Agenda packet — Belmont City Council, February 24, 2026 (part 2 of 5)

102. Grading & Building Noise. The applicant must ensure that the following preventative and monitoring measures are enforced during grading and building operations:
a) Limit construction activity to the hours listed in the City Noise Ordinance. (8:00 am to 5:00 pm on weekdays, 10:00 am to 5:00 pm on Saturdays, no construction activity on Sundays and holidays). Exceptions to these hours may be approved by the Building Official though the standard City process. b) Schedule highest noise-generating activity and construction activity away from noise- sensitive land uses.
c) Equip internal combustion engine-driven equipment with original factory (or equivalent) intake and exhaust mufflers which are maintained in good condition.
d) Prohibit and post signs prohibiting unnecessary idling of internal combustion engines.
e) Locate all stationary noise-generating equipment such as air compressors and portable generators as far as practicable from noise-sensitive land uses. f) Utilize “quiet” air compressors and other stationary equipment where feasible and available.
103. Engine Noise. Prior to issuance of grading or building permits, the applicant must demonstrate that a condition of contract of all contractors and subcontractors requires the use of internal combustion engine-driven equipment with original factory (or equivalent) intake and exhaust mufflers, which are maintained in good condition. 104. Equipment Noise. Prior to issuance of grading or building permits, the applicant must demonstrate that a condition of contract of all contractors and subcontractors requires the use of “quiet” air compressors and other stationary equipment. If the applicant demonstrates that the use of quiet air compressors and other stationary equipment is not feasible, moveable sound barriers or portable sound huts must be used for noise mitigation.

Operation
105. The Project Noise Consultant shall conduct an acoustic analysis of all mechanical and HVAC equipment proposed with the final building permit plans. The results of the analysis and design recommendations to ensure compliance with the City’s Noise Ordinance shall be summarized by the Consultant in a letter submitted with the building permit plans. The consultant’s recommendations shall be incorporated into the building plans, prior to issuance of a building permit.

Interior Noise
106. Noise Impacted locations. All new development that would be exposed to noise greater than the “normally acceptable” noise level range, and residential and other noisesensitive land uses within the 65 dB contours, as shown in [BVSP] Figure 6-6d are 118

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required to reduce interior noise through design, sound insulation, or other measures to achieve an interior noise level of not more than 45 dBA. At minimum, the following is required: A detailed acoustical analysis of the project must be completed by a qualified acoustical consultant to define the measures required such that the interior noise level requirements are satisfied.
107. Priorto issuance of aBuilding Permit, the project noise consultant must certify in writing that the submitted Building Plansinclude all required noise reduction recommendations specified in the detailed acoustical analysis (i.e., construction methods, increased insulation, noise baffling, etc.) to reduce interior noise levels below the City and State level of 45 dB.

Construction Vibration
108. After obtaining permission from the subject property owners, the applicant must conduct preconstruction photo surveys of foundation/building wall cracks in adjacent structures, and install vibration monitors at any sensitive receptor sites identified in the project Vibration Assessment. The applicant must submit a copy of the photo survey and written confirmation from the Project Acoustic Consultant to the Planning and Building Departments that all required monitors have been installed and inspected, and that they meet the consultant’s specifications, prior to issuance of grading or building permits.
109. The applicant must designate a person responsible for registering and investigating claims of excessive vibration. The contact information of such person shall be clearly posted on the construction site.
110. Neighboring property owners within 300 feet of the project site must be noticed of the construction activities and construction schedule (including estimated dates of various construction phases) at least two weeks prior to the start of construction. 111. The applicant must ensure that the preventative and monitoring measures identified in the Vibration Assessment are enforced during grading and building operations. The applicant must demonstrate that all project construction personnel have been made aware of these measures, prior to issuance of a grading or building permits. On-site identification of any buffer distances between construction (i.e., vibratory rollers, excavators, backhoes, etc.) and adjacent structures that are specified in the Vibration Assessment must occur prior to grading operations.
112. Vibration monitors shall be placed at the sensitive receptors to monitor construction activities and make sure the project thresholds are met. Real-time alerts must be sent to the Contractor in case of near threshold vibration levels or in case of threshold exceedances. In case of exceedances, work must stop, and the source of the exceedance must be identified, and the required mitigation measure should be incorporated. 119

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113. Building structures near the project must be periodically checked for cracks, and any cracks must be monitored. If minor cracks are reported or existing cracks propagate, vibration project action levels must be restricted.
114. Whenever possible, construction or equipment activity generating relatively high levels of vibration must not occur at the same time and shall be spaced as far apart in time as possible from one another. In general, the most severe activities must be reserved for the middle of the day (noon). If activities must occur simultaneously, they shall be performed as far away from one-another as possible within the construction zone. 115. All deliveries of material and equipment must occur during daytime hours, including queueing of construction vehicles outside the site. Vehicles delivering materials and equipment must be operated in strict conformance with regulations established by the United States Department of Transportation and all State and Local requirements. All materials and equipment must be stored on-site and within the confines of the construction barricades.
116. Stationary and portable construction equipment must be located at positions where the noise/vibration impact to nearby noise/vibration-sensitive receptors is minimal. At times where the equipment cannot be positioned at a minimal noise/vibration impacting location, mitigation devicesshall be implemented, as determined by the ProjectAcoustic Consultant or designated Vibration Monitor.
117. After construction activities are complete, the applicant must conduct a postconstruction photo survey of previously surveyed buildings for foundation /building wall cracks. The post construction survey, and a summary letter of any resulting actions taken (repairs or restitutions) must be provided to the Community Development Department, prior to final building permit inspection.

Transportation & Traffic
Transportation
Transportation Demand Management (TDM)
118. The applicant shall demonstrate compliance with the City of Belmont’s TDM programs by submitting a completed TDM application form (available on the City website) which will be subject to review and approval by the Department of Public Works. The applicant shall implement the TDM program as described in the approved TDM Plan. The applicant shall submit an annual TDM compliance report and pay a TDM review fee, as specified in the City’s Master Fee Schedule. In addition, the following is required:
a) The Applicant, using the adopted TDM program, shall provide a tally of how many points and under which categories the project will be achieving TDM measures.
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b) The applicant shall submit an annual TDM compliance report and pay a TDM review fee, as specified in the City’s Master Fee Schedule. c) The TDM program shall be evaluated annually to assess the actual level of trip reduction achieved at the site and to identify any adjustments to the program necessary to ensure the TDM measures are successful. Consistent with common traffic engineering data collection principles, trip generation shall be monitored annually by means of AM and PM commute hour driveway counts. The counts shall be conducted between 7:00 AM and 9:00 AM and between 4:00 PM and 6:00 PM one day per year on a typical weekday (Tuesday, Wednesday, or Thursday) during the fall when school isin session.

Mechanical tube counts, hand counts, or video counts may be used. The peak 60-minute period should be calculated for each two-hour traffic count period. d) An annual employee survey should be conducted to determine transportation mode choice (i.e., drive alone, carpool, bus, Caltrain, etc.). The site TDM coordinator shall work with an independent consultant to obtain traffic count data, implement the annual commuter surveys and document the results in a TDM monitoring report.
e) The annual monitoring report shall be submitted to the Public Works Director or citywide TMA by the TDM coordinator. The data shall be reviewed by the City to assess whether the goal of a 15% trip reduction is being met. f) In addition to the annual monitoring reports, a five-year review shall be conducted to evaluate the overall effectiveness of the TDM measures. If the city determines that the trip reduction goal is not being achieved, additional TDM measures may be implemented. Modifications to the TDM plan may include additional programs or services listed in the City of Belmont’s TDM program or otherwise available for achieving vehicle trip reductions. g) The annual TDM monitoring report shall describe any planned modifications to the TDM program intended to ensure compliance with the trip reduction targets established for this project.

Construction Traffic
119. Prior to issuance of a building or grading permit, the Applicant shall prepare a construction management plan (CMP) for review and approval by the Public Works Department in consultation with the Community Development Department and Police Department. For properties located at or in close proximity to the City borders, the plan shall be routed to adjacent jurisdictions. The CMP shall include a response to construction-related conditions and requirements identified by reviewing City departments, and outside agencies for inclusion in the Plan. The plan shall include at least the following items:
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a) Schedule
A project construction schedule shall be provided that includes the approximate date and expected time frame for each stage of construction. At minimum, the schedule shall include:
• Excavation & Shoring (as applicable)
• Below Grade & Foundation Construction
• Above Grade Construction & Framing
• Exterior & Interior Finish Work
• Public Frontage Improvements
• Offsite & Utility Improvements
b) Site & Logistics Plan
Site and logistics plan(s) shall be provided for each phase of project construction. Said plan(s) shall include:
• Location of Construction Fencing & Access Control for The Site • Proposed Circulation Pattern, including Access & Egress, for Each Phase of Construction
• Location of Dewatering Tanks, Construction Trailer,
Temporary Power Pole, & Restrooms
• Erosion & Dust Control Plans
• Security & Lighting Plans
• Location of Construction Staging Areas for Materials, Equipment, & Vehicles
• Crane Plane (Location, Height, & Radius), as applicable • Construction Worker Parking
c) Traffic Control Plan
Routes for construction-related traffic (hauling, deliveries, works, etc.) shall be identified in consultation with the Department of Public Works. Grading, hauling, and construction delivery traffic shall be timed to avoid peak hour school and work commute traffic. The CMP shall identify the maximum size of construction equipment/trucks during construction, expected temporary street closure, the use of flag personnel during construction, and the location of construction worker parking/car-pooling. Comprehensive 122

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traffic control measures shall be identified, including: any required detour signage, lane closures, and sidewalk closures. A 24 Hour Written notice must be given to the Public Works and Police Departments prior to lane closures.

Trained flag persons shall be positioned at both ends of blocked traffic lanes to ensure safe movement of vehicles, and pedestrians. The proposed traffic control plan may require review by a traffic engineer, to ensure an adequate intersection/driveway turning radius would be provided for large vehicles, and/or when other large projects are in construction at the same time. d) Noticing
The CMP shall include notice to property owners within 300 feet of the project site two weeks prior to grading, and identification of haul route(s) and staging area for the project. The notice shall also include a process for responding to, and tracking, complaints pertaining to construction activity, including identification of an on-site complaint manager. 24-hour advance written notice shall also be provided to adjacent property owners, adjacent businesses, and Public Works and Police Department personnel prior to all major deliveries, detours, and lane closures.
e) Road Conditions
Documentation of road pavement conditions shall be provided to the Public Works Department for all routes that will be used by construction vehicles, both before and after project construction. Roads found to have been damaged by construction vehicles shall be repaired as required by current City pavement restoration standards, or as otherwise directed by the City Engineer.
f) Response to CMP Conditions
A response shall be provided to CMP conditions from other City departments, and outside agencies.

Encroachment Permits
120. The property owner/applicant shall apply for and obtain temporary encroachment permits from the Department of Public Works for work in the City public right-of-way, easements or property in which the City holds an interest, including driveway, sidewalk, sewer connections, sewer clean-outs, curb drains, storm drain connections, placement of a debris box, etc.
121. The property owner/applicant shall apply for and obtain a permanent encroachment agreement (PEA) from the Department of Public Works, with approval by the City Council, for a structure, retaining wall, awning, or other features constructed in the public right-of-way, easement or on property in which the City holds an interest. This 123

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PEA shall be recorded with the San Mateo County Recorder’s office prior to project construction.

Emergency Access
122. Street widening, improvements, and dedications shall be in accordance with City Standards and specifications as required by the Department of Public Works. 123. Streets, sidewalks and curbs in need of repair within and bordering the project shall be repaired and/or removed and replaced in accordance with the Department of Public Works approved standards. Photographs or video of before condition are recommended.
124. A commercial driveway approach shall be installed in accordance with the Department of Public Works approved standards.

General Fees
The applicant/developer must pay all applicable regulatory, connection, and impact fees, in accordance with Government Code Section 65589.5(o), and as specified by each respective City Ordinance or the City's Master Fee Schedule, as follows:

Traffic Improvements
125. Prior to issuance of a building permit, the applicant shall submit construction drawings, and applicable review fees for the Transportation Impact Fee identified below for review and approval by the Public Works Department. The applicant shall construct the following improvements prior to certificate of occupancy.

Public Art
126. The City has a development standard that requires non-residential and mixed use development involving 10,000 square feet or more of new floor area to devote an amount not less than 1% of building development costs for acquisition and installation of public art on the development site. For projects that do not include public art, developers can meet this obligation by either: 1) providing an in-lieu contribution (payment) to the City for acquisition and placement of public art in the city; or 2) by acquiring and installing freely accessible art on city property or in the public right of way. The calculated In-Lieu fee is $141,050 for the Phase 1 Project. Fees must be paid prior to issuance of Building Permit. Phase 2 project costs will be determined upon the Master Revenue Fee schedule in effect at the date of submittal.

Building Permit/Plan Check
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may be calculated using the adopted FY 2025-26 fee schedule located on the Finance page of the City’s website. Fees will be adjusted to the most current adopted fee schedule in effect at the time of payment. Plan check fees must be paid at the time of building permit application. Building permit fees must be paid prior to building permit issuance.
128. General Plan Maintenance Fee - 0.75% of Building Valuation. Must be paid prior to building permit issuance.
129. Sewer Connection Fees. Fees will be adjusted to the most current adopted fee schedule in effect at the time of payment. The fee must be paid prior to building permit issuance for the Phase 1 Project.

Transportation Impact Fees
130. The applicant shall pay all required Transportation Impact Fees (TIF), as identified in the City’s adopted Ordinance, and most current fee schedule. The calculated fee is $150,960.44 for the Phase 1 Project. Fees must be paid prior to issuance of Building Permit. Phase 2 project costs will be determined upon the Master Revenue Fee schedule in effect at the date of submittal.

Housing Impact Fees
131. The applicant shall pay all required Housing Impact Fees, as identified in the City’s adopted Ordinance, and most current fee schedule. The calculated fee is $59,211.90 for the Phase 1 Project. Fees must be paid prior to issuance of Building Permit. Phase 2 project costs will be determined upon the Master Revenue Fee schedule in effect at the date of submittal.

Park Improvement Impact Fees
132. The applicant shall pay all required Park Improvement Impact Fees, as identified in the City’s adopted Ordinance, and most current fee schedule. The calculated fee is $9,689.22 for the Phase 1 Project. Fees must be paid prior to issuance of Building Permit. Phase 2 Project costs will be determined upon the Master Revenue Fee schedule in effect at the date of submittal.

Community Benefits Donation – McDougal Park Improvements 133. Prior to issuance of a Certificate of Occupancy (CO) for the Phase 1 Academic Buildings Project for the campus, the school shall make a Community Benefits donation of One-Hundred Thousand Dollars ($100,000) to the City to be applied to McDougal Park improvements for use by the Parks and Recreation Department. 125

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Utilities
Stormwater
134. Prior to issuance of a building permit, the applicant shall submit a final C.3 and C.6 Development Review Checklist, documenting the LID treatment reduction credit, a narrative of LID Feasibility/Infeasibility and a Storm Water Treatment Plan showing a minimum of 100% LID treatment unless demonstrated to be infeasible isincorporated into the storm water treatment design as shown on the City approved Preliminary Stormwater Management Plan for review and approval by the City Engineer. 135. The Property Owner shall enter into a Maintenance Agreement with the municipality to ensure long‐term maintenance and servicing by the Property Owner of stormwater site design and treatment control [and/or HM] measures according to the approved Maintenance Plan(s). The Maintenance Agreement shall be recorded for the property and/or made part of the CC&Rs.
136. The developer shall be responsible for t he total cost of upgrading the existing drainage pipes. The costs will include design, permitting, construction, construction management, inspection and closeout activities. The contribution for the upgrade of the existing drainage pipes shall be paid to the City before the issuance of the building permit.

Sewer
137. The owner/applicant shall analyze the existing sewer system from the property boundary to the nearest pump station or main trunk line to determine its capacity to handle increased sewer flows from this development. Should any deficiency in this system be found, the owner/applicant shall improve the downstream system or contribute a proportionate share of the cost for improvements as determined by the Public Works Department.
138. Applicant shall install the sanitary sewer connection in accordance with Department of Public Works approved standards and pay the applicable sewer connection fee. Sanitary sewer to include a back flow prevention device.

New Facilities/Supply – Water
139. The applicant shall demonstrate that the final landscape plan has been reviewed and approved by the Mid-Peninsula Water District (MPWD), and is consistent with MPWD’s Water Efficient Landscape Ordinance (WELO), prior to installation of landscaping. A post installation certification from MPWD is also required prior to final building permit inspection. Contact the MPWD Water Conservation Administrative Specialist at (650) 591-8941 or [email protected] for more information. 126

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Solid Waste
140. The owner/applicant shall provide plans and materials that include details for collecting trash and recycling for the proposed development project (i.e., location of facilities, and proposed access for collection). The City’s trash and recycling hauler (Recology) shall review the plans and determines the appropriate levels service for the projects.

Recology and Public Works staff shall also determine if there is adequate access/circulation for their vehicles to pick up materials from the site. A letter shall be provided from the Recology stating that service is available to the project as designed.

Public Works will review the proposed service for impacts to the right-of-way.

II. COMPLY WITH THE FOLLOWING CONDITIONS OF THE COMMUNITY DEVELOPMENT DEPARTMENT:

Planning Division
Conceptual Development Plan & Detailed Development Plan 138. The Conceptual Development Plan (CDP) and Detailed Development Plan (DDP) shall be constructed in two phases. The Conceptual Development Plan for Phase 1 includes the development of a new academic wing (three new classroom buildings). Phase 2 includes the construction of an athletics building and kitchen. The relative locations of all proposed Phase 1 and 2 improvements is delineated on plan Sheet AS-102 of the Detailed Development plans. The project shall be consistent with the following design standards, which are derived from the plans on file, dated January 30, 2026, and as referenced below.

A. Minimum Lot Size. 4.92 Acres (214,315 sq. ft.)
B. Permitted Uses.

1. A private school for up to 290 students, including supporting/accessory activities and uses such as a gymnasium, kitchen, and multipurpose room for the subject property.

2. Community recreational use of playgrounds, and other recreational facilities during off-school hours; the school will post signage that delineates when their school facilities are open to the community to avoid any confusion. Access for school staff and small-group activities until 10:00 p.m. on weekdays, and weekend access from 9:00 a.m. to 6:00 p.m. on the campus.

3. Allowance of twelve (12) weekend events annually involving 25 or more attendees (e.g., schoolwide gatherings, accreditation visits, graduation).

4. Permission of three (3) special Saturday evening events each year such as a musical or alumni gathering or benefit event with activities ending by 10:00 p.m.
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5. Authorized dismissals on nearby neighborhood streets for up to four (4) special events per year to ease traffic congestion associated with large on-campus gatherings.

6. Coordinated and shared use of McDougal Park for limited weekend or additional weekday access including during the school’s four-week summer session. No additional exclusive use of McDougal Park is requested by the school.

C. Maximum Floor Area of buildings. 53,579 sq. ft.

D. Maximum Floor Area Ratio. 0.25
E. Minimum Setbacks and Building Separations: Pursuant to Plan Sheet C2.0, and as follows:

Criteria - Setbacks1 CDP
Standards DDP – Right Side & Rear Setback
Front 30’ No change to existing setbacks
which exceed CDP minimum.

Left Side 25’ No change to existing setbacks
which exceed CDP minimum.

Right Side 15’ Academic Building A - 42’8”
Academic Building B - 25’2”
Academic Building C - 16’9”
Rear 15’ Athletics Building + Kitchen - 18’5”
1 Setbacks as measured from property line to closest proposed building wall.

F. Maximum Building Height: Pursuant to submitted Elevation Drawings dated January 30, 2026 – Sheets A-200 through A-601 (see table below). Building height measured from finished grade to the top most point of the roof above (including mechanical equipment and all other building features).

Criteria CDP Standards Proposed DDP
Height Maximum of 40 feet
Academic Building A -33’6”
Academic Building B - 34’2”
Academic Building C – 21’3”
Athletics Building + Kitchen -
32’0”
G. Off-Street Parking: 85 Parking Spaces (four of which are ADA accessible) pursuant to Section 8 (parking) of the Zoning Ordinance for School Uses. In addition, the school will add one parking space for any additional employees during the traditional school day beyond 85.
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H. Landscaping/Lighting: Landscape and lighting shall comply with submitted Landscape and Lighting Drawings dated January 30, 2026 – Sheets L101 through Sheet L103, except as modified through a Detailed Development Plan or amendment thereto, and Design Review. Landscaping shall be native or locally acclimated, draught-tolerant species and consistent with all applicable state and local landscape requirements. All lighting shall be downcast on the project site and shall not create glare off-site. Parking lot and walkway lighting shall be the minimum required for safety. There shall be no floodlighting of landscape plantings, buildings, courtyards, patios, or areas between buildings.

I. Building Materials: Building materials shall be consistent with Elevation Drawing and submitted materials – Sheets A600 through A601, dated January 30, 2026 except as modified via an approved DDP for the school.

J. Circulation Plan: – Circulation shall be consistent with Sheet #2 of the Conceptual Development Plan, dated January 30, 2026, except as modified via an approved Detailed Development Plan (DDP) or amendment thereto, after review and approval by the Director of Public Works in consultation with the Police and Fire Departments.

K. Fencing: Fencing locations shall be consistent with proposed materials and standards (see table below), except as modified through a Detailed Development Plan or amendment thereto, and Design Review.

L. Roof Mounted Mechanical Equipment: Installation of roof mounted mechanical equipment shall be consistent with Elevation Drawings dated January 30, 2026 – Sheets A200 through A300 (see table below), except as modified by a Detailed Development Plan (DDP) or amendment thereto.

Criteria DDP Standards Proposed Project
Roof-mounted
Mechanical
Equipment
Screened from
Public Vantage
Points
Screened from Public Vantage
Points
M. Signage: Signage shall be consistent with drawings dated January 30, 2026 – Sheets #5 and 11 (see table below), except as modified by a Detailed Development Plan or amendment thereto.

Criteria DDP Standards Proposed Project
Fencing
Chain Link and
Wood – Maximum
of 6 feet in height
Chain Link and Wood –
Maximum of 6 feet in height
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Criteria DDP Standards Proposed Project
Signage Per Master Sign
Program
Vehicular Directional
Monument Sign – 20 sq. ft.

LED Monument Signs - 60 sq.
ft.

Building Identification Signs
Informational Signage
N. Floor Area: Floor area shall be consistent with drawings dated January 30, 2026 – Sheets G-002, except as modified by a Detailed Development Plan or amendment thereto, provided that total floor area does not exceed 0.25 FAR (53,579 sq. ft.).

CDP Standards Proposed Project
Building Floor Area
Existing
a) Classroom Building 1
b) Classroom Building 2
c) Classroom Building 3
d) Multi-Purpose Building
Total - 29,677 sq. ft.

Classroom 1 - (7,346 sq. ft.)
Classroom 2 - (6,840 sq. ft.)
Classroom 3 - (6,840 sq. ft.)
Multi-Purpose Building - (8,651 sq. ft.)
New Academic Wing – Phase 1
e) Building A
f) Building B
g) Building C
Total - 11,893 sq. ft.

Building A - (6,364 sq. ft.)
Building B - (4,237 sq. ft.)
Building C - (1,292 sq. ft.)
New Athletic Building – Phase 2
h) Gymnasium
i) Support/Kitchen
Total - 11,126 sq. ft.

Gymnasium- (7,973 sq. ft.)
Kitchen - 1,400 sq. ft.; Ancillary support
space – 1,753 sq. ft.

Total Floor Area & FAR 52,696 sq. ft. (0.246)
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O. Minor deviations of up to 10% of numeric standards from the Detailed Development Plan may be approved administratively by the Director of Community Development or their designee, except for the Phase 2 Athletics Building setback standards for abutting residential properties.

Operational Standard Conditions
139. The following “Student Loading Policy” shall be required to minimize school traffic impacts on the residential neighborhood.
a. No Charles Armstrong School Student shall drive to school; during school operating hours; the required parking spaces are intended for school employees or visitors.
b. Morning Drop-Off for the school begins at 7:30 AM until the start of school at 8:30 AM. School staff has assigned a traffic director to direct school traffic off Solana Drive and down to the lower parking lot. A second traffic director, in the parking lot, opens the car door and assists the student out of the vehicle. Once the student is safely away from the vehicle, the vehicle driver is directed out of the lot and back out of the campus and off of the neighborhood streets as quickly as possible. c. Afternoon Pick-Up includes staggered class dismissal times. Drivers begin arriving at approximately 2:45 PM where a staff person directs pick-up traffic to the lower driveway and into the schoolyard. At a designated time, all vehicles are halted, and the students are allowed to go to their vehicle. Homeroom teachers accompany their students to the lower schoolyard and when the first group of students are safely in their vehicles, student movement is halted, and the loaded vehicles are directed out of the lot. There are at least six (6) traffic directors always managing the pedestrian and vehicle traffic movement.
140. The applicant shall arrange for refuse/recycling pick-up to occur between Mondays through Friday, 7:00 AM to 5:00 PM.
141. The school shall prepare and amil a calendar of special events on a quarterly basis to all property owners within 300 feet of the school property in order to notify neighbors of upcoming school events.
142. The school shall conduct a minimum of one open house meeting annually in order to foster neighbor communication.
143. A report, verifying continued conditions of approval compliance, shall be generated by the school and submitted to the Director of Community Development on an annual basis after one (1) year of Certificate of Occupancy issuance of the Phase 1 Project Scope. After three annual reports after the Certificate of Occupancy of the Phase 1 Project Scope, Community Development Director may amend the report to be required only once every five (5) years.
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General Conditions
144. The developer is hereby notified, as required by Government Code §66020, that the approved plans, the conditions of approval, and the adopted City fee schedule found at www.belmont.gov constitute written notice of the description of the dedications, reservations, amount of fees and other exactions related to the project. As of the date of project approval, the 90-day period has begun in which Developer may protest any dedications, reservations, fees or other exactions imposed by the City. Failure to file a protest in compliance with all of the requirements of Government Code §66020 will result in a legal bar to challenging the dedications, reservations, fees or other exactions. 145. Indemnification. Land Owner hereby agrees to and shall indemnify, defend, and hold harmless City, any City agencies and their respective elected and appointed councils, boards, commissions, officers, agents, employees, volunteers, and representatives (collectively, for the purposes of this Performance Standard, "City") from any and all loss, liability, fines, penalties, forfeitures, costs, and damages (whether in contract, tort, or strict liability, including but not limited to personal injury, death at any time, and property damage) and from any and all claims, demands, and actions in law or equity (including attorneys' fees and litigation expenses) directly or indirectly arising or alleged to have arisen out of or in any way related to: (a) the approval of the Development Agreement or the City Approvals; (b) any development or use of the Property under the Development Agreement or the City Approvals; and (c) any actions or inactions by the Land owner or its contractors, subcontractors, agents, or employees in connection with the construction or improvement of the Property and the Project; excepting to the extent arising from the intentional acts or willful misconduct of City, its elected and appointed representatives, officers, agents, employees, contractors or subcontractors.
146. This indemnification and hold harmless agreement applies to all damages and claims for damages suffered or alleged to have been suffered by reason of the operations referred to in this Performance Standard, regardless of whether or not City prepared, supplied, or approved plans or specifications for the Property, but does not apply to damages and claims for damages caused by City with respect to public improvements and facilities after City has accepted responsibility for them. 147. Fees. The applicant/developer agrees to pay all fees including plan check, building permit, General Plan Maintenance, Business License, and Tree Removal as specified by each respective City Ordinance or the City's Master Fee Schedule.

Building Permit Submittal
148. Construction Staging and Storage areas. The applicant shall provide a written plan for construction staging and storage areas. This information shall be submitted in conjunction with application for a building permit for City review and approval. 132

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149. Tree Removal Permit. All protected trees removed for the project shall be replaced onsite at a 1:1 ratio using preferred species trees or in-lieu fees shall be paid at 1:1 ratio in the amount identified on the City's adopted Fee Schedule at the time of building permit issuance.
150. Prior to issuing a permit for grubbing, demolition, tree removal, grading, or construction, the following must occur:

Pruning:

Any pre-project pruning of trees on or adjacent to the subject property shall be performed only by or under direct site supervision of an ISA Certified Arborist and shall conform to the most recent edition of ANSI A300 Part I: Tree, Shrub, and Other Woody Plant Maintenance, Standard Practices, Pruning. Tree Care Companies performing work on the subject property shall contact the City Arborist (CCA) prior to commencement of any work. The CCA will request a receipt for all tree care related work to verify compliance with this pruning recommendation.

Tree Protection Zone (TPZ):

The applicant shall install tree protection measures for the project as recommended by a certified arborist. The arborist shall inspect and verify, in writing, that appropriate measures have been installed prior to beginning construction. The protective measures must not be temporarily moved during construction. No materials, tools, excavated soil, liquids, substances, etc. are to be placed or dumped, even temporarily, inside the TPZ. 151. Prior to issuance of a building permit, the project plans must be reviewed and approved by the Mid-Peninsula Water District (MPWD). Contact the Water Administrative Specialist at (650) 591-8941 or [email protected] for more information.

Please be advised that any alterations to the landscaping after MPWD approval may require subsequent review by MPWD.
152. After the City permits are approved, but before beginning construction, the property owner/applicant shall hold a preconstruction conference with Community Development Department and Public Works Department staff, among other interested parties. The developer shall arrange for the attendance of the construction manager, contractor, and all subcontractors who are responsible for grading and erosion and sedimentation protection controls.
153. Prior to issuance of a building permit, the Geotechnical Engineer of Record ("GEOR") shall review the geotechnical aspects of the completed project civil and architectural drawings and provide a professional certification letter to the City. In addition, the GEOR shall be consulted by the project structural engineer ("SE") during the design process, provide assistance as needed in determination of design pier lengths, and review the completed structural plans and calculations for conformance to the GEOR's geotechnical recommendations. The GEOR shall also provide supplemental recommendations as necessary and provide a professional certification letter to the City 133

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to that effect. The aforementioned letters may be required to be peer-reviewed by the City’s geotechnical consultant prior to issuance of a building permit. 154. The GEOR shall be retained to observe the geotechnical and foundation aspects of the construction. The GEOR shall observe pier foundation excavations and based upon their observations, confirm that adequate embedment has been achieved in supporting materials judged to be competent supporting material. The GEOR should provide written documentation in a final construction report to the City for the following activities:
a. Earthwork operations, including subgrade preparation, earthwork construction, and site drainage installations as applicable.
b. Recording of test locations and results of field and laboratory compaction tests where testing is determined to be appropriate by the project geotechnical engineer. c. Building foundations, including observation of foundation supporting materials and confirmation of individual foundation embedment and/or supporting materials with respect to the project geotechnical engineer’s recommendations. d. Site drainage, including finish grading around the residence and discharge of collected surface and subsurface water to appropriate discharge facilities.

The aforementioned final construction report may be required to be peer-reviewed by the City’s geotechnical consultant prior to issuance of a Planning final.

Prior to Certificate of Occupancy
155. Demolition waste shall either be used on-site or separated and trucked to certified recyclers in conformance with CalGreen standards. All solid waste generated on-site shall be disposed of in accordance with all applicable federal and State regulations related to solid waste.

Phase 2 Athletics Building Community Access
156. In the six months prior to Charles Armstrong School occupying the Athletics Building (Phase 2), the City and Charles Armstrong School will conduct a meeting to review Armstrong’s expected Athletics Building use and the availability for some City/Community rental of the gym outside of the hours Armstrong requires. The discussion will also facilitate the process for potential required amendments of the Detailed Development Plan associated with Phase 2 to address said joint use. Subsequent Annual Reviews regarding school use and Phase 2 Athletics Building Belmont rental will also occur annually in June, once the Athletics Building is completed. 134

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III. COMPLY WITH THE FOLLOWING CONDITIONS OF THE BUILDING DEPARTMENT:

Building Permit Submittal
157. The building permit submittal shall be in conformance with the approved project plans (PA2024-0050).
158. The applicant shall obtain all required permits.
159. The Project shall comply with the buildings standards in the California Building Standards Code, as adopted and amended by the City of Belmont.
160. A minimum of 65% of the construction waste generated by this project shall be recycled or salvaged for use. Documentation shall be provided before the final inspection.

Sample forms found in A Guide to the California Green Building Standards Code (Residential) located at www.hcd.ca.gov/CALGreen.html may be used to assist in documenting compliance, CALGreen Section 4.408.
161. Provide on the plans the existing and proposed locations of the electric and gas meters, subpanels, water heater and furnace.
162. A soils and engineering geology report for all new or substantially altered foundations is required per BCC Section 7-12 and 2013 CBC Section 1803. Provide such a report and a letter from the geotechnical engineer confirming that the foundation plan has been reviewed and that it has been determined that the recommendations in the soils report are properly incorporated into the plans.
163. Provide a record of survey.
164. Amend the plans to show the location of all transformers, fire standpipes, and back flow preventers. Provide on the plans the existing and proposed location of the main electrical service, all subpanels, gas meter, furnace and water heater. 165. After the City permits are approved but before beginning construction, the owner/applicant shall hold a preconstruction conference with Building and Public Works Department staff and other interested parties. The developer shall arrange for the attendance of the construction manager, contractor, and all subcontractors who are responsible for grading and erosion and sedimentation protection controls.

During Construction
166. All construction and related activities which require a City permit shall be allowed only during the hours of 8:00 a.m. to 5:00 p.m., Monday through Friday and 10:00 a.m. to 5:00 p.m., Saturdays. No construction activity or related activities shall be allowed outside of the aforementioned hours or on Sundays and the following holidays: New Year’s Day, 135

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President’s Day, Memorial Day, 4th of July, Labor Day, Thanksgiving Day and Christmas Day. All gasoline powered construction equipment shall be equipped with an operating muffler or baffling system as originally provided by the manufacturer, and no modification to these systems is permitted.
167. Post hours of operation and phone numbers for noise complaints. 168. Investigate opportunities for salvaging material for reuse. 169. Every building, or structure, shall be provided with an address. Numerals shall be located where clearly visible from the street or roadway upon which it fronts. Residential Structures shall have numerals a minimum of 4 inches in height and of stroke. Commercial Structures shall have numerals a minimum of 6 inches in height and inch stroke. Numerals shall be of contrasting color to their background and illuminated at night. Numerals shall be white in color where located upon glazing.

IV. COMPLY WITH THE FOLLOWING CONDITIONS OF THE BELMONT FIRE DEPARTMENT:
170. A separate application and permit are required for the installation or alteration of any Automatic Fire Extinguishing System. The application shall be made by either a Registered Engineer or by the Licensed Fire Sprinkler Contractor who will be performing the work. This application shall include any Fixed Fire Protection System.

