervening uses and distances of separation) and local wind patterns, the project site would not be subject to significant hazardous materials, noise (including night noise), vibration, dust, air contaminant, or odor impacts associated with existing
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nearby 24-hour industrial activities.
Table 4.3 identifies existing industries in the project vicinity and potential land use compatibility issues with the proposed Marina Shores Village project (an analysis similar to Table 4.3 was completed at the request of nearby industrial tenants for the Pacific Shores EIR). [See Table 4.3 on Draft EIR page 4-32.]
Chapter 7 (Transportation and Circulation) addresses potential traffic impacts of the proposed project in combination with future background and cumulative traffic conditions (i.e., including nearby industrial operations).
In response to the numerous comments questioning this conclusion and the overall adequacy of the Draft EIR with respect to this land use compatibility issue, this discussion has been reconsidered and expanded in this Final EIR. The following additional explanations have been added to Draft EIR pages 4-31 through 4-33 and page 5-26 (see revised versions of pages 4-31 through 4-33 and 5-26 in section 3 herein, Revisions to the Draft EIR):
Project compatibility with existing heavy commercial and industrial activities in the Bayfront vicinity will be a function of the following factors: distance, visual (especially light and glare) impacts, traffic impacts, noise and vibration impacts, air quality (especially dust) impacts, and project impacts on continued viability of the existing heavy commercial and industrial activities.
Distance. A principal consideration in evaluating project compatibility with existing heavy commercial and industrial activities in the Bayfront vicinity is the distance between the nearest proposed project residential elements and the nearest existing heavy commercial and industrial activities. An additional table, Table 4.4, listing the names and addresses of the numerous existing heavy commercial and industrial activities in the project vicinity, and indicating their approximate distances from the closest proposed project residential units. Table 4.4 (see next page) has been added to page 4-32 of the Draft EIR (see revised version of page 4-32 in section 3 herein, Revisions to the Draft EIR). As indicated by the table, the closest of the existing local heavy commercial and industrial uses, Frey’s Garden Products, is roughly 0.15 mile (approximately 800 feet) from the nearest proposed project residential tower. The Granite Rock site and associated industrial operations on Blomquist Street (Pavex Construction, T&H Lumber, Peninsula Concrete, and Peninsula Road Materials) are approximately 0.30 to 0.31 miles (approximately 1,600 to 1,650 feet) from the nearest proposed project residential tower. The Lyngso Garden Materials operation on Seaport Boulevard is approximately 0.52 mile (approximately 2,750 feet) from the nearest proposed residential tower. The Sims-LMC Recyclers and the RMC Lonestar operations on Seaport Boulevard are approximately one mile and 1.4 miles, respectively, from the nearest proposed project residential tower. These separation distances are sufficient to reduce associated visual (light and glare), noise, vibration, and air quality impacts on the proposed project residential components to less than significant levels, as more fully explained below.
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Table 4.4 EXISTING HEAVY COMMERCIAL AND INDUSTRIAL OPERATIONS IN THE BAIR ISLAND ROAD/SEAPORT BOULEVARD/PORT OF REDWOOD CITY VICINITY--DISTANCE FROM THE PROJECT SITE
Approximate Distance to Closest Proposed Project Operator: Address: Residential Tower:
Frey’s Garden Products 1450 E. Maple 0.15 mile Alan Steel and Supply 505 E. Bayshore 0.24 mile Continental Tool 20 Chemical Way 0.27 mile General Hardware and Builders 80 Chemical Way 0.30 mile Supply Granite Rock 330 Blomquist 0.30 mile Pavex Construction 330 Blomquist 0.30 mile T&H Lumber 350 Blomquist 0.30 mile Peninsula Concrete 355 Blomquist 0.31 mile Peninsula Road Materials 365 Blomquist -- Malibu Castle Golf Course and 320 Blomquist 0.32 mile Games Malibu Grand Prix Blomquist/Seaport 0.50 mile Harbor Ready-Mix 123 Seaport 0.50 mile Peninsula Building Materials 109 Seaport 0.50 mile Lyngso Garden Materials 19 Seaport 0.52 mile Redwood City Recycling Center 195 Seaport -- Port of Redwood City 675 Seaport 0.70 mile Sims-LMC Recyclers 699 Seaport 1.0 mile Central Concrete 775 Seaport 1.1 miles Bell Marine 775 Seaport 1.2 miles Harbor Sand and Gravel 775 Seaport 1.3 miles RMC Lonestar 876 Seaport 1.4 miles
SOURCE: Wagstaff and Associates, June 2003.
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Visual Impacts: The visual compatibility of the proposed project with existing heavy commercial and industrial uses in the Bayfront vicinity would be a function of three key factors: the extent of light intrusion into the project from these uses, the potential glare impacts of these uses on views from the project, and the degree of visual distraction or view disruption associated with these uses.
Light Intrusion and Glare Impacts. As indicated by a number of comments received, some of the existing heavy commercial and industrial uses listed in Table 4.4 are 24-hour operations illuminated at night with elevated, high-intensity light fixtures. Some of these light sources (arc tubes, etc.) have not been fully shielded. Concerns have been expressed that these nighttime lighting features could generate significant spill light and glare impacts on the project and that such effects are not adequately addressed in the Draft EIR.
Given the proposed height of the residential structures, views towards existing heavy commercial and industrial activities and associated exterior lighting in the Bayfront vicinity would be largely unobstructed and, although these existing nighttime light sources do not appear to blink, flash or oscillate, many of these light sources and associated reflections off of reflected surfaces would be highly visible from the elevated residential vantage points (windows and balconies above two stories).
The intensity of a light source is inversely proportional to the distance from the light source. Light intensity is in fact inversely proportional to the square of the distance from the light source- -e.g., an unshielded high-beam light source measuring 150,000 foot candles at the source would have an illumination value of 0.15 foot candle at 1,000 feet (1 = 150,000 ÷ 1,000,000 = 0.15). One of the closest of the existing nighttime light sources to the project, the Granite Rock operations at 330 to 365 Blomquist, is approximately 1,500 or more feet from the nearest proposed Pete’s Harbor residential tower. The Lyngso Garden materials operation at 19 Seaport Boulevard is approximately 2,700 to 2,800 feet (roughly one-half mile) from the nearest proposed Peninsula Marina residential tower. The Port of Redwood City (675 Seaport), Bell Marine (775 Seaport) and RMC Lonestar (876 Seaport) industrial operations and associated exterior light sources would range in distance from approximately three quarters to one and one quarter miles from the nearest proposed Pete’s Harbor residential tower. At distances of 1,000 or more feet, high intensity exterior light sources at nearby extended-hour operations, would be clearly visible in the panoramic view field from residential windows and balcony vantage points in the proposed project. However, there would be little or no light intrusion onto the project site from these sources. Moderate density window curtains in the project residential units would not be highly illuminated.
People experience glare when light sources or reflective surfaces within the field of view are judged to be “too bright.” There are two kinds of glare, both of which can affect view and vision: an unwanted reflection, or a bright light source that obscures other features in a view. Glare can cause discomfort when it results in annoyance or actual eye pain when there is high distribution of brightness in the field of view. High glare levels can interfere with seeing other objects in the field of view, or can otherwise distract the eye in an annoying way. The glare threshold generally rises with the distance between the vantage point and the glare source, and
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the breadth of the field of view.
Apparent brightness depends on the characteristics (brightness, etc.) of the visual background and the viewer’s adaptation level. Individual viewers will have differing levels of tolerance for bright light sources in a field of view. In the case of the Bair Island Road/Seaport Boulevard/Port of Redwood City area, there is an abundance of evening light sources typical of a suburban/urban, maritime environment, resulting in an assumed viewer adaptation level to nighttime light sources that is comparatively high. There is no commonly-accepted specific luminance value above which “significant” glare occurs. The City does not apply any prevailing or default lighting standards. No substantial evidence has not been provided by commenters on the Draft EIR that the degree of glare at the project site from existing industrial light sources in the area would be significant. Given the degree of separation between these existing activities and light sources from the proposed project residential units (0.3 to 1.4 miles), the level of glare (individual light source brightness and reflectivity in the field of view) would not be expected to be uncomfortable to the eye or interfere with seeing other objects in the field of view. The bright, high-intensity light sources would be clearly visible and noticeable in the view from residential windows and balcony vantage points, but because of the distance to these sources (one quarter to one third of a mile to the Granite Rock area, one half mile to the Lyngso Garden Materials/inner Seaport Boulevard area, and from three-quarters to one and one-half mile to the Port of Redwood City, outer Seaport Boulevard area), and because the field of such views would be panoramic, including long-range views of the bay to the northeast, north, and southeast, and Peninsula urban areas and the coast range mountain backdrop to the east, southeast, south, and southwest, combined with an abundance of exterior light sources in the intermediate and foreground views (street lights, parking area lighting, vehicular headlights on the freeway and local streets, etc.), the glare impacts of these local exterior lighting sources would be less than significant.
Visual Distraction: There is no universal agreement among experts regarding how much nighttime light or other visual distraction is acceptable in an urban/suburban environment. Because prospective purchasers and tenants of the project residential units would have a general understanding that they would be occupying a residential unit in an existing urban/suburban/maritime area, they would be less likely to be bothered by views of nearby heavy commercial and industrial activity, including nighttime light sources, than would prospective purchasers and tenants seeking a more rural setting.
There is an existing abundance of urban activity and associated nighttime light sources in the Bair Island Road/Seaport Boulevard/Port of Redwood City area, and a general perception of a suburban/urban/maritime environment. It is therefore assumed that the residential viewer adaptation levels to the existing maritime/industrial activities and nighttime light sources in the Bayfront area would be comparatively high.
Traffic Conflicts. Most of the heavy commercial and industrial addresses listed in Table 4.4 (all but Alan Steel and Supply) are currently served by Seaport Boulevard. The project site is not currently served by Seaport Boulevard. The Blomquist Extension, anticipated to be completed before project buildout, would divert some of the existing heavy commercial and industrial traffic
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from East Maple, Chemical Way, East Bayshore, and Blomquist addresses towards the Whipple Avenue interchange, the principal region access point for the project. However, most of the local heavy commercial and industrial traffic would continue to use Seaport Boulevard.
Noise Conflicts. Please see Master Response E (Project Compatibility with Aviation and Industrial Noise). As explained in section 13.3 of the Draft EIR, daily and intermittent noise levels at the project site due to existing heavy commercial and industrial activity in the Bayfront vicinity would not exceed City- or state-established thresholds of significance. In general, noise from the freeway and San Carlos Airport aviation activity would be more noticeable than noise from the heavy commercial and industrial activities.
Air Quality Conflicts. Please see response PC 5.05. Due to distances of separation and prevailing winds, dust and other air pollution impacts on the project due to existing heavy commercial and industrial activities in the Bayfront area would not be significant.
Conclusion: Nevertheless, the commenters may be correct that introduction of these multi-story residential elements in proximity to existing industrial activities in the Bair Island Road/Seaport Boulevard/Port of Redwood City area could result in an increase in nuisance complaints about, and requests to limit, some of these existing extended-hour industrial operations, and associated visual, noise, traffic or air quality nuisance aspects. A number of the commenters have suggested that the City require project owner disclosure to prospective residential purchasers and tenants of the existing industrial activities in the Bayfront area and possible perceptions of associated nuisance characteristics. The applicant has expressed a willingness to provide for such disclosure and associated buyer and renter acknowledgment, notification, and signature requirements which would be included in the property CC&Rs (Covenants, Conditions and Restrictions).1
To ensure that such disclosure does take place, the City could establish, as a condition of project approval, a requirement, formulated to run in perpetuity with the project property title, that prospective project residents (including prospective purchasers and tenants) of all project residential units, particularly those with east-, southeast- and south-facing windows and balconies, shall be notified in writing by the seller or person offering a unit for rent that there are existing extended-hour, heavy commercial and industrial activities in the project’s Bair Island Road/Seaport Boulevard/Port of Redwood City vicinity that may have perceived daytime and nighttime visual, traffic, noise, and/or air quality-related nuisance effects, and that this written disclosure shall be included in the sales and rental materials to be signed by the prospective project residents.
Project Impacts on the Viability of Existing Heavy Commercial and Industrial Uses. Although it may warrant consideration in the City’s future deliberations on the project, the question of whether or not introduction of the project would affect the viability of one or more of these existing heavy commercial and industrial operations in the Bayfront area is not an
1Telephone conversation with Tim Ridner, Glenborough-Pauls, May 29, 2003.
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“environmental” question warranting evaluation in the project EIR (it has not been demonstrated that such an economic effect would result in its own significant secondary environmental effects).
Project Consistency with Redwood City Strategic General Plan Policies Pertaining to Land Use Compatibilities. The Strategic General Plan, City of Redwood City Land Use Element (Chapter 6) states the following with respect to the desire to avoid incompatible uses and more specifically, the desired relationships between residential and industrial uses:
Page 6-1: "The residential land use objectives and policies reflect concerns for the protection of neighborhoods from incompatible land uses,..."
Page 6-2: "The industrial land use objectives and policies call for modernizing older industrial areas and minimizing negative impacts of industrial activities on neighboring land uses."
Page 6-2: "Heavy industrial is associated with the Port and adjacent properties and signifies types of industries that would be objectionable if located near residential areas."
These excerpts from the General Plan represent background narrative leading up to the Land Use Element listing of actual City-adopted "Land Use Objective" (page 6-5), and "Land Use Policies" (pages 6-5 and 6-6). All of the listed "Land Use Objectives" and "Land Use Policies" that are pertinent to consideration of the proposed Marina Shores Village project, including the issue of its compatibility with nearby existing industrial land uses, have been excerpted, listed in section 4.2.1 of the Draft EIR (Redwood City Strategic General Plan) on pages 4-11 through 4- 12, and fully considered in making associated Draft EIR impact and mitigation findings. None of the listed objectives or policies identifies industry and nearby residential development as, by definition, incompatible uses. Rather, the plan narrative describes the need "for the protection of neighborhoods from incompatible uses..." and "minimizing negative impacts of industrial activities on neighboring land uses," and how heavy industrial uses "associated with the Port and adjacent properties"..."would be objectionable if located near residential uses." The associated land use concerns raised by the proposed location of the Marina Shores Village project in the vicinity of these port-related industrial activities have therefore given full and careful consideration in the Draft EIR. As explained above, due primarily to the degree of separation of the proposed project from these existing port-related industrial properties and from Seaport Boulevard, the project would not result in significant land use compatibility impacts with these existing industrial uses. In response to the numerous comments questioning this conclusion, this discussion has been carefully reconsidered and expanded upon in this Final EIR, with additional discussion and explanation added regarding associated potentials for visual impacts (light intrusion and glare impacts, visual distraction points), traffic conflicts, noise conflicts, air quality conflicts, and project impacts on the economic viability of heavy commercial and industrial land uses.
Master Response B: Airport-Related Land Use, Public Health, and Safety Issues. Several comments made during the Draft EIR public hearing and submitted in writing during the Draft
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EIR public review period expressed concern over proposed project airport/land use compatibility issues with the San Carlos Airport, including project consistency with the San Carlos Airport Land Use Plan (ALUP) and Federal Aviation Administration (FAA) review requirements. In addition, some comments were received pertaining to project compatibility with San Francisco International Airport. Generally, these airport-related comments pertained to the following concerns: the effects of overflights, FAA height restrictions, airplane-related nuisances to project residents, arrival-departure patterns, appropriateness of an avigation easement, and the need for Airport Land Use Commission (ALUC) review.
Response: In the Draft EIR, airport-related issues are addressed in subsections 4.2.5 (Land Use, San Carlos Airport Land Use Plan, page 4-15) and 12.3.2 (Public Health and Safety, Impacts and Mitigation Measures, Impact 12-1, page 12-11), with “Safety Impacts Related to San Carlos Airport” identified as a “potentially significant impact.” These Draft EIR subsections were prepared by the EIR authors, relying on numerous personal and written communications with ALUC staff as identified in the Draft EIR footnotes.
The need for project review by the FAA and ALUC has been identified from the outset of the Marina Shores Village EIR process. Prior to release of the Draft EIR, issues of project land use compatibility with the San Carlos Airport were identified in the Draft EIR Notice of Preparation and Initial Study (February 5, 2002), under items VII.e (Hazards and Hazardous Materials), IX.b (Land Use and Planning), and XI.e (Noise). Also, as described in Draft EIR subsection 4.2.5, “Because the project site is located within the ALUP-designated restricted height area for the San Carlos Airport, and because the proposed project would include structures over 200 feet in height (the FAA-identified potential airspace obstruction threshold), the project’s relationship to the [Federal Aviation Regulations] FAR Part 77-based imaginary surfaces constraints for the San Carlos Airport would warrant FAA review.” The same subsection identifies the need for ALUC review as well. In Draft EIR subsection 12.3.2 (Impact and Mitigation 12-1), the details of these review procedures are described, addressing such issues as “obstruction to air navigation,” “building heights above mean sea level,” avigation easements, and other related matters. Mitigation 12-1 concludes, in part, “If the proposed project structures are deemed to be obstructions to air navigation, specific mitigation measures required by the FAA shall be implemented to ensure that navigation is not obstructed.” In addition, the mitigation describes a potential Avigation Easement resulting from ALUC review.
The particular issue inherent in some of the comments is when FAA and ALUC review could or should occur. Should such review occur before or after Draft EIR circulation? As stated in Draft EIR subsection 12.3.2 (text under Impact 12-1), “The density and building heights...proposed by the project would warrant review of the project design by the FAA to ensure compliance with FAA height limitations related to the San Carlos Airport and to give the FAA opportunity to further define appropriate mitigations for any potential intrusion by a project structure into navigable airspace....ALUC review of any proposed project would include an analysis of the detailed project designs when they become available, including, among other related variables, buildings heights above Mean Sea Level (MSL)...and building locations.”
The Draft EIR project description (chapter 3, section 3.4, page 3-12, among other EIR pages)
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recognizes the preliminary nature of the proposed Marina Shores Village project as follows: “As project details are designed and refined throughout the City review process, the numbers and height of buildings may change. The project architects have designed the site plan...to depict how the primary project components...could be accommodated on the site.”
The project applicant is refining the project details to address current FAA, ALUC, and Mitigation 12-1 concerns. The EIR authors have received the following information subsequent to the Draft EIR public release:
1. The project applicant has submitted a set of specific coordinates (latitude and longitude), located in the middle of the Peninsula Marina property, to the FAA for review; the FAA has determined that the maximum building height limit at the submitted coordinates is 195 feet, which is below the approximately 252-to-340-foot limit range preliminarily depicted on Map SC-16 (FAR Part 77 Civil Airport Imaginary Surfaces Height Restrictions) of the currently adopted San Carlos Airport ALUP. The FAA letter informing the applicant of this determination (dated February 5, 2003) is included after this master response.
2. FAA staff have informed the project applicant that an Instrument Flight Rules (IFR) corridor overlay (referred to as FAA Order 8260.3b), which is also not depicted in the currently adopted ALUP, affects the project site.
3. After learning of the IFR corridor overlay and the methodology for plotting the overlay, the project applicant’s civil engineer has prepared a more detailed map illustrating the potential impacts of the overlay on FAA height restrictions, indicating the project engineer's determinations that:
(a) for the proposed project, the structures on the Pete’s Harbor property would not exceed the clarified FAA height restrictions;
(b) for the Peninsula Marina property, FAA height restrictions would range from 182 to 205 feet, depending on the structures’ specific coordinates;
(c) for Draft EIR Alternative 6 (reduced building heights), the height of one proposed tower on the Peninsula Marina property would need to be reduced accordingly (all other towers heights indicated for the alternative would be below the clarified FAA height limits); and
(d) for Draft EIR Alternative 6, the proposed building heights on the Pete’s Harbor property would not exceed the clarified FAA height restrictions.
4. The project applicant has forwarded these more detailed building height limitation determinations by the project civil engineer (the map and calculations described under item #3 above) to the FAA for review and comment.
5. The project applicant has also forwarded the center point coordinates for each of the
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proposed 17 towers to the FAA to confirm the applicable height limit for each.
6. The project applicant has also stated the understanding and intent that no project structure will be constructed in excess of FAA height regulations.
7. The project applicant has also stated the intent to include specific language in the purchase and sale agreement for each project residence, requiring the buyer’s initials and acknowledgment, indicating awareness of the Marina Shores Village project’s proximity to airport and industrial operations (see Master Response A, Project Compatibility with Existing Industrial Uses); the same language would also be included in the property CC&Rs (Covenants, Conditions, and Restrictions).
No increase in the significance or severity of any Draft EIR-identified impact or a significant new impact, mitigation, or alternative not already considered in preparing the Draft EIR has occurred as a result of these additional, post-Draft EIR findings (CEQA Guidelines section 15088.5).
Project-related noise concerns associated with airport operations are discussed below in Master Response E (Project Compatibility with Aviation and Industrial Noise).
Master Response C: Water Supply Issues. Several comments concerning regional, local, and project water supply were made during the Draft EIR public hearing and/or submitted in writing during the Draft EIR public review period. This issue is adequately addressed in Draft EIR chapter 10 (Infrastructure and Public Services), section 10.1 (Water Service), including an explanation of recent legislation (Senate Bill/SB 610 and SB 221) that requires completion of a Water Supply Assessment for any proposed large-scale development project. Accordingly, in accordance with SB 610 and SB 221, such a Water Supply Assessment has been prepared by the City of Redwood City Public Works Services Department, and approved by the Redwood City City Council on August 26, 2002, and incorporated into chapter 10, section 10.1 (Water Service), of the Draft EIR. In addition, as also required by SB 610, the entire Water Supply Assessment for the proposed project is included in Appendix 21.2 of the Draft EIR (Water Supply Assessment for the Proposed Marina Shores Village Project).
Two comments pertaining to water supply made at the Draft EIR public hearing (PC 2.02 and PC 2.03) were addressed at the hearing by City staff and the EIR consultants.
Some related comments on the Draft EIR requested more detail regarding the City’s recycled water project. The specific details of the City's recycled water project were unknown at this writing. At the time the Draft EIR was released for public review (March 4, 2003), the recycled water project was a “pilot program [as] part of a long-term recycled water project that is in the
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(3-page FAA letter -- page one)
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(3-page FAA letter -- page two)
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(3-page FAA letter -- page three)
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preliminary planning phase, pending further review by the City Council” (Draft EIR page 10-3, Redwood City Recycled Water Project). Attached to this response is a May 2, 2003 letter from the Redwood City Office of the City Manager, which was mailed to Redwood City residents. The letter reports that the City Council recently voted in favor of a voluntary residential recycled water program for landscape irrigation. Extensive additional background information and updates regarding the City's recycled water project’s status can be found on the City’s website (www.redwoodcity.org).
Because an achievable water supply source has yet to be identified for the proposed project, the effectiveness of EIR Mitigation 10-1 (pertaining to project-related and cumulative municipal water service demand) remains uncertain; therefore, the Draft EIR has concluded that the impact would be significant and unavoidable. Nevertheless, “The project applicant would be required to comply with all applicable current and future City of Redwood City water demand performance standards, including standards included in the City of Redwood City Urban Water Management Plan, the City’s recycled water project, and the City’s water conservation program” (Mitigation 10-1).
Master Response D: Bayfront Study Discussion. A number of comments were made at the Draft EIR public hearing and in writing during the Draft EIR public review period pertaining to the City’s ongoing Bayfront Study process. Some commenters stated that the Bayfront Study hearings and associated Planning Commissioner comments clearly acknowledged the importance of existing industrial activities in the area (PC 5.01, PC 10.02, 14.01, 17.05, 17.11, 24.07). Other comments indicated that contrary to what was indicated in the Draft EIR, the Bayfront Study was not available for review at City Hall (PC 5.05, PC 10.02). Other comments suggested that the Bayfront Study is an applicable land use plan and its content should be included in the list of “significance criteria” applied in the Draft EIR (PC 10.02, 14.01, 17.01, 17.05, 26.01) and that the Draft EIR should reflect the Bayfront Study more often and more completely (25.04 and 29.01). Other comments simply requested clarifications regarding the Bayfront Study content and timing (PC 13.01).
Response: The Bayfront Study was being conducted by the City at the same time that the Draft EIR for the Marina Shores Village project was being prepared. A preliminary version of the Bayfront Study document is now available for review at the City of Redwood City Community Development Services Department, City Hall, 1017 Middlefield Road; public workshops on the study are underway. To ensure that all pertinent land use, urban design, and transportation planning concepts raised and considered during the Bayfront Study process have been properly considered in preparing the Marina Shores Village Project EIR, the EIR authors have regularly participated in the Bayfront Study process, attending numerous related City staff meetings and City Planning Commission and City Council work sessions over the past year.
Also, the Bayfront Study urban design consultant, Bottomley Planning and Design, was included as a subcontracted member of the EIR preparation team specifically to address potential visual aesthetic/urban design considerations and impacts and to ensure that the EIR-identified mitigations formulated to maximize project compatibility with the Bayfront environs
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5-2-03 Redwood City Manager letter (2 pages)
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5-2-03 Redwood City Manager letter (2 pages)
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adequately reflect the most recent input on this matter from the public and Redwood City Planning Commission.
