The 2013 General Plan EIR found that with the implementation of mitigating General plan Policies CON 1.1, CON 1.2, CON 1.7 – CON 1.14, CSF 2.1-2.15, SA 3.1- SA 3.13 and Actions CON 1f-1k, CSF 2a2g, SA 3a-3h as well as through the application of applicable state and local regulation, impacts to hydrology and water quality were less than significant.
Stormwater Regulation
The State Water Resources Control Board (SWRCB) is responsible for implementing the Clean Water Act (CWA) and has issued a statewide General Permit for construction, which acts to minimize pollutant runoff to surface waters and groundwater. The City of Cotati is mostly located within the North Coast Hydrologic Region, which manages the Russian River watershed, and a portion of the southern part of the city drains to San Pablo Bay by the Petaluma River and is managed as a part of the San Francisco Bay Hydrologic Region. Within the city, there are two hydrologic subareas, the Upper Laguna de Santa Rosa Subarea (Russian River) and the Petaluma River Subarea (San Pablo). Cotati has joined with other permittees in the Santa Rosa Plain under a Phase 1 National Pollution Discharge Elimination System (NPDES permit (Water Quality Order No. R1-2015-0030) (NPDES No. CA0025054) which imposes requirements on municipalities to mitigate for stormwater quality and quantity and provides the Santa Rosa Storm Water Low Impact Development Technical Design Manual (LID Manual) as guidance.
Project Consistency with the 2013 General Plan EIR
A preliminary Hydrology and Hydraulics Report was prepared by Civil Design Consultants (February 2024) that evaluated existing hydrology of the site and the storm drain capacity and is relied upon to inform this analysis.
5.10(a) (Discharge) – No Substantial Change Relative to the General Plan EIR Construction
The Project’s construction activities and the installation of new impervious areas have the potential to result in increased runoff that could contain sediment and other pollutants that could degrade water quality if not properly controlled. Potential pollutants commonly associated with construction include fuel, grease, oil, concrete material, sediment, and litter. These pollutants have the potential to degrade water quality if not properly managed. However, as concluded in the 2013 General Plan EIR, the NPDES requirements, including the preparation and implementation of a Storm Water Pollution Prevention Plan (SWPPP) and compliance with the RWQCB Order No. R1-2015-0030, Waste Discharge Requirements minimize the impacts from future development. The purpose of the SWPPP is to identify potential sediment sources and other pollutants and prescribe BMPs to ensure that potential adverse erosion, siltation, and contamination impacts would not occur during construction activities.
Public Works has imposed a Condition of Approval that requires that the SWPPP be approved by the North Coast Regional Water Quality Control Board (NCRWQCB). Further, the Project is required to conform to Chapter 14.36 of the Municipal Code, which contains grading and erosion control 271 of 1220
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Cotati Village Community Two Project Page 96 of 157 CEQA Analysis requirements. In compliance with the 2013 General Plan Policy CON 1.12, Policy SA 3.3, and Policy SA
3.13, COA HYD-1 requires that the applicant secure an SWPPP approved by the NCRWQCB and submit to the City’s Engineer prior to issuance of a grading permit. With condition of approval, implementing the Policies of the General Plan and in conformance with RWQCB Order No. R1-2015-0030, the Project’s potential to result in impacts due to contaminated discharges during construction will be less than significant.
Operation
The proposed Project is required to conform to Chapter 13.68 of the Cotati Municipal Code, which regulates storm water discharge. A preliminary Stormwater Control Plan was prepared for the Project that demonstrates that Low Impact Design Strategies can feasibly pre-treat stormwater prior to entry into the municipal storm drain. A preliminary Hydrology and Hydraulics Report was prepared by Civil Design Consultants (February 2024) that evaluated existing hydrology of the site and the storm drain capacity of the 36-inch storm drain in Alder Avenue. The report concluded that sufficient capacity exists to accommodate Project flows without expansion of municipal storm utilities.
Public Works provided Conditions of Approval that require that Project stormwater capture and discharge design meet the most recent edition of City of Cotati, Phase I MS4 permit and the City of Santa Rosa Low Impact Development (LID) Technical Design Manual, and that prior to approval of the improvement plans, the applicant shall submit a Final Storm Water Low Impact Development Plan (FSWLID), subject to review and acceptance by the City Engineer. The applicant prepared a preliminary Stormwater Low Impact Development Submittal, and to ensure compliance with this requirement, COA HYD-2 is imposed, and requires that the FSWLID include post-construction storm water treatment and peak reduction measures and address maintenance of private and/or public storm water facilities.
As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact to stormwater discharge relative to the 2013 General Plan EIR.
5.10(b) (Groundwater) – No Substantial Change Relative to the General Plan EIR Buildout of the Cotati General Plan will result in the introduction of new impervious surfaces that could potentially reduce rainwater infiltration and groundwater recharge. However, the General Plan EIR determined that impacts would be minimal in urban areas since the net change in impervious surfaces would be negligible. The 2013 General Plan EIR further determined that development anticipated under the General Plan would result in less than significant impact due to the depletion of ground water supplies or interference with groundwater recharge. The City has established maximum groundwater extraction volume policies that reduce the drawdown of groundwater and is not expanding use of groundwater supplies.
The State of California adopted the Sustainable Groundwater Management Act (SGMA) in 2014 which called for the creation of local Groundwater Sustainability Agencies (GSA) to develop and implement Groundwater Sustainability Plans for the long-term management of groundwater resources. The Santa Rosa Plain GSA was formed through a joint powers authority (JPA) between the cities of Cotati, Rohnert Park, Santa Rosa, and Sebastopol, Town of Windsor, County of Sonoma, Sonoma Water, Gold Ridge Resource Conservation District, and Sonoma Resource Conservation District (Sonoma RCD) and 272 of 1220
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Cotati Village Community Two Project Page 97 of 157 CEQA Analysis has a participation agreement with mutual water companies and CPUC-regulated water corporations that allows for participation in the GSA.
The Groundwater Sustainability Plan (GSP) for the Santa Rosa Plain Subbasin was approved by the California Department of Water Resources (DWR) on January 26, 2023. It establishes a standard for sustainability of groundwater management and use and determines how the basin will achieve this standard by 2042.
The Project proposes to rely exclusively on municipal water supplies and does not propose the extraction or use of groundwater. Furthermore, to ensure the Project complies with guidance from the Bay Area Stormwater Management Agencies Association (BASMAA) Post-Construction Manual, including low impact development strategies and best management practices in site design to mimic pre-project site hydrology, COA HYD-2 has been imposed. As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.10(c i-iv) (Drainage Pattern) – No Substantial Change Relative to the General Plan EIR The 2013 General Plan EIR determined that impacts due to increases in impervious surfaces and alteration of drainage conditions, as they relate to erosion, runoff, and drainage flow would be less than significant with General Plan policies and mitigation. Implementation of General Plan policies, Municipal Code regulations, and applicable provisions of the City’s MS4 permit were identified as measures that would reduce impacts to less than significant levels.
Through the implementation of COA HYD-1, the Project will comply with these requirements during construction. The site design is also required to implement best practices for low impact development to mimic pre-project site hydrology through COA HYD-2. Further, the Public Works/Engineering conditions require City Engineer approval of stormwater management, on-site drain facilities, grading, and any drainage improvements.
The City is served by an existing storm drain system, and the City’s Engineer has confirmed the infrastructure capacity for the Project. As new developments have the potential to incrementally increase the use of storm drains, the City has established development impact fees levied on new developments to contribute to any needs for new or expanded infrastructure. Payment of development impact fees, as well as review of final drainage plans for compliance with uniformly applied standards, is a requirement in the building permit process. Development impacts fees are used to maintain and build out the city’s storm drain system as planned.
The Project includes a preliminary plan for onsite infiltration and connection to the storm drain system. To ensure compliance with the 2013 General Plan EIR Policies CON 1.12, CON 1.13, SA 3.2, and SA 3.12, COA HYD-2 requires the Project plans to include onsite storm drain infrastructure with connections to the existing storm drain system and shall pay any required development impact fees.
As conditioned, and through the application of uniformly applied standards, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.10(d) (Pollutants in Flood Hazard, Tsunami, or Seiche Zones) – No Change Relative to the General Plan EIR
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Cotati Village Community Two Project Page 98 of 157 CEQA Analysis The City of Cotati is subject to flooding of the Laguna de Santa Rosa and Cotati creeks and implementation of the General Plan could result in the flooding of development in these areas. As shown in Figure 3.8-1: Watersheds of the 2013 General Plan EIR, the Project site is not located near any streams or rivers that could be directly impacted by the proposed Project. As shown in Figure 3.8- 2: Flood Hazard Map of the 2013 General Plan EIR, the Project site is located outside of the regulated 100-year flood plain and within the 500-year floodplain, which is considered a low to moderate flood hazard area, but it is not within any tsunami or seiche hazard zones. Therefore, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.10(e) (Conflict with Water Quality Control Plan or Sustainable Groundwater Management Plan) – No Change Relative to the General Plan EIR
The 2013 General Plan EIR determined that new development would be required to adhere to pertinent local, state, and federal agency requirements, and that with implementation of Policy SA 3.2 and compliance with water quality regulation including NPDES requirements, potential impacts to water quality would be reduced to less than significant levels.
COA HYD-1 and COA HYD-2 require implementation of pertinent local, state, and federal agency requirements, including the Cotati Municipal Code, and ensures the Project would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
Policy CON 1.12: Require discretionary projects, as well as new flood control and stormwater conveyance projects, to integrate best management practices (BMPs) and natural features to the greatest extent feasible, while ensuring that these features adequately convey and control stormwater to protect human health, safety, and welfare.
Status: The Project is subject to the regulations of the Regional Water Quality Control Board and as a project that is larger than one acre is required to prepare a Storm Water Pollution Prevention Plan (SWPPP), comply with the RWQCB Order No. R1-2009-0045 Waste Discharge Requirements, implement BMPs, and comply with the City’s Municipal Code Chapter 13.68 which regulates storm water discharge, as well as Chapter 14.36, which regulates erosion and sediment control. A preliminary erosion control plan has been prepared and Public Works Engineering Conditions require a SWPPP approved by the RWQCB. Further, COA HYD-1 requires submittal of a final SWPPP and acceptance by the City Engineer to ensure compliance with applicable regulations and incorporation of required construction practices into the project. A preliminary storm water control plan (SCP) has been prepared that demonstrates that the Project can accommodate stormwater flows from impervious surface in bioretention planters distributed throughout the site. The planters would provide treatment and removal of pollutants prior to collection in underground volume capture, infiltrate stormwater, and discharge excess flows to the municipal storm drain in Alder Avenue. COA HYD-2 requires submittal of a final SCP plan and acceptance by the City Engineer to ensure compliance with the City’s Municipal Code and the City’s MS4 permit during Project operation. As conditioned, the Project is consistent with this policy. 274 of 1220
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Cotati Village Community Two Project Page 99 of 157 CEQA Analysis Policy CON 1.13: Prioritize the use of natural features such as bioswales, vegetation, retention ponds, and other measures to remove surface water pollutants prior to discharge into surface waters.
Status: The Project is designed to include a series of bioretention areas that will receive gutter and impervious surface runoff, and which are designed to remove surface water pollutants prior to entering into storm drains. COA HYD-2 requires submittal of a final SCP and acceptance by the City Engineer to ensure compliance with the City’s Municipal Code and the City’s MS4 permit during Project operation. As conditioned, the Project is consistent with this policy.
Policy SA 3.2: Require all development projects to demonstrate how storm water runoff will be detained or retained on-site and/or conveyed to the nearest drainage facility as part of the development review process. Project applicants shall demonstrate that project implementation would comply with all applicable provisions of the City’s MS4 permit and companion documents, which collectively define the design storm event for water detention and retention features.
Status: The project will treat stormwater through the use of bioretention areas dispersed throughout the development that receive stormwater from gutters and runoff off of impervious surfaces.
Overflow from bioretention areas will be conveyed to the existing municipal storm drain in Alder Avenue. As conditioned by COA HYD-2, a Storm Water Low Impact Development Plan (FSWLID) and Stormwater Mitigation Plan shall be submitted for review and approval by the City Engineer. COA HYD-2 also requires the City Engineer to review final construction plans to ensure appropriate application of best management practices for low impact development. As conditioned, the Project complies with this policy.
Policy SA 3.3: Ensure that construction activities will not result in adverse impacts to existing flood control and drainage structures.
Policy SA 3.13: Ensure that adequate drainage and erosion controls are provided during construction of all new developments.
Status: Best management practices for soil erosion and sediment control are required to be applied during construction by COA HYD-1. Additionally, the Project is subject to Municipal Code Chapter
14.36, Erosion and Sediment Control Plan, which requires preparation and implementation of a final erosion and sediment control plan. Compliance with this condition and the uniformly applied development standards ensures that potential adverse effects of erosion during construction activities are avoided. COA HYD-1 requires that the applicant submit final plans to the City Engineer for approval prior to issuance of the grading permit. As conditioned, the Project complies with this policy.
Policy SA 3.12: Require all new developments in the city to be designed to minimize vegetation removal, soil compaction, and site coverage.
Status: The site is dominated by ruderal vegetation and contains 41 trees. The Tree Inventory (Appendix C) details that it is possible to preserve 36 trees on the project site as well as existing street trees located along Alder Avenue. Soil treatments during grading must be conducted in accordance with the recommendations of the Project geotechnical investigation, as required by COA GEO-1, and 275 of 1220
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Cotati Village Community Two Project Page 100 of 157 CEQA Analysis will be confirmed by the City during site inspections. As conditioned by COA HYD-2, the Project would be required to implement low impact development strategies per the Santa Rosa Storm Water Low Impact Development Technical Design Manual. As conditioned, the project complies with this policy.
Action SA 3g: As part of the development review process, require developers to prepare hydrological studies for all new developments as required by the City Engineer. Studies shall encompass the project site as well as the entire drainage area.
Status: A hydrology study, dated February 2024, was prepared by Civil Design Consultants for the project, encompassing the Project site and drainage area as required by SA 3g. The hydrology study evaluated the capacity and condition of the municipal storm drain in Alder Avenue and concluded that there is sufficient capacity to accommodate the Project. The City Engineer has conducted an initial review of the proposed plans and provided a memo that includes conditions of approval. As such, the project complies with this policy.
Conclusion and Environmental Conditions of Approval
The Project is within the scope of development projected under the General Plan and as conditioned and through the application of uniform standards, complies with the mitigating policies and actions in the 2013 General Plan EIR. As conditioned the Project would not result in any substantial new or more severe impacts to hydrology and water quality relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The following environmental conditions of approval are required to implement the 2013 General Plan EIR mitigating policies:
COA HYD-1: Prior to issuance of a building permit, the applicant shall submit a Storm Water Prevention and Pollution Plan (SWPPP) and erosion and sediment control plan for approval by the City Engineer. The SWPPP shall include Best Management Practices to be implemented during grading and construction activities. The SWPPP shall incorporate the requirements of all applicable federal, state, and local regulations. Submitted plans shall also demonstrate compliance with City of Cotati Municipal Code Chapter 13.68 Storm Water Ordinance and Chapter 14.36 Erosion and Sediment Control.
COA HYD-2: Prior to issuance of a grading permit, the applicant shall submit a final Stormwater Control Plans (SCP) including a final Storm Water Low Impact Development Plan (FSWLID) and Stormwater Mitigation Plan for review and approval by the City Engineer. 276 of 1220
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Cotati Village Community Two Project Page 101 of 157 CEQA Analysis
5.11. LAND USE AND PLANNING
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) Physically divide an established
community?
b) 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?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015. 2013 General Plan EIR Findings
The 2013 General Plan EIR evaluated potential impacts to Land Use in Chapter 3.9 and determined the following:
• Impact 3.9-1: General Plan implementation has the potential to physically divide an established community. The proposed General Plan does not include any new areas designated for urbanization or new roadways, infrastructure, or other features that would divide existing communities and would result in a less than significant impact. • Impact 3.9-2: General Plan implementation has the potential to conflict with an applicable land use plan, policy, or regulation of an agency with jurisdiction over the project adopted to avoid or mitigate an environmental effect. Implementation of the General Plan could result in potential adverse environmental impacts, including traffic, noise, water quality, biological resources, drainage and water quality, air quality, hazards, geology/soils, and cultural resources. Through compliance with local, state, and federal regulations as well as the mitigating policies and actions evaluated in the 2013 General Plan EIR, implementation of the General Plan would have a less than significant impact.
Project Consistency with the 2013 General Plan EIR
5.11(a) (Physically Divide Community) – No Change Relative to the General Plan EIR The Project proposes development on a privately-owned, underdeveloped parcel. The site is surrounded by existing roads on the south and east, the existing Cotati Cottages residential development to the east, as well as a currently vacant parcel to the east (recently approved for mixed use development Cotati Villages 1), and commercial to the west. The Project would introduce new residences and access in a manner anticipated by the General Plan and consistent with the site’s zoning. As such, the Project would not physically divide a community. Additionally, the project will 277 of 1220
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Cotati Village Community Two Project Page 102 of 157 CEQA Analysis introduce a multi-use path along the frontage to SR-116, a sidewalk along Alder Avenue, and new internal pathways that will provide connections to existing, planned, and proposed facilities.
Therefore, the Project would not substantially increase the severity of the less than significant impacts nor would it result in new significant impacts related to physical division of an established community that were not identified in the 2013 General Plan EIR.
5.11(b) (Conflict with Land Use) – No Substantial Change Relative to the General Plan EIR The Project is consistent with the General Plan land use designation and allowable density and FAR for the site, as provided by the State Density Bonus law. Through the environmental review process and design review process, the Project is found to be consistent with the General Plan policies and zoning code standards applicable to the proposed development and as provided by the State Density Bonus law. Implementation of the Project would be subject to compliance with conditions of approval imposed on the Project as a standard part of the entitlements process to ensure compliance and implementation of General Plan policies, regulations, and development standards, from the subsequent permitting and construction process. Therefore, as conditioned the Project would not substantially increase the severity of the less than significant impacts nor would it result in new significant impacts that were not identified in the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
The 2013 General Plan EIR did not identify any mitigating policies for Land Use, however the EIR notes that the General Plan could result in potential adverse environmental impacts, including to traffic, noise, water quality, biological resources, drainage and water quality, air quality, hazards, geology/soils, and cultural resources. The EIR notes that the Impacts to these resources, including consistency with applicable plans, policies, and regulations, are evaluated in the appropriate sections of the 2013 General Plan EIR.
The Project is conditioned to ensure compliance and consistency with relevant mitigating policies and actions identified in the 2013 General Plan EIR in the relevant sections of this document and as conditioned, is consistent with the mitigating policies and actions in the 2013 General Plan EIR.
Conclusion
The Project is within the scope of development projected under the General Plan. As conditioned through the review process, the Project is consistent with the General Plan and complies with the City’s zoning code and would not physically divide a community. As conditioned, the Project would not substantially increase the severity of the less than significant impacts nor would it result in new significant impacts that were not identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The Project Conditions of Approval are required to implement the 2013 General Plan EIR mitigating policies and actions. 278 of 1220
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Cotati Village Community Two Project Page 103 of 157 CEQA Analysis
5.12. MINERAL RESOURCES
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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?
b) Result in the loss of availability of a
locally-important mineral resource
recovery site delineated on a local general
plan, specific plan or other land use plan?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015. Mines Online by California Department of Conservation Division of Mine Reclamation viewed on May 13, 2024. 2013 General Plan EIR Findings
The California Department of Conservation Surface Mining and Reclamation Act of 1975 (§ 2710), also known as SMARA, provides a comprehensive surface mining and reclamation policy that permits the continued mining of minerals, as well as the protection and subsequent beneficial use of the mined and reclaimed land. The 2013 EIR did not identify any known significant mineral resources of value to the region and residents of the state within the city.
Project Consistency with the 2013 General Plan EIR
5.12(a-b) (Mineral Resources) – No Change Relative to the General Plan EIR The site does not contain known significant mineral resources of value.3 As such, the Project will not impact mineral resources and the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
There are no applicable General Plan EIR mitigation measures to this Project.
Conclusion
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to land use and planning relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and 3 California Department of Conservation, Division of Mne Reclamation. Mines Online. https://maps.conservation.ca.gov/mol/index.html Accessed: May 13, 2024. 279 of 1220
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Cotati Village Community Two Project Page 104 of 157 CEQA Analysis there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. No Conditions of Approval are required beyond compliance with uniformly applied development standards and applicable local and state regulations. 280 of 1220
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Cotati Village Community Two Project Page 105 of 157 CEQA Analysis
5.13. NOISE
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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?
b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) 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 of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels?
Source: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; Cotati Village Community Two Noise and Vibration Analysis prepared by Illingworth and Rodkin on June 7, 2024; and City of Cotati Municipal Code; and Public Works/Engineering Conditions of Approval prepared in February 29, 2024. 2013 General Plan EIR Findings
The City of Cotati 2013 General Plan EIR identifies the City’s existing noise and vibration sources and levels, standards of measurement and thresholds, and potential impacts resulting from implementation of the General Plan. The 2013 General Plan EIR concludes that, with implementation of General Plan policies, impacts to ambient noise levels in the City due to traffic noise sources as well as cumulative stationary noise sources and increased traffic noise would be significant and unavoidable.
The 2013 General Plan EIR evaluated potential impacts to Noise in Chapter 3.10 and determined the following:
• Impact 3.10-1: General Plan implementation has the potential to increase ambient noise levels due to traffic noise sources. While implementation of the Policies N 1.1 – N 1.3, N1.6 – N 1.14 and Actions N 1a – N 1g of the General Plan will reduce noise and land use compatibility impacts from vehicular traffic noise sources and would ensure that new development is 281 of 1220
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Cotati Village Community Two Project Page 106 of 157 CEQA Analysis designed to include noise-attenuating features, some traffic noise impacts cannot be mitigated to a less-than-significant level due the proximity of sensitive receivers to major roadways, and because noise attenuation may not be feasible in all circumstances. Therefore, implementation of the General Plan could potentially result in a significant increase in ambient noise levels and would result in a significant and unavoidable impact.
• Impact 3.10-2: General Plan implementation has the potential increase ambient noise levels due to railroad noise sources. This is considered a less than significant impact. Through the implementation of the mitigating General Plan Policies N 1.1 – N 1.3, N 1.8, N 1.11, and Actions N 1a – N 1c, and 1g, implementation of the General Plan would have a less than significant impact.
• Impact 3.10-3: General Plan implementation has the potential increase ambient noise levels due to stationary noise sources. Through the implementation of the mitigating General Plan Policies N 1.1, N 1.2, N 1.3, N 1.4, N 1.5, N 1.7, N 1.8, N 1.9, N 1.11, N 1.13, and Actions N 1a – N 1c, and 1g, implementation of the General Plan would have a less than significant impact. • Impact 3.10-4: General Plan implementation has the potential increase ambient noise levels due to construction noise sources. Through the implementation of the mitigating General Plan Policies N 1.5, N 1.12, and Actions N 1c, N 1d, N 1e, and N 1h, implementation of the General Plan would have a less than significant impact.
• Impact 3.10-5: General Plan implementation has the potential to cause increased perceptible groundborne vibration levels during construction. Through the implementation of the mitigating General Plan Policies N 1.5, N 1.12, N 1.15, and Actions N 1c and N 1h, implementation of the General Plan would have a less than significant impact. • Impact 3.10-7: Under cumulative conditions, the General Plan would accommodate development that would result in increased traffic noise and an increase in stationary noise sources. The General Plan includes mitigating Policies N 1.1- N 1.14, and Actions N 1a – N1h that are intended to reduce noise associated with both stationary sources and traffic. While these policies will reduce noise impacts, some traffic noise impacts cannot be mitigated to a less-than-significant level due the proximity of sensitive receivers to major roadways, and because noise attenuation may not be feasible in all circumstances. As a result, this is a significant and unavoidable cumulative impact.
• The City of Cotati adopted the Findings of Fact and Statement of Overriding Considerations on March 24, 2015, including for the significant and unavoidable impacts identified for Noise (Impact 3.10-1 and 3.10-7). The City findings determined that subsequent development under the General Plan would result in an increase in noise. While consistency with policies and actions would help reduce exposure of sensitive receptors to noise levels, it may not be feasible to mitigate the impact to less than significant levels in all instances, particularly where existing development is located near proposed development. Additionally, some traffic noise impacts cannot be mitigated to less than significant levels due to proximity of sensitive receptors to 282 of 1220
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Cotati Village Community Two Project Page 107 of 157 CEQA Analysis major roadways and noise attenuation may not be feasible in all circumstances. The City findings determined that despite the significant and unavoidable impact to noise, no other project alternative would meet the City’s objective to realize the development potential of undeveloped lands for residential, office, and commercial uses necessary for housing opportunity and job growth.
Project Consistency with the 2013 General Plan EIR
5.13(a) (Increase in Ambient Noise) – No Substantial Change Relative to the General Plan FEIR The existing noise environment at the site consists primarily of noise from vehicular traffic on SR116, with distant noise from Highway 101 contributing to background sound levels. Other sources of noise include commercial, agricultural, and residential noise in the vicinity. The General Plan provides that “specified land use may be permitted only after detailed analysis of noise reduction requirements is made and needed noise insulation features are included in the design.” The City of Cotati Municipal Code Section 17.30.050 further states that the maximum allowable noise levels for residential outdoor and interior spaces are 65 dBA Ldn and 45 dBA Ldn, respectively.
A Noise and Vibration Assessment was prepared for the proposed Project by Illingworth and Rodkin on June 7, 2024 (Appendix F). A noise survey included three short-term measurement locations, shown as ST-1, ST-2, and ST-3, two of these measurements (ST-1 and ST-2) were made in the vicinity of proposed buildings A and B at approximately 235 feet and 400 feet from the centerline of SR-116. A third location (ST-3), which was conducted at the position of the long-term measurement closest to SR-116 east of the site at the Cotati Village #1 location. LT-1 was made on the trunk of a tree at a height of 12 feet above grade and approximately 100 feet from the centerline of SR-116. Average daytime noise levels ranged from 62 to 68 dBA Leq, the average hourly nighttime noise levels ranged from 53 to 66 dBA Leq, and overall average Day/Night noise Level (Ldn) is 68-69 dBA.
Based on existing noise levels and the distances from the facades of proposed Building A and B with views of SR-116 traffic, it is anticipated that the traffic noise exposure at Building A would range from 56 to 62 dBA Ldn and the traffic noise exposure at Building B would range from 60 to 61dBA Ldn under existing conditions.
The future noise environment, like the existing environment, would primary be due to roadway traffic. The noise assessment estimates the increase in traffic volume along SR-116, not related to the project will result in a projected increase in noise conditions by 3 dBA resulting in a range of 59-65 dBA Ldn for areas of Building A with views of SR-116 and a range of 63 to 64 Ldn for areas of Building B with views of SR-116.
As detailed in the Noise and Vibration Assessment, and established by General Plan Policy N1.7, a substantial permanent noise increase would occur if the noise level increase resulting from the Project is 1.5 dBA where existing traffic noise levels are greater than 65 dBA Ldn, 3 dBA Ldn where existing traffic noise levels are between 60 and 65 dBA Ldn, and 5 dBA Ldn where existing traffic noise levels are less than 60 dBA Ldn as established by the Cotati General Plan.
The Project proposes a central common open space area, approximately 275 feet from the centerline of SR-116 and will receive partial acoustical shielding from intervening structures.
Without partial shielding, sound levels in the common space area are expected to be up to 65 283 of 1220
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Cotati Village Community Two Project Page 108 of 157 CEQA Analysis dBA Ldn. This exterior noise level is considered to be “normally acceptable” for multifamily residential land uses, and no further noise reduction measures are required.
For interior noise level in new residential buildings, the interior noise levels from normal construction are typically 20-25 dBA below exterior noise levels with windows closed, or 15 dBA below when windows are partially open. For building frontages facing the SR-116 frontage, final project design would need to incorporate features to reduce the 65 dBA Ldn noise level to an interior standard of 45 dBA Ldn. To ensure interior noise standards are met, COA NOI-1 has been imposed and requires the installation of mechanical ventilation systems to supply fresh air to all apartments in Buildings A and B that are within 400 feet of the centerline of SR-116. As conditioned, construction of the project would not substantially increase noise levels and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact
Operational Noise Generation
The proposed project would place new residential uses within 175 feet of the future Cotati Village #1 residential development to the east and within 200 feet of an existing multi-family housing development to the northeast. The occupation and use of the proposed homes is expected to result in the typical noises associated with residential development, including voices of the new residents, home maintenance activities, barking dogs and children. The Heating Ventilation and Air Conditioning (HVAC) and other mechanical equipment associated with multifamily residential development may also add noise to the existing environment. As described in the Noise and Vibration Assessment, the outdoor condensing units at the proposed residences may produce constant sound levels of 47 to 50 dBA Leq at 50 feet and could operate continuously during both daytime and nighttime hours. Considering these noise levels and distances to the adjacent residential uses, noise from the project HVAC equipment would be at or below ambient noise levels at these adjacent residences. Additionally, though noise resulting from occupation of the new residences may noticeably change the noise environment in some adjacent residential areas, these sources are not expected to increase noise levels in any surrounding areas by four or more dBA and the noise associated with the proposed residences is not incompatible with the surrounding land uses. Therefore, the operation of the project would not substantially increase noise levels and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact.
Project Generated Traffic Noise
A substantial increase would occur if the project traffic on area roadways were to result in a noise level increase of 5 dBA Ldn or greater at multi-family homes east of the project site, or by 1.5 dBA Ldn or greater at the single-family homes south of the project site on the opposite side of SR-116.
The traffic analysis for the Cotati Village #2 development indicates that it would generate 68 trips during the a.m. peak hour and 69 during the p.m. peak hour, and the Traffic Impact Analysis for the Cotati Village #1 indicates that it would generate 110 trips during the a.m. peak hour and 178 during the p.m. peak hour for a total trip generation between the Village #1 and Village #2 projects of 178 trips during the a.m. peak hour and 247 trips during the p.m. peak hour. The analysis from Cotati Village #1 traffic report also indicated that there are currently 1,348 am peak hour trips and 1,251 pm peak hour trips on SR-116 adjacent to the site. 284 of 1220
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Cotati Village Community Two Project Page 109 of 157 CEQA Analysis Considering traffic volumes from the recently approved Cotati Village #1 and the subject proposed project, Cotati Village #2, traffic would result in a less than 1 dBA increase in noise levels on SR-116. Further, under the proposed project, traffic on Alder Avenue would result in a 3 dBA or less increase in noise levels. As such the project would not substantially increase traffic noise.
As conditioned, the Project will not result in a substantial increase in noise and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact to noise relative to the 2013 General Plan EIR.
5.13(b) (Groundborne Vibration) – No Substantial Change Relative to the General Plan EIR The City of Cotati 2013 General Plan EIR determined that construction activities from buildout of the General Plan could result in periods of significant ambient noise levels and groundborne vibration. As outlined below, General Plan action items relevant to the proposed Project include Actions N 1c and N 1h. Action N 1c requires an acoustical study for all new discretionary projects and Action N 1h contains suggested “best practices” for control of construction noise. In compliance with these action items identified in the 2013 General Plan EIR, a Noise and Vibration Analysis was prepared for the Project (Appendix F).
Construction activities would include site preparation work such as grading and the installation of utilities, foundation work, and new building framing and may generate groundborne vibrations.
Construction techniques that generate the highest vibration levels, such as impact or vibratory pile driving, are not expected.
Construction activities would generally occur at distances of 200 feet or more from the nearest residential units to the northeast. A standard vibration limit of 0.5 in/sec, PPV, used by the California Department of Transportation, is applied to consider structural damage for buildings designed to modern engineering standards; 0.2 in/sec, PPV is used for buildings found to be structurally sound but where structural damage is a major concern. As shown in Table 5.1, vibration source levels for typical construction equipment would not exceed these vibration limits at distances of 200 feet. As such, construction vibration levels would be well below limits at the closest residential structures.
Table 5.8: Vibration Source Levels for Construction Equipment Source PPV at 25 ft. (in/sec) PPV at 200 ft. (in/sec)
Clam shovel drop 0.202 0.009
Hydromill (slurry wall) in soil 0.004 0.0004
Hydromill (slurry wall) in rock 0.008 0.001
Vibratory Roller 0.210 0.009
Hoe Ram 0.089 0.004
Large bulldozer 0.089 0.004
Caisson drilling 0.089 0.004
Loaded trucks 0.076 0.003
Jackhammer 0.035 0.002
Small bulldozer 0.003 0.0001
Source: Noise and Vibration Assessment, prepared by Illingworth and Rodkin, Inc, June 7, 2024. 285 of 1220
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Cotati Village Community Two Project Page 110 of 157 CEQA Analysis Construction would result in a temporary increase in noise levels at adjacent residential receivers.
Construction activities are typically carried out in stages with variations in noise levels by stage and within stages as different mixes of equipment are used. Typical noise levels at 50 feet were calculated during construction of housing to range from approximately 65 to 88 dBA, as shown in Table 5.9.
Table 5.9: Typical Ranges of Leq Construction Noise Levels at 50 Feet, dBA Construction Stage Domestic Housing Public Works Roads & Highways, Sewers, and Trenches
I II I II
Ground Clearing 83 83 84 84
Evacuation 88 75 88 78
Foundations 81 81 88 88
Erection 81 65 79 78
Finishing 88 72 84 84
Notes: I – All pertinent equipment present at site, II – Minimum required equipment present at site.
Source: Noise and Vibration Assessment, prepared by Illingworth and Rodkin, Inc, November 14, 2022 Per the Noise and Vibration Assessment, the nearest noise sensitive uses will be 120 to 200 feet from the nearest construction activities. Average noise levels produced by site preparation and site improvement activities associated with construction work at this distance would range from 74 to 88 dBA. Construction activities at this distance would range from 73 to 90 dBA, with average levels of 75 to 78 dBA. Home building activities at this distance would range from 63 to 90 dBA with an average level of 77 dBA. These noise levels drop off at a rate of about 6 dBA per doubling of distance between the noise source and receptor. Most noise levels produced during site construction activities would occur at distances of 400 feet or more from adjacent noise sensitive uses and would produce average noise levels of 71 dBA.
Construction is not expected to expose adjacent existing residences to construction-related noise exceeding 60 dBA Leq for a period of greater than one year, based on the construction schedule, noise levels at varying distances, and a degree of noise attenuation once intervening structures are built.
The Project would also be required to follow standard “best practice” controls from Action N1h as contained in Policy N 1.15 of the General Plan. To implement this policy and associated action COA NOI-2 has been established and requires standard “best practice” controls as well as applicable noise standards outlined in Section 17.30.050 of the Municipal Code.
As conditioned, the Project would not result in a new significant impact or substantially increase the severity of a previously identified significant impact to vibration relative to the 2013 General Plan.
5.13I (Airfield Noise) – No Change Relative to the General Plan EIR The proposed Project is not located within the vicinity of a private airstrip or an airport land use plan, nor is it within two miles of a public airport or public use airport. Therefore, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact to airfield noise relative to the 2013 General Plan EIR. 286 of 1220
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Cotati Village Community Two Project Page 111 of 157 CEQA Analysis 2013 General Plan EIR Mitigating Policies and Actions
Policy N 1.2: Require development and infrastructure projects to be consistent with the Land Use Compatibility for Community Noise Environments standards indicated in General Plan Table N-1 (EIR Table 3.10-9) to ensure acceptable noise levels at existing and future uses.
Policy N 1.3: Require development to mitigate excessive noise through best practices, including building location and orientation, building design features, placement of noise-generating equipment away from sensitive receptors, shielding of noise-generating equipment, placement of noise-tolerant features between noise sources and sensitive receptors, and use of noise-minimizing materials such as rubberized asphalt.
Policy N 1.8: Ensure that new development does not expose indoor sleeping areas to indoor noise levels in excess of 45 dBA Ldn.
Status: The Noise and Vibration Assessment for the Project (Appendix F) determined that with incorporation of sound attenuation measures as imposed by COA NOI-1, the Project can be constructed to meet noise level standards. As conditioned this Project complies with these policies.
Action N 1c: Require an acoustical study for all new discretionary projects, including development and transportation, with potential noise impacts. The study shall include mitigation measures necessary to ensure compliance with this Noise Element and relevant noise standards in the Land Use Code.
Status: Illingworth & Rodkin, Inc prepared a Noise and Vibration Assessment for the proposed Project (Appendix F) on June 7, 2024. The study addressed the existing and future noise environment with respect to the requirements of the City of Cotati General Plan and Cotati Municipal Code and proposed noise attenuation measures, which are imposed as Conditions of Approval. As such, the Project complies with this action.
Action N 1h: During the environmental review process, determine if proposed construction will constitute a significant impact on nearby residents and require mitigation measures in addition to the standard “best practice” controls. Suggested “best practices” for control of construction noise:
• Construction period shall be less than twelve months. • Noise-generating construction activities, including truck traffic coming to and from the construction site for any purpose, shall be limited to between the hours of 7:00 am and 7:00 pm on weekdays and 9:00 am and 5:00 pm on Saturdays (if allowed through specific project conditions of approval). No construction shall occur on Sundays or holidays. • All equipment driven by internal combustion engines shall be equipped with mufflers, which are in good condition and appropriate for the equipment. • The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists.
• At all times during project grading and construction, stationary noise-generating equipment shall be located as far as practicable from sensitive receptors and placed so that emitted noise is directed away from residences.
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Cotati Village Community Two Project Page 112 of 157 CEQA Analysis • Unnecessary idling of internal combustion engines shall be prohibited. • Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction. • The required construction-related noise mitigation plan shall also specify that haul truck deliveries are subject to the same hours specified for construction equipment. • Neighbors located adjacent to the construction site shall be notified of the construction schedule in writing.
• The construction contractor shall designate a “noise disturbance coordinator” who will be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and institute reasonable measures as warranted to correct the problem. A telephone number for the disturbance coordinator shall be conspicuously posted at the construction site.
Status: Construction activities associated with the Project have the potential to result in temporary noise and vibration levels that would impact adjacent homes periodically over the course of the construction period and COA NOI-2 is required for consistency with this policy which includes the standard noise attenuation conditions including conformance with Chapter 17.30.050 of the Municipal Code, which establishes allowable hours of operation for construction activities. As conditioned, there would be no additional construction-related noise and vibration impacts beyond those analyzed in the 2013 General Plan EIR and the Project is consistent with this policy.
Conclusion and Environmental Conditions of Approval
The Project is within the scope of development projected under the General Plan and as conditioned complies with the 2013 General Plan and would not result in any substantial new or more severe impacts to noise relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The following environmental conditions of approval are required to implement the 2013 General Plan EIR mitigating policies and actions:
COA NOI-1: Prior to issuance of the building permit, the applicant shall submit final design plans that incorporate and certify the inclusion of mechanical ventilation equipment for all apartments located in Buildings A and B with a clear view of traffic on SR-116. The mechanical ventilation shall supply fresh air via an acoustically rated straight air transfer duct such as the Fresh 80, 90 or 100-dB units by Fresh Ventilation or an equivalent unit or other system deemed satisfactory by the local building official, to provide adequate fresh air to the residences with closed windows to maintain interior noise levels at or below 45 dBA Ldn.
COA NOI-2: The Project shall implement best management practices to minimize construction-related noise impacts as set forth in Action N1h of the General Plan, as listed below, and shall meet all applicable noise standards as set forth in Section 17.30.050 of the Cotati Municipal Code:
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Cotati Village Community Two Project Page 113 of 157 CEQA Analysis
1. Noise-generating construction activities, including truck traffic coming to and from the construction site for any purpose, shall be limited to between the hours of 7:00 am and 7:00 pm on weekdays and 9:00 am and 5:00 pm on Saturdays. No construction shall occur on Sundays or holidays.
2. All equipment driven by internal combustion engines shall be equipped with mufflers, which are in good condition and appropriate for the equipment.
3. The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists.
4. At all times during project grading and construction, stationary noise--‐generating equipment shall be located as far as practicable from sensitive receptors and placed so that emitted noise is directed away from residences.
5. Unnecessary idling of internal combustion engines shall be prohibited.
6. Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction.
7. Neighbors located adjacent to the construction site shall be notified of the construction schedule in writing.
8. The construction contractor shall designate a “noise disturbance coordinator” who will be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and institute reasonable measures as warranted to correct the problem. A telephone number for the disturbance coordinator shall be conspicuously posted at the construction site.
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Cotati Village Community Two Project Page 114 of 157 CEQA Analysis
5.14. POPULATION AND HOUSING
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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 roads or
other infrastructure)?
b) Displace substantial numbers of
existing people or housing, necessitating
the construction of replacement housing
elsewhere?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; City of Cotati Housing Element Update 2023-2031 certified on June 2, 2023; and City of Cotati, 2023-2031 Housing Element Update: Addendum Evaluation, March 2023.
2013 General Plan EIR Findings
The 2013 General Plan EIR evaluated potential impacts to Population and Housing in Chapter 3.9 and determined the following:
• Impact 3.9--‐5: General Plan implementation has the potential to induce substantial population growth. Through implementation of General Plan policies and actions intended to guide growth to appropriate areas and limit land uses allowed under the proposed General Plan, population and housing growth associated with the proposed General Plan would result a less than significant impact.
• Impact 3.9--‐6: General Plan implementation does not have the potential to displace substantial numbers of people or existing housing. The General Plan could result in development that would remove residences, but the development allowed under the General Plan would result in an increase in the total number of residences and provide housing opportunities for persons that may be displaced as a result of development. This provision of replacement “housing opportunities” is essentially a self-mitigating aspect and implementation of the General Plan and would have a less than significant impact.
The City of Cotati 2013 General Plan EIR determined that the 2030 General Plan would accommodate approximately 2,140 new residential units within the City Limits and the Sphere of Influence through 2035. This new growth would increase the Planning Area’s population by 290 of 1220
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Cotati Village Community Two Project Page 115 of 157 CEQA Analysis approximately 5,243 residents. The population in Cotati in 2013 was estimated at 7,310 in the 2013 General Plan EIR. The proposed General Plan is intended to accommodate the City’s fair share of statewide housing needs, which are allocated by the Association of Bay Area Governments.
The 2013 General Plan EIR determined that with implementation of General Plan policies and actions intended to guide growth to appropriate areas and provide services necessary to accommodate growth, the land uses allowed under the proposed General Plan, the infrastructure anticipated to accommodate proposed land uses, and the goal and policy framework would not induce growth that would exceed adopted thresholds but did not specify any mitigating policies.
Additionally, the 2013 General Plan EIR determined that while the proposed General Plan may result in development that would remove residences, development allowed under the General Plan would result in an increase in the total number of residences and provide housing opportunities for persons that may be displaced as a result of development. This provision of replacement “housing opportunities” was found to be self-mitigating aspect as a result of implementation of the proposed General Plan and impacts from population and housing were found to be less than significant.
Project Consistency with the 2013 General Plan EIR
5.14(a) (Induced Substantial Growth) – No Change Relative to the General Plan EIR The City of Cotati has an existing population of approximately 7,584 residents4 which is only slightly more than the population in 2010 (7,265), and the City has not reached the growth planned in the 2013 General Plan (an additional 5,243 residents). The General Plan Housing Element establishes the policies and programs to plan for the projected population growth and units needed to accommodate the housing needs of the city.
The Project would result in the construction of 126 units within two apartment buildings. The 126 units proposed on the site were considered in the 2023-2031 Housing Element as planned units that would contribute to meeting the City’s regional housing needs allocation in the Housing Element. The addendum to the General Plan EIR prepared in conjunction with the 2023-2031 Housing Element update (SCH# 2013082037) affirms that the units facilitated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan. 5 The Project site is located within City limits and would connect to the existing water and sewer lines.
As such, the Project site is served by existing services and infrastructure and will not require the extension or construction of new utilities to provide adequate service. There are no other elements of the Project that would induce growth at levels beyond what has been anticipated by the City of Cotati 2013 General Plan EIR. The project will not substantially increase the severity of the significance of impacts nor would it result in new significant impacts relative to the 2013 General Plan EIR.
5.14(b) (Displacement) – No Change Relative to the General Plan EIR The Project site is located within the City limits and currently contains one unoccupied single-family residence that is proposed for demolition. As such, the proposed Project would not displace a 4 City of Cotati, Housing Element 2023-2031, certified June 2, 2023. 5 City of Cotati, 2023-2031 Housing Element Update: Addendum Evaluation, March 2023. 291 of 1220
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Cotati Village Community Two Project Page 116 of 157 CEQA Analysis substantial number of people or existing housing that would require the construction of replacement housing elsewhere. The Project proposes to develop 126 dwelling units, which would provide an increase in housing. Therefore, Project impacts related to the displacement of housing or people would not exceed those analyzed in the City of Cotati 2013 General Plan EIR and the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
There are no applicable 2013 General Plan EIR mitigation measures related to Population and Housing.
Conclusion
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to land use and planning relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. No Conditions of Approval are required beyond compliance with uniformly applied development standards and applicable local and state regulations including the State Density Bonus. 292 of 1220
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Cotati Village Community Two Project Page 117 of 157 CEQA Analysis
5.15. PUBLIC SERVICES
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
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 any of the
public services:
a) Fire protection?
b) Police protection?
c) Schools?
d) Parks?
e) Other public facilities?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; and Memorandum from Rancho Adobe Fire Protection District prepared on February 14, 2024. 2013 General Plan EIR Findings
The 2013 General Plan EIR evaluated potential impacts to Public Services in Chapter 3.11 and determined the following:
• Impact 3.11-1: General Plan implementation has the potential to result in adverse physical impacts associated with governmental facilities and the provision of public services.
Through the implementation of mitigating policies CSF 1.1 – CSF 1.3, CSF 2.28 – CSF 2.36, CSF 4.7, CSF 4.8, OS 2.1 – OS 2.6, LU 3.12, LU 3.14, LU 3.15, and LU 4.1 and mitigating actions CSF 1a, CSF 1b, CSF 2o – CSF 2s, CSF 4d, CSF 4e, OS 2a – OS 2c, implementation of the General Plan would have a less than significant impact.
• Impact 3.11-2: Implementation of the General Plan has the potential to result in adverse physical impacts associated with the deterioration of existing parks and recreation facilities or the construction of new parks and recreation facilities. Through the implementation of mitigating General Plan policies OS 2.1 – OS 2.6 and mitigating actions OS 2a – OS 2c, 293 of 1220
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Cotati Village Community Two Project Page 118 of 157 CEQA Analysis implementation of the General Plan would have a less than significant impact.
The 2013 General Plan EIR determined that development accommodated under the 2013 General Plan would result in additional residents and businesses in the City, including new residential, industrial, office, and commercial uses and accommodate approximately 1,541 new residential dwelling units. The new growth was expected to increase the City’s population by approximately 3,775 residents while development within the City limits and the Sphere of Influence of influence could add 2,140 new residential units or 5,243 new residents. This would result in increased demand for public services, including fire protection, law enforcement, schools, parks, libraries, and other public and governmental services. The 2013 General Plan includes policies and actions to ensure that public services are provided at acceptable levels and to ensure that development and growth does not outpace the provision of public services. The 2013 General Plan EIR concluded that the implementation of the mitigating policies CSF 1.1 – CSF 1.3, CSF 2.28 – CSF 2.36, CSF 4.7, CSF 4.8, OS 2.1 – OS 2.6, LU 3.12, LU 3.14, LU 3.15, and LU 4.1 and mitigating actions CSF 1a, CSF 1b, CSF 2o – CSF 2s, CSF 4d, CSF 4e, OS 2a, OS 2b, and OS 2c would result in a less than significant impact.
Project Consistency with the 2013 General Plan EIR
5.15(a) (Fire) – No Change Relative to the General Plan EIR The Project site is served by the Rancho Adobe Fire Protection District (RAFD). The District was formed in 1993 through the combining of two smaller districts, the Cotati Fire Protection District and the Penngrove Fire Protection District. The RAFD provides services to the Penngrove, Cotati, and unincorporated areas of Petaluma. RAFD covers an emergency response area of roughly 86 square miles and serves approximately 28,000 people. Service is provided by three stations located at 1 East Cotati Avenue; 11000 Main Street in Penngrove and 99 Liberty Road in Petaluma. Currently, there are 13 full-time Firefighters, Engineers and Captains; three Battalion Chiefs; 24 part-time Firefighters; one part-time Fire Chief; and one Administrative Manager.
The RAFD has automatic aid agreements with neighboring districts, including the California Department of Forestry and Fire Protection (CAL FIRE) and the City of Rohnert Park. CAL FIRE provides automatic aid for emergency incidents in the west portions of the District and to State Responsibility Area fires. CAL FIRE provides fire response to anywhere in the District at the District’s request. Under the automatic aid agreement between RAFD and the City of Rohnert Park, the City of Rohnert Park responds to structure fires, water-flow alarm-sounding, vegetation fires, and vehicle collision calls in the RAFD service area, including locations in Cotati.
The Project proposes to install new water mains on site that will be sized according to City standards that would connect to existing water mains on Alder Avenue. The system is required to comply with the standards of the California Fire Code (CFC) as referenced in the City of Cotati Municipal Code
14.04.110. The Project proposes six new fire hydrants on site and relocation of an existing hydrant along SR-116 back several feet to line up with proposed improvements on SR-116. The final location of hydrants would be subject to review and approval by RAFD. Project plans have been reviewed by the RAFD and noted that final review and approval is contingent on the implementation of conditions applied to all projects.