A valid Permit and Approved Plans shall be at the jobsite at all times. 171. A separate application and permit are required for the installation of any underground fire service lines. Application shall be made by a Registered Engineer or by either a General Engineering Contractor or a Licensed Fire Sprinkler Contractor, who will be performing the work.
172. Building plans shall include general notes provided on the Cover Sheet as follows:

A separate application and permit are required for the installation or alteration of any Automatic Fire Extinguishing System. The application shall be made by either a Registered Engineer or by the Licensed Fire Sprinkler Contractor who will be performing the work. This shall include any Fixed Fire Protection System. A valid Permit and Approved Plans shall be at the jobsite at all times. 173. Prior to application for a Fire Sprinkler Permit, the applicant shall submit plans to MidPeninsula Water District for their review and approval. Contact MPWD at 650-591- 8941.
174. A separate application and permit are required for the installation or alteration of any Fire Alarm, or Water-flow Monitoring System. This shall include the interconnection of any Fixed Fire Protection System to an Alarm System where provided. A valid Permit and Approved Plans shall be at the jobsite at all times. 136

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175. A separate application and permit are required for the installation of any underground fire service lines. Application shall be made by a Registered Engineer or by either a General Engineering Contractor or a Licensed Fire Sprinkler Contractor, who will be performing the work.
176. Every building, or structure, shall be provided with an address. Numerals shall be located where clearly visible from the street or roadway upon which it fronts.

Residential Structures shall have numerals a minimum of 4 inches in height and of ½ stroke. Commercial Structures shall have numerals a minimum of 6 inches in height and ¾ inch stroke. Numerals shall be of contrasting color to their background and illuminated at night. Numerals shall be white in color where located upon glazing. 177. A Knox Key-Lock Box is required to be installed as shown on plans. Contact Fire Prevention at 650-637-2939 to obtain an application.
178. All Fire Inspections are performed on Wednesdays between 9:00a.m.-2:00p.m., unless special arrangements are made with the Fire Inspector. Call 650-637-2939 to schedule an inspection. A minimum of 48 hours advance notice is required. In accordance with the Municipal/Regional Stormwater Permit no fire sprinkler system drain shall discharge into any Storm Drain System. The system shall discharge to either a landscape area large enough to contain the outflow, or to the Sanitary Sewer by means of an indirect connection. The location of the Fire Sprinkler System drain shall be shown on plans submitted for a building permit.

V. COMPLY WITH THE FOLLOWING CONDITIONS OF THE BELMONT PARKS AND RECREATION DEPARTMENT:
179. The Project landscape plan shall include both fire resistive planting including slope stabilizers that are native and fire resistive along the urban/wildland interface. Nonnatives shall be a sterile variety and as such not invasive and not planted along the wildland/urban interface.

VI. COMPLY WITH THE FOLLOWING CONDITIONS OF THE PUBLIC WORKS DEPARTMENT:

Prior to Building Permit Issuance
180. The plans shall show the installation of a trash full capture system(s) from a list of certified trash full capture systems by the State Water Resources Control Board. The list of certified trash full capture systems can be viewed from the Water Board’s webpage at:
https://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/trash_imple mentation/2025/full-cptre-for-public.pdf.
181. In conjunction with the Building Permit plan submittal, the Applicant shall provide an updated title report dated within the previous six (6) months, including functional hyperlinks to each listed exception. The permit plan submittal shall include a separate 137

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plan sheet identifying the location and description of all title exceptions affecting the project site. The Applicant is advised that, because a current title report was not provided during entitlement processing, existing title exceptions may be identified that could require modifications to the approved site layout. 182. The project is subject to the review and approval a drainage capacity analysis which, at a minimum, must address the following:
i. Supports the sizing of the on-site storm drain system and connections to the public storm system.
ii. Impacts to capacity of the existing storm drain main and if any hydromodification is needed on-site to mimic pre-existing site peak flow. iii. Addresses impacts of the proposed “Re-route of Public Storm Water” around the new school facilities. Applicant is advised that the City Engineer, at their sole discretion, may require modifications to the approved storm drain re-route configuration.

The Applicant is advised that if any deficiencies in the existing City storm drain system are identified that would be affected by increased runoff from the project site, the Applicant shall be required to either improve the affected downstream facilities at their sole expense or contribute a proportionate share of the cost of such improvements, as determined by the Public Works Director.
183. The project is subject to the review and approval a Stormwater Management Plan that illustrates compliance with the Municipal Regional Stormwater NPDES Permit Provision C.3 Order No. R2-2022-0018 (MRP 3.0) and San Mateo Countywide Water Pollution Prevention Program’s (SMCWPPP) C.3 Stormwater Technical Guidance.

The Stormwater Management Plan shall include, at a minimum:
i. C.3 and C.6 Development Review Checklist.
ii. Exhibit(s) showing drainage areas and locations of Low Impact Development (LID) treatment measures.
iii. Project watershed.
iv. Total project site area and total area of land disturbed. v. Total new and/or replaced impervious area.
vi. Treatment measures and hydraulic sizing calculations. Applicant shall note that all stormwater treatment measures shown on the improvement plans shall provide sufficient elevation and dimensional information to be field verified during construction by the City Inspector.
vii. A listing of source control and site design measures to be implemented at the site. All site design and source control measures checked “yes” in the C.3 Regulated Project Checklist’s Sections II.B and II.C shall be strictly adhered to. Source control measures shall be clearly labeled on the improvement plans.
viii. Projects shall comply with all requirements of the Municipal Regional Stormwater NPDES Permit Provision C.3 (MRP 3.0) and San Mateo 138

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Countywide Water Pollution Prevention Program’s (SMCWPPP) C.3 Stormwater Technical Guidance to the satisfaction of the City Engineer. ix. The Project is subject to an existing Maintenance Agreement for Stormwater Treatment Measures and Hydromodification Management Controls, dated February 25, 2015 (San Mateo County Record Document #2015-027138) for six existing stormwater biotreatment planters. The Stormwater Management Plan shall show the existing six (6) stormwater biotreatment control measures, the associated pipe conveyance system for the treatment control measures, and the proposed revisions to the existing stormwater biotreatment control measures. The following information shall also be shown:

1. The pre-development/existing stormwater biotreatment control measures, conveyance piping, and the drainage management areas.

2. Identification of the project’s intent and proposed modifications to the existing stormwater biotreatment control measures, conveyance piping, and the drainage management areas (e.g. remain in place, relocate, modify, etc.).

3. Provide calculations for the modified existing stormwater biotreatment measures to confirm that the existing DMAs comply with Provision C.3 sizing requirements.

4. Provide a revised C.3/C.6 checklist to account for the modifications to the existing biotreatment control measures.

The Applicant shall be fully responsible for complying with all applicable MRP 3.0 requirements and is advised that modifications to the approved site layout may be required to achieve compliance.
184. The project is subject to the review and approval an existing sewer system capacity analysis to determine whether adequate capacity exists in the City’s sewer main to accommodate the increased flows generated by the project. The analysis shall be accompanied by existing CCTV footage of the sewer main from the project’s point of connection to the sewer main in Chula Vista Drive. If deficiencies in the existing City sewer system are identified through the capacity analysis or CCTV condition assessment, the Applicant shall be required to design and construct improvements to the affected downstream facilities at the Applicant’s sole expense. 185. The Applicant shall obtain final approval from San Mateo Consolidated for the locations of all fire hydrants, fire department connections (FDCs), and the underground fire service lines. The Applicant is advised that, to ensure compliance with City Building and Fire Code requirements, modifications to the approved site layout may be required.

186. The Applicant shall provide approval from the project geotechnical engineer for the overall improvement plans. This approval shall specifically address the placement of 139

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stormwater structures and storm drain mains adjacent to, or in some cases directly against, building structures and foundations.
187. The Applicant shall clarify the disposition of the nature trail improvements that are shown on the Landscaping Plans and located southeast of the proposed plaza area. If the Applicant is proposing the nature trail, the Applicant plans shall provide updated grading, drainage, and stormwater control plans for the nature trail improvements. 188. The project is required to submit irrigation system layout plans to support the planting within the stormwater biotreatment planters for City review and approval. 189. The project shall update the Stormwater Control Plan to incorporate the building and site improvements that are between the eastern side of the proposed academic buildings and the proposed easterly perimeter concrete v-ditches. 190. The project shall provide detailed roofing plans for the City’s review and approval. The roofing plans shall provide sufficient details to confirm the project’s proposed DMA delineation on the stormwater control plan.
191. The Applicant shall provide plan provisions/notes for the proposed reuse of the existing 24” City storm drain pipe located between the northeast corner of the new gymnasium and the southwest corner of the existing lower classroom building. The reuse of the existing 22” storm drain is subject to City review of the pipe’s CCTV inspection to confirm the condition and pipe meet current City Standards. If the storm drain pipe reuse is not approved by the City, the segment shall be replaced in accordance with City Standards.
192. The project shall provide system details of the proposed on-site sanitary sewer pump station for City review and approval. The on-site sewer pump station plans shall provide sufficient details to demonstrate that the pump station has adequate overflow gravity facilities, backup power, and other improvements to mitigate sewer overflows from the site. The sewer pump station shall be subject to Public Works and Building review and approval.
193. If applicable, the project shall provide the location(s) of the buildings’ electric transformers.
194. The following Public Works’ comments shall be resolved by the project prior to Building Permit issuance:
a. The plans shall be updated to label the public and private wet utility systems. b. The project shall provide additional topographic survey finished grade elevation information for the existing northern parking lot that is proposed for DMA #4; the elevation information shall be reviewed by the City to confirm that the proposed area will drain to the proposed IMP #4 biotreatment area. c. Assess the potential capacity impacts in the drainage report for the proposed rerouted storm drain main. Note that adding multiple 90-degree bends and 140

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longer/flatter pipe segments can reduce capacity. Perform a capacity study to confirm adequacy.
d. Indicate whether the City’s public storm drain main is located within a dedicated easement. If so, and if the City approves the re-routing, the existing easement would need to be vacated and a new easement recorded. Applicant shall work with City staff to determine the allowable easement width.
e. If the proposed public storm drain pipe alignment is allowed within the hillside area, the project may be required to provide additional grading and surface improvements to ensure the City can access and maintain the public storm drain pipe.
f. The Applicant shall provide an updated sewer capacity analysis with the modeling application result data and narrative on the existing capacity of the downstream City sewer main that the project will connect to.
g. Provide CCTV footage of the existing sanitary sewer main proposed for reuse to verify its condition. Additionally, clarify the location where the existing sanitary sewer lateral ultimately connects to the main line.
h. Revise the plans to show the extents and connection points to the existing service lateral(s) of the existing sewer piping for the existing Upper and Middle Classroom buildings.
i. Provide a project stormwater management report outlining the overall treatment strategy for the project site and explaining how the project will comply with NPDES Municipal Regional Permit requirements. The report shall also include discussions on the modifications to the existing stormwater treatment measures and the proposed in-lieu treatment of DMA #4 for DMA #3.
j. The plans show two existing 12” storm drain pipes between the existing classroom buildings. Revise the plans to identify the existing storm drain piping’ extents, the disposition of the existing piping (e.g. will the piping remain or be relocated out of the proposed building footprints), and the system invert elevation information.

Prior to Building Permit Final
195. The Project is subject to an existing Maintenance Agreement for Stormwater Treatment Measures and Hydromodification Management Controls, dated February 25, 2015 (San Mateo County Record Document #2015-027138) for six existing stormwater biotreatment planters. An update or supplemental Operations and Maintenance (O&M) Plan for new treatment measures shall be recorded prior to Building Permit issuance.

The appropriate form of recordation shall be determined by the City Engineer. 196. The Applicant shall dedicate a Storm Drain Easement over all City-owned storm drain facilities located within the project site. The final alignment and width of the easement shall be determined by the City Engineer.
197. The Applicant shall quitclaim any existing easements which are necessary to be removed to support the Project.
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198. The Applicant shall dedicate Emergency Vehicle Access Easement(s) (EVAE) over the parking lot and rear courtyard areas for fire vehicles/equipment and in accordance with San Mateo Consolidated approval of the project’s Fire Access Plan. The EVAE dedication instrument shall be submitted to City for review and approval. 199. The Applicant shall submit a letter from Mid-Peninsula Water District (MPWD), confirming MPWD review and approval of the project’s on-site domestic water system and its configuration.
200. As part of the Construction Management Plan, the Applicant shall include the phasing intent for the construction of the proposed stormwater treatment control measures and storm drain system conveyance improvements, in conjunction with the project’s buildings and site improvement scheduling. The phasing shall include any modifications to the existing stormwater treatment control measures. If the project intends to be phased for future construction of the stormwater treatment control measures, each phase of the development shall be compliant with Provision C.3 of the MRP.

VII. COMPLY WITH THE FOLLOWING CONDITIONS OF THE BELMONT POLICE DEPARTMENT:
201. All activities shall be subject to the requirements of the Belmont Noise Ordinance. 202. No debris boxes or building materials shall be stored on the street unless permitted. 203. Any burglar alarm shall be registered with the PD per BCC 18-50 et. seq. 204. The applicant shall provide a security plan to the Police Department plan for the construction period, prior to issuance of a building permit. Said plan shall, at minimum, include: lighting, surveillance, physical security of property, and securing of any tools, equipment and/or materials left on site. The Police Department shall also be provided 24-hour emergency contact information for the contractor and owner. Route emergency contact information to PD Attn: Sgt. Thompson or email to [email protected]. 205. No Trespassing signs, per 602 PC, required to be posted around property to discourage unauthorized entry and aid in criminal prosecutions for trespassing/theft. 206. Ensure PD has access to any secured emergency access easements/gates/pathways.

Certification of Approved Final Conditions:

Carlos de Melo, Community Development Director Date
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ORDINANCE NO. ______

AN ORDINANCE OF THE CITY OF BELMONT AMENDING THE CONCEPTUAL DEVELOPMENT PLAN FOR CHARLES ARMSTRONG SCHOOL AT 1405 SOLANA

DRIVE TO ALLOW FOR EXPANSION OF THE SCHOOL
WHEREAS, Charles Armstrong School desires to renovate its existing campus at 1405 Solana Drive (Assessor’s Parcel Number 045-122-190) and has applied (Appl. No. PA2024-0050) for approval of an amended conceptual development plan for the planned development zoned property, a conditional use permit, detailed development plan, design review, grading plan and permit, and a tree removal permit, which will allow for construction of an 11,893-square-foot academic wing and an 11,126-square-foot athletics building in two phases and campus operational modifications; and,
WHEREAS, on February 10, 2026, the City Council held a duly noticed public hearing to consider the Planning Commission’s recommendations and receive public testimony and a staff report on the requested entitlements, including the amendment of the conceptual development plan; and, WHEREAS, the City Council hereby adopts the staff report dated February 10, 2026, and the facts contained therein as its own findings of facts; and,
WHEREAS, the City Council did hear and use their independent judgment and considered all reports, recommendations, public input and testimony.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF BELMONT DOES ORDAIN AS FOLLOWS:

SECTION 1. CONCEPTUAL DEVELOPMENT PLAN AMENDED
(a) The recitals above are true and correct.
(b) After reviewing all the relevant evidence before the City Council, including the information provided in the staff reports and enclosures to the Planning Commission and City Council, the public hearings and testimony received, the City Council incorporates herein by reference the staff report to the City Council dated February 10, 2026, and adopts the analysis and findings herein as its own findings of fact under Belmont Zoning Ordinance Section 12.3.B related to the Conceptual Development Plan amendment.
(c) Based on the evidence before the City Council, the City Council finds the proposed Conceptual Development Plan amendment is consistent with the General Plan. (d) The application to amend the Conceptual Development Plan for Charles Armstrong School is approved based on the findings set forth herein and subject to the Conditions of Approval for the Project adopted by the City Council at its February 24, 2026 meeting, by Resolution __________. (e) The Conceptual Development Plan for the Charles Armstrong School Planned Development District, previously adopted by Ordinance No. 783, is amended and replaced as shown on Exhibit A – Conceptual Development Plan – Development Standards, and Exhibit B – Conceptual Development Plan – Campus Site & Building Location Plan, attached hereto. 143

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SECTION 2. EFFECTIVE DATE.

This Ordinance takes effect and will be enforced 30 days after its adoption. * * *
The City Council of the City of Belmont, California introduced the foregoing ordinance, on February 10, 2026 and adopted the ordinance at a regular meeting held on [insert date] by the following vote:

Ayes:

Noes:

Absent:

Abstain:

ATTEST:

City Clerk Mayor
APPROVED AS TO FORM:

City Attorney
144
Exhibit A
Ordinance 2026-____
Conceptual Development Plan - Development Standards
Charles Armstrong School – 1405 Solana Drive
145
Exhibit A - Conceptual Development Plan (CDP) – Development Standards Charles Armstrong School – 1405 Solana Drive
2 The Conceptual Development Plan (CDP) for the Charles Armstrong School campus shall be constructed in two phases. The CDP for Phase 1 includes the development of a new academic wing (three new classroom buildings); Phase 1 is proposed to begin construction in 2026. Phase 2 includes the construction of an Athletics Building; Phase 2 is anticipated to be constructed in the 2031-2032 school year. The relative locations of all proposed Phase 1 and 2 improvements are delineated on Exhibit B – CDP Campus Site & Building Location Plan. The CDP shall also be consistent with the following development/use standards as referenced below.

A. Minimum Lot Size. 4.92 Acres (214,315 sq. ft.)
B. Permitted Uses.

1. A private school for up to 290 students, including supporting/accessory activities and uses such as a gymnasium, kitchen, and multipurpose room for the subject property.

3. Allowance of twelve (12) weekend events annually involving 25 or more attendees (e.g., schoolwide gatherings, accreditation visits, graduation).

4. Permission of three (3) special Saturday evening events each year such as a musical or alumni gathering or benefit event with activities ending by 10:00 p.m.

5. Authorized dismissals on nearby neighborhood streets for up to four (4) special events per year to ease traffic congestion associated with large on-campus gatherings.

C. Maximum Floor Area of buildings: 53,579 sq. ft.

D. Maximum Floor Area Ratio (FAR): 0.25
E. Minimum Setbacks:
146
Exhibit A - Conceptual Development Plan (CDP) – Development Standards Charles Armstrong School – 1405 Solana Drive
3 Criteria - Setbacks1 CDP
Standards
Proposed Project – Right Side &
Rear Setback
Front 30’ No change to existing setbacks
which exceed CDP minimum.

Left Side 25’ No change to existing setbacks
which exceed CDP minimum.

F. Maximum Building Height: The maximum building height may be 40 feet, as measured from finished grade to the top most point of the roof above (including mechanical equipment and all other building features).

Criteria CDP Standards Proposed Project
Height Maximum of 40 feet
Academic Building A -33’6”
Academic Building B - 34’2”
Academic Building C - 21’3”
Athletics Building + Kitchen -
32’0”
G. Off-Street Parking: 85 Parking Spaces (four of which are ADA accessible) pursuant to Section 8 (parking) of the Zoning Ordinance for School Uses and shall be consistent with Exhibit B – CDP Campus Site/Building Location Plan.

In addition, the school will add one parking space for any additional employees during the traditional school day beyond 85.

H. Landscaping/Lighting: Landscaping shall be native or locally acclimated, draught-tolerant species and consistent with all applicable state and local landscape requirements. All lighting shall be downcast on the project site and shall not create glare off-site. Parking lot and walkway lighting shall be the minimum required for safety. There shall be no floodlighting of landscape plantings, buildings, courtyards, patios, or areas between buildings.

I. Building Materials: Building materials shall be consistent with Elevation Drawings and submitted materials via an approved Detailed Development Plan (DDP) for the school.

J. Circulation Plan: – Circulation shall be consistent with Exhibit B – CDP Campus Site/Building Location Plan, except as modified via an approved Detailed Development Plan (DDP) or amendment thereto, after review and approval by 147
Exhibit A - Conceptual Development Plan (CDP) – Development Standards Charles Armstrong School – 1405 Solana Drive
4 the Director of Public Works in consultation with the Police and Fire Departments.

K. Fencing: Fencing standards shall be consistent with the materials and standards as outlined below.

L. Roof Mounted Mechanical Equipment: Installation of roof mounted mechanical equipment shall be consistent with the standards as outlined below.

Criteria CDP Standards Proposed Project
Roofmounted
Mechanical
Equipment
Screened from Public
Vantage Points
Screened from Public
Vantage Points
M. Signage: Signage shall be consistent with standards outlined below, except as modified by a Detailed Development Plan (DDP) or amendment thereto.

Criteria CDP Standards Proposed Project
Signage Per Detailed Development
Plan (DDP)
Vehicular Directional
Monument Sign – 20 sq. ft.

LED Monument Signs - 60
sq. ft.

Building Identification Signs
Informational Signage
N. Floor Area: Permitted floor area for the school shall be consistent with the standards outlined below except as modified by a Detailed Development Plan (DDP) amendment thereto, provided that total floor area does not exceed 0.25 FAR (53,579 sq. ft.) for the campus.

Criteria CDP Standards Proposed Project
Fencing
Chain Link and Wood –
Maximum of 6 feet in
height
Chain Link and Wood –
Maximum of 6 feet in height
148
Exhibit A - Conceptual Development Plan (CDP) – Development Standards Charles Armstrong School – 1405 Solana Drive
5 CDP Standards Proposed Project
Building Floor Area
Existing
a) Classroom Building 1
b) Classroom Building 2
c) Classroom Building 3
d) Multi-Purpose Building
Total - 29,677 sq. ft.

Building A - (6,364 sq. ft.)
Building B - (4,237 sq. ft.)
Building C - (1,292 sq. ft.)
New Athletic Building – Phase 2
h) Gymnasium
i) Support/Kitchen
Total - 11,126 sq. ft.

Gymnasium - (7,973 sq. ft.)
Kitchen - 1,400 sq. ft.; Ancillary support
space – 1,753 sq. ft.

Total Floor Area & FAR 52,696 sq. ft. (0.246)
O. Minor deviations of up to 10% of numeric standards from the Detailed Development Plan may be approved administratively by the Director of Community Development or their designee, except for the Phase 2 Athletics Building setback standards for abutting residential properties. 149
Exhibit B
Ordinance 2026-_____
Conceptual Development Plan - Campus Site & Building Location Plan Charles Armstrong School - 1405 Solana Drive
150
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90 285
280
275
270
265
260

SOLANA DRIVE
(E) PLAYGROUND
(E) MULTI-PURPOSE BUILDING
(E) CLASSROOMS
BUILDING 1
(E) CLASSROOMS
BUILDING 2
(E) CLASSROOMS
BUILDING 3
(N) LEARNING COURT
(N) PLAZA
(N) MAKER'S PATIO
(N) ATHLETICS BUILDING
(N) ACADEMIC BUILDING
AREA A
(N) ACADEMIC BUILDING
AREA B
(N) ACADEMIC BUILDING
AREA C
50 68
69 74
75 85

MCDOUGAL PARK

BIORETENTION,
SEE CIVIL, TYP.

PROJECT SCOPE

PROJECT SCOPE
9 NEW RELOCATED SPACES, 2 NEW ADDITIONAL SPACES
(N) SHADE CANOPY

SEE CIVIL FOR EASEMENTS

BIORETENTION,
SEE CIVIL, TYP.
18'-5"
16'-9"

SEE LANDSCAPE FOR

SCOPE OF WORK

PROJECT
NORTH
TRUE
NORTH
PROJECT NUMBER:

SHEET NUMBER:

SCALE:

SHEET TITLE:

KEY PLAN
5856 Doyle Street
Emeryville, CA 94608
Tel 510 899 6400
www.ratcliffarch.com
A
B
C
D
1 2 3 4 5
(E) CLASSROOM

BUILDINGS
(N) ACADEMIC

BUILDING
(E) MULTI

BUILDING
(N) ATHLETICS

BUILDING
3 2
1 C
B
A
1" = 20'-0"
8/1/2024 9:40:51 AM
AS-102
24404
08/02/2024 ENTITLEMENTS APPLICATION

CHARLES

ARMSTRONG SCHOOL
1405 Solana Drive
Belmont, CA 94002

NEW ACADEMIC &

ATHLETICS

BUILDINGS
1" = 20'-0" A1 SITE PLAN
ISSUE SCHEDULE NO. DATE
ENTITLEMENTS APPLICATION 1 08/02/2024
16'-9"

PROPOSED SETBACK
2 18'-5"

PROPOSED SETBACK
BLDG HEIGHT: 34'-2" BLDG HEIGHT: 33'-6" BLDG HEIGHT: 21'-3" BLDG HEIGHT: 17'-6" BLDG HEIGHT: 17'-6" BLDG HEIGHT: 17'-6" BLDG HEIGHT: 32'-0" BLDG HEIGHT: 20'-6" Permitted Uses:
- A private school (grades 2-8) for up to 290 students and 85 staff members, including supporting/accessory activities and uses such as a gymnasium, multipurpose room, and athletic fields (basketball courts and play park)
- Offices and work rooms for employee usage ancillary to the school of the site. (E) ATHLETIC COURTS PHASE 2: 2031-2032 PHASE 1: 2026-2027 PHASE 2
PHASE 1 12/19/2025
Building Phase Floor Area (GSF) FAR Height
Multi-Purpose Building Existing 8,651 0.041 ±20'-6"
Kitchen2 800 0.004
Maker Space2 500 0.002
Library2 1,200 0.006
Classrooms #1 Existing 7,346 0.034 ±17'-6"
Classrooms #2 Existing 6,840 0.032 ±17'-6"
Classrooms #3 Existing 6,840 0.032 ±17'-6"
Academic Bldg, Area A New, Phase 1A 6,364 0.030 33'-6"
Academic Bldg, Area B New, Phase 1A 4,237 0.020 34'-2"
Storage2 220 0.001
Academic Bldg, Area C New, Phase 1B 1,292 0.006 21'-3"
Athletics Building New, Phase 2 11,126 0.052 32'-0"
Gymnasium2 7,973 0.037
Kitchen2 3,153 0.015
Total Floor Area & FAR 52,696 0.247
Floor Area Ratio & Height from Submitted Plans 1
1 Building floor areas and maximum heights as delineated in project plans submittal. 2 Building areas indicated in red are portions of the same building in which they are located, and are already included in the overall floor area for that building.

Lot Area = 213,250 SF
151
276
277
276
259
258
257
256
253
259
261
262
258
254
259
256
259
259
259
259
271
268
269
267
266
263
264
261
262
268
273
274
277
278
277
276
277
278
279
281
260
260
260
260
255
270
265
260
280
260
265
260
255
255
250
250
270
275
280
285
290
295
300
305
315
275
265
270
300
290
285
280
90 285
280
275
270
265
260

MCDOUGAL PARK

BIORETENTION,
SEE CIVIL, TYP.

PROJECT SCOPE

PROJECT SCOPE
9 NEW RELOCATED SPACES, 2 NEW ADDITIONAL SPACES
(N) SHADE CANOPY

SEE CIVIL FOR EASEMENTS

BIORETENTION,
SEE CIVIL, TYP.
18'-5"
16'-9"

SEE LANDSCAPE FOR

SCOPE OF WORK

PROJECT
NORTH
TRUE
NORTH
PROJECT NUMBER:

SHEET NUMBER:

SCALE:

SHEET TITLE:

KEY PLAN
5856 Doyle Street
Emeryville, CA 94608
Tel 510 899 6400
www.ratcliffarch.com
A
B
C
D
1 2 3 4 5
(E) CLASSROOM

BUILDINGS
(N) ACADEMIC

BUILDING
(E) MULTI

BUILDING
(N) ATHLETICS

BUILDING
3 2
1 C
B
A
1" = 20'-0"
8/1/2024 9:40:51 AM
AS-102
24404
08/02/2024 ENTITLEMENTS APPLICATION

CHARLES

ARMSTRONG SCHOOL
1405 Solana Drive
Belmont, CA 94002

NEW ACADEMIC &

ATHLETICS

BUILDINGS
1" = 20'-0" A1 SITE PLAN
ISSUE SCHEDULE NO. DATE
ENTITLEMENTS APPLICATION 1 08/02/2024
RELOCATED 9 -- 9
PROPOSED TOTAL 81 4 85

PARKING COUNT

STANDARD ACCESSIBLE TOTAL
EXISTING 79 4 83
NEW 2 0 11
RELOCATED 9 -- 9
PROPOSED TOTAL 81 4 85 46 3 49
35 1 36

STANDARD ACCESSIBLE TOTAL

EMPLOYEE ONLY
79 4 83
EMPLOYEE+PUBLIC SHARED*

CARPOOL PICKUP/DROPOFF,

EXISTING TO REMAIN

TIMED PICKUP/DROPOFF,
EXISTING TO REMAIN 1
41 42 49 *USE VARIES BASED ON DAY/TIME 12/19/2025

RELOCATED

PROPOSED TOTAL
152
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 1 Exhibit C
General Plan Conformity Analysis – Charles Armstrong School Project 1405 Solana Drive – PA2024-0050
In determining General Plan consistency for the project, applicable goals and policies of the City’s General Plan must be considered by decision-makers. The goals and policies of applicable area plans also must be considered because they are ancillary long-range plans that connect to and support the General Plan; however, there are no area plans applicable to the project site. The applicable goals and policies of the City’s Climate Action Plan (CAP) must also be considered. A key factor when evaluating policy consistency is whether the project would substantially further or advance the goals and policies of the applicable plans.

A General Plan consistency analysis for the project is presented in Table 0-1 below. Based on this analysis, the project would be consistent with the General Plan because it would substantially further or advance the General Plan’s goals and policies. The project also would be consistent with the CAP’s goals and policies.

Table 0-1 Project Consistency with the Goals and Policies of the Belmont General Plan and Belmont Climate Action Plan
Goal or Policy Determination and Discussion
City of Belmont General Plan
Land Use Goal 2.1: Promote a diversity of
compatible land uses throughout the city, to
enable people to live close to job locations,
adequate and convenient commercial services,
and public services and facilities such as transit,
parks, and schools.

Consistent. The project would enhance a long-standing
community-serving educational use in an established
residential neighborhood. The school’s expansion would
strengthen local access to specialized educational services without introducing land use conflicts or disrupting the existing neighborhood fabric.

Land Use Goal 2.2: Support the creation and
enhancement of “complete neighborhoods” in
Belmont, with well-integrated single-family and
multi-family residential development, pedestrian
and bicycle-friendly environments, and activity
nodes featuring schools, parks, and
neighborhood commercial areas.

Consistent. Refer to the determination in Land Use Goal 2.1.

Land Use Policy 2.3-4: Focus new development
in or directly adjacent to already-developed
areas, where it can be served by existing public
services and infrastructure.

Consistent. Refer to the determination in Land Use Goal 2.1.

Land Use & Design Policy 2.13.1-4 &
Conservation Element Policy 5.3.6: Minimize light
and glare from new development; Avoid light
pollution and unnecessary glare by requiring
development projects to use design features and
shielding methods that cast outdoor light
downward and minimize glare and to install the
Consistent. The project would include lighting for building entries, walkways, and gathering spaces that would be fully shielded and directed downward. No pole-mounted or highwattage floodlights are proposed. Lighting would be limited to that necessary for safe circulation and site security, consistent with the City’s dark-sky goals. Final fixture selection and photometric design would be in compliance with the City’s lighting standards.
153
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 2 Goal or Policy Determination and Discussion
minimum amount of outdoor lighting necessary
for safety and security.

Circulation / Mobility, and Complete Streets
Goal 3.1: Provide for the safe and efficient
movement of people and vehicles within and
through the community that fosters accessibility
and connectivity; accommodates a mixture of
automobiles, transit, bicyclists, and pedestrians;
and encourages higher transit ridership.

Consistent. The project would maintain and enhance
internal circulation for pedestrians and vehicles, including Americans with Disabilities Act-compliant access routes, drop-off/pick-up staging, and designated parking areas. The small enrollment increase (from 260 to 290) would not
generate significant new trips, and the Transportation
Demand Management (TDM) practices—such as staggered
dismissal and carpool coordination—would reduce potential traffic impacts. The campus is near existing transit
corridors, and the project design/scale would accommodate multimodal access without altering public street
infrastructure.

Circulation / Mobility, and Complete Streets
Goal 3.8: Provide a balanced and well-managed
parking supply that accommodates demand
while maximizing efficiency.

Consistent. The project would increase the existing on-site parking supply of 83 by two spaces to 85 spaces across the upper and lower lots. With a projected staffing increase of approximately 11 persons and all staff being required to park on campus, the parking demand would remain within
capacity because of staggered schedules and part-time
staffing. Armstrong also would implement carpooling
strategies and formalize this protocol in its TDM Plan. No on-street parking demand or oversupply is expected to
occur.

Conservation and Biological Resources Goal 5.3:

Protect and restore biological and ecological
resources in Belmont, including sensitive wildlife
species and their habitats.

Consistent. The project would be entirely within a previously developed school campus and would not impact any
sensitive biological resources or wildlife habitats. Although 61 trees would be removed (including 39 protected trees, 33 of which are coast live oaks), the project would comply with the City’s protected tree replacement standards by providing 33 new oak trees onsite and 6 other preferred species replacement trees, or through in-lieu fees if all replacements cannot be accommodated. As noted below,
pre-construction nesting bird surveys would be conducted as required by the City through its standard conditions of approval. The project landscape plan would incorporate
native and drought-tolerant species, supporting urban
biodiversity and long-term ecological value on site. No riparian zones or undeveloped habitat areas would be
disturbed.

Conservation and Biological Resources
Policy 5.3-3: To the greatest extent feasible,
ensure that development does not disturb
sensitive habitat and special status species by
requiring appropriate and feasible mitigation
measures.

Consistent. The project site is fully developed and urbanized, with no identified sensitive habitats. However, there is the potential for nesting birds and bats (specifically the Alameda Sparrow and the Pallid Bat) and the San Francisco Duskyfooted Woodrat which are special-status species.

Preconstruction surveys would be conducted by a qualified biologist at the appropriate times prior to construction in accordance with the City standard COAs. If special-status 154
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 3 Goal or Policy Determination and Discussion
species are encountered, protective measures would be
implemented as identified and determined by the qualified biologist. In addition, the project design would incorporate best practices, such as native plantings, tree protection measures, and erosion control BMPs that would align with the intent of this policy.

Conservation and Biological Resources
Policy 5.3-5: In design and construction, require
use of best practices that preserve natural
resources, such as soil, trees, native plants, and
permeable surfaces.

Consistent. Refer to the determination in Conservation and Biological Resources Goal 5.3.

Conservation and Biological Resources
Policy 5.3-7: Encourage the planting of native
trees, shrubs, and grasslands in order to
preserve the visual integrity of the landscape,
provide habitat conditions suitable for native
vegetation, and ensure the maximum number
and variety of well-adapted plants are
maintained.

Consistent. Refer to the determination in Conservation and Biological Resources Goal 5.3.

Conservation and Water Quality Policy 5.5-3:

Require development projects to incorporate
structural and non- structural best management
practices (BMPs) to mitigate or reduce the
projected increases in pollutant loads, in
accordance with the NPDES permit guidelines.

Consistent. The project would include Low Impact
Development-based stormwater infrastructure, designed in compliance with National Pollutant Discharge Elimination System and Special Provision C.3 requirements. Bioretention areas and on-site treatment systems would improve runoff quality and reduce peak flow, consistent with City and
regional water quality objectives.

Conservation and Water Quality Policy 5.5-5:

Implement water pollution prevention methods to
the maximum extent practicable, supplemented
by pollutant source controls and treatment.

Consistent. Refer to the determination in Conservation and Water Quality Policy 5.5-3.

Conservation and Water Supply 5.6: Preserve
water resources and provide for long-range
community water needs by adopting best
management practices for water use and
conservation.

