Colma City Council
March 23, 2022

state scenic highway. Although the Town of Colma contains wide areas of open spaces that provide scenic value to the town, there are no officially designated scenic vistas or highways within the Planning Area. Accordingly, the Project would not damage scenic resources within a state scenic highway.

For these reasons and the reasons discussed in the EIR, the Project would have a less than significant impact relating to this issue and no mitigation measures are required. (Draft EIR, pp. 4.1-6 through 4.1-7.)

3. Visual Character
Threshold: In non -urbanized areas, would the project substantially degrade the existing visual character or quality of public view of the site and its surroundings?
Finding: Less than significant. (Draft EIR, p. 4.1-8.)
Explanation: The 2040 General Plan Update would not substantially degrade the existing visual character or quality of public views of the site and its surroundings.

While the town does have limited open areas that could be redeveloped as “opportunity” or infill sites at higher intensity or heights for any new development under the Project, due to the limited number of vacant and potentially redevelopment sites in the town, the Project has limited potential to change the visual character of the town.

Moreover, no existing developed areas would be altered in terms of uses and architecture. Since the town is limited to infill and redevelopment growth for future residential, commercial or office uses, compact development near the town center is encouraged and would protect th e existing visual character of developed areas of the town and would protect the town’s visual character and existing cemetery and open space uses.

Moreover, all future development projects would have to be consistent with applicable zoning in the town. Infill development would be encouraged to be aesthetically pleasing and be compatible to surrounding land uses, particularly in the downtown area of the town of Colma. This would assist in creating minimal aesthetic contrasts with the existing uses in terms of scale, color, form, or overall visual character of the area.

Moreover, the following proposed General Plan policies address impacts to the visual character of the Town of Colma:

Policy LU-1-1 General Plan Land Use Diagram. Maintain and implement a Land Use Diagram for purposes of describing the types of allowed land uses by geographic location and the density and/or intensity of allowed uses within each designation.

Findings

Policy LU-1-2 Zoning Consistency. Ensure that zoning designations are consistent with the General Land Use Diagram (Figure LU-4).

Policy LU-1-3 Balance New Development with Existing Setting. Prioritize new and higher density development consistent with the Town’s planning areas to ensure new development is context sensitive and contributes to creating a strong sense of place. New development shall serve to protect and enhance the positive aesthetic qualities of the Town and each geographic area.

Policy LU-1-5 Clear and Predictable Development Standards. Strive to adopt and communicate clear and predictable development standards to ensure new development meets the expectations of the town.

Policy LU-10-6 Spanish Mediterranean Design. To create a consistent desi gn theme along El Camino Real and at entry gateways, properties included in the Spanish Mediterranean Design Overlay shall utilize Spanish and Mediterranean design elements.

Policy LU-12-1 Cemetery and Agriculture. Consider cemetery and agricultural uses as the primary permitted land uses in the Hillside Boulevard Planning Area (Less than Significant).

Implementation of the above General Plan policies would assist in reducing impacts associated with land use changes that have the potential to change the overall visual character of the town of Colma. For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update’s impacts would be less than significant relating to this issue, and no further mitigation is required. (Draft EIR, pp. 4.1-8 through 4.1-9.)

4. Light and Glare
Threshold: Would the Project create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Finding: Less than significant. (Draft EIR, p. 4.1-9.)
Explanation: The 2040 General Plan Update would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.

Though the town has limited areas for redevelopment, other than the Sterling Park reside ntial neighborhood, most of the future development would be in existing commercial areas of the town. However, since the town is primarily built out , future development would be limited to the redevelopment or infill development of underutilized parcels. T herefore, though these new development areas could result in new light sources, they would be compatible with nearby light sources (e.g., light from exiting commercial doors and windows, or upper story residential windows), especially in the Town Center, along Serramonte Blvd and Collins Avenue, and on specific sites on El Camino Real.

Findings

Moreover, the following proposed General Plan policies address impacts daytime glare and night-time lighting:

Policy M-6-1: Site Planning. Locate and design development projects within a scenic corridor to carefully fit within their environment and setting. The scenic character of the site should be maintained as much as possible. All development should be sited and designed to minimize the impacts of noise, light, glare, and odors on adjacent properties with the community at large.

Policy M-6-2: Lighting. The T own shall minimize obtrusive light by limiting outdoor lighting that is misdirected, excessive, or unnecessary from surrounding residential areas.

Policy M-6-3: Lighting. Encourage street and parking lot lighting that creates a sense of security, complements building and landscape design, is energy -efficient, considers night sky visibility impacts (e.g., “dark skies”), and avoids conflicts with nearby residential uses.

Policy M-6-4: Glare. The Town shall require that new development avoid the creation of incompatible glare through development design features, nighttime lighting timing restrictions, height restrictions, and types of lights, particularly adjacent to residential areas.

Implementation of the policies described above would assist in further reducing impacts associated with daytime glare and night -time lighting.

For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update would have a less than significant impact related to daytime glare and nighttime lighting and no further mitigation is required. (Draft EIR, pp. 4.1-9 through 4.1-10.)

B. AGRICULTURE AND FOREST RESOURCES

1. Farmland Conversion
Threshold: Would the Project convert Primate Farmland, Unique Farmland, or Farmland of Statewide significance, as shown on the maps p repared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?
Finding: No impact. (Draft EIR, p. 5.0-4.)
Explanation: The T own of Colma does not encompass any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and therefore the proposed Project would not convert the aforementioned property to non - agricultural use. Therefore, there would be no impacts. (Draft EIR, p. 5.0-

4.)
Findings

2. Agricultural Zoning
Threshold: Would the Project conflict with existing zoning for agricultural use, or a Williamson Act contract?
Finding: No impact. (Draft EIR, p. 5.0-4.)
Explanation: No land in the town is designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Impo rtance, and the 2040 General Plan Update would not conflict with existing zoning for agricultural use or a Williamson Act contract. For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update would have no impact relating to this issue.

3. Forestland Zoning
Threshold: Would the Project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g)?
Finding: No impact. (Draft EIR, p. 5.0-4.)
Explanation: The town of Colma does not encompass any forest land or timberland, and therefore the proposed General Plan Update would not conflict with existing zoning for, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production. There would be no impact. (Draft EIR, p.

5.0-4.)

4. Loss of Forest Land
Threshold: Would the Project result in the loss of forest land or conversion of forest land to non-forest use?
Finding: No impact. (Draft EIR, p. 5.0-4.)
Explanation: The town of Colma does not encompass any forest land or timberland, and therefore the 2040 General Plan Update would not result in the loss of forest land or conversion of forest land to non-forest use. There would be no impact. (Draft EIR, p. 5.0-4.)
Findings

5. Conversion of Farmland or Forestland
Threshold: Would the Project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use? Finding: No impact. (Draft EIR, p. 5.0-4)
Explanation: For the reasons discussed in the above findings and for the reasons discussed in the EIR, the 2040 General Plan Update would not involve changes in the existing environment that could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. There would be no impacts relating to this issue. (Draft EIR, p. 5.0-

4.)
C. AIR QUALITY

1. Air Quality Plans and Air Quality Standards
Threshold: Would the Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Finding: Less than significant. (Draft EIR, p. 4.2-25.) Explanation: The following describes potential air quality impacts of consistency with the AQMP from the implementation of the proposed Project. The General Plan plays an important role in local agency project review by linking local planning and individual projects to the
2017 Clean Air Plan. It fulfills the
CEQA goal of informing decision makers of the environmental efforts of the project under consideration at an early enough stage to ensure that air quality concerns are fully addressed. It also provides the local agency with ongoing information as to whether they are contributing to clean air goals in the Bay Area.

BAAQMD requires a consistency evaluation of a plan with its current AQMP measures. BAAQMD considers project consistency with the AQMP in accordance with the following:

• Does the project support the primary goals of the AQMP? • Does the project include applicable control measures from the AQMP?
• Does the project disrupt or hinder implementation of any AQMP control measures?
• Is the project VMT or vehicle trip increase less than or equal to the projected population increase.

Ba y Area Air Quality Management District 2017 Clean Air Plan Goals
Findings

The primary goals of the 2017 Clean Air Plan are to attain the State and federal AAQS, reduce population exposure and protect public health in the Bay Area, reduce GHG emissions, and protect the climate. Furthermore, the 2017 Clean Air Plan lays the groundwork for reducing GHG emissions in the Bay Area to meet the state’s 2030 GHG reduction target and 2050 GHG reduction goal.

Attain Air Quality Standards

BAAQMD’s 2017 Clean Air Plan strategy is based on regional population and employment projections in the Bay Area compiled by ABAG, which are based in part on cities’ general plan land use designations. These demographic projections are incorporated into Plan Bay Area. Demographic trends incorporated into Plan Bay Area determine VMT in the Bay Area, which BAAQMD uses to forecast future air quality trends. The SFBAAB is currently designated a nonattainment area for O3, PM2.5, and PM10 (State AAQS only).

Future growth associated with the proposed Project would occur incrementally throughout the 2040 buildout horizon. The anticipated growth from the proposed Project is within the population and employment projections identified by ABAG for the town of Colma. Because population and employment projections of the proposed Project are consistent with regional projections, BAAQMD emissions forecasts consider the additional growth and associated emissions from the proposed Project. Thus, emissions resulting from potential future development associated with the proposed Project are included in BAAQMD projections, and future development accommodated under the proposed General Plan would not hinder BAAQMDs ability to attain the California or National AAQS.

Accordingly, impacts would be less than significant.

Reduce GHG Emissions and Protect the Climate

Consistency of the proposed Project with State, regional, and local plans adopted for the purpose of reducing GHG emissions are discussed in Chapter 4.7.1, Greenhouse Gas Emissions, of the Draft EIR. Future development allowed by the proposed Project would be required to adhere to statewide measures that have been adopted to achieve the GHG reduction targets of AB 32 and SB 32. The proposed Project is consistent with regional strategies for infill development identified in Plan Bay Area.

Furthermore, the proposed Project would also be consistent with the Town of Colma Climate Action Plan 2030. The proposed Project is consistent with state, regional and local plans to reduce GHG emissions. Therefore, the proposed Project is consistent with the goal of the 2017 Clean Air Plan to
reduce GHG emissions and protect the climate, and the impact would be less than significant.

Findings

2017 Clean Air Plan Control Measures

Table 4.2.8: Control Measures from the BAAQMD 2017 Clean Air Plan of the Draft EIR, identifies the control measures included in the 2017 Clean Air Plan that are required by BAAQMD to reduce emissions for a wide range of both stationary and mobile sources. As shown in the table, the proposed Project would not conflict with the 2017 Clean Air Plan and would not hinder BAAQMD from implementing the control measures in the 2017 Clean Air Plan. Accordingly, impacts would be less than significant .

Regional Growth Projections for VMT and Population

Future potential development allowed by the proposed Project would result in additional sources of criteria air pollutants. Growth accommodated by the proposed Project could occur throughout the buildout horizon.

BAAQMDs approach to evaluating impacts from criteria air pollutants generated by a plan’s long-term growth is done by comparing population estimates to the VMT estimates. This is because BAAQMDs AQMP plans for growth in the SFBAAB are based on regional population projections identified by ABAG and growth in VMT identified by C/CAG. Changes in regional, community-wide emissions in the EIR Study Area could affect the ability of BAAQMD to achieve the air quality goals in the AQMP. Therefore, air quality impacts for a plan-level analysis are based on consistency with the regional growth projections. Table 4.2.9: Comparison of the Change in Population and VMT in the Town of Colma of the Draft EIR, compares the projected increase in population with the projected increases in total VMT.

As stated, BAAQMD’s AQMP requires that the VMT increase by less than or equal to the projected population increase from the proposed Project (e.g., generate the same or less VMT per population). However, because the proposed Project accommodates both residential and nonresidential growth, a better indicator of how efficiently the town is growing can be made by comparing the increase in VMT to the increase in service population (e.g., generate the same or less VMT per service population).

This approach is similar to the efficiency metrics for GHG emissions, which consider the total service population when calculating project efficiency. In addition, because the 2017 Clean Air Plan utilized growth projections based, in part, on cities’ general plan land use designations, the growth rate in VMT compared to service population is evaluated between buildout under the proposed Project and buildout under the currently allowed under General Plan 2020.

VMT estimates based on data provided by Kittelson & Associates, were calculated for the town of Colma. Implementation of the proposed Project would increase daily VMT by 20,886 vehicle miles per day in the town, or about 30 percent, when compared to existing conditions. However, implementation of the proposed Project would result in lower VMT per capita than under existing conditions (32 percent lower in the town) and Findings

lower VMT per service population (8 percent lower in the Town), than under existing conditions. Compared to the demographic and VMT growth projections of the 2040 Without Project conditions (i.e., growth that would occur as currently allowed and projected under the current General Plan), the 2040 With Project conditions would also decrease the VMT/SP by approximately 1 percent in the town. This indicates that buildout conditions under the proposed Project would be more efficient in reducing VMT on a per service population basis. Thus, the proposed Project would be consistent with the goals of the 2017 Clean Air Plan. In summary, implementation of the proposed Project
would not conflict with the 2017
Clean Air Plan, and impacts would b e less than significant and no mitigation is required.

Proposed General Plan Update Policies

The General Plan policies listed in Table 4.2.9 of the Draft EIR would ensure consistency with the AQMP. (Draft EIR, pp. 4.2-25 through 4.2-35.)

2. Cumulatively Considerable Pollutant Emissions
Threshold: Would the Project result in cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard? Finding: Less than significant. (Draft EIR, p. 4.2-35.) Explanation: Operation

BAAQMD has identified thresholds of significance for criteria pollutant emissions and criteria air pollutant precursors, including VOC, NO, PM10, and PM2.5. Development projects below the significance thresholds are not expected to generate sufficient criteria pollutant emissions to violate any air quality standard or contribute substantially to an existing or projected air quality violation. According to BAAQMD’s CEQA Guidelines, long-range plans, such as the proposed General Plan, present unique challenges for assessing impacts. Due to the SFBAAB’s nonattainment status for ozone and PM and the cumulative impacts of growth on air quality, many of these plans have significant, unavoidable adverse air quality impacts.

Implementation and adoption of the proposed Project would result in an increase in development intensity in the town. Buildout of the proposed Project would result in direct and indirect criteria air pollutant emissions from transportation, energy (e.g., natural gas use), and area sources (e.g., aerosols and landscaping equipment). Although BAAQMD’s CEQA Air Quality Guidelines only require an emissions inventory of criteria air pollutants for project-level analyses, enough information regarding the buildout of the proposed 2040 General Plan is available; thus, an inventory of criteria air pollutants was generated to identify the magnitude of Findings

emissions from buildout of the proposed General Plan. Table 4.2.10: Town of Colma Criteria Air Pollutant Emissions Forecast of the Draft EIR, identifies the emissions associated with buildout of the proposed Project. Subsequent environmental review of development projects would be required to assess potential impacts under BAAQMD’s project-level thresholds.

The proposed Project includes several policies to reduce air quality impacts of potential future development, particularly in the Land Use (LU), Mobility (M), and Open Space and Conservation (C) Elements . Overall, th ese components of the proposed P roject would contribute to reducing emissions.

Buildout of the proposed Project would not generate a substantial increase in criteria air pollutant emissions because emissions would not exceed the BAAQMD regional significance thresholds for VOC, NOx, PM10, and PM2.5.

Moreover, compliance with the following 2040 General Plan Update policies and programs would contribute to minimizing long-term emissions:

Policy LU-2-10. Green Building. Support sustainability and green building best practices through the orientation, design, and placement of buildings and facilities to optimize their energy efficiency in preparation of State zero-net energy requirements for residential construction and commercial construction.

Policy LU-3-6. Walkable Neighborhoods. The Town shall promote walkable neighborhoods by supporting alternative modes of transportation; enhancing bike and pedestrian connectivity to local commercial districts and transit centers; and maintaining sidewalks, public plazas, parks and greenways, parkways, street tree canopies, and landscaping throughout residential neighborhoods.

Policy M-2-1. Reduce Vehicle Miles Traveled. Require new development projects to achieve a reduction in VMT pe r capita or VMT per service population compared to both baseline VMT performance conditions and General Plan 2040 VMT performance conditions. The Town will regularly monitor baseline VMT to provide updated benchmarks for project applicants.

Encourage use of VMT reduction strategies and methods to encourage non- automobile travel.

Policy M-2-2. Other Traffic Flow Benchmarks. Establish additional traffic flow benchmarks, such as VMT, vehicle -hours of travel, and safety -related metrics, in order to evaluate and monitor changes in traffic flow over time.

Policy M-2-3. VMT Transportation Performance Measures. Update the Town’s transportation measures and thresholds to use VMT standards for traffic impact analysis rather than LOS.

Findings

Policy M-4-4. Transit Oriented Development. Promote the development of multi - modal mixed -use development at sites surrounding the Colma BART station, where feasible along Mission Road, and at the Town Center site.

Policy M-4-5. Connections to Homes and Businesses. Seek opportunities to improve first and last mile connections between transit, homes, and businesses.

Policy M-5-2. Design for All Travel Modes. Plan, design, and construct transportation projects to safely accommodate the needs of pedestrians, bicyclists, transit riders, motorists, people with mobility challenges, and persons of all ages and abilities.

Policy M-7-1. TDM Program. Continue to participate in the TDM Program as outlined by the San Mateo City/County Association of Governments (C/CAG).

Policy M-7-2. TDM Program f or New Development. Require major development proposals to include a detailed, verifiable TDM program for consideration by the Town during the review of the development application.

Policy M-7-3. Vehicle Trip Reduction. Support vehicle trip reduction strategies, including building safer and more inviting transportation networks, supporting connections to high frequency and regional transit, implementing TDM programs, and integrating land use and transportation decisions.

Policy OSC-3-1. Transit Oriented Development. Encourage, to the extent feasible, higher density residential development to be located near transit corridors and public transportation.

For these reasons and the reasons discussed in the EIR, implementation of the proposed Project would result in a less than significant operational impact. (Draft EIR, pp. 4.2-37 through 4.2-40.)

3. Sensitive Receptors
Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than significant. (Draft EIR, p. 4.2-40.) Explanation: The 2040 General Plan Update would not expose sensitive receptors to substantial pollutant concentrations.

Operational Phase Community Risk and Hazards

Findings

Types of land uses that typically generate substantial quantities of TACs and PM2.5 include industrial and manufacturing (stationary sources) and warehousing (truck idling) land uses.

Stationary (Permitted) So urces

Various industrial and commercial processes (e.g., manufacturing, dry cleaning) allowed under the proposed General Plan would be expected to release TACs. Since TAC emissions are generated by stationary and point sources of emissions within the SFBAAB, they are regulated and controlled by BAAQMD. However, emissions of TACs from mobile sources when operating at a property (e.g., truck idling) are regulated by statewide rules and regulations, not by BAAQMD, and have the potential to generate substantial concentrations of air pollutants.

Land uses that would require a permit from BAAQMD for emissions of TACs include chemical processing facilities, chrome -plating facilities, dry cleaners, and gasoline -dispensing facilities. Though such services are limited in the town, any emissions of TACs from stationary sources are controlled by BAAQMD. Therefore, any future permitting would be subject to further study and health risk assessment prior to the issuance of any necessary project level air quality permits under Regulation 2, New Source Review, as well as Regulation 11, Rule 18, Reduction of Risk from Air Toxic Emissions at Existing Facilities.

Review under New Source Review ensures that stationary source emissions (permitted sources) would be reduced or mit igated below BAAQMD significance thresholds. Though these sources would incrementally contribute to the proposed General Plan’s inventory individually, they would be mitigated to the standards identified above. Impacts related to permitted stationary sourc es of TACs are considered less than significant
.

CO Hotspots

Areas of vehicle congestion have the potential to create pockets of CO, called hotspots. These pockets have the potential to exceed the State 1 - hour standard of 20 ppm or the 8- hour standard of 9.0 ppm. Since CO is produced in the greatest quantities from vehicle combustion and does not readily disperse into the atmosphere, adherence to AAQS is typically demonstrated through an analysis of localized CO concentrations. Hotspots are typically produced at intersections, where traffic congestion is highest because vehicles queue for longer periods and are subject to reduced speeds.

C/CAG’s CMP must be consistent with the ABAG/MTC’s Plan Bay Area, which is updated periodically. An overarching goal of the Plan Bay Area is to concentrate development in areas where there are existing services and Findings

infrastructure rather than allocate new growth in outlying areas where substantial transportation investments would be necessary to achieve the per capita passenger vehicle VMT and associated GHG emissions reductions.

The GPU would be consistent with the overall goals of the Plan Bay Area.

Additionally, the proposed General Plan would not hinder the capital improvements outlined in the CMP. Thus, the proposed General Plan would not conflict with C/CAG’s CMP. Furthermore, under existing and future vehicle emission rates, a project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour — or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited— in order to generate a significant CO impact (BAAQMD 2017a).

The proposed General Plan would not increase traffic volumes at affected intersections by more than BAAQMD screening criteri a of 44,000 vehicles per hour or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited. Therefore, overall, the proposed Project would not have the potential to substantially increase CO hotspots at intersections in the town and vicinity.

Moreover, the following 2040 General Plan Update policies would further reduce congestion and associated emissions:

Policy M-7-1. TDM Program. Continue to participate in the TDM Program as outlined by the San Mateo City/County Association of Governments (C/CAG).

Policy M-7-2. TDM Program for New Development. Require major development proposals to include a detailed, verifiable TDM program for consideration by the Town during the review of the development application.

Policy M-7-3. Vehicle Trip Reduction. Support vehicle trip reduction strategies, including building safer and more inviting transportation networks, supporting connections to high frequency and regional transit, implementing TDM programs, and integrating land use and transportation decisions.

For these reasons and the reasons discussed in the EIR, localized air quality impacts related to mobile -source emissions would be less than significant
and no further mitigation is required for mobile source emission impacts. (Draft EIR, pp. 4.2-43 through 4.2-44.)

4. Other Adverse Emissions
Threshold: Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Finding: Less than significant. (Draft EIR, p. 4.2-44.) Findings

Explanation: The Project would not result in other emissions, such as those leading to odors, that would adversely affect a substantial number of people.

Construction -Related Odors

During construction activities of future developments in the Town, construction equipment exhaust and application of asphalt and architectural coatings would temporarily generate odors. Any construction- related odor emissions would be temporary and intermittent. Additionally, noxious odors would be confined to the immediate vicinity of the construction equipment. By the time such emissions reach any sensitive receptor sites, they would be diluted to well below any level of air quality concern, and impacts would be less than significant
.

Operation -Related Odors

Nuisance odors are regulated under BAAQMD Regulation 7, Odorous Substances, which requires abatement of any nuisance generating an odor complaint. BAAQMD’s Regulation 7, Odorous Substances, places general limitations on odorous substances and specific emission limitations on certain odorous compounds. In addition, odors are also regulated under BAAQMD Regulation 1, Rule 1-301, Public Nuisance. Accordingly, the 2040 General Plan Update would not result in emissions that would adversely affect a substantial number of people.

Moreover, the following proposed General Plan Update policy would further reduce potential impacts relating to odors.

Policy M-6-1. Site Planning. Locate and design development projects within a scenic corridor to carefully fit within their environment and setting. The scenic character of the site should be maintained as much as possible. All development should be sited and designed to minimize the impacts of noise, light, glare, and odors on adjacent properties with the community at large.

Review of projects using BAAQMD’s odor screening distances during future CEQA review, implementation of the policies and programs above, and compliance with BAAQMD Regulation 7 would ensure that odor impacts are minimized to less than significant
. (Draft EIR, p. 4.2- 44 through 4.2 -

46.)

D. BIOLOGICAL RESOURCES

1. Sensitive Species
Threshold: Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or Findings

regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service?
Finding: Less than significant. (Draft EIR, p. 4.3-12.) Explanation: The 2040 General Plan Update would not have a substantial adverse effect on any sensitive species.

A search of the California Natural Diversity Data Base has revealed the potential occurrence of one amphibian, one bird species, one fish species, four insect species, one reptile (California garter snake), and eight plant species with the town of Colma that are either State or Federal Threatened or Endangered species.

The Project proposes few changes that could potentially alter the future development pro posed in the town. The proposed Project updates the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas include development standards such as height, FAR, and density as well as development standard bonuses for specific uses in opportunity sites.

Though the proposed Project in itself would not directly approve or entitle any development, it would facilitate future development by allowing for infill development as well as redevelopment of the few vacant and underutilized parcels that exist within the town of Colma, thereby incentivizing new development in already developed areas with limited potential for wildlife habitat.

Moreover, the following proposed General Plan policies would minimize or avoid impacts to riparian corridors and natural communities:

Policy OSC-4-7: Colma Creek Bank Setback. Protect and enhance areas of Colma Creek for riparian habitat, linear park opportunities, and aesthetic value.

Policy OSC-5-3: Sensitive Biological Habitats. Require new development on or near sensitive habitats such as open creeks, ponds and other water features to be subject to an investigation of the presence of the threatened Red-legged frog and endangered San Francisco garter snake.

Policy OSC-5-4: Habitat Enhancement. Require new development to minimize the disturbance of natural habitats and vegetation, and revegetation of disturbed habitat with native or non-invasive, naturalized species.

