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phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate on earth.

The primary GHGs contributing to the greenhouse effect are carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). Fluorinated gases also make up a small fraction of the GHGs that contribute to climate change. Examples of fluorinated gases include chlorofluorocarbons (CFCs), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3); however, it is noted that these gases are not associated with typical land use development. Human-caused emissions of GHGs exceeding natural ambient concentrations are believed to be responsible for intensifying the greenhouse effect and leading to a trend of unnatural warming of the Earth’s climate, known as global climate change or global warming.

GHGs are global pollutants, unlike criteria air pollutants and toxic air contaminants (TACs), which are pollutants of regional and local concern. Whereas pollutants with localized air quality effects have relatively short atmospheric lifetimes (approximately one day), GHGs have long atmospheric lifetimes (one to several thousand years). GHGs persist in the atmosphere for long enough time periods to be dispersed around the globe. Although the exact lifetime of a GHG molecule is dependent on multiple variables and cannot be pinpointed, more CO2 is emitted into the atmosphere than is sequestered by ocean uptake, vegetation, or other forms of carbon sequestration. Of the total annual human-caused CO2 emissions, approximately 55 percent is sequestered through ocean and land uptakes every year, averaged over the last 50 years, whereas the remaining 45 percent of human-caused CO2 emissions remains stored in the atmosphere (Intergovernmental Panel on Climate Change, 2013). Table 10-1: Description of Greenhouse Gases, described the primary GHGs attributed to global climate change, including their physical properties.

GHGs are emitted by both natural processes and human activities. Of these gases, CO2 and CH4 are emitted in the greatest quantities from human activities. Emissions of CO2 are largely byproducts of fossil fuel combustion, whereas CH4 results from off-gassing associated with agricultural practices and landfills. GHGs have the potential to adversely affect the environment because such emissions contribute, on a cumulative basis, to climate change.

Climate change is by definition a cumulative impact because it occurs worldwide. Although emissions of one single project do not cause climate change, GHG emissions from multiple projects (past, present and future) throughout the world could result in a cumulative impact with respect to climate change.

Man-made GHGs, many of which have greater heat-absorption potential than CO2, include fluorinated gases and SF6 (California Environmental Protection Agency [CalEPA], 2006).

Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as “carbon dioxide equivalent” (CO2e), and is the amount of a GHG emitted 1066
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multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane CH4 has a GWP of 28, meaning its global warming effect is 28 times greater than carbon dioxide on a molecule per molecule basis (United Nations Intergovernmental Panel on Climate Change [IPCC], 2014).

The accumulation of GHGs in the atmosphere regulates the earth’s temperature. Without the natural heat trapping effect of GHGs, Earth’s surface would be about 34° C cooler (CalEPA, 2006). However, it is believed that emissions from human activities, particularly the consumption of fossil fuels for electricity production and transportation, have elevated the concentration of these gases in the atmosphere beyond the level of naturally occurring concentrations.

Table 10-1: Description of Greenhouse Gases
Greenhouse Gas Description
Carbon Dioxide (CO2)
CO2 is a colorless, odorless gas that is emitted naturally and through human activities. Natural sources include decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic sources are from burning coal, oil, natural gas, and wood.

The largest source of CO2 emissions globally is the combustion of fossil fuels such as coal, oil, and gas in power plants, automobiles, and industrial facilities. The atmospheric lifetime of CO2 is variable because it is readily exchanged in the atmosphere. CO2 is the most widely emitted GHG and is the reference gas (Global Warming Potential of 1) for determining Global Warming Potentials for other GHGs.

Nitrous Oxide (N2O)
N2O is largely attributable to agricultural practices and soil management. Primary human-related sources of N2O include agricultural soil management, sewage treatment, combustion of fossil fuels, and adipic and nitric acid production. N2O is produced from biological sources in soil and water, particularly microbial action in wet tropical forests. The atmospheric lifetime of N2O is approximately 120 years.

The Global Warming Potential of N2O is 298.

Methane (CH4)
Methane, a highly potent GHG, primarily results from off-gassing (the release of chemicals from nonmetallic substances under ambient or greater pressure conditions) and is largely associated with agricultural practices and landfills.

Methane is the major component of natural gas, about 87 percent by volume.

Human-related sources include fossil fuel production, animal husbandry, rice cultivation, biomass burning, and waste management. Natural sources of CH4 include wetlands, gas hydrates, termites, oceans, freshwater bodies, non-wetland soils, and wildfires. The atmospheric lifetime of CH4 is about 12 years and the Global Warming Potential is 25.

Hydrofluorocarbons
(HFCs)
HFCs are typically used as refrigerants for both stationary refrigeration and mobile air conditioning. The use of HFCs for cooling and foam blowing is increasing, as the continued phase out of Chlorofluorocarbons (CFCs) and HCFCs gains momentum.

The 100-year Global Warming Potential of HFCs range from 124 for HFC-152 to 14,800 for HFC-23.

Perfluorocarbons (PFCs)
PFCs have stable molecular structures and only break down by ultraviolet rays about 60 kilometers above Earth’s surface. Because of this, they have long lifetimes, between 10,000 and 50,000 years. Two main sources of PFCs are primary aluminum 1067
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Greenhouse Gas Description
production and semiconductor manufacturing. Global Warming Potentials range from 6,500 to 9,200.

Chlorofluorocarbons
(CFCs)
CFCs are gases formed synthetically by replacing all hydrogen atoms in methane or ethane with chlorine and/or fluorine atoms. They are nontoxic, nonflammable, insoluble, and chemically unreactive in the troposphere (the level of air at the earth’s surface). CFCs were synthesized in 1928 for use as refrigerants, aerosol propellants, and cleaning solvents. The Montreal Protocol on Substances that Deplete the Ozone Layer prohibited their production in 1987. Global Warming Potentials for CFCs range from 3,800 to 14,400.

Sulfur Hexafluoride (SF6)
SF6 is an inorganic, odorless, colorless, and nontoxic, nonflammable gas. It has a lifetime of 3,200 years. This gas is manmade and used for insulation in electric power transmission equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas. The Global Warming Potential of SF6 is 23,900.

Hydrochlorofluorocarbons
(HCFCs)
HCFCs are solvents, similar in use and chemical composition to CFCs. The main uses of HCFCs are for refrigerant products and air conditioning systems. As part of the Montreal Protocol, HCFCs are subject to a consumption cap and gradual phase out.

The United States is scheduled to achieve a 100 percent reduction to the cap by 2030. The 100-year Global Warming Potentials of HCFCs range from 90 for HCFC-123 to 1,800 for HCFC-142b.

Nitrogen trifluoride
Nitrogen trifluoride (NF3) was added to Health and Safety Code section 38505(g)(7) as a GHG of concern. This gas is used in electronics manufacture for semiconductors and liquid crystal displays. It has a high global warming potential of 17,200.

Source: Compiled from U.S. EPA, Overview of Greenhouse Gases, April 11, 2018 (https://www.epa.gov/ghgemissions/overview-greenhouse-gases); U.S. EPA, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2016, 2018; IPCC Climate Change 2007: The Physical Science Basis, 2007; National Research Council, Advancing the Science of Climate Change, 2010; U.S. EPA, Methane and Nitrous Oxide Emission from Natural Sources, April 2010;

10.3.2 Greenhouse Gas Emissions Inventory
Total U.S. GHG emissions were 5,981.4 million metric tons (MMT) CO2e in 2020 (United States Environmental Protection Agency [U.S. EPA], March 2022). Total U.S. emissions have decreased by 7.3 percent from 1990 to 2020 and decreased by 21.4 percent below 2005 levels in 2020, after accounting for sequestration from the land sector (U.S. EPA, 2020). In 2020, fossil fuel combustion accounted for 92.1 percent of CO2 emissions (U.S. EPA, April 2022).

Important drivers influencing emissions levels include: (1) changes in demand for energy and (2) a general decline in the carbon intensity of fuels combusted for energy in recent years by non-transport sectors of the economy.

Based upon the California Air Resources Board (CARB) California Greenhouse Gas Emissions for 2000 to 2019 (CARB, July 2021), California produced 418.2 MMT CO2e in 2019. The major source of GHGs in California is transportation, contributing 39.7 percent of the state’s total GHG emissions. Industrial activity is the second largest source, contributing 21.1 percent of the state’s GHG emissions (CARB, July 2021). California’s relatively high emissions compared to other states are due in part to its large size and large population compared to other states. 1068
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The City of Dublin has roughly 60 percent of total CO2e coming from transportation, 18 percent from commercial and industrial uses, roughly 18 percent from residential, and the remaining four percent from solid waste and water & wastewater (City of Dublin, 2020); refer to Table 10- 2: City of Dublin CAP Reduction Goal Analysis.

Table 10-2: Dublin Community-wide 2015 GHG Emissions and Adjusted Forecast by Sector (MTCO2e) Emissions Summary 2015 2020 2025 2030 2045
Residential Electricity 21,199 11,505 10,507 8,202 525
Commercial/Industrial
Electricity 33,628 17,502 16,362 13,055 890
Residential Gas 35,997 40,162 41,178 42,194 43,210
Commercial/Industrial
Gas
20,961 23,752 24,931 26,109 28,466
Waste 12,736 14,138 14,961 15,784 16,881
Water/Wastewater 2,258 1,218 1,148 923 62
Transportation 191,061 168,488 163,288 156,503 164,699
Total Emissions 317,840 276,765 272,374 262,770 254,733 Population 57,514 64,624 68,083 71,541 75,000
Emissions Per Capita 5.5 4.3 4.0 3.7 3.4
Source: City of Dublin Climate Action Plan, 2020. Table 4-2- Dublin Community-Wide 2015 Emissions and Adjusted Forecast by Sector (MT CO2e).

10.4 Applicable Regulations, Plans, and Standards

10.4.1 Federal
To date, no national standards have been established for nationwide GHG reduction targets, nor have any regulations or legislation been enacted specifically to address climate change and GHG emissions reduction at the project level. Various efforts have been promulgated at the federal level to improve fuel economy and energy efficiency to address climate change and its associated effects.

Energy Independence and Security Act of 2007. The Energy Independence and Security Act of 2007 among other key measures, requires the following, which would aid in the reduction of national GHG emissions:
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 Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in 2022.  Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct the National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.
 Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

U.S. Environmental Protection Agency Endangerment Finding. The U.S. EPA authority to regulate GHG emissions stems from the U.S. Supreme Court decision in Massachusetts v. U.S.

EPA (2007). The Supreme Court ruled that GHGs meet the definition of air pollutants under the existing Clean Air Act and must be regulated if these gases could be reasonably anticipated to endanger public health or welfare. Responding to the Court’s ruling, the U.S. EPA finalized an endangerment finding in December 2009. Based on scientific evidence it found that six GHGs (carbon dioxide [CO2], methane [CH4], nitrous oxide [N2O], hydrofluorocarbons [HFCs], perfluorocarbons [PFCs], and sulfur hexafluoride [SF6]) constitute a threat to public health and welfare. Thus, it is the Supreme Court’s interpretation of the existing Act and the U.S. EPA’s assessment of the scientific evidence that form the basis for the EPA’s regulatory actions.

Federal Vehicle Standards. In response to the U.S. Supreme Court ruling discussed above, the George W. Bush Administration issued Executive Order 13432 in 2007 directing the U.S. EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008.

In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in 2010, the EPA and NHTSA issued a final rule regulating cars and light-duty trucks for model years 2012–2016.

In 2010, President Barack Obama issued a memorandum directing the Department of Transportation, Department of Energy, U.S. EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastructure.

In response to this directive, the U.S. EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017–2025 light-duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO2 in model year 2025, on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency. The final rule was adopted in 2012 for model years 2017–2021, and NHTSA intends to set standards for model years 2022–2025 in a future rulemaking. On January 12, 2017, the U.S. EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks. 1070
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In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the U.S. EPA and NHTSA announced fuel economy and GHG standards for medium- and heavyduty trucks for model years 2014–2018. The standards for CO2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the U.S. EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6 to 23 percent over the 2010 baselines.

In August 2016, the U.S. EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain trailers, and model years 2021 through 2027 for semi-trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion metric tons and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program.

In 2018, the President and the U.S.EPA stated their intent to halt various federal regulatory activities to reduce GHG emission, including the phase two program. California and other states have stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures and have committed to cooperating with other countries to implement global climate change initiatives. On September 27, 2019, the U.S. EPA and the NHTSA published the “Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program.” (84 Fed. Reg. 51,310 (Sept. 27, 2019.) The Part One Rule revokes California’s authority to set its own GHG emissions standards and set zero-emission vehicle mandates in California. On March 31, 2020, the U.S. EPA and NHTSA finalized rulemaking for SAFE Part Two sets CO2 emissions standards and corporate average fuel economy (CAFE) standards for passenger vehicles and light duty trucks, covering model years 2021-2026. The current U.S. EPA administration has repealed SAFE Rule Part One, effective January 28, 2022, and is reconsidering Part Two.

10.4.2 State
CARB is responsible for the coordination and oversight of State and local air pollution control programs in California. Various statewide and local initiatives to reduce California’s contribution to GHG emissions have raised awareness about climate change and its potential for severe long-term adverse environmental, social, and economic effects.

Assembly Bill 1493
Assembly Bill (AB) 1493 (2002), referred to as “Pavley,” requires CARB to develop and adopt regulations to achieve “the maximum feasible and cost-effective reduction of GHG emissions from motor vehicles.” On June 30, 2009, U.S. EPA granted the waiver of Clean Air Act preemption to California for its greenhouse gas emission standards for motor vehicles beginning with the 2009 model year. Pavley I took effect for model years starting in 2009 to 2016, and Pavley II, which is now referred to as “LEV (Low Emission Vehicle) III GHG” covers 2017 to 2025.
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Under Pavley, fleet average emission standards were intended to reach 22 percent reduction from 2009 levels by 2012 and 30 percent by 2016. The Advanced Clean Cars program coordinates the goals of the Low Emissions Vehicles (LEV), Zero Emissions Vehicles (ZEV), and Clean Fuels Outlet programs and would provide major reductions in GHG emissions. By 2025, when the rules would be fully implemented, new automobiles would emit 34 percent less GHGs. Statewide CO2e emissions would be reduced 3 percent by 2020 and 12 percent by 2025.

The reduction would increase to 27 percent in 2035 and even further to 33 percent reduction in 2050 (CARB, 2013).

Assembly Bill 32 and Scoping Plan
California’s major initiative for reducing GHG emissions is outlined in Assembly Bill 32 (AB 32), the “California Global Warming Solutions Act of 2006.” AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020 (essentially a 15 percent reduction below 2005 emission levels; the same requirement as under S-3-05) and requires CARB to prepare a Scoping Plan that outlines the main state strategies for reducing GHGs to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to require reporting and verification of statewide GHG emissions. Additional development of these measures and adoption of the appropriate regulations occurred through the end of 2013. Key elements of the Scoping Plan include:
 Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.
 Achieving a statewide renewables energy mix of 33 percent by 2020.  Developing a California cap-and-trade program that links with other programs to create a regional market system and caps sources contributing 85 percent of California’s GHG emissions (adopted in 2011).
 Establishing targets for transportation related GHG emissions for regions throughout California and pursuing policies and incentives to achieve those targets (several Sustainable Communities Strategies have been adopted).
 Adopting and implementing measures pursuant to existing State laws and policies, including California’s clean car standards, heavy-duty truck measures, the Low Carbon Fuel Standard (amendments to the Pavley Standard adopted 2009; Advanced Clean Car standard adopted 2012), goods movement measures, and the Low Carbon Fuel Standard (adopted 2009).
 Creating targeted fees, including a public goods charge on water use, fees on gasses with high global warming potential, and a fee to fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation (CARB 2008).

After completing a comprehensive review and update process, CARB approved a 1990 statewide GHG level and 2020 limit of 427 MMT CO2e. CARB approved the Scoping Plan on 1072
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December 11, 2008. The Scoping Plan includes measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e. g Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and-Trade) have been adopted and implementation activities are ongoing.

In May 2014, CARB approved the first update to the AB 32 Scoping Plan. The 2014 Scoping Plan update defined CARB’s climate change priorities for the next 5 years and sets the groundwork to reach post-2020 goals set forth in EO S-3-05. The 2014 update highlighted California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluated how to align the State’s longer-term GHG reduction strategies with other State policy priorities, such as for water, waste, natural resources, clean energy and transportation, and land use (CARB, 2014).

In 2016, the Legislature passed SB 32, which codifies a 2030 GHG emissions reduction target of 40 percent below 1990 levels. With SB 32, the Legislature passed companion legislation, AB 197, which provides additional direction for developing the Scoping Plan. On December 14, 2017 CARB adopted a second update to the Scoping Plan9. The 2017 Scoping Plan details how the State will reduce GHG emissions to meet the 2030 target set by Executive Order B-30-15 and codified by SB 32. Other objectives listed in the 2017 Scoping Plan are to provide direct GHG emissions reductions; support climate investment in disadvantaged communities; and support the Clean Power Plan and other Federal actions. These measures include increasing the Renewable Portfolio Standard to 50 percent by 2030 and extending the cap-and-trade program to 2030 and providing the revenue towards climate programs, disadvantage communities, and projects like the high-speed rail. The 2017 Scoping Plan also includes a 50 percent reduction in petroleum use in vehicles, increasing energy efficiency savings at existing buildings, carbon sequestration in the land base, and reducing methane, black carbon, and other short-live climate pollutants.

The AB 32 Scoping Plan also identifies a cap-and-trade program as one of the strategies California will employ to reduce GHG emissions. Under the cap-and-trade program, an overall limit on GHG emissions from capped sectors will be established and facilities subject to the cap will be able to trade permits (allowances) to emit GHGs. The program began on January 1, 2012, with an enforceable compliance obligation beginning with the 2013 GHG emissions and extending until 2030.

Senate Bill 1368
Senate Bill (SB) 1368 (Emission Performance Standards) is the companion bill of AB 32, which directs the California Public Utilities Commission to adopt a performance standard for GHG 9 California Air Resources Board, California’s 2017 Climate Change Scoping Plan, https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf. Accessed May 9, 2022. 1073
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emissions for the future power purchases of California utilities. SB 1368 limits carbon emissions associated with electrical energy consumed in California by forbidding procurement arrangements for energy longer than 5 years from resources that exceed the emissions of a relatively clean, combined cycle natural gas power plant. The new law effectively prevents California’s utilities from investing in, otherwise financially supporting, or purchasing power from new coal plants located in or out of the State. The California Public Utilities Commission adopted the regulations required by SB 1368 on August 29, 2007. The regulations implementing SB 1368 establish a standard for baseload generation owned by, or under longterm contract to publicly owned utilities, of 1,100 lbs. of CO2 per megawatt-hour (MWh).

Senate Bill 375
SB 375, signed in September 2008, enhances the State’s ability to reach AB 32 goals by directing CARB to develop regional GHG emission reduction targets to be achieved from vehicles for 2020 and 2035. In addition, SB 375 directs each of the state’s 18 major Metropolitan Planning Organizations (MPOs) to prepare a “sustainable communities strategy” (SCS) that contains a growth strategy to meet these emission targets for inclusion in the Regional Transportation Plan (RTP). On September 23, 2010, CARB adopted final regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035.

Senate Bills 1078 and X1-2 and Executive Orders S-14-08 and S-21-09 These bills enact the renewable electricity standards for the State. SB 1078 requires California to generate 20 percent of its electricity from renewable energy by 2017. SB 107 changed the due date to 2010 instead of 2017. On November 17, 2008, then-Governor Arnold Schwarzenegger signed Executive Order S-14-08, which established a Renewable Portfolio Standard target for California requiring that all retail sellers of electricity serve 33 percent of their load with renewable energy by 2020. The existing RPS requires retail sellers to supply 20 percent of their total electrical load from renewable energy sources by 2010. SB 350 (see below) extended this goal to 50 percent by 2050.

To meet this new goal, a substantial increase in the development of wind, solar, geothermal, and other “RPS eligible” energy projects will be needed. Executive Order S-14-08 seeks to accelerate such development by streamlining the siting, permitting, and procurement processes for renewable energy generation facilities. To this end, S-14-08 issues two directives: (1) the existing Renewable Energy Transmission Initiative will identify renewable energy zones that can be developed as such with little environmental impact and (2) the California Energy Commission (CEC) and the California Department of Fish & Wildlife (CDFW) will collaborate to expedite the review, permitting, and licensing process for proposed RPS-eligible renewable energy projects.

Executive Order S-21-09 also directed CARB to adopt a regulation by July 31, 2010, requiring the State’s load serving entities to meet a 33 percent renewable energy target by 2020. CARB approved the Renewable Electricity Standard on September 23, 2010 by Resolution 10-23.

SBX1-2, which codified the 33 percent by 2020 goal.
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Senate Bill 350
The Clean Energy and Pollution Reduction Act of 2015 was signed into law on October 7, 2015, SB 350 implements the goals of Executive Order B-30-15. The objectives of SB 350 are to increase the procurement of electricity from renewable sources from 33 percent to 50 percent (with interim targets of 40 percent by 2024, and 25 percent by 2027) and to double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation. SB 350 also reorganizes the Independent System Operator (ISO) to develop more regional electricity transmission markets and improve accessibility in these markets, which will facilitate the growth of renewable energy markets in the western United States.

Assembly Bill 398
Signed on July 25, 2017, AB 398 extended the duration of the Cap-and-Trade program from 2020 to 2030. AB 398 required CARB to update the Scoping Plan and for all GHG rules and regulations adopted by the State. It also designated CARB as the statewide regulatory body responsible for ensuring that California meets its statewide carbon pollution reduction targets, while retaining local air districts’ responsibility and authority to curb toxic air contaminants and criteria pollutants from local sources that severely impact public health. AB 398 also decreased free carbon allowances over 40 percent by 2030 and prioritized Cap-and-Trade spending to various programs including reducing diesel emissions in impacted communities.

Senate Bill 32
Signed into law in September 2016, SB 32 codifies the 2030 GHG reduction target in Executive Order B-30-15 (40 percent below 1990 levels by 2030). CARB also must adopt rules and regulations in an open public process to achieve the maximum, technologically feasible, and cost-effective GHG reductions to achieve 40 percent below 1990 levels by 2030.

Senate Bill 150
Signed on October 10, 2017, SB 150 aligns local and regional GHG reduction targets with State targets (i.e., 40 percent below their 1990 levels by 2030). SB 150 creates a process to include communities in discussions on how to monitor their regions’ progress on meeting these goals.

The bill also requires the CARB to regularly report on that progress, as well as on the successes and the challenges regions experience associated with achieving their targets. SB 150 provides for accounting of climate change efforts and GHG reductions and identify effective reduction strategies.

Senate Bill 100
Signed into Law in September 2018, SB 100 increased California’s renewable electricity portfolio from 50 to 60 percent by 2030. SB 100 also established a further goal to have an electric grid that is entirely powered by clean energy by 2045. 1075
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Executive Orders
California’s Executive Branch has taken several actions to reduce GHGs through the use of executive orders. Although not regulatory, they set the tone for the State and guide the actions of state agencies.

Executive Order S-3-05. Executive Order S-3-05 was issued on June 1, 2005, which established the following GHG emissions reduction targets:
 By 2010, reduce greenhouse gas emissions to 2000 levels.  By 2020, reduce greenhouse gas emissions to 1990 levels.  By 2050, reduce greenhouse gas emissions to 80 percent below 1990 levels.

The 2050 reduction goal represents what some scientists believe is necessary to reach levels that will stabilize the climate. The 2020 goal was codified in AB 32. Because the 2050 target is only contained in an executive order, the goals are not legally enforceable for local governments or the private sector.