Consistent. The project would include a drought-tolerant landscape plan, in accordance with the current MidPeninsula Water District (MPWD) water efficiency in the landscape ordinance (WELO). The project applicant has
secured an “Intent to Serve” letter from MPWD, and the
project would be required to meet all applicable CALGreen (indoor water efficiency) standards at the time of building permit issuance.

Water Supply Policy 5.6-4: Set appropriate
conditions of approval for each new
development proposal to ensure that the
necessary water supply facilities and water
resources are in place prior to occupancy.

Consistent. Refer to the determination in Conservation and Water Supply Policy 5.6.
155
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 4 Goal or Policy Determination and Discussion
Conservation and Water Policy 5.6-5: Continue
the City’s Water Conservation Strategy to reduce
water use, control water cost, and promote
environmental sustainability in municipal
buildings, parks, landscaped areas, and athletic
fields, as feasible and appropriate.

Consistent. Refer to the determination in Conservation and Water Supply Policy 5.6.

Air Quality Policy 5.10-3: Ensure that
construction and grading activities minimize
short-term impacts to air quality by employing
appropriate mitigation measures and best
practices.

Consistent. In addition to the implementation of the City’s standard COAs for construction air quality emissions
minimization such as the use of equipment with Tier 4
engines, as developed through the General Plan EIR, the applicant and their construction contractor would
implement Bay Area Air Quality Management District
(BAAQMD) best practices for dust control, including regular watering of exposed soils, vehicle washdowns, and
covering of haul trucks. Diesel equipment would meet the California Air Resource Board’s emissions standards. These measures would minimize short-term emissions, furthering City and regional compliance efforts to ensure that regional thresholds are not exceeded.

Air Quality Policy 5.11-2: Support the Climate
Action Plan’s goals and implement the CAP’s
reduction measures and strategies to reduce
greenhouse gas emissions.

Consistent. The project would support the City’s CAP goals by avoiding fossil fuel use, by including efficient mechanical systems, and by using low-energy fixtures. The new
buildings would maximize daylighting and natural ventilation.

A new electrical service would power the entire campus.

Safety Goal 6.1: Minimize risks of property
damage and personal injury posed by geologic
and seismic hazards.

Consistent. A comprehensive geotechnical investigation
was prepared for the project and reviewed by the City, and no considerable geologic hazards were found on site (see Project Description Attachment E). The investigation report provides detailed recommendations for grading, drainage, slope stabilization, and foundation design. These
recommendations would be implemented, including slab-ongrade and shallow mat foundations, over-excavation of fill areas, and minor shoring. No pile driving or deep
foundations are proposed. Thus, the project would meet City standards for seismic and slope safety and minimize the risk of geotechnical hazards.

Safety Policy 6.1-1: Continue to maintain and
enforce appropriate standards to ensure new
development is designed to meet current safety
codes and requirements associated with seismic
activity. Require public and private development
to be located, designed, and constructed to
minimize the risk of loss of life and injury in the
event of a major earthquake or other natural
disaster.

Consistent. Refer to the determination in Safety Goal 6.1. 156
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 5 Goal or Policy Determination and Discussion
Safety Policy 6.1-2: Continue to regulate
development, including remodeling or structural
rehabilitation, to ensure adequate mitigation of
safety hazards on sites having a history or threat
of seismic dangers, erosion, landslides, or shrink
swell.

Consistent. Refer to the determination in Safety Goal 6.1.

Safety Policy 6.1-4: Continue to require
geotechnical site analysis for proposed
development on sites as specified in the
Municipal Code, prior to allowing site
development.

Consistent. Refer to the determination in Safety Goal 6.1.

Safety Policy 6.1-5: Geotechnical studies shall
identify any geologic hazards affecting the
proposed project site, any necessary mitigation
measures, and a statement of the site’s
suitability for the proposed development and
whether or not it will be safe from geologic
hazard for its expected life. The study shall
identify net developable areas, if any, based on
landslide or ground shaking potential or erosion
risk. Impacts from the development, such as
those resulting from increased water runoff,
shall also be determined. Such studies must be
signed by a licensed Certified Engineering
Geologist or Geotechnical Engineer and are
subject to review and approval by City staff
and/or contracted employees.

Consistent. Refer to the determination in Safety Goal 6.1.

Safety Policy 6.1-6: Require any geotechnical
studies to include the study of expansive and
creeping soils, as well as analysis of erosion,
seismic, and other geotechnical hazards, and
make recommendations, as warranted.

Consistent. Refer to the determination in Safety Goal 6.1.

Safety Policy 6.1-8: Ensure consideration of
seismic and geologic hazards at the earliest
possible point in the development process,
preferably before comprehensive engineering
work has commenced.

Consistent. Refer to the determination in Safety Goal 6.1.

Safety Goal 6.3: Protect soils, surface water, and
groundwater from contamination from hazardous
materials.

Consistent. The project has not proposed the use, storage, or disposal of hazardous materials during operation.

Construction activities would comply with all applicable stormwater pollution prevention measures, including best management practices for erosion control, materials
handling, and spill prevention. No existing or historical hazardous waste concerns have been identified on site, and excavation would be monitored for any unexpected
conditions.
157
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 6 Goal or Policy Determination and Discussion
Safety Goal 6.5: Ensure that utilities that are
essential to contemporary life are available and
adequate to meet the demands of the Belmont
community while also ensuring the utilities
maintain and enhance Belmont’s physical
diversity, visual qualities, and small-town
characteristics.

Consistent. The project would connect to all essential
utilities (i.e., water, sewer, electrical, internet). A new electrical service would be installed to support the allelectric design. An “Intent to Serve” letter has been secured from MPWD. No natural gas infrastructure is proposed.

Safety Policy 6.5-5: Require all new development
to be connected to the City’s sewer system. Consistent. Refer to the determination in Safety Goal 6.5.

Noise Goal 7.1: Strive to achieve an acceptable
noise environment for the environmental, health,
and safety needs of present and future residents
of Belmont.

Consistent. Construction noise would occur during Cityapproved project hours, and the project would not require nighttime work. No operational noise exceedances are
anticipated; mechanical systems would be screened and
compliant with City thresholds. Ventilation systems would allow indoor use with the windows closed.

Noise Policy 7.1-2: Use the Community Noise
Level Exposure Standards, as review criteria for
new land uses. Require all new development that
would be exposed to noise greater than the
“normally acceptable” noise level range to
reduce interior noise through design, sound
insulation, or other measures.

Consistent. Refer to the determination in Noise Goal 7.1.

Noise Policy 7.1-3: Require noise-reducing
mitigation to meet allowable outdoor and indoor
noise exposure standards in [General Plan] Table
7-2. Noise mitigation measures that may be
approved to achieve these noise level targets
include but are not limited to the following:
• Construct façades with substantial weight and
insulation;
• Use sound-rated windows for primary sleeping
and activity areas;
• Use sound-rated doors for all exterior entries at
primary sleeping and activity areas;
• Use minimum setbacks and exterior barriers;
• Use acoustic baffling of vents for chimneys,
attic and gable ends; and,
• Install a mechanical ventilation system that
provides fresh air under closed window
conditions.

Alternative acoustical designs that achieve the
prescribed noise level reduction may be
approved, provided a qualified Acoustical
Consultant submits information demonstrating
that the required reductions to meet the specific
Consistent. The project would be designed with durable, well-insulated façades, and sound-rated windows and doors consistent with City standards for noise control. Mechanical ventilation systems would provide fresh air under closedwindow conditions, maintaining interior noise levels below 45 dBA Ldn. These design features would achieve
compliance with the allowable interior and exterior noise exposure standards identified in General Plan Table 7-2.

A qualified acoustical consultant prepared a projectspecific mechanical equipment noise study based on a preliminary list of HVAC equipment, which indicates that the proposed design and construction methods would achieve
compliance with the City’s interior and exterior noise
standards. If any alternative acoustical designs or materials are proposed during building permit review, they would be reviewed and approved by the qualified acoustical
consultant to ensure compliance with City standards for stationary noise sources.
158
Charles Armstrong School Expansion Project ● General Plan Conformity Analysis 7 Goal or Policy Determination and Discussion
targets for outdoor activity areas and interior
spaces can be achieved and maintained.

Noise Policy: 7.1.8: Continue to enforce
applicable Federal and State Noise Insulation
Standards (CCR, Title 24) and noise
requirements.

Consistent. The project would comply with all applicable State Building Code (Title 24) noise insulation standards for educational facilities. The project’s design incorporates acoustical materials and mechanical ventilation that meet the minimum insulation performance standards for sensitive uses such as classrooms and activity areas.

Noise Policy: 7.1.10: Require developers of new
development anticipated to generate a
substantial amount of vibration during
construction to implement mitigation practices to
reduce vibration, which can include: operating
heavy equipment as far as practical from
residential uses; using smaller bulldozers
(operating weight less than 20,000 pounds) when
grading must occur within approximately 50 feet
of residential uses or other vibration sensitive
uses; and using quiet pile driving technology
when feasible.

Consistent. No pile-driving or other high-vibration activities are proposed. Construction would primarily involve standard building and grading equipment, operated at distances
greater than 50 feet from nearby residences. Equipment
would be staged as far from property lines as feasible, and smaller, lower-impact machinery would be used for fine
grading and finishing work. These practices would ensure compliance with City standards and avoid substantial
vibration effects on adjacent sensitive uses.

Noise Policy Goal 7.2: Protect noise-sensitive
land uses, such as schools, hospitals, and senior
care facilities, from encroachment of and
exposure to excessive levels of noise.

Consistent. Refer to the determination in Noise Goal 7.1.

City of Belmont Climate Action Plan
CAP Goal 3.1.1: Increase municipal, residential,
and commercial energy efficiency, renewable
energy, efficient water use, and green building.

Consistent. The project would be all-electrically powered and meet CALGreen and WELO standards. It would include
on-site recycling and composting as well as droughttolerant landscaping, Construction waste would be diverted in accordance with Recology guidelines.

CAP Goal 3.2.1: Reduce emissions from
transportation through efficient land use,
alternate modes of transportation, and
operational innovations.

Consistent. The project would support this goal by
maintaining a neighborhood-serving school in close
proximity to housing and transit. The project would also formalize an existing TDM program that includes staggered drop-off and dismissal times, carpool coordination, and onsite staff parking restrictions. Implementation of these operational practices would reduce single-occupancy
vehicle trips and lower transportation-related emissions, in alignment with CAP objectives.

CAP Goal 3.3.1: Reduce solid waste generated
and sent to landfills.

Consistent. Armstrong maintains a waste diversion program, and the project would include adequate space for recycling and compost collection.
159

Page 1 of 2 ends

CSG Amendment #1 to Task Order #2 – Building Plan Review Services Meeting Date: February 24, 2026
Agency: City of Belmont
Staff Contact: Carlos de Melo, Community Development Director, (650) 595-7440 [email protected]
Agenda Title: CSG Building Plan Review Services – Amendment #1 to Task Order #2 Agenda Action: Motion
Recommendation
Adopt a motion authorizing the City Manager to negotiate and execute Amendment #1 to Task Order #2 with CSG Consultants, Inc. for Building Plan Review Services to authorize an additional $200,000 expenditure for Fiscal Year 25-26 to increase the total authorized contract amount to $620,000.

Strategic Focus Area
Economic Development and Housing
Background
The City contracts with CSG Consultants, Inc. for on-call building plan review services. These services supplement internal staffing resources and provide specialized technical expertise not currently available within the Community Development Department. Engaging a consultant enables the City to uphold high standards in the permit review process while ensuring timely and efficient processing of applications.

In addition to Building Plan Review Services, CSG provides Inspection Services (as needed by the Public Works Department) and Permit Technician Services. These services offer the flexibility and technical capacity needed to support the City’s development review workload.

Analysis
Amendment #1 to Task Order #2 establishes a not-to-exceed amount of $620,000 to support the expected volume of plan review services anticipated for the remainder of FY 2025-26. The City received building permit applications for two large projects which has resulted in spend rate for the Task Order to be higher than anticipated for this Fiscal Year. Approval of a not-to-exceed additional contract limit of $200,000 will ensure that the City will be able to provide building plan review services for the remainder of FY 2025- 2026. The consultant services are directly reimbursed by the plan review fees collected by the Building Division and therefore will not result in any additional burden on the City’s General Fund.

CSG Consultants, Inc. has demonstrated a consistent ability to deliver high-quality services, is well-versed in the City’s development regulations and internal procedures and can respond effectively to changes in application volume and complexity. Their continued support remains essential to maintaining timely, accurate, and thorough permit review processes.
160

Page 2 of 2 ends

CSG Amendment #1 to Task Order #2 – Building Plan Review Services Alternatives

1. Refer back to staff for additional information.

2. Continue the item for further discussion.

Attachments
None.

Fiscal Impact
☒ No Fiscal Impact
There is available budget for this Task Order Amendment in the Development Services Fund (Account# 210-5-904-8351). This amendment is not expected to have a financial impact on the General Fund.
☒ Funding Source Confirmed
Source: Purpose: Public Outreach:

Staff Discretionary Action Posting of Agenda
*E-Notification of agendas, public notification as required for the February 24, 2026 City Council meeting 161

Page 1 of 8 ends

1301 Shoreway Road Development Project

STAFF REPORT
Meeting Date: February 24, 2026
Agency: City of Belmont
Staff Contact: Laura Russell, Deputy Community Development Director, [email protected] Christopher Dacumos, Contract Senior Planner, [email protected] Agenda Title: 1301 Shoreway Road Commercial Development Project Agenda Action: Ordinance
Recommendation

1. Conduct a Public Hearing and consider Planning Commission recommendations related to the project.

2. Introduce an Ordinance Rezoning 1301 Shoreway Road from Regional Commercial (RC) to Planned Unit Development (PD) and related Zoning Map Amendment; approving the Conceptual Development Plan; and approving the Development Agreement.

3. Review a Resolution Adopting the CEQA Findings of Fact, Certifying the Environmental Impact Report and Adopting the Mitigation Monitoring and Reporting Program.

4. Review a Resolution approving the Detailed Development Plan, Conditional Use Permit, Design Review, Grading Plan and Permit, and Tree Removal Permit.

Strategic Focus Area
Economic Development & Housing
Background
The owner of 1301 Shoreway Road, 1 Shoreway Owner, LLC, represented by Four Corners Properties (“applicant”), proposes to redevelop the property (“project”). The site is currently developed with a fourstory office building with 149,919 square feet (sf). The applicant submitted a proposal in June 2022 to redevelop the site to an office and/or life science project.

Public Engagement
Four Corners Properties provided notification of the proposed project and an invitation to an open house to hear about the project to property owners within 300 feet from their project in the spring of 2023. The applicant held the open house on May 3, 2023 to introduce and discuss the project at 1301 Shoreway Road.

There were no persons in attendance.

The City created a project page on website with project information for the public to review. The project page includes information on contacts, project plans, environmental reports and meetings. The City noticed property owners and occupants within 300 feet of the project site of the proposed project, that an Environmental Impact Report (EIR) was being prepared, and to invite interested parties to comment on the project and scope of the environmental analysis.

Additionally, the City has held five public meetings with the Planning Commission or City Council to seek feedback from the community:
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• May 7, 2024 – Preliminary Site Plan and Design Review • July 16, 2024 – Receive feedback on the scope of the environmental review • November 4, 2024 – Receive comments on the Draft Environmental Impact Report • October 28, 2025 – Receive feedback on the draft Development Agreement terms • January 20, 2026 – Consider Recommending the Certification of the Environmental Impact Report, Rezoning from Regional Commercial to Planned Development, and Related Project Entitlements Public comments received during the meetings included concern that the site would be overparked, the need for more bicycle parking, and requesting the applicant to engage with and/or use labor groups.

Additional comments were received in writing on the scope of the environmental analysis and potential impacts. Comments on the scope of the environmental analysis are included in the Draft EIR. Comments on the project’s potential impacts are addressed and responded to in the Final EIR.

Planning Commission Review
At their January 20, 2026 meeting, the Planning Commission conducted a duly noticed public hearing to review the project, including consideration of the proposed EIR and associated entitlements. The Planning Commission posed questions to the applicant regarding building design and proposed potential life science uses, and engaged in discussion regarding the merits of the project.

Commissioners expressed their support for the project, citing its location, potential to strengthen the City’s economic base, and the inclusion of the public amenities. Following deliberations, The Planning Commission voted unanimously to recommend City Council approval through adoption of Resolution No. 2026-02, Resolution No. 2026-03, and Resolution No. 2026-04.

Analysis
The applicant proposes to demolish the existing office building at 1301 Shoreway Road and construct two new office and/or life science buildings, an above-grade parking structure with additional surface parking spaces, and a publicly accessible trail with associated amenities.

Table 1. Project Data
Sitewide Data
Lot Size (acres | square feet (sf)) 6.9 acres | 300,564 sf Vehicle Parking 1,626 total: 1,533 in a garage, 93 uncovered surface spaces Bicycle Parking (short- | long-term) 92 | 109
General Plan Land Use Designation Regional Commercial
Existing Zoning Regional Commercial (RC)
Proposed Zoning Planned Unit Development (PD)
Trees Removed | Trees Planted 157 | 166
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Building 1 Building 2 Parking Garage
Stories / levels, Height in Feet 8 stories | 133’ 7 stories | 117’ 9 levels | 89’ Building 1 Building 2 Parking Garage
Square Footage 270, 452 sf 271,583 sf
442,690 sf
Total SF by Type 542,035 sf
Floor Area Ratio (FAR) by Type 1.8 1.5
Total FAR 3.3
Figure 1. Illustrative Site Plan
The applicant is requesting that the City Council certify and/or approval the following:
• Certification of the Environmental
Impact Report
• Adoption of the Mitigation Monitoring
and Reporting Program
• Rezoning from Regional Commercial
(RC) to Planned Unit Development
(PD) and Zoning Map Amendment
• Conceptual Development Plan
• Development Agreement
• Detailed Development Plan
• Conditional Use Permit
• Design Review
• Grading Plan and Permit
• Tree Removal
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General Plan Consistency
The Regional Commercial General Plan land use designation allows for community-serving retail and services, visitor- and retail-serving auto-oriented commercial services, such as lodging, service stations, car dealerships, and commercial office uses. The designation also envisions that certain light industrial and research and development (R&D) uses may also be permitted.

The project is consistent with the goals and policies of the City’s General Plan related to land use, open space, transportation, design, community benefits, public health and safety, and airport land use compatibility. General Plan consistency analysis is included in Exhibit D to Attachment 2.

Planned Unit Development (PD District)
The applicant has requested rezoning the subject site from Regional Commercial (RC) to Planned Unit Development (PD) District in accordance with Belmont Zoning Ordinance Section 12 - Planned Unit Development. The process to rezone RC to PD requires a Zoning Amendment and Zoning Map Amendment (Exhibit A to Attachment 2) as described under Section 16 of the Zoning Ordinance.

The applicant is requesting the rezoning to the PD District to add Life Science and Research and Development (R&D) as allowed uses and provide greater flexibility with site-specific development standards. The RC District currently limits office uses to above-ground levels, while allowing other commercial uses on all floors. The applicant is requesting flexibility to allow permitted uses to occur consistently across all levels of the buildings. The analysis supporting the rezoning is also included in Exhibit D to Attachment 2.

The proposed project complies with all development standards of the RC District and other Belmont Zoning Ordinance regulations except for height, FAR and driveway width. The project complies with setback requirements, landscaping, parking and other requirements. The applicant is requesting the following Planned Development zoning standard adjustments:

1. Height: Exceed the maximum height of 55 feet allowed in the RC District. The applicant proposes Building 1 at 133 feet, Building 2 at 117 feet and the above ground parking garage at 89 feet.

2. FAR: The maximum FAR allowed within the RC district is 1.8. The applicant requests to separately calculate the FAR of commercial uses and structured parking. In considering just the two commercial buildings, the FAR is 1.8. The FAR of the of the parking garage is 1.5. The total FAR including the commercial buildings and parking garage is 3.3.

3. Driveway width: Exceed the maximum driveway width of 20 feet. The proposed driveway widths are 24 feet.

Conceptual Development Plan
Belmont’s Zoning Ordinance requires that a request for a Planned Development approval be accompanied by a CDP, which would establish site-specific development standards and uses for the project site.

Attachment 2 includes the findings and analysis necessary to rezone the site to the PD District. Exhibit B to Attachment 2 is the CDP proposed by the applicant. The CDP establishes the permitted and conditional uses within the Planned Development (PD) District. Unlike the RC which restricts offices as an allowed use on ground floors, the CDP allows permitted uses on all floors. The CDP includes the uses permitted under RC and adds life science and research and development. It also includes development standards, including maximum building height, FAR, and parking, landscaping, and circulation requirements. 165

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1301 Shoreway Road Development Project
Development Agreement
The proposed community benefit package negotiated by the City is consistent with the general Community Benefit Program implementation guidance provided by the City Council at their February 25, 2025 meeting. The package is premised on the concept that both the City and Four Corners would share in the increased project value resulting from the more permissive development standards authorized under the PD zoning district.

The draft community benefits package includes a $6.3 million cash contribution to the City to support projects and services that advance community priorities, including but not limited to:
• Community Center reconstruction
• Public infrastructure (stormwater, roadways, transportation, etc.) • Public recreation opportunities (parks and plazas, access to fields, courts, etc.) • Funding for ongoing City services and operations
• Affordable childcare
The cash contribution would increase to a total of $7.0 million if the developer does not submit for building permit applications within the first seven years of the Development Agreement term. In addition to the cash contribution, Four Corners has committed to providing a minimum of 50% of their required Public Art investment (estimated to be $5.4 million) to the City as an in-lieu payment for use on Citywide public art projects, the remainder will be spent on site. Lastly, Four Corners has included labor provisions in the term sheet regarding to local hire goals, participation in apprenticeship programs, having a union signatory general contractor, and reporting on their labor goal compliance to the City.

On October 28, 2025 the City Council held a public meeting to review and provide direction on the proposed project and draft DA term sheet. The Council also received public comment regarding the proposed terms. After considering the staff presentation, applicant input, and public testimony, the Council expressed general support for the DA framework, noting in particular the value of providing community benefits that extend beyond the project site and the flexibility afforded to the applicant to pursue offices and/or life science uses. The meeting agenda, staff report, and meeting video are available for reference here.

Additional Entitlements
• The Detailed Development Plan (DDP) provides detailed specifications supporting the overall project design, including site grading, finished elevations, utilities, public improvements, building placement, circulation, landscaping, parking, and site coverage, and serves as the technical implementation document for the approved Site Plan and building design. The project plans serve as the DDP, which are included as Attachment 3, Exhibit A. • A Conditional Use Permit (CUP) is required to establish the DDP, and staff determined the required findings can be made because the project is compatible with surrounding commercial and utility uses, is served by existing infrastructure, and will not adversely impact surrounding properties due to mitigation measures, conditions of approval, and Development Agreement requirements as supported by the analysis in Attachment 3, Exhibit B.
• Design Review is required for new buildings. The project is consistent with design standards related to building scale, massing, materials, screening, signage, and landscaping. The building layout responds to site constraints such as PG&E easements and public access requirements, while providing frontages along Shoreway Road and Sem Lane. The architectural design incorporates complementary 166

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1301 Shoreway Road Development Project
materials, articulated massing, screening elements, and native landscaping that supports the creek corridor setting.
• The project requires a Grading Plan and Permit because it includes approximately 8,000 cubic yards of net fill to raise the site up two feet above the FEMA base flood elevation, consistent with City flood protection standards, with final grading details to be approved prior to building permit issuance.
• A Tree Removal Permit is required because the project includes removal of 157 trees, including 53 protected trees, and planting with 166 trees, the majority of which are California native species.

Transportation Impact Analysis and Transportation Demand Management The developer prepared a Traffic Impact Analysis (TIA) and Transportation Demand Management Plan (TDM). The City reviewed the TIA and TDM and determined its conclusions related to traffic impacts and vehicle miles traveled (VMT) reduction meet the City’s standards. The TDM identifies measures that would reduce VMT for employee trips to reduce potential impacts. Examples of measures included are:
• Short-term and long-term bicycle parking
• Preferential parking for carpool/vanpool spaces
• Telecommuting and flexible work schedules
• Participation in a Transportation Management Association, if one is formed in the area Additional information is provided in the above linked TDM Plan. Overall, the measures would reduce the project’s VMT by 15% meeting the City’s and the San Mateo County City and County Association of Governments’ (C/CAG) VMT reduction goals.

Environmental Review
The City has undertaken an environmental review of the project as required by the California Environmental Quality Act (CEQA). The potential for the project to result in environmental impacts was assessed in an Environmental Impact Report (EIR) addressing all environmental topics under CEQA.

Impact Analysis
The Draft EIR identifies several potentially significant environmental effects associated with Project implementation; however, all potentially significant impacts were determined to be reduced to less than significant with implementation of mitigation measures identified in the Mitigation Monitoring and Reporting Program (MMRP) and standard conditions of approval. Attachment 4 includes a summary of the environmental impact analysis. A complete analysis is provided in the project’s Draft EIR.

The Draft EIR was made available for a 45-day public review and comment period from October 8, 2024 through November 22, 2024. Notice of the availability of the Draft EIR was circulated to State and local agencies as required by CEQA Guidelines, as well as property owners and occupants within 300 feet of the site.

Final Environmental Impact Report
The City prepared a Final EIR which includes responses to all comments received. The Final EIR is attached as Exhibit B to Attachment 1 and is linked here. The Final EIR incorporates the MMRP which identifies potential impacts the mitigations required to reduce impacts to a less than significant level. The 167

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1301 Shoreway Road Development Project
City has also prepared Findings of Fact (Attachment 1, Exhibit A) which the City is required to make prior to certifying an EIR complies with CEQA and that the City has considered the results of the analysis it in its evaluation of the project.

Conclusion
The requested approvals require the City Council to make specific findings in support of the project.

Attachments 1, 2, and 3 contain the required findings associated with each of the proposed approvals.

Staff recommends that the City Council conduct a public hearing, receive public comment, consider the Planning Commission’s recommendations, and review all materials contained in the staff report and accompanying attachments. Following deliberation, staff recommends that the Council introduce the Ordinance included as Attachment 2.

The Resolution certifying the Environmental Impact Report (EIR) and the Resolution approving the associated entitlements are anticipated to be considered for adoption at a subsequent City Council meeting in conjunction with the second reading of the Ordinance.

Alternatives

1. Continue the item for more discussion.

2. Refer the item back to staff for further evaluation.

Attachments

1. Resolution Certifying the Environmental Impact Report and adopting the Mitigation Monitoring and Reporting Plan and Findings of Fact.
• Exhibit A – Findings of Fact
• Exhibit B – Final Environmental Impact Report and Mitigation Monitoring and Reporting Program

2. Ordinance Rezoning 1301 Shoreway Road from Regional Commercial (RC) to Planned Unit Development (PD) and related Zoning Map Amendment, approve the Conceptual Development Plan, and approve the Development Agreement
• Exhibit A – Belmont Zoning Map Amendment
• Exhibit B – Conceptual Development Plan
• Exhibit C – Development Agreement
• Exhibit D – Findings and General Plan Consistency

3. Resolution approving the Design Review, Detailed Development Plan, Conditional use Permit, Grading Plan and Permit, and Tree Removal Permit
• Exhibit A – Detailed Development Plan (Project Plans) • Exhibit B – Findings
• Exhibit C – Conditions of Approval

4. Environmental Impact Analysis Table
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5. Planning Commission Resolution 2026-02 recommending the City Council certify the Environmental Impact Report and adopt the Mitigation Monitoring and Reporting Plan and Findings of Fact (Without Exhibits)

6. Planning Commission Resolution 2026-03 recommending the City Council adopt the Ordinance Rezoning 1301 Shoreway Road from Regional Commercial (RC) to Planned Unit Development (PD) and related Zoning Map Amendment, and approve the Conceptual Development Plan (Without Exhibits)

7. Planning Commission Resolution 2026-04 recommending the City Council approve the Design Review, Detailed Development Plan, Conditional use Permit, Grading Plan and Permit, and Tree Removal Permit (Without Exhibits)
Links
• January 20, 2026 – Planning Commission Hearing Staff Report • Transportation Impact Analysis, including Transportation Demand Management Plan • Draft Environmental Impact Report (EIR)
Additional project related documents can be located on the City’s pages for development projects under “1301 Shoreway Project: www.belmont.gov/developmentprojects Fiscal Impact

☐
No Fiscal Impact

☒
Funding Source Confirmed:

There is no direct fiscal impact to this entitlement. Applicant and development related fees and corresponding City
expenditures to process the project are accounted for in the Development Services Fund, General Plan Maintenance Fee Fund, and various impact fee funds. Future operation of the office and/or life science project will generate City service demands but also revenue from property taxes, as well as through community benefit contributions.

Source: Purpose: Public Outreach:

Staff Council Vision/Priority Posting of Agenda
** Public notice mailed to all property owners within 300’ of the project site 169
RESOLUTION NO. 2026____

RESOLUTION OF THE CITY COUNCIL TO ADOPT THE CEQA FINDINGS OF FACT

AND CERTIFY THE FINAL ENVIRONMENTAL IMPACT REPORT AND ADOPT THE MITIGATION MONITORING AND REPORTING PROGRAM FOR THE 1301 SHOREWAY PROJECT (APPL. NO. PA2022-0024)
WHEREAS, Four Corners Properties submitted an application to the City of Belmont for the construction of two office and/or life science buildings and an above ground parking garage (“Project”) at 1301 Shoreway Road in Belmont (Assessor Parcel Number: 040-371- 110); and,
WHEREAS, on June 19, 2024, the City sent a Notice of Preparation of an Environmental Impact Report (“EIR”) for the Project to the State Clearinghouse and responsible agencies, trustee agencies, and interested parties, under California Code of Regulations Title 14 (“14 CCR”), Section 15082 and Public Resources Code (“PRC”) Section 21080.4, to review and provide comment on the scope of the EIR with a 37 day comment period ending on July 26, 2024; and,
WHEREAS, the City received eight (8) comment letters from interested parties, State, regional, and local public agencies during the public review period; and, WHEREAS, the City completed the Draft EIR and filed a Notice of Completion with the State Clearinghouse (identified by SCH#2024060880) in accordance with 14 CCR Section 15087 for a 45-day public review period commencing on October 8, 2024, and ending on November 22, 2024, in accordance with PRC Section 21161 and 14 CCR Section 15085; and, WHEREAS, the City prepared a Notice of the Availability of the Draft EIR for public review and comment in accordance with PRC Section 21092(b) and 14 CCR Section 15087(c), and on October 8, 2024, provided the Notice to parties who had requested it as required by PRC Section 21092(b)(3) and 14 CCR Section 15087(a), filed the notice with the County of San Mateo Recorder’s Office as required by PRC Section 21092.3 and 14 CCR Section 15087(d), mailed notice to property owners within a 300 foot radius of the site, and posted the Notice at the site, in accordance with PRC Section 21092(b)(3) and 14 CCR Section 15087(a); and,
WHEREAS, on October 8, 2024, the City made the Draft EIR available for public inspection at City Hall and at the Belmont Public Library, and posted a copy on the City’s website in accordance with 14 CCR Sections 15087(g) and 15201; and, 170
Resolution – Final Environmental Impact Report
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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WHEREAS, for at least 45 days following publication, posting and direct mailing of the Notice of Availability, the public was given an opportunity to comment, in writing, on environmental issues related to the Project; and,
WHEREAS, the Planning Commission held a public meeting for the Project on November 4, 2024, at which meeting the Commission reviewed and considered the Draft EIR, received oral and written comments from the public, and gave input to staff; and, WHEREAS, the public was given a meaningful opportunity to comment on the substantial adverse environmental effects of the Project and the feasible means to mitigate or avoid such effects, and the City received a total of seven comment letters on the Draft EIR; and,
WHEREAS, the Final EIR dated January 2026, includes: (1) the comments and recommendations received on the Draft EIR; (2) the list of persons, organizations, and public agencies that commented on the Draft EIR; (3) the City’s responses to the significant environmental points raised by the comments submitted during the review consultation process; and (4) revisions to the Draft EIR, consistent with PRC Section 21092.5(a) and 14 CCR Sections 15088, 15089, and 15132; and,
WHEREAS, the City has duly mailed written responses to comments to all public agencies that commented on the Draft EIR as required by PRC Section 21092.5, and sent courtesy copies of the responses to members of the public that commented; and WHEREAS, the EIR consists of the Draft EIR and the Final EIR; and WHEREAS, at a regular meeting conducted on January 20, 2026, the Planning Commission held a duly noticed public hearing at which hearing the Commission considered the Project, received public testimony and evidence, and received a staff report and presentation on the Final EIR and the record of proceeding for the Final EIR; and WHEREAS, on January 20, 2026, the Planning Commission adopted Resolution No. 2026-_____ recommending that the City Council certify the Final EIR and adopt the CEQA Findings of Fact and adopt the Mitigation Monitoring and Reporting Program (“MMRP”) for the 1301 Shoreway Project.

WHEREAS, on February 24, 2026, the City Council of the City of Belmont (“City”), following notification in the prescribed manner, conducted a public hearing, at which hearing the Council considered public testimony and a staff report on the aforementioned EIR Findings of Fact, Final EIR, and MMRP; and
NOW, THEREFORE, the City Council of the City of Belmont resolves:
171
Resolution – Final Environmental Impact Report
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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1. The City Council, having independently heard, considered, and weighed all the evidence in the record, finds that the above recitals are accurate and constitute findings in this matter and, together with the staff report and the application materials, including without limitation the Final EIR, Project plans, and all other documents, reports, studies, memoranda, maps, oral and written testimony, and materials in the City’s file for the applications and the Project, and all adopted City planning documents relating to the Project and the property including the City’s General Plan, Municipal Code, Zoning Ordinance, and other applicable City laws and regulations, and all associated approved and certified environmental documents, have together served as an adequate and appropriate evidentiary basis for the findings and actions set forth in this Resolution and are hereby incorporated by reference.

2. CEQA. The City Council, based on its independent judgment and analysis, certifies the Final EIR and adopts the MMRP, both of which are on file in the Office of the City Clerk of the City of Belmont, and incorporated herein by this reference, based on the following findings:
a. The City of Belmont is the lead agency under CEQA for preparing the EIR and is the entity with final decision-making authority with regard to approval of the proposed Project.
b. The Final EIR has been completed in compliance with CEQA (Public Resources Code Section 21000 et seq.) and the CEQA Guidelines (Title 14, Section 15000 et seq., of the California Code of Regulations) and the applicable provisions of the Belmont Municipal Code.
c. The Final EIR was reviewed and considered by the Planning Commission prior to the City Council’s rendering of any decision regarding the approval of the Project entitlements.
d. The Final EIR reflects the City’s independent judgment and analysis and has been found by the City to be adequate to support the City’s consideration of the Project entitlements.
e. The information added in the Final EIR does not constitute new significant information requiring recirculation.
f. Pursuant to Section 15091 of the CEQA Guidelines, the City’s actions with respect to the Project shall be based upon and subject to the findings, conclusions, mitigation measures and statements set forth in the Findings of Fact required by the California 172
Resolution – Final Environmental Impact Report
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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Environmental Quality Act dated __________, 2026 and attached hereto as Exhibit A and incorporated herein by reference. g. Pursuant to Section 15091 of the CEQA Guidelines, any subsequent actions or approvals to implement the Project shall be based upon and subject to the findings, conclusions, mitigation measures and statements set forth in the Findings of Fact required by the California Environmental Quality Act dated ___________, 2026 and attached hereto as Exhibit A.