For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update would have a less than significant impact on species identified as a candidate, sensitive, or special statute species in local or regional plans, policies, regulations or by the California Department of Fish Findings

and Wildlife or the U.S. Fish and Wildlife Service. Moreover, these less than significant impacts would be further reduced with the implementation of the policies described above and no further mitigation is required. (Draft EIR, pp. 4.3-12 through 4.3-13.)

2. Riparian Habitat
Threshold: Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Finding: No impact. (Draft EIR, p. 4.3-13.)
Explanation: There are no streams, rivers, vernal pools or marshes within the Planning Area. Colma Creek flows from the San Bruno Mountains through Colma to the San Francisco Bay. While portions of the creek provide habitat and could support protected species, the portions of the creek that flow through Colma flows mostly underground. While portions of the creek daylight in town, it is concrete-lined and does not provide habitat.

There are no State or federally protected wetlands within the General Plan Update Planning Area. Moreover, the majority of the 1225.18-acre Planning Area is either dedicated for cemetery uses or is already developed with residential and commercial uses. Therefore, there would be no impact and no mitigation measures are required. (Draft EIR, p. 4.3-13.)

3. Wetlands
Threshold: Would the Project have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Finding: No impact. (Draft EIR, p. 4.3-13.)
Explanation: There are no streams, rivers, vernal pools or marshes within the Planning Area. Colma Creek flows from the San Bruno Mountains through Colma to the San Francisco Bay. While portions of the creek provide habitat and could support protected species, the portions of the creek that flow through Colma flows mostly underground and do not provide habitat.

There are no State or federally protected wetlands within the General Plan Update Planning Area. Moreover, the majority of the 1225.18-acre Planning Area is either dedicated for cemetery uses or is alread y developed with residential and commercial uses. Therefore, there would be no impact and no mitigation measures are required. (Draft EIR, p. 4.3-13.)

4. Wildlife Movement
Findings

Threshold: Would the Project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Finding: Less than significant. (Draft EIR, p. 4.3-13.) Explanation: The 2040 General Pl an Update would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites.

While the Planning Area is mainly developed with urban uses, there are small areas of diversified wildlife population within the town. Table 4.3.1 of the Draft EIR lists the various native and migratory wildlife, bird and amphibious species that may be found in the town of Colma, particularly along its areas that abut San Bruno Mountain. Since the town of Colma is located along the Pacific Flyway, migratory birds are often found in the town’s open spaces related to cemetery uses. The town’s tall tree masses are also potential testing sites for sensitive raptors protected by the Migratory Bird Treaty Act. Major parts of Colma Creek that flow through the town of Colma, are either underground water resources or contained by narrow culverts. Existing habitats that could support wildlife are surrounded by urban areas and therefore do not support the migration of land animals. Ornamental ponds within some of the town’s cemeteries may be potential habitat for the federally listed threatened Red-legged frog. Site conditions favoring this species include ponds at least two feet deep with moving water and borders of dense, shrubby or emergent riparian vegetation. Although the state and federally -listed endangered San Francisco garter snake seeks the Red-legged frog as a food source, there are currently no known populations of the snake in the town of Colma.

Ornamental ponds within some of the town’s cemeteries may be potential habitat for the federally listed threatened Red -legged frog. Conditions favoring this species include ponds at least two feet deep with moving water and borders of dense, shrubby or emergent riparian vegetation.

Although the state and federally -listed endangered San Francisco garter snake seeks the Red-legged frog as a food source, there are curren tly no known populations of the snake in the town of Colma.

Wildlife species typically use movement corridors in various ways.

However, movement corridors through the town are somewhat limited due to the geography of the town and its numerous cemetery use s. Since the only large continuous areas of open space within the Planning Area are related to the town’s cemetery uses, given their contiguous nature these are the few areas that have the potential to function as wildlife corridors.

Future new development will either consist of redevelopment of underutilized or infill sites and no new development would be allowed in Findings

the town’s cemetery sites. Therefore, although there may be indirect impacts to the movement of wildlife, development/redevelopment under the 2040 General Plan Update is not expected to result in direct impacts to habitat or fragmentation of open space.

In addition to Policy OSC- 3.7, Program OSC -3.8a, Policy OSC- 4.3, and Policy OSC-4.4, the following proposed General Plan policy minimizes or avoids impacts to important wildlife corridors and linkages:

Policy OSC-5-5: Nesting Bird Protection. Require project applicants to retain the services of a qualified biologist(s) to conduct a pre-construction nesting bird survey during the nesting season (February 1 through August 31) prior to all new development that may remove or be in close proximity to any trees or vegetation that may provide suitable nesting habitat for migratory birds or other special -status bird species. If nests are found the qualified biologist(s) shall identify appropriate avoidance measures, and these measures shall be incorporated into the project and implemented accordingly.

Implementation of the policies described above would further ensure that environmental impacts associated with wildlife species movement is less than significant and no mitigation is required. (Draft EIR, pp. 4.3-13 through 4.3-14.)

5. Local Policies and Ordinances
Threshold: Would the Project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Finding: No impact. (Draft EIR, p. 4.3-14.)
Explanation: The Town of Colma has a Tree Ordinance that promotes the healthy growth of trees, controls the removal of trees, and encourages the replacement of trees within the Town. Any buildout activity under the proposed Project would be required to follow these regulations. Therefore, any buildout activities under the proposed Project would have no impact and mitigation is not required. (Draft EIR, p. 4.3-14.)

6. Habitat Conservation Plans
Threshold: Would the Project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? Finding: No impact. (Draft EIR, p. 4.3-15.)
Explanation: There are no adopted Habitat Conservation Plans for the Town, nor are there any Natural Community Conservation Plans at the county level that Findings

include land within the Planning Area. Therefore, future development under the Project would not conflict with provisions of these conservation plans.

There would be no impact and no mitigation is required. (Draft EIR, p.

4.3-15.)

E. ENERGY
Threshold: Would the Project result in potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Threshold: Would the Project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Finding: Less than significant. (Draft EIR, p. 4.5-7.)
Explanation: The 2040 General Plan Update will not result in a potentially significant impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project construction or operation.

Construction of future development, or even redevelopment projects, under the 2040 General Plan Update has the potential to consume electricity, natural gas, gasoline and diesel during the operation of heavy- duty construction equipment and vehicles. However, these would be temporary consumption of energy, only related to project construction under future development projects. Further, any future development would be limited by the town’s geography and relation to existing cemetery uses.

The town anticipates that future development projects would be limited to the town center or existing commercial and residential areas. The town of Colma therefore is anticipating more mixed use development, in terms of its growth. This in itself would reduce travel distances and energy consumption.

Additionally, although it is anticipated that energy efficiency will also improve in the future, and any new development under the Project would have to conform to the State of California’s AB 32 Scoping Plan (for Greenhouse Gas emissions) and the Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24, Part 6) and CALGreen Code (Title 24, Part 11). These standards outline improved building design and energy conservation measures to ensure that there are no unnecessary or inefficient use of energy. M ost of the town is already developed, with few vacant parcels remaining, and future construction would not require the excessive amount of energy consumptions that typically occur with large scale industrial facilities. Proposed Project policies that would reduce air quality impacts during project construction, as well as constantly evolving energy efficiency standards, would also result in associated reductions in construction related energy uses.

Findings

The following proposed General Plan policies further reduce the anticipated less than significant wasteful, insufficient or unnecessary consumption of energy resources during project construction and operation:

Policy OSC-3-1: Transit Oriented Development. Encourage, to the extent feasible, higher density residential development to be located near transit corridors and public transportation.

Policy OSC-3-2: Reduce Energy Consumption. Support measures and education to reduce energy consumption and increase energy efficiency in residential, commercial, and industrial buildings.

Policy OSC-3-3: Energy Efficiency in Municipal Operations. Pursue opportunities to improve energy efficiency and install renewable energy systems, where feasible, in new and existing Town-owned facilities and operations.

Policy OSC-3-4: GHG Reduction. Implement the Climate Action Plan to achieve GHG reduction targets that are consistent with the State Scoping Plan, AB 32, and SB 32 and the Town’s goals.

Policy OSC-3-5: Pedestrian-Scaled Design. Support the use of public/mass transit by encouraging pedestrian-friendly street design and mixed-use development near transit hubs.

For these reasons and the reasons discussed in the EIR, environmental impacts associated with consumption of energy resources would be less than significant and no mitigation is required. (Draft EIR, pp. 4.5 -7 through 4.5-9.)

F. GEOLOGY AND SOILS

1. Fault Rupture
Threshold: Would the Project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; strong seismic ground shaking; seismic -related ground failure including liquefaction; or landslides?
Finding: Less than significant. (Draft EIR, p. 4.6-12.) Explanation: The 2040 General Plan Update would not directly or indirectly cause potential substantial adverse effects involving rupture of a known earthquake fault, strong seismic ground shaking, seismic -related ground failure including liquefaction, or landslides. The 2040 General Plan Update proposes few changes that could potentially alter the future development Findings

proposed in the town, and none of these changes would directly or indirectly cause such substantial adverse effects.

Moreover, t he proposed General Plan policies CS- 2.1 through CS- 2.6 address seismic hazards.

Policy CS-2-1: Geotechnical Studies. Require geotechnical, soils, and foundation reports for proposed projects and subdivisions on sites that have been identified as having moderate or high potential for ground failure, liquefaction, and seismic activity by the Town or by the San Mateo County Seismic and Safety Element.

Policy CS-2-2: Development in Hazardous Areas. Prohibit development, including any land alteration, grading for roads and structural development, in areas of slope instability unless the appropriate mitigation measures are taken.

Policy CS-2-3: Unsafe Buildings. Encourage seismic retrofits of existing buildings based on the recommendations of a license d engineer or architect. Prioritize working with owners of buildings whose loss would impact the greatest number of people and/or particularly vulnerable groups such as seniors, children, or low-income households.

Policy CS-2-4: Water Infrastructure Safet y. Collaborate with San Mateo County, California Water Service Company, and the San Francisco Water District to ensure that all water tanks and main water pipelines are capable of withstanding high seismic stress.

Policy CS-2-5: Erosion Prevention. Require new grading or development to prevent erosion on slope and hillside areas by revegetation or use of slope protection material. Require project grading and drainage plans to demonstrate how the project will maintain natural surface drainage and existing vegetation, to the extent feasible.

Policy CS-2-6: Seismic Hazards. Continue to enforce appropriate standards to ensure existing and new development is located, designed, and constructed to minimize the risk of loss of life and property from seismic hazards.

For these reasons and the reasons discussed in the EIR, environmental impacts associated with such hazards are less than significant level and no mitigation is required. (Draft EIR, pp. 4.6-12 through 4.6-13.)

2. Soil Erosion
Threshold: Would the Project result in substantial soil erosion or the loss of topsoil? Finding: Less than significant. (Draft EIR, p. 4.6-13.) Findings

Explanation: The Project would not result in substantial soil erosion or the loss of topsoil.

Generally, development related construction activities on more than one acre are subject to the National Pollutant Discharge Elimination System (NPDES) permit. As a requirement under the NPDES permit, all such development activities have to follow best management practices that reduce soil erosion, loss of topsoil, and pollution of waterways. In addition, earthwork and ground -disturbing activities, typically require grading permits, compliance with which minimizes erosion. Once construction is complete and exposed areas are revegetated or covered by buildings, asphalt, or concrete, the potential erosion hazard is substantially eliminated or reduced.

The proposed General Plan p olicies CS-2.1, CS -2.2, CS -2.4, and CS- 2.6 address soil erosion and loss of topsoil.

Policy CS-2-1: Geotechnical Studies. Require geotechnical, soils, and foundation reports for proposed projects and subdivisions on sites that have been identified as having moderate or high potential for ground failure, liquefaction, and seismic activity by the Town or by the San Mateo County Seismic and Safety Element.

Policy CS-2-2: Development in Hazardous Areas. Prohibit development, including any land alteration, grading for roads and structural development, in areas of slope instability unless the appropriate mitigation measures are taken.

Policy CS-2-4: Water Infrastructure Safety. Collaborate with San Mateo County, California Water Service Company, and the San Francisco Water District to ensure that all water tanks and main water pipelines are capable of withstanding high seismic stress.

Policy CS-2-6: Seismic Hazards. Continue to enforce appropriate standards to ensure existing and new development is located, des igned, and constructed to minimize the risk of loss of life and property from seismic hazards.

For these reasons and the reasons discussed in the EIR, environmental impacts associated with soil erosion and loss of topsoil are less than significant and no mitigation is required. (Draft EIR, pp. 4.6-12 through

4.6-14.)

3. Unstable Soils
Threshold: Would the Project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off- site landslide, lateral spreading, subsidence, liquefaction or collapse?
Finding: Less than significant. (Draft EIR, p. 4.6-15.) Findings

Explanation: The 2040 General Plan Update would not result in development located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse. While San Mateo County has hillsides with medium or very high susceptibility for landslides, the town of Colma does not have steep slopes. Though it borders the base of the San Bruno Mountains, these are also the areas of the town’s cemetery uses and no future development would be allowed with these land uses.

Moreover, t he following 2040 General Plan Update policies address potential slope instability and landslide issues within the town of Colma.

Policy CS-2.1: Geotechnical Studies. Require geotechnical, soils, and foundation reports for proposed projects and subdivisions on sites that have been identified as having moderate or high potential for ground failure, liquefaction, and seismic activity by the Town or by the San Mateo County Seismic and Safety Element.

Policy CS-2.2: Development in Hazardous Areas. Prohibit development, including any land alteration, grading for roads and structural development, in areas of slope instability unless the appropriate mitigation measures are taken.

Policy CS-2.5: Erosion Prevention. Require new grading or development to prevent erosion on slope and hillside ar eas by revegetation or use of slope protection material. Require project grading and drainage plans to demonstrate how the project will maintain natural surface drainage and existing vegetation, to the extent feasible.

For these reasons and the reasons discussed in the EIR, impacts relating to this issue are therefore less than significant and no mitigation is required. (Draft EIR, p. 4.6-15.)

4. Expansive Soils
Threshold: Would the Project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code, creating substantial risks to life or property? Finding: No impact. (Draft EIR, p. 4.6-15.)
Explanation: The 2040 General Plan Update would not result in development located on expansive soil that could create substantial risks to life or property. Future development under the Project would be limited to redevelopment of underutilized or infill sites within the town. These available sites are already developed either wholly or partially with residential, commercial or public service uses, and no soil related issues were identified as these sites were developed. Therefore, the proposed Project would have no impact related to unstable or expansive soils and no mitigation measures are required. (Draft EIR, pp. 4.6-15 through 4.6-16.)
Findings

5. Septic Tanks
Threshold: Would the Project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
Finding: No impact. (Draft EIR, p. 4.6-16.)
Explanation: The 2040 General Plan Update would not result in development requiring septic tanks or alternative waste water disposal systems. The T own has approximately 33,600 lineal feet of sewer mains for its wastewater collection. As such, there are no significant adverse environmental impacts associated with septic tanks that would result from implementation of the 2040 General Plan Update. Therefore, the proposed Project would have no impact related to soils capability to support wastewater disposal and no mitigation measures are required. (Draft EIR, p. 4.6-16.)

6. Paleontological Resources
Threshold: Would the Project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Finding: Less than significant. (Draft EIR, p. 4.6-16.) Explanation: The Town of Colma is not located on any unique geological features, nor does it have areas of unique paleontological resources. Moreover, a ny future new development will consist of redevelopment of underutilized or infill sites, and no new development would be allowed in the town’s cemetery sites. In the possibility that unknown resources are found during construction activities in the Town, federal and State regulations would require protective measures should any paleontological re sources be discovered. Section 5097 of the Public Resources Code specifies the procedures to be followed in the event of the unexpected discovery of paleontological re sources. Additionally, Section 4.4 Cultural and Tribal Resources of the Draft EIR and 2040 General Plan Update Policy OSC-6-3 address potential impacts on paleontological resources. Potential impacts from adoption of the Project would be less than significant and n o further mitigation is required. (Draft EIR, pp. 4.6-16 through 4.6-17.)

G. GREENHOUSE GAS EMISSIONS

1. Emission Reduction Plans
Threshold: Would the Project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emission of greenhouse gases? Finding: Less than significant. (Draft EIR, P. 4.7-23.) Findings

Explanation: Applicable plans adopted for the purpose of reducing GHG emissions include CARB’s Scoping Plan, ABAG’s/MTC’s Plan Bay Area, and the Town’s CAP. A consistency analysis with these plans is presented below.

CARB Scoping Plan
The CARB Scoping Plan is applicable to state agencies but is not directly applicable to cities/counties and individual projects (i.e., the Scoping Plan does not require the town to adopt policies, programs, or regulations to reduce GHG emissions). However, new regulations adopted by the State agencies from the Scoping Plan result in GHG emissions reductions at the local level. So local jurisdictions benefit from reductions in transportation emissions rates, increases in water efficiency in the building and landscape codes, and other statewide actions that affect a local jurisdiction’s emissions inventory from the top down. Statewide strategies to reduce GHG emissions include the LCFS and changes in the corporate average fuel economy standards.

Project GHG emissions shown in Table 4.7.5 of the Draft EIR include reductions associated with statewide strategies that have been adopted since AB 32 and SB 32. Development projects accommodated under the proposed Project are required to adhere to the programs and regulations identified by the Scoping Plan and implemented by state, regional, and local agencies to achieve the statewide GHG reduction goals of AB 32 and SB 32. Future development projects would be required to comply with these state GHG emissions reduction measures because they are statewide strategies. For example, new buildings associated with land uses accommodated by implementing the proposed Project would be required to meet the CALGreen and Building Energy Efficiency Standards in effect at the time when applying for building permits. Furthermore, the proposed Project includes goals, policies, and programs that would help reduce GHG emissions and therefore help achieve GHG reduction goals. Therefore, implementation of the proposed Project would not obstruct implementation of the CARB Scoping Plan, and impacts would be less than significant.

Plan Bay Area
Plan Bay Area is the Bay Area’s regional transportation plan to achieve the passenger vehicle emissions reductions identified under SB 375. Plan Bay Area 2050 is the current SCS for the Bay Area, which was adopted October 21, 2021 (ABAG and MTC 2021).

Plan Bay Area 2050 includes strategies to reduce GHG emissions include focusing housing and commercial construction in walkable, transit - accessible places; investing in transit and active transportation; and shifting the location of jobs to encourage shorter commutes (ABAG and MTC 2021). The town of Colma’s designated PDA and TPA are areas anticipated to harbor most of the Town’s growth in the next 20 years.

Findings

The proposed Project places higher-density uses near transit stations and in areas that are less auto dependent. This is supported by Policy LU -1.3, which strives to reduce GHG emissions through the way the town designs and locates new housing, offices, public buildings, and other uses. Thus, the project would be consistent with the overall goals of Plan Bay Area 2050 in concentrating new development in locations where there is existing infrastructure and tr ansit. Therefore, the proposed P
roject would not
conflict with the land use concept plan in Plan Bay Area 2050, and impacts would be less than significant
.

Colma Climate Action Plan
The CAP provides additional measures and strategies to achieve a GHG reduction target of 15 percent below 2005 levels by 2020, consistent with AB 32. The CAP lays out measures that would exceed the 2020 target and put the town on a trajectory to meet the 2050 goal under Executive Order S-03-05. The proposed P roject would further the goals of the CAP by introducing policies and programs that align with the CAP (see Table 4.7.6:

Colma Climate Change Action Plan 2030 Consistency Analysis, of the Draft EIR). Consequently, the proposed P
roject is consistent with the town’s CAP,
and impacts are less than significant.

Proposed General Plan Update Policies
Measures identified in Table 4.7.6 of the Draft EIR would furter ensure consistency of the General Plan with plans that have been adopted to reduce GHG emissions.

The Town has prepared an update to the Climate Action Plan to provide guidance for meeting GHG reduction goals to the year 2030. Although not yet officially adopted, the Town plans to adopt the plan in the near future.

For all of the foregoing reasons and the reasons discussed in the EIR, the 2040 General Plan Update would result in a less than significant impact relating to this issue, and no mitigation is required. (Draft EIR, pp. 4.7-23 through 4.7-34.)

H. HAZARDS AND HAZARDOUS MATERIALS

1. Hazardous Materials
Threshold: Would the Project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Finding: Less than significant. (Draft EIR, p. 4.8-13.) Explanation: The use, transport and disposal of hazardous materials is regulated and monitored by local fire departments and the California Highway Patrol (CHP).

Findings

While US 280 and State Route 1 (SR 1) border the western edge of the town, neither of these are designated hazardous material transportation routes. Moreover, as required by local, State and federal regulations, any use, transportation, and disposal of hazardous materials is regulated and monitored by the town’s fire department, Certified Unified Progra m Agencies (CUPAs), the California Division of Occupational Safety and Health (OSHA), and the California Department of Toxic Substances Control (DTSC).

The precise increase in the amount of regulated hazardous materials transported to or from the Planning Area as a result of implementation of the proposed Project, cannot be definitively predicted at this time.

However, as previously mentioned, all future projects allowed under the 2040 General Plan Update would be required to comply with local, state and federal requirements related to hazardous materials. The use, storage, and transport of hazardous materials by developers, contractors, business owners, and others are required to be in compliance with local, state, and federal regulations during project construction and operation, as well as to be in compliance with a Hazardous Materials Business Plan in accordance with State of California regulations. Facilities that use hazardous materials are required t o obtain permits and comply with appropriate regulatory agency standards designed to avoid hazardous waste releases.

Moreover, the following proposed General Plan policies address the use and handling of hazardous materials and associated land uses involv ing hazardous materials through the coordination with appropriate agencies regarding route planning and incident response:

Policy CS-7-1: Hazard Mitigation Plan. Implement, maintain, and update the Local Hazard Mitigation Plan which is part of the larger County Hazard Mitigation Plan.

Policy CS-7.2: Emergency Management Plan. Continue to participate with San Mateo County’s Mutual Aid Programs and Plans for community emergency preparedness.

Policy CS-7.3: Promote Emergency Preparedness. Utilize mult iple information channels to educate residents and businesses of the Town’s emergency operations procedure.

Policy CS-7.4: Collaborative Planning. Improve inter -jurisdictional and interagency cooperation with regard to hazard prevention and emergency resp onse through town participation in and initiation of coordination meetings and exercises.

Policy CS-7.5: Evacuation Routes. Utilize emergency evacuation routes established by the Town and ensure that all residential areas of Colma maintain access to at least two routes for evacuation.

Findings

Impacts from the use and handling of hazardous materials would be less than significant and no mitigation is required. Moreover, implementation of the policies described above, as well as adherence to all federal, state, and local regulations regarding the transportation of hazardous materials, would further reduce the environmental impacts associated with the transportation, use and storage of hazardous materials (Draft EIR, pp. 4.8- 13 through 4.8-15.)

2. Accident or Upset
Threshold: Would the Project 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? Finding: Less than significant. (Draft EIR, 4.8-13.)
Explanation: The Project would not 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.

As
required by local, State and federal regulations, any use, transportation, and disposal of hazardous materials is regulated and monitored by the town’s fire department, Certified Unified Program Agencies (CUPAs), the California Division of Occupational Safety and Health (OSHA), and the California Department of Toxic Substances Control (DTSC), though in the event of an accidental release of hazardous materials, the local emergency management agencies (e.g., fire and police departments) would be the first to respond.

Compliance with all applicable federal and state laws related to the transportation of hazardous materials would reduce the likelihood and severity of accidents during transit. The use, storage, and transport of hazardous materials by developers, contractors, business owners, and others are required to be in compliance with local, state, and federal regulations during project construction and operation, as well as to be in compliance with a Hazardous Materials Business Plan in accordance with State of California regulations. Facilities that use hazardous materials are required to obtain permits and comply with appropriate regulatory agency standards designed to avoid hazardous waste releases.

Moreover, the following proposed General Plan policies address the use and handling of hazardous materials and associated land uses involving hazardous materials through the coordination with appropriate agencies regarding route planning and incident response:

Policy CS-7.2: Emergency Management Plan. Continue to participate with San Mateo County’s Mutual Aid Programs and Plans for community emergency preparedness.

Findings

Policy CS-7.3: Promote Emergency Preparedness. Utilize multiple information channels to educate residents and businesses of the Town’s emergency operations procedure.

Policy CS-7.4: Collaborative Planning. Improve inter -jurisdictional and interagency cooperation with regard to hazard prevention and emergency response through town participation in and initiation of coordination meetings and exercises.

Policy CS-7.5: Evacuation Routes. Utilize emergency evacuation routes established by the Town and ensure that all residential areas of Colma maintain access to at least two routes for evacuation.

Impacts from accidents involving the release of hazardous materials would be less than significant and no mitigation is required. Moreover, implementation of the policies described above, as well as adherence to all federal, state, and local regulations regarding the transportation of hazardous materials, would further reduce the environmental impacts associated with the transportation, use and storage of hazardous materials (Draft EIR, pp. 4.8-13 through 4.8-15.)