Executive Order S-01-07. Issued on January 18, 2007, Executive Order S 01-07 mandates that a statewide goal shall be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020. In particular, the executive order established a Low Carbon Fuel Standard (LCFS) and directed the Secretary for Environmental Protection to coordinate the actions of the California Energy Commission, CARB, the University of California, and other agencies to develop and propose protocols for measuring the “life-cycle carbon intensity” of transportation fuels. CARB adopted the Low Carbon Fuel Standard on April 23, 2009.

Executive Order S-13-08. Issued on November 14, 2008, Executive Order S-13-08 facilitated the California Natural Resources Agency development of the 2009 California Climate Adaptation Strategy. Objectives include analyzing risks of climate change in California, identifying and exploring strategies to adapt to climate change, and specifying a direction for future research.

Executive Order S-14-08. Issued on November 17, 2008, Executive Order S-14-08 expands the State’s Renewable Energy Standard to 33 percent renewable power by 2020.

Executive Order S-21-09. Issued on July 17, 2009, Executive Order S-21-09 directs CARB to adopt regulations to increase California's Renewable Portfolio Standard (RPS) to 33 percent by 2020. This builds upon SB 1078 (2002), which established the California RPS program, requiring 20 percent renewable energy by 2017, and SB 107 (2006), which advanced the 20 percent deadline to 2010, a goal which was expanded to 33 percent by 2020 in the 2005 Energy Action Plan II.

Executive Order B-30-15. Issued on April 29, 2015, Executive Order B-30-15 established a California GHG reduction target of 40 percent below 1990 levels by 2030 and directs CARB to 1076
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update the Climate Change Scoping Plan to express the 2030 target in terms of MMCO2e. The 2030 target acts as an interim goal on the way to achieving reductions of 80 percent below 1990 levels by 2050, a goal set by Executive Order S-3-05. The executive order also requires the State’s climate adaptation plan to be updated every three years and for the State to continue its climate change research program, among other provisions. With the enactment of SB 32 in 2016, the Legislature codified the goal of reducing GHG emissions by 2030 to 40 percent below 1990 levels.

Executive Order B-55-18. Issued on September 10, 2018, Executive Order B-55-18 establishes a goal to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter. This goal is in addition to the existing statewide targets of reducing GHG emissions. The executive order requires CARB to work with relevant state agencies to develop a framework for implementing this goal. It also requires CARB to update the Scoping Plan to identify and recommend measures to achieve carbon neutrality.

The executive order also requires state agencies to develop sequestration targets in the Natural and Working Lands Climate Change Implementation Plan.

California Regulations and Building Codes
Title 20- Appliance Efficiency Regulations. The California Energy Commission adopted Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608) on October 11, 2006. The regulations were approved by the California Office of Administrative Law on December 14, 2006. The regulations include standards for both federally regulated appliances and non-federally regulated appliances. While these regulations are now often viewed as “business-as-usual,” they exceed the standards imposed by all other states and they reduce GHG emissions by reducing energy demand.

Title 24- California Building Code. The California Energy Resources Conservation and Development Commission adopted energy conservation standards for new residential and nonresidential buildings in June 1977 in response to a legislative mandate to reduce California’s energy consumption. These standards were most recently revised in 2022 and take effect on January 1, 2023 (Title 24, Part 6, of the California Code of Regulations [CCR]). The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.

On July 17, 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code was adopted as part of the California Building Standards Code (CALGreen) (Part 11, Title 24, CCR). The green building standards that became mandatory in the 2010 edition of the code established voluntary standards on planning and design for sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and internal air contaminants. CALGreen also provides voluntary tiers and measures that local governments may adopt that encourage or require additional measures in the five green building topics.
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On August 11, 2021, the CEC adopted the 2022 Energy Code. In December, it was approved by the California Building Standards Commission for inclusion into the California Building Standards Code. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 Energy Code.

10.4.3 Regional & Local
Bay Area Air Quality Management District
The BAAQMD regulates air quality in the San Francisco Bay Area Air Basin and is responsible for attainment planning related to criteria air pollutants and for district rule development and enforcement. The district inspects stationary sources and responds to citizen complaints, monitors ambient air quality and meteorological conditions, and implements programs and regulations required by law. It also reviews air quality analyses prepared for CEQA assessments and has published the CEQA Air Quality Guidelines documents for use in evaluation of air quality (including GHG) impacts. In April 2022, the BAAQMD approved new CEQA thresholds for evaluating climate impacts from land use projects and plans.

East Bay Community Energy
East Bay Community Energy (EBCE) is a community choice aggregation local power supplier that began serving Dublin customers in 2018. In January 2022, standard residential accounts moved from an automatic default service “Bright Choice” which is 80 percent carbon free to EBCE’s “Renewable 100” product which is sourced from California wind and solar facilities.

Non-residential customers will default to Renewable 100 beginning in October 2022.

City of Dublin General Plan
The City of Dublin’s General Plan contains the following policies associated with GHG emissions that are relevant to the project:

Energy Efficiency and Conservation in New Development
Guiding Policy 13.3.2.A:

1. Encourage the installation of alternative energy technology in new residential and commercial development.

2. Encourage designing for solar access.

3. Encourage energy efficient improvements be made on residential and commercial properties.

Implementing Policy 13.3.2.B

1. New development proposals shall be reviewed to ensure lighting levels needed for a safe and secure environment are provided - utilizing the most energy-efficient fixtures 1078
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(in most cases, LED lights) - while avoiding over-lighting of sites. Smart lighting technology (e.g. sensors and/or timers) shall also be employed in interior and exterior lighting applications where appropriate.

2. New development projects shall install LED streetlights in compliance with the City’s LED light standard.

3. In new commercial and residential parking lots, require the installation of conduit to serve electric vehicle parking spaces to enable the easier installation of future charging stations.

4. Encourage the installation of charging stations for commercial projects over a certain size and any new residential project that has open parking (i.e. not individual, enclosed garages).

5. Encourage buildings (and more substantially, whole neighborhoods) to be designed along an east-west axis to maximize solar exposure. Where feasible, require new development projects to take advantage of shade, prevailing winds, landscaping and sun screens to reduce energy use; and to use regenerative energy heating and cooling source alternatives to fossil fuels.

6. Continue to implement parking lot tree planting standards that would substantially cool parking areas and help cool the surrounding environment. Encourage landscaping conducive to solar panels in areas where appropriate.

7. Promote and encourage photovoltaic demonstration projects in association with new development.

Consider creating a recognition program for commercial or residential projects that install large-scale solar or wind energy systems and to publicly commend and acknowledge businesses or individuals that construct or remodel buildings that save more energy than required by Title 24 or by the Cal Green Building Code.

City of Dublin Climate Action Plan
The City of Dublin Climate Action Plan 2030 and Beyond (CAP 2030) establishes a vision for the City to reach carbon neutrality by 2045 and includes quantified actions the City will take to GHG emissions by 65,090 metric tons CO2e by 2030. The CAP 2030 identifies additional actions that will need to be implemented to reach carbon neutrality.

The purpose of the CAP 2030 is to meet the State’s 2030 GHG emissions reductions target of at least 40 percent below 1990 levels by 2030. The CAP 2030 identifies GHG reduction strategies and measures that relate to renewable and carbon‐free energy, building efficiency and electrification, sustainable mobility and land use, materials and waste management, and municipal leadership. The City has determined that implementing all the measures in the CAP 2030 should reduce the impacts from activities under the CAP to a less than significant level under CEQA.

If a project were consistent with the applicable emissions reduction target, the project would be considered to have a less than significant impact due to GHG emissions and climate change consistent with Public Resources Code 21083.3 and CEQA Guidelines Sections 15183.5, 15064 and 15130.
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Dublin Green Building Code
In 2009, the City adopted the Dublin Green Building Code (Municipal Code Chapter 7.94) requiring residential projects over 20 units to reach 50 points on the GreenPoint Rated system or achieve LEED for Homes. GreenPoint Rated is a green building program administered by the nonprofit organization Build It Green with assistance from StopWaste. The GreenPoint Rated system includes five categories: energy efficiency, resource conservation, indoor air quality, water conservation, and community. Currently the City enforces the City enforces the 2019 California Green Building Standards Code with City amendments. The City is in the process of adopting the 2022 California Green Building Standards Codes.

10.5 Environmental Impacts and Mitigation Measures

10.5.1 Significance Thresholds
According to the adopted Appendix G of the State CEQA Guidelines, impacts related to GHG emissions from a project would be significant if the project would:
 Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and/or
 Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The Bay Area Air Quality Management District’s (BAAQMD’s) approach to developing a threshold of significance for GHG emissions is to identify the emissions level for which a project would not be expected to substantially conflict with existing California legislation adopted to reduce statewide GHG emissions needed to move towards climate stabilization. If a project would generate GHG emissions above the threshold level, it would be considered to contribute considerably to a significant cumulative impact. Stationary-source projects include land uses that would accommodate processes and equipment that emit GHG emissions and would require an Air District permit to operate. If annual emissions of operational-related GHGs exceed these levels, the project would result in a cumulatively considerable contribution to a cumulatively significant impact to global climate change. BAAQMD’s recommended thresholds are as follows: BAAQMD’s recommended thresholds are as follows:

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. 1080
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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 electric vehicle requirements in the most recently adopted version of CALGreen Tier 2; and
B. Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA Guidelines section 15183.5(b) C
A qualified GHG Reduction Strategy adopted by a local jurisdiction should include the following elements as described in the State CEQA Guidelines Section 15183.5(b)(1):
 Quantify GHG emissions, both existing and projected over a specified time period, resulting from activities within a defined geographic area;  Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable;  Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area;
 Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level;
 Establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels; and  Be adopted in a public process following environmental review.

It should be noted that the BAAQMD does not have an adopted threshold of significance for construction-related GHG emissions. However, the BAAQMD recommends quantification and disclosure of construction GHG emissions. The BAAQMD also recommends that the Lead Agency should make a determination on the significance of these construction generated GHG 1081
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emission impacts in relation to meeting AB 32 GHG reduction goals, as required by the Public Resources Code, Section 21082.2. The Lead Agency is encouraged to incorporate best management practices to reduce GHG emissions during construction, as feasible and applicable.

For CEQA analyses, project‐related GHG impacts can be categorized as either direct or indirect.

Direct emissions refer to those emitted by stationary sources at the project site or caused by project activity on‐site, and these emissions are normally within control of the project sponsor or applicant. Indirect emissions include those emissions that are not within the direct control of the project sponsor or applicant, but may occur as a result of the project, such as the motor vehicle emissions induced by the project. Indirect emissions include emissions from any off‐site facilities used for project support as a result of the construction or operation of a project, and these emissions are likely to occur outside the control of the project far off‐site or even outside of California.

Construction‐phase GHG emissions are quantified as part of the air quality impact assessment (see Chapter 6, Air Quality, and Appendix B for supporting calculations). These one‐time emissions can be amortized over the life of the project to describe an equivalent annual emission rate. To amortize the construction emissions over the life of the project, the total GHG emissions due to construction are divided by a 30 year period. The amortized construction emissions can then be added to the annual operational GHG emissions.

The effects of the project are also considered based on whether the project implements reduction strategies identified in AB 32, SB 32, 2017 Scoping Plan, the Governor’s Executive Order S‐14‐08, or other strategies to help reduce GHGs to the level proposed by the Governor.

If so, it could reasonably follow that the project would not result in a significant contribution to the cumulative impact of global climate change.

Significance Classifications
The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.
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10.5.2 Study Methodology
The project’s construction and operational emissions were calculated using the California Emissions Estimator Model version 2020.4.0 (CalEEMod). Details of the modeling assumptions and emission factors are provided in Appendix B: CalEEmod Air Quality Analysis. However, with updated BAAQMD CEQA thresholds, quantification of emissions is not required. Emission amounts are provided for informational purposes. For construction, CalEEMod calculates emissions from off-road equipment usage and on-road vehicle travel associated with haul, delivery, and construction worker trips. The project’s construction-related GHG emissions were forecasted based on the proposed construction schedule and applying the mobile-source and fugitive dust emissions factors derived from CalEEMod. The project’s construction-related GHG emissions would be generated from off-road construction equipment, on-road hauling, and vendor (material delivery) trucks, and worker vehicles.

The project’s operations-related GHG emissions would be generated by vehicular traffic, area sources (e.g., landscaping maintenance, consumer products), electrical generation, natural gas consumption, water supply and wastewater treatment, and solid waste.

Details of the modeling assumptions and emission factors are provided in Appendix B:

CalEEMod Air Quality Analysis.

10.5.3 Summary of No and/or Beneficial Impacts
There are no “no” impacts or “beneficial” impacts.

10.5.4 Impact Analysis
Global climate change is, by definition, a cumulative impact of GHG emissions. Therefore, there is no project-level analysis.

Impact GHG-1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment or conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases (Class III).

Project-Related Sources of Greenhouse Gas Emissions
The project would include direct and indirect GHG emissions. Direct operational-related GHG emissions for the project would include emissions from area and mobile sources, while indirect emissions are from energy consumption, water demand, and solid waste.

Construction Emissions
Construction of the project would result in direct emissions of CO2, N2O, and CH4 from the operation of construction equipment and the transport of materials and construction workers to and from the project site. Construction GHG emissions are typically summed and amortized 1083
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over a 30-year period, then added to the operational emissions.10 It is reasonable to look at a 30-year time frame for buildings since this is a typical interval before a new building requires the first major renovation.11 Total GHG emissions generated during all phases of construction were combined and are presented in Table 10-3: Project Construction-Related Greenhouse Gas Emissions. The CalEEMod outputs are contained within Appendix B, Air Quality/Greenhouse Gas Emissions Data. As shown in Table 10-3, the project would result in 34,189 MTCO2e (1,140 MTCO2eq/yr. when amortized over 30 years).

Table 10-3: Project Construction-Related Greenhouse Gas Emissions Year Emissions (MTCO2e)
2023 3,188.67
2024 9,685.01
2025 10,645.51
2026 7,024.41
2027 2,728.98
2028 917.01
Total Construction Emissions 34,189.59
Annualized over 30 years 1,139.65
Notes:

MTCO2e = metric tons of carbon dioxide equivalents
Source: CalEEMod Version 2020.4.0.

Operational Emissions
Operational or long-term emissions occur over the life of the project. GHG emissions would result from direct emissions such as project generated vehicular traffic, on-site combustion of natural gas, operation of any landscaping equipment. Operational GHG emissions would also result from indirect sources, such as off-site generation of electrical power over the life of the project, the energy required to convey water to, and wastewater from the project site, the emissions associated with solid waste generated from the project site, and any fugitive refrigerants from air conditioning or refrigerators. Table 10-4: Project Operation-Related Greenhouse Gas Emissions, summarizes the total GHG emissions associated with project. As shown, the project would generate approximately 11,919.82 metric tons of CO2e annually. 10 The project lifetime is based on the standard 30-year assumption of the South Coast Air Quality Management District (South Coast Air Quality Management District, Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #13, August 26, 2009). 11 International Energy Agency, Energy Efficiency Requirements in Building Codes, Energy Efficiency Policies for New Buildings, March 2008. 1084
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Table 10-4: Project Operation-Related Greenhouse Gas Emissions Emissions Source Emissions (MTCO2e)
Area 8.11
Energy 1,354
Mobile 9,052.49
Waste 253.86
Water and Wastewater 111.74
Construction (annualized) 1,139.65
Total Operational Emissions 11,919.82
Notes:

MTCO2e = metric tons of carbon dioxide equivalents
Source: CalEEMod Version 2020.4.0.

Area Source Emissions. Area source emissions were calculated using CalEEMod and project specific land use data. The primary GHG emission sources calculated by CalEEMod include hearths and landscape equipment. As noted in Table 10-4, the project would result in approximately 8 MTCO2e/year of area source GHG emissions.

Mobile Source. CalEEMod relies upon trip data as part of the transportation analysis and project specific land use data to calculate mobile source emissions. The project would directly result in approximately 9,052 MTCO2e/year of mobile source-generated GHG emissions; refer to Table 10-4.

Energy Consumption. Energy consumption emissions were calculated using CalEEMod and project-specific land use data. Electricity is provided by East Bay Community Energy (EBCE) and conveyed to customers through Pacific Gas and Electric’s (PG&E) existing infrastructure. The project would indirectly result in approximately 1,354 MTCO2e/year due to energy consumption; refer to Table 10-4. It should be noted that Dublin electricity customers are automatically enrolled in community choice energy through EBCE, which would further reduce the energy emissions.

Water Demand. The project’s water supply would be provided by local groundwater and imported surface water. Emissions from indirect energy impacts due to water treatment and transport would result in approximately 112 MTCO2e/year; refer to Table 10-4.

Solid Waste. Solid waste associated with operations of the project would result in approximately 254 MTCO2e/year; refer to Table 10-4.

It should be noted that the operational emissions are based on the 2019 Title 24 Part 6 (Building Energy Efficiency Standards) energy consumption rates. The standards also require 1085
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updated thermal envelope standards (preventing heat transfer from the interior to exterior and vice versa), residential and nonresidential ventilation requirements, and nonresidential lighting requirements that would cut residential energy use by more than 50 percent (with solar) and nonresidential energy use by 30 percent. The standards also encourage demand responsive technologies including battery storage and heat pump water heaters and improve the building’s thermal envelope through high performance attics, walls and windows to improve comfort and energy savings (California Energy Commission, March 2018).

The proposed project would also comply with the appliance energy efficiency standards in Title 20 of the California Code of Regulations. The Title 20 standards include minimum levels of operating efficiency, and other cost-effective measures, to promote the use of energy- and water-efficient appliances. The proposed project would be constructed according to the standards for high-efficiency water fixtures for indoor plumbing and water efficient irrigation systems required in 2019 Title 24, Part 11 (CALGreen).

As noted above, the California Building Standards Commission adopted the 2022 Energy Code for inclusion into the California Building Standards Code. The latest building encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more.

The analysis conservatively uses 2019 Energy Code as the project would be required to comply with 2022 or later standards which would increase efficiency of buildings.

At the State and global level, improvements in technology, policy, and social behavior can also influence and reduce operational emissions generated by a project. The state is currently on a pathway to achieving the Renewable Portfolio Standards goal of 33 percent renewables by 2020 and 60 percent renewables by 2030 per SB 100. Despite these goals, the majority of the proposed project’s emissions would still be from mobile and energy sources. Future mobile source emissions are greatly dependent on changes in vehicle technology, fuels, and social behavior, which can be influenced by policies to varying degrees. Due to these external factors, average emissions from transportation in 2050 would mostly still generate GHG emissions, but the quantity is uncertain in light of potential changes in technology and policy over the next 30 years.

The majority of project emissions (approximately 88 percent) would occur from mobile and energy sources. As noted above, energy and mobile sources are targeted by statewide measures such as low carbon fuels, cleaner vehicles, strategies to promote sustainable communities and improved transportation choices that result in reducing VMT, continued implementation of the Renewable Portfolio Standard (the target is now set at 60 percent renewables by 2030), and extension of the Cap and Trade program (requires reductions from industrial sources, energy generation, and fossil fuels).

The Cap and Trade program covers approximately 85 percent of California’s GHG emissions as of January 2015. The statewide cap for GHG emissions from the capped sectors (i.e., electricity generation, industrial sources, petroleum refining, and cement production) commenced in 2013 1086
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and will decline approximately three percent each year, achieving GHG emission reductions throughout the program’s duration. The passage of AB 398 in July 2017 extended the duration of the Cap and Trade program from 2020 to 2030. With continued implementation of various statewide measures, the proposed project’s operational energy and mobile source emissions would continue to decline in the future.

The project would include additional energy efficiency and GHG reduction design features per City’s Climate Action Plan, including eliminating the use of natural gas in new developments, LED streetlights, efficient outdoor lighting, options for photovoltaic solar systems, solar ready buildings, and drought tolerant and water efficient landscaping. Additionally, as described in Chapter 6 (Air Quality), implementation of MM AQ-2.4: Wood Burning Fireplaces would require the project to prohibit the use of wood burning devices (e.g., fireplaces, wood stoves) and ensure compliance with BAAQMD Regulation 6, Rule 3.

The project also reduces transportation GHG emissions by applying smart growth principles as an urban in-fill development with a mix of retail, entertainment, and residential uses adjacent to transit/multi-modal corridors and within two miles of a BART station. The project facilitates the use of existing bus routes with stops adjacent to the project site. As of May 2022. the Livermore Amador Valley Transit Authority (LAVTA) runs bus service from the project site (Dublin Boulevard and Tassajara Road) to the BART station with 30-minute headways.

Additionally, the project would improve and complete pedestrian and bicycle connections around its perimeter and through the project site. Bicycle storage would be provided in the multi-family buildings, as required, and bicycle racks would be provided near the commercial uses. The project would also improve and complete bicycle lanes and facilities along the perimeter and through the project site that connect with existing bicycle routes. As discussed in Chapter 6: Air Quality, the project would also implement MM AQ-2.5: Vehicle Trip Reduction, which would include a Transportation Demand Management (TDM) plan to reduce mobile GHG emissions for all uses.

Consistency with City of Dublin CAP 2030
The CAP 2030 identifies additional actions that will need to be implemented to reach carbon neutrality. The purpose of the CAP 2030 is to meet the State’s 2030 GHG emissions reductions target of at least 40 percent below 1990 levels by 2030. The CAP 2030 identifies GHG reduction strategies and measures that relate to renewable and carbon‐free energy, building efficiency and electrification, sustainable mobility and land use, materials and waste management, and municipal leadership. The CAP 2030 is a qualified GHG Reduction Strategy under CEQA, which can be used to determine the significance of GHG emissions from a project (CEQA Guidelines section 15183.5). BAAQMD also recognizes the use of a CAP as a significance threshold for a project’s GHG emissions. Therefore, if the project is consistent with the CAP 2030, then the project would result in a less than significant cumulative impact to global climate change in 2030.
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The City’s CAP 2030 constitutes a qualified GHG Reduction Strategy and has been utilized in this analysis for determining the level of significance of the project’s GHG emissions. The analysis of the project’s cumulative contribution to climate change and GHG emissions is the analysis of the project’s consistency with the applicable CAP 2030 measures that is provided in Table 10-5:

Project Consistency with the City of Dublin Climate Action Plan 2030 and Beyond Control Measures. Thus, the project would help implement the CAP 2030, and would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. A less than significant impact would occur in this regard.

Table 10-5: Project Consistency with Applicable City of Dublin Climate Action Plan 2030 and Beyond Control Measures
Control Measure Description Project Consistency
Strategy 1: 100% Renewable and Carbon-Free Electricity
Measure CF-1:

Opt-Up to 100%
Renewable and
Carbon-Free
Electricity
The City of Dublin will set 100%
renewable and carbon-free
electricity as the default electricity
for all Dublin customers served by
East Bay Community Energy to
unlock health and GHG emissions
reduction benefits associated with
carbon-free electricity.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.

Measure CF-2:

Develop a
Renewable
Resource Buildout
Plan
The City will leverage State and
local funding and partnerships to
develop local community solar
projects in Dublin and investigate
development of micro-grids to
improve the resilience of the local
electricity infrastructure.

Not applicable. The City is the responsible
party for this measure. The project would
be required to comply with any associated
standards or requirements.

Strategy 2: Building Efficiency and Electrification
Measure EE-1:

Achieve All-Electric
New Building
Construction
Adopt an all-electric building reach
code for new construction to
reduce natural gas use and limit the
development of new gas
infrastructure in the City of Dublin.

Consistent. The City is the responsible
party for this measure. However, the
project would not include new natural gas
infrastructure.

Measure EE-2:

Implement the
State Building
Energy Disclosure
Program
The City of Dublin will require all
commercial and multifamily
buildings covered by AB 802 to
report energy use through the
Energy Star Portfolio Manager tool.

Consistent. The project would require all
commercial and multifamily buildings to
report energy use through the Energy Star
Portfolio Manager tool.