The City Council, based on its independent judgment and analysis and pursuant to Section 15091 of the CEQA Guidelines, adopts the CEQA Findings of Fact attached hereto and incorporated herein as Exhibit A. Having fully reviewed, considered, and evaluated, pursuant to Section 15092 of the CEQA Guidelines, all of the testimony and evidence submitted in this matter and based on its independent judgment and analysis, the City Council certifiesthe Final EIR and adoptsthe MMRP (collectively included as Exhibit B), both of which are on file in the Office of the City Clerk of the City of Belmont and incorporated herein by this reference. * * * * * * * * * * * * *
ADOPTED __________, 2026 by the City of Belmont City Council by the following vote:

Ayes:

Noes:

Absent:

Abstain:

ATTEST
City Clerk Mayor
APPROVED AS TO FORM:
173
Resolution – Final Environmental Impact Report
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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City Attorney
174
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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EXHIBIT A
TO RESOLUTION 2026-__________

CITY OF BELMONT

FINDINGS OF FACT
FOR THE:
1301 SHOREWAY PROJECT

PURSUANT TO THE CALIFORNIA ENVIRONEMNTAL QUALITY ACT
1 INTRODUCTION
The City of Belmont (City), as lead agency under the California Environmental Quality Act Public Resources Code Section 21000, et seq. (CEQA), prepared an Environmental Impact Report (State Clearinghouse No. 2016082075, EIR) for the 1301 Shoreway Project (Project). The EIR is a project-level EIR prepared pursuant to CEQA Guidelines Section 15168 and consists of the Draft Environmental Impact Report released on October 8, 2024 (Draft EIR), and the Final Environmental Impact Report released on January 8, 2026 (Final EIR). The EIR addresses the potential environmental effects associated with the Project.

A public agency may not approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects, unless the public agency makes one or more written findings for each of those significant effects. Each finding must be accompanied by a brief explanation of the rationale for each finding (CEQA Guidelines Section 15091).

1.1 Project Description
The Project is a proposal for an office and life science/research campus and associated parking structure located on a 6.91-acre Project site at 1301 Shoreway Road within the city of Belmont. The site is located on one parcel (Accessor Parcel Number [APN] 040-371-110) and bounded by Shoreway Road to the west, Sem Lane to the north, Belmont Creek and Redwood City to the east, and a PG&E electrical substation to the south. The Project site is currently developed with a 148,919 square foot multi-tenant medical office building and associated surface parking and landscaping. The proposed development includes 542,035 square feet of employment uses (e.g., office and/or life science space), a 442,690- square-foot parking garage, and landscape improvements including a central courtyard.

The proposed Project would involve demolition of the existing 148,919-square-foot medical office building and surface parking lot, tree removal and replanting or replacement, and the development of a new complex consisting of two commercial office and/or life science laboratory buildings. Building 1 would be located on the western portion of the Project site adjacent to Shoreway Road and Building 2 would be on the northeastern portion of the Project site along Sem Lane. Buildings 1 and 2 are proposed to be 8 and 7 stories tall, respectively. The Project also involves the removal of 157 existing trees and planting and/or transplanting of 147 new trees. While no tenants have been identified, the applicant has 175
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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indicated that the life science use could potentially be occupied with laboratories with a biosafety level (BSL) of up to BSL-3. The southeast portion of the property would be developed with a 9-level parking garage to serve both buildings, with a total of 1,533 spaces. Ninety-three additional spaces are provided on-site at grade. The total number of spaces provided is 1,626The site would also include a central plaza as well as other amenities such as landscaped areas and sports courts.

The Project site has a General Plan land use designation of Regional Commercial (COM-R) and corresponding zoning of Regional Commercial (RC). The Project involves a rezoning from the current RC designation to a Planned Unit Development (PD) zoning designation with an associated Conceptual Development Plan and Detailed Development Plan (CDP & DDP) to allow for life science/laboratory and research uses along with increased building height. The PD District is designed to accommodate various types of development, such as professional and administrative areas, commercial service centers, industrial parks, and other uses or a combination of uses, to allow flexibility of design, in accordance with the objectives and spirt of the General Plan.

The Project is proposed to be constructed as a single action/single phase, but with primary structures constructed in sequence to allow planned construction staging and flow of materials and equipment. The general sequence of activity would involve site clearing and demolition, grading and excavation, utility relocation, foundations, building erection, and final finishes. Equipment and materials would be staged and moved as necessary during construction. Construction activities are anticipated to last approximately 18 to 20 months. The Final EIR identified several potentially significant environmental effects associated with Project implementation; however, all potentially significant impacts were determined to be reduced to less than significant with implementation of mitigation measures.

1.2 Purpose of the Findings
The purpose of the Findings of Fact (Findings) that follow is to satisfy CEQA's requirements as set forth Public Resources Code Section 21000, et seq., and Sections 15091, 15092, 15093 and 15097 of the CEQA Guidelines associated with approval of the Project. The Findings set forth below are presented for consideration and adoption by the City Council as the City’s independent findings under the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et seq.) and the CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.).

The Findings provide the written explanation, evidence, reasoning, and conclusions of the City regarding the Project’s environmental impacts, mitigation measures, and alternatives, which in the City’s judgement, justify approval of the 1301 Shoreway Project. 2 PROJECT OBJECTIVES
The applicant is proposing a an office and/or life science campus and an associated parking structure at 1301 Shoreway Road, consistent with allowable uses for the property under the 2035 General Plan. The Project would create life science/laboratory research space and supporting office that would generate economic and jobs growth within the city. The Project, or alternatives to the Project, must meet all or most of the following stated applicant and City objectives:

Applicant Objectives:
176
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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1. Create an integrated office and/or life science campus in an underutilized area of Belmont with a cohesive courtyard and with sufficient parking.

2. Build a project in a highly visible and accessible corridor to increase employment opportunities in the City of Belmont.

3. Create additional green space.

4. Provide Transportation Demand Management measures to reduce and mitigate vehicle miles traveled generated by the project.

5. Achieve architectural compatibility with surrounding vicinity through well-articulated buildings.

6. Address flood elevation requirements.

7. Improve site aesthetics through enhanced landscaping and amenities.

8. Provide access to and amenities on lands within Bay Conservation and Development Conservation (BCDC) jurisdiction consistent with BCDC guidelines.

9. Deliver a sustainable and energy efficient project to reduce carbon load impact.

10. Improve street and pedestrian safety as well as vehicular, pedestrian and bicycle access through design efficiencies.
3 RECORD OF PROCEEDINGS AND CUSTODIAN OF RECORD
Pursuant to CEQA Guidelines Section 15367, the City is the Lead Agency for the Project. Accordingly, the City has taken the following actions in relation to the EIR to satisfy CEQA:
• The City sent the Notice of Preparation (NOP) of the EIR to the State Clearinghouse and to state, local, and regional agencies on June 19, 2024. The City accepted written comments on the scope of the EIR until July 26, 2024, and concerns raised in response to the NOP were considered during preparation of the Draft EIR. The written comments that the City received in response to the NOP are included as Appendix X of the Draft EIR.
• On October 8, 2024, the City published a Notice of Availability (NOA) for the Draft EIR, and the Draft EIR was concurrently submitted to the Office of Planning and Research State Clearinghouse (the State Clearinghouse) and circulated for public review and comment as well as to solicit comments from agencies and individuals on the adequacy and accuracy of the Draft EIR. The City distributed copies of the Draft EIR to state agencies, local governments, elected officials, groups, and interested parties on the City's mailing list. The Draft EIR was made available through the following website maintained by the City:
o https://www.belmont.gov/home/showpublisheddocument/24007/638639803042670000 • The Draft EIR was also made available for public review in printed form at the public counter of the Community Development Department-Permit Center at Belmont City Hall and at the Belmont Public Library throughout the public comment period.
• The Draft EIR's public review period encompassed 45 days between October 8, 2024 and November 22, 2024.
• On January 8,2026, the City released the Final EIR. All comments received on the Draft EIR during the public comment period were responded to and included in the Final EIR. Collectively the Final EIR and the Draft EIR as amended by the Final EIR constitute the EIR for the Project. 177
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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• On January 20, 2026, the Planning Commission conducted a duly and properly noticed public hearing on certain components of the Project. The Planning Commission recommended that the City Council certify the EIR. The Planning Commission also recommended that the City Council approve the proposed 1301 Shoreway Project.
• On __________, 2026 the City Council certified the EIR following a duly and properly noticed public hearing and adopted the Mitigation Monitoring and Reporting Program (MMRP) and the Findings and the City Council approved the Project.

For purposes of CEQA and the analysis set forth in these Findings, the record of proceedings (the "Administrative Record") consists of the following documents and testimony, and at a minimum:
• The NOP, comments received on the NOP, the NOA, and all other public notices issued by the City in relation to the Project or the EIR;
• The EIR, including the Final EIR issued on January 8, 2026 and the Draft EIR as amended by the Final EIR, including all technical materials cited in the document; • The MMRP and all appendices to the Draft and Final EIR; • All non-draft and non-confidential reports and memoranda prepared by the City and its consultants in relation to the Project and the EIR;
• Minutes of the discussions regarding the Project and/or Project components at public hearings or scoping meetings held by the Planning Commission and the City Council; • Staff reports associated with Planning Commission and City Council hearings on the Project or the EIR;
• All of the comments and staff responses entered into the record orally and in writing between, as well as accompanying technical memoranda or evidence entered into the record; • Matters of common knowledge to the City Council which they consider, such as the City's existing General Plan, any other applicable specific plans or other similar plans, and the City's Municipal Code; and,
• Any other category of material identified in Public Resources Code Section 21167.6 prepared in connection with Project or the EIR.

The Community Development Department is designated as the custodian of the documents and record of proceedings on which this decision is based. The documents and materials that constitute the administrative record are available for review at the City of Belmont Community Development Department, One Twin Pines Lane, Suite 310, Belmont, CA 94002 and the telephone number is (650) 595-7417.
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Exhibit A – Findings of Fact
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4 FINDINGS ARE DETERMINATIVE
The City Council certifies that the EIR has been completed in compliance with CEQA and that it was presented to, and reviewed and considered by, the City Council prior to acting on the Project. In so certifying, the City Council recognizes that there may be differences in and among the different sources of information and opinions offered in the documents and testimony that make up the EIR and the Administrative Record; that experts disagree; and that the City Council must base its decision and these Findings on the substantial evidence in the record that it finds most compelling. Therefore, by these Findings, the City Council ratifies, clarifies, and/or makes insignificant modifications to the EIR and resolves that these Findings shall control and are determinative of the significant impacts of the Project.

The mitigation measures proposed in the EIR and further described in Section 5 of these Findings are adopted in these Findings, substantially in the form proposed in the EIR, with such clarifications and nonsubstantive modifications as the City Council has deemed appropriate to implement the mitigation measures, if any. Further, the mitigation measures adopted in these Findings are expressly incorporated into the Project.

The analysis and determinations in these Findings are to be considered as an integrated whole and, whether or not any subdivision of these Findings fails to cross-reference or incorporate by reference any other subdivision of these Findings, that any finding or determination required or permitted to be made shall be deemed made if it appears in any portion of this document. All of the text included in this document constitutes findings and determinations, whether or not any particular caption sentence or clause includes a statement to that effect.

Each finding in these Findings is based on the entire record. The omission of any relevant fact from the summary discussions below is not an indication that a particular finding is not based in part on the omitted fact.

Many of the mitigation measures imposed or adopted pursuant to these Findings to mitigate the environmental impacts identified in the Administrative Record may have the effect of mitigating multiple impacts (e.g., conditions imposed primarily to mitigate traffic impacts may also secondarily mitigate air quality impacts, etc.). The City Council has not attempted to exhaustively cross-reference all potential impacts mitigated by the imposition of a particular mitigation measure; however, such failure to crossreference shall not be construed as a limitation on the potential scope or effect of any such mitigation measure.
5 IMPACTS, MITIGATION MEASURES, AND FINDINGS
In conformance with CEQA Guidelines Section 15091, this section of the Findings lists each significant environmental effect of the Project identified in the EIR; describes those mitigation measures recommended in the EIR; and, as required by Section 15091(a), finds that either: (i) the adopted mitigation measures have substantially lessened the significant effect; (ii) the adopted mitigation measures, though implemented, do not substantially lessen the significant effect; (iii) the mitigation measures cannot be adopted and implemented because they are the responsibility of another public agency; or (iv) that specific considerations make mitigation measures infeasible. All feasible mitigation measures referenced below have been incorporated into the MMRP, further described in Section 11 of 179
Exhibit A – Findings of Fact
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these Findings. Any future projects approved or constructed pursuant to the Project will incorporate all conditions contained in the MMRP.

5.1 Issues With No Impact or Less Than Significant Impacts The Initial Study/Notice of Preparation determined that the following environmental categories do not have the potential to be significantly impacted by the proposed 1301 Shoreway Project. Environmental categories under which there would be no impacts or less than significant impacts include the following:
• Energy
• Greenhouse Gas Emissions
• Hydrology and Water Quality
• Land Use, Population, and Housing
• Public Services and Recreation
All feasible mitigation measures listed below have been incorporated into the MMRP, further described in Section 11 of these Findings. Any future projects approved or constructed pursuant to the Project will incorporate all conditions contained in the MMRP.

Unless otherwise noted, all page numbers shown below refer to the Draft EIR as modified by the Final EIR.

Aesthetics
Impact AES-1: The Project would alter the visual character or quality of the site and its surroundings as seen from public viewpoints.
• Significant Environmental Effect: This impact is further described beginning on page 5-18 of the Draft EIR. The Project would degrade the visual character and quality of the site in the immediate area, including along the trail along the creek, during approximately 18-20 months of construction.
• Mitigation Measures: The following mitigation measure as discussed in the Draft EIR at pages 5-18 is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM AES-1.1 Construction Screening: To minimize and soften the visual effects of construction as seen from nearby businesses and adjacent land uses, the project proponent shall incorporate construction fencing or screening around the perimeter of the site. The screening material shall be of sufficient height to mask ground-level activities. Screening shall remain in place during site preparation and new building construction. Screening shall not be necessary during the final stages of construction when architectural coatings, detailing and landscaping are applied. • Finding: Mitigation Measure (MM) AES-1.1 requires construction fencing or screening to be installed around the perimeter of the project site to minimize and soften the visual effects of construction. The site consists of low visual quality and there are no significant visual features or 180
Exhibit A – Findings of Fact
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landmarks on or near the site. Screening of sufficient height to mask ground-level construction activities would effectively reduce the visibility of the project during construction by trail users, adjacent hotels, businesses, and mitigate impacts to a less than significant level with mitigation.

Impact AES-3: The Project would introduce new sources of light and glare to the Project site and Project area.
• Significant Environmental Effect: This impact is further described beginning on page 5-28 of the Draft EIR. Due to increases in building height, the project would create new sources of glint or glare from windows and reflective surfaces, which could cause bird strikes and affect neighboring properties and Highway 101 at certain times of the day. • Mitigation Measures: The following mitigation measure as discussed in the Draft EIR at pages 5-28 and 5-29 is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM AES-3.1 Light/Glare Reduction and Design: Prior to the issuance of building permits, final improvement, lighting and architectural plans shall clearly demonstrate the light glare reducing features and finishes of the project. Lighting and finishes shall be selected to reduce reflective glare, bird strike, and light spill to neighboring properties and habitat areas.
• Finding: MM AES-3.1 requires that lighting and architectural plans clearly demonstrate light and glare reducing features and finishes of the project to reduce reflective glare, bird strike, and light spill into neighboring properties and habitat areas. Implementation of MM AES-3.1 would reduce lighting impacts to a less than significant level with mitigation.

Air Quality
Impact AQ-2: The Project could result in a cumulatively considerable net increase of a criteria pollutant for which the Project region is in non-attainment under an applicable federal or State ambient air quality standard.
• Significant Environmental Effect: This impact is further described on pages 6-23 through 6-25 of the Draft EIR. The project would temporarily generate construction emissions through the use of heavy equipment, construction worker vehicle trips, on-road truck trips, paving, and the use of architectural coatings.
• Mitigation Measures: The following are mitigation measures included in the City’s General Plan EIR, discussed in the Draft EIR on page 6-19, and are hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM AQ-1: Require Tier 4 Engines on Construction Equipment: All applicants proposing development of projects within Belmont shall require their contractors, as a condition of contract, to further reduce construction-related exhaust emissions by ensuring that all off-road equipment greater than 50 horsepower (hp) and operating for more than 20 total hours over the entire duration of construction activities shall operate on an EPA-approved Tier 4 or newer engine. 181
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Exemptions can be made for specialized equipment where Tier 4 engines are not commercially available within 200 miles of the project site. The construction contract must identify these pieces of equipment, document their unavailability, and ensure that they operate on no less than an EPA approved Tier 3 engine. ARB regulations will result in the percentage of Tier 4 engines increasing over the next several years.

MM AQ-3: Require Low-VOC Coatings During Construction: All applicants proposing development of projects within Belmont shall require their contractors, as a condition of contract, to reduce construction-related fugitive ROG emissions by ensuring that low-VOC coatings that have a VOC content of 10 grams/liter (g/L) or less are used during construction. The project applicant will submit evidence of the use of low-VOC coatings to BAAQMD prior to the start of construction.

MM AQ-4: Require Fugitive Dust Best Management Practices: All applicants proposing development of projects within Belmont shall require their contractors, as a condition of contract, to reduce construction-related fugitive dust by implementing BAAQMD’s basic control measures at all construction and staging areas. The following measures are based on BAAQMD’s current CEQA guidelines:
o All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) will be watered two times per day. o All haul trucks transporting soil, sand, or other loose material offsite will be covered. o All visible mud or dirt track-out onto adjacent public roads will be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
o All vehicle speeds on unpaved roads, driveways, or driving surfaces shall be limited to 15 mph.
o All roadways, driveways, and sidewalks to be paved will be completed as soon as possible. Building pads will be laid as soon as possible after grading unless seeding or soil binders are used.
o Post a publicly visible sign with the telephone number and the name of the person to contact at the lead agency regarding dust complaints. This person will respond and take corrective action within 48 hours. The phone number of the District will also be visible to ensure compliance.
• Finding: MMs AQ-1, AQ-3, and AQ-4 from the City of Belmont’s General Plan EIR require management and specific methods to control fugitive dust and pollutants for all development within the city. With the incorporation of MMs AQ-1, AQ-3, and AQ-4 into the air quality modeling assumptions and implementation of the MMs, which are already required by the City’s General Plan EIR, potentially significant pollutant impacts during construction would be reduced to a less than significant impact with mitigation and no further measures would be required. 182
Exhibit A – Findings of Fact
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Biological Resources
Impact BIO-1: The Project could have a direct or indirect adverse effect on special status species. • Significant Environmental Effect: This impact is further described on pages 7-16 through 7-22 of the Draft EIR. Construction of the project has the potential to result in direct and indirect impacts to special-status avian, mammal, and fish species and associated sensitive habitats surrounding the project site, such as Belmont Creek and nearby tidal marshes. • Mitigation Measures: The following mitigation measures as discussed in the Draft EIR at pages 7-16 through 7-21 are hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM BIO-1.1 Avoidance and Preconstruction Surveys:
o Seasonal Avoidance. Tree removal, demolition, and the start of construction activities shall be scheduled to avoid the nesting season. If such activities take place outside the nesting season, all impacts on nesting birds protected under the MBTA and California Fish and Game Code will be avoided. The nesting season for most birds in San Mateo County extends from February 1 through August 31.
o Preconstruction/Pre-disturbance Surveys. If it is not possible to schedule construction activities between September 1 and January 31, then preconstruction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no nests of migratory birds will be disturbed during project implementation. These surveys shall be conducted no more than 7 days prior to the initiation of tree removal, demolition, ground disturbance, or construction activities for each construction phase. During this survey, the biologist will inspect all trees and other potential nesting habitats (e.g., trees, shrubs, buildings, and the ground) in and immediately adjacent to the impact areas for migratory bird nests. o Buffers. If an active nest is found within areas that would be disturbed by project activities, the ornithologist will determine the extent of a construction-free buffer zone to be established around the nest (typically 300 ft for raptors and 100 ft for other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code will be disturbed during project implementation.
o Inhibition of Nesting. If construction activities will not be initiated until after the start of the nesting season, all potential nesting substrates (e.g., bushes, trees, grasses, and other vegetation) that are scheduled to be removed by the project may be removed prior to the start of the nesting season (e.g., prior to February 1). This will preclude the initiation of nests in this vegetation and prevent the potential delay of the project due to the presence of active nests in these substrates.

MM BIO-1.2 Project Construction Precautionary Measures
o Worker Environmental Awareness Program. Before any construction activities begin, a qualified biologist shall conduct a training session for all construction personnel. At a 183
Exhibit A – Findings of Fact
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minimum, the training will include descriptions of the salt marsh harvest mouse and salt marsh wandering shrew, their habitats, the laws protecting them, the general measures that are being implemented to conserve these species as they relate to the project, and the boundaries within which the project may be accomplished. o Exclusion Barrier. Prior to the start of construction activities along the eastern edge of the project site, a barrier will be installed at the outer limits of the work area on the east side of the project site to exclude salt marsh harvest mice and salt marsh wandering shrews from the project site. This barrier will consist of a 3-ft tall, tight cloth, smooth plastic, or sheet-metal (or similar material) fence toed into the soil at least 3 inches deep and supported with stakes placed on the inside of the barrier. Following the installation of the barrier, designated construction personnel will check its integrity each morning that construction activities occur and will initiate repairs immediately as needed. o Environmentally Sensitive Area Fencing. Prior to the start of construction activities along the eastern edge of the project site, the project limits on the east side of the site will be clearly demarcated with highly visible Environmentally Sensitive Area fencing to avoid inadvertent disturbance of any habitat outside of the designated construction area during construction activities. This fencing may be combined with the exclusion barrier but must not be outside that barrier.
o Immediate Work Stoppage. If a salt marsh harvest mouse, salt marsh wandering shrew, or an animal that could be one of these species is observed on the project site during project activities, all work that could result in the injury or death of the animal will stop immediately and a qualified biologist will be immediately notified. The animal will be allowed to leave the area on its own and shall not be handled except by a qualified biologist authorized to do so.

MM BIO-1.3 Water Quality: During construction, the contractor shall employ the following measures to treat and minimize runoff from the Project site. o All relevant erosion control, sediment control, source control, treatment control, material management, and stormwater management measures consistent with the latest edition of the California Stormwater Quality Association “Stormwater Best Management Practices Handbook,” available at www.capmphandbooks.com, will be implemented. o Spill prevention kits shall always be in close proximity when using hazardous materials (e.g., crew trucks and other logical locations).
o If any fueling of equipment needs to occur in areas directly draining to the wetlands along Belmont Creek, containment shall be provided in such a manner that any accidental spill of fuel shall not be able to enter the water or contaminate sediments that may come in contact with water.
o A hazardous materials management/fuel spill containment plan will be developed and implemented by the construction contractor and given to all contractors working on the 184
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project, with at least one copy of the plan located on the site at all times. The purpose of the plan is to provide construction managers, environmental compliance monitors, and regulatory agencies with a detailed description of hazardous materials management, spill prevention, and spill response/cleanup measures associated with the construction of the project elements. The primary objective of the plan is to prevent a spill of hazardous materials. Elements of the plan will include, but are not limited to the following:
▪ A discussion of hazardous materials management, including delineation of hazardous material and hazardous waste storage area, access and egress routes, waterways, emergency assembly areas, and temporary hazardous waste storage areas;
▪ Materials Safety Data Sheets for all chemicals used and stored on site; ▪ An inventory list of emergency equipment;
▪ Spill control and countermeasures including employee spill prevention/response training;
▪ Notification and documentation procedures; and
▪ A monthly reporting plan.
o Vehicles will be checked daily for oil or fuel leaks and will be washed only at an approved area. No washing of vehicles will occur within areas directly draining to the wetlands along Belmont Creek.
o Within 100 ft of tidal wetlands along Belmont Creek, the work site, areas adjacent to the site, and access areas will be maintained in an orderly condition, free and clear from debris and discarded materials. Personnel will not sweep, grade, or flush surplus materials, rubbish, debris, or dust onto adjacent areas or wetlands or waterways. Upon completion of work, all building materials, debris, unused materials, concrete forms, and other construction-related materials will be removed from the project site. o Stockpiled materials in areas draining to the tidal wetlands along Belmont Creek will be covered by plastic sheeting, tarps, or similar material that can be secured during wind and rain. A sediment fence or berm will be installed around stockpiled dredged material to prevent runoff from transporting sediment into sensitive habitats (such as wetlands and open waters).
o Water conservation methods will ensure that water used in the project site does not create surface flows capable of carrying pollutants to the nearby slough channel. All personnel, including sub-contractors, will be instructed on the practical methods of preventing leaks or over-use of watering, and will be required to adhere to the practices in the detail sheets provided.
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o Silt fencing will be erected along the limits of disturbance between the project site and wetlands along Belmont Creek during construction activities that could potentially result in siltation of wetlands and open waters of Belmont Creek.

MM BIO-1.4 Project Lighting: The following measures shall be identified on the project’s final improvement plans and incorporated into the project design to reduce the effects of glare or increased luminance experienced by migratory birds and wildlife using Belmont Creek:
o Exterior lighting shall be minimized (e.g., by turning lights off) in accordance with recommendations from the International Dark-Sky Association (2011) from midnight until dawn, at a minimum, except as needed for safety and city code compliance. o Spillage of lighting from building interiors shall be minimized using occupancy sensors, dimmers, or other mechanisms from midnight until dawn, at a minimum, during bird migration seasons (February–May and August–November). This measure may be voluntarily implemented year-round.
• Finding: MMs BIO-1.1, BIO-1.2, BIO-1.3, and BIO-1.4 require avoidance and protection measures to reduce effects to special status species and sensitive habitat areas that may be encountered on or in the vicinity of the Project site. These measures would be effective by directly avoiding potential effects on special status species with environmental training, preconstruction surveys, the oversight of a qualified biologist, and exclusionary fencing, and reducing indirect effects to water quality and surrounding habitat areas. These measures have been made conditions of Project approval and would work together to mitigate impacts to a less than significant level with mitigation.

Impact BIO-2: The Project could have an adverse effect on sensitive natural communities, including riparian habitat.
• Significant Environmental Effect: This impact is further described on pages 7-23 through 7-25 of the Draft EIR. Construction of the Project has the potential to degrade water quality, indirectly degrading the sensitive habitats adjacent to the Project site, such as Belmont Creek and nearby tidal marshes.
• Mitigation Measures: MM BIO-1.3, as discussed in the Draft EIR at pages 7-19 and 7-20 and under Impact BIO-1 above, has been adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program.
• Finding: The Project is required to comply with the California Regional Water Quality Control Board, San Francisco Bay Region, Municipal Stormwater NPDES Permit (MRP). The MRP requires that all projects implement best management practices (BMPs) and incorporate low impact development practices into design to reduce water quality impacts and indirect impacts to sensitive tidal wetland and salt marsh communities and Belmont Creek. Compliance with the MRP stormwater requirements and implementation of MM BIO-1.3 would mitigate water quality impacts and associated impacts to sensitive communities to less than significant levels.

Impact BIO-3: The Project could have an adverse effect on protected wetlands. 186
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• Significant Environmental Effect: This impact is further described on page 7-23 of the Draft EIR. Similar to Impact BIO-2, construction of the Project has the potential to degrade water quality, indirectly degrading the wetlands adjacent to the Project site, such as Belmont Creek and nearby tidal marshes.
• Mitigation Measures: MM BIO-1.3, as discussed in the Draft EIR at pages 7-19 and 7-20 and under Impact BIO-1 above, has been adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program.
• Finding: Similar to the rationale presented above for Impact BIO-2, compliance with the MRP stormwater requirements and implementation of MM BIO-1.3 would mitigate direct and indirect wetland impacts to less than significant levels.

Impact BIO-4: The Project could interfere with the movement of native resident or migratory wildlife and/or associated nursery sites.
• Significant Environmental Effect: This impact is further described on pages 7-23 through 7-25 of the Draft EIR. Due to the proximity of marsh and aquatic habitat, in the form of Belmont Creek, and the transparency of the proposed windows for the Project building, the Project has the potential to result in bird mortality from birds’ collisions with transparent surfaces. • Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on page 7-25, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM BIO-4.1 Bird Safe Building Design: Glazing on identified bird hazards (the east and north facades of Building 1 and all facades of Building 2) will be treated with a bird-safe glazing treatment such that no more than 10% of the total façade area from 0–60 feet above grade consists of untreated glazing. Bird-friendly glazing includes, but is not limited to, opaque glass, covering the outside surface of clear glass with patterns, paned glass with fenestration, frit or etching patterns, and external screens over nonreflective glass. Highly reflective glass is not permitted. Bird-safe glazing shall have the following parameters:
o Vertical elements of the window patterns should be at least 0.25 inches wide at a maximum spacing of four inches and/or have horizontal elements at least 0.125 inches wide at a maximum spacing of two inches; OR
o Bird-safe glazing shall have a Threat Factor less than or equal to 30.

To reduce reflections of clouds and vegetation in glass and help ensure that bird-safe treatments on the lower surfaces of glass are visible below any reflections, all glazing on the buildings will have a visible reflectance of 15% or lower. These features shall be included in final improvement plans.
• Finding: MM BIO-4.1 requires bird safe building design to minimize the potential for bird strikes (bird collisions with buildings) due to the Project’s proximity to Belmont Creek and nearby tidal 187
Exhibit A – Findings of Fact
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marshes. MM BIO 4.1 requires glazing on identified bird hazards such as the east and north facades of Building 1 and all facades of Building 2. Glazing could include opaque glass, covering the outside surface of glass with patterns, paned glass with fenestration, frit or etching patterns, and external screens over nonreflective glass. Implementation of MM BIO 4.1 would reduce impacts to native and migratory birds to less than significant levels through project design changes, which have been made conditions of Project approval.

Cultural Resources
Impact CR-2: The Project has the potential to cause a substantial adverse change to unknown archaeological and cultural resources.
• Significant Environmental Effect: This impact is further described on pages 8-12 through 8-14 of the Draft EIR. Project construction activities involving ground disturbance have the potential to encounter subsurface archaeological and cultural resources on the Project site. • Mitigation Measures: The following mitigation measures, as discussed in the Draft EIR on page 8-13, are hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM CR-2.1 Cultural resource Awareness Training: Prior to any project-related ground disturbance, all construction workers shall receive training overseen by a qualified professional archaeologist who is experienced in teaching non-specialists to ensure that contractors can recognize archaeological resources in the event that any are discovered during construction. The construction staff directly overseeing excavation, or operating ground-disturbing vehicles, will be required to participate in this preconstruction training.

MM CR-2.2 Inadvertent Discovery of Archaeological Resources: If unknown precontact or historic-period archaeological materials are encountered during project activities, all work in the immediate vicinity of the find shall halt until a qualified archaeologist can evaluate the find and make recommendations. Cultural resources materials may include precontact resources such as flaked and ground stone tools and debris, shell, bone, ceramics, and fire-affected rock as well as historic resources such as glass, metal, wood, brick, or structural remnants. If the qualified archaeologist determines that the discovery represents a potentially significant cultural resource, additional investigations shall be required to mitigate adverse impacts from project implementation. These additional studies may include, but are not limited to, recordation, archaeological excavation, or significance evaluation.

The applicant shall inform its contractor(s) of the sensitivity of the project site for archaeological deposits and include the following directive in the appropriate contract documents:
“The subsurface of the construction site may contain archaeological deposits. If archaeological deposits are encountered during project subsurface construction, all ground-disturbing activities within 25 feet shall be redirected and a qualified archaeologist shall assess the situation, consult with agencies as appropriate, and make recommendations for the treatment of the discovery.

Project personnel shall not collect or move any archaeological materials. Archaeological deposits 188
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can include, but are not limited to, shellfish remains; bones, including human remains; flakes of, and tools made from, obsidian, chert, and basalt; mortars and pestles; historical trash deposits containing glass, ceramics, and metal artifacts; and structural remains, including foundations and wells.”
The City shall verify that the language has been included in the grading plans prior to issuance of a grading permit or permit for other project actions that include ground disturbing activities on the project site.
• Finding: MMs CR-2.1 and CR-2.2 provide specific direction to construction personnel and the applicant if previously unknown precontact or historic-period archaeological resources are encountered during construction. These measures would be effective because they require training to construction personnel on how to recognize archaeological resources, halting construction in the event of a discovery, establishing setbacks, avoiding resources, and contacting a qualified archaeologist to assess any discoveries prior to continuing with work consistent with State law. These measures would be applied to construction documents and enforced as conditions of Project approval to avoid and properly treat and handle archaeological resources in the event they are encountered. Implementation of mitigation measures CR-2.1 and CR-2.2 and compliance with existing codes and regulations for the treatment of these resources would reduce potential impacts to unknown archaeological and cultural impacts to a less than significant level.

Impact CR-3: The Project has the potential to cause a disturbance to human remains, including those interred outside of dedicated cemeteries.
• Significant Environmental Effect: This impact is further described on pages 8-14 and 8-15 of the Draft EIR. Project construction has the potential to inadvertently uncover human remains due to ground disturbing activities.
• Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on pages 8-14 and 8-15, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM CR-3.1 Inadvertent Discovery of Human Remains: In the event that human remains are identified during project construction, the remains will be treated in accordance with California Health and Safety Code Section 7050.5 and PRC Section 5097.98, as appropriate. In the event of the discovery or recognition of any human remains in any location other than a dedicated cemetery, Section 7050.5 of the California Health and Safety Code states that there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the remains were discovered has determined whether or not the remains are subject to the coroner’s authority. If the human remains are of Native American origin, the coroner must notify the NAHC within 24 hours of identification. The NAHC will identify a Native American MLD to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods. PRC Section 5097.98 states that the NAHC, upon notification of the discovery of Native American human remains, pursuant to California Health and Safety Code Section 7050.5, shall immediately notify those persons (i.e., the MLD) it believes to be descended from the deceased. With 189
Exhibit A – Findings of Fact
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permission of the landowner or a designated representative, the MLD may inspect the remains and any associated cultural materials and make recommendations for the treatment or disposition of the remains and associated grave goods. The MLD shall provide recommendations or preferences for treatment of the remains and associated cultural materials within 48 hours of being granted access to the site.
• Finding: MM CR-3.1 provides specific direction to construction personnel and the applicant if previously unknown human remains are encountered during construction and requires treatment of such remains in accordance with the California Health and Safety Code Section 7050.5 and Public Resources Code Section 5097.98. This measure would be effective because it requires halting excavation or further disturbance in the event of a discovery until the county coroner can determine whether the remains are subject to the coroner’s authority. State law also requires notifying the Native American Heritage Commission (NAHC) if the remains are of Native American origin. If the remains are determined to be Native American, a Most Likely Descendent must be identified to provide recommendations for proper treatment. These measures would be applied to construction documents and enforced as conditions of project approval to avoid and properly treat the discovery of human remains in the event they are encountered. Implementation of the mitigation measures and compliance with existing codes and regulations for the treatment of remains pursuant to established standards would reduce potential impacts to a less than significant level.