3. Hazards Near Schools
Threshold: Would the Project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school?
Finding: Less than significant. (Draft EIR, p. 4.8-15.) Explanation: The 2040 General Plan Update would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. N o schools are
located, or planned for, within the Planning Are a. Moreover, r esidential land uses do not typically involve the storage or use of substantial quantities of hazardous materials. There would not be an increase in the storage and use of hazardous materials. Implementation of the project would result in environmental impacts associated with the school hazards to less than significant and no further mitigation is required. (Draft EIR, p. 4.8-15.)

4. Waste Sites
Threshold: Would the Project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Finding: Less than significant. (Draft EIR, p.4.8-15.)
Findings

Explanation: There are a number of sites within the town that are included on a list of hazardous material sites compiled by pursuant to Go vernment Code Section §65962.5. These sites are subject to various State and federal laws and regulators, including the Certified Unified Program Agencies (CUPAs), the California Division of Occupational Safety and Health (OSHA), and the California Department of Toxic Substances Control (DTSC). The transportation of hazardous materials on area roadways is regulated by the CHP, U.S. Department of Transportation (Hazardous Materials Transportation Act) and Caltrans and use of these materials is regulated by the DTSC (22 Cal. Code Regs. Section §66001, et seq.).

The town of Colma, San Mateo County and the California State Water Resources Board lists 21 hazardous waste sites with the Town. Of these, 19 are closed/completed sites, two are open and one is open but eligible for closure. The Project would result in additional development on already developed properties, two of which are listed as open hazardous sites:
7778 El Camino Real, as well as 1 Sandhill Road, which is a closed landfill and does not have development potential. The property at 7778 El Camino Real has been identified as an opportunity site for future mixed -use development. Adherence to all federal, state, and local regulations regarding hazardous materials sites would ensure environmental impacts associated with the re-use of such sites would be less than significant.

Additionally, the following proposed General Plan policies address hazards to the public and the environment:

Policy CS-2.1: Geotechnical Studies. Require geo technical, soils, and foundation reports for proposed projects and subdivisions on sites that have been identified as having moderate or high potential for ground failure, liquefaction, and seismic activity by the Town or by the San Mateo County Seismic and Safety Element.

The Project would have a less than significant impact relating to development of sites included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5. No mitigation measures are required. Moreover, w ith implementation of the policy described above, as well as adherence to all federal, state, and local regulations regarding the hazardous materials sites, would further reduce the environmental impacts associated with the re-use of such sites. (Draft EIR, pp. 4.8-15 through 4.8-16.)

5. Public Airports
Threshold: For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
Findings

Finding: Less than significant. (Draft EIR, p. 4.8-16.) Explanation: While the town of Colma does not have any public or private airports within the town limits, it is within influence area B of the San Franci sco International Airport (SFO) . The SFO Airport is 5.5 miles away from the Planning Area. Other airports in close proximity include the Half Moon Bay Airport, located 11 miles from the Planning Areas and the Oakland Airport and San Carlos Airport, located 13 miles and 15.5 miles, respectively, from the town of Colma. Aircrafts taking off from the closed airport, SFO, fly over a 1.2-mile-wide and 5.8-mile-long area that is referred to as the “gap”.

The gap stretches over the cities of San Bruno, South San Francisco, and Daly City and is directly adjacent to the town of Colma. In addition, though SFO has designated transitional surfaces as alternate routes for planes to take off or land, one of these transitional surfaces extends over the town and has the potential to affect the town residences.

Proposed General Plan Update Policies

Moreover, t he following proposed General Plan policies address airport hazards:

Policy CS-9.1: ALUC Plan. Require development within the Airport Influence Area B, designated in the Airport Land Use Compatibility Plan (ALUCP) of the San Francisco International Airport, to comply with all applicable federal and State laws with respect to land use safety and airspace protection criteria.

Policy CS-9.2: Airport Land Use Commission Review. Require that all future land use actions and/or associated development conforms to the relevant height, aircraft noise, and safety policies and compatibility criteria contained in the most recently adopted version of the ALUCP for the environs of San Francisco International Airport.

Implementation of the policies described above would ensure the environmental impacts associated with any airport hazards are less than significant and no mitigation measures are required. (Draft EIR, pp. 4.8- 16 through 4.8-17.)

6. Emergency Plans
Threshold: Would the Project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Finding: Less than significant. (Draft EIR, p. 4.8-17.) Explanation: Though the Project would allow for some new residential and commercial development in the Town of Colma, any future projects are not anticipated to impede evacuation routes in the town. Further, the town already has an established roadway and circulation system that may be used for the evacuation of residents and the mobility of fire suppression, emergency Findings

response, and law enforcement vehicles. Therefore, there should not be any potential future conflicts with existing emergency response or emergency evacuation plans from implementation of emergency response activities.

Moreover, the following proposed General Plan policies address emergency response and evacuation plans:

Policy CS-7-1: Hazard Mitigation Plan. Implement, maintain, and update the Local Hazard Mitigation Plan which is part of the larger County Hazard Mitigation Plan.

Policy CS-7-2: Emergency Management Plan. Continue to participate with San Mateo County’s mutual aid programs and plans for community emergency preparedness.

Policy CS-7-3: Promote Emergency Preparedness. Utilize multiple information channels to educate residents and businesses of the Town’s emergency operations procedure.

Policy CS-7-4: Collaborative Planning. Improve inter -jurisdictional and interagency cooperation with regard to hazard prevention and emergency response through town participation in and initiation of coordination meetings and exercises.

Policy CS-7-5: Evacuation Routes. Utilize emergency evacuation routes established by the Town and ensure that all residential areas of Colma maintain access to at least two routes for evacuation.

The Project would have a less than significant impact relating to an adopted emergency response or evacuation plan and no mitigation measure are required. Moreover, implementation of the policies described above would further reduce environmental impacts to an adopted emergency response or evacuation plan. (Draft EIR, p. 4.8-17.)

7. Wildland Fires
Threshold: Would the Project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?
Finding: No impact. (Draft EIR, p. 4.8-18.)
Explanation: The California Department of Forestry and Fire Protection (CAL FIRE) determines the degree of wildland fire hazard based on the natural setting of the area, the degree of human use of the area and the level and ability of public services to respond to fires that do occur. CAL FIRE has rated the San Bruno Mountain Park and the adjacent undeveloped areas of the town Findings

of Colma as areas of moderate fire hazard. Fires in these areas usually occur during the summers primarily where grass and brush grow. CAL FIRE responds to wildland fires from several stations, depending on their proximity and availability. The closest fire station serving the town is at 20 Tower Road in the city of Belmont. The areas that are still undeveloped in the town of Colma are lands for cemetery uses. New residential or commercial land uses can only occur on previously developed land or on approximately 2.8 acres of vacant land. While the Project does have the potential to add future development, all future projects under the GPU would be required to comply with local, State, and federal requirements related to wildland fires, building standards and safety codes, as well as defensible space requirements, where applicable. Further, wildland fires typically are a potential hazard to development located in unmaintained open spaces. Other than cemetery uses, the town is fairly developed, with no large open spaces dedicated to land development. Therefore, the potential for wildland fire is non -existent and the proposed Project would not expose people or structure to a risk of loss, injury, or death. Thus, there is no impact and no mitigation is required. (Draft EIR, p. 4.8-18.)

I. HYDROLOGY AND WATER QUALITY

1. Water Quality Standards
Threshold: Would the Project violate any water quality standards or waste discharge requirements?
Finding: Less than significant. (Draft EIR, p. 4.9-8.)
Explanation: The 2040 General Plan Update would not violate any water quality standards or waste discharge requirements.

The Clean Water Act and California State Water Resources Control Board require any development, infrastructure, redevelopment, or improvement project over one acre in size, to be approved for a Storm Water Pollution Prevention Plan (SWPPP), a General Permit particularly during construction activities, as well as implementation of BMPs and methods to prevent erosion and tracking would be required. A lso, the town is obligated to follow the mandates of the San Francisco Bay Municipal Regional Stormwater Permit (MRP) to control stormwater discharge within the town limits. Provisions of the MRP require onsite treatment of stormwater, discharges by businesses, trash capture devices in the storm drain system and more. Furthermore, the proposed policies in the General Plan Update would help mitigate the impacts to surface water quality.

Moreover, the following proposed General Plan policies address surface water quality standards

Findings

Policy OSC-4-1: Comply with Water Quality Regulations. Continue to comply with all State and federal regulations for water quality.

Policy OSC-4-2: Participation in the San Mateo County Stormwater Pollution Prevention Program (SMCWPPP). Continue to be an active member agency of the SMCWPPP to reduce pollution from being conveyed through the storm water system to the San Francisco Bay.

Policy OSC-4.-9: Water Quality and Conservation Public Information. Continue to support and coordinate with the Countywide Stormwater Program, Cal Water, and the San Francisco Public Utilities Commission (SFPUC) on their public outreach and education campaigns to conserve and maintain water quality.

Policy LU-2-4: Low Impact Development. Regulate new development and construction to minimize pollutant and sediment concentrations in receiving waters and ensure that surface water meets or exceeds applicable regulatory water quality standards. Require new development to incorporate Low Impact Development features that treat and reduce surface runoff volumes.

For these reasons and the reasons discussed in the EIR, the Project’s environmental impacts associated with surface water quality would be less than significant and no further mitigation is required. (Draft EIR, pp. 4.9- 8 through 4.9-9.)

2. Groundwater Supplies
Threshold: Would the Project substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin?
Finding: Less than significant. (Draft EIR, p. 4.9-9.)
Explanation: The Town of Colma is serviced by Cal Water’s South San Francisco District, which provides water from a combination of groundwater as well as purchased water sources and has adequate resources to meet the present needs and foreseeable growth of the town. On both developed and undeveloped sites, compliance with the San Francisco Bay Municipal Regional Stormwater Permit (MRP)
requires that projects to include
stormwater treatment measures that would allow for the treatment and retention of surface runoff. This improves water quality and allows for ground water recharge opportunities on developed sites and mitigates the impact of future development and redevelopment activities. The majority of the town’s groundwater usage comes from the irrigation of cemetery lands. The development of cemetery structures such as a mausoleum may reduce the ground water use by reducing the need to irrigate. In addition, Colma Municipal Code Chapter 5.11 requires that new development projects that affect 500 square feet or more and landscape modification projects that affect 2,500 square feet or more, including cemetery lands, Findings

improve water use efficiency by planting less water intensive species of vegetation and increasing efficiency in irrigation.

Also, statewide NPDES permits are required for construction runoff and dewatering and other releases to surface water as well as the LID techniques required by Policy LU -2-4, would protect groundwater quality under future development and redevelopment activities in the town of Colma. The policies discussed below would further minimize any potential impact from the proposed Project.

Moreover, t he following proposed General Plan policies address groundwater supplies and groundwater recharge:

Policy OSC-4-1: Comply with Water Quality Regulations. Continue to comply with all State and federal regulations for water quality.

Policy OSC-4-3: Reclaimed Water. Pursue opportunities to install water recycling infrastructure for Town-owned and cemetery landscape areas.

Policy OSC-4-4: Use of Drought Tolerant and Native Plants. Encourage the use of drought tolerant and native plants in landscaping plans.

Policy OSC-4-5: Green Infrastructure. Incorporate green infrastructure, which relies on natural processes for stormwater treatment/drainage, groundwater recharge and flood control, into street and rights -of-way wherever practicable, including curb cuts, flow-through planters and bioswales that slow stormwater runoff by dispersing it to vegetated areas, harvesting and use of runoff, and promote infiltration and use of bioretention to clean stormwater runoff.

Policy LU-2-6: Green Infrastructure. Encourage green infrastructure installations that rely on natural processes for stormwater treatment/drainage, groundwater recharge and flood control.

Policy LU-2-7: Public Green Infrastructure. Incorporate green infrastructure into street and rights -of-way wherever practicable, including curb cuts, flow - through planters and bioswales that slow stormwater runoff by dispersing it to vegetated areas, harvesting and use of runoff, and promote infiltration and use of bioretention to clean stormwater runoff.

Implementation of the policies described above would reduce the environmental impacts associated with groundwater and groundwater quality to less than significant and no further mitigation is required. (Draft EIR, pp. 4.9-9 through 4.9-11.)

3. Erosion or Siltation
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site?
Findings

Finding: Less than significant. (Draft EIR, p. 4.9-11.) Explanation: The Town of Colma has limited vacant parcels and new development under the Project would primarily come from redevelopment of infill sites with higher intensities, with some new development area around the center of the town.

Grading, construction, and general development of a site with urban and infill uses has the potential to alter infiltration and runoff processes by introducing impervious uses that absorb less rainfall and moisture.

However, the construction of underground storm drain, as needed, and as part of future development projects in the town could provide for efficient conveyance of runoff to downstream locations of discharge. As new impervious surfaces are added to areas, and as surface and underground drainage conveyance becomes more efficient and more concentrated, the natural infiltration and storage processes are reduced. This in turn could result in increasing the frequency, volume and flow rate of stormwater runoff, increased downstream flooding and/or erosion/sedimentation processes, even outside the town of Colma boundaries.

However, the town also has to comply with the San Mateo Countywide Water Pollutions Prevention Program which addresses issues related to stormwater pollution, which may include, but is not limited to flooding, sedimentation reduction, erosion, and water quality. New development or even redevelopment activities under the 2040 GPU may involve land clearing, grading. Ground disturbance activities that have the potential to temporarily increase soil erosion rates or affect exiting water quality in a project construction area. On both developed and undeveloped sites, compliance with the MRP requires that projects that alter more than 5,000 square feet of land area are required to include stormwater treatment measures that would allow for the treatment and retention of surface runoff. This would improve water quality and allow for ground water recharge opportunities on redeveloped sites and mit igate the impact of development on vacant sites. The stormwater treatment measures would also slow surface runoff before it enters the storm drain system, reducing the load.

Moreover, t he following proposed General Plan policies that address stormwater and drainage:

Policy OSC-4-6: Stormwater Runoff. Require large- scale projects (over 0.5 acres) to channel surface and roof runoff to on- site detention facilities to facilitate groundwater recharge, reduce stormwater pollution, and mitigate flooding of Colma Creek.

Policy OSC-4-8: Colma Creek Enhancements. Enhance Colma Creek where possible by concrete channel removal, adding landscaping, public pathways, and sitting areas.

Findings

Policy CS-3-2: Maintain Drainage Facilities. Maintain drainage facilities to accommodate the flow capacity of Colma Creek through Colma to accommodate the storm water runoff from a 100-year storm.

Policy CS-3-4: S tormwater Detention. Require new developments over one half acre in size to construct on -site storm water detention facilities which contribute runoff to Colma Creek in order to store the difference in runoff between the 10-year pre-development storm (original natural state) and the 100- year post-development storm. Any stormwater release should be at the 10- year predevelopment rate.

Policy LU-2-5: Green Infrastructure Plan. Implement a Green Infrastructure Plan to ensure compliance with the Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit.

Implementation of the General Plan Update policies LU-2-6, LU-2-7, OSC- 4-5 and the policies described above manage stormwater runoff and provides opportunities for storm water retention and treatment. For the reasons discussed above and in the EIR , the impacts associated with the increase of impervious surfaces and the alteration of drainage patterns would be reduced to less than significant and no further mitigation is required. (Draft EIR, pp. 4.9-11 through 4.9-12.)

4. Flooding
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site? Finding: Less than significant. (Draft EIR, pp. 4.9-11 through 4.9-12.) Explanation: The 2040 General Plan Update would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site.

The Town must comply with the San Mateo Countywide Water Pollution s Prevention Program, which addresses issues related to stormwater pollution, which may include, but is not limited to flooding, sedimentation reduction, erosion, and water quality. Moreover, o n both developed and undeveloped sites, compliance with the MRP requires that projects that alter more than 5,000 square feet of land area are required to include stormwater treatment measures that would allow for the treatment and retention of surface runoff. This would improve water quality and allow for ground water recharge opportunities on redeveloped sites and mitigate the impact of development on vacant sites. The stormwater treatment Findings

measures would also slow surface runoff before it enters the storm drain system, reducing the load.

Implementation of the General Plan Update policies LU-2-6, LU-2-7, OSC- 4-5, OSC-4-6, OSC-4-8, CS-3-2, CS-3-4, and LU -2-5 manage stormwater runoff and provides opportunities for storm water retention and treatment.

With the General Plan Update policies, the impacts associated with the increase of impervious surfaces and the alteration of drainage patterns would be reduced to less than significant and no further mitigation is required. (Draft EIR, pp. 4.9-11 through 4.9-12.)

5. Runoff
Threshold: Would the Project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned sto rmwater drainage systems or provide substantially additional sources of polluted runoff or impede or redirect flood flows?
Finding: Less than significant. (Draft EIR)
Explanation: The 2040 General Plan Update would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantially additional sources of polluted runoff or impede or redirect flood flows.

The T own also has to comply with the San Mateo Countywide Water Pollutions Prevention Program which addresses issues related to stormwater pollution, which may include, but is not limited to flooding, sedimentation reduction, erosion, and water quality. Moreover, on both developed and undeveloped sites, compliance with the MRP requires that projects that alter more than 5,000 square feet of land area are required to include stormwater treatment measures that would allow for the treatment and retention of surface runoff. This would improve water quality and allow for ground water recharge opportunities on redeveloped sites and mitigate the impact of development on vacant sites. The stormwater treatment measures would also slow surface runoff before it enters the storm drain system, reducing the load.

Moreover, t he following proposed General Plan policies that address stormwater and drainage:

Policy OSC-4-6: Stormwater Runoff. Require large- scale projects (over 0.5 acres) to channel surface and roof runoff to on- site detention facilities to facilitate Findings

groundwater recharge, reduce stormwater pollution, and mitigate flooding of Colma Creek.

Policy OSC-4-8: Colma Creek Enhancement s. Enhance Colma Creek where possible by concrete channel removal, adding landscaping, public pathways, and sitting areas.

Policy CS-3-2: Maintain Drainage Facilities. Maintain drainage facilities to accommodate the flow capacity of Colma Creek through Co lma to accommodate the storm water runoff from a 100-year storm.

Policy CS-3-4: S tormwater Detention. Require new developments over one half acre in size to construct on -site storm water detention facilities which contribute runoff to Colma Creek in order to store the difference in runoff between the 10-year pre-development storm (original natural state) and the 100- year post-development storm. Any stormwater release should be at the 10- year predevelopment rate.

Policy LU-2-5: Green Infrastructure Plan. Implement a Green Infrastructure Plan to ensure compliance with the Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit.

Implementation of the General Plan Update policies LU-2-6, LU-2-7, OSC- 4-5 and the policies des cribed above manage stormwater runoff and provides opportunities for storm water retention and treatment. For these reasons and the reasons discussed in the EIR, the impacts associated with the increase of impervious surfaces and the alteration of drainage patterns would be reduced to less than significant and no further mitigation is required. (Draft EIR, pp. 4.9-11 through 4.9-12.)

6. Flood Hazard
Threshold: In flood hazard, tsunami, or seiche zones, would the Project risk release of pollutants due to project inundation?
Finding: No impact. (Draft EIR, p. 4.9-12.)
Explanation: Tsunamis and seiches have not been of historic flooding concern for this area and the implementation of the 2040 General Update will not increase this risk for future development projects. There will be no impact and no further mitigation is required. (Draft EIR, pp. 4.9-12 through 4.9-13.)

7. Water Quality Control Plan
Threshold: Would the Project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan? Finding: Less than significant. (Draft EIR, p. 4.9-13.) Explanation: The Planning Area falls within the jurisdiction of the California Regional Water Quality Control Board, San Francisco Bay Region 2 (RWQCB). The Findings

Bay area’s RWQCB overall mission is to protect area’s overall surface water and groundwater quality.

The town’s 2040 GPU does propose additional development in the town over the next 20 years. However, this Program level EIR (PEIR) does not evaluate specific development projects and related impacts to surface water and groundwater, future development and redevelopment activities would have to comply with all construction related General Permit and BMPs. Erosion control, site runoff activities, potential soil and groundwater contamination would have to also comply with existing water quality control plan and groundwater management plan.

Implementation of Policies OSC 4-1, OSC 4-2-, OSC-4-3, OSC-4-4, OSC-4- 5, OSC-4-6, OSC-4-8, OSC-4-9, CS-3-2, CS-3-4, LU-2-4, LU-2-5, LU-2-6, LU-2-7 would reduce the environmental impacts associated with groundwater management to less than significant and no further mitigation is required. (Draft EIR, p. 4.9-13.)

J. LAND USE AND PLANNING

1. Established Communities
Threshold: Would the Project physically divide an established community? Finding: Less than significant. (Draft EIR, p. 4.10-11.) Explanation: The type of project most likely to have the effect of physically dividing an established community would be a major new road, highway, or similar infrastructure, none of which are proposed as a part of the town’s 2040 GPU. The Planning Area currently includes a majority of cemetery uses and some residential, commercial office and public/semi-public uses, with very little space for either new development or infill redevelopment. Future development projects in the town would include the redevelopment of the town center, the commercial core and areas east of Hillside Boulevard and would not separate established communities or neighborhoods. Further, no new transportation corridors are being planned for under the 2040 GPU which could have the potential to divide established communities. Given that the proposed GPU will not divide an established community, the impact of proposed P
roject, the 2040 Town of Colma General Plan is considered less than significant.

Moreover, the following proposed General Plan policies address compatible land uses and existing communities:

Policy LU-1-1: General Plan Land Use Diagram. Maintain and implement a Land Use Diagram for purposes of describing the types of allowed land uses by geographic location and the density and/or intensity of allowed uses within each designation.

Findings

Policy LU-1-2 Zoning Consistency. Ensure that zoning designations are consistent with the General Land Use Diagram (Figure LU-4).

Policy LU-6-1: New Incompatible Land Uses. The Town shall prohibit the introduction of new incompatible land uses and environmental hazards into existing residential areas.

Policy LU-10-1: Neighborhood and small scale commercial and service uses.

Neighborhood and small scale and service uses are encouraged on the east side of El Camino Real from the BART bridge north.

Policy LU-10-2: El Camino Real Housing. Limit housing on El Camino Real to the Town Center site and existing sites by the BART station.

Policy LU-10-3: Mixed Use and Nonresidential Development. Limit parking, traffic, and other impacts of mixed -use and nonresidential development on adjacent uses and promote high-quality architectural design and effective transportation options.

Implementation of the policies described above would further reduce any impacts to a less th an significant regarding potential divisions to established communities. No mitigation measure are required. (Draft EIR, pp. 4.10-11 through 4.10-12.)

2. Conflicts With Plans
Threshold: Would the Project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Finding: Less than significant. (Draft EIR, p. 4.10-12.) Explanation: T he Project proposes few changes that could potentially alter the future development proposed in the town. The proposed Project would allow for an additional 328 residential units, 992,500 square feet of commercial uses, and 35,000 square feet of office uses in the Sterling Park, Mission Road, Hillside Boulevard, Commercial Core Planning Areas as well as the Bocci Center, Town Center and Sandblaster sites.

As set forth by state law, the General Plan serves as the primary planning document for a jurisdiction and subordinate documents and plans should be updated to be consistent with any changes to a jurisdiction’s existing General Plan. Future development and infrastructure projects will be considered by the town, each project will be evaluated for conformance by the town’s General Plan, Zoning Ordinance, and other relevant plans and regulations.

The proposed Project revises many existing goals and policies and includes new goals, policies and actions to support the town’s vision for 2040. The policies and programs address many topics including sustainability, Findings

preservation of communities and historic resources and economic development. The update also reflects current codes, design guidelines, and master plans that have been initiated or adopted by the town since the last update. In addition, the Project will update the town’s Land Use Map with more defined uses such separating the Residential land use designation to Low Density Residential and Medium Density Residential, minor revisions to established goals and policies, as well as new goals and policies to encou rage future mixed -use development/redevelopment projects. The Project would also reflect codes, design guidelines, master plans and other programs that have been initiated or adopted by the town since the last GPU. As needed, other regulations such as the town’s existing plans, programs, policies or other implementing tools, may need to be updated to effectively implement the Project . The town’s Planning Department has primary responsibility for administering the laws, regulations and requirements that pertain to the physical development of the town of Colma. Amendments may also be needed from time to time to conform to State or federal law passed since adoption of the Project .

The proposed Land Use Element has been prepared to be consistent with the other Elements of the GPU, and would therefore not conflict with other plans, policies or regulations adopted to mitigate any environmental effects. Any future projects would have to be analyzed for their particulate potential environmental impacts pursuant with CEQA. Therefore, the proposed Project would have a less than significant impact with regard to conflicts with applicable land use plans, policies or regulations.

Moreover, t he following proposed General Plan policies address the consistency with existing plans:

Policy LU-1-1: General Plan Land Use Diagram. Maintain and implement a Land Use Diagram for purposes of describing the types of allowed land uses by geographic location and the density and/or intensity of allowed uses within each designation.

Policy LU-1-2 Zoning Consistency. Ensure that zoning designations are consistent with the General Land Use Diagram (Figure LU-4).

Policy LU-2-5: Green Infrastructure Plan. Implement a Green Infrastructure Plan to ensure compliance with the Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit.

Policy LU-2-11: Climate Action Plan. Maintain a Climate Action Plan and continue to partner with San Mateo County’s Regional Climate Action Planning Suite (RICAPS) to prepare community-wide greenhouse gas inventories.