Measure EE-3:

Streamline Battery
Storage Permit
Requirements
The City will ensure that permitting
for the installation of new battery
storage in residential and
commercial buildings is streamlined
and clear in order to promote the
Consistent. The City is the responsible
party for this measure. The project would
not conflict with implementation and
would comply with the battery storage
requirements in the latest building code.
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Control Measure Description Project Consistency
installation of additional energy
storage capacity in Dublin.

Measure EE-4:

Develop an
Existing Building
Electrification Plan
Develop a plan to promote the
retrofit of 22% of existing buildings
in Dublin to all electric by 2030 and
consider development of existing
building electrification ordinances
in the future.

Not applicable. This measure establishes
countywide building retrofit measures and
specifications for energy efficiency, water
and resource conservation, and indoor air
quality and health. As the project does not
include existing structures, this measure
does not apply.

Strategy 3: Sustainable Mobility and Land Use
Measure SM-1:

Adopt an Electric
Vehicle Charging
Station Ordinance
The City of Dublin will adopt an
electric vehicle (EV) charging
station ordinance for multifamily
and commercial buildings to
increase access to charging stations
and promote the use of electric
vehicles.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.

Measure SM-2:

Develop an Electric
Vehicle
Infrastructure Plan
Develop an electric vehicle (EV)
infrastructure plan to ensure that
the City is optimally siting EV
chargers and using the most
beneficial program for publicly
accessible EV chargers.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.

Measure SM-3:

Develop a
Transportation
Demand
Management Plan
Develop a comprehensive
Transportation Demand
Management (TDM) Plan for the
City of Dublin. The TDM Plan will
identify strategies to help facilitate
the move from single-occupancy
vehicles to less carbon intensive
transportation modes.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.

Additionally, the project includes MM AQ2.5 Vehicle Trip Reduction that would include a TDM plan for both residential and
non-residential uses to reduce air quality
and GHG emissions, and encourage
reduction in VMT.

Measure SM-4:

Develop a Citywide
Parking
Management Plan
Develop a comprehensive Parking
Management Plan that will specify
parking requirements and costing
that supports multi-modal
transportation and a reduction in
vehicle miles traveled.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.
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Control Measure Description Project Consistency
Measure SM-5:

Update the Bicycle
and Pedestrian
Master Plan
Update the Bicycle and Pedestrian
Master Plan to contribute to the
overall VMT reduction required to
meet the City’s climate goals. The
plan will maximize the convenience
and safety of active transportation
within the City of Dublin.

Consistent. The City is the responsible
party for this measure; however, the
project would be required to comply with
any associated standards or requirements.

The project includes connections to existing
bikeways and pedestrian pathways.

Additionally, the project includes MM AQ2.5 Vehicle Trip Reduction for both residential and non-residential uses, that
includes provisions regarding bicycle
facilities.

Measure SM-6:

Continue to
Prioritize Transit
Oriented
Development
Dublin has access to two BART
stations and several LAVTA bus
lines. Focusing higher density
development and amenities around
these transit stops can decrease
VMT and GHG emissions generated
within Dublin.

Not applicable. While the project is not
located within a TOD area, it is 1.5 miles
from the East Dublin / Pleasanton BART
station and will provide high density mixeduses near a transit stop.

Measure SM-7:

Develop a Built
Environment that
Prioritizes Active
Mobility
The City of Dublin will implement
building standards that improve the
pedestrian experience and create a
built environment that prioritizes
active mobility.

Consistent. The project includes various
multi-use paths and walkways that connect
the residents and retail patrons with
adjacent open space, surrounding
neighborhoods and nearby Emerald Glen
Park Additionally, the project includes
walkways and connections between
neighborhoods through the internal park
system. The project provides a variety of
open spaces for users.

Section 6.4: Strategy 4: Materials and Waste Management Measure MM-1:

Achieve the
Organic Waste
Reduction
Requirements of
SB 1383
The City of Dublin will coordinate
with community stakeholders to
achieve the goal of organics
comprising less than 9.35% of
Dublin waste by 2025. Additionally,
at least 20% of currently disposed
edible food will be recovered for
human consumption by 2025.

Consistent. The City is the responsible
party for this measure. The project would
be included in the City’s organics program
that includes curbside pickup of food waste
and yard waste for residential
neighborhoods.

Measure MM-2:

Reduce the
Embodied GHG
Emissions
Associated with
Building Materials
The City of Dublin will require the
use of low carbon concrete in new
construction projects to reduce
lifecycle GHG emissions and the
embodied carbon associated with
construction projects.

Consistent. The project would comply with
the City’s low carbon concrete
requirements as they are adopted.
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Control Measure Description Project Consistency
Section 6.5: Strategy 5: Municipal Leadership Measures
Measure ML-1:
100% Renewable
Electricity for
Municipal
Buildings and
Operations
The City of Dublin’s municipal
government will help achieve GHG
emission reduction goals related to
municipal electricity use by optingup all municipal accounts to 100% renewable electricity and
expanding the City’s battery
storage capacity.

Not applicable. There are no municipal
buildings associated with the proposed
project.

Measure ML-2:

Reduce Municipal
Employee
Commute GHG
Emissions
The City of Dublin’s municipal
government will achieve its GHG
emissions reduction and mobility
goals by incentivizing municipal
employee alternative
transportation use as well as
electric vehicle use.

Not applicable. The City is the responsible
party for this measure. The project would
not conflict with the City’s ability to enact
the measure.

Measure ML-3:

Electrify Municipal
Vehicle Fleet and
Equipment
The City of Dublin’s municipal
government will electrify at least
33% of its municipal vehicle fleet
and municipal maintenance
equipment by 2030.

Not applicable. The City is the responsible
party for this measure. The project would
not conflict with the City’s ability to enact
the measure.

Measure ML-4:

Total Cost of
Ownership and
Life-Cycle Analysis
of GHG Impacts in
Municipal Project
Request for
Proposals
The City of Dublin’s municipal
government will aim to ensure it is
constructing projects with the
lowest total cost of ownership and
lowest GHG emissions for new
construction projects through a
requirement that all capital
improvement projects include a
life-cycle cost analysis and lifecycle
GHG emissions analysis.

Not applicable. This is a municipal
measure. The project would not conflict
with the City’s ability to enact the measure.

Measure ML-5:

Promote Municipal
Awareness of
Sustainable Goods
and Services
The City of Dublin’s municipal
government will achieve its
materials and waste management
goals by promoting awareness to
City staff regarding the purchase of
sustainable goods and services.

Not applicable. This is a municipal
measure. The project would not conflict
with the City’s ability to enact the measure.

Measure ML-6:

Enhance Municipal
Carbon
Sequestration
Opportunities
The City of Dublin’s municipal
government will strive to increase
carbon sequestration activities
through tree planting and compost
application throughout the City.

Not applicable. This is a municipal
measure. The project would not conflict
with the City’s ability to enact the measure.

Measure ML-7:

Implement the
The City of Dublin’s municipal
government will work to achieve its
resilience goals through
implementation of the City of
Not applicable. This is a municipal
measure. The project would not conflict
with the City’s ability to enact the measure.
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Control Measure Description Project Consistency
Green Stormwater
Infrastructure Plan
Dublin Green Stormwater
Infrastructure Plan.

Source: City of Dublin Climate Action Plan 2030 and Beyond, 2020 and Kimley-Horn & Associates, 2022.

Consistency with the CARB Scoping Plan
The California State Legislature adopted AB 32 in 2006. AB 32 focuses on reducing GHGs (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) to 1990 levels by the year 2020. Pursuant to the requirements in AB 32, CARB adopted the Climate Change Scoping Plan (Scoping Plan) in 2008, which outlines actions recommended to obtain that goal. The Scoping Plan provides a range of GHG reduction actions that include direct regulations, alternative compliance mechanisms, monetary and nonmonetary incentives, voluntary actions, market- based mechanisms such as the cap-and-trade program, and an AB 32 implementation fee to fund the program.

The latest CARB Climate Change Scoping Plan (2017) outlines the state’s strategy to reduce state’s GHG emissions to return to 40 percent below 1990 levels by 2030 pursuant to SB 32.

The CARB Scoping Plan is mostly applicable to state agencies and is not directly applicable to cities/counties and individual projects. Nonetheless, the Scoping Plan has been the primary tool that is used to develop performance-based and efficiency-based CEQA criteria and GHG reduction targets for climate action planning efforts. CARB is developing an updated 2022 scoping plan that has not been adopted.

The 2017 Scoping Plan Update identifies additional GHG reduction measures necessary to achieve the 2030 target. These measures build upon those identified in the First Update to the Climate Change Scoping Plan (2013). Although a number of these measures are currently established as policies and measures, some measures have not yet been formally proposed or adopted. It is expected that these measures or similar actions to reduce GHG emissions would be adopted as required to achieve statewide GHG emissions targets. As shown in Table 10-5:

Project Consistency with Applicable CARB Scoping Plan Measures, the project is consistent with most of the strategies, while others are not applicable to the project.

Table 10-5: Project Consistency with Applicable CARB Scoping Plan Measures Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Transportation California Cap-andTrade Program
Linked to Western
Climate Initiative
Regulation for the
California Cap on
Greenhouse Gas
Emissions and
Market-Based
Compliance
Mechanism October
Not Applicable. The Cap-and-Trade Program applies
to large industrial sources such as power plants,
refineries, and cement manufacturers. However, the
regulation indirectly affects people who use the
products and services produced by these industrial
sources when increased cost of products or services
(such as electricity and fuel) are transferred to the
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Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
20, 2015 (CCR
95800)
consumers. The Cap-and-Trade Program covers the
GHG emissions associated with electricity consumed
in California, whether generated in-state or imported.

Accordingly, GHG emissions associated with CEQA
projects’ electricity usage are covered by the Cap-andTrade Program. The Cap-and-Trade Program also covers fuel suppliers (natural gas and propane fuel
providers and transportation fuel providers) to
address emissions from such fuels and from
combustion of other fossil fuels not directly covered at large sources in the Program’s first compliance period.

California Light-Duty
Vehicle Greenhouse
Gas Standards
Pavley I 2005
Regulations to
Control GHG
Emissions from
Motor Vehicles
Consistent. This measure applies to all new vehicles
starting with model year 2012. The project would not
conflict with its implementation as it would apply to
all new passenger vehicles purchased in California.

Passenger vehicles, model year 2012 and later,
associated with construction and operation of the
project would be required to comply with the Pavley
emissions standards.
2012 LEV III
Amendments to the
California
Greenhouse Gas and
Criteria Pollutant
Exhaust and
Evaporative
Emission Standards
Consistent. The LEV III amendments provide
reductions from new vehicles sold in California
between 2017 and 2025. Passenger vehicles
associated with the site would comply with LEV III
standards.

Low Carbon Fuel
Standard
2009 readopted in
2015. Regulations
to Achieve
Greenhouse Gas
Emission Reductions
Sub article 7. Low
Carbon Fuel
Standard CCR 95480
Consistent. This measure applies to transportation
fuels utilized by vehicles in California. The project
would not conflict with implementation of this
measure. Motor vehicles associated with construction
and operation of the project would utilize low carbon
transportation fuels as required under this measure.

Regional
TransportationRelated Greenhouse
Gas Targets.

SB 375. Cal. Public
Resources Code §§
21155, 21155.1,
21155.2, 21159.28
Consistent. The project would provide development
in the region that is consistent with the growth
projections in the Regional Transportation
Plan/Sustainable Communities Strategy (SCS) (Plan
Bay Area 2040).

Goods Movement Goods Movement
Action Plan January
2007
Not applicable. The project does not propose any
changes to maritime, rail, or intermodal facilities or
forms of transportation.

Medium/Heavy-Duty
Vehicle
2010 Amendments
to the Truck and Bus
Regulation, the
Consistent. This measure applies to medium and
heavy-duty vehicles that operate in the state. The
project would not conflict with implementation of this
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Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Drayage Truck
Regulation and the
Tractor-Trailer
Greenhouse Gas
Regulation
measure. Medium and heavy-duty vehicles associated
with construction and operation of the project would
be required to comply with the requirements of this
regulation.

High Speed Rail Funded under SB
862
Not applicable. This is a statewide measure that
cannot be implemented by a project applicant or Lead
Agency.

Electricity and
Natural Gas
Energy Efficiency Title 20 Appliance
Efficiency Regulation
Consistent. The project would not conflict with
implementation of this measure. The project would
comply with the latest energy efficiency standards. Title 24 Part 6 Energy Efficiency
Standards for
Residential and NonResidential Building
Title 24 Part 11
California Green
Building Code
Standards
Renewable Portfolio
Standard/Renewable
Electricity Standard.
2010 Regulation to
Implement the
Renewable
Electricity Standard
(33% 2020)
Consistent. The project would provide the option to
home buyers to include photovoltaic solar systems.

Photovoltaic systems would be installed on the
rooftops of commercial buildings. All structures that
do not include solar PV panels will be “solar ready,” as required by City Municipal Code sections 7.94.060 and

7.94.070. The project would obtain electricity from
the electric utility PG&E. PG&E obtained 33 percent of
its power supply from renewable sources in 2016.

Therefore, the utility would provide power when
needed on site that is composed of a greater
percentage of renewable sources.

SB 350 Clean Energy
and Pollution
Reduction Act of
2015 (50% 2030)
Million Solar Roofs
Program
Tax incentive
program
Consistent. This measure is to increase solar
throughout California, which is being done by various
electricity providers and existing solar programs.

Homeowners within the project would be able to take
advantage of incentives that are in place at the time of construction.

Water Water Title 24 Part 11
California Green
Building Code
Standards
Consistent. The project would comply with the
California Green Building Standards Code, which
requires a 20 percent reduction in indoor water use.

The project would also comply with the City’s WaterEfficient Landscaping Regulations (Chapter 8.88 of the Dublin Municipal Code). SBX 7-7—The Water
Conservation Act of
2009
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Scoping Plan
Sector
Scoping Plan
Measure
Implementing
Regulations Project Consistency
Model Water
Efficient Landscape
Ordinance
Green
Buildings
Green Building
Strategy
Title 24 Part 11
California Green
Building Code
Standards
Consistent. The State is to increase the use of green
building practices. The project would implement
required green building strategies through existing
regulation that requires the project to comply with
various CalGreen requirements. The project would
include sustainability design features that support the Green Building Strategy.

Industry Industrial Emissions 2010 CARB
Mandatory
Reporting
Regulation
Not applicable. The project does not include
industrial land uses.

Recycling and
Waste
Management
Recycling and Waste Title 24 Part 11
California Green
Building Code
Standards
Consistent. The project would not conflict with
implementation of these measures. The project is
required to achieve the recycling mandates via
compliance with the CALGreen code. The City has
consistently achieved its state recycling mandates. AB 341 Statewide 75 Percent Diversion
Goal
SB 1383 Mandatory
Organics Diversion
Forests Sustainable Forests Cap and Trade
Offset Projects
Not applicable. The project site is in an area
designated for urban uses. No forested lands exist onsite.

High Global
Warming
Potential
High Global
Warming Potential
Gases
CARB Refrigerant
Management
Program CCR 95380
Not applicable. The regulations are applicable to
refrigerants used by large air conditioning systems and large commercial and industrial refrigerators and cold
storage system. The project is not expected to use
large systems subject to the refrigerant management
regulations adopted by CARB.

Agriculture Agriculture Cap and Trade
Offset Projects for
Livestock and Rice
Cultivation
Not applicable. The project site is designated for
urban development. No grazing, feedlot, or other
agricultural activities that generate manure occur
currently exist on-site or are proposed to be
implemented by the project.

Source: California Air Resources Board (CARB), California’s 2017 Climate Change Scoping Plan, November 2017 and CARB, Climate Change Scoping Plan, December 2008.

As discussed above, the Scoping Plan reflects the 2030 target of a 40 percent reduction below 1990 levels, set by Executive Order B-30-15 and codified by SB 32. 1095
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Appendix B, Local Action, of the 2017 CARB Scoping Plan lists potential actions that support the State’s climate goals. However, the Scoping Plan notes that the applicability and performance of the actions may vary across the regions. The document is organized into two categories (A) examples of plan-level GHG reduction actions that could be implemented by local governments and (B) examples of on-site project design features, mitigation measures, that could be required of individual projects under CEQA, if feasible, when the local jurisdiction is the lead agency. Many of these on-site project design features are included in the CAP.

The project would implement several Mitigation Measures included in the Air Quality Assessment during construction that would help reduce construction-related GHG emissions.

For example, a few of the construction measures include enforcing idling time restrictions on construction vehicles, use of added exhaust muffling and filtering devices, replant vegetation in disturbed areas as quickly as possible, and posting a publicly visible sign with the telephone number and person at the lead agency to contact regarding dust complaints. As indicated above, GHG reductions are also achieved as a result of State of California energy and water efficiency requirements for new non-residential developments. These efficiency improvements correspond to reductions in secondary GHG emissions. Therefore, energy saving measures, such as Title 24, reduces GHG emissions from the power generation facilities by reducing load demand.

The project would be required to comply with existing regulations, including applicable measures from the City’s General Plan and CAP 2030, or would be directly affected by the outcomes (vehicle trips and energy consumption would be less carbon intensive due to statewide compliance with future low carbon fuel standard amendments and increasingly stringent Renewable Portfolio Standards). As such, the project would not conflict with any other state-level regulations pertaining to GHGs.

Regarding goals for 2050 under Executive Order S-3-05, at this time it is not possible to quantify the emissions savings from future regulatory measures, as they have not yet been developed; nevertheless, it can be anticipated that operation of the project would benefit from implementation of current and potential future regulations (e.g., improvements in vehicle emissions, SB 100/renewable electricity portfolio improvements, etc.) enacted to meet an 80 percent reduction below 1990 levels by 2050. The CAP 2030 shows a path towards carbon neutrality by 2045.

Therefore, based on the above analysis, project related GHG emissions would not result in a cumulatively considerable contribution to the significant cumulative impact of climate change.

Consistency with Plan Bay Area
The project would be consistent with the overall goals of the Metropolitan Transportation Commission’s Plan Bay Area 2040 Regional Transportation Plan/Sustainable Communities Strategy in concentrating new development in locations where there is existing infrastructure as the project would develop the project site to provide a mix of land uses. The project is located approximately 1.5 miles of the Dublin/Pleasanton BART station, adjacent to I-580, other 1096
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major arterials, and bicycle lanes. The project includes various multi-use paths and walkways that connect the residents and retail patrons with adjacent open space, surrounding neighborhoods and nearby Emerald Glen Park. The project would provide housing and mixed uses on an infill location near transit. These project design features are consistent with the GHG reduction planning efforts and housing performance targets outlined in Plan Bay Area 2040. Therefore, the project would not conflict with the land use concept plan in Plan Bay Area 2040 and impacts would be less than significant.

10.5.5 Level of Significance After Mitigation
Table 10-6: Summary of Impacts and Mitigation Measures – Greenhouse Gas Emissions summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to greenhouse gas emissions.

Table 10-6: Summary of Impacts and Mitigation Measures – Greenhouse Gas Emissions Impact Impact Significance Mitigation
Impact GHG-1: Would the project
generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment or conflict with an
applicable plan, policy, or regulation
adopted for the purpose of reducing
the emissions of greenhouse gases
(Class III).

Less than Significant

10.6 References
Bay Area Air Quality Management District, 2017 CEQA Air Quality Guidelines, 2017.

Bay Area Air Quality Management District, Final 2017 Clean Air Plan, 2017.

Bay Area Air Quality Management District, Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, 2022.

California Air Pollution Control Officers Association, CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, 2008.

California Air Pollution Control Officers Association (CAPCOA). 2016. CalEEMod User’s Guide.

California Air Resources Board, Climate Change Proposed Scoping Plan. 2008.

California Air Resources Board, Greenhouse Gas for 2000-2019 — Trends of Emissions and Other Indicators, July 2021.
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California Air Resources Board, California Greenhouse Gas Inventory for 2000-2010 — by Category Defined in the Scoping Plan, 2013.

California Air Resources Board, California’s 2017 Climate Change Scoping Plan, 2017.

City of Dublin. Climate Action Plan2030 And Beyond, 2020.

Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: Synthesis Report, the Fourth IPCC Assessment Report. Available at: http://www.ipccnggip.iges.or.jp/public/index.html Intergovernmental Panel on Climate Change (IPCC). 2014. Climate Change 2014: Synthesis Report, the Fifth IPCC Assessment Report. Available at:
https://www.ipcc.ch/report/ar5/
US EPA. April 2018. Overview of Greenhouse Gases. Available at:
https://www.epa.gov/ghgemissions/overview-greenhouse-gases US EPA. April 2018. Inventory of U.S. Greenhouse Gas Emissions and Sinks. Available at:
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks1990-2016 1098
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11 Hazards & Hazardous Materials

11.1 Introduction
This section describes effects of hazards and hazardous materials that would result from implementation of the project. Information used to prepare this section came from the following resources:
 ENGEO Incorporated, Phase I Environmental Site Assessment, 2018 (see Appendix E)  City of Dublin, General Plan, 1985, as amended 2022
 City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022

11.2 Scoping Issues Addressed
During the public comment scoping period for the project, comments requesting analysis of the potential for hazards release, aerially deposited lead, sampling of backfill material, pesticides, and hazards in general were received.

11.3 Environmental Setting
This section presents information on the potential for hazardous conditions on the project site.

11.3.1 Hazardous Materials
Hazardous materials, as defined by the California Code of Regulations, are substances with certain physical properties that could pose a substantial present or future hazard to human health or the environment when handled, disposed, or otherwise managed improperly.

Hazardous materials are grouped into the following four categories, based on their properties:
 Toxic – causes human health effects
 Ignitable – has the ability to burn
 Corrosive – causes severe burns or damage to materials  Reactive – causes explosions or generates toxic gases Hazardous waste is any hazardous material that is discarded, abandoned, or slated to be recycled. The criteria that define a material as hazardous also define a waste as hazardous. If handled, disposed, or otherwise handled improperly, hazardous materials and hazardous waste can result in public health hazards if released into the soil or groundwater or through airborne releases in vapors, fumes, or dust. Soil and groundwater having concentrations of hazardous material constituents higher than specific regulatory levels must be handled and disposed of as hazardous waste when excavated or pumped from an aquifer. The California Code of Regulations, Title 22, Sections 66261.20-24 contain technical descriptions of toxic characteristics that could cause soil or groundwater to be classified as hazardous waste. 1099
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11.3.2 Phase I Environmental Site Assessment
A Phase I ESA was prepared by ENGEO in January 2018 to determine the presence or absence of hazardous materials on the project site. This assessment included a review of local, state, tribal, and federal environmental record sources, standard historical sources, aerial photographs, fire insurance maps and physical setting sources. A reconnaissance of the property was conducted to review site use and current conditions to check for the storage, use, production or disposal of hazardous or potentially hazardous materials and interviews with persons knowledgeable about current and past site use. The findings are summarized as follows.

Existing Conditions
The Phase I ESA identified 11 Federal USGS wells located within one mile of the project site.

The closed well, Well Number 1, is located less than one-half-mile east-southeast of the property, and 20 groundwater level measurements were observed, which ranged between 34.9 feet and 36.9 feet below the ground.

No Recognized Environmental Conditions (RECs), historical RECs, nor controlled RECs were identified on the property. However, ENGEO identified the following conditions that could pose an environmental concern:
 One five-gallon bucket containing petroleum hydrocarbon material and one five-gallon bucket containing petroleum hydrocarbon spilt material (middle parcel APN 985-52-24).  Approximately nine drums in poor condition (middle parcel APN 985-52-24).  Minor stained soil with odors (middle parcel APN 985-52-24).  Minor stressed vegetation under abandoned tractors (middle parcel APN 985-52-24).  Solid waste debris (middle parcel AP: 985-52-24 and southern parcel APN 985-51-5).  Abandoned Zone 7 water supply well (middle parcel APN 985-52-24).