Specific references to the ongoing Bayfront Study are included throughout the Draft EIR. For example, on Draft EIR pages 3-8 and 3-9, the document describes the City’s current consideration of a number of substantial development activities in the Bayfront area, including the pending Marina Shores Village and Abbott Laboratories applications, and the anticipated (recently received) Syufy Enterprises (Syufy Theaters) application, and states the following with regard to the subject Bayfront Study:
"...to supplement and integrate these three substantial project-specific development and environmental review efforts, and analyze the key urban design and transportation issues associated with such development in the Bayfront Area, the City is currently undertaking the Bayfront Study, which is being completed with the assistance of a consulting urban design firm (Bottomley Planning and Design), and will establish specific land use criteria, development standards, and design guidelines to ensure optimal and harmonious development of the area consistent with the Redwood City Strategic General Plan. A Bayfront Transportation Options Study, which is part of the Bayfront Study, is being completed with the assistance of a consulting transportation planner (Kimley-Horn and Associates, Inc.) and a planning and design firm (Fukuji Planning and Design) in order to identify specific and innovative transportation options for the area, with emphasis on possible multi-modal (vehicular, pedestrian, bicycle, transit, and water) connections within the Bayfront Area, and between the area, the downtown, and major interregional transit corridors.
The proposed approximately 136-acre Bayfront Study area includes the Marina Shores Village, Abbott Laboratories, and Syufy Enterprises sites, as well as additional lands surrounding the project site. Planning issues will focus on the visual appearance, urban design, transportation, infrastructure, and fiscal aspects of anticipated future redevelopment of the Bayfront Area.
Also, Draft EIR section 4.2.4 (Current Planning Studies for the ”Bayfront” Area) and section 16.2 (Current Redwood City Bayfront Study), the Draft EIR provides the following additional more detailed description of the Bayfront Study effort:
To integrate and supplement these three substantial project-specific development and environmental review efforts, and study the key urban design, transportation, infrastructure, and fiscal issues associated with such development in the Bayfront Area, the City is currently undertaking the Bayfront Study. The proposed approximately 136- acre Bayfront Study area includes the Marina Shores Village, Abbott Laboratories, and Syufy Enterprises sites, as well as additional lands surrounding the project site. The study is being completed with the assistance of a consulting urban design firm (Bottomley Planning and Design), and will identify specific land use, urban design, and transportation concepts for achieving appropriate, harmonious development of the Bayfront Area consistent with the Redwood City Strategic General Plan. As part of the Bayfront Study, a
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Bayfront Transportation Options Study is also being completed with the assistance of a consulting transportation planner (Kimley-Horn and Associates, Inc.) and a planning and design firm (Fukuji Planning and Design) in order to identify specific and innovative transportation options for the area, with emphasis on possible multi-modal (vehicular, pedestrian, bicycle, transit, and water) connections within the Bayfront Area, and between the area, the downtown, and major interregional transit corridors. The current Bayfront Study is available for review at the City of Redwood City Community Development Services Department, City Hall, 1017 Middlefield Road.
However, as some commenters have correctly indicated, contrary to the last sentence in the above Draft EIR paragraph, a Bayfront Study product was not available for review at City Hall at the time the Draft EIR was released for public review. As of this writing, a preliminary version of the Bayfront Study document is available for review, and public workshops are being conducted.
Also, as indicated in the Draft EIR under Mitigation 7-2 (DEIR pages 2-21 and 7-49), transportation demand management (TDM) measures currently being considered for the Marina Shores Village project as part of the Bayfront Study effort are listed at the end of Draft EIR chapter 7 (Transportation and Parking, page 7-103) for consideration by the City and the project applicant in implementing the EIR-required future, more detailed TDM program for the project.
A number of commenters have also suggested that the “Bayfront Plan” policies should be treated in the Draft EIR as part of the significance criteria applied to determine land use impacts (referring to Draft EIR section 4.3.1, “Significance Criteria”). The list of significance criteria included in this Draft EIR section has been carefully based upon pertinent CEQA Guidelines, as noted in the associated footnote. The list here (Draft EIR page 4-23) includes under item (2) whether the project would “conflict with any applicable land use plan, policy or regulation of the City...,” a criterion that was derived from CEQA Guidelines Appendix G, item IX (Land Use and Planning), subsection (b): “Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan, specific plan, local coastal programs, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect?” The Bayfront Study does not meet this CEQA definition. It is a “study,” not a “plan,” and as of this writing, it has not been “adopted” by the City as an official plan, policy, or regulation.
Master Response E: Project Compatibility with Aviation and Industrial Noise. Many comments made during the Draft EIR public hearing and submitted in writing during the Draft EIR public review period expressed concern over existing noise in the project vicinity and the compatibility of the proposed project with the existing noise environment; such comments were not concerned with noise generated by the proposed project itself. (Comments received regarding construction noise generated by the proposed project are not addressed in this master response, but in response PC 4.01.)
Concerns raised regarding the existing noise environment focused on the adequacy of the noise measurements (noise monitoring data) included in the Draft EIR and the actual impact of
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existing and projected noise levels on the project from two existing noise sources: (1) airplane overflights, especially from the San Carlos Airport, and (2) nearby industrial uses. Each of these issues is discussed below.
1. Noise Generated by Airplane Overflights. Existing and projected aircraft noise and associated potential impacts and mitigation needs are fully and adequately addressed in Draft EIR chapter 13 (Noise), as summarized and clarified below.
Noise measurements conducted on-site by the EIR acoustical consultants, Illingworth & Rodkin, Inc., in combination with a review of the San Mateo County Comprehensive Airport Land Use Plan (ALUP) and the San Carlos Airport Noise Abatement Procedures contained therein, indicate that existing and anticipated future noise generated by aircraft would be less than 55 dBA CNEL at ground-level exterior areas within the project site. Residential land uses in such exterior noise environments of less than 55 dBA CNEL are considered compatible with the ALUP. The 55 dBA CNEL noise contours represent adjusted average 24-hour noise levels generated by aircraft only. Following standard CNEL noise computation procedures, variations in noise generated by single events have been averaged into the calculations of the CNEL contours. The standard CNEL value computation methodology has been formulated to account for noise generated by individual aircraft, planned annual operations, and varying sensitivities based on the time of day that the noise events occur. Weekend versus weekday and seasonal variations of the flight path have also been accounted for in the Draft EIR calculation of the CNEL noise contours.
The height of the proposed residential towers is such that maximum intermittent noise levels generated by individual aircraft overflights would be about 6 dBA higher at the highest residential stories than those measured at ground level, and the CNEL (adjusted average 24- hour noise level) would be approximately 3 dBA higher than the level reported at the ground. Therefore, exterior noise levels at the highest stories of the residential towers could exceed the City-adopted 55 dBA CNEL limit for compatible residential land uses. Where CNEL noise levels exceed 55 dBA but are less than 60 dBA, residential land uses are considered by the City (General Plan Noise Element) to be "conditionally compatible" (see Draft EIR subsection 13.2.3- -San Carlos Airport Land Use Plan). No shielding of aircraft noise by project structures was assumed in the noise calculations. During future, more detailed project architectural design phases, a design-specific noise study would be required to identify specific noise insulation measures (specifications) required to meet the interior noise standard of 45 dBA CNEL established by the City and the State. The Draft EIR stipulates that any project-related residential construction shall be undertaken only after this more detailed, specification level analysis of the noise reduction requirements is made and the required noise insulation features are included in the project design (see Mitigation 13-1).
The project applicant has also stated the intent to include specific language in the purchase and sale agreement for each residence, requiring the buyer’s initials, indicating acknowledgment of the Marina Shores Village project’s proximity to airport and industrial operations and associated potential noise levels; the applicant has also indicated that the same language would be included in the property CC&Rs (Covenants, Conditions, and Restrictions).
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2. Noise Generated by Nearby Industrial Uses. Noise data collected on-site by the EIR acoustical consultant, Illingworth & Rodkin, Inc., during the noise monitoring survey, in combination with data collected by the same acoustical consultant during the preparation of the Pacific Shores EIR, were analyzed to identify the potential for noise impacts on the project resulting from adjacent industrial operations. The monitoring data demonstrates that the predominant source of noise affecting the project site is vehicular traffic along U.S. 101 and general aviation aircraft overflights, as identified in Draft EIR chapter 13 (Noise). Areas immediately adjacent to industrial land uses to the east of the project site may also be affected by industrial noise. Two long-term noise measurements were conducted over a period of several days to record the daily trend in noise affecting the project site. Additionally, several short-term noise measurements were conducted to quantify noise levels throughout the site.
Based on observations made during these noise measurements of a materials processing plant immediately east of the nearest proposed project residential land uses (noise measurement location ST-5 on Draft EIR Figure 13.1), the EIR acoustical consultants have estimated that exterior noise levels at the project site resulting from the nearest industrial uses would range from approximately 58 to 59 dBA CNEL. The projected overall exterior noise level, including noise generated by U.S. 101 and general aviation aircraft, would be approximately 60 to 63 dBA CNEL.
In addition, noise measurements of industrial uses north of the project site along Seaport Boulevard were conducted by the EIR acoustical consultants in March 1996 to quantify noise levels for the Pacific Shores EIR. Calculations completed by the EIR acoustical consultant of the propagation of noise from these industrial sources north of the Marina Shoes Village site along Seaport Boulevard (e.g., Sims Metal, etc.) indicate that noise generated by these facilities currently yield CNEL noise levels of about 40 dBA at the project site. These estimated noise levels generated by these industrial facilities would not measurably contribute to the ambient noise environment resulting from U.S. 101 and general aviation aircraft.
Based on the Marina Shores Village preliminary site plan, it appears that many of the proposed project exterior use areas would be located in areas that would be shielded by the proposed buildings themselves. Exterior noise levels in such internal protected areas would be expected to be below the City’s normally acceptable level of 60 dBA CNEL for residential areas, assuming the shielding provided by the buildings. However, exterior noise levels generated by traffic, aircraft, and adjacent industrial uses would exceed 60 dBA CNEL at a number of multifamily land use locations on both the north (Pete's Harbor) and south (Peninsula Marina) portions of the project. Mitigation requirements identified in the Draft EIR as necessary to meet the interior noise standard of 45 dBA CNEL established by the City and the State (Mitigation 13-1) include conducting a design-specific noise study during future, more detailed project design phases to identify the noise insulation specifications required in the project architectural design to meet an interior noise level of 45 dBA CNEL. These measures may include the incorporation of forced- air mechanical ventilation systems and sound-rated windows.
The City's normally acceptable noise level for open space, which would include the proposed
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project's perimeter pedestrian and bicycle paths as well as the proposed off-site public park, is 75 dBA CNEL. One of the proposed public open space areas is projected to exceed this threshold: a portion of a path near U.S. 101 (see noise measurement location ST-3 on Draft EIR Figure 13.1). However, based on the General Plan (page 11-4), because no "concentrations of people (spectator sports or some recreational facilities) or of animals (livestock farming and animal breeding)" are proposed, open space use in this particular area would be considered acceptable.
The project applicant has stated an intent to include specific language in the purchase and sale agreement for each residence, requiring the buyer’s initials, and acknowledging awareness of the Marina Shores Village project’s proximity to airport and industrial operations and associated potential noise impacts. The same language would also be included in the property CC&Rs (Covenants, Conditions, and Restrictions).
Master Response F: Bird Collision. Several comments made during the Draft EIR public hearing and submitted in writing during the Draft EIR public review period expressed concern over bird collisions (strikes) resulting from the number and heights of buildings proposed under the project. This issue is discussed in Draft EIR chapter 8 (Biological Resources), subsection 8.3.5 (General Plant and Wildlife Impacts), Impact 8-8 (Project-Related Bird Collisions).
Draft EIR Mitigation 8-8 (page 8-45) concludes that bird collisions resulting from the proposed project would be a significant unavoidable impact. Because most birds avoid collisions during daylight hours, the Draft EIR concludes that the primary method for reducing collisions would be to adopt a lighting policy (e.g., requiring minimal exterior night-lighting, shielding techniques, light timers, etc.) as part of the project’s architectural review process. Reduced and shielded low-intensity lighting set against the existing background of the west shoreline would reduce the number of birds attracted to the proposed project towers during nocturnal movements; such mitigation applied to structures of any height could reduce bird collisions. However, because some collisions still would occur, the impact is identified in the Draft EIR significant and unavoidable.
In addition to reducing the potential for bird collisions, Mitigation 8-8 would effectively mitigate project-related general outdoor lighting impacts on biological resources (see Draft EIR page 8- 45). In effect, the same measure (i.e., an adopted lighting policy incorporating the performance standards described under Mitigation 8-8) would help reduce two different impacts. In the case of general outdoor lighting impacts (Impact 8-9), Mitigation 8-8 would reduce these impacts to less-than-significant levels by reducing light intrusion into nearby natural communities.
In addition, the option of reducing project building heights in order to avoid bird collisions is considered in Draft EIR chapter 17 (Alternatives to the Proposed Project) under the “(e) Biological Resources” heading for each alternative. Generally, as the number and/or heights of buildings decrease, so would the expected number of bird collisions; however, the alternatives analysis concludes that, except for the “No Project” (i.e., no development) alternative, all project alternatives would result in a significant unavoidable bird collision impact because, based on the introduction of new buildings and structures, such strikes would be inevitable. Even with no
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additional development on-site (i.e., no additional environmental impacts), an undocumented number of bird strikes would continue to occur (e.g., into the electrical towers, airplanes, and existing buildings).
Regarding the comments received from the Oracle Corporation (4.01 and 4.02), the anecdotal reports of bird collisions at the Oracle site are lower than expected; however, small songbirds and shorebirds migrating at night may collide with buildings without being noticed, especially if the birds fall into landscaping or are removed by nocturnal scavengers. Raptors, such as the falcons at the Oracle site, rarely are themselves victims of collisions, since they typically are not active at night.
Master Response G: Project Consistency with “Smart Growth” Concepts. A number of comments were made during the Draft EIR public hearing and subsequently in writing, pertaining to project consistency with so-called “smart growth” and “sustainable growth” planning concepts. One commenter urged City consideration of how the proposed project fits in to the “sustainable growth” picture (PC 19.01), particularly in terms of project traffic and water use impacts (PC 19.02). Another commenter questioned the Draft EIR conclusions regarding project consistency with “smart growth” concepts, noting that the Draft EIR includes a mitigation measure calling for a shuttle bus connection to the City’s central transportation hub, while “smart growth policy” calls for location of infill next to or within walking distance of the hub (PC 20.06, 17.06). Another commenter suggested that the “effective transit link” smart-growth measure could include “designated shuttles beyond additional SamTrans buses” (17.21), and a water taxi, as first proposed by the applicant, to provide a direct link between the project residential component and job concentrations in Pacific Shores Center (17.22). Another commenter suggested that, if relocated to the downtown, the project could take better advantage of existing transportation infrastructure and facilitate the City’s downtown redevelopment objectives (29.02).
Response: The Draft EIR discusses “smart growth” and “sustainable growth” concepts on pages 4-19 through 4-22 and 4-33 through 4-36 pointing out their relevance to consideration of the proposed Marina Shores Village project, a high-intensity residential infill development. The Draft EIR points out on these pages that: (1) the “smart growth” concepts, policies and criteria set forth in adopted local (Redwood City General Plan) and regional (ABAG) land use policy documents are particularly applicable to intensive, large-scale residential and commercial development like the proposed project; and (2) the project embodies a number of fundamental “smart growth” characteristics: it is a compact, high-density residential project that is pedestrian-oriented and located within an existing urban area, rather than being geographically isolated. But the Draft EIR also points out on these pages that the project would be considered inconsistent with various other key City and ABAG “smart growth” policies and criteria, unless the applicant can demonstrate to City satisfaction that: (1) there will be adequate water and park facilities to serve the project, (2) a “convenient and effective” transit link can be provided to a local or regional transit corridor or hub (e.g., the El Camino Real transit corridor, Redwood City/CalTrain intermodal station, and Redwood City downtown), (3) retail commercial provisions will be provided onsite or nearby sufficient to serve the convenience needs of project residents and businesses, and (4) a specific and substantial below-market-rate housing component is
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included in the project.
There is no adopted City or regional “policy” specifically requiring location of such high-intensity infill developments next to or within walking distance of the City’s hub. As indicated on Draft EIR page 4-20, there are City General Plan policies stating that: (a) higher residential densities should be “promoted at locations near or within commercial and financial centers, employment centers, and transportation terminals” (Policy L-3); (b) residential development “should be located only where services and facilities can be provided” (Policy L-1); and (c) the City should “promote the construction of lower-income housing developments located in areas that are convenient to public transportation, shopping, recreation, schools, hospitals, employment, and other community facilities” (Housing Policy 1).
There is no known applicable policy or requirement that a project of this nature be located within a specific distance of a transit hub or the downtown. As indicated on Draft EIR pages 4-20 and 4-21, ABAG-suggested “smart growth” criteria include development that “revitalizes central cities and older suburbs,” “supports and enhances public transit,” “promotes walking and bicycling.” The Draft EIR also identifies the “unofficial” smart-growth criteria of the Greenbelt Alliance public interest group, including the endorsement criterion that the project be “within 1/2 mile or a ten-minute walk from major transit service, defined as a rail or bus stop served by six or more buses per hour during peak periods,” and the similar unofficial smart growth criteria of the Urban Ecology public interest group, including the endorsement criterion that the project be “within 1/4 mile of a downtown or 1/2 mile of a transit stop with current or planned service levels of at least six vehicles per hour during the peak period.” These unofficial public interest group criteria are presented in the Draft EIR for informational purposes only and cannot be officially applied in the EIR as adopted policy or regulation.
To substantially improve project consistency with official “smart growth” policies and unofficial “smart growth” criteria, the Draft EIR under Mitigation 4-3 does call for implementation of specific measures to: (1) assure adequate water service (with reference to related Mitigations 10-1 and 10-8), (2) ensure convenient and effective transit link between the project and local and regional express transit corridors and/or hubs, including the El Camino Real transit corridor and Redwood City CalTrain intermodal stations, and “between the project, downtown Redwood City, and other local employment, financial and retail concentrations”; (3) provide onsite convenience retail provisions within the project; and (4) provide a “substantial affordable housing component.”
With regard to the shuttle bus system suggested by one commenter, as indicated on Draft EIR pages 3-26, 7-49 and 7-54, the project applicant is proposing to establish, in cooperation with Sam Trans, a shuttle bus system connecting the project via downtown Redwood City to the CalTrain station and El Camino Real interregional transit corridor 1.5 miles southeast of the project site. At this preliminary point, the shuttle system is envisioned by the applicant as “a single shuttle bus with a round trip route that would take approximately 30 to 35 minutes.” The applicant has indicated that “additional shuttle service could be added based on rider demand.” As also stated in Draft EIR page 7-54, “once the Blomquist Extension is completed, the Marina Shores Village shuttle could link with existing shuttles that presently serve Seaport Center and
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Pacific Shores Center.”
The “water taxi” to Pacific Shores concept mentioned by one commenter would be of limited effectiveness, i.e., would provide only a limited link between the project and one of many local and regional employment centers.
With regard to the commenter suggestion that the project be relocated to a downtown site, from a hypothetical standpoint, a downtown location would, as the commenter suggests, be more in keeping with identified “smart growth” concepts and criteria, but such a measure has not been identified in the Draft EIR as a mitigation requirement, since the applicant has no current prospect of control over a downtown property of sufficient size to accommodate such a project, and such a measure would therefore be infeasible (and therefore, contrary to Public Resources Code sec. 21081(c) and related CEQA Guidelines section 15091(a)(3)).
Master Response H: Loss of Peninsula Marina Slips Prior to EIR. One particular comment submitted in writing during the Draft EIR public review period (comment 11.03) expressed concern over the removal of boat slips from Peninsula Marina in November 2001, and why this action was not considered part of the proposed project addressed in the Draft EIR. To clarify this technical issue, this master response has been prepared.
Specifically, CEQA Guidelines section 15126.2 (Consideration and Discussion of Significant Environmental Impacts) explains, “In assessing the impact of a proposed project on the environment, the lead agency should normally limit its examination to changes in the existing physical conditions in the affected area as they exist at the time the notice of preparation is published, or where no notice of preparation is published, at the time environmental analysis is commenced.” The Notice of Preparation (NOP) for the Marina Shores Village project (see EIR appendix 21.1) was published in February 2002. The removal of the Peninsula Marina boat slips by the property owner/project applicant, which was a separate action taken prior to the submittal of the Marina Shores Village project application, occurred in November 2001, prior to the publication of the Marina Shores Village NOP. Therefore, the removal of the boat slips is considered a separate action that is not part of the proposed project. Nevertheless, if Marina Shores Village is developed, it is assumed that an undetermined number of the future new project residents with boats would relocate their boats from public slips in the Bay area to the private Marina Shores Village marinas, thereby making available an undetermined number of these previously occupied Bay area public boat slips.
Also, please see Draft EIR chapter 6 (Population, Housing, and Employment), subsection 6.3.6 (Impacts and Mitigation Measures), for a discussion of how the displacement of live-aboard represents a "nonenvironmental" housing issue.
Master Response I: Project-Related Affordable Housing Issues. Several comments in support of, or posing questions regarding the adequacy of the proposed project’s affordable housing component were made at the Draft EIR public hearing and/or submitted in writing during the Draft EIR public review period. Under CEQA, issues regarding housing affordability are socio-economic rather than environmental, and therefore not a required EIR subject.
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Effects analyzed under CEQA must be related to a physical change in the environment (Guidelines sec. 15358(b)). Economic and social effects are not considered environmental effects under CEQA. These effects need to be considered in EIRs only if they would lead to an environmental effect. Also, as Draft EIR chapter 6 (Population, Housing, and Employment), page 6-14, states, “The goals, policies, and regulations of the City with respect to housing do not include specific housing affordability requirements for new residential development.” As a privately financed and developed project outside a redevelopment area, the proposed project is therefore not required to offer residential units at below-market rates. However, the project applicant (Glenborough-Pauls, LLC) has committed to formulating and implementing a “workforce housing program” as described below by the applicant.
Glenborough-Pauls (GP) is committed to providing 15 percent of the homes in Marina Shores Village as workforce housing. This commitment is voluntary, as Redwood City does not have inclusionary zoning that would mandate affordability of homes.
Based on 1,930 homes proposed for the entire project, this would equate to 290 workforce-priced homes.
GP's intent is to provide homes across a full spectrum of below-market income levels.
Workforce homes would be available across all income levels earning between 30 percent through 170 percent of the County median household income (at the time of home purchase).
The workforce homes would be distributed throughout all phases and across all building types (towers and mid-rise), except for the townhomes and homes located on floors where there are four homes or less per floor in the towers.
There would be an approximate equal number of one-bedroom and two-bedroom homes made available throughout the entire project. The number of specific home types may be different within a given phase of development.
GP would underwrite extremely attractive financing to fund the difference between the "market" price of the home and the amount needed to achieve affordability requirements.
Subordinated loans (2nd and 3rd loans) would be made by the Housing Endowment and Trust of San Mateo County (HEAT-SMC) (or comparable agency), backed by GP. Loans would be based on the Countywide Homeowner Investment Partnership (CHIP) model (or comparable financing model) that is presently used by several public agencies in San Mateo County.
Any shared appreciation created by rising home values would flow back to HEAT-SMC (subject to a mutually acceptable agreement) and be counted as a contribution to HEAT on behalf of the City of Redwood City.
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First Home (or a similar entity) would administer the "workforce housing finance" program and likely arrange mortgage financing for many of the buyers. Program administration would be in accordance with the priorities and preferences determined by the City of Redwood City.
First Home is also proposing a "Community Challenge" program through which employers would be able to direct homes to income-qualified buyers by funding a portion of the CHIP loans.
Any participation in the Community Challenge would be additive to the GP commitment. With active participation in the Community Challenge program, the actual number of workforce homes would exceed the 15 percent GP commitment.
Other possible program elements could include a "Silver Lining" program where residents moving from a single-family residence in San Mateo County and into Marina Shores Village could direct a workforce home to an income-qualified buyer.
The commitment of GP's financial subsidy would be pre-determined and "capped" in each project phase.
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PLANNING COMMISSION MEETING COMMENTS ON THE DRAFT EIR
The following section includes the minutes for the segment of the April 1, 2003, City of Redwood City Planning Commission meeting devoted to the Draft EIR on the Marina Shores Village Project, including Commissioner comments and public hearing comments from members of the public, immediately followed by the EIR authors' response to substantive comments therein pertaining to the adequacy of the EIR. The comments and responses are correlated by code numbers added to the right margin of the minutes.
2.4 RESPONSES TO APRIL 1, 2003 REDWOOD CITY
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(95-page transcript incl. handout re. noise from James Jonas)
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PC 1. Tim Ridner, Director of Development, Glenborough-Pauls
PC 1.01 General comment: EIR thoroughly analyzes impacts; very conservative approach taken; various alternatives analyzed; not a marketing piece for the project.
Response: Comment acknowledged; no response necessary.
PC 2. Commissioner Kenneth McCoy
PC 2.01 CEQA-Required Assessment Considerations–significant unavoidable impacts: question regarding relationship between EIR-identified “significant unavoidable impacts,” certification of EIR, and potential approval of a project.
Response: The comment was adequately addressed by City staff and the EIR consultant at the public hearing; no additional response necessary.
PC 2.02 Water Service–impacts and mitigation measures: question regarding timing of water supply verification and tentative subdivision map approval.
Response: The comment was adequately addressed by the EIR consultant at the public hearing. Also, please see Master Response C (Water Supply Issues).