Policy LU- 5-1: Regional Cooperation. Participate with other cities in the county and across the region in working towards solutions to the issues of regional land use, housing, homelessness, and transportation planning through partnership with the Association of Bay Area Government s, the Findings

Metropolitan Transportation Commission, and the San Mateo City/County Association of Governments (C/CAG).

Policy OSC-3-4: GHG Reduction. Implement the Climate Action Plan to achieve GHG reduction targets that are consistent with the State Scoping Plan, AB 32, and SB 32 and the Town’s goals.

Policy OSC-6-2: Tribal Consultation Compliance. Comply with SB 18,AB 52, and other applicable State and federal laws by consulting with local California Native American tribes prior to development decisions or General Plan or Specific Plan amendments. Respect tribal policies regarding confidentiality of information about tribal resources or sacred sites.

Policy CS-3-1: Participate in Regional Adaptation Efforts. Coordinate with regional agencies, such as the San Francisco Bay Conservation and Development Commission (BCDC) and the Bay Area Regional Collaborative (BARC), in adaptation planning.

Policy CS-7-1: Hazard Mitigation Plan. Implement, maintain and update the Local Hazard Mitigation Plan which is part of the larger County Hazard Mitigation Plan.

Policy CS-7-2: Emergency Management Plan. Continue to participate with San Mateo County’s mutual aid programs and plans for community emergency preparedness.

Policy CS-9-1: ALUC Plan. Req uire development within the Airport Influence Area B, designated in the Airport Land Use Compatibility (ALUC) Plan of the San Francisco International Airport, to comply with all applicable federal and State laws with respect to land use safety and airspace protection criteria.

Policy CS-9-2: Airport Land Use Commission Review. Require that all future land use actions and/or associated development conforms to the relevant height, aircraft noise, and safety policies and compatibility criteria contained in the most recently adopted version of the ALUC Plan for the environs of San Francisco International Airport.

Policy M-3-3: Regional Transportation Planning. Actively participate in and support regional transportation planning efforts.

Policy HR-1-1: General Plan Consistency. Ensure that future plans, ordinances, and City programs are complimentary to the historic preservation goals and policies contained within the Town’s Historic Resources Element.

For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update would have less than significant impacts relating to this issue and no mitigation measures would be required. (Draft EIR, pp. 4.10- 11 through 4.10-14.)

K. MINERAL RESOURCES

1. Regional and Statewide Mineral Resources
Findings

Threshold: Would the Project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
Finding: No impact. (Draft EIR, p. 5.0-5.)
Explanation: Colma sand is a well-known construction resource, and had been previously mined from the Hillside Landfill, which closed in 2012. The State Division of Mines and Geology has not classified or designated any areas in the town of Colma as containing regionally significant mineral resources.

Therefore, there would be no impacts to Mineral Resources from the proposed Project. (Draft EIR, p. 5.0-5.)

2. Locally-Important Mineral Resource
Threshold: Would the Project result in the loss of availability of a localy -important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
Finding: No impact. (Draft EIR, p. 5.0-5.)
Explanation: Colma sand is a well-known construction resource, and had been previously mined from the Hillside Landfill, which closed in 2012. The State Division of Mines and Geology has not classified or designated any areas in the town of Colma as containing regionally significant mineral resources.

Therefore, there would be no impacts to Mineral Resources from the proposed Project. (Draft EIR, p. 5.0-5.)
L. NOISE

1. Noise Standards
Threshold: Would the Project result in the generation of 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?
Finding: Less than significant. (Draft EIR, p. 4.11-16.) Explanation: The Project would not result in the generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standa rds established in the local general plan or noise ordinance, or applicable standards of other agencies.

Section 2.05.040 of the town of Colma Municipal Code exempts construction noise from the Noise Limitation included in Section 2.05 of the code. Section 5.04.220 of the Municipal Code includes language regarding standard hours of construction, which should be considered for all future development projects within the Planning Area. As presented in Regulatory Findings

Framework, noise generating construction activity within a radius of 500 feet from any residential unit within town boundaries should only be permitted between the following hours/days: Monday Through Friday 8:00 AM through 7:00 PM; Saturday 9:00 AM through 5:00 PM; Sundays 12:00 PM to 5:00 PM. Noise g enerating construction activity is prohibited on all of the Federal Holidays listed in the Regulatory Framework Section above.

The Building Official, or his or her designee, may grant an exception for special conditions when requested in writing and approved by the Building Official, or his or her designee, prior to the start of the noise generating noise activity.

For projects more than 500 feet from a residential unit in the town of Colma, construction hours shall be assigned on a project -by-project basis by the Building Official, or his or her designee, or as established within a project’s Conditions of Approval, based on evaluation of potential noise - related impacts on surrounding uses. See the Regulatory Framework Section for additional information about the town of Colma Standard Hours of Construction.

All future projects within the Planning Area must adhere to the Standard Hours of Construction limitations delineated in the town of Colma Municipal Code. Since construction activities could temporarily increase the existing ambient noise environment around nearby sensitive receptors, construction noise associated with future development within the planning area should be reviewed on a case -by-case basis, and must adhere to Conditions of Approval and any project-specific quantitative noise standards, if applicable.

Conditions of Approval or other construction noise requirements will vary on a case -by-case basis, however, neither CEQA nor the town of Colma Municipal Code provides quantitative significance thresholds or guidelines for construction noise impacts within the planning area. As such, where quantitative construction criteria apply to future developments within the planning area, project construction noise criteria must be developed on a project-specific basis. Project construction noise criteria should account for the existing noise environment, the absolute noise levels during construction activities, the duration of the construction, and the adjacent land use(s). The Federal Transit Administration (FTA) provides several construction noise standards that would apply to future developments within the Planning Area. While the following guidelines may not apply to all developments within the planning area, the following guidelines can be considered r easonable criteria for assessment. If these criteria are exceeded, there may be adverse community reaction. The FTA’s general assessment of construction noise standards are summarized in Table 4.11- 4: General Assessment Guidelines for Construction Noise Impacts of the Draft EIR.

Findings

At this time, details about specific construction activities associated with future developments within the planning area are not known. Future projects within the town of Colma will be required to undergo separate CEQA analyses and will be required to mitigate noise effects to a less than significant level and no mitigation measures are required.

The proposed Project is expected to result in increased traffic noise levels throughout the planning area. To determine the significance of increases in roadway noise levels throughout the town, this analysis considers typical human response to noise, described above. Based on this methodology, all noise level increases in excess of 5 dB are considered significant; noise level increases of 3 dB – that are in proximity to residential land uses – are considered significant. Estimated roadway noise levels associated with existing conditions and Future (2040) plus project conditions, as well as the estimated noise level increase, are presented in Table 4.11-5: Noise Level Increases over Study Area Roadways of the Draft EIR.

As shown in Table 4.11-5 of the Draft EIR, all roadway noise increases due to implementation of the proposed general plan are expected to be less than 3 dB; as such, increases in roadway noise are exp ected to be less than significant and no mitigation is required. (Draft EIR, pp. 4.11- 16 through 4.11-18.)

2. Vibration
Threshold: Would the Project result in the exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? Finding: Less than significant. (Draft EIR, p. 4.11-18.) Explanation: Implementation of the town of Colma General Plan Update would consist of many future developments within the planning area. Construction of new development within the planning area has the potential to expose people and buildings to high levels of ground -borne vibration. Although vibration levels from construction activities rarely reach the level of causing building damage, construction -related vibration has the potential to cause annoyance at nearby sensitive receivers. The effects of construction vibration vary depending on the intensity of the construction activities, local soil type, and distance to/land use type of nearby receptors. Construction vibration impacts associated with new development in the planning area would occur from the operation of heavy equipment on the project site. In general, site work and demolition activities typically generate the highest levels of vibration throughout a construction project.

Construction activities associated with future development within the planning area would be temporary. All future projects within the p lanning area must adhere to the Standard Hours of Construction limitations delineated in the town of Colma Municipal Code. Since construction activities could potentially generate high levels of vibration, construction Findings

vibration associated with future development within the planning area should be reviewed on a case-by-case basis and must adhere to Conditions of Approval and any project -specific quantitative vibration standards, if applicable.

At this time, details about specific construction activities associated with future developments within the planning area are not known. Future projects within the town of Colma will be required to undergo separate CEQA analyses and will be required to mitigate vibration effects to a less than significant level. The F TA provides industry- standard construction vibration standards that could apply to future developments within the planning area.5 While the following guidelines may not apply to all developments within the planning area, the following guidelines can be considered reasonable criteria for assessment. If these criteria are exceeded, there may be adverse community reaction.

The FTA has adopted vibration standards that are used to evaluate potential building damage impacts related to construction activities. Th e vibration damage criteria adopted by the FTA are shown in Table 4.11- 6:

Construction Vibration – Building Damage Criteria of the Draft EIR.

In addition to vibration impact thresholds related to project-related building damage, the FTA also provides standards that quantify acceptable levels of vibration in terms of human perception. The vibration perception (annoyance) criteria adopted by the FTA are shown in Table 4.11- 7:

Construction Vibration – Human Perception of the Draft EIR.

Vibration impact criteria that would apply to many developments within the planning area are provided above. Future projects within the Town of Colma will be required to undergo separate CEQA analyses and will be required to mitigate vibration effects to a less than significant level. Given the limited potential for construction vibration impacts associated with the General Plan update, effects from construction vibration are considered less than significant and no mitigation measures are required.

The Project does not introduce any new sources of industrial land uses, or transportation sources that would generate significant levels of vibration.

Traffic, including heavy trucks traveling on a highway, rarely generates vibration amplitudes high enough to cause structural or cosmetic damage.

Vibration impacts associated with new zoning or transportation uses are considered less than significant and no mitigation measures are required. (Draft EIR, pp. 4.11-18 through 4.11-21.)

3. Airport Noise
Threshold: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles Findings

of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? Finding: No impact. (Draft EIR, p. 4.11-21.)
Explanation: T he entire town of Colma is outside of the CNEL 65 dBA noise contour associated with the San Francisco International Airport. People residing or working in the Planning Area are not expected to be exposed to excessive noise levels associated with airports. There would be no impact related to noise levels associated with airports and no mitigation measures are required. (Draft EIR, p. 4.11-21.)

M. POPULATION AND HOUSING

1. Population Growth
Threshold: Would the Project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of road or other infrastructure?
Finding: Less than significant. (Draft EIR, p. 4.12-8.) Explanation: The proposed Project could accommodate limited additional growth through mixed use development, single-family uses, as well as through the expansion of existing business locations. The Project proposes updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas include development standards such as height, FAR, and density as well as development standard bonuses for specific uses in opportunity sites. In addition, the proposed GPU introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to res ult in a total 2,269 people within the Planning Area at buildout (2040). This represents Findings

an increase of approximately 765 persons (from a current population of 1,504 people) over the next 20 years, within the Planning Area.

Since the proposed Project is an update to the town’s existing General Plan (including the Land Use and Circulation elements as well as the Climate Action Plan), the P roject by itself does not propose any specific development at this time. There will be a slight buildout of jobs and housing under future development proposed by the Project. Cemetery land uses account for approximately 75% of the town’s land area, while approximately 13% of land area is available for residential and commercial uses. Population projections by the Associatio n of Bay Area Governments (ABAG) only increase the town’s population by approximately 765 people (from 1,5054 in 2010 to 2,269 in the Buildout Year of 2040) and by 328 households between 2010 and 2040 (Buildout Year). There should not be any substantial unplanned development or population growth in the town of Colma under full buildout of the GPU. Moreover, any population growth in the town over the next 20 years would still remain within the growth levels projected Statewide.

Moreover, t he following proposed General Plan policies address future population growth for the town:

Policy LU-1-1: General Plan Land Use Diagram. Maintain and implement a Land Use Diagram for purposes of describing the types of allowed land uses by geographic location and the density and/or intensity of allowed uses within each designation.

Policy LU-1-2: Zoning Consistency. Ensure that zoning designations are consistent with the General Land Use Diagram.

Policy LU-1-3: Balance New Development with Existing Setting. Prioritize ne w and higher density development consistent with the Town’s Planning Areas to ensure new development is context sensitive and contributes to creating a strong sense of place. New development shall serve to protect and enhance the positive aesthetic qualities of the Town and each geographic area.

Policy LU-1-5: Clear and Predictable Development Standards. Strive to adopt and communicate clear and predictable development standards to ensure new development meets the expectations of the Town.

For the reasons discussed above and in the EIR, the Project would have a less than significant impact relating to this issue and no mitigation measures are required. (Draft EIR, pp. 4.12-8 through 4.12-9.)

2. Displacement of Housing
Threshold: Would the Project displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere; and Findings

displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?
Finding: Less than significant. (Draft EIR, p. 4.12-9.) Explanation: While the Project does not directly propose any new development, now, or within the GPU’s planning horizon of 20 years, the Project would allow for the future development of currently vacant lands or the expansion of already developed areas. The proposed growth would be concentrated on the five planning areas proposed under the Project. However, it should be noted that the town of Colma is limited in its areas of additional new housing, which are anticipated to be more mixed-use, multi-family housing than single-family uses. Since the total number of dwelling units can only increase by 328 units up to 2040, displaced residents, if any, should be able to find replacement housing within the Town.

Moreover, t he following proposed General Plan policies address future population growth for the town:

Policy LU-1-1: General Plan Land Use Diagram. Maintain and implement a Land Use Diagram for purposes of describing the types of allowed land uses by geographic location and the density and/or intensity of allowed uses within each designation.

Policy LU-1-3: Balance New Development with Existing Setting. Prioritize new and higher density development consistent with the Town’s Planning Areas to ensure new development is context sensitive and contributes to creating a strong sense of place. New development shall serve to protect and enhance the positive aesthetic qualities of the Town and each geographic area.

Policy LU-3-3: Adequate and Affordable Housing. The Town shall continue to provide opportunities for a variety of housing types at varying densities and affordability levels.

Policy LU-4-2: Adequacy to Serve New and Existing Developments. The Town shall continue to ensure that new and existing developments can be adequately served by municipal services and facilities in accordance with Town standards.

Implementation of Policies LU -1-1, LU -1-2, LU -1-3 and LU -1-5 would further ensure that the impacts to the displacement of existing population is a less than significant impact and no mitigation measures are required. (Draft EIR, p. 4.12-9.)

N. PUBLIC SERVICES

1. Fire Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of Findings

which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection?
Finding: Less than significant. (Draft EIR, p. 4.13-5.) Explanation: The town of Colma is primarily built out and all new development would primarily come from infill redevelopment with limited new areas for commercial and residential uses. The Project
proposes few changes that
could potentially alter the future development proposed in the town. The proposed Project updates the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed Project introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Bou levard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximately 765 persons (from a current population of 1,504 people) over the next 20 years, within the Planning Area. However, even the limited redevelopment and growth would result in increased demand for fire protection services over the town’s Planning Area buildout.

Though not located within its boundaries, the town is serviced by a fire station located less than one mile to the north of the town limit. The proposed Project does not identify the location of any new fire stations within the town’s boundaries nor does it require future development to provide a site for a fire station. Should the future residential and commercial uses in the town of Colma require additional fire protection services and stations, these would be addressed in the appropriate project- level environmental document prepared at that time. Also, any new development would be subject to California Fire Code regulations regarding fire resistance rated construction, fire protection systems, appropriate fire apparatus access, means of egress, and fire safety during construction and operation. For the following reasons, the Project would not result in adverse physical impacts associated with the provision of new or physically Findings

altered fire protection services and facilities, and impacts would be less than significant.

Moreover, the following proposed General Plan policies address fire safety for the Town of Colma:

Policy CS-4-1: Alternate EOC. Establish an alternative Emergency Operations Center (EOC) if the existing EOC is not operational during a fire event.

Policy CS-4-2: Mutual Aid Agreements. The Town shall continue to participate in San Mateo County mutual aid agreements related to fire protection.

Policy CS-4-3: Fire Prevention Education. Provide regular public education an d fire safety programs to the Town’s residents and businesses.

Policy CS-5-1: Adequate Water Supplies. Require new development projects to document adequate water supplies for fire suppression.

Policy CS-5-2: Removal of Fire Hazards. Ensure the Town’s code enforcement programs promote the removal of fire hazards such as (but not limited to) litter, rubbish, overgrown vegetation, and dilapidated or abandoned structures.

Policy CS-5-3: Building Fire Codes. Require that all buildings and facilities comply with local, State, and federal regulatory standards, such as the California Building and Fire Codes as well as other applicable fire safety standards.

Policy CS-5-4: Urban Fire Risks. Work with the Colma Fire Protection District to maintain an ongoing fire inspection program to reduce fire hazards associated with multifamily development, critical facilities, public assembly facilities, industrial buildings, and nonresidential buildings.

For the foregoing reasons and the reasons discussed in the EIR, impacts relating to fire protection services would be less than significant and no mitigation is required. (Draft EIR, pp. 4.13-5 through 4.13-6.)

2. Police Protection
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for Sheriff Law Enforcement Services?
Finding: Less than significant. (Draft EIR, p. 4.13-8.) Explanation: The Project updates the tow n’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 Findings

square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

The town of Colma’s police protection is provided by 33 employees consisting of 19 sworn officers and supporting personnel. The town’s police department is located at the center of the town at 1199 El Camino Real.

The Department provides dispatch and detective services, community service outreach, and participates in the Daly City/North San Mateo County Special Weapons and Tactics (SWAT) team.

The Department is organized into four divisions: Administration, Patrol, Communications, and Grants, each with specific duties and staff. The Administration, Communications, and Grants divisions provide oversight, clerical and record keeping services, funding and officer tr aining costs of the entire police department. The department’s Police Patrol Division responds to all security service related needs, enforces traffic laws, investigates crimes against people and property, and addresses neighborhood quality of life issues.

Future growth under the town’s 2040 GPU may result in the increased need for additional law enforcement officials. It is anticipated that the town may increase its current population of 1,504 persons and 490 households to about 2,269 persons and 660 households. This constitutes a 0.28% change in population and a 0.26% change in the number of households under the GPU buildout year and may result in a small increase to the town’s police force. The national average of police officer per residents is approximately

2.4 officers per 1,000 residents (FBI Police Employee data, 2011).

Therefore the town would need approximately two or three additional officers on its police force, under the 2040 GPU buildout.

Moreover, t he following proposed General Plan policies address law enforcement for the town of Colma:

Policy CS-8.1: Staffing Levels. Maintain sufficient police staffing levels, including sworn officers and volunteer support, necessary to meet current and projected community needs.

Policy CS-8.2: Facilities Planning. Develop, maintain, and implement a Police Department Facilities Master Plan that guides the provision of equipment, facilities, training.

Policy CS-8.3: Response Times. Identify, monitor, and achieve appropriate minimu m police response times of no more than 10 minutes, for all call levels.

Findings

Policy CS-8.4: Communication. Encourage and maintain two-way communication with the Town of Colma community to facilitate effective policing.

For the foregoing reasons and the reasons discussed in the EIR, the 2040 General Plan Update would a less than significant relating to police protection services, and no mitigation is required. (Draft EIR, pp. 4.13 -8 through 4.13-9.)

3. Schools
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable se rvice ratios, response times, or other performance objectives for schools?
Finding: Less than significant. (Draft EIR, p. 4.13-16.) Explanation: The Project proposes updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed Project introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximate ly 765 persons over existing conditions within the Planning Area. Any increases in the town’s future population could therefore increase the use of existing neighborhood and regional parks and recreational facilities and result in eventual deterioration of such existing facilities.

Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town, through its 2040 GPU, is however committed to providing public park and recreation facilities that meet the needs of its residents. Since the town does not have the capacity to create additional recreational facilities, this commitment may require the Findings

town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law. Typical environmental impacts regarding the construction and operation of parks and recreational facilities include noise (during construction and associated with playfields and playgrounds), air quality (during the construction of the facility), biological resources (depending on location), historic/cultural resources (depending on location), public services and utilities (demand for police and fire protection, water, and wastewater service), and traffic on a local neighborhood level.

Moreover, the following proposed General Plan policies address parks and recreation land:

Policy OSC-1-2: Flexible Open Space Land Uses. Allow for the use of open space and future cemetery lands for commercial nursery, farming, or other uses which provide a community benefit.

Policy OSC-1-4: Pedestrian Trails, Bikeways Walkways. Expand and improve pedestrian trails, bikeways, and walkways to connect trails and allow access to open space land and regional trail facilities.

Policy OSC-1-5: Colma Creek Trail. Coordinate with the City of South San Francisco to provide continuous pedestrian access from the Colma BART station along El Camino Real to the southern border of the town.

Policy OSC-2-1: Open Space for Recreation Use. Develop and maintain open spaces and recreation areas that are conveniently located, properly designed, and well-maintained to serve the recreation needs and healthy living of the entire community.

Policy OSC-2-2: Recreation Requirements for New Developments. Require dedication of improved land, or payment of a fee in lieu of, for park and recreation land for all residential uses.

Policy OSC-2-3: Expansion of Recreation Space. Acquire and enhance properties within Colma for recreation and public use if opportunities become available.

Policy OSC-4-7: Colma Creek Bank Setback. Protect and enhance areas of Colma Creek for riparian habitat, linear park opportunities, and aesthetic value.

Policy OSC-4-8: Colma Creek Enhancements. Enhance Colma Creek where possible by concrete channel removal, adding landscaping, public pathways, and sitting areas.

For the foregoing reasons and the reasons discussed in the EIR, the Proejct’s impacts relating to this issue are less than significant and no mitigation measures are required. (Draft EIR, pp. 4.13- 16 through 4.13 -

17.)

Findings

4. Parks
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable se rvice ratios, response times, or other performance objectives for parks?
Finding: Less than significant. (Draft EIR, p. 4.13-16.) Explanation: The Project proposes updates the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed Project
introduces new land
uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximately 765 persons over existing conditions within the Planning Area. Any increases in the town’s future population could therefore increase the use of existing neighborhood and regional parks and recreational facilities and result in eventual deterioration of such existing facilities.

Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town, through its 2040 GPU, is however committed to providing public park and recreation facilities that meet the needs of its residents. Since the town does not have the capacity to create additional recreational facilities, this commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law. Typical environmental impacts regarding the construction and operation of parks and recreational facilities include noise (during construction and associated Findings

with playfields and playgrounds), air quality (during the construction of the facility), biological resources (depending on l ocation), historic/cultural resources (depending on location), public services and utilities (demand for police and fire protection, water, and wastewater service), and traffic on a local neighborhood level.

Implementation of Policies OSC-1-2, OSC-1-4, OSC-1-5, OSC-2-1, OSC-2- 2, OSC-2- 3, OSC-4- 7, and OSC-4-8 would further reduce the Project’s impacts to less than significant and no mitigation measures are required. (Draft EIR, pp. 4.13-16 through 4.13-17.)

5. Other Public Facilities
Threshold: Would the Project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable se rvice ratios, response times, or other performance objectives for other public facilities?
Finding: Less than significant. (Draft EIR, p. 4.13-16.) Explanation: The Project proposes updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed Project
introduces new land
uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximate ly 765 persons over existing conditions within the Planning Area. Any increases in the town’s future population could therefore increase the use of existing neighborhood and regional parks and recreational facilities and result in eventual deterioration of such existing facilities.

Findings

Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town, through its 2040 GPU, is however committed to providing public park and recreation facilities that meet the needs of its residents. Since the town does not have the capacity to create additional recreational facilities, this commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law. Typical environmental impacts regarding the construction and operation of parks and recreational facilities include noise (during construction and associated with playfields and playgrounds), air quality (during the construction of the facility), biological resources (depending on location), historic/cultural resources (depending on location), public services and utilities (demand for police and fire protection, water, and wastewater service), and traffic on a local neighborhood level.

Moreover, the following proposed General Plan policies address parks and recreation land:

Policy OSC-1-2: Flexible Open Space Land Uses. Allow for the use of open space and future cemetery lands for commercial nursery, farming, or other uses which provide a community benefit.

Policy OSC-1-4: Pedestrian Trails, Bikeways Walkways. Expand and improve pedestrian trails, bikeways, and walkways to connect trails and allow access to open space land and regional trail facilities.

Policy OSC-1-5: Colma Creek Trail. Coordinate with the City of South San Francisco to provide continuous pedestrian access from the Colma BART station along El Camino Real to the southern border of the town.

Policy OSC-2-1: Open Space for Recreation Use. Develop and maintain open spaces and recreation areas that are conveniently located, properly designed, and well-maintained to serve the recreation needs and healthy living of the entire community.

Policy OSC-2-2: Recreation Requirements for New Developments. Require dedication of improved land, or payment of a fee in lieu of, for park and recreation land for all residential uses.

Policy OSC-2-3: Expansion of Recreation Space. Acquire and enhance properties within Colma for recreation and public use if opportunities become available.

Policy OSC-4-7: Colma Creek Bank Setback. Protect and enhance areas of Colma Creek for riparian habitat, linear park opportunities, and aesthetic value.

Policy OSC-4-8: Colma Creek Enhancements. Enhance Colma Creek where possible by concrete channel removal, adding landscaping, public pathways, and sitting areas.