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Cotati Village Community Two Project Page 119 of 157 CEQA Analysis As a standard condition of project approval, the applicant will be required to pay all applicable development impact fees, including fire suppression facilities impact fees. These funds will be sufficient to offset any cumulative increase in demands for fire protection services. Through the implementation of uniformly applied standards, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.15(b,d,e) (Police, Parks, Other) – No Change Relative to the General Plan EIR The increase in residents and addition of commercial space may incrementally increase the demand for public services. However, new demands on police services and recreational facilities have been previously anticipated as part of General Plan buildout. As a standard condition of Project approval, the applicant will be required to pay all development impact fees applicable to a mixed-use development project, including recreation facilities impact fees. These funds will be sufficient to offset any increase in demand for public services. As such, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.15(c) (Schools) – No Change Relative to the General Plan EIR The proposed Project involves the construction of 126 dwelling units and a café, which is expected to result in some additional student enrollment consistent with incremental increase anticipated by the General Plan. The site is located within the Cotati-Rohnert Park Unified School District (CRPUSD). The CRPUSD includes eight elementary schools, two middle schools, and two high schools. As of August 31, 2017, total enrollment within the CRPUSD was 5,844 students.6 The CRPUSD has a capacity to serve approximately 8,227 students;7therefore the school district can accommodate up to 2,383 more students.
The City of Cotati levies School Impact Fees on new development as allowed by Senate Bill 50 (SB 50).
It is outlined in California Government Code Section 65996 that development fees authorized by SB 50 are considered, “full and complete school facilities mitigation.” As a new development, the Project is subject to the standard payment of requisite school impact fees, which will offset any potential impacts related to school facilities. Fees will be leveraged as student enrollment reaches capacity to expand facilities as necessary. As such, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
2013 General Plan EIR Mitigating Policies and Actions
Action CSF 2p: As part of the development review process for new projects, the City will continue to refer applications to the Rancho Adobe Fire Protection District (RAFD) for determination of the 6 Cotati-Rohnert Park Unified School District, Month Enrollment as of August 31, 2017, presented to Board of Trustees on September 15, 2017.
7 Developer Fee Justification Study for Cotati-Rohnert Park Unified School District, prepared by SchoolWorks, Inc., https://www.crpusd.org/developerfees, March 2016.
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Cotati Village Community Two Project Page 120 of 157 CEQA Analysis project’s potential impacts on fire protection services. Requirements will be added as Conditions of Approval to project’s approving resolutions.
Status: In accordance with City processing procedures, the application was routed to RAFD for initial review of the proposed project. Comments and conditions provided by RAFD on February 14, 2024 have been incorporated into the Project conditions of approval. Final plans for construction are required to be reviewed by RAFD to confirm the final design is consistent with conditions of approval and standards for development. As such, the project complies with this action.
Action CSF 2q: As part of the development review process, consult with the Police Department in order to ensure that the project design facilitates adequate police response time and public safety and that the project addresses its impacts on police services.
Status: In accordance with City processing procedures, the application was routed to the Police Department for input. The Police Department reviewed the site plans and found them adequate for police protection purposes. Prior to certificate of occupancy, the City will assess and require payment of a police services impact fee. As such, the Project complies with Action CSF 2q.
Conclusion
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to public services relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. No Conditions of Approval are required beyond compliance with uniformly applied development standards and applicable local and state regulations.
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Cotati Village Community Two Project Page 121 of 157 CEQA Analysis
5.16. RECREATION
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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?
b) 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?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015 and California State Parks Community FactFinder Report pulled from State of California Department of Parks and Recreation website on May 10, 2024. 2013 General Plan EIR Findings
The 2013 General Plan EIR evaluated potential impacts to Recreation in Chapter 3.11 and determined the following:
• Impact 3.11-2: General Plan implementation has the potential to result in adverse physical impacts associated with the deterioration of existing parks and recreation facilities or the construction of new parks and recreation facilities. Through the implementation of mitigating General Plan Policies OS 2.1 – OS 2.6 and Actions OS 2a – OS 2c, implementation of the General Plan would have a less than significant impact.
Project Consistency with the 2013 General Plan EIR
5.16(a-b) (Deterioration of Recreational Facilities, Additional Recreation Facilities) – No Substantial Change Relative to the General Plan EIR
Cotati contains a total of 15 parks. Helen Putnam Park (8.3 acres) is located approximately 1.25 miles southeast of the Project site. Additionally, Sonoma County Regional Park District (EBRPD) manages approximately 15,500 acres of open space and preserves providing regional amenities to Cotati 297 of 1220
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Cotati Village Community Two Project Page 122 of 157 CEQA Analysis residents. Overall, in the City of Cotati, 76% of residents live in areas with less than 3 acres of parkland or open space per 1,000 residents.8
The Project would result in an increase in the City’s population and potential use of parks and recreational facilities. As noted in population and housing, this increase is accounted for in the 2013 General Plan. Mitigating General Plan Action OS-2a requires that new development maintain a minimum of one acre of park land per 200 residents. According to the California State Parks Community FactFinder Report9for the Project site, there are 0 acres per 1,000 residents within 0.5 miles of the Project. Therefore, to comply with Action OS-2a, COA REC-1 is established to require the dedication of parkland at a ratio of one acre per 200 residents or pay an equivalent in-lieu fee. As conditioned, the Project will not cause substantial or accelerated physical deterioration of recreational facilities and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
Action OS-2a: Update the Municipal Code to establish minimum parks and open space standards for new development. At a minimum, the standards shall seek to maintain one acre of park land per 200 residents. Additional measures may include requirements to establish assessment or tax districts to fund park maintenance, open space requirements, and provisions for in-lieu fees in instances where it is not feasible or appropriate for new development to provide park land on-site.
Status: The Project will result in an increase in the number of residents and the site is located in an area where there is a ratio of 0 acres of parkland per 1,000 residents within 0.5 miles of the Project.
Therefore, COA REC-1 requires that the applicant dedicate parkland at a ratio of one acre per 200 people or pay an equivalent in-lieu fee. As conditioned, this Project complies with Action OS-2a and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
Conclusion and Environmental Conditions of Approval
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to recreation relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The following environmental conditions of approval are required to implement the 2013 General Plan EIR mitigating policies and actions:
COA REC-1: Prior to issuance of the building permit, the applicant shall dedicate one acre of parkland per 200 residents or pay an in-lieu fee as determined by the Community Development Director. 8 California State Parks, Park Access Tool for City of Cotati, accessed on June 24, 2024. https://www.parksforcalifornia.org/parkaccess/?search=city0616560&overlays1=parks%2Cnoparkaccess&overlays2=parks%2Cparksper1000 9 California State Parks, Community FactFinder Report for Coordinates: 38.3334, -122.7213. Generated on May 10, 2024. 298 of 1220
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5.17. TRANSPORTATION
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) Conflict with a program plan,
ordinance, or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian
facilities?
b) Conflict or be inconsistent with CEQA
Guidelines section 15064.3 subdivision
(b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible uses (e.g., farm equipment)?
d) Result in inadequate emergency
access?
Sources: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; Technical Advisory on Evaluating Transportation Impact in CEQA, prepared by the California Office of Planning and Research, December 2018; Cotati Active Transportation Plan adopted on May 14, 2024; Guidelines for Analysis of Vehicle Miles Traveled, adopted by City of Cotati September 22, 2020; Memorandum from Rancho Adobe Fire Protection District prepared on February 14, 2024; and Traffic Impact study for Cotati Village 2 prepared by W-Trans on July 23, 2024. 2013 General Plan EIR Summary
The City of Cotati 2013 General Plan EIR identifies the City’s circulation network, including the roadway network, pedestrian and bicycle facilities, transit service, park and ride lots, rail service, and truck routes. The 2013 General Plan EIR concludes that, with implementation of General Plan policies, impacts to traffic operations in the City due to funding uncertainty, traffic operations on SR-116, and traffic operations on US 101 freeway facilities would be significant and unavoidable. The following impacts to transportation and circulation were considered under the 2013 General Plan EIR:
• Impact 3.12-1: Implementation of the proposed General Plan would result in acceptable traffic operation at the study intersections and roadway segments controlled by the City of Cotati, though the ability to fully fund all identified improvements is uncertain. Implementation of mitigating General Plan Policies CI 1.1, CI 1.2, CI 1.3, CI 1.5, CI 1.7, CI 1.20, CI 3.2, CI 3.3, CI 3.4, and Actions CI 1a, CI 1b, CI 1e- CI 1g, CI 1o- CI 1r, and CI 3b are not sufficient to reduce the impacts and implementation of the General Plan would result in a significant and unavoidable impact.
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Cotati Village Community Two Project Page 124 of 157 CEQA Analysis • Impact 3.12-2: General Plan buildout as well as regional growth would require improvements on Gravenstein Highway, a Caltrans facility. Because the City does not control the funding or timing of these improvements, the City cannot determine that the improvements will be made in time to accommodate regional and local growth. Implementation of mitigating General Plan Policies CI 1.1, CI 1.2, CI 1.3, CI 1.5, CI 1.7, CI 1.20, CI 3.2, CI 3.3, CI 3.4, CI 4.1, CI 4.3, - CI 4.7 and Actions CI 1a, CI 1b, CI 1e- CI 1g, CI 1o- CI 1r, CI 3b, and CU 4a would not sufficiently mitigate the lack of a regional fee program, or Ir Identified source of funding. As such, implementation of the General Plan would result in a significant and unavoidable impact and no further mitigation is available.
• Impact 3.12-3: General Plan implementation would contribute to unacceptable operation on US 101 freeway facilities. The Metropolitan Transportation Commission, County of Sonoma, City of Cotati, and SCTA recognize that US 101 will experience congestion into the foreseeable future, and that there will be no further major capacity enhancements such as expansions or new freeways. Implementation of the mitigating General Plan Policies CI 3.2 – CI 3.4, CI 4.1, CI
4.4, CI 4.6, CI 4.7, LU 2.5, LU 2.10, LU 3.8, and Actions CI 3b and CI 4a would not reduce the impacts to less than significant levels and implementation of the General Plan would result in significant and unavoidable impacts.
• Impact 3.12-4: The proposed General Plan would not conflict with an applicable congestion management program. As of the writing of the 2013 General Plan EIR, there was no congestion management program for Sonoma County or the City of Cotati. As such, implementation of the General Plan would have no impact.
• Impact 3.12-5: The proposed General Plan would not result in a change in air traffic patterns.
The City has no existing or planned airport facilities and is not located near any airports, approach, or departure zones. As such, the General Plan would have no impact. • Impact 3.12-6: Implementation of the proposed General Plan would not substantially increase hazards due to a design feature. Development and infrastructure projects in Cotati would be required to comply with the General Plan, Land Use Code, and applicable state and local regulations. Through the implementation of the mitigating General Plan Policies CI 1.8, CI 1.9, CI 1.18, and CI 1.24 and Actions CI 1j, CI 1l, CI 1m, CI 1r, and CI 2f, implementation of the General Plan would result in a less than significant impact. • Impact 3.12-7: Emergency Access. Through the implementation of the mitigating General Plan Policies CI 1.10, CI 1.14, CI 1.16 and Actions CI 1r, implementation of the General Plan would not impede emergency access and would result in a less than significant impact. • Impact 3.12-8: The proposed General Plan would accommodate increased demand for public transit and supports a shift in trips from automobile to transit modes. Through the implementation of the mitigating General Plan Policies CI 1.6, CI 2.14 – CI 2.22, and CI 3.2 and Actions CI 2i – CI 2k, implementation of the General Plan would have a less than significant impact.
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Cotati Village Community Two Project Page 125 of 157 CEQA Analysis • Impact 3.12-9: The proposed General Plan is consistent with adopted bicycle and pedestrian plans and supports enhancements that emphasize bicycle and pedestrian circulation.
Through the implementation of the mitigating General Plan Policies CI 1.2, CI 1.6, CI 1.9, CI
1.11, CI 1.12, CI 1.17, CI 1.19, CI 1.20, CI 1.21, CI 2.1-CI 2.13, CI 2.23, and CI 2.24, and Actions CI 1a, CI 1m, CI 1n, CI 1p – CI 1r, CI 2a – CI 2d, CI 2f – CI 2h, and CI 2l – CI 2o, implementation of the General Plan would have a less than significant impact. • The City of Cotati adopted the Findings of Fact and Statement of Overriding Considerations on March 24, 2015, including for the significant and unavoidable impacts identified for Transportation and Circulation (Impacts 3.12-1, 3.12-2, and 3.12-3). The City findings determined that despite the significant and unavoidable impact to transportation and circulation, no other project alternative would meet the City’s objective to realize the development potential of undeveloped lands for residential, office, and commercial uses necessary for housing opportunity and job growth.
Level of Service to Vehicle Miles Traveled (SB 743)
Level of service (LOS) has historically been used as a standard measure of traffic service. Pursuant to SB 743, as of July 1, 2020, lead agencies are required to evaluate transportation impacts of a project using a Vehicle Miles Traveled (VMT) metric, which focuses on balancing the needs of congestion management with statewide goals related to infill development, promotion of public health through increased active transportation facilitated by closer proximity to alternative travel modes and reduces greenhouse gas emissions.
In December 2018, the California Governor’s Office of Planning and Research (OPR) published the Technical Advisory on Evaluating Transportation Impacts in CEQA, which provides recommendations for evaluating a project’s transportation impact using a VMT metric, thresholds of significance, and mitigation measures. Pursuant to Government Code Section 15064.3(b), lead agencies have discretion to select the most appropriate methodology for evaluating a project’s VMT impacts.
On September 22, 2020, the City of Cotati adopted VMT guidelines for analysis of vehicle miles traveled. The guidelines identify criteria, situations, and thresholds to determine VMT impacts and their significance. The 202 VMT guidelines identified that the City of Cotati maintained a residential VMT per capita of 19.42. Based on data from the February 2022 update of the SCTA model, the City of Cotati has a baseline average residential VMT of 18.3 miles per capita. Applying the City guidelines, a residential project generating a VMT that is 15 percent or more below this value, or 15.5 miles per capita or less, would have a less-than-significant VMT impact. The SCTA model includes traffic analysis zones (TAZ) covering geographic areas throughout Sonoma County that are used to determine the baseline VMT. Projects which are within a half mile of an existing major transit stop or a stop along an existing high-quality transit corridor are determined not to have significant VMT impacts.
It should be noted that LOS is still used by the City for purposes of determining consistency with general plan but is no longer used for determining significant impacts under CEQA. Pursuant to CEQA Guidelines Section 15064.3, impact significance is based upon VMT. Consistency with General Plan goals and policies related to transportation, including adopted LOS policies, will be considered by the decision-makers as part of the project review process.
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Cotati Village Community Two Project Page 126 of 157 CEQA Analysis Public Transit
Bus service in Cotati is provided by Sonoma County Transit, Golden Gate Transit, and Paratransit.
Sonoma County Transit is the primary transit provider in Cotati; it provides regularly-scheduled fixedroute service to major activity centers and transit hubs within the City limits. Golden Gate Transit Routes 74, 80, and 101 serve Cotati with stops located at either the Hub or the St. Josephs Park and Ride. Paratransit, also known as dial-a-ride or door-to-door service, is available for those that are unable to independently use the transit system due to a physical or mental disability.
Bus stops in proximity to the site are located approximately 150 feet west of the Alder Avenue and SR-116 intersection, at the southern edge of the Alder Avenue and SR-116 intersection, and along SR116 approximately 600 feet and 820 feet east of the site.
Rail Service
Sonoma-Marin Area Rail Transit (SMART) offers passenger rail service in Sonoma and Marin counties.
SMART’s initial 43 miles of rail corridor includes 10 stations, from the Sonoma County Airport to Downtown San Rafael, and includes a station in Cotati. The full project will provide 70 miles of passenger rail service and a bicycle-pedestrian pathway.
Rail freight operation on the SMART rail corridor is overseen by the North Coast Railroad Authority.
Freight service currently operates between Lombard (located in Napa County where the North Coast Railroad Authority interfaces with the national rail system) and Petaluma. Several round-trip freight trains per week are expected to pass through Cotati as freight service expands.
The Cotati SMART station is located approximately 1.75 miles from the site.
Bike and Pedestrian Facilities
This Cotati Active Transportation Plan (ATP) was developed as a component of the Sonoma County Transportation Authority‘s (SCTA’s) 2024 Countywide Active Transportation Master Plan and updated in 2014. While part of the Master Plan, the City of Cotati plan is also a stand-alone document to be used by the City of Cotati to guide implementation of local projects and programs and document city policy. It is also designed to be a component of the SCTA Countywide Active Transportation Master Plan to improve coordination in realizing the countywide bicycle and pedestrian system.
The purposes of the SCTA Countywide Active Transportation Master Plan are to:
• Assess the needs of bicyclists and pedestrians throughout Sonoma County in order to identify a set of local and countywide improvements and implementation strategies that will encourage more people to walk and bicycle;
• Identify local and countywide systems of physical and programmatic improvements to support bicycling and walking;
• Provide local agencies that adopt the Plan with eligibility for various funding programs, including the State Bicycle Transportation Account (BTA) which is now part of the State’s Active Transportation Program;
• Act as a resource and coordinating document for local actions and regional projects; and • Foster cooperation between entities for planning purposes and to create Geographic Information System (GIS) maps and a database of existing and proposed facilities countywide.
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Cotati Village Community Two Project Page 127 of 157 CEQA Analysis City of Cotati Local Roadway Safety Plan (2021)
The City Council of Cotati adopted the Local Roadway Safety Plan (LRSP) on December 14, 2021. The plan serves as a framework to systematically identify and analyze transportation safety issues, collaborate with partner agencies and stakeholder, and develop a multidisciplinary toolbox of traffic safety countermeasures. It is also a blueprint for addressing traffic safety issues throughout the County across the 4 E's of traffic safety disciplines; Engineering, Education, Enforcement, & Emergency Services. The LRSP is divided into 3 core parts. The first is an assessment of historical collision trends and patterns. The second is identification of systemic Citywide collision patterns, not at any specific location, with a framework and toolbox for countering those collision patterns. The third is identification of the highest location specific collision patterns, with recommended countermeasures to reduce collisions. The City of Cotati adopted the updated LRSP on December 14, 2021.
Vision Zero Action Plan (2022)
Developed in collaboration with the City of Cotati, the Sonoma County Vision Zero Action Plan outlines practical, evidence-based steps to build a future for Sonoma County where roads are free of fatal and life-altering crashes. Vision Zero is a traffic safety philosophy that lays out a new set of principles for engineering roads, educating travelers, and creating a sense of collective responsibility.
The Sonoma County Transportation Authority (SCTA) and Sonoma County Department of Health Services (OHS) convened the Vision Zero Advisory Committee (VZAC) and set a target goal of zero traffic deaths and severe injuries on roadways within the County by 2030. The Vision Zero plan builds on the efforts of local jurisdictions, including the City of Cotati LRSP, and other agencies and identifies the additional strategies and resources required to meet Sonoma County's Vision Zero goal. It represents a commitment to specific Vision Zero actions that are organized into six high-level goals:
Create Safe Speeds, Eliminate Impaired Driving, Create a Culture of Safety, Build Safe Streets for All, Make Vehicles Safer and Reduce Private Vehicle Use, and Improve Data for Effective Decision Making.
The City of Cotati adopted the Vision Zero Plan in February 2023, and will incorporate program, maintenance, and infrastructure improvement actions to address identify challenges along the City’s High Injury Network (HIN).
Sonoma County Comprehensive Transportation Plan
Moving Forward 2050, Sonoma County’s Comprehensive Transportation Plan (CTP), is a 25-year plan that serves as the vision for transportation throughout Sonoma County, with goals for the transportation system and the well-being of the communities. Moving Forward 2050 establishes five goals: Deliver a seamless network that allows people to use a variety of transportation types easily, affordably and dependably; Provide safe and well-maintained transportation infrastructure; Implement place-based transportation projects, tailored to urban, suburban, and rural communities that will improve local mobility; Provide zero-emission transportation opportunities that meet diverse community needs, improve health and enhance quality of life.
Projects identified in Moving Forward 2050 relative to Cotati include: updating the US 101 and Railroad Avenue Interchange; widening and rehabilitation of SR-116 between US 101 and Stony Point Road and the addition of signalized intersections, new bike lanes, and new sidewalk to improve the vehicle LOS, improve the safety of SR-116 for all modes of transportation, and create safe new corridors for pedestrian and bicyclists; Bicycle and pedestrian upgrades (citywide); constructing sidewalks along 303 of 1220
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Cotati Village Community Two Project Page 128 of 157 CEQA Analysis west Cotati Avenue to close gaps; US 101/SR-116 north bound on-ramp improvements; Multimodal streetscape improvements joining all four legs of La Plaza Street around La Plaza Park; widening Old Redwood Highway for safer bike lanes, sidewalks, and center island medians; US 101/West Sierra Avenue south bound off-ramp improvements; and local street pavement rehabilitation from La Plaza to Gravenstein Highway.
Project Consistency with the 2013 General Plan EIR
5.17(a) (Conflicts with Plans, Policies, Ordinances) – No Substantial Change Relative to the General Plan FEIR
The Project’s Traffic Impact Study (TIS) was completed by W-Trans on July 23, 2024 (Appendix G). The study analyzed 126 multi-family housing units and a 2,250 square foot café with access from Alder Avenue via two driveways that will intersect with Alder Ave. on the northern and southern end of the development, forming a one-way loop through the Project from north to south. The southern driveway exiting the development includes a woonerf that is approximately 160 feet long and approximately 35 feet wide. The Project also includes a Class 1 multi-use path that will run the length of the project along SR-116 and that will connect with a Class 1 multi-use path east of Alder Avenue, approved as part of the Cotati Villages 1 Project. The Class 1 path will connect to an additional proposed Class I path that will extend north along the western development limits of the Project. The proposed network of pedestrian, bicycle, and vehicle facilities is consistent with the City’s General Plan Policy 1.19 which requires effective linkages to the surrounding circulation system.
The project will provide 206 parking spaces including the 44 existing spaces at the existing commercial development and the nine on-street parking spaces. Through the application of a Density Bonus Waiver in compliance with State Density Bonus Law (Government Code 65915), the proposed parking complies with the number of spaces required in the City’s Land Use Code Section 17.36.050 Number of Parking Spaces Required.
Level of Service
The proposed project is expected to generate an average of 1,180 net new trips per day, including 157 a.m. peak hour trips and 82 trips during the p.m. peak hour. The General Plan Circulation Element Policy CI 1.3 calls for a minimum level of service (LOS) standard of LOS D at intersections. The TIS analyzed traffic operations at the intersections of SR-116 and Alder Avenue, and the intersection of SR-116 at West Cotati Avenue to determine the level of service under the existing conditions, existing conditions plus project conditions, baseline (existing plus approved projects), baseline plus project, an alternative baseline and alternative baseline plus project, and future, and future plus project conditions at weekday morning peak hour and weekday afternoon peak hour traffic. The results of the LOS analysis are summarized in Table 5.17.1, Table 5.17.2, and Table 5.17.3 below.
Under existing conditions, with the addition of Project-generated traffic, the southbound Alder Avenue approach would be expected to operate unacceptably at LOS F. As this is below the LOS D which is the minimum standard in Policy CI 1.3, the analysis considered options to improve the level of service.
The installation of a southbound left-turn lane on Alder Avenue, which is a condition of the Cotati Village 1 project, as a stop sign controlled intersection, would result in an LOS E, which would not meet the standard. Additionally, signalization of the intersection of Alder Ave. and SR-116 was evaluated, and would result in LOS B, which would meet the minimum standard set by the General Plan, as shown in Table 5.10 below.
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Cotati Village Community Two Project Page 129 of 157 CEQA Analysis Table 5.10 Existing and Existing plus Project Peak Hour Intersection Levels of Service Existing Existing + Project
AM Peak PM Peak AM Peak PM Peak
Delay LOS Delay LOS Delay LOS Delay LOS
1. SR-116/Alder Ave
Southbound (Alder Ave) Approach
0.7 A 0.8 A 4.3 A 1.7 A
19.5 C 22.2 C 55.5 F 27.4 D
With Southbound Left Turn Lane - - - - 36.2 E - -
Traffic Signal (Overall Operation) - - - - 14.6 B - -
2. SR-116/W Cotati Ave
Northbound (W Cotati Ave)
Approach
0.5 A 0.9 A 0.5 A 0.9 A
18.1 C 17.7 C 19.15 C 18.3 C
Notes: Delay is measured in average seconds per vehicle; LOS = Level of Service; Results for minor approaches to two-way stop-controlled intersections are indicated in italics. Bold text= deficient operation, shaded cells indicated conditions with recommended improvements (as conditioned) Source: Transportation Impact Study, prepared by W-Trans, July 23, 2024 Similarly, under the baseline conditions which includes the approved Cotati Village Community (One) project, the proposed project would not operate at an acceptable LOS without the addition of the traffic signal, as presented in the Table below.
Table 5.11 Baseline and Baseline plus Project Peak Hour Intersection Levels of Service Baseline Baseline + Project
AM Peak PM Peak AM Peak PM Peak
Delay LOS Delay LOS Delay LOS Delay LOS
1. SR-116/Alder Ave
Southbound (Alder Ave) Approach
1.3 A 1.4 A 9.8 A 2.3 A
27.5 D 25.1 C 51.0 E 29.1 D
Traffic Signal (overall operation) - - - - 18.1 B 10.9 B
2. SR-116/W Cotati Ave
Northbound (W Cotati Ave)
Approach
0.5 A 0.9 A 0.5 A 0.9 A
18.6 C 18.3 C 19.9 C 18.7 C
Notes: Delay is measured in average seconds per vehicle; LOS = Level of Service; Results for minor approaches to two-way stop-controlled intersections are indicated in italics, shaded cells indicated conditions with recommended improvements (as conditioned)
Source: Transportation Impact Study, prepared by W-Trans, July 23, 2024 The General Plan indicates that at buildout, the intersection of SR-116/Alder Avenue will be eliminated and replaced with the SR-116/New North-South Street intersection to the west of the Project site. This new signalized intersection would include four legs with dedicated turn lanes on each leg, as well as separate right-turn lanes on the new street approaches. The planned future widening of SR-116 would provide two through lanes in each direction between Redwood Drive and Madrone Avenue.
While this is one scenario considered by the General Plan, it is foreseeable that the new north/south street may not be feasible and only the SR-116/West Cotati Avenue intersection would be realigned and signalized with protected left turns on SR-116 and split phasing on West Cotati Avenue. In this alternative baseline scenario, it is assumed that Alder Ave. would be a stop-controlled intersection 305 of 1220
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Cotati Village Community Two Project Page 130 of 157 CEQA Analysis with right-turn-in/right-turn-out only and the new Batchelor Lane (identified on plans for Cotati Village 1) would have a public access easement allowing through access to vehicles heading east to exit on Alder Ave. travel east on Batchelor Lane, and turn left at the new signalized intersection at West Cotati Ave and SR-116 (as proposed by the W. Cotati Ave. Realignment Project currently undergoing planning review). Table 5.17.3 shows the alternative baseline and alternative baseline plus project peak hour intersection levels of service which would operate at a C or better.
Table 5.12: Alternative Baseline plus Project Peak Hour Intersection LOS Alternative Baseline Alternative Baseline +
Project
AM Peak PM Peak AM Peak PM Peak
Delay LOS Delay LOS Delay LOS Delay LOS
1. SR-116/Alder Ave
Southbound (Alder Ave) Approach
0.5 A 0.4 A 1.0 A 0.6 A
9.5 A 13.5 B 10.1 B 14.3 B
2. SR-116/W Cotati Ave. 14.8 B 18.6 B 21.6 C 20.4 C
Under the Alternative Baseline + Project scenario, all intersections would operate at an acceptable Level of Service.
An analysis of the future conditions at the intersection at SR-116 and West Cotati Avenue was prepared by Fehr and Peers on June 4, 2024 for the State Route 116 Safety Improvement Project also known as the SR-116/W Cotati Ave. Realignment Project. The Fehr and Peers Analysis includes the traffic volumes that would be generated by Cotati Village 1 (approved), Cotati Village 2 (subject of this analysis), and Redwood Row (in planning process). It does not include the construction of the new North/South Street but does assume that Alder Ave. would have a left-turn lane for traffic turning from SR-116 onto Alder Ave. Under this scenario, left turns would be prohibited from Alder onto SR116. Table 5.13 shows the estimated Future Plus Project conditions for the SR-116/W. Cotati Ave intersection which includes the realignment of West Cotati Ave, construction of the signal, and construction of all three residential development projects.
Table 5.13: SR-116/W. Cotati Ave. Intersection Analysis by Fehr and Peers Future Future + Project
AM Peak PM Peak AM Peak PM Peak
Delay LOS Delay LOS Delay LOS Delay LOS
SR-116/W Cotati Ave 16.0 B 21.4 C 25.3 C 32.5 C
Source: State Route 116 Safety Improvement Project Memo prepared by Fehr and Peers on June 4, 2024.
As shown above, under the future plus project conditions for the SR-116/W. Cotati Realignment project and the buildout and operation of Cotati Village 1 (approved), Cotati Village 2 (subject of this analysis), and Redwood Row, the intersection of W. Cotati and SR-116 would operate at an acceptable level of service. While the baseline condition assumes that the intersection improvements at W. Cotati would already be in place prior to construction of Cotati Village 2, there is no set timeline for the improvements.
To ensure that the project does not result in an intersection with less than an LOS D, signalization will need to be completed at either the Alder Avenue/SR-116 intersection or at the new alignment of W. 306 of 1220
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Cotati Village Community Two Project Page 131 of 157 CEQA Analysis Cotati Ave/SR-116, along with the public access easement of Batchelor Lane prior to project occupancy. To ensure a coordinated approach that effectively manages Project generated traffic in compliance with the General Plan Policy to achieve LOS D or greater, COA TRA-1 has been established.
COA TRA-1 requires that the applicant provide the City with final plans for road improvements and signalization with a memo from a qualified traffic engineer demonstrating that the final improvement plans will result in a minimum LOS D.
Pedestrian & Bicycle Facilities
The Project proposes the construction of a Class I Multiuse Path serving bicyclists and pedestrians.
The facility provides a pedestrian and bicycle circulation extension from the existing sidewalks and bike lane on Alder Avenue. The Cotati Active Transportation Plan indicates that the portion of SR-116 in front of the Project site was planned for a Class II Bike lane, and the Project proposal for a Class I facility is an improvement that provides physical separation from vehicular traffic. In order to accommodate public improvements to SR-116, a 19-foot wide area has already been dedicated as Right of Way along the entire length of the project along SR-116.
The Project provides bicycle parking to meet minimum municipal code requirements. As required by Cotati Municipal Code Section 17.36.070, a ratio of one space per ten motor vehicle spaces is required for new development. The Project plans include 206 vehicle parking spaces and 43 bicycle parking spaces which exceed the required number of bicycle parking spaces.
Public Transit
Public transit within Cotati is provided through Sonoma County Transit. Bus route 26 runs between Mirabel Park to the west of the site and Sonoma State University to the east and stops at SR-116 and Alder Avenue approximately 150 feet west of the intersection. Currently, the bus stop is unimproved and not connected via pedestrian or bicycle facilities. As determined in the Traffic Impact Study, existing transit facilities serving the project site are not adequate due to the lack of pedestrian facilities connecting to the transit stop. Therefore, COA TRA-2 has been imposed, which requires that the applicant improve the bus stop located west of the SR-116 and Alder Ave. intersection to meet Sonoma County Transit Requirements and to ensure that the bus stop can be accessed from the multi-use pathway along the frontage. Depending on the future location of traffic signalization, the applicant may re-locate the bus stop to the east of the SR-116/Alder Avenue intersection.
State Highway Regulations
The California Department of Transportation (Caltrans) provided comments upon review of the project referral on March 8, 2024. The comments covered standards and the requirements that the Project would need to ensure compliance with State Highway Regulations. These included permit requirements for excessive load vehicles, permit requirements for work within the public Right of Way, and Caltrans facility requirements to meet American Disabilities Act (ADA) Standards after project completion. Caltrans also requires that the project maintain bicycle and pedestrian access during construction. COA TRA-3 has been imposed to require implementation.
As conditioned, the Project does not conflict with a program, plan, ordinance, or policy addressing the circulation system, public transit, roadway design, bicycle, and pedestrian facilities. Therefore, as conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 307 of 1220
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5.17(b) (Conflict with 15064.3(b) VMT) – No Change Relative to the General Plan EIR The Traffic Impact Study (Appendix G) for the Project analyzed the estimated Vehicle Miles Traveled (VMT) that would be introduced by the Project. The City uses the State of California Office of Planning and Research recommended VMT threshold of fifteen percent (15%) below the existing baseline city residential VMT per capita. Based on the Sonoma County Transportation Authority model, the baseline average residential VMT for Cotati is 18.3 miles per capita and 15 percent below this value provides a significance threshold of 15.5 miles per capita. The Project is located in Traffic Analysis Zone (TAZ) 425, which has a baseline VMT per capita of 20.2 miles. For the Project to be below the significance threshold of 15.5 per capita, VMT would need to be 23.2 percent lower than the average for the TAZ. As analyzed in the Traffic Impact Study, the Project proposes high density residential development, which is associated with lower VMT per capita compared to conventional single-family development and has a project-specific rate of 14.6 miles per capita.
City VMT guidelines indicate that a retail project under 10,000 square feet screens out from VMT analysis because this size of retail would not be likely to result in a net increase in regional total VMT.
The Project includes a 2,250 square foot cafe, which would have a negligible effect on the regional total VMT. Additionally, given the size and location of the spaces, it is expected that the cafe would be local-serving. The State Office of Planning and Research (OPR) guidance recommends screening localserving retail from VMT analysis since they introduce a greater mix of services into the urban fabric, resulting in improved proximity of retail to many residents and thereby resulting in shorter trips and a reduction in total VMT.
Therefore, the Project would not exceed VMT thresholds and will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.17 (c) (Geometric Design Feature Hazard) – No Substantial Change Relative to the General Plan EIR
The site is located west of Alder Avenue and north of SR-116. At present, there is no dedicated leftturn lane to reach Alder Ave from eastbound SR-116. The approved Cotati Village Community (One) project, located east of the Alder Ave./ SR-116 intersection, included the left-turn pocket from SR-116 onto Alder Ave. in the design plans. The TIS prepared for the Cotati Village 2 Project concluded that the left-turn pocket is warranted independent of the adjacent development (Cotati Village Community (One)). As such, COA TRA-4 has been imposed and requires the installation of a 50-foot-long left-turn pocket to accommodate traffic from the Project.
The project would create two new driveway connections into the project from Alder Avenue. Site distances at the two new intersections were analyzed using the approach travel speeds as the basis for determining the recommended site distance. Using traffic speeds measured at the proposed entrance, Alder Ave. was determined to have an 85th percentile speed of 29 miles per hour in both directions. For the purposes of the analysis, 30 mph was used. Each access would need a site distance of 290 feet to the north of the new intersections and 330 feet to the south of each new intersection for the driver to complete a left turn. As shown in Table 5.14, the northern intersection/driveway has a site distance of 335 feet to the north and 445 feet to the south. At the southern driveway/intersection, the site distances are approximately 385 feet to the north and 350 feet to the 308 of 1220
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Table 5.14 Sight Distances at Proposed Intersections
Location
Site Distance
North (ft) South (ft)
Site Distance needed @ 30 mph 290 330
Proposed northern intersection/driveway @ Alder Ave. 335 445 Proposed southern intersection/driveway @ Alder Ave. 385 350 Source: Traffic Impact Analysis prepared by W-Trans on July 23, 2024 To ensure that sight distances shall be maintained, COA TRA-5 has been imposed to keep sight lines free of obstructions such as signs, structures, and tall landscaping. As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.17(d) Emergency Access – No Substantial Change Relative to the General Plan EIR The Project site’s primary access for emergency vehicles would be from Alder Avenue via the new Woonerf and driveway/private road, which range between 20-26 feet wide. The internal driveways and frontage improvements would be built to City and Caltrans standards as applicable. The site layout has been reviewed by the City’s Engineering Division and the Rancho Adobe Fire Protection District (RAFD), which provides fire protection services to the City, for evaluation of preliminary design with regards to design standards and adequate emergency access. The standard review process of approval which is required by the RAFD includes uniformly applied requirements for emergency access.
Additionally, through the implementation of conditions, the Project will only have minor increases in delay resulting from traffic from the Project. As required by the City of Cotati Municipal Code, all signals are required to have signal pre-emption which allows appropriately equipped emergency vehicles to flip the signal to green to provide safer access through intersections. Therefore, as conditioned, the project would not result in a new significant impact or substantially increase the severity of a previously identified significant impact to emergency access relative to the 2013 General Plan EIR.
2013 General Plan EIR Mitigating Policies and Actions
Policy CI 1.3: Establish a minimum motor vehicle Level of Service (LOS) standard of LOS D at intersections. The following shall be taken into consideration in applying LOS standards: (see General Plan Page 2-5 for full list of considerations)
Status: In order to ensure LOS D or better at study area intersections, signalization is required and may be accommodated at either Alder Ave or the new alignment of West Cotati Avenue with SR-116.
To ensure the project achieves LOS D or greater, COA TRA-1 has been established to require that the applicant provide final improvement plans with a memo prepared by a transportation engineering 309 of 1220
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Cotati Village Community Two Project Page 134 of 157 CEQA Analysis demonstrating that both the Alder Ave. and W. Cotati Ave. intersections with SR-116 operate at an LOS D or better. As conditioned, the project is consistent with this policy.
Policy CI 1.18: Intersections shall be designed to provide adequate and safe access for all users including pedestrians, bicyclists, and motorists of all ages and abilities.
Status: The proposed Project will include the development of sidewalks, pathways, and a Class I Multiuse Path that would serve pedestrians and bicyclists and connect to the existing facilities. As conditioned by COA TRA-5, the Project will maintain clear sight lines, which ensures safe access. As such, the Project is consistent with this policy because it will provide adequate and safe access for all users.
Policy CI 1.20: Require new development to contribute its fair share cost of circulation improvements necessary to address cumulative transportation impacts on roadways throughout the City as well as the bicycle and pedestrian network.
Action CI 1e: As part of the development review and planning process, review general plan amendments, zone change requests, specific plans, and development projects to ensure that adequate circulation improvements are included, that the project addresses its proportional share of impacts to the City’s circulation network, and that the project provides for complete streets to the extent feasible.
Action CI 1r: As part of the development review process, ensure that new development facilitates walking, biking, and transit modes; incorporates streets that are designed to maintain safe and efficient traffic flow; constructs or (if deemed appropriate by the City Engineer) contributes funds toward construction of off-site improvements necessary to mitigate traffic impacts; provides adequate emergency vehicle access; and pays development impact fees that contribute to cumulative circulation improvements.
Status: The Project is subject to payment of City development impact fees as a new development project. Impacts fees, as required by Municipal Code Chapter 4.10 Traffic Impact Fee, contribute fair share costs to circulation improvements for the Project’s proportional share of impacts to the City’s circulation network. The traffic impact fees are calculated and required through the uniformly applied building permit review process. As such, the project is consistent with these policies.
Action CI 1l: Require developers to design local roadways (i.e., streets other than arterials and collectors) for speeds of 25 miles per hour or less.
Status: The construction of streets within the site would be required to comply with the uniformly applied standards in Municipal Code Section 17.26.030 Street and streetscape standards. Section E requires a maximum speed limit of 20 miles per hour. Through the application of this standard, the Project is consistent with this policy.
Action CI 1q: As part of the development review process, require new development to mitigate circulation impacts by making improvements to the motorized and non-motorized circulation networks as necessary, and in a fair manner with an established nexus between the level of impact and required improvements and/or contributions.
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Cotati Village Community Two Project Page 135 of 157 CEQA Analysis Status: The Project design and COA TRA-1 through TRA-5 ensure that the project will not have circulation impacts that result from the project. As conditioned, the Project is consistent with this policy.
Conclusion and Environmental Conditions of Approval
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to transportation relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The following environmental conditions of approval are required to implement the 2013 General Plan EIR mitigating policies and actions:
COA TRA-1: The Applicant shall provide public improvement plans to the City for review and acceptance prior to issuance of a grading permit. The final plans shall include signalization at either the intersection of Alder Avenue/SR-116 or the signalization of W. Cotati Ave/SR-116. If no signal is installed at Alder Avenue, final improvement plans shall include a physical barrier designed in compliance with Caltrans Highway Design Manual to prevent left turns from Alder Avenue onto SR116 and shall also include a public access easement to allow vehicles to use Batchelor Lane (through Cotati Village 1). A memo from the Project’s traffic engineer confirming that the final plans are designed to achieve intersection operation at Level of Service D or greater. The final plans shall be reviewed and accepted by the City’s Engineer prior to issuance of a grading permit and shall be fully installed prior to issuance of a certificate of occupancy for the project.
COA TRA-2: The applicant shall improve the bus stop located west of the SR-116 and Alder Ave. intersection to meet Sonoma County Transit Requirements and shall include a shelter, a bench, and ADA access to the proposed multi-use pathway along SR-116 as well as any other elements required by Sonoma County Transit Authority. The bus stop may be relocated east of Alder Avenue if a signal is installed at W. Cotati/SR-116 intersection and not at the Alder Avenue/SR-116 intersection.
COA TRA-3: The Project shall comply with all requirements from Caltrans to address design, engineering, and operation requirements within the State right-of-way. Prior to commencing any work in the public right of way, the applicant shall secure an encroachment permit from Caltrans and provide the following to Caltrans:
1. Detailed information regarding any connections and or modifications to State drainage systems must be provided.
2. Any engineering calculations for onsite systems out-letting to State drainage systems (pipe or ditch) must be provided, such as flow rates for shed areas, detention time for detention basins, etc. If additional runoff is generated from the site and drains towards SR-116, the runoff must be metered to pre-construction levels.
The applicant shall provide a copy of the approved encroachment permit to the City prior to commencing work within the public right of way. If Project work requires the movement of oversized or excessive load vehicles on State roadways, the Applicant shall secure a transportation permit from Caltrans and provide a copy to the City.
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Cotati Village Community Two Project Page 136 of 157 CEQA Analysis COA TRA-4: The Applicant shall install a 50-foot-long left-turn pocket on SR-116 at the eastbound approach to Alder Avenue, or as otherwise approved by the City Engineer. If signalized, the southbound Alder Avenue approach to SR-116 shall be restriped to include a separate left-turn lane.
The left-turn lane and restriping plan shall be submitted to the City Engineer for review and approval prior to building permit issuance. All required approvals shall be obtained from Caltrans and submitted to the City.
COA TRA-5: Final landscaping plans shall be submitted and show compliance with Cotati Municipal Code (CMC) Section 17.30.040(c)(2). Final landscaping plans shall include the specific plants that will be placed in the traffic safety visibility area (see CMC Section 17.30.040.E) and their maximum projected height which shall be no taller than 36 inches except for trees with their canopy trimmed to a minimum of eight feet above grade. These standards shall be applied to access drive from Alder Avenue, as well as the intersections of the multi-use path and Alder Avenue. 312 of 1220
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5.18. TRIBAL CULTURAL RESOURCES
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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 the
lead agency, in its discretion and
supported by substantial
evidence, to be significant
pursuant to criteria set forth in
subdivision I of Public Resources
Code Section 5024.1. In applying
the criteria set forth in
subdivision I of Public Resource
Code Section 5024.1, the lead
agency shall consider the
significance of the resource to a
California Native American tribe.
Source: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; Cultural Resources Study, prepared by Tom Origer & Associates on June 23, 2016; Cultural Resources Addendum prepared by Evans and De Shazo on May 31, 2024; and AB52 Project Notification dated September 7, 2023.
According to Public Resources Code (PRC) Section 21074, tribal cultural resources are defined as follows:
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1. Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
a. Included or determined to be eligible for inclusion in the California Register of Historical Resources; or
b. Included in a local register of historical resources as defined in PRC Section 5020.1(k).
2. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in PRC Section 5024.1I. In applying the criteria set forth in PRC Section 5024.1I, the lead agency shall consider the significance of the resource to a California Native American tribe.
3. A cultural landscape that meets the criteria of PRC Section 21074(a) to the extent that the landscape is geographically defined in terms of the size and scope of the landscape.
4. A historical resource described in PRC Section 21084.1, a unique archaeological resource as defined in PRC Section 21083.2(g), or a “non-unique archaeological resource” as defined in PRC Section 21083.2(h), if it conforms with the criteria of PRC Section 21074(a). 2013 General Plan EIR Findings
As stated in Section 3.4 Cultural Resources, the 2013 General Plan EIR determined that General Plan implementation could result in a substantial adverse change in the significance of an historical or archaeological resource, including tribal cultural resources. Through the implementation of mitigating General Plan Policies CON 4.1, CON 4.3 – CON 4.6, and mitigating actions CON 4a – CON 4c, and CON 4f, implementation of the General Plan would have a less than significant impact.
Additionally, implementation of the General Plan could result in the disturbance of human remains.
Through the implementation of General Plan Policies CON 4.2 and Action CON 4c and compliance with the provisions of California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98, the implementation of the General Plan would have a less than significant impact.
Project Consistency with the 2013 General Plan EIR
5.8(a.i-ii) (Listed or Eligible for Listing, Significant Tribal Resources) – No Substantial Change Relative to the General Plan EIR
In accordance with PRC Section 21080.3.1(d), the City of Cotati provided written formal notification to the FIGR on August 8, 2023, which included a brief description of the proposed project and its location, the City of Cotati’s contact information, and a notification that the Federated Indians of Graton Rancheria has 30 days to request consultation pursuant to this section. The City of Cotati received a response requesting consultation under PRC Section 21080.3.1(b)(2) from the FIGR on September 7, 2023. The City of Cotati entered into consultation with FIGR and provided requested information on October 5, 2023. Subsequent correspondence resulted in a request from the Tribe to review the CEQA Analysis, which was provided to the Tribe on June 10, 2024. No response was received.
The Cultural Resources Inventory prepared for the Project site determined that no significant or potentially significant cultural resources will be impacted by development (Appendix D Confidential).
No evidence of cultural resources was observed on site during the surface inspection. Due to past grading activities the original surface is no longer extant and any subtle cultural features that 314 of 1220
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Cotati Village Community Two Project Page 139 of 157 CEQA Analysis may have been present would have been removed. Although unlikely, the potential exists for unknown, buried cultural resources to be discovered during development. COA CUL-1, establishes procedures to be implemented in the event that significant archaeological and historic resources, including tribal resources, are discovered during construction. Due to the former presence of a pre-1920 residence, the site has the potential to contain historic era resources, and COA CUL-2 is imposed, which requires an Archaeological Monitoring Plan (AMP). As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
Policy CON 4.3: Work with Native American representatives to identify and appropriately address, through avoidance or mitigation, impacts to Native American cultural resources and sacred sites during the development review process.
Policy CON 4.4: Consistent with State local and tribal intergovernmental consultation requirements such as SB18, the City shall consult with Native American tribes that may be interested in proposed new development and land use policy changes.
Action CON 4a: Work with the Federated Indians of the Graton Rancheria to prepare a narrative description of the Native American background of the Cotati area and request the Federated Indians of the Graton Rancheria provide pictorial examples of the types of Native American resources present in the vicinity. Place this description on the City’s website as a link under the History of Cotati section.
Status: In accordance with PRC Section 21080.3.1(d), the City of Cotati provided written formal notification to the FIGR on August 8, 2023, which included a brief description of the proposed project and its location, the City of Cotati’s contact information, and a notification that the Federated Indians of Graton Rancheria has 30 days to request consultation pursuant to this section. The City of Cotati received a response requesting consultation under PRC Section 21080.3.1(b)(2) from the FIGR on September 7, 2023. The City of Cotati entered into consultation with FIGR and provided requested information on October 5, 2023. Subsequent correspondence resulted in a request from the Tribe to review the CEQA Analysis, which was provided to the Tribe in June 2024 and no response was received.
Action CON 4c: Require all development, infrastructure, and other ground--‐disturbing projects to comply with the following conditions in the event of an inadvertent discovery of cultural resources or human remains: (see Cultural Resources for full list)
Status: COA CUL-1 requires the implementation of the required protocol in Action CON 4c. As such, the Project complies with this policy.
Conclusion
The Project is within the scope of development projected under the General Plan and would not result in any substantial new or more severe impacts to recreation relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR.
COA CUL-1 and COA CUL-2 (see Cultural Resources section) are required to implement the 2013 General Plan EIR mitigating policies and actions.
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5.19. UTILITIES AND SERVICE SYSTEMS
Would The Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) 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?
b) Have sufficient water supplies available
to serve the project and reasonably
foreseeable future development during
normal, dry, and multiple dry years?
c) Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments?
d) 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?
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
Source: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; City of Cotati Municipal Code; Sonoma County Water Agency 2020 Urban Water Management Plan, prepared by Brown and Caldwell, June 2021; Water and Wastewater Assessment Report prepared by Carollo on September 2023; and City of Cotati Public Works Conditions of Approval prepared February, 2024.
2013 General Plan EIR Findings
The 2013 General Plan EIR evaluated potential impacts to Utilities and Service Systems in Chapter 3.13 and determined the following:
• Impact 3.13-1: General Plan implementation has the potential to result in an increased 316 of 1220
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Cotati Village Community Two Project Page 141 of 157 CEQA Analysis demand for water supplies. However, through implementation of mitigating General Plan Policies CSF 1.1-1.6, CSF 2.1- CSF 2.1 and Actions CSF 1a, CSF 1b, CSF 2b- CSF 2g, implementation of the General Plan would have a less than significant impact. • Impact 3.13-2: General Plan implementation would not result in the construction of a new water treatment facility or expansion of existing facilities, which could cause significant environmental effects because the projected 2035 water supplies are adequate to meet demand that would be generated by buildout of the 2013 General Plan. • Impact 3.13-3: General Plan implementation has the potential to exceed wastewater capacity or the requirements of the RWQCB. Upon full buildout of the 2013 General Plan within the City limits, total ADWF is projected to be 0.74 mgd. Within the entire Planning Area, the ADWF would be 0.83 mgd upon full buildout of the General Plan. These ADWF projections exceed the projections used in the 2011 Sewer Collection System Master Plan.