Records Search
Environmental Data Resources, Inc. (EDR) performed a search of federal, State, and local databases listing contaminated sites, brownfield sites (a development site having the presence or potential presence of hazardous substance, pollutant, or contaminate), underground storage tank sites, waste storage sites, toxic chemical sites, contaminated well sites, clandestine drug lab sites, and other sites containing hazardous materials. The project site and adjacent sites were not listed on any databases.

Topographic Maps and Aerial Photographs
ENGEO reviewed historical USGS topographic maps and aerial photographs provided by EDR of the project site dating back to 1906. In the 1906 map, no structures were identified. Structures do appear in 1953 and disappear by 1998.
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In the aerial photographs the project site was vacant or used as agricultural land in 1939 and four structures appear on the site in 1949. The site appears to have historically been used as agricultural row crops based on 1966 and 1968 aerial photographs.

Hazardous Building Materials
The Phase I ESA concluded that asbestos-containing materials and lead-based paint were not a concern because of the absence of buildings on the project site.

11.3.3 Livermore Municipal Airport
The Livermore Municipal Airport is located in the western portion of Livermore, immediately south of I-580, and approximately two miles from the project site. The airport is owned and operated by the City of Livermore.

The Livermore Executive Airport Land Use Compatibility Plan (ALUCP) indicates that 600 aircraft were based at the airport in 2008, with that number projected to increase to 900 by 2030. The airport averaged 394 operations per day in 2014 (143,810 operations annually).

Most of the project site, excluding the most northerly portion, is located with the Airport Influence Area (AIA)/Overlay Zoning District. This area is designated as an area in which current or future airport-related noise, overflight, safety and/or airspace protection factors may affect land uses or necessitate restrictions on those uses. The AIA is a designation in the ALUCP by the Alameda County Airport Land Use Commission.

As shown in Figure 11-1: Livermore Municipal Airport Safety Compatibility Zones, the same portion of the project site is also located within Land Use Compatibility Zone 7 (Area of Influence) of the Livermore Municipal Airport, as established in the ALUCP.

11.4 Applicable Regulations, Plans, and Standards
The management of hazardous materials and hazardous wastes is regulated at federal, State, and local levels, including, among others, through programs administered by the U.S.

Environmental Protection Agency (U.S. EPA); agencies within the California Environmental Protection Agency (CalEPA), such as the Department of Toxic Substances Control (DTSC); federal and state occupational safety agencies; and the Alameda County Department of Environmental Health. Regulations pertaining to flood hazards are discussed in Chapter 12:

Hydrology & Water Quality, and regulations for geologic and soil-related hazards are discussed in Chapter 9: Geology and Soils.

11.4.1 Federal
Toxic Substances Control Act/Resource Conservation and Recovery Act/Hazardous and Solid Waste Act
The federal Toxic Substances Control Act of 1976 and Resource Conservation and Recovery Act (RCRA) established a program administered by the U.S. EPA for the regulation of the 1101
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generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA was amended in 1984 by the Hazardous and Solid Waste Act (HSWA), which affirmed and extended the “cradle to grave” system of regulating hazardous wastes.

Comprehensive Environmental Response, Compensation, and Liability Act/Superfund Amendments and Reauthorization Act
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund, was enacted by Congress on December 11, 1980. This law (U.S. Code Title 42, Chapter 103) provides broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA establishes requirements concerning closed and abandoned hazardous waste sites; provides for liability of persons responsible for releases of hazardous waste at these sites; and establishes a trust fund to provide for cleanup when no responsible party can be identified. CERCLA also enables the revision of the National Contingency Plan (NCP). The NCP (Title 40, Code of Federal Regulation [CFR], Part 300) provides the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, and/or contaminants. The NCP also established the National Priorities List. CERCLA was amended by the Superfund Amendments and Reauthorization Act on October 17, 1986.

Clean Water Act/SPCC Rule
The Clean Water Act (CWA) (33 U.S.C. Section 1251 et seq., formerly the Federal Water Pollution Control Act of 1972), was enacted with the intent of restoring and maintaining the chemical, physical, and biological integrity of the waters of the United States. The CWA requires states to set standards to protect, maintain, and restore water quality through the regulation of point source and certain non‐point source discharges to surface water. Those discharges are regulated by the National Pollutant Discharge Elimination System (NPDES) permit process (CWA Section 402). In California, NPDES permitting authority is delegated to, and administered by, the nine Regional Water Quality Control Boards (RWQCBs). The project is within the jurisdiction of the San Francisco RWQCB.

Section 402 of the Clean Water Act authorizes the California State Water Resources Control Board to issue NPDES General Construction Storm Water Permit (Water Quality Order 99‐08‐ DWQ), referred to as the “General Construction Permit.” Construction activities can comply with and be covered under the General Construction Permit provided that they:
 Develop and implement a Storm Water Pollution Prevention Plan (SWPPP) which specifies Best Management Practices (BMPs) that will prevent all construction pollutants from contacting stormwater and with the intent of keeping all products of erosion from moving off‐site into receiving waters;
 Eliminate or reduce non‐stormwater discharges to storm sewer systems and other waters of the nation; and
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 Perform inspections of all BMPs.

NPDES regulations are administered by the RWQCB. Projects that disturb one or more acres are required to obtain NPDES coverage under the Construction General Permits.

As part of the CWA, U.S. EPA oversees and enforces the Oil Pollution Prevention regulation contained in Title 40 of the CFR, Part 112 (Title 40 CFR, Part 112) which is often referred to as the “SPCC rule” because the regulations describe the requirements for facilities to prepare, amend and implement Spill Prevention and Countermeasures (SPCC) Plans. A facility is subject to SPCC regulations if a single oil (or gasoline, or diesel fuel) storage tank has a capacity greater than 660 gallons, the total above ground oil storage capacity exceeds 1,320 gallons, or the underground oil storage capacity exceeds 42,000 gallons, and if, due to its location, the facility could reasonably be expected to discharge oil into or upon the “Navigable Waters” of the United States.

Occupational Safety and Health Administration
Occupational Safety and Heather Administration’s (OSHA) mission is to ensure the safety and health of America's workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health. OSHA staff establishes and enforces protective standards and reaches out to employers and employees through technical assistance and consultation programs. OSHA standards are listed in Title 29 CFR Part 1910.

OSHA’s Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. This includes any employees who are exposed or potentially exposed to hazardous substances — including hazardous waste — and who are engaged in one of the following operations:
 Clean‐up operations — required by a governmental body, whether federal, State, local, or other involving hazardous substances — that are conducted at uncontrolled hazardous waste sites;
 Corrective actions involving clean‐up operations at sites covered by RCRA as amended (42 U.S.C. 6901 et seq.);
 Voluntary clean‐up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;  Operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. EPA to implement RCRA regulations; and
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 Emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

11.4.2 State
Hazardous Materials Release Response Plans and Inventory Act of 1985 The California Health and Safety Code, Division 20, Chapter 6.95, known as the Hazardous Materials Release Response Plans and Inventory Act or the Business Plan Act, requires businesses using hazardous materials to prepare a plan that describes their facilities, inventories, emergency response plans, and training programs. Businesses must submit this information to the County Environmental Health Division. The Environmental Health Division verifies the information and provides it to agencies responsible for protection of public health and safety and the environment. Business Plans are required to include emergency response plans and procedures in the event of a reportable release or threatened release of a hazardous material, including, but not limited to, all of the following:
 Immediate notification to the administering agency and to the appropriate local emergency rescue personnel.
 Procedures for the mitigation of a release or threatened release to minimize any potential harm or damage to persons, property, or the environment.  Evacuation plans and procedures, including immediate notice, for the business site.  Business Plans are also required to include training for all new employees, and annual training, including refresher courses, for all employees in safety procedures in the event of a release or threatened release of a hazardous material.

Hazardous Waste Control Act
The Hazardous Waste Control Act created the State hazardous waste management program, which is similar to but more stringent than the federal RCRA program. The act is implemented by regulations contained in Title 26 of the CCR, which describes the following required aspects for the proper management of hazardous waste: identification and classification; generation and transportation; design and permitting of recycling, treatment, storage, and disposal facilities; treatment standards; operation of facilities and staff training; and closure of facilities and liability requirements. These regulations list more than 800 materials that may be hazardous and establish criteria for identifying, packaging, and disposing of such waste. Under the Hazardous Waste Control Act and Title 26, the generator of hazardous waste must complete a manifest that accompanies the waste from generator to transporter to the ultimate disposal location. Copies of the manifest must be filed with the DTSC. 1104
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Unified Hazardous Waste and Hazardous Materials Management Regulatory Program The Unified Hazardous Waste and Hazardous Materials Management Regulatory Program (Unified Program) required the administrative consolidation of six hazardous materials and waste programs (Program Elements) under one agency, a Certified Unified Program Agency (CUPA). The Program Elements consolidated under the Unified Program are Hazardous Waste Generator and On‐site Hazardous Waste Treatment Programs (a.k.a. Tiered Permitting); Aboveground Petroleum Storage Tank SPCC; Hazardous Materials Release Response Plans and Inventory Program (a.k.a. Hazardous Materials Disclosure or “Community‐Right‐To‐Know”); California Accidental Release Prevention Program (Cal ARP); Underground Storage Tank (UST) Program; and Uniform Fire Code Plans and Inventory Requirements.

The Unified Program is intended to provide relief to businesses complying with the overlapping and sometimes conflicting requirements of formerly independently managed programs. The Unified Program is implemented at the local government level by CUPAs. Most CUPAs have been established as a function of a local environmental health or fire department. Some CUPAs have contractual agreements with another local agency, a participating agency, which implements one or more Program Elements in coordination with the CUPA.

Department of Toxic Substance Control
Department of Toxic Substance Control (DTSC) is a department of Cal EPA and is the primary agency in California that regulates hazardous waste, cleans up existing contamination, and looks for ways to reduce the hazardous waste produced in California. DTSC regulates hazardous waste in California primarily under the authority of the federal RCRA and the California Health and Safety Code (primarily Division 20, Chapters 6.5 through 10.6, and Title 22, Division 4.5). Other laws that affect hazardous waste are specific to handling, storage, transportation, disposal, treatment, reduction, cleanup, and emergency planning. Government Code §65962.5 (commonly referred to as the Cortese List) includes DTSC-listed hazardous waste facilities and sites, Department of Health Services (DHS) lists of contaminated drinking water wells, sites listed by the California Water Resources Control Board as having UST leaks and have had a discharge of hazardous wastes or materials into the water or groundwater and lists from local regulatory agencies of sites that have had a known migration of hazardous waste/material.

California Office of Emergency Services
To protect the public health and safety and the environment, the California Office of Emergency Services (OES) is responsible for establishing and managing statewide standards for business and area plans relating to the handling and release or threatened release of hazardous materials. Basic information on hazardous materials handled, used, stored, or disposed of (including location, type, quantity, and the health risks) needs to be available to firefighters, public safety officers, and regulatory agencies. The information must be included in these institutions’ business plans to prevent or mitigate the damage to the health and safety of persons and the environment from the release or threatened release of these materials into the workplace and environment.
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These regulations are covered under Chapter 6.95 of the California Health and Safety Code Article 1– Hazardous Materials Release Response and Inventory Program (Sections 25500 to 25520) and Article 2– Hazardous Materials Management (Sections 25531 to 25543.3). CCR Title 19, Public Safety, Division 2, Office of Emergency Services, Chapter 4–Hazardous Material Release Reporting, Inventory, and Response Plans, Article 4 (Minimum Standards for Business Plans) establishes minimum statewide standards for Hazardous Materials Business Plans (HMBP).

These plans shall include the following: (1) a hazardous material inventory in accordance with Sections 2729.2 to 2729.7; (2) emergency response plans and procedures in accordance with Section 2731; and (3) training program information in accordance with Section 2732. Business plans contain basic information on the location, type, quantity, and health risks of hazardous materials stored, used, or disposed of in the State. Each business shall prepare a HMBP if that business uses, handles, or stores a hazardous material or an extremely hazardous material in quantities greater than or equal to the following: 500 pounds of a solid substance, 55 gallons of a liquid, 200 cubic feet of compressed gas, a hazardous compressed gas in any amount, or hazardous waste in any quantity.

California Occupational Safety and Health Administration The California Occupational Safety and Health Administration (Cal/OSHA) is the primary agency responsible for worker safety in the handling and use of chemicals in the workplace. Cal/OSHA standards are generally more stringent than federal regulations. The employer is required to monitor worker exposure to listed hazardous substances and notify workers of exposure (8 CCR Sections 337‐340). The regulations specify requirements for employee training, availability of safety equipment, accident‐prevention programs, and hazardous substance exposure warnings.

11.4.3 Local
City of Dublin General Plan
The City of Dublin General Plan contains the following policies associated with hazards and hazardous materials that are relevant to the project:

Guiding Policy 8.3.4.A.1: Maintain and enhance the ability to regulate the use, transport, and storage of hazardous materials and to quickly identify substances and take appropriate action during emergencies.

Guiding Policy 8.3.4.A.2: Minimize the risk of exposure to hazardous materials from contaminated sites.

Implementing Policy 8.3.4.B.2: As part of the City’s Comprehensive Emergency Response Plan, the City has adopted a Hazardous Materials Response Plan. The City will periodically review the Plan to prepare for and respond to emergencies related to hazardous materials. 1106
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Implementing Policy 8.3.4.B.3: Periodically review and enforce the City’s ordinances regulating the handling, transport, and storage of hazardous materials and hazardous waste.

Implementing Policy 8.3.4.B.4: Require site-specific hazardous materials studies for new development projects where there is a potential for the presence of hazardous materials from previous uses on the site. If hazardous materials are found, require the clean-up of sites to acceptable regulatory standards prior to development.

Guiding Policy 8.4.1.A.1: All proposed land uses within the Airport Influence Area (AIA) shall be reviewed for consistency with the safety compatibility policies and airspace protection policies of the Airport Land Use Compatibility Plan (ALUCP) for the Livermore Municipal Airport.

Implementing Policy 8.4.1.B.1: Adopt an Airport Overlay Zoning District to ensure that all proposed development within the Airport Influence Area (AIA) is reviewed for consistency with all applicable Livermore Municipal Airport, Airport Land Use Compatibility Plan (ALUCP) policies.

Eastern Dublin Specific Plan
The City of Dublin’s Eastern Dublin Specific Plan contains the following policy associated with hazards and hazardous materials that are relevant to the project:

Policy 11-1 Prior to issuance of building permits for site-specific Phase I (and if necessary Phase II) environmental site assessments shall be made available to the Community Development Director, with appropriate documentation that all recommended remediation actions have been completed.

Alameda County – Livermore Executive Airport Land Use Compatibility Plan The Livermore Executive Airport Land Use Compatibility Plan (ALUCP) governs land use around Livermore Municipal Airport. The ALUCP was adopted by the Alameda County Airport Land Use Commission (ALUC) in 2012.

The ALUCP should act as a guide for the ALUC and local jurisdictions in safeguarding the general welfare of the public. The ALUCP establishes that the following “specific characteristics” are to be avoided: (1) glare or distracting lights that could be mistaken for airport lights; (2) sources dust, heat, steam, or smoke that may impair pilot vision; (3) sources of steam or other emissions that may cause thermal plumes or other forms of unstable air that generate turbulence within the flight path; (4) sources of electrical interferences with aircraft communications or navigation; or (5) features that create an increased attraction for wildlife including landfills or agricultural and recreational uses that attract large flocks of birds. 1107
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11.5 Environmental Impacts and Mitigation Measures

11.5.1 Significance Criteria
The following significance criteria for hazards & hazardous materials were derived from the Environmental Checklist in CEQA Guidelines Appendix G. An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria.
 Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
 Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
 Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.  Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, create a significant hazard to the public or the environment.
 For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, result in a safety hazard or excessive noise for people residing or working in the project area.  Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
 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.

Significance Classifications
The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required. 1108
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No Impact.

11.5.2 Summary of No and/or Beneficial Impacts
Hazards within 0.25 Mile of a School
The nearest public school to the project site is Eleanor Murray Fallon Middle School, located .25 miles north of the project site. Kolb Elementary School is located 0.5 miles east of the project site. Emerald High School located at 3600 Central Parkway is currently under construction and Phase 1 is scheduled to be completed in early 2024. Located .25 miles east, it will be the nearest school to the project site. The project does not propose any industrial uses and the proposed residential and commercial uses would utilize commercially common chemicals (e.g. cleaning supplies) that are readily prevalent at schools and the surrounding community.

Therefore, the project would not affect an existing or proposed school within the designated rate of one-quarter mile and this threshold is not evaluated further.

Listed Hazardous Material Site
The project site is also not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5; therefore, this threshold is not evaluated further.

Emergency Response Plan
The project site is not located within the area of or within the direct vicinity of an emergency response plan. Therefore, this threshold is not further evaluated.

Wildland Fire
The project site is not located adjacent to wildlands that would put the property at risk for fires.

Therefore, this threshold is not further evaluated.

11.5.3 Impacts of the Proposed Project
Impact HAZ-1: Exposure to known hazardous contaminants (Class II).

The project site is currently undeveloped and has not supported urban development in the past. Although the Phase I ESA concluded there were no Recognized Environmental Conditions (RECs) or historical RECs on the site, the following deleterious materials were observed:
 One 5-gallon bucket of petroleum hydrocarbon containing material and one 5-gallon bucket of petroleum hydrocarbon containing spilt material (middle parcel APN 985-52- 24).
 Approximately nine drums in poor condition (middle parcel APN 985-52-24).  Minor stained soil with odors (middle parcel APN 985-52-24).  Minor stressed vegetation under abandoned tractors (middle parcel APN 985-52-24).  Solid waste debris (middle parcel AP: 985-52-24 and southern parcel APN 985-51-5). 1109
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 Abandoned Zone 7 water supply well (middle parcel APN 985-52-24).

Based on the land uses being proposed, the disturbance of these deleterious materials could result in the exposure of hazardous contaminants into the environment. This is considered a potentially significant impact. Implementation of MM HAZ-1.1: Disposal of Deleterious Materials would reduce this impact to less than significant.

Mitigation for Impact HAZ-1
MM HAZ-1.1 Disposal of Deleterious Materials.

Prior to any ground disturbance on the middle parcel (APN 985-52-24), the project applicant shall retain a qualified hazardous materials contractor to properly dispose of the observed deleterious materials, and any others discovered during remediation. Additionally, the applicant shall close the abandoned Zone 7 water supply well in accordance with applicable regulatory agency requirements.

Impact HAZ-2: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials, or through reasonably foreseeable upset and accident conditions. (Class III).

Project construction activities may involve the use, transport, and disposal of hazardous materials. These materials may include chemicals such as gasoline, diesel fuel, lubricating oil, hydraulic oil, lubricating grease, automatic transmission fluid, paints, solvents, glues, and other substances used during construction. Construction of the project would also require the use of gasoline and diesel‐powered heavy equipment, such as bulldozers, backhoes, water pumps, and air compressors. Transportation, storage, use, and disposal of hazardous materials during construction activities would be required to comply with applicable federal, State, and local statutes and regulations regarding the transport, storage, and use of hazardous materials.

Compliance with these statutes and regulations would ensure that human health and the environment are not exposed to hazardous materials.

The project would develop a mixed-use of commercial and residential uses on the project site.

The project’s end uses would not involve the routine use of large quantities of hazardous materials. Small quantities of hazardous materials would be used as part of daily operations, including cleaning solvents (e.g., degreasers, diesel, paint thinners, and aerosol propellants), paints, disinfectants, and fertilizers. These substances would be stored in secure areas and would be required to comply with all applicable regulatory requirements.

If future commercial users propose to use, handle, or store hazardous materials or waste in quantities that are regulated by the Alameda County Department of Environmental Health, they would be required to submit a Hazardous Materials Business Plan documenting basic information on the location, type, quality, and health risks of hazardous materials and/or 1110
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waste. Transport of these materials would be performed by commercial vendors who would be required to comply with applicable federal and state regulations.

For the residential portion of the project, there would be a less than significant impact to the transport, use or disposal of hazardous materials, since residential development does not use, store or transport significant quantities of hazardous materials. To the extent there are potentially hazardous materials used in construction, the impacts would be less than significant due to compliance with regulatory requirements, and no mitigation would be required.

Impact HAZ-3: Create aviation hazards for persons residing or working in the project area (Class III).

Most of the project site is located with the Airport Influence Area (AIA)/Overlay Zoning District.

This area is designated as an area in which current or future airport-related noise, overflight, safety and/or airspace protection factors may affect land uses or necessitate restrictions on those uses.

The ALUP establishes that the following “specific characteristics” are to be avoided in the AIA:
1) Glare or distracting lights that could be mistaken for airport lights; 2) Sources of dust, heat, steam, or smoke that may impair pilot vision; 3) Sources of steam or other emissions that may cause thermal plumes or other forms of unstable air that generate turbulence within the flight path; 4) Sources of electrical interferences with aircraft communications or navigation; or 5) Features that create an increased attraction for wildlife including landfills or agricultural and recreational uses that attract large flocks of birds.

The project does not: 1) Propose any exterior lights that could be mistaken for airport lights; 2) Propose any uses or activities that emit substantial amounts of dust, heat, steam, or smoke; 3) Propose any uses or activities that would generate electrical interference; or 4) Have features that could attract large flocks of birds (e.g., a pond). Therefore, the project would be compatible with the flight hazards policies of the Airport Land Use Compatibility Plan and impacts would be less than significant.

Existing airport noise is addressed in Chapter 14: Noise and Vibration. The project’s location relative to the AIA would not result in significant noise exposure to future residents, businesses or employees.

11.5.4 Cumulative Impact Analysis
The geographical area for the analysis of cumulative impacts involving risks associated with hazards and hazardous materials is the is the project site and adjacent properties. 1111
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Impact HAZ‐4: Contribute to cumulatively considerable impacts to hazards and hazardous materials (Class II).

Most hazards and hazardous materials impacts from development are site-specific and if properly designed would not result in additive worsening of the environmental or public health and safety. Cumulative development would be subject to site-specific hazards and/or hazardous materials constraints; pursuant to the City of Dublin’s building requirements.

Nevertheless, development of past, present and reasonably foreseeable future developments could cumulatively increase the potential for exposure of people throughout the City of Dublin to existing soil contamination from ground disturbance during construction; hazards associated with the use, transport, or disposal of hazardous materials for any industrial projects; wildland fire hazards from development in a Fire Hazard Severity Zone; and compliance with the Alameda County Emergency Response and/or Evacuation Plans because of the addition of residents and employees in areas without adequate emergency access. Therefore, an overall increase in the potential for exposure to hazards, hazardous materials, and wildland fires could occur as development occurs. The project’s potential contribution to this cumulative increase would be less than significant based on the primary site-specific nature of potential impacts, compliance with regulatory requirements, and implementation of MM HAZ- 1.1: Disposal of Deleterious Materials.

11.5.5 Level of Significance after Mitigation
Table 11-1: Summary of Impacts and Mitigation Measures – Hazards & Hazardous Materials summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to hazards and hazardous materials. 1112
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Table 11-1: Summary of Impacts and Mitigation Measures – Hazards & Hazardous Materials Impact
Impact
Significance Mitigation
Impact HAZ-1: Exposure to known
hazardous contaminants (Class II).

Less than
Significant
with
Mitigation
MM HAZ- 1.1: Disposal of Deleterious Materials.

Impact HAZ-2: Create a significant
hazard to the public or the
environment through the routine
transport, use, or disposal of
hazardous materials, or through
reasonably foreseeable upset and
accident conditions. (Class III).

Less than
Significant
None required.

Impact HAZ-3: Create aviation
hazards for persons residing or
working in the project area (Class III)
Less than
Significant
None required.

Impact HAZ‐4: Contribute to
cumulatively considerable impacts
to hazards and hazardous materials
(Class II).

Less than
Significant
with
Mitigation
MM HAZ- 1.1: Disposal of Deleterious Materials.