Findings

Implementation of the policies described above would further reduce the Project’s impacts to less than significant and no mitigation measures are required. (Draft EIR, pp. 4.13-16 through 4.13-17.)

O. RECREATION

1. Increased Use
Threshold: Would the Project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? Finding: Less than significant. (Draft EIR)
Explanation: The Project p roposes updates the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed Project
introduces new land
uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential un its, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed Project is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximately 765 persons over existing conditions within the Planning Area. Any increases in the town’s future population could therefore increase the use of existing neighborhood and regional parks and recreational facilities and result in eventual deterioration of such existing facilities.

Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town, through its 2040 GPU, is however committed to providing public park and recreation facilities that meet the needs of its residents. Since the town does not have the capacity to create additional recreational facilities, this commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or Findings

expansion of existing recreational facilities) wo uld be subject to its own environmental review pursuant to CEQA and State law. Typical environmental impacts regarding the construction and operation of parks and recreational facilities include noise (during construction and associated with playfields and playgrounds), air quality (during the construction of the facility), biological resources (depending on location), historic/cultural resources (depending on location), public services and utilities (demand for police and fire protection, water, and wastewater service), and traffic on a local neighborhood level.

Implementation of Policies OSC-1-2, OSC-1-4, OSC-1-5, OSC-2-1, OSC-2- 2, OSC-2-3, OSC-4-7, OSC-4-8 would further reduce the Project’s impacts to less than significant and no mitigation measures are required. (Draft EIR, pp. 4.13-16 through 4.13-17.)

2. Construction and Expansion
Threshold: Does the Project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Finding: Less than significant. (Draft EIR)
Explanation: The 2040 GPU proposes updates the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. In addition, the proposed GPU introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The 2040 GPU would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Implementation of the proposed General Plan Update is expected to result in a total 2,269 people within the Planning Area at buildout (2040). This represents an increase of approximately 765 persons over existing conditions within the Planning Area. Any increases in the town’s future population could therefore increase the use of existing neighborhood and regional parks and recreational facilities and result in eventual deterioration of such existing facilities.

Findings

Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town, through its 2040 GPU, is however committed to providing public park and recreation facilities that meet the needs of its residents. Since the town does not have the capacity to create additional recreational facilities, this commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law. Typical environmental impacts regarding the construction and operation of parks and recreational facilities include noise (during construction and associated with playfields and playgrounds), air quality (during the construction of the facility), biological resources (depending on location), historic/cultural resources (depending on location), public services and utilities (demand for police and fire protection, water, and wastewater service), and traffic on a local neighborhood level.

Moreover, the following proposed General Plan policies address parks and recreation land:

Policy OSC-1-2: Flexible Open Space Land Uses. Allow for the use of open space and future cemetery lands for commercial nursery, farming, or other uses which provide a community benefit.

Policy OSC -1-4: Pedestrian Trails, Bikeways Walkways. Expand and improve pedestrian trails, bikeways, and walkways to connect trails and allow access to open space land and regional trail facilities.

Policy OSC-1-5: Colma Creek Trail. Coordinate with the City of South San Francisco to provide continuous pedestrian access from the Colma BART station along El Camino Real to the southern border of the town.

Policy OSC-2-1: Open Space for Recreation Use. Develop and maintain open spaces and recreation areas that are conveniently located, properly designed, and well-maintained to serve the recreation needs and healthy living of the entire community.

Policy OSC -2-2: Recreation Requirements for New Developments. Require dedication of improved land, or payment of a fee in lieu of, for park and recreation land for all residential uses.

Policy OSC-2-3: Expansion of Recreation Space. Acquire and enhance properties within Colma for recreation and public use if opportunities become available.

Policy OSC-4-7: Colma Creek Bank Setback. Protect and enhance areas of Colma Creek for riparian habitat, linear park opportunities, and aesthetic value.

Findings

Policy OSC-4-8: Colma Creek Enhancements. Enhance Colma Creek where possible by concrete channel removal, adding landscaping, public pathways, and sitting areas.

For these reasons and the reasons discussed in the EIR, the 2040 General Plan Update would have less than significant impacts relating to this issue, and no mitigation measures are required. (Draft EIR, pp. 4.13 -16 through 4.13-17.)

P. TRANSPORTATION / TRAFFIC

1. Plans, Policies, and Ordinances
Threshold: Would the Project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
Finding: Less than significant. (Draft EIR, p. 4.14-19.) Explanation: Implementation of the proposed Project could lead to increases in the town of Colma’s population and employment, resulting in an associated increase in the demand for transit services offered by BART and SamTrans. While there are no established standards regarding transit levels of service that have been adopted by the Town or transit agencies, the Project includes policies that support transit-oriented development patterns, strengthen ties between the pedestrian and bicycle networks to transit, promote enhancements to transit facilities, and support increased transit coverage and frequencies in the Town of Colma.

Additionally, implementation of the Project would improve the existing bicycle and pedestrian circulation infrastructure and require future development to provide multimodal circulation improvements. Increases in the town’s population and employment that could result under implementation of the Project would also likely lead to increases in pedestrian and bicycle travel beyond current levels.

The Mobility Element developed as part of the Project contains several policies that support access to and the performance of transit, bicycle, and pedestrian facilities. These applicable policies are listed below. Further, the Project includes mixed -use development that is supportive of non- automotive modes.

Moreover, the following General Plan Update policies address the GPU’s potential conflict with a program, plan, ordinance or policy addressing the town’s circulation system:

Findings

Policy M-1.2: Capital Improvement Prioritization. Maintain and upgrade exiting rights-of-way and ensure that the needs of non -motorized travelers are considered in planning, programing, and design of improvements.

Policy M-2-4: Multi-Modal Impact Fee. Consider establishing a transportation impact fee for new development tied to performance measures to generate funds for improving all modes of transportation.

Policy M-3-2: El Camino Real. Ensure that El Camino Real retains its distinct character, while encouraging improvements which support increased multi -modal use.

Policy M-3-4: Transit Funding. Seek joint transportation and transit funding opportunities with adjoining jurisdictions or agencies to improve transit access in and around Colma.

Policy M-3-5: Transportation Gaps. Eliminate gaps in the regional active transportation network in Colma.

Policy M-4-1: Transit Stops. Support the installation of transit stop amenities including shelters, benches, real-time information panels, lighting, bike parking, and bike sharing stations.

Policy M-4-2: Reliable Transportation Services. Encourage SamTrans and other public transit providers to provide service on regular schedules along El Camino Real, arterial streets, and, as feasible, major collectors; support these transportation services to increase the mobility of seniors, the disabled, and others who depend on public transportation.

Policy M-4.3: Consult with SamTrans. Encourage and support various public transit agencies and companies, ride -sharing programs, and other incentive programs that provide residents and visitors with transportation choices other than the private automobile.

Policy M-4.3: Encourage Transportation Options. Encourage and support various public transit agen cies and companies, ride -sharing programs, and other incentive programs that provide residents and visitors with transportation choices other than the private automobile.

Policy M-4.4: Transit Oriented Development. Promote the development of multi - modal mixed -use development at sites surrounding the Colma BART station, where feasible along Mission Road, and at the Town Center site.

Policy M-5-1: Complete Streets. Incorporate Complete Streets infrastructure elements into new streets, street retrofits and certain maintenance projects to encourage multiple modes of travel, based on the modal priorities in Table M-2, as appropriate to the context and determined reasonable and practicable by the Town.

Policy M-5-2: Design for All Travel Modes. Plan, design, and construct transportation projects to safely accommodate the needs of pedestrians, bicyclists, transit riders, motorists, people with mobility challenges, and persons of all ages and abilities.

Findings

Policy M-5-3: Bicycle Connection Coordination. Coordinate with BART, South San Francisco, Daly City, Caltrans, and San Mateo County to plan and implement bicycle and pedestrian improvements which connect with improvements to BART facilities and regional networks.

Policy M-5-4: Accessibility and Universal Design. Prioritize implementation of pedestrian facilities that improve accessibility consistent with guidelines established by the Americans with Disabilities Act (ADA), allowing mobility- impaired users, such as the disabled and seniors, to travel safely and effectively within and beyond the town.

Policy M-5.5: Design of New Development. Require new development to incorporate design that prioritizes safe pedestrian and bicycle travel and accommodate senior citizens, people with mobility challenges, and children.

Policy M-8-1: Parking Standards. Reevaluate minimum parking standards to account for emerging mobility trends, such as shared mobility, micromobility, autonomous vehicles, and future technology changes. The Consider reducing parking requirements for mixed-use developments.

The proposed General Plan policies above address the Project’s conflict with a program, plan, ordinance or policy regarding the town’s circulation system and further reduces any impacts to a level of less than significant and no mitigation is required. (Draft EIR, pp. 4.14-19 through 4.14-20.)

2. VMT
Threshold: Would the Project conflict or be inconsistent with CEQA Guidelines sections 15064.3, subdivision (b)?
Finding: Less than significant. (Draft EIR, p. 4.14-22.) Explanation: The residential and employee VMT under the Current General Plan and the Proposed General Plan Update for the town of Colma are shown in Table

4.14.2: Existing and Future VMT per Resident and Employee of the Draft EIR. As shown in the table, the Project is expected to increase VMT per resident above No Project/Previous General Plan conditions. Home -based VMT per resident is expected to increase by 10% while work -based VMT per employee is expected to decrease by approximately 5% under the Project. This change in VMT could be attributed to the increasing amounts of residents living within the town of Colma under the Project and residents needing to travel further for employment opportunities or other needs given the additional residents. The commute VMT red uction may be explained by increased employment opportunities within the town with the Project and better jobs housing balance for those who live and work in the town. For example, the increase of office, retail, and other uses within the town would decrease the need for the town’s residents to travel long distances inside and outside the town for their employment or other needs, resulting in shorter vehicular travel distances per capita. However, due to the relatively higher increase in population compared to employment, some Findings

residents will need to travel outside the town to reach their employment destinations which may explain the higher home-based VMT per person.

The Project is expected to increase VMT per person above No Project conditions (an increase of 10%, from 9.40 to 10.35). The Project includes policies designed to ensure a VMT threshold is established and Transportation Demand Management (TDM) measures are provided. See the relevant policies to ensure potential VMT impacts are below a level of significance.

The following proposed General Plan policies address vehicle miles traveled:

Policy M-2-1: Reduce Vehicle Miles Traveled. Require new development projects to achieve a reduction in VMT per capita or VMT per service population compared to both baseline VMT performance conditions and General Plan 2040 VMT performance conditions. The Town will regularly monitor baseline VMT to provide updated benchmarks for project applicants.

Encourage use of VMT reduction strategies and methods to encourage non- automobile travel.

Policy M-2-2: Other Traffic Flow Benchmarks. Establish additional traffic flow benchmarks, such as vehicle-hours of travel and safety-related metrics, in order to evaluate and monitor changes in traffic flow over time.

Policy M-2-3: VMT Transportation Performance Measures. Update the Town’s transportation measures and thresholds to use VMT standards for traffic impact analysis rather than LOS.

Policy M-2-6: Development Review Requirements. Require proposed development projects that could result in increased traffic to include improvements that assure LOS levels do not fall below the established minimum standard.

Ensure that improvements are coordinated with roadway improvements programmed for funding through transportat ion-related impact fees and that the operational benefits of large -scale, automobile capacity -focused improvements are balanced against the induced VMT resulting from the improvements.

Policy M-7-1: TDM Program. Continue to participate in the TDM Program as outlined by the San Mateo City/County Association of Governments (C/CAG).

Policy M-7-2: TDM Program for New Development. Require major development proposals to include a detailed, verifiable TDM program for consideration by the Town during the review of the development application.

Policy M-7-3: Vehicle Trip Reduction. Support vehicle trip reduction strategies, including building safer and more inviting transportation networks, supporting connections to high frequency and regional transit, implementing TDM programs, and integrating land use and transportation decisions.

Findings

Implementation of the policies described above would ensure less than significant impacts relating to VMT, and no mitigation measures required. (Draft EIR, pp. 4.14-22 through 4.14-24.)

3. Design Hazards
Threshold: Would the Project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
Finding: Less than significant. (Draft EIR, p. 4.14-20.) Explanation: The town of Colma maintains improvement standards that guide the construction of new transportation facilities to minimize design hazards for all users of the system. Through the Town’s environmental review process, future land use proposals that would add traffic to streets not designed to current standards would be carefully evaluated. If needed, appropriate mitigation measures would be identified, and the project would be conditioned to construct or provide funding for an improvement that would minimize or
eliminate the hazard. Typical improvements include shoulder widening, adding turn pockets, adding sidewalks or crosswalks, realigning sharp curves, prohibiting certain turning movements, and signalizing intersections, among other options. New and upgraded roadways needed to accommodate new development will be designed according to applicable Federal, State, and local design standards.

The types of uses included within the town as part of the Project are generally similar to existing and surrounding uses and thereby are compatible with the existing uses in the Planning Area. Development and infrastructure projects in the town of Colma would be required to comply with the General Plan, Municipal Code, and applicable State and local regulations. In addition, the Mobility Element developed as part of the General Plan Update contains policies in support of roadway network safety and reducing design hazards. These applicable policies are listed below.

Proposed General Plan Update Policies

The following proposed General Plan policies address hazards due to design features:

Policy M-1-1: Vision Zero. Eliminate traffic fatalities and reduce the number of non-fatal collisions by 50 percent by 2040.

Policy M-1-2: Capital Improvement Prioritization. Maintain and upgrade exiting rights-of-way and ensure that the needs of non -motorized travelers are considered in planning, programing, and design of improvements.

Policy M-5-1: Complete Streets. Incorporate Complete Streets infrastructure elements into new streets, street retrofits and certain maintenance projects to Findings

encourage multiple modes of travel, based on the modal priorities in Table M-2, as appropriate to the context and determined reasonable and practicable by the Town.

Policy M-5-2: Design for All Travel Modes. Plan, design, and construct transportation projects to safely accommodate the needs of pedestrians, bicyclists, transit riders, motorists, people with mobility challenges, and persons of all ages and abilities.

Policy M-5-3: Bicycle Connection Coordination. Coordinate with BART, South San Francisco, Daly City, Caltrans, and San Mateo County to plan and implement bicycle and pedestrian improvements which connect with improvements to BART facilities and regional networks.

Policy M-5-4: Accessibility and Universal Design. Prioritize implementation of pedestrian facilities that improve accessibility consistent with guidelines established by the Americans with Disabilities Act (ADA), allowing mobility- impaired users, such as the disabled and seniors, to travel safely and effectively within and beyond the town.

Policy M-5-5: Design of New Development. Require new development to incorporate design that prioritizes safe pedestrian and bicycle travel and accommodate senior citizens, people with mobility challenges, and children.

For the reasons discussed in above and in the EIR, this impact is less than significant and no further mitigation is required. (Draft EIR, pp. 4.14-20 through 4.14-21.)

4. Emergency Access
Threshold: Would the Project result in inadequate emergency access? Finding: Less than significant. (Draft EIR, p. 4.14-22.) Explanation: Implementation of the proposed Project would result in increased development which would increase the number of users on the town’s transportation system. There will be a need to ensure that adequate emergency access provisions are made to accommodate increased population and growth. However, it should be noted that the Project is a
programmatic-level document, and emergency accessibility is typically assessed at the project -level. Adequacy of emergency access associated with future development projects would be analyzed and evaluated in detail through this future environmental review process. Additionally, the Mobility Element developed as part of the General Plan update contains policies in support of emergency access along local roads. These applicable policies are listed below.

Moreover, the following proposed General Plan policies address emergency access:

Findings

Policy M-4-6: Design of New Development. Require new development to incorporate design that considers emergency access and prioritizes safe pedestrian and bicycle travel and accommodates senior citizens, people with mobility challenges, and children.

Policy M-4-7: Emergency Services. Prioritize emergency service needs when developing transportation plans and making transportation network changes.

For the foregoing reasons and the reasons discussed in the EIR, impacts relating to emergency circulation and access are less than significant and no mitigation measures are required. (Draft EIR, p. 4.14-22.)

Q. UTILITIES AND SERVICE SYSTEMS

1. Wastewater Treatment Requirements
Threshold: Would the Project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? Finding: Less than significant. (Draft EIR, p. 4.15-8.) Explanation: The town does not have its own wastewater treatment facilities and is under agreements with the North San Mateo County Sanitation District Treatment Plant and the South San Francisco Water Quality Control Plant for such services. While wastewater treatment capacity is projected to be adequate by the North San Mateo County Sanitation District Treatment Plant, new construction in certain areas in town may require the need to construct a sewer lift station. As a part of the town’s review process, projects are routed to the wastewater treatment districts to determine if a sewer capacity study is required. The sewer capacity study determines if the sewer lift station is required. The South San Francisco Water Quality Control Plant is unable to determine if there will be an impact to their infrastructure without specific project locations and proposed uses. Since there is no project, South San Francisco Water Quality Control Plant will continue to
review project applications for proposed projects within the town and determine if capacity is adequate at that time. Project conditions may be imposed to upgrade existing infrastructure to support proposed projects.

Moreover, t he following proposed General Plan policies address water, sewer and wastewater uses in the town:

Policy OSC-4-1: Comply with Water Quality Regulations. Continue to comply with all State and federal regulations for water quality.

Findings

Policy OSC-4-2: Participation in the San Mateo County Stormwater Pollution Prevention Program (SMCWPPP). Continue to be an active member agency of the SMCWPPP to reduce pollution from being conveyed through the storm water system to the San Francisco Bay.

Policy OSC-4-3: Reclaimed Water. Pursue opportunities to install water recycling infrastructure for Town-owned and cemetery landscape areas.

Policy OSC-4-6: Stormwater Runoff. Require large- scale projects (over 0.5 acres) to channel surface and roof runoff to on -site detention facilities to facilitate groundwater recharge, reduce stormwater pollution, and mitigate flooding of Colma Creek.

Policy OSC-4.-9: Water Quality and Conservation Public Information. Continue to support and coordinate with the Countywide Stormwater Program, Cal Water, and the San Francisco Public Utilities Commission (SFPUC) on their public outreach and education campaigns to conserve and maintain water quality.

Policy CS-3-4: Stormwater Detention. Require new developments over one half acre in size to construct on-site storm water detention facilities which contribute runoff to Colma Creek in order to store the difference in runoff between the 10-year pre-development storm (original natural state) and the 100- year post-development storm. Any stormwater release should be at the 10- year predevelopment rate.

Policy LU-2-4: Low Impact Development. Regulate new development and construction to minimize pollutant and sediment concentrations in receiving waters and ensure that surface water meets or exceeds applicable regulatory water quality standards. Require new development to incorporate Low Impact Development features that treat and reduce surface runoff volumes.

Policy LU-2-6: Green Infrastructure. Encourage green infrastructure installations that rely on natural processes for stormwater treatment/drainage, groundwater recharge and flood control.

Policy LU-4-2: Adequacy to Serve New and Existing Developments. The Town shall continue to ensure that new and existing developments can be adequately served by municipal services and facilities in accordance with Town standards.

Policy LU-4-3: New Development Fair Share. The Town shall regularly evaluate and update development impact fees to ensure that new development pays its fair share of providing new public facilities and services and/or the costs necessary to improve or expand infrastructure to serve them, including street improvements, parks, wastewater, stormwater drainage, and other public services.

Policy LU-4-4: Capital Improvement Program (CIP). The City shall continue to fund maintenance, improvements, and expansion of town infrastructure, including sewer lines and street infrastructure through a multi-year Capital Improvement.

Findings

While there would be no significant need for the construction of new water and wastewater facilities, implementation of the above policies would further assist in reducing the Project impacts to wastewater to a less than significant level and no mitigation is required . (Draft EIR, pp. 4.15-8 through 4.15-10.)

2. Water Supplies
Threshold: Would the Project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Finding: Less than significant. (Draft EIR, p. 4.9-9.)
Explanation: The implementation of the town of Colma’s 2040 proposed General Plan Update would increase the potential redevelopment of infill sites. The Project proposes updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas introduce opportunity sites and new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Since the Project would allow for additional development of residential, commercial and office uses, this could result in increased demand for water even this increase would not impact local groundwater supplies. The town of Colma is serviced by Cal Water’s South San Francisco District, which provides water from a combination of groundwater as well as purchased water sources and has adequate resources to meet the present needs and foreseeable growth of the town. On both developed and undeveloped sites, compliance with the MRP requires that projec ts to include stormwater treatment measures that would allow for the treatment and retention of surface runoff. This improves water quality and allows for ground water recharge opportunities on developed sites and mitigates the impact of future development and redevelopment activities. The majority of the town’s groundwater usage comes from the irrigation of cemetery lands.

The development of cemetery structures such as a mausoleum may reduce the ground water use by reducing the need to irrigate. In addition, Colma Findings

Municipal Code Chapter 5.11 requires that new development projects that affect 500 square feet or more and landscape modification projects that affect 2,500 square feet or more, including cemetery lands, improve water use efficiency by planting le ss water intensive species of vegetation and increasing efficiency in irrigation.

Also, statewide NPDES permits are required for construction runoff and dewatering and other releases to surface water as well as the LID techniques required by Policy LU -2-4, would protect groundwater quality under future development and redevelopment activities in the town of Colma. The policies discussed below would further minimize any potential impact from the proposed Project.

Moreover, t he following proposed General Pl an policies address groundwater supplies and groundwater recharge:

Policy OSC-4-1: Comply with Water Quality Regulations. Continue to comply with all State and federal regulations for water quality.

Policy OSC-4-3: Reclaimed Water. Pursue opportunities to install water recycling infrastructure for Town-owned and cemetery landscape areas.

Policy OSC-4-4: Use of Drought Tolerant and Native Plants. Encourage the use of drought tolerant and native plants in landscaping plans.

Policy OSC-4-5: Green Infrastructure. Incorporate green infrastructure, which relies on natural processes for stormwater treatment/drainage, groundwater recharge and flood control, into street and rights -of-way wherever practicable, including curb cuts, flow-through planters and bioswales that slow stormwater runoff by dispersing it to vegetated areas, harvesting and use of runoff, and promote infiltration and use of bioretention to clean stormwater runoff.

Policy LU-2-6: Green Infrastructure. Encourage green infrastructure installations that rely on natural processes for stormwater treatment/drainage, groundwater recharge and flood control.

Policy LU-2-7: Public Green Infrastructure. Incorporate green infrastructure into street and rights -of-way wherever practicable, including curb cuts, flow - through planters and bioswales that slow stormwater runoff by dispersing it to vegetated areas, harvesting and use of runoff, and promote infiltration and use of bioretention to clean stormwater runoff.

For the foregoing reasons and the reasons discussed in the EIR, the Project would have a less than significant impact relating to this issue, and no further mitigation is required. (Draft EIR, pp. 4.9-9 through 4.9-11.)

3. Wastewater Capacity
Threshold: Would the Project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate Findings

capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
Finding: Less than significant. (Draft EIR, p. 4.15-10.) Explanation: The town of Colma’s collection system is divided into the northern portion of the town which is connected to and serviced by the North San Mateo County Sanitation District, and the southern portion of the collection system which is connected to the City of South San Francisco.

Correspondence with these providers in February 2021 have indicated that the North San Mateo County Sanitation District Treatment Plant will have adequate capacity however, new construction in certain areas in town may require the need to construct a sewer lift station. In addition, the South San Francisco Water Quality Control Plant is unable to determine if there will be an impact to their infrastructure without specific project locations and proposed uses but will continue to review project applications for proposed projects within the town and determine if capacity is adequate at that time.

Additionally, current State regulations would require that the town comply with existing wastewater quality standards and that any future new development or infill projects be reviewed by the appropriate wastewater district to ensure that new projects would not exceed their wastewater conveyance and treatment capacities.

Moreover, the following proposed General Plan policies address the town’s wastewater treatment needs:

Policy LU-4-1: Maintaining Adequate Public Infrastructure and Facilities. The Town shall adequately maintain public infrastructure to ensure the provision of safe and reliable infrastructure to meet the town’s current and future needs, including facilitating upgrades to the utility infrastructure necessary for improved and emerging technologies.

Policy LU-4-2: Adequacy to Serve New and Existing Developments. The Town shall continue to ensure that new and existing developments can be adequately served by municipal services and facilities in accordance with Town standards.

Policy LU-4-3: New Development Fair Share. The Town shall regularly evaluate and update development impact fees to ensure that new development pays its fair share of providing new public facilities and services and/or the costs necessary to improve or expand infrastructure to serve them, including street improvements, parks, wastewater, stormwater drainage, and other public services.

Policy LU-4-4: Capital Improvement Program (CIP). The City shall continue to fund maintenance, improvements, and expansion of town infrastructure, including sewer lines and street infrastructure through a multi-year Capital Improvement Program (CIP).

Findings

Wastewater treatment demand resulting from the Project would be accommodated by the town of Colma ’s existing wastewater service providers, and no additional new wastewater facilities would be required to serve the town. In addition, implementation of the above policies would further assist in further reducing the Project impacts to wastewater to a less than significant level and no mitigation is required. (Draft EIR, pp.

4.15-10 through 4.15-11.)