Even with mitigating General Plan Policies CSF 1.1-CSF 1.6 and CSF 2.16 – CSF2.27 and Actions CSF 1a, CSF 1b, CSF 2h-2n, implementation of the General Plan would result in a cumulatively considerable significant and unavoidable impacts. • Impact 3.13-4: General Plan implementation has the potential to require or result in the construction of new wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. Through the implementation of mitigating Policies CSF 2.20, CSF 2.22, and CSF 2.24 implementation of the 2013 General Plan would have a less than significant impact. • Impact 3.13-5: General Plan implementation would be served by a landfill for solid waste disposal needs and will require compliance with various laws and regulations. Through implementation of the mitigating General Plan Policies CSF 3.1-CSF 3.8 and Actions CSF 3aCSF 3e, implementation of the 2013 General Plan would have a less than significant impact. • The City of Cotati adopted the Findings of Fact and Statement of Overriding Considerations on March 24, 2015, including for the significant and unavoidable impacts identified for utilities and service systems (Impact 3.13-3). The City findings determined that despite the significant and unavoidable impact to utilities and service systems, no other project alternative would meet the City’s objective to realize the development potential of undeveloped lands for residential, office, and commercial uses necessary for housing opportunity and job growth.
Project Consistency with the 2013 General Plan EIR
5.19(a) (Relocation or Expansion of Utilities) – No Change Relative to the General Plan EIR The Project is not anticipated to induce substantial growth in the area, either directly or indirectly, beyond what has been anticipated by the General Plan. The increase in residents, introduced by the 317 of 1220
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Cotati Village Community Two Project Page 142 of 157 CEQA Analysis proposed project, will incrementally increase the demand for water supplies, wastewater treatment, and solid waste disposal.
The Project site is located within City limits and is currently served by existing utilities and service systems. New service connections will be required to tie into the existing facilities, which are located on SR-116 and Alder Avenue. The City of Cotati’s Engineer has confirmed in the February 29, 2024 letter that the Project can be served by the City’s water distribution system and wastewater conveyance system and that there is sufficient water, wastewater, and off-site water supply for domestic and fire suppression purposes, which will be furnished on demand without exception to each lot/unit. Demand for utilities and service systems generated by the Project is anticipated by the 2013 General Plan EIR and does not require the relocation or expansion of infrastructure.
Therefore, the Project will not result in the relocation, construction, or expansion of utilities, and as such will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.19(b) (Sufficient Water Supplies) – No Substantial Change Relative to the General Plan EIR The Project would generate water demand consistent with the buildout projections of the General Plan. The City of Cotati receives potable water supplies through a contract with Sonoma Water, the regional wholesale water provider. Water supplies provided by Sonoma Water are sourced principally from the Russian River to eight water contractors, other water transmission system customers, and to the Marin Municipal Water District (Marin Water). Sonoma Water prepared an Urban Water Management Plan (Plan) in 2020 that addresses the water transmission system and includes a description of the water supply sources, historical and projected water use, and a comparison of water supply to water demands during normal, single-dry, and multiple-dry years.
The Sonoma Water UWMP anticipates that 592 acre feet of potable water supplies were provided to the City of Cotati in 2020 and that deliveries to Cotati will increase to 1,215 acre feet per year by 2045.
The Sonoma Water UWMP concludes that that potable water demand for all users, including the City of Cotati, is within the available supply, during normal water years for cumulative demand through 2045. Sonoma Water has adequate water supplies through the 2045 planning horizon, except for single-dry years, starting after 2025. During single dry years Sonoma Water works with all wholesale customers to reduce water usage in accordance with the Water Shortage Contingency Plan set forth in the UWMP.
The City of Cotati Municipal Code Chapter 13.30 Water Shortage Contingency Plan contains provisions for water conservation during water shortages. Through the implementation of these actions, the City reduces water usage during drought years to ensure sufficient resources to adequately serve all customers in accordance with the requirements of the UWMP.
At the project-level, a Water and Wastewater Assessment Report was prepared that anticipated the water demand generated by the project to be approximately 21,645 gallons per day (gpd) for Average Day Demand, 51,947 gpd for Maximum Day Demand, and 77,921 gpd for Peak Hour Demand. The City Engineer has reviewed the Project plans and assessment report and determined that the anticipated water demand for the Project can be met by existing and planned water resources, along with all other existing and planned water demands. The final plans and assessment report are required to be submitted to the City Engineer prior to issuance of a building permit in accordance with COA UTI-1.
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Cotati Village Community Two Project Page 143 of 157 CEQA Analysis Further, the Project is required to incorporate water efficient development standards consistent with all applicable State and Cotati municipal code requirements. The Project is required to adhere to the Water Conservation Ordinance contained in Chapter 13.30 of the City of Cotati Municipal Code.
Additionally, the Project is subject to Municipal Code Chapter 17.34, which requires compliance with standard water efficient landscaping standards. COA UTI-2 requires that final plans showing incorporation of water efficiency requirements be submitted and confirmed prior to building permit issuance.
Further, to ensure that the Project contributes its fair share toward necessary water infrastructure and supply COA UTI-3 has been imposed and requires the applicant to execute a City standard Public Improvement Agreement to address the proposed public improvements. The agreement shall address design, construction, and dedication of and City acceptance of the public improvements. COA UTI-3 also requires also requires that the site be annexed into the Community Facilities District (CFD).
As conditioned, the water supplies are sufficient to meet existing water demands of the Project and other existing and planned future water users during normal, single, and multiple dry year scenarios and the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.19(c) (Wastewater Capacity) – No Substantial Change Relative to the General Plan EIR The 2013 General Plan EIR concluded that even with implementation of the policies and action items in the General Plan, an increase in permitted capacity at the Laguna Wastewater Treatment Plant cannot be guaranteed, and impacts were considered cumulatively considerable, and significant and unavoidable. As part of the development review process, the City Engineer of the City of Cotati will determine adequacy and compliance of the Project with the City’s sewer system requirements and compliance with the City of Cotati Sewer Collection System Master Plan, Urban Water Management Plan, and Water Distribution System Master Plan. A Water and Wastewater Assessment Report was prepared for the Project that anticipated the wastewater generation to be approximately 18,282 gallons per day (gpd) for Average Dry Weather Flow, 27,789 gpd for Peak Dry Weather Flow, and 33,409 gpd for Peak Wet Weather Flow.
The City Engineer has reviewed the Project plans and Assessment Report and determined that the anticipated wastewater generation from the Project can be met by wastewater infrastructure. The final plans and Assessment Report are required to be submitted to the City Engineer to confirm wastewater generation of final plans can be met by utilities prior to permit issuance under condition of approval COA UTI-1.
As conditioned, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR.
5.19(d-e) (Solid Waste Generation and Compliance with Solid Waste Management) – No Change Relative to the General Plan EIR
The 2013 General Plan EIR concluded that General Plan implementation would be served by a landfill for solid waste disposal needs and will require compliance with various laws and regulations, and the impact would be considered a less than significant impact.
During construction, the Project would generate solid waste from concrete and asphalt from the removal of existing improvements and vegetation waste from tree removal. The applicant will be 319 of 1220
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Cotati Village Community Two Project Page 144 of 157 CEQA Analysis required to recycle or salvage at least 65 percent of nonhazardous construction and demolition waste and prepare a Construction Waste Management Plan that documents the diversion of materials as required by CalGreen.10 The Project will be required to comply with Cotati Municipal Code Section
17.39.030.G(5), which requires coordination with refuse pickup providers to determine the adequate size and number of containers required to accommodate all waste streams (landfill, recycling, and composting). Therefore, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
Policy CSF 1.1: Require all development projects to demonstrate, to the satisfaction of the City Engineer, that the City’s public services and utilities can accommodate the increased demand for services associated with the project.
Status: As part of the development review process, the City Engineer has reviewed the Project, including the Water and Wastewater Assessment Report. The City’s Engineer determined that the City’s facilities are adequate to serve the Project. As such, the Project is consistent with this policy.
Policy CSF 1.2: Require new development to offset or mitigate impacts to public services and facilities to ensure that service levels for existing users are not degraded or impaired by new development, to the satisfaction of the City Engineer.
Status: Through the building permit review process, the Project Applicant will be required to pay water and sewer connection fees that are intended to cover the maintenance and incremental expansion of facilities as planned to accommodate buildout of the General Plan. Through implementation of the uniformly applied development standards in the Municipal Code, the Project is consistent with this policy.
Policy CSF 1.3: Limit approvals of new development to areas where adequate infrastructure and services are available or will be provided by the development.
Status: The Project site is located within City limits and is currently well served by existing utilities and service systems. New service connections will be required that tie into the existing facilities, which are located along Alder Avenue and SR-116. The connection of new services is anticipated by the General Plan and does not require substantial infrastructure improvements or enhancements to adequately serve the Project. As such the Project is consistent with this policy.
Policy CSF 1.6: Require development, infrastructure, and long-term planning projects to be consistent with all applicable City plans and programs related to public services and facilities, including but not limited to the Water Master Plan, the Sanitary Sewer Master Plan and the Capital Improvement Plan.
New projects shall assist with the implementation of these plans through the provision of fair-share payments, construction of improvements, or other means identified as appropriate by the City Engineer.
10 California Green Building Standards Code (2022), Effective January 1, 2023. 320 of 1220
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Cotati Village Community Two Project Page 145 of 157 CEQA Analysis Status: Prior to issuance of a building permit, the applicant is required to pay development impact fees for incremental increase in demand for public services and facilities, as well as comply with all Public Works/Engineering’s Conditions of Approval. Therefore, the project is consistent with this policy.
Policy CSF 2.2: Prior to the approval of development, infrastructure, Specific Plans, or other projects that would result in increased demand for public water production, conveyance, treatment or storage, project proponents must demonstrate proof of adequate water supply (e.g., that existing services are adequate to accommodate the increased demand, or improvements to the capacity of the system to meet increased demand will be made prior to project implementation) and that potential cumulative impacts to water users and the environment will be addressed.
Action CSF 2a: As part of the development review process, determine the potential impacts of development and infrastructure projects on the water system and ensure that new development contributes its fair share toward necessary water infrastructure and supply. The Planning Department and the City Engineer shall be responsible for ensuring that the assessments are made.
Status: The City Engineer has determined that the Project will adequately connect to and comply with the City’s sewer system requirements and compliance with the City of Cotati Sewer Collection System Master Plan, Urban Water Management Plan, and Water Distribution System Master Plan.
Additionally, the City requires that the Project enter into a Public Improvement Agreement (PIA). The City also requires that the site be annexed into the Community Facilities District (CFD) and COA UTI-3 is required. As conditioned, the Project complies with this policy and action.
Policy CSF 3.8: Require new or significantly remodeled residential and all non-residential development to incorporate sufficient, attractive, and convenient interior and exterior storage areas for recyclables and green waste.
Status: The Project site plan identifies two trash enclosures on site that are separate from the buildings. Exterior storage areas for waste would be composed of durable materials, including splitfaced CMU block and a metal covering, and would be located in the parking area next to tree-lined landscaping strips. As such, the Project design is consistent with this policy.
Conclusion and Environmental Conditions of Approval:
COA UTI-1: The final plans and a final Water and Wastewater Assessment Report shall be submitted by the Applicant and reviewed/accepted by the City Engineer to confirm water demand and wastewater generation of final project design can be met by utilities prior to permit issuance.
COA UTI-2: The applicant shall submit landscape and irrigation plans for plantings at the time of the Improvement Plan submittal package. All landscaping and irrigation shall comply with the City Water Efficient Landscape Ordinance (WELO) and is subject to review and approval by the City Engineer. Prior to issuance of a certificate of occupancy, all plantings and irrigation systems in the approved final landscaping plan shall be completed.
COA UTI -3: The applicant shall execute a City standard Public Improvement Agreement to address the proposed public improvements. The agreement shall address design, construction, dedication of, 321 of 1220
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The agreement shall also address the ownership, maintenance, lighting, parking, access and shall be recorded against the lands of the project. The site shall be annexed into the Community Facilities District.
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5.20. WILDFIRE
If located in or near state
responsibility areas or lands classified
as very high fire hazard severity
zones, would the Project:
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) Substantially impair an adopted
emergency response plan or
emergency evacuation plan?
b) Due to slope, prevailing winds,
and other factors, exacerbate
wildfire risks, and thereby expose
project occupants to pollutant
concentrations from a wildfire or
the uncontrolled spread of a
wildfire?
c) Require the installation or
maintenance of associated
infrastructure (such as 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?
d) 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?
Source: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; State Responsibility Area Fire Hazard Severity Zones April 1, 2024; State Responsibility Area Fire Hazard Severity Zones November 2007; Local Responsibility Area Fire Hazard Severity Zones November 2008; and Memorandum from Rancho Adobe Fire Protection District prepared on February 14, 2024.
2013 General Plan EIR Findings
The 2013 General Plan EIR addressed impacts related to wildfire hazards in Chapter 3.7 – Hazards.
The following impact related to wildfires was considered under the 2013 General Plan EIR:
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Cotati Village Community Two Project Page 148 of 157 CEQA Analysis • Impact 3.7-6: The General Plan does not have the potential to 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. Through the implementation of mitigating General Plan Policies CSF 2.28-CSG 2.32, CSF 2.36, and SA 1.1 - SA 1.7 and Actions CSF 2o, CSF 2p, CSF SA 1a, and SA 1d, implementation of the 2013 General Plan would have a less than significant impact.
Mitigating policies and actions provided in the General Plan are included in the 2013 General Plan EIR to ensure public facilities are able to respond to wildfire emergencies, effective coordination between fire districts, and maintenance of emergency response facilities and infrastructure. Individual projects are directed to be reviewed by the City and the Rancho Adobe Fire Protection District for code compliance. The California Department of Forestry and Fire Protection (CalFire) has identified the site as being located outside of a State Responsibility Area (SRA) and Local Responsibility Area (LRA) Fire Hazard Severity Zone.
In October 2017, the Tubbs Fire (Central LNU Complex) burned approximately 36,807 acres in Sonoma County. Residents were exposed to direct effects of the wildfire, such as the loss of structures, and to the secondary effects of the wildfire, such as smoke and air pollution. Smoke generated by wildfire consists of visible and invisible emissions that contain particulate matter (soot, tar, water vapor, and minerals) and gases (carbon monoxide, carbon dioxide, nitrogen oxides). Public health impacts associated with wildfire include difficulty in breathing, odor, and reduced visibility.
SONOMA COUNTY HAZARD MITIGATION PLAN
On September 28, 2021, the Cotati City Council adopted the Sonoma County Multijurisdictional Hazard Mitigation Plan (HMGP) to guide pre- and post-disaster mitigation of identified hazards. The plan includes actions to mitigate current risk from hazards and changes in hazard impacts resulting from climate change, including wildfires. The plan includes Best Management Practices to Mitigate the Wildfire Hazard. These practices include what are called “personal scale” alternatives such as:
• Clear overgrown underbrush and diseased trees;
• Create and maintain defensible space around structures; • Regular mowing/landscape maintenance;
• Use of fire-resistant building materials;
• Employ techniques from the Firewise USA Program; and
• Installing or replacing roofing with non-combustible materials.
Sonoma County Community Wildfire Protection Plan
In June 2023, the County Community Wildfire Protection Plan (CWPP) was incorporated by reference into the Sonoma County Annex of the Multi-Jurisdiction Hazard Mitigation Plan (MJHMP). Part of this plan includes the Sonoma County Wildfire Risk Index (WRI). Published on November 17, 2022, the WRI predicts relative wildfire risk. The Wildfire Risk Analysis divides the county's landmass into 100-acre hexagons which are assigned a risk level. While each hexagon is assigned an overall risk level, conditions may vary significantly within the shape. It is entirely possible that areas of relatively low risk could exist within a polygon whose overall risk is high. The purpose of the CWPP and WRI is to inform planning to improve wildfire resiliency.
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5.20(a-d) (Impair Emergency Plans, Exacerbate Wildfire Risks, Infrastructure Contribution to Risks, Exposure to Wildfire-Related Risks) – No Change Relative to the General Plan EIR The Project is consistent with the allowable uses under the land use designations in the General Plan.
As such, the Project would not conflict with an emergency plan in that the General Plan accounts for the impacts of the planned development under the 2013 General Plan EIR. The Project site is not located in the VHFHSZ as provided by CalFire and is not within a watercourse or significant slope that may become unstable following a wildfire. Additionally, the Project falls under the jurisdiction of the Rancho Adobe Fire Protection District who implements the fire resiliency requirements in the Sonoma County Multijurisdictional Hazard Mitigation Plan. The project has undergone initial review by RAFD and plans have been determined to be adequate with standard conditions applied to all projects.
Therefore, the Project would not conflict with an emergency plan, interfere with emergency access, or otherwise exacerbate wildfire risk. Through the application of uniformly applied standards in the building and fire codes, the Project will not result in a new significant impact or substantially increase the severity of a previously identified significant impact relative to the 2013 General Plan EIR. 2013 General Plan EIR Mitigating Policies and Actions
Policy CSF 2.30: Design and maintain City streets in such a way so as to maintain acceptable emergency vehicle response times.
Action CSF 2p: As part of the development review process for new projects, the City will continue to refer applications to the Rancho Adobe Fire Protection District for determination of the project’s potential impacts on fire protection services. Requirements will be added as Conditions of Approval to project’s approving resolutions.
Action CSF 2o: Continue to enforce the California Building Code and the California Fire Code to ensure that all construction implements fire-safe techniques, including fire resistant materials, where required.
Status: The project was reviewed and conditioned by the Rancho Adobe Fire Protection District on February 14, 2024 to ensure compliance with uniformly applied standards for fire safety and emergency vehicle access. The final Project plans will be reviewed by Rancho Adobe Fire Protection District for review and approval. Construction plans will be routed to the District for confirmation that final design meets emergency access requirements. Through the implementation of uniformly applied development standards, the Project is consistent with this policy and associated actions.
Conclusion
The Project is within the scope of development projected under the General Plan and through the application of uniformly applied standards would not result in any substantial new or more severe impacts to wildfire relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. No Conditions of Approval are required beyond compliance with uniformly applied development standards and applicable local and state regulations.
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5.21. MANDATORY FINDINGS OF SIGNIFICANCE
New
Significant
Impact
Relative to
General
Plan EIR
More
Severe
Impact
Relative to
General
Plan EIR
No
Substantial
Change
Relative to
General
Plan EIR
No Change
Relative to
General
Plan EIR
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause
a fish or wildlife population to drop below
self-sustaining levels, threaten to
eliminate a plant or animal community,
substantially reduce the number or
restrict the range of a rare or endangered
plant or animal or eliminate important
examples of the major periods of
California history or prehistory?
b) Does the project have impacts that are
individually limited, but cumulatively
considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the
effects of other current projects, and the
effects of probable future projects)?
c) Does the project have environmental
effects, which will cause substantial
adverse effects on human beings, either
directly or indirectly?
Source: Cotati General Plan and 2013 General Plan EIR adopted and certified on March 24, 2015; and Public Works/Engineering Conditions of Approval prepared on September 27, 2023. 2013 General Plan EIR Findings
Under the requirements of CEQA, an EIR is required to discuss cumulative impacts to which the project would contribute. A cumulative impact is defined as an impact resulting from the combined effects of past, present, and reasonably foreseeable future projects or activities. The 2013 General Plan EIR concluded that implementation of the General Plan to Air Quality, Biological Resources, Cultural Resources, Geology and Soils, Greenhouse Gasses and Climate Change, Hazards, Hydrology and Water Quality, Land Use and Population, Agriculture, Public Services, and Recreation. 326 of 1220
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Cotati Village Community Two Project Page 151 of 157 CEQA Analysis The 2013 General Plan EIR determined that the implementation of the General Plan would result in the following Cumulative impacts:
• Impact 3.10--‐7: Cumulative Noise Impacts (Significant and Unavoidable) • Impact 3.13--‐3: Potential to exceed wastewater treatment capacity or the requirements of the RWQCB (Cumulatively Considerable and Significant and Unavoidable) • Impact 4.1: Cumulative Degradation of the Existing Visual Character of the Region (Considerable Contribution and Significant and Unavoidable) • Impact 4.11: Cumulative Exposure of Noise--‐Sensitive Land Uses to Noise in Excess of Normally Acceptable Noise Levels or to Substantial Increases in Noise (Considerable Contribution and Significant and Unavoidable)
• Impact 4.13: Cumulative Impact on the Transportation Network (Considerable Contribution and Significant and Unavoidable)
• Impact 4.14: Cumulative Impact on Utilities (Considerable Contribution and Significant and Unavoidable)
• Impact 4.15: Irreversible Effects (Significant and Unavoidable) Project Consistency with the 2013 General Plan EIR
5.21(a-c) (Threaten to eliminate a biological resource or cultural resource, cumulatively considerable, substantial adverse effects) – No Substantial Change Relative to the General Plan EIR
The proposed Project is consistent with both the General Plan Land Use Designation of General Commercial and Zoning designation of Commercial, Gravenstein Corridor (CG). The Project Conditions of Approval ensure that the Project complies with the policies and actions of the 2013 General Plan.
Additionally, and as noted throughout this document, the Project shall comply with the federal, state, and local regulations including the uniformly applied standards of the City of Cotati Municipal Code.
Further, the Project has been reviewed by the City of Cotati Planning Department, Building Department, Public Works and Engineering Department, and the Rancho Adobe Fire Protection District. The development review has established over 130 project conditions to ensure that the project complies with the City of Cotati Municipal Code and all pertinent regulations, thus ensuring that the project will not have a cumulatively considerable or substantially adverse effect as a result of the project.
Additionally, there are three other proposed projects in the vicinity, the Cotati Village Community and Redwood Row projects to the east, and the SR-116/West Cotati Avenue Realignment southeast of the site. While these projects are on different timelines, it is possible that construction activities may overlap. In order to prevent cumulative effects from multiple projects, COA MF-1 requires the applicant to coordinate with the City to coordinate concurrent construction and reduce any possible lane closures, haul trips, and minimize dust and noise as much as feasible.
The Project’s effects on Level of Service at SR-116 and Alder Avenue and West Cotati Avenue have been considered in relationship to the two other development projects proposed as well as future signalization of W. Cotati Ave. COA TRA-1 requires the final plans be submitted with confirmation that they will meet the minimum Level of Service Requirement prior to final approval. COA TRA-1 also 327 of 1220
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Cotati Village Community Two Project Page 152 of 157 CEQA Analysis requires the installation of the improvements prior to issuance of the certificate of occupancy. This ensures that the final traffic improvement plans will not result in cumulative effects to transportation.
The Project is within the scope of development projected under the General Plan and is conditioned as such that it would not result in any substantial new or more severe impacts relative to what was identified in the 2013 General Plan EIR. Furthermore, there are no circumstances peculiar to the Project site and there have been no substantial changes in environmental circumstances that would result in new or more severe significant environmental effects than were identified and evaluated in the 2013 General Plan EIR. The environmental conditions of approval that implement the 2013 General Plan EIR mitigating policies are listed in section 7 including the following:
COA MF-1: The applicant shall coordinate the project’s construction activities and construction schedule with the City to coordinate the concurrent construction of projects within 1,000 feet of the project site to ensure that overlapping lane closures, periods of increased noise and dust generation are minimized to the extent practicable.
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6. REFERENCE DOCUMENTS
The following reference documents are hereby incorporated by reference and are available for review during normal business hours at Cotati City Hall 201 W. Sierra Avenue in Cotati, CA.
6.1. TECHNICAL APPENDICES
A. Air Quality and Greenhouse Gas Assessment prepared by Illingworth and Rodkin on June 5, 2024 .
B. Biological Resource Analysis for Cotati Village Site prepared by Monk and Associates on October 11, 2022 and Letter confirming current validity of findings prepared by Monk and Associates on June 3, 2024.
C. Tree Inventory Report for Cotati Village Community Two prepared by Horticultural Associates on April 30, 2024.
D. Cultural Resources Addendum prepared by Evans and De Shazo on May 31, 2024. NO PUBLIC
DISTRIBUTION
E. Phase I Environmental Assessment prepared by Property Solutions Inc. on August 3, 2011.
F. Cotati Village Noise and Vibration Assessment prepared by Illingworth and Rodkin Inc on June 7, 2024.
G. Transportation Impact Study for the Cotati Village Project prepared by W-Trans on July 23, 2024.
6.2. OTHER DOCUMENTS REFERENCED
1. Cotati Village Community 2 Plan Set prepared by Trachtenberg Architects on May 23, 2024.
2. 2022 California Green Building Standards Code (CalGreen), Effective January 1, 2023.
3. Air Quality and Greenhouse Gas Assessment for Cotati Village Community (1) prepared by Illingworth and Rodkin on November 17, 2022.
4. Geotechnical Feasibility Evaluation prepared by Miller Pacific Engineering Group on April 15, 2015 and follow up memo prepared on April 17, 2024 by Miller Pacific Engineering.
5. Preliminary Hydrology & Hydraulics Study for Cotati Village Community Two prepared by Civil Design Consultants on February 1, 2024.
6. Stormwater Low Impact Development Submittal for Cotati Village 2 prepared by Civil Design Consultants, Inc on February 1, 2024.
7. Cotati Village 1 & 2 Water and Wastewater Assessment Report prepared by Carollo for the City of Cotati on September 26, 2023.
8. BAAQMD 2022 Bay Area Clean Air Plan, prepared by the Bay Area Air Quality Management District, April 2022.
9. BAAQMD CEQA Guidelines, prepared by the Bay Area Air Quality Management District, April 2022. 329 of 1220
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10. BAAQMD Recommended Methods for Screening and Modeling Local Risks and Hazards, prepared by the BAAQMD, May 2011.
11. California Code, Government Code Section 66477.
12. California Code, Health and Safety Code Section 25501(n)(1).
13. California Scenic Highway Mapping System, Scenic Highway System Lists, Cal Trans. https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-livi-scenic-highways, accessed December 15, 2023.
14. California Department of Conservation Farmland Mapping and Monitoring Program website accessed on December 26, 2023. https://maps.conservation.ca.gov/dlrp/ciff/
15. City of Cotati Municipal Code. https://www.codepublishing.com/CA/Cotati
16. Climate Action 2020 and Beyond: Sonoma County Regional Climate Action Plan, prepared by Sonoma County Regional Climate Protection Authority, July 2016.
17. City of Cotati Active Transportation Plan, adopted on May 14, 2024.
18. Cultural Resources Study for the Proposed Residential Care Facility at 8145 Highway 116 and 7515 Alder Ave., Cotati, Sonoma, County, CA prepared by Tom Origer & Associates on June 23, 2016.
19. EnviroStor, managed by the Department of Toxic Substances Control, accessed September 2023.
20. Fire Hazard Maps, Office of the State Fire Marshal, April 1, 2024.
21. GeoTracker, managed by the State Water Resources Control Board, accessed September 2023.
22. Groundwater Sustainability Plan for the Santa Rosa Plain Subbasin prepared by Sonoma Water, December 2021.
23. Guidelines for Analysis of Vehicle Miles Traveled, adopted by City of Cotati September 22, 2020.
24. Initial Study and Mitigated Negative Declaration for a Zoning Amendment and Residential Care Facility for the Elderly and a Commercial Building prepared by M-Group and adopted by City of Cotati City Council on November 12, 2019.
25. Local Responsibility Area Fire Severity Zone Map, Office of the State Fire Marshal, November 2007.
26. Moving Forward 2050: Sonoma County Comprehensive Transportation Plan (CTP) prepared by Sonoma County Transportation Authority and updated on September 7, 2021.
27. MTC/ABAG Hazard Viewer Map, accessed June 12, 2024.
28. National Flood Hazard Layer. FEMA. September 2023. https://www.fema.gov/floodmaps/national-flood-hazard-layer 330 of 1220
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29. Public Works Conditions of Approval for Cotati Village Two Conditions of Approval prepared by City of Cotati Department of Public Works and Engineering, February 29, 2024
30. Rancho Adobe Fire District Memorandum on Permit PA#23-1- 3rd Submittal (dated 2/7/2024) prepared on February 14, 2024.
31. Recovery Plan for the Santa Rosa Plain, US Fish and Wildlife Service (USFWS), 2016.
32. Reinitiation of Formal Consultation on Issuance of Clean Water Act, Section 404 Permits by the U.S. Army Corps of Engineers (Corps) on the Santa Rosa Plain, Sonoma County, California, prepared by USFWS, 2020.
33. Santa Rosa Plain Conservation Strategy, prepared by USFWS, 2005.
34. Santa Rosa Plain Conservation Strategy Map, prepared by USFWS, 2007.
35. Sonoma County Multijurisdictional Hazard Mitigation Plan Update 2021, prepared by Tetra Tech Consultants for Permit Sonoma, October 2021.
36. Sonoma County Permit Sonoma GIS, Williamson Act Contracts, Sonoma County, 2019.
37. Sonoma County Water Agency 2020 Urban Water Management Plan, prepared by Brown and Caldwell, June 2021.
38. State Responsibility Area Fire Severity Zone Map, Office of the State Fire Marshal, June 15, 2023.
39. Technical Advisory on Evaluating Transportation Impact in CEQA, prepared by the California Office of Planning and Research, December 2018.
40. Traffic Impact Study for Cotati Village Community (1) prepared by W-Trans on June 15, 2023.
41. USGS Land Cover Classification System.
42. USFWS 2020 Programmatic Biological Opinion for US Army Corps of Engineers Permitted Projects that Affect the California Tiger Salamander and Three Endangered Plant Species on the Santa Rosa Plain, California issued on June 11, 2020.
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7. ENVIRONMENTAL CONDITIONS OF APPROVAL
The following conditions of approval have been identified through this analysis and ensure implementation of applicable mitigation measures and policies set forth in the 2013 General Plan EIR.
COA AQ-1: During any construction period ground disturbance, the Project will ensure that the Project contractor(s) implement the following measures to control dust and exhaust that are recommended by BAAQMD and listed below:
9. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
10. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
11. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
12. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph).
13. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
14. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
15. All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
16. Designate a Disturbance Coordinator and post a publicly visible sign with the telephone number of the Disturbance Coordinator to contact regarding dust complaints. The Disturbance Coordinator shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
COA AQ-2: All contractors shall implement a Construction Minimization Plan including all feasible measures to reduce diesel particulate matter emissions as follows:
3. All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 emission standards for PM (PM10 and PM2.5), if feasible. If Tier 4 equipment is not available for a particular piece of equipment, then use equipment that meets U.S. EPA emission standards for Tier 2 or engines and include particulate matter emissions control equivalent to CARB Level 3 verifiable diesel emission control devices that altogether achieve a 45 percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination).
4. Alternatively, the applicant may develop another construction operations plan demonstrating that the construction equipment used on-site would achieve a reduction in construction diesel particulate matter emissions by 45 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Installation of electric power lines during early construction phases to avoid use of diesel portable equipment,
• Use of electrically-powered equipment,
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• Change in construction build-out plans to lengthen phases, and • Implementation of different building techniques that result in less diesel equipment usage. Provide line power to the site during the early phases of construction to minimize the use of diesel-powered stationary equipment.
COA BIO-1: In accordance with agency regulations and per the 2020 Programmatic Biological Opinion for the Santa Rosa Plain, vernal pool conservation credits shall be purchased for impacts to suitable Sebastopol meadowfoam habitat at a 1.5:1 ratio. Credits shall be purchased by the applicant and proof of purchase shall be provided to the City prior to the issuance of a grading permit.
COA BIO-2: Prior to issuance of a grading permit, California Tiger Salamander mitigation credits shall be purchased by the applicant from a USFWS approved Conservation Bank at a ratio of 2 square feet of mitigation for every square foot of upland habitat (2:1), and proof of purchase shall be provided to the City.
COA BIO-3: Prior to issuance of a demolition or grading permit (including removal of existing structures and trees), the project biologist shall perform bat roost emergence surveys no more than 7 days prior to the start of activities outside of the hibernation period (November 1 to March 1). Results of the survey shall be provided to the City of Cotati prior to commencing work. If bats are found, a bat exclusion plan shall be prepared and submitted to CDFW to include the following:
d. Bats shall be excluded between March 1 (once overnight low temperatures exceed 45 degrees Fahrenheit) and April 15, or between September 1 and October 15 to ensure no impact to maternity roosting occurs. Once bats have been fully excluded, the structure may be demolished or removed.
e. If a maternity roost is found, a replacement roost must be established either on‐site or at a nearby off‐site at a permanently protected location in consultation with CDFW. f. Tree removal for trees greater than 16‐inch dbh shall be performed using the three‐step removal process. First the crown or upper 1/3 of the tree shall be removed and any limbs removed and left overnight. Next, the rest of the tree shall be felled and left overnight. On the third day, the biologist shall examine the felled tree to make sure any bats have escaped prior to chipping on‐site or hauling to an off‐site location for disposal.
COA BIO-4: To prevent any potential affects to nesting birds, the following actions shall be taken:
4. If construction begins between February 1 and August 31, a pre‐construction nesting bird (both passerine and raptor) survey of the habitats within 500 feet of all work areas shall be performed within 7 days of groundbreaking. If no nesting birds are observed, no further action is required, and grading must occur within one week of the survey to prevent “take” of individual birds that could begin nesting after the survey. A follow-up survey is required if a stoppage in work occurs for longer than 7 days between February 1 and July 1.
5. If active bird nests (passerine and/or raptor) are observed during the pre‐ construction survey, a disturbance‐free buffer zone shall be established around the 333 of 1220
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6. To delineate the “no‐work” buffer zone around a nesting tree, orange construction fencing must be placed at the specified radius from the base of the tree within which no construction related activity or machinery shall intrude.
COA BIO-5: Prior to issuance of a demolition, grading, or building permit, credits from a US Army Corps of Engineers- and Regional Water Quality Control Board-approved wetland mitigation bank shall be purchased by the applicant at a ratio of no less than 1:1 to compensate for the loss of waters of the U.S. and State, and proof of credits shall be provided to the City of Cotati.
COA BIO-6: Tree removal or unintentionally damaged trees shall be replaced in compliance with Chapter 17.54 Tree Protection ordinance. All contractors shall comply with and implement the Tree Protection measures established in the Planning Division’s Project Conditions of Approval, specifically Conditions 7E and 11.
COA BIO-7: Rare plant surveys shall be conducted annually by a qualified biologist during appropriately timed blooming periods until construction commences on the project site. Results of rare plant surveys shall be submitted to the City prior to issuance of grading permit.
COA BIO-8: Indirect impacts to adjacent, offsite waters of the U.S./State shall be minimized to the maximum extent practicable by the use of best management practices (BMPs) that are installed prior to earth-work to protect waters of the U.S./State outside of the designated work areas. These practices shall include installing orange construction fencing, silt fencing, wildlife friendly hay wattles (that is, no monofilament netting), gravel wattles, and other protective measures between project activities and preserved offsite waters of the U.S./State. Orange construction fencing and other appropriate BMPs shall be installed along the riparian area located along the western boundary of the project site and the onsite construction areas. If the drainage ditch along SR-116 is to be preserved, orange construction fencing and other appropriate BMPs shall be installed during earthwork for all on and offsite improvements.
COA CUL-1: In the event that cultural resources, human remains, or unique paleontological resources are inadvertently discovered during ground disturbing activities, the following conditions shall apply:
d. If construction or grading activities result in the discovery of significant historic or prehistoric archaeological artifacts or unique paleontological resources, all work within 100 feet of the discovery shall cease, the Community Development Department shall be notified, the resources shall be examined by a qualified archaeologist, paleontologist, or historian for appropriate protection and preservation measures; and work may only resume when appropriate protections are in place and have been approved by the Community Development Department.
e. If human remains are discovered during any ground disturbing activity, work shall stop until the Community Development Department and the County Coroner have been contacted; if the human remains are determined to be of Native American origin, the Native American Heritage Commission (NAHC) and the most likely descendants have 334 of 1220
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Cotati Village Community Two Project Page 159 of 157 CEQA Analysis been consulted; and work may only resume when appropriate measures have been taken and approved by the Community Development Department. • If the skeletal remains are found to be prehistoric, Native American and not modern, then the coroner must call the Native American Heritage Commission in Sacramento that will designate the “Most Likely Descendant” (or MLD) of the discovered remains.
The MLD will be responsible for recommending the disposition and treatment of the remains (before construction is resumed). Although the likelihood of encountering human skeletal remains in the project area seems slight, it is important to have a procedure for alternate tasks that can be put into effect quickly in the event that human remains are discovered. This allows for work to continue elsewhere on the project area (where appropriate given the size of the property and location of the discovery) while the remains are properly investigated. f. If any prehistoric artifactual materials such as modified obsidian flakes or formed tools or concentrations of natural obsidian nodules are observed during any phase of grading or future construction on the property, all work in the vicinity of the find shall be stopped until the area of the discovery can be evaluated by an archaeologist. Depending on the extent and cultural composition of the discovered materials, subsequent excavation monitored by an archaeologist may be required, who shall be ready to record, recover and/or protect significant artifactual materials from further damage.
COA CUL-2: Prior to any ground disturbing activities, a Secretary of the Interior qualified archaeologist shall prepare an Archaeological Monitoring Plan (AMP) and provide the appropriate level of archaeological monitoring of ground-disturbing activities in the area shown on Figure 21 (pg. 34) of the Cultural Resources Study prepared by Evans and De Shazo on May 31, 2024. The AMP shall include the following provisions:
1. A pre-construction Cultural Resources Awareness Training (CRAT) and details regarding the types of archaeological resources that could be found within the Project Area, and the procedures to follow should any archaeological material be encountered, including proper notification to Tribes, agencies, and stakeholders, and for an assessment of the significance of any archaeological resources encountered during construction shall be provided.
2. The archaeological monitor shall be empowered to halt construction activities at the location of a discovery to review possible archaeological material and to protect the resource while the find is being assessed.
3. Monitoring shall continue until the Secretary of Interior-qualified archaeologist determines that full time monitoring of specific excavation activities or in specific areas of the Project can be reduced to spot check monitoring or that monitoring is no longer warranted.
4. A report shall also be prepared by the monitor that documents findings after the ground disturbance is complete and submitted to the City.
COA GEO-1: Prior to issuance of a grading or building permit, the applicant shall submit a geotechnical investigation report for review and acceptance by the Chief Building Official and/or the City Engineer.
The report shall include design-level recommendations, which shall be incorporated into the final project plans.
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City of Cotati
Cotati Village Community Two Project Page 160 of 157 CEQA Analysis a. At the time of permit application submittal, the applicant shall include a letter, together with the geotechnical analyses, from the Project’s geotechnical engineer certifying that all recommendations in the Project’s geotechnical analyses meet current geotechnical design standards and that all applicable recommendations have been incorporated into the construction plans. Where the geotechnical engineer recommends technical changes to the recommendations in any of the geotechnical analyses, such changes shall be clearly identified in the letter.
b. The Project’s geotechnical engineer shall inspect the construction work and shall certify to the City, prior to issuance of a certificate of occupancy, that the improvements have been constructed in accordance with the geotechnical analyses.
COA GHG-1: The applicant shall submit final plans that include electric vehicle charging infrastructure in compliance with CalGreen Tier 2 Voluntary Measures. Plans shall be reviewed and confirmed for compliance by the City of Cotati Building Department prior to issuance of an occupancy permit.
COA HYD-1: Prior to issuance of a building permit, the applicant shall submit a Storm Water Prevention and Pollution Plan (SWPPP) and erosion and sediment control plan for approval by the City Engineer. The SWPPP shall include Best Management Practices to be implemented during grading and construction activities. The SWPPP shall incorporate the requirements of all applicable federal, state, and local regulations. Submitted plans shall also demonstrate compliance with City of Cotati Municipal Code Chapter 13.68 Storm Water Ordinance and Chapter 14.36 Erosion and Sediment Control.
COA HYD-2: Prior to issuance of a grading permit, the applicant shall submit a final Stormwater Control Plans (SCP) including a final Storm Water Low Impact Development Plan (FSWLID) and Stormwater Mitigation Plan for review and approval by the City Engineer.
COA NOI-1: Prior to issuance of the building permit, the applicant shall submit final design plans that incorporate and certify the inclusion of mechanical ventilation equipment for all apartments located in Buildings A and B with a clear view of traffic on SR-116. The mechanical ventilation shall supply fresh air via an acoustically rated straight air transfer duct such as the Fresh 80, 90 or 100-dB units by Fresh Ventilation or an equivalent unit or other system deemed satisfactory by the local building official, to provide adequate fresh air to the residences with closed windows to maintain interior noise levels at or below 45 dBA Ldn.
COA NOI-2: The Project shall implement best management practices to minimize constructionrelated noise impacts as set forth in Action N1h of the General Plan, as listed below, and shall meet all applicable noise standards as set forth in Section 17.30.050 of the Cotati Municipal Code:
9. Noise-generating construction activities, including truck traffic coming to and from the construction site for any purpose, shall be limited to between the hours of 7:00 am and 7:00 pm on weekdays and 9:00 am and 5:00 pm on Saturdays. No construction shall occur on Sundays or holidays.
10. All equipment driven by internal combustion engines shall be equipped with mufflers, which are in good condition and appropriate for the equipment.
11. The construction contractor shall utilize “quiet” models of air compressors and other stationary noise sources where technology exists.
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City of Cotati
Cotati Village Community Two Project Page 161 of 157 CEQA Analysis
12. At all times during project grading and construction, stationary noise--‐generating equipment shall be located as far as practicable from sensitive receptors and placed so that emitted noise is directed away from residences.
13. Unnecessary idling of internal combustion engines shall be prohibited.
14. Construction staging areas shall be established at locations that will create the greatest distance between the construction-related noise sources and noise-sensitive receptors nearest the project site during all project construction.
15. Neighbors located adjacent to the construction site shall be notified of the construction schedule in writing.
16. The construction contractor shall designate a “noise disturbance coordinator” who will be responsible for responding to any local complaints about construction noise. The disturbance coordinator would determine the cause of the noise complaint (e.g., starting too early, bad muffler, etc.) and institute reasonable measures as warranted to correct the problem. A telephone number for the disturbance coordinator shall be conspicuously posted at the construction site.
COA REC-1: Prior to issuance of the building permit, the applicant shall dedicate one acre of parkland per 200 residents or pay an in-lieu fee as determined by the Community Development Director.
COA TRA-1: The Applicant shall provide public improvement plans to the City for review and acceptance prior to issuance of a grading permit. The final plans shall include signalization at either the intersection of Alder Avenue/SR-116 or the signalization of W. Cotati Ave/SR-116. If no signal is installed at Alder Avenue, final improvement plans shall include a physical barrier designed in compliance with Caltrans Highway Design Manual to prevent left turns from Alder Avenue onto SR116 and shall also include a public access easement to allow vehicles to use Batchelor Lane (through Cotati Village 1). A memo from the Project’s traffic engineer confirming that the final plans are designed to achieve intersection operation at Level of Service D or greater. The final plans shall be reviewed and accepted by the City’s Engineer prior to issuance of a grading permit and shall be fully installed prior to issuance of a certificate of occupancy for the project.
COA TRA-2: The applicant shall improve the bus stop located west of the SR-116 and Alder Ave. intersection to meet Sonoma County Transit Requirements and shall include a shelter, a bench, and ADA access to the proposed multi-use pathway along SR-116 as well as any other elements required by Sonoma County Transit Authority. The bus stop may be relocated east of Alder Avenue if a signal is installed at W. Cotati/SR-116 intersection and not at the Alder Avenue/SR-116 intersection.
COA TRA-3: The Project shall comply with all requirements from Caltrans to address design, engineering, and operation requirements within the State right-of-way. Prior to commencing any work in the public right of way, the applicant shall secure an encroachment permit from Caltrans and provide the following to Caltrans:
1. Detailed information regarding any connections and or modifications to State drainage systems must be provided.
2. Any engineering calculations for onsite systems out-letting to State drainage systems (pipe or ditch) must be provided, such as flow rates for shed areas, detention time for detention basins, 337 of 1220
City of Cotati
Cotati Village Community Two Project Page 162 of 157 CEQA Analysis etc. If additional runoff is generated from the site and drains towards SR-116, the runoff must be metered to pre-construction levels.
The applicant shall provide a copy of the approved encroachment permit to the City prior to commencing work within the public right of way. If Project work requires the movement of oversized or excessive load vehicles on State roadways, the Applicant shall secure a transportation permit from Caltrans and provide a copy to the City.
COA TRA-4: The Applicant shall install a 50-foot-long left-turn pocket on SR-116 at the eastbound approach to Alder Avenue, or as otherwise approved by the City Engineer. If signalized, the southbound Alder Avenue approach to SR-116 shall be restriped to include a separate left-turn lane.
The left-turn lane and restriping plan shall be submitted to the City Engineer for review and approval prior to building permit issuance. All required approvals shall be obtained from Caltrans and submitted to the City.
COA TRA-5: Final landscaping plans shall be submitted and show compliance with Cotati Municipal Code (CMC) Section 17.30.040(c)(2). Final landscaping plans shall include the specific plants that will be placed in the traffic safety visibility area (see CMC Section 17.30.040.E) and their maximum projected height which shall be no taller than 36 inches except for trees with their canopy trimmed to a minimum of eight feet above grade. These standards shall be applied to access drive from Alder Avenue, as well as the intersections of the multi-use path and Alder Avenue.
COA UTI-1: The final plans and a final Water and Wastewater Assessment Report shall be submitted by the Applicant and reviewed/accepted by the City Engineer to confirm water demand and wastewater generation of final project design can be met by utilities prior to permit issuance.
COA UTI-2: The applicant shall submit landscape and irrigation plans for plantings at the time of the Improvement Plan submittal package. All landscaping and irrigation shall comply with the City Water Efficient Landscape Ordinance (WELO) and is subject to review and approval by the City Engineer. Prior to issuance of a certificate of occupancy, all plantings and irrigation systems in the approved final landscaping plan shall be completed.
COA UTI -3: The applicant shall execute a City standard Public Improvement Agreement to address the proposed public improvements. The agreement shall address design, construction, dedication of, and City acceptance of the public improvements. The agreement shall include and engineer’s cost estimate for the public improvements, security for the completion of these improvements, an initial deposit and execution of the City’s deposit account agreement for City inspection of the construction of the public improvements. The agreement shall be submitted for review and approval by the City.
The agreement shall also address the ownership, maintenance, lighting, parking, access and shall be recorded against the lands of the project. The site shall be annexed into the Community Facilities District.
COA MF-1: The applicant shall coordinate the project’s construction activities and construction schedule with the City to coordinate the concurrent construction of projects within 1,000 feet of the project site to ensure that overlapping lane closures, periods of increased noise and dust generation are minimized to the extent practicable.
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Cotati Village 2
7515 Alder Ave/8145 Gravenstein Hwy (SR 116)
PA# 23-19
Cotati City Council Community
Development
Department
August 27, 2024 339 of 1220
Project Location
Northwest corner of Alder Ave. & SR-116
Site
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Project Site
5.62 acres; Zoning—Commercial, Gravenstein Corridor (CG); Mixed-use 341 of 1220
Background
2019--Proposal for commercial development and
residential care facility for elderly
Commercial space completed and occupied (Jane
Dispensary, Acre Pizza); frontage improvements on 116
and Alder completed
February 2023—SB 330 application for Cotati Village 2 November 2023—Neighborhood meeting for project
March 2024—Design Review and Tree Removal Permit
applications submitted
Planning Commission recommended approval at its
August 5, 2024 public hearing 342 of 1220
Project Description
State Density Bonus
126 apartments
13 BMR/Inclusionary units
5 – 1BR, 5 – 2BR, 3 – 3BR
2,250 sf commercial (café)
Open space & woonerf
153 off-street parking
spaces
Public improvements:
Bike/Ped paths, Alder Ave.