11.6 References
CAL FIRE (California Department of Forestry and Fire Protection). 2008. Very High Fire Hazard Severity Zones in LRA in Alameda County. Available at
https://osfm.fire.ca.gov/divisions/community-wildfire-preparedness-andmitigation/wildland-hazards-building-codes/fire-hazard-severity-zones-maps/. Accessed April 4, 2022.

City of Dublin. Eastern Dublin Specific Plan 1994, updated 2022.

County of Alameda. Livermore Executive Airport Land Use Compatibility Plan, 2012. 1113
6,000’ 5,500’
6,800’
4,000’
2,700’
500’ 1,200’
750’
1,000’
1,425’
1,000’
7L
7R 25L
25R
1,750’
1,500’
1,000’
1,000’
3,500’
2,000’
1,900’
2,000’
6,800’
3,800’ 3,800’
3,000’
3,000’
3,500’
7R & 25L RPZ Dimensions
Length = 1,000’/
W1 = 250’/W2 = 450’
580
84 84
Stanley Blvd
1st St
El Charro Rd
Santa Rita Rd
N Livermore Ave
Portola Ave
Holmes St
Tassajara Rd
College Ave
S L St
Valley Ave
Arroyo Rd
Owens Dr
Main St
Las Positas Rd
Hacienda Dr
S Livermore Ave
East Ave
W Las Positas Blvd
Hopyard Rd
Vineyard Ave
Bernal Ave
1st St
Vineyard Ave
Murrieta Blvd
Arroyo Mocho
Arroyo Mocho
Arroyo del Valle
Tassajara Creek Tassajara Creek
Cayetano Creek Cayetano Creek
Arroyo del Valle

EAST COUNTY

PLANNING AREA

EAST COUNTY

PLANNING AREA
DUBLIN

PLEASANTON

LIVERMORE
Primary Surface
Zone 1: Runway Protection Zone
Zone 2: Inner Approach/Departure Zone
Zone 3: Inner Turning Zone
Zone 4: Outer Approach/Departure Zone
Zone 5: Sideline Safety Zone
Zone 6: Traffic Pattern Zone
AIA: Airport Influence Area
APA: Airport Protection Area
Airport Property
Jurisdictional Boundaries
Zone 7: Area between Zone 6 and the AIA
boundary
0 2400
Feet
. 202229
Figure 3-3
Safety Compatibility Zones
SOURCE: ESA Airports, ESRI, California Airport Land Use Planning Handbook (Caltrans, 2002) Livermore Municipal Airport Land Use Compatibility Plan Source: Alameda County ALUC, 2012
Figure 11-1: Livermore Municipal Airport Safety Compa�bility Zones SCS Dublin Project
Environmental Impact Report
Not to scale
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12 Hydrology & Water Quality

12.1 Introduction
This chapter describes effects on water resources (hydrology and water quality) that would be caused by implementation of the project. Information used to prepare this chapter came from the following resources:
 Aerial/satellite photography
 Project application and related materials
 Dublin-San Ramon Services District, 2020 Urban Water Management Plan, 2021

12.2 Scoping Issues Addressed
During the public comment scoping period for the project, one comment letter was received requesting analysis of planned potable water supply, wastewater connection, irrigation water supply, and hydrology and water quality in general.

12.3 Environmental Setting
This section presents information on the existing conditions of the project site and vicinity for hydrology and water quality.

12.3.1 Surface Water
Watershed
The project site is located within the Livermore Drainage Unit which is one of two major drainage basins in the Alameda Creek Watershed, and east of Tassajara Creek, which runs in a north-south direction. Tassajara Creek is a natural watercourse north of Interstate 580; but is channelized south of Interstate 580, prior to its convergence with Arroyo Mocho. Arroyo Mocho flows south to Arroyo De La Laguna, which empties into the San Francisco Bay.

The project site is located in the service area of the Dublin-San Ramon Services District (DSRSD), which serves the City of Dublin with potable water and non-potable recycled water. Alameda County Flood Control and Water Conservation District, known as Zone 7, supplies wholesale water to DSRSD.

Flooding
Flood Insurance Rate maps partition flood areas into three zones: Zone A for areas of 100-year flood; Zone B for areas of 500-year flood; and Zone C for areas of minimal flooding. The National Flood Insurance Program 100-year floodplain is considered the base flood condition.

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floodplains that must be kept free of encroachment as much as possible so that the 100-year floods can be carried without substantial increases (no more than one foot) in flood elevations.

According to the Federal Emergency Management Agency (FEMA) mapped Flood Insurance Rate Map (FIRM), the majority of the project site is within Zone X (areas of the 0.2% annual chance flood; areas of one percent annual chance flood with average depth of less than one foot or with drainage areas less than one square mile; and areas protected by levees from 1% annual chance flood), except the southerly portion of PA-1, which lies within zone AH (flood depth of one to three feet) with a base flood elevation of 349.0. (FEMA, 2009). As shown in Figure 12-1: Flood Hazard Areas, the southerly portion of the project site is located within the 100-year floodplain.

12.3.2 Groundwater
The project is within the Livermore Valley Groundwater Basin which extends about 14 miles from the Pleasanton Ridge east to the Altamont Hills and about three miles from the Livermore Upland north to the Orinda Upland. Principal streams providing surface drainage include Arroyo Valle, Arroyo Mocho, and Arroyo Las Positas, with Alamo Creek, South San Ramon Creek, and Tassajara Creek as minor streams. All streams converge on the west side of the basin to form Arroyo de la Laguna, which flows south and joins Alameda Creek in Sunol Valley.

Some geologic structures restrict the lateral movement of groundwater, but the general groundwater gradient is to the west, then south towards Arroyo de la Laguna. Elevations within the basin range from about 600 feet in the east, near the Altamont Hills, to about 280 feet in the southwest, where Arroyo de la Laguna flows into Sunol Groundwater Basin. Average annual precipitation ranges from 16 inches on the valley floor to more than 20 inches along the southeast and northwest basin margins.

The floor of the Livermore Valley and portions of the upland areas on all sides of the valley overlie groundwater‐bearing materials. The materials are continental deposits from alluvial fans, outwash plains, and lakes. They include valley‐fill materials, the Livermore Formation, and the Tassajara Formation. Under most conditions, the valley‐fill and Livermore sediments yield adequate to large quantities of groundwater to all types of wells. The quality of water produced from these rocks ranges from poor to excellent, with most waters in the good to excellent range.

Total storage capacity of the basin is estimated at about 500,000 acre‐feet (af). Groundwater storage was estimated at 219,000 af in 1999.

Zone 7 has maintained an annual hydrologic inventory of supply and demand since 1974. The inventory describes the balance between groundwater supply and demand. Under average hydrologic conditions, the groundwater budget is essentially in balance. Groundwater budget inflow components include natural recharge of 10,000 acre‐feet, artificial recharge of 10,900 af, applied water recharge of 1,740 acre‐feet, and subsurface inflow of 1,000 af. Groundwater budget outflow components include urban extraction of 10,290 af, agricultural extraction of 1116
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190 af, other extraction and evaporation associated with gravel mining operations of 12,620 af, and subsurface outflow of 540 af.

Zone 7 extracts groundwater from the Livermore Valley Main Groundwater Basin (Main Basin) which contains high-yielding aquifers and good quality groundwater. The Main Basin has an estimated storage capacity of approximately 254,000 af. California Department of Water Resources (DWR) has not identified the Main Basin as a basin in overdraft or a basin expected to be in overdraft. The Main Basin is considered a storage facility and not a long-term source of water supply because Zone 7 only pumps groundwater it has artificially recharged using its surface water supplies.

DSRSD, the City of Pleasanton, the City of Livermore, and California Water Service Company have agreements with Zone 7 limiting their extraction of the long-term sustainable yield of the Main Basin. This agreement, along with Zone 7’s other groundwater management activities, keeps the groundwater budget in balance under average hydraulic conditions. Each of these entities, known as retailers, has a groundwater pumping quota (GPQ) and are responsible for a fee if they pump in excess of their GPQ.

DSRSD groundwater supply is pumped by Zone 7 from Mocho well No. 4, a Zone 7 installed well located in the Mocho well field. Groundwater from Mocho No.4 is blended with water from other Zone 7 water supplies and is delivered to DSRSD to meet its total water demand.

Zone 7 conducts a program of groundwater replenishment by recharging imported surface water via its streams ("in-stream recharge") for storage in the Main Basin. Zone 7's operational policy is to maintain the balance between the combination of natural and artificial recharge and withdrawal, ensuring that groundwater levels do not drop below the historic low level of 128,000 af. Zone 7 plans to recharge 9,200 afy on average, which means that Zone 7 can pump an equivalent 9,200 afy on average from the Main Basin.

12.4 Applicable Regulations, Plans, and Standards

12.4.1 Federal and State
Clean Water Act
Under the Clean Water Act of 1972, the United States Environmental Protection Agency (U.S.

EPA) is authorized to regulate the discharge of pollutants in the waters of the United States and to regulate water quality standards for surface waters. The U.S. EPA has delegated authority for implementing water quality regulations to the California State Water Resources Control Board (State Water Board), which has nine Regional Water Quality Control Boards (RWQCB).

Porter‐Cologne Water Quality Control Act
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jurisdiction of the San Francisco Bay RWQCB, which is responsible for the implementation of state and federal water quality protection statutes, regulations and guidelines.

National Pollutant Discharge Elimination System
Pursuant to Section 402 of the CWA and the Porter‐Cologne Water Quality Control Act, municipal storm water discharges in the City of Dublin are regulated under the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, Order No. R2‐2022-0018, NPDES Permit No. CAS612008, adopted May 11, 2022, and the San Francisco Bay Regional Water Quality Control Board (RWQCB) Transmittal of Order No. R2-2003-0032, Water Quality Certification and Waste Discharge Requirements, Dublin Ranch Project, dated April 22, 2003. Both NPDES permits are overseen by the RWQCB.

The City of Dublin is a member agency of the Alameda Countywide Clean Water Program, which assists municipalities and other agencies in Alameda County with implementation of the Municipal Regional Permit. Provision C.3 addresses post‐construction stormwater management requirements for new development and redevelopment projects that add and/or replace 5,000 square feet or more of impervious area. Provision C.3 requires the incorporation of site design, source control, and stormwater treatment measures into development projects to minimize the discharge of pollutants in stormwater runoff and non‐stormwater discharges, and to prevent increases in runoff flows. Low Impact Development (LID) methods are to be the primary mechanism for implementing such controls.

Municipal Regional Permit Provision C.3.g pertains to hydromodification management. This Municipal Regional Permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition. Increases in runoff flow and volume must be managed so that the post‐project runoff does not exceed estimated pre‐project rates and durations, where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force.

The Hydromodification Management Susceptibility Map developed by the Alameda Countywide Clean Water Program indicates that Dublin drains primarily to earthen channels; therefore, projects that create or replace one acre or more of impervious surface and increase impervious surface over pre‐project conditions are subject to hydromodification management requirements.

In addition, projects disturbing more than one acre of land during construction are required to comply with the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, Order No. 2009‐0009‐DWQ, NPDES No.

CAS000002 (Construction General Permit). Construction General Permit activities are regulated at a local level by the RWQCB.

To obtain coverage under the Construction General Permit, a project applicant must provide a Notice of Intent, a Stormwater Pollution Prevention Plan (SWPPP), and other documents 1118
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required by Attachment B of the Construction General Permit. Activities subject to the Construction General Permit include clearing, grading, and disturbances to the ground, such as grubbing or excavation. The permit also covers linear underground and overhead projects such as pipeline installations.

The Construction General Permit uses a risk‐based permitting approach and mandates certain requirements based on the project risk level (Level 1, 2, or 3). The project risk level is based on the risk of sediment discharge and the receiving water risk. The sediment discharge risk depends on project location and timing (such as wet season versus dry season activities). The receiving water risk depends on whether the project would discharge to a sediment‐sensitive receiving water. The determination of the project risk level would be made by project applicants when the Notice of Intent is filed (and more details of the timing of the construction activity are known).

The performance standard in the Construction General Permit is that dischargers minimize or prevent pollutants in stormwater discharges and authorized non‐stormwater discharges through the use of controls, structures, and best management practices (BMPs). A SWPPP must be prepared by a qualified SWPPP developer that meets the certification requirements in the Construction General Permit. The purpose of the SWPPP is: 1) to help identify the sources of sediment and other pollutants that could affect the quality of stormwater discharges, and 2) to describe and ensure the implementation of BMPs to reduce or eliminate sediment and other pollutants in stormwater as well as non‐stormwater discharges resulting from construction activity. Operation of BMPs must be overseen by a qualified SWPPP practitioner who meets the requirements outlined in the permit.

Section 303(d) and Total Maximum Daily Loads
Section 303(d) of the Clean Water Act (CWA) requires each state to identify water bodies that are impaired, and which consequently require further action to support their beneficial uses.

Once a water body is identified as impaired, the state is required to establish a Total Maximum Daily Load (TMDL) for each pollutant that is a source of impairment. A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still meet water quality standards, which will ensure the protection of beneficial uses. The Basin Plan establishes TMDLs and the attainment strategies that need to be implemented to meet the standards.

TMDL attainment strategies are implemented by the RWQCB through National Pollutant Discharge Elimination System (NPDES) permits.

National Flood Insurance Program
The National Flood Insurance Program (NFIP), implemented by the Congress of the United States in 1968, enables participating communities to purchase flood insurance. Flood insurance rates are set according to flood‐prone status of property as indicated by FIRMs developed by FEMA. FIRMs identify the estimated limits of the 100‐year floodplain for mapped watercourses, among other flood hazards. As a condition of participation in the NFIP, communities must adopt regulations for floodplain development intended to reduce flood damage for new 1119
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development through such measures as flood proofing, elevation on fill, or floodplain avoidance.

Senate Bill 610
Senate Bill (SB) 610 was passed on January 1, 2002, amending California state law to require detailed analysis of water supply availability for large development projects. An SB 610 Water Supply Assessment (WSA) must be prepared if the following three conditions are met: 1) the project is subject to CEQA under Water Code Section 10910; 2) the project meets criteria to be defined as a “Project” under Water Code Section 10912; and 3) the applicable water agency’s current Urban Water Management Plan (UWMP) does not account for the water supply demand associated with the project. A project would meet the definition of “Project” per Water Code Section 10912 if it is:
 A proposed residential development of more than 500 dwelling units;  A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space;  A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space;
 A proposed hotel or motel, or both, having more than 500 rooms;  A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area;
 A mixed‐use project that includes one or more of the projects specified in this subdivision; or
 A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling unit project (DWR, 2003b).

12.4.2 Local
City of Dublin General Plan
The City of Dublin General Plan establishes the following policies associated with hydrology and water quality that are relevant to the project:

Guiding Policy 7.3.1.A.1: Maintain natural hydrologic systems.

Implementing Policy 7.3.1.B.1: Enforce the requirements of the Municipal Regional Permit for stormwater issued by the San Francisco Bay Regional Water Quality Control Board or any subsequent permit as well as Chapter 7 (Public Works) and Chapter 9 (Subdivisions) of the Dublin Municipal Code for maintenance of water quality and protection of stream courses. 1120
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Implementing Policy 7.3.1.B.2: Review development proposals to ensure site design that minimizes soil erosion and volume and velocity of surface runoff.

Guiding Policy 12.3.5.A.1: Protect the quality and quantity of surface water and groundwater resources that serve the community.

Guiding Policy 12.3.5.A.2: Protect water quality by minimizing stormwater runoff and providing adequate stormwater facilities.

Guiding Policy 12.3.5.A.3: To minimize flooding in existing and future development, design stormwater facilities to handle design‐year flows based on buildout of the General Plan.

Implementing Policy 12.3.5.B.1: Support Zone 7’s efforts to complete planned regional storm drainage improvements.

Implementing Policy 12.3.5.B.2: With the goal of minimizing impervious surface area, encourage design and construction of new streets to have the minimum vehicular travel lane width possible while still meeting circulation, flow, and safety requirements for all modes of transportation.

Implementing Policy 12.3.5.B.3: Discourage additional parking over and above the required minimum parking standards for any land use unless the developer can demonstrate a need for additional parking.

Implementing Policy 12.3.5.B.5: Review design guidelines and standard details to ensure that developers can incorporate clean water runoff requirements into their projects.

Implementing Policy 12.3.5.B.6: Maximize the runoff directed to permeable areas or to stormwater storage by appropriate site design and grading, using appropriate detention and/or retention structures, and orienting runoff toward permeable surfaces designed to manage water flow.

Implementing Policy 12.3.5.B.7: Review development plans to minimize impervious surfaces and generally maximize infiltration of rainwater in soils, where appropriate. Strive to maximize permeable areas to allow more percolation of runoff into the ground through such means as bioretention areas, green strips, planter strips, decomposed granite, porous pavers, swales, and other water permeable surfaces. Require planter strips between the street and the sidewalk within the community, wherever practical and feasible.

Implementing Policy 12.3.5.B.8: Continue conducting construction site field inspections to ensure proper erosion control and materials/waste management implementation to effectively prohibit non‐stormwater discharges.
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Eastern Dublin Specific Plan
The City of Dublin’s Eastern Dublin Specific Plan contains the following program associated with hydrology and water quality that are relevant to the project:

Program 6H: The City should enact and enforce an erosion and sedimentation control ordinance establishing performance standards to ensure maintenance of water quality and protection of stream channels. The ordinance should regulate grading and development activities adjacent to streams and wetland areas, and require revegetation of all ground disturbances immediately after construction to reduce erosion potential. Until such an ordinance is in place, the City shall require project applicants to provide a detailed erosion and sedimentation control plan as part of the project submittal.

12.5 Environmental Impacts and Mitigation Measures

12.5.1 Significance Criteria
The following significance criteria for hydrology & water quality were derived from the Environmental Checklist in CEQA Guidelines Appendix G. These significance criteria have been amended or supplemented, as appropriate, to address Lead Agency requirements and the full range of potential impacts related to this project.

An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria:
 Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface water or ground water quality.  Substantially decrease groundwater supplies or interfere substantially with groundwater recharge, such that the project may impede sustainable groundwater management of the basin.
 Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner that would: Result in a substantial erosion or siltation on- or offsite; Substantially increase the rate or amount of runoff in a manner which would result in flooding on-or off-site; Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or Impede or redirect flood flows.  In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.
 Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.
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The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.

12.5.2 Summary of No and/or Beneficial Impacts
Based on the site’s location, it would not be subject to inundation by seiche, tsunami, or mudflow. Therefore, these thresholds are not evaluated further in this chapter.

12.5.3 Impacts of the Proposed Project
Impact HYD-1: Contribute to the depletion of local groundwater supplies or interfere with groundwater recharge (Class III).

The project could substantially deplete local groundwater supplies or interfere with groundwater recharge if it:
 Affected groundwater basin in overdraft conditions;
 Caused the affected groundwater basin to be in overdraft;  Caused a substantial local groundwater level drawdown at wells in the area; or  Redirected natural recharge to the basin, such as through the introduction of impervious areas that prevent infiltration.

As further described in Chapter 16: Public Services, Utilities & Service Systems, the project would generate a total water demand of approximately 225afy. The project water demand, inclusive of potable, recycled, and groundwater, would not be higher than the demand included for the project site in the DSRSD’s 2020 UWMP. Therefore, the project would not exceed the capacity of the groundwater production system.

Furthermore, DWR has not identified the Main Basin as a basin in overdraft nor as a basin expected to be in overdraft. Thus, the project would not cause the groundwater basin to be in overdraft, and it would not result in substantial local groundwater level drawdown at wells in the area.

Given that the site is currently vacant and undeveloped, the project would result in a net increase in impervious surfaces on-site. An increase in impervious surfaces from the primarily 1123
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pervious existing condition could reduce groundwater recharge. Site acreage and impervious surface acreage includes building footprints, public and private street pavement, sidewalks, walkways and driveways. Pursuant to the Stormwater Control Plans to be prepared for the project, however, stormwater would be reduced through inclusion of bioretention, Silva Cells with bioretention, and landscaping throughout the project site that would allow infiltration of stormwater. These features would allow for infiltration and replenishment of the groundwater basin.

In conclusion, the project would not result in groundwater overdraft, substantial local groundwater level drawdown; or substantially redirect stormwater such that natural basin recharge would be precluded. Impacts to local groundwater would be less than significant (Class III).

Impact HYD‐2: Increase stormwater runoff due to an increase in impervious surfaces (Class III).

The rate and amount of surface runoff is determined by multiple factors, including the following: amount and intensity of precipitation; amount of other imported water that enters a watershed; and amount of precipitation and imported water that infiltrates to the groundwater. Infiltration is determined by several factors, including soil type, antecedent soil moisture, rainfall intensity, the amount of impervious surfaces within a watershed, and topography. The rate of surface runoff is largely determined by topography and the intensity of rainfall over time. The project would not alter any precipitation amounts or intensities, nor would it require any additional water to be imported into the project site. However, construction would include earth‐disturbing activities which may affect site‐specific infiltration and permeability during construction (temporary) and operation (permanent).

The project would include a drainage system that would collect and convey runoff and ultimately discharge it to the City of Dublin’s municipal storm drainage system. In accordance with the C.3 provision of the Municipal Regional Storm Water Permit (MRP) and the California Regional Water Control Board (RWQCB) Transmittal of Order No. R2-2003-0032, Water Quality Certification and Waste Discharge Requirements, Dublin Ranch Project, dated April 22, 2003, the project would be required to implement post construction stormwater treatment measures minimizing long term water quality impacts by using low impact development, site design and source control measures.

The Dublin Ranch West Side Storm Drain Benefit District, adopted March 18, 2008, allocated flow from watershed PA-1, PA-2 and PA-3 for design of the storm drain system that has since been constructed. Below is a summary of the allocated 15-year peak flows for the project:
 Watershed PA-1 = 24.52 cubic feet/second (cfs)
 Watershed PA-2a and 2b = 26.21 cfs
 Watershed PA-2c = 25.19 cfs
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 Watershed PA-3 = 19.60 cfs
 Watershed PA-4 = not a part of the Dublin Ranch Master Drainage Watershed  Watershed “Tassajara” = not a part of the Dublin Ranch Master Drainage Watershed The majority of the project site, including parcels PA-2 and PA-3, as well as Dublin Boulevard, Central Parkway and Brannigan Street, is located within the Dublin Ranch Master Drainage Watershed. Most drainage from the project site is discharged into the existing underground storm drain system in the public streets surrounding the project site. The existing storm drain system has been previously constructed in accordance with the Dublin Ranch Drainage Master Plan infrastructure improvements. Thus, the watersheds and drainage connection points for each development parcel and surrounding public streets have been previously identified and hydraulically sized as part of the revised SWMP for Dublin Ranch (March 2003), and the Dublin Ranch Drainage Master Plan (March 2006).

As a part of the Dublin Ranch Drainage Master Plan improvements, a water quality/detention basin was constructed at the downstream end of the Dublin Ranch Development Watershed adjacent to Interstate 580. This water quality/detention basin treats stormwater runoff for the properties that were included in the Dublin Ranch Development Watershed, including parcels PA-2 and PA-3. The stormwater quality/detention pond was constructed to meet the mandates in California Regional Water Quality Control Board San Francisco Bay Region Order No.

R2--2003-0031, Waste Discharge Requirements and Water Quality Certification for Dublin Ranch Project, Dublin and Livermore, Alameda County.

Impervious surface area within PA-1, PA-4, Gleason Drive and Tassajara Road were not included in the Dublin Ranch Drainage Master Plan, therefore full compliance to the MRP C.3 Requirements and Zone 7 Water Agency requirements shall be met within the project boundaries.