4. Solid Waste
Threshold: Would the Project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Finding: Less than significant. (Draft EIR, p. 4.15-11.) Explanation: T he implementation of the proposed Project has the potential to allow for future development and infill projects that could result in additional solid waste generation over existing levels for the town. This waste would eventually be deposited at the local landfill, which could result in the landfill’s current being reduced at a faster rate. Currently, Republic Services, the town’s franchise waste hauler, hauls waste to the Los Trancos (Ox Mountain) landfill located in Half Moon Bay. As of December 31, 2019 the Ox Mountain landfill had 18,206,200 cubic yards of remaining capacity.

The site is projected to reach its permitted capacity in 2039. Additionally, future land use activities developed under the 2040 GPU would be required to comply with all local, state, and federal statutes and regulations related to solid waste.

Policies LU-4-1 to LU-4-4 ensure that new developments can be supported by public infrastructure and mitigate impacts to landfill capacity. The Project’s impacts to solid waste would be reduced by ensuring that the town has access to landfill waste site(s) with sufficient services and capacity. Implementation of the above policies would assist in reducing the Project impacts to solid waste to a less than significant level and no mitigation is required. (Draft EIR, p. 4.15-11.)

5. Solid Waste Laws
Threshold: Will the Project comply with federal, state, and local statutes and regulations related to solid waste?
Finding: Less than significant. (Draft EIR, p. 4.15-11.)

Explanation: T he implementation of the proposed Project has the potential to allow for
future development and infill projects that could result in additional solid waste generation over existing levels for the town. This waste would eventually be deposited at the local la ndfill, which could result in the landfill’s current being reduced at a faster rate. Currently, Republic Findings

Services, the town’s franchise waste hauler, hauls waste to the Los Trancos (Ox Mountain) landfill located in Half Moon Bay. As of December 31, 2019 the Ox Mountain landfill had 18,206,200 cubic yards of remaining capacity.

The site is projected to reach its permitted capacity in 2039. Additionally, future land use activities developed under the 2040 GPU would be required to comply with all local, state, and federal statutes and regulations related to solid waste.

Policies LU-4-1 to LU-4-4 ensure that new developments can be supported by public infrastructure and mitigate impacts to landfill capacity. The Project’s impacts to solid waste would be reduced by ensuring that the town has access to landfill waste site(s) with sufficient services and capacity. Implementation of the above policies would assist in reducing the Project impacts to solid waste to a less than significant level and no mitigation is required. (Draft EIR, p. 4.15-11.)

R. WILDFIRE

1. Response Plans
Threshold: If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project substantially impair an adopted emergency response plan or emergency evacuation plan? Finding: Less than significant. (Draft EIR, p. 4.16-8.) Explanation: Implementation of the proposed Project would result in project occupants to be exposed to pollutants concentrations from a wildfire or the uncontrolled spread of a wildfire due to slope, prevailing winds, and other factors that exacerbate wildfire risks. While the town of Colma is limited in its land area for future development which can only be focused on limited residential development as well as commercial redevelopment on existing sites within the town, the Project
does propose new land uses such a
medium density residential land use that is consistent with current developments as well as a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

However, any future development would be required to comply with the town’s Local Hazard Mitigation Plan (Plan) as well as any criteria under the Findings

County of San Mateo’s Emergency Operations Services. The town is covered under the services by the Colma Fire Protection District. Though the District has a number of fire stations in close proximity to the town, Fire Station 85 is located approximately less than a mile to the town’s northern boundary. Future development projects would have to comply with Action items specifically related to Actions C -1, C-3, C-6, C-7, C-11 and C-20 (San Mateo County Hazard Mitigation Plan, 2016). Additionally, fire safety codes, emergency access routes and evacuation procedures are already addressed in the town’s Local hazard Mitigation Plan and emergency operators (Town staff, fire and police staff). Construction and operation of new residential or commercial development within the town would nominally increase the demand for fire protection in the town. Thus the proposed Project would not impair an adopted emergency response plan or emergency evacuation plan, or would it expose project occupants to uncontrolled wildfire risks.

Moreover, the following proposed General Plan policies address emergency response plans and actions:

Policy CS-2-2: Development in Hazardous Areas. Prohibit development, including any land alteration, grading for roads and structural development, in areas of slope instability unless the appropriate mitigation measures are taken.

Policy CS-2-3: Unsafe Buildings. Encourage seismic retrofits of existing buildings based on the recommendations of a licensed engineer or architect. Prioritize working with owners of buildings whose loss would impact the greatest number of people and/or particularly vulnerable groups such as seniors, children, or low-income households.

Policy CS-4-1: Alternate EOC. Establish an alternative Emergency Operations Center (EOC) to be used in the event the existing EOC is not operational during a fire event.

Policy CS-7-1: Hazard Mitigation Plan. Implement, maintain and update the Local Hazard Mitigation Plan which is part of the larger County Hazard Mitigation Plan.

Policy CS-7-2: Emergency Management Plan. Continue to participate with San Mateo County’s Mutual Aid Programs and Plans for community emergency preparedness.

Policy CS-7-3: Promote Emergency Preparedness. Utilize multiple information channels to educate residents and businesses of the Town’s emergency operations procedure.

Policy CS-7-4: Collaborative Planning. Improve inter -jurisdictional and interagency cooperation with regard to hazard prevention and emergency response through town participation in and initiation of coordination meetings and exercises.

Findings

Policy CS-7-5: Evacuation Routes. Utilize emergency evacuation routes established by the Town and ensure that all residential areas of Colma maintain access to at least two routes for evacuation..

For the foregoing reasons and the reasons discussed in the EIR, environmental impacts relating to this issue would be less than significant, and no mitigation is required. (Draft EIR, pp. 4.16-8 through

4.16-9.)

2. Pollutant Concentrations
Threshold: Due to slope, prevailing winds, and other factors, would the Project exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of wildfire?
Finding: Less than significant. (Draft EIR, p. 4.16-8.) Explanation: A ny future development would be required to comply with the town’s Local Hazard Mitigation Plan (Plan) as well as any criteria under the County of San Mateo’s Emergency Operations Services. The town is covered under the services by the Colma Fire Protection District. Though the Distri ct has a number of fire stations in close proximity to the town, Fire Station 85 is located approximately less than a mile to the town’s northern boundary.

Future development projects would have to comply with Action items specifically related to Actions C-1, C-3, C-6, C-7, C-11 and C-20 (San Mateo County Hazard Mitigation Plan, 2016). Additionally, fire safety codes, emergency access routes and evacuation procedures are already addressed in the town’s Local hazard Mitigation Plan and emergency operators (Town staff, fire and police staff). Construction and operation of new residential or commercial development within the town would nominally increase the demand for fire protection in the town. Thus the proposed Project would not impair an adopted emergency response plan or emergency evacuation plan, or would it expose project occupants to uncontrolled wildfire risks.

For the foregoing reasons and the reasons discussed in the EIR, the 2040 General Plan Update’s environmental impacts would have a less than significant relating to this issue, and no mitigation is required. (Draft EIR, pp. 4.16-8 through 4.16-9.)

3. Infrastructure Risks
Threshold: Would the Project require the installation or maintenance of associated infrastructure (such a roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
Findings

Finding: No impact. (Draft EIR, p. 4.16-9.)
Explanation: The town of Colma is fairly developed with residential and commercial uses.

Existing cemetery land in the town account for approximately 75% of the town’s land area, leaving approximately 25% of the town’s 1.91 acreages to residential, office, and commercial uses. The types of future GPU las uses would include an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Any new development would therefore be incorporated into the town’s existing infrastructure such as road s, emergency water sources, power lines and other utilities. Maintenance of these existing infrastructure would continue as per the town’s typical maintenance of its facilities. Therefore implementation of the Project would not require the installation of any new infrastructure and this would have no impact, nor require mitigation measures. (Draft EIR, pp. 4.16-9 through 4.16-10.)

4. Runoff Risks
Threshold: Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post- fire slope instability, or drainage changes?
Finding: No impact. (Draft EIR, p. 4.16-10.)
Explanation: The town of Colma is not located on a slope or downstream from any rivers or streams. The Colma Creek mainly runs underground through the town and there are no water bodies located with the town limits. Therefore implementation of the Project would not expose people or structure to any impacts from downslope or downstream flooding. There would be no impact and no mitigation measures are required. (Draft EIR, p. 4.16-10.)

SECTION III.

IMPACTS THAT ARE LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED The City Council hereby finds that Mitigation Measures have been identified in the EIR and these Findings that will avoid or substantially lessen the following potentially significant environmental impacts to a less than significant level. The potentially significant impacts, and the Mitigation Measures that will reduce them to a less than significant level, are as follows:

Findings

A. AIR QUALITY

1. Air Quality Plans and Air Quality Standards
Threshold: Would the Project conflict with or obstruct implementation of the applicable air quality plan; violate any air quality standard or contribute substantially to an existing or projected air quality violation?
Finding: Less than significant with mitigation. (Draft EIR, p. 4.2-26.) Explanation: Reduce Population Exposure and Protect Public Health

Buildout of the proposed Project could result in new sources of TACs and PM2.5. Stationary sources, including smaller stationary sources (e.g., dry cleaners, restaurants with charbroilers, emergency generators and boilers) are subject to review by BAAQMD a s part of the permitting process.

Adherence to BAAQMD permitting regulations would ensure that new stationary sources of TACs do not expose populations to significant health risk. Mobile sources of air toxics (e.g., truck idling) are not regulated directly by BAAQMD. As a result, development allowed by the proposed Project could result in new sources of criteria air pollutant emissions and/or TACs near existing or planned sensitive receptors. Mitigation Measure AQ-3.2 would ensure mobile sources of TACs not covered under BAAQMD permits are considered during subsequent project -level environmental review by the town of Colma. Individual development projects would be required to achieve the incremental risk thresholds established by BAAQMD. Thus, implementation of the proposed Project would not result in introducing new sources of TACs that on a cumulative basis, could expose sensitive populations to significant health risk. Therefore, impacts would be less than significant with mitigation. (Draft EIR, p. 4.2-26.)

2. Sensitive Receptors
Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Less than significant with mitigation. (Draft EIR, p. 4.2-41.) Explanation: Nonpermitted Sources

Mobile sources of TACs are not regulated by BAAQMD. The primary mobile source of TACs within the town is truck idling and use of off- road equipment. New warehousing operations could generate substantial DPM emissions from off-road equipment use and truck idling. In addition, some warehousing and industrial facilities may include use of TRUs for cold storage. New land uses in the town that would be permitted under the proposed GPU that would use trucks, including trucks with TRUs, could generate an increase in DPM that would contribute to cancer and noncancer health risk in the SFBAAB. Additionally, these types of facilities Findings

could also generate particulate matter (PM10 and PM2.5) that may cause an exceedance or contribute to the continuing exceedance of the f ederal and State AAQS. These new land uses could be near existing sensitive receptors. In addition, trucks would travel on regional transportation routes throughout the Bay Area, contributing to near- roadway DPM concentrations. The GPU does not anticipate
significant new growth from
industrial warehousing. However, health risk impacts from nonpermitted sources associated with potential development of industrial and commercial land uses are considered significant.

Proposed General Plan Update Policies

Policy LU- 5-1. Regional Cooperation. Participate with other cities in the county and across the region in working towards solutions to the issues of regional land use, housing, homelessness, and transportation planning through partnership with the Association of Bay Area Governments, the Metropolitan Transportation Commission, and the San Mateo City/County Association of Governments (C/CAG).

Policy LU-5-2. San Mateo County Collaboration. Continue to consult with San Mateo County and other cities in the region on effective land use, transportation, sustainability, and economic development strategies to learn about additional strategies that could be used in Colma to achieve the community’s vision and goals.

Policy LU-6-3. Environmental Protection. The Town shall apply environmental protection measures equally among geographic and socioeconomic neighborhoods of the town.

Policy M-3-1. Agency Collaboration and Coordination. Collaborate with Caltrans, the City and County Association of Governments (C/CAG), surrounding jurisdictions, and other agencies to improve connectivity between the county, cities, and the town.

Policy M-3-3. Regional Transportation Planning. Actively participate in and support regional transportation planning efforts.

Policy CS-1-1. Health in All Policies. Prioritize the overall health of Colma residents in Town strategies, programs, daily operations, and practices.

The policies and programs listed above would contribute toward minimizing potential heal th risk impacts to sensitive receptors. However, implementation of the proposed Project could expose sensitive receptors to substantial toxic air contaminant concentrations from nonpermitted sources.

MM AQ-4: Prior to discretionary project approval, applicants for industrial or warehousing land uses in addition to commercial land uses that would Findings

generate substantial diesel truck travel— i.e., 100 diesel trucks per day or 40 or more trucks with diesel-powered transport refrigeration units per day based on the CARB recommendations for siting new sensitive land uses — shall contact the BAAQMD or the town of Colma in conjunction with the BAAQMD to determine the appropriate level of HRA required. If preparation of an HRA is required, all HRAs shall be submitted to the town and the BAAQMD for evaluation.

The HRA shall be prepared in accordance with policies and procedures of the OEHHA and the BAAQMD. If the HRA shows that the incremental cancer risk exceeds ten in one million (10E-06) or the risk thresholds in effect at the time a project is considered, or the appropriate noncancer hazard index exceeds 1.0, or 0.3 µ/m3 of PM2.5 or the thresholds as determined by the BAAQMD at the time a project is considered, the applicant will be required to identify and demonstrate that measures are capable of reducing potential cancer and noncancer risks to an acceptable level, including appropriate enforcement mechanisms.

Measures to reduce risk impacts may include but are not limited to:
• Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible.
• Electrifying warehousing docks.
• Requiring use of newer equipment and/or vehicles.
• Restricting off-site truck travel through the creation of truck routes.

Measures identified in the HRA shall be identified as mitigation measures in the environmental document and/or incorporated into the site development plan as a component of the proposed General Plan.

Development allowed by the proposed Project could result in new sources of criteria air pollutant emissions and/or TACs near existing or planned sensitive receptors. Review of development projects by BAAQMD for permitted sources of air toxics (e.g., industrial facilities, dry cleaners, and gasoline dispensing facilities) in addition to proposed General Plan goals, policies, and programs would ensure that health risks are minimized.

Additionally, Mitigation Measure AQ-4 would ensure mobile sources of TACs not covered under BAAQMD permits are considered during subsequent project -level environmental review by the town of Colma.

Individual development projects would be required to achieve the incremental risk thresholds established by BAAQMD, and TAC and PM2.5 , and impacts would be less than significant wit h Mitigation Measure AQ-4. (Draft EIR, pp. 4.2-41 through 4.2-43.)

Findings

SECTION IV.

IMPACTS THAN CANNOT BE FULLY MITIGATED TO A LESS THAN SIGNIFICANT LEVEL
The City Council hereby finds that, despite the incorporation of Mitigation Measures identified in the EIR and in these Findings, the following environmental impacts cannot be fully mitigated to a less than significant level and a Statement of Overriding Considerations is therefore included herein:

A. AIR QUALITY

1. Cumulatively Considerable Pollutant Emissions
Threshold: Would the Project result in cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard? Finding: Significant and unavoidable. (Draft EIR, p. 4.2-35.) Explanation: This section analyzes potential impacts related to air quality that could occur from the buildout associated with the proposed Project in combination with the regional growth in the SFBAAB. The SFBAAB is currently designated a nonattainment area for California and National O3, California and National PM2.5, and California PM10 AAQS. At a plan level, air quality impacts are measured by the potential for a project to exceed BAAQMDs significance criteria and contribute to the State and federal nonattainment designations in the SFBAAB. Any project that produces a significant regional air quality impact in an area that is in nonattainment adds to the cumulative impact. The proposed Project would be consistent with the
2017 Clean Air Plan. However, the proposed General Plan could generate a substantial increase in criteria air pollutant emissions from construction and operational activities that could exceed the BAAQMD regional significance thresholds.

Construction

Construction activities would temporarily increase criteria air pollutant emissions within the SFBAAB. The primary source of NOx emissions is the operation of construction equipment. The primary sources of particulate matter (PM10 and PM2.5) emissions are activities that disturb the soil, such as grading and excavation, road construction, and building demolition and construction. The primary sources of VOC emissions are the application of architectural coating and off-gas emissions associated with asphalt paving.

A discussion of health impacts associated with air pollutant emissions generated by construction activities is included under “Air Pollutants of Concern” in
Section 4.2.2: Regulatory Framework of the Draft EIR .

Construction activities associated with the proposed Project would occur over the buildout horizon, causing short -term emissions of criteria air Findings

pollutants. Information regarding specific development projects, soil types, and the locations of receptors would be needed in order to quantify the level of impact associated with cons truction activity. Due to the scale of development activity associated with buildout of proposed General Plan, emissions would likely exceed the BAAQMD regional significance thresholds. In accordance with the BAAQMD methodology, emissions that exceed the regional significance thresholds would cumulatively contribute to the nonattainment designations of the SFBAAB. Emissions of VOC and NOX are precursors to the formation of O3. In addition, NOX is a precursor to the formation of particulate matter (PM10 and PM2.5). Therefore, the proposed Project would cumulatively contribute to the nonattainment designations of the SFBAAB for O3 and particulate matter (PM10 and PM2.5).

Future development under the proposed Project would be subject to separate environmental review pursuant to CEQA in order to identify and mitigate potential air quality impacts. Subsequent environmental review of development projects would be required to assess potential impacts under BAAQMDs project -level thresholds based on site- specific con struction phasing and buildout characteristics. For the proposed Project, which is a broad-based policy plan, it is not possible to determine whether the scale and phasing of individual projects would exceed the BAAQMD's short-term regional or localized construction emissions thresholds. As a result, construction activities associated with implementation of the proposed Project could potentially violate an air quality standard or contribute substantially to an existing or projected air quality violation.

Existing federal, State, and local regulations, and the policies and programs of the proposed Project described throughout this section protect local and regional air quality. Continued compliance with these regulations would reduce construction-related impacts. In addition, there are certain General Plan policies that would reduce construction emissions.

Proposed General Plan Update Policies

The General Plan policies listed in Table 4.2.9 of the Draft EIR would ensure consistency with the AQMP. While the existing regulations and policies have the potential to reduce emissions, potential future development projects accommodated under the proposed General Plan (individually or cumulatively) could still exceed the BAAQMD significance thresholds for construction. Therefore, implementation of the proposed Project could result in significant construction-related regional air impacts and the following mitigation measures are required.

MM AQ-1: As part of the town’s development approval process, the town of Colma shall require applicants for future development projects to comply with the current BAAQMD basic control measures for fugitive dust control, including:

Findings

• Water all active construction areas at least twice daily, or as often as needed to control dust emissions. Watering should be sufficient to prevent airborne dust from leaving the site. Increased watering frequency may be necessary whenever wind speeds exceed 15 miles per hour. Reclaimed water should be used whenever possible. • Pave, apply water twice daily or as often as necessary to control dust, or apply (non -toxic) soil stabilizers on all unpaved access roads, parking areas, and staging areas at construction sites. • Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least 2 feet of freeboard (i.e., the minimum required space between the top of the load and the top of the trailer).
• Sweep daily (with water sweepers using reclaimed water if possible) or as often as needed all paved access roads, parking areas and staging areas at the construction site to control dust. • Sweep public streets daily (with water sweepers using reclaimed water if possible) in the vicinity of the project site, or as often as needed, to keep streets free of visible soil material.
• Hydroseed or apply nontoxic soil stabilizers to inactive construction areas.
• Enclose, cover, water twice daily, or apply nontoxic soil binders to exposed stockpiles (dirt, sand, etc.).
• Limit vehicle traffic speeds on unpaved roads to 15 miles per hour. • Replant vegetation in disturbed areas as quickly as possible.

MM AQ-2: Prior to issuance of building permits, development project applicants that are subject to CEQA and exceed the screening sizes in the BAAQMD CEQA Guidelines shall prepare and submit to the town of Colma a technical assessment evaluating potential project construction -related air quality impacts. The evaluation shall be prepared in conformance with the BAAQMD methodology in assessing air quality impacts. If construction - related criteria air pollutants are determined to have the potential to exceed the BAAQMD thresholds of significance, as identified in the BAAQMD CEQA Guidelines, the town shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities to below these thresholds to the Nextent feasible. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the town of Colma and shall be verified by the Town’s Building Division and/or Planning Division.

Mitigation Measure AQ -1 would require adherence to the current BAAQMD basic control measures for reducing fugitive dust and reduce fugitive emissions to less-than-significant levels, and Mitigation Measure AQ-2 would reduce NOX emissions. However, future development in the town could still generate construction exhaust emissions in excess of the BAAQMD significance thresholds. An analysis of emissions generated from the construction of specific future projects under the proposed Project Findings

would be required to evaluate emissions compared to BAAQMDs project - level significance thresholds during individual environmental review. Th e identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects that comply with BAAQMD screening criteria or meet applicable thresholds of significance.

However, due to the programmatic nature of the proposed Project, no additional mitigation measures are available, and the impact is considered significant and unavoidable. (Draft EIR, pp. 4.2-35 through 4.2-37.)

2. Sensitive Receptors
Threshold: Would the Project expose sensitive receptors to substantial pollutant concentrations?
Finding: Significant and unavoidable. (Draft EIR, p. 4.2-40.) Explanation: Implementation of the proposed Project would cause or contribute significantly to elevated pollutant concentration levels such that it would expose sensitive receptors to elevated pollutant concentrations. Unlike regional emissions, localized emissions are typically evaluated in terms of air concentration rather than mass so they can be more readily correlated to potential health effects.

Construction Community Risk and Hazards

Future construction under the proposed Project would temporarily elevate concentrations of TACs and DPM in the vicinity of sensitive land uses during construction activities. Since the details regarding future construction activities are not known at this time, due to this analysis being conducted at a GPU Program level — including phasing of future individual projects, construction duration and phasing, and preliminary construction equipment— construction emissions are evaluated qualitatively in accordance with BAAQMD’s plan -level guidance. Subsequent environmental review of future development projects would be required to assess potential impacts under BAAQMD’s project -level thresholds.

However, construction emissions associated with the proposed Project could exceed BAAQMD’s project level and cumulative significance thresholds for community risk and hazards. Therefore, construction-related health risk impacts associated with the proposed General Plan are considered significant.

Proposed General Plan Update Policies

The proposed Project includes the fol lowing policies that would reduce construction-related air quality impacts:

Findings

Policy LU-6-3. Environmental Protection. The Town shall apply environmental protection measures equally among geographic and socioeconomic neighborhoods of the town.

Policy CS-1-1. Health in All Policies. Prioritize the overall health of Colma residents in its strategies, programs, daily operations, and practices.

MM AQ-3: Applicants for construction within 1,000 feet of residential and other sensitive land use projects (e.g., hospitals, nursing homes, day care centers) in the town of Colma, as measured from the property line of the project to the property line of the source/edge of the nearest travel lane, shall submit a health risk assessment (HRA) to the town prior to future discretionary project approval. The HRA shall be prepared in accordance with policies and procedures of the Office of Environmental Health Hazard Assessment (OEHHA) and the BAAQMD. The latest OEHHA guidelines shall be used for the analysis, including age-sensitivity factors, breathing rates, and body weights appropriate for children ages 0 to 16 years. If the HRA shows that the incremental cancer risk exceeds ten in one million (10E-06), PM2.5 concentrations exceed 0.3 µg/m3, or the appropriate nonca ncer hazard index exceeds 1.0, the applicant will be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and noncancer risks to an acceptable level (i.e., below ten in one million or a hazard index of 1.0), including appropriate enforcement mechanisms. Measures to reduce risk may include, but are not limited to:
• During construction, use construction equipment rated as US EPA Tier 4 Interim for equipment of 50 horsepower or more.
• During construction, use of construction equipment fitted with Level 3 Diesel Particulate Filters for all equipment of 50 horsepower or more.

Measures identified in the HRA shall be included in the environmental document and/or incorporated into the site develop ment plan as a component of the proposed Project. Prior to issuance of any construction permit, the construction contractor shall ensure that all construction plans submitted to the Town of Colma Planning Division and/or Building Division clearly show incorporation of all applicable mitigation measures.

Implementation of Mitigation Measures AQ-2 and AQ-3 would reduce construction-related health risk impacts to the extent feasible. However, despite implementation of mitigation, construction -related health r isk impacts may still exceed the applicable thresholds due to future project - specific circumstances. Therefore, this impact remains significant and unavoidable. (Draft EIR, pp. 4.2-40 through 4.2-41.)

B. CULTURAL RESOURCES

1. Historical Resources
Findings

Threshold: Would the Project cause a substantial adverse change in the significance of a historical resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Significant and unavoidable. (Draft EIR, p. 4.4-23.) Explanation: The demolition or substantial alteration of a resource listed on, or formally determined eligible for, the NRHP or the CRHR, including contributors to National Register or California Register Historic Districts, or that meet the CEQA criteria for historical resources, would represent a significant direct impact to historical resources. Additionally, grading, excavation and other ground-disturbing activities associated with development projects may affect currently unknown significant archaeological sites or traditional cultural properties that would represent a significant direct impact to historical resources.