Land dedications for future road projects 343 of 1220 Access to/from SR 116
Two primary options:
Option 1: Alder Avenue
Install traffic signal at
Alder and 116
Add left turn lane to
Alder southbound
Add left turn lane to SR
116 eastbound
LOS B
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Option 2: W. Cotati Avenue
Complete W. Cotati Ave realignment/traffic
signal
Build Batchelor Lane (thru CV1); public access
Extend median on 116 to make Alder right
in/right out only (no traffic signal)
LOS C
Cotati Cotati Village 1
Village 2
W. Cotati Ave
Realignment 345 of 1220
Renderings
Building B from west side of courtyard
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Renderings
Buildings A and B from east side of courtyard
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Renderings
Commercial building 348 of 1220
Renderings
View from Alder Avenue
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Required Entitlements & Approvals
City Council
Preliminary Design Review
Tree Removal Permit
Future approvals
Final Design Review (staff)
Affordable Housing/Inclusionary
housing agreement (Council)
Improvement plans (staff)
Construction permits (staff)
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State Density Bonus Law
Density Bonus—50% bonus for providing 15%
BMR/inclusionary units
Calculation:
Base density per CG zoning: Maximum 15
units/acre x 5.62 acres = 84 units
15% of 84 units to be BMR (very low
income) = 13
Bonus: 84 x 50% = 42 units
84 + 42 = 126 units allowed with DB
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State Density Bonus Law
Reduced parking minimums for residential
166 off-street spaces required per State DB law for
residential
332 required per City Code (pre-Plex housing
ordinance)
Project proposes 153 off-street for residential, plus
Shared parking with commercial (4 “surplus”
spaces out of 44 total in commercial lot)
Use of new on-street spaces on Alder (9)
Total of 206 potential parking spaces (conforms
to SDBL residential, plus City standard for
commercial)
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State Density Bonus Law
Concessions/waivers of City standards:
Building height 4 stories
Reduced commercial floor area
Residential buildings do not meet front build-to lines Reduced woonerf standards
Structures and parking placed in side setbacks
Reduced land dedication for future N-S street to west
Residential buildings not oriented to street
Apply on-street parking to off-street parking
requirement
Allow shared parking between commercial and
residential
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Planning Considerations
Design Review
Zoning & Development Standards
Multifamily Objective Design
Standards
Architecture
Site layout
Open space and amenities
Landscaping
City Services
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Planning Considerations
Tree Removal
41 existing trees on site, primarily Valley Oaks
5 trees to be removed: 3 heritage Valley Oaks,
1 Redwood, 1 Mexican Fan Palm
Retaining 36 trees on site, including a Valley Oak for common space oak grove
Mitigation trees required
On-site: 24 Valley Oaks on site; 16 other
Payment to tree in-lieu fund: 31 oaks x $300 each
Total new trees on site: 138
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CEQA
Project is consistent with the General Plan and
zoning
No unidentified or project-specific impacts
peculiar to the project or site
CEQA Guidelines §15183
Environmental analysis tiers from the Cotati
General Plan EIR (2015)
Mitigation measures from the Cotati General Plan
EIR apply to project
Conditions of Approval
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Planning Commission Recommendation
Public hearing August 5—voted to recommend
Council approval of entitlements
Comments
Building design—more color, texture, material
variation
Pedestrian safety—speed limit, traffic calming
on-site and on Batchelor Lane in CV1
Play structure location and design
Manage commercial business event parking
impacts
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Recommendation
The Planning Commission and City staff recommend
that the City Council conduct a Public Hearing and
adopt the accompanying resolution finding the
project consistent with the General Plan EIR under
CEQA Guidelines Section 15183, and approving
Preliminary Design Review and a Tree Removal Permit
to allow construction of a multifamily mixed-use
development of 126 apartments and 2,250 square
feet of commercial space on a 5.62 acre property
located at 7515 Alder Avenue and 8145 Gravenstein
Highway (SR-116).
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Questions?
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COTATI VILLAGE #2
AIR QUALITY & GREENHOUSE
GAS ASSESSMENT
Cotati, California
June 11, 2024
Prepared for:
Heather Gurewitz, AICP
Senior Planner
M-Group
1275 4th Street #265
Santa Rosa, CA 95404
Prepared by:
Casey Divine
William Popenuck
Jordyn Bauer
429 East Cotati Avenue
Cotati, CA 94931
(707) 794-0400
I&R Project#: 24-049
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1 Introduction
The purpose of this report is to address air quality, health risk, and greenhouse gas (GHG) impacts associated with the proposed Cotati Village #2 project located at 7515 Alder Avenue in Cotati, California. Air quality and GHG would be associated with the construction of new buildings and infrastructure, and operation of the project. Air pollutants and GHG emissions associated with construction and operation of the project were predicted using appropriate computer models. In addition, the potential project health risk impacts (construction and operation) and the impact of existing toxic air contaminant (TAC) sources affecting the nearby and proposed sensitive receptors were evaluated. The analysis was conducted following guidance provided by the Bay Area Air Quality Management District (BAAQMD).1
Project Description
The approximately 4-acre project site is located on a vacant parcel. The project proposes to construct two, four-story buildings totaling 126 residential units and a separate 2,250 square-foot (sf) café. It would also include 168 parking spaces throughout the site.
Setting
The project is located in the portion of Sonoma County that is part of the San Francisco Bay Area Air Basin. Ambient air quality standards have been established at both the State and federal level.
The Bay Area meets all ambient air quality standards with the exception of ground-level ozone, respirable particulate matter (PM10) and fine particulate matter (PM2.5). In Sonoma County, measured levels of air pollutants are below air quality standards, including ozone, PM10 and PM2.5.
Air Pollutants of Concern
High ozone concentrations in the air basin are caused by the cumulative emissions of reactive organic gases (ROG) and nitrogen oxides (NOX). These precursor pollutants react under certain meteorological conditions to form ozone concentrations. Controlling the emissions of these precursor pollutants is the focus of the Bay Area’s attempts to reduce ambient ozone concentrations. The highest ozone concentrations in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources. High ozone concentrations aggravate respiratory and cardiovascular diseases, reduced lung function, and increase coughing and chest discomfort.
Particulate matter is another problematic air pollutant in the air basin. Particulate matter is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM10) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM2.5). Elevated concentrations of PM10 and PM2.5 are the result of both region-wide (or cumulative) emissions and localized emissions. High particulate matter concentrations aggravate respiratory and cardiovascular diseases, reduce lung function, increase mortality (e.g., lung cancer), and result in reduced lung function growth in children. 1 Bay Area Air Quality Management District, 2022 CEQA Guidelines, April 2023. 361 of 1220
2 Toxic Air Contaminants
TACs are a broad class of compounds known to cause morbidity or mortality, often because they cause cancer. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter [DPM] near a freeway). Because chronic exposure of TACs can result in adverse health effects, they are regulated at the regional, State, and federal level.
Diesel exhaust is the predominant TAC in urban air and is estimated to represent about threequarters of the cancer risk from TACs (based on the Bay Area average). According to the California Air Resources Board (CARB), diesel exhaust is a complex mixture of gases, vapors, and fine particles. This complexity makes the evaluation of health effects from diesel exhaust exposure a complex scientific issue. Some of the chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the CARB, and are listed as carcinogens either under the State's Proposition 65 or under the Federal Hazardous Air Pollutants programs. Health risks from TACs are estimated using the Office of Environmental Health Hazard Assessment (OEHHA) risk assessment guidelines, which were published in February of 2015 and incorporated in BAAQMD’s current CEQA guidance.2
Sensitive Receptors
There are groups of people more affected by air pollution than others. CARB has identified the following persons who are most likely to be affected by air pollution: children under 16, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, elementary schools, and parks. For cancer risk assessments, children are the most sensitive receptors, since they are more susceptible to cancer causing TACs. Residential locations are assumed to include infants and small children. The closest sensitive receptors to the site are the residents in the townhomes northeast of the project site, with additional single-family homes in the surrounding area. If the Cotati Village #1 project adjacent to the east of the site is completed before this project begins, it would also have sensitive receptors. The project will introduce new sensitive (i.e., residential) receptors.
Regulatory Setting
Federal Regulations
The United States Environmental Protection Agency (EPA) sets nationwide emission standards for mobile sources, which include on-road (highway) motor vehicles such trucks, buses, and automobiles, and non-road (off-road) vehicles and equipment used in construction, agricultural, industrial, and mining activities (such as bulldozers and loaders). The EPA also sets nationwide 2 OEHHA, 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines, The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Office of Environmental Health Hazard Assessment.
February.
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3 fuel standards. California also has the ability to set motor vehicle emission standards and standards for fuel used in California, as long as they are the same or more stringent than the federal standards.
In the past decade the EPA has established a number of emission standards for on- and non-road heavy-duty diesel engines used in trucks and other equipment. This was done in part because diesel engines are a significant source of NOX and particulate matter (PM10 and PM2.5) and because the EPA has identified DPM as a probable carcinogen. Implementation of the heavy-duty diesel onroad vehicle standards and the non-road diesel engine standards are estimated to reduce particulate matter and NOX emissions from diesel engines up to 95 percent in 2030 when the heavy-duty vehicle fleet is completely replaced with newer heavy-duty vehicles that comply with these emission standards.3
In concert with the diesel engine emission standards, the EPA has also substantially reduced the amount of sulfur allowed in diesel fuels. The sulfur contained in diesel fuel is a significant contributor to the formation of particulate matter in diesel-fueled engine exhaust. The new standards reduced the amount of sulfur allowed by 97 percent for highway diesel fuel (from 500 parts per million by weight [ppmw] to 15 ppmw), and by 99 percent for off-highway diesel fuel (from about 3,000 ppmw to 15 ppmw). The low sulfur highway fuel (15 ppmw sulfur), also called ultra-low sulfur diesel (ULSD), is currently required for use by all vehicles in the U.S.
All of the above federal diesel engine and diesel fuel requirements have been adopted by California, in some cases with modifications making the requirements more stringent or the implementation dates sooner.
State Regulations
To address the issue of diesel emissions in the state, CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles.4 In addition to requiring more stringent emission standards for new on-road and off-road mobile sources and stationary diesel-fueled engines to reduce particulate matter emissions by 90 percent, a significant component of the plan involves application of emission control strategies to existing diesel vehicles and equipment. Many of the measures of the Diesel Risk Reduction Plan have been approved and adopted, including the federal on-road and non-road diesel engine emission standards for new engines, as well as adoption of regulations for low sulfur fuel in California.
CARB has adopted and implemented a number of regulations for stationary and mobile sources to reduce emissions of DPM. Several of these regulatory programs affect medium and heavy-duty diesel trucks that represent the bulk of DPM emissions from California highways. CARB regulations require on-road diesel trucks to be retrofitted with particulate matter controls or replaced to meet 2010 or later engine standards that have much lower DPM and PM2.5 emissions.
This regulation will substantially reduce these emissions between 2013 and 2023. While new trucks and buses will meet strict federal standards, this measure is intended to accelerate the rate 3 USEPA, 2000. Regulatory Announcement, Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements. EPA420-F-00-057. December. 4 California Air Resources Board, 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from DieselFueled Engines and Vehicles. October. 363 of 1220
4 at which the fleet either turns over so there are more cleaner vehicles on the road or is retrofitted to meet similar standards. With this regulation, older, more polluting trucks would be removed from the roads sooner.
CARB has also adopted and implemented regulations to reduce DPM and NOX emissions from inuse (existing) and new off-road heavy-duty diesel vehicles (e.g., loaders, tractors, bulldozers, backhoes, off-highway trucks, etc.). The regulations apply to diesel-powered off-road vehicles with engines 25 horsepower (hp) or greater. The regulations are intended to reduce particulate matter and NOX exhaust emissions by requiring owners to turn over their fleet (replace older equipment with newer equipment) or retrofit existing equipment in order to achieve specified fleetaveraged emission rates. Implementation of this regulation, in conjunction with stringent federal off-road equipment engine emission limits for new vehicles, will significantly reduce emissions of DPM and NOX.
Bay Area Air Quality Management District (BAAQMD)
BAAQMD has jurisdiction over an approximately 5,600-square mile area, commonly referred to as the San Francisco Bay Area (Bay Area). The District’s boundary encompasses the nine San Francisco Bay Area counties, including Alameda County, Contra Costa County, Marin County, San Francisco County, San Mateo County, Santa Clara County, Napa County, southwestern Solano County, and southern Sonoma County.
BAAQMD is the lead agency in developing plans to address attainment and maintenance of the National Ambient Air Quality Standards and California Ambient Air Quality Standards. The District also has permit authority over most types of stationary equipment utilized for projects. The BAAQMD is responsible for permitting and inspection of stationary sources; enforcement of regulations, including setting fees, levying fines, and enforcement actions; and ensuring that public nuisances are minimized.
BAAQMD’s Community Air Risk Evaluation (CARE) program was initiated in 2004 to evaluate and reduce health risks associated with exposures to outdoor TACs in the Bay Area.5 The program
examines TAC emissions from point sources, area sources, and on-road and off-road mobile sources with an emphasis on diesel exhaust, which is a major contributor to airborne health risk in California. The CARE program is an on-going program that encourages community involvement and input. The technical analysis portion of the CARE program has been implemented in three phases that includes an assessment of the sources of TAC emissions, modeling and measurement programs to estimate concentrations of TAC, and an assessment of exposures and health risks.
Throughout the program, information derived from the technical analyses has been used to develop emission reduction activities in areas with high TAC exposures and high density of sensitive populations. Risk reduction activities associated with the CARE program are focused on the most at-risk communities in the Bay Area. Seven areas have been identified by BAAQMD as impacted communities. They include Eastern San Francisco, Richmond/San Pablo, Western Alameda, San José, Vallejo, Concord, and Pittsburgh/Antioch. The project site is not within any of the BAAQMD CARE areas.
5 See BAAQMD: https://www.baaqmd.gov/community-health/community-health-protection-program/communityair-risk-evaluation-care-program. 364 of 1220
5 Overburdened communities are areas located (i) within a census tract identified by the California Communities Environmental Health Screening Tool (CalEnviroScreen), Version 4.0 implemented by OEHHA, as having an overall score at or above the 70th percentile, or (ii) within 1,000 feet of any such census tract.6
The BAAQMD has identified several overburdened areas within its boundaries. However, the project site is not within an overburdened area as the Project site is scored at the 38th percentile on CalEnviroScreen.7
BAAQMD CEQA Air Quality Guidelines
In June 2010, BAAQMD adopted thresholds of significance to assist in the review of projects under CEQA. In 2023, the BAAQMD revised the California Environmental Quality Act (CEQA) Air Quality Guidelines that include significance thresholds to assist in the evaluation of air quality impacts of projects and plans proposed within the Bay Area. The current BAAQMD guidelines provide recommended procedures for evaluating potential air impacts during the environmental review process consistent with CEQA requirements including thresholds of significance, mitigation measures, and background air quality information. They include assessment methodologies for criteria air pollutants, air toxics, odors, and GHG emissions as shown in Table
1.8 Air quality impacts and health risks are considered potentially significant if they exceed these thresholds.
The BAAQMD recommends all projects include a “basic” set of best management practices (BMPs) to manage fugitive dust and consider impacts from dust (i.e., fugitive PM10 and PM2.5) to be less than significant if BMPs are implemented (listed below). BAAQMD strongly encourages enhanced BMPs for construction sites near schools, residential areas, other sensitive land uses, or if air quality impacts were found to be significant.
6 See BAAQMD: https://www.baaqmd.gov/~/media/dotgov/files/rules/reg-2-permits/2021- amendments/documents/20210722_01_appendixd_mapsofoverburdenedcommunities-pdf.pdf?la=en. 7 OEHAA, CalEnviroScreen 4.0 Maps https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 8 Bay Area Air Quality Management District, 2022 CEQA Guidelines. April2023. 365 of 1220
6 Table 1. BAAQMD CEQA Significance Thresholds
Criteria Air
Pollutant
Construction Thresholds Operational Thresholds
Average Daily Emissions
(lbs./day)
Average Daily
Emissions (lbs./day)
Annual Average
Emissions (tons/year)
ROG 54 54 10
NOX 54 54 10
PM10 82 (Exhaust) 82 15
PM2.5 54 (Exhaust) 54 10
CO Not Applicable 9.0 ppm (8-hour average) or 20.0 ppm (1-hour average)
Fugitive Dust Construction Dust Ordinance or other
Best Management Practices (BMPs)* Not Applicable
Health Risks
and Hazards
Single Sources/
Individual Project
Combined Sources (Cumulative from all
sources within 1000-foot zone of influence)
Excess Cancer
Risk
>10 in a
million
OR
Compliance with
Qualified
Community
Risk Reduction Plan
>100 in a million OR
Compliance with
Qualified Community
Risk Reduction Plan
Hazard Index >1.0 >10.0
Incremental
annual PM2.5
>0.3 µg/m3 >0.8 µg/m3
Greenhouse Gas Emissions
Land Use Projects
– (Must Include A
or B)
A. Projects must include, at a minimum, the following project design elements:
1. Buildings
a. The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).
b. The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.
2. Transportation
a. Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA:
i. Residential projects: 15 percent below the existing VMT per capita ii. Office projects: 15 percent below the existing VMT per employee iii. Retail projects: no net increase in existing VMT
b. Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.
B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).
Note: ROG = reactive organic gases, NOX = nitrogen oxides, PM10 = course particulate matter or particulates with an aerodynamic diameter of 10 micrometers (µm) or less, PM2.5 = fine particulate matter or particulates with an aerodynamic diameter of 2.5µm or less. GHG = greenhouse gases.
* BAAQMD strongly recommends implementing all feasible fugitive dust management practices especially when construction projects are located near sensitive communities, including schools, residential areas, or other sensitive land uses.
Source: Bay Area Air Quality Management District, 2022
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7 City of Cotati 2013 General Plan
The 2013 Cotati General Plan Conservation Element includes an extensive list of policies and action measures that are aimed at improving air quality. Additionally, the General Plan Land Use Element and Land Use Map promotes a compact urban development pattern that emphasizes infill development and ensures that land use patterns do to not expose sensitive receptors to unhealthy pollutant concentrations. Furthermore, the Circulation Element includes a range of policies and action items that would effectively reduce vehicle travel, through the use of complete streets and multi-modal transportation systems. Applicable General Plan policies include:
Policy CON 2.1: Improve air quality through continuing to require a compact development pattern that focuses growth in and around existing urbanized areas, locating new housing near places of employment, encouraging alternative modes of transportation, and requiring projects to mitigate significant air quality impacts.
Policy CON 2.2: Minimize exposure of sensitive receptors to concentrations of air pollutant emissions and toxic air contaminants.
Policy CON 2.4: Require new development or significant remodels to install fireplaces, stoves, and/or heaters which meet current BAAQMD standards. Policy CON 2.5: Continue to require all construction projects and ground disturbing activities to implement BAAQMD dust control and abatement measures. Policy CON 2.7: Continue to aggressively implement the greenhouse gas (GHG) reduction measures contained in the 2008 Cotati Greenhouse Gas Emissions Reduction Action Plan. Policy CON 3.1: Continue to require all new public and privately constructed buildings to meet and comply with CALGreen Tier 1 standards.
Policy CON 3.2: Support innovative and green building best management practices, including LEED certification, for all new development, and encourage project applicants to exceed CALGreen Tier 1 standards, if feasible.
Policy CON 3.3: Promote the use of alternative energy sources in new development. Policy CON 3.7: Encourage tree planting, including widespread use of trees as windbreaks to maximize the effects of cooling westerly winds and planting of deciduous trees to help reduce summer temperatures, either in conjunction with new development or through private sector participation.
Policy CON 3.8: Promote water conservation among water users. Policy CON 3.9: Require the use of drought-tolerant and regionally native plants in landscaping.
Policy CON 3.10: Ensure that the layout and design of new development and significant remodels encourages the use of transportation modes other than automobiles and trucks. Policy CON 3.16: Improve and maintain landscaping around commercial areas in order to minimize the "heat island" effect, provide shade, soften the harshness of such commercial areas, and create a more leisurely ambience.
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8 AIR QUALITY IMPACTS
Impact AIR-1: Conflict with or obstruct implementation of the applicable air quality plan?
BAAQMD, with assistance from the Association of Bay Area Governments (ABAG) and Metropolitan Transportation Commission (MTC), implements specific plans to meet the applicable federal and State laws, regulations, and programs. The most recent and comprehensive plan is the Bay Area 2017 Clean Air Plan.
9 The primary goals of the Clean Air Plan are to attain air quality standards, reduce population exposure and protect public health, and reduce GHG emissions and protect the climate. The BAAQMD has also recently updated its CEQA guidelines to assist lead agencies in evaluating the significance of air quality impacts. In formulating compliance strategies, BAAQMD relies on planned land uses established by local general plans. Land use planning affects vehicle travel, which in turn affects region-wide emissions of air pollutants and GHGs.
The 2017 Clean Air Plan, adopted by BAAQMD in April 2017, includes control measures that are intended to reduce air pollutant emissions in the Bay Area either directly or indirectly. Plans must show consistency with the control measures listed within the Clean Air Plan. At the project-level, there are no consistency measures or thresholds. The proposed project would not conflict with the latest Clean Air planning efforts since 1) project would have construction and operational emissions below the BAAQMD thresholds and 2) the project would be considered urban infill, and 3) the project would be located near employment centers.
Impact AIR-2: Result in a 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? The Bay Area is considered a non-attainment area for ground-level O3 and PM2.5 under both the NAAQS and the CAAQS. The area is also considered non-attainment for PM10 under the CAAQS, but not the NAAQS. The area has attained both the NAAQS and CAAQS for carbon monoxide (CO). As part of an effort to attain and maintain the NAAQS and CAAQS for O3, PM2.5 and PM10, the BAAQMD has established thresholds of significance for these air pollutants and their precursors. These thresholds are for O3 precursor pollutants (ROG and NOX), PM10, and PM2.5 and apply to both construction period and operational period impacts.
Construction Period Emissions
The California Emissions Estimator Model (CalEEMod) Version 2022 was used to estimate emissions from on-site construction activity, construction vehicle trips, and evaporative emissions.
The project land use types and size, and anticipated construction schedule were input to CalEEMod. The CalEEMod model output along with construction inputs are included in Attachment 1.
9 Bay Area Air Quality Management District (BAAQMD), 2017. Final 2017 Clean Air Plan. 368 of 1220
9 CalEEMod Inputs
Land Uses
The proposed project land uses were entered into CalEEMod as described in Table 2.
Table 2. Summary of Project Land Use Inputs
Project Land Uses Size Units Square Feet Acreage
Apartments Mid Rise 126 Dwelling Units 141,680
Fast Food Restaurant w/o Drive Thru 2.25 1,000-sf 2,250 4 Parking Lot 168 Parking Spaces -
Construction Inputs
CalEEMod computes annual emissions for construction that are based on the project type, size, and acreage. The model provides emission estimates for both on-site and off-site construction activities. On-site activities are primarily made up of construction equipment emissions, while offsite activity includes worker, hauling, and vendor traffic. The construction build-out scenario, including equipment quantities, average hours per day, total number of workdays, and schedule, were based on a blend of CalEEMod defaults and information provided by the project applicant (included in Attachment 1). The construction schedules assumed that the earliest possible start date would be January 2025 and the project would be built out over a period of approximately 10 months or 216 construction workdays. The earliest full year of project operation was assumed to be 2026.
Construction Traffic Emissions
Construction would produce traffic in the form of worker trips and truck traffic. The traffic-related emissions are based on worker and vendor trip estimates produced by CalEEMod and haul trips that were computed based on the amount of estimated demolition material to be exported, soil imported and/or exported to the site, and amount of concrete truck trips to and from the site.
CalEEMod provides daily estimates of worker and vendor trips for each applicable phase. Haul trips for demolition and grading were estimated by CalEEMod using the provided demolition soil import/export volumes. The number of total concrete haul trips was provided for the project and converted to daily one-way trips, assuming two trips per delivery. These values are shown in the project construction equipment worksheets included in Attachment 1.
Summary of Computed Construction Period Emissions
Average daily emissions were annualized for each year of construction by dividing the annual construction emissions by the number of active workdays during that year. Table 3 shows the uncontrolled annualized average daily construction emissions of ROG, NOX, PM10 exhaust, and PM2.5 exhaust during construction of the project. As indicated in Table 3, predicted uncontrolled annualized project construction emissions would not exceed the BAAQMD significance thresholds during any year of construction.
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10 Table 3. Construction Period Emissions
Year ROG NOx PM10
Exhaust
PM2.5
Exhaust
Construction Emissions Per Year (Tons)
2025 1.13 0.93 0.04 0.03
Average Daily Construction Emissions Per Year (pounds/day) 2025 (216 construction workdays) 10.43 8.57 0.34 0.31
BAAQMD Thresholds (pounds per day) 54 lbs./day 54 lbs./day 82 lbs./day 54 lbs./day Exceed Threshold? No No No No
Construction activities, particularly during site preparation and grading, would temporarily generate fugitive dust in the form of PM10 and PM2.5. Sources of fugitive dust include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site deposit mud on local streets, which is an additional source of airborne dust after it dries. The BAAQMD recommends all projects include a “basic” set of best management practices (BMPs) to manage fugitive dust and considers impacts from dust (i.e., fugitive PM10 and PM2.5) to be less-than-significant if BMPs are implemented.
General Plan Policy CON 2.5 requires projects to implement BAAQMD dust control measures.
Furthermore, the Project intends to implement a Construction Emissions Minimization Plan that includes measures that are consistent with the BAAQMD-recommended basic control measures for reducing fugitive particulate matter.
Operational Period Emissions
ROG, PM, and NOX emissions from the project would be generated primarily from autos driven by future residents. Evaporative emissions from architectural coatings and maintenance products (classified as consumer products) are also typical ROG emission sources from these types of land uses. CalEEMod was used to estimate emissions from operation of the proposed project assuming full build-out.
CalEEMod Inputs
Land Uses
The project operational land uses were entered into CalEEMod as described above for the construction period modeling.
Model Year
Emissions associated with vehicle travel depend on the year of analysis because emission control technology requirements are phased-in over time. Therefore, the earlier the year analyzed in the model, the higher the emission rates utilized by CalEEMod. The earliest full year of operation would be 2026 if construction begins in 2025. Emissions associated with build-out later than 2026 would be lower.
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11 Traffic Information
CalEEMod allows the user to enter specific vehicle trip generation rates. Therefore, the projectspecific daily trip generation rate provided by the traffic consultant was entered into the model.10 The project would produce approximately 1,773 daily trips. When accounting for the Internal Capture and Diverted Link Reductions, the project would then produce 1,180 new daily trips. The daily trip generation was calculated using ITE trip generation rates, the size of the project land uses, and the adjusted total automobile trips after reductions. The Saturday and Sunday trip rates were derived by multiplying the ratio of the CalEEMod default rates for Saturday and Sunday trips to the default weekday rate with the project-specific daily weekday trip rate. The default trip lengths and trip types specified by CalEEMod were used.
Energy
CalEEMod defaults for energy use were used, which include the 2019 Title 24 Building Standards.
GHG emissions modeling includes those indirect emissions from electricity consumption. The CalEEMod default emission factor of 39.46 pounds of CO2 per megawatt of electricity produced by Sonoma Clean Power was used.
The project will be all electric according to the project applicant. Therefore, natural gas for the residential and cafe land use was set to zero and the energy use associated with natural gas reassigned to electricity use in CalEEMod.
Wood-Burning Devices
CalEEMod default inputs assume new residential construction would include woodburning fireplaces and stoves. The project would not include wood-burning devices, as these devices are prohibited by BAAQMD Regulation 6, Rule 3.11 Therefore, the number of woodstoves and woodburning fireplaces in CalEEMod were set to zero.
Other Inputs
Default model assumptions for emissions associated with solid waste generation use were used.
Wastewater treatment was changed to 100 percent aerobic conditions to represent the use of city sewer services (i.e., project would not send wastewater to septic tanks or facultative lagoons).
Summary of Computed Operational Emissions
Annual emissions were predicted using CalEEMod and daily emissions were estimating assuming 365 days of operation. Table 4 shows uncontrolled net average daily operational emissions of ROG, NOX, total PM10, and total PM2.5 during operation of the project. The uncontrolled operational period emissions would not exceed the BAAQMD significance thresholds. 10 Email correspondence from Heather Gurewitz, M-Group., May 23, 2024. Attachment: CV 2-trip generation summary.pdf.
11 Bay Area Air Quality Management District, https://www.baaqmd.gov/~/media/dotgov/files/rules/regulation-6- rule-3/documents/20191120_r0603_final-pdf.pdf?la=en
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12 Table 4. Operational Period Emissions
Scenario ROG NOx PM10 PM2.5
2026 Annual Project Operational Emissions (tons/year) 1.68 0.96 1.38 0.36 BAAQMD Thresholds (tons /year) 10 tons 10 tons 15 tons 10 tons Exceed Threshold? No No No No
2026 Daily Project Operational Emissions (pounds/day)
1 9.20 5.27 7.55 1.98
BAAQMD Thresholds (pounds/day) 54 lbs. 54 lbs. 82 lbs. 54 lbs.
Exceed Threshold? No No No No
Notes: 1Assumes 365-day operation.
Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations? Project impacts related to increased health risk can occur by generating emissions of TACs and air pollutants. This project would introduce new sources of TACs during construction (e.g., on-site construction and truck hauling emissions) and operation (e.g., mobile sources). Project construction activity would generate dust and equipment exhaust that would affect nearby sensitive receptors. The project would not include stationary sources but would generate some traffic consisting of mostly light-duty gasoline-powered vehicles, which would produce TAC and air pollutant emissions.
Project impacts to existing sensitive receptors were addressed for temporary construction activities and long-term operational conditions. There are also several sources of existing TACs and localized air pollutants in the vicinity of the project. The impact of the existing sources of TACs was assessed in terms of the cumulative risk which includes the project contribution, as well as the risk on the new sensitive receptors introduced by the project.
Health Risk Methodology for Construction and Operation
Health risk impacts were addressed by predicting increased cancer risk, the increase in annual PM2.5 concentrations, and computing the Hazard Index (HI) for non-cancer health risks. The risk impacts from the project are the combination of risk from construction and operation sources.
These sources include on-site construction activity, construction truck hauling, and increased traffic from the project. To evaluate the increased cancer risks from the project, a 30-year exposure period was used, per BAAQMD guidance,12 with the sensitive receptors being exposed to both project construction and operation emissions during this timeframe.
The project increased cancer risk is computed by summing the project construction cancer risk and operation cancer risk contribution. Unlike the increased maximum cancer risk, the annual PM2.5 concentration, and HI values are not additive but based on an annual maximum value for the entirety of the project. The project maximally exposed individual (MEI) is identified as the sensitive receptor that is most impacted by the project’s construction and operation. 12 BAAQMD, 2022. BAAQMD CEQA Air Quality Guidelines Appendix E. April 2023. 372 of 1220
13 The methodology for computing health risks impacts is contained in Appendix E of the BAAQMD CEQA Guidelines. TAC and PM2.5 emissions are calculated, a dispersion model used to estimate ambient pollutant concentrations, and cancer risks and HI calculated using DPM concentrations.
Modeled Sensitive Receptors
Receptors for this assessment included locations where sensitive populations would be present for extended periods of time (i.e., chronic exposures). This includes the nearby existing residences surrounding the project site and the future Cotati Village #1 residences, as shown in Figure 1.13 Residential receptors are assumed to include all receptor groups (e.g., third trimester, infants, children, and adults) with almost continuous exposure to project emissions. While there are additional sensitive receptors within 1,000 feet of the project site, the receptors chosen are adequate to identify maximum impacts from the project.
Health Risks from Project Construction
The primary health risk impact associated with construction projects are cancer risks associated with diesel exhaust (i.e., DPM), which is a known TAC, and exposure to high ambient concentrations of dust (i.e., PM2.5). DPM poses both a potential health and nuisance impact to nearby receptors. A health risk assessment of the project construction activities was conducted that evaluated potential health effects to nearby sensitive receptors from construction emissions of DPM and PM2.5.
14 This assessment included dispersion modeling to predict the offsite and onsite concentrations resulting from project construction, so that increased cancer risks and non-cancer health effects could be estimated.
Construction Emissions
The CalEEMod model provided total uncontrolled annual PM10 exhaust emissions (assumed to be DPM) for the off-road construction equipment and for exhaust emissions from on-road vehicles.
Total DPM emissions were estimated to be 0.04 tons (72 pounds) and fugitive dust emissions (PM2.5) to be 0.09 tons (173 pounds) from all construction stages. The on-road emissions are a result of haul truck travel during grading activities, worker travel, and vendor deliveries during construction. A trip length of half a mile was used to represent vehicle travel while at or near the construction site. It was assumed that the emissions from on-road vehicles traveling at or near the site would occur at the construction site.
Dispersion Modeling
The U.S. EPA’s AERMOD model is the preferred model from predicting DPM and PM2.5 concentrations. Due to the relatively rural nature of the surrounding area, the closest representative BAAQMD AERMOD meteorological data set are for Sonoma County Airport in Santa Rosa which has a quite different winds than the Project site area. Meteorological data collected by BAAQMD is available for Valley Ford, which is considered much more representative of the Project site. Use of this meteorological data set requires use of a slightly different dispersion model. The U.S. EPA 13 Cotati Village #1 is anticipated to be almost completely constructed when construction begins. 14 DPM is identified by California as a toxic air contaminant due to the potential to cause cancer. 373 of 1220
14 ISCST3 dispersion model was used to predict DPM and PM2.5 concentrations at sensitive receptors (residences) in the vicinity of the project construction area. The ISCST3 dispersion model is a BAAQMD-recommended model for use in modeling analysis of these types of emission activities for CEQA projects when meteorological data suitable for use with the AERMOD model are not available.15 Emission sources for the construction site were grouped into two categories: exhaust emissions of DPM and fugitive PM2.5 dust emissions.
Construction Sources
To represent the construction equipment exhaust emissions, an area source emission release height of 20 feet (6 meters) was used for the area sources.16 The release height incorporates both the physical release height from the construction equipment (i.e., the height of the exhaust pipe) and plume rise after it leaves the exhaust pipe. Plume rise is due to both the high temperature of the exhaust and the high velocity of the exhaust gas. It should be noted that when modeling an area source, plume rise is not calculated by the ISCST3 dispersion model as it would do for a point source (exhaust stack). Therefore, the release height from an area source used to represent emissions from sources with plume rise, such as construction equipment, should be based on the height the exhaust plume is expected to achieve, not just the height of the top of the exhaust pipe.
For modeling fugitive PM2.5 emissions, a near-ground level release height of 7 feet (2 meters) was used for the area source. Fugitive dust emissions at construction sites come from a variety of sources, including truck and equipment travel, grading activities, truck loading (with loaders) and unloading (rear or bottom dumping), loaders and excavators moving and transferring soil and other materials, etc. All of these activities result in fugitive dust emissions at various heights at the point(s) of generation. Once generated, the dust plume will tend to rise as it moves downwind across the site and exit the site at a higher elevation than when it was generated. For all these reasons, a 7-foot release height was used as the average release height across the construction site.
Emissions from the construction equipment and on-road vehicle travel were distributed throughout the modeled area sources.
ISCST3 Inputs and Meteorological Data
Health risk impacts from construction were based on the construction emissions computed by CalEEMod and modeled with the ISCST3 model using 5 years of meteorological data (1990-1994) from the BAAQMD Valley Ford meteorological station. The Valley Ford station is about 10 miles west-southwest from the project site. DPM and PM2.5 emissions from construction activities during the 2025 period were modeled as area sources. Concentrations were calculated at nearby residential receptors at receptor heights of 1.5 and 4.5 meters, representative of the breathing heights of residents in first and second floor levels. Construction was assumed to occur for 12 hours per day (7:00am – 7:00pm).
15 BAAQMD, Appendix E of the 2022 BAAQMD CEQA Guidelines, April 2023 16 California Air Resource Board, 2007. Proposed Regulation for In-Use Off-Road Diesel Vehicles, Appendix D:
Health Risk Methodology. April. Web: https://ww3.arb.ca.gov/regact/2007/ordiesl07/ordiesl07.htm 374 of 1220
15 Figure 1. Location of Project Construction Site, Off-Site Sensitive Receptors, and Maximum TAC Impacts (MEI)
Summary of Construction Health Risk Impacts
The maximum increased cancer risks were calculated using the modeled TAC concentrations combined with BAAQMD CEQA guidance for age-sensitivity factors and exposure parameters.
Non-cancer health hazards and maximum PM2.5 concentrations were also calculated and identified.
Age-sensitivity factors reflect the greater sensitivity of infants and small children to cancer causing TACs. Third trimester, infant, child, and adult exposures were assumed to occur at all residences during the entire construction period.
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16 The maximum modeled annual PM2.5 concentration was calculated based on combined exhaust and fugitive concentrations. The maximum computed HI values was based on the ratio of the maximum DPM concentration modeled and the chronic inhalation DPM refence exposure level of 5 µg/m3 .
The modeled maximum annual DPM and PM2.5 concentrations were identified at nearby sensitive receptors to find the MEI from construction activities. Results of this assessment indicated that the cancer risk MEI and annual PM2.5 concentration MEI occurred at the same location on two different floors. The construction cancer risk MEI was located on the second floor (15 feet) of a residence in the southwest corner of the existing townhomes along Alder Avenue. The annual PM2.5 concentration MEI was located at the same location on the first floor (5 feet). The location of the MEIs and nearby sensitive receptors are shown in Figure 1. Table 5 lists the health risks from construction at the location of the residential MEIs. Attachment 2 to this report includes the emission calculations used for the construction modeling and the cancer risk calculations.
Health Risks from Project Operation
The Project would not include stationary sources (e.g., emergency generators) of TACs. Diesel powered vehicles are the primary concern with local traffic-generated TAC impacts. This project would generate 1,773 daily trips or 1,180 net daily trips.17 The project traffic would be dispersed on the roadway system with a majority of the trips being from light-duty vehicles (e.g., passenger automobiles). In addition, projects with the potential to cause or contribute to increased cancer risk from traffic include those that have high numbers of diesel-powered on road trucks or use off-road diesel equipment on site, such as a warehouse distribution center, a quarry, or a manufacturing facility, may potentially expose existing or future planned receptors to substantial cancer risk levels and/or health hazards. This is not a project of concern for mobile sources given the low trip quantity and type of trips generated by the project. Therefore, emissions from project traffic are considered negligible and not included within this analysis.
Summary of Project-Related Health Risks at the Off-Site Project MEIs For this project, the sensitive receptors identified in Figure 1 as the construction MEIs are also the project MEIs. At this location, the MEIs would be exposed to one year of project construction.
The annual PM2.5 concentration and HI values are based on an annual maximum risk for the entirety of the project. As shown in Table 5, the uncontrolled maximum cancer risks and annual PM2.5 concentration from construction activities would exceed their respective BAAQMD singlesource significance thresholds. However, with the implementation of the Condition of Approval (COA) AQ-1, the controlled risk and hazard values would reduce emissions such that cancer risk and PM2.5 concentration caused by construction would no longer exceed the BAAQMD singlesource significance thresholds. The uncontrolled HI does not exceed the BAAQMD single-source significance threshold.
17 Email correspondence from Heather Gurewitz, M-Group., May 23, 2024. Attachment: CV 2-trip generation summary.pdf.
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17 Table 5. Health Risk Impacts at the Off-Site Project MEIs Source
Cancer Risk1
(per million)
Annual PM2.5
1 (µg/m3)
Hazard
Index
Project Construction Without COA
With COA2
16.46 (infant)
4.41 (infant)
0.45 0.16
0.02 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? Without COA
With COA2
Yes
No
Yes
No
No
No
Notes: 1 Maximum cancer risk and PM2.5 concentration occur at the same receptor on different floors. 2 Construction equipment with Tier 4 Interim engines and basic BMPs as COA.
COA AQ-1: Implement a Construction Emissions Minimization Plan that includes dust control measures and use of construction equipment that has low diesel particulate matter exhaust emissions.
To reduce construction emissions and dust generation, the Project shall implement a Construction Minimization Plan. This plan is intended to implement BAAQMD recommended measures to control dust generation and measures to reduce diesel exhaust emissions that may affect nearby residences or other sensitive receptors.
Measures to Control Dust
During any construction period ground disturbance, the applicant shall ensure that the project contractor implements measures to control dust and exhaust that are recommended by BAAQMD and listed below:
1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
4. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph).
5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.
Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
6. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
7. All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
8. Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel. 377 of 1220
18 9. Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations.
The measures above are consistent with BAAQMD-recommended basic BMPs for reducing fugitive dust contained in the BAAQMD CEQA Air Quality Guidelines. For this analysis, only the basic set of BMPs are required.
Measures to Control Exhaust Emissions
The Project will implement feasible measures to reduce diesel particulate matter emissions from new construction by 45 percent such that increased cancer risk from construction would be reduced below TAC significance levels as follows:
1. All construction equipment larger than 25 horsepower used at the site for more than two continuous days or 20 hours total shall meet U.S. EPA Tier 4 emission standards for PM (PM10 and PM2.5), if feasible. If Tier 4 equipment is not available for a particular piece of equipment, then use equipment that meets U.S. EPA emission standards for Tier 2 or 3 engines and include particulate matter emissions control equivalent to CARB Level 3 verifiable diesel emission control devices that altogether achieve a 45 percent reduction in particulate matter exhaust in comparison to uncontrolled equipment; alternatively (or in combination).
2. Alternatively, the applicant may develop another construction operations plan demonstrating that the construction equipment used on-site would achieve a reduction in construction diesel particulate matter emissions by 45 percent or greater. Elements of the plan could include a combination of some of the following measures:
• Installation of electric power lines during early construction phases to avoid use of diesel portable equipment,
• Use of electrically-powered equipment,
• Forklifts and aerial lifts used for exterior and interior building construction shall be electric or propane/natural gas powered,
• Change in construction build-out plans to lengthen phases, and • Implementation of different building techniques that result in less diesel equipment usage.
Such a construction operations plan would be subject to review by an air quality expert and approved by the City prior to construction.
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19 Effectiveness of COA AQ-1:
The Project will implement a Construction Emissions Minimization Plan. This plan would reduce both exhaust and dust (including PM2.5) emissions. The plan includes the use of BAAQMDrecommended measures to minimize dust generation and use of construction equipment that meets U.S. EPA Tier 4 engine standards for particulate matter emissions. Effects of this plan were included in the CalEEMod modeling.
CalEEMod was used to compute emissions associated with the implementation of COA AQ-1, assuming that all equipment meets U.S. EPA Tier 4 interim engines standard and BAAQMD basic BMPs for construction were included. With these measures implemented, the project’s total construction cancer risk levels (assuming infant exposure) would be reduced by 73 percent to 4.41 chances per million and annual PM2.5 concentrations would be reduced by 65 percent to 0.16 µg/m3
. An alternative plan that reduces DPM emissions from construction by 45 percent would reduce total cancer risk to about 9.05 chances per million and annual PM2.5 concentrations to 0.25 µg/m3
, which would be below the BAAQMD single-source significance thresholds. The impact would be reduced to a level of less-than-significant with implementation of COA AQ-1.
Cumulative Health Risks of all TAC Sources at the Off-Site Project MEI Cumulative health risk assessments typically look at all substantial sources of TACs that can affect sensitive receptors located within 1,000 feet of a project site (i.e., influence area). These sources include rail lines, freeways or highways, busy surface streets, and stationary sources identified by BAAQMD.
A review of the project area using BAAQMD’s geographic information systems (GIS) screening maps identified the existing health risks from nearby sources at the MEIs. Highway 116 (S.R. 116) was identified as a potential TAC source that could affect the project MEIs. No existing stationary sources were identified within the influence area. In addition, there is one development project whose potential simultaneous construction would contribute to the cumulative risk. The risk impacts from this development are included within the analysis. Figure 2 shows the location of the sources affecting the MEIs. Health risk impacts from these sources upon the MEIs are reported in Table 6. Details of the cumulative screening and health risk calculations are included in Attachment
3. Highways – S.R.116
The project site is located near S.R. 116 (see Figure 2). Cancer risk, PM2.5 concentrations, and HI associated with traffic on S.R. 116 were estimated using BAAQMD screening values provided via GIS data files (i.e., raster files). BAAQMD raster files provide screening-level cancer risk, PM2.5 concentrations, and HI for roadways within the Bay Area and were produced using AERMOD and 20x20-meter emissions grid. The raster file uses EMFAC2021 data for vehicle emissions and fleet mix for roadways, and includes Appendix E of the Air District’s CEQA Air Quality Guidance for risk assessment assumptions. Note that these values are not adjusted for age sensitivity or exposure duration and are considered higher than values that would be obtained with refined modeling 379 of 1220
20 methods. Screening-level cancer risk, PM2.5 concentration, and HI at the project MEIs were identified using GIS software and are listed in Table 6.
BAAQMD Permitted Stationary Sources
Permitted stationary sources of air pollution near the project site were identified using BAAQMD’s Permitted Stationary Sources 2021 GIS website,18 which identifies the location of nearby stationary sources and their estimated risk and hazard impacts, based on emissions and adjustments to account for OEHHA’s risk guidance. There were no identified sources within the project’s 1,000-foot influence area.
Figure 2. Project Site and Nearby TAC and PM2.5 Sources Construction Risk Impacts from Nearby Developments
The Cotati Village #1 is a potential project located within 1,000 feet of the proposed Project. It would include the construction of six, three-story mixed-use buildings that would consist of 177 residential units, approximately 29,415-sf of retail and office space, and 271 parking spaces. The 18 BAAQMD, Stationary Source Screening Map, 2023. Web:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=845658c19eae4594b9f4b805fb9d89a3 380 of 1220
21 controlled construction risks and hazard values for the nearby development were available from its air quality technical report conducted by Illingworth & Rodin, Inc.Construction of this project is anticipated to be all or almost fully completed prior to construction of the proposed Project. This cumulative analysis conservatively assumed the entire construction period from the proposed project would overlap with the nearby development’s construction schedule. This approach provides an overestimate of the health risk and hazard levels because it assumes that maximum impacts from the nearby development occurs concurrently with the proposed project at the proposed project’s MEIs. The controlled construction risks reported in the applicable air quality assessments were included in Table 6.
Summary of Health Risks at the Project MEI
Table 6 reports both the project and cumulative health risk impacts at the sensitive receptors most affected by the project (i.e., the MEI). The project would have an exceedance with respect to health risk caused by project construction activities, since the maximum uncontrolled cancer risk and annual PM2.5 concentration exceed the BAAQMD single-source thresholds and the annual PM2.5 concentration exceeds the cumulative-source thresholds. With the implementation of COA AQ-1, the project’s cancer risk and PM2.5 concentration would be lowered to levels below the significance thresholds. The HI risk value, which includes uncontrolled and controlled, does not exceed the single- or cumulative source threshold.
Table 6. Cumulative Health Risk Impacts at the Location of the Project MEI Source Cancer Risk
(per million)
Annual PM2.5
(μg/m3)
Hazard
Index
Project Impacts
Project Construction Without COA
With COA
16.46 (infant)
4.41 (infant)
0.45 0.16
0.02 0.01
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? Without COA
With COA
Yes
No
Yes
No No
Cumulative Sources
S.R. 116, BAAQMD Raster Screening Tool 14.17 0.25 0.04
Cotati Village #1 Controlled Construction Impacts 4.50 0.11 <0.01 Combined Sources Without COA
With COA
35.13 23.08
0.81 0.52
<0.07
<0.06
BAAQMD Cumulative Source Threshold 100 0.8 10.0
Exceed Threshold? Without COA
With COA
No
No
Yes
No
No
No
Non-CEQA: On-Site Health Risk Assessment for TAC Sources - New Project Residences The BAAQMD CEQA Air Quality Guidelines recommend that proposed projects that include sensitive receptors address the impacts of nearby sources upon them. In addition, Cotati’s General Plan Policy CON 2.2 requires that projects minimize exposure of sensitive receptors to air pollutants and toxic air contaminants. Therefore, a health risk assessment was completed to assess the impact that the existing TAC sources would have on the new proposed sensitive receptors (i.e., residents) introduced by the project. The same TAC sources identified above were used in this 381 of 1220
22 health risk assessment.19 BAAQMD’s recommended thresholds for health risks and hazards, shown in Table 1, are used to evaluate on-site exposure. All on-site health risk results are listed in Table 7. Attachment 3 includes the screening and risk calculations for TAC source impacts upon the proposed on-site sensitive receptors.
Highways – S.R. 116
The roadway analysis for the project residents was conducted in the same manner with the BAAQMD screening tools as described above for the off-site MEIs. Table 7 shows the health screening results from the roadway.
Stationary Sources
As mentioned above, there are no nearby stationary sources within 1,000 feet of the project site.
Construction Risk Impacts from Nearby Development
Impacts from construction of the nearby development is not included in this portion of the analysis since it is assumed that construction of the Cotati Village #1 development would be completed prior to occupation of the proposed project.
Combined Cumulative Health Risk at Project Site
Health risk impacts from the existing TAC sources upon the project site are reported in Table 7.
The risks from the TAC sources are compared against both the BAAQMD single-source threshold and the cumulative source threshold. As shown, existing sources of TAC emissions do not exceed the BAAQMD single-source or cumulative-source thresholds for cancer risk, annual PM2.5 concentration, or HI.
Table 7. Cumulative Health Risk Impacts Upon the On-site Sensitive Receptors Source Cancer Risk
(per million)
Annual PM2.5
(µg/m3)
Hazard
Index
S.R. 116, BAAQMD Raster Screening Tool 9.48 0.12 0.02
BAAQMD Single-Source Threshold 10 0.3 1.0
Exceed Threshold? No No No
BAAQMD Cumulative Source Threshold 100 0.8 10.0
Exceed Threshold? No No No
19 We note that to the extent this analysis considers existing air quality issues in relation to the impact on future residents of the Project, it does so for informational purposes only pursuant to the judicial decisions in CBIA v.
BAAQMD (2015) 62 Cal.4th 369, 386 and Ballona Wetlands Land Trust v. City of Los Angeles (2011) 201 Cal.App.4th 455, 473, which confirm that the impacts of the environment on a project are excluded from CEQA unless the project itself “exacerbates” such impacts.
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23 GREENHOUSE GAS EMISSIONS
Setting
Gases that trap heat in the atmosphere, GHGs, regulate the earth’s temperature. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate. The most common GHGs are carbon dioxide (CO2) and water vapor but there are also several others, most importantly methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These are released into the earth’s atmosphere through a variety of natural processes and human activities. Sources of GHGs are generally as follows:
CO2, CH4, and N2O are byproducts of fossil fuel combustion. N2O is associated with agricultural operations such as fertilization of crops. CH4 is commonly created by off-gassing from agricultural practices (e.g., keeping livestock) and landfill operations.