PC 2.03 Water Service–impacts and mitigation measures: can demolition or soil grading occur if water supply has not been verified?
Response: No. The comment was adequately addressed by City staff and the EIR consultant at the public hearing. Also, please see Master Response C (Water Supply Issues).
PC 3. Commissioner John D. Seybert
PC 3.01 Water Service–impacts and mitigation measures: questions regarding water supply and relationship between Senate Bill (SB) 610 and SB 211.
Response: The comment was adequately addressed at the public hearing. Also, please see Master Response C (Water Supply Issues).
PC 4. James Jonas, Docktown Resident
PC 4.01 Noise–impacts and mitigation measures: for Docktown residents, construction noise impacts will be substantial; if construction lasts months or years, substantial impact on Docktown property valuation could result; “much more detailed [noise] analysis” recommended.
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Response: Construction period noise impacts are discussed in the Draft EIR under Impact 13-3. Given the potential for high noise levels during project construction and the anticipated duration of project construction, the impact has been identified in the Draft EIR as potentially significant. Measures presented in the Draft EIR under Mitigation 13-3 would reduce noise generated by project construction. However, the Draft EIR indicates that this impact would remain significant and unavoidable given the proximity of nearby residential receivers and the duration of construction.
Economic effects that may arise at neighboring properties from construction noise are not germane to an EIR (CEQA Guidelines section 15131); however, the comment is now part of the public record to be considered by City decision-makers in their future deliberations on the project.
PC 4.02 Noise–impacts and mitigation measures: EIR noise mitigation insufficient; “continuous [noise] monitoring” and “monitoring program” recommended.
Response: As suggested by this commenter, continuous monitoring of noise generated by project construction could be incorporated into Draft EIR Mitigation 13- 3. However, such a measure is considered to be infeasible due to the difficulty of continuously measuring and monitoring temporary noise events. Instead, assignment of a noise disturbance coordinator has been suggested to respond to construction noise complaints and find reasonable solutions to correct any problems.
PC 4.03 Air Quality, and Transportation and Circulation–impacts and mitigation measures: concerns regarding dust, southerly winds, bicycle traffic (welcomed), and Blomquist Extension.
Response: Construction and demolition dust issues are addressed on pages 15-8 and 15-9 of the Draft EIR. Construction dust is identified as a potentially significant but temporary impact. The Draft EIR identifies construction dust mitigation practices to be included in project construction contracts. Implementation of appropriate dust control measures as recommended in the Draft EIR would, according the Bay Area Air Quality Management District, reduce this impact to a less-than-significant level.
PC 5. Clem Maloney, employee, Lyngso Garden Materials; Secretary, Seaport Industrial Association
PC 5.01 Land Use–impacts and mitigation measures: compatibility of proposed project with existing nearby industrial uses “is definitely a significant impact”; Bayfront Study acknowledges existing industry’s importance.
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and D (Bayfront Study Discussion).
PC 5.02 Transportation and Circulation–impacts and mitigation measures: EIR does not
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include U.S. 101 southbound on-ramp at Seaport Boulevard.
Response: As shown in Table 7.16, the proposed project is not expected to result in a significant impact at the Blomquist Street/Seaport Boulevard intersection with the extension of Blomquist Street over Redwood Creek. The intersection is expected to operate at LOS D. It is important to note that in addition to providing access between the Bair Island area and Seaport Boulevard, the Blomquist Street Extension will allow traffic from Seaport Boulevard to use the U.S. 101/Whipple Avenue interchange. The Woodside Road/Veterans Boulevard-SB 101 on-ramp is projected to operate at LOS D, and no significant impacts are anticipated in the near term. However, a cumulative project impact (Impact 7-20) was identified at this location, and the associated mitigation measure calls for widening Veterans Boulevard to include two southbound lanes plus widening of the on-ramp.
PC 5.03 Transportation and Circulation–impacts and mitigation measures: expected back-up on Whipple at Veterans will result in drivers using Blomquist-Seaport route to U.S. 101 south; expanded left-turn pocket may be needed at Seaport on-ramp.
Response: The Whipple Avenue/Veterans Boulevard intersection is projected to operate at LOS D with the proposed project in place and no significant impacts are projected. It is important to note that in addition to providing access between the Bair Island area and Seaport Boulevard, the extension will allow traffic from Seaport Boulevard to use the U.S. 101/Whipple Avenue interchange. It is also important to note that the housing portion of the proposed project will primarily generate inbound trips during the PM peak hour (when the westbound left-turn queue at the Veterans Boulevard/Woodside Road intersection is expected to be at its worst). These inbound trips would not contribute to the queue at this intersection. A queuing analysis was conducted and it was determined that the addition of project traffic to the left-turn movement would not increase the maximum expected queue at the intersection under Project Conditions with the Blomquist Street Extension in place.
PC 5.04 Transportation and Circulation–impacts and mitigation measures: incompatibility between proposed commute vehicles and existing large delivery trucks on Blomquist Street is a significant impact.
Response: The addition of passenger vehicles to streets with large trucks does not inherently cause an increase in potential traffic hazards as addressed by the CEQA Guidelines (see Draft EIR subsection 7.3.b, significance criteria for traffic and parking impacts). Additionally, there is no City policy that discourages commute traffic from being added to roadways serving heavy vehicles. As long as roads are designed to appropriate standards and adequate sight distance is provided, the addition of passenger vehicles to streets with higher truck traffic volumes is not expected to result in a significant transportation impact.
PC 5.05 Project Consistency With Adopted Plans and Policies–current Redwood City
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Bayfront Study: EIR refers to “Bayfront Study as an important planning document,” but study was not available when requested.
Response: Please see Master Response D (Bayfront Study Discussion).
PC 5.06 Land Use–impacts and mitigation measures: “neighborhood compatibility is important”; tenants “need to be made fully aware of the neighborhood that they are moving into.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
PC 6. Jack Castle
PC 6.01 Land Use and Visual Factors–impacts and mitigation measures: other cities have “benefited greatly” from infill projects with tall buildings. Hopefully, the EIR analysis and mitigation process can allow for tall buildings in Redwood City.
Response: Comment acknowledged. Comment pertains to general merits of project and hopes for the EIR process, rather than Draft EIR adequacy; no additional response is necessary.
PC 7. Chris Mann, Director of Real Estate, Granite Rock
PC 7.01 General Comment: in the EIR, “everything around within a mile radius didn’t seem to get addressed.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and responses to subsequent specific comments PC 7.02 and PC 7.03 below.
PC 7.02 Transportation and Circulation–impacts and mitigation measures: EIR traffic analysis should include future full occupancy of Pacific Shores offices.
Response: Full occupancy of Pacific Shores and Excite@Home was assumed under Background Conditions prior to analyzing near-term project impacts, and traffic from all approved projects was included under this scenario. The transportation analysis addresses cumulative conditions, including all pending projects, beginning with subsection 7.3.13 (Cumulative [Year 2020] Without Project Conditions).
PC 7.03 Land Use, Noise, and Air Quality–impacts and mitigation measures: nearby industries operate 24 hours a day, and contribute noise and dust to area; project residents might complain about historical and ongoing industrial conditions; willing to work with developer on disclosure documents for future residents.
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Response: Please see Master Response A (Project Compatibility with Existing Residential Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise). Regarding dust issues, the Draft EIR identifies industrial sources as existing pollutant sources in chapter 15 (Air Quality) on page 15-6. The Draft EIR identifies these sources as asphalt and concrete batch plants, sand and gravel operations, and bulk material handling facilities. On page 15-10 of the Draft EIR, the potential for air quality based land use conflicts is discussed. An increase in potential for land use conflicts also is identified. However, there are ameliorating factors to be considered. The first is the presence of Redwood Creek, which provides a buffer zone between the land uses, and the second is the character of the wind at the site, which places the proposed project upwind of existing industrial sources approximately 97 percent of the time. Based on this analysis of siting and climate, air quality related land use conflicts are considered to be less-than- significant.
PC 8. Pat Dixon, Redwood Shores Resident
PC 8.01 Noise–impacts and mitigation measures: noise analysis does not address noise “carry[ing] over the wetlands” or noise resulting from the airport landing pattern; “I have not seen a noise study done.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise). As the commenter notes, sound does “carry” over water (e.g., wetlands); except for the dispersion of sound over distance, water does not provide additional sound absorption. Based on the project characteristics and the EIR noise analysis results, the EIR acoustical consultants have concluded that noise from the proposed project would not measurably contribute to the noise environment off-site.
The proposed project is not expected to alter airport operations; therefore, the effect of existing airport operational noise on adjacent (off-site) wetlands is an existing condition that would not be affected by the project and therefore is not germane to the EIR. However, in accordance with CEQA, Draft EIR chapter 8 (Biological Resources, Impact and Mitigation 8-4) does address project-generated construction- period and long-term operational noise impacts on wildlife.
PC 8.02 Soils and Geology–setting, impacts and mitigation measures: project area is all filled land; can something this size be built on that land?
Response: Yes. Based on site-specific analyses, Draft EIR chapter 11 (Soils and Geology) adequately describes existing soil and geotechnical conditions at the project site, potential project impacts in light of these conditions, and mitigation measures necessary to reduce potentially significant soil and geologic impacts to less-than-significant levels, including the need (requirement) for subsequent, more detailed, design-level geotechnical investigations as the project design details are
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advanced. At this preliminary stage in project design, required mitigation measures are expected to include pile-driven foundations, flexible utility connections, hinged exterior slabs and ramps attached to buildings, sloped/shored excavations, and other specific design and construction measures.
PC 8.03 Transportation and Circulation–impacts and mitigation measures: will there be an additional 75-second wait at most of the intersections?
Response: The trip generation for the proposed project was estimated using standard trip rates for high-rise apartment buildings and compared to surveys conducted at several multifamily residential locations on the Peninsula, which actually exhibited lower trip rates. As shown in Draft EIR Tables 7.11 and 7.16, the additional average wait time at signalized intersections resulting from the addition of project-generated traffic is expected to range from 0.1 to 10.5 seconds under near- term conditions.
PC 8.04 Water Service, Sewer Service, and Parks and Recreation–impacts and mitigation measures: insufficient water, sanitary lines, and lack of bike trail not addressed in Draft EIR.
Response: All of the above-mentioned issues are adequately described in the Draft EIR, as follows: water service–chapter 10 (Infrastructure and Public Services), section 10.1 (Water Service); sanitary lines–chapter 10, section 10.2 (Sewer Service); and bike trails–chapter 7 (Transportation and Circulation), subsection 7.1.4 (Bicycle and Pedestrian Facilities), Impact/Mitigation 7-9 (Bicycle Accessibility Impact), and chapter 4 (Land Use), subsection 4.2.6 (Regional Plans), including Figure 4.4 (Planned San Francisco Bay Trail Alignment). For additional information regarding water service, please see Master Response C (Water Supply Issues).
PC 8.05 Transportation and Circulation–setting, impacts and mitigation measures: existing rail lines along Seaport Boulevard “should be converted to light rail” that could run along Blomquist Street “to the far end of Pacific Shores,” which would alleviate traffic.
Response: Use of the existing railroad lines to provide future light service is addressed in the Bayfront Study, which on completion will be available for review at the City of Redwood City Community Development Services Department, City Hall, 1017 Middlefield Road. However, this improvement is not approved or funded and, therefore, was not included in the Draft EIR analysis; the result is a more conservative evaluation of project traffic impacts, consistent with CEQA.
PC 8.06 General Comment: “It is a lovely project but just not for that particular location.”
Response: Comment pertains to general merits of project. Alternative locations for the proposed project have been adequately described in accordance with CEQA in
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Draft EIR chapter 17 (Alternatives to the Proposed Project), section 17.9 (Alternative 9: Alternative Sites).
PC 9. Mike Claire, Vice President of Construction, Canada College
PC 9.01 Population, Housing, and Employment–impacts and mitigation measures: “on behalf of the college, finding housing that is attractive is very difficult and is a key obstacle in terms of attracting and retaining faculty and staff.”
Response: Comment acknowledged. Please see Master Response I (Project- Related Affordable Housing Issues).
PC 10. Greg Greenway, Executive Director, Seaport Industrial Association
PC 10.01 Population, Housing, and Employment–impacts and mitigation measures: general support for project, particularly affordable housing component and proposed public space; following comments intended to “improve the EIR as a technical document that is part of a good planning process.”
Response: Comment acknowledged. Please see Master Response I (Project- Related Affordable Housing Issues).
PC 10.02 Land Use and Current Redwood City Bayfront Study–impacts and mitigation measures: Bayfront Study purpose is to address development areawide, rather than project-by-project; study not yet available; study should be part of significance criteria regarding potentially significant impacts; Bayfront Study process has stressed compatibility between heavy industry, light industry, and residential uses.
Response: This issue was addressed by City staff later in the public hearing; please see comment PC 13.01. Also, see Master Response D (Bayfront Study Discussion).
PC 10.03 Land Use, Visual Factors, and Noise–impacts and mitigation measures: “EIR does not take a realistic view of the compatibility issues between heavy industrial uses in the Seaport area and this new residential development”; distance between uses across open water and marshland “does not render those impacts insignificant.”
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise).
PC 10.04 Visual Factors and Noise–setting, impacts and mitigation measures: adequate existing baseline required to assess cumulative light, noise, and other environmental impacts.
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise).
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PC 10.05 Land Use–impacts and mitigation measures: if potentially significant land use compatibility impacts are found, the EIR should include pertinent mitigation; Pacific Shores and West Point Marina mitigation requiring berms, extensive sound-proofing, and notification of tenants regarding nearby industry, should also be considered for Marina Shores Village project.
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise). Also, see mitigation measures in Draft EIR chapters 4 (Land Use) and 13 (Noise).
PC 10.06 Transportation and Circulation–impacts and mitigation measures: cumulative traffic impacts (e.g., with Pacific Shores project) and mitigation should be coordinated with Bayfront Study areawide traffic alternatives analysis and recommendations.
Response: Comment acknowledged. Please see Master Response D (Bayfront Study Discussion).
PC 11. Tom Cronin, Redwood City Resident
PC 11.01 Population, Housing, and Employment; and Parks and Recreation–impacts and mitigation measures: support for developer’s voluntary provision of 15 percent “affordable” residential units, and for public accessibility to currently underutilized waterfront.
Response: Comment pertains to general merits of proposed project. Regarding affordable housing issues, please see Master Response I (Project-Related Affordable Housing Issues).
PC 11.02 Water Service–impacts and mitigation measures: water supply “is the biggest single issue”; quotes from Draft EIR provided; City should consider mandatory use of recycled water.
Response: Please see Master Response C (Water Supply Issues).
PC 12. Linda Kresge, Chief Nurse, Sequoia Hospital
PC 12.01 Population, Housing, and Employment; and Public Health and Safety–setting, impacts and mitigation measures: “Our recruitment efforts have been hampered by nurses’ inability to find affordable housing”; emergency departments need nurses in order to stay open; project could provide local housing for nurses who now commute long distances.
Response: Please see Master Response I (Project-Related Affordable Housing Issues).
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PC 12.02 Transportation and Circulation–impacts and mitigation measures: related to comment 12.01, if nurses lived closer to local work areas and had shorter commutes, wouldn’t traffic be impacted in a positive way?
Response: Yes. Providing additional housing in the vicinity of employment centers in Redwood City and the surrounding area would help to reduce the amount of traffic that must commute across the region.
PC 13. Tom Passanisi, Principal Planner, City of Redwood City
PC 13.01 Project Consistency With Adopted Plans and Policies–Current Redwood City Bayfront Study: response to various comments tonight to clarify content and timing of Bayfront Study (no longer considered a Bayfront Plan); graphics being added to text, then staff review, then public review, then Planning Commission meeting; also may incorporate some of tonight’s comments; Planning Commission will review before EIR is certified.
Response: Comment clarified earlier issues raised at this public hearing regarding Bayfront Study. Also, please see Master Response D (Bayfront Study Discussion).
PC 14. Robin Smith, Sequoia Audubon Society for San Mateo County PC 14.01 Biological Resources–setting, impacts and mitigation measures: Bair Island being restored for three endangered species–tern, California rail, and salt marsh harvest mouse; project on western flyway for migrating birds, which EIR does not address; EIR does not address other birds (e.g., swallows) currently using project area.
Response: No project-related impacts on Bair Island have been identified in the Draft EIR (see chapter 8, Biological Resources). Significant impacts to migratory birds, including shorebirds and passerines, are related to bird collisions with the proposed buildings, and are addressed on Draft EIR page 8-45 (Impact and Mitigation 8-8); please also see Master Response F (Bird Collision).
PC 14.02 Biological Resources–impacts and mitigation measures: “lighting pointing downward” is not enough mitigation to avoid bird strikes into project windows.
Response: Please see Master Response F (Bird Collision).
PC 14.03 CEQA-Required Assessment Considerations–significant unavoidable impacts and cumulative impacts: cumulative effect of “significant unavoidable impacts” not reflected in the EIR.
Response: Cumulative impacts are adequately discussed in the EIR in accordance with CEQA Guidelines section 15130(a) (Discussion of Cumulative Impacts). Please see Draft EIR chapter 18 (CEQA-Required Assessment Considerations), section
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18.4 (Cumulative Impacts), as well as the individual environmental issue chapters (e.g., chapter 7–Transportation and Circulation, chapter 10–Infrastructure and Public Services, and chapter 15–Air Quality).
PC 15. Paul Powers, Glenborough-Pauls
PC 15.01 Transportation and Circulation–impacts and mitigation measures: project location is within three-to-four miles of approximately 93,000 jobs, so shorter commutes would result from potential Marina Shores Village residents who are employed within this radius.
Response: The proposed project does provide additional housing in the vicinity of employment centers in Redwood City and the surrounding area, which would help to reduce the length of commute trips into and out of the greater area (i.e., the Peninsula) and to reduce overall vehicle miles traveled (VMT). However, the project would still generate vehicle trips within the immediate study area which would be added to the study intersections.
PC 15.02 General Comment: EIR purpose is to “measure very conservatively all of the negative impacts”; positive attributes of project will be presented by developer at a later date.
Response: Comment pertains to general EIR purpose and intended use (see Draft EIR chapter 1–Introduction).
PC 16. Kay Eckhardt
PC 16.01 Population, Housing, and Employment–impacts and mitigation measures: a larger project with 15 percent “affordable” residential units will address the Peninsula’s affordable housing shortage more than would a smaller project with 15 percent affordable units.
Response: Comment acknowledged. Please see Master Response I (Project- Related Affordable Housing Issues).
PC 16.02 Introduction–EIR purpose and intended use: 1970 California Environmental Quality Act (CEQA) Guidelines “are inadequate and incomplete and outdated.”
Response: The comment was adequately addressed by the EIR consultant at the public hearing. Please also see response to comment PC 23.08.
The California Environmental Quality Act is California’s most important environmental law. It requires state, local, and other agencies subject to the
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jurisdiction of California to evaluate the environmental implications of their actions. Under the direction of CEQA, the California Resources Agency has adopted regulations, known as the State CEQA Guidelines, which provide detailed procedures that agencies must follow to implement the law. The California Environmental Quality Act (CEQA) and the associated CEQA Guidelines have been periodically updated since the Act was first adopted in 1970. Since 1970, a series of state initiatives have been passed to streamline CEQA, fix practical problems, and make CEQA more effective in achieving its objectives. These initiatives were reflected in comprehensive revisions to the CEQA Guidelines made in 1998. The Draft EIR for the Marina Shores Village project has been carefully formulated to comply with the most recent changes to CEQA, including all legislative and regulatory changes adopted through 1998 and effective in 1999.
PC 16.03 Hydrology and Water Quality–impacts and mitigation measures: if recycled water program is expanded, contaminants, microbes, and radioactivity in the bay will not be removed with chlorine; EIR has no medical expert; who will clean up the contamination–the developer, the taxpayer, or is there some other method?
Response: Projected demand for water in Redwood City exceeds the City’s allocation from the Hetch Hetchy project. Therefore, the City plans to increase its reliance on reclaimed water for non-potable uses such as landscape irrigation. Reclaimed water in Redwood City is provided and managed by the South Bayside System Authority (SBSA). All reclaimed water is subject to disinfection and tertiary treatment, which produces water that meets all of the potable water criteria established by the State Department of Health Services (DHS). This does not mean, however, that such reclaimed water would be contemplated as part of the drinking water supply. A comparative analysis of water quality constituents and characteristics is available on the City website (www.redwoodcity.org), under the heading “Redwood City Recycled Water Project: Water Quality Analysis and Monitoring--Water Quality Table.” Also, the Santa Clara County Medical Association endorses South Bay water recycling. For further information on recycled water safety, see the City website under the heading “Is Recycled Water Safe?”. Given this background information, no significant contamination of surface waters would be expected if the Marina Shores Village project were constructed and the recycled/reclaimed water program were implemented as proposed. Also, please see Master Response C (Water Supply Issues).
PC 17. Judy Sullivan, Redwood City Resident and Employee
PC 17.01 Population, Housing, and Employment–impacts and mitigation measures: EIR adequately describes housing deficiency; in addition, “not only will Marina Shores Village offer new housing stock, but those of us moving there will be freeing existing housing for families.”
Response: Comment acknowledged; no additional response is necessary.
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PC 18. Jim Woolridge, President, San Carlos Airport Pilots Association
PC 18.01 Noise–setting: Draft EIR noise analysis is deficient (noise measurements made on weekdays, not weekends; in winter, not summer; close to ground, not from air where planes are and project towers will be).
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
PC 18.02 Noise–impacts and mitigation measures: “Draft EIR does not analyze the noise effects of the [airplane] traffic pattern in general.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
PC 18.03 Noise–setting, impacts and mitigation measures: Draft EIR does not discuss single- event noise and early morning and late evening take-offs.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
PC 18.04 Noise–setting, impacts and mitigation measures: existing noise measurement peaks assumed to be from aircraft; “not clear what mitigation measures will be effective at ground level or where residents sleep.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
PC 18.05 Public Health and Safety–impacts and mitigation measures: “Overflight[s] at 200-to- 300 feet above the building[s] will have a significant safety, fear, and distress impact”; Draft EIR does not adequately document or mitigate.
Response: Please see Master Response B (Airport-Related Land Use, Public Health and Safety Issues) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
PC 18.06 Public Health and Safety–impacts and mitigation measures: Federal Aviation Administration (FAA) determined that any project “height above 195 feet would warrant a hazard to air navigation”; Draft EIR “should have included the FAA’s required review and its determination and proposed mitigation.”
Response: Please see Master Response B (Airport-Related Land Use, Public Health and Safety Issues).
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PC 19. Ray Wang, Redwood City Resident
PC 19.01 Land Use–setting: comment regarding sustainable growth and City’s “compact with Bay Area Alliance.”
Response: Please see Master Response G (Project Consistency with “Smart Growth” Concepts). Regarding a "compact with Bay Area Alliance," City staff is unaware of any adopted agreement between the City of Redwood City and a group known as the "Bay Area Alliance," nor is staff aware of any adopted agreement with the Greenbelt Alliance, should this be to whom the commenter was referring.
PC 19.02 Land Use–setting, impacts and mitigation measures: comment regarding Redwood City’s overall philosophy related to “pro-growth” versus “sustainable growth.”
Response: Please see Master Response G (Project Consistency with “Smart Growth” Concepts).
PC 19.03 CEQA-Required Assessment Considerations–cumulative impacts: project should be considered “in a more holistic fashion” in context of other Redwood City projects (e.g., Sequoia, Kaiser, Abbott Labs, downtown cinema and housing units).
Response: The Draft EIR does evaluate the cumulative impacts of the proposed project in accordance with CEQA Guidelines section 15130(a); please see Draft EIR chapter 18 (CEQA-Required Assessment Considerations), section 18.4 (Cumulative Impacts). A “holistic” approach to considering development in Redwood City is also the coordinated responsibility of City of Redwood City planning and engineering staff, elected officials, and other City decision-makers. For example, see Master Response D (Bayfront Study Discussion) regarding the City's ongoing efforts to establish specific land use criteria, development standards, and design guidelines to ensure optimal and harmonious development of the Bayfront Area consistent with the Redwood City Strategic General Plan.
PC 20. Commissioner Hilary Paulson
PC 20.01 Project Description–basic project objectives: EIR (p. 3-9) needs to state more clearly that project goals are applicant’s goals, not the City’s.
Response: The text on page 3-9 states that the project objectives are “based on statements and project description materials provided by the applicant.” There is no implication that City residents, staff, or decision-makers subscribe to these same objectives. In response to this comment, the text, in section 3 herein (Revisions to the Draft EIR), has been revised to include this clarification.
PC 20.02 Project Description–EIR (p. 3-10) needs to be consistent about tower heights (e.g., 21 stories over 2 stories parking versus 23 stories); also (p. 3-26), “why does Pete’s
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Harbor section not need a flushing channel like the other marina is getting?”
Response: The descriptions of tower heights are consistent throughout the Draft EIR. The references to “stories above parking” indicate to the reader where the parking structures would be located; such a description can help the reader envision what is proposed on the project site, especially when reading the text while viewing the project illustrations. In any instance where “stories above parking” is mentioned, the total number of stories is indicated in parentheses in the same sentence.
The proposed flushing channel at Peninsula Marina is not required to mitigate any Draft EIR-identified project impact (see Draft EIR page 9-23, Project Water Quality Impacts), although it would slightly reduce “residence times” for the water in Peninsula Marina. Therefore, the flushing channel is basically considered an aesthetic and design feature of the project to allow residents and visitors to be near the water as they walk the site.