ASM Affiliates (2020) completed a cultural resource study that included a review of historical aerial photographs, topographic maps, and a comprehensive CHRIS records search. Results concluded that no previously recorded archaeological resources are located within the town, and, as such, no archaeological and/or TCRs are listed as historic properties. The town’s
Historical Resources Element (1999) outlines architectural historic properties within the Planning Area. The 2040 GPU proposes updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas under the proposed GPU introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The Project would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Proposed General Plan Update Policies

The following proposed GPU policies address the preservation of historic resources in the town of Colma:

Policy LU-13-2: Historic Buildings. Historic buildings and uses along Mission Road shall be maintained and enhanced according to the Secretary of the Interior’s standards. Adaptive reuse of structures is encouraged.

Findings

Policy HR-2-1: Preservation Collaboration. Work with the Colma Historical Association as a partner to improve awareness of local preservation.

Policy HR-2-2: Consultation on Projects. Consult with the Colma Historical Association on discretionary review projects involving cultural sites and historic resources in the Town of Colma.

Policy HR-3-1: Public Awareness. Foster awareness, appreciation and celebration of the Town’s unique historic and cultural heritage and educate and encourage preservation of these resources.

According to the
Historical Resources Element for the town’s GPU, historic properties as they pertain to architectural resources are present within the town, though no historic resources as they pertain to archaeological or TCRs are currently within the town limits.

While the GPU does not specifically propose demolition, or substantial alteration of a historical resource, or ground -disturbing activities such as grading or excavation, there are historic properties within the Planning Area and as such it can be assumed that future development consistent with the goals and policies of the GPU have the potential to result in significant direct and/or indirect impacts to historical resources. Therefore, this is a significant and unavoidable impact, and the following mitigation measures are proposed:

MM CUL-1

1. For any project with potential to impact historical resources, a historical resource inventory of the project footprint shall be required to identify any historical resources. Before actual field reconnaissance occurs, background research shall include a record search at the NWIC, as well as a review of the SLF maintained by the NAHC. The project archaeologist shall determine the likelihood for the project site to contain archaeological resources by reviewing site photographs and existing historic information and conducting a site visit (for projects with exposed ground).

2. If archaeological resources cannot be avoided, significance evaluations shall be required when a survey identifies new resources, when a survey re-locates previously recorded resources that have not been previously evaluated, and when the survey does not re -locate previously recorded sites if there is a likelihood that the resources still exist.

3. Significance evaluations shall not be required if the historical resource has been evaluated for CEQA significance or for NRHP eligibility within the last five years, and if there has been no change in the conditions that contributed to the determination of significance or eligibility. A historical resource shall be reevaluated if its condition or setting has either improved or deteriorated, if new information is available, or if the resource is becoming increasingly rare due to the loss of other similar resources.

Findings

4. An archaeological testing program shall be required for archaeological sites in need of historical resource significance evaluation. Archaeological testing programs include evaluating the horizontal and vertical dimensions of a site, the chronological placement, site function, artifact/ecofact density and variability, presence/absence of subsurface features, and research potential. Tribal representatives and/or Native American monitors shall be involved in making recommendations regarding the significance of prehistoric archaeological sites during this phase of the process. The testing program may require reevaluation of the proposed Project, which could result in a combination of project redesign to preserve significant resources as well as mitigation in the form of data recovery and monitoring (as recommended by the qualified archaeologist and Native American representative).

5. If significant historical resources are identified within the project footprint, the site may be eligible for designation in one or more registers.

If no significant resources are identified, and site conditions are such that there is no potential for further discoveries, then no further action shall be required. If a survey and/or assessment finds nonsignificant resources, no further work shall be required beyond documentation of the resources on the appropriate California Department of Parks and Recreation site forms and inclusion of results in the survey and/or assessment report. If the survey finds no significant resources but results of the initial evaluation and testing phase indicate there is still a potential for resources to be present in portions of the property that could not be tested, then mitigation monitoring shall be required.

6. Preferred mitigation for historical resources shall be to avoid and preserve the resource through project redesign. If the resource cannot be entirely avoided, an archaeologist who meets the U.S. Secretary of the Interior’s Professional Qualifications Standards (SOIPQS) for Archaeology shall take all prudent and feasible measures to minimize harm. For archaeological resources for which preservation is not an option, an archaeologist who meets the SOIPQS for Archaeology shall prepare a research design for a data recovery program. The data recovery program shall be based on a written research design and is subject to the provisions as outlined in CEQA, Section 21083.2. Archaeological monitoring may be required during building demolition and/or construction grading when significant resources are known or suspected to be present on a site but cannot be recovered prior to grading due to obstructions such as existing development or dense vegetation.

7. When subsurface investigations, including geotechnical testing and other ground-disturbing activities, impact an archaeological site or a Native American Traditional Cultural Property within the project footprint, a Native American monitor shall be retained. In the event that the data recovery and/or monitoring program reveals human remains, the provisions of PRC Findings

Section 5097 shall be applied. An archaeologist who meets the SOIPQS for Archaeology shall consult the Native American monitor during the preparation of the written report, at which time the monitor may express concerns about the treatment of sensitive resources. (Draft EIR, pp. 4.4 - 23 through 4.4-25.)

2. Archaeological Resources
Threshold: Would the Project cause a substantial adverse change in the significance of an archaeological resource pursuant to State CEQA Guidelines, section 15064.5?
Finding: Significant and unavoidable. (Draft EIR, p. 4.4-25.) Explanation: ASM Affiliates (2020) completed a cultural resource study that included a review of historical aerial photographs, topographic maps, and a comprehensive CHRIS records search. Results concluded that no previously recorded archaeological resources are located within the town, and, as such, no archaeological and/or TCRs are listed as histor ic properties. The town’s
Historical Resources Element (1999) outlines architectural historic properties within the Planning Area.

Proposed General Plan Update Policies

The following proposed GPU policies address potential disturbances of cultural resources and human remains due to future development:

Policy OSC-6-1: Development Review Process. Require, as part of the development review process, standard conditions of approval or mitigation measures that identify proper measures and protocols to be followed in the event that tribal or cultural resources are discovered on a project site.

According to the
Historical Resources Element for the Town’s GPU, historic properties as they pertain to architectural resources are present within the town, though no historic resources as they pertain to archaeological or TCRs are currently within the town limits.

While the GPU does not specifically propose demolition, or substantial alteration of a historical resource, or ground -disturbing activities such as grading or excavation, the GPU does propose updates to the town’s existing planning areas, simplifying the town’s existing planning areas into five new planning areas that are consistent with the present condition of the town and the vision of the City Council. The planning areas under the proposed GPU introduces new land uses such a medium density residential land use that is consistent with current developments and a commercial overlay over vacant and underutilized cemetery land east of Hillside Boulevard. The 2040 GPU would allow for an additional 11 residential units in the Sterling Park Planning Area; 20 infill residential units, 15,000 square feet of Findings

commercial uses, and 5,000 square feet of office uses in the Mission Road Planning Area; 315,000 square feet of commercial uses within the Hillside Boulevard Planning Area; 310,000 square feet of commercial uses and 10,000 square feet of office uses in the Commercial Core Planning Area; and, 20,000 square of office uses, 352,500 square feet of commercial uses, and 42 residential units, 240 residential units, and 15 residential units at the Bocci Center, Town Center and Sandblaster site, respectively.

Therefore there is the potential that previously undiscovered historic properties may exist within the Planning Area and as such it can be assumed that future development consistent with the goals and policies of the GPU have the potential to result in significant direct and/or indirect impacts to cultural resources. Therefore, this is a significant and unavoidable im pact and the following mitigation measure would be required:

MM CUL-2

1. If an archaeological resource is identified during future development or operations, all activity within 100 feet of the archaeological resource shall cease and be flagged for avoidance. An archaeologist who meets the SOIPQS for Archaeology shall be immediately notified of the discovery. The archaeologist shall inspect the find and notify the Town of their assessment.

2. If the assessment concludes that the discovery constitutes a significant or unique archaeological resource, or TCR, the resource shall be avoided if possible. If avoidance is not possible, the Town shall consult with all applicable parties, including Native American tribes if prehistoric, in an effort to determi ne measures to mitigate any potential impacts to the resource in accordance with PRC Section 21083.2 and CEQA Guidelines Section 15126.4. An archaeologist who meets the SOIPQS for Archaeology shall employ measures that include documentation of the resource.

3. If an archaeological site does not meet the criteria defined in subsection (a), but does meet the definition of a unique archaeological resource in Section 21083.2 of the PRC, the site shall be treated in accordance with the provisions of section 21083.2. The time and cost limitations described in PRC Section 21083.2 (c -f) do not apply to surveys and site evaluation activities intended to determine whether the project location contains unique archaeological resources.

4. If an archaeological resource is neither a unique archaeological nor a historical resource, the effects of the project on those resources shall not be considered a significant effect on the environment. These procedures shall be included as Condition of Approval for all projects. Wher e appropriate, preconstruction measures will follow the guidelines as stated in CUL-1. (Draft EIR, pp. 4.4-26 through 4.4-27.)

3. Human Remains
Findings

Threshold: Would the Project disturb any human remains, including those interred outside of dedicated cemeteries?
Finding: Significant and unavoidable. (Draft EIR, p. 4.4-29.) Explanation: There are no known areas within the town of Colma where prehistoric human remains have been uncovered, yet much of the town consists of historic cemeteries and burials. Therefore, the potential for encountering prehistoric human remains during construction development activities is low, but the potential for encountering human remains in general is possible, and GPU implementation may result in impacts to human remains.

While the GPU does not specifically propose demolition or substantial alteration of a resource or ground -disturbing activities such as grading or excavation, as discussed under Impacts 4.4.1- 4.4.2, it is possible that future development consistent with the goals and policies of the 2040 General Plan Update have the potential to disturb human remains.

Therefore, this is a significant and unavoidable impact and the following mitigation measures should be implemented:

MM CUL-4

1. If Native American human remains are discovered within a project footprint, the Town shall work with the most likely descendants identified by the NAHC as provided in PRC Section 5097.98. The applicant may develop an agreement for treating or disposing of, with appropriate dignity, the human remains, and any items of cultural patrimony associated with Native American burials with the appropriate Native Americans as identified by the NAHC. Action implementing such an agreement is exempt from the general prohibition on disinterring, disturbing, or removing human remains from any location other than a dedicated cemetery (Health and Safety Code Section 7050.5).

2. In the event of the accidental discovery or recognition of any human remains in any location other than a dedicated cemetery, the following steps shall be taken:

a. All construction activity shall cease within 100 feet of the discovery until the San Mateo County Medical Examiner is contacted and has completed their study.
b. The San Mateo County Medical Examiner shall be contacte d to determine whether an investigation of the cause of death is required.
c. If the medical examiner determines that the remains are Native American, the medical examiner shall contact the NAHC within 24 hours.
d. The NAHC shall identify the person or persons it believes to be the Most Likely Descendant from the deceased Native American.

Findings

e. The landowner shall discuss and confer with the Most Likely Descendant regarding all reasonable options for treatment of human remains and any associated grave goods as provided in PRC Section 5097.98.

3. As part of the objectives, criteria, and procedures required by PRC Section 21082, a lead agency shall make provisions for historical or unique archaeological resources accidentally discovered during construction.

These provisions shall include an immediate evaluation of the find by a qualified archaeologist. If the archaeologist determines the find to be a significant historical or archaeological resource, contingency funding and a time allotment sufficient to allow for implementation of avoidance measures or appropriate mitigation shall be necessary. Work may continue on other parts of the project site while resource mitigation takes place. (Draft EIR, pp. 4.4-29 through 4.4-30.)

C. GREENHOUSE GAS EMISSIONS

1. Emissions Generation
Threshold: Would the Project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Finding: Significant and unavoidable. (Draft EIR, p. 4.7-16.) Explanation: Future potential development under the proposed Project would contribute to global climate change through direct and indirect emissions of GHGs in the town. However, a general plan is a long -range policy document that does not directly result in development without additional approvals. Any development proposed in the town of Colma must be analyzed for consistency with the General Plan,
zoning requirements, and other
applicable local and State requirements; comply with the requirements of CEQA if required; and obtain all necessary clearances and permits from regulatory agencies.

Buildout of the proposed Project is not linked to a specific development time frame but is assumed over a 20-year project horizon. Implementation of the proposed Project by the horizon year of 2040 would result in a net increase of 1,395 people and 889 employees in the town. Table 4.7.5, Horizon Year 2040 GHG Emissions Forecast of the Draft EIR , provides a comparison of the change in GHG emissions in the Town between the CEQA baseline (2020) and the General Plan horizon year (2040) conditions.

Buildout of the land uses accommodated under the proposed 2040 GPU would result in a net increase of 103 MTCO2e of GHG emissions (1 percent in GHG emissions) from existing conditions and would not exceed the 660 MTCO2e BAAQMD bright -line screening threshold. In addition, though buildout under the proposed Project is projected to increase service Findings

population by 2,284 persons6 (a 41 percent increase), e missions per person would decrease compared to the baseline. Emissions per service population would decrease to 2.2 MTCO2e/SP in horizon year 2040 from

3.0 MTCO2e/SP for the baseline year.

Consistency with SB 32 and Executive Order S -03 -05 GHG Reduction T argets
While the proposed Project would not generate an increase in GHG emissions from the CEQA baseline in the 2040 horizon year forecast, the Draft EIR also analyzes the potential for the proposed Project to conflict with the GHG reduction goals established under SB 32 and Executive Order S-03-05, which require a reduction in statewide GHG emissions from existing conditions to 40 percent below 1990 levels by 2030 and an 80 percent below 1990 levels by 2050. The Draft EIR assumes that the CEQA baseline (2020 emissions) reflects the AB 32 goal in 2020. As a result, at the General Plan horizon year of 2040, the town would need to reduce GHG emissions by 60 percent to ensure the town is on a trajectory to achieve the long-term goal under Executive Order S-03-05, which is equivalent to 10,119 MTCO2e in the town by the year 2040.

Implementation of the proposed Project would result in a small net increase (103 MTCO2e) in emissions in horizon year 2040 compared to existing baseline. Due to the magnitude of growth anticipated (41 percent increase), GHG emissions would not achieve the 60 percent reduction necessary to ensure the town is on a trajectory to achieve the long -term year 2050 reduction goal of Executive Order S-03-05. Reduction strategies to meet the long -term 2050 GHG reduction goal in addition to establishment of a 2050 reduction target will be included in the planned future updates to the CAP. Additionally, State strategies to achieve post - 2030 targets will be necessary. Therefore, until such time, GHG emissions impacts for the proposed Project are considered potentially significant in regard to meeting the long-term year 2050 reduction goal.

Proposed General Plan Update Policies
While growth within the town would cumulatively contribute to GHG emissions impacts, the current General Plan included goals, policies, and programs to reduce GHG emissions. The proposed Project retains or slightly modifies those goals and policies. These are in the Community Health and Safety (CHS), Land Use (LU), Mobility (M), and Open Space and Conservation (OSC) elements. The following describes the goals, policies, and programs that directly and indirectly result in the reduction of GHG emissions by reducing air pollution, incentivizing alternate modes of transportation, creating safe environments for pedestrians and bicyclists, establishing parking spaces for more sustainable modes of travel, and placing higher density housing and commercial uses near transit stations.

Findings

Policy CS-1-3. Physical Activity and the Built Environment. Support new developments or infrastructure improvements in existing neighborhoods that enable people to drive less and walk, bike, or take public transit more.

Policy LU-1-4. Land Uses that Support Transit. Encourage higher -intensity development on the specific opportunity sites designated in the El Camino Real planning area.

Policy LU-1-6. Public-Private Partnerships. Consider opportunities to use public investment to form partnerships with the private sector to achieve quality infill development, enhance the public realm, and encourage public transit, walking, and biking.

Policy LU-2-1. Water Conservation. Promote water conservation by educating and encouraging residents and businesses to incorporate drought tolerant and low water using planting, smart irrigation systems, water efficient appliances, and recycled water systems.

Policy LU-2-2. Water Efficient Landscape. Apply the Water Efficient Landscape Ordinance to new development and projects that include a qualifying amount of replacement or new landscaping.

Policy LU-2-3. Open Space. Require accessible, attractive open space that is well maintained and uses sustainable practices and materials in all new multiple dwelling and mixed-use development.

Policy LU-2-4. Low Impact Development. Regulate new development and construction to minimize pollutant and sediment concentrations in receiving waters and ensure that surface water meets or exceeds applicable regulatory water quality standards. Require new development to incorporate Low Impact Development features that treat and reduce surface runoff volumes.

Policy LU-2-5. Energy Efficiency. Support energy efficient improvements in aging building stock.

Policy LU-2-6: Solar Energy. Provide incentives f or installation of solar and photovoltaic systems on existing buildings and new development.

Policy LU-2-7: Electric Vehicles. As Town gasoline -powered vehicles are replaced, purchase electric and hybrid vehicles when practicable. Install electric vehicle charging stations with new commercial and mixed -use developments.

Policy LU-2-8: Climate Action Plan. Maintain a Climate Action Plan and continue to partner with San Mateo County’s Regional Climate Action Planning Suite (RICAPS) to prepare community-wide greenhouse gas inventories.

Findings

Policy LU-2-9: Greenhouse Gas Reduction Targets. Work to achieve greenhouse gas emissions reductions that are consistent with the targets established by AB32 (California Global Warming Solutions Act) and subsequent supporting legislation.

Policy LU-2-10: Green Building. Support sustainability and green building best practices through the orientation, design, and placement of buildings and facilities to optimize their energy efficiency in preparation of State zero-net energy requirements for residential construction and commercial construction.

Policy LU-3-6. Walkable Neighborhoods. The Town shall promote walkable neighborhoods by supporting alternative modes of transportation; enhancing bike and pedestrian c onnectivity to local commercial districts and transit centers; and maintaining sidewalks, public plazas, parks and greenways, parkways, street tree canopies, and landscaping throughout residential neighborhoods.

Policy LU- 5-1. Regional Cooperation. Participate with other cities in the county and across the region in working towards solutions to the issues of regional land use, housing, homelessness, and transportation planning through partnership with the Association of Bay Area Governments, the Metropolitan Transportation Commission, and the San Mateo City/County Association of Governments (C/CAG).

Policy LU-5-2. San Mateo County Collaboration. Continue to consult with San Mateo County and other cities in the region on effective land use, transportation, sustainability, and economic development strategies to learn about additional strategies that could be used in Colma to achieve the community’s vision and goals.

Policy M-2-1. Reduce Vehicle Miles Traveled. Require new development projects to achieve a reduction in VMT per capita or VMT per service population compared to both baseline VMT performance conditions and General Plan 2040 VMT performance conditions. The Town will regularly monitor baseline VMT to provide updated benchmarks for project applicants.

Encourage use of VMT reduction strategies and methods to encourage non- automobile travel.

Policy M-2-2. Other Traffic Flow Benchmarks. Establish additional traffic flow benchmarks, such as VMT, vehicle -hours of travel, and safety -related metrics, in order to evaluate and monitor changes in traffic flow over time.

Policy M-2-3. VMT Transportation Performance Measures. Update the Town’s transportation measures and thresholds to use VMT standards for traffic impact analysis rather than LOS.

Findings

Policy M-2-4. Multi-Modal Impact Fee. Consider establishing a transportation impact fee for new development tied to performance measures to generate funds for improving all modes of transportation.

Policy M-3-3. Regional Transportation Planning. Actively participate in and support regional transportation planning efforts.

Policy M-3-4. Transit Funding. Seek joint transportation and transit funding opportunities with adjoining jurisdictions or agencies to improve transit access in and around Colma.

Policy M-3-5. Transportation Gaps. Eliminate gaps in the regional active transportation network in Colma.

Policy M-4-2. Reliable Transportation Services. Encourage SamTrans and other public transit providers to provide service on regular schedules along El Camino Real, arterial streets, and, as feasible, major collectors; support these transportation services to increase the mobility of seniors, the disabled, and others who depend on public transportation.

Policy M-4.3. Encourage Transportation Options. Encourage and support various public transit agencies and companies, ride -sharing programs, and other incentive programs that provide residents and visitors with transportation choices other than the private automobile.

Policy M-4.4. Transit Oriented Development. Promote the development of multi-modal mixed-use development at sites surrounding the Colma BART station, where feasible along Mission Road, and at the Town Center site.

Policy M-4.5. Connections to Homes and Businesses. Seek opportunities to improve first and last mile connections between transit, homes, and businesses.

Policy M-5-1. Complete Streets. Incorporate Complete Streets infrastructure elements into new streets, street retrofits and certain maintenance projects to encourage multiple modes of travel, based on the modal priorities in Table M-2, as appropriate to the context and determined reasonable and practicable by the Town.

Policy M-5-2. Design for All Travel Modes. Plan, design, and construct transportation projects to safely accommodate the needs of pedestrians, bicyclists, transit riders, motorists, people with mobility challenges, and persons of all ages and abilities.

Policy M-5-3. Bicycle Connection Coordination. Coordinate with BART, South San Francisco, Daly City, Caltrans, and San Mateo County to plan and implement bicycle and pedestrian improvements which connect with improvements to BART facilities and regional networks.

Findings

Policy M-5-4. Accessibility and Universal Design. Prioritize implementation of pedestrian facilities that improve accessibility consistent with guidelines established by the Americans with Disabilities Act (ADA), allowing mobility- impaired users, such as the disabled and seniors, to travel safely and effectively within and beyond the town.

Policy M-5-5. Design of New Development. Require new development to incorporate design that prioritizes safe pedestrian and bicycle travel and accommodate senior citizens, people with mobility challenges, and children.

Policy M-7-1. TDM Program. Continue to participate in the TDM Program as outlined by the San Mateo City/County Association of Governments (C/CAG).

Policy M-7-2. TDM Program for New Development. Require major development proposals to include a detailed, verifiable TDM program for consideration by the Town during the review of the development application.

Policy M-7-3. Vehicle Trip Reduction. Support vehicle trip reduction strategies, including building safer and more inviting transportation networks, supporting connections to high frequency and regional transit, implementing TDM programs, and integrating land use and transportation decisions.

Policy OSC-1-3. Sustainable Landscape Practices. Encourage the enhancement of public areas with landscaping practices that minimize water usage.

Policy OSC-1-4. Pedestrian Trails, Bikeways Walkways. Expand and improve pedestrian trails, bikeways, and walkways to connect trails and allow access to open space land and regional trail facilities.

Policy OSC-1-5. Colma Creek Trail. Coordinate with the City of South San Francisco to provide continuous pedestrian access from the Colma BART station along El Camino Real to the southern border of the town.

Policy OSC-2-1. Open Space for Recreation Use. Develop and maintain open spaces and recreation areas that are conveniently located, properly designed, and well-maintained to serve the recreation needs and healthy living of the entire community.

Policy OSC-2-2. Recreation Requirements for New Developments. Require dedication of improved land, or payment of a fee in lieu of, for park and recreation land for all residential uses.

Policy OSC-2-3. Expansion of Recreation Space. Acquire and enhance properties within Colma for recreation and public use if opportunities become available.

Policy OSC-3-1. Transit Oriented Development. Encourage, to the extent feasible, higher density residential development to be located near transit corridors and public transportation.

Findings

Policy OSC-3-2. Reduce Energy Consumption. Support measures and education to reduce energy consumption and increase energy efficiency in residential, commercial, and industrial buildings.

Policy OSC-3-3. Energy Efficiency in Municipal Operations. Pursue opportunities to improve energy efficiency and install renewable energy systems, where feasible, in new and existing Town-owned facilities and operations.

Policy OSC-3-4. GHG Reduction. Implement the Climate Action Plan to achieve GHG reduction targets that are consistent with the State Scoping Plan, AB 32, and SB 32 and the Town’s goals.

Policy OSC-3-5. Pedestrian-Scaled Design. Support the use of public/mass transit by encouraging pedestrian-friendly street design and mixed-use development near transit hubs.

Policy OSC-4-4. Use of Drought Tolerant and Native Plants. Enc ourage the use of drought tolerant and native plants in landscaping plans.

Policy OSC-5-6. Regional Open Space Preservation Efforts. Support regional and sub- regional efforts to acquire, develop and maintain open space conservation lands.

Despite the policies of the General Plan, implementation of the proposed P
roject would not meet the long-term GHG reduction goal under Executive Order S-03-05, and impacts would be potentially significant.

Implementation of Mitigation Measure GHG -1 would ensure that th e town is tracking and monitoring the town’s GHG emissions in order to chart a trajectory to achieve the long-term year 2050 GHG reduction goal set by Executive Order S-03-05. However, at this time, there is no plan past 2030 that achieves the long -term GH G reduction goal established under Executive Order S-03-05. As identified by the California Council on Science and Technology, the State cannot meet the 2050 goal without major advancements in technology (CCCC 2012). Advancement in technology in the future could provide additional reductions to allow the State and town to meet the 2050 goal; however, no additional statewide measures are currently available. Therefore, this impact
would be significant and
unavoidable. (Draft EIR, pp. 4.7-16 through 4.7-22.)

MM GHG-1: The town of Colma shall update the Climate Action Plan (CAP) every five years to ensure the town is monitoring the plan’s progress toward achieving the town’s greenhouse gas (GHG) reduction target and to require amendment if the plan is not achieving a specified level. The update shall consider a trajectory consistent with the GHG emissions reduction goal established under Executive Order S -03-05 for year 2050 and the latest applicable statewide legislative GHG emission reduction that may be in Findings

effect at the time of the CAP update (e.g., Senate Bill 32 for year 2030).