Chlorofluorocarbons (CFCs) were widely used as refrigerants, propellants, and cleaning solvents but their production has been stopped by international treaty. HFCs are now used as a substitute for CFCs in refrigeration and cooling. PFCs and sulfur hexafluoride emissions are commonly created by industries such as aluminum production and semi-conductor manufacturing.
Each GHG has its own potency and effect upon the earth’s energy balance. This is expressed in terms of a global warming potential (GWP), with CO2 being assigned a value of 1 and sulfur hexafluoride being several orders of magnitude stronger. In GHG emission inventories, the weight of each gas is multiplied by its GWP and is measured in units of CO2 equivalents (CO2e).
An expanding body of scientific research supports the theory that global climate change is currently affecting changes in weather patterns, average sea level, ocean acidification, chemical reaction rates, and precipitation rates, and that it will increasingly do so in the future. The climate and several naturally occurring resources within California are adversely affected by the global warming trend. Increased precipitation and sea level rise will increase coastal flooding, saltwater intrusion, and degradation of wetlands. Mass migration and/or loss of plant and animal species could also occur. Potential effects of global climate change that could adversely affect human health include more extreme heat waves and heat-related stress; an increase in climate-sensitive diseases; more frequent and intense natural disasters such as flooding, hurricanes and drought; and increased levels of air pollution.
Federal and Statewide GHG Emissions
The U.S. EPA reported that in 2022, total gross nationwide GHG emissions were 5,215.6 million metric tons (MMT) carbon dioxide equivalent (CO2e).20 These emissions were lower than peak levels of 7,416 MMT that were emitted in 2007. CARB updates the statewide GHG emission 20 United States Environmental Protection Agency, 2022. Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2020. February. Web: https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-andsinks 383 of 1220
24 inventory on an annual basis where the latest inventory includes 2000 through 2020 emissions.21 In 2020, GHG emissions from statewide emitting activities were 369.2 MMT CO2e. The 2020 emissions have decreased by 25 percent since peak levels in 2004 and are 35.3 MMT CO2e lower than 2019 emissions level and almost 62 MMT CO2e below the State’s 2020 GHG limit of 431 MMT CO2e. Per capita GHG emissions in California have dropped from a 2001 peak of 13.8 MT CO2e per person to 9.3 MT CO2e per person in 2020.
Recent Regulatory Actions for GHG Emissions
Executive Order S-3-05 – California GHG Reduction Targets Executive Order (EO) S-3-05 was signed by Governor Arnold Schwarzenegger in 2005 to set GHG emission reduction targets for California. The three targets established by this EO are as follows:
(1) reduce California’s GHG emissions to 2000 levels by 2010, (2) reduce California’s GHG emissions to 1990 levels by 2020, and (3) reduce California’s GHG emissions by 80 percent below 1990 levels by 2050.
Assembly Bill 32 – California Global Warming Solutions Act (2006) Assembly Bill (AB) 32, the Global Warming Solutions Act of 2006, codified the State’s GHG emissions target by directing CARB to reduce the State’s global warming emissions to 1990 levels by 2020. AB 32 was signed and passed into law by Governor Schwarzenegger on September 27, 2006. Since that time, the CARB, CEC, California Public Utilities Commission (CPUC), and Building Standards Commission have all been developing regulations that will help meet the goals of AB 32 and Executive Order S-3-05, which has a target of reducing GHG emissions 85 percent below 1990 levels.
The first Scoping Plan for AB 32 was adopted by CARB in December 2008. Its most recent update was completed in December of 202222. It contains the State’s main strategies to achieve carbon neutrality by 2045. This plan extends and expands upon the earlier versions with a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. It also takes the step of adding carbon neutrality as a science-based guide and touchstone for California’s climate work.
Measures to achieve carbon neutrality include rapidly moving to zero emission vehicles (ZEV), removing natural gas as an option for space conditioning, increasing the number of solar arrays and wind turbines, and scaling up renewable hydrogen for hard-to-electrify end uses.
Senate Bill 375 – California's Regional Transportation and Land Use Planning Efforts (2008) California enacted legislation (SB 375) to expand the efforts of AB 32 by controlling indirect GHG emissions caused by urban sprawl. SB 375 provides incentives for local governments and applicants to implement new conscientiously planned growth patterns. This includes incentives for creating attractive, walkable, and sustainable communities and revitalizing existing communities. 21 CARB. 2022. California Greenhouse Gas Emission for 2000 to 2020. Web:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020_ghg_inventory_trends.pdf 22 CARB. 2022. Final 2022 Scoping Plan Update and Appendices. Web: https://ww2.arb.ca.gov/ourwork/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents 384 of 1220
25 The legislation also allows applicants to bypass certain environmental reviews under CEQA if they build projects consistent with the new sustainable community strategies. Development of more alternative transportation options that would reduce vehicle trips and miles traveled, along with traffic congestion, would be encouraged. SB 375 enhances CARB’s ability to reach the AB 32 goals by directing the agency in developing regional GHG emission reduction targets to be achieved from the transportation sector for 2020 and 2035. CARB works with the metropolitan planning organizations (e.g., ABAG and MTC) to align their regional transportation, housing, and land use plans to reduce VMT and demonstrate the region's ability to attain its GHG reduction targets. A similar process is used to reduce transportation emissions of ozone precursor pollutants in the Bay Area.
Senate Bill 350 - Renewable Portfolio Standards
In September 2015, the California Legislature passed SB 350, which increases the states Renewables Portfolio Standard (RPS) for content of electrical generation from the 33 percent target for 2020 to a 50 percent renewables target by 2030.
Executive Order B-30-15 & Senate Bill 32 GHG Reduction Targets – 2030 GHG Reduction Target In April 2015, Governor Brown signed EO B-30-15, which extended the goals of AB 32, setting a GHG emissions target at 40 percent of 1990 levels by 2030. On September 8, 2016, Governor Brown signed Senate Bill (SB) 32, which legislatively established the GHG reduction target of 40 percent of 1990 levels by 2030. In November 2017, CARB issued California’s 2017 Climate Change Scoping Plan.
23 While the State is on track to exceed the AB 32 scoping plan 2020 targets, this plan is an update to reflect the enacted SB 32 reduction target.
SB 32 was passed in 2016, which codified a 2030 GHG emissions reduction target of 40 percent below 1990 levels. CARB has drafted a 2022 Scoping Plan Update to reflect the 2030 target set by Executive Order B-30-15 and codified by SB 32. The 2022 draft plan:
Identifies a path to keep California on track to meet its SB 32 GHG reduction target of at least 40 percent below 1990 emissions by 2030.
Identifies a technologically feasible, cost-effective path to achieve carbon neutrality by 2045 or earlier.
Focuses on strategies for reducing California’s dependency on petroleum to provide consumers with clean energy options that address climate change, improve air quality, and support economic growth and clean sector jobs.
Integrates equity and protecting California’s most impacted communities as a driving principle.
Incorporates the contribution of natural and working lands to the state’s GHG emissions, as well as its role in achieving carbon neutrality.
Relies on the most up to date science, including the need to deploy all viable tools, including carbon capture and sequestration as well a direct air capture. 23 California Air Resource Board, 2017. California’s 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Targets. November. Web:
https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/scoping_plan_2017.pdf 385 of 1220
26 Evaluates multiple options for achieving our GHG and carbon neutrality targets, as well as the public health benefits and economic impacts associated with each.
The Scoping Plan was updated in 2022 and lays out how the state can get to carbon neutrality by 2045 or earlier. It is the first Scoping Plan that adds carbon neutrality as a science-based guide and touchstone beyond statutorily established emission reduction targets.24 The mid-term 2030 target is considered critical by CARB on the path to obtaining an even deeper GHG emissions target of 80 percent below 1990 levels by 2050, as directed in Executive Order S3-05. The 2022 Scoping Plan outlines the suite of policy measures, regulations, planning efforts, and investments in clean technologies and infrastructure, providing a blueprint to continue driving down GHG emissions and to not only obtain the statewide goals, but cost-effectively achieve carbon-neutrality by 2045 or earlier. In the 2022 Scoping Plan, CARB recommends:
VMT per capita reduced 12% below 2019 levels by 2030 and 22% below 2019 levels by 2045.
100% of Light-duty vehicle sales are zero emissions vehicles (ZEV) by 2035. 100% of medium duty/heavy duty vehicle sales are ZEV by 2040. 100% of passenger and other locomotive sales are ZEV by 2030. 100% of line haul locomotive sales are ZEV by 2035.
All electric appliances in new residential and commercial building beginning 2026 (residential) and 2029 (commercial).
80% of residential appliance sales are electric by 2030 and 100% of residential appliance sales are electric by 2035.
80% of commercial appliance sales are electric by 2030 and 100% of commercial appliance sales are electric by 2045.
SB 743 Transportation Impacts
Senate Bill 743 required lead agencies to abandon the old “level of service” metric for evaluating a project’s transportation impacts, which was based solely on the amount of delay experienced by motor vehicles. In response, the Governor’s Office of Planning and Research (OPR) developed a VMT metric that considered other factors such as reducing GHG emissions and developing multimodal transportation25. A VMT-per-capita metric was adopted into the CEQA Guidelines Section 15064.3 in November 2017. Given current baseline per-capita VMT levels computed by CARB in the 2030 Scoping Plan of 22.24 miles per day for light-duty vehicles and 24.61 miles per day for all vehicle types, the reductions needed to achieve the 2050 climate goal are 16.8 percent for light-duty vehicles and 14.3 percent for all vehicle types combined. Based on this analysis (as well as other factors), OPR recommended using a 15-percent reduction in per capita VMT as an appropriate threshold of significance for evaluating transportation impacts. 24 https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022-scoping-plan-documents 25 Governor’s Office of Planning and Research. 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December.
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27 Executive Order B-55-18 – Carbon Neutrality
In 2018, a new statewide goal was established to achieve carbon neutrality as soon as possible, but no later than 2045, and to maintain net negative emissions thereafter. CARB and other relevant state agencies are tasked with establishing sequestration targets and creating policies/programs that would meet this goal.
Senate Bill 100 – Current Renewable Portfolio Standards In September 2018, SB 100 was signed by Governor Brown to revise California’s RPS program goals, furthering California’s focus on using renewable energy and carbon-free power sources for its energy needs. The bill would require all California utilities to supply a specific percentage of their retail sales from renewable resources by certain target years. By December 31, 2024, 44 percent of the retails sales would need to be from renewable energy sources, by December 31, 2026 the target would be 40 percent, by December 31, 2027 the target would be 52 percent, and by December 31, 2030 the target would be 60 percent. By December 31, 2045, all California utilities would be required to supply retail electricity that is 100 percent carbon-free and sourced from eligible renewable energy resources to all California end-use customers.
California Building Standards Code – Title 24 Part 11 & Part 6 The California Green Building Standards Code (CALGreen Code) is part of the California Building Standards Code under Title 24, Part 11.26 The CALGreen Code encourages sustainable construction standards that involve planning/design, energy efficiency, water efficiency resource efficiency, and environmental quality. These green building standard codes are mandatory statewide and are applicable to residential and non-residential developments. The most recent CALGreen Code (2022 California Building Standard Code) was effective as of January 1, 2023.
The California Building Energy Efficiency Standards (California Energy Code) is under Title 24, Part 6 and is overseen by the California Energy Commission (CEC). This code includes design requirements to conserve energy in new residential and non-residential developments, while being cost effective for homeowners. This Energy Code is enforced and verified by cities during the planning and building permit process. The current energy efficiency standards (2022 Energy Code) replaced the 2019 Energy Code as of January 1,2023. Under the 2019 standards, single-family homes are predicted to be 53 percent more efficient than homes built under the 2016 standard due more stringent energy-efficiency standards and mandatory installation of solar photovoltaic systems. For nonresidential developments, it is predicted that these buildings will use 30 percent less energy due to lightening upgrades.27
Requirements for electric vehicle (EV) charging infrastructure are set forth in Title 24 of the California Code of Regulations. The CALGreen standards consist of a set of mandatory standards required for new development, as well as two more voluntary standards known as Tier 1 and Tier
2. The CalGreen 2022 standards require deployment of additional EV chargers in various building 26 See: https://www.dgs.ca.gov/BSC/Resources/Page-Content/Building-Standards-Commission-Resources-ListFolder/CALGreen#:~:text=CALGreen%20is%20the%20first%2Din,to%201990%20levels%20by%202020. 27 See: https://www.energy.ca.gov/sites/default/files/2020-03/Title_24_2019_Building_Standards_FAQ_ada.pdf 387 of 1220
28 types, including multifamily residential and nonresidential land uses. They include requirements for both EV capable parking spaces and the installation of Level 2 EV supply equipment for multifamily residential and nonresidential buildings. The 2022 CALGreen standards include requirements for both EV readiness, installation of EV chargers, and include both mandatory requirements and more aggressive voluntary Tier 1 and Tier 2 provisions. Providing EV charging infrastructure that meets current CALGreen requirements will not be sufficient to power the anticipated more extensive level of EV penetration in the future that is needed to meet SB 30 climate goals.
CEC studies have identified the most aggressive electrification scenario as putting the building sector on track to reach the carbon neutrality goal by 2045.28 Installing new natural gas infrastructure in new buildings will interfere with this goal. To meet the State’s goal, communities have been adopting “Reach” codes that prohibit natural gas connections in new and remodeled buildings.
Advanced Clean Cars
The Advanced Clean Cars Program, originally adopted by CARB in 2012, was designed to bring together CARB’s traditional passenger vehicle requirements to meet federal air quality standards and also support California’s AB 32 goals to develop and implement programs to reduce GHG emissions back down to 1990 levels by 2020, a goal achieved in 2016 as a result of numerous emissions reduction programs.
Advanced Clean Cars II (ACC II) is phase two of the original rule. ACC II establishes a year-byyear process, starting in 2026, so all new cars and light trucks sold in California will be zeroemission vehicles by 2035, including plug-in hybrid electric vehicles. The regulation codifies the light-duty vehicle goals set out in Governor Newsom’s Executive Order N-79-20. Currently, 16 percent of new light-duty vehicles sold in California are zero emissions or plug-in hybrids. By 2030, 68 percent of new vehicles sold in California would be zero emissions and 100 percent by 2035.
City of Cotati
The City of Cotati currently has no adopted Climate Action Plan (CAP); however, Cotati General Plan Policy CON2.8 supports the development and implementation of a CAP. The City is involved in Sonoma County’s efforts to reduce countywide emissions to 25% below 1990 emissions by 2020.29
28 California Energy Commission. 2021. Final Commission Report: California Building Decarbonization Assessment. Publication Number CEC-400-2021-006-CMF.August 29 City of Cotati, 2016. Cotati Commitments to meeting community greenhouse gas reduction goals. Accessed October 10,2022. Web: https://www.cotaticity.org/DocumentCenter/View/255/Climate-Action-PDF 388 of 1220
29 BAAQMD GHG Significance Thresholds
On April 20, 2022, BAAQMD adopted new thresholds of significance for operational GHG emissions from land use projects for projects beginning the CEQA process. The following framework is how BAAQMD will determine GHG significance moving forward.30 Note BAAQMD intends that the thresholds apply to projects that begin the CEQA process after adoption of the thresholds, unless otherwise directed by the lead agency. The new thresholds of significance are:
A. Projects must include, at a minimum, the following project design elements:
a. Buildings
i. The project will not include natural gas appliances or natural gas plumbing (in both residential and non-residential development).
ii. The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.
b. Transportation
i. Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA:
1. Residential Projects: 15 percent below the existing VMT per capita
2. Office Projects: 15 percent below the existing VMT per employee
3. Retail Projects: no net increase in existing VMT
ii. Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.
B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).
Any new land use project would have to include either section A or B from the above list, not both, to be considered in compliance with BAAQMD’s GHG thresholds of significance.
Impact GHG-1: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
GHG emissions associated with development of the proposed project would occur over the shortterm from construction activities, consisting primarily of emissions from equipment exhaust and worker and vendor trips. There would also be long-term operational emissions associated with vehicular traffic within the project vicinity, energy and water usage, and solid waste disposal.
Emissions for the proposed project are discussed below. 30 Justification Report: BAAQMD CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Project and Plans. Web: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-thresholds2022/justification-report-pdf.pdf?la=en 389 of 1220
30 CalEEMod Modeling
CalEEMod was used to predict GHG emissions from operation of the site assuming full build-out of the project. The project land use types and size and other project-specific information were input to the model, as described above within the construction period emissions. CalEEMod output is included in Attachment 1.
Construction GHG Emissions
GHG emissions associated with construction were computed at 240 MT of CO2e for the total construction period. These are the emissions from on-site operation of construction equipment, vendor and hauling truck trips, and worker trips. Neither the City nor BAAQMD have an adopted threshold of significance for construction-related GHG emissions, though the California Office of Planning and Research (OPR) recommends quantifying emissions and disclosing that GHG emissions would occur during construction, even in cases where BAAQMD does not. BAAQMD encourages the incorporation of best management practices to reduce GHG emissions during construction where feasible and applicable.
Operational GHG Emissions
The CalEEMod model, along with the project vehicle trip generation rates, were used to estimate daily emissions associated with operation of the proposed project. As shown in Table 8 for informational purposes, annual GHG emissions resulting from operation of the proposed project are predicted to be 1,488 MT of CO2e in 2026.
Table 8. Annual Project GHG Emissions (CO2e) in Metric Tons Source Category Proposed Project in 2026
Mobile 1,427
Area 2
Energy Consumption 19
Water Usage 3
Solid Waste Generation 37
Total (MT CO2e/year) 1,488
There are no quantified thresholds for GHG emissions adopted by the City or currently used by BAAQMD for evaluation of project GHG emissions. BAAQMD in their latest adopted GHG thresholds recommend that the significance of project GHG emissions be evaluated based on consistency with an adopted GHG reduction plan or meet design elements that are critical in reducing GHG emissions. As described above, the City has not adopted a CAP but has met design elements that will reduce GHG emissions such as Title 24 and Cal Green Tier 1 compliance, all electric appliances, and the required amount of EV parking spaces.
The Project generally meets the requirements for Project thresholds identified above by BAAQMD. To avoid interference with statewide GHG reduction measures identified in CARB’s Scoping Plan and SB 100 goals, the project would include the following standard requirements:
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31 1. Avoid construction of new natural gas connections for the residential buildings, Conforms – the applicant has confirmed that the project will be all electric and not include natural gas infrastructure.
2. Avoid wasteful or inefficient use of electricity,
Conforms – would meet CALGreen Building Standards Code requirements that are considered to be energy efficient.
3. Include electric vehicle (EV) charging infrastructure that meets current Building Code CALGreen Tier 2 compliance, and
Does Not Conform – project will provide EV parking spaces as required by Cotati Municipal Code 14.04.130, which only meets the CalGreen Tier 1 requirements for EV parking and charging infrastructure.
4. Reduce VMT per service population by 15 percent over regional average. Conforms – According to the traffic analysis,31 the project daily VMT per capita is
14.6 miles, which is lower than the significance threshold of 15.5 miles. The retail coffee shop screens out because it is considered to be local serving retail and would not increase total VMT.
COA GHG-1: Include EV parking and charging infrastructure that would meet CalGreen Tier 2 requirements.
The applicant and City shall develop a plan to include EV charging stations and infrastructure to meet the general requirements of CalGreen Tier 2, which is the threshold used by BAAQMD to judge GHG impacts from new land use projects.
Effectiveness of COA GHG-1:
With appropriate EV charging stations and infrastructure implemented, the project would meet all the GHG requirements and conform with Threshold A.
Impact GHG-2: Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The proposed Project buildings would be constructed in conformance with CALGreen, the Title 24 Building Code, and the City’s General Plan, which requires high-efficiency water fixtures, water-efficient irrigation systems, and compliance with current energy efficacy standards. The Project would not interfere with City or State efforts to reduce GHG emissions.
Conclusions
The purpose of this report is to address air quality, health risk, and greenhouse gas (GHG) impacts associated with the construction and operation of this proposed Cotati Village #2 project. Air quality impacts from this project would be associated with the demolition/grading of the existing land uses, construction of the new building and infrastructure, and operation of the project. Air 31 Email correspondence from Heather Gurewitz, M-Group and Barry Bergman, W-Trans, May 28, 2024. 391 of 1220
32 pollutants and GHG emissions associated with construction and operation of the project were predicted using appropriate computer models. In addition, the potential project health risk impacts (includes construction and operation) and the impact of existing toxic air contaminant (TAC) sources affecting the nearby and proposed sensitive receptors were evaluated. The analysis was conducted following guidance provided by BAAQMD. Findings of this report are as follows:
Emissions of criteria air pollutants from construction and operation of the Project were modeled to be below thresholds recommended by BAAQMD that are used to judge the significance in terms of burden to air basin-wide emissions. Construction period emissions of diesel particulate matter, which is a TAC, are above BAAQMD project-level thresholds. COA AQ-1 would reduce emissions of diesel particulate matter and dust. COA AQ-1 would reduce TAC emissions by 73 percent or more and dust emissions by 65 percent or more. This would reduce the impact to a level of lessthan-significant. Operation of the Project is not anticipated to result in substantial localized TAC emissions that would cause or contribute to significant impacts. The Project would meet three of the four GHG thresholds by not having significant VMT impacts, would be all electric, and constructed to meet current CalGreen standards that would make it energy efficient. However, the Project would only meet the City’s CalGreen Tier 1 requirements for EV parking and charging infrastructure and not CalGreen Tier 2 as required by the BAAQMD GHG threshold. COA GHG-1 would require CalGreen Tier 2 for EV parking and charging infrastructure, and then the project would meet all the GHG requirements and conform with Threshold A.
Supporting Documentation
Attachment 1 includes the CalEEMod output for project construction and operational criteria air pollutant. Also included are any modeling assumptions.
Attachment 2 is the health risk assessment. This includes the summary of the dispersion modeling and the cancer risk calculations for construction. The ISCST3 dispersion modeling files for this assessment, which are quite voluminous, are available upon request and would be provided in digital format.
Attachment 3 includes the cumulative screening results and health risk calculations from sources affecting the MEIs and project sensitive receptors.
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Attachment 1: CalEEMod Modeling Inputs and Outputs
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Unmitigated ROG NOX PM10 Exhaust PM2.5 Exhaust PM2.5 Fugitive CO2e Year MT
2025 1.13 0.93 0.04 0.03 0.10 239.90
Tons 1.13 0.93 0.04 0.03 239.90
Pounds/Workdays
2025 10.43 8.57 0.34 0.31 216
Threshold ‐ lbs/day 54.0 54.0 82.0 54.0
Pounds 2252.95 1850.66 72.72 66.99 0.00
Average 10.43 8.57 0.34 0.31 0.00 216.00
Threshold ‐ lbs/day 54.0 54.0 82.0 54.0
Unmitigated ROG NOX Total PM10 Total PM2.5
Year
Total 1.68 0.96 1.38 0.36
Total
Tons/year 1.68 0.96 1.38 0.36
Threshold ‐ Tons/year 10.0 10.0 15.0 10.0
Pounds Per Day 9.20 5.27 7.55 1.98
Threshold ‐ lbs/day 54.0 54.0 82.0 54.0
Category
Project Existing Project 2030 Existing
Mobile 1426.23
Area 1.60
Energy 18.88
Water 3.33
Waste 37.22
Refrig. 0.75
TOTAL 1488.00 0.00 0.00 0.00
Net GHG Emissions 1488.00 0.00
2025 1/5/2025 11/1/2025 301 216
301 216 Total Workdays
Phase Start Date End Date Days/Week Workdays
Demolition 1/5/2025 1/7/2025 5 2
Site Preparation 1/8/2025 2/9/2025 5 23
Grading 2/10/2025 3/3/2025 5 16
Building Construction 3/21/2025 9/15/2025 5 127
Paving 10/11/2025 11/1/2025 5 15
Architectural Coating 9/16/2025 10/10/2025 5 19
Trenching 3/4/2025 3/20/2025 5 13
Number of Days Per Year
Existing Use Emissions
Net Annual Operational Emissions
Average Daily Emissions
CO2e
Tons
Total Construction Emissions
Construction Equipment
Construction Criteria Air Pollutants
Tons
Average Daily Emissions Workdays
Total Construction Emissions
Operational Criteria Air Pollutants
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Air Quality/Noise Construction Information Data Request Project Name: Cotati Village #2 See Equipment Type TAB for type, horsepower and load factor Project Size 126 Dwelling Units 4 total project acres disturbed 141,680 s.f. residential Pile Driving? Y/N? NO
s.f. retail
2250 s.f. office/commercial
Project include on-site GENERATOR OR FIRE PUMP during project OPERATION (not construction)? Y/N? NO
s.f. other, specify: IF YES (if BOTH separate values) --> s.f. parking garage spaces Kilowatts/Horsepower: __________ s.f. parking lot 168 spaces Fuel Type: _____________
Construction Days (i.e, M-F) Monday to Friday Location in project (Plans Desired if Available):
Construction Hours 7 am to 7 pm
DO NOT MULTIPLY EQUIPMENT HOURS/DAY BY THE QUANTITY OF EQUIPMENT Quantity Description HP Load Factor Hours/day
Total
Work
Days
Avg.
Hours per
day
HP
Annual
Hours Comments
Demolition Start Date: 1/5/2025 Total phase: 2 Overall Import/Export Volumes End Date: 1/7/2025
1 Concrete/Industrial Saws 81 0.73 0 0 Demolition Volume 3 Excavators 158 0.38 0 0 Square footage of buildings to be demolished 2 Rubber-Tired Dozers 247 0.4 0 0 (or total tons to be hauled) Tractors/Loaders/Backhoes 97 0.37 8 2 8 0 1200 square feet or Other Equipment? 0 Hauling volume (tons)
Any pavement demolished and hauled? _0_ tons
Site Preparation Start Date: 1/8/2025 Total phase: 22
End Date: 2/9/2025
Graders 187 0.41 0 0
3 Rubber Tired Dozers 247 0.4 8 11 4 26083
4 Tractors/Loaders/Backhoes 97 0.37 8 11 4 12633
Other Equipment?
Grading / Excavation Start Date: 2/10/2025 Total phase: 13 End Date: 3/3/2025 Soil Hauling Volume
1 Excavators 158 0.38 8 13 8 6244 Export volume = 0 cubic yards? 1 Graders 187 0.41 8 13 8 7974 Import volume = 1200 cubic yards? 1 Rubber Tired Dozers 247 0.4 8 13 8 10275
Concrete/Industrial Saws 81 0.73 0 0
3 Tractors/Loaders/Backhoes 97 0.37 8 13 8 11198
Other Equipment?
Trenching/Foundation Start Date: 3/4/2025 Total phase: 12 End Date: 3/20/2025
1 Tractor/Loader/Backhoe 97 0.37 8 12 8 3445
1 Excavators 158 0.38 8 12 8 5764
Other Equipment?
Building - Exterior Start Date: 3/21/2025 Total phase: 121 Cement Trucks? _90_ Total Round-Trips End Date: 9/15/2025
1 Cranes 231 0.29 7 0 0 0 Electric? (Y/N) ___ Otherwise assumed diesel 3 Forklifts 89 0.2 8 121 8 51691 Liquid Propane (LPG)? (Y/N) ___ Otherwise Assumed diesel 1 Generator Sets 84 0.74 8 121 8 60171 Or temporary line power? (Y/N) Y 3 Tractors/Loaders/Backhoes 97 0.37 7 121 7 91196
1 Welders 46 0.45 8 121 8 20038
Other Equipment?
Building - Interior/Architectural Coating Start Date: 9/16/2025 Total phase: 18 End Date: 10/10/2025
1 Air Compressors 78 0.48 6 18 6 4044
Aerial Lift 62 0.31 0 0
Other Equipment?
Paving Start Date: 10/11/2025 Total phase: 14
Start Date: 11/1/2025
Cement and Mortar Mixers 9 0.56 0 0
2 Pavers 130 0.42 8 14 8 12230
2 Paving Equipment 132 0.36 8 14 8 10644
2 Rollers 80 0.38 8 14 8 6810
Tractors/Loaders/Backhoes 97 0.37 0 0
Other Equipment?
Additional Phases Start Date: 1/5/2025 Total phase: 202 Start Date: 11/1/2025
00 00
00 00
00 Equipment types listed in "Equipment Types" worksheet tab.
Equipment listed in this sheet is to provide an example of inputs Complete one sheet for each project component It is assumed that water trucks would be used during grading Add or subtract phases and equipment, as appropriate
Modify horsepower or load factor, as appropriate
Complete ALL Portions in Yellow
Asphalt? 499 cubic yards or ____ round trips?
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Land Use Size Daily Trips New Trips Weekday Trip Gen Weekday Sat Sun Retail ‐ Coffee Shop ksf 2.25 1201 642 285.33 346.23 696 500 Internal Capture Reduction ‐34 Rev 573.58 412.06
Diverted Reduction ‐525
Mid‐Rise Residential DU 126 572 538 4.27 5.44 4.91 4.09 Internal Capture Reduction ‐34 Rev 3.85 3.21
Total 1180
Traffic Consultant Trip Gen CalEEMod Default
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24-049 Cotati Village #2 BMPs T4i 2026 Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.3. Construction Emissions by Year, Mitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
2.6. Operations Emissions by Sector, Mitigated
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
3.2. Demolition (2025) - Mitigated
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3.3. Site Preparation (2025) - Unmitigated
3.4. Site Preparation (2025) - Mitigated
3.5. Grading (2025) - Unmitigated
3.6. Grading (2025) - Mitigated
3.7. Building Construction (2025) - Unmitigated
3.8. Building Construction (2025) - Mitigated
3.9. Paving (2025) - Unmitigated
3.10. Paving (2025) - Mitigated
3.11. Architectural Coating (2025) - Unmitigated
3.12. Architectural Coating (2025) - Mitigated
3.13. Trenching (2025) - Unmitigated
3.14. Trenching (2025) - Mitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.1.2. Mitigated
4.2. Energy
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4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.2. Electricity Emissions By Land Use - Mitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.2.4. Natural Gas Emissions By Land Use - Mitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.3.2. Mitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.4.2. Mitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.5.2. Mitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.6.2. Mitigated
4.7. Offroad Emissions By Equipment Type
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4.7.1. Unmitigated
4.7.2. Mitigated
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
4.8.2. Mitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.9.2. Mitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated
5. Activity Data
5.1. Construction Schedule
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5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2. Mitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.3.2. Mitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.9.2. Mitigated
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5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.1.2. Mitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.10.4. Landscape Equipment - Mitigated
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.11.2. Mitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.12.2. Mitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.13.2. Mitigated
5.14. Operational Refrigeration and Air Conditioning Equipment 402 of 1220
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5.14.1. Unmitigated
5.14.2. Mitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.15.2. Mitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
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5.18.2.1. Unmitigated
5.18.2.2. Mitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name 24-049 Cotati Village #2 BMPs T4i 2026
Construction Start Date 1/5/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.20
Precipitation (days) 9.60
Location 7515 Alder Ave, Cotati, CA 94931, USA
County Sonoma-San Francisco
City Cotati
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 972
EDFZ 2
Electric Utility Sonoma Clean Power
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.23
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
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Apartments Mid Rise 126 Dwelling Unit 4.00 141,680 24,302 0.00 323 — Fast Food
Restaurant w/o Drive
Thru
2.25 1000sqft 0.00 2,250 0.00 — — —
Parking Lot 168 Space 0.00 0.00 0.00 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-5 Use Advanced Engine Tiers
Construction C-10-A Water Exposed Surfaces
Construction C-11 Limit Vehicle Speeds on Unpaved Roads
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Unmit. 106 8.19 0.31 0.88 1.19 0.28 0.21 0.50 2,870
Mit. 106 8.36 0.11 0.88 0.99 0.10 0.21 0.32 2,870
% Reduced < 0.5% -2% 65% — 17% 64% — 37% —
Daily, Winter (Max) — — — — — — — — —
Unmit. 106 17.4 0.73 9.97 10.7 0.67 5.09 5.71 3,842
Mit. 106 11.4 0.11 3.98 4.03 0.10 2.00 2.05 3,842
% Reduced < 0.5% 35% 85% 60% 62% 85% 61% 64% —
Average Daily
(Max)
— — — — — — — — —
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Unmit. 6.17 5.07 0.20 1.28 1.48 0.18 0.55 0.74 1,449
Mit. 5.83 4.34 0.05 0.71 0.77 0.05 0.27 0.32 1,449
% Reduced 6% 14% 74% 44% 48% 73% 52% 57% —
Annual (Max) — — — — — — — — —
Unmit. 1.13 0.93 0.04 0.23 0.27 0.03 0.10 0.13 240
Mit. 1.06 0.79 0.01 0.13 0.14 0.01 0.05 0.06 240
% Reduced 6% 14% 74% 44% 48% 73% 52% 57% —
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily - Summer
(Max)
— — — — — — — — —
2025 106 8.19 0.31 0.88 1.19 0.28 0.21 0.50 2,870
Daily - Winter
(Max)
— — — — — — — — —
2025 106 17.4 0.73 9.97 10.7 0.67 5.09 5.71 3,842
Average Daily — — — — — — — — —
2025 6.17 5.07 0.20 1.28 1.48 0.18 0.55 0.74 1,449
Annual — — — — — — — — —
2025 1.13 0.93 0.04 0.23 0.27 0.03 0.10 0.13 240
2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily - Summer
(Max)
— — — — — — — — —
2025 106 8.36 0.11 0.88 0.99 0.10 0.21 0.32
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Daily - Winter
(Max)
— — — — — — — — —
2025 106 11.4 0.11 3.98 4.03 0.10 2.00 2.05 3,842
Average Daily — — — — — — — — —
2025 5.83 4.34 0.05 0.71 0.77 0.05 0.27 0.32 1,449
Annual — — — — — — — — —
2025 1.06 0.79 0.01 0.13 0.14 0.01 0.05 0.06 240
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Unmit. 12.2 6.95 0.12 10.8 10.9 0.11 2.75 2.86 13,341
Daily, Winter (Max) — — — — — — — — —
Unmit. 11.2 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,677
Average Daily
(Max)
— — — — — — — — —
Unmit. 9.20 5.27 0.08 7.47 7.55 0.08 1.90 1.98 8,988
Annual (Max) — — — — — — — — —
Unmit. 1.68 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,488
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Mobile 7.91 6.88 0.11 10.8 10.9 0.11 2.75 2.86 12,958
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Area 4.28 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6 Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 12.2 6.95 0.12 10.8 10.9 0.11 2.75 2.86 13,341
Daily, Winter (Max) — — — — — — — — —
Mobile 7.56 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,313
Area 3.63 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 11.2 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,677
Average Daily — — — — — — — — —
Mobile 5.24 5.24 0.08 7.47 7.55 0.07 1.90 1.98 8,614
Area 3.95 0.03 < 0.005 — < 0.005 < 0.005 — < 0.005 9.66 Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 9.20 5.27 0.08 7.47 7.55 0.08 1.90 1.98 8,988
Annual — — — — — — — — —
Mobile 0.96 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,426
Area 0.72 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60 Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 18.9
Water — — — — — — — — 3.33
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Waste — — — — — — — — 37.2
Refrig. — — — — — — — — 0.75
Total 1.68 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,488
2.6. Operations Emissions by Sector, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Mobile 7.91 6.88 0.11 10.8 10.9 0.11 2.75 2.86 12,958
Area 4.28 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6 Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 12.2 6.95 0.12 10.8 10.9 0.11 2.75 2.86 13,341
Daily, Winter (Max) — — — — — — — — —
Mobile 7.56 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,313
Area 3.63 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 11.2 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,677
Average Daily — — — — — — — — —
Mobile 5.24 5.24 0.08 7.47 7.55 0.07 1.90 1.98 8,614
Area 3.95 0.03 < 0.005 — < 0.005 < 0.005 — < 0.005 9.66 410 of 1220
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Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 114
Water — — — — — — — — 20.1
Waste — — — — — — — — 225
Refrig. — — — — — — — — 4.53
Total 9.20 5.27 0.08 7.47 7.55 0.08 1.90 1.98 8,988
Annual — — — — — — — — —
Mobile 0.96 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,426
Area 0.72 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60 Energy 0.00 0.00 0.00 — 0.00 0.00 — 0.00 18.9
Water — — — — — — — — 3.33
Waste — — — — — — — — 37.2
Refrig. — — — — — — — — 0.75
Total 1.68 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,488
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.11 1.10 0.04 — 0.04 0.04 — 0.04 291
Demolition — — — 0.59 0.59 — 0.09 0.09 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — —
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Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.26 Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.01 0.01 0.00 0.02 0.02 0.00 < 0.005 < 0.005 20.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.77 0.01 0.13 0.13 0.01 0.04 0.04 559
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.11 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.07 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.51
3.2. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D
PM2.5T CO2e 412 of 1220
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Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.04 1.18 0.01 — 0.01 0.01 — 0.01 291
Demolition — — — 0.59 0.59 — 0.09 0.09 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.26 Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.01 0.01 0.00 0.02 0.02 0.00 < 0.005 < 0.005 20.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.77 0.01 0.13 0.13 0.01 0.04 0.04 559
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.11 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 3.07 413 of 1220
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Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.51
3.3. Site Preparation (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
1.66 15.8 0.68 — 0.68 0.63 — 0.63 2,657
Dust From Material
Movement
— — — 9.83 9.83 — 5.05 5.05 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.10 1.00 0.04 — 0.04 0.04 — 0.04 167
Dust From Material
Movement
— — — 0.62 0.62 — 0.32 0.32 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.02 0.18 0.01 — 0.01 0.01 — 0.01 27.7
Dust From Material
Movement
— — — 0.11 0.11 — 0.06 0.06 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — —
—
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Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.07 0.07 0.00 0.14 0.14 0.00 0.03 0.03 144
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 9.17 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.52 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.4. Site Preparation (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.32 7.37 0.05 — 0.05 0.05 — 0.05 2,657
Dust From Material
Movement
— — — 3.83 3.83 — 1.97 1.97 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
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Off-Road 0.02 0.46 < 0.005 — < 0.005 < 0.005 — < 0.005 167 Equipment
Dust From Material
Movement
— — — 0.24 0.24 — 0.12 0.12 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 27.7
Dust From Material
Movement
— — — 0.04 0.04 — 0.02 0.02 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.07 0.07 0.00 0.14 0.14 0.00 0.03 0.03 144
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 9.17 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.52 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 416 of 1220 24-049 Cotati Village #2 BMPs T4i 2026 Detailed Report, 5/23/2024 21 / 74
Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
1.74 16.3 0.72 — 0.72 0.66 — 0.66 2,970
Dust From Material
Movement
— — — 7.09 7.09 — 3.43 3.43 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.08 0.71 0.03 — 0.03 0.03 — 0.03 130
Dust From Material
Movement
— — — 0.31 0.31 — 0.15 0.15 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.01 0.13 0.01 — 0.01 0.01 — 0.01 21.6
Dust From Material
Movement
— — — 0.06 0.06 — 0.03 0.03 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.06 0.00 0.12 0.12 0.00 0.03 0.03 123
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 1.04 0.01 0.17 0.18 0.01 0.05 0.06 749
Average Daily — — — — — — — — —
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Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.47 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.04 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 32.9 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.91 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.44
3.6. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.39 10.3 0.08 — 0.08 0.08 — 0.08 2,970
Dust From Material
Movement
— — — 2.76 2.76 — 1.34 1.34 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.02 0.45 < 0.005 — < 0.005 < 0.005 — < 0.005 130
Dust From Material
Movement
— — — 0.12 0.12 — 0.06 0.06 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 21.6
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Dust From Material
Movement
— — — 0.02 0.02 — 0.01 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.06 0.00 0.12 0.12 0.00 0.03 0.03 123
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 1.04 0.01 0.17 0.18 0.01 0.05 0.06 749
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.47 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.04 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 32.9 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.91 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.44
3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.80 7.24 0.30 — 0.30 0.28 — 0.28 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
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Off-Road
Equipment
0.80 7.24 0.30 — 0.30 0.28 — 0.28 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.28 2.52 0.11 — 0.11 0.10 — 0.10 535
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.05 0.46 0.02 — 0.02 0.02 — 0.02 88.5
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.37 0.28 0.00 0.76 0.76 0.00 0.18 0.18 812
Vendor 0.01 0.51 0.01 0.10 0.10 0.01 0.03 0.03 402
Hauling < 0.005 0.16 < 0.005 0.03 0.03 < 0.005 0.01 0.01 119 Daily, Winter (Max) — — — — — — — — —
Worker 0.36 0.37 0.00 0.76 0.76 0.00 0.18 0.18 754
Vendor 0.01 0.54 0.01 0.10 0.10 0.01 0.03 0.03 401
Hauling < 0.005 0.16 < 0.005 0.03 0.03 < 0.005 0.01 0.01 119 Average Daily — — — — — — — — —
Worker 0.12 0.12 0.00 0.26 0.26 0.00 0.06 0.06 265
Vendor < 0.005 0.18 < 0.005 0.03 0.04 < 0.005 0.01 0.01 140 Hauling < 0.005 0.06 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 41.4 Annual — — — — — — — — —
Worker 0.02 0.02 0.00 0.05 0.05 0.00 0.01 0.01 43.9
Vendor < 0.005 0.03 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 23.1 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.86 420 of 1220
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3.8. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.32 7.41 0.10 — 0.10 0.10 — 0.10 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.32 7.41 0.10 — 0.10 0.10 — 0.10 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.11 2.58 0.04 — 0.04 0.03 — 0.03 535
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.02 0.47 0.01 — 0.01 0.01 — 0.01 88.5
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.37 0.28 0.00 0.76 0.76 0.00 0.18 0.18 812
Vendor 0.01 0.51 0.01 0.10 0.10 0.01 0.03 0.03 402
Hauling < 0.005 0.16 < 0.005 0.03 0.03 < 0.005 0.01 0.01 119 Daily, Winter (Max) — — — — — — — — —
Worker 0.36 0.37 0.00 0.76 0.76 0.00 0.18 0.18 754
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Vendor 0.01 0.54 0.01 0.10 0.10 0.01 0.03 0.03 401
Hauling < 0.005 0.16 < 0.005 0.03 0.03 < 0.005 0.01 0.01 119 Average Daily — — — — — — — — —
Worker 0.12 0.12 0.00 0.26 0.26 0.00 0.06 0.06 265
Vendor < 0.005 0.18 < 0.005 0.03 0.04 < 0.005 0.01 0.01 140 Hauling < 0.005 0.06 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 41.4 Annual — — — — — — — — —
Worker 0.02 0.02 0.00 0.05 0.05 0.00 0.01 0.01 43.9
Vendor < 0.005 0.03 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 23.1 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 6.86
3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.67 6.38 0.30 — 0.30 0.28 — 0.28 1,296
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.03 0.26 0.01 — 0.01 0.01 — 0.01 53.3
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — —
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Off-Road
Equipment
0.01 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 8.82
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.06 0.00 0.12 0.12 0.00 0.03 0.03 123
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.94 0.01 0.15 0.16 0.01 0.04 0.05 683
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.13 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.04 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 28.1 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.85 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.65
3.10. Paving (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.20 6.05 0.07 — 0.07 0.06 — 0.06 1,296
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Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.25 < 0.005 — < 0.005 < 0.005 — < 0.005 53.3
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 8.82
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.06 0.00 0.12 0.12 0.00 0.03 0.03 123
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.01 0.94 0.01 0.15 0.16 0.01 0.04 0.05 683
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 5.13 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.04 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 28.1 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.85 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 4.65 424 of 1220
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3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.13 0.88 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.13 0.88 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 6.97
Architectural
Coatings
5.53 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.15
Architectural
Coatings
1.01 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — —
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Daily, Summer
(Max)
— — — — — — — — —
Worker 0.07 0.06 0.00 0.15 0.15 0.00 0.04 0.04 162
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
Worker 0.07 0.07 0.00 0.15 0.15 0.00 0.04 0.04 151
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 7.93 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.31 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.12. Architectural Coating (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.02 1.07 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 426 of 1220
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Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.02 1.07 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.06 < 0.005 — < 0.005 < 0.005 — < 0.005 6.97
Architectural
Coatings
5.53 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.15
Architectural
Coatings
1.01 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.07 0.06 0.00 0.15 0.15 0.00 0.04 0.04 162
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
Worker 0.07 0.07 0.00 0.15 0.15 0.00 0.04 0.04 151
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 0.01 0.01 0.00 < 0.005 < 0.005 427 of 1220
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.31 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.13. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.20 1.93 0.07 — 0.07 0.06 — 0.06 434
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 15.4
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 2.56
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — —
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Worker 0.02 0.02 0.00 0.04 0.04 0.00 0.01 0.01 41.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.48 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.25 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.14. Trenching (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.07 2.28 0.04 — 0.04 0.03 — 0.03 434
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 15.4
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005
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Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.02 0.02 0.00 0.04 0.04 0.00 0.01 0.01 41.1
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.48 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.25 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
2.28 1.89 0.03 2.91 2.94 0.03 0.74 0.77 3,497
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Fast Food 5.63 4.99 0.08 7.90 7.98 0.08 2.01 2.09 9,461 Restaurant w/o
Drive Thru
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 7.91 6.88 0.11 10.8 10.9 0.11 2.75 2.86 12,958
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
2.18 2.17 0.03 2.91 2.94 0.03 0.74 0.77 3,324
Fast Food
Restaurant w/o
Drive Thru
5.38 5.73 0.08 7.90 7.98 0.08 2.01 2.09 8,989
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 7.56 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,313
Annual — — — — — — — — —
Apartments Mid
Rise
0.37 0.36 0.01 0.50 0.51 0.01 0.13 0.13 526
Fast Food
Restaurant w/o
Drive Thru
0.58 0.60 0.01 0.86 0.87 0.01 0.22 0.23 900
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.96 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,426
4.1.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
2.28 1.89 0.03 2.91 2.94 0.03 0.74 0.77 3,497
Fast Food
Restaurant w/o
Drive Thru
5.63 4.99 0.08 7.90 7.98 0.08 2.01 2.09 9,461
431 of 1220
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Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 7.91 6.88 0.11 10.8 10.9 0.11 2.75 2.86 12,958
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
2.18 2.17 0.03 2.91 2.94 0.03 0.74 0.77 3,324
Fast Food
Restaurant w/o
Drive Thru
5.38 5.73 0.08 7.90 7.98 0.08 2.01 2.09 8,989
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 7.56 7.91 0.11 10.8 10.9 0.11 2.75 2.86 12,313
Annual — — — — — — — — —
Apartments Mid
Rise
0.37 0.36 0.01 0.50 0.51 0.01 0.13 0.13 526
Fast Food
Restaurant w/o
Drive Thru
0.58 0.60 0.01 0.86 0.87 0.01 0.22 0.23 900
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.96 0.96 0.01 1.36 1.38 0.01 0.35 0.36 1,426
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 92.8
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 21.2
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Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 114
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 92.8
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 21.2
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 114
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 15.4
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.51
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 18.9
4.2.2. Electricity Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 92.8
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 21.2
Parking Lot — — — — — — — — 0.00
114 Total — — — — — — — —
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Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 92.8
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 21.2
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 114
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 15.4
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.51
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 18.9
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
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Apartments Mid 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Rise
Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Annual — — — — — — — — —
Apartments Mid
Rise
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
4.2.4. Natural Gas Emissions By Land Use - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
435 of 1220
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Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Annual — — — — — — — — —
Apartments Mid
Rise
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Fast Food
Restaurant w/o
Drive Thru
0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Parking Lot 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Total 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
4.3. Area Emissions by Source
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Consumer
Products
3.08 — — — — — — — —
Architectural
Coatings
0.55 — — — — — — — —
Landscape
Equipment
0.65 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6
Total 4.28 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6 Daily, Winter (Max) — — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00
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Consumer
Products
3.08 — — — — — — — —
Architectural
Coatings
0.55 — — — — — — — —
Total 3.63 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Annual — — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Consumer
Products
0.56 — — — — — — — —
Architectural
Coatings
0.10 — — — — — — — —
Landscape
Equipment
0.06 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Total 0.72 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
4.3.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Consumer
Products
3.08 — — — — — — — —
Architectural
Coatings
0.55 — — — — — — — —
Landscape
Equipment
0.65 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6
Total 4.28 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 19.6 Daily, Winter (Max) — — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
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Consumer 3.08 — — — — — — — —
Products
Architectural
Coatings
0.55 — — — — — — — —
Total 3.63 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Annual — — — — — — — — —
Hearths 0.00 0.00 0.00 — 0.00 0.00 — 0.00 0.00
Consumer
Products
0.56 — — — — — — — —
Architectural
Coatings
0.10 — — — — — — — —
Landscape
Equipment
0.06 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Total 0.72 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 17.2
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 2.88
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 20.1
Daily, Winter (Max) — — — — — — — — —
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Apartments Mid — — — — — — — — 17.2
Rise
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 2.88
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 20.1
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 2.85
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 0.48
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 3.33
4.4.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 17.2
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 2.88
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 20.1
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 17.2
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Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 2.88
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 20.1
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 2.85
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 0.48
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 3.33
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 176
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 48.9
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 225
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 176
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Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 48.9
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 225
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 29.1
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 8.09
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 37.2
4.5.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 176
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 48.9
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 225
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 176
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 48.9
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Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 225
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 29.1
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 8.09
Parking Lot — — — — — — — — 0.00
Total — — — — — — — — 37.2
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 1.01
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.52
Total — — — — — — — — 4.53
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 1.01
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.52
Total — — — — — — — — 4.53
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Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 0.17
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 0.58
Total — — — — — — — — 0.75
4.6.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 1.01
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.52
Total — — — — — — — — 4.53
Daily, Winter (Max) — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 1.01
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 3.52
Total — — — — — — — — 4.53
Annual — — — — — — — — —
Apartments Mid
Rise
— — — — — — — — 0.17
Fast Food
Restaurant w/o
Drive Thru
— — — — — — — — 0.58
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Total — — — — — — — — 0.75
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.7.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.8. Stationary Emissions By Equipment Type
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4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.8.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e 445 of 1220
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Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.9.2. Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipment Type ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
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Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Daily, Winter (Max) — — — — — — — —
—
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Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Annual — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
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4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
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Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Annual — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/5/2025 1/7/2025 5.00 2.00 —
Site Preparation Site Preparation 1/8/2025 2/9/2025 5.00 23.0 — Grading Grading 2/10/2025 3/3/2025 5.00 16.0 —
Building Construction Building Construction 3/21/2025 9/15/2025 5.00 127 — Paving Paving 10/11/2025 11/1/2025 5.00 15.0 —
Architectural Coating Architectural Coating 9/16/2025 10/10/2025 5.00 19.0 — Trenching Trenching 3/4/2025 3/20/2025 5.00 13.0 —
5.2. Off-Road Equipment
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5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Site Preparation Rubber Tired Dozers Diesel Average 3.00 4.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 4.00 84.0 0.37
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 Trenching Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Trenching Excavators Diesel Average 1.00 8.00 36.0 0.38
5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 1.00 8.00 84.0 0.37
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Site Preparation Rubber Tired Dozers Diesel Tier 4 Interim 3.00 4.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 4.00 4.00 84.0 0.37
Grading Excavators Diesel Tier 4 Interim 1.00 8.00 36.0 0.38 Grading Graders Diesel Tier 4 Interim 1.00 8.00 148 0.41 Grading Rubber Tired Dozers Diesel Tier 4 Interim 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 3.00 8.00 84.0 0.37
Building Construction Forklifts Diesel Tier 4 Interim 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Tier 4 Interim 1.00 8.00 46.0 0.45 Paving Pavers Diesel Tier 4 Interim 2.00 8.00 81.0 0.42 Paving Paving Equipment Diesel Tier 4 Interim 2.00 6.00 89.0 0.36 Paving Rollers Diesel Tier 4 Interim 2.00 6.00 36.0 0.38 Architectural Coating Air Compressors Diesel Tier 4 Interim 1.00 6.00 37.0 0.48 Trenching Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 1.00 8.00 84.0 0.37
Trenching Excavators Diesel Tier 4 Interim 1.00 8.00 36.0 0.38
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 2.50 11.7 LDA,LDT1,LDT2
Demolition Vendor — 8.40 HHDT,MHDT
Demolition Hauling 7.00 20.0 HHDT
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Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor — 8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 11.7 LDA,LDT1,LDT2
Grading Vendor — 8.40 HHDT,MHDT
Grading Hauling 9.38 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 91.7 11.7 LDA,LDT1,LDT2
Building Construction Vendor 13.8 8.40 HHDT,MHDT
Building Construction Hauling 1.49 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor — 8.40 HHDT,MHDT
Paving Hauling 8.55 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 18.3 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor — 8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
Trenching — — — —
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Trenching Worker 5.00 11.7 LDA,LDT1,LDT2
Trenching Vendor — 8.40 HHDT,MHDT
Trenching Hauling 0.00 20.0 HHDT
Trenching Onsite truck — — HHDT
5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 2.50 11.7 LDA,LDT1,LDT2
Demolition Vendor — 8.40 HHDT,MHDT
Demolition Hauling 7.00 20.0 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 11.7 LDA,LDT1,LDT2
Site Preparation Vendor — 8.40 HHDT,MHDT
Site Preparation Hauling 0.00 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 11.7 LDA,LDT1,LDT2
Grading Vendor — 8.40 HHDT,MHDT
Grading Hauling 9.38 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 91.7 11.7 LDA,LDT1,LDT2
Building Construction Vendor 13.8 8.40 HHDT,MHDT
Building Construction Hauling 1.49 20.0 HHDT
Building Construction Onsite truck — — HHDT
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Paving — — — —
Paving Worker 15.0 11.7 LDA,LDT1,LDT2
Paving Vendor — 8.40 HHDT,MHDT
Paving Hauling 8.55 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 18.3 11.7 LDA,LDT1,LDT2
Architectural Coating Vendor — 8.40 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
Trenching — — — —
Trenching Worker 5.00 11.7 LDA,LDT1,LDT2
Trenching Vendor — 8.40 HHDT,MHDT
Trenching Hauling 0.00 20.0 HHDT
Trenching Onsite truck — — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 286,902 95,634 3,375 1,125 —
5.6. Dust Mitigation
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5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 1,200 —
Site Preparation — — 17.3 0.00 —
Grading 1,200 — 16.0 0.00 —
Paving 0.00 0.00 0.00 0.00 0.00
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%
Fast Food Restaurant w/o Drive Thru 0.00 0%
Parking Lot 0.00 100%
5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 39.5 0.03 < 0.005
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Apartments Mid Rise 538 486 404 186,675 4,078 3,680 3,066 1,414,901 456 of 1220
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Fast Food
Restaurant w/o Drive
Thru
642 1,291 927 283,015 5,507 11,070 7,952 2,427,569
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.9.2. Mitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Apartments Mid Rise 538 486 404 186,675 4,078 3,680 3,066 1,414,901 Fast Food
Restaurant w/o Drive
Thru
642 1,291 927 283,015 5,507 11,070 7,952 2,427,569
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0
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5.10.1.2. Mitigated
Hearth Type Unmitigated (number)
Apartments Mid Rise —
Wood Fireplaces 0
Gas Fireplaces 0
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 0
Conventional Wood Stoves 0
Catalytic Wood Stoves 0
Non-Catalytic Wood Stoves 0
Pellet Wood Stoves 0
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
286902 95,634 3,375 1,125 —
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 180
5.10.4. Landscape Equipment - Mitigated
Season Unit Value
Snow Days day/yr 0.00 458 of 1220
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Summer Days day/yr 180
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 817,023 39.5 0.0330 0.0040 0.00
Fast Food Restaurant w/o Drive
Thru
186,323 39.5 0.0330 0.0040 0.00
Parking Lot 0.00 39.5 0.0330 0.0040 0.00
5.11.2. Mitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Apartments Mid Rise 817,023 39.5 0.0330 0.0040 0.00
Fast Food Restaurant w/o Drive
Thru
186,323 39.5 0.0330 0.0040 0.00
Parking Lot 0.00 39.5 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 4,061,837 266,080
Fast Food Restaurant w/o Drive Thru 682,951 0.00
Parking Lot 0.00 0.00
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5.12.2. Mitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Apartments Mid Rise 4,061,837 266,080
Fast Food Restaurant w/o Drive Thru 682,951 0.00
Parking Lot 0.00 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 93.3 —
Fast Food Restaurant w/o Drive Thru 25.9 —
Parking Lot 0.00 —
5.13.2. Mitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Apartments Mid Rise 93.3 —
Fast Food Restaurant w/o Drive Thru 25.9 —
Parking Lot 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
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Apartments Mid Rise Household refrigerators
and/or freezers
R-134a 1,430 0.12 0.60 0.00 1.00
Fast Food Restaurant
w/o Drive Thru
Household refrigerators
and/or freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Fast Food Restaurant
w/o Drive Thru
Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Fast Food Restaurant
w/o Drive Thru
Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
5.14.2. Mitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Apartments Mid Rise Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Apartments Mid Rise Household refrigerators
and/or freezers
R-134a 1,430 0.12 0.60 0.00 1.00
Fast Food Restaurant
w/o Drive Thru
Household refrigerators
and/or freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Fast Food Restaurant
w/o Drive Thru
Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Fast Food Restaurant
w/o Drive Thru
Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.15.2. Mitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor 461 of 1220
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5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)
5.17. User Defined
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
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5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.1 annual days of extreme heat Extreme Precipitation 11.6 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 9.76 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events.
Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters 463 of 1220 24-049 Cotati Village #2 BMPs T4i 2026 Detailed Report, 5/23/2024 68 / 74
Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
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Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 7.52
AQ-PM 9.31
AQ-DPM 29.2
Drinking Water 50.3
Lead Risk Housing 37.7
Pesticides 54.5
Toxic Releases 12.8
Traffic 59.6
Effect Indicators —
CleanUp Sites 63.7
Groundwater 83.3
Haz Waste Facilities/Generators 80.3
Impaired Water Bodies 77.3
Solid Waste 88.9
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Sensitive Population —
Asthma 24.4
Cardio-vascular 15.3
Low Birth Weights 26.1
Socioeconomic Factor Indicators —
Education 48.6
Housing 83.9
Linguistic 8.49
Poverty 57.6
Unemployment 25.2
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 46.47760811
Employed 43.98819453
Median HI 38.23944566
Education —
Bachelor's or higher 59.98973438
High school enrollment 100
Preschool enrollment 28.89772873
Transportation —
Auto Access 75.69613756
Active commuting 42.15321442
Social —
2-parent households 8.469138971
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Voting 86.56486591
Neighborhood —
Alcohol availability 42.71782369
Park access 7.019119723
Retail density 28.16630309
Supermarket access 43.11561658
Tree canopy 66.18760426
Housing —
Homeownership 53.27858334
Housing habitability 49.89092776
Low-inc homeowner severe housing cost burden 38.29077377 Low-inc renter severe housing cost burden 31.695111
Uncrowded housing 67.80443988
Health Outcomes —
Insured adults 68.56152958
Arthritis 0.0
Asthma ER Admissions 65.8
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 25.4
Cognitively Disabled 9.0
Physically Disabled 59.0
Heart Attack ER Admissions 83.1
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Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 74.2
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 59.5
Elderly 36.8
English Speaking 70.1
Foreign-born 31.6
Outdoor Workers 56.3
Climate Change Adaptive Capacity —
Impervious Surface Cover 82.2
Traffic Density 66.8
Traffic Access 47.9
Other Indices —
Hardship 44.4
Other Decision Support —
2016 Voting 86.7
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 38.0 Healthy Places Index Score for Project Location (b) 48.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) Yes Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Characteristics: Utility Information Characteristics: Utility Information Sonoma Clean Power is the default clean energy provider for Cotati.
Land Use Applicant provided land uses in provided construction worksheet. Restaurant land use used as closest CalEEMod land use to Coffee/Donut Shop use.
Construction: Construction Phases Construction Schedule provided by project applicant.
Construction: Off-Road Equipment Default construction equipment/hours provided and revised by the applicant.
Construction: Trips and VMT Building construction = 90 cement truck round trips (1.49 trips/day), Paving = 499-cy asphalt hauling (8.55 trips/day).
Operations: Vehicle Data Provided trip generation with internal capture and diverted reductions. 469 of 1220
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Operations: Hearths No hearths.
Operations: Energy Use Applicant confirmed project would be all-electric. Natural gas converted to electricity.
Operations: Water and Waste Water Wastewater treatment 100% aerobic. No septic tanks or lagoons. 470 of 1220
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24-049 Cotati Village #2 BMPs T4i HRA Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.3. Construction Emissions by Year, Mitigated
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
3.2. Demolition (2025) - Mitigated
3.3. Site Preparation (2025) - Unmitigated
3.4. Site Preparation (2025) - Mitigated
3.5. Grading (2025) - Unmitigated
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3.6. Grading (2025) - Mitigated
3.7. Building Construction (2025) - Unmitigated
3.8. Building Construction (2025) - Mitigated
3.9. Paving (2025) - Unmitigated
3.10. Paving (2025) - Mitigated
3.11. Architectural Coating (2025) - Unmitigated
3.12. Architectural Coating (2025) - Mitigated
3.13. Trenching (2025) - Unmitigated
3.14. Trenching (2025) - Mitigated
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated 472 of 1220
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5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.2.2. Mitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.3.2. Mitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.18. Vegetation
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5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.1.2. Mitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
5.18.2.2. Mitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
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7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name 24-049 Cotati Village #2 BMPs T4i HRA
Construction Start Date 1/5/2025
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.20
Precipitation (days) 9.60
Location 7515 Alder Ave, Cotati, CA 94931, USA
County Sonoma-San Francisco
City Cotati
Air District Bay Area AQMD
Air Basin San Francisco Bay Area
TAZ 972
EDFZ 2
Electric Utility Sonoma Clean Power
Gas Utility Pacific Gas & Electric
App Version 2022.1.1.23
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Apartments Mid Rise 126 Dwelling Unit 4.00 141,680 24,302 0.00 323 — 476 of 1220
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Fast Food
Restaurant w/o Drive
Thru
2.25 1000sqft 0.00 2,250 0.00 — — —
Parking Lot 168 Space 0.00 0.00 0.00 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector Sector # Measure Title
Construction C-5 Use Advanced Engine Tiers
Construction C-10-A Water Exposed Surfaces
Construction C-11 Limit Vehicle Speeds on Unpaved Roads
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Unmit. 106 7.50 0.30 0.04 0.34 0.28 0.01 0.29 1,632
Mit. 106 7.67 0.10 0.04 0.14 0.10 0.01 0.11 1,632
% Reduced < 0.5% -2% 66% — 58% 65% — 63% —
Daily, Winter (Max) — — — — — — — — —
Unmit. 106 16.4 0.72 9.83 10.5 0.66 5.05 5.68 3,011
Mit. 106 10.4 0.10 3.84 3.89 0.10 1.97 2.02 3,011
% Reduced < 0.5% 36% 86% 61% 63% 85% 61% 64% —
Average Daily
(Max)
— — — — — — — — —
Unmit. 6.15 4.72 0.20 0.95 1.14 0.18 0.47 0.65
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Mit. 5.81 4.00 0.05 0.38 0.43 0.05 0.19 0.23 947
% Reduced 6% 15% 75% 60% 62% 75% 60% 64% —
Annual (Max) — — — — — — — — —
Unmit. 1.12 0.86 0.04 0.17 0.21 0.03 0.09 0.12 157
Mit. 1.06 0.73 0.01 0.07 0.08 0.01 0.03 0.04 157
% Reduced 6% 15% 75% 60% 62% 75% 60% 64% —
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily - Summer
(Max)
— — — — — — — — —
2025 106 7.50 0.30 0.04 0.34 0.28 0.01 0.29 1,632
Daily - Winter
(Max)
— — — — — — — — —
2025 106 16.4 0.72 9.83 10.5 0.66 5.05 5.68 3,011
Average Daily — — — — — — — — —
2025 6.15 4.72 0.20 0.95 1.14 0.18 0.47 0.65 947
Annual — — — — — — — — —
2025 1.12 0.86 0.04 0.17 0.21 0.03 0.09 0.12 157
2.3. Construction Emissions by Year, Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily - Summer
(Max)
— — — — — — — — —
2025 106 7.67 0.10 0.04 0.14 0.10 0.01 0.11 1,632
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Daily - Winter — — — — — — — — —
(Max)
2025 106 10.4 0.10 3.84 3.89 0.10 1.97 2.02 3,011
Average Daily — — — — — — — — —
2025 5.81 4.00 0.05 0.38 0.43 0.05 0.19 0.23 947
Annual — — — — — — — — —
2025 1.06 0.73 0.01 0.07 0.08 0.01 0.03 0.04 157
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.11 1.10 0.04 — 0.04 0.04 — 0.04 291
Demolition — — — 0.59 0.59 — 0.09 0.09 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.26 479 of 1220
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Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.01 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.40 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.12 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 24.7 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.01 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.14 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.02
3.2. Demolition (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.04 1.18 0.01 — 0.01 0.01 — 0.01 291
Demolition — — — 0.59 0.59 — 0.09 0.09
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Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.60
Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 0.26 Demolition — — — < 0.005 < 0.005 — < 0.005 < 0.005 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.01 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 1.40 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.12 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 24.7 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.01 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.14 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 < 0.005 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.02
3.3. Site Preparation (2025) - Unmitigated
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Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
1.66 15.8 0.68 — 0.68 0.63 — 0.63 2,657
Dust From Material
Movement
— — — 9.83 9.83 — 5.05 5.05 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.10 1.00 0.04 — 0.04 0.04 — 0.04 167
Dust From Material
Movement
— — — 0.62 0.62 — 0.32 0.32 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.02 0.18 0.01 — 0.01 0.01 — 0.01 27.7
Dust From Material
Movement
— — — 0.11 0.11 — 0.06 0.06 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 9.82 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
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Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.62 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.4. Site Preparation (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.32 7.37 0.05 — 0.05 0.05 — 0.05 2,657
Dust From Material
Movement
— — — 3.83 3.83 — 1.97 1.97 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.02 0.46 < 0.005 — < 0.005 < 0.005 — < 0.005 167
Dust From Material
Movement
— — — 0.24 0.24 — 0.12 0.12 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 27.7
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Dust From Material
Movement
— — — 0.04 0.04 — 0.02 0.02 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 9.82 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.62 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.5. Grading (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
1.74 16.3 0.72 — 0.72 0.66 — 0.66 2,970
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Dust From Material — — — 7.09 7.09 — 3.43 3.43 —
Movement
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.08 0.71 0.03 — 0.03 0.03 — 0.03 130
Dust From Material
Movement
— — — 0.31 0.31 — 0.15 0.15 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.01 0.13 0.01 — 0.01 0.01 — 0.01 21.6
Dust From Material
Movement
— — — 0.06 0.06 — 0.03 0.03 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.05 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.42 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.16 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 33.1 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.45 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 485 of 1220
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3.6. Grading (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.39 10.3 0.08 — 0.08 0.08 — 0.08 2,970
Dust From Material
Movement
— — — 2.76 2.76 — 1.34 1.34 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.02 0.45 < 0.005 — < 0.005 < 0.005 — < 0.005 130
Dust From Material
Movement
— — — 0.12 0.12 — 0.06 0.06 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 21.6
Dust From Material
Movement
— — — 0.02 0.02 — 0.01 0.01 —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.05 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.42 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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Hauling < 0.005 0.16 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 33.1 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.37 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.45 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.24
3.7. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.80 7.24 0.30 — 0.30 0.28 — 0.28 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.80 7.24 0.30 — 0.30 0.28 — 0.28 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.28 2.52 0.11 — 0.11 0.10 — 0.10 535
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
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Off-Road 0.05 0.46 0.02 — 0.02 0.02 — 0.02 88.5
Equipment
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.33 0.08 0.00 0.03 0.03 0.00 0.01 0.01 53.1
Vendor 0.01 0.16 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 37.0 Hauling < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.24 Daily, Winter (Max) — — — — — — — — —
Worker 0.31 0.09 0.00 0.03 0.03 0.00 0.01 0.01 51.4
Vendor 0.01 0.16 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 37.0 Hauling < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.25 Average Daily — — — — — — — — —
Worker 0.11 0.03 0.00 0.01 0.01 0.00 < 0.005 < 0.005 17.9 Vendor < 0.005 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.9 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.83 Annual — — — — — — — — —
Worker 0.02 0.01 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.96 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.13 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.30
3.8. Building Construction (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
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Off-Road
Equipment
0.32 7.41 0.10 — 0.10 0.10 — 0.10 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.32 7.41 0.10 — 0.10 0.10 — 0.10 1,536
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.11 2.58 0.04 — 0.04 0.03 — 0.03 535
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.02 0.47 0.01 — 0.01 0.01 — 0.01 88.5
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.33 0.08 0.00 0.03 0.03 0.00 0.01 0.01 53.1
Vendor 0.01 0.16 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 37.0 Hauling < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.24 Daily, Winter (Max) — — — — — — — — —
Worker 0.31 0.09 0.00 0.03 0.03 0.00 0.01 0.01 51.4
Vendor 0.01 0.16 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 37.0 Hauling < 0.005 0.03 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 5.25 Average Daily — — — — — — — — —
Worker 0.11 0.03 0.00 0.01 0.01 0.00 < 0.005 < 0.005 17.9 Vendor < 0.005 0.06 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 12.9 Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.83 489 of 1220
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Annual — — — — — — — — —
Worker 0.02 0.01 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.96 Vendor < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 2.13 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.30
3.9. Paving (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.67 6.38 0.30 — 0.30 0.28 — 0.28 1,296
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.03 0.26 0.01 — 0.01 0.01 — 0.01 53.3
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
0.01 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 8.82
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
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Daily, Winter (Max) — — — — — — — — —
Worker 0.05 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.42 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.14 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 30.1 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.35 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.24 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.20
3.10. Paving (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.20 6.05 0.07 — 0.07 0.06 — 0.06 1,296
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.25 < 0.005 — < 0.005 < 0.005 — < 0.005 53.3
Paving 0.00 — — — — — — —
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Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 8.82
Paving 0.00 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.05 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 8.42 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.14 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 30.1 Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.35 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 1.24 Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.06 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 0.20
3.11. Architectural Coating (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
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Off-Road
Equipment
0.13 0.88 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.13 0.88 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.05 < 0.005 — < 0.005 < 0.005 — < 0.005 6.97
Architectural
Coatings
5.53 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.15
Architectural
Coatings
1.01 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.07 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 10.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.09 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.12. Architectural Coating (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Off-Road
Equipment
0.02 1.07 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.02 1.07 0.03 — 0.03 0.03 — 0.03 134
Architectural
Coatings
106 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — —
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Off-Road
Equipment
< 0.005 0.06 < 0.005 — < 0.005 < 0.005 — < 0.005 6.97
Architectural
Coatings
5.53 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 1.15
Architectural
Coatings
1.01 — — — — — — — —
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Worker 0.07 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 10.6 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Daily, Winter (Max) — — — — — — — — —
Worker 0.06 0.02 0.00 0.01 0.01 0.00 < 0.005 < 0.005 10.3 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.54 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.09 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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3.13. Trenching (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.20 1.93 0.07 — 0.07 0.06 — 0.06 434
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
0.01 0.07 < 0.005 — < 0.005 < 0.005 — < 0.005 15.4
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 2.56
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.02 0.01 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.81 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
3.14. Trenching (2025) - Mitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Onsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Off-Road
Equipment
0.07 2.28 0.04 — 0.04 0.03 — 0.03 434
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Average Daily — — — — — — — — —
Off-Road
Equipment
< 0.005 0.08 < 0.005 — < 0.005 < 0.005 — < 0.005 15.4
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — —
Off-Road
Equipment
< 0.005 0.01 < 0.005 — < 0.005 < 0.005 — < 0.005 2.56
Onsite truck 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — —
Daily, Summer
(Max)
— — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Worker 0.02 0.01 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 2.81 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
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Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Average Daily — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Annual — — — — — — — — —
Worker < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 0.02 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e 498 of 1220
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Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — —
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Annual — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
4.10.4. Soil Carbon Accumulation By Vegetation Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — — —
Annual — — — — — — — — —
Total — — — — — — — — —
4.10.5. Above and Belowground Carbon Accumulation by Land Use Type - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land Use ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Total — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Total — — — — — — — —
—
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Annual — — — — — — — — —
Total — — — — — — — — —
4.10.6. Avoided and Sequestered Emissions by Species - Mitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T CO2e Daily, Summer
(Max)
— — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Daily, Winter (Max) — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
Annual — — — — — — — — —
Avoided — — — — — — — — —
Subtotal — — — — — — — — —
Sequestered — — — — — — — — —
Subtotal — — — — — — — — —
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Removed — — — — — — — — —
Subtotal — — — — — — — — —
— — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/5/2025 1/7/2025 5.00 2.00 —
Site Preparation Site Preparation 1/8/2025 2/9/2025 5.00 23.0 — Grading Grading 2/10/2025 3/3/2025 5.00 16.0 —
Building Construction Building Construction 3/21/2025 9/15/2025 5.00 127 — Paving Paving 10/11/2025 11/1/2025 5.00 15.0 —
Architectural Coating Architectural Coating 9/16/2025 10/10/2025 5.00 19.0 — Trenching Trenching 3/4/2025 3/20/2025 5.00 13.0 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Site Preparation Rubber Tired Dozers Diesel Average 3.00 4.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Average 4.00 4.00 84.0 0.37
Grading Excavators Diesel Average 1.00 8.00 36.0 0.38
Grading Graders Diesel Average 1.00 8.00 148 0.41
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Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Average 3.00 8.00 84.0 0.37
Building Construction Forklifts Diesel Average 3.00 8.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Average 1.00 8.00 46.0 0.45 Paving Pavers Diesel Average 2.00 8.00 81.0 0.42
Paving Paving Equipment Diesel Average 2.00 6.00 89.0 0.36 Paving Rollers Diesel Average 2.00 6.00 36.0 0.38
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48 Trenching Tractors/Loaders/Backh
oes
Diesel Average 1.00 8.00 84.0 0.37
Trenching Excavators Diesel Average 1.00 8.00 36.0 0.38
5.2.2. Mitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 1.00 8.00 84.0 0.37
Site Preparation Rubber Tired Dozers Diesel Tier 4 Interim 3.00 4.00 367 0.40 Site Preparation Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 4.00 4.00 84.0 0.37
Grading Excavators Diesel Tier 4 Interim 1.00 8.00 36.0 0.38 Grading Graders Diesel Tier 4 Interim 1.00 8.00 148 0.41 Grading Rubber Tired Dozers Diesel Tier 4 Interim 1.00 8.00 367 0.40 Grading Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 3.00 8.00 84.0 0.37
Building Construction Forklifts Diesel Tier 4 Interim 3.00 8.00 82.0 0.20 503 of 1220
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Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 3.00 7.00 84.0 0.37
Building Construction Welders Diesel Tier 4 Interim 1.00 8.00 46.0 0.45 Paving Pavers Diesel Tier 4 Interim 2.00 8.00 81.0 0.42 Paving Paving Equipment Diesel Tier 4 Interim 2.00 6.00 89.0 0.36 Paving Rollers Diesel Tier 4 Interim 2.00 6.00 36.0 0.38 Architectural Coating Air Compressors Diesel Tier 4 Interim 1.00 6.00 37.0 0.48 Trenching Tractors/Loaders/Backh
oes
Diesel Tier 4 Interim 1.00 8.00 84.0 0.37
Trenching Excavators Diesel Tier 4 Interim 1.00 8.00 36.0 0.38
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 2.50 0.50 LDA,LDT1,LDT2
Demolition Vendor — 0.50 HHDT,MHDT
Demolition Hauling 7.00 0.50 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 0.50 LDA,LDT1,LDT2
Site Preparation Vendor — 0.50 HHDT,MHDT
Site Preparation Hauling 0.00 0.50 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 0.50 LDA,LDT1,LDT2
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Grading Vendor — 0.50 HHDT,MHDT
Grading Hauling 9.38 0.50 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 91.7 0.50 LDA,LDT1,LDT2
Building Construction Vendor 13.8 0.50 HHDT,MHDT
Building Construction Hauling 1.49 0.50 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 0.50 LDA,LDT1,LDT2
Paving Vendor — 0.50 HHDT,MHDT
Paving Hauling 8.55 0.50 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 18.3 0.50 LDA,LDT1,LDT2
Architectural Coating Vendor — 0.50 HHDT,MHDT
Architectural Coating Hauling 0.00 0.50 HHDT
Architectural Coating Onsite truck — — HHDT
Trenching — — — —
Trenching Worker 5.00 0.50 LDA,LDT1,LDT2
Trenching Vendor — 0.50 HHDT,MHDT
Trenching Hauling 0.00 0.50 HHDT
Trenching Onsite truck — — HHDT
5.3.2. Mitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — — 505 of 1220
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Demolition Worker 2.50 0.50 LDA,LDT1,LDT2
Demolition Vendor — 0.50 HHDT,MHDT
Demolition Hauling 7.00 0.50 HHDT
Demolition Onsite truck — — HHDT
Site Preparation — — — —
Site Preparation Worker 17.5 0.50 LDA,LDT1,LDT2
Site Preparation Vendor — 0.50 HHDT,MHDT
Site Preparation Hauling 0.00 0.50 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 15.0 0.50 LDA,LDT1,LDT2
Grading Vendor — 0.50 HHDT,MHDT
Grading Hauling 9.38 0.50 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 91.7 0.50 LDA,LDT1,LDT2
Building Construction Vendor 13.8 0.50 HHDT,MHDT
Building Construction Hauling 1.49 0.50 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 15.0 0.50 LDA,LDT1,LDT2
Paving Vendor — 0.50 HHDT,MHDT
Paving Hauling 8.55 0.50 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 18.3 0.50 LDA,LDT1,LDT2
Architectural Coating Vendor — 0.50 HHDT,MHDT
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Architectural Coating Hauling 0.00 0.50 HHDT
Architectural Coating Onsite truck — — HHDT
Trenching — — — —
Trenching Worker 5.00 0.50 LDA,LDT1,LDT2
Trenching Vendor — 0.50 HHDT,MHDT
Trenching Hauling 0.00 0.50 HHDT
Trenching Onsite truck — — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 286,902 95,634 3,375 1,125 —
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Building Square Footage)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 1,200 —
Site Preparation — — 17.3 0.00 —
Grading 1,200 — 16.0 0.00 —
Paving 0.00 0.00 0.00 0.00 0.00
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5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user.
5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Apartments Mid Rise — 0%
Fast Food Restaurant w/o Drive Thru 0.00 0%
Parking Lot 0.00 100%
5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 39.5 0.03 < 0.005
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1.2. Mitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
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Biomass Cover Type Initial Acres Final Acres
5.18.1.2. Mitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
5.18.2.2. Mitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 11.1 annual days of extreme heat Extreme Precipitation 11.6 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 9.76 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi. 509 of 1220 24-049 Cotati Village #2 BMPs T4i HRA Detailed Report, 5/23/2024 40 / 46
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events.
Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat N/A N/A N/A N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise N/A N/A N/A N/A
Wildfire N/A N/A N/A N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
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Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation N/A N/A N/A N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 7.52
AQ-PM 9.31
AQ-DPM 29.2
Drinking Water 50.3
Lead Risk Housing 37.7
Pesticides 54.5
Toxic Releases 12.8
Traffic 59.6
Effect Indicators —
CleanUp Sites 63.7
Groundwater 83.3
Haz Waste Facilities/Generators 80.3
Impaired Water Bodies 77.3
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Solid Waste 88.9
Sensitive Population —
Asthma 24.4
Cardio-vascular 15.3
Low Birth Weights 26.1
Socioeconomic Factor Indicators —
Education 48.6
Housing 83.9
Linguistic 8.49
Poverty 57.6
Unemployment 25.2
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 46.47760811
Employed 43.98819453
Median HI 38.23944566
Education —
Bachelor's or higher 59.98973438
High school enrollment 100
Preschool enrollment 28.89772873
Transportation —
Auto Access 75.69613756
Active commuting 42.15321442
Social —
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2-parent households 8.469138971
Voting 86.56486591
Neighborhood —
Alcohol availability 42.71782369
Park access 7.019119723
Retail density 28.16630309
Supermarket access 43.11561658
Tree canopy 66.18760426
Housing —
Homeownership 53.27858334
Housing habitability 49.89092776
Low-inc homeowner severe housing cost burden 38.29077377 Low-inc renter severe housing cost burden 31.695111
Uncrowded housing 67.80443988
Health Outcomes —
Insured adults 68.56152958
Arthritis 0.0
Asthma ER Admissions 65.8
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 25.4
Cognitively Disabled 9.0
Physically Disabled 59.0
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Heart Attack ER Admissions 83.1
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 74.2
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors —
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures —
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 59.5
Elderly 36.8
English Speaking 70.1
Foreign-born 31.6
Outdoor Workers 56.3
Climate Change Adaptive Capacity —
Impervious Surface Cover 82.2
Traffic Density 66.8
Traffic Access 47.9
Other Indices —
Hardship 44.4
Other Decision Support —
2016 Voting 86.7
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 38.0 Healthy Places Index Score for Project Location (b) 48.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) Yes Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Characteristics: Utility Information Characteristics: Utility Information Sonoma Clean Power is the default clean energy provider for Cotati.
Land Use Applicant provided land uses in provided construction worksheet. Restaurant land use used as closest CalEEMod land use to Coffee/Donut Shop use.
Construction: Construction Phases Construction Schedule provided by project applicant.
Construction: Off-Road Equipment Default construction equipment/hours provided and revised by the applicant.
Construction: Trips and VMT Building construction = 90 cement truck round trips (1.49 trips/day), Paving = 499-cy asphalt hauling (8.55 trips/day). HRA = 0.5 mile trip length for localized emissions.
Operations: Vehicle Data Provided trip generation with internal capture and diverted reductions. 515 of 1220
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Operations: Hearths No hearths.
Operations: Energy Use Applicant confirmed project would be all-electric. Natural gas converted to electricity.
Operations: Water and Waste Water Wastewater treatment 100% aerobic. No septic tanks or lagoons. 516 of 1220
Attachment 2: Project Construction Emissions and Health Risk Calculations
517 of 1220
Cotati Village 2 ‐ Cotati, CA
Construction Emissions
Unmitigated PM10 Exhaust PM2.5 Fugitive Mitigated PM10 Exhaust PM2.5 Fugitive Year Year
2025 0.0358 0.0862 2025 0.0088 0.0341
Tons 0.04 0.09 Tons 0.009 0.03
Unmitigated Construction Emissions Mitigated Construction Emissions Construction Equipment Construction Equipment
Cotati Village 2 - Cotati, CA
DPM Emissions and Modeling Emission Rates - Uncontrolled DPM
Emissions Modeled Emission
Model DPM Area DPM Emissions Area Rate
Year Activity (ton/year) Source (lb/yr) (lb/hr) (g/s) (m2 ) (g/s/m2)
2025 Construction 0.0358 DPM 71.7 0.01637 2.06E-03 15,317 1.35E-07 Modeled Operation Hours
hr/day = 12 (7am - 7pm)
days/yr = 365
hours/year = 4380
PM2.5 Fugitive Dust Emissions for Modeling - Uncontrolled PM2.5
Modeled Emission
Construction Area PM2.5 Emissions Area Rate
Year Activity Source (ton/year) (lb/yr) (lb/hr) (g/s) (m2 ) g/s/m2
2025 Construction FUG 0.0862 172.5 0.03938 4.96E-03 15,317 3.24E-07 Modeled Operation Hours
hr/day = 12 (7am - 7pm)
days/yr = 365
hours/year = 4380
518 of 1220
Cotati Village - Cotati, CA
DPM Construction Emissions and Modeling Emission Rates - With Controls DPM
Emissions Modeled Emission
Model DPM Area DPM Emissions Area Rate
Year Activity (ton/year) Source (lb/yr) (lb/hr) (g/s) (m2 ) (g/s/m2)
2025 Construction 0.0088 DPM 17.7 0.00404 5.09E-04 15,317 3.32E-08 Modeled Operation Hours
hr/day = 12 (7am - 7pm)
days/yr = 365
hours/year = 4380
PM2.5 Fugitive Dust Construction Emissions for Modeling - With Controls PM2.5
Modeled Emission
Construction Area PM2.5 Emissions Area Rate
Year Activity Source (ton/year) (lb/yr) (lb/hr) (g/s) (m2 ) g/s/m2
2025 Construction FUG 0.0341 68.2 0.01557 1.96E-03 15,317 1.28E-07 Modeled Operation Hours
hr/day = 12 (7am - 7pm)
days/yr = 365
hours/year = 4380
Cotati Village 2 - Cotati, CA
Construction Health Impacts Summary
Maximum Impacts at Construction MEI Locations - Uncontrolled Maximum Concentrations Maximum
Exhaust Fugitive Cancer Risk Hazard Annual PM2.5
Emissions PM10/DPM PM2.5 (per million) Index Concentration Year (μg/m3
) (μg/m3) Child Adult (-) (μg/m3)
2025 0.1002 0.3627 16.46 0.29 0.020 0.45
Maximum Concentrations Maximum
Exhaust Fugitive Cancer Risk Hazard Annual PM2.5
Emissions PM10/DPM PM2.5 (per million) Index Concentration Year (μg/m3
) (μg/m3) Child Adult (-) (μg/m3)
2025 0.0269 0.1433 4.41 0.07 0.005 0.16
Maximum Impacts at Construction MEI Locations - With Mitigation 519 of 1220
Cotati Village 2 - Cotati, CA - Uncontrolled Emissions
Maximum DPM Cancer Risk Calculations From Construction
Impacts at Off-Site Receptors- 1st Floor (1.5 meter receptor height) Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x 1.0E6 Where: CPF = Cancer potency factor (mg/kg-day)-1
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Cair x DBR x A x (EF/365) x 10-6
Where: Cair = concentration in air (μg/m3)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 = Conversion factor
Values
Infant/Child Adult
Age --> 3rd Trimester 0 - 2 2 - 9 2 - 16 16 - 30
Parameter
ASF = 10 10 3 3 1
CPF = 1.10E+00 1.10E+00 1.10E+00 1.10E+00 1.10E+00
DBR* = 361 1090 631 572 261
A = 1 1 1 1 1
EF = 350 350 350 350 350
AT = 70 70 70 70 70
FAH = 1.00 1.00 1.00 1.00 0.73
* 95th percentile breathing rates for infants and 80th percentile for children and adults Construction Cancer Risk by Year - Maximum Impact Receptor Location Infant/Child - Exposure Information Infant/Child Adult - Exposure Information Adult Exposure Age Cancer Modeled Age Cancer
Exposure Duration DPM Conc (ug/m3) Sensitivity Risk DPM Conc (ug/m3) Sensitivity Risk Fugitive Total Year (years) Age Year Annual Factor (per million) Year Annual Factor (per million) PM2.5 PM2.5 0 0.25 -0.25 - 0* - 10 - - - - -
1 1 0 - 1 2025 0.0853 10 14.00 2025 0.0853 1 0.24 0.3627 0.448 2 1 1 - 2 0.0000 10 0.00 0.0000 1 0.00
3 1 2 - 3 0.0000 3 0.00 0.0000 1 0.00
4 1 3 - 4 0.0000 3 0.00 0.0000 1 0.00
5 1 4 - 5 0.0000 3 0.00 0.0000 1 0.00
6 1 5 - 6 0.0000 3 0.00 0.0000 1 0.00
7 1 6 - 7 0.0000 3 0.00 0.0000 1 0.00
8 1 7 - 8 0.0000 3 0.00 0.0000 1 0.00
9 1 8 - 9 0.0000 3 0.00 0.0000 1 0.00
10 1 9 - 10 0.0000 3 0.00 0.0000 1 0.00
11 1 10 - 11 0.0000 3 0.00 0.0000 1 0.00
12 1 11 - 12 0.0000 3 0.00 0.0000 1 0.00
13 1 12 - 13 0.0000 3 0.00 0.0000 1 0.00
14 1 13 - 14 0.0000 3 0.00 0.0000 1 0.00
15 1 14 - 15 0.0000 3 0.00 0.0000 1 0.00
16 1 15 - 16 0.0000 3 0.00 0.0000 1 0.00
17 1 16-17 0.0000 1 0.00 0.0000 1 0.00
18 1 17-18 0.0000 1 0.00 0.0000 1 0.00
19 1 18-19 0.0000 1 0.00 0.0000 1 0.00
20 1 19-20 0.0000 1 0.00 0.0000 1 0.00
21 1 20-21 0.0000 1 0.00 0.0000 1 0.00
22 1 21-22 0.0000 1 0.00 0.0000 1 0.00
23 1 22-23 0.0000 1 0.00 0.0000 1 0.00
24 1 23-24 0.0000 1 0.00 0.0000 1 0.00
25 1 24-25 0.0000 1 0.00 0.0000 1 0.00
26 1 25-26 0.0000 1 0.00 0.0000 1 0.00
27 1 26-27 0.0000 1 0.00 0.0000 1 0.00
28 1 27-28 0.0000 1 0.00 0.0000 1 0.00
29 1 28-29 0.0000 1 0.00 0.0000 1 0.00
30 1 29-30 0.0000 1 0.00 0.0000 1 0.00
Total Increased Cancer Risk 14.00 0.24
* Third trimester of pregnancy
520 of 1220
Cotati Village 2 - Cotati, CA - Mitigated Emissions
Maximum DPM Cancer Risk Calculations From Construction
Impacts at Off-Site Receptors- 1st Floor (1.5 meter receptor height) Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x 1.0E6 Where: CPF = Cancer potency factor (mg/kg-day)-1
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Cair x DBR x A x (EF/365) x 10-6
Where: Cair = concentration in air (μg/m3)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 = Conversion factor
Values
Infant/Child Adult
Age --> 3rd Trimester 0 - 2 2 - 9 2 - 16 16 - 30
Parameter
ASF = 10 10 3 3 1
CPF = 1.10E+00 1.10E+00 1.10E+00 1.10E+00 1.10E+00
DBR* = 361 1090 631 572 261
A = 1 1 1 1 1
EF = 350 350 350 350 350
AT = 70 70 70 70 70
FAH = 1.00 1.00 1.00 1.00 0.73
* 95th percentile breathing rates for infants and 80th percentile for children and adults Construction Cancer Risk by Year - Maximum Impact Receptor Locations Infant/Child - Exposure Information Infant/Child Adult - Exposure Information Adult Exposure Age Cancer Modeled Age Cancer
Exposure Duration DPM Conc (ug/m3) Sensitivity Risk DPM Conc (ug/m3) Sensitivity Risk Fugitive Total Year (years) Age Year Annual Factor (per million) Year Annual Factor (per million) PM2.5 PM2.5 0 0.25 -0.25 - 0* - 10 - - - - -
1 1 0 - 1 2025 0.0210 10 3.44 2025 0.0210 1 0.06 0.1433 0.164 2 1 1 - 2 0.0000 10 0.00 0.0000 1 0.00
3 1 2 - 3 0.0000 3 0.00 0.0000 1 0.00
4 1 3 - 4 0.0000 3 0.00 0.0000 1 0.00
5 1 4 - 5 0.0000 3 0.00 0.00000 1 0.00
6 1 5 - 6 0.0000 3 0.00 0.0000 1 0.00
7 1 6 - 7 0.0000 3 0.00 0.0000 1 0.00
8 1 7 - 8 0.0000 3 0.00 0.0000 1 0.00
9 1 8 - 9 0.0000 3 0.00 0.0000 1 0.00
10 1 9 - 10 0.0000 3 0.00 0.0000 1 0.00
11 1 10 - 11 0.0000 3 0.00 0.0000 1 0.00
12 1 11 - 12 0.0000 3 0.00 0.0000 1 0.00
13 1 12 - 13 0.0000 3 0.00 0.0000 1 0.00
14 1 13 - 14 0.0000 3 0.00 0.0000 1 0.00
15 1 14 - 15 0.0000 3 0.00 0.0000 1 0.00
16 1 15 - 16 0.0000 3 0.00 0.0000 1 0.00
17 1 16-17 0.0000 1 0.00 0.0000 1 0.00
18 1 17-18 0.0000 1 0.00 0.0000 1 0.00
19 1 18-19 0.0000 1 0.00 0.0000 1 0.00
20 1 19-20 0.0000 1 0.00 0.0000 1 0.00
21 1 20-21 0.0000 1 0.00 0.0000 1 0.00
22 1 21-22 0.0000 1 0.00 0.0000 1 0.00
23 1 22-23 0.0000 1 0.00 0.0000 1 0.00
24 1 23-24 0.0000 1 0.00 0.0000 1 0.00
25 1 24-25 0.0000 1 0.00 0.0000 1 0.00
26 1 25-26 0.0000 1 0.00 0.0000 1 0.00
27 1 26-27 0.0000 1 0.00 0.0000 1 0.00
28 1 27-28 0.0000 1 0.00 0.0000 1 0.00
29 1 28-29 0.0000 1 0.00 0.0000 1 0.00
30 1 29-30 0.0000 1 0.00 0.0000 1 0.00
Total Increased Cancer Risk 3.44 0.06
* Third trimester of pregnancy
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Cotati Village 2 - Cotati, CA - Uncontrolled Emissions
Maximum DPM Cancer Risk Calculations From Construction
Impacts at Off-Site Receptors-2nd Floor (4.5 meter receptor height) Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x 1.0E6 Where: CPF = Cancer potency factor (mg/kg-day)-1
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Cair x DBR x A x (EF/365) x 10-6
Where: Cair = concentration in air (μg/m3)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 = Conversion factor
Values
Infant/Child Adult
Age --> 3rd Trimester 0 - 2 2 - 9 2 - 16 16 - 30
Parameter
ASF = 10 10 3 3 1
CPF = 1.10E+00 1.10E+00 1.10E+00 1.10E+00 1.10E+00
DBR* = 361 1090 631 572 261
A = 1 1 1 1 1
EF = 350 350 350 350 350
AT = 70 70 70 70 70
FAH = 1.00 1.00 1.00 1.00 0.73
* 95th percentile breathing rates for infants and 80th percentile for children and adults Construction Cancer Risk by Year - Maximum Impact Receptor Location Infant/Child - Exposure Information Infant/Child Adult - Exposure Information Adult Exposure Age Cancer Modeled Age Cancer
Exposure Duration DPM Conc (ug/m3) Sensitivity Risk DPM Conc (ug/m3) Sensitivity Risk Fugitive Total Year (years) Age Year Annual Factor (per million) Year Annual Factor (per million) PM2.5 PM2.5 0 0.25 -0.25 - 0* - 10 - - - - -
1 1 0 - 1 2025 0.1002 10 16.46 2025 0.1002 1 0.29 0.2669 0.367 2 1 1 - 2 0.0000 10 0.00 0.0000 1 0.00
3 1 2 - 3 0.0000 3 0.00 0.0000 1 0.00
4 1 3 - 4 0.0000 3 0.00 0.0000 1 0.00
5 1 4 - 5 0.0000 3 0.00 0.0000 1 0.00
6 1 5 - 6 0.0000 3 0.00 0.0000 1 0.00
7 1 6 - 7 0.0000 3 0.00 0.0000 1 0.00
8 1 7 - 8 0.0000 3 0.00 0.0000 1 0.00
9 1 8 - 9 0.0000 3 0.00 0.0000 1 0.00
10 1 9 - 10 0.0000 3 0.00 0.0000 1 0.00
11 1 10 - 11 0.0000 3 0.00 0.0000 1 0.00
12 1 11 - 12 0.0000 3 0.00 0.0000 1 0.00
13 1 12 - 13 0.0000 3 0.00 0.0000 1 0.00
14 1 13 - 14 0.0000 3 0.00 0.0000 1 0.00
15 1 14 - 15 0.0000 3 0.00 0.0000 1 0.00
16 1 15 - 16 0.0000 3 0.00 0.0000 1 0.00
17 1 16-17 0.0000 1 0.00 0.0000 1 0.00
18 1 17-18 0.0000 1 0.00 0.0000 1 0.00
19 1 18-19 0.0000 1 0.00 0.0000 1 0.00
20 1 19-20 0.0000 1 0.00 0.0000 1 0.00
21 1 20-21 0.0000 1 0.00 0.0000 1 0.00
22 1 21-22 0.0000 1 0.00 0.0000 1 0.00
23 1 22-23 0.0000 1 0.00 0.0000 1 0.00
24 1 23-24 0.0000 1 0.00 0.0000 1 0.00
25 1 24-25 0.0000 1 0.00 0.0000 1 0.00
26 1 25-26 0.0000 1 0.00 0.0000 1 0.00
27 1 26-27 0.0000 1 0.00 0.0000 1 0.00
28 1 27-28 0.0000 1 0.00 0.0000 1 0.00
29 1 28-29 0.0000 1 0.00 0.0000 1 0.00
30 1 29-30 0.0000 1 0.00 0.0000 1 0.00
Total Increased Cancer Risk 16.46 0.29
* Third trimester of pregnancy
522 of 1220
Cotati Village 2 - Cotati, CA - Mitigated Emissions
Maximum DPM Cancer Risk Calculations From Construction
Impacts at Off-Site Receptors-4.5 meter receptor height Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x 1.0E6 Where: CPF = Cancer potency factor (mg/kg-day)-1
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Cair x DBR x A x (EF/365) x 10-6
Where: Cair = concentration in air (μg/m3)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 = Conversion factor
Values
Infant/Child Adult
Age --> 3rd Trimester 0 - 2 2 - 9 2 - 16 16 - 30
Parameter
ASF = 10 10 3 3 1
CPF = 1.10E+00 1.10E+00 1.10E+00 1.10E+00 1.10E+00
DBR* = 361 1090 631 572 261
A = 1 1 1 1 1
EF = 350 350 350 350 350
AT = 70 70 70 70 70
FAH = 1.00 1.00 1.00 1.00 0.73
* 95th percentile breathing rates for infants and 80th percentile for children and adults Construction Cancer Risk by Year - Maximum Impact Receptor Location Infant/Child - Exposure Information Infant/Child Adult - Exposure Information Adult Exposure Age Cancer Modeled Age Cancer
Exposure Duration DPM Conc (ug/m3) Sensitivity Risk DPM Conc (ug/m3) Sensitivity Risk Fugitive Total Year (years) Age Year Annual Factor (per million) Year Annual Factor (per million) PM2.5 PM2.5 0 0.25 -0.25 - 0* - 10 - - - - -
1 1 0 - 1 2025 0.0269 10 4.41 2025 0.0247 1 0.07 0.1055 0.130 2 1 1 - 2 0.0000 10 0.00 0.0000 1 0.00
3 1 2 - 3 0.0000 3 0.00 0.0000 1 0.00
4 1 3 - 4 0.0000 3 0.00 0.0000 1 0.00
5 1 4 - 5 0.00000 3 0.00 0.00000 1 0.00
6 1 5 - 6 0.0000 3 0.00 0.0000 1 0.00
7 1 6 - 7 0.0000 3 0.00 0.0000 1 0.00
8 1 7 - 8 0.0000 3 0.00 0.0000 1 0.00
9 1 8 - 9 0.0000 3 0.00 0.0000 1 0.00
10 1 9 - 10 0.0000 3 0.00 0.0000 1 0.00
11 1 10 - 11 0.0000 3 0.00 0.0000 1 0.00
12 1 11 - 12 0.0000 3 0.00 0.0000 1 0.00
13 1 12 - 13 0.0000 3 0.00 0.0000 1 0.00
14 1 13 - 14 0.0000 3 0.00 0.0000 1 0.00
15 1 14 - 15 0.0000 3 0.00 0.0000 1 0.00
16 1 15 - 16 0.0000 3 0.00 0.0000 1 0.00
17 1 16-17 0.0000 1 0.00 0.0000 1 0.00
18 1 17-18 0.0000 1 0.00 0.0000 1 0.00
19 1 18-19 0.0000 1 0.00 0.0000 1 0.00
20 1 19-20 0.0000 1 0.00 0.0000 1 0.00
21 1 20-21 0.0000 1 0.00 0.0000 1 0.00
22 1 21-22 0.0000 1 0.00 0.0000 1 0.00
23 1 22-23 0.0000 1 0.00 0.0000 1 0.00
24 1 23-24 0.0000 1 0.00 0.0000 1 0.00
25 1 24-25 0.0000 1 0.00 0.0000 1 0.00
26 1 25-26 0.0000 1 0.00 0.0000 1 0.00
27 1 26-27 0.0000 1 0.00 0.0000 1 0.00
28 1 27-28 0.0000 1 0.00 0.0000 1 0.00
29 1 28-29 0.0000 1 0.00 0.0000 1 0.00
30 1 29-30 0.0000 1 0.00 0.0000 1 0.00
Total Increased Cancer Risk 4.41 0.07
* Third trimester of pregnancy
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Attachment 3: Health Risk Screening Information and Calculations 524 of 1220
BAAQMD RASTER Screening Data – Roadway Cancer Risk Impacts at the Cancer Risk MEI 525 of 1220
BAAQMD RASTER Screening Data – Roadway PM2.5 Concentration Impacts at the PM2.5 MEI
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BAAQMD RASTER Screening Data – Roadway Hazard Index Impacts at the Cancer Risk MEI
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BAAQMD RASTER Screening Data – Roadway Cancer Risk Impacts at the Project Site
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BAAQMD RASTER Screening Data – Roadway PM2.5 Concentration Impacts at the Project Site 529 of 1220
BAAQMD RASTER Screening Data – Roadway Hazard Index Impacts at the Project Site 530 of 1220
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Screening Report
Area of Interest (AOI) Information
Area : 5,325,516.41 ft²
May 17 2023 11:11:57 Pacific Daylight Time
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Summary
Name Count Area(ft²) Length(ft)
Permitted Stationary Sources 0 N/A N/A
NOTE: A larger buffer than 1000 feet may be warranted depending on proximity to significant sources. 532 of 1220
MONK & ASSOCIATES
Environmental Consultants
June 3, 2024
Townsend Capital Partners LLC &
7515 Alder Avenue, LLC
1101 Fifth Avenue, Suite 300
San Rafael, California 94901
Attention: Collin Monahan
RE: Biological Resources at
Cotati Village II
Cotati, California
Dear Mr. Monahan:
On October 11, 2022, Monk & Associates (M&A) prepared a CEQA level Biological Resources Analysis (BRA) for the Cotati Village II project site (at that time we were still referring to the project site as Reds Residential).