PC 20.03 Transportation and Circulation–impacts and mitigation measures: referring to Draft EIR p. 3-30, “does the number parking spaces to be provided meet the current Zoning Ordinance requirement for parking?”
Response: No. The footnotes directly below the table on page 3-30 explain the proposed project’s relationship to current City parking requirements. Also, please see Draft EIR chapter 7 (Transportation and Circulation), subsection 7.3.12 (Project Parking Adequacy), page 7-70.
PC 20.04 Visual Factors–setting, and impacts and mitigation measures: Figure 4.1 (Existing Land Use Context) should show existing building heights or number of stories.
Response: Figure 5.7 on page 5-21 of the Draft EIR illustrates the “existing building height and orientation context” of the project site. Figure 4.1 is intended to show the basic pattern of land use types (existing and planned) in the project vicinity, rather than existing building heights. The separate issue of existing building heights in the project vicinity is fully discussed on Draft EIR pages 4-2, 4-5, 4-6, 4-29, 5-2, 5-3, 5- 12, 5-13, 5-14, 5-15, 5-16, 5-17, 5-19, 5-20, and 5-25. As indicated on these DEIR exhibits and pages, project height relationships to surrounding existing structures have been adequately considered for CEQA purposes. If City decision-makers desire preparation of additional exhibits which graphically illustrate these relationships in more detail, they may ask City staff to do so.
PC 20.05 CEQA-Required Assessment Considerations–significant unavoidable impacts: must City Council adopt a “statement of overriding considerations” for a significant unavoidable impact?; should read “may adopt”; also check for consistent use of “overriding considerations” text in each “significant unavoidable impact” box in EIR.
Response: The comment appears to be equating the City action of “certifying the
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Final EIR” with the City action of “approving the project”; these are two separate and distinct actions. The Final EIR discusses what actions (e.g., General Plan amendments, permit approvals, mitigation measures, etc.) must be taken if the project is approved. Certification of the Final EIR does not constitute any approval or disapproval of the proposed project itself. The Marina Shores Village project cannot be considered for approval until its Final EIR is certified.
As indicated by CEQA Guidelines 15090 (Certification of the Final EIR), EIR certification indicates that the City has “certified” that: (1) the Final EIR has been completed in compliance with CEQA; (2) the Final EIR was reviewed and considered by the decision-making body; (3) the Final EIR represents the lead agency’s independent judgment and analysis; and (4) if certification is by a non-elected body, an appeal to the elected body must be allowed.
Project approval is a subsequent, separate, and distinct action from certification of the Final EIR. Under CEQA section 15093 (Statement of Overriding Considerations), if the lead agency approves a project that would result in a significant unavoidable environmental impact, the lead agency must adopt a statement of overriding considerations at the time of project approval. Therefore, the Final EIR for any project must identify that CEQA requirement. The lead agency cannot state in the Final EIR that it may adopt a statement of overriding considerations; if the lead agency subsequently approves a project that is based on such a Final EIR, that EIR would immediately become inadequate (i.e., illegal) under CEQA.
Regarding consistent text within each “significant unavoidable impact box” (i.e., the mitigation box that identifies a significant unavoidable impact), in response to this comment the following mitigation boxes have been revised accordingly; these revisions are included in section 3 herein (Revisions to the Draft EIR) under Mitigations 6-1, 6-2, 7-1, 7-2, 7-3, 7-4, 7-5, 7-6, 7-15, 7-19, 7-22, 7-23, 7-24, 7-25, 7- 26, 7-27, 8-8, 13-3, and 15-2. PC 20.06 Land Use–impacts and mitigation measures: “smart growth” discussion (p. 4-33) inconsistency regarding infill development near, next to, or within walking distance of a transportation hub.
Response: None of identified smart growth criteria on Draft EIR pages 4-19 through 4-22 refer to walking distance to a “transportation hub”; the listed criteria do include the terms “public transit” (DEIR page 4-21), “transit service” (DEIR page 4-21) and “transit stop” (DEIR page 4-22). Mitigation 4-3 on DEIR page 4-36 includes the terms “transit link,” and “transit corridors and/or hubs.”
Please also see Master Response G (Project Consistency with “Smart Growth” Concepts).
PC 20.07 Land Use–impacts and mitigation measures: referring to Draft EIR p. 4-36
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(cumulative land use impacts), “why is this [project] not a cumulative land use development...when you already are over your water allotment?”
Response: The proposed project is included as part of the cumulative development described on Draft EIR page 4-36. Also, this particular discussion of cumulative impacts on Draft EIR page 4-36--i.e., within the Land Use chapter--is limited in scope to cumulative “land use” impacts. Cumulative impacts on water supply and service adequacy are discussed on Draft EIR pages 10-4 through 10-9 of Chapter 10, Infrastructure and Public Services.
PC 20.08 Visual Factors–impacts and mitigation measures: referring to Draft EIR p. 5-24, Mitigation 5-2, visual simulation or figure depicting 50-foot height limit requested.
Response: Preparation of the numerous computer-generated visual simulations included in the Draft EIR was costly (approximately $25,000). In an effort to keep the EIR scope and cost within reasonable bounds, the photo-simulation aspect of the visual impact analysis was intentionally focused on those project height combinations alternatives with the greatest potential for visual impact. Because it was determined that the 50-foot building height limit suggested on Draft EIR under Mitigation 5-2 on Draft EIR page 5-24 would be similar in character to the existing structural and landscape visual plane shown in the “before” images on Figures 5.2 through 5.6, simulation of a 50-foot maximum height project was given lower priority than the higher building height combinations that were also being considered.
The lack of a 50-foot project simulation does not invalidate the Draft EIR conclusions that limiting project building heights to 50 feet would reduce associated visual impacts to less than significant levels. The rationale and evidence for this conclusion is adequately explained on Draft EIR pages 5-17 through 5-26.
If City decision-makers do wish to have such a 50-foot project simulation prepared separate from the EIR process, they may request City staff to do so.
Please also see response to similar comment 11.01.
PC 20.09 Visual Factors–impacts and mitigation measures: referring to Draft EIR p. 5-37, “don’t understand” architectural language; clarify or provide picture.
Response: Comment acknowledged. In response to this comment, the text on Draft EIR page 5-37 has been revised to provide clearer explanations with less urban design jargon. Please see the revised version of Draft EIR pages 5-38 and 5-39 in section 3 herein (Revisions to the Draft EIR).
PC 20.10 Population, Housing, and Employment–impacts and mitigation measures: referring to Draft EIR p. 6-13, Mitigation 6-1 (regarding project-related resident population growth), list all specific mitigation measures referred to in mitigation box.
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Response: The intent of this mitigation language is to indicate that if all of the referenced mitigations in these various individual, topical sections of the Draft EIR are implemented as required, environmental impacts associated with the project population would be mitigated. To list (repeat) all of the mitigations (there are 43) would be voluminous and potentially more confusing. Alternatively, in response to this comment, reference has been added under this mitigation to Mitigations 7-1 through 7-27, on pages 2-19 through 2-47; Mitigations 10-1 through 10-9 on Draft EIR pages 2-65 through 2-75, Mitigations 13-1 through 13-3 on Draft EIR pages 2-89 through 2-93, and Mitigations 15-1 and 15-2 on Draft EIR pages 2-95 through 2-98.
PC 20.11 Biological Resources–pertinent plans and policies: referring to Draft EIR p. 8-26, “why does BCDC [Bay Conservation and Development Commission] not have jurisdiction over the entire project?”
Response: Information regarding BCDC jurisdiction over portions of the project site, as included on page 8-26, was derived directly from the San Francisco Bay Plan and in written and personal communications with Steve McAdam, Deputy Director, BCDC.
PC 20.12 Biological Resources–impacts and mitigation measures: Draft EIR does not adequately discuss cumulative effect on the bay; note that replacement open water/wetlands need not be located in Redwood City.
Response: Draft EIR subsection 8.3.1 discusses impact significance criteria. Subsection 8.3.4 (Impact 8-5) identifies the loss of 11.54 acres of estuarine habitat as significant and that compensatory (replacement) mitigation, among other mitigation and permitting requirements, should be included in a mitigation and monitoring plan. Since the project applicant had not completed a mitigation plan at the time the Draft EIR was prepared, Mitigation 8-5 describes what an acceptable mitigation plan should, at a minimum, include; additional conditions may be imposted by the reviewing agencies (e.g., Corps, NMFS, USFWS, CDFG, RWQCB), as noted in Mitigation 8-5.
PC 20.13 Biological Resources–impacts and mitigation measures: referring to Draft EIR p. 8- 37, disagreement with conclusion regarding “very small elimination of the available waterbird foraging habitat”; “any additional loss should be considered significant.”
Response: The loss of 11.54 acres of estuarine, waterbird foraging habitat is identified as a significant impact (Impact 8-5). This habitat is open water, not Bayland or tidal marsh habitat. Most of the habitat losses in San Francisco Bay have been tidal marsh habitat, not open water.
PC 20.14 Biological Resources–impacts and mitigation measures: Mitigation 8-8 (regarding project-related bird collisions), which would result in a “significant unavoidable
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impact,” is used to create a “less-than-significant impact” for Impact 8-9 (Project- Related General Outdoor Lighting Impacts on Biological Resources); not sufficient mitigation.
Response: Please see Master Response F (Bird Collision).
PC 20.15 Biological Resources–impacts and mitigation measures: Mitigation 8-10 (regarding project-related introduction of invasive, non-native plants) needs to state more clearly what landscaping should be allowed.
Response: As stated in the Impact 8-10 discussion, the applicant’s proposed landscape plan was reviewed and all invasive, non-native species were identified. The mitigation would eliminate those non-native species from the approved landscape plan. To clarify, the following text has been added to Mitigation 8-10 on Draft EIR page 8-47: “Additions/substitutions to the landscape plan plant list shall be subject to City approval.”
PC 20.16 Water Service–impacts and mitigation measures: referring to Draft EIR p.10-10, how big will the required water storage tank be and how will it be taken care of?
Response: As required by the City of Redwood City Engineering and Construction Department, the water storage tank would hold approximately 1.54 million gallons. Further, future design details (including precise dimensions and location) would be subject to City review and approval. Since the water storage tank would be specifically for the Marina Shores Village project, the project applicant/owner would be responsible for maintenance in accordance with City criteria.
PC 20.17 Sewer Service–setting, impacts and mitigation measures: clarify differences between dry and wet weather sewage capacity.
Response: Please see Draft EIR chapter 10 (Infrastructure and Public Services), section 10.2 (Sewer Service). In accordance with CEQA Guidelines section 15147 (Technical Detail), the technical details of this issue have been included in the EIR “sufficient to permit full assessment of significant environmental impacts.” Dry and wet weather sewage flow/capacity is explained beginning on page 10-11, paragraph 4. In short, average dry weather sewage flow (ADDWF) is a daily average of actual sewage generated. Peak wet weather flow (PWWF)--which, by definition, is a higher number--adds a peaking factor (i.e., to accommodate “peak,” instead of “average,” flow) plus rain and other discharges that can seep into the sewer system. Therefore, a City/project applicant can “purchase” dry weather treatment capacity because it can be calculated and monitored from a project site. To provide a conservative analysis, an infiltration factor (for rain and other discharges) has been added to the proposed project’s sewage generation calculations. In addition, mitigation for project-generated sewage flows (see Mitigation 10-2) would include not only the purchase of additional dry weather treatment capacity, but also upgrades to the
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sewage treatment plant, pumping facilities, and sewer lines in order to accommodate wet weather flows as well.
PC 20.18 Police Service–impacts and mitigation measures: referring to Draft EIR p. 10-22, will new police officers be funded by general fund or project applicant?
Response: As stated in Mitigation 10-3, “property tax revenue flow increases from the project” to the City’s general fund would be expected to fund required additional police service (estimated at four additional officers over 10-15 years). If police service standards cannot be met at any project phase, the certificates of occupancy for that phase shall be withheld.
PC 20.19 Fire Protection/Emergency Medical Services–setting, impacts and mitigation measures: referring to Draft EIR p. 10-24, response time should be considered a significant impact, based on additional future traffic in area; additional mitigation required.
Response: Response time by a fire department or emergency medical team typically is not affected by daily traffic conditions because the sirens generally are observed by motorists, who will move their vehicles. Nevertheless, Draft EIR Mitigation 10-6 states, “The City shall withhold approval of the project Certificate of Occupancy if it is determined that adequate fire protection and emergency medical service cannot be provided and service standards cannot be met by the time of project occupancy.”
PC 20.20 Schools–setting, impacts and mitigation measures: “section needs to be updated in light of the current budget cuts.” Response: CEQA Guidelines sections 15041 (Authority to Mitigate) and 15126.4 (Consideration and Discussion of Mitigation Measures Proposed to Minimize Significant Effects) require a “nexus” (connection) and “rough proportionality” between a project impact and the mitigation imposed. There is no nexus between current state budget cuts affecting schools and the potential future students generated by the as-yet-unapproved proposed project. However, any increases in school impact fees over time would be assessed toward the proposed project as mandated by the state. In addition, the project applicant and the Redwood City School District are currently completing a “student yield study” and “district capacity analysis” to more accurately forecast potential project-generated impacts on the Redwood City School District. At this time, and as described on Draft EIR page 10- 31, “[T]he permitted mitigation for school enrollment increase impacts is limited to the state-authorized statutory authority of school districts to impose school impact fees.”
PC 20.21 Schools–setting, impacts and mitigation measures: Orion School, though nearest to project site, would not be project’s neighborhood school; EIR needs to identify appropriate school, distance from project site, and availability.
Response: Page 10-28 of the Draft EIR (Schools Serving the Project Vicinity)
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describes the attendance boundaries of the two school districts serving the project site. Six Redwood City School District (RCSD) schools are open to any Redwood City residents who wish to attend (i.e., no attendance boundaries). No existing or projected school capacity shortages were identified by the district representative of either school district. The Draft EIR (page 10-28) does note that no public school is located on the Bay side of U.S. 101 in the project vicinity. The project applicant and the Redwood City School District are currently completing a “student yield study” and “district capacity analysis” to more accurately forecast potential project-generated impacts on the Redwood City School District.
PC 20.22 Parks and Recreation–impacts and mitigation measures: referring to Draft EIR p. 10- 35, definition of “usable open space” needs clarification; does this includes tree boxes, planters, and people’s patios?
Response: No. As described on Draft EIR page 10-35, “open space” for purposes of this project includes “public pedestrian and bicycle paths, public plazas and promenades, and a proposed link to the planned San Francisco Bay Trail extension,” as well as the off-site, approximately two-acre community park depicted on the project’s conceptual landscape plans. Detailed calculations of and requirements for open space would be formulated as part of the Precise Plan process for the project.
PC 20.23 Parks and Recreation–impacts and mitigation measures: referring to Mitigation 10-8 (regarding project impacts on parks and recreation services), Draft EIR p. 10-37, parks and recreation commissioners should be included in Precise Plan formulation. Response: Comment acknowledged. Draft EIR Mitigation 10-8 inherently includes the Parks and Recreation Commissioners when it refers to the “Parks, Recreation and Community Services Department” and “the City”.
PC 20.24 Soils and Geology–impacts and mitigation measures: please define “redox potential” (p. 11-19); Mitigation 11-5 (regarding corrosive soils) does not say how materials will be protected from corrosive soil.
Response: In response to this comment, this technical terminology has been removed from the Draft EIR text; please see revision to DEIR page 11-19 in section 3 herein (Revisions to the Draft EIR). As Mitigation 11-5 states, due to the need for detailed, design-level geotechnical investigations, the technical details of protecting materials from corrosive soil would require “a corrosion expert during the project’s detailed design phase to help design the most effective corrosion protection.”
PC 20.25 Alternatives to the Proposed Project: more pictures requested, particularly for Alternative 8 (Residential/Commercial–Reduced Residential and Reduced Commercial to Permit No Marina Fill).
Response: The City did not authorize additional visual simulations of project alternatives; the simulations provided in the Draft EIR cover the general range of
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building locations, heights, and massing for those alternatives whose proposed heights are above the City maximum allowable height of 75 feet at the project site. Please also see responses to comments PC 20.08 and PC 23.02.
PC 20.26 Alternatives to the Proposed Project: why is there no alternative for buildout under current zoning with no marina fill?
Response: Please see Draft EIR page 17-25, paragraph 2, which explains how and why the EIR analysis compares alternatives with and without marina fill. The alternatives analysis (chapter 17) is intended to allow the City to certify the Final EIR even if the City subsequently approves any one, or a combination, of the alternatives evaluated in the EIR.
PC 21. Commissioner Tamara Piulle
PC 21.01 Noise–impacts and mitigation measures: concern about “canyon effect” of noise at “Villas at Bair Island” residences; Marina Shores Village towers would surround those residences, and noise would not be able to escape.
Response: The distance between the north and south parcels of the Marina Shores Village project ranges from approximately 300 to 500 feet. While some sounds may reflect off the proposed buildings on the north and south parcels, the distance between the buildings is sufficient such that the Villas at Bair Island would not experience reverberation of sounds or the “canyon effect." This situation is not analogous to high-rise buildings in close proximity to one another, such as in downtown San Francisco where this effect may occur. Additionally, the proposed buildings constructed on the south parcel would provide some shielding of traffic noise from Highway 101 and would attenuate noise levels at the Villas at Bair Island.
PC 21.02 Water Service–impacts and mitigation measures: Mitigation 10-1 (regarding project- related and cumulative municipal water service demand) needs to specify where recycled water will be used (e.g., landscaping, toilets).
Response: Please see Master Response C (Water Supply Issues).
PC 21.03 Sewer Service–impacts and mitigation measures: referring to Draft EIR p. 10-17, would the City’s option to purchase 2.1 millions gallons per day (mgd) of sewage treatment capacity accommodate only the proposed project, or would it also cover other projects, such as Abbott Labs?
Response: As stated on Draft EIR page 10-17, the Marina Shores Village project would require a net increase of approximately 317,000 mgd sewage treatment capacity, which is approximately 15 percent of the 2.1 mgd option to purchase. Capacity remains for the Abbott Labs and other projects.
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PC 21.04 Project Description–proposed circulation/shuttle bus system; and Transportation and Circulation–impacts and mitigation measures: referring to Draft EIR p. 3-26, when would shuttle bus system be implemented (e.g., end of project buildout, or as housing is built over time)?
Response: Implementation of fixed-route public bus service is under the control of SamTrans. Provision of private shuttle service to the downtown Redwood City CalTrain station and other City destinations as appropriate should be implemented as soon as economically viable to encourage the use of alternative travel modes and to reduce the number of project-generated vehicle trips.
PC 21.05 Alternatives to the Proposed Project–Alternative 6 (residential/commercial–same residential, reduced commercial, with reduced building heights, reduced marina fill, added hotel, and increased retail, plus transit and transportation demand management provisions): regarding noise “canyon effect” (see comment 21.01), recommend that taller housing be located at Peninsula Marina, with scaled down Pete’s Harbor property.
Response: Comment acknowledged (comment does not pertain to Draft EIR adequacy).
PC 22. Commissioner Ralph A. Garcia, Jr.
PC 22.01 General Comment: still reading and gathering information from fellow commissioners; no further comment.
Response: Comment acknowledged. No further written response required.
PC 23. Commissioner John D. Seybert
PC 23.01 Project Consistency With Adopted Plans and Policies–current Redwood City Bayfront Study: “how did the EIR consider...the Bayfront Study when it’s not been officially recognized?”; important to consider the Bayfront Study.
Response: Please see Master Response D (Bayfront Study Discussion).
PC 23.02 Visual Factors–impacts and mitigation measures: referring to Mitigation 5-4 (regarding potential light and glare impacts), request for additional discussion of project’s nighttime impacts, especially on views from hillside areas; any computer simulation to show that?
Response: The impact of the project on views, including views from Redwood City hillside residential areas, was fully considered and addressed in the Draft EIR under Impact and Mitigation 5-2, Visual Impacts on Views from City Hillside Areas. Figure 5.6 in the Draft EIR provides a "before-and-after" photo-montage simulation of a
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typical view from the hillside neighborhoods of Redwood City towards the proposed project site. The hillside vantage point depicted on Figure 5.6 is the view toward the project site from Edgewood County Park, a popular public vantage point off of Edgewood Road, above the Emerald Lake neighborhood and below I-280. This particular view is considered highly representative of views looking northeast toward the Bay from a large portion of the Redwood City's hillside residential areas. Anticipated project impacts on views and vistas from Redwood City hillside residential areas were addressed on Draft EIR pages 5-19 through 5-21 (especially page 5-20). In response to this comment, revisions have been made to the description of Impact 5-2 to clarify that the description encompasses views from "the western hills." Please see the revisions to Draft EIR page 5-19 in section 3 herein (Revisions to the Draft EIR). In response to this comment, the text under Impact 5-2 has been revised to more clearly explain that, as a result of the proposed project building heights, which "would extend significantly above" the existing plane of development and vegetation, "impacting the visual quality of the Bayfront Area" and..."shifting the focus of views from natural features to the project development," and "the proposed project would have substantial
Anticipated impacts of the project (project lighting, etc.) on nighttime views from Redwood City hillside residential areas were also considered in determining project light and glare impacts and associated mitigation needs, which were described on Draft EIR pages 5-26 and 5-27. In response to this comment, additional explanation has been added to these Draft EIR pages.
In particular, please see the revisions made to Draft EIR pages 5-26 in section 3 herein (Revisions to the Draft EIR) to more fully explain the nature of nighttime light and glare impacts from distant light sources. Implementation of Mitigation 5-4 would provide reasonable assurance against significant project nighttime lighting impacts on views from Redwood City hillside residential neighborhoods.
As indicated in response to similar comment PC 20.08, the need to prepare another computer-generated simulation depicting project effects on the nighttime view was not identified as an assessment priority when the EIR scope was determined at the outset of the CEQA program. The lighting impact conclusions under Impact 5-4 and design measures described under Mitigation 5-4 would not substantially change as a result of adding a computer generated simulation of this nighttime view. Such a simulation would be costly and is not warranted for CEQA purposes. City decision- makers continue to have the ability to request such a simulation to assist with future development review and design review activities.
PC 23.03 General Comment: regarding disclosures in sales materials to prospective residents, “I am a little concerned that sales materials end with the person who first buys property”; sample areas pertinent to disclosure include nearby industries, noise, dust, and airport operations; disclosure process must be honest.
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Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses), which includes a suggested sales material notification language requirement that would run in perpetuity with the property title.
PC 23.04 Transportation and Circulation–impacts and mitigation measures: Mitigation 7-2 [regarding transportation demand management (TDM) program] should discuss further consequences or actions if TDM program is not effective.
Response: For purposes of the CEQA analysis, the TDM program included in Mitigation 7-2 was not assumed to reduce any of the project impacts to a less-than- significant level. All other mitigation is required regardless of TDM implementation. City staff and C/CAG would work with the project sponsor to determine the appropriate TDM measures to be implemented, including associated monitoring and effectiveness.
PC 23.05 Parks and Recreation–impacts and mitigation measures: suggestion that water area of proposed project be considered part of parks and open space (see Impact 10-8); can a table show different types of project open space?
Response: There is no adopted City policy, ordinance, or plan that identifies water area as “parks and open space”; however, if such a policy were instituted by the City, Mitigation 10-8 would still apply to the project, and water area would presumably be applied as a “credit” toward complying with the mitigation.
Regarding a table showing different types of project open space, please see Draft EIR Table 3.2 (Existing and Proposed Site Utilization), page 3-14, including the footnote. More detailed descriptions and calculations of open space would be required by the City during the Precise Plan process and review of design-level details.
PC 23.06 CEQA-Required Assessment Considerations–significant unavoidable impacts: referring to p. 18-2, Impact 4-2 (regarding project compatibility with adjacent residential land uses) is missing from the list of significant unavoidable impacts.
Response: Comment acknowledged. As noted in Mitigation 4-2, Impact 4-2 would be significant and unavoidable only if the measures listed in Mitigation 4-2 were not implemented. Since such an unavoidable impact situation would remain a possibility if and when conditions of project approval are adopted, Impact 4-2 has been added to the list of potential unavoidable impacts in EIR section 18.2 (Significant Unavoidable Impacts); see associated revisions in section 3 herein (Revisions to Draft EIR).
PC 23.07 Alternatives to the Proposed Project: Table 17.1 (Alternative 7 column) accidently reverses words “more” and “less” in description.
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Response: The comment is correct; in response to this comment, the change to Table 17.1 has been made and is included in section 3 (Revisions to Draft EIR) herein.
PC 23.08 Introduction–EIR purpose and intended use: CEQA was created in 1970, but has been updated continuously since 1970.
Response: Comment acknowledged. Please see response to Comment PC 16.02.
PC 24. Commissioner Nancy Radcliffe
PC 24.01 Project Description–proposed project characteristics: Outer Pete’s Harbor marina is subject to a State Lands Commission land lease that expires in June 2033; what would happen to the marina after 2033?
Response: Ownership of the marina will revert back to the State Lands Commission, at which time the Commission will decide the marina’s disposition. At this time, no decision has been made.