The CAP update shall include the following:

• GHG inventories of existing and forecast year GHG levels. • Tools and strategies for reducing GHG emissions to ensure a trajectory with the long-term GHG reduction goal of Executive Order S-03-05.
• Plan implementation guidance that includes, at minimum, the following components consistent with the proposed CAP:
• Administration and staffing
• Finance and budgeting
• Timelines for measure implementation
• Community outreach and education
• Monitoring, reporting, and adaptive management
• Tracking tools

D. TRIBAL CULTURAL RESOURCES

1. Tribal Cultural Resources
Threshold: Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
(i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k); or (ii) A resource determined by t he lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in Public Resources Code section 5024.1?
Finding: Significant and unavoidable. (Draft EIR, p. 4.4-27.) Explanation: Records searches completed by ASM for the town (ASM Affiliates 2020) from the NAHC and NWIC report no known TCRs within the town’s Planning Area. The Town has sent information request letters to contacts provided by the NAHC; however, no responses have been received to date. Though there are no reported
TCRs within the Planning Area, Native American
tribes were distributed across the San Francisco Peninsula region, and there is a possibility that unknown TCRs exist within the area.

Proposed General Plan Update P olicies

Policy OSC-6-2: Tribal Consultation Compliance. Comply with SB 18,AB 52, and other applicable State and federal laws by consulting with local California Native American tribes prior to development decisions or General Plan or Specific Findings

Plan amendments. Respect tribal policies regarding confidentiality of information about tribal resources or sacred sites.

In addition to the policies listed above, GPU Policy OSC-6-1 also addresses potential disturbances of TCRs.

While the Project does not specifically propose demolition or substantial alteration of a resource or ground -disturbing activities such as grading or excavation, it can be assumed that future development consistent with the goals and policies of the Project have the potential to result in significant direct and/or indirect impacts to TCRs. Therefore there is the potential that previously undiscovered TCRs may exist within the Planning Area and as such it can be assumed that future development consistent with the goals and policies of the Project have the potential to result in significant direct and/or indirect impacts to . Therefore, this is a significant and unavoidable impact and the following mitigation measures should be included:

MM CUL-3

1. For any project with potential to result in adverse impacts to TCRs, the Town shall avoid and/or minimize impacts by facilitating the identification of tribal cultural resources through field studies. Coordination and collaboration regarding the resource shall be completed with agencies, tribes, and institutions, such as the Northwest Information Cent er, the Native American Heritage Commission, and local tribal governments, including consultation as outlined in Senate Bill 18 and Assembly Bill 52.

The resource shall be treated with culturally appropriate dignity, taking into account the tribal cultural values and meaning of the resource, including, but not limited to, the following: (A) Protecting the cultural character and integrity of the resource; (B) Protecting the traditional use of the resource; and (C) Protecting the confidentiality of the resource.

2. If possible, the Town shall avoid and preserve the resources in place, including, but not limited to, planning and construction to avoid the resources and protect the cultural and natural context.

3. Greenspace, parks, or other open space shall use appropriate planning to incorporate the resources with culturally appropriate protection and management criteria. Permanent conservation easements or other interests in real property shall be created with culturally appropriate management criteria for the purposes of preserving or utilizing the resources or places. (Draft EIR, pp. 4.4-27 through 4.4-28.)

Findings

SECTION V.

CUMULATIVE IMPACTS
Regarding the Project’s potential to result in cumulative impacts, the City hereby finds as follows:

A. AESTHETICS
The Project has the potential to change the visual character of the town. Since the town of Colma is mostly built out, future development or addition of new residential and commercial uses, even under cumulative circumstances, would be located on infill sites, underu tilized sites, or redevelopment of existing sites. While such structures could impact views from surrounding jurisdictions, overall impacts related to aesthetics would be minimal and limited in a cumulative context.

Although the Project anticipates additional housing and commercial uses over the 20-year General Plan horizon, as mentioned, all future development is anticipated to be developed on vacant or underutilized sites within the town limits. Since the town is limited to infill and redevelopment growth for future residential, commercial or office uses, compact development near the center of town is encouraged and would protect the existing visual character of the town while not visually impacting existing cemetery and open space uses. Infill development would be encouraged so as to be aesthetically pleasing as well as compatible to surrounding land uses, particularly in the central area of the town of Colma. This would, in turn, assist in creating minimal aesthetic contrasts with the existing uses in terms of scale, color, form or overall visual character of the area. Further, though new infill development and redevelopment projects may result in taller or larger buildings than what currently exists in the town, the Project’s policies has the potential to reduce any impacts and ensure compatible development.

Implementation of the proposed Project would result in new infill development or redevelopment of existing properties that may add to the potential sources or glare and night-time lighting. These new development areas could result in new light sources which intensifies daytime glare and nighttime lighting levels. However, the Project contains numerous polices related to the protection of aesthetic resources in the Planning Area and future projects would have to be consistent with the 2040 General Plan’s policies and minimize effects for light and glare.

Therefore, the impact to aesthetics would be less than cumulatively considerable . (Draft EIR, p. 5.0-6.)

B. AGRICULTURE AND FORESTRY RESOURCES
The town of Colma is a small community recognized for its large expanses of cemetery land. Prior to the town’s cemetery development, the town of Colma was used for agricultural production, primarily providing produce to the growing City of San Francisco. Agricultural uses were generally limited to small-scale farms and greenhouse activities. The town of Colma and the surrounding area are urbanized and has one zoning designation for memorial park, agriculture, and recreation.

The town does not have areas zoned as forest land or timberland, or timberland zoned as Timberland Production. According to the Farmland Mapping and Monitoring Program of the California Resources Agency, the town of Colma is designated as Urban and Built Up. No land in the town is design ated as Prime Farmland, Unique Farmland, or Farmland of Statewide Findings

Importance. Urban and Built-Up Land is defined as “occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10- acre parcel. The majo r components of the total open space resource in the town of Colma (about 75% of the total land area) is land owned by cemeteries that is used for memorial parks, agriculture or general open space. The largest landholding of land that is not in use for cemetery use is owned by the Archdiocese of San Francisco. The land is located east of Hillside Boulevard and is primarily used for several wholesale nurseries, in -ground agriculture and landscape contractors. The town of Colma does not encompass any Prime Farmland, Unique Farmland, Farmland of Statewide Importance, forest land, or timberland. (Draft EIR, p. 5.0- 4.) Thus, there would be no cumulative impact.

C. AIR QUALITY
Emissions of pollutants are not confined to the town’s boundaries but are dispersed throughout and accounted for by air basin. Therefore, the cumulative area for air quality impacts is the San Francisco Bay Area Air Basin (SFBAAB). California is divided into air basins for the purpose of managing the air resources of the state based on meteorological and geographic conditions. Like greenhouse gas (GHG) emissions impacts, air quality impacts are regional in nature as no single project generates enough emissions that would cause an air basin to be designated as a nonattainment area. Construction emissions generated by cumulative development associated with buildout of the proposed Project could exceed Bay Area Air Quality Management District’s (BAAQMD) project -level significance thresholds and would contribute to the nonattainment designations of the SFBAAB. The SFBAAB is currently designated a nonattainment area for California and National O3, California and National PM2.5, and California PM10 AAQS. However the 2010 Clean Air Plan, prepared by BAAQMD contains numerous control measures that seek to reduce air pollution in the San Francisco Bay Area by promoting, for example, mixed use development, compact development that reduces vehicle emissions, and projects that reduce exposure from stationary and mobile source pollutants.

The Project does contain goals and policies that promote higher density mixed used development as well as ensuring that future development projects would comply with regional efforts to reduce air quality emissions throughout the Bay Area. However, in combination with past, present, and reasonably foreseeable projects elsewhere within the SFBAAB, the proposed Project ’s contribution
to cumulative air quality impacts would result in a significant and unavoidable impact. (Draft EIR, pp. 5.06 through 5.07.)

D. BIOLOGICAL RESOURCES
The cumulative area for impacts to biological resources is the Planning Area as well as surrounding jurisdictions. On a cumulative level, the change in land uses can potentially contribute to a loss of potential habitat for special-status species that currently inhabit the area or could inhabit the area in the future. In addition to potential direct impacts on biological resources from project implementation, the increased human presence can cause potential indirect impacts that could result in direct mortality, habitat loss, deterioration of habitat suitability, and avoidance of habitat.

The wildlife species associated with each habitat will likely be affected as well.

Findings

However, with the majority of the land reserved for cemetery uses, the town is generally built out. The majority of new development will come from in -fill sites or redevelopment of underutilized sites and would not occur within any potential biological features or habitat located within the town. In addition, the Conservation and Natural Resources Element of the General Plan establishes policies and programs to protect and conserve special status species and their habitat.

Therefore, the P
roject would have a less than cumulatively considerable impact on biological resources. (Draft EIR, p. 5.0-7.)

E. CULTURAL RESOURCES
Historical Resources
The cumulative area for impacts to cultural and tribal resources is the Planning Area as well as surrounding jurisdictions. Therefore, the Planning Area and the surrounding areas of San Mateo County as a whole must be considered for the purpose of evaluating land use conversion issues associated with cultural and tribal resources on a cumulative level. The jurisdictional boundaries of the town form the geographic context in which to analyze cumulative impacts to historical resources. Compliance with the goals and policies in the town’s GPU related to historical resources will be necessary for its implementation. Mitigation Measures CUL-1 and CUL-2 will apply to historical resources inadvertently discovered during construction activities. Future development projects will have to demonstrate that the project includes adequate measures to mitigate potentially significant impacts to historical resources in accordance with CEQA, and the preservation of resources outlined in the town’s GPU, thereby reducing cumulative impacts of historical resources to a less than significant level. Therefore, the proposed Project would have a less than cumulatively considerable
impact to historical resources.

Archaeological Resources
The San Francisco Bay Area provides the geographic context for the cumulative impacts analysis of archaeological resources. Though evidence of human occupation exists throughout the San Francisco Peninsula region, there are no known archaeological sites within ¼ mi. of the GPU project area. Throughout this region, many archaeological sites do exist that contain artifacts and features of value in reconstructing cultural patterns of early indigenous people. Construction activities associated with implementation of the GPU and future development projects have the potential to impact unknown archaeological resources and may present a significant cumulative impact to those resources. However, Mitigation Measures CUL-1 and CUL-3 would apply to
archaeological resources inadvertently discovered during construction activities and would reduce potential impacts to a less than significant level. Therefore, implementation of the proposed Project would have a less than cumulatively considerable impact to archaeological resources.

Human Remains
The San Francisco Bay region provides the geographic context for cumulative impacts analysis of human remains. The numerous archaeological sites in the San Francisco Bay region indicate that prehistoric early human occupation occurred throughout. Additionally, historic-era occupation of the area increases the possibility that humans could be interred outside formal cemeteries.

Cumulative development projects could encounter unknown, interred human remains during construction activities, which would result in a significant cumulative impact. Unidentified human remains, whether as part of a prehistoric burial, an archaeological site, or an isolated occurrence, could be present below the ground surface. Mitigation Measures CUL-1 and CUL-4, which include compliance with Health and Safety Code Section 7050.5 and PRC Section 5097.98, apply Findings

to the identification of human remains inadvertently discovered during construction activities.

These measures would provide an opportunity to minimize disturbance and appropriately treat human remains discovered. These measures would reduce the impacts of inadvertent discoveries of human remains to a less than significant level. Therefore, the proposed Project would have a less than cumulatively considerable
impact to human remains. (Draft EIR, pp. 5.0-7 through

5.0-8.)

F. ENERGY
The California Energy Commission oversees the achievement of the State’s ambitious climate and energy goals and ensures that the State’s energy systems remain accessible, reliable, safe and affordable through planning and policy implementation. Therefore, the cumulative area of analysis for energy impacts is the State of California.

The implementation of the Project
could result in the addition of 765 people, 328 housing units and 1,028,500 square feet of commercial and office developments. The addition of population and buildings has the potential to have an adverse impact on the environment by using more energy. However, California is transitioning its electricity system to one that relies increasingly on clean energy sources and increasing energy efficiency through building code updates. The 2019 Building Energy Efficiency Standards improve upon the 2016 Energy Standards for new construction of, and additions and alterations to, residential and nonresidential buildings. In addition, the population and anticipated growth in the town of Colma is small in comparison to the growth in San Mateo County and the state of California. Therefore, the impact to energy is less than cumulatively considerable
. (Draft EIR, pp. 5.0-8 through 5.0-9.)

G. GEOLOGY AND SOILS
The cumulative area for geology impacts is the Planning Area as well as surrounding jurisdictions.

Potential infill projects within the town and any future development projects with the Bay Area has the potential to bring additional people and structures to this area. There is always a chance that a fault located anywhere in the cumulative area could rupture and impact the town. The relative risk to safety from potential ground shaking within San Mateo County varies by location, geologic conditions and the source of the triggering event. Additionally, construction, grading, excavation, removal of vegetation and loading activities could temporarily increase runoff, erosion, and sedimentation.

While cumulative impacts to geology and soils may occur in the region as individual projects are constructed, the town’s General Plan policies and programs, along with state and federal regulations, reduce the risk to people in the region. Considering the programs and policies from the proposed Project and state and federal regulations, the overall impact of the proposed Project

to geology and soils would be less than significant and the project’s cumulative contribution to geology and soils impacts would be less than cumulatively considerable. (Draft EIR, p. 5.0-

9.)

H. GREENHOUSE GAS EMISSIONS
Findings

Greenhouse Gas Emissions (GHG emissions) have the potential to adversely affect the environment because, on a cumulative basis, they contribute to global climate change. In turn, global climate change has the potential to result in rising sea levels, which can inundate low-lying areas; affect rain and snow fall, leading to changes in water supply; and affect habitat, leadi ng to adverse effects on biological and other resources. Since GHG emissions come from many different sources in both current and expected future activities in a growing community, identification and reduction of GHG emissions is an important consideration in long-range planning efforts.

The town of Colma has updated its Climate Action Plan (CAP) so as to strive for reductions in GHGs over the 20 year horizon of the 2040 GPU. The town’s updated CAP provides guidance to the town’s future development/redevelopment and includes guidance for new development so as to attempt to reduce any future project’s contribution to climate change. Implementation of the proposed P
roject would result in a small, 1 percent increase in GHG emissions in horizon year 2040 from existing baseline and would not meet the long -term GHG reduction goal under Executive Order S -03-05. Implementation of Mitigation Measure GHG -1 would ensure that the town is tracking and monitoring the town’s GHG emissions in order to chart a trajectory to achieve the long-term year 2050 GHG reduction goal set by Executive Order S- 03-05. It should be noted though that no one single emitter of GHGs is solely capable of triggering global climate change on its own. Therefore, the incremental addition to cumulative global GHG impacts of the proposed 2040 GPU buildout would be significant and unavoidable . (Draft EIR, p. 5.0-9.)

I. HAZARDOUS AND HAZARDOUS MATERIALS
The land use policies in the proposed Project would provide direction for growth within the town limits, while the San Mateo County General Plan policies provides direction for growth outside the town limits, but within the Planning Area boundaries. Thus, the cumulative area for hazard impacts is the Planning Area as well as surrounding jurisdictions.

Development in the region identified in Section 4.0 of the Draft EIR would change the intensity of land uses in the town. In particular, the implementation of the Project would provide additional housing, employment, shopping, and recreational opportunities. Growth in the town could lead to increased noise, risk of flooding, risk of fire, and transport of hazardous materials on the state highways and interstates as well as that also serve the town. In addition, development elsewhere in the region could have a greater effect on the transport and accidental release of hazardous materials.

However, considering the town’s General Plan Update policies and programs, and state and federal regulations to reduce impacts related to hazards and the transport of hazardous materials, the overall impact would be less than significant and the project’s contribution to cumulative hazards and human health impacts would be less than cumulatively considerable . (Draft
EIR, p. 5.0-10.)

J. HYDROLOGY AND WATER QUALITY
Findings

All of the surface drainage in the town of Colma’s boundaries ultimately flows into Colma Creek, through the city of South San Francisco, and out into the San Francisco Bay. Therefore, the cumulative area of hydrology impacts is the Colma Creek watershed and San Francisco Bay. While the town of Colma is limited in its land area for future development, future development is anticipated to utilize infill and underutilized sit es at higher densities and intensities for both residential and commercial projects. The implementation of the Project may also increase
construction that results in runoff and the introduction of additional pollutants to runoff. These future development/redevelopment projects have the potential to impact groundwater recharge, impact water quality and alter drainage patterns, among others. However, future developments are required to include stormwater treatment measures that would retain and treat runoff if 5,000 square feet or greater, of land area is affected. This improves water quality by removing pollutants, allows for ground water recharge opportunities on developed sites and mitigates the impact of development on vacant sites. In addition, any future development/redevelopment project in the town would be required by the San Mateo Countywide Water Pollution Preventio n Program (SMCWPP) to comply with the NPDES Stormwater Discharge Permit, all local stormwater permit requirements. Compliance with water quality regulations, including the implementation of best management practices at construction sites would prevent erosion and tracking would mitigate construction runoff impacts. Therefore, impacts to hydrology would be less than cumulatively considerable. (Draft EIR, p. 5.0-10.)

K. LAND USE AND PLANNING
The cumulative area for land use impacts is the Planning Area as well as surrounding jurisdictions.

Typically, a cumulative impact on land use may result from projects that would destroy an established community by the construction of new roadways, highways or infrastructure, or plans and policies (in the cumulative context) that would conflict with existing plans at a cumulative level. While the Project would increase land use intensities within the town and anticipated adding more residences and businesses within the town boundaries by 2040, the Project itself does not
propose any specific developments. GPU policies ensure that new developments and redevelopment projects would be designed to be compatible in use and character, are compatible with existing neighborhoods, and comply with zoning regulations. In addition GPU policies ensure that the developments are compatible with other adopted land use plans and regulations.

Therefore, the cumulative impacts to land use are less than cumulatively considerable .
(Draft EIR, p. 5.0-10.)

L. MINERAL RESOURCES
The State Division of Mines and Geology has not classified or designated any areas in the town of Colma as containing regionally significant mineral resources. Therefore there would be no cumulative impacts to Mineral Resources from the proposed Project. (Draft EIR, p. 5.0-5.)

Findings

M. NOISE
Ambient noise levels within the town of Colma and its surrounding cities and counties have the potential to increase temporarily due to the construction of new development. Thus, the cumulative area for noise impacts is the Planning Area as well as surrounding jurisdictions.

Construction noise impacts typically result from noise generated by the operation of heavy equipment on a project site, as well as from trucks arriving to and departing from the site, which would be an intermittent source of noise. Typical project construction activities normally include demolition, grading/excavation, installation of utilities, and erection of the building. Equipment used in these activities typically include bulldozers, excavators, graders, backhoes, concrete trucks, loaders, and heavy-duty trucks.

Implementation of the Project has the potential to result in a number of future developments and redevelopment within the Planning Area. Construction within the Planning Area as well in those jurisdictions around the town, has the potential to expose people and buildings to high levels of ground-borne vibration. Although vibration levels from construction activities rarely reach the level of causing building damage, construction -related vibration has the potential to cause annoyance at nearby sensitive receivers. The effects of construction vibration vary depending on the intensity of the construction activities, local soil type, and distance to/land use type of nearby receptors. Construction vibration impacts would occur from the operation of heavy equipment on a project site. In general, site work and demolition activities typically generate the highest levels of vibration throughout a construction project.

However, it should be noted that the town is primarily built out and future development would be limited to infill sites or as redevelopment on developed but underutilized sites. Buildout of the Project, in relation to cumulative buildout in the areas surrounding the town would not result in substantial increase in noise levels. Therefore, cumulative noise impacts associated with the Project are less than cumulatively considerable. (Draft EIR, p. 5.0-11.)

N. POPULATION AND HOUSING
The cumulative area for population and housing impacts is the Planning Area as well as surrounding jurisdictions. The Project would increase land use intensities within the town and would add more residences within the town boundaries by 2040. Given that population and housing impacts are cumulative in nature, and that residents do not always work where they live in the regional area, the general region surrounding the town, including all of San Mateo County and parts of the city and county of San Francisco, Santa Clara County, and Alameda County must be considered when evaluating cumulative land use impacts. Population growth is not, in itself, an environmental impact; however, the direct and indirect effects related to population growth can lead to physical environmental effects.

While the GPU has the potential to increase the intensity of land uses in the town and increase the potential growth of the town, the Project
in itself are not expected to induce substantial
population growth in a cumulative context. GPU policies also encourage mixed use developments and developments around transit-oriented corridors, mitigating some of the impacts of growth.

In addition, GPU policies ensure that land uses are compatible with each other and are consistent with zoning, resulting in compatible communities. Therefore, the cumulative impacts to population growth are less than cumulatively considerable. (Draft EIR, p. 5.0-11.) Findings

O. PUBLIC SERVICES
The cumulative area for impacts to public services is the Planning Area as well as surrounding jurisdictions. The Project has the potential add 765 people, 328 housing units and 1,028,500 square feet of commercial and office developments, that may require more public resources. The town estimated that two additional police officers would be required under the Project; the number of firefighters is more difficult to estimate since the town operates solely on volunteer fire fighting resources. The town’s existing fire protection and emergency medical services, and police services, primarily serve the town but people outside of the town could also use those resources, therefore the project area and the surrounding areas of unincorporated San Mateo County, Daly City, and South San Francisco should be considered for the purpose of evaluating impacts related to public services.

In regard to fire protection, police and emergency medical services, the proposed Project does not identify the location of any new stations within the town’s boundaries to expand existing services. Should the future residential and commercial uses in the town of Colma require additional fire protection, police, or medical services, these would be addressed in the appropriate project-level environmental document prepared at that time.

Any increases in the town’s future population could increase the use of existing neighborhood and regional parks and recreational facilities. Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town is however committed to providing public park and recreation facilities that meet the needs of its residents. This commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law.

While the potential growth at buildout would impact existing resources and services, policies in the proposed Project
would ensure that public services are funded to continue to provide services to the town. Therefore, the cumulative impact to Public Services is less than cumulatively considerable. (Draft EIR, p. 5.0-12.)

P. RECREATION
The cumulative area for impacts to recreation is the Planning Area as well as surrounding jurisdictions. The Project has the potential add 765 people, 328 housing units and 1,028,500 square feet of commercial and office developments, that may require more public resources. The town’s existing recreation services primarily serve the town but people outside of the town could also use those resources, therefore the project area and the surrounding areas of unincorporated San Mateo County, Daly City, and South San Francisco should be considered for the purpose of evaluating impacts related to recreation.

Findings

Any increases in the town’s future population could increase the use of existing neighborhood and regional parks and recreational facilities. Since the town is limited on space to add new public park and/or recreational facilities, the creation of such additional recreational facilities would be a challenge to the town. The town is however committed to providing public park and recreation facilities that meet the needs of its residents. This commitment may require the town to creatively utilize its existing facilities or to enter into development agreements with neighboring jurisdictions to allow for the creation and maintenance of walkways, trails and bike facilities. The construction (or expansion of existing recreational facilities) would be subject to its own environmental review pursuant to CEQA and State law.

While the potential growth at buildout would impact existing resources and services, policies in the proposed Project
would ensure that public services are funded to continue to provide services to the town. Therefore, the cumulative impact to Recreation is less than cumulatively considerable. (Draft EIR, p. 5.0-12.)

Q. TRANSPORTATION
The transportation analysis assesses impacts between No Project (Current General Plan) and Cumulative (2040) Plus Plan (Proposed General Plan Update) to determine if the implementation of the GPU would result in a cumulative increase in VMT and congestion. In addition, impacts to emergency access are reviewed on the same level. Therefore, the cumulative area for transportation impacts is the regional transportation system.

The implementation of the Project
would increase VMT per person and congestion over No Project Conditions. However, implementation of GPU policies would mitigate the impacts to these areas and therefore, impacts to transportation are less than cumulatively considerable. (Draft EIR, p. 5.0-12.)

R. TRIBAL CULTURAL RESOURCES
The San Francisco Bay region provides the geographic context for the cumulative impacts analysis to Tribal Cultural Resources (TCRs). Impacts would be cumulative if the project, in combination with cumulative development, contributed to the permanent loss of TCRs on a regional scale. The cumulative context for TCRs is the ancestral land affiliated with the Ohlone or Costanoan group of Native Americans.

The Project includes goals and policies for preserving and protecting TCRs. Specifically, these measures include requesting information and tribal contacts from the NAHC, as well as outreach and consultation. Compliance with the goals and policies in the Project related to TCRs will be necessary for its implementation and to demonstrate that the project includes adequate measures to mitigate potentially significant impacts to resources in accordance with CEQA and AB 52.

Mitigation Measures CUL -1 and CUL-3 will apply to the identification of tribal cultural resources inadvertently discovered during construction activities. Following the town’s request for information from tribal representatives with regard to the GPU, there are no known TCRs within the GPU Planning Area, and thus a direct affect to known TCRs would not occur; however, past development within the regional San Francisco Bay tribal affiliated areas has caused undeveloped Findings