To update baseline conditions and past floristic surveys conducted on the project site, in the spring of 2024, I conducted protocol level special-status plant surveys on the project site (dates of surveys: April 8, April 30, and May 14, 2024). A stand-alone report was prepared at the completion of those surveys and provided to you. No special-status plants were identified onsite.
All other baseline information and survey findings contained in the 2022 Biological Resources Analysis remains accurate today.
I do not see a reason to update the 2022 BRA as it remains valid today. While federal regulations governing waters of the U.S. have changed since the 2022 BRA was prepared, the U.S. Army Corps of Engineers has stated that the Jurisdictional Determination prepared for the project site is still valid today and they are honoring the existing map. This federal agency is in the process of preparing a Section 404 Nationwide Permit for the current project (i.e., Cotati Village Phase II) (an application package was submitted to the Corps in April 2024).
If you have any questions, please do not hesitate to contact me.
Sincerely,
Principal Biologist
1136 Saranap Ave., Suite Q ♦ Walnut Creek ♦ California ♦ 94595 (925) 947-4867 ♦ www.monkassociates.com
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MONK & ASSOCIATES
Environmental Consultants
BIOLOGICAL RESOURCES ANALYSIS
REDS RESIDENTIAL
(APNs 144-040-11 and 21)
CITY OF COTATI, SONOMA COUNTY, CALIFORNIA
October 11, 2022
Prepared for
7515 Alder Avenue, LLC
1101 Fifth Avenue, Suite 150
San Rafael, California 94901
Attention: Mr. Collin Monahan
Prepared by
Monk & Associates, Inc.
1136 Saranap Avenue, Suite Q
Walnut Creek, California 94595
Contact: Sam Stewart
1136 Saranap Ave., Suite Q Walnut Creek California 94595 (925) 947-4867 FAX (925) 947-1165 534 of 1220
MONK & ASSOCIATES
Biological Resources Analysis
Reds Residential
City of Cotati, Sonoma County, California
TABLE OF CONTENTS
1. INTRODUCTION ............................................................................................................................1
2. PROJECT LOCATION AND SETTING........................................................................................2
3. PROPOSED PROJECT....................................................................................................................2
4. ANALYSIS METHODS ..................................................................................................................2
4.1 Background Research..............................................................................................................2
4.2 Site Investigation .....................................................................................................................2
4.3 Wetland Delineation................................................................................................................3
4.4 Formal Special-Status Plant Surveys......................................................................................3
4.5 California Tiger Salamander Surveys.....................................................................................4
5. RESULTS OF RESEARCH AND PROJECT SITE ANALYSES ................................................6
5.1 Topography and Hydrology ....................................................................................................6
5.2 Soils..........................................................................................................................................6
5.3 Plant Communities and Associated Wildlife Habitats ...........................................................7
5.3.1 RUDERAL HERBACEOUS COMMUNITY....................................................................................7
5.3.2 SEASONAL WETLAND ..............................................................................................................8
5.4 Wildlife Corridors....................................................................................................................8
6. SPECIAL-STATUS SPECIES DEFINITION.................................................................................9
6.1 Definitions................................................................................................................................9
6.2 Potential Special-Status Plants on the Project Site...............................................................12
6.3 Potential Special-Status Animals on the Project Site ...........................................................13
6.3.1 CALIFORNIA TIGER SALAMANDER........................................................................................13
6.3.2 PALLID BAT............................................................................................................................16
7. REGULATORY FRAMEWORK FOR NATIVE WILDLIFE, FISH AND PLANTS...............17
7.1 Federal Endangered Species Act...........................................................................................17
7.1.1 RESPONSIBLE AGENCY ..........................................................................................................19
7.1.2 APPLICABILITY TO THE PROPOSED PROJECT .........................................................................19
7.2 Federal Migratory Bird Treaty Act .......................................................................................19
7.2.1 APPLICABILITY TO THE PROPOSED PROJECT........................................................................20
7.3 California Endangered Species Act ......................................................................................20
7.3.1 SECTION 2081 OF THE STATE ENDANGERED SPECIES ACT ..................................................20
7.3.2 APPLICABILITY TO PROPOSED PROJECT................................................................................22
7.4 California Fish and Game Code §§ 3503, 3503.5, 3511, and 3513.....................................22
7.4.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................22
7.5 Santa Rosa Plain Conservation Strategy...............................................................................22
7.5.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................24
7.6 Santa Rosa Plain 2020 Programmatic Biological Opinion ..................................................24
7.6.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................24
7.7 USFWS Recovery Plan for the Santa Rosa Plain (USFWS 2016)......................................25
7.7.1 APPLICABILITY TO PROPOSED PROJECT................................................................................26
7.8 City of Cotati Tree Ordinance - Chapter 17.54 Tree Preservation and Protection..............27
7.8.1 APPLICABILITY (17.54.020)...................................................................................................27
7.8.2 TREE PERMIT APPLICATION REQUIREMENTS (17.54.030)....................................................28
7.8.3 TREE PLANTING AND REPLACEMENT (17.54.050)................................................................31
7.8.4 TREE PERMIT APPROVAL FINDINGS AND CONDITIONS (17.54.060)......................................32 i
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Reds Residential
City of Cotati, Sonoma County, California
7.8.5 APPLICABILITY TO THE PROPOSED PROJECT .........................................................................33
8. REGULATORY REQUIREMENTS PERTAINING TO WATERS OF THE UNITED STATES AND STATE..................................................................................................................................33
8.1 U.S. Army Corps of Engineers Jurisdiction and Permitting ................................................33
8.2 Permitting Corps Jurisdictional Areas ..................................................................................36
8.2.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................38
8.3 State Water Resources Control Board (SWRCB)/California Regional Water Quality Control Board (RWQCB)............................................................................................................38
8.3.1 SECTION 401 OF THE CLEAN WATER ACT ............................................................................38
8.3.2 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................39
8.3.3 PORTER-COLOGNE WATER QUALITY CONTROL ACT ..........................................................39
8.3.4 APPLICABILITY TO PROPOSED PROJECT................................................................................40
8.3.5 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) ..............................40
8.3.6 APPLICABILITY TO THE PROPOSED PROJECT........................................................................43
9. STORM WATER LOW IMPACT DEVELOPMENT (SWLID).................................................43
9.1 Projects That Trigger Requirements .....................................................................................45
9.1.1 APPLICABILITY TO THE PROPOSED PROJECT ........................................................................45
10. CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE PROTECTIONS ......................46
10.1 Section 1602 of California Fish and Game Code...............................................................46
10.2 Applicability to Proposed Project .......................................................................................46
11. CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) REGULATIONS.................46
11.1.1 APPLICABILITY TO THE PROPOSED PROJECT ......................................................................47
12. IMPACTS ANALYSIS ................................................................................................................47
12.1 Significance Criteria............................................................................................................47
12.1.1 THRESHOLDS OF SIGNIFICANCE ..........................................................................................48
13. IMPACT ASSESSMENT AND PROPOSED MITIGATION...................................................49
13.1 Impact BIO-1: Development of the Proposed Project May Have a Potentially Significant Impact on Suitable Habitat for State and Federally listed Vernal Pool Plants (Potentially Significant)...................................................................................................................................49
13.2 Mitigation Measure BIO-1. For Impacts to Federally Listed Vernal Pool Plant Suitable Habitat..........................................................................................................................................50
13.3 Impact BIO-2. Development of the Proposed Project Would Have a Potentially Significant Adverse Impact on the State and Federally Listed California Tiger Salamander...50
13.4 Mitigation BIO-2. California Tiger Salamander ................................................................51
13.5 Impact BIO-3. Development of the Proposed Project Could Have a Potentially Significant Impact on Special-status Bats...................................................................................52
13.6 Mitigation Measure BIO-3. Special-Status Bats ................................................................52
13.7 Impact BIO-4. Development of the Proposed Project Would Have a Potentially Significant Impact on Nesting Raptors and Passerine Birds......................................................53
13.8 Mitigation Measure BIO-4. Nesting Birds .........................................................................53
13.9 Impact BIO-5. Development of the Proposed Project Would Have a Significant Impact on Waters of the United States and/or State. ..............................................................................54
13.10 Mitigation Measure BIO-5. Waters of the United States and/or State ............................54
13.11 Impact BIO-6. Development of the Proposed Project Would Have a Significant Impact on Protected Trees .......................................................................................................................55
13.12 Mitigation BIO-6. Protected Trees....................................................................................55 ii 536 of 1220
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Biological Resources Analysis
Reds Residential
City of Cotati, Sonoma County, California
14. LITERATURE CITED.................................................................................................................57
FIGURES
(At Back of Report)
Figure 1. Regional Map of the Project Site.
Figure 2. Project Site Location.
Figure 3. Aerial Photograph of the Project Site.
Figure 4. Closest Known Records of Special-Status Species Within 3 Miles of the Project Site.
Figure 5. Critical Habitat in the Vicinity of the Project Site.
Figure 6. Santa Rosa Plain Portion of Recovery Planning Area.
Figure 7. California Tiger Salamander Mitigation Requirement.
TABLES
(At Back of Report)
Table 1. Plant Species Observed on the Project Site.
Table 2. Wildlife Species Observed on the Project Site.
Table 3. Special-Status Plant Species Known to Occur in the Vicinity of the Project Site.
Table 4. Special-Status Wildlife Species Known to Occur in the Vicinity of the Project Site. iii 537 of 1220
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Biological Resources Analysis
Reds Residential
City of Cotati, Sonoma County, California
ATTACHMENTS
Attachment A. Formal Consultation on the Proposed Sterling Senior Community Project, Santa Rosa, Sonoma County, California (Corps File Number: 2007-400822N) Attachment B. Email from Mr. Jason Hanni on September 19, 2022, Approving Use of Existing BO for Sterling Senior Communities Project for Proposed Red’s Residential Project Attachment C. Stamped Jurisdictional Map for the Reds Project Site in Cotati, California dated May 21, 2018, from the U.S. Army Corps of Engineers.
Attachment D. Letter of Jurisdiction Determination dated May 21, 2018, from the U.S. Army Corps of Engineers.
Attachment E. Reds residential 126 unit residential development exhibit. Prepared by Design, Draw Build, August 17, 2022.
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Biological Resources Analysis
Reds Residential
City of Cotati, Sonoma County, California
1. INTRODUCTION
On behalf of 7515 Alder Avenue, LLC (the applicant), Monk & Associates (M&A) has prepared this Biological Resources Analysis (report) for the proposed Reds Residential Project (hereinafter the proposed project or project) in Cotati, California (formerly known as the Monahan Reds Project and later known as the Sterling Senior Communities Project) (Figures 1, 2, and 3). The project is proposed to be constructed on a 5.63-acre site located west of Highway 101 in the City of Cotati (herein referred to as the project site).
The project site is already partially developed with a retail/commercial building and a parking lot with some landscaping fronting Highway 116 and a now-abandoned home at the rear. The abandoned home would be removed to accommodate the remainder of this redevelopment project.
Biological resources include common plant and animal species, and special-status plants and animals as designated by the U.S. Fish and Wildlife Service (USFWS), California Department of Fish and Wildlife (CDFW), National Marine Fisheries Service (NMFS), and other resource organizations including the California Native Plant Society. Biological resources also include waters of the United States (U.S.) and State, as regulated by the U.S. Army Corps of Engineers (Corps), California Regional Water Quality Control Board (RWQCB), and CDFW.
The USFWS has already issued a Biological Opinion (BO) for the project site under a different project (Corps File Number: 2007-00822N, USFWS File No. 81420-2008-F-2061) dated December 10, 2019 (Attachment A). As the USFWS made it clear that this existing BO could be used for the Reds Residential project and it was not necessary to reinitiate Section 7 consultation solely for an updated project description, M&A believes that initiation of Section 7 is not warranted for this project. Mr. Mark Jasper (M&A) has been in contact with Mr. Jason Hanni (USFWS and author of the BO) about whether or not the BO would remain valid under the Reds Residential Project and a new Nationwide Permit (NWP). Per Mr. Hanni’s email on September 19, 2022 (Attachment B), the USFWS confirmed with M&A that the “effects of this project remain the same, while the project description would be the only part of the proposed action that would change. Based on those assumptions this would not trigger reinitiation, as it doesn't fit the reinitiation criteria as identified at the end of the Biological Opinion.” Note that the impacts to wetlands, federally listed species, and their habitats will be identical to the previously proposed project, the Sterling Senior Communities Project, for which the existing BO was issued.
This biological resources analysis also provides mitigation measures for “potentially significant” and “significant” impacts that could occur to biological resources. Whenever possible, upon implementation, the prescribed mitigation measures would reduce impacts to levels considered less than significant pursuant to the California Environmental Quality Act (CEQA) (Pub.
Resources Code §§ 21000 et seq.; 14 Cal. Code Regs §§ 15000 et seq). Accordingly, this report is suitable for review and inclusion in any review being conducted by the City of Cotati for the proposed project pursuant to the CEQA.
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Reds Residential
City of Cotati, Sonoma County, California
2. PROJECT LOCATION AND SETTING
The 5.63-acre project site is located at the northwest corner of Gravenstein Highway (Hwy 116) and Alder Avenue (Figures 2 and 3). Cotati Large Animal Hospital lies directly to the west of the project site. To the south of the project site, on the opposite side of Gravenstein Hwy, is Shamrock Materials, Inc., a commercial business specializing in stone and concrete building supplies. Ruderal (weedy) vegetation and annual grassland with ranchette style housing occurs to the north of the project site. Beyond Alder Avenue to the northeast is a recently built residential townhouse development called the Cotati Cottages subdivision, a vacant lot east of the project site is being reviewed by the City for final approval for a residential development.
North of the existing retail/commercial building is a ruderal field that was previously farmed and that is now disked annually for fire control practices. The former residence sits to the east of this disked field along Alder Avenue. Additionally, there are scattered native oaks that occur on the project site (Quercus garryana and Q. lobata).
3. PROPOSED PROJECT
The proposed project includes updating the existing commercial buildings on the southern side of the site along Gravenstein Highway frontage (formerly a bar/night club which is currently undergoing renovations. To the north of the existing commercial space, the proposed project includes the construction of a mixed-use apartment development, featuring 126 units across four buildings, on a 5.63-acre site. Additionally, a 3,410 square foot community center will be constructed at the center of the project site with residential amenities. Thirteen of the 126 units are intended to be rented as affordable units for families in the very low-income bracket at 50% of area median income.
The northern portion of the project site is currently a large field and the master plan aims to maintain maximum open space with unobstructed sight lines across the site. The building aesthetic will be a modern craftsman style, to remain consistent with the character of the surrounding neighborhood and the City of Cotati.
4. ANALYSIS METHODS
4.1 Background Research
Prior to preparing this Biological Resource Analysis, M&A researched the most recent version of the California Department of Fish and Wildlife (CDFW) Natural Diversity Database (CNDDB), RareFind 5 application (CNDDB 2022) for historical and recent records of special-status plants and wildlife known to occur in the region of the project site. All special-status species records were compiled in tables. M&A examined all known record locations for special-status species to determine if special-status species could occur on the project site or within an area of affect.
4.2 Site Investigation
M&A biologists have a long history working on this project site. M&A biologists conducted a general survey of the project site on July 15, 2016 (Geoff Monk and Christy Owens) and on May 31, 2022 (Sam Stewart and Sarah Lynch), to record biological resources and to assess the 2 540 of 1220
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Reds Residential
City of Cotati, Sonoma County, California
likelihood of resource agency regulated areas on the project site. Other surveys of the site were also conducted as reported in the Wetland Delineation and Rare Plant Survey Methods sections below. During all surveys of the project site M&A recorded all plant and wildlife species observed. M&A then cross-referenced the habitats found on the project site against the habitat requirements of local or regionally known special-status species to determine if the proposed project could directly or indirectly impact such species.
4.3 Wetland Delineation
On July 25, 2008, the U.S. Army Corps of Engineers (Corps) confirmed the extent of its jurisdiction on the project site (Corps File No. SPN-2007-400822-N). This jurisdictional map remained valid until July 25, 2010. On July 15, 2016, and April 24, 2017, M&A biologists Mr.
Monk and Ms. Owens visited the project site to re-examine potential Corps-regulated areas.
Delineation fieldwork was conducted in 2016 and again in 2017 after the wettest winter on record in more than 50 years. Mapped features on the project site were determined to meet jurisdictional criteria presented in the Corps’ 1987 Wetlands Delineation Manual (Corps 1987) and the Corps’ Regional Supplement for the Arid West Region (Corps 2008). A Request for a Preliminary Jurisdictional Determination (PJD) and the Preliminary Aquatic Resources Map were submitted to the Corps on August 18, 2017. On September 8, 2017, Ms. Roberta Morganstern from the Corps confirmed the extent of the Corps’ jurisdiction on the project site.
On March 20, 2018, M&A biologist, Ms. Christy Owens, visited the project site again to examine potential Corps-regulated areas within potential offsite impact areas associated with City-required improvements to Highway 116 including acceleration and deceleration lanes. Ms.
Owens mapped all features within the potential offsite impact areas that were determined to meet jurisdictional criteria presented in the Corps’ 1987 Wetlands Delineation Manual (Corps 1987) and the Corps’ Regional Supplement for the Arid West Region (Corps 2008). An amended Request for a Preliminary Jurisdictional Determination and the Preliminary Aquatic Resources Map were submitted to the Corps on August 18, 2018, and confirmed by Ms. Roberta Morganstern of the Corps on May 21, 2018, verifying the extent of the Corps’ jurisdiction within the expanded limits of delineation which includes the project site (Attachments C and D). The issued PJD is still valid today.
4.4 Formal Special-Status Plant Surveys
Formal special-status plant surveys were conducted on the project site in 2015 by Mr. Roy Buck, Senior Botanist with California Environmental Services, LLC. The surveys followed the rare plant survey methods required then by California Department of Fish and Game [now the CDFW] (CDFG 2000), California Native Plant Society (CNPS) published survey guidelines (CNPS 2001), and the USFWS’ guidelines for the Santa Rosa Plain (USFWS 2005a). Plant phenology (flowering periods) reference site surveys conducted by Mr. Buck confirmed that targeted rare plants were visible and in flower at the reference site on the dates of project site surveys. Specifically, Mr. Buck confirmed that Sonoma Sunshine (Blennosperma bakeri), Burke’s goldfields (Lasthenia burkei), and Sebastopol meadowfoam (Limnanthes vinculans) were visible and in flower during the period that rare plant surveys were conducted on the project site. These plant phenology reference site surveys were conducted by Mr. Buck on March 28, 3 541 of 1220
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City of Cotati, Sonoma County, California
April 18, and May 3, 2015, at the Alton Lane Conservation Area. No special-status plants were identified on the project site in 2015.
On July 15, 2016; April 24, May 26, and June 15, 2017; and April 9, April 30 and May 23, 2019, M&A biologists Ms. Owens and Mr. Monk conducted formal special-status plant surveys on the project site. Surveys conducted in 2016 were targeted for early and mid-summer blooming special-status plant taxa. All surveys were conducted according to USFWS-published survey guidelines for the Santa Rosa Plain as well as the CDFW- and CNPS-published survey guidelines. Following these guidelines, all surveys in 2017 were conducted in a timeframe when listed plants known from the Santa Rosa Plain were confirmed to be visible and in flower. Ms.
Owens and Mr. Monk conducted reference site visits to confirm that Sonoma Sunshine (Blennosperma bakeri), Burke’s goldfields (Lasthenia burkei), and Sebastopol meadowfoam (Limnanthes vinculans) were visible and in flower at the reference site during the period that special-status plant surveys were conducted on the project site in 2017. These plant phenology reference site surveys were conducted by Mr. Monk and Ms. Owens on April 24, May 26, and June 15, 2017, at Alton Lane Conservation Area. During all special-status plant surveys of the project site, all plants observed were identified to a level necessary to determine rarity status. No special-status plants were identified on the project site in 2016 or 2017. All species observed during M&A’s 2016, 2017, 2019 and 2022 surveys are included in Table 1.
One additional year of special-status plant surveys were conducted in spring and early summer of 2019 by M&A biologist Christy Owens on April 9, April 30, and May 23, 2019. Surveys were conducted according to USFWS-published survey guidelines for the Santa Rosa Plain as well as the CDFW- and CNPS-published survey guidelines. These surveys were conducted in accordance with newly published-CDFW survey guidelines released as of March 18, 2018, and serve to bring the previous year’s surveys up to date with new survey guidelines and fulfill the CDFW recommendation for yearly surveys of annual and short-lived perennial special-status plants in herbaceous plant communities to accurately document baseline conditions for the purposes of impact assessment.
4.5 California Tiger Salamander Surveys
Circa 1995, M&A’s Principal Biologist, Mr. Monk, confirmed that the California tiger salamander (Ambystoma californiense) was breeding in two seasonal pools on the now mostlydeveloped Sonoma Business Park project site located immediately east of the project site.
Sonoma Business Park was mass-graded, and a master drainage plan was installed in 2001. At that time, the California Department of Fish and Game (CDFG) (now CDFW) designated the California tiger salamander as a “species of special concern.” This salamander was not federally listed until July 22, 2002, and it was not state listed until August 19, 2010. All California tiger salamander habitat was removed by that grading project in 2001. All impacts to California tiger salamander were fully mitigated to the satisfaction of the USFWS and CDFG (now CDFW) by the Sonoma Business Park developer as part of the mass grading permit conditions from these agencies.
As part of the Sonoma Business Park development project, in a subsequent phase of the development in 2003/2004, the developer was required to salvage California tiger salamander 4 542 of 1220
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Reds Residential
City of Cotati, Sonoma County, California
presumed to be migrating from adjacent properties, including the project site, to the former (now developed) breeding pools on the Sonoma Business Park project site. This salvage was conducted under the assumption that all adult California tiger salamanders and their breeding habitat had been removed from the Sonoma Business Park project site when it was mass graded in June 2002. The recovery/salvage project was implemented under expectation that the balance of the Sonoma Business Park and the parcel to the north (then called the Nibe project site) and the project site would be developed under a master development project.
Mr. Jim Browning of the USFWS reviewed and approved the California tiger salamander salvage plan. On November 5, 2003, Mr. Dan Buford of the USFWS provided an email approval for M&A to construct and operate the California tiger salamander drift fence/pitfall trapping arrays as part of the salvage operation. The USFWS approved the translocation of salvaged (captured) California tiger salamanders under the condition that it would be completed under the direct supervision of Mr. Liam Davis and Mr. Bill Cox of the CDFW.
During the 2003/2004 trapping season, to conduct California tiger salamander salvage, M&A installed drift fence/trapping arrays prior to the onset of heavy seasonal rains. Approximately 4,220 linear feet of drift fence was constructed immediately to the west and the north of the Sonoma Business Park Project Site boundaries. One array was installed on the Nibe site to the north and one on the Reds site (on the project site) to the west of the Business Park project site.
These arrays were expected to catch California tiger salamanders that could still be migrating to the two now developed pools on the Sonoma Business Park project site that had been removed in June of 2002. A total of 141 pitfall traps were installed in the drift fence arrays. A total of 82 adult California tiger salamanders were captured and about one third of these were translocated under the supervision and direction of Mr. Bill Cox of the CDFW to the Gobbi Bank site. The rest of the California tiger salamanders were likely located to the Alton Lane Conservation Preserve per information in an email of December 9, 2003, from Mr. Jim Browning to Wayne White, Cay Goude and Dan Buford at USFWS. In this email, Mr. Browning stated that he had just talked to Mr. Carl Wilcox (of the CDFW) and told him that USFWS was okay with CDFW's proposal to relocate the captured California tiger salamander to the Alton Lane Preserve (now known as the Alton Lane Conservation Site).
In September 2007, M&A prepared and submitted a report to the USFWS and CDFW summarizing the salvage trapping effort titled California Tiger Salamander (Ambystoma californiense) Survey and Salvage Summary of the “Nibe” and “Red’s” Project Sites Santa Rosa, California September 20, 2007. That report indicates that 12 of the adult California tiger salamanders that were captured on the Reds Project Site in 2003/2004 winter and were surrendered to the CDFW for translocation.
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5. RESULTS OF RESEARCH AND PROJECT SITE ANALYSES
5.1 Topography and Hydrology
The project site is relatively flat with slight undulating topography. There is a topographic depression located on the project site’s northern edge (W1 on Attachment C). This low area remains inundated and/or saturated throughout the winter and early spring months. During large (episodic) storm events, W1 overflows and conveys water overland eastward where these flows enter a City of Cotati storm drain inlet along Alder Avenue that eventually conveys stormwaters into the Laguna de Santa Rosa, that drains into Mark West Creek, which flows into the Russian River.
Offsite, just beyond the project site’s western boundary, there is an incised drainage ditch. This ditch receives large storm event sheet flows off surrounding properties including the western portion of the project site. This drainage ditch will not be modified by the proposed project.
Large storm event sheet flows that collect in the offsite drainage ditch flow southward to a roadside ditch along the north side of Highway 116, that then conveys these large storm event (flashy) flows westward of the project site. The parallel roadside ditch was originally excavated in uplands when Highway 116 was constructed decades ago.
The segment of roadside ditch along the frontage of the project site and in the offsite improvement areas along Highway 116 were investigated as part of both the 2016/2017 and the 2018 wetland delineations conducted by M&A of the project site and potential offsite impact areas, respectively. The roadside ditch along the project site’s frontage does not support wetland features and showed no evidence of standing water or flow patterns and thus likely only conveys water during large storm events. It also does not drain from wetlands. Thus, it was determined by the Corps on September 8, 2017, and again on May 21, 2018 (Attachments C and D), that the small roadside ditch along Highway 116 within the proposed limits of the project including offsite improvement areas, does not support any jurisdictional “wetlands” or “other waters.”
5.2 Soils
The Soils Conservation Service (SCS), now called the Natural Resource Conservation Service (NRCS), mapped one soil type for the project site. The mapped soil unit is Haire Fine Sandy Loam, Hummocky, 0 to 5 percent slopes. The Haire Soil series consists of moderately welldrained soils that occur on nearly level to moderately steep hills, on old terraces, and alluvial fans. Slope ranges from 0 to 30 percent, and elevation ranges from 20 to 300 feet. These soils formed from alluvium derived from sedimentary rock. The vegetation in uncultivated areas consists of annual grasses and forbs. Permeability is very slow, and the hazard of erosion is slight. Haire soils are mainly used for dryland and irrigated pasture, but some areas are used for vineyards and rangeland. Typically, Haire soils have gray and grayish brown, neutral or slightly acid, light clay loam upper horizons. Haire fine sandy loam is found on undulating or hummocky terrain, with a clay subsurface layer. Soils typically have low fertility with an available water capacity at 6 to 8 inches. Haire Fine Sandy Loam, Hummocky, 0 to 5 percent slopes is not a hydric (“wetland”) soil.
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The project site soils have been heavily altered by a combination of historical development and farming that occurred on the project site over past decades. While the northern half of the project site exhibits soils that meet the NRCS soil profile, the southern half of the project site exhibit gravelly loams that range from a few inches thick to greater than 12 inches. These currently or formerly developed soils overlay the Haire Soils that the NRCS mapped on the project site.
5.3 Plant Communities and Associated Wildlife Habitats
The majority of the project site is undeveloped. However, there is a small, abandoned residence in the northeastern corner, and two refurbished retail buildings fronting Highway 116. There is also a small shed surrounding a well/water tank.
The majority of the northern side of the project site is an undeveloped field with scattered native oaks (Quercus garryana and Q. lobata). Due to the history of intensive site disturbance, only two distinct plant communities were identified on the project site: ruderal herbaceous and seasonal wetland.
Nomenclature used for plant names follows The Jepson Manual, 2nd edition (Baldwin 2012) and changes made to this manual as published on the Jepson Interchange Project website (http://ucjeps.berkeley.edu/interchange/index.html). A complete list of plant species observed on the project site is presented in Table 1. Nomenclature for wildlife follows the CDFW’s Complete list of amphibian, reptile, bird, and mammal species in California (CDFW 2016) and any changes made to species nomenclature as published in scientific journals since the publication of the CDFW’s list. A complete list of wildlife species observed on the project site is presented in Table 2.
5.3.1 RUDERAL HERBACEOUS COMMUNITY
Ruderal (weedy) communities are assemblages of plants that thrive in waste areas, roadsides and other sites that have been disturbed by human activity. This community is typically dominated by introduced annual grasses and forbs that are highly adapted to high-intensity ongoing disturbance. The native, perennial bunchgrasses that dominated the native grassland prior to European settlement have now been largely displaced by these ruderal species.
A ruderal herbaceous community comprises the majority of the project site. Some of these nonnative grass dominants found on the project site include Harding grass (Phalaris aquatica), wild oats (Avena barbata), soft chess (Bromus hordeaceus), ripgut brome (Bromus diandrus), Italian ryegrass (Festuca perennis), brome fescue (Festuca bromoides), hare barley (Hordeum murinum ssp. leporinum) and tall oatgrass (Arrhenatherum elatius). Common non-native forbs found on the project site include bristly ox-tongue (Helminthotheca echioides), bindweed (Convolvulus arvensis), Italian thistle (Carduus pycnocephalus ssp. pycnocephalus), purple salsify (Tragopogon porrifolius), Queen Ann’s lace (Daucus carota), fennel (Foeniculum vulgare), prickly lettuce (Lactuca serriola), rough cat’s ear (Hypochaeris radicata), spring vetch (Vicia sativa), wild radish (Raphanus sativus), cutleaf geranium (Geranium dissectum), mustards (Brassica nigra, Hirschfelda incana and Sisymbrium altissimum) and clovers (Trifolium incarnatum, Trifolium subterraneum, Trifolium dubium and Trifolium hirtum). Due to past cultivation of lavender fields and grading disturbance, very few native, herbaceous taxa remain 7 545 of 1220
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on the project site. The few native plant species found in the ruderal community includes California poppy (Eschscholzia californica), Spanish clover (Acmispon americanus ssp. americanus), willow herb (Epilobium brachycarpum), cleavers (Galium aparine), summer cottonweed (Epilobium brachycarpum) and creeping wildrye (Elymus triticoides ssp. triticoides).
Animals observed or expected to occur in ruderal habitats are typically those species adapted to human disturbance such as the following species observed on the project site: northern mockingbird (Mimus polyglottos), European starling (Sturnus vulgaris), mourning dove (Zenaida macroura), house sparrow (Passer domesticus), house finch (Haemorhous mexicanus), and black phoebe (Sayornis nigricans).
5.3.2 SEASONAL WETLAND
Seasonal wetlands are habitats that may appear dry in the summer and fall months but following the first winter rains, become saturated or hold water for a period of several weeks to months at a time. Seasonal wetlands may remain inundated for a prolonged period typically due to the presence of impervious soils and/or confining topography such as topographic low areas.
Typically, these wetlands are dominated by a mix of native and non-native, hydrophytic plant species.
One seasonal wetland occurs in a slight topographic low area in the northern portion of the project site. M&A examined this wetland in the winter months in 2003/04. It pooled to a few inches deep before drying/draining and then refilling with successive larger storm events. M&A examined this wetland again over the years, between 2016 through 2022. A mix of common nonnative and native upland and hydrophytic(wetland) herbaceous species were observed within this seasonal wetland. Dominant species included annual semaphore grass (Pleuropogon californicus), Italian ryegrass, Mediterranean barley (Hordeum marinum ssp gussoneanum), meadow foxtail (Alopecurus pratensis), pennyroyal (Mentha pulegium) and hawkbit (Leontodon saxitilis). Other associated species include brown-headed rush (Juncus phaeocephalus ssp. paniculatus), English plantain (Plantago lanceolata), prickly little sedge (Carex echinata ssp. echinata), tall flatsedge (Cyperus eragrostis), foothill clover (Trifolium ciliolatum), velvet grass (Holcus lanatus), curly leaved dock (Rumex crispus) and hairy cat’s ear (Hypochaeris radicata).
Seasonal wetlands provide wildlife with a seasonal water source that allows animals to drink and forage in the water during the winter and spring months; however, the shallow, highly disturbed and highly ephemeral nature of the seasonal wetland on the project site make them nearly unavailable for wildlife use.
5.4 Wildlife Corridors
Wildlife corridors are linear and/or regional habitats that provide connectivity to other natural vegetation communities within a landscape fractured by urbanization and other development.
Wildlife corridors have several functions: 1) they provide avenues along which wide-ranging animals can travel, migrate, and breed, allowing genetic interchange to occur; 2) populations can move in response to environmental changes and natural disasters; and 3) individuals can recolonize habitats from which populations have been locally extirpated (Beier and Loe 1992).
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to wildlife. Regional wildlife corridors provide foraging, breeding, and retreat areas for migrating, dispersing, immigrating, and emigrating wildlife populations. Local wildlife corridors also provide access routes to food, cover, and water resources within restricted habitats.
The proposed project will not interfere with the movement of native wildlife. The project site is immediately north of Gravenstein Highway (Hwy 116) and west of Alder Avenue, both of which are pre-existing barriers to wildlife movement. Gravenstein Highway, in particular, is a heavily used commuter route providing access from/to Highway 101 to the surrounding residential and commercial areas as well as being the primary commuter route to/from Sebastopol.
Cotati Large Animal Hospital lies directly to the west of the project site. To the south of the property, across the Gravenstein Hwy, is Shamrock Materials, Inc., a business specializing in stone and concrete building supplies. Ruderal (weedy) vegetation and annual grassland with ranchette style housing occurs to the north of the project site. As such, development of the project site will not impact any significant or regional wildlife corridor. The project site is a formerly developed parcel that has been subjected to intense uses over the past 20 years. Overall, the project site is highly disturbed by grading and horticultural cultivation, developed with buildings or hard-packed, gravel-impregnated roadways and parking areas around buildings with the remaining areas cultivated as lavender fields. The project site does not have regional context between other open spaces and there virtually is nowhere that wildlife could be moving to/from except developed areas. While the project site may provide movement habitat for local mammals, most of these mammals are associated with development, such as house cats. The development of the project site will not adversely impact any significant or regional wildlife movement corridor.
6. SPECIAL-STATUS SPECIES DEFINITION
6.1 Definitions
For purposes of this analysis, special-status species are plants and animals that are legally protected under the California and Federal Endangered Species Acts (CESA and FESA, respectively) or other regulations, and species that are considered rare by the scientific community (for example, the CNPS). Special-status species are defined as:
plants and animals that are listed or proposed for listing as threatened or endangered under the CESA (Fish and Game Code §2050 et seq.; 14 CCR §670.1 et seq.) or the FESA (50 CFR 17.12 for plants; 50 CFR 17.11 for animals; various notices in the Federal Register [FR] for proposed species);
plants and animals that are candidates for possible future listing as threatened or endangered under the FESA (50 CFR 17; FR Vol. 64, No. 205, pages 57533-57547, October 25, 1999); and under the CESA (California Fish and Game Code §2068); plants and animals that meet the definition of endangered, rare, or threatened under the CEQA (14 CCR §15380) that may include species not found on either CESA or FESA lists;
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plants occurring on Ranks 1A, 1B, 2A, 2B, 3, and 4 of CNPS’ electronic Inventory (CNPS 2001). The CDFW recognizes that Ranks 1A, 1B, 2A and 2B of the CNPS inventory contain plants that, in the majority of cases, would qualify for State listing, and CDFW requests their inclusion in EIRs. Plants occurring on CNPS Ranks 3 and 4 are "plants about which more information is necessary," and "plants of limited distribution," respectively (CNPS 2022). Such plants may be included as special-status species on a case-by-case basis due to local significance or recent biological information (more on CNPS Rank species below);
migratory nongame birds of management concern listed by the USFWS (Migratory Nongame Birds of Management Concern in the United States: The list 1995; Office of Migratory Bird Management; Washington D.C.; Sept. 1995); animals that are designated as "species of special concern" by CDFW (2022); animal species that are “fully protected” in California (Fish and Game Codes 3511, 4700, 5050, and 5515).
bat Species that are designated on the Western Bat Working Group’s (WBWG) Regional Bat Species Priority Matrix as: “RED OR HIGH.” This priority is justified by the WBWG as follows: “Based on available information on distribution, status, ecology, and known threats, this designation should result in these bat species being considered the highest priority for funding, planning, and conservation actions. Information about status and threats to most species could result in effective conservation actions being implemented should a commitment to management exist. These species are imperiled or are at high risk of imperilment.”
In the paragraphs below, we provide further definitions of legal status as they pertain to the special-status species discussed in this report or in the attached tables.
Federal Endangered or Threatened Species. A species listed as endangered or threatened under the FESA is protected from unauthorized “take” (that is, harass, harm, pursue, hunt, shoot, trap) of that species. If it is necessary to take a federally listed endangered or threatened species as part of an otherwise lawful activity, it would be necessary to receive permission from the USFWS prior to initiating the take.
State Threatened Species. A species listed as threatened under the state CESA (§2050 of California Fish and Game Code) is protected from unauthorized “take” (that is, harass, pursue, hunt, shoot, trap) of that species. If it is necessary to “take” a State listed threatened species as part of an otherwise lawful activity, it would be necessary to receive permission from CDFW prior to initiating the “take.”
California Species of Special Concern. These are species in which their California breeding populations are seriously declining and extirpation from all or a portion of their range is possible. 10 548 of 1220
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This designation affords no legally mandated protection; however, pursuant to the CEQA Guidelines (14 CCR §15380), some species of special concern could be considered “rare.” Pursuant to its rarity status, any unmitigated impacts to rare species could be considered a “significant effect on the environment” (§15382). Thus, species of special concern must be considered in any project that will, or is currently, undergoing CEQA review, and/or that must obtain an environmental permit(s) from a public agency.
CNPS Rank Species. The CNPS maintains an “Inventory” of special status plant species. This inventory has four lists of plants with varying rarity. These lists are: Rank 1, Rank 2, Rank 3, and Rank 4. Although plants on these lists have no formal legal protection (unless they are also State or federally listed species), CDFW requests the inclusion of Rank 1 species in environmental documents. In addition, other State and local agencies may request the inclusion of species on other lists as well. The Rank 1 and 2 species are defined below:
Rank 1A: Presumed extinct in California;
Rank 1B: Rare, threatened, or endangered in California and elsewhere; Rank 2A: Plants presumed extirpated in California, but more common elsewhere; Rank 2B: Rare, threatened, or endangered in California, but more common elsewhere.
All of the plants constituting Rank 1B meet the definitions of Section 1901, Chapter 10 (Native Plant Protection Act) or Sections 2062 and 2067 (California Endangered Species Act) of the Fish and Game Code, and are eligible for state listing (CNPS 2001). Rank 2 species are rare in California, but more common elsewhere. Ranks 3 and 4 contain species about which there is some concern, and are reviewed by CDFW and maintained on “watch lists.” Additionally, in 2006, the CNPS updated their lists to include “threat code extensions” for each list. For example, Rank 1B species would now be categorized as Rank 1B.1, Rank 1B.2, or Rank 1B.3. These threat codes are defined as follows:
.1 is considered “seriously endangered in California (over 80% of occurrences threatened/high degree and immediacy of threat)”;
.2 is “fairly endangered in California (20-80% of occurrences threatened)”; .3 is “not very endangered in California (less than 20% of occurrences threatened or no current threats known).”
Under the CEQA review process only CNPS Rank 1 and 2 species are considered since these are the only CNPS species that meet CEQA’s definition of “rare” or “endangered.” Impacts to Rank 3 and 4 species are not regarded as significant pursuant to CEQA.
Fully Protected Birds. Fully protected birds, such as the White-tailed Kite (Elanus leucurus) and Golden Eagle (Aquila chrysaetos), are protected under California Fish and Game Code (§3511).
Fully protected birds may not be “taken” or possessed (i.e., kept in captivity) at any time. 11 549 of 1220
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6.2 Potential Special-Status Plants on the Project Site Figure 4 provides a graphical illustration of the known records of special-status plant species within three miles of the project site and helps readers visually understand the number of sensitive species that occur in the vicinity of the project site. Based on a record search of the CDFW’s CNDDB (2022) for special-status plant records occur within three miles of the project site, and the CNPS Inventory (CNPS 2022) for a list of special-status plant species from the same U.S. Geological Survey quadrangle as the project site (Cotati Quadrangle), M&A compiled a list of 12 special status plant species that are known from the region of the project site (Table 3).
Formal special-status plant surveys were conducted on the project site in 2015 by Mr. Roy Buck, Senior Botanist with California Environmental Services, LLC, and by staff at M&A in 2016, 2017 and 2019. No special-status plants were found during the required two years of specialstatus plant surveys conducted at appropriate times when the targeted listed plants were identified in flower at reference population sites. Similarly, M&A conducted a mid-summer special-status plant survey on July 15, 2016, and further special-status plant surveys on April 24, May 26 and June 15, 2017, and on, April 9, April 30, and May 23, 2019 for late-blooming species and identified no special-status plants. In compliance with the (then) newly publishedCDFW survey guidelines released on March 18, 2018, one additional year of surveys was conducted on the project site in 2019 to bring the previous year’s surveys up to date and to demonstrate the absence of special-status plants on the project site under the most current and up to date survey guidelines. No special-status plants have been identified on the project site during surveys conducted in 2015, 2016, 2017, and 2019. Thus, pursuant to the CEQA, development of the project site will not result in significant impacts on federally, state-listed plants, or other plants that have special status species designations.
Regardless, pursuant to the existing BO issued in 2019, even when two years of surveys proves absence of endangered listed plants, due to the potential for a seedbank being present, impacts to “Suitable Habitat”1 must nonetheless be mitigated for by purchase of conservation credits providing 1.5:1 occupied or established habitat (any combination) with success criteria met prior to groundbreaking at the project site. Thus, if the project requires a Corps permit, even with two years of formal rare plant surveys that were negative for rare plants, to obtain a Corps permit,
1.5:1 replacement to impacts of vernal pool listed plant mitigation credit must be obtained by the project, if mitigation occurs in the same core area as impacts; and, if mitigation occurs in a different core area as impacts, then a 3:1 replacement to impacts of vernal pool listed plant mitigation credit must be obtained. See Section 13.2 below for further details on mitigation proposed to offset impacts to suitable habitat for Burke’s goldfields, Sebastopol meadowfoam, and Sonoma sunshine.
1 in this case suitable habitat falls under the 2020 Programmatic BO definition of a “seasonal wetland located within a Core or Management Area”
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6.3 Potential Special-Status Animals on the Project Site Based on a record search of the CDFW’s CNDDB (2022) for special-status wildlife records within three miles of the project site, M&A compiled a list of nine special-status wildlife species that are known from the vicinity of the project site (Table 4). The project site does not provide suitable habitat for eight of these nine species, and as such, these species are summarily dismissed from further consideration. An additional species to those listed in Table 4 which could occur onsite is the regionally occurring pallid bat (Antrozous pallidus) (there is an occurrence from 1997 approximately 9 miles southeast of the project site (Occurrence #50).
As the California tiger salamander has been captured on the site during a salvage project that was approved and implemented in 2003/2004, and as there is suitable habitat for the pallid bat (Antrozous pallidus), which are known to occur in the region of the project site, we discuss these species further below. Figure 4 provides a visual representation of the known records of specialstatus wildlife species within three miles of the project site.
6.3.1 CALIFORNIA TIGER SALAMANDER
The project site is located within the known range of the Sonoma County “Distinct Population Segment” (DPS) of the California tiger salamander. Under the FESA, the USFWS emergency listed the Sonoma County DPS as endangered on July 22, 2002. The USFWS formalized the listing of the Sonoma County DPS of the California tiger salamander as endangered on March 19, 2003 (USFWS 2003b). The USFWS determined that this population is significantly and immediately imperiled by a variety of threats including habitat destruction, degradation, and fragmentation due to urban development, road construction, pesticide drift, collection, and inadequate regulatory mechanisms. In addition, it was determined that this population could face extinction because of naturally occurring events (e.g., fires, droughts) due to the small and isolated nature of the remaining breeding sites combined with the small number of individuals in the population.
Finally, in 2011, the USFWS designated revised critical habitat for the Sonoma County DPS. In total, approximately 47,383 acres (19,175 hectares) of land were designated as critical habitat for the Sonoma County DPS of the California tiger salamander under the revised Final Rule (USFWS 2011). The project site is within this mapped critical habitat (Figure 5).
On March 4, 2010, the California tiger salamander was also state listed as a threatened species under the CESA. Proposed projects may not impact the California tiger salamander without incidental take authority from both the USFWS and the CDFW. Prior to impacting habitat that supports the California tiger salamander, the USFWS must prepare an incidental take permit pursuant to either Section 7 or Section 10 of the Federal Endangered Species Act. Similarly, projects that impact the California tiger salamander also require incidental take authority from the CDFW.
CTS occur in grasslands and open oak woodlands that provide suitable over-summering and/or breeding habitats. M&A has worked with populations that are almost at sea level (Catellus Site in the City of Fremont) to almost 2,900 feet above sea level (Kammerer Ranch, East Santa Clara County). California tiger salamanders spend most their lives underground. They typically only 13 551 of 1220
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emerge from their subterranean refugia for a few nights each year during the rainy season to migrate to breeding ponds. While 1.3 miles is typically considered the maximum migration distance of California tiger salamanders to/from their breeding pools to upland over-summering habitat, there is literature suggesting that California tiger salamanders could migrate up to 1.5 miles from their breeding pools. This migration distance is reported by the USFWS’ Recovery Plan for the Santa Rosa Plain (USFWS 2016) where it states: Based on distances travelled per night, Searcy and Shaffer (2011) estimated that Central California tiger salamanders are physiologically capable of moving up to 2.4 km (1.5 mi) each breeding season, with an average dispersal distance estimated to be 0.56 km (1,840 ft). Orloff (2007) found that the majority of California tiger salamanders dispersed at least 0.5-mile (0.8 km) from the breeding site, with a smaller number of salamanders appearing to move even farther—from 1.2 to 2.2 km (0.75 to 1.3 mi) between breeding ponds and upland habitat. M&A biologists, Mr. Geoff Monk and Ms.
Sarah Lynch have observed California tiger salamanders migrating up to 0.6-mile and further from their underground refugia to breeding ponds (personal data from Livermore, California; Monk & Lynch 1997). As such, unobstructed migration corridors are important component of California tiger salamander habitat.