PC 24.02 Soils and Geology–setting, impacts and mitigation measures: if project site soil is very corrosive, should excavated soil be used for fill? Response: According to the Treadwell & Rollo geotechnical report referenced in Draft EIR chapter 11 (Soils and Geology), the measures included in Mitigation 11-5 would reduce any corrosive potential on iron, steel, metal, and concrete to a less- than-significant level; however, the detailed, design-level geotechnical investigations included in the mitigation could result in additional or different feasible solutions. Also, please see Draft EIR subsection 11.3.2 (Future Study and Subsequent Mitigation) on page 11-8.
PC 24.03 Visual Factors–impacts and mitigation measures: concerns over shadow effects on Bair Island, nearby residences, and Seaport businesses.
Response: Comment acknowledged. The Draft EIR on pages 5-28 through 5-35 identifies significant concerns with regard to such shadow impacts, and also indicates that without substantial reductions in project building heights sufficient to reduce shadow impacts on adjacent sensitive areas and uses, this impact would be "significant and unavoidable."
PC 25. Commissioner Kenneth McCoy
PC 25.01 Population, Housing, and Employment; and Transportation and Circulation–impacts and mitigation measures: referring to Draft EIR p. 6-11, estimated 3,262 employed residents at proposed project may be understated, which would result in greater traffic generation than described on Draft EIR p. 7-41.
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Response: The project employment estimates described on Draft EIR pages 6-12 and 6-13 are based on employee-per-square-foot-of-floor-space rates commonly applied throughout the Bay Area for planning purposes. These employee per square feet rates are considered to provide conservatively high, but reasonable project employment totals. In any event, the traffic impact conclusions described in Draft EIR chapter 7 are not based on these employment totals, but rather are based on per-square-foot trip generation rates published by the Institute of Transportation Engineers for "office" space, as shown on DEIR page 7-39 (Table 7.10, Project Trip Generation). The trip generation rates applied in the EIR are those consistently used by traffic planners and engineers throughout the Bay Area for office development of this nature, and again, are considered to be conservatively high, and thus appropriate, for EIR purposes.
PC 25.02 Soils and Geology–impacts and mitigation measures: referring to p. 11-19, paragraph regarding corrosive soils is confusing; what would be form of corrosive protection?; would cathodic protection interfere with other infrastructure on-site (e.g., sewer lines, power distribution, overhead power lines)?; discussion “should be expanded on significantly.”
Response: At this preliminary stage in project design, the answers to some of these questions are not currently known. The technical information in chapter 11 (Soils and Geology) was summarized from the Preliminary Geotechnical Investigation, Bair Island Project, June 21, 2001, prepared by Treadwell & Rollo (see footnote #1 on Draft EIR page 11-1, and footnote #4 on page 11-3), which is available for review at the City of Redwood City Planning Department. Specifically, the discussion on page 11-19, paragraph 2, identifies what condition is causing a particular corrosion potential: chloride ion concentrations, sulfate ion concentrations, or pH.
Additional site-specific issues not addressed in the Treadwell & Rollo report would need to be included in the detailed, design-level geotechnical investigations included in Mitigation 11-5. Also, please see Draft EIR subsection 11.3.2 (Future Study and Subsequent Mitigation) on page 11-8 and response PC 24.02.
The comment is now in the public record regarding issues that should be examined in the subsequent geotechnical investigations.
PC 26. Chairwoman Rosanne Foust
PC 26.01 Land Use–setting, impacts and mitigation measures: Figure 4.1 (Existing Land Use Context) should include square footages and heights of existing development, to compare with future proposed development.
Response: The Draft EIR does provide surrounding square footage and building height data for comparison purposes, but not on Figure 4.1, which is intended to generally depict existing and planned land use types in the project vicinity.
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Surrounding building height characteristics are diagrammed on Figure 5.7 and are extensively described in the Draft EIR text (please see response to similar comment PC 20.04).
Existing floor area totals (square footages) for the project site are described on Draft EIR page 4-2, directly opposite Figure 4.1. Floor area data for other land uses in the project vicinity is not available from any City or other official data base known to the EIR authors. If available, such floor area data would not substantially change any of the CEQA-required impact evaluation or mitigation recommendations in the Draft EIR.
PC 26.02 Land Use–pertinent plans and policies: note that Strategic General Plan last adopted in 1990; portions of the General Plan, including zoning districts, have been updated over time; recommends “reflection on what has changed in specifically the land use categor[ies] of the General Plan.”
Response: The planning and land use policy and regulatory history and background leading up to the current project application is described on Draft EIR pages 3-8 (section 3.2, "Site History"). Current project land use designations (General Plan and Zoning) are described on Draft EIR page 4-12 through 4-15. Portions of the Redwood City Strategic General Plan have been updated over time; the City is currently in the process of formulating major revisions to the General Plan, which could be completed in approximately one year.
PC 26.03 Land Use–impacts and mitigation measures: regarding smart growth (see Draft EIR p. 4-23), clarify relationship between proposed project’s inconsistencies with smart growth and associated Mitigation 4-3.
Response: Please see Master Response G (Project Consistency with "Smart Growth" Concepts).
PC 26.04 Transportation and Circulation–pertinent plans and policies: request to have traffic component of Bayfront Study available before end of public comment period.
Response: Please see Master Response D (Bayfront Study Discussion). A preliminary version of the Bayfront Study is now available for review at the City of Redwood City Community Development Services Department, City Hall, 1017 Middlefield Road.
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AND IMMEDIATELY AFTER THE DRAFT EIR PUBLIC REVIEW PERIOD
The following section includes the reproductions of the 37 letters, memoranda and e-mail received by the City pertaining to the Draft EIR, including the 28 received during, and the nine received after the close of, the 45-day public review period, each immediately followed by the EIR authors' written response to comments therein pertaining to the content and adequacy of the Draft EIR. The comments and responses are correlated by code numbers added to the right margin of the letters, memoranda and e-mails.
2.5 RESPONSES TO WRITTEN COMMENTS RECEIVED DURING
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Letter #1: one page
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1. Letter from Claire Felong; undated
1.01 Population, Housing, and Employment–impacts and mitigation measures: desire for continued residential boat slips in marina[s].
Response: Comment acknowledged. Please see Master Response H (Loss of Marina Slips Prior to EIR). The comment pertains to a nonenvironmental issue rather than to the adequacy of the Draft EIR. The comment is in the record for consideration by City decision-makers in their future deliberations on the merits of the project.
1.02 Schools–impacts and mitigation measures: a shuttle between the project site and schools must be provided.
Response: Draft EIR subsection 10.5.4 (under Project Impacts on Public School Services) explains that the nearest school (Orion School) is located over a mile from the project site and that the Redwood City School District does not receive state funding for school bus transportation. The project applicant and the Redwood City School District are currently completing a “student yield study” and “district capacity analysis” to more accurately forecast potential project-generated impacts on the Redwood City School District. At this time, and as described on Draft EIR page 10-31, “[T]he permitted mitigation for school enrollment increase impacts is limited to the state-authorized statutory authority of school districts to impose school impact fees.” Therefore, shuttle school buses currently cannot be mandated as mitigation.
1.03 Schools–impacts and mitigation measures: representatives from the parent community and school districts must report to City Council on implications of the project.
Response: Please see response 1.02. The Draft EIR public review period, public workshops on the proposed project, and public hearings on the proposed project have provided opportunities for input from “the parent community.” Any subsequent, additional opportunities for public input would be decided upon by the City.
1.04 Child Care–impacts and mitigation measures: on-site child care should be provided.
Response: Please see Draft EIR section 10.8 (Child Care). Consistent with City policy (e.g., Land Use Policy L-12), the City can “encourage,” but not require, child care facilities. Therefore, the Draft EIR (page 10-46) recommends “giving a density or other development bonus to the project, based on applicant provision of adequate (i.e., consistent with state space requirements) child care space or facilities on the project site.”
1.05 Population, Housing, and Employment–impacts and mitigation measures: some low- income housing should be provided by the project.
Response: Please see Master Response I (Project-Related Affordable Housing Issues).
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The comment pertains to a nonenvironmental issue rather than to the adequacy of the Draft EIR. The comment is in the record for consideration by City decision-makers in their future deliberations on the merits of the project.
1.06 Transportation and Circulation–impacts and mitigation measures: “Where will the public be able to park?”
Response: The Precise Plan process would identify designated public parking areas (which might include the existing parking lot on USFWS land north of the Peninsula Marina property). City staff would review these plans for conformity to City requirements. It is assumed that the parking adjacent to the retail portions of the proposed project would be public parking.
1.07 Project Description–proposed project characteristics, and Parks and Recreation-- impacts and mitigation measures: “Where will the public be able to picnic, launch a boat, [and] use the shoreline which we own?”
Response: All development under the proposed project would occur on privately owned land. No development would occur on public land, nor would any public boat launch be eliminated by the development. Please see Draft EIR subsections 3.4.2 (Proposed Architectural and Landscape Design Concepts), 3.4.3 (Proposed Circulation), and 3.4.6 (Proposed Marina and Creek Shoreline Modifications) for descriptions and illustrations of privately-owned project components that would be open to the public, including proposed pedestrian/bicycle/jogger paths, marina walks, shoreline paths, public plazas, and a possible community park.
1.08 Transportation and Circulation–impacts and mitigation measures: proposed project phasing must be coordinated with Blomquist Extension construction.
Response: The Draft EIR analysis of emergency access based on traffic congestion (see subsection 7.3.9--Project Emergency Access Impacts) concluded that a total of approximately 750 units could be built before a secondary access (i.e., the Blomquist Street Extension) would need to be constructed.
1.09 Transportation and Circulation–impacts and mitigation measures: project should include a pedestrian/bicycle bridge across the freeway.
Response: Comment acknowledged. The City has no current plans to construct such a facility. Draft EIR chapter 7 (Transportation and Circulation), subsection 7.3.8 (Project Impacts on Transit, Pedestrian, and Bicycle Facilities), concludes that project impacts on pedestrians and bicyclists would be less-than-significant after implementation of Mitigations 7-8 (continuous pedestrian facility) and 7-9 (dedicated bicycle right-of-way).
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Letter #2: one page
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2. Letter from Garrett Dunwoody, C/CAG Consultant, City/County Association of Governments of San Mateo County (C/CAG); March 27, 2003
2.01 Transportation and Circulation–impacts and mitigation measures: C/CAG needs more information to equate transportation demand management (TDM) strategies included in EIR with number of trip reduction credits under the Congestion Management Plan (CMP).
Response: Comment acknowledged. Please see response PC 23.04.
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Letter #3: one page
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3. Letter from Marilyn Anderson, 2138 Hillcrest Road, Redwood City; March 28, 2003
3.01 Water Service–impacts and mitigation measures: concern over water supply; “Redwood City is already over its allotment from Hetch Hetchy.”
Response: Please see Master Response C (Water Supply Issues).
3.02 Sewer Service–impacts and mitigation measures: “are current residents, once again, expected to foot the bill to add the needed additional [sewage] capacity?”
Response: Although the reference to “once again” is unclear, the answer pertaining to this particular project is “No.” As described in Mitigation 10-2 (Draft EIR page 10-17), “The project applicant shall reimburse the City for all costs associated with the purchase of [the required sewage] treatment capacity (e.g., the capacity option itself, and associated administrative costs), the procedural details of which shall be included in a development agreement for the project.”
3.03 Soils and Geology–impacts and mitigation measures: concern over liquefaction during earthquake.
Response: Please see Draft EIR chapter 11 (Soils and Geology), especially subsections 11.1.4 (Seismicity), 11.3.4 (Foundation and Settlement Impacts), and 11.3.5 (Seismic Impacts). In summary, the Draft EIR has concluded that, with adequate and feasible mitigation, the project can physically withstand the possibility of liquefaction.
3.04 Public Health and Safety–impacts and mitigation measures: will proximity of San Carlos Airport be a nuisance to future tenants of proposed project, who will then become opponents of an airport that has existed for many years?
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
3.05 Transportation and Circulation–impacts and mitigation measures: traffic concerns, “with at least 2 drivers (average) per household.”
Response: The trip generation for the proposed project was estimated using standard trip rates for high-rise apartment buildings and compared to surveys conducted at several multifamily residential locations on the Peninsula, which actually exhibited lower trip rates. Although there might be two or more drivers in some of the housing units, these drivers would not all travel during the morning and evening peak hours, which are the periods for which trips were estimated.
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Letter #4: one page
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4. Letter from Randall Smith, Vice President, Real Estate & Facilities, Oracle Corporation; April 4, 2003
4.01 Biological Resources–impacts and mitigation measures: Oracle campus has experienced approximately one bird collision mortality per year through 1998, all pigeons; despite many herons, egrets, and other shore birds, no reports of mortalities of these birds.
Response: Please see Maser Response F (Bird Collision).
4.02 Biological Resources–impacts and mitigation measures: since nesting pair of endangered peregrine falcons arrived at one Oracle rooftop, no incidence of bird collision mortality has occurred.
Response: Please see Maser Response F (Bird Collision).
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Letter #5: one page
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5. Letter from Teri Tith, 236 Shorebird Circle, Redwood City; April 8, 2003
5.01 Biological Resources–impacts and mitigation measures: concern that EIR does not address impacts on Bair Island refuge, including impacts on the endangered clapper rail, least tern, Western snowy plover, and salt harvest mouse, and impacts on migratory birds.
Response: Draft EIR chapter 8 (Biological Resources) addresses potential impacts on fish, fish habitat, California clapper rail, salt marsh harvest mouse, California brown pelican, double-crested cormorant, western snowy plover, California least tern, wetlands, and general construction impacts to adjacent habitat (pages 8-30 to 8-47). No project- related impacts on Bair Island were identified. Also, please see Master Response F (Bird Collision).
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Letter #6: one page
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6. Letter from Mr. and Mrs. Cossins, 459 Marin Drive, Burlingame; April 11, 2003
6.01 Biological Resources–impacts and mitigation measures: EIR does not address impacts on migratory birds and local birds (e.g., endangered clapper rail, least tern, snowy plover), and cumulative impacts on local wildlife population.
Response: Please see response 5.01.
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Letter #7: one page
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7. Letter from Ronald F. Crates, Ed.D., Superintendent, Redwood City School District; April 10, 2003
7.01 Schools–impacts and mitigation measures: EIR contains “no mitigation regarding a potential increase of the student population and how that will impact Redwood City School District’s facilities.”
Response: As described in Draft EIR subsection 10.5.4 (under Project Impacts on Public School Services, page 10-30) and using student generation factors supplied by the affected school districts, the proposed project is expected to generate approximately 200 to 285 K-8 students and 580 9-12 students at full occupancy in approximately 15 years. At this time, and as described on Draft EIR page 10-31, “The permitted mitigation for school enrollment increase impacts is limited to the state-authorized statutory authority of school districts to impose school impact fees”; in current dollars, those project-generated school impact fees are projected at approximately $6.3 million. As noted in the Draft EIR (page 10-31), identification of any secondary physical environmental impacts that might be related to projected increases in student enrollment remains highly speculative. Nevertheless, the project applicant and the Redwood City School District are currently completing a “student yield study” and “district capacity analysis” to more accurately forecast potential project-generated impacts on the Redwood City School District.
7.02 Schools–impacts and mitigation measures: project applicant has agreed to fund “a student yield study to ascertain the potential number of students generated by the project.”
Response: The comment is correct; please see response 7.01.
7.03 Schools–impacts and mitigation measures: school district will not be able to provide facilities in the project area.
Response: Comment acknowledged; the comment could be referring to the situation wherein the current state-authorized school impact fees and property tax revenues alone often are inadequate to fund the entire development of new school facilities (including acquisition of land, facilities construction, staffing, maintenance, and operation).
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Letter #8: one page
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8. E-mail from Matt Leddy, 275 D Street, Redwood City; April 12, 2003
8.01 Noise–impacts and mitigation measures: San Carlos Airport Noise Abatement Procedures “should be an essential part of the EIR.”
Response: The Noise Abatement Procedures are part of the San Mateo County Comprehensive Airport Land Use Plan (ALUP), which itself is a public document utilized in preparation of this EIR. In particular, the Noise Abatement Procedures were reviewed as part of the Draft EIR noise analysis. Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
8.02 Public Health and Safety, and Noise–impacts and mitigation measures: EIR Mitigation 12-1 (regarding safety impacts related to San Carlos Airport) needs to include abatement procedures noted in comment 8.01 and statement regarding permanency of current arrival-departure procedures.
Response: Please see Master Responses B (Airport-Related Land Use, Public Health, and Safety Issues) and E (Project Compatibility with Aviation and Industrial Noise).
8.03 Noise–impacts and mitigation measures: EIR should include noise contour map from San Carlos Airport Land Use Plan and explain how “shielding” from project structures would lower noise levels from aircraft.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
8.04 Noise–impacts and mitigation measures: EIR needs information regarding airport noise levels during critical periods (i.e., people outside, airplanes taking off southward, warm weather, calm winds).
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
8.05 Noise–impacts and mitigation measures: EIR Mitigation 13-1 (regarding State Title 24 requirements, including sound-rated windows) assumes that windows will never be open; not realistic.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise). State Title 24 requirements assume closed windows; the choice to open or close windows is a personal one not dictated by State Title 24.
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Letter #9: one page
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9. E-Mail from Matt Leddy, 275 D Street, Redwood City; April 12, 2003
9.01 Biological Resources–impacts and mitigation measures: concerns regarding shadow impacts on phytoplankton productivity in water; EIR conclusion of “no significant impact” should be changed to “potentially significant impact,” with corresponding mitigation.
Response: Mr. Leddy is correct in pointing out that Jassby et al. identify high light levels as an important factor triggering phytoplankton blooms in the Bay; however, it is not the main limiting factor in the Bay food web. A thorough reading of Jassby et al. indicates that, even with optimum light, primary production is low if there is thorough mixing of the water column. In tidal channels, such as those in the project area, significant turbulent mixing both reduces the light available to phytoplankton and makes the phytoplankton available to the benthic community of filter feeders.
The seasonal shadow effects from the proposed project are daily and seasonally transient, and therefore insignificant in channels with large tidal surges twice daily, as is the case with the project area. Project-related shadows will not have a significant local effect on phytoplankton production, much less affect productivity in the South Bay.
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Letter #10: two pages
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Letter #10: two pages
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10. E-Mail from Matt Leddy, 275 D Street, Redwood City; April 12, 2003
10.01 Transportation and Circulation–impacts and mitigation measures: EIR does not consider impacts of motorists using neighborhood streets to avoid congested Whipple Avenue intersections.
Response: Although the proposed project is expected to result in a significant impact at the El Camino Real/Whipple Avenue intersection, this location is projected to operate at LOS E, which does not represent “gridlocked” conditions. It is possible that some traffic could use alternate routes to avoid this intersection, but the amount of commute traffic diversion is not expected to be substantial.
10.02 Transportation and Circulation–impacts and mitigation measures: EIR should analyze following additional “intersections”: El Camino Real/Edgewood Road, Edgewood Road/Alameda de las Pulgas, Edgewood Road between El Camino Real and Alameda de las Pulgas, and Edgewood Road/Cordilleras Road.
Response: Study intersections were selected in consultation with City staff and according to City criteria. Locations with potential operational issues, and expected to serve approximately ten project-generated peak-hour trips per lane, were selected for analysis.
10.03 Transportation and Circulation–impacts and mitigation measures: EIR transportation demand management (TDM) strategies are voluntary, and “there is no assurance that they will succeed in mitigating the significant traffic impacts.”
Response: For purposes of the CEQA analysis, the TDM program included in Mitigation 7-2 was not assumed to reduce any of the project impacts to a less-than-significant level. All other mitigation is required regardless of TDM implementation. City staff and C/CAG would work with the project sponsor to determine the appropriate TDM measures to be implemented, including associated monitoring and effectiveness.
10.04 Alternatives to the Proposed Project–Alternative 8, and Transportation and Circulation– impacts and mitigation measures: EIR needs to generate traffic level of service (LOS) ratings for Alternative 8 (Residential/Commercial–Reduced Residential and Reduced Commercial to Permit No Marina Fill) to explain how significant traffic impacts could be mitigated with this alternative to the proposed project.
Response: Please see the discussion of CEQA Guidelines section 15126.6(d) on Draft EIR page 17-4 regarding the level of detail required in an analysis of project alternatives.
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Letter #11: 3 pages
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Letter #11: 3 pages
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Letter #11: 3 pages
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11. E-Mail from Matt Leddy, 275 D Street, Redwood City; April 12, 2003
11.01 Visual Factors–impacts and mitigation measures: “EIR should include a visual simulation of the proposed development as viewed from the Bair Island levee trail at the closest point to the project (just across the tidal channel to the north)”
Response: Preparation of computer-generated photomontage visual simulations is not a specific CEQA requirement, but rather has been included in the EIR scope as an effective means of illustrating the range of project visual effects. Preparation of the numerous computer-generated, photomontage visual simulations included in the Draft EIR scope for both the project as proposed and for various project alternatives has been a costly EIR component (over $25,000). In the interest of keeping the EIR scope within reasonable bounds, the number of visual simulation vantage points was limited to five (5) vantage points considered most representative of project site visibility (see Draft EIR page 5-10). Factors considered in selecting the five viewpoints included relative project visibility, the number and sensitivity of viewers, and effects on views from public open spaces.
Simulations of the project from a vantage point as close as the suggested Bair Island levee trail location just across the tidal channel to the north would result in essentially a close-in architectural elevation of the project not dissimilar to the architectural elevation depicted on Draft EIR Figure 3.5. The availability of such an additional exhibit would not result in a substantial change in the impact conclusions and mitigation recommendations in Draft EIR chapter 5 pertaining to visual impacts. City decision-makers may certainly request such detailed architectural depiction information from City staff or the applicant separate from the EIR process, perhaps as part of subsequent development review and design review phases if the project is advanced.
11.02 Biological Resources–impacts and mitigation measures: “EIR should include a reduction in building height as a mitigation measure to avoid bird collision mortality.”
Response: Please see Maser Response F (Bird Collision).
11.03 Land Use–setting, impacts and mitigation measures: EIR omits November 2001 removal of Peninsula Marina boat slips as part of proposed project.
Response: As explained in section 1.1 on DEIR page 1-2, the Draft EIR scope has been specifically to address the effects of the "project" as currently proposed, including the current set of project applications and associated City actions--i.e., the requested General Plan Amendment, Precise Plan, Design Review Permit, subdivision map, improvement plan grading permits, building permits, and various infrastructure hookups. The environmental implications of the recent removal of the boat slips, which presumedly have been primarily beneficial, are the subject of a previous separate action that took place prior to the current project applications and are therefore not included in the scope of the Draft EIR. Please see Master Response H (Loss of Peninsula Marina
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Slips Prior to EIR).
11.04 Population, Housing, and Employment; and Parks and Recreation–setting, impacts and mitigation measures: EIR must thoroughly analyze regional demand for public marina slips; “conclusion of ‘no significant impact’ [EIR p. 4-27] has not been substantiated.”
Response: The issue of regional demands for marina slips, although a factor germane to City deliberations on the merits of the proposed project, is a socio-economic rather than an "environmental" issue and does not fall within the CEQA-stipulated scope of a project EIR. The issue is therefore intentionally not addressed in the Draft EIR. City decision-makers are certainly not precluded from investigating this nonenvironmental issue separately from the EIR process as another item of information to consider in their future deliberations on this project. Please see Master Response H (Loss of Peninsula Marina Slips Prior to EIR).
The conclusion of “no significant impact” on the loss of marina slips is substantiated in the discussion on Draft EIR pages 4-25 and 4-26 (Loss of Local Marina Slips), based substantially on the recently approved West Pointe Marina project at the end of Seaport Boulevard, which will include approximately 420 publicly available recreational boat slips.
11.05 Population, Housing, and Employment–impacts and mitigation measures: regarding housing affordability, EIR should define “above moderate-income” and “moderate- income”; EIR should compare current salaries for entry-level “workforce” jobs with moderate-income housing affordability; will moderately priced units remain so in perpetuity?
Response: Please see Master Response I (Project-Related Affordable Housing Issues), including a description of the project applicant’s voluntary “workforce housing program.” There is no CEQA or City requirement for this privately owned development to offer housing at below market rate prices. Draft EIR subsection 6.1.2 (Projected Housing Needs) explains the citywide and countywide housing needs determinations made by the Association of Bay Area Governments (ABAG), which is the council of governments for the nine-county San Francisco Bay region.
11.06 Alternatives to the Proposed Project–Alternative 8: EIR should include an alternative similar to #8, but with allowable building heights reduced to 75 feet.
Response: As described in Draft EIR chapter 17 (Alternatives to the Proposed Project), page 17-1, section 15126.6(a) of the CEQA Guidelines requires an EIR to “...describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” Although the alternative described by the commenter is not specifically evaluated in the EIR, City decision-makers are permitted
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under CEQA to approve a combination of the alternatives evaluated while still certifying the Final EIR. Regarding the alternative proposed by the commenter, reducing building heights to 75 feet (current zoning), while maintaining the approximately 850 condominiums and existing marina areas proposed under the alternative, could be accomplished on the approximately 23 acres of residential land at an overall project density of approximately 37 units per acre (23 acres X 37 units per acre). Alternative 2, as summarized in Table 17.1, includes a similar residential density within a comparable 80-foot height limit.