Geology
Impact GEO-6: The Project is located on a geologic unit or soil that could be either unstable, or that could become unstable as a result of the Project, and potentially result in on-or off-site landslide, lateral spreading, subsidence, liquefaction, collapse or expansive soils. • Significant Environmental Effect: This impact is further described on page 10-11 and 10-12 of the Draft EIR. There is a potential for lateral displacement near the proposed Building 2 on the northeastern portion of the Project site as a result of the existing underlying Bay Mud within the soil.
• Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on page 10-12, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM GEO-6.1 Final Geotechnical Evaluation: A final construction level geotechnical evaluation shall be required for the project. The project shall be required to adhere to and incorporate all standards and recommended engineering measures to mitigate for settlement concerns related to lateral spreading from compression of underlying near-surface soils layers and Bay Mud layers.

The final geotechnical evaluation will be provided to the City for review and approval prior to the issuance of building permits.
• Finding: MM GEO-6.1 requires a final construction-level geotechnical evaluation. This evaluation will ensure that all standards and recommended engineering solutions are incorporated into Project design to meet State and local building codes and mitigate for settlement concerns 190
Exhibit A – Findings of Fact
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related to lateral spreading from compression of underlying near-surface soils layers and Bay Mud. Application of this required evaluation into the design and construction process pursuant to building codes would effectively mitigate these potential risks and impacts to less than significant levels.

Impact GEO-7: The Project could directly or indirectly destroy a unique paleontological resource or site or unique geologic features during construction.
• Significant Environmental Effect: This impact is further described on pages 10-12 and 10-13 of the Draft EIR. Project construction has the potential to inadvertently uncover previously unknown or unrecorded paleontological resources due to ground disturbing activities. • Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on page 10-13, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM GEO-7.1 Inadvertent Discovery of Paleontological Resources: In the event that fossils or fossil-bearing deposits are discovered during construction activities, work shall be temporarily halted with a 25-foot radius of the discovered materials and workers should avoid altering the materials and their context until a qualified paleontologist has evaluated the situation and provided appropriate recommendations. Construction and potential impacts to the area(s) within a radius determined by the paleontologist shall not recommence until the assessment is complete.

If it is determined that the proposed development could damage unique paleontological resources, mitigation shall be implemented in accordance with Public Resources Code Section 21083.2 and Section 15126.4 of the CEQA Guidelines. Possible mitigation under Public Resources Code Section 21083.2 requires that reasonable efforts be made for resources to be preserved in place or left undisturbed. If preservation in place is not feasible, the applicant shall mitigate significant effects. Excavation as mitigation shall be limited to those parts of resources that would be damaged or destroyed by a project. Possible mitigation under CEQA emphasizes preservation-inplace measures, including planning construction avoid paleontological sites, incorporating sites into parks and other open spaces, covering sites with stable soil, and deeding the site into a permanent conservation easement. Under CEQA Guidelines, when preservation in place is not feasible, data recovery through excavation shall be conducted with a data recovery plan in place. • Finding: MM GEO-7.1 provides specific direction to construction personnel and the applicant if previously unknown fossils or fossil-bearing deposits are discovered during construction. The measure requires a work stoppage and a buffer zone around the find and an assessment of the resource by a qualified paleontologist consistent with the Public Resources Code. This measure would be effective because it is proportional to the likelihood of a paleontological find and specifies techniques to protect and/or preserve any such resource. This measure would be applied to construction documents and enforced as conditions of Project approval to avoid and properly treat and handle paleontological resources in the event they are encountered. With implementation of MM GEO-7.1 and compliance with General Plan policies, potential impacts to paleontological resources would be reduced to a less than significant level. 191
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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Hazardous Materials
Impact HAZ-1: The Project has the potential to create a hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. • Significant Environmental Effect: This impact is further described on pages 12-15 through 12- 18 of the Draft EIR. Ground disturbing activities associated with Project construction have the potential to encounter hazardous soil impacted by contamination from commercial and industrial uses at the nearby 248 and 248A Harbor Boulevard. The transport, use, generation, storage. And disposal of the materials and contaminants from the Biosafety Level (BSL) 3 laboratory proposed as part of Project operations have the potential to be hazardous. • The transport, use, and disposal of the materials and contaminants from the BSL 3 laboratory proposed as part of Project operations have the potential to be compromised and introduce a biohazard in the event of a significant earthquake, structure fire, prolonged power outage, act of sabotage, equipment failure or human error
• Mitigation Measures: The following mitigation measures, as discussed in the Draft EIR on pages 12-16 and 12-17, are hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM HAZ-1.1 Pre-Demolition Surveys and Management Plan: Prior to demolition and removal of material from the site, the project applicant shall conduct surveys and testing for asbestos containing building materials (ACBMs), lead based paints and products, mercury and polychlorinated biphenyl caulking products. If such materials are not identified, no further action is required. If these materials are identified, the applicant shall prepare and implement an Operation and Management (O&M) Plan for removal and disposal. The O&M Plan shall be prepared consistent with National Emissions Standards for Hazardous Air Pollutants (NESHAP) guidelines for the removal of potentially friable ACBMs and other materials if present. The plan shall be reviewed and approved by the City of Belmont prior to implementation. Removal and disposal work will be completed pursuant to all federal, State and local regulations by certified professionals.

MM HAZ-1.2 Imported Fill: Prior to depositing fill on the project site, all imported soil and fill material shall be tested to ensure any contaminants of concern are within DTSC and U.S.

Environmental Protection Agency Regional Screen Levels for the intended land use. To minimize the possibility of introducing contaminated soil and fill material the applicant shall document the origins of the soil or fill material and, if applicable, conduct sampling to ensure that the imported soil and fill material meets screening levels outlined in the Preliminary Endangerment Assessment (PEA) Guidance Manual.

MM HAZ-1.3 Management of Potentially Hazardous Materials: If BSL 3 certification is pursued, the life science laboratory/office buildings shall be designed and constructed as BSL 3 facilities.

For any BSL level, the project sponsor shall independently pursue and obtain all necessary federal, state and local approvals, permits, certifications and/or licenses for the design, operation, transport, use and disposal of materials used. Proof of compliance and all related management plans shall be provided to the City of Belmont prior to building occupancy. 192
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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• Finding: MMs HAZ-1.1, HAZ-1.2, and HAZ-1.3 require survey, testing, proper handing, transport, and disposal of hazardous materials to reduce effects to the public and the environment due to the occurrence and/or use of hazardous materials on the Project site. MM HAZ-1.1 requires pre-demolition surveys and the development of a management plan to survey and test for asbestos-containing building materials, lead-based paints and products, mercury, and polychlorinated biphenyl caulking products. MM HAZ-1.1 also requires the development and implementation of an Operation and Management Plan for removal and disposal of such materials if they are found onsite. This plan would be made a condition of approval on final plans and implemented during construction. MM HAZ 1.2 requires that all imported fill material be tested prior to delivery to the Project site to ensure any contaminants of concern are within DTSC and U.S. Environmental Protection Agency Regional Screening Levels for the intended land use. The MM also requires documentation of the origins of the soil or fill material and, if applicable, sampling of the material. MM HAZ-1.3 requires that if the Project applicant, pursues a BSL 3 certification, that the life science laboratory/office buildings be designed and constructed as BSL 3 facilities and independently acquire all necessary federal, State, and local approvals, permits, and certifications necessary for the design, operation, transport, use and disposal of materials used. These measures would be effective to mitigate risk of hazards to the public or the environment because they require execution of the work by certified professionals, review of all management plans by the City prior to implementation, documentation and sampling of soil or fill material prior to use onsite, and use, removal, transport, and disposal of hazardous materials in accordance with federal, State, and local regulations. With implementation of the mitigation measures, potential impacts are reduced to a less than significant level.

Impact HAZ-2: The Project could create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
• Significant Environmental Effect: This impact is further described on pages 12-18 and 12-19 of the Draft EIR. The transport, use, and disposal of the materials and contaminants from the BSL 3 laboratory proposed as part of Project operations have the potential to be compromised and introduce a biohazard in the event of a significant earthquake, structure fire, prolonged power outage, act of sabotage, equipment failure or human error. These scenarios are unlikely and federal, state, and local certifications, design standards, and permit requirements are in place to prevent or reduce the risk of such a scenario.
• Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on page 12-19, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM HAZ-2.1 Emergency Response Plan and First Responder Training. Prior to building occupancy for BSL 3 use, the project sponsor or lab operator shall prepare and submit an emergency response plan to the City of Belmont and San Mateo Consolidated Fire Department (SMC Fire) tailored to the specific lab operations, hazardous materials and class of pathogens expected to be present. Based on those specific pathogens or other hazardous substances, the project sponsor or lab operator shall also conduct specialized training and education session(s) with SMC Fire hazmat personnel and the Redwood City Fire Department regarding lab 193
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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operations. This training shall be specific to the biohazards present at the facility, strategy for response and potential need for specialized equipment and/or vaccination protocols, if warranted.

Training shall be periodic and updated as needed based on the biohazards present. • Finding: MM HAZ-2.1 requires that prior to building occupancy for BSL 3 use, the applicant or lab operator prepare an emergency response plan and submit the plan to the City of Belmont and San Mateo Consolidated Fire Department for review. This plan would be tailored to specific lab operations and the hazardous materials and class of pathogens expected to be present. As part of this measure, specialized training with San Mateo County Fire hazmat personnel and Redwood City Fire Department would be required regarding lab operations, biohazards known to be present at the facility, and specialized response protocols. MM HAZ-2.1 requirements, in combination with implementation of MM HAZ 1.3, would be effective to mitigate risk of hazards and reduce potential impacts to a less than significant level because they require preventative management and regulatory oversight associated with the use of hazardous materials and measures to minimize effects in the event of accident or upset conditions associated with a BSL 3 facility.

Noise
Impact N-1: The Project would generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.
• Significant Environmental Effect: This impact is further described on pages 15-17 through 15- 26 of the Draft EIR. The Project would temporarily generate construction noise audible to nearby sensitive receptors through the use of construction equipment. The proposed HVAC system has the potential to generate noise during Project operation. • Mitigation Measures: The following mitigation measures, as discussed in the Draft EIR on page 15-20 and 15-24, are hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM N-1.1 Construction Noise Control Plan: The applicant shall identify site-specific noise attenuation measures to be included with construction plans to reduce noise to levels below the FTA threshold of 80 dBA Leq. Prior to commencement of construction activities, the applicant shall submit the construction noise control plan to the city for review and approval. Noise attenuation measures shall be identified in the plan and implemented to reduce noise levels to the greatest extent feasible. Noise measures may include, but are not limited to, the following:
o Using smaller equipment with lower horsepower or reducing the hourly utilization rate of equipment on the site to reduce noise levels at 50 feet to the allowable level. o Locating construction equipment as far as feasible from noise-sensitive uses. o Requiring that all construction equipment powered by gasoline or diesel engines have sound control devices that are at least as effective as those originally provided by the manufacturer and that all equipment be operated and maintained to minimize noise generation.
194
Exhibit A – Findings of Fact
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o Prohibiting gasoline or diesel engines from having unmuffled exhaust systems. o Not idling inactive construction equipment for prolonged periods (i.e., more than 2 minutes).
o Constructing a solid plywood barrier around the construction site and adjacent to operational businesses, residences, or other noise-sensitive land uses. o Using temporary noise control blanket barriers.
o Monitoring the effectiveness of noise attenuation measures by taking noise measurements.
o Using “quiet” gasoline-powered compressors or electrically powered compressors and electric rather than gasoline- or diesel-powered forklifts for small lifting.

MM N-1.2 Reduce Noise From Project Mechanical Equipment: To reduce potential noise effects resulting from project heating, cooling, and ventilation equipment as well as project emergency generators at the proposed project, a supplemental noise analysis shall be prepared to estimate the actual noise levels of project-specific equipment once the equipment models and design features to attenuate noise have been selected. The analysis shall be conducted prior to the issuance of building permits and shall be prepared by persons qualified in acoustical analysis and/or engineering, demonstrating with reasonable certainty that the mechanical equipment selected for the project and the attenuation features incorporated into project design would not result in an exceedance of the applicable City noise standards of 45 dBA Leq and 65 dBA Lmax during the nighttime and 55 dBA Leq and 70 dBA Lmax during the daytime.

Options to reduce noise from heating and cooling equipment include enclosing equipment in mechanical equipment rooms, shielding equipment with mechanical screens at least as tall as the equipment, and selecting quieter equipment models.

All recommendations from the acoustical analysis necessary to ensure that noise sources meet the above standards shall be incorporated into the building design and operations. This measure should be implemented concurrently with MM AES-1.1 (Construction Screening) to provide a barrier that addresses both visual and noise effects.
• Finding: MMs N-1.1 and N-1.2 include measures to reduce construction noise and noise from mechanical equipment, respectively. MM N-1.1 provides a series of standard noise attenuation measures to reduce temporary construction noise. These measures focus on compliance with the General Plan policies and requirements of the City Code. Construction noise can be effectively addressed through construction timing, equipment maintenance, placement of equipment, and use of noise attenuation barriers or devices, and monitoring the effectiveness of noise attenuation measures by taking noise measurements. Similarly, MM N-1.2 provides options to reduce noise from Project heating, cooling, and ventilation equipment such as using equipment enclosures and shielding, and selection of quieter equipment. The quantitative noise analysis in the EIR demonstrates that MMs N-1.1 and N-1.2, along with compliance with City Code requirements, would be effective in reducing noise impacts to less than significant levels by physically 195
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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reducing noise levels and by avoiding the generation of excessive noise. These measures are enforceable as conditions of approval and included in construction documents.

Transportation
Impact TRA-1: The Project would conflict or be inconsistent with adopted Vehicle Miles Traveled policies, plans, or programs per CEQA Guidelines section 15064.3. • Significant Environmental Effect: This impact is further described on pages 17-14 through 17- 16 of the Draft EIR. During Project operation, the vehicle miles traveled (VMT) per employee would exceed the City/County Association of Governments of San Mateo County applicable VMT threshold.
• Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on pages 17-15 and 17-16, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM TRA-1 Final Transportation Demand Management Program: Prior to occupancy, the project shall prepare and implement a final transportation demand management (TDM) program to reduce the project’s VMT to below the significance threshold as noted in Table 17-1. The program includes encouraging employees to use alternative modes of transportation to singleoccupant vehicles. The City of Belmont has an adopted TDM policy requiring projects that exceed 50,000 square feet to achieve 18 TDM points. Compliance with the city’s TDM policy would reduce the project trips and the VMT by an estimated 15 percent or more, which would be more than the required 7.4 percent reduction needed if using the C/CAG VMT estimation tool and the 6.0 percent reduction needed if using the C/CAG travel demand model. The effectiveness of the TDM plan shall be reviewed annually and adjusted as necessary to maintain these trip and VMT reductions.
• Finding: MM TRA-1 requires that prior to occupancy, the Project prepare and implement a final transportation demand management (TDM) program to reduce the Project’s VMT by encouraging employees to use alternative modes of transport and complying with the City of Belmont’s TDM policy requiring projects that exceed 50,000 square feet to achieve 18 TDM points. By complying with the City’s TDM policy, Project trips would be reduced by 15 percent or more, which would be more than the 7.4 percent required reduction utilizing the C/CAG VMT estimation tool and the

6.0 percent reduction needed if using the C/CAG travel demand model. Implementation of the final TDM plan would result in less than significant VMT impacts by reducing VMT to levels below established thresholds.

Impact TRA-2: The Project could conflict with a program, plan, ordinance, or policy addressing transit facilities.
• Significant Environmental Effect: Project operation is expected to generate demand for transit and there are no existing public transit facilities within a ½-mile of the Project site. 196
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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• Mitigation Measures: The following mitigation measure, as discussed in the Draft EIR on page 17-16, is hereby adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program:

MM TRA-2 Transit Improvements: To enhance transit service and facilities consistent with City policy, the project sponsor shall coordinate with the City and Commute.org to reestablish local shuttle service such as the Redwood LIFE Caltrain shuttle stop at the project site that connects to the San Carlos Belmont Caltrain Station and Redwood Shores community. Because the feasibility, demand and location of additional shuttle stops are ultimately determined by Commute.org and the transit operator, the applicant’s responsibility is limited to supporting a shuttle stop on the property, participating in applicable employer-based funding mechanisms, identifying a shuttle stop location on the project’s final improvement plans, and promoting use of the shuttle and alternative modes of transportation through the project’s TDM program. • Finding: MM TRA-2 requires the Project sponsor to coordinate with the City and Commute.org to reestablish a local shuttle service stop at the Project site that connects to the San Carlos Belmont Caltrain Station and Redwood Shores community. The project sponsor would be responsible for supporting a shuttle stop on the property, participating in applicable employerbased funding mechanisms, identifying a shuttle stop location on the Project’s final improvement plans, and promoting use of the shuttle and alternative modes of transportation through the Project’s TDM program. Accommodating expanded transit options near the Project site would ensure consistency with the City’s circulation policy, reduce potential conflicts with programs, plans, and policies addressing transit facilities, and effectively mitigate impacts to less than significant levels.

Tribal Cultural Resources
Impact TR-2: The Project has the potential to cause a substantial adverse change in the significance of a tribal cultural resource as determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.
• Significant Environmental Effect: This impact is further described on pages 18-9 and 18-10 of the Draft EIR. Project construction activities involving ground disturbance have the potential to encounter tribal cultural resources on the Project site. • Mitigation Measures: MMs CR-2.1, CR-2.2, and CR-3.1; as discussed in the Draft EIR at pages 8-13 through 8-15 and under Impacts CR-2 and CR-3 above; have been adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program. • Finding: MMs CR-2.1, CR-2.2, and CR-3.1 would reduce impacts to archaeological resources, including resources that could be of cultural value to a tribe. As described in MM CR-2.1 and MM CR-2.2, awareness training would be implemented prior to crew members beginning work onsite and work would stop if unknown precontact or historic-period archaeological materials are encountered during Project activities. Per MM CR-3.1, if any human remains, including Native American burials, are found during construction activities, site disturbance would stop and the 197
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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NAHC would be notified. With implementation of MMs CR-2.1, MM CR-2.2, and MM CR 3.1, impacts associated with tribal cultural resources would be reduced to a less than significant level.

These measures would be applied to construction documents and enforced as conditions of Project approval to avoid and properly treat and handle archaeological, tribal, and other cultural resources in the event they are encountered. With implementation of these mitigation measures, impacts associated with tribal cultural resources would be reduced to a less than significant level.

Utilities and Service Systems
Impact UTIL-1: The Project will require construction to connect and/or upgrade service systems to service the Project.

Significant Environmental Effect: This impact is further described on pages 19-11 and 19-12 of the Draft EIR. Project construction associated with connection and/or upgrades to service systems activities has the potential to temporarily impact water quality and Project site visual character, as well as generate noise and air quality emissions from construction equipment.

Mitigation Measures: MMs AES-1.1 and N-1.1, and General Plan EIR mitigation measures AQ-1, AQ3, and AQ-4; as discussed in the Draft EIR at pages 5-18 through 15-20 and under Impacts AES-1, AQ-2, BIO-1, and N-1 above; have been adopted and shall be implemented as provided in the Mitigation and Monitoring Reporting Program.

Finding: MMs AES-1.1 and N-1.1, General Plan EIR mitigation measures AQ-1, AQ-3, and AQ-4, as well as several existing ordinances, regulations, and standards governing construction methods directly address construction-related impacts. As the construction of Project utility and service systems are directly related to and incorporated into the overall development and construction program for the Project, these MMs and existing regulations would effectively reduce or eliminate construction-related effects for the same reasons explained elsewhere in these Findings and reduce potential impacts to a less than significant level.
6 FINDINGS FOR SIGNIFICANT IMPACTS THAT CANNOT BE AVOIDED OR

REDUCED TO A LESS THAN SIGNIFICANT LEVEL (SIGNIFICANT AND

UNAVOIDABLE EFFECTS)
There are no significant impacts that cannot be avoided or reduced to a less than significant level. 7 FINDINGS FOR SIGNIFICANT CUMULATIVE EFFECTS
The Final EIR discusses the Project’s potential cumulative effects consistent with CEQA Guidelines Section 15130. This discussion considers the Project’s incremental contribution to potentially significant impacts when combined with other past, present, and/or reasonably foreseeable future projects within relevant geographic limits. The Final EIR concluded that no specific or unique cumulatively considerable impacts would be triggered by the Project, with the incorporation of mitigation measures, when combined with other cumulative development projects being implemented or considered. 198
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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8 FINDINGS REGARDING SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL

CHANGES WHICH WOULD BE CAUSED BY THE PROJECT SHOULD IT BE

IMPLEMENTED
Section 15126.2(d) of the State CEQA Guidelines requires an EIR for certain projects to discuss the significant irreversible environmental changes that would result from implementation of a proposed Project. This discussion focuses on the use of nonrenewable resources during project construction and operation and irreversible damage from environmental accidents.

8.1 Use of Non-Renewable Resources
A variety of resources, including energy, water, construction materials, and human resources would be irretrievably committed for the Project’s initial construction, infrastructure installation, and connection to existing utilities and its continued maintenance. Construction of the proposed project would require the commitment of a variety of other non-renewable or slowly renewable natural resources such as lumber and other forest products, sand and gravel, asphalt, petrochemicals, and metals. Additionally, a variety of resources would be committed to the ongoing maintenance and life of the proposed Project.

Finding: The City of Belmont finds such resource commitments insignificant for the following reasons:
• The Project is in a developed area and will not convert prime agricultural land, preclude access to mineral resources, or otherwise commit ongoing or large quantities of nonrenewable resources (through removal or nonuse).
• None of the resources required for construction are unique, rare, or in danger of being depleted by the Project.
• Use of defined water resources would not deplete or threaten existing supplies of surface or groundwater resources.
• The Project does not include components (such as a highway or roadway that provides access to a previously in accessible area) that would lead to associated secondary impacts or commit future generations to such irreversible changes.

For these reasons, the City of Belmont finds that the Project would not lead to irreversible damage from environmental accidents.

8.2 Damage from Environmental Accidents
The Project proposes a potential land use (life science laboratory up to BSL 3) which could generate hazardous materials or involve the handling of hazardous materials, substances, or waste in significant quantities that could have an impact to surrounding uses in the unlikely event of upset or accident. In addition to common hazardous materials that would be routinely handled (e.g., cleaning products, paints, pesticides, petroleum, oil, lubricants, thinners, fertilizers, solvents, aerosols, corrosives, and fuels), a BSL 3 facility could also introduce the transport, use and disposal of biomedical materials such as tissues, fluids and cultures, microbes, chemical compounds, and radiological and medical equipment. 199
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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Finding: The City of Belmont finds such damage from environmental accidents insignificant for the following reasons:
• Several federal, state and local certifications, design standards, and permit requirements are currently in place to prevent or reduce the risk of upset, accident, or disaster at or near the facilities.
• A BSL lab would be required to be designed with multiple internal containments, backup system, and incident response plans. Commercial and laboratory uses are required to comply with all applicable federal, state, and regional regulations designed to reduce the risk of hazardous material generation and usage on the site.
• To minimize potential impacts associated with the accidental release of hazardous materials (known or unknown) into the environment during construction, MMs HAZ-1.1 and HAZ-1.2 would be implemented to prevent the risk of accidental release. To further reinforce existing regulations and laboratory standards for operations, MM HAZ-1.3 is required to address BSL 3 design standards, and MM HAZ-2.1 addresses first responder coordination and training if a BSL 3 certification is pursued.

With implementation of these existing regulations and Project-specific mitigation measures, the risk of irreversible environmental damage from hazardous materials accidents during construction and operation would be reduced to a less than significant level. For these reasons, the City of Belmont finds that the Project would not lead to irreversible damage from environmental accidents. 9 FINDINGS REGARDING POTENTIAL GROWTH INDUCING EFFECTS
CEQA defines a project as growth inducing if it “could foster economic or population growth, or the construction of additional housing either directly or indirectly, in the surrounding environment”.

Similarly, under CEQA, a project would indirectly induce growth if it would remove an obstacle to additional growth and development, such as removing a constraint on a required public service. Increases in population could tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects.

Finding: The City of Belmont finds the following regarding the Project’s potential growth inducing effects:
• The 1301 Shoreway Project would not induce growth directly because it would not involve the construction of new housing.
• The Project could induce growth indirectly by constructing an office and/or life sciences campus that is more than 3.5 times the size of the existing building on site (based on square footage).

Assuming a proportional increase in employees (up to 2,500), the Project would likely result in hundreds of additional employees seeking housing opportunities in the greater Belmont/San Carlos/Redwood City area and within San Mateo County. Such growth and attraction of new employees resulting from this single Project is unlikely to have a significant impact, however, as the area is highly urban in character and there are housing opportunities in the region to absorb 200
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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this level of employment growth without causing environmental effects. It is expected that many of these employees would already be residing in the region. In addition, the Project is not of such a large size or construction duration as to create a significant influx of short-term construction labor that would require temporary housing.
• The Project’s proposed building heights and massing are similar to other nearby office, life science, and R&D projects, indicating market for similar employment-based development and intensification of existing parcels in the vicinity of the Project. A well-designed project of this size, if successfully implemented, could conceivably further stimulate the market for similar projects on other nearby properties.
• Cumulatively, these development projects could result in thousands of local jobs, creating a need for housing growth beyond the Project alone. While it is difficult to assess the potential environmental effects of such growth, it is reasonable to predict that increased demand for additional housing projects could lead to cumulative effects related to construction, GHG emissions, VMT increases, and demands on public services.

The environmental implications of land use intensification because of these projects would be evaluated on a project-specific and cumulative basis as projects are processed and evaluated under CEQA. The General Plan EIR also considered assumptions and changes in land use at a programmatic level. While the Project could result in indirect growth inducing environmental effects, such effects have been anticipated within the framework of the City’s planning efforts city-wide. 10 FINDINGS REGARDING PROJECT ALTERNATIVES
Consistent with CEQA Guidelines Section 15091 (c), the City of Belmont makes the following findings regarding the alternatives considered in the Final EIR:

10.1 Alternative A, No Project Alternative
CEQA Guidelines section 15126.6 (e) requires the No Project alternative be evaluated along with its impacts.

Finding: The No Project alternative would be environmentally superior but meets none of the stated objectives of the Project and is inconsistent with the city’s vision and economic development objectives for the area as identified in the City General Plan. The site would remain in its current state as an underutilized building and no intensification, public benefits, or improvements would be realized. For these reasons, the alternative has been rejected.

10.2 Alternative B, Development Consistent with Existing Zoning Alternative B assumes that the property would be developed to the maximum allowed under the existing RC zoning designation, which could result in a project with one or more office buildings with a FAR of

1.8 and a maximum building height of 55 feet. To reach an FAR of 1.8 with existing building heights, the design of the Project would require a much larger building footprint, reduced setbacks, and greater site coverage (45-50 percent compared to the proposed project’s 22 percent). This alternative is intended to provide lower building heights, eliminate the need for a Planned Unit Development (PD) rezoning 201
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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process and modified standards, and reduce VMT and GHG emissions as a result of the smaller scale of the development.

Finding: Alternative B would meet most of the primary Project objectives but would not achieve Objective 1 (cohesive courtyard), Objective 3 (additional green space), and Objective 5 (architectural compatibility with its surroundings. Alternative B would have some environmental benefits due to an overall reduction in size and scale. However, Alternative B would not completely avoid a significant impact, nor would it reduce any significant impact of the Project to a less than significant level.

Alternative B has the potential to increase the degree of impact in other areas such as biological resources, noise and water quality, due to the increased site coverage, location of rooftop equipment, and more limited site area for open space and water quality treatment. Alternative B would meet some of the Project’s stated objectives and represents a feasible alternative from a technological and environmental perspective; however, the economic feasibility of such an option, with a 45% reduction in leasable square footage, is questionable. For these reasons, Alternative B is not environmentally superior to the proposed Project or the other alternatives and therefore has been rejected.

10.3 Alternative C: Reduced Parking Alternative
Under Alternative C, there would be a reduction in total parking from 1,626 proposed vehicle spaces to 1,300 (20 percent reduction from the minimum office parking standard). The alternative may require adjustments to the development program to accommodate the new parking plan or a smaller parking structure. The intent of this alternative is to reduce overall vehicle miles travelled (VMT) and greenhouse gas emissions through the promotion of alternative transportation modes.

Finding: Alternative C would meet most or all the primary Project objectives as the overall development program would be similar. However, this alternative would have difficulty achieving Objective 1 (sufficient parking). This alternative would result in very similar environmental consequences when compared to the proposed Project. While this alternative would result in fewer mobile source emissions by reducing parking inventory, these environmental benefits would be relatively small and would not reduce any significant impacts to a less than significant level. Reducing the amount of parking also relies heavily on the successful implementation of Transportation Demand Management (TDM) measures. If ineffective, reducing on-site parking could also lead to unintended consequences of increased demand for on-street parking, or employees using restricted parking on neighboring property. For these reasons, Alternative C is not the environmentally superior alternative.

10.4 Alternative D: Office Use Only
Alternative D would eliminate programmed laboratory or manufacturing uses on site and buildings would be used for professionally office space only. Ground floor spaces could also include limited supporting commercial uses such as food service/cafes and convenience services. The total number of employees occupying the buildings under Alternative D could be slightly greater, as laboratory spaces could involve larger interior working spaces and higher ceilings (compared to typical private offices and workstations).

All other aspects of the development program and design would remain the same. The intent of the alternative is to remove the laboratory elements and specialized design features required for a BSL-3 facility and reduce energy and water consumption, while meeting the Project objectives. 202
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
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Finding: Environmental impacts would be similar or slightly reduced as compared to the proposed Project or other alternatives. With the removal of life science laboratory uses up to BSL-3, this alternative would reduce the degree of impact in several areas including total air quality and GHG emissions, energy use, water consumption and noise, but would slightly increase the degree of potential impacts to transportation. Alternative D would also remove concerns regarding the use and transport of hazardous materials at the Project site. CEQA Section 15126.6 requires the selection of an environmentally superior alternative to the proposed Project. Although the No Project Alternative must be analyzed, if the environmentally superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives. As such, Alternative D was identified as the environmentally superior alternative but determined to not reduce any significant impact to a degree that is less than significant.

10.5 Conclusion
In summary, the Project as proposed does not result in any significant unavoidable environmental effects, and the feasible alternatives analyzed, by comparison, do not eliminate or reduce one or more significant effects to a less than significant level once Project mitigation is applied. The alternatives reduce environmental effects by a matter of degree but may not result in environmental benefits that warrant consideration of an alternative over the Project as proposed.

The applicant is pursuing an office and/or life science project given uncertainty in the market. Having the flexibility to pursue an office and/or life science project improves the applicant’s ability to attract businesses and tenants which would achieve several of the City’s goals and policies. The City of Belmont has adopted General Plan goals and policies that promote diverse employment opportunities, increase local jobs, strengthen Belmont’s tax base and fiscal sustainability, and leverage regional growth to concentrate compatible commercial and employment development, especially in areas east of U.S. 101 (Goal 2.7, Policy 2.7-1, Goal 2.17, Policy 2.17-1, Policy 2.17-2, Goal 2.22, and Policy 2.22-1).

Having the flexibility to develop the site with office and/or life science uses directly advances these goals and policies. The flexibility between office and/or life science enables a broader range of employmentgenerating activities that diversify Belmont’s economic base and respond to changing market conditions.

San Mateo County is recognized as the birthplace and center of biotechnology. While these biotechrelated economic opportunities may have begun in South San Francisco, life science and biotech spaces have expanded to neighboring San Carlos and nearby Foster City, Menlo Park, Redwood City and San Bruno. Allowing for possible life science allows Belmont to leverage one of the region’s strengths in order to increase economic opportunities in Belmont. Doing so would also acknowledge Belmont’s place in the region as being attractive to a range of different businesses. Approving an office-only project would not achieve that goal.

Additionally, though Alternative D is slightly environmentally superior to a degree, an office-only project may not result in environmental benefits that warrant consideration over an office and/or life science project. Alternative D, by comparison, does not eliminate or greatly reduce one or more significant effects to a less than significant level once project mitigation is applied. For example, office only projects slightly increase impacts related to transportation since offices generally have higher employment per square foot than life science projects which would need more space dedicated to laboratories. 203
Exhibit A – Findings of Fact
Application ID: PA2022-0024; 1301 Shoreway Road
February 24, 2026

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11 MITIGATION MONITORING AND REPORTING PROGRAM
The MMRP sets forth specific monitoring actions, timing requirements, and monitoring/verification entities for each mitigation measure adopted in these Findings, in compliance with Public Resources Code Section 21081.6(a)(1) and CEQA Guidelines Section 15097. The City hereby adopts the MMRP and determines that compliance with the MMRP is a condition of approval of the Project. 12 FILING NOTICE OF DETERMINATION
The City Council hereby directs the Planning Division to file a Notice of Determination regarding the approval of the Project within five (5) business days of adoption of this resolution. 13 SEVERABILITY
If any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to the Project, shall continue in full force and effect unless amended or modified by the City. 14 INCORPORATION BY REFERENCE
These findings incorporate the text of the EIR for the Project, including the MMRP, City staff reports relating to the Project and other documents relating to public hearings on the Project, by reference, in their entirety. Without limitation, this incorporation is intended to elaborate on the scope and nature of mitigation measures, Project and cumulative impacts, the basis for determining the significance of impacts, the comparison of the alternatives to the Project, the determination of the environmentally superior alternative, and the reasons for approving the Project. 204
1301 Shoreway
Final Environmental Impact Report
SCH # 2024060880
January 2026
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Final Environmental Impact Report
for the
1301 Shoreway Project
SCH #2024060880
Prepared by:

City of Belmont
Community Development Department
1 Twin Pines Lane
Suite 310
Belmont, California 94002
With assistance from:
10 S Almaden Boulevard, Suite 1250
San Jose, California 95113
January 2026
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January 2026
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January 2026
Table of Contents
1 Introduction 1-1
2 Public Comments and Response to Comments on the Draft EIR 2-1 3 Changes to the Draft EIR (EIR Errata) 3-1
4 Draft Mitigation Monitoring and Reporting Program 4-1 Appendices
Appendix A: Written Public Comments Received on the Draft EIR Appendix B: Minutes of November 4th, 2024 Public Hearing at Planning Commission 209
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Introduction
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1 Introduction
This Final Environmental Impact Report (Final EIR) is an informational document prepared by the City of Belmont (City) to evaluate the potential environmental impacts of the proposed 1301 Shoreway Road Project. The primary objectives under the California Environmental Quality Act (CEQA) are to inform decision makers and the public about a project’s potential significant environment effects, identify possible ways to minimize significant effects, and consider reasonable alternatives to the project. This Final EIR has been prepared with assistance from the EIR consultant team and reviewed by city staff for completeness and adequacy in accordance with Public Resources Code Sections 21000-21177 and the State CEQA Guidelines.

The 1301 Shoreway Draft Environmental Impact Report (Draft EIR) was circulated for a 45-day public review period from October 8, 2024, to November 22, 2024. The State of California Governor’s Office of Planning and Research State Clearinghouse and CEQA regulations require a minimum of 45 days for review. Electronic copies of the document were accessible from the City’s public facing website, and distributed to State, regional, and local agencies, as well as organizations and individuals, for review and comment. Hard copies of the Draft EIR and its appendices were also made available at the City of Belmont Planning Department and were available for review at the public library.