In accordance with MRP C.3 Requirements and Zone 7 flood control requirements, drainage for the project site would be designed to maintain the existing watershed drainage pattern and avoid any impact to downstream watersheds by reducing the post development runoff for the site to the predevelopment condition by incorporating low impact development features such as bioretention and Silva Cells to treat and reduce stormwater pollutants from entering into the municipal separate storm drain system. The grading design would maintain the north/south sloping layout of the land, matches existing grades along project perimeters, minimizes the use of retaining walls, while minimizing the earthwork cut and fill.

Although the project would increase the amount of impervious surface area within the project site, the use of on-site treatment and detention would prevent a substantial increase in stormwater flows. Furthermore, stormwater discharges from the project and other new developments in the City would be required to comply with the Construction General Permit, MRP Provision C.3 requirements, and incorporate appropriate site-specific LID and source and treatment control measures. Thus, the project would not result in an increase in stormwater 1125
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runoff due to an increase in impervious surfaces. Impacts would be less than significant (Class III).

Impact HYD‐3: Substantially alter drainage patterns on- or off-site that would result in the storm water transport of contaminants, pollutants, bacteria, salts, and sediment into downstream facilities (Class III).

Regulations under three State stormwater permits are applicable to this impact: 1) The Municipal Regional Stormwater NPDES Permit Provision C.3 Requirements (MRP), 2) The California Regional Water Control Board (RWQCB) Transmittal of Order No. R2-2003-0032, Water Quality Certification and Waste Discharge Requirements, Dublin Ranch Project, dated April 22, 2003, and 3) The NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Construction General Permit).

Construction General Permit
Because the project would disturb more than one acre of land, the project applicant would be required to submit a Notice of Intent (NOI) to the State Water Resources Control Board and apply for coverage under the Construction General Permit. As part of the NOI application process a Stormwater Pollution Prevention Plan (SWPPP) must be submitted for review and approval prior to commencing construction.

In addition to potential sediment transport, construction activities require the use of gasoline‐ and diesel‐powered heavy equipment, such as bulldozers, backhoes, water pumps, and air compressors and chemicals such as gasoline, diesel fuel, lubricating oil, hydraulic oil, lubricating grease, automatic transmission fluid, paints, solvents, and glues. An accidental release of any of these substances could degrade the quality of the surface water runoff and adversely affect receiving waters.

To address this potential impact, the project applicant is required to prepare a Stormwater Pollution Prevention Plan (SWPPP) in accordance with the requirements of the statewide Construction General Permit. The SWPPP shall be designed to address the following objectives:
(1) All pollutants and their sources, including sources of sediment associated with construction, construction site erosion, and all other activities associated with construction activity are controlled;
(2) Where not otherwise required to be under a Regional Water Quality Control Board permit, all non‐stormwater discharges are identified and either eliminated, controlled, or treated;
(3) Site Best Management Practices (BMPs) are effective and result in the reduction or elimination of pollutants in stormwater discharges and authorized non‐stormwater discharges from construction activity; and
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(4) Stabilization BMPs installed to reduce or eliminate pollutants after construction are completed.

The SWPPP is required to be consistent with the BMP requirements as described in the most recent version of the California Stormwater Quality Association (CASQA) Stormwater Best Management Handbook‐Construction or the Caltrans Stormwater Quality Handbook Construction Site BMPs Manual. The project applicant has prepared preliminary erosion control plans which follow CASQA guidelines and which includes silt fences, fiber rolls, drop inlet protection and curb inlet sediment barriers, and rocked construction site entrances.

Construction BMPs include soil preparation, hydroseeding, wind erosion control, water conservation practices, and stockpile management.

MRP Provision C.3 Requirements
The Municipal Regional Stormwater NPDES Permit (MRP) adopted by the RWQCB, requires the implementation of post construction stormwater treatment measures minimizing long term water quality impacts by using low impact development, site design and source control measures. Pursuant to the RWQCB requirements, the project applicant will be required to prepare a Preliminary Storm Water Management Plan (SWMP) for the project.

Given that the project would meet the water quality requirements required by the Construction General Permit, MRP Provision C.3 Requirements, and the California Regional Water Control Board (RWQCB) Transmittal of Order No. R2-2003-0032, Water Quality Certification and Waste Discharge Requirements, Dublin Ranch Project, dated April 22, 2003, the impact would be less than significant (Class III) and no mitigation is necessary.

Impact HYD-4: Place structures which would impede or redirect flood flows within a 100-year flood hazard area (Class III).

According to FIRM map number 06001C328G, the majority the project is outside of a 100-year flood hazard area. A portion of PA-1 is currently within the AH zone with a flood depth of 1-3 feet. As shown in 12-1: Flood Hazard Areas, implementation of the project would include an import of soils to elevate structures within PA-1 above the 100-year flood elevation level; thus, as a part of the design process, the project applicant would seek a Conditional Letter of Map Revision (CLOMR) from FEMA. A CLOMR describes the changes that can be expected as a result of the project and states whether these changes would be in accordance with NFIP regulations.

In accordance with the comments and instructions provided in the CLOMR, the project applicant would initiate a request for a LOMR which would modify the associated FIRM map to show the elevation and hydrology alterations to the regulatory floodway resulting from the project. LOMR approval would be required prior to construction. The raised elevations within PA-1 and the associated CLOMR and LOMR process would reduce impacts to a less-thansignificant level and no mitigation is required. 1127
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12.5.4 Cumulative Impact Analysis
The geographical area for cumulative hydrology impacts is the Alameda Creek Watershed.

Impact HYD-5: Contribute to cumulatively considerable impacts on hydrology and water quality (Class III).

Present and reasonably foreseeable future projects could contribute to cumulatively considerable impacts on hydrology and water quality, including an increase the amount of impervious surfaces in the area, which would decrease the area available for water percolation and groundwater recharge. However, the WSA for the project provides verification of sufficient water supply to satisfy the water demand of the project. Per the Urban Water Management Plan (UWMP), DSRSD has adequate water supply to meet demands of future projects during normal, dry, and multiple-dry years through 2035. UWMP water demand estimates, including groundwater, are based on the full General Plan build out of the municipalities within the DSRSD service area. Thus, the future water demand estimates would account for the water supply and potential demands of reasonably foreseeable future projects as well as the project.

Stormwater discharges from the project and other new developments in the City would be required to comply with the Construction General Permit, MRP Provision C.3 requirements, and the California Regional Water Control Board (RWQCB) Transmittal of Order No. R2-2003-0032, Water Quality Certification and Waste Discharge Requirements, Dublin Ranch Project, dated April 22, 2003 incorporate appropriate site-specific LID and source and treatment control measures. Compliance with these regulations would ensure that the project and other new developments would not increase stormwater runoff or substantially alter drainage patterns.

The project, combined with present and reasonably foreseeable future projects, would result in less-than-significant cumulative impacts to stormwater quantity and water quality.

12.5.5 Level of Significance after Mitigation
Table 12-1: Summary of Impacts and Mitigation Measures – Hydrology & Water Quality summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to hydrology & water quality. 1128
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Table 12-1: Summary of Impacts and Mitigation Measures – Hydrology & Water Quality Impact
Impact
Significance Mitigation
Impact HYD-1: Contribute to the
depletion of local groundwater
supplies or interfere with
groundwater recharge (Class III).

Less than
Significant
None required.

Impact HYD‐2: Increase stormwater
runoff due to the increase in
impervious surfaces (Class II).

Less than
Significant
None required.

Impact HYD‐3: Substantially alter
drainage patterns on- or off-site that
would result in the storm water
transport of pollutants, bacteria,
salts, and sediment into
downstream facilities (Class III).

Less than
Significant
None required.

Impact HYD‐4: Place structures
which would impede or redirect
flood flows within a 100-year flood
hazard area? (Class III).

Less than
Significant
None required.

Impact HYD-5: Contribute to
cumulatively considerable effects on
hydrology and water quality (Class
III).

Less than
Significant
None required.

12.6 References
CASQA (California Stormwater Quality Association). 2003. “Construction Handbook.” Dublin-San Ramon Services District. 2021. 2020 Urban Water Management Plan. Available at https://www.dsrsd.com/home/showpublisheddocument/7749/637607511715070000.

Accessed April 4, 2022.

DWR (California Department of Water Resources). 2003. “Guidebook for Implementation of Senate Bill 610 and Senate Bill 221 of 2001 to assist water suppliers, cities, and counties in integrating water and land use planning”. Available at:
https://digitalcommons.law.ggu.edu/caldocs_agencies/95/. Accessed April 4, 2022.

DWR (California Department of Water Resources). 2021. California’s Groundwater Update 2020 (Bulletin 118). Available at https://data.cnra.ca.gov/dataset/calgw_update2020. Accessed April 4, 2022.

Federal Emergency Management Agency. 2009. Flood Insurance Rate Map Number 06001C0328G. Available at https://msc.fema.gov/portal/home. Accessed April 4, 2022. 1129
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Mackay & Somps. 2006. Dublin Ranch Drainage Master Plan.

USACE (U.S. Army Corps of Engineers). 2008. A Field Guide to the Identification of the Ordinary High Water Mark (OHWM) in the Arid West Region of the Western United States: A Delineation Manual. Available at:
https://www.spk.usace.army.mil/Portals/12/documents/regulatory/pdf/Ordinary_High _Watermark_Manual_Aug_2008.pdf. Accessed April 4, 2022. 1130
Source: Kimley-Horn, 20ϮϮ; FEMA, 2009
Figure 12-1: Flood Hazard Areas
SCS Dublin Project
Environmental Impact Report
Not to scale
Gleason Drive
LEGEND
Project Site
Special ood hazard areas subject to
inundation by the 1% annual chance ood
Flood depths of 1 to 3 feet (usually sheet ow)
Zone AH
All other areas are located in Zone X
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13 Land Use & Planning

13.1 Introduction
This section describes effects on land use and planning that would be caused by implementation of the project. Information used to prepare this section came from the following resources:
 City of Dublin, General Plan, 1985 as amended 2022
 City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022  City of Dublin, Municipal Code
 Alameda County, Livermore Executive Airport Land Use Compatibility Plan, 2012

13.2 Scoping Issues Addressed
During the public comment scoping period for the project, a comment requesting general analysis of land use and planning was received.

13.3 Environmental Setting
This section presents information on the existing conditions of the project site and vicinity for land use.

13.3.1 Project Site Land Uses
The project site was previously used for agricultural purposes and has remained vacant, with exception to of seasonal uses and consists of low lying native and non­native grasses turned periodically for the purposes of weed abatement and fire hazard management. A small group of trees and shrubs is located near the corner of Tassajara Road and Central Parkway. No grading for development has occurred to date.

13.3.2 Land Uses in the Project Site Vicinity
West
Tassajara Road forms the western boundary of the project site. Medium density residential, parks/public recreation, general commercial, and campus office uses are located to the west.

North
Undeveloped land contemplated for future residential development form the northern boundary of the project site just north of Gleason Drive. Single family medium density residential uses are located to the north.
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East
Brannigan Street forms the eastern boundary of the project site. A broad mix of land uses are located to the east including multi-family residential, general commercial, and a vacant parcel at the southeast corner of Dublin Boulevard and Brannigan Street South
Interstate 580 forms the southern boundary of the project site. The City of Pleasanton is located south of the project site.

13.3.3 Livermore Municipal Airport
The Livermore Municipal Airport 12 is located in the western portion of the City of Livermore, south of I-580 and approximately two miles southeast from the project site. The airport is owned and operated by the City of Livermore and features two parallel runways: 7L /25R and 7R/25L, 5,255 feet in length and 2,699 feet in length, respectively.

The majority of the project site is also located within Land Use Compatibility Zone 7 of the Airport Influence Area, as established in the Livermore Executive Airport Land Use Compatibility Plan.

13.4 Applicable Regulations, Plans, and Standards
Appendix G of the State CEQA Guidelines recommends the evaluation of a project’s potential conflicts with: 1) Physically divide an established community, 2) Conflict with any applicable land use plan, policy or regulation of an agency having jurisdiction over a project adopted for the purpose of avoiding or mitigating an environmental effect; and 3) any applicable Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP).Applicable local land use plans and ordinances for land use are described below. See Chapter 6: Air Quality for a discussion of the project’s consistency with applicable federal, State, and local air quality plans.

13.4.1 Federal
Federal Aviation Regulations
The Federal Aviation Regulations (FAR), Part 77 – Safe, Efficient Use, and Preservation of Navigable Airspace, requires the Federal Aviation Administration (FAA) be noticed of proposed construction or alternation as described in FAR Part 77 Section 77.9. This pertains to any 12 The City of Livermore refers to the airport as “Livermore Municipal Airport” while the Alameda County Airport Land Use Commission refers to the airport as “Livermore Executive Airport”. This EIR will refer to it as “Livermore Municipal Airport” except in instances where the “Livermore Executive Airport Land Use Plan” is discussed. 1133
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construction or alteration that exceeds an imaginary surface extending outward and upward at any of the following slopes:
(1) 100 to 1 for a horizontal distance of 20,000 ft. from the nearest point of the nearest runway of each airport with its longest runway more than 3,200 ft. in actual length, excluding heliports.
(2) 50 to 1 for a horizontal distance of 10,000 ft. from the nearest point of the nearest runway of each airport with its longest runway no more than 3,200 ft. in actual length, excluding heliports.
(3) 25 to 1 for a horizontal distance of 5,000 ft. from the nearest point of the nearest landing and takeoff area of each heliport.

Notice received by the FAA under this subpart is used to:
(1) Evaluate the effect of the proposed construction or alteration on safety in air commerce and the efficient use and preservation of the navigable airspace and of airport traffic capacity at public use airports;
(2) Determine whether the effect of proposed construction or alteration is a hazard to air navigation;
(3) Determine appropriate marking and lighting recommendations, using FAA Advisory Circular 70/7460-1, Obstruction Marking and Lighting;
(4) Determine other appropriate measures to be applied for continued safety of air navigation; and
(5) Notify the aviation community of the construction or alteration of objects that affect the navigable airspace, including the revision of charts, when necessary.

13.4.2 State
State Aeronautics Act
The State Aeronautics Act requires each county with an airport to establish an Airport Land Use Commission to regulate land use around airports, to protect public safety and ensure that land uses near airports do not interfere with aviation operations. The Livermore Executive Airport Land Use Compatibility Plan regulates land use around Livermore Municipal Airport by requiring compliance with the applicable policies. In certain circumstances, local governments have the ability to override the decisions of the Airport Land Use Commission by a two-thirds vote. 1134
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13.4.3 Local
City of Dublin General Plan
The City of Dublin General Plan is the comprehensive planning document governing development within the City, and contains goals, policies, and programs describing the community’s vision for economic viability, livable neighborhoods, and environmental protection.

The General Plan, as amended, establishes policies for the orderly growth and development of the City of Dublin. Among other purposes, the General Plan identifies policies necessary to protect and enhance those features and services which contribute to the quality of life of the community in which it serves.

The General Plan is a comprehensive policy plan which sets forth a series of written statements (goals, policies and objectives) defining the direction, character and composition of future land use development, and establishes guidelines (policies and actions) necessary to attain conformance with the plan. It is made up of 12 elements and various maps which accompany the elements. The elements are: 1) Land Use 2) Parks & Open Space 3) Schools, Public Lands & Utilities 4) Circulation & Scenic Highways, 5) Housing, 6) Conservation, 7) Seismic Safety & Safety, 8) Noise, 9) Community Design & Sustainability, 10) Economic Development, 11) Water Resources, 12) Energy Conservation. The General Plan Land Use Plan Map visually represents the physical relationship of all portions of the text, including development densities.

General Plans are reviewed annually and should be updated every three years to ensure that the most recent technical data, community goals and state law requirements are recognized.

Major updates typically occur every 10 to 30 years, depending on changes in land use patterns, growth and development pressures, and new regulations.

As shown in Figure 3-3: Existing General Plan Land Use Designations, the southern and western portions of the project site are designated General Commercial in the General Plan. The northern and eastern portions of the project site are designated Medium Density Residential, Public/Semi-Public, Medium/High Density Residential, and Neighborhood Commercial in the General Plan.

Eastern Dublin Specific Plan
The Eastern Dublin Specific Plan (EDSP) provides a framework to guide future land use and development decisions in eastern Dublin. It serves as an extension of the General Plan and can be used as both a policy and regulatory document. For projects within the EDSP area, policies and standards in the Specific Plan will take precedence over more general policies and standards applied throughout the rest of the city.

The project site is located within the following Planning Subareas of the EDSP: 1) Town Center – Commercial, along Tassajara Road south of Gleason Drive and north of Dublin Boulevard; 2) Town Center – Residential, along Brannigan Street south of Gleason Drive and north of Dublin 1135
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Boulevard; 3) Tassajara Gateway, area south of Dublin Boulevard; and 4) Foothill Residential for the small area of the project on the north side of Gleason Drive. The EDSP’s description of the land use concept for each Subarea is described as follows:

Town Center – Commercial Subarea
This subarea represents the commercial core for eastern Dublin. The area is intended to be a high density, pedestrian-oriented commercial, civic, and entertainment center for Dublin and the surrounding communities. The subarea consists of two distinct parts; the General Commercial area and the Neighborhood Commercial area.

The General Commercial area, which extends along Tassajara Road, is intended to include uses with a broader market area and a greater orientation to the motoring public, including a full range of regional and community retail, service, office, and restaurant uses. Ideally, a major community shopping center, with supermarket, drug store, hardware store, liquor store, and other supporting retail and service uses would be located in this area.

Town Center – Residential Subarea
This subarea is generally located in the area bounded by Dublin Boulevard on the south, Fallon Road on the east, Gleason Drive on the north and Hacienda Drive on the west. The residential subarea is bisected by the Town Center--Commercial subarea. A community park and open space occupy the eastern portion of the subarea and residential is designated for the western portion.

Tassajara Gateway Planning Subarea
This subarea is located at the Tassajara Road interchange with I-580 and includes the areas on either side of Tassajara Road between I-580 and Dublin Boulevard. The land use concept for the Tassajara Gateway encourages the development of uses that will benefit from their location at the intersection of the area's two major east-west travel corridors (I- 580 and Dublin Boulevard) with the major north-south corridor (Tassajara Road). The area is favored for uses that depend on the location’s high visibility and convenient vehicular access. Uses which fit these criteria might include activities such as hotels, campus office, conference center, restaurants, and quality regional retail.

Foothill Residential Subarea
This subarea includes most of the Specific Plan area north and east of the Town Center subarea.

Land use in this subarea is predominantly single-family residential. Other uses include schools and parks.

East Alameda County Conservation Strategy
The East Alameda County Conservation Strategy (EACCS) is a guidance document intended to provide a framework to protect, enhance, and restore natural resources in eastern Alameda County, while improving and streamlining the environmental permitting process for impacts resulting from infrastructure and development studies. The City of Dublin adopted the EACCS 1136
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as its guidance document for public projects and uses the document to provide input for managing biological resources and conservation priorities during project-level planning and environmental planning. For privately sponsored development projects such as this project, proponents are encouraged to consult the EACCS for guidance, but compliance with the document is not mandatory.

Alameda County - Livermore Executive Airport Land Use Compatibility Plan The Livermore Executive Airport Land Use Compatibility Plan (ALUCP) governs land use around Livermore Municipal Airport. This Plan was adopted by the Alameda County Airport Land Use Commission (ALUC) in 2012.

The ALUCP should act as a guide for the ALUC and local jurisdictions in safeguarding the general welfare of the public. To guide future development, the ALUCP provides compatibility criteria for noise, safety and airspace protection.

As stated in the ALUCP, in comparison to noise, safety is in many respects a more difficult concern to address in airport land use compatibility policies. The primary reason for this difference is that safety policies address uncertain events which may occur with occasional aircraft operations, whereas noise policies deal with known, quantifiable, and more or less predictable events which do occur with every aircraft operation.

In regard to airspace protection whether a particular object constitutes an airspace obstruction depends upon the height of the object relative to the runway elevation and its proximity to the airport. The acceptable height of objects near an airport is most commonly determined by application of standards set forth in Federal Aviation Regulation Part 77.

13.4.4 Zoning
The City of Dublin Zoning Ordinance implements the General Plan and Specific Plans and to guide and manage the future growth of the city in accordance with those plans. As shown in Figure 3-4: Existing Zoning, the project site is designated Planned Development (PD) per Resolution No. 104-94, which was adopted as part of the EDSP. This PD Pre-zoning allowed for the annexation of 1,538 acres.

The purpose of the PD is to allow flexibility to encourage innovative development while ensuring that the goals, policies and action programs of the General Plan and Eastern Dublin Specific Plan are met. In particular, the PD is intended to implement the following policies:

1. Allow and encourage mixed use residential and commercial development in order to meet specific housing and employment needs, reduce vehicular trips, and foster pedestrian access to shopping and employment areas.

2. Concentrate development on less environmentally and visually sensitive or constrained portions of the plan area and preserve significant open space areas and natural and topographic landscape features with minimum alteration of land forms. 1137
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3. Encourage innovative approaches to site planning, building design and construction to create housing products for all segments of the community, including commercial and office structures.

4. Encourage higher intensity development near transit corridors.

5. Create an attractive, efficient and safe environment.

6. Develop an environment that encourages social interaction and the use of common open areas for neighborhood or community activities and other amenities.

7. Create an environment that decreases dependence on the private automobile.

13.5 Environmental Impacts and Mitigation Measures

13.5.1 Significance Criteria
The following significance criteria for land use & planning were derived from the Environmental Checklist in CEQA Guidelines Appendix G. These significance criteria have been amended or supplemented, as appropriate, to address Lead Agency requirements and the full range of potential impacts related to this project.

An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria.
 Physically divide an established community.
 Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect.

Significance Classifications
The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.
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13.5.2 Summary of No and/or Beneficial Impacts
Physically Divide an Established Community
The project would not physically divide an established community because it is located in within the City limits and would be compatible with surrounding land uses. In addition, existing roadway connections to the surrounding community would be maintained. Therefore, there would be no impact.

The environmental effects related to compatibility between proposed on-site land uses and adjacent land uses during both construction and operation are described in the respective impact section of the following environmental resource chapters: Aesthetics, Air Quality, Greenhouse Gas Emissions, Noise, and Transportation and Circulation.

13.5.3 Impacts of the Proposed Project
Impact LU-1: Substantially conflict with an applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect (Class III) General Plan/Specific Plan Amendment
As shown in Figure 3-5: Proposed General Plan Land Use Designations, the project would include a General Plan/Specific Plan amendment that would re-designate the project site from six to five land use designations. With City Council approval of the project and certification of the EIR, the project would be consistent with applicable land use plan, policy, and regulations.

And environmental impacts would be less than significant and no mitigation is required.

Ordinances and Regulations
The project would be required to comply with all applicable City of Dublin ordinances and regulations.

The Top Golf netting and support poles would be up to 190 feet in height and therefore require review by the Federal Aviation Administration (FAA) in accordance with FAR Part 77. Section

2.6.2.f. of the Alameda County Airport Land Use Plan (ALUP) recommends review by the Airport Land Use Commission (ALUC ) for projects that involve “Any obstruction reviewed by the FAA in accordance with FAR Part 77 that receives a finding other than ‘not a hazard to air navigation’.” However, if the proposed project receives a finding from the FAA of “not a hazard to air navigation,” no ALUC review is required.

13.5.4 Cumulative Impact Analysis
The geographic area for the analysis of cumulative impacts to land use and planning is the greater EDSP area, where land use changes could interact with land use changes under the project to result in cumulative effects.
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Impact LU-2: Contribute to cumulatively considerable land use impacts (Class III).

Land use impacts would be cumulatively considerable if the project, in conjunction with other past, present, reasonably foreseeable future projects, would be designed or otherwise conditioned to maintain consistency with adopted land use plans and ordinances or be amended with the appropriate mitigation and conditions of approval.

As described above, the project, with implementation of the General Plan amendment, would be consistent with the City’s General Plan and the EDSP. All feasible mitigation measures to address environmental impacts of the project have been described in this EIR.