In Sonoma County, California tiger salamanders emerge during the first heavy, warm rains of the year, typically in late November and early December. In most instances, larger movements of California tiger salamanders do not occur unless it has been raining hard and continuously for several hours. Typically, for larger movements of California tiger salamanders to occur, nighttime temperatures also must be above 48° F (G. Monk and S. Lynch pers. observations).
Other factors that encourage larger movements of California tiger salamanders to their breeding ponds include flooding of refugia (observed by G. Monk in Springtown, east Alameda County in 1997) as occurs after significant rainfall events.
During the spring, summer, and fall months, most known populations of the California tiger salamander throughout this species range in California predominately use California ground squirrel (Spermophilus beechyi) burrows as over summering habitat. However, in Sonoma County where California ground squirrel populations are scarce to non-existent, subterranean refugia likely include Botta’s pocket gopher (Thomomys bottae) burrows, deep fissures in desiccated clay soils, and debris piles (e.g., downed wood, rock piles) (G. Monk personal observation).
Stock ponds, seasonal wetlands, and deep vernal pools typically provide most of the breeding habitat used by California tiger salamanders. In such locations, California tiger salamander attach their eggs to rooted, emergent vegetation, and other stable filamentous objects in the water column. Eggs are gelatinous and are laid singly or occasionally in small clusters. Eggs range in size from about ¾ the diameter of a dime to the full diameter of a dime.
Occasionally, California tiger salamanders are found breeding in slow moving streams or ditches. In 1997, Mr. G. Monk observed California tiger salamanders breeding in large, still ditches in Fremont, California. Similarly, in 2001/2002, Mr. D. Wooten observed California tiger salamanders breeding in a roadside ditch in Cotati, California (D. Wooten, formerly of USFWS, pers. comm. w/ Mr. G. Monk). Ditches and/or streams that are subject to rapid flows, even if only on occasion, typically will not support or sustain California tiger salamanders egg 14 552 of 1220
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attachment through hatching, and thus, are not usually used successfully by California tiger salamanders for breeding (G. Monk and S. Lynch, pers. observations). Similarly, streams and/or ditches that support predators of California tiger salamanders or their eggs and larvae such as fish, bullfrogs (Rana catesbeiana), red swamp crayfish (Procambarus clarkii), or signal crayfish (Pacifastacus leniusculus), almost never constitute suitable breeding habitat.
In most of the range of the California tiger salamander, seasonal wetlands that are used for breeding typically must hold water into the month of May to allow enough time for larvae to fully metamorphose. Typically, in Sonoma County, pools that are 16 inches or deeper in the peak winter months will remain inundated long enough to provide good breeding conditions for California tiger salamanders. In dry years, seasonal wetlands, especially shallower pools, may dry too early to allow enough time for California tiger salamander larvae to successfully metamorphose. Under such circumstances, desiccated California tiger salamander larvae are often found in dried pools. In addition, as pools dry down to very small areas of inundation, California tiger salamander larvae become concentrated and are very susceptible to predation.
On the project site, there is a single seasonal wetland that M&A inspected in the winter of 2003/2004 (W1 on Attachment C) and again in multiple survey years. This seasonal wetland does not pool water deeper than three to four inches deep and it fills and drains/dries throughout the winter months in accordance with the frequency of large storm events. No wetland on the project site is deep enough or has sufficient ponding duration to support breeding California tiger salamanders; hence, no impacts to California tiger salamander breeding and larval development habitat is expected from the proposed project.
In 2003/2004 the Sonoma Business Park development project that is located immediately east of the Reds Residential project site was underway. The developer was required by USFWS and CDFG (now CDFW) to salvage California tiger salamanders presumed to be migrating from their upland retreats on adjacent properties, including the Reds project site, to a breeding pool that occurred on the now-developed Sonoma Business Park. This California tiger salamander salvage project was supervised by the CDFW and the USFWS under the assumption that all adult California tiger salamanders and their breeding habitat had been removed from the Sonoma Business Park project site when it was mass-graded in June 2002. The recovery/salvage project was implemented under expectation that the balance of the Sonoma Business Park and the parcel to the north (then called the Nibe project site) and the project site (then referred to as the Reds project site) would be developed under a master development project. Thus, California tiger salamanders’ salvage occurred in the winter of 2003/2004 via use of drift fences and pitfall traps installed on the Reds, Nibe, and Sonoma Business Park properties.
In September 2007, M&A prepared and submitted a report to the USFWS and CDFW summarizing the salvage trapping effort titled California Tiger Salamander (Ambystoma californiense) Survey and Salvage Summary “Nibe” and “Red’s” Project Sites Santa Rosa, California September 20, 2007. That report indicates that 12 adult California tiger salamanders were captured on the Reds Project Site (the project site under review herein) in the winter of 2003/2004 and were surrendered to the CDFW. Thus, there is an assumption that California tiger salamanders were removed from the project site, and in the absence of potential breeding habitat removed from the area in 2002, that this salamander likely no longer occupies the Reds site (the 15 553 of 1220
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project site under discussion herein). Regardless, there is an assumption that the proposed project could impact the California tiger salamander, and thus it will mitigate these impacts as detailed below in the Impacts and Mitigation section of this report.
The project site is in an area of the Santa Rosa Plain that is designated in Figure 3 of the USFWS’ Conservation Strategy (USFWS 2005b) (see Conservation Strategy Section below) as within “Sonoma County Incorporated Areas” in a “Development Area.” Accordingly, the USFWS anticipated that this project site would be developed when it prepared the Conservation Strategy. In addition, the project site is not within 500 feet of a known and extant California tiger salamander breeding pond/pool. While not believed to still be a viable record location, the closest known record for California tiger salamander is located 0.1-mile north of the project site (Occurrence No. 82) within a drainage ditch alongside Alder Avenue.
The possibility of California tiger salamanders migrating across the project site today, under the considerations that the population was regarded as “salvaged” or removed, and that the breeding pools are no longer present, is very low. Regardless, the presence of this salamander cannot be dismissed entirely. Accordingly, the applicant will be required to acquire permits from the USFWS and the CDFW for project impacts to the California tiger salamander. Please review the FESA and CESA regulatory considerations. Also, please review the Impacts and Mitigation Section of this report for a full discussion on mitigation requirements.
6.3.2 PALLID BAT
The pallid bat is a California “species of special concern.” It has no federal status. The “species of special concern” status designation does not provide any special legally mandated protection for this bat species. However, this status designation meets the definition of “rare” pursuant to the CEQA (14 CCR §15380(2)(A)).
The pallid bat is a locally common species of low elevations in California. It occurs throughout California except for the high Sierra Nevada from Shasta to Kern Counties, and the northwestern corner of the state from Del Norte and western Siskiyou counties to northern Mendocino County.
It occurs in a wide variety of habitats. It is most common in open, dry habitats with rocky areas for roosting. Day roosts are in caves, crevices, mines, and occasionally in hollow trees and buildings. Roosts must protect bats from high temperatures. Night roosts may be in more open sites such as porches and open buildings. A social bat, the pallid bat roosts in groups of 20 or more.
This species is known from the region of the project site. The nearest CNDDB occurrence was a 1997 record roughly 9.0 miles southeast of the project site (Occurrence #50). As abandoned buildings and trees on the project site provide suitable roosting habitat for this species, impacts to pallid bat cannot be ruled out. Prior to building demolition or construction, bat surveys must be conducted to confirm or negate this species presence on the project site. The Impacts and Mitigation sections below address these impacts.
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7. REGULATORY FRAMEWORK FOR NATIVE WILDLIFE, FISH AND PLANTS This section provides a discussion of those laws and regulations that are in place to protect native wildlife, fish, and plants. Under each law we discuss their pertinence to the proposed development.
7.1 Federal Endangered Species Act
The FESA forms the basis for the federal protection of threatened or endangered plants, insects, fish, and wildlife. FESA contains four main elements, they are as follows:
Section 4 (16 USCA §1533): Species listing, Critical Habitat Designation, and Recovery Planning: outlines the procedure for listing endangered plants and wildlife.
Section 7 (§1536): Federal Consultation Requirement: imposes limits on the actions of federal agencies that might impact listed species.
Section 9 (§1538): Prohibition on Take: prohibits the "taking" of a listed species by anyone, including private individuals, and State and local agencies.
Section 10: Exceptions to the Take Prohibition: non-federal agencies can obtain an incidental take permit through approval of a Habitat Conservation Plan (HCP).
In the case of salt water fish and other marine organisms, the requirements of FESA are enforced by the National Marine Fisheries Service (NMFS). The USFWS enforces all other cases. Below, Sections 9, 7, and 10 of FESA are discussed since they are the sections most relevant to the proposed project.
Section 9 of FESA as amended, prohibits the "take" of any fish or wildlife species listed under FESA as endangered. Under Federal regulation, "take" of fish or wildlife species listed as threatened is also prohibited unless otherwise specifically authorized by regulation. "Take," as defined by FESA, means "to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” "Harm" includes not only the direct taking of a species itself, but the destruction or modification of the species' habitat resulting in the potential injury of the species. As such, "harm" is further defined to mean "an act which kills or injures wildlife; such an act may include significant habitat modification or degradation where it kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering" (50 CFR 17.3). A December 2001 decision by the 9th Circuit Court of Appeals (Arizona Cattle Growers’ Association, Jeff Menges, vs. the U.S. Fish and Wildlife Service and Bureau of Land Management, and the Southwest Center for Biological Diversity) ruled that the USFWS must show that a threatened or endangered species is present on a project site and that it would be taken by the project activities. According to this ruling, the USFWS can no longer require mitigation based on the probability that the species could use the site. Rather they must show that it is “reasonably certain to occur.” Section 9 applies to any person, corporation, federal agency, or any local or State agency. If "take" of a listed species is necessary to complete an otherwise lawful activity, this triggers the 17 555 of 1220
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need to obtain an incidental take permit either through a Section 7 Consultation as discussed further below (for federal actions or private actions that are permitted or funded by a federal agency such as the Corps), or through Section 10 of FESA which requires preparation of an HCP (for State and local agencies, or individuals, and projects without a federal “nexus”; for example, projects that do not need a Corps permit).
Section 7(a)(2) of the Act requires that each federal agency consult with the USFWS to ensure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of an endangered or threatened species or result in the destruction or adverse modification of critical habitat for listed species. Critical habitat designations mean: (1) specific areas within a geographic region currently occupied by a listed species, on which are found those physical or biological features that are essential to the conservation of a listed species and that may require special management considerations or protection; and (2) specific areas outside the geographical area occupied by a listed species that are determined essential for the conservation of the species.
The Section 7 consultation process only applies to actions taken by federal agencies that are considering authorizing discretionary projects. Section 7 is by and between the NMFS and/or the USFWS and the federal agency contemplating a discretionary approval (that is, the “federal nexus agency,” for example, the Corps or the Federal Highway Administration). Private parties, cities, counties, etc. (i.e., applicants) may participate in the Section 7 consultation at the discretion of the federal agencies conducting the Section 7 consultation. The Section 7 consultation process is triggered by a determination of the “action agency” – that is, the federal agency that is carrying out, funding, or approving a project - that the project “may affect” a listed species or critical habitat. If an action is likely to adversely affect a listed species or designated critical habitat, formal consultation between the nexus agency and the USFWS/NMFS is required. As part of the formal consultation, the USFWS/NMFS may resolve any issues informally with the nexus agency or may prepare a formal Biological Opinion assessing whether the proposed action would be likely to result in “jeopardy” to a listed species or if it could adversely modify designated critical habitat. If the USFWS/NMFS prepares a Biological Opinion, it will contain either a “jeopardy” or “non-jeopardy” decision. If the USFWS/NMFS concludes that a proposed project would result in adverse modification of critical habitat or would jeopardize the continued existence of a federally listed species (that is, it will issue a jeopardy decision), the nexus federal agency would be most unlikely to authorize its discretionary permit. If the USFWS/NMFS prepares a “non-jeopardy” Biological Opinion, the nexus federal agency may authorize the discretionary permit making all conditions of the Biological Opinion conditions of its discretionary permit. A non-jeopardy Biological Opinion constitutes an “incidental take” permit that allows applicants to “take” federally listed species while otherwise carrying out legally sanctioned projects.
For non-federal entities, for example private parties, cities, counties that are considering a discretionary permit, Section 10 provides the mechanism for obtaining take authorization. Under Section 10 of FESA, for the applicant to obtain an ITP, the applicant is required to submit a "conservation plan" to the USFWS or NMFS that specifies the impacts that are likely to result to federally listed species, and the measures the applicant will undertake to minimize and mitigate such impacts, and the funding that will be available to implement those steps. Conservation plans 18 556 of 1220
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under FESA have come to be known as "habitat conservation plans" or "HCPs" for short. The terms incidental take permit, Section 10 permit, and Section 10(a)(1)(B) permit are used interchangeably by the USFWS. Section 10(a)(2)(B) of FESA provides statutory criteria that must be satisfied before an ITP can be issued.
7.1.1 RESPONSIBLE AGENCY
FESA gives regulatory authority to the USFWS for federally listed terrestrial species and nonanadromous fish. The NMFS has regulatory authority over federally listed marine mammals and anadromous fish.
7.1.2 APPLICABILITY TO THE PROPOSED PROJECT
The project site does not provide fisheries habitat; thus, the project would not result in impacts to federally listed fish species. As such, consultation with the NMFS for the proposed project is not warranted.
Several federally listed plant and wildlife species are known to occur in the region of the project site (Tables 3 and 4). No federally listed plants were found during special-status plant surveys conducted on the project site in 2015, 2016, 2017, and 2019.
Regardless of the fact that special-status plant surveys dismissed presence of state and federally listed vernal pool plants in 2015, 2016, 2017, and 2019, the existing BO requires mitigation for impacts to Suitable Habitat2, due to the potential for a seedbank being present. Mitigation is the purchase of conservation credits providing 1.5:1 occupied or established habitat (any combination) with success criteria met prior to groundbreaking at the project site. Thus, if the project requires a Corps permit, even with two years of formal rare plant surveys that were negative for rare plants, to obtain a Corps permit, 1.5:1 replacement to impacts of vernal pool listed plant mitigation credit must be obtained by the project, if mitigation occurs in the same core area as impacts; and, if mitigation occurs in a different core area as impacts, then a 3:1 replacement to impacts of vernal pool listed plant mitigation credit must be obtained.
7.2 Federal Migratory Bird Treaty Act
The Migratory Bird Treaty Act of 1918 (16 U.S.C. §§ 703-712, July 3, 1918, as amended 1936, 1960, 1968, 1969, 1974, 1 978, 1986 and 1989) makes it unlawful to “take” (kill, harm, harass, shoot, etc.) any migratory bird listed in Title 50 of the Code of Federal Regulations, Section
10.13, including their nests, eggs, or young. Migratory birds include geese, ducks, shorebirds, raptors, songbirds, wading birds, seabirds, and passerine birds (such as warblers, flycatchers, swallows, etc.).
Executive Order 13186 for conservation of migratory birds (January 11, 2001) requires that any project with federal involvement address impacts of federal actions on migratory birds. The order is designed to assist federal agencies in their efforts to comply with the MBTA and does not constitute any legal authorization to take migratory birds. The order also requires federal 2 in this case suitable habitat falls under the BO 2020 definition of a “seasonal wetland located within a Core or Management Area”
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agencies to work with the USFWS to develop a memorandum of understanding (MOU).
Protocols developed under the MOU must promote the conservation of migratory bird populations through the following means:
avoid and minimize, to the extent practicable, adverse impacts on migratory bird resources when conducting agency actions;
restore and enhance habitat of migratory birds, as practicable; and prevent or abate the pollution or detrimental alteration of the environment for the benefit of migratory birds, as practicable.
7.2.1 APPLICABILITY TO THE PROPOSED PROJECT
No take (i.e., to kill) of birds listed under the Migratory Bird Treaty Act is legal. Passerine (perching) birds or raptors could nest in trees, on abandoned buildings, or in the grassland of the project site. While birds are adept at flying out of harm’s way, bird nests, eggs, and nestlings are stationary and subject to construction related impacts. To comply with the Migratory Bird Treaty Act, preconstruction surveys would have to be conducted for nesting bird species to ensure that there is no direct take of these birds including their eggs or young. Non-disturbance buffers would have to be established around any active nesting site and would have to be of sufficient size to protect the nesting birds from harm. Upon completion of nesting the buffers could be removed, and the project could commence as otherwise planned. Please review specific requirements for avoidance of nest sites for nesting bird species in the Impacts and Mitigations section below.
7.3 California Endangered Species Act
7.3.1 SECTION 2081 OF THE STATE ENDANGERED SPECIES ACT
In 1984, the state legislated the CESA (Fish and Game Code §2050). The basic policy of CESA is to conserve and enhance endangered species and their habitats. State agencies will not approve private or public projects under their jurisdiction that would impact threatened or endangered species if reasonable and prudent alternatives are available. Because CESA does not have a provision for "harm" (see discussion of FESA, above), the CDFW considerations pursuant to CESA are limited to those actions that would result in the direct take of a listed species.
If the CDFW determines that a proposed project could impact a State-listed threatened or endangered species, the CDFW will provide recommendations for "reasonable and prudent" project alternatives. The CEQA lead agency can only approve a project if these alternatives are implemented, unless it finds that the project's benefits clearly outweigh the costs, reasonable mitigation measures are adopted, there has been no "irreversible or irretrievable" commitment of resources made in the interim, and the resulting project would not result in the extinction of the species. In addition, if there would be impacts to threatened or endangered species, the lead agency typically requires project applicants to demonstrate that they have acquired "incidental take" permits from the CDFW and/or USFWS (if it is a federally listed species) prior to allowing/permitting impacts to such species.
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If proposed projects would result in impacts to a State-listed species, an "incidental take" permit pursuant to §2081 of the Fish and Game Code would be necessary (versus a federal ITP for federally listed species). The CDFW will issue an incidental take permit only if:
1) The authorized take is incidental to an otherwise lawful activity; 2) the impacts of the authorized take are minimized and fully mitigated; 3) measures required to minimize and fully mitigate the impacts of the authorized take:
a) are roughly proportional in extent to the impact of the taking on the species; b) maintain the project applicant’s objectives to the greatest extent possible; and, c) capable of successful implementation; and,
4) adequate funding is provided to implement the required minimization and mitigation measures and to monitor compliance with, and the effectiveness of, the measures.
If an applicant is preparing an HCP as part of the federal 10(a) permit process, the HCP might be incorporated into the §2081 permit if it meets the substantive criteria of §2081(b). To ensure that an HCP meets the mitigation and monitoring standards in Section 2081(b), an applicant should involve the CDFW staff in development of the HCP. If a final Biological Opinion (federal action) has been issued for the project pursuant to Section 7 of the FESA, it might also be incorporated into the §2081 permit if it meets the standards of §2081(b).
No §2081 permit may authorize the take of a species for which the Legislature has imposed strict prohibitions on all forms of “take.” These species are listed in several statutes that identify “fully protected” species and “specified birds.” See Fish and Game Code §§ 3505, 3511, 4700, 5050, 5515, and 5517. If a project is planned in an area where a “fully protected” species or a “specified bird” occurs, an applicant must design the project to avoid all take.
Fish and Game Code §2080.1 allows an applicant who has obtained a “non-jeopardy” federal Biological Opinion pursuant to Section 7 of the FESA, or who has received a federal 10(a) permit (federal incidental take permit) pursuant to the FESA, to submit the federal opinion or permit to CDFW for a determination as to whether the federal document is “consistent” with CESA. If after 30 days CDFW determines that the federal incidental take permit is consistent with state law, and that all state listed species under consideration have been considered in the federal Biological Opinion, then no further permit or consultation is required under CESA for the project. However, if CDFW determines that the federal opinion or permit is not consistent with CESA, or that there are state listed species that were not considered in the federal Biological Opinion, then the applicant must apply for a state CESA permit under Section 2081(b). Section 2081(b) is of no use if an affected species is state listed, but not federally listed.
State and federal ITPs are issued on a discretionary basis and are typically only authorized if applicants can demonstrate that impacts to the listed species in question are unavoidable and can be mitigated to an extent that the reviewing agency can conclude that the proposed impacts would not jeopardize the continued existence of the listed species under review. Typically, if there would be impacts to a listed species, mitigation that includes habitat avoidance, preservation, and creation of endangered species habitat is necessary to demonstrate that projects would not threaten the continued existence of a species. In addition, management endowment fees are usually collected as part of the agreement for the incidental take permit(s). The 21 559 of 1220
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endowment is used to manage any lands set-aside to protect listed species, and for biological mitigation monitoring of these lands over (typically) a five-year period.
7.3.2 APPLICABILITY TO PROPOSED PROJECT
Several State-listed plant and wildlife species are known to occur in the region of the project site (Tables 3 and 4). No State-listed plants were found during special-status plant surveys conducted on the project site in 2015, 2016, 2017, and 2019. Therefore, it can safely be concluded that the proposed project will not impact state listed plant species. Thus, an Incidental Take Permit is not required for the project for state-listed plants.
7.4 California Fish and Game Code §§ 3503, 3503.5, 3511, and 3513 California Fish and Game Code §3503, 3503.5, 3511, and 3513 prohibit the “take, possession, or destruction of birds, their nests or eggs.” Disturbance that causes nest abandonment and/or loss of reproductive effort (killing or abandonment of eggs or young) is considered “take.” Such a take would also violate federal law protecting migratory birds (Migratory Bird Treaty Act).
All raptors (that is, hawks, eagles, owls) their nests, eggs, and young are protected under California Fish and Game Code (§3503.5). Additionally, “fully protected” birds, such as the White-tailed Kite (Elanus leucurus) and Golden Eagle (Aquila chrysaetos), are protected under California Fish and Game Code (§3511). “Fully protected” birds may not be taken or possessed (that is, kept in captivity) at any time.
7.4.1 APPLICABILITY TO THE PROPOSED PROJECT
Passerine (perching) birds or raptors could nest in trees, on abandoned buildings, or in the grassland of the project site. These birds while nesting would be protected by the Fish and Game Codes that protect nesting birds. As long as there is no direct mortality of species protected pursuant to these codes caused by development of the site, there should be no constraints to development of the site. To comply with the Fish and Game Codes that protect nesting birds, preconstruction surveys would have to be conducted for nesting bird species to ensure that there is no direct take or these birds including their eggs or young. Non-disturbance buffers would have to be established around any active nesting sites and would have to be of sufficient size to protect the nesting birds from harm. Upon completion of nesting the buffers could be removed, and the project could commence as otherwise planned. Please review specific requirements for avoidance of nest sites in the Impacts and Mitigations section below.
7.5 Santa Rosa Plain Conservation Strategy
The Federal listing of California tiger salamander resulted in uncertainty for many local jurisdictions, landowners, and developers about its effects on their current and proposed activities. Because of this uncertainty, local private and public interest groups met with the USFWS to discuss a cooperative approach to protecting California tiger salamander, while allowing currently planned and future land uses to occur within its range. The result of these discussions was the creation of the Final Santa Rosa Plain Conservation Strategy (“Conservation Strategy”) (USFWS 2005).
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The purpose of the Conservation Strategy is threefold: (1) to establish a long-term conservation program sufficient to mitigate potential adverse effects of future development on the Santa Rosa Plain, and to conserve and contribute to the recovery of the listed species and the conservation of their sensitive habitat; (2) to accomplish the preceding in a fashion that protects stakeholders’ (both public and private) land use interests, and (3) to support issuance of an authorization for incidental take of Sonoma County California tiger salamander and listed plants that may occur in the course of carrying out a broad range of activities on the Santa Rosa Plain. The Conservation Strategy establishes interim and long-term mitigation requirements and designates conservation areas where mitigation will occur. It describes how habitat preserves will be established and managed. It also includes guidelines for translocation, management plans, adaptive management, and funding.
The Conservation Strategy identifies areas within the Santa Rosa Plain that should be conserved to benefit the listed plants and Sonoma County California tiger salamander. Their designation was based upon the following factors: 1) known distribution of the California tiger salamander; 2) the presence of suitable habitat; 3) presence of large blocks of natural or restorable land; 4) proximity to existing Preserves; and 5) known location of the listed plants. The designation of conservation areas also generally attempted to avoid future development areas established by urban growth boundaries and city general plans. The objective of these conservation areas is to ensure that preservation occurs throughout the distribution of the species.
The goal of the Conservation Strategy is to preserve a large enough area of suitable habitat to ensure the conservation of California tiger salamander and listed plants and contribute to their recovery. In order to do this, areas are identified within the Santa Rosa Plain that currently or potentially support California tiger salamander and listed plants, as well as the areas that currently or likely will support development. This information was used to develop appropriate “conservation areas” and requirements as well as mitigation guidelines and requirements, in order to “provide consistency, timeliness and certainty for permitted activities.” Proposed projects within the potential California tiger salamander range will fall into one of three categories:
a.) Projects within 1.3 miles of a known California tiger salamander breeding site, and likely to impact California tiger salamander breeding and/or upland habitat; or b.) Projects beyond 1.3 miles from a known California tiger salamander breeding site, but within the “Potential for Presence of California tiger salamander” or “Potential for Presence of California tiger salamander and Plants”; or c.) Projects where “Presence of California tiger salamander is Not Likely.” Different mitigation ratios are recommended for each of these categories.
The Conservation Strategy recommends that projects filling potential listed plant habitat should mitigate these impacts via the preservation of existing occupied habitat at a 1:1 ratio, and projects filling known listed plant habitat should mitigate these impacts via the preservation of existing occupied habitat at a 2:1 ratio, as per a Programmatic Biological Opinion (USFWS 1998) in effect at the time of the Conservation Strategy was prepared in 2005. The USFWS’ 23 561 of 1220
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2020 Programmatic Biological Opinion (USFWS 2020) has since superseded the 2007 and 1998 Programmatic Biological Opinions and the mitigation ratios have changed as discussed below and in the 2020 Programmatic Biological Opinion.
The Conservation Strategy recommends that projects filling wetlands should mitigate these impacts via the preservation of wetlands at a minimum of a 1:1 replacement ratio, depending on the quality of the filled wetlands, as per a Programmatic Biological Opinion (USFWS 1998) in effect at the time of the Conservation Strategy was prepared in 2005. The 1998 Programmatic Biological Opinion was superseded by a Programmatic Biological Opinion prepared by the USFWS for the Corps in 2007 (USFWS 2007) and again in 2020 (USFWS 2020).
7.5.1 APPLICABILITY TO THE PROPOSED PROJECT
The project site is in an area of the Santa Rosa Plain that is designated in Figure 3 of the USFWS’ Conservation Strategy (USFWS 2005b) (see Conservation Strategy Section below) as within “Sonoma County Incorporated Areas” in a “Development Area.” In the USFWS’ 2016 Recovery Plan (USFWS 2016), the project site is shown on Figure 1 of that plan (See M&A Figure 6 in this report) as not being within a designated “Conservation Area.” Accordingly, the USFWS anticipated in 2005 that this project site would be developed when it prepared the Conservation Strategy.
Per the existing BO issued in 2019 for the Sterling Senior Communities Project, which Jason Hanni (USFWS and author of the BO) confirmed remains valid for this project, the applicant will purchase listed plant preservation or establishment credits at a 1.5:1 ratio from a USFWS approved mitigation bank(s). Additionally, per the existing BO, to mitigate for impacts to 3.64 acres of California tiger salamander habitat, the applicant shall secure 7.28 acres of California tiger salamander mitigation credit from a USFWS (and CDFW) approved Conservation Bank.
7.6 Santa Rosa Plain 2020 Programmatic Biological Opinion The Programmatic Biological Opinion (USFWS 2020) is based on the biological framework presented in the Conservation Strategy. This Programmatic Biological Opinion replaces (supersedes) the July 17, 1998 Programmatic Formal Consultation for U.S. Army Corps of Engineers 404 Permitted Projects that May Affect Four Endangered Plant Species on the Santa Rosa Plain (USFWS 1998), as well as the revisions made in 2007 (USFWS 2007), which were prepared for listed plant species on the Santa Rosa Plain. Projects that require a Corps permit and that remain consistent with objectives stated in the Conservation Strategy can be appended to the Programmatic Biological Opinion at the discretion of the USFWS. Projects that are appended to the Programmatic Biological Opinion will be provided individual take authorization for impacts to federally listed species.
7.6.1 APPLICABILITY TO THE PROPOSED PROJECT
As the existing BO issued in 2019 for the Sterling Senior Communities Project remains valid for this proposed project, reinitiation of Section 7 consultation between the Corps and the USFWS is not required, and this project does not need to be appended to the 2020 Programmatic Biological Opinion.
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In accordance with the project’s existing BO, although federally and state-listed plants were not observed on the project site during years of formal rare plant surveys conducted in 2015, 2016, 2017, and 2019, seasonal wetlands on the site are still regarded by USFWS to be “suitable habitat.” Consequently, impacted seasonal wetlands on the project site would still be required to be mitigated as “suitable” listed plant habitats.
Per the existing BO, prior to any earthmoving activities the applicant shall be required to purchase preservation or establishment credits for Sebastopol meadowfoam at a 1.5:1 ratio from a USFWS-approved mitigation bank(s) located in a Core or Management Area as defined in the 2016 Recovery Plan (unless otherwise approved by the USFWS). Since the proposed project will directly impact approximately a 0.06-acre wetland (W1 on Attachment C) that is suitable habitat for Sebastopol meadowfoam, the applicant has proposed to offset the loss of 0.06 acre of suitable listed plant habitat by purchasing 0.09 acre (0.06 acre x 1.5) of Sebastopol meadowfoam preservation or establishment credits.
Additionally, per the existing BO, to mitigate for impacts to 3.64 acres of California tiger salamander habitat, the applicant shall secure 7.28 acres of California tiger salamander mitigation credit from a USFWS (and CDFW) approved Conservation Bank within the West Cotati Core California tiger salamander area in accordance with the USFWS’ Recovery Plan (USFWS 2016). Currently, the applicant is proposing to purchase California tiger salamander credits from the Margaret West and/or Alton Lane Conservation Banks. The applicant could use other conservation banks as well as approved by the USFWS (and CDFW).
7.7 USFWS Recovery Plan for the Santa Rosa Plain (USFWS 2016) In December 2016, the USFWS adopted a formal Recovery Plan for the Santa Rosa Plain addressing recovery efforts necessary to protect and otherwise eventually recover the federally listed Sonoma County Distinct Population Segment of the California tiger salamander (Ambystoma californiense) and three vernal pool plants: Sonoma sunshine (Blennosperma bakeri); Burke’s goldfields (Lasthenia burkei); and Sebastopol meadowfoam (Limnanthes vinculans) (USFWS 2016). All four species are confined almost entirely to the Santa Rosa Plain.
The Recovery Plan and its objectives are implemented through cooperative CEQA lead agencies, and through federal nexus agency consultations (e.g., Corps consultations) with the USFWS via Section 7 of the FESA. Any federal nexus agency that consults with the USFWS pursuant to Section 7 will obtain a letter of no effect or a Biological Opinion that provides or denies “incidental take authority.” Pursuant to the FESA, Incidental take would include loss of a listed species habitat or harm that could occur to a federally listed species. An Incidental Take Permit allows an otherwise legally sanctioned activity to proceed even if there is a collateral impact to a federally listed species. Similarly, any Section 10 FESA consultation with the USFWS, which is allowed for in the FESA for all non-federal entities, which results in Incidental Take authority granted by the USFWS to the non-federal entities, would otherwise include provisions for compliance with the objectives of the Recovery Plan.
The USFWS has determined that the primary threats to the three listed vernal pool plants and the California tiger salamander on the Santa Rosa Plain is the reduction and fragmentation of habitat due to urban development, agricultural land conversion, and habitat degradation that modifies 25 563 of 1220
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vernal pool hydrology, and colonization of seasonal wetlands by competitive invasive plants.
Consequently, the Recovery Plan focuses on these threats. To downlist or delist the four species that are imperiled in the Santa Rosa Plain, the threats to the species’ habitat must be reduced or eliminated. The USFWS criteria for downlisting are based upon preservation of extant vernal pools systems and attending uplands that support wetland complexes. The USFWS has segmented the Santa Rosa Plain into “Core” and “Management Areas” (Exhibits A and B) where species preservation, and habitat enhancement and management must occur to recover these four listed species.
[The following information has been obtained from various personal communications in 2016 and 2017 between Mr. G. Monk and Mr. Vincent Griego and/or Mr. Ryan Olah of the Sacramento Endangered Species Office of the USFWS]: The USFWS is now requiring that projects that impact federally listed plant species in Core habitats, and/or California tiger salamander Core habitat (Exhibits A and B), mitigate through preservation and enhancement of extant listed species habitats in the same Core Area where the impacts will occur. Mitigation for Core area species always takes precedence over Management area species. The USFWS is also now requiring that impacts to specific federally listed species’ Management Areas, be mitigated in the affected species Core Areas or its Management Areas as designated in the USFWS’ 2016 Santa Rosa Plain Recovery Plan (USFWS 2016). Impacts to California tiger salamander outside of Core and Management Areas may be mitigated in any Core or Management Area designated in the Santa Rosa Plain (Ryan Olah pers. Comm. With G. Monk, January 18, 2017).
7.7.1 APPLICABILITY TO PROPOSED PROJECT
The project site is within the Sebastopol meadowfoam (Limnanthes vinculans) Core Area.
Accordingly, vernal pool plant mitigation that is implemented to offset impacts to “suitable vernal pool plant species habitat” must be obtained within this Core Area to meet the objectives of the Recovery Plan (USFWS 2016). Regarding impacts that would occur to the California tiger salamander from the implementation of the proposed project, these impacts would occur within the West Cotati Core California tiger salamander area. Thus, compensation for these impacts must be obtained from this Core Area. The applicant is currently proposing to purchase California tiger salamander credits from the Margaret West and/or Alton Lane Conservation Banks, and to purchase 0.09 acre (0.06 acre x 1.5) of Sebastopol meadowfoam preservation or establishment credits from a USFWS approved mitigation bank(s) located in a Core or Management Area as defined in the 2016 Recovery Plan (unless otherwise approved by the USFWS).
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7.8 City of Cotati Tree Ordinance - Chapter 17.54 Tree Preservation and Protection Below are key provisions of the City of Cotati’s Tree Ordinance. Since the project will impact both native and non-native (i.e. landscape) trees, this ordinance will apply.
7.8.1 APPLICABILITY (17.54.020)
A. Applicability of Requirements. The provisions of this chapter shall apply in all zoning districts to the removal or relocation of any tree with a circumference of twelve inches or more, measured at fifty-four inches above natural grade.
B. Tree Permit Required.
1. Activities Requiring a Permit. A tree permit shall be required prior to:
a. The relocation, removal, cutting-down, or other act that causes the destruction of a tree;
b. Prior to any grading, paving, or other ground-disturbing activity within the protected zone of a tree; and
c. The approval of a use permit, minor use permit, variance, minor variance, or subdivision, hereafter referred to as “discretionary projects.”
2. Permit Issuance. The procedure and review authority for a tree permit is as follows:
a. Developed Parcel. A tree permit for the removal of other than a native oak from a developed parcel shall be issued as follows:
i. A permit for a parcel developed with one single-family dwelling may be issued by the director after a site inspection. In this case, the director may waive the prior submittal of a site plan.
ii. A permit for a parcel developed with multiple dwellings or a nonresidential structure may be issued by the director after the review of a complete tree permit application in compliance with Section 17.54.030 (Tree permit application requirements) of this chapter.
b. Vacant Parcel. A tree permit for the removal of other than a native oak from a vacant parcel shall require commission approval, and shall not be granted except in conjunction with:
i. The approval of a discretionary project for the same site; ii. The approval of a building permit for the same site; or iii. The approval of improvement plans for a subdivision of the same property.
C. Native Oak Removal. The removal of a native oak with a trunk circumference of twelve inches measured at fifty-four inches above natural grade shall be prohibited, except where approved by the council after a public hearing in compliance with Chapter 17.88 (Public Hearings) of this title, in conjunction with the approval of a subdivision or other specific development project.
D. Timing of Removal of Large-Stature Trees. The removal of a tree with a height of fifty feet or more shall not occur between April 15 and June 15 of any year, to provide for the nesting and stopover patterns of raptors, migratory birds, and other bird species. 27 565 of 1220
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E. Exceptions. The removal or relocation of a tree that would otherwise require a tree permit is exempt from the provisions of this chapter only in case of emergency, where the director, city engineer, a member of a law enforcement agency, or the fire district determines that a tree poses an imminent threat to the public safety, or general welfare. (Ord. 766 § 2 Exh. A (part), 2004).
7.8.2 TREE PERMIT APPLICATION REQUIREMENTS (17.54.030)
A. Application Contents. Each tree permit application shall include the information and materials required by the department, and:
1. Shall be accompanied by the application fee required by the city fee schedule;
2. The application may be required to include an arborist’s report, at the discretion of the director; and
3. If the site is subject to conditions, covenants, and restrictions (CC&Rs) that address tree removal and are administered by an active homeowners’ association, the application shall include a letter from the homeowners’ association authorizing the tree removal.
B. Application Filing. An application for a tree permit involving a discretionary project shall be included as part of the application for the discretionary project. An application for a tree permit not associated with a discretionary project shall be filed with the department separately. (Ord. 766 § 2 Exh. A (part), 2004).
7.8.2.1 Protection of Trees to Be Retained
A. Purpose. The purpose of this section is to define procedures necessary to protect the health of affected protected trees. Great care must be exercised when work is conducted upon or around trees that are not authorized for removal.
B. Applicability. The requirements of this section shall apply to all encroachments into the protected zone of a tree that is not authorized for removal from a site when approved grading or other construction is to occur. All tree permits shall be deemed to incorporate the requirements of this section except as a tree permit may otherwise specifically provide.
C. Trenching Procedure. Trenching within the protected zone of a protected tree, when permitted, may only be conducted with hand tools or as otherwise directed by the city, to avoid root injury.
D. Cutting Roots.
1. Minor roots less than one inch in diameter may be cut, but damaged roots shall be traced back and cleanly cut behind any split, cracked or damaged area.
2. Major roots over one inch in diameter may not be cut without the director’s approval.
Depending upon the type of improvement being proposed, bridging techniques or a new site design may need to be employed to protect the root and the tree. 28 566 of 1220
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E. Irrigation Systems. An independent low-flow drip irrigation system may be used for establishing drought-tolerant plants within the protected zone of a tree to be protected.
F. Plant Materials Under Oaks. Planting live material under native oak trees is generally discouraged, and it will not be permitted within six feet of the trunk of a native oak tree with a circumference of less than twelve inches measured at fifty-four inches above natural grade, or within ten feet of the trunk of a native oak tree with a circumference of twelve inches or more measured at fifty-four inches above natural grade. Only drought-tolerant plants will be permitted within the protected zone of native oak trees.
G. Protective Fencing.
1. Type of Fencing. A minimum five-foot high chain link or substitute fence approved by the director shall be installed at the outermost edge of the protected zone of each protected tree or groups of protected trees. Exceptions to this policy may occur in cases where protected trees are located on slopes that will not be graded. However, approval must be obtained from the department to omit fences in any area of the project.
2. Fence Installation. The fences shall be installed in accordance with the approved fencing plan prior to the commencement of any grading operations or such other time as determined by the review authority. The developer shall call the city engineer for an inspection of the fencing prior to grading operations.
3. Signing. Signs shall be installed on the fence in four equidistant locations around each individual protected tree. The size of each sign must be a minimum of two feet by two feet and must contain the following language: “WARNING, THIS FENCE SHALL NOT
BE REMOVED OR RELOCATED WITHOUT WRITTEN AUTHORIZATION FROM THE COTATI PLANNING AND BUILDING DEPARTMENT.” Signs placed on fencing around a grove of protected trees, shall be placed at approximately fifty-foot intervals.
4. Fence Removal. Once approval has been obtained, the fences shall remain in place throughout the entire construction period and shall not be removed without obtaining written authorization from the department.
H. Retaining Walls and Root Protection. Where a tree permit has been approved for construction of a retaining wall within the protected zone of a protected tree, the developer shall provide for the immediate protection of exposed roots from moisture loss during the time prior to completion of the wall. The retaining wall shall be constructed within seventy-two hours after completion of grading.
I. Preservation Devices. If required, preservation devices such as aeration systems, oak tree wells, drains, special foundation systems, special paving and cabling systems must be installed per approved plans.
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J. Grading.
1. Every effort shall be made to avoid cut and/or fill slopes within or in the vicinity of the protected zone of any protected tree.
2. No grade change shall cause water to drain into an area around a protected tree equal to twice the longest radius of the protected zone.
3. No grade changes are permitted that will lower or raise the ground on any side of the tree.
K. Chimney Locations. A chimney for a wood burning fireplace or stove shall not be located within the canopy of a tree or in any location that sparks emitted from the chimney may damage a tree.
L. On-site Information. The following information shall be on-site while any construction activity is ongoing for a project requiring a tree permit:
1. Any applicable arborist’s report and any subsequent modifications to the arborist’s report;
2. Tree location map with a copy of the tree fencing plan;
3. Tree permit and approved construction plans;
4. Approved planting and irrigation drawings.
M. Information on Standards. The developer shall be responsible for informing all subcontractors and individuals who will be performing work around protected trees of the requirements of this section for working around trees and conditions of approval for the project. This information shall be provided in writing to the subcontractors and employees by the general contractor or applicant.
N. Utility Trenching Pathway Plan. In the event trenching is proposed, the tree permit application shall include a utility trenching pathway plan for approval following approval of the project improvement or civil plans.
1. Contents. The trenching-pathway plan shall depict all of the following systems: storm drains, sewers, easements, water mains, area drains, and underground utilities. Except in lot sale subdivisions, the trenching-pathway plan must show all lateral lines serving buildings. To be completely effective, the trenching-pathway plan must include the surveyed locations of all protected trees on the project as well as an accurate plotting of the protected zone of each protected tree.
2. Standards for Plan. The trenching-pathway plan shall be developed considering the following general guidelines:
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a. The trenching-pathway plan shall be developed to avoid trenching in the protected zone of any protected tree on its path from the street to the building. b. Where it is impossible to avoid the protected zone, the design shall minimize the extent of trenching within the protected zone. The required arborist’s report shall include mitigation measures for any trenching within the protected zone.
O. Final Certification of Tree Work. All of the tree preservation measures required by the conditions of the discretionary project approval, and/or the tree permit, as applicable, shall be completed, and certified by an arborist selected by the director prior to city issuance of a final building inspection or certificate of occupancy. (Ord. 766 § 2 Exh. A (part), 2004).
7.8.3 TREE PLANTING AND REPLACEMENT (17.54.050)
The city’s principal objective for the tree permit process is the preservation of native oaks and other significant trees, particularly in groves. Where the review authority determines that preservation is infeasible, replacement plantings may be allowed in compliance with this section.
A. Extent of Replacement Required. The review authority may condition any tree permit for the removal of a tree to require tree replacement, as shown in Table 5-2. The review authority may approve a replacement program using one of the methods identified in subsection B or C of this section, or any combination of the methods.
Table 5-2
Minimum Required Replacement Trees
Mitigation Value Required Size and
Species of Tree to be Circumference of Tree to (required number Species of Removed be Removed(1) of replacement
trees)
Replacement Trees
for Mitigation Value
Oaks (Black, Valley, 12 to 49 inches
Live)
5 15-gallon, oak of the
same species removed
50 to 79 inches 10
20 2
80 or more inches
Other 12 to 49 inches 15-gallon, of species
determined by city
50 to 79 inches 4
80 or more inches 6
Notes:
(1) Circumference shall be measured at a point fifty-four inches above the natural grade at the base of the tree.
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B. Location and Specifications for Replacement Trees. The replacement trees required by Table 5-2 shall be planted on-site (the city’s preferred method of mitigation), except that the review authority may authorize other areas where maintenance to ensure survival of the trees will be guaranteed.
1. All replacement trees shall be of the same species as the trees being replaced, propagated from locally gathered seeds, except in the case where a replacement tree is approved in a location characterized by nonnative species (for example, within a narrow roadway median where existing trees are ornamental non-natives), or where the review authority otherwise determines that native species are inappropriate.
2. The review authority may allow up to fifty percent of the required replacement trees to have a five-gallon container size, where it determines that long-term tree health and survival will be improved by starting with a smaller container size, and that each tree with a container size less than fifteen gallons will not be planted where it will be subject to damage while becoming established.
3. The review authority may require fewer and/or larger replacement trees than required by Table 5-2 where it determines that fewer but significantly larger trees are appropriate because of the size of the site, or on-site environmental resources or terrain constraints.
4. Replacement trees shall be in addition to any trees required by provisions of this land use code other than this chapter (e.g., required parking lot landscaping or street trees).
C. In-lieu Mitigation Fee. The review authority may determine that the remedies described above are not feasible or desirable and may instead require the payment of an in-lieu fee for the cost of purchasing, planting, irrigating, and maintaining each tree for a period of ten years. The in-lieu fee shall be as required by the city fee schedule. The in-lieu fee shall be deposited into the city’s tree fund. (Ord. 766 § 2 Exh. A (part), 2004).
7.8.4 TREE PERMIT APPROVAL FINDINGS AND CONDITIONS (17.54.060) A. Required Findings. The approval of a tree permit shall require that the review authority first make all the following findings:
1. The approval of the tree permit will not be detrimental to the public health, safety or welfare, and approval of the tree permit is consistent with the provisions of this chapter;
2. Measures have been incorporated into the project or permit to mitigate impacts to remaining trees or to replace the trees removed in compliance with this chapter;
3. The removal of a healthy tree cannot be avoided by:
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b. Trimming, thinning, tree surgery, or other reasonable treatment, as determined by the director;
4. Adequate provisions for drainage, erosion control, land stability, windscreen, buffers along the road and between neighbors have been made where these problems are anticipated as a result of the removal; and,
5. The tree to be removed does not contain an active nest that has been identified through the environmental process or is otherwise known to the review authority as the nest of a migratory bird, except where a qualified professional has determined that the nest can be relocated without damage to the nestlings.
B. Conditions of Approval. The approval of a tree permit shall include conditions of approval as necessary to ensure compliance with Section 17.54.050 (Tree planting and replacement) of this chapter. (Ord. 766 § 2 Exh. A (part), 2004).
7.8.5 APPLICABILITY TO THE PROPOSED PROJECT
The project will impact both native and non-native trees subject to the City of Cotati’s Tree Protection Ordinance. An Arborist Report has been prepared by Mr. John Meserve (Meserve 2017) that details tree impacts for the proposed project. M&A used this report and identified tree impacts to prepare Table A (presented in the Mitigation Measures section below), which states which trees would be impacted that require replacement mitigation. It should be noted that pursuant to the City of Cotati’s Tree Ordinance, the City has the discretion to set a different number of replacement trees depending on the desired character for the post developed project site. The applicant shall submit the arborist’s report and an application for a tree permit as part of the application for the development project. In compliance with the Tree Protection Ordinance, tree replacement species and numbers are presented in Table A or as otherwise required by the City of Cotati.
8. REGULATORY REQUIREMENTS PERTAINING TO WATERS OF THE UNITED
STATES AND STATE
This section presents an overview of the criteria used by the Corps, the RWQCB, the State Water Resources Control Board (SWRCB), and the CDFW to determine those areas within a project area that would be subject to their regulation.
8.1 U.S. Army Corps of Engineers Jurisdiction and Permitting Congress enacted the Clean Water Act “to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters” (33 U.S.C. §1251(a)). Pursuant to Section 404 of the Clean Water Act (CWA) (33 U.S.C. 1344), the Corps regulates the disposal of dredged or fill material into "waters of the United States" (33 CFR Parts 328 through 330). This requires project applicants to obtain authorization from the Corps prior to discharging dredged or fill materials into any water of the United States.
On November 18, 2021, the U.S. EPA and the Corps (the “agencies”) announced the signing of a proposed rule to revise the definition of “waters of the United States.” On December 7, 2021, the 33 571 of 1220
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proposed rule was published in the Federal Register. The agencies propose to put back into place the pre-2015 definition of “waters of the United States,” (40 CFR 230.3(s)). This proposal redefining wetlands is not final at this time. The agencies are interpreting “waters of the United States” consistent with the pre-2015 regulatory regime until further notice.
In the published proposed rule from the Federal Register, the term “waters of the United States” is defined as:
1. All waters which are currently used, or were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters which are subject to the ebb and flow of the tide
2. All interstate waters including interstate wetlands
3. All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds:
(i) That are relatively permanent, standing or continuously flowing bodies of water with a continuous surface connection to the waters identified in paragraph (1), (2), (5)(i), or (6) of this section; or (ii) That either alone or in combination with similarly situated waters in the region, significantly affect the chemical, physical, or biological integrity of waters identified in paragraph (1), (2), or (6) of this section (ii)
4. All impoundments of waters otherwise defined as waters of the United States under the definition, other than impoundments of waters identified under 3 of this section
5. Tributaries of waters identified in (1), (2), (4), or (6) of this section (i) That are relatively permanent, standing or continuously flowing bodies of water; or
(ii) That either alone or in combination with similarly situated waters in the region, significantly affect the chemical, physical, or biological integrity of waters identified in (1), (2), or (6) of this section
6. The territorial seas
7. Wetlands adjacent to the following waters (other than waters that are themselves wetlands):
(i) Waters identified in (1), (2), or (6) of this section; or (ii) Relatively permanent, standing or continuously flowing bodies of water identified in paragraph (4) or (5)(i) of this section and with a continuous surface connection to such waters; or
(iii) Waters identified in (4) or (5)(ii) of this section when the wetlands either alone or in combination with similarly situated waters in the region, significantly affect the chemical, physical, or biological integrity of waters identified in paragraph (1), (2), or (6) of this section Waters of the United States do not include:
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