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Letter #12: two pages
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Letter #12: two pages
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12. E-Mail from Patricia Dixon; April 13, 2003
12.01 Noise–impacts and mitigation measures: concerns regarding “airport noise bouncing off the buildings”; “Water being both a carrier and magnetizer will send all noise west across [U.S.] 101 and also north over the wetlands (with interference to the wildlife).”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise) and response PC 8.01. Water is not a “magnetizer” (or magnifier) of sound, nor does water provide sound absorption. For potential effects of construction noise on wildlife, please see Impact and Mitigation 8-4 in Draft EIR chapter 8 (Biological Resources), which conclude that, with the mitigation described, such impacts would be less-than-significant.
12.02 Transportation and Circulation–impacts and mitigation measures: “Listing some [intersections] at level [of service] C or D is ridiculous since most have been at level F since I was on TAC!”
Response: In accordance with the CEQA Guidelines, the baseline for evaluating potential project impacts was established at the time the Notice of Preparation was published (February 2002). The traffic analysis was based on traffic counts conducted in July and October 2001, and supplemented with counts in January and February 2002. The EIR acknowledges that traffic volumes at some locations may be lower than previously counted due to recent economic conditions. This could result in better intersection operating levels than previously observed and identified. Trips from unoccupied office space were accounted for under Background Conditions. As shown in Draft EIR Tables 7.11 and 7.16, the additional average wait time at signalized intersections resulting from the addition of project-generated traffic is expected to range from 0.1 to 10.5 seconds under near-term conditions.
12.03 Air Quality–impacts and mitigation measures: could not find carbon monoxide analysis in EIR; carbon monoxide effects should address wildlife and humans, summer and winter.
Response: Please refer to chapter 15 (Air Quality) of the Draft EIR. Carbon monoxide effects are described in Table 15.1, page 15-2, and existing air quality data for this pollutant are shown in Table 15.3, page 15-5. Carbon monoxide impacts of the project are addressed on pages 15-10 through 15-12. Project impacts on carbon monoxide levels are shown in Table 15.4 at worst-case locations. Impacts are determined by comparing predicted concentrations with the state and federal standards. These standards were established to not only protect public health, but to protect public welfare, which includes effects on plants, animals, and materials. The project would not result in any violations of the ambient air quality standards, and so is considered to have a less-than-significant impact resulting from carbon monoxide.
12.04 Noise–setting, impacts and mitigation measures: EIR should analyze noise in summer, weekdays and weekends, and at level of approach–not 15 feet above ground.
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Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
12.05 Population, Housing, and Employment–housing affordability: applicant’s affordable housing program needs to be thoroughly discussed prior to granting any permits.
Response: Please see Master Response I (Project-Related Affordable Housing Issues).
12.06 Soils and Geology–impacts and mitigation measures: concerns regarding locating project on “shaky ground.”
Response: Please see response PC 8.02. Mitigation measures necessary to reduce potentially significant soil and geologic impacts to less-than-significant levels are identified in Draft EIR chapter 11 (Soils and Geology).
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Letter #13: on page
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13. Letter from Neena Sessa; April 13, 2003
13.01 Biological Resources–impacts and mitigation measures: EIR does not address impacts on migratory birds and local birds (e.g., endangered clapper rail, least tern, snowy plover), and cumulative impacts on local wildlife population.
Response: Please see response 5.01.
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Letter #14: one page
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14. Letter from Joe P. Morey, Jr., President, Peninsula Building Materials Co.; April 15, 2003
[Note: also see letters 17 and 26, which have identical comments 1-4.]
14.01 Land Use and Transportation and Circulation–impacts and mitigation measures: significance criteria should address Bayfront Study, which is an “applicable land use plan,” in order to assure compatibility between existing uses and proposed new uses, and to utilize study’s “transportation alternatives” analysis to help mitigate impacts.
Response: Please see Master Response D (Bayfront Study Discussion).
14.02 Land Use, Visual Factors, Noise–setting, impacts and mitigation measures: “we are certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “EIR fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light across open water and wetlands; “mitigations might include extensive soundproofing, landscaping and design features to create buffers, and disclosures in leases and to homeowners.”
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise).
14.03 Transportation and Circulation–impacts and mitigation measures: “U.S. 101 southbound on-ramp from Seaport Boulevard is omitted from the impacted intersections”; “project will have a significant negative impact on this intersection”; an expanded left-turn pocket might mitigate this impact.
Response: The Woodside Road/Veterans Boulevard-SB 101 on-ramp is projected to operate at LOS D under near-term conditions, and no significant intersection operations impacts are anticipated in the near-term with the Blomquist Street Extension in place. A cumulative project impact (Impact 7-20) was identified at this location, and the mitigation measure calls for widening Veterans Boulevard to include two southbound lanes plus widening of the on-ramp. The provision of additional intersection capacity would allow the signal phasing to assign more “green time” to the westbound left-turn movement. The left-turn pocket could be lengthened, but this improvement might be affected by reconstruction of the U.S. 101 overcrossing as part of the U.S. 101/Woodside Road- Seaport Boulevard interchange.
14.04 Transportation and Circulation–impacts and mitigation measures: an incompatibility will exist between commute vehicles and large delivery trucks on Blomquist Street; “Such incompatibility directly meets the definition of a significant impact as defined by this EIR section [Transportation and Circulation]”; mitigations might include developer implementation of “transportation alternatives” recommendations from Bayfront Study.
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Response: Please see response PC 5.04.
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Letter #15: two pages
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Letter #15: two pages
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15. Letter from Erik Olafsson, Senior Planner, Strategic and Long Range Planning, San Mateo County Transit District (SamTrans); April 15, 2003. Please also see letter 33 from SamTrans.
15.01 Transportation and Circulation–impacts and mitigation measures: EIR transportation demand management (TDM) measures should be quantified to estimate trip reductions.
Response: Once the final measures to be included in the TDM plan are identified, an estimate of the potential vehicle trip reduction can also be identified. Also, please see response PC 23.04.
15.02 Transportation and Circulation–impacts and mitigation measures: have Abbott Laboratories and Kaiser Permanente projects been included in cumulative traffic analysis, along with “all existing, recently approved and future developments that would affect the [transportation] facilities being evaluated”?
Response: Traffic volumes from the Abbott Laboratories project and Kaiser Hospital Expansion were included in the cumulative traffic analysis since both of the these projects are pending but have not been approved. In addition to these and other defined projects, an annual growth factor of one (1) percent per year was applied to represent future growth in through traffic.
15.03 Transportation and Circulation–impacts and mitigation measures: mitigation measures should discuss financing, scheduling, implementation, and monitoring.
Response: Comment acknowledged. Mitigation implementation is defined in the mitigation measures. Financing and precise scheduling would be detailed in the Precise Plan or development agreement (subsequent to Final EIR certification). Monitoring would be addressed in the project’s Mitigation Monitoring Program (see EIR chapter 19-- Mitigation Monitoring).
15.04 Transportation and Circulation–setting: “SamTrans no longer offers the RX route to the [project] area” (EIR p. 7-18).
Response: Comment acknowledged. The text on page 7-18, in section 3 herein (Revisions to the Draft EIR), has been revised.
15.05 Transportation and Circulation–impacts and mitigation measures: “Mitigation 7-2 seems to assume SamTrans financial ability to supply a shuttle to the proposed project.”
Response: Any shuttle service to the project site is expected to be operated in similar fashion to the Pacific Shores Employer and Seaport Employer Shuttles. Since these shuttles are privately funded and operated, any Marina Shores shuttle would also be privately funded and operated.
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15.06 Transportation and Circulation–impacts and mitigation measures: Mitigation 7-7 implies that SamTrans would implement a bus route to the Marina Shores Village site, but “SamTrans is currently in a non-expansion period and may be for a number of years.”
Response: The purpose of Mitigation 7-7 is to not preclude operation of full-size transit buses in the project vicinity. This measure does not assume the operation of a SamTrans bus route in the near term.
15.07 Transportation and Circulation–impacts and mitigation measures: SamTrans notes significant impacts on U.S. 101 and State Route 84 which would not be fully mitigated by the project sponsor (as listed in chapter 18--CEQA-Required Assessment Considerations, section 18.2–Significant Unavoidable Impacts).
Response: Comment acknowledged; no additional response necessary.
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Letter #16: two pages
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Letter #16: two pages
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16. Letter from Paul Shepherd, Land Manager, Cargill Salt; April 15, 2003
16.01 Land Use–setting: correction and clarification to text regarding existing “salt crystallizers” east of Seaport Boulevard.
Response: Comment acknowledged. In response to this comment, the text on Draft EIR page 4-7 has been revised to replace "Active Cargill Salt evaporation ponds..." with "Cargill Salt crystallizer facilities (for the harvesting of salt crystals that settle from saline solutions)..." Figure 4.1 has been revised to change the corresponding "SE" designation to "SC" and to change the legend reference from "CARGILL SALT EVAPORATORS" to "CARGILL SALT CRYSTALLIZERS." These revisions are included in section 3 herein (Revisions to the Draft EIR).
16.02 Land Use–setting: correction to Figure 4.1 (Existing Land Use Context) regarding existing “salt crystallizers.”
Response: Comment acknowledged. See response to comment 16.01.
16.03 Land use–setting: correction and clarification to text regarding existing Cargill Salt lands at the northern terminus of Seaport Boulevard.
Response: Comment acknowledged. In response to this comment, the text on Draft EIR page 4-7 has been revised here to now read, "Cargill Salt Company lands are located at the northern terminus of Seaport Boulevard. These salt company lands have been used for a various salt crystallization and harvesting operations." These revisions are included in section 3 herein (Revisions to the Draft EIR). The changes have no substantive effect on any Draft EIR impact or mitigation finding.
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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Letter #17: 12 pages
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17. Memorandum from Greg Greenway, Executive Director, Seaport Industrial Association; April 15, 2003
17.01 Land Use and Transportation and Circulation–impacts and mitigation measures: significance criteria should address Bayfront Study, which is an “applicable land use plan,” in order to assure compatibility between existing uses and proposed new uses, and to utilize study’s “transportation options” analysis to help mitigate impacts.
Response: Please see Master Response D (Bayfront Study Discussion). The proposed project does not preclude implementation of any of the transportation options discussed in the Bayfront Study.
17.02 Land Use, Visual Factors, Noise–setting, impacts and mitigation measures: “we are certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “EIR fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light across open water and wetlands; “mitigations might include extensive soundproofing, landscaping and design features to create buffers, and disclosures in leases and to homeowners.”
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise).
17.03 Transportation and Circulation–impacts and mitigation measures: “U.S. 101 southbound on-ramp from Seaport Boulevard is omitted from the impacted intersections”; “project will have a significant negative impact on this intersection”; an expanded left-turn pocket might mitigate this impact.
Response: Please see response 14.03.
17.04 Transportation and Circulation–impacts and mitigation measures: an incompatibility will exist between commute vehicles and large delivery trucks on Blomquist Street; “Such incompatibility directly meets the definition of a significant impact as defined by this EIR section [Transportation and Circulation]”; mitigations might include developer implementation of “transportation options” recommendations from Bayfront Study.
Response: Please see response PC 5.04.
17.05 Land Use–pertinent plans and policies, and impacts and mitigation measures: Bayfront Study should be referenced in the significance criteria as an “applicable land use plan”; the study has not been available for review.
Response: Please see Master Response D (Bayfront Study Discussion).
17.06 Land Use–pertinent plans and policies: according to “smart growth” criteria, proposed
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project is not “transit-oriented development” because it is not within walking distance of a major transit hub.
Response: Please see Master Response G (Project Consistency with "Smart Growth" Concepts).
17.07 Land Use, Visual Factors, and Noise–impacts and mitigation measures: Table 4.3 (Existing Industries in Project Vicinity with Potential Nuisance Conflicts with Proposed Project) should include Port of Redwood City businesses; all incompatibilities listed in the table are “potentially significant.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses). The table 4.3 listing of "Existing Industries in the Project Vicinity with Potential Nuisance Conflicts with the Proposed Project" is intended to be a selected sampling rather than a complete listing of nearby industries. In response to this and other related comments pertaining to perceived project compatibility with existing heavy commercial and industrial activities on the project's Bayfront vicinity, a more comprehensive list of nearby industries, their location, and their distance from the closest proposed project residential tower has been provided in an added new table, Table 4.4 ("Existing Heavy Commercial and Industrial Operations in the Bair Island Road/Seaport Boulevard/Port of Redwood City Vicinity--Distance from the Project Site"), and the Draft EIR discussion of project relationships to and compatibility with these uses has been expanded. Please see Master Response A (Project Compatibility with Existing Industrial Uses), and associated revisions to Draft EIR pages 4-31 through 4-33, and 5-26, in section 3 herein (Revisions to the Draft EIR). Contrary to this comment, the EIR concludes that potential project incompatibilities with these listed uses would be less than significant, for the numerous reasons described in Master Response A.
17.08 Land Use–impacts and mitigation measures: incompatibilities between proposed residences and neighboring industries might result in future perceived impacts and nuisance complaints “precisely analogous” to those identified in Impact 4-1 resulting from the existing overhead electrical transmission lines adjacent to the project site.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
17.09 Land Use–impacts and mitigation measures: “future nuisance complaints always result when residences are built nearby existing industry.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
17.10 Land Use–pertinent plans and policies: Redwood City Strategic General Plan Land Use Element identifies industry and nearby residential development as incompatible uses.
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Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
17.11 Land Use–impacts and mitigation measures: Bayfront Study hearings and Planning Commission comments “clearly favored” compatibility between industry and new projects; any incompatibility should be mitigated.
Response: Please see Master Response D (Bayfront Study Discussion).
17.12 Transportation and Circulation–impacts and mitigation measures: interaction of project- generated commuter vehicles and ongoing commercial trucks, and proposed Blomquist bridge to Seaport area, raises safety issues.
Response: Please see response PC 5.04.
17.13 Transportation and Circulation–impacts and mitigation measures: regarding chapter 7 (Transportation and Circulation) appendix, “Moderate Innovation Strategies,” purchase of the Union Pacific right-of-way (for potential alternative transportation solutions) would present potential incompatibilities with industries that use this railroad.
Response: As explained on its cover (page 7-103), the chapter 7 appendix is excerpted from the Redwood City Bayfront Transportation Options Study Executive Summary. Detailed discussions of transportation strategies are included in the full document, available for review at the City of Redwood City Community Development Services Department, City Hall, 1017 Middlefield Road. Use of the Union Pacific right-of-way for potential alternative transportation during specifically scheduled times would not inherently interfere with use of the railroad by industry.
17.14 Transportation and Circulation–impacts and mitigation measures: regarding chapter 7 (Transportation and Circulation) appendix, Exhibit 6 (Trip Reduction Toolbox for Employment Centers), adding high occupancy vehicle (HOV) lanes to Seaport Boulevard would present potential incompatibilities, particularly during construction.
Response: Please see response 17.13. This is a construction issue which would be temporary, and would not be expected to create any significant impacts. The potential addition of HOV lanes is intended to improve traffic conditions on Seaport Boulevard.
17.15 Land Use–impacts and mitigation measures: compatibility issues with Pacific Shores Center (PSC), as described in EIR, are not the same as with Marina Shores Village project (e.g., office vs. residential, mitigation required at PSC, all tenants at PSC notified of nearby industry).
Response: The Draft EIR does not anywhere state or imply that the Pacific Shores Center compatibility issues are the same as the Marina Shores project compatibility issues. On the contrary, the Draft EIR states the opposite, on pages 4-30 and 4-31,
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explaining how the Pacific Shores Center development land use compatibility issues, which were cited as pertinent by local industrial interests during the initial EIR scope phase, were substantially different from the Marina Shores Village project. For example, the Draft EIR includes the following statement on Draft EIR page 4-31 in comparing the two development applications: "However, the Marina Shores Village project site is located several hundred yards from the Cargill site, and therefore, potential nighttime noise, dust, odor, or light intrusion is not expected to be substantial." Please see Master Response A (Project Compatibility with Existing Industrial Uses).
17.16 Land Use–impacts and mitigation measures: City required written notification regarding nearby industry to all tenants and live-aboards at approved West Point Marina.
Response: Please see the "Conclusion" subheading under Master Response A (Project Compatibility with Existing Industrial Uses).
17.17 Visual Factors and Noise–impacts and mitigation measures: light and noise impacts of nearby industry, particularly at nighttime, “need to be studied empirically.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.18 Visual Factors and Noise–setting, impacts and mitigation measures: cumulative light and noise impacts on existing residents during project construction cannot be estimated without an accurate study of existing light and noise.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.19 Visual Factors and Noise–impacts and mitigation measures: proposed project heights will result in residents having a direct view into industrial yards; light and sound “carry well” across the open water and marshland separating the project site from industry.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.20 Land Use, Visual Factors, and Noise–impacts and mitigation measures: significant compatibility issues should be mitigated (e.g., with soundproofing, design features, landscaping, written disclosure); EIR already suggests such mitigations for other significant impacts. Response: Comment acknowledged. Implementation of these EIR-identified mitigations would also reduce any noticeable noise intrusion from existing industrial activities. Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.21 Land Use–impacts and mitigation measures: regarding “smart growth,” “an ‘effective
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transit link’ [see Mitigation 4-3] might include designated shuttles beyond additional SamTrans buses.”
Response: Project applicant plans to include a shuttle bus system as part of the proposed project are described on DEIR page 3-26 ("Shuttle Bus System"). Please also see shuttle bus system and water taxi related responses in Master Response G herein (Project Consistency with "Smart Growth" Concepts).
17.22 Land Use–impacts and mitigation measures: regarding “smart growth” Mitigation 4-3, “an effective link to nearby job centers would provide increased mitigation”; a water taxi, first proposed by the project applicant, could provide such a link between the project and Pacific Shores Center.
Response: Please see Master Response G (Project Consistency with "Smart Growth Concepts"), especially the specific references to the potential effectiveness of such a water taxi.
17.23 Population, Housing, and Employment–impacts and mitigation measures: regarding housing affordability, the Seaport Industrial Association “supports the developer’s commitment to provide at least 15 percent of the project units at below market rates.”
Response: Comment acknowledged. Please see Master Response I (Project-Related Affordable Housing Issues).
17.24 Transportation and Circulation–impacts and mitigation measures: EIR identifies 14 significant unavoidable traffic impacts; “City should be aggressive in identifying mitigations beyond those listed in the EIR”; traffic impacts should be examined regionally; Bayfront Study “Transportation Options Study” has not been fully incorporated into traffic mitigations.
Response: Traffic impacts are examined regionally; traffic impacts have been evaluated in accordance with countywide C/CAG criteria (see Draft EIR subsection 7.2.2.e--C/CAG Guidelines for the Implementation of the Land Use Component of the 1999 Congestion Management Plan). Please see Master Response D (Bayfront Study Discussion). The proposed project does not preclude any of the transportation options discussed in the Bayfront Study. Although increasing the number of trips internalized to the Bayfront area could help reduce trip generation by the proposed project, most of the transportation options included in the Bayfront Study are not expected to reduce Marina Shores Village project impacts to a less-than-significant level.
17.25 Transportation and Circulation–impacts and mitigation measures: regarding Exhibit 5 from the Bayfront Study “Transportation Options Study” (reproduced in EIR chapter 7 appendix), the “Strategy Areas” have not been fully integrated into the EIR as traffic mitigations.
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Response: Please see response 17.24.
17.26 Transportation and Circulation–impacts and mitigation measures: impacts of the U.S. 101 northbound-Seaport Boulevard east (north)-Seaport/Blomquist intersection route to the proposed project have not been examined.
Response: The Draft EIR includes an analysis of conditions with the Blomquist Street Extension in place, which would provide project traffic a direct access to the U.S. 101/Seaport Boulevard-Woodside Road interchange. This improvement is required as Mitigation 7-10 for a potentially significant emergency access impact. Project-generated traffic was assigned to this route and to the U.S. 101/Seaport-Woodside interchange, and the resulting operations at all study intersections are presented in Tables 7.15 and 7.16. the only new impact under this scenario is expected to occur at the Blomquist Street/Maple Street intersection.
17.27 Transportation and Circulation–setting: regarding U.S. 101 southbound, Whipple Avenue to Woodside Road, AM peak hour: “level of service under ‘existing conditions’ will worsen when the economy improves, and existing offices are closer to capacity.”
Response: Comment appears to be referring to “Background Conditions,” not “Existing Conditions.” See response 17.28 immediately below.
17.28 Transportation and Circulation–impacts and mitigation measures: transportation demand management (TDM) measures will not solve congestion at U.S. 101 southbound exit at Woodside/Seaport.
Response: Traffic volumes from larger, unoccupied office space in Redwood City (e.g., Excite @ Home, Pacific Shores) were added under Background Conditions to provide a more realistic estimate of stronger economic conditions. Comment on interchange operations acknowledged; it should be noted that the proposed project, which is largely residential in nature, will generate peak-hour trips generally in the opposite direction compared to those generated by the office/R&D land uses in the Seaport Boulevard area. The Draft EIR acknowledges that plans to modify the U.S. 101/Seaport-Woodside interchange are currently being prepared, and funding for this improvement is in place. TDM measures are not expected to eliminate any projected operating deficiencies, but are expected to reduce traffic volumes and minimize potential project impacts.
17.29 Transportation and Circulation–impacts and mitigation measures: cumulative unavoidable traffic impacts should be mitigated by having “all developers within the area contribute [funds] to solutions.”
Response: The City has established a funding mechanism in the form of a citywide traffic impact fee for providing traffic improvements on local facilities. These funds are also designated for implementing trip-reducing measures and traffic calming projects. A funding mechanism for freeway improvements has not yet been established and cannot
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be imposed as mitigation through the CEQA process. Future participation in such a fee would have to be required as part of other City approvals (i.e., Precise Plan, development agreement). The Draft EIR acknowledges that plans to modify the U.S. 101/Seaport-Woodside interchange are currently being prepared, and funding for this improvement is in place. In general, the physical improvements included in the Bayfront Study that are within the control of the project sponsor have been or will be incorporated or accommodated as part of the site plan. Comment regarding AM impacts acknowledged.
17.30 Transportation and Circulation–impacts and mitigation measures: regarding emergency access impact (Impact 7-10), does traffic analysis account for proposed 600 apartments on Syufy (Century Cinema) property?
Response: Yes. Projected traffic from the proposed 600 apartments on the Syufy property was included in the analysis of cumulative conditions.
17.31 Transportation and Circulation–impacts and mitigation measures: regarding the Blomquist Extension, EIR Secondary Impact 7-10A should extend to Seaport Boulevard.
Response: A significant impact was not identified at any of the Seaport Boulevard intersections with the extension of Blomquist Street over Redwood Creek. It is important to note that in addition to providing access between the Bair Island area and Seaport Boulevard, the extension will allow traffic from Seaport Boulevard to use the U.S. 101/Whipple Avenue interchange.
17.32 Transportation and Circulation–impacts and mitigation measures: same recommendation as comment 17.31.
Response: Please see response 17.31.
17.33 Transportation and Circulation–impacts and mitigation measures: some southbound AM commuters from project are likely to use Woodside to access U.S. 101; what are traffic assumptions?
Response: The Seaport Boulevard interchange is typically much more congested than the Whipple Avenue interchange. As such, it is more likely that traffic diversion would occur from the Seaport Boulevard corridor as compared to the Bair Island area. Some diversion from both areas during the peak periods was assumed in the estimate of Background traffic volumes with the Blomquist Street Extension in place.
17.34 Transportation and Circulation–impacts and mitigation measures: some northbound PM commuters to project are likely to use Woodside to exit U.S. 101; what are traffic assumptions?
Response: Please see response 17.33.
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17.35 Transportation and Circulation–impacts and mitigation measures: mitigation should account for trucks leaving driveways and heading south on Blomquist.
Response: As with any roadway improvement that increases traffic on a street, an increase in delays to traffic entering from driveways is expected. The traffic signals on Blomquist Street at Seaport Boulevard and at Maple Street (in the future) would provide some gaps in through traffic, allowing vehicles to enter and exit the roadway. Additionally, design of the Blomquist Street Extension should consider maintaining a low speed limit (30 miles per hour or less) and the possibility of including a two-way left turn lane to facilitate driveway access on Blomquist Street.
17.36 Transportation and Circulation–impacts and mitigation measures: “Will trucks be allowed to cross Blomquist bridge and travel to Whipple?”; will roadway accommodate trucks?”
Response: Yes. The Blomquist Street bridge will be constructed to accommodate all commercial vehicles. The proposed roundabout at the Bair Island Road/East Bayshore Road intersection was designed to accommodate full-size tractor-trailer truck combinations that are up to 55 feet in length.
17.37 Transportation and Circulation–impacts and mitigation measures: same as comments 17.32 through 17.35.
Response: Please see responses 17.32 through 17.35.
17.38 Transportation and Circulation–impacts and mitigation measures: do cumulative (2020) conditions include the Abbott Labs and Syufy projects (Draft EIR p. 7-19)?
Response: Yes. Traffic volumes from the Abbott Laboratories project and Syufy residential project were included in the cumulative traffic analysis, since both of the these projects are pending but have not yet been approved.
17.39 Transportation and Circulation–impacts and mitigation measures: ”Woodside freeway interchange is extremely dangerous, and mitigations are required for additional impacts”; statistics from EIR regarding traffic volumes provided; developers should fund extended left turn pocket at freeway interchange.
Response: Currently, a tree with low limbs limits sight-distance for southbound through traffic at this location. It is recommended that the tree be trimmed to improve sight distance. Additionally, the posted speed limit is 35 miles per hour (mph) in this section, which is considered reasonable given the characteristics of the roadway. As discussed under response PC 5.03, a queuing analysis indicated that the proposed project is not expected to increase the maximum expected queue at the intersection. Lastly, placement of advanced warning signs (e.g. a “Signal Ahead” sign) would help to inform drivers of potential queues ahead and the possible need to stop.