Implementation of future projects requiring a change in the General Plan land use designation would require discretionary approval, similar to this project review and approval process. It is reasonably assumed that these projects would be designed or otherwise conditioned to maintain consistency with adopted land use plans and ordinances or be amended with the appropriate mitigation and conditions of approval.

As described above, the project would be consistent with applicable land use goals, policies and objectives of the General Plan. Mitigation measures to address potential environmental impacts of the project have been included in this EIR. Given the project’s consistency, as well as the potential for other projects in the cumulative impact scenario to be generally consistent with the land use policy framework, overall cumulative land use consistency impacts would be less than significant.

13.5.5 Level of Significance after Mitigation
Table 13 -1: Summary of Impacts and Mitigation Measures – Land Use & Planning summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to land use & planning.

Table 13-1: Summary of Impacts and Mitigation Measures – Land Use & Planning Impact Impact Significance Mitigation
Impact LU-1: Substantially conflict
with an applicable land use plan,
policy, or regulation adopted for
the purpose of avoiding or
mitigating an environmental effect
(Class III).

Less Than Significant None required.

Impact LU-2: Contribute to
cumulatively considerable land use
impacts (Class III).

Less Than Significant None required.
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13.6 References
Alameda County, Livermore Executive Airport Land Use Compatibility Plan, 2012.

City of Dublin, General Plan, 1985 as amended 2022.

City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022.

City of Dublin, Municipal Code.

Code of Federal Regulations. Available at https://www.ecfr.gov/current/title-14/chapterI/subchapter-E/part-77. Accessed April 4, 2022. 1141
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14 Noise & Vibration

14.1 Introduction
This section describes the potential noise effects that would be caused by implementation of the project. Information used to prepare this section came from the following resources:
 Project application and related materials
 City of Dublin, General Plan, 1985 amended 2022
 City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022  2022 Noise Analysis Technical Data (Appendix F)

14.2 Scoping Issues Addressed
During the public comment scoping period for the project, a comment requesting analysis of project construction noise was received.

14.3 Environmental Setting
This section presents information on the existing conditions of the project site and vicinity for noise and vibration.

14.3.1 General Information on Noise
To describe environmental noise and to assess impacts on areas sensitive to community noise, a frequency weighting measure that simulates human perception is customarily used. The frequency weighting scale known as A‐weighting best reflects the human ear’s reduced sensitivity to low frequencies and correlates well with human perceptions of the annoying aspects of noise. The A‐weighted decibel scale (dBA) is cited in most noise criteria. In general, a difference of more than 3 dBA is a perceptible change in environmental noise, while a 5 dBA difference typically causes a change in community reaction. An increase of 10 dBA is perceived by people as a doubling of loudness.

As shown in Table 14-1: Typical A-Weighted Noise Levels, people experience a wide range of sounds in the environment. Excessive noise is not only undesirable but may also cause physical and/or psychological damage. The amount of annoyance or damage caused by noise is dependent primarily upon: the amount and nature of the noise, the amount of ambient noise present before the intruding noise, and the activity of the person working or living in the area.

Environmental and community noise levels rarely are of sufficient intensity to cause irreversible hearing damage, but disruptive environmental noise can interfere with speech and other communication and be a major source of annoyance by disturbing sleep, rest, and relaxation. 1142
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Table 14-1: Typical A-Weighted Noise Levels
Noise Level (dBA) Indoor Noise Source Outdoor Noise Source 0 (Lowest Threshold of Human Hearing) (Lowest Threshold of Human Hearing) 10-20 Broadcast/ recording studio
30 Library
Bedroom at night, concert hall
(background)
Quiet rural nighttime
40 Theater, large conference room
(background) Quiet urban/ suburban nighttime
50 Dishwasher in next room Quiet urban daytime
60 Large business office Heavy traffic at 300 feet
70 Vacuum cleaner at 10 feet
Normal Speech at 3 feet
Noisy urban area, daytime
Gas lawnmower, 100 feet
Commercial area
80 Garbage disposal at 3 feet Diesel truck at 50 feet at 50 mph 90 Food blender at 3 feet Gas lawn mower at 3 feet
100 Jet fly-over at 1,000 feet
110 Rock band
Source: California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, September 2013 Decibels are logarithmic units that conveniently compare the wide range of sound intensities to which the human ear is sensitive. Therefore, the cumulative noise level from two or more sources will combine logarithmically, rather than linearly (i.e., simple addition). For example, if two identical noise sources produce a noise level of 50 dBA each, the combined noise level would be 53 dBA, not 100 dBA. Sound is generally propagated by spherical spreading according to the “inverse square law,” where the sound energy decreases with the square of the distance.

As such, the sound pressure level would be reduced by 6 decibels per doubling of distance from a ground‐level stationary or point source. For a noise source which is relatively long, such as a constant stream of highway traffic (line source), the sound pressure spreads at a rate of three decibels per doubling of distance. At very large distances, beyond several hundred feet, wind and temperature gradients influence sound propagation. Changes in noise levels due to wind are generally short‐term without persistent directional winds, where some hours may be one or two decibels louder than others within the margin of precision of this assessment.

The community noise environment and the consequences of human activities cause noise levels to be widely variable over time. For simplicity, sound levels are usually best represented by an equivalent level over a given time period (Leq) or by an average level occurring over a 24‐hour period. The Leq, or equivalent sound level, is a single value for any desired duration, which includes all of the time‐varying sound energy in the measurement period, usually 1 hour. Given 1143
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the sensitivity to noise increases during evening and nighttime hours when people are trying to sleep, 24‐hour descriptors have been developed that incorporate artificial noise penalties added to quiet‐time sounds. The Community Noise Equivalent Level, CNEL, is a measure of the day‐night noise exposure, with a 5-decibel penalty added to evening sounds (7:00 p.m. to 10:00 p.m.) and a 10 dBA addition to nighttime sounds (10:00 p.m. to 7:00 a.m.). The Ldn, or day‐ night average sound level, is equal to the 24‐hour equivalent sound level (in dBA) with a 10 decibel penalty applied to nighttime sounds occurring between 10:00 p.m. and 7:00 a.m.

Community noise levels are closely related to the intensity of human activity and land use.

Noise levels are generally considered low when ambient levels are below 45 dBA Leq, moderate in the 45 to 60 dBA Leq range, and high above 60 dBA Leq. In wilderness areas, the Ldn noise levels can be below 35 dBA. In small towns or wooded and lightly used residential areas, the Ldn is more likely to be approximately 50 or 60 dBA. Levels of approximately 75 dBA Leq are more common in busy urban areas (e.g. downtown Los Angeles), and levels up to 85 dBA Leq occur near major freeways and airports.

Although people often accept the higher levels associated with very noisy urban residential and residential‐commercial zones, the surrounding land uses dictate what noise levels would be considered acceptable or unacceptable. Lower levels are expected in rural or suburban areas than what would be expected for commercial or industrial zones. Nighttime ambient levels in urban environments are about seven decibels lower than the corresponding daytime levels. In rural areas, away from roads and other human activity, the day‐to‐night difference can be considerably less. Areas with full‐time human occupation that are subject to nighttime noise are often considered objectionable because of the likelihood of disrupting sleep. Noise levels higher than 45 dBA Ldn at night can result in the onset of sleep interference effects. At 70 dBA Ldn, sleep interference effects become considerable (U.S. EPA, 1974).

14.3.2 General Information on Vibration
Sources of groundborne vibrations include natural phenomena (earthquakes, volcanic eruptions, sea waves, landslides, etc.) or man-made causes (explosions, machinery, traffic, trains, construction equipment, etc.). Vibration sources may be continuous (e.g. factory machinery) or transient (e.g. explosions). Ground vibration consists of rapidly fluctuating motions or waves with an average motion of zero. Several different methods are typically used to quantify vibration amplitude, including Vibration Decibels (VdB), peak particle velocity (PPV), and the root mean square (RMS) velocity. VdB is the vibration velocity level in the decibel scale. PPV is defined as the maximum instantaneous positive or negative peak of the vibration wave. The RMS velocity is defined as the average of the squared amplitude of the signal. The PPV and RMS vibration velocity amplitudes are used to evaluate human response to vibration.

Table 14-2: Human Reaction and Damage to Buildings for Continuous or Frequent Intermittent Vibrations, displays the reactions of people and the effects on buildings produced by continuous vibration levels. The annoyance levels shown in the table should be interpreted with care since vibration may be found to be annoying at much lower levels than those listed, depending on the level of activity or the sensitivity of the individual. To sensitive individuals, 1144
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vibrations approaching the threshold of perception can be annoying. Low-level vibrations frequently cause irritating secondary vibration, such as a slight rattling of windows, doors, or stacked dishes. The rattling sound can give rise to exaggerated vibration complaints, even though there is very little risk of actual structural damage. In high noise environments, which are more prevalent where groundborne vibration approaches perceptible levels, this rattling phenomenon may also be produced by loud airborne environmental noise causing induced vibration in exterior doors and windows.

Table 14-2: Human Reaction and Damage to Buildings for Continuous or Frequent Intermittent Vibrations Maximum
PPV
(inch/sec)
Vibration Annoyance
Potential Criteria
Vibration Annoyance
Potential Criteria
FTA Vibration Damage
Criteria

0.008 -
Extremely fragile historic
buildings, ruins, ancient
monuments
-

0.01 Barely Perceptible - -

0.04 Distinctly Perceptible - -

0.1 Strongly Perceptible Fragile buildings -

0.12 - -
Buildings extremely
susceptible to vibration
damage

0.2 - - Non-engineered timber and
masonry buildings

0.25 - Historic and some old
buildings -

0.3 - Older residential structures Engineered concrete and masonry (no plaster)

0.4 Severe - -

0.5 -
New residential structures,
Modern
industrial/commercial
buildings
Reinforced-concrete, steel, or
timber (no plaster)
PPV = peak particle velocity; inch/sec = inches per second; FTA = Federal Transit Administration Source: California Department of Transportation, Transportation and Construction Vibration Guidance Manual, 2020; and Federal Transit Administration, Transit Noise and Vibration Assessment Manual, 2018.

Ground vibration can be a concern in instances where buildings shake, and substantial rumblings occur. However, it is unusual for vibration from typical urban sources such as buses and heavy trucks to be perceptible. Common sources for groundborne vibration are planes, trains, and construction activities such as earth-moving which requires the use of heavy-duty earth moving equipment. For the purposes of this analysis, a PPV descriptor with units of inches per second (inch/sec) is used to evaluate construction-generated vibration for building damage and human complaints.

14.3.3 Project Setting
The City of Dublin General Plan Noise Element (Noise Element), Figure 9-1: 2011 Existing Noise Exposure Contours, shows contours of 70 and 75 dB near I-580, 60 and 65 dB along Dublin 1145
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Boulevard, 60 and 65 dB along Tassajara Road, and 60 dB along Gleason Drive. Noise Element Figure 9-2: 2035 Projected Noise Exposure Contours, shows projected noise contours in 2035 and shows an increase to 70 dB along Dublin Boulevard.

The primary sources of stationary noise in the project vicinity are those associated with the operations of adjacent residential uses to the north and east, as well as commercial uses to the east and west. The noise associated with these sources may represent a single-event noise occurrence, short-term, or long-term/continuous noise.

14.3.4 Sensitive Receptors
Noise exposure standards and guidelines for various types of land uses reflect the varying noise sensitivities associated with each of these uses. Residences, hospitals, schools, guest lodging, libraries, and churches are treated as the most sensitive to noise intrusion and therefore have more stringent noise exposure targets than other uses, such as manufacturing or agricultural uses that are not subject to impacts such as sleep disturbance.

The closest sensitive receptors to the project site include residential uses located adjacent to the north, east, and west.

14.3.5 Existing Ambient Noise Measurements
To quantify existing ambient noise levels in the project area, Kimley-Horn and Associates conducted four short-term noise measurements on April 13, 2022 (see Appendix F and Figure 14-1: Noise Measurement Locations). Meteorological conditions consisted of cool temperatures (53 degrees Fahrenheit [F]), calm winds under six miles per hour (mph), and clear skies. The noise measurement sites were representative of typical existing noise exposure within and immediately adjacent to the project site. The 10-minute measurements were taken between 11:00 a.m. and 12:30 p.m. The noise measurements were taken during the midday hours, as the midday hours typically have the highest daytime noise levels in urban environments. The sound level meter and microphone were mounted on a tripod five feet above the ground. Short-term (Leq) measurements are considered representative of the noise levels throughout the day. The average noise levels and sources of noise measured at each location are listed in Table 14-3: Existing Noise Measurements.
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Table 14-3: Existing Noise Measurements
Site No. Location
Leq
(dBA)
Lmin
(dBA)
Lmax
(dBA) Peak Time
1 East of project site, within residential
neighborhood located at 4650 Rimini
Court

49.7 42.3 65.4 86.6 11:08 am
2 North of project site, within residential
neighborhood located at 5086 Osborne
Circle

53.4 36.2 73.7 100.5 11:45 am
3 West of project site, within residential
neighborhood located at 4865 Swinford
Court

57.3 42.9 68.9 90.7 12:04 pm
4 East of project site, within residential
neighborhood located at 4093
Clarinbridge Circle

52.5 45.6 67.6 79.9 10:40 am
Source: Kimley-Horn and Associates, 2022
As shown in Table 14-3: Existing Noise Measurements, the ambient recorded noise levels ranged from 49.7 dBA to 57.4 dBA Leq near the project site. The maximum noise levels in the project vicinity ranged from 65.4 dBA to 73.7 dBA. The field survey noted the most commonly present noises in the project vicinity are produced by automotive vehicles (cars, trucks, buses, and motorcycles) on local roadway traffic and landscaping equipment. Traffic moving along streets and freeways produces a sound level that remains relatively constant and is therefore a component of the City’s minimum ambient noise level. Vehicle noise varies with the volume, speed, and type of traffic. Slower traffic produces less noise than fast moving traffic. Trucks typically generate more noise than cars. Infrequent or intermittent noise also is associated with some vehicles, including sirens, vehicle alarms, slamming of doors, garbage and construction vehicle activity, and honking of horns. These noises add to urban noise and are regulated by a variety of agencies (as described below).

14.3.6 Existing Roadway Noise Levels
Existing roadway noise levels were calculated for the roadway segments in the project vicinity.

This task was accomplished using the Federal Highway Administration (FHWA) Highway Traffic Noise Prediction Model (FHWA-RD-77-108) and existing traffic volumes from the transportation analysis. The noise prediction model calculates the average noise level at specific locations based on traffic volumes, average speeds, roadway geometry, and site environmental conditions. The average vehicle noise rates (also referred to as energy rates) used in the FHWA model have been modified to reflect average vehicle noise rates identified for California by the California Department of Transportation (Caltrans). The Caltrans data indicates that California automobile noise is 0.8 to 1.0 dBA higher than national levels and that medium and heavy truck noise is 0.3 to 3.0 dBA lower than national levels. The average daily noise levels along roadway segments in proximity to the project site are included in Table 14-4: Existing Traffic Noise Levels.
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Table 14-4: Existing Traffic Noise Levels
Roadway Segment ADT
CNEL at 100 feet from
Centerline of Roadway (dBA)
Hacienda Drive
Central Parkway to Dublin Boulevard 13,530 62.3
Dublin Boulevard to I-580 WB Off Ramp 33,050 66.4
I-580 WB Off Ramp to I-580 EB Off Ramp 37,540 66.6
I-580 EB Off Ramp to Owens Drive 45,340 68.9
Tassajara Road
Fallon Road to Gleason Drive 25,250 67.3
Gleason Drive to Aviano Way 23,410 67.0
Aviano Way to Project Driveway 23,410 67.0
Project Driveway to Central Parkway 23,410 67.0
Central Parkway to Project Driveway (South Entry Level
Townhomes) 27,290 67.8
Project Driveway (South Entry Level Townhomes) to
Finnian Way
27,850 67.9
Finnian Way to Project Driveway (Affordable Housing) 27,100 67.9 Project Driveway (Affordable Housing) to Dublin Boulevard 27,100 67.9 Dublin Boulevard to Northside Drive 38,450 69.2
Northside Drive to I-580 WB Off-Ramp 39,360 69.2
I-580 WB Off-Ramp to Pimlico Drive 48,660 70.1
Saint Rita Road
I-580 WB Off-Ramp to Pimlico Drive 38,050 69.0
Brannigan Street
Gleason Drive to Aviano Way 3,250 53.4
Aviano Way to Central Parkway 3,700 54.0
Central Parkway to Finnian Way 2,200 51.8
Finnian Way to Project Driveway (South Family Homes) 3,140 53.3 Project Driveway (South Family Homes) to Dublin
Boulevard 3,140 53.3
Dublin Boulevard to Project Driveway (Commercial) 2,040 51.4 1148
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Roadway Segment ADT
CNEL at 100 feet from
Centerline of Roadway (dBA)
Fallon Road
Tassajara Road to Gleason Drive 14,050 63.6
Gleason Drive to Central Parkway 21,530 65.5
Central Parkway to Dublin Boulevard 25,190 67.4
Dublin Boulevard to I-580 WB Off Ramp 28,670 67.9
I-580 WB Off Ramp to I-580 EB Off Ramp 24,540 67.1
I-580 EB Off Ramp to W Jack London Boulevard 23,640 65.9 Gleason Drive
Tassajara Road to Project Driveway 9,410 61.7
Project Driveway to Brannigan Street 9,410 61.7
Brannigan Street to Grafton Street 7,170 60.6
Grafton Street to Fallon Road 6,960 60.5
Central Parkway
Hacienda Drive to Tassajara Road 7,110 59.2
Tassajara Road to Project Driveway (North Side) 9,040 60.3 Project Driveway (North Side) to Brannigan Street 9,040 60.3 Brannigan Street to Montalcino Street/Chancery Lane 7,940 59.7 Montalcino Street/Chancery Lane to Grafton Street 7,340 59.3 Grafton Street to Fallon Road 6,670 58.9
Dublin Boulevard
Hacienda Drive to Tassajara Road 27,760 68.0
Tassajara Road to Project Driveway (South Family Homes) 24,740 67.3 Project Driveway (South Family Homes) to Brannigan
Street
24,740 67.3
Brannigan Street to Grafton Street 21,530 66.9
Grafton Street to Keegan Street 19,610 66.5
Keegan Street to Lockhart Street 13,640 64.9
Lockhart Street to Fallon Road 14,570 65.2
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Notes: ADT = average daily trips; dBA = A-weighted decibels; CNEL = community noise equivalent level.

Data source: Based on traffic data within the transportation analysis for the SCS Dublin Project, prepared by Kimley-Horn, 2022. Refer to Appendix Ffor traffic noise modeling assumptions and results.

Source: Kimley-Horn and Associates, 2022
As depicted in Table 14-4: Existing Traffic Noise Levels, the existing traffic-generated noise levels on project-vicinity roadways currently ranges from 51.4 to 70.1 dBA CNEL. As previously described, CNEL is 24-hour average noise level with a 5 dBA “weighting” during the hours of 7:00 a.m. to 10:00 p.m. and a 10 dBA “weighting” added to noise during the hours of 10:00 p.m. to 7:00 a.m. to account for noise sensitivity in the evening and nighttime, respectively.

14.4 Applicable Regulations, Plans, and Standards

14.4.1 State
California Building Code
Title 24 of the California Code of Regulations contains standards for allowable interior noise levels associated with exterior noise sources. The standards apply to new hotels, motels, dormitories, apartment houses, and dwellings other than detached single-family residences.

The standards require interior noise level attributable to exterior sources not exceed 45 dBA CNEL in any habitable room. Multi-family residential structures proposed where the CNEL would exceed 60 dBA requires an acoustical analysis showing that the proposed building design would achieve the prescribed allowable interior noise standard.

In 1974, the California Commission on Housing and Community Development adopted noise insulation standards for multi-family residential buildings (Title 24, Part 2, California Code of Regulations). Title 24 establishes standards for interior room noise (attributable to outside noise sources). The regulations also specify that acoustical studies must be prepared whenever a multi-family residential building or structure is proposed to be located near an existing or adopted freeway route, expressway, parkway, major street, thoroughfare, rail line, rapid transit line, or industrial noise source, and where such noise source or sources create an exterior CNEL (or Ldn) of 60 dBA or greater. Such acoustical analysis must demonstrate that the residence has been designed to limit intruding noise to an interior CNEL (or Ldn) of at least 45 dBA.

California Noise Control Act of 1973
Sections 46000 through 46080 of the California Health and Safety Code, known as the California Noise Control Act, find that excessive noise is a serious hazard to public health and welfare, and that exposure to certain levels of noise can result in physiological, psychological, and economic damage. The Act also finds that there is a continuous and increasing bombardment of noise in urban, suburban, and rural areas. The California Noise Control Act declares that the State has a responsibility to protect the health and welfare of its citizens by the control, prevention, and abatement of noise. It is the policy of the State to provide an environment for all Californians that is free from noise that jeopardizes their health or welfare. 1150
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14.4.2 Local
City of Dublin General Plan
The Noise Element of the City of Dublin General Plan establishes residential, commercial, and industrial land use compatibility standards for noise measured at the property line of the receiving land use. The land use compatibility noise criteria provide the basis for decisions on location of land uses in relation to noise sources and for determining noise mitigation requirements.

Table 14-5: Land Use/Noise Compatibility Matrix shows the City of Dublin’s Land Use Compatibility for Community Noise Environments standards for specific land uses. As indicated, the normally acceptable exterior noise level is 70 dBA CNEL or less for office, retail, and commercial land uses (the types of land uses proposed for development with implementation of the project). Noise levels over 75 dBA CNEL are considered normally unacceptable for new development of these types of land uses. For residential land uses, the normally acceptable exterior noise level is 60 dBA CNEL or less and noise levels over 70 dBA CNEL are considered normally unacceptable.

Table 14-5: Land Use/Noise Compatibility Matrix
Land Use Category
Normally
Acceptable
Conditionally
Acceptable*
Normally
Unacceptable
Clearly
Unacceptable
Residential 60 or less 61-70 71-75 Over 75
Motels, hotels 60 or less 61-70 71-80 Over 80
Schools, churches, nursing homes 60 or less 61-70 71-80 Over 80 Neighborhood parks 60 or less 61-65 66-70 Over 70
Offices: retail commercial 70 or less 71-75 76-80 Over 80 Industrial 70 or less 71-75 Over 75
Notes:
*Conditionally acceptable exposure requires noise insulation features in building design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning will normally suffice.

Source: City of Dublin General Plan Noise Element, 1993, as amended. Table 9.1 General Plan Policies
The City of Dublin General Plan establishes the following policies associated with noise and vibration that are relevant to the project:

Guiding Policy 9.2.1.A.1: Where feasible, mitigate traffic noise to levels indicated by Table 9.1:

Land Use Compatibility for Community Noise Environments.

Implementing Policy 9.2.1.B.4: Noise impacts related to all new development shall be analyzed by a certified acoustic consultant.
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Implementing Policy 9.2.1.B.5: Request demonstration of ability to mitigate noise prior to approval of light rail or bus service in the Southern Pacific Right-of-Way Transportation Corridor.

A depressed rail line or noise walls close to the tracks could make light rail a good neighbor.

Implementing Policy 9.2.1.B.6: Review all multi-family development proposals within the projected 60 CNEL contour for compliance with noise standards (45 CNEL in any habitable room) as required by State law.

Because the General Plan designates almost all residential sites subject to 60 or greater CNEL for multifamily development, this standard will be effective in Dublin. Project designers may use one or more of four available categories of mitigation measures: site planning, architectural layout (bedrooms away from noise source, for example), noise barriers, or construction modifications.

Implementing Policy 9.2.1.B.7: Review all non-residential development proposals within the projected CNEL 65 dBA contour for compliance with exterior noise transmission standards as required by the California Green Building Standards Code.