This Final EIR has been prepared in accordance with CEQA and State and local CEQA Guidelines and represents the independent judgment of the City, as CEQA Lead Agency. This Final EIR, together with the Draft EIR, technical appendices, and other written documentation prepared during the EIR process, as those documents may be modified by the City Council at the time of certification, will constitute the Final EIR, as defined in the State CEQA Guidelines, Section 15132, and the City of Belmont’s environmental document reporting procedures.

The Final EIR must be certified as complete and adequate prior to any action on the proposed project. Once the EIR is certified and all information is considered, the City can take action to go forward with the proposal, make changes, or select an alternative to the proposed project.

While the environmental information in the EIR is important, it is only one of several factors the City may consider in its decision-making process. The City is also required to make findings on each significant environmental effect when making that decision.

1.1 Document Organization and Framework
This document is organized as follows:
 Section 1 provides a brief introduction to this report.  Section 2 provides a list of agencies and interested persons commenting on the Draft EIR.

This section also contains master responses and individual responses to comments. To facilitate review of the responses, an index number (e.g., 1-1, 1-2, 2-1) has been assigned to each comment and to its corresponding responses.
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 Section 3 contains minor changes, or errata, to the Draft EIR as a result of minor changes to the project, comments by agencies and interested persons, or minor corrections.  Section 4 contains the Mitigation Monitoring and Reporting Program (MMRP). Lastly, this document contains a series of Attachments with information relevant to the comments received.

City staff has reviewed the comment letters, draft responses and information generated in the course of preparing the responses and determined that none of this material constitutes significant new information that requires a recirculation period for further public comment under CEQA Guideline Section 15088.5. None of this new material indicates that the project will result in a significant new environmental impact not previously disclosed in the Draft EIR.

Additionally, none of this material indicates that there would be a substantial increase in the severity of a previously identified environmental impact that will not be mitigated, or that there would be any of the other circumstances requiring recirculation as described in Section 15088.5.

1.2 CEQA Requirements Regarding Comments and Responses
CEQA Guidelines Section 15204 (a) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be, “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated.

Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, considering factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and geographic scope of the project.

CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.”
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2 Public Comments and Response to Comments on the Draft EIR

2.1 Summary of Agency, Organization, and Individual Comments on the Draft EIR
This section includes all written comments received on the Draft EIR, verbal comments received during the November 4, 2024, Planning Commission public comment meeting, and the City’s responses to each comment. Comment letters and specific comments are given numbers for reference purposes. For example, Comment Letter 1 may be broken into Comment 1-1, Comment 1-2, Comment 1-3. This section of the Final EIR includes responses to each of the comments raised in every comment letter. Where sections of the Draft EIR are excerpted in this document, the sections are shown indented. Changes to the Draft EIR text, if any, are shown in underline for additions and strikeout for deletions. Additionally, add text changes to the Draft EIR are listed in Section 3 of this document.

All written public comments received on the Draft EIR, with comment numbering corresponding to this section of the Final EIR, are included as Appendix A to this Final EIR. The following is a list of agencies and persons that submitted comments on the Draft EIR during the public review period:

Table 2-1: List of Written Comments Received on the Draft EIR Comment Letter
No. Commenting Agency / Organization / Individual Date
Agencies
1 San Francisco Bay Conservation and Development Commission, Alyssa Please, Coastal Program Analyst November 22, 2024 2 California Department of Fish and Wildlife, Erin Chappell, Regional Manager November 13, 2024
3 California Department of Transportation, Yunsheng Luo, Branch Chief, Local Development Review November 22, 2024
Organizations
4 Advocates for the Environment, Dean Wallraff, Executive Director October 28, 2024
5 Adams Broadwell Joseph & Cardozo, Alaura McGuire and
Christina Caro November 4, 2024
Individuals
6 Steven and Nina Goodale November 22, 2024
Letters Received After the Public Comment Period
7 San Mateo County Flood & Sea Level Rise Resiliency District (OneShoreline) March 25, 2025
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2.2 Master Responses

2.2.1 Master Response Related to Sea Level Rise
CEQA generally does not require the analysis of existing or future environmental conditions, such as Sea Level Rise (SLR), on a project. Rather, CEQA requires the analysis of a project’s impact on the environment. As such, the comments received regarding the 1301 Shoreway Project’s impacts associated with SLR are not CEQA concerns.

It is not definitive how severe SLR and its effects will be to the city of Belmont and the region, and it is beyond the scope of CEQA to analyze for that scenario. However, the Draft EIR proactively acknowledges local guidelines and SLR estimates in the Project’s design. The Draft EIR document considers the Ocean Protection Council (OPC) guidelines for SLR resiliency and BCDC guidelines for addressing SLR adaptation through 2100. As described in Chapter 13 Hydrology Section 13.5.4, the project would raise the elevation of the project site by 2 feet to address the City’s requirement to establish development sites 2 feet above the Federal Emergency Management Agency (FEMA) base flood elevation. By raising the base flood elevation from 10 feet by 2 feet to +12 feet NAVD88, the project would not be within the 100-year flood zone for the region. This, in turn with anticipated SLR adaptation measures along Belmont Slough for addressing the OPC (2024) Intermediate-High SLR Scenario projections, ensure the Project development would remain resilient to SLR through the end of the century.

Separately and outside of the CEQA process, compliance with BCDC policies and permitting ensures that SLR is fully addressed through a regulatory framework specifically designed for that purpose, including preparation of a Sea Level Rise Risk Assessment for review and approval by BCDC. Additionally, the City’s future Climate Action and Adaptation Plan Update will establish key strategies for increasing resilience across Belmont and align with regional guidance regarding such. Given CEQA’s statutory limitations and the specialized jurisdiction of BCDC, the EIR does not include a standalone analysis of SLR and the Project will comply with BCDC requirements, which ensure compliance with regional resiliency standards.

2.2.2 Master Response to Project Use for Consistency Purposes The Draft EIR includes variation in the terminology used to describe the project’s primary use. Terms such as “office and life science/research campus,” “commercial office/life science laboratory buildings,” and “life science/office” were used in various sections throughout the EIR. To provide clarity and ensure consistency throughout the EIR, this master response confirms that the intended and representative project use for environmental analysis and entitlement purposes is “office and/or life science.” This use encompasses general office functions and/or laboratory and research activities typical of life science tenants and is consistent with the project applicant’s development proposal and expected occupancy. The environmental analysis presented in the Draft EIR remains valid and conservative based on this clarified use. 214
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2.3 Agency Responses to Comments

2.3.1 Response to Letter 1: San Francisco Bay Conservation and Development Commission, Alyssa Please, Coastal Program Analyst
1-1 Introductory Comments. Introductory comments stating that BCDC will rely on the Final EIR for project permit approvals and BCDC permitting authority as a responsible agency are noted for the record. The comments are informational and do not address the analysis of the Draft EIR. No further response is required. 1-2 BCDC Jurisdiction. The comments confirm that BCDC staff has worked with the applicant team to map the limits of BCDC jurisdictional boundaries and note that the project is partially located within the shoreline band of BCDC’s permitting jurisdiction. With respect to mapping and Draft EIR Figure 3-4, the BCDC jurisdictional boundary shown is based on the engineering plans and information provided in the project application package. This boundary represents the line mapped by the project team in consultation with BCDC staff, showing the shoreline at MSL + 5 feet (8.35 feet NAVD88).

Please note that the engineering plans and application package are prepared to scale.

The “Not to Scale” notation in Draft EIR Figure 3-4 simply acknowledges that the report graphic is of such a size as to render the scale unusable, as it has been edited to fit the formatting of the Draft EIR.

The project application includes a full civil engineering package. The Draft EIR does not contain every exhibit within the engineering plans. The notes within the engineering package indicate that the mapping is based on a topographic survey prepared by BKF Engineers dated November 11, 2021. Engineering notes regarding the benchmark also indicate that the applicant used NAVD88 and that elevations are based upon a field survey performed by BKF engineers.1 The notes specify that “Prior to the acceptance of these elevations, multiple NGS benchmarks within the site vicinity were observed with redundant measurements and were checked to a tolerance of =/- 0.05’.” The “Limit of BCDC Jurisdiction” noted on maps and Draft EIR Figure 3-4 are based on these benchmarks. Further, Figure 7-1 on page 7-7 in the Draft EIR and Figure 3 on page 20 of Appendix C of the Draft EIR depict the BCDC Bay Shoreline and 100-foot shoreline band to scale, based on the benchmarks described above.

Additionally, please see the exhibit below prepared by the applicant showing the limits of the 100-foot shoreline band. The exhibit was drawn to 1”=100’ scale based on the topographic survey. This exhibit is provided here in the Final EIR for clarification 1 The North American Vertical Datum of 1988 (NAVD 88) is a vertical datum used to measure and compare elevations across the United States and Canada. It's the official vertical datum for the United States and is used by surveyors, engineers, and mapping professionals. A vertical datum is a reference system that uses a fixed point as a baseline to measure elevations. NAVD 88 is a leveling network that's attached to a single origin point in Quebec, Canada.
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purposes. It does not conflict with the Draft EIR figures mentioned and, as such, is not intended to replace the existing figures in the Draft EIR. 216
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1-3 Assessment of Biological Resources. The commenter cites BCDC’s comments on the Notice of Preparation (NOP) regarding defining the study area, areas that could be affected by construction or operations, and potential impacts along Belmont Creek. In response, the Draft EIR Chapter 7 and Draft EIR Appendix C (Biological Resources Report) provide a thorough analysis and disclosure of potential environmental impacts, with a primary focus upon biological resources that are or may be present within the riparian corridor of Belmont Creek. Page 7 of the Biological Resources Report, which is the basis of Chapter 7 of the Draft EIR, describes the “study area” as “the project boundary plus surrounding areas within 100 feet, which were studied to allow for assessment of indirect impacts of the project.” Indirect impacts considered by the Draft EIR include potential effects related to light, sound, debris, and runoff from the Project site. Further, the Draft EIR clearly identifies the study area evaluated by the biologist, as shown in Draft EIR Figure 7-1. The study area does include a portion of Belmont Creek and land along the San Francisco Bay Shoreline adjacent to the project site to assess potential direct and indirect project-related impacts on biological resources. Potential construction-related and operational effects of the project on biological resources are addressed on pages 7-16 through 7-26 of the Draft EIR, including detailed analyses of project lighting (page 7-20 and 7-21), water quality protection (pages 7-19 and 7-20), construction debris (page 7-20), construction noise on special status species (page 7-18 and 15-20) and riparian and wetland areas (pages 7-22 and 7-23). Please note that Chapter 7 of the Draft EIR was also reviewed by the California Department of Fish and Wildlife (CDFW).
1-4 McAteer-Petris Act. The comment is correct that the information regarding the McAteer-Petris Act should be located under the “State” heading within Section 7.4 Applicable Regulations Plans and Standards. The clarifications to this text on page 7-15 of the Draft EIR are acknowledged, shown below, and incorporated into the record.

Draft EIR, page 7-15:

BCDC jurisdiction includes the San Francisco Bay and a 100-foot-wide band along the shoreline of the San Francisco Bay., as well as other areas not relevant to this particular project. The Bay shoreline is defined as all areas that are subject to tidal action from the south end of the San Francisco Bay to the Golden Gate (Point Bonita–Point Lobos), and to the Sacramento River line (a line between Stake Point and Simmons Point, extended northeasterly to the mouth of 218
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Marshall Cut), including. The BCDC will claim all sloughs, and (specifically the marshlands lying between mean high tide and up to 5 feet above mean sea level where marsh vegetation is present); tidelands (lands lying between mean high tide and mean low tide); and submerged lands (land lying below mean low tide) in this region. The McAteer-Petris Act also provides that within the 100-foot shoreline band, the BCDC may deny an application for a permit on the grounds that the project fails to provide maximum feasible public access, consistent with the proposed project, to the Bay and its shoreline. requires that “maximum feasible public access, consistent with a project be included as part of each project to be approved by the BCDC.”
The edits to the Draft EIR as submitted provide clarifications about the McAteer-Petris Act but do not change the conclusions of the analysis within the Draft EIR. 1-5 Hazards and Hazardous Materials (Groundwater). The commenter notes BCDC’s comments on the NOP specific to groundwater rise relative to contaminants in soil or groundwater. The Draft EIR Chapter 12 (Hazards and Hazardous Materials), page 12-5, provides a summary of extensive investigations conducted at the site and surrounding properties. As documented on page 12-5 there are two open cases of known contamination of groundwater and/or soils from neighboring upgradient industrial businesses. Remediation and monitoring at these sites is ongoing, and no volatile organic compounds (VOCs) have been detected at the project’s on-site monitoring well since 2013. This indicates that changes in elevation of the groundwater table, if it were to occur, would not further mobilize contaminants because incidents of past contamination are already being addressed. The potential effects of soil and groundwater quality are discussed on page 12-18 of the Draft EIR.

It is also important to note that the comment is addressing an existing recognized environmental condition, and rising groundwater is not a consequence of the project.

CEQA requires the evaluation of physical environmental effects of a project upon the environment. Implementation of the project will have no effect upon existing remediation efforts, nor will the project alter changes in groundwater levels. 1-6 Hydrology and Water Quality. The City of Belmont acknowledges BCDC’s NOP comments and reference to the OPC’s 2024 SLR Guidance document. Please see detailed responses to comments below.
1-7 Sea Level Rise and Flood Resilience. The comment notes the most current OPC SLR guidance document dated June 2024 and suggests that the analysis of SLR should reflect end of century (year 2100) projections.

As background, the prior OCP guidance (2018) projected approximately 2 feet of SLR by mid-century (year 2050). The recently updated OPC guidance (2024) revises projected SLR down to one foot by 2050 (based on the Intermediate-High SLR scenario). The most 219
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current FEMA Flood Insurance Rate Map (FIRM) for the area (Panel No. 06081C0169G, 2019) identifies the project area as located in flood zone X. In flood zone X, the project site does not have a specific FEMA base flood elevation. The adjacent property and Belmont Creek are located in flood zone AE with a base flood elevation of 10 feet. Due to the proximity of zone AE, the City of Belmont has requested that the finished floor of future buildings be at least 12 feet above MSL to ensure the buildings are high enough due to their relationship to the nearby zone AE. The Draft EIR Section 13.3.2 simply provides setting information regarding the Mean Higher High Water (MHHW) sea level elevation, King Tides, and previously mapped 100-year and 500-year flood zones near the project site.

As noted in Section 2.2.1 Master Response above, CEQA generally does not require the analysis of existing or future environmental conditions, such as SLR, on the project.

Because the content of the received comments pertains to SLR rather than projectrelated impacts to the environment, the comments from BCDC associated with SLR are not CEQA concerns. However, in direct response to BCDC’s comments the following information is provided.

BCDC requires that permit applicants prepare a SLR Risk Assessment for review and approval by BCDC. This assessment involves evaluating the project site's vulnerability to SLR and storm surge based on BCDC’s guidance, and documenting compliance with Bay Plan policies as it relates to the project and SLR. The SLR Risk Assessment will also identify and demonstrate how the project incorporates SLR adaptation measures along Belmont Slough to remain resilient through flood hazards expected by mid-century per the OPC (2024) Intermediate-High SLR Scenario, and through the end of the century.

A SLR Risk Assessment will be provided to BCDC as part of BCDC’s review of the project and will address the specific SLR and flood resilience concerns in BCDC’s comment letter but is not required or relevant to the CEQA environmental impact analysis in this EIR.

While none of the findings of less than significant impacts as identified in Chapter 13 of the Draft EIR would change as a result of the BCDC permitting process, existing project details already address resiliency in regards to SLR as follows:
• The proposed finished floor elevation at elevation +12 feet NAVD88 incorporates a SLR allowance of 1.6 feet over the 100-year extreme tide elevation, which makes the buildings resilient to around year 2061.
• With the proposed SLR adaptation measures along Belmont Slough, and assuming adjoining areas will have similar levels of protection in the future, the development would remain resilient to SLR through the end of the century. • With the proposed site improvements, the Belmont Creek Trail will be located at approximately +12.5 feet NAVD88, which incorporates a SLR allowance of 2.1 220
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feet over the 100-year extreme tide level (ETL). Based on this trail elevation, the trail would not have a potential to be impacted by a 1% annual chance (100- year) storm event until after 2068. Depending on the rate of SLR toward the end of the century, the trail could potentially be temporarily inundated on King Tides after 2090 but would not experience flooding during daily tides until 2110. • With proposed SLR adaptation measures along Belmont Slough in place, the trail would not be projected to be impacted by SLR until after the end of the century. 1-8 OneShoreline’s Planning Policy Guidance. The relationship and relevancy of the June 2023 OneShoreline Planning Policy Guidance document is noted for the record. As noted on page 2, the document is identified as voluntary guidance to local agencies but does not represent mandatory regulations. The document is considered an important local resource and its recommendations will be considered by the City of Belmont during project review. However, as a guidance document it is not necessary to include these recommendations and planning policies within the regulatory setting of the Draft EIR.

Regarding sea level rise resilience through the end of the project life and protection of public access, please see response to comment 1-7 above. Additionally, the project proposes on-site and off-site public access improvements, such as constructing a new sidewalk along Sem Lane and widening the Belmont Creek Trail. This proposed development would be designed to be resilient to projected SLR and flood hazards through mid-century and incorporate adaptive planning elements to accommodate SLR and potential flood hazards through end-of-century.
1-9 Stormwater System Design and Operation. The City and the project design team understand and are aware of the shallow underground water table. The applicant’s design team has followed the recommendation of the Geotechnical report prepared by Cornerstone Earth Group (Draft EIR Appendix F, June 2022), as well as the guidelines in Appendix E of the San Mateo County C.3 Stormwater technical guidance.

To clarify the operation of the stormwater system, the design for the post-construction stormwater measures include an impermeable liner around the bioretention areas, which would prevent infiltration from ground water. The ground water was observed to be 4 feet below the current grade based on exploratory borings (not 3 feet, as suggested in the comment).

The project design includes the current guidelines of the County C.3 stormwater technical guidance and recommendation of the geotechnical report to ensure the successful long-term function of the storm drain system and stormwater measures given the site conditions.
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With respect to groundwater rise, based on OPC (2024) guidance, proposed buildings and amenities related to the 1301 Shoreway Project would not be impacted by potential groundwater flooding until after the end of the century. Specifically, because the project site would be graded to a new elevation of +12 feet NAVD88, and the groundwater elevation is approximately +7 feet NAVD88, there would be approximately 5 feet between the new grade elevation and the groundwater levels. Per the OPC, the Intermediate-High SLR Scenario for the year 2100 has a projected SLR of 4.8 feet, which does not exceed the 5 foot allowance between the proposed site grade and groundwater level.
1-10 Drainage Patterns. The comment requests a discussion that explains how raising the elevation of the site would not increase the rate and volume of drainage volumes off site into adjacent areas. In response, raising the site elevation is not the primary factor affecting runoff volume. As noted on page 13-16 of the Draft EIR, raising the base elevation of the project site would not change off-site stormwater flows or result in a significant impact to project site runoff volumes. Further, the reduction in runoff volume calculated for the project compared to existing conditions is a function of designing with greater areas of landscaping and pervious pavement materials. Pre- and post-project drainage volumes are described on page 13-14 of the Draft EIR. 1-11 Flood Hazards. The comment requests that the Draft EIR address the potential for flooding from groundwater rise in the context of inundation and release of pollutants. In response, please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 above regarding SLR adaptation and the project design’s responsiveness to groundwater rise. Considering the project’s flood protection measures through midcentury and long-term adaptation through the end of the century, flood risk (and the potential for inundation and pollutant release from flood risk) is correspondingly minimized. It should also be noted that the project’s buildings propose no subsurface/below grade spaces that would be subject to inundation. 1-12 Land Use and Planning. The comment regarding the McAteer-Petris Act and the Bay Plan, in the context of BCDC comments on the NOP, are acknowledged. While the McAteer-Petris Actis a State law that was amended to make BCDC a permanent regulatory agency, this law is referenced elsewhere in the Draft EIR (page 7-15, Biological Resources). For the purposes of the Draft EIR, State law is appropriately cited for regulatory context but does not require a detailed analysis relative to the project under review.

Similarly, and in response to BCDC comments on the NOP, the Bay Plan is referenced throughout the Draft EIR (for example, page 7-13, Biological Resources, page 16-5, Public Services, and page 17-8, Transportation). Consistency with the Plan is discussed in the context of CEQA significance criteria, and specific elements and policies of the Plan have been considered within the impact analysis and mitigation measures of the Draft EIR.
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Draft EIR Chapter 14, Land Use, Population and Housing (and Table 14-1, General Plan Consistency Analysis), is focused on City of Belmont policies as the lead agency under CEQA. While it is understood that BCDC will review and consider the City’s Final EIR with the project’s permit application, the City anticipates that BCDC will conduct its own consistency determination during project review as a State responsible agency. 1-13 Public Services and Recreation. The comment reiterates comments received from BCDC on the NOP regarding the project’s service area, service population and related effects upon recreation facilities within BCDC jurisdiction.

In response, the service area of the Belmont Creek Trail and associated amenities along the creek are identified on Draft EIR page 16-10, noting that the service area and population is limited in scope due to the project location and land use pattern of the immediate area. The potential effects of the project are described on pages 16-9 and 16-10, explaining that this employment use would be expected to increase use of the trail, but not to levels to cause physical deterioration to the point where CEQA thresholds would be exceeded.

Regarding public access and recreational facility resiliency to SLR, please see Section

2.2.1 Master Response, and response to comments 1-7 and 1-8 above. 1-14 Conclusion. Closing remarks and contact information are appreciated and noted. No further response is required.

2.3.2 Response to Letter 2: California Department of Fish and Wildlife, Erin Chappell, Regional Manager
2-1 Introductory Comments. Introductory comments confirming CDFW receipt of the Notice of Availability of the Draft EIR and opportunity to provide comments are noted for the record. No further response is required.
2-2 CDFW Role. Comments documenting CDFW’s reviewing role as both a Trustee Agency and Responsible agency are appreciated and noted for the record. As the comments do not raise substantive issues specific to the EIR analysis, no further response is necessary. 2-3 Project Description Summary. Comments regarding the basic components of the project description are noted for the record. These factual comments do not raise substantive issues regarding the EIR analysis. No further response is necessary. 2-4 Comments and Recommendations – Potential Impacts to California Ridgway’s Rail and California Black Rail. CDFW’s comments focus on the potential presence of these species, potential impacts including direct mortality from project construction, and note the state and federal protected status of the species.
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The Draft EIR Chapter 7 (Biological Resources, page 7-2) notes the potential presence of these species adjacent to the project site. According to the CNDDB (2022) database and field surveys (H.T. Harvey, 2022), preliminary evidence indicates that CRRA and BLRA, if present, are more likely to be occasional foragers, migrants, or transients along Belmont Creek. Given the level of conservation risk, however, existing mitigation within the Draft EIR has been amplified to conservatively address CDFW’s concerns and recommendations. See Response 2-5 below.
2-5 Recommended Mitigation Measures. CDFW comments recommend mitigation measures specific to CRRA and BLRA. While Draft EIR mitigation measure MM BIO-1.1 (Draft EIR page 7-19) includes provisions for surveys, buffers, and avoidance, the measure now includes language clarifications and amplifications to specifically address CRRA and BLRA. This measure is reflected in the project’s mitigation monitoring and reporting program (MMRP).

MM BIO-1.1 Avoidance and Preconstruction Survey
Seasonal Avoidance. Tree removal, demolition, and the start of construction activities shall be scheduled to avoid the nesting season for breeding and special status bird species. If such activities take place outside the nesting season, all impacts on nesting birds protected under the MBTA and California Fish and Game Code will be avoided. The nesting season for most birds in San Mateo County extends from February 1 through August 31, and January 15 through August 31 for CRRA.

Preconstruction/Pre-disturbance Surveys. If it is not possible to schedule construction activities between September 1 and January 3114, then preconstruction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no nests of migratory birds will be disturbed during project implementation. These surveys shall be conducted no more than 7 days prior to the initiation of tree removal, demolition, ground disturbance, or construction activities for each construction phase. During this survey, the biologist will inspect all trees and other potential nesting habitats (e.g., trees, shrubs, buildings, and the ground) in and immediately adjacent to the impact areas for migratory bird nests.

In addition to the general surveys above, a qualified biologist shall conduct protocol-level surveys of CRRA and BLRA in suitable habitats adjacent to the project using the 2017 California Clapper Rail Survey Protocol.

Buffers. If an active nest is found within areas that would be disturbed by project activities, the biologist will determine the extent of a construction-free buffer zone to be established around the nest (typically 300 ft for raptors and 100 ft for 224
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other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code will be disturbed during project implementation.

If CRRA or BLRA are found in suitable habitat near the project site, a 700-foot nowork buffer shall be implemented between construction activity and any current-year breeding CRRA and BLRA detections if construction cannot be avoided during the rail breeding season. If a 700-foot buffer is not feasible, noise reduction through modification to equipment and/or implementation of acoustic barriers/blankets may be employed to attenuate noise and reduce visual impacts to breeding rails. Buffers and/or physical barriers shall be established in consultation with CDFW.

Inhibition of Nesting. If construction activities will not be initiated until after the start of the nesting season, all potential nesting substrates (e.g., bushes, trees, grasses, and other vegetation) that are scheduled to be removed by the project may be removed prior to the start of the nesting season (e.g., prior to February 1 January 15). This will preclude the initiation of nests in this vegetation and prevent the potential delay of the project due to the presence of active nests in these substrates.
2-6 Environmental Data. The comment requests that any special-status species and natural communities identified during project surveys be reported to the CNDDB. The qualified project biologist will be asked by the applicant and/or City of Belmont to submit any required survey forms to inform the database.
2-7 Environmental Document Filing Fees. Comments regarding filing fees are noted and will be paid by the project sponsor upon filing of the Notice of Determination. 2-8 Conclusion. Conclusionary comments and contact information are appreciated and noted for the record.

2.3.3 Response to Letter 3: California Department of Transportation, Yunsheng Luo, Branch Chief, Local Development Review
3-1 Introductory Comments and Project Understanding. Introductory comments regarding Caltrans’ Local Development Review program and understanding of the project under review are noted for the record. No further response is required. 3-2 Travel Demand Analysis. Comments note and concur that the project VMT analysis and significance determination are consistent with City of Belmont VMT policy. The project’s employee trip reduction strategies within Draft EIR Chapter 17 and the final Transportation Demand Management (TDM) plan will be documented with annual monitoring reports, as required by the project’s mitigation monitoring and reporting program (MMRP).
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3-3 C/CAG VMT/Greenhouse Gas (GHG) Model Mitigation Program. The City of Belmont acknowledges the origins of the C/CAG Model Mitigation Program. The City welcomes collaboration with Caltrans and C/CAG to explore additional program options. As this comment reflects citywide and regional policy, no further response is required. 3-4 Hydrology. The City of Belmont notes Caltrans’ conclusion that no significant adverse drainage condition is expected on US 101 as a result of the project. No further response is required.
3-5 Water Quality Regulations. Comment recommending that the most current (2022) National Pollutant Discharge Elimination System (NPDES) Construction Stormwater General Permit should be referenced is acknowledged and noted for the record. The comment is correct that the most current information should be referenced in Section

13.4 of the Draft EIR where the NPDES Construction Stormwater General Permit is discussed. The clarifications to this text are acknowledged, shown below, and incorporated into the record.

Draft EIR, page 13-5:

Increased compliance tasks under the most recently adopted 2009 2022 Construction General Permit include project risk evaluation, effluent monitoring, receiving water monitoring, training, inspections, electronic data submission of the SWPPP and all other permit registration documents, and a Rain Event Action Plan (REAP), which must be designed to protect all exposed portions of a project site within 48 hours prior to any likely precipitation event.

Draft EIR, page 13-8:

Pursuant to the CWA, in 2009, the SWRCB issued a statewide general NPDES Permit for stormwater discharges from construction sites (NPDES No.

CAS000002). The NPDES permit was reissued in 2022 (Order WQ 2022-0057- DWQ). Under this reissued permit, discharges of stormwater from construction sites with a disturbed area of one or more acres must obtain individual NPDES permits or be covered by the General Permit—i.e., by filing a Notice of Intent with the SWRCB and developing and implementing a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP must contain a site map that shows the construction site perimeter, existing and proposed buildings, lots, roadways, stormwater collection and discharge points, general topography both before and after construction, and drainage patterns across the project site. The SWPPP must also list best management practices (BMPs) implemented on the construction site to protect/retain stormwater runoff, and must contain a visual monitoring program, a sampling, analysis, and monitoring requirement for "nonvisible" pollutants, and a monitoring plan if the site discharges directly to a water body listed on the state’s 303(d) list of impaired waters. 226
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Additionally, as noted on page 13-13 in Section 13.5.4 of the Draft EIR, the project would comply with the NPDES permit requirements. As such, the edits to the Draft EIR as submitted provide clarifications about the most current version of the NPDES Construction Stormwater General Permit, but do not change the conclusions of the analysis within the Draft EIR. Therefore, document recirculation would not be necessary, and no further response is required.
3-6 Construction-Related Impacts. Reminders regarding other Caltrans projects in the project vicinity and Caltrans contact information for future coordination is noted for the record and appreciated. No further response is required.

2.4 Organization Responses to Comments

2.4.1 Response to Letter 4: Advocates for the Environment, Dean Wallraff, Executive Director
4-1 Introductory Comments. Comments regarding representation and the basic components of the project description are noted for the record. These comments do not raise substantive issues regarding the EIR analysis. No further response is necessary. 4-2 Net-Zero Greenhouse Gas Emissions Threshold. The commenter suggests that the City should use a net-zero GHG significance threshold, with unsubstantiated statements that it is more affordable to construct new buildings to be net-zero now than to retrofit an old building in the future to meet the same standard. The commenter also references California’s policy to achieve net-zero GHG emissions no later than 2045 (presumably AB 1279). In response, the State has not adopted a net-zero GHG threshold (or any GHG threshold) for individual development projects. The State’s policy to achieve net-zero GHG emissions by 2045 requires CARB to ensure that their Scoping Plan updates identify and recommend measures to achieve carbon neutrality, and to identify and implement policies and strategies that enable carbon dioxide (CO2) removal solutions and carbon capture, utilization, and storage (CCUS) technologies. As discussed in Draft EIR page 11- 23, the project would not conflict with the 2022 CARB Scoping Plan following compliance with all applicable regulations.

The commenter states that two of the largest mixed-use developments in the history of California have moved forward as net-zero communities after losing CEQA lawsuits.

However, the 2022 CARB Scoping Plan notes that projects that have agreed to net zero GHG emissions such as “…the Newhall and Tejon Ranch projects do not necessarily represent the type of development that California most needs to simultaneously tackle the housing and climate crises…” Each of those projects represent large new mixed-use communities. The 2022 CARB Scoping Plan notes that several key State actions should be accounted for in local target-setting, including zero-emission light-duty vehicles (relevant to transportation electrification); smart growth/VMT reduction (relevant to vehicle miles traveled reduction); and new and existing residential and commercial buildings (relevant to building decarbonization).
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The 2022 CARB Scoping Plan does not recommend a net-zero GHG threshold for individual development projects, noting that such thresholds may make it more difficult to achieve statewide goals by prohibiting or complicating projects that are needed to support the State’s climate goals, like infill development or solar arrays. The 2022 CARB Scoping Plan also cautions using net-zero targets and specifically notes that jurisdictions considering a net-zero target should carefully consider the implications it may have on emissions in neighboring communities and beyond. Appendix D page 18 of the 2022 CARB Scoping Plan states the following:
“Jurisdictions should also avoid creating targets that are impossible to meet as a basis to determine significance. For example, a net-zero target may imply that the GHG emissions of any project that are not reduced or offset to zero would be considered potentially significant. This may lead to undue burdens and frustrate project approval processes, which may be particularly problematic for residential development in climate-smart, infill areas. In addition, some jurisdictions have more land capacity to remove and store carbon, while others host GHG-emitting facilities that serve necessary functions and will take time to transition to new technology (e.g., municipal wastewater treatment plants, landfills, energy generation facilities).” Local governments have the discretion to adopt targets that apply to their jurisdictions as long as those targets are supported by substantial evidence. The Draft EIR uses a GHG threshold developed by the BAAQMD, which is based on substantial evidence as explained in the Draft EIR Section 11.5, Greenhouse Gas Emissions pages 11-14 and as discussed under Response 4-3 below. Based on this threshold, which is supported by substantial evidence, the project’s GHG impacts were found to be less than significant. 4-3 Threshold Is Not Supported by Substantial Evidence: The City of Belmont has not yet adopted a numeric significance threshold for determining significant impacts associated with GHG emissions. Air districts typically act in an advisory capacity to local governments in establishing the framework for environmental review of air pollution impacts under CEQA. This may include recommendations regarding significance thresholds, analytical tools to estimate emissions and assess impacts, and mitigations for potentially significant impacts. Although air districts will also address some of these issues on a project-specific basis as responsible agencies, they may provide general guidance to local governments on these issues.
2 The City utilized BAAQMD’s recommended thresholds in the Draft EIR because BAAQMD’s thresholds are supported with substantial evidence (BAAQMD Appendix B, 2023). In Draft EIR Section 11.5.1 the analysis explains the BAAQMD thresholds that a project must meet in order to result in a less than cumulatively considerable 2 Bay Area Air Quality Management District, 2017 CEQA Air Quality Guidelines, 2017. 228
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contribution to cumulative climate change impacts. A project must meet criteria A or B below:

A. Projects must include, at a minimum, the following project design elements:

1. Buildings
a. The project would not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development). b. The project would not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

2. Transportation
a. Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted SB 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA:
i. Residential projects: 15 percent below the existing VMT per capita
ii. Office projects: 15 percent below the existing VMT per employee
iii. Retail projects: no net increase in existing VMT
b. Achieve compliance with electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

B. Be consistent with a local greenhouse gas reduction strategy (GHGRS) that meets the criteria under the CEQA Guidelines section 15183.5(b).

Because the Climate Action Plan (CAP) is consistent with SB 32 and is a qualified GHGRS under the CEQA Guidelines section 15183.5(b) the proposed project can use the CAP to evaluate the impact significance of full-build out emissions. The CAP spotlights 23 recommended GHG emissions reductions, and of these 23 only 10 apply to the project.

The other 13 measures do not apply to the project as they are directed toward public project development. See Table 11-4 on page 11-19 for consistency evaluation. 229
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The City thus relies on use of consistency with the qualified CAP, Plan Bay Area, AB 32, and SB 32, as the threshold. The City of Belmont's CAP is a guide that outlines a path for the City to achieve its community GHG reduction goal of 50 percent reduction below 2005 levels by 2035.
4-4 Insufficient Evidence for 15% VMT Reduction for TDM Program. The comment summarizes the project’s transportation mitigation measure (MM TRA-1) as identified in the Draft EIR to reduce vehicle miles traveled (VMT) impacts to a less than significant impact. The commenter argues that the mitigation lacks evidence of effectiveness and performance standards, and claims the Draft EIR improperly defers the formulation of MM TRAF-1 to a later date. In response, it is important to consider how TDM programs can be effectively implemented, monitored, and adjusted over time to meet the trip reduction performance standards established by the lead agency.