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A cumulative project impact (Impact 7-20) was identified at this location, and the mitigation measure calls for widening Veterans Boulevard to include two southbound lanes, plus widening of the on-ramp. The project sponsor would make a fair-share contribution towards this improvement. The provision of additional intersection capacity would allow the signal phasing to assign more “green time” to the westbound left-turn movement. The left-turn pocket could be lengthened, but this improvement may be affected by reconstruction of the U.S. 101 overcrossing as part of the U.S. 101/Woodside Road-Seaport Boulevard interchange.
17.40 Transportation and Circulation–impacts and mitigation measures: EIR-identified additional receiving lane on U.S. 101 southbound on-ramp at Woodside Road “does not by itself address the backup under the freeway.”
Response: Mitigation 7-20, which includes the additional southbound receiving lane onto U.S. 101, would result in a level of service (LOS) of D at the Veterans/Woodside intersection; LOS D is considered an acceptable operating condition under City criteria.
17.41 Transportation and Circulation–impacts and mitigation measures: “EIR should study the interaction between commuter cars and commercial trucks.”
Response: The scope of work for the transportation analysis was developed in consultation with City traffic engineering and Planning Department staff. The issue of interaction between passenger vehicles and commercial vehicles was not identified as a problem issue to be included in the study. Additionally, there is no City policy that discourages commute traffic from being added to roadways serving heavy vehicles. The addition of passenger vehicles to streets with large trucks does not inherently result in an increase in potential hazards as addressed by the CEQA Guidelines. As long as roads are designed to appropriate standards and adequate sight distance is provided, the addition of passenger vehicles to streets with higher truck traffic volumes is not expected to result in a significant transportation impact.
17.42 Transportation and Circulation–impacts and mitigation measures: “EIR should study the issue of truck access to Blomquist from business driveways on that street.”
Response: Please see response 17.35.
17.43 Transportation and Circulation–impacts and mitigation measures: same as comments 17.27 through 17.29.
Response: Please see responses 17.27 through 17.29.
17.44 Water Service–setting, impacts and mitigation measures: “Given the seriousness of the [water supply] situation,...it would not be prudent for the City to adopt a statement of overriding consideration[s] for this significant unavoidable impact if new sources of water
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are not generated.”
Response: Please see Master Response C (Water Supply Issues).
17.45 Transportation and Circulation, and Fire Protection/Emergency Medical Services-- impacts and mitigation measures: regarding emergency response and evacuation impacts, what analysis supports “less-than-significant” impacts if 14 significant unavoidable traffic impacts are identified in the EIR?; emergency response and evacuation analysis must include Seaport Boulevard area.
Response: The mitigation for the emergency access impact (Impact 7-10) is the provision of another roadway access to the Bair Island area. The second roadway access to the project site is designed to serve emergency vehicles to provide a second vehicle evacuation route for residents. Congestion and significant unavoidable impacts on other roadways in the study area are separate and distinct issues from emergency access impacts. Although the project would result in cumulative intersection operations impacts, emergency access to the Seaport Boulevard area is not expected to be significantly impacted by the proposed project.
Regarding emergency access to the project site itself, the Draft EIR analysis of emergency access based on traffic congestion (see subsection 7.3.9--Project Emergency Access Impacts) concluded that a total of approximately 750 units could be built before a secondary access (i.e., the Blomquist Street Extension) would need to be constructed.
17.46 Fire Protection/Emergency Medical Services–impacts and mitigation measures: “Impacts on access to Seaport Boulevard in the event of a fire or disaster should be included”; mitigations might include contributions toward a firefighting boat. Response: Please see response 17.45. A firefighting boat is not required to maintain adequate fire protection/emergency medical services to the Seaport Boulevard area.
17.47 Solid Waste Service–impacts and mitigation measures: Seaport Industrial Association supports the developer’s commitment to recycling.”
Response: Comment pertains to merits of project, not to Draft EIR adequacy; no additional response necessary.
17.48 Child Care–impacts and mitigation measures: Seaport Industrial Association “encourages the City to consider giving incentives to the developer to provide adequate child care space or facilities on the project site.”
Response: Comment pertains to Draft EIR text on page 10-46, which states, “The City should consider giving a density or other development bonus to the project, based on applicant provision of adequate (i.e., consistent with state space requirements) child care space or facilities on the project site”; no additional response necessary.
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17.49 Noise–setting, impacts and mitigation measures: existing noise measurements are limited because: (1) “they were not designed to measure noise from industrial uses,” (2) “they were conducted for only two days (Wednesday and Thursday nights)”, and (3) “they were conducted at 10 to 12 feet above surrounding ground.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.50 Noise–impacts and mitigation measures: additional noise mitigation might include adequate noise buffers, written notification to all tenants regarding nearby noise sources, and relocation of towers away from noise sources.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
17.51 Noise–impacts and mitigation measures: regarding cumulative noise impacts from project construction, “reliable data on existing noise conditions” must be presented.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
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Letter #18: 3 pages
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Letter #18: 3 pages
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Letter #18: 3 pages
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18. Letter from Jim Woolridge, President, San Carlos Airport Pilots Association; April 16, 2003
18.01 Noise–setting, impacts and mitigation measures: EIR noise analysis is deficient for reasons related to: (1) time that noise measurements were taken (weekdays, not weekends; winter, not summer; recently post-9/11); and (2) proximity of proposed residential towers to runway 12 takeoff path.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
18.02 Noise–impacts and mitigation measures: Draft EIR does not analyze aircraft noise effects in general.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
18.03 Noise–impacts and mitigation measures: no discussion of single-event aircraft noise impacts, especially related to runway 12.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
18.04 Noise–setting: EIR existing noise measurements show peaks as high as 73 and 83 dBA, “that we can only assume are aircraft noise”; source of the noise needs to be documented, with associated effective mitigation measures identified.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
18.05 Noise–impacts and mitigation measures: “Without adequate disclosure and appropriate easements, there will be many noise complaints from the new development and very unhappy residents.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
18.06 Public Health and Safety–impacts and mitigation measures: “Overflights at 200-300 feet above the building[s] will have a significant safety and fear and distress impact”; EIR needs to document and mitigate; avigation easement (part of Mitigation Measure 12-1) is not a safety measure.
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
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18.07 Public Health and Safety–impacts and mitigation measures: required Federal Aviation Administration (FAA) review of project should be included in EIR.
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety).
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Letter #19: two pages
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Letter #19: two pages
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19. Letter from Timothy C. Sable, District Branch Chief, IGR/CEQA, California Department of Transportation (Caltrans); April 16, 2003
19.01 Transportation and Circulation–impacts and mitigation measures: apparent discrepancy between summation of project trips for U.S. 101 off-ramp/Whipple Avenue intersection with and without project in year 2020.
Response: The traffic volumes do not add up because the Cumulative analysis assumes that the Blomquist Street Extension has been completed. Some project traffic was redistributed using Blomquist Street; therefore, the project trip assignment under Project Conditions is not the same as that under Cumulative Conditions.
19.02 Transportation and Circulation–impacts and mitigation measures: recommendations for mitigation measures for northbound U.S. 101 off-ramp with Whipple Avenue, including “converting the existing shared off-ramp lane into a left-turn-only lane and adding a dedicated right-turn-only lane,” and adding a second through lane to eastbound Whipple Avenue at this intersection.
Response: A significant impact was not identified at the Whipple Avenue/NB U.S. 101 off-ramp intersection. As shown on Figure 7.2 (Existing Intersection Lane Configurations), the intersection currently is configured with one exclusive left turn lane and a shared left/right-turn lane. A queuing analysis at the intersection indicated that there is sufficient storage to serve expected demand on the off-ramp under near-term Project Conditions. However, under Cumulative With Project Conditions, queues are expected to be more substantial and extend back to the mid-point of the off-ramp. The addition of a dedicated right turn lane (in combination with converting the existing shared left/right-turn lane to a dedicated left turn lane) would improve intersection operations and queuing capacity at the intersection, but is not deemed a required mitigation for the proposed project because no significant impact was identified.
19.03 Transportation and Circulation–setting, impacts and mitigation measures: “Please provide a complete freeway interchange analysis for the three U.S. 101 intersections at Whipple Avenue, State Route 84 (SR 84), and Marsh Road, and for the SR 84 intersection at SR 82. In addition, please provide us with the transportation and circulation technical appendices with the trip generation surveys for the proposed project.”
Response: The Draft EIR transportation chapter includes an analysis of freeway and ramp operations at the Whipple and SR 84 interchanges. At the Marsh Road interchange, the southbound ramp intersection was analyzed. There are no standard analysis techniques to analyze interchanges between these two arterial roadways with a non-standard design configuration (the analysis techniques in the Highway Capacity Manual are for freeway interchanges). Additionally, the proposed project is expected to add less than one vehicle per minute to any one ramp at the interchange. This relatively low volume is not expected to result in a significant impact to the interchange. Fehr &
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Peers Associates, EIR transportation consultants, will send Caltrans a copy of the technical appendices with the trip generation surveys.
19.04 Transportation and Circulation–impacts and mitigation measures: disagreement that level of service impacts to State Routes are “significant and unavoidable”; “project applicant should provide fair-share fee for current and future improvements”; please provide more details regarding anticipated effectiveness and timing of transportation demand management (TDM) measures.
Response: The City does not have a formal mechanism for obtaining fair-share traffic contributions for freeway improvements. Also, the addition of any capacity to the freeway mainline within the study area is not considered feasible due to right-of-way and existing building constraints. As stated in Draft EIR chapter 7 (Transportation and Circulation, Mitigation 7-2), the implementation of a TDM program is expected to reduce the project’s impacts on freeway segments; however, the impact is not expected to be reduced to a less-than-significant level. The City is working with the project sponsor to finalize a TDM program and establish monitoring requirements, which will be subject to City and C/CAG approval.
19.05 Transportation and Circulation–setting: study intersection #9 (Veterans at Maple) on Figure 7.2 is depicted as a four-way intersection, but Thomas Bros. map shows it as a “T” intersection; clarify.
Response: The fourth leg of this intersection is a driveway that serves a private development.
19.06 Transportation and Circulation–impacts and mitigation measures: does the Draft EIR consider the impacts of the reconstruction project for the U.S. 101/SR 84 interchange?
Response: No. The final design for this interchange has not been finalized. As such, no changes to the interchange were included in the Draft EIR analysis.
19.07 Public Health and Safety–setting: more extensive hazardous waste database review recommended, to include National Priority List , Corrective Action Reports, etc.
Response: As described in Draft EIR subsection 12.1.3 (Recorded Sites on or Near the Project Property), beginning on page 12-2, an extensive records search of available local (San Mateo County), state, and federal government databases was completed for the EIR by Environmental Data Resources (EDR), Inc. The records search included sites of known soil or groundwater contamination on the project site or within the vicinity, “including sites already cleaned up or targeted for cleanup, locations of underground storage tanks, and sites where hazardous materials are generated, stored, handled, or treated.” All of the sources mentioned in the comment were included in the search, but since no such sites exist in the project vicinity, these sources were not listed in the inventory in Draft EIR subsection 12.1.3. A complete copy of the records search is on
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file with the Redwood City Planning Department.
19.08 Public Health and Safety–setting: evaluation of leaking underground storage tank (LUST) at Docktown Marina, 13 LUST sites within half-mile of project site, and all other relevant listed sites recommended.
Response: Implementation of established evaluation procedures and regulations, as described in Draft EIR subsection 12.3.2 (Impacts and Mitigation Measures), pages 12-7 and 12-8, would mitigate potential impacts noted in the comment to less-than-significant levels. As noted on page 12-8, applicable requirements are defined by the City of Redwood City, Regional Water Quality Control Board (RWQCB), and California Department of Toxic Substances Control (DTSC).
19.09 Noise–setting, impacts and mitigation measures: noise monitoring site ST-3 (near U.S. 101) has existing noise level of Leq 69 dBA, which exceeds federal criterion; how will this be mitigated?; please provide noise measurement data in Leq format.
Response: The federal and Caltrans noise abatement criterion would not apply to this project; regardless, the project design goal is more restrictive than the federal and Caltrans noise abatement criterion. Under the Draft EIR recommended noise mitigation program, the project would be designed such that exterior areas of frequent human use would be 60 dBA CNEL or less (see discussion under Impact 13-1, Draft EIR page 13- 15). The worst-hour Leq(hr) generated by vehicular traffic along U.S. 101, therefore, would be less than the federal and Caltrans noise abatement criterion of 67 dBA Leq(hr).
19.10 Transportation and Circulation–impacts and mitigation measures: encroachment permit required for any work that encroaches onto a State right-of-way.
Response: Comment acknowledged; the City and the project applicant are aware of this potential requirement.
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Letter #20: two pages
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Letter #20: two pages
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20. Letter from Audrey C. Rust, President, Peninsula Open Space Trust; April 16, 2003
20.01 Biological Resources–impacts and mitigation measures: Peninsula Open Space Trust (POST) “urges the City to safeguard the integrity of this natural area” [Bair Island].
Response: No project-related impacts on Bair Island have been identified in the Draft EIR (see chapter 8, Biological Resources). The proposed project would be constructed on already developed land.
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Letter #21: one page
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21. Letter from Kilicaslan Mertan, Marina Pointe Homeowner, 305 Louis Lane, Redwood City; April 16, 2003
21.01 Infrastructure and Public Services–satellite dishes: EIR does not address loss of satellite broadcast reception due to proposed high-rise buildings near Marina Pointe townhouses.
Response: This is not an issue subject to the environmental requirements of CEQA. Nevertheless, based on the effective use of satellite dishes in areas of high density and tall buildings (such as downtown San Francisco), the loss of satellite broadcast reception cannot be assumed.
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Letter #22: two pages
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Letter #22: two pages
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22. Letter from Nancy Oliver, 147 Belvedere Avenue, San Carlos; April 17, 2003
22.01 Visual Factors and Biological Resources–impacts and mitigation measures: housing already built near Peninsula Marina replaced natural shoreline and wildlife habitat with “ugly cement bulkhead” visible from Diving Pelican restaurant.
Response: The recent change in the environmental setting cited in this comment was an impact of the previously approved and constructed "Villas at Bair Island" townhouse residential project located on a property between the Peninsula Marina and Pete's Harbor portions of the project site. The environmental impacts and mitigation needs associated with the previous "Villas at Bair Island" development were the subject of the CEQA document prepared for that previous project (November 5, 1997 Negative Declaration for 700 Bair Island Road, City File No. EA 10903-7).
22.02 Visual Factors, Parks and Recreation, and Biological Resources–impacts and mitigation measures: proposed buildings should be set back from the shore, with pathways for walking, bike riding, skating; shoreline should be kept natural to protect wildlife habitat.
Response: Comment acknowledged. This commenter's recommendation regarding the project design is in the record for consideration by City decision-makers in their future deliberations on the project. This mitigation suggestion is consistent with related Draft EIR Mitigation 5-2-1, which calls for design revisions to "set back project buildings from adjacent waterways and public trails...," and Mitigation Alternative 5-5-1 ("...step back, and/or relocate towers...to reduce shadow impacts on...perimeter waterways"). Shoreline protection needs will also be an important focus topic in preparing the Habitat Mitigation and Monitoring Plan(s) (HMMP) called for by the Draft EIR under Mitigations 8-3, 8-4, 8-5, 8-6 and 8-7.
22.03 Transportation and Circulation–impacts and mitigation measures: with only one access road, project impact could be “devastating” during commute times, emergency, or disaster.
Response: The need for a secondary access was identified under Impact 7-10 and the identified mitigation is construction of the Blomquist Street Extension over Redwood Creek. This improvement would provide secondary access for emergency vehicle access and evacuation purposes.
22.04 Visual Factors–impacts and mitigation measures: to allow for better views out to the bay and up to the hills, tall buildings should “separated by a vast area of open space.”
Response: Comment acknowledged. The Draft EIR already includes careful consideration of the proposed placement and spacing between the proposed project tower structures, and associated effects on views, noting under the discussion of Impact 5-2, Visual Impacts on Views and Vistas, that the project "mid-rise and high-rise buildings would block views to the northern Peninsula hills, including San Bruno
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Mountain" (DEIR page 5-20), "would block views to portions of Redwood Creek, the Port of Redwood City, Seaport Center,...and First and Westpoint Sloughs" (DEIR page 5-20), and "would block views of the sky and distant hills from surrounding areas" (DEIR page 5-20). The Draft EIR also notes that "View corridors between residential towers would be narrow, and depending on the viewpoint, would disappear entirely, creating an appearance of solid building mass," and notes that the proposed project's intrusion above the existing visual horizon plane, and associated blocking of views, would detract from the visual qualities that characterize the Bayfront Area" and, also noting that "Such conditions may be inconsistent with certain City policies and guidelines (see section 5.2, Pertinent Plans and Policies)" (DEIR pages 5-23 and 5-24). To address this impact, the Draft EIR under Mitigation Alternative 5-2-1 calls for reducing project building heights to 50 feet to merge with the existing visual plane of the project site vicinity, stating that, "at this height, buildings would not obstruct existing views of the sky and surrounding hills to a greater degree than existing buildings and vegetation" (DEIR page 5-24). Alternatively, under Mitigation 5-2-1 (the Draft EIR calls for preparation and adoption of a "Precise Plan" for the project site that would permit building heights "in excess of 75 feet," in conjunction with "a set of Precise Plan Standards and Guidelines" for City adoption "pertaining to building form, height, shadow, conformity, setbacks, facades, etc..." In response to this comment, the word "separation" has been added here (see revisions to page 5-18 in section 3 herein, Revisions to the Draft EIR).
22.05 Visual Factors, Parks and Recreation, and Biological Resources–impacts and mitigation measures: shoreline should be available for everyone, buildings should be surrounded with open space, wildlife habitat should remain intact, shoreline restaurants should be retained and encouraged, and houseboats should continue to have berths.
Response: Comment acknowledged. This commenter's recommendation regarding the project design is in the record for consideration by City decision-makers in their future deliberations on the project. Please also see response herein to similar Comment 22.02.
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Letter #23: one page
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23. E-Mail from Robin Smith, Sequoia Audubon Society; April 17, 2003
23.01 Biological Resources–impacts and mitigation measures: proposed towers will have an impact on migratory birds; nighttime migration may be affected by illuminated tower windows; daytime bird strikes may result from proposed towers, existing high-tension electrical towers, and San Carlos Airport planes; “more study needs to be done.”
Response: Please see Master Response F (Bird Collision).
23.02 Biological Resources–impacts and mitigation measures: EIR does not address pet cat cats and dogs that may enter the wildlife refuge and harm endangered species.
Response: Domestic animal impacts are discussed under Impact 8-3 (Impacts on the California Clapper Rail), Draft EIR page 8-33.
23.03 Water service–impacts and mitigation measures: “Where will the water come from [and] will there be mandatory water rationing in Redwood City?”; “this issue needs greater study.”
Response: Please see Master Response C (Water Supply Issues).
23.04 CEQA-Required Assessment Considerations–significant unavoidable impacts: “a third of the studied impacts are significantly or cumulatively unavoidable”; “the EIR needs to reflect on the totality of the impacts.”
Response: Comment acknowledged. The Draft EIR does evaluate the significant unavoidable impacts and cumulative impacts of the proposed project in accordance with CEQA Guidelines sections 15126.2(b) and 15130(a), respectively. Draft EIR chapter 18 (CEQA-Required Assessment Considerations) includes a summary of these impacts, which are discussed in detail throughout the EIR document.
23.05 “Cost-Benefit Ratio”: EIR should consider “cost-benefit ratio” of this project for Redwood City.
Response: If the use of the word "cost" here pertains to monetary costs or feasibility, the Draft EIR intentionally excludes any such evaluation of the feasibility or "cost of the project" or its potential fiscal (public cost versus revenue generating) effects. Such economic and socioeconomic factors are non-"environmental" issues which may warrant consideration by City decision-makers, but are not proper subjects for an EIR (CEQA Guidelines sections 15064(f) and 15382).
With regard to weighing "environmental" impacts, against economic ("cost") factors, the CEQA Guidelines under sections 15091 (Findings) and 15093 (Statement of Overriding Considerations) do provide for consideration of economic factors in instances where there are identified significant unavoidable adverse environmental impacts associated
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with a project, but the lead agency (in this case, the City) determines that there are economic benefits which outweigh these environmental effects.
If the use of the term "cost" pertains to other "environmental costs," the EIR provides adequate information on the various potential adverse environmental effects of the project (i.e., adverse land use, visual, traffic, parking, air quality, noise, public services and other environmental effects) for consideration by City decision-makers in their future deliberations regarding the project. There is no CEQA requirement that the EIR include a "cost-benefit ratio" of various identified beneficial and adverse environmental impacts.
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Letter #24: 5 pages
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Letter #24: 5 pages
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Letter #24: 5 pages
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Letter #24: 5 pages
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Letter #24: 5 pages
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24. Letter from Whitman F. Manley and Sabrina V. Teller; Remy, Thomas, Moose and Manley, LLP, Attorneys at Law; April 17, 2003
24.01 Land Use, Visual Factors, Transportation and Circulation, and Noise–impacts and mitigation measures: Sims Metal and other existing industry in the project vicinity (the Port of Redwood City) may inherently contribute loud noises, vibrations, traffic (heavy truck, rail, marine), and visual (including night lighting) and aesthetic impacts to the project vicinity, which may be offensive to residents of the proposed residential towers; Sims is concerned about the EIR’s lack of mitigation for these potential impacts.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
24.02 Noise and Visual Factors–impacts and mitigation measures: “Please explain how the DEIR authors arrived at the conclusion that the future residents of such tall buildings would not be adversely affected by the unobstructed view of, and exposure to sounds and night lighting from, the industrial Port area, which includes the Sims’ facility.”
Response: Please see Master Responses A (Project Compatibility with Existing Industrial Uses) and E (Project Compatibility with Aviation and Industrial Noise).
24.03 Land Use, Visual Factors, and Noise–impacts and mitigation measures: Draft EIR proposes no mitigation for potential nuisance conflicts with existing industrial uses; the following mitigation measures should be adopted for the project: (1) deed disclosures and restrictions informing potential buyers of possible impacts arising from the Port’s industrial facilities; (2) appropriate soundproofing, light shielding, landscaping, and other design features to create buffers; (3) and a reduction in maximum heights of the project towers so that potential visual and noise impacts arising from the Port’s industrial operations might be less noticeable.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
24.04 Visual Factors–impacts and mitigation measures: views outward from the project towers will include the Port and its associated facilities; EIR should analyze related potential visual impacts, and identify appropriate mitigation.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
24.05 Noise–impacts and mitigation measures: EIR “noise impact analysis does not acknowledge the potential noise impact to the residents of the proposed [p]roject’s towers that may result from intermittent, loud noises from the Port’s industrial operations....Because noise events at the Port are episodic, the limited ambient noise data in the [Draft EIR] is insufficient.”
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Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
24.06 Project Consistency With Adopted Plans and Policies–City of Redwood City Strategic General Plan and Zoning Ordinance: “Sims [Metal] disputes the [Draft EIR’s] statement that the [p]roject has been fully analyzed with respect to all of the applicable General Plan policies”; Draft EIR “does not mention the General Plan’s policy regarding the desirability of isolating heavy industrial uses from residences.”
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses).
24.07 Project Consistency With Adopted Plans and Policies–current Redwood City Bayfront Study: as part of the Bayfront Study process, the Redwood City Planning Commission has recommended that existing land uses and proposed new uses be compatible; Draft EIR does not address how such compatibility will be assured, “in light of the issues set out above.”
Response: Please see Master Response D (Bayfront Study Discussion).
24.08 Transportation and Circulation–impacts and mitigation measures: Draft EIR appears to omit the U.S. 101 southbound on-ramp from Seaport Boulevard from the intersections evaluated under the proposed project.
Response: The identified intersection is #15 (Veterans Boulevard/Woodside Road) in the Draft EIR traffic analysis; Seaport Boulevard does not have a direct southbound on- ramp to U.S. 101. Also, please see response 14.03.
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Letter #25: 6 pages
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Letter #25: 6 pages
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Letter #25: 6 pages
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Letter #25: 6 pages
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Letter #25: 6 pages
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Letter #25: 6 pages
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25. Letter from Christopher S. Mann, Director of Real Estate Services, Granite Rock Company; April 17, 2003
25.01 Land Use, Visual Factors, Transportation and Circulation, Noise, and Air Quality–setting, impacts and mitigation measures: “Draft EIR must discuss and analyze the effect of existing heavy industrial operations near the [p]roposed [p]roject as they are relevant physical conditions already in place in the area”; some of these operations include an asphalt batch plant, concrete ready mix batch plant, heavy equipment yard, concrete and asphaltic rubble recycling operation, building material production, and metal recycling operations; such 24-hour operations inherently produce noise, dust, traffic, light, and glare–all of which should be given “full and fair assessment” in relation to the proposed project.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
25.02 Noise–setting, impacts and mitigation measures: noise analysis does not discuss noise from nearby industrial operations.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
25.03 Land Use, Visual Factors, Transportation and Circulation, Noise, and Air Quality–setting: EIR needs to adequately describe the existing heavy industrial conditions in the neighborhood.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
25.04 Project Consistency With Adopted Plans and Policies–current Redwood City Bayfront Study: “EIR needs to incorporate the Bayfront Study more often and more completely as it is a relevant regional land use and planning document.”