The noise element specifies that project designers may use one or more of four available categories of mitigation measures: site planning, architectural layout (bedrooms away from noise source, for example), noise barriers, or construction modifications.

Eastern Dublin Specific Plan
The City of Dublin’s Eastern Dublin Specific Plan establishes the following policy associated with noise and vibration that are relevant to the project:

Policy 6-44: Require development along the I-580 frontage to provide adequate mitigation to conform to the State Land Use Compatibility Standards for noise and policies and standards in the City of Dublin's Noise Element.

City of Dublin Municipal Code
Noise regulations listed in the City of Dublin’s Municipal Code are enacted for the purpose of securing and promoting the public health, comfort, safety, welfare, and prosperity and the peace and quiet of the city and its inhabitants. The goal is to maintain and preserve the quiet atmosphere of the city, and to implement programs and enact legislation consistent with the objectives and goals set forth in the Noise Element of the General Plan and aimed at retaining noise levels throughout the city acceptable values established in the General Plan.

Code Section 5.28.020 prohibits any person within the City to from making any loud, or disturbing, or unnecessary, or unusual or habitual noise or any noise which annoys or disturbs or injures or endangers the health, repose, peace or safety of any reasonable person of normal sensitivity present in the area. Section 8.36.060(C)(3) states that lots less than 5,000 square feet with mechanical equipment that generates noise (such as swimming pool, spa, and air 1152
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conditioning equipment) on the property shall be enclosed as necessary to reduce noise at the property line to a maximum of 50 dBA at any time. For lots 5,000 square feet or larger, mechanical equipment that generates noise when located within a required setback as allowed by this subsection, and within 10 feet of an existing or potential residence, or an existing paved patio area on adjoining property, shall be enclosed as necessary to reduce noise at the property line to a maximum of 50 dBA at any time.

14.5 Environmental Impacts and Mitigation Measures

14.5.1 Significance Criteria
CEQA does not define what construction or operational noise level increase would be considered substantial. Typically, a noise increase of 3 dBA Ldn or greater at a residential receptor would be considered significant when existing ambient noise levels are between 60 and 65 dBA Ldn (FICON, 1992). A noise increase of 5 dBA Ldn or greater at the receptor would be considered a significant impact when existing ambient noise levels are less than 60 dBA Ldn (FICON, 1992). Noise due to construction activities is usually considered to be less than significant in terms of CEQA compliance if the construction activity is temporary and the use of heavy construction equipment and noisy activities are limited to daytime hours. As indicated above, the City of Dublin does not have separate noise standards for construction.

The following significance criteria for noise were derived from the Environmental Checklist in CEQA Guidelines Appendix G.

An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria.
 Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies (refer to Impact N-1).  Generate excessive groundborne vibration or groundborne noise levels (refer to Impact N-2).
 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, expose people residing or working in the project area to excessive noise levels. (refer to Impact N-3).

Significance Classifications
The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant. 1153
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Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.

Impacts Assessment Methodology
Construction
Construction noise estimates are based upon noise levels on typical noise levels generated by construction equipment published by the Federal Transit Administration (FTA) and Federal Highway Administration (FHWA). Construction noise is assessed in dBA Leq. This unit is appropriate because Leq can be used to describe noise level from operation of each piece of equipment separately, and levels can be combined to represent the noise level from all equipment operating during a given period. The FTA’s Transit Noise and Vibration Impact Assessment Manual (2018) (FTA Noise and Vibration Manual) identifies a maximum 8-hour noise level standard of 80 dBA Leq at residential uses and 90 dBA Leq at commercial and industrial uses for short-term construction activities.

Construction noise modeling was conducting using the FHWA Roadway Construction Noise Model (RCNM). Reference noise levels are used to estimate noise levels at nearby sensitive receptors based on a standard noise attenuation rate of 6 dB per doubling of distance (line-ofsight method of sound attenuation for point sources of noise). Construction noise level estimates do not account for the presence of intervening structures or topography, which may reduce noise levels at receptor locations. Therefore, the noise levels presented herein represent a conservative, reasonable worst-case estimate of actual temporary construction noise. As noted above, the City of Dublin does not establish quantitative construction noise standards and therefore, this analysis conservatively uses the FTA’s threshold of 80 dBA (8-hour Leq) for residential uses and 90 dBA (8-hour Leq) for non-residential uses to evaluate construction noise impacts. The construction noisemodeling assumptions and outputs are provided in Appendix F of thisEIR.

Operational
The analysis of the existing and future noise environments is based on noise prediction modeling and empirical observations. Reference noise level data are used to estimate the project operational noise impacts from stationary sources. Noise levels are collected from field noise measurements and other published sources from similar types of activities are used to estimate noise levels expected with the project’s stationary sources. The reference noise levels are used to represent a worst-case noise environment as noise levels from stationary sources can vary throughout the day.
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Traffic noise impacts are assessed using the U.S. Federal Highway Traffic Noise Prediction Model (FHWA-RD-77-108). Model input data includes without- and with-project average daily traffic volumes on adjacent roadway segments, day/night percentages of autos, medium and heavy trucks, vehicle speeds, ground attenuation factors, and roadway widths. The roadway speeds are based on the posted speed limits observed during site visits. The model analyzed the noise impacts from the nearby roadways onto the project vicinity, which consists of the area that has the potential of being impacted from the on-site noise sources as well as the project-generated traffic on the nearby roadways. The roadway traffic model input assumptions are presented in Appendix F.

Vibration
Groundborne vibration levels associated with construction-related activities for the project were evaluated utilizing typical groundborne vibration levels associated with construction equipment, obtained from FTA published data for construction equipment. Potential groundborne vibration impacts related to structural damage and human annoyance were evaluated, considering the distance from construction activities to nearby land uses and typically applied criteria for structural damage and human annoyance.

14.5.2 Summary of No and/or Beneficial Impacts
There are no “no” impacts nor “beneficial” impacts.

14.5.3 Impacts of the Proposed Project
Impact N-1: Would the Project generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? (Class II) Construction
There are two types of short-term noise impacts associated with construction, noise generated from equipment and increase in traffic flow on local streets.

Equipment Noise
Construction noise typically occurs intermittently and varies depending on the nature or phase of construction (e.g. land clearing, grading, excavation, paving). Noise generated by construction equipment, including earth movers, material handlers, and portable generators, can reach high levels. During construction, exterior noise levels could affect the residential neighborhoods surrounding the construction site. The nearest sensitive receptors to the project construction area are existing residential uses to the north, with the nearest residential building located approximately 30 feet from the construction area. However, it is acknowledged that construction activities would occur throughout the project site and would not be concentrated at a single point near sensitive receptors. 1155
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Construction activities would include site preparation, grading, paving, building construction, and architectural coating applications. Such activities would require dozers and tractors during site preparation; excavators, graders, dozers, scrapers, and tractors during grading; cranes, forklifts, generators, pavers, paving equipment, rollers, tractors, and welders during building construction; pavers, air compressors, paving equipment, and rollers during paving; and air compressors during architectural coating applications. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 to 4 minutes at lower power settings. Other primary sources of acoustical disturbance would be random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts). Typical noise levels associated with individual construction equipment are listed in Table 14-6: Typical Construction Equipment Noise Levels.

Table 14-6: Typical Construction Equipment Noise Levels Equipment Onsite Typical Level (dBA) 50 Feet
from the Source
Air Compressor 80
Backhoe 80
Compactor 82
Concrete Mixer 85
Concrete Pump 82
Concrete Vibrator 76
Crane, Derrick 88
Crane, Mobile 83
Dozer 85
Generator 82
Grader 85
Impact Wrench 85
Jack Hammer 88
Loader 80
Paver 85
Pump 77
Roller 85
Saw 76
Scraper 85
Shovel 82
Truck 84
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018
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The FHWA Roadway Construction Noise Model (RCNM) was used to calculate the worst-case construction noise levels at nearby sensitive receptors surrounding the project site during construction. The modeled receptor locations represent the closest existing receiving land uses to project construction activities. Noise levels at other sensitive receptors surrounding the project site would be located further away and would experience lower construction noise levels than the closest receptors modeled.

The Municipal Code does not establish quantitative exterior construction noise standards and therefore, this analysis conservatively uses the FTA’s threshold of 80 dBA (8-hour Leq) for residential uses and 90 dBA (8-hour Leq) for non-residential uses to evaluate construction noise impacts.13
The noise levels calculated in Table 14-7: Project Construction Noise Levels show estimated exterior noise levels for the worst-case construction noise scenario without accounting for attenuation from intervening barriers, structures, or topography. Because site preparation, grading, and infrastructure activities are anticipated to overlap, the equipment from these phases have been combined. Further, the equipment from the building construction and paving phases have been combined, as these phases are also anticipated to overlap. During construction, equipment would operate throughout the project site and the associated noise levels would not occur at a fixed location for extended periods of time.

Table 14-7: Project Construction Noise Levels
Construction
Phase/Activity
Receptor Location Estimated
Exterior
Construction
Noise Level
(dBA Leq)
Noise
Threshold
(dBA
Leq)2
Exceeded?
Land Use Direction Distance1
Site Preparation /
Grading /
Infrastructure
Residential North 500 71.6 80 No
Commercial East 500 71.6 90 No
Building Construction /
Paving
Residential North 500 71.5 80 No
Commercial East 500 71.5 90 No
Notes:

1. Following FTA methodology, all equipment is assumed to operate at the center of the project site because equipment would operate throughout the project site and not at a fixed location for extended periods of time. Thus, the worst-case distance used in the RCNM model was 500 feet to the residential property line north of the construction zone and 500 feet to the commercial property line east of the construction zone.

2. The FTA Noise and Vibration Manual establishes construction noise standards of 80 dBA Leq(8-hour) for residential uses and 90 dBA Leq(8-hour) for commercial and industrial uses.

Source: Federal Highway Administration, Roadway Construction Noise Model, 2006. Refer to Appendix F for noise modeling results. 13 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, Table 7-2, Page 179, September 2018. 1157
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As shown in Table 14-7, construction noise levels would range from approximately 71.5 to 71.6 dBA Leq at the nearest residential and commercial receptors, which would not exceed the FTA’s construction noise standards of 80 dBA Leq and/or 90 dBA Leq. Notwithstanding, the project would be required to implement MM N-1.1: Construction Noise Reduction to reduce construction noise levels. MM N-1.1 would require construction best management practices and limit noise-generating construction activities to occur between the daytime hours of 7:00 a.m. to 7:00 p.m., Monday through Saturday and non-City holidays. Implementation of the construction noise best management practices would ensure that construction noise would not result in annoyance or disturbance or injury or endangerment of the health, repose, peace or safety of any reasonable person of normal sensitivity residing in the project vicinity. With implementation of MM N-1.1, impacts would be reduced to a less than significant level.

Construction Traffic Noise
Construction activities would cause increased noise along access routes to and from the project site due to movement of equipment and workers, as well as hauling trips. Grading at the project site would require approximately 93,600 cubic yards of import, which would result in approximately 11,700 hauling trips.14 It is anticipated that construction worker trips would be a maximum of 951 trips per day, and vendor trips would be a maximum of 285 trips per day.15 As a result, mobile source noise would increase along access routes to and from the project site during construction. However, mobile traffic noise from construction trips would be temporary and would cease upon completion of project construction.

According to the Highway Traffic Noise Analysis and Abatement Policy and Guidance, a doubling of traffic volumes would result in a 3 dB increase in traffic noise levels, which is barely detectable by the human ear. As shown in Table 14-4: Existing Traffic Noise Levels, all roadway segments in the project vicinity have greater than 2,039 average daily trips (ADT). Project construction trips would result in a maximum of 1,236 trips per day during the building construction phase. Therefore, project-generated construction trips (i.e., 1,236 trips per day) would not double existing traffic volumes (i.e. 2,039 ADT). It should be noted that this analysis conservatively assumes that every single project-generated construction trip would travel along one roadway segment. However, in reality, the project’s construction trips would be distributed along the surrounding local roadways. Thus, the project-generated construction trips would not have the potential to significantly increase traffic noise volumes in the project vicinity and impacts would be less than significant. Additionally, the combination of on-site construction equipment and construction traffic noise would not exceed the FTA threshold. 14 Ibid.
15 Ibid.
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14.5.4 Operations
Implementation of the project would create new sources of noise in the project vicinity. The major noise sources associated with the project that would potentially impact existing and future nearby residences include the following:
 Traffic noise;
 Mechanical equipment (i.e., trash compactors, air conditioners, etc.);  Slow moving delivery/supply trucks on the project site, approaching and leaving the loading areas;
 Activities at the loading areas (i.e., maneuvering and idling trucks, banging and clanging of equipment); and
 Parking areas (i.e., car door slamming, car radios, engine start-up, and car pass-by).

Traffic Noise
The proposed project would result in additional traffic on adjacent roadways from daily activities, thereby increasing vehicular noise in the vicinity of existing and proposed land uses.

Based on the transportation analysis, typical daily activities are forecast to generate 10,983 average daily trips. In general, traffic noise level increases of less than 3 dBA is barely perceptible to people, while a 5‐dBA increase is readily noticeable (Caltrans, 2013). Generally, traffic volumes on project area roadways would have to approximately double for the resulting traffic noise levels to increase by 3 dBA. Therefore, permanent increases in ambient noise levels of less than 3 dBA are considered to be less than significant.

Traffic noise levels for roadways primarily affected by the project were calculated using the FHWA’s Highway Noise Prediction Model (FHWA-RD-77-108). Traffic noise modeling was conducted for conditions with and without the project, based on traffic volumes obtained from the transportation analysis. The calculated traffic noise levels for the “Near Term Without Project” and “Near Term With Project” scenarios are compared in Table 14-8: Near Term and Near Term Plus Project Traffic Noise Levels. As described in Table 14-8, under the “Near Term Without Project” scenario, noise levels would range from approximately 52.7 dBA to 70.7 dBA, with the highest noise levels occurring along the Dublin Boulevard segment from Tassajara Road to Brannigan Street. The “Near Term With Project” scenario noise levels would range from approximately 53.7 dBA to 70.8 dBA, with the highest noise levels also occurring along the Dublin Boulevard segment from Tassajara Road to Brannigan Street. 1159
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Table 14-8: Near Term and Near Term Plus Project Traffic Noise Levels Roadway
Near Term
Without Project
Noise Level
(dBA CNEL)
Near Term
With
Project
Noise Level
(dBA CNEL) Change
Significant
Impact
Hacienda Drive
Central Parkway to Dublin Boulevard 62.5 62.5 0.0 No
Dublin Boulevard to I-580 WB Off Ramp 67.1 67.2 0.1 No
I-580 WB Off Ramp to I-580 EB Off Ramp 67.1 67.2 0.1 No I-580 EB Off Ramp to Owens Drive 69.0 69.1 0.1 No
Tassajara Road
Fallon Road to Gleason Drive 68.0 68.0 0.0 No
Gleason Drive to Aviano Way 67.6 67.7 0.1 No
Aviano Way to Project Driveway 67.6 67.7 0.1 No
Project Driveway to Central Parkway 67.6 67.7 0.1 No
Central Parkway to Project Driveway (South
Entry Level Townhomes) 68.1 68.3 0.2 No
Project Driveway (South Entry Level
Townhomes) to Finnian Way 68.2 68.3 0.1 No
Finnian Way to Project Driveway
(Affordable Housing) 68.2 68.6 0.4 No
Project Driveway (Affordable Housing) to
Dublin Boulevard 68.2 68.6 0.4 No
Dublin Boulevard to Northside Drive 69.9 70.2 0.3 No
Northside Drive to I-580 WB Off-Ramp 69.9 70.2 0.3 No
I-580 WB Off-Ramp to Pimlico Drive 70.5 70.7 0.2 No
Saint Rita Road
I-580 WB Off-Ramp to Pimlico Drive 69.2 69.4 0.2 No
Brannigan Street
Gleason Drive to Aviano Way 54.4 54.6 0.2 No
Aviano Way to Central Parkway 54.9 55.4 0.5 No
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Roadway
Near Term
Without Project
Noise Level
(dBA CNEL)
Near Term
With
Project
Noise Level
(dBA CNEL) Change
Significant
Impact
Central Parkway to Finnian Way 52.7 53.7 1.0 No
Finnian Way to Project Driveway (South
Family Homes) 54.0 55.2 1.2 No
Project Driveway (South Family Homes) to
Dublin Boulevard 54.0 55.6 1.6 No
Dublin Boulevard to Project Driveway
(Commercial) 51.6 54.4 2.8 No
Fallon Road
Tassajara Road to Gleason Drive 64.2 64.2 0.0 No
Gleason Drive to Central Parkway 66.5 66.5 0.0 No
Central Parkway to Dublin Boulevard 68.1 68.1 0.0 No
Dublin Boulevard to I-580 WB Off Ramp 68.6 68.7 0.1 No
I-580 WB Off Ramp to I-580 EB Off Ramp 67.6 67.7 0.1 No I-580 EB Off Ramp to W Jack London
Boulevard 66.5 66.6 0.1 No
Gleason Drive
Tassajara Road to Project Driveway 62.0 62.1 0.1 No
Project Driveway to Brannigan Street 62.0 62.1 0.1 No
Brannigan Street to Grafton Street 61.0 61.1 0.1 No
Grafton Street to Fallon Road 60.7 60.7 0.0 No
Central Parkway
Hacienda Drive to Tassajara Road 60.7 60.9 0.2 No
Tassajara Road to Project Driveway (North
Side) 61.8 62.0 0.2 No
Project Driveway (North Side) to Brannigan
Street 61.8 61.9 0.1 No
Brannigan Street to Montalcino
Street/Chancery Lane 61.6 61.7 0.1 No
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Roadway
Near Term
Without Project
Noise Level
(dBA CNEL)
Near Term
With
Project
Noise Level
(dBA CNEL) Change
Significant
Impact
Montalcino Street/Chancery Lane to
Grafton Street 62.0 62.1 0.1 No
Grafton Street to Fallon Road 62.2 62.3 0.1 No
Dublin Boulevard
Hacienda Drive to Tassajara Road 70.6 70.7 0.1 No
Tassajara Road to Project Driveway (South
Family Homes) 70.7 70.8 0.1 No
Project Driveway (South Family Homes) to
Brannigan Street 70.7 70.8 0.1 No
Brannigan Street to Grafton Street 70.5 70.6 0.1 No
Grafton Street to Keegan Street 70.5 70.5 0.0 No
Keegan Street to Lockhart Street 69.9 69.9 0.0 No
Lockhart Street to Fallon Road 70.0 70.0 0.0 No
East of Fallon Road 68.3 68.3 0.0 No
Source: Noise modeling is based on traffic data within the transportation analysis for the SCS Dublin Project, prepared by Kimley-Horn, 2022.

As depicted in Table 14-8: Near Term and Near Term Plus Project Traffic Noise Levels, the “Near Term With Project” traffic noise levels would not exceed the 3.0 dBA increase significance threshold along any of the surrounding roadways. As a result, the project would not result in a perceptible increase in traffic noise levels and impacts would be less than significant.

On-Site Mobile Noise
Future residents at the project site would be exposed to mobile traffic noise along Tassajara Road, Dublin Boulevard, Central Parkway, Brannigan Street, and Gleason Drive. Table 14-8:

Near Term and Near Term Plus Project Traffic Noise Levels identifies traffic noise levels at 100 feet from the roadway centerline. As shown in Table 14-8, the “Near Term With Project” traffic noise levels along adjacent roadways (i.e. Tassajara Road, Dublin Boulevard, Central Parkway, and Gleason Drive) would range from 61.9 to 70.8 dBA CNEL. Therefore, future on-site residences facing adjacent roadways would experience traffic noise levels above the City’s 60 dBA Normally Acceptable exterior standard for residential uses and the City’s 45 dBA interior standard per the State Building Code and Implementing Policy 9.2.1.B.6. 1162
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As such, the project would be required to comply with MM N-1.2: Noise Attenuation, which requires a detailed acoustical study demonstrating that all residential units would meet the City’s 60 dBA exterior noise standard for all common outdoor living areas through any necessary noise reduction features (barriers, berms, enclosures, etc.). Further, MM N-1.2 also requires all residential units to be designed to ensure that interior noise levels in habitable rooms from exterior sources (including vehicles on adjacent roadways) not exceed 45 dBA, in compliance with Title 24 of the California Code of Regulations and Implementing Policy

9.2.1.B.6. Compliance with MM N-1.2 would ensure on-site mobile noise impacts would be less than significant.

Mechanical Equipment
Regarding mechanical equipment, the project would generate stationary-source noise associated with heating, ventilation, and air conditioning (HVAC) units. Such HVAC units typically generate noise levels of approximately 52 dBA at a reference distance of 50 feet 16 from the operating units during maximum heating or air conditioning operations, which would attenuate to 46 dBA at 100 feet. The nearest existing sensitive receptors would be located more than 100 feet from the commercial and mixed-use areas of the project site. The proposed PA-4 single family residential areas would be located adjacent to existing residences (north of Gleason Drive). However, the mechanical equipment associated with the proposed residences would be similar to the existing uses and would also be buffered by an existing wall, a proposed road and existing and proposed setbacks and would be approximately 100 feet away from the closest residences. Given that existing sensitive receptors would be located beyond 100 feet from on-site HVAC units, noise generated by HVAC units would not result in a significant impact.

Slow Moving Trucks (Deliveries) and Loading Areas
Potential noise impacts with the project’s commercial uses would be associated primarily with truck deliveries. The primary noise associated with truck deliveries is the arrival and departure of trucks. Noise sources at truck loading areas may include maneuvering and idling trucks, truck refrigeration units, forklifts, banging and clanging of equipment (i.e., hand carts and rollup doors), and voices of truck drivers and employees. The closest sensitive receptors would be located 400 feet or more away from proposed commercial loading areas and in most cases, would not have a direct line of sight to the loading areas.

Delivery truck loading/unloading activities typically result in maximum noise levels from 68 dBA at 30 feet.17 These activities are expected to occur intermittently throughout the day, as trucks arrive and leave the parking lot areas for deliveries. Delivery truck noise at the existing sensitive receptors would be attenuated to 45.5 dBA and would not exceed the City’s Normally 16 Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden, Noise Navigator Sound Level Database with Over 1700 Measurement Values, June 26, 2015. 17 Loading dock reference noise level measurements conducted by Kimley-Horn on December 18, 2018. 1163
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Acceptable standard of 60 dBA. Therefore, truck delivery noise impacts would be less than significant.

Parking Areas
The instantaneous maximum sound levels generated by a car door slamming, engine starting up, and car pass-bys range from 53 to 61 dBA.18 Conversations in parking areas may also be an annoyance to adjacent sensitive receptors. Sound levels of speech typically range from 33 dBA at 50 feet for normal speech to 50 dBA at 50 feet for very loud speech.19 These activities are expected to occur intermittently throughout the day, as residents, visitors, and employees arrive and leave the parking areas. As such, noise associated with parking lots is typically not of sufficient volume to exceed community noise standards, which are based on a time-averaged scale such as the CNEL scale. While the instantaneous maximum sound levels generated by a car door slamming, engine starting up, and car pass-bys may be an annoyance, noise levels are not a significant impact.

The nearest sensitive receptors would be the residences located approximately 120 feet to the east of potential non-residential parking areas within the project site. At this distance, noise levels would attenuate to 53.4 dBA. As parking lot noise levels would not exceed the City’s 60 dBA standard, project-related parking lot noise impacts would be less than significant.

Operations Conclusion
Overall, with implementation of MM N-1.2: Noise Attenuation and adherence to Municipal Code requirements, noise impacts associated with traffic, mechanical equipment, deliveries, loading/unloading activities, and parking lot noise would be reduced to a less than significant level.

Mitigation for Impact N-1
MM N-1.1 Construction Noise Reduction
To reduce the effects of construction noise, the City of Dublin shall ensure that the project applicants include the following on all construction contracts