The specific trip reduction strategies are stated within the draft TDM Plan (Hexagon, 2024, Draft EIR Appendix I, beginning page 39). The draft TDM plan identifies specific measures related to active transportation, transit, and on-site amenities that would be appropriate for an employment generating use such as the proposed project. The draft plan demonstrates that there are effective measures available to the project to meet the City’s TDM policy. In addition, the project is required to meet the C/CAG TDM requirements, which are a 35 percent trip reduction for this type of project and size.

Following C/CAG methodology, Table 12 in the Hexagon report shows how the measures sum up to a 35 percent trip reduction. Following review and consideration by the City, a final TDM plan will be prepared that the project must implement. The specific measures identified in the TDM plan will be evaluated for effectiveness and enforced by the City over time (annually) per the mitigation monitoring and reporting program (MMRP) to be adopted at the time the Final EIR is certified. For the purposes of CEQA, this is a sufficient mitigation measure because it specifies a clear performance standard, timing, and enforcement requirements tied directly to the City’s TDM policy and trip reduction thresholds, which are stated in MM TRA-1. If the project is not meeting its trip reduction goals, the City can require adjustments to the program to increase effectiveness. This approach to TDM Plan implementation is common practice.

Draft EIR page 17-16 states that the “effectiveness of the TDM plan shall be reviewed annually and adjusted as necessary to maintain these trips and VMT reductions.” Therefore, there is no improper deferral of mitigation, nor is there a failure to demonstrate that the TDM program would effectively mitigate the project’s potentially significant employment VMT impact. MM TRA-1 is not needed to reduce a GHG impact.

Comments and critique regarding the structure of the City of Belmont VMT policy, with respect to the size of the project, is noted. The TDM Program Report and guidebook, reduction criteria and points system represent established and adopted policy are based on professional transportation planning principles. The Draft EIR appropriately identifies 230
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City policy as the threshold of review. The Draft EIR does not establish the City’s thresholds.
4-5 Inadequate Commitment to BAAQMD Best Management Practices. The comment suggests a lack of enforceability for the BAAQMD’s construction Best Management Practices (BMPs). These are standard construction practices included in the BAAQMD’s 2022 CEQA Guidelines in Tables 5-2 and 5-3 and recommended for all projects within the air basin (see Appendix D: Using CalEEMod for Bay Area Projects). The BAAQMD strongly encourages projects to include the Enhanced Best Management Practices. The commenter incorrectly assumes the Enhanced Best Management Practices are also required for all projects. However, project construction modeling conservatively did not include a majority of the BMPs to show emissions remained below the BAAQMD criteria pollutant thresholds.

The BAAQMD acknowledges that “construction emissions are temporary and variable, the Air District has not developed a quantitative threshold of significance for constructionrelated GHG emissions. However, the Lead Agency should quantify and disclose GHG emissions that would occur during construction” (2022 CEQA Guidelines Chapter 6). The Project specific construction GHG impacts were disclosed on page 11-16 of the DEIR. This methodology is also included on page 11-17 of the DEIR. The 2022 CEQA guidelines go on to state that while significance of construction-related GHG emissions are not determined, in order to minimize air quality pollutants, projects should incorporate BMPs included as Table 6-1 in the guidelines. The Project has included some of these practices such as Tier 4 Final equipment (MM AQ-1).

In addition, the comment and DEIR are citing BAAQMD’s 2017 CEQA Guidelines. These specific measures listed were removed in the new BAAQMD 2022 CEQA Guidelines.

Other measures and practices are included as Basic Best and Enhanced Management Practices for Construction-Related Fugitive Dust Emissions and the Best Management Practices for Construction-Related GHG Emissions. The Project modeling did not assume the measures besides Tier 4 Final per MM AQ 1. Therefore, the construction values shown in Tables 6-7, 9-3, and 11-2 are conservative and inclusion of these BMPs would further reduce emissions. Impacts would remain less than significant. Therefore, the additional measures are not necessary nor required for the project. 4-6 Consistency with Identified Applicable Plans: The comment incorrectly asserts that the Draft EIR did not evaluate consistency with all applicable GHG reduction plans. The Draft EIR evaluated the project’s consistency with the CARB 2022 Scoping Plan (Draft EIR pages 11-23), City of Belmont Climate Action Plan (Draft EIR pages 11-19 through 11- 22), and Plan Bay Area/ California Senate Bill 375 (Draft EIR page 11-22). These are the governing GHG reduction plans applicable to the project. Additionally, the broader air quality and GHG regulatory framework is outlined in Section 11.4 of the Draft EIR. 231
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The comment incorrectly implies that AB 32 is used as a project level GHG threshold. AB 32 is discussed in the Draft EIR in reference to BAAQMD methodology recommendations (page 11-16), in conjunction with various State reduction targets for context (page 11- 17), and discussed for disclosure and background to the Scoping Plan (page 11-23) and the overall regulatory environment. The AB 32 discussion in the analysis is provided for disclosure and background to the Scoping Plan consistency analysis since AB 32 required the State’s initial Scoping Plan and requires Scoping Plan updates every five years. The Draft EIR’s GHG impact conclusions do not rely on consistency with AB 32 and the analysis is not based on AB 32 related thresholds or reduction targets.

The Draft EIR instead evaluates consistency with the 2022 Scoping Plan, which accounts for the State’s latest GHG reduction targets established by SB 32 and AB 1279 (among others). The key elements of the 2022 CARB Scoping Plan focus on transportation.

Specifically, the 2022 CARB Scoping Plan aims to rapidly move towards zero-emission (ZE) transportation (i.e., electrifying cars, buses, trains, and trucks), which constitutes California’s single largest source of GHGs. The project would benefit from the State targets set forth within the 2022 CARB Scoping Plan. Approximately 92 percent of the project’s emissions (and approximately 130 percent of the project’s net emissions) are from energy and mobile sources which would be further reduced by implementation of current State programs. It should be noted that the project and the City have no control over vehicle emissions (approximately 80 percent of the project’s total emissions and 115 percent of the project’s net emissions). However, these emissions would decline in the future due to statewide measures including the reduction in the carbon content of fuels, CARB’s advanced clean car program, CARB’s mobile source strategy, fuel efficiency standards, cleaner technology, and fleet turnover. Accordingly, the project does not interfere with the State’s efforts to reduce GHG emissions under the 2022 CARB Scoping Plan, the 2017 Scoping Plan, Executive Order B-55-18 (statewide carbon neutrality by 2045), or the Belmont City Code (all electric buildings [prescriptive compliance pathway only] or all-electric ready).

As noted on Draft EIR page 11-18, project operations would also benefit from the implementation of current and potential future energy regulations including the SB 100 renewable electricity portfolio target of 60 percent renewable energy by 2030. SB 100 also established a further goal to have an electric grid that is entirely powered by clean energy by 2045.

Further, as noted in the Draft EIR the proposed project is required to comply with all building codes in effect at the time of construction which include energy conservation measures mandated by Title 24 of the California Building Standards Code – Energy Efficiency Standards (see Draft EIR page 11-18). Title 24 is part of the State's plans and regulations for reducing emissions of GHGs to meet and exceed State energy reduction goals. Because Title 24 standards require energy conservation features in new construction, they help reduce GHG emissions. Building Energy Efficiency Standards are updated on an approximately three‐year cycle and the most recent 2022 standards 232
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went into effect January 1, 2023. The project would be required to comply with the latest applicable version of the Building Energy Efficiency Standards.

AB 1279 codified the requirements of Executive Order B-55-18 and requires the State both to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissions thereafter. As noted above, these GHG reduction targets do not require individual development projects to achieve net zero GHG emissions or use a net zero threshold (see response to Comment 4-2).

Additionally, as noted above, the Draft EIR does not rely on consistency with AB 32 and the analysis is not based on AB 32 related thresholds or reduction targets. Therefore, the GHG analysis does not base any conclusions or its significance finding on outdated policy.

The comment asserts that the Draft EIR did not evaluate consistency with all applicable GHG reduction plans and lists Executive Oder B-55-18, the 2022 CARB Scoping Plan, the 2017 Scoping Plan, and the Belmont City Code. However, the comment is general and does not refer to any specific plans that should be addressed, beyond consistency with the applicable plans listed above. As noted above, AB 1279 codified the requirements of Executive Order B-55-18 and the 2022 CARB Scoping Plan incorporates these reduction goals. As the 2022 CARB Scoping Plan includes EO B-55-18 goals of net zero GHG emissions by 2045, evaluating the project against the 2022 CARB Scoping Plan ensures consistency with the State’s net zero goal.

The comment states that the project is inconsistent with Executive Order B-55-18 because it does not prohibit the use of gasoline, diesel, and natural gas. However, Executive Order B-55-18 includes no such requirement. The Executive Order sets a goal to achieve carbon neutrality by 2045 but does not establish a project level threshold or require the State to prohibit any fuels. The purpose of the Executive Order is to direct State policies and programs.

The comment also cites a 2022 CARB Scoping Plan for 50 percent of all industrial energy demand to be electrified by 2045. It should be noted that the 2022 CARB Scoping Plan does not identify this as a project level requirement. The 2022 CARB Scoping Plan cites AB 197 to achieve this goal. AB 197 provides additional guidance on how to achieve the reduction targets established in EO B-30-15 and SB 32. Additionally, the 2022 CARB Scoping Plan’s goal is intended to reduce GHG emissions from industrial processes. The comment also notes that the 2022 CARB Scoping Plan emphasizes decarbonizing “industrial facilities.” As the project is office and/or life science space, it is not an industrial facility and would not include industrial processes as part of project operations. Further, the displacement of fossil fuel use referenced in the comment cites a section of the Scoping Plan that addresses energy demand in industrial manufacturing, oil and gas extraction, and petroleum refining. As noted above, the project proposes an office and/or life science space and does not involve any industrial manufacturing, oil 233
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and gas extraction, and petroleum refining. Therefore, the goal cited in the comment is not applicable to the project.

The Draft EIR also evaluated the project’s consistency with the City of Belmont Climate Action Plan, Plan Bay Area/ California Senate Bill 375, AB 32, and SB 32. As noted above, AB 32 established the foundation of the State’s GHG reduction goals and Scoping Plan requirements and has been built upon with more recent legislation as discussed in the Draft EIR (page 11-23). The Draft EIR analysis discusses AB 32 in conjunction with various State reduction targets for context but does not use the regulation as the CEQA threshold for GHG emissions.

The project would be required to comply with all applicable City Code requirements.

Chapter 7 Article IV, Division 10 of the Belmont City Code requiring all-electric buildings is applicable. However, exceptions are provided if an all-electric prescriptive compliance pathway is not achievable for the project. The applicant must apply for a modification to the code requirement for the laboratory component of the project, if the ultimate end user requires natural gas for any aspect of operation. The remaining office uses would be all-electric and would not include natural gas infrastructure. While the use of natural gas within the project is not known at this time, the Draft EIR analysis is conservative as it was modeled with the possibility of natural gas for the laboratory portion. The project must also meet any existing standards for electrical vehicle charging per City of Belmont General Plan Consistency Table on page 14-11.
4-7 Conclusion. Closing remarks summarizing prior comments are noted for the record and require no further response.

2.4.2 Response to Letter 5: Adams Broadwell Joseph & Cardozo, Alaura McGuire and Christina Caro
5-1 Introductory Comments. Comments regarding representation and the basic components of the project description are noted for the record. These factual comments do not raise substantive issues regarding the EIR analysis. No further response is necessary. 5-2 CEQA Compliance Required. The comment recommends that the City of Belmont comply with CEQA and engage with the public as part of a Development Agreement.

These suggestions are comments noted for the record but do not raise substantive issues regarding the EIR analysis. No further response is necessary. 5-3 Statement of Interest. The commentor identify the parties and labor unions represented and the interests of those parties. General editorial comments are also included regarding the potential effects of some projects. These suggestions are comments are noted for the record but are not specific to the 1301 Shoreway Project and do not raise substantive issues regarding the EIR analysis. No further response is necessary. 234
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5-4 City Must Comply with CEQA. The comment requests that the City of Belmont comply with CEQA and summarizes some of the EIR’s findings regarding potentially significant effects. Comments are noted for the record. The EIR has been prepared to identify the project’s potentially significant effects as required by CEQA. 5-5 Development Agreement. The Draft EIR notes that the applicant intends to enter into a Development Agreement with the City of Belmont as one of the project’s potential actions and approvals. Comments further describe the purpose of a Development Agreement and possible provisions of such an agreement.

The comment is correct that a Development Agreement is not included in the description beyond noting the applicant’s intent to pursue such an agreement. The Draft EIR analyzes the project’s potential environmental effects as the project has been presented in the project application. A Development Agreement is not a requirement of discretionary projects and often addresses financial obligations or benefits. For example, the commentor notes “workforce benefits” and “workforce training” as possible provisions of a Development Agreement. Such provisions would have no physical environmental effect.

It is not uncommon for the terms of an agreement to be negotiated outside of the CEQA review process. Should any future agreement alter the project description or include physical improvements beyond or significantly different from what has been analyzed in the Draft EIR, the City of Belmont would be required to consider the environmental implications of such improvements, if any.
5-6 Conclusion. Closing remarks summarizing prior comments are noted for the record and require no further response.

2.5 Individual Responses to Comments

2.5.1 Response to Letter 6: Steven and Nina Goodale
6-1 Introductory Comments. General statement regarding concern for the project’s potential effects are noted for the record. Please see specific responses to the issues raised below.
6-2 Site Vulnerability and Current Conditions. The comment provides general information about the project location relative to Belmont Creek and the Belmont Slough and estuary. Similar setting information is provided on pages 13-2 and 13-3 of the Draft EIR.

Comments also suggest that the existing private sump pump at the site is located in an area subject to tidal inundation, and reports nearby stage gauge levels. These observations and information appear to provide background for other specific comments. The existing sump pump would remain on the project site, as shown in Figure 3-13 of the Draft EIR. As identified in Draft EIR Chapter 13, Hydrology and Water Quality, the project would result in a reduction of impervious surface of approximately 235
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58,000 square feet, thereby reducing the amount of stormwater flowing into the creek compared to existing conditions. No information in the comments is specific to the analysis provided in the Draft EIR, and therefore no further response to this comment is necessary.
6-3 Watershed Capacity and Flood Risks. The comment provides hydrological data and statistics for Belmont Creek, citing the 2019 Belmont Creek Watershed Management Plan. This plan, prepared for San Mateo County and the cities of Belmont and San Carlos, identify a series of flow conveyance and stormwater detention measures to manage creek flows into the future. The Draft EIR text has been updated, as shown below, to reference the plan for informational purposes and incorporated into the record.

Draft EIR, Page 13-10:

Belmont Creek Watershed Management Plan
The Belmont Creek Watershed Management Plan was prepared for San Mateo County, and the cities of Belmont and San Carlos, and adopted in 2019. The plan proposes flood risk reduction measures, green infrastructure, and water quality improvements to address flooding along Belmont Creek. Specifically, the plan targets improvements between Old County Road and Industrial Road in the City of Belmont, the City of San Carlos, unincorporated areas of the County, and the Caltrain tracks.

It is important to note that the measures proposed in the Belmont Creek Watershed Management Plan are located upstream from the project site and are not located within or immediately adjacent to the project site. Implementation of these measures, detention basins, and other improvements identified in the plan would serve to reduce peak flow volumes within the creek as it approaches the Bay. As such, the less than significant impacts related to flood risk in the project area analyzed on pages 13-15 through 13-18 of the Draft EIR could be decreased as a result of reduced peak flow volumes upstream. Moreover, no information in the comment is specific to the analysis provided in the Draft EIR. Therefore, the edits to the Draft EIR are provided for reference to potential improvements along Belmont Creek, but do not change the conclusions of the analysis within the Draft EIR. No further response is required. 6-4 Projected Sea Level Rise and its Implications. The comment notes projected sea level rise data for Belmont Creek, citing NOAA but with no specific document reference.

Please refer to Section 2.2.1 Master Response and response to Comment 1-7 and 1-8 regarding SLR and resiliency relative to the OPC’s 2024 guidance document and the Bay Plan.
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6-5 Ocean Protection Council Report (2024). The comment cites information and SLR projections contained within the OPC’s most current SLR guidance document. Additional comments regarding predicted changes in future storm and tide events are acknowledged but do not directly relate to the effects of the project on the environment. Please refer to Section 2.2.1 Master Response and response to Comments 1-7 and 1-8 regarding SLR and resiliency relative to the OPC’s 2024 guidance document and the Bay Plan.
6-6 Critical Concerns. The comment notes and summarizes several of the commenter’s concerns regarding site drainage performance, watershed drainage relative to tidal waters, and flooding potential.

With respect to high tides and site drainage, the project’s preliminary storm drainage analysis (BKF, 2023) documents that, with the on-site stormwater drainage controls, pervious surface materials and a reduction in impervious surface area, the post-project water volumes leaving the site during storm events will be reduced compared to existing (pre-development) conditions. As the commenter notes, the project would raise the site elevation by approximately 2 feet, such that groundwater would be approximately 5 feet below the new site grade. According to the OPC, the projected SLR in 2100 is 4.8 feet, which is within the 5-foot allowance. The sump pump rim would be raised to be at, or above, the new site grade, to prevent groundwater from flowing into the sump.

With the proposed drainage improvements, rise in base flood elevation by 2 feet, and incorporation of mid-century flood protection and end of century adaptation measures, the potential for site flooding will be reduced with the project. Over time, it is also assumed that specific upstream projects as identified in the Belmont Creek Watershed Management Plan would be implemented to further reduce flood risk and peak flows downstream.

With respect to the interface between Bay waters and waters of the Belmont Creek watershed, these water bodies are hydrologically connected under existing conditions.

As noted in the above response, post-project drainage conditions will reduce the amount of peak runoff created at the project site compared to existing conditions.

With respect to flood mitigation for existing and future scenarios, the project will raise the base flood elevation from 10 feet by 2 feet to +12 feet NAVD88, which will provide flood protection consistent with FEMA flood mapping. Extreme tides in the San Francisco Bay were assessed by BCDC in 2016, and a comprehensive study of tidal datums was published in 20213. The study identified a 100-year extreme tide level of 3 BCDC (2022). SF Bay Tidal Datums Web Application. San Francisco Bay Conservation & Development Commission.

Published: November 9, 2021. Updated: June 8, 2022. SF Bay Conservation and Develop Commission Open Data Portal: https://databcdc.opendata.arcgis.com/apps/BCDC::sf-bay-tidal-datums-web-application/explore 237
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elevation +10.45 feet NAVD88. Flooding associated with a 100-year extreme tide event could occur around 2061. The proposed strategy to adapt to SLR would be to raise the elevation of the Belmont Creek Trail to elevation+18.0 feet NAVD88. With these improvements, the proposed development would not be impacted by SLR until after the end of the century.

Please see Section 2.2.1 Master Response, as well as response to comments 1-7 through 1-9 regarding long term planning and resiliency to sea level rise, groundwater, and flooding.

Regarding the combination of extreme high tides and significant storm events, the comment is noted for the record and the project design and location is responsive to flood risk data and FIRM recognized by FEMA.
6-7 Conclusion and Request. Concluding comments summarize previously stated concerns regarding flooding potential, and request that the City consider: project feasibility (as related to flood risk); long term environmental and safety issues associated with development of life science laboratory uses; and comprehensive flood mitigation strategies.

See above responses. The issues raised and requests to the City all ultimately relate to flood risk and flood protection. As the project raises the base flood elevation by 2 feet above existing conditions, the project will be located at an elevation above the 100-year floodplain. The project design and location is responsive to flood risk data and FIRM recognized by FEMA, as well as the City of Belmont and the OPC 2024 guidance document. These are recognized benchmarks for engineering purposes and assessing flood risk. As noted above, the City of Belmont, along with the City of San Carlos and San Mateo County, have prepared the Belmont Creek Watershed Management Plan, which represents a comprehensive flood mitigation strategy for managing peak flows for Belmont Creek.

With respect to the life science laboratory use, the risk associated with the use and transport of hazardous materials associated with this proposed land use is evaluated in detail within Draft EIR Chapter 12, Hazards and Hazardous Materials. For the reasons stated above, raising the base flood elevation provides acceptable risk protection based on FEMA benchmarks and planning policy of the OPC 2024. 238
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2.6 Letters Received After the Public Comment Period

2.6.1 Response to Letter 7: San Mateo County Flood & Sea Level Rise Resiliency District (OneShoreline)
7-1 Planning Policy Guidance Consideration. Please refer to response to Comment 1-8 above regarding OneShoreline’s Planning Policy Guidance (PPG) document. The PPG document is considered an important local resource and its recommendations will be considered by the City of Belmont during project review. However, as a guidance document it is not necessary to include these recommendations and planning policies within the regulatory setting of the Draft EIR, and no further response is required. 7-2 BCDC Comment. The comment discusses properly reflecting BCDC jurisdictional boundaries in Draft EIR text as well as maps and figures. Please see response to Comment 1-2 for appropriate consideration of BCDC jurisdictional boundaries regarding maps and diagrams.
7-3 Sea Level Rise. The comment requests that the Draft EIR contents pertaining to SLR be updated to incorporate local guidance. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 regarding long term planning and resiliency to SLR and consideration of planning guidelines.
7-4 Regional Shoreline Adaptation Plan Guidance. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 regarding long term planning and resiliency to SLR and consideration of planning guidelines. Impacts would remain less than significant and additional adaptation measures are not necessary nor required for the project.
7-5 Drainage and Hydrology Analysis. The comment refers to the evaluation of site drainage and suggested considerations related to climate change, SLR, groundwater, and watershed drainage. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 through 1-10 regarding project features that address SLR, groundwater drainage, and flooding.
7-6 Groundwater Monitoring and Percolation. The comment expresses agreement with BCDC comments relating to monitoring rising groundwater and onsite drainage. Please see response to Comment 1-5 above. Rising groundwater is not a consequence of the project. CEQA requires the evaluation of physical environmental effects of a project upon the environment. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 regarding long term planning and resiliency to SLR and consideration of planning guidelines.
7-7 Sea Level Rise Language. The comment suggests clarity in language surrounding scenarios relating to SLR and flooding in the SLR Assessment Report. The suggestion is 239
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noted and further explanation regarding the SLR Assessment can be found in Section

2.2.1 Master Response.
7-8 FEMA Base Flood Elevation Consideration. The comment discusses local requirements regarding FEMA base flood elevation (BFE) standards and how that is incorporated into the project design. The project is located in FEMA Flood Zone X. There is no BFE required for this zone. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 regarding long term planning and resiliency to sea level rise and flooding, and how the FEMA BFE is further considered in the project details. 7-9 Overtopping. Please see Section 2.2.1 Master Response, as well as response to comments 1-7 and 1-9 for further discussion concerning flooding. 7-10 Critical Equipment Risk. The comment expresses concern over siting of critical equipment in areas at risk of flooding. Please see Section 2.2.1 Master Response regarding a SLR Assessment, as well as response to comments 1-7 and 1-9 for further discussion concerning flooding. These suggestions are comments noted for the record but do not raise substantive issues regarding the EIR analysis. No further response is necessary.
7-11 Conditions for Intervention. This comment is noted for the record. A second intervention is proposed based on the assumption of a timeline of 5 to 10 years for preproject planning, site investigations, concept design, detailed design, permitting, and construction. As the comment does not raise substantive issues specific to the EIR analysis, no further response is necessary.
7-12 Adaptation Assumptions Along Shoreline. The comment notes that the proposed project has vulnerabilities from other shoreline reaches regarding overtopping and flooding, affecting more than just the pathway adjacent to the slough. Please see Section 2.2.1 Master Response regarding the SLR Assessment, as well as response to comments 1-7 and 1-9 for further discussion concerning flooding. As the comment does not raise substantive issues specific to the EIR analysis, no further response is necessary. 7-13 Additional Resiliency Considerations. These suggestions regarding additional resilience measures are noted for the record but do not raise substantive issues regarding the EIR analysis. No further response is necessary.
7-14 Shoreline Infrastructure Recommendations. This comment concerning development standards for shoreline infrastructure has been noted for the record but does not raise substantive issues regarding the EIR analysis. No further response is necessary. 7-15 Bay Trail Design Guidelines. The trail along the eastern edge of the Project site is the Belmont Creek Trail, see Figure 3-4, Proposed Site Plan. The Bay Trail is located across Belmont Creek further east of the Project site and follows the north side of Twin Dolphin 240
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Drive, see Figure 3-3, Surrounding Land Uses. As such, the Project will not impact the Bay Trail and therefore will not be required to adhere to Bay Trail Design Guidelines. 7-16 Natural Infrastructure. The comment suggests incorporation of natural infrastructure into the shoreline area. This suggestion has been noted for the record but does not raise substantive issues regarding the EIR analysis. No further response is necessary. 7-17 FEMA Accredited Levee. Shoreline interventions would not result in a FEMA accredited levee. As the comment does not raise substantive issues specific to the EIR analysis, no further response is necessary.
7-18 Drainage Alteration. The comment summarizes the existing drainage setting into the Slough and inquires about alterations to the outfall. The existing outfall is to remain as is, with the addition of a backflow valve to ensure there will not be any water from the slough backing into the storm drain system. There is no anticipated increase in stormwater discharge from the project site into the slough. As the comment does not raise substantive issues specific to the EIR analysis, no further response is necessary. 7-19 Slough Maintenance. Comments regarding defining the maintenance requirements and accessibility to the slough are noted for the record. As the comment does not raise substantive issues specific to the EIR analysis, no further response is necessary.

2.7 Response to Comments Received at Planning Commission November 4, 2024
Summary of Comments
The Planning Commission met on the evening of November 4, 2024 to hold a public hearing and receive public comments on the Draft EIR. Several comments were made (and questions asked) by both members of the public and individual Commissions. Most of these comments and questions, however, addressed issues unrelated to the environmental analysis contained within the Draft EIR. The following summary of comments addresses only those issues relevant to the environmental review. The Minutes of the November 4 public hearing are included herein as Appendix B.

Commissioner Ademkewics asked who reviews the sufficiency of the Project TDM Plan. All proposed development projects must demonstrate compliance with the City’s TDM program by submitting a completed TDM application form along with all other applicable development or building permit forms. TDM submissions are subject to review and approval by the Department of Public Works (DPW). The TDM Plan is provided as Appendix I of the Draft EIR. 241
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Commissioner Majeski asked what is the standard for noise mitigation regarding the roof features, and does that adapt to changes? The rooftop noise mitigation features will meet the existing City standard and can go through applicable changes to remain as such.

Commissioner Gurevich asked does the level of noise from the highway affect the Project? The highway noise exists currently at the site, and the Project would not be considered a noise sensitive use. As such, the highway noise would not significantly impact the Project. 242
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3 Changes to the Draft EIR (EIR Errata)
Changes to the Draft EIR are shown on the following pages in the order that they appear in the Draft EIR. New text is shown in underline, and removed text is shown in strikethrough.

Additionally, Mitigation Measures MM Bio-1.2 and MM CR-2.1 have been revised for the purposes of clarity. These text changes do not constitute substantial new information (per CEQA Guidelines Section 15088.5) and do not result in significant new impacts or the increase in severity of impacts already disclosed. As such, recirculation of the Draft EIR is not triggered.

Draft EIR, page 1-4 to 1-5 and 7-16 to 7-17
MM BIO-1.1 Avoidance and Preconstruction Surveys
Seasonal Avoidance. Tree removal, demolition, and the start of construction activities shall be scheduled to avoid the nesting season for breeding and special status bird species. If such activities take place outside the nesting season, all impacts on nesting birds protected under the MBTA and California Fish and Game Code will be avoided. The nesting season for most birds in San Mateo County extends from February 1 through August 31, and January 15 through August 31 for CRRA.

In addition to the general surveys above, a qualified biologist shall conduct protocollevel surveys of CRRA and BLRA in suitable habitats adjacent to the project using the 2017 California Clapper Rail Survey Protocol.

Buffers. If an active nest is found within areas that would be disturbed by project activities, the biologist will determine the extent of a construction-free buffer zone to be established around the nest (typically 300 ft for raptors and 100 ft for other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code will be disturbed during project implementation.

If CRRA or BLRA are found in suitable habitat near the project site, a 700-foot no-work buffer shall be implemented between construction activity and any current-year breeding CRRA and BLRA detections if construction cannot be avoided during the rail 243
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breeding season. If a 700-foot buffer is not feasible, noise reduction through modification to equipment and/or implementation of acoustic barriers/blankets may be employed to attenuate noise and reduce visual impacts to breeding rails. Buffers and/or physical barriers shall be established in consultation with CDFW.

This will preclude the initiation of nests in this vegetation and prevent the potential delay of the project due to the presence of active nests in these substrates Draft EIR, pages 1-5 to 1-6 and 7-18:

MM BIO-1.2 Project Construction Precautionary Measures
Worker Environmental Awareness Program. Before any construction activities begin, a qualified biologist shall conduct a training session for all construction personnel. At a minimum, the training will include descriptions of the salt marsh harvest mouse and salt marsh wandering shrew, their habitats, the laws protecting them, the general measures that are being implemented to conserve these species as they relate to the project, and the boundaries within which the project may be accomplished. Upon completion of the Worker Environmental Awareness Program, all construction personnel shall sign an affidavit stating they attended the training and understand all information and protection measures presented. These forms shall be provided to the City prior to the commencement of construction activity and monthly prior to new personnel beginning work on the project.

Draft EIR, pages 1-11 and 8-13:

MM CR-2.1 Cultural Awareness Training
Prior to any project-related ground disturbance, all construction workers shall receive training overseen by a qualified professional archaeologist who is experienced in teaching non-specialists to ensure that contractors can recognize archaeological resources in the event that any are discovered during construction. The construction staff directly overseeing excavation, or operating ground-disturbing vehicles, will be required to participate in this preconstruction training. Upon completion of the preconstruction training, all construction personnel shall sign an affidavit stating they attended the training and understand all information and protection measures presented. These forms shall be provided to the City 244
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prior to the commencement of construction activity and monthly prior to new personnel beginning work on the project.

Draft EIR, page 7-15:

McAteer-Petris Act
The McAteer-Petris Act, enacted on September 17, 1965, serves as a legal provision under California State law to preserve San Francisco Bay from indiscriminate filling. The Act initially established the BCDC as a temporary State agency charged with preparing a plan for the long-term use of the San Francisco Bay. In August 1969, the McAteer-Petris Act was amended to make BCDC a permanent regulatory agency and to incorporate the policies of the Bay Plan. BCDC jurisdiction includes the San Francisco Bay and a 100-footwide band along the shoreline of the San Francisco Bay., as well as other areas not relevant to this particular project. The Bay shoreline is defined as all areas that are subject to tidal action from the south end of the San Francisco Bay to the Golden Gate (Point Bonita–Point Lobos), and to the Sacramento River line (a line between Stake Point and Simmons Point, extended northeasterly to the mouth of Marshall Cut), including.

The BCDC will claim all sloughs, and (specifically the marshlands lying between mean high tide and up to 5 feet above mean sea level where marsh vegetation is present); tidelands (lands lying between mean high tide and mean low tide); and submerged lands (land lying below mean low tide) in this region. The McAteer-Petris Act also provides that within the 100-foot shoreline band, the BCDC may deny an application for a permit on the grounds that the project fails to provide maximum feasible public access, consistent with the proposed project, to the Bay and its shoreline. requires that “maximum feasible public access, consistent with a project be included as part of each project to be approved by the BCDC.”
Draft EIR, page 13-5:

Draft EIR, page 13-8:

Pursuant to the CWA, in 2009, the SWRCB issued a statewide general NPDES Permit for stormwater discharges from construction sites (NPDES No. CAS000002). The NPDES permit was reissued in 2022 (Order WQ 2022-0057-DWQ). Under this reissued permit, discharges of stormwater from construction sites with a disturbed area of one or more 245
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acres must obtain individual NPDES permits or be covered by the General Permit—i.e., by filing a Notice of Intent with the SWRCB and developing and implementing a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP must contain a site map that shows the construction site perimeter, existing and proposed buildings, lots, roadways, stormwater collection and discharge points, general topography both before and after construction, and drainage patterns across the project site. The SWPPP must also list best management practices (BMPs) implemented on the construction site to protect/retain stormwater runoff, and must contain a visual monitoring program, a sampling, analysis, and monitoring requirement for "non-visible" pollutants, and a monitoring plan if the site discharges directly to a water body listed on the state’s 303(d) list of impaired waters.

Draft EIR, Page 13-10:

4.1 Public Resources Code
When approving projects with Environmental Impact Reports (EIRs) that identify significant impacts, the California Environmental Quality Act (CEQA) requires public agencies to adopt monitoring and reporting programs or conditions of project approval to mitigate or avoid the identified significant effects (Public Resources Code Section 21081.6(a)(1)). A public agency adopting measures to mitigate or avoid the significant impacts of a proposed project is required to ensure that the measures are fully enforceable, through permit conditions, agreements, or other means (Public Resources Code Section 21081.6(b)). The program must be designed to ensure project compliance with mitigation measures during project implementation.

The Mitigation Monitoring and Reporting Program (MMRP) is organized in a table format (see Table 4-1: Mitigation Monitoring and Reporting Program for the 1301 Shoreway Project, keyed to each significant impact and each EIR mitigation measure. Only mitigation measures adopted to address significant impacts are included in this program. Each mitigation measure is set out in full, followed by a tabular summary of monitoring requirements. The column headings in the tables are defined as follows:
 Mitigation Measures: This column presents the mitigation measure identified in the EIR.  Monitoring/Reporting Responsibility: This column contains an assignment of responsibility for the monitoring and reporting tasks.
 Timing of Implementation: This column refers to when the measure is required to be implemented.
 City Staff/Notes: This column will be used by the lead agency to document the person who verified the implementation of the mitigation measure and the date on which this verification occurred.

4.2 Enforcement
If the project is approved, the MMRP for the development would be incorporated as a condition of such approval. Therefore, all mitigation measures for significant impacts must be carried out to fulfill the requirements of approval. A number of the mitigation measures would be implemented during the course of the development review process. These measures would be checked on plans, in reports, and in the field prior to construction. Most of the remaining mitigation measures would be implemented during the construction, or project implementation phase.
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Table 4-1: Mitigation Monitoring and Reporting Program for the 1301 Shoreway Project Impact
Number Mitigation Measures Implementation Responsibility Agency Responsible
for Monitoring
City Staff
Notes, Initials
/ Date when
Done
Timing of
Implementation Monitoring Action Monitoring Frequency
Aesthetics
AES-1 MM AES-1.1 Construction
Screening
To minimize and soften the visual
effects of construction as seen
from nearby businesses and
adjacent land uses, the project
proponent shall incorporate
construction fencing or screening
around the perimeter of the site.

The screening material shall be of
sufficient height to mask groundlevel activities. Screening shall remain in place during site
preparation and new building
construction. Screening shall not
be necessary during the final
stages of construction when
architectural coatings, detailing
and landscaping are applied.

Project Applicant or
their designee
Construction
Contractor
Community
Development
Department Director
or their designee
Plan for
screening to be
submitted prior
to the issuance of
any building or
grading permits.