Response: Please see Master Response D (Bayfront Study Discussion).
25.05 Transportation and Circulation–impacts and mitigation measures: future construction of the Blomquist Extension is not certain; also, EIR includes “apparently conflicting positions” regarding Blomquist--as a road to accommodate emergency vehicles and relieve congestion, as well as “enjoy[ing] the relative seclusion of the [p]roposed [p]roject’s roadway access.”
Response: The Blomquist Street Extension is included in the City’s Traffic Impact Mitigation Fee (TIMF) program and is approximately 50 percent funded, according to City staff. The EIR transportation chapter calls for construction of the Blomquist Street Extension as mitigation for Impact 7-10, which describes the potential emergency
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access impact of the proposed project. To maintain a less-than-significant emergency access impact, approximately 750 dwelling units could be developed without construction of the Blomquist Street Extension.
25.06 Transportation and Circulation, Water Service, Soils and Geology, and Noise–impacts and mitigation measures: future studies identified in the EIR “should not be delayed as their outcomes need to be considered in the EIR process.”
Response: Please see Draft EIR chapter 11 (Soils and Geology), subsection 11.3.2 (Future Study and Subsequent Mitigation), page 11-8, for a discussion of this issue relevant to the CEQA Guidelines and recent court decisions. Under CEQA, mitigation “measures may specify performance standards which would mitigate the significant effect of the project and which may be accomplished in more than one specific way” (Bass, R. et al. CEQA Deskbook, 1999 (Second) Edition with 2001 Supplement, Solano Press Books). All of the mitigation measures referred to in the comment specify performance standards that must be met before certain project approvals or permits are issued. Any impact which feasible mitigation cannot reduce to a less-than-significant level is identified as a significant, unavoidable impact requiring the City to adopt a Statement of Overriding Considerations should the City approve the project.
25.07 Land Use–setting: EIR must accurately describe the existing industrial conditions around the project area.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
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Letter #26: two pages
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Letter #26: two pages
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26. Memorandum from Vic Thomas, President, Lyngso Garden Materials, Inc.; April 17, 2003
26.01 Land Use and Transportation and Circulation–impacts and mitigation measures: significance criteria should address Bayfront Study, which is an “applicable land use plan,” in order to assure compatibility between existing uses and proposed new uses, and to utilize study’s “transportation alternatives” analysis to help mitigate impacts.
Response: Please see Master Response D (Bayfront Study Discussion).
26.02 Land Use, Visual Factors, Noise–setting, impacts and mitigation measures: “we are absolutely certain that compatibility issues between existing industrial businesses and new housing nearby are significant, and they require mitigation”; “industrial owners on Blomquist Street plan to be here permanently”; “EIR also fails to acknowledge 24/7 nature of industrial operations” and understates potential impacts of noise and light on proposed homes.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
26.03 Land Use, Visual Factors, Noise–impacts and mitigation measures: mitigation for impacts identified in comment 26.02 should include extraordinary soundproofing and disclosures in leases and to home buyers.
Response: Please see Master Response A (Project Compatibility with Existing Industrial Uses) and Master Response E (Project Compatibility with Aviation and Industrial Noise).
26.04 Transportation and Circulation–impacts and mitigation measures: “U.S. 101 southbound on-ramp from Seaport Boulevard will be a significantly impacted intersection”; an expanded left-turn pocket is needed to mitigate this impact.
Response: Please see response 14.03.
26.05 Transportation and Circulation–impacts and mitigation measures: an incompatibility will exist between commute vehicles and large delivery trucks on Blomquist Street; “Such incompatibility directly meets the definition of a significant impact, as defined by this EIR section [Transportation and Circulation].”
Response: Please see response PC 5.04.
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Letter #27: one page
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27. Letter from Christopher Mohr, Executive Director, Housing Leadership Council of San Mateo County; April 17, 2003
27.01 Population, Housing, and Employment–impacts and mitigation measures: proposed project will provide housing that is critically needed on the Peninsula, while preserving open space.
Response: Comment pertains to the merits of the project rather than to the adequacy of the Draft EIR. Please see Master Response I (Project-Related Affordable Housing Issues).
27.02 Transportation and Circulation–impacts and mitigation measures: local traffic impacts of the project may be substantial, but the following will lessen the impacts: project’s location near jobs (which will also reduce regional commuter traffic), likely number of older residents, and planned mitigations.
Response: Comment acknowledged; no additional response required.
27.03 Population, Housing, and Employment–impacts and mitigation measures: proposed project will offer Redwood City “a variety of new housing types.”
Response: Comment pertains to the merits of the project rather than to the adequacy of the Draft EIR. Please see Master Response I (Project-Related Affordable Housing Issues).
27.04 Population, Housing, and Employment–impacts and mitigation measures: proposed architecture and construction of the project will provide housing “for a long time to come.”
Response: Comment pertains to the merits of the project rather than to the adequacy of the Draft EIR. Please see Master Response I (Project-Related Affordable Housing Issues).
27.05 Population, Housing, and Employment–impacts and mitigation measures: developer has proposed to make 15 percent of the units affordable, which, “if achieved, would help Redwood City further its housing goals.”
Response: Comment pertains to the merits of the project rather than to the adequacy of the Draft EIR. Please see Master Response I (Project-Related Affordable Housing Issues).
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Letter #28: 28 pages
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28. Letter from Richard Newman, Chairperson, City/County Association of Governments of San Mateo County (C/CAG) Airport Land Use Commission (ALUC); April 17, 2003
28.01 Project Description–required jurisdictional approvals: C/CAG ALUC staff will coordinate review process with City staff, as needed, regarding required approvals (e.g., General Plan Amendment, Precise Plan, Design Review [Architectural] Permit).
Response: Comment acknowledged. Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.02 Land Use, Public Health and Safety, Noise, and Air Quality–setting, impacts and mitigation measures: “Draft EIR does address key airport/land use compatibility issues related to aircraft operations” as identified in February 22, 2001 letter to former Marina Shores Village Project Manager (Attachment No. 1 to comment letter), including noise, vibration, electromagnetic interference, fuel particles, dust, fear, and “complicated airspace” issues.
Response: Please see Master Responses B (Airport-Related Land Use, Public Health and Safety Issues) and E (Project Compatibility with Aviation and Industrial Noise).
28.03 Land Use, Public Health and Safety, Noise, and Air Quality–setting, impacts and mitigation measures: two subsequent letters from the ALUC, as well as an ALUC regular meeting in 2001, identified the same and similar issues.
Response: “Fuel particles” refer to unburned jet fuel associated with the take-off mode of jet-powered engines. The project site is not located such that it would be affected by jets in the take-off mode from either San Carlos Airport or San Francisco International Airport.
Emissions from aircraft are similar to emissions from other internal combustion sources in that they consist primarily of gaseous elements with only small amounts of particulate (dust). Jet aircraft generate substantially more particulate than piston-driven aircraft. Aircraft operations for San Mateo County airports (including San Francisco International Airport) generate roughly 120 pounds per day of particulate matter, or about 0.39 percent of the total for the county. These emissions are spread over a large geographical area both horizontally and vertically within the atmosphere and therefore are typically diluted. Aircraft particulate emissions are an environmental concern in the upper atmosphere, where they are suspected of impacting the atmosphere’s ozone layer. Particulate emissions from aircraft or airport operations do not appear to be a concern at the project site.
Please see Master Responses B (Airport-Related Land Use, Public Health and Safety Issues) and E (Project Compatibility with Aviation and Industrial Noise).
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28.04 Land Use, Public Health and Safety, Noise, and Air Quality–impacts and mitigation measures: Draft EIR page 12-12 “explains the land use compatibility issues the ALUC and C/CAG would address as part of their formal reviews, but it does not include any text to explain how the proposed project relates to those same issues....This is a significant omission that must be corrected before final action is taken on the adequacy of the EIR, per the relevant CEQA requirements.”
Response: Please see Master Responses B (Airport-Related Land Use, Public Health and Safety Issues) and E (Project Compatibility with Aviation and Industrial Noise).
28.05 Public Health and Safety–impacts and mitigation measures: due to the project site’s proximity to San Carlos Airport and the proposed heights of project buildings, review by the Federal Aviation Administration (FAA) will be required; Draft EIR addresses the airspace/height issues, beginning on page 12-11 (Public Health and Safety, Impact 12-1: Safety Impacts Related to San Carlos Airport); after applicant’s submittal of project plans, the FAA concluded, in a February 5, 2003 letter to the applicant (Attachment No. 3 to comment letter), that the proposed project “is presumed to be a hazard to air navigation”; Draft EIR omits FAA findings and does not identify necessary mitigation (i.e., reductions in tower heights).
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.06 Public Health and Safety–impacts and mitigation measures: Mitigation Measure 12-1 should be rewritten to address issues noted in comment 28.05.
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.07 Noise–pertinent plans and policies: identified 45 dB CNEL interior noise standard (EIR page 13-11) is consistent with the FAA interior standard for residential uses; the identified requirement for an acoustical study (Mitigation 13-1, page 13-16) is consistent with the 1996 San Carlos Airport Land Use Plan, as amended.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.08 Noise–impacts and mitigation measures: Draft EIR noise analysis is inadequate regarding aircraft and overflight noise; noise study period (winter weekdays) was not representative of typical aircraft operations.
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.09 Noise–impacts and mitigation measures: Draft EIR “does not address impacts from
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periods of high aircraft activity and related single-event noise levels.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.10 Noise–impacts and mitigation measures: Draft EIR noise analysis was “conducted at or near ground level and fails to account for the height of the buildings” (i.e., residences at higher floors will experience more aircraft noise).
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.11 Noise–impacts and mitigation measures: Draft EIR “further fails to address the impacts of single-event and cumulative noise on outdoor activities at the project site.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.12 Noise–impacts and mitigation: project site is “well outside of the 55 dB CNEL aircraft noise contour,” as indicated in the Airport Master Plan Update Draft EIR (June 2002); however, the “site is subject to single-event noise impacts from: (1) aircraft arrivals and departures at San Carlos Airport, (2) commercial jet arrivals to San Francisco International Airport, and (3) transient aircraft traversing the area. Aircraft can be as low as 300-400 feet in the project vicinity....This is another significant omission of critical information in the [Draft EIR] that must be rectified before the [Draft EIR] is certified under CEQA.”
Response: Please see Master Response E (Project Compatibility with Aviation and Industrial Noise).
28.13 Public Health and Safety–impacts and mitigation measures: Draft EIR does not address the safety guidelines contained in the Airport Land Use Plan; potential project design issues--including reflective glass; site lighting; size, type, and location of communication equipment; size and location of HVAC exhaust vents; and water features that may attract birds–will be evaluated by the C/CAG ALUC and C/CAG as part of their formal project reviews; EIR should discuss these issues.
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.14 Public Health and Safety–impacts and mitigation measures: Draft EIR “correctly states that the project site is located outside of the current San Carlos Airport Avigation Easement Review Area (AERA) boundary”; ALUC has determined that “it would be very appropriate for the project sponsor to grant an avigation easement to the County of San Mateo, as the proprietor of San Carlos Airport, either voluntarily, or as a condition of
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approval of the project by the City of Redwood City.”
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.15 Public Health and Safety–impacts and mitigation measures: ALUC has “also determined that it would be appropriate for the project sponsor to grant an avigation easement to the City and County of San Francisco, as the proprietor of San Francisco International Airport, either voluntarily, or as a condition of approval of the project by the City of Redwood City.”
Response: Please see Master Response B (Airport-Related Land Use, Public Health, and Safety Issues).
28.16 Land Use, Public Health and Safety, Noise, and Air Quality–impacts and mitigation measures: “content of the [Draft EIR] is weak and incomplete, regarding the relationship of the proposed project to airport/aircraft operations at San Carlos Airport and other aircraft operations in the vicinity of the project site.”
Response: Please see Master Responses B (Airport-Related Land Use, Public Health and Safety Issues) and E (Project Compatibility with Aviation and Industrial Noise).
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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Letter #29: 8 pages
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29. E-Mail from Leslie Young; April 18, 2003
29.01 Land Use, and Parks and Recreation–impacts and mitigation measures: proposed project is not integrated with the Bayfront Study; Bayfront Trail path on project site needs to be defined; only open space appears to be under PG&E power lines.
Response: With regard to project and project EIR relationships to the Bayfront Study, please see Master Response D (Bayfront Study Discussion).
With regard to the location (definition) of the proposed Bayfront Trail alignment on the project site, this aspect of the project, which currently remains conceptual (the onsite trail alignment details have not yet been designed) is generally described on Draft EIR pages 3-28 (see subsection f, "Proposed Link to Planned Bay Trail Extension"), 4-17 (subsection b), and 4-24 through 4-25 (subsection c), and is illustrated on Figure 4.4 (Planned San Francisco Bay Trail Alignment) on Draft EIR page 4-18. More onsite trail alignment specifics and details would be formulated if and when the project is advanced.
With regard to the PG&E easement component of project open space provisions, the Draft EIR on page 3-10 explains that:
the 80-foot-wide PG&E easement with overhead electrical transmission lines would continue to run east-west between the Pete's Harbor and Peninsula Marina portions of the project site;
the applicant proposes to convert this existing easement into an approximately two- acre park;
the easement property is currently owned by the U.S. Fish and Wildlife Service (USFWS); and
no agreement between the USFWS and the applicant has been established regarding the applicant's proposal to use this PG&E easement as a park.
Project open space provisions are more fully described on Draft EIR pages 3-19 (subsection d, "Possible Community Park"), 10-35, and 10-36. Project common open space and possible community park aspects are further described under subsection (a), Common Open Space, on pages 10-35 and 10-36 and subsection (b), Possible Community Park, on page 10-36. As stated on pages 10-35 and 10-36, "the proposed project includes approximately 15.8 acres of common landscape/hardscape open space to be shared between residents, visitors, and the general public," including "public pedestrian and bicycle paths, public plazas and promenades, and a proposed link to the planned San Francisco Bay Trail Extension (not yet designed)." Also, in reference to the PG&E easement component of the project open space provisions, the Draft EIR states on page 10-36 that "the project's conceptual landscape plans include a proposed approximately two-acre community park, but this adjacent off-site land is owned by the
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U.S. Fish and Wildlife Service (USFWS); the project applicant currently does not have development rights to this property."
29.02 Project Consistency With Adopted Plans and Policies--City of Redwood City Strategic General Plan and Zoning Ordinance: project is not integrated into an overall plan for Redwood City, including the redevelopment of downtown; if located in downtown Redwood City, the project could take advantage of existing transportation infrastructure and help fuel redevelopment of downtown.
Response: Regarding locating the project downtown, please see Master Response G (Project Consistency with “Smart Growth” Concepts). Regarding the local and regional perspective of the EIR analysis, the proposed project is evaluated from a regional perspective as well as a local perspective. Please see Draft EIR chapter 16 (Project Consistency with Adopted Plans and Policies) and subsection 4.2.6 (Regional Plans, page 4-17), among numerous associated references throughout the EIR (including the “Pertinent Plans and Policies” section of each environmental issue chapter). As just one example described in the EIR (page 16-3), the City of Redwood City, as a member of the Association of Bay Area Governments (ABAG), is subject to A Proposed Land Use Policy Framework for the San Francisco Bay Area, adopted by the ABAG Executive Board in July 1990. This document is described as a regional policy framework for future land use decisions in the Bay Area that respects the need for strong local control, but that also recognizes the importance of regional comprehensive planning for issues of regional significance (e.g., public services and infrastructure, housing, growth boundaries).
29.03 Project Consistency With Adopted Plans and Policies–pertinent regional plans: project “is not integrated into a plan considering surrounding cities.”
Response: Please see response 29.02.
29.04 Economic Factors, Visual Factors, Transportation and Circulation, Police Service, Parks and Recreation–impacts and mitigation measures: “a whole chapter is missing from the EIR regarding economic impact”; concerns regarding unsafe traffic, crime, and shadows, resulting in decreased home values in area; green space needed.
Response: Please see response to similar comment 23.05. All of the issues mentioned in the comment are addressed from an environmental perspective, as mandated by CEQA, in corresponding chapters of the Draft EIR.
29.05 Transportation and Circulation–impacts and mitigation measures: intersection of Whipple Avenue and U.S. 101 dangerous for bicyclists, will worsen with project; photos provided to show possible striping of roadway for mitigation.
Response: The City is currently developing a plan to connect Bair Island to Main Street via a bicycle connection under U.S. 101. Additionally, the Blomquist Street Extension
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(which will connect to Maple Street) will have bicycle lanes and will provide additional bicycle access to the project site.
29.06 Economic Factors, Visual Impacts, Transportation and Circulation, Police Service, Parks and Recreation, Project Consistency With Adopted Plans and Policies: summary of comments 29.01 through 29.05.
Response: Please see response 29.01 through 29.05.
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Letter #30: one page
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30. E-Mail from Nina Miller, forwarded by Irene Barragan, City Manager’s Office, City of Redwood City; April 18, 2003
30.01 Population, Housing, and Employment–impacts and mitigation measures: ample vacant space available for housing in other areas of Redwood City.
Response: Comment does not pertain to EIR content or adequacy; no additional response necessary.
30.02 Biological Resources, and Parks and Recreation–impacts and mitigation measures: shoreline should be preserved as much as possible; “low-profile recreation” acceptable use.
Response: Comment pertains to recommendation for shoreline preservation and “low- profile recreation,” not to content or adequacy of EIR; no additional response required.
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Letter #31: two pages
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Letter #31: two pages
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31. Letter from Terry Roberts, Director, State Clearinghouse; April 18, 2003
31.01 Introduction–EIR purpose and intended use: “This letter acknowledges that you [City of Redwood City] have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act.”
Response: Notice of City compliance with State Clearinghouse CEQA requirements; no additional response necessary.
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Letter #32: one page
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32. Letter from John and Nena Padley, 211 36th Avenue, Apt. B, San Mateo; undated
32.01 Biological Resources–impacts and mitigation measures: concern about project impacts on wildlife and endangered species.
Response: Comment acknowledged. Chapter 8 (Biological Resources), section 8.3, discusses potential project impacts on biological resources. Also, see response 5.01.
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Letter #33: one page
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33. Letter from Ian B. McAvoy, Deputy Chief of Development, San Mateo County Transit District (SamTrans); April 25, 2003
33.01 Transportation and Circulation–impacts and mitigation measures: proposed “project is a positive effort to provide high-density housing near our suite of existing and future transit services”; project “will afford us significant growth in all modes of transit ridership.”
Response: Comment pertains to merits of project, not to EIR content or adequacy; no additional response is necessary.
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Letter #34: 7 pages
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Letter #34: 7 pages
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Letter #34: 7 pages
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Letter #34: 7 pages
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Letter #34: 7 pages
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Letter #34: 7 pages
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Letter #34: 7 pages
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34. Letter from Andrea M. Gaut, Coastal Program Analyst, San Francisco Bay Conservation and Development Commission (BCDC); April 25, 2003
34.01 Project Description--proposed project characteristics, and Parks and Recreation-- impacts and mitigation measures: public access should average at least 100 feet in width from top of [shoreline] bank landward; current project plans show very narrow public access without consideration of open spaces directly adjacent to the site; open spaces should be useable by the general public and residents alike.
Response: Comment acknowledged. The project would be required to receive a BCDC permit for those portions of the project site within BCDC jurisdiction; please see explanation in Draft EIR chapter 4 (Land Use), subsection 4.2.6(c) (Regional Plans– BCDC’s San Francisco Bay Plan), page 4-17.
34.02 Hydrology and Water Quality–impacts and mitigation measures: relocation of displaced live-aboard boats could result in uncontrolled discharges and a significant water quality impact.
Response: As indicated in Draft EIR chapter 3 (Project Description), subsection 3.4.6 (Proposed Marina and Creek Shoreline Modifications), and elsewhere in the EIR, project implementation would reduce the number of available boat slips associated with the downsized marinas, and no live-aboards would be permitted on-site. As the commenter states, this could relocate some potentially illegal dumpers to other locations around San Francisco Bay. However, even if this were the case, there would not be a net increase in contaminants reaching San Francisco Bay. The waste pumpout facilities available to boaters in the upgraded marinas would likely result in a significant enhancement of water quality in the marinas and in lower Redwood Creek.
Many municipalities have passed, or are in the process of passing, ordinances pertaining to live-aboards. In most cases, the ordinances promote the rehabilitation of marina pumpout stations. However, the cost of these upgrades can be significant; grant programs are often offered as an enticement to implement the upgrades. In summary, the comment is valid, but the potential relocation of dischargers is unlikely to cause a significant impact on off-site water quality.
34.03 Visual Factors–impacts and mitigation measures: berthing layout should promote unobstructed views of wildlife refuge from public access areas.
Response: This recommendation is in the record for consideration by City decision- makers in their future deliberations on the merits of the project. The comment does not specifically pertain to the adequacy of the Draft EIR.
34.04 Land Use–pertinent plans and policies (BCDC’s San Francisco Bay Plan): previously submitted (March 28, 2002) Notice of Preparation (NOP) letter attached, regarding BCDC jurisdiction and related issues of concern.
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Response: Comment acknowledged. The March 28, 2002 letter from BCDC was received by City and given careful consideration by the EIR authors in their preparation of the Draft EIR document. Project-related BCDC jurisdiction, interests, and environmental concerns, including those identified in the March 28, 2002 BCDC letter, have been fully considered and described in the Draft EIR--see Draft EIR pages ii, 3-37, 4-17, 4-18, 4-19, 8-26, 8-42, 8-43, 9-16, 9-30, 9-31, and 9-32.
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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Letter #35: 8 pages
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35. Letter from Terry Roberts, Senior Planner, State Clearinghouse; April 30, 2003
35.01 Introduction–EIR purpose and intended use: attached BCDC comment letter received at State Clearinghouse after end of state review period, which closed April 17, 2003.
Response: Attached to this letter 34 is the same BCDC letter previously received by the City of Redwood City; please see comments and responses 34.01 through 34.04.
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Letter #36: one page
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36. Letter from Alison Mader, Director, Development, The Irvine Company Apartment Communities; May 23, 2003
36.01 Transportation and Circulation, and Infrastructure and Public Services--impacts and mitigation measures: project should be required to pay "fair share" of mitigation costs.
Response: Comment acknowledged. The project applicant would be required to contribute “fair-share” payments toward mitigating project-generated traffic and infrastructure impacts. In addition, the project applicant would be responsible for the full cost of mitigation for those impacts that are completely and directly attributable to the proposed project (e.g., see Draft EIR chapter 10–Infrastructure and Public Services).
36.02 Visual Factors--impacts and mitigation measures: "Villas at Bair Island" and Bair Island Marina will be impacted by shadows and glare.
Response: Comment acknowledged. Please see Draft EIR chapter 5 (Visual Factors), Impact and Mitigation 5-4 and Impact and Mitigation 5-5 for a description and analysis of project-generated glare and shadow impacts, respectively. The project is not expected to result in significant glare impacts (see Master Response A, Project Compatibility with Existing Industrial Uses); however, shadow impacts resulting from the proposed project would be considered significant and unavoidable.
36.03 Transportation and Circulation--impacts and mitigation measures: project does not meet City parking requirements; overflow parking at "Villas at Bair Island" may result.
Response: Comment acknowledged. Please see Draft EIR chapter 7 (Transportation and Circulation), subsection 7.3.12 (Project Parking Adequacy), beginning on page 7-70, for a description and analysis of potential parking impacts and recommended mitigation, including an Ongoing Parking Management Program.
36.04 Hydrology and Water Quality--impacts and mitigation measures: concern that project dredging and filling may impact Bair Island Marina access.
Response: Comment acknowledged. Please see Draft EIR chapter 9 (Hydrology and Water Quality) for a description and analysis of existing and projected tidal, siltation, and other hydrological conditions in the project vicinity.
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Letter #37: two pages
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Letter #37: two pages
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37. Letter from Ellen Miramontes, Bay Design Analyst, San Francisco Bay Conservation and Development Commission (BCDC); May 1, 2003
37.01 Project Description–required jurisdictional approvals: public access issues related to BCDC area of jurisdiction on Pete’s Harbor property.
Response: The comment responds to a revised site plan and conceptual diagram (dated April 23, 2003) presented to BCDC by the project applicant. Comment letter #34 from BCDC is referenced; please see response 34.01. Otherwise, the comment pertains to the merits of the proposed project and BCDC design recommendations to increase public access as part of the BCDC permit approval process; no additional response pertaining to EIR adequacy is necessary.
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The following section includes all revisions to the Draft EIR made in response to comments received during and immediately after the Draft EIR public review period. All text revisions are indicated by an "r" in the left margin next to the revised line. All of the revised pages supersede the corresponding pages in the February 2003 Draft EIR. None of the criteria listed in CEQA Guidelines section 15088.5 (Recirculation of an EIR Prior to Certification) indicting the need for recirculation of the February 2003 Draft EIR has been met as a result of the revisions which follow. In particular:
no new significant environmental impact due to the project or due to a new mitigation measure has been identified;
no substantial increase in the severity of an environmental impact has been identified; and
no additional feasible project alternative or mitigation measure considerably different from others previously analyzed in the Draft EIR has been identified that would clearly lessen 3. REVISIONS TO THE DRAFT EIR the significant environmental impacts of the project.
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