Measure to
remain in place
until final stages
of construction.

Incorporate
requirements into
the project plans,
construction
contracts and/or
construction bid
solicitation
materials.

Comply with
measures and
limitations.

During
project site
preparation
and
construction
activities up
to the final
stages of
construction.

AES-3 MM AES-3.1 Light/Glare
Reduction and Design
Prior to the issuance of building
permits, final improvement,
lighting and architectural plans
shall clearly demonstrate the light
glare reducing features and
finishes of the project. Lighting
and finishes shall be selected to
reduce reflective glare, bird strike,
Project Applicant or
their designee
Qualified Biologist
Community
Development
Department Director
or their designee
Project Applicant
to incorporate
light glare
reducing features
to minimize glare
as part of final
improvement
plans.

Submit project
plans to City
Community
Development
Department that
meet the
requirements of
the mitigation
measure.

Prior to
issuance of
building
permits.
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Impact
Number Mitigation Measures Implementation Responsibility Agency Responsible
for Monitoring
City Staff
Notes, Initials
/ Date when
Done
Timing of
Implementation Monitoring Action Monitoring Frequency
and light spill to neighboring
properties and habitat areas.

Peer review and
approval of the
above by a
qualified biologist
with appropriate
expertise.

Air Quality
AQ-2

MM AQ-1: Require Tier 4 Engines
on Construction Equipment1
All applicants proposing
development of projects within
Belmont shall require their
contractors, as a condition of
contract, to further reduce
construction-related exhaust
emissions by ensuring that all offroad equipment greater than 50 horsepower (hp) and operating for
more than 20 total hours over the
entire duration of construction
activities shall operate on an EPAapproved Tier 4 or newer engine.

Exemptions can be made for
specialized equipment where Tier
4 engines are not commercially
available within 200 miles of the
project site. The construction
contract must identify these
pieces of equipment, document
their unavailability, and ensure
that they operate on no less than
an EPA approved Tier 3 engine.

ARB regulations will result in the
Project Applicant or
their designee
Construction
Contractor
Community
Development
Department Director
or their designee
Prior to and
throughout the
duration of
construction
activities.

Incorporate
requirements into
the construction
contracts and/or
construction bid
solicitation
materials.

Comply with
measures and
limitations.

Prior to
issuance of
demolition
and/or
building
permits.

During all
project
construction
activities.
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Impact
Number Mitigation Measures Implementation Responsibility Agency Responsible
for Monitoring
City Staff
Notes, Initials
/ Date when
Done
Timing of
Implementation Monitoring Action Monitoring Frequency
percentage of Tier 4 engines
increasing over the next several
years.

MM AQ-3: Require Low-VOC
Coatings During Construction1
All applicants proposing
development of projects within
Belmont shall require their
contractors, as a condition of
contract, to reduce constructionrelated fugitive ROG emissions by ensuring that low-VOC coatings
that have a VOC content of 10
grams/liter (g/L) or less are used
during construction. The project
applicant will submit evidence of
the use of low-VOC coatings to
BAAQMD prior to the start of
construction.

Construction
Contractor
BAAQMD Air Quality
Inspector
Community
Development
Department Director
or their designee
Prior to the start
of construction.

Incorporate
requirements into
the construction
contracts and/or
construction bid
solicitation
materials.

Comply with
measures and
limitations.

Prior to
issuance of
demolition
and/or
building
permits.

During all
project
construction
activities.

MM AQ-4: Require Fugitive Dust
Best Management Practices1
All applicants proposing
development of projects within
Belmont shall require their
contractors, as a condition of
contract, to reduce constructionrelated fugitive dust by implementing BAAQMD’s basic
control measures at all
construction and staging areas.

The following measures are based
Project Applicant or
their designee
Construction
Contractor
Community
Development
Department Director
or their designee
Throughout the
duration of
construction
activities.

Incorporate
requirements into
the construction
contracts and/or
construction bid
solicitation
materials.

Respond to any
dust complaints.

Prior to
issuance of
demolition
and/or
building
permits.

During all
project
construction
activities.
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Impact
Number Mitigation Measures Implementation Responsibility Agency Responsible
for Monitoring
City Staff
Notes, Initials
/ Date when
Done
Timing of
Implementation Monitoring Action Monitoring Frequency
on BAAQMD’s current CEQA
guidelines.
• All exposed surfaces (e.g.,
parking areas, staging
areas, soil piles, graded
areas, and unpaved
access roads) will be
watered two times per
day.
• All haul trucks
transporting soil, sand, or
other loose material
offsite will be covered.
• All visible mud or dirt
track-out onto adjacent
public roads will be
removed using wet
power vacuum street
sweepers at least once
per day. The use of dry
power sweeping is
prohibited.
• All vehicle speeds on
unpaved roads,
driveways, or driving
surfaces shall be limited
to 15 mph.
• All roadways, driveways,
and sidewalks to be
paved will be completed
as soon as possible.

Building pads will be laid
as soon as possible after
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Impact
Number Mitigation Measures Implementation Responsibility Agency Responsible
for Monitoring
City Staff
Notes, Initials
/ Date when
Done
Timing of
Implementation Monitoring Action Monitoring Frequency
grading unless seeding or
soil binders are used.

Post a publicly visible sign with the
telephone number and the name
of the person to contact at the
lead agency regarding dust
complaints. This person will
respond and take corrective action
within 48 hours. The phone
number of the District will also be
visible to ensure compliance.

Biological Resources
BIO-1 MM BIO-1.1 Avoidance and
Preconstruction Surveys
Seasonal Avoidance. Tree
removal, demolition, and the start
of construction activities shall be
scheduled to avoid the nesting
season for breeding and special
status bird species. If such
activities take place outside the
nesting season, all impacts on
nesting birds protected under the
MBTA and California Fish and
Game Code will be avoided. The
nesting season for most birds in
San Mateo County extends from
February 1 through August 31, and
January 15 through August 31 for
CRRA.

Preconstruction/Pre-disturbance
Surveys. If it is not possible to
Project Applicant
CDFW and USFWSapproved Biologist
Community
Development
Department Director
or their designee
Applicant to
schedule on-site
tree removal,
demolition, and
grading to occur
outside of the
nesting and
breeding season
(February 1
through
September 1 and
January 15
through August
31) to avoid nest
disturbance.

If surveys are
required, results
shall be
submitted to the
Community
Development
Community
development
Department to
review and confirm
any potentially
required survey
results.

Prior to tree
removal.

During all
project
construction
activities.
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schedule construction activities
between September 1 and January
3114, then preconstruction
surveys for nesting birds shall be
conducted by a qualified biologist
to ensure that no nests of
migratory birds will be disturbed
during project implementation.

These surveys shall be conducted
no more than 7 days prior to the
initiation of tree removal,
demolition, ground disturbance, or
construction activities for each
construction phase. During this
survey, the biologist will inspect all
trees and other potential nesting
habitats (e.g., trees, shrubs,
buildings, and the ground) in and
immediately adjacent to the
impact areas for migratory bird
nests.

In addition to the general surveys
above, a CDFW and USFWSapproved biologist shall conduct protocol-level surveys of CRRA and
BLRA in suitable habitats adjacent
to the project using the 2017
California Clapper Rail Survey
Protocol.

Buffers. If an active nest is found
within areas that would be
disturbed by project activities, the
ornithologist will determine the
Department prior
to
commencement
of site work/tree
removal.
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extent of a construction-free
buffer zone to be established
around the nest (typically 300 ft
for raptors and 100 ft for other
species), to ensure that no nests
of species protected by the MBTA
and California Fish and Game Code
will be disturbed during project
implementation.

If CRRA or BLRA are found in
suitable habitat near the project
site, a 700-foot no-work buffer
shall be implemented between
construction activity and any
current-year breeding CRRA and
BLRA detections if construction
cannot be avoided during the rail
breeding season. If a 700-foot
buffer is not feasible, noise
reduction through modification to
equipment and/or
implementation of acoustic
barriers/blankets may be
employed to attenuate noise and
reduce visual impacts to breeding
rails. Buffers and/or physical
barriers shall be established in
consultation with CDFW.

Inhibition of Nesting. If
construction activities will not be
initiated until after the start of the
nesting season, all potential
nesting substrates (e.g., bushes,
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trees, grasses, and other
vegetation) that are scheduled to
be removed by the project may be
removed prior to the start of the
nesting season (e.g., prior to
February 1 or January 15). This will
preclude the initiation of nests in
this vegetation and prevent the
potential delay of the project due
to the presence of active nests in
these substrates.

MM BIO-1.2 Project Construction
Precautionary Measures
Worker Environmental
Awareness Program. Before any
construction activities begin, a
qualified biologist shall conduct a
training session for all
construction personnel. At a
minimum, the training will include
descriptions of the salt marsh
harvest mouse and salt marsh
wandering shrew, their habitats,
the laws protecting them, the
general measures that are being
implemented to conserve these
species as they relate to the
project, and the boundaries within
which the project may be
accomplished. Upon completion
of the Worker Environmental
Awareness Program, all
construction personnel shall sign
Project Applicant
Qualified Biologist
Community
Development
Department Director
or their designee
Construction
awareness
training and
barrier and
fencing
installation to
occur prior to any
demolition or
construction
activities.

If a salt marsh
harvest mouse,
salt marsh
wandering
shrew, or an
animal that could
be one of these
species is
observed on the
project site, all
construction
activities will be
Community
Development
Department to
review and provide
confirmation of
reception of
monthly
construction
personnel list.

Community
Development
Department to
verify required
measures.

Prior to
construction
activities.

During all
project site
preparation
and
construction
activities.
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an affidavit stating they attended
the training and understand all
information and protection
measures presented. These forms
shall be provided to the City prior
to the commencement of
construction activity and monthly
prior to new personnel beginning
work on the project.

Exclusion Barrier. Prior to the start
of construction activities along the
eastern edge of the project site, a
barrier will be installed at the
outer limits of the work area on
the east side of the project site to
exclude salt marsh harvest mice
and salt marsh wandering shrews
from the project site. This barrier
will consist of a 3-ft tall, tight
cloth, smooth plastic, or sheetmetal (or similar material) fence toed into the soil at least 3 inches
deep and supported with stakes
placed on the inside of the barrier.

Following the installation of the
barrier, designated construction
personnel will check its integrity
each morning that construction
activities occur and will initiate
repairs immediately as needed.

Environmentally Sensitive Area
Fencing. Prior to the start of
construction activities along the
halted until a
qualified biologist
is able to handle
the discovered
species.
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eastern edge of the project site,
the project limits on the east side
of the site will be clearly
demarcated with highly visible
Environmentally Sensitive Area
fencing to avoid inadvertent
disturbance of any habitat outside
of the designated construction
area during construction activities.

This fencing may be combined
with the exclusion barrier but
must not be outside that barrier.

Immediate Work Stoppage. If a
salt marsh harvest mouse, salt
marsh wandering shrew, or an
animal that could be one of these
species is observed on the project
site during project activities, all
work that could result in the injury
or death of the animal will stop
immediately and a qualified
biologist will be immediately
notified. The animal will be
allowed to leave the area on its
own and shall not be handled
except by a qualified biologist
authorized to do so.

MM BIO-1.3 Water Quality
During construction, the
contractor shall employ the
following measures to treat and
Construction
Contractor
Community
Development
Department Director
or their designee
Throughout the
duration of
construction
activities.

Incorporate
requirements into
the project plans,
construction
contracts and/or
construction bid
During
project site
preparation
and
construction
activities.
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minimize runoff from the project
site.
• All relevant erosion
control, sediment control,
source control, treatment
control, material
management, and
stormwater management
measures consistent with
the latest edition of the
California Stormwater
Quality Association
“Stormwater Best
Management Practices
Handbook,” will be
implemented.
• Spill prevention kits shall
always be in close
proximity when using
hazardous materials (e.g.,
crew trucks and other
logical locations).
• If any fueling of
equipment needs to
occur in areas directly
draining to the wetlands
along Belmont Creek,
containment shall be
provided in such a
manner that any
accidental spill of fuel
shall not be able to enter
the water or contaminate
solicitation
materials.

Comply with
measures and
limitations.
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sediments that may come
in contact with water.
• A hazardous materials
management/fuel spill
containment plan will be
developed and
implemented by the
construction contractor
and given to all
contractors working on
the project, with at least
one copy of the plan
located on the site at all
times.
• Vehicles will be checked
daily for oil or fuel leaks
and will be washed only
at an approved area. No
washing of vehicles will
occur within areas
directly draining to the
wetlands along Belmont
Creek.
• Within 100 ft of tidal
wetlands along Belmont
Creek, the work site,
areas adjacent to the site,
and access areas will be
maintained in an orderly
condition, free and clear
from debris and
discarded materials.

Personnel will not sweep,
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grade, or flush surplus
materials, rubbish, debris,
or dust onto adjacent
areas or wetlands or
waterways. Upon
completion of work, all
building materials, debris,
unused materials,
concrete forms, and
other constructionrelated materials will be
removed from the project
site.
• Stockpiled materials in
areas draining to the tidal
wetlands along Belmont
Creek will be covered by
plastic sheeting, tarps, or
similar material that can
be secured during wind
and rain. A sediment
fence or berm will be
installed around
stockpiled dredged
material to prevent
runoff from transporting
sediment into sensitive
habitats (such as
wetlands and open
waters).
• Water conservation
methods will ensure that
water used in the project
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site does not create
surface flows capable of
carrying pollutants to the
nearby slough channel.
• Silt fencing will be
erected along the limits
of disturbance between
the project site and
wetlands along Belmont
Creek during construction
activities that could
potentially result in
siltation of wetlands and
open waters of Belmont
Creek.

MM BIO-1.4 Project Lighting
The following measures shall be
identified on the project’s final
improvement plans and
incorporated into the project
design to reduce the effects of
glare or increased luminance
experienced by migratory birds
and wildlife using Belmont Creek:
• Exterior lighting shall be
minimized (e.g., by
turning lights off) in
accordance with
recommendations from
the International DarkSky Association (2011)
from midnight until
Project Applicant or
designee
Qualified biologist
Community
Development
Department Director
or their designee
Prior to approval
of project plans.

Submit project
plans to City
Building Division
that meet the
requirements of
the mitigation
measure.

Peer review and
approval of the
above by a
qualified biologist
with appropriate
expertise.

Prior to
issuance of
building
permits.
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dawn, at a minimum,
except as needed for
safety and City code
compliance.
• Spillage of lighting from
building interiors shall be
minimized using
occupancy sensors,
dimmers, or other
mechanisms from
midnight until dawn, at a
minimum, during bird
migration seasons
(February–May and
August–November). This
measure may be
voluntarily implemented
year-round.

BIO-4 MM BIO -4.1 Bird Safe Building
Design
Glazing on identified bird hazards
(the east and north facades of
Building 1 and all facades of
Building 2) will be treated with a
bird-safe glazing treatment such
that no more than 10% of the total
façade area from 0–60 feet above
grade consists of untreated
glazing. Bird-friendly glazing
includes, but is not limited to,
opaque glass, covering the outside
Project Applicant or
designee
Community
Development
Department Director
or their designee
Prior to approval
of project plans.

Submit project
plans to City
Building Division
that meet the
requirements of
the mitigation
measure.

Prior to
issuance of
building
permits.
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surface of clear glass with
patterns, paned glass with
fenestration, frit or etching
patterns, and external screens
over nonreflective glass. Highly
reflective glass is not permitted.

Bird-safe glazing shall have the
following parameters:
o Vertical
elements of the
window patterns
should be at
least 0.25 inches
wide at a
maximum
spacing of four
inches and/or
have horizontal
elements at least

0.125 inches
wide at a
maximum
spacing of two
inches; OR
o Bird-safe glazing
shall have a
Threat Factor
less than or
equal to 30.

To reduce reflections of clouds
and vegetation in glass and help
ensure that bird-safe treatments
on the lower surfaces of glass are
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visible below any reflections, all
glazing on the buildings will have a
visible reflectance of 15% or
lower. These features shall be
included in final improvement
plans.

Cultural Resources
CR-2 MM CR-2.1 Cultural Awareness
Training
Prior to any project-related
ground disturbance, all
construction workers shall receive
training overseen by a qualified
professional archaeologist who is
experienced in teaching nonspecialists to ensure that
contractors can recognize
archaeological resources in the
event that any are discovered
during construction. The
construction staff directly
overseeing excavation, or
operating ground-disturbing
vehicles, will be required to
participate in this preconstruction
training. Upon completion of the
preconstruction training, all
construction personnel shall sign
an affidavit stating they attended
the training and understand all
information and protection
measures presented. These forms
shall be provided to the City prior
Construction
Contractor
Qualified Archaeologist
Community
Development
Department Director
or their designee
Prior to ground
disturbing
activities.

Community
Development
Department to
review and provide
confirmation of
reception of
monthly
construction
personnel list.

Prior to
ground
disturbing
activities.

During all
ground
disturbance
activities.
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to the commencement of
construction activity and monthly
prior to new personnel beginning
work on the project.

MM CR-2.2 Inadvertent Discovery
of Archaeological Resources
If unknown precontact or historicperiod archaeological materials are encountered during project
activities, all work in the
immediate vicinity of the find shall
halt until a qualified archaeologist
can evaluate the find and make
recommendations. Cultural
resources materials may include
precontact resources such as
flaked and ground stone tools and
debris, shell, bone, ceramics, and
fire-affected rock as well as
historic resources such as glass,
metal, wood, brick, or structural
remnants. If the qualified
archaeologist determines that the
discovery represents a potentially
significant cultural resource,
additional investigations shall be
required to mitigate adverse
impacts from project
implementation. These additional
studies may include, but are not
limited to, recordation,
archaeological excavation, or
significance evaluation.

Construction
Contractor
Qualified Archaeologist
Community
Development
Department Director
or their designee
During ground
disturbing
activities; prior to
issuance of
grading permit.

Community
Development
Department to
verify language is
included in grading
plans.

Prior to
issuance of
grading
permits.
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The applicant shall inform its
contractor(s) of the sensitivity of
the project site for archaeological
deposits and include the following
directive in the appropriate
contract documents:
“The subsurface of the
construction site may contain
archaeological deposits. If
archaeological deposits are
encountered during project
subsurface construction, all
ground-disturbing activities within
25 feet shall be redirected and a
qualified archaeologist shall assess
the situation, consult with
agencies as appropriate, and make
recommendations for the
treatment of the discovery.

Project personnel shall not collect
or move any archaeological
materials. Archaeological deposits
can include, but are not limited to,
shellfish remains; bones, including
human remains; flakes of, and
tools made from, obsidian, chert,
and basalt; mortars and pestles;
historical trash deposits containing
glass, ceramics, and metal
artifacts; and structural remains,
including foundations and wells.”
The City shall verify that the
language has been included in the
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grading plans prior to issuance of a
grading permit or permit for other
project actions that include
ground-disturbing activities on the
project site.

CR-3 MM CR-3.1 Inadvertent Discovery
of Human Remains
In the event that human remains
are identified during project
construction, the remains will be
treated in accordance with
California Health and Safety Code
Section 7050.5 and PRC Section
5097.98, as appropriate. In the
event of the discovery or
recognition of any human remains
in any location other than a
dedicated cemetery, Section
7050.5 of the California Health
and Safety Code states that there
shall be no further excavation or
disturbance of the site or any
nearby area reasonably suspected
to overlie adjacent remains until
the coroner of the county in which
the remains were discovered has
determined whether or not the
remains are subject to the
coroner’s authority. If the human
remains are of Native American
origin, the coroner must notify the
NAHC within 24 hours of
identification. The NAHC will
Construction
Contractor
Qualified Archaeologist
San Mateo County
Coroner
California Native
American Heritage
Commission
San Mateo County
Coroner
During ground
disturbing
activities.

Compliance if any
human remains are
discovered on the
project site.

During all
grounddisturbing
activities.
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identify a Native American MLD to
inspect the site and provide
recommendations for the proper
treatment of the remains and
associated grave goods. PRC
Section 5097.98 states that the
NAHC, upon notification of the
discovery of Native American
human remains, pursuant to
California Health and Safety Code
Section 7050.5, shall immediately
notify those persons (i.e., the
MLD) it believes to be descended
from the deceased. With
permission of the landowner or a
designated representative, the
MLD may inspect the remains and
any associated cultural materials
and make recommendations for
the treatment or disposition of the
remains and associated grave
goods. The MLD shall provide
recommendations or preferences
for treatment of the remains and
associated cultural materials
within 48 hours of being granted
access to the site.

Geology & Soils
GEO-6 MM GEO-6.1 Final Geotechnical
Evaluation
A final construction level
geotechnical evaluation shall be
required for the project. The
Project Applicant or
their designee
Qualified Engineer
Community
Development
Department Director
or their designee
Prior to the
issuance of
building permits.

Review and
approval of the
Geotechnical
Evaluation.

Prior to the
issuance of
building
permits.
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project shall be required to adhere
to and incorporate all standards
and recommended engineering
measures to mitigate for
settlement concerns related to
lateral spreading from
compression of underlying nearsurface soils layers and Bay Mud layers. The final geotechnical
evaluation will be provided to the
City for review and approval prior
to the issuance of building permits
GEO-7 MM GEO-7.1 Inadvertent
Discovery of Paleontological
Resources
In the event that fossils or fossilbearing deposits are discovered during construction activities,
work shall be temporarily halted
with a 25-foot radius of the
discovered materials and workers
should avoid altering the materials
and their context until a qualified
paleontologist has evaluated the
situation and provided
appropriate recommendations.

Construction and potential
impacts to the area(s) within a
radius determined by the
paleontologist shall not
recommence until the assessment
is complete.

Project Applicant or
their designee
Construction
Contractor
Qualified
Paleontologist
Community
Development
Department Director
or their designee
During ground
disturbing
activities.

Compliance if any
human remains are
discovered on the
project site
During all
ground
disturbing
activities.
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If it is determined that the
proposed development could
damage unique paleontological
resources, mitigation shall be
implemented in accordance with
Public Resources Code Section
21083.2 and Section 15126.4 of
the CEQA Guidelines. Possible
mitigation under Public Resources
Code Section 21083.2 requires
that reasonable efforts be made
for resources to be preserved in
place or left undisturbed. If
preservation in place is not
feasible, the applicant shall
mitigate significant effects.

Excavation as mitigation shall be
limited to those parts of resources
that would be damaged or
destroyed by a project. Possible
mitigation under CEQA
emphasizes preservation-in-place
measures, including planning
construction avoid paleontological
sites, incorporating sites into parks
and other open spaces, covering
sites with stable soil, and deeding
the site into a permanent
conservation easement. Under
CEQA Guidelines, when
preservation in place is not
feasible, data recovery through
excavation shall be conducted
with a data recovery plan in place.
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Hazards & Hazardous Materials
HAZ-1 MM HAZ-1.1 Pre-Demolition
Surveys and Management Plan
Prior to demolition and removal of
material from the site, the project
applicant shall conduct surveys
and testing for asbestos containing
building materials (ACBMs), lead
based paints and products,
mercury and polychlorinated
biphenyl caulking products. If such
materials are not identified, no
further action is required. If these
materials are identified, the
applicant shall prepare and
implement an Operation and
Management (O&M) Plan for
removal and disposal. The O&M
Plan shall be prepared consistent
with National Emissions Standards
for Hazardous Air Pollutants
(NESHAP) guidelines for the
removal of potentially friable
ACBMs and other materials if
present. The plan shall be
reviewed and approved by the City
of Belmont prior to
implementation. Removal and
disposal work will be completed
pursuant to all federal, State and
local regulations by certified
professionals.

Project Applicant or
their designee
City Building Official
Community
Development
Department Director
or their designee
Prior to
demolition and
material removal
activities.

Review and
approve O&M
Plan, if specified
materials are
identified.

Prior to
issuance of
demolition or
construction
permits.
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HAZ-1 MM HAZ-1.2 Imported Fill
Prior to depositing fill on the
project site, all imported soil and
fill material shall be tested to
ensure any contaminants of
concern are within DTSC and U.S.

Environmental Protection Agency
Regional Screen Levels for the
intended land use. To minimize
the possibility of introducing
contaminated soil and fill material
the applicant shall document the
origins of the soil or fill material
and, if applicable, conduct
sampling to ensure that the
imported soil and fill material
meets screening levels outlined in
the Preliminary Endangerment
Assessment (PEA) Guidance
Manual.

Project Applicant or
their designee
Community
Development
Department Director
or their designee
Prior to filldepositing
activities.

Review
documented
origins of soil and
fill material.

Prior to filldepositing
activities.

HAZ-1 MM HAZ-1.3 Management of
Potentially Hazardous Materials
If BSL 3 certification is pursued,
the life science laboratory/office
buildings shall be designed and
constructed as BSL 3 facilities. For
any BSL level, the project sponsor
shall independently pursue and
obtain all necessary federal, state
and local approvals, permits,
certifications and/or licenses for
the design, operation, transport,
use and disposal of materials used.

Project Applicant or
their designee
City Building Official.

Community
Development
Department Director
or their designee
Prior to building
occupancy.

Review proof of
compliance and all
related BSL 3
management
plans.

Prior to
building
occupancy.
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Proof of compliance and all
related management plans shall
be provided to the City of Belmont
prior to building occupancy.

HAZ-2 MM HAZ-2.1 Emergency
Response Plan and First
Responder Training
Prior to building occupancy for BSL
3 use, the project sponsor or lab
operator shall prepare and submit
an emergency response plan to
the City of Belmont and San
Mateo Consolidated Fire
Department (SMC Fire) tailored to
the specific lab operations,
hazardous materials and class of
pathogens expected to be present.

Based on those specific pathogens
or other hazardous substances,
the project sponsor or lab
operator shall also conduct
specialized training and education
session(s) with SMC Fire hazmat
personnel and the Redwood City
Fire Department regarding lab
operations. This training shall be
specific to the biohazards present
at the facility, strategy for
response and potential need for
specialized equipment and/or
vaccination protocols, if
warranted. Training shall be
Project Applicant or
their designee
City Building Official
SMC Fire
Redwood City Fire
Department
Community
Development
Department Director
or their designee
SMC Fire
Prior to building
occupancy.

Review and
approve the BSL 3
emergency
response plan for
the project.

Conduct
specialized training
and education
session(s)
Prior to
building
occupancy.

As needed
during BSL 3
operations.
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periodic and updated as needed
based on the biohazards present.

Noise & Vibration
N-1 MM N-1.1 Construction Noise
Control Plan
The applicant shall identify sitespecific noise attenuation measures to be included with
construction plans to reduce noise
to levels below the FTA threshold
of 80 dBA Leq. Prior to
commencement of construction
activities, the applicant shall
submit the construction noise
control plan to the city for review
and approval. Noise attenuation
measures shall be identified in the
plan and implemented to reduce
noise levels to the greatest extent
feasible. Noise measures may
include, but are not limited to, the
following:
• Using smaller equipment
with lower horsepower or
reducing the hourly
utilization rate of equipment
on the site to reduce noise
levels at 50 feet to the
allowable level.

Project Applicant or
their designee
Construction
Contractor
Community
Development Director
or their designee
Prior to
commencement
of construction
activities.

Review and
approve the
prepared
construction noise
control plan.

Prior to the
issuance of
any
construction
permit.
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• Locating construction
equipment as far as feasible
from noise-sensitive uses.
• Requiring that all
construction equipment
powered by gasoline or diesel
engines have sound control
devices that are at least as
effective as those originally
provided by the
manufacturer and that all
equipment be operated and
maintained to minimize noise
generation.
• Prohibiting gasoline or
diesel engines from having
unmuffled exhaust systems
• Not idling inactive
construction equipment for
prolonged periods (i.e., more
than 2 minutes).
• Constructing a solid
plywood barrier around the
construction site and
adjacent to operational
businesses, residences, or
other noise-sensitive land
uses.
• Using temporary noise
control blanket barriers.
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Done
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• Monitoring the
effectiveness of noise
attenuation measures by
taking noise measurements.
• Using “quiet” gasolinepowered compressors or
electrically powered
compressors and electric
rather than gasoline- or
diesel-powered forklifts for
small lifting.

N-1 MM N-1.2 Reduce Noise from
Project Mechanical Equipment
To reduce potential noise effects
resulting from project heating,
cooling, and ventilation
equipment as well as project
emergency generators at the
proposed project, a supplemental
noise analysis shall be prepared to
estimate the actual noise levels of
project-specific equipment once
the equipment models and design
features to attenuate noise have
been selected. The analysis shall
be conducted prior to the issuance
of building permits and shall be
prepared by persons qualified in
acoustical analysis and/or
engineering, demonstrating with
reasonable certainty that the
mechanical equipment selected
for the project and the
Project Applicant or
their designee
Qualified Acoustical
Analystand/or
Engineering
Professional
Community
Development
Department Director
or their designee
Prior to the
issuance of
building permits
Review and
approve project
plans with
incorporated
acoustical analysis
recommendations.

Prior to the
issuance of
building
permits.
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attenuation features incorporated
into project design would not
result in an exceedance of the
applicable City noise standards of
45 dBA Leq and 65 dBA Lmax during
the nighttime and 55 dBA Leq and
70 dBA Lmax during the daytime.

Options to reduce noise from
heating and cooling equipment
include enclosing equipment in
mechanical equipment rooms,
shielding equipment with
mechanical screens at least as tall
as the equipment, and selecting
quieter equipment models.

Transportation and Circulation
TRA-1 MM TRA-1 Final Transportation
Demand Management Program
Prior to occupancy, the project
shall prepare and implement a
final transportation demand
Project Applicant or
their designee
Community
Development Director
or their designee
Prior to building
occupancy.

Conduct annual
review of the
project’s TDM
Plan.

Prior to
building
occupancy
and annually,
or as
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management (TDM) program to
reduce the project’s VMT to below
the significance threshold as noted
in Table 17-1. The program
includes encouraging employees
to use alternative modes of
transportation to single-occupant
vehicles. The City of Belmont has
an adopted TDM policy requiring
projects that exceed 50,000
square feet to achieve 18 TDM
points. Compliance with the city’s
TDM policy would reduce the
project trips and the VMT by an
estimated 15 percent or more,
which would be more than the
required 7.4 percent reduction
needed if using the C/CAG VMT
estimation tool and the 6.0
percent reduction needed if using
the C/CAG travel demand model.

The effectiveness of the TDM plan
shall be reviewed annually and
adjusted as necessary to maintain
these trip and VMT reductions.
adjusted,
thereafter.

TRA-2 TRA-2 Transit Improvements
To enhance transit service and
facilities consistent with City
policy, the project sponsor shall
coordinate with the City and
Commute.org to reestablish local
shuttle service such as the
Redwood LIFE Caltrain shuttle stop
Project Applicant or
their designee
Department of Public
Works Director or their
designee
Department of Public
Works Director or
their designee
Prior to building
occupancy and
throughout
project
operations.

Reestablish local
shuttle services.

Throughout
project
operations.
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at the project site that connects to
the San Carlos Belmont Caltrain
Station and Redwood Shores
community. Because the
feasibility, demand and location of
additional shuttle stops are
ultimately determined by
Commute.org and the transit
operator, the applicant’s
responsibility is limited to
supporting a shuttle stop on the
property, participating in
applicable employer-based
funding mechanisms, identifying a
shuttle stop location on the
project’s final improvement plans,
and promoting use of the shuttle
and alternative modes of
transportation through the
project’s TDM program.

Tribal Cultural Resources
TR-2 Refer to MM CR-2.1, MM CR-2.2,
and MM CR-3.1.

Refer to MM CR-2.1,
MM CR-2.2, and MM
CR-3.1.

Refer to CR-2.1,
MM CR-2.2, and
MM CR-3.1.

Refer to MM CR2.1, MM CR-2.2,
and MM CR-3.1.

Refer to MM
CR-2.1, MM
CR-2.2, and
MM CR-3.1.

Utilities & Service Systems
UTIL-1 Refer to MM N-1.1, MM AES-1.1,
MM AQ-1, MM AQ-3, and MM AQ4.

Refer to MM AES-1.1,
MM AQ-1, MM AQ-3,
and MM AQ-4.

Refer to MM
AES-1.1, MM AQRefer to MM AES1.1, MM AQ-1,
Refer to MM
AES-1.1, MM
AQ-1, MM
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/ Date when
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1, MM AQ-3, and
MM AQ-4.

MM AQ-3, and
MM AQ-4.

AQ-3, and
MM AQ-4.
1 MM AQ-1, MM AQ-3, and MM AQ-4 were established in the City’s General Plan EIR document and are included, as applicable, to mitigate potential air quality impacts related to the project.
280
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Appendix A: Written Public Comments Received on the Draft EIR 281
1-1
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Docusign Envelope ID: 01 FB5191-3ECD-4F9D-B87C-E624542E1 C98 .

San Francisco Bay Conservation and Development Commission 375 Beale Street, Suite 510, San Francisco, California 94105 tel 415 352 3600 fax 888 348 5190 State of California I Gavin Newsom- Governor I [email protected] I www.bcdc.ca.qov November 22, 2024
City of Belmont
1 Twin Pines Ln, Suite 310
Belmont, CA 94002
ATTN: Carlos de Melo, Community Development Director
Via E-mail: [email protected]
SUBJECT: Comments on the Draft Environmental Impact Report for the 1301 Shoreway Project; BCDC Inquiry File No. SM.BM.2024.01
Dear Carlos,
Thank you for the opportunity to comment on the Draft Environmental Impact Report {DEIR) for the 1301 Shoreway Project (Project).

The San Francisco Bay Conservation and Development Commission (BCDC) is providing the following comments as a responsible agency with discretionary approval power over aspects of the Project, as described below. BCDC will rely on the Final EIR when considering its approvals for the Project, and we appreciate this opportunity to comment on the information and analyses presented in the DEIR. The Commission itself has not reviewed the DEIR; the following comments are based on BCDC staff review of the DEIR, the McAteer-Petris Act (Title 7.2 of the California Government Code), and the San Francisco Bay Plan (Bay Plan).

San Francisco Bay Conservation and Development Commission BCDC is a State planning and regulatory agency with permitting authority over San Francisco Bay, the Bay shoreline, and Suisun Marsh, as established in the McAteer-Petris Act and the Suisun Marsh Preservation Act. Per the McAteer-Petris Act, BCDC is responsible for granting or denying permits for any proposed fill; extraction of materials; or substantial changes in use of any water, land, or structure within the Commission's jurisdiction {Government Code Section 66632). Additionally, BCDC establishes land use policies for the Bay as a resource and for development of the Bay and shoreline in the Bay Plan, which provides the basis for the Commission's review and actions on proposed projects.

BCDC Jurisdiction
The Project site is partially located within the shoreline band area of BCDC's permitting jurisdiction, consisting of all territory located between the shoreline of the Bay and 100 feet landward of and parallel with the shoreline (Government Code Section 66610[b]). The Project team has previously worked with BCDC staff to map the limits of this jurisdictional area. Areas in the shoreline band jurisdiction include the shoreline, most of the open space and public access amenities, and portions of the surface parking lot located near Belmont Creek. 282
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Docusign Envelope ID: 01 FB5191 -3ECD-4F9D-BB7C-E624542E1 C9B 1301 Shoreway Project
BCDC Inquiry File No. SM .BM .2024.01

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Belmont City CouncilFebruary 24, 2026

Belmont City Council
February 24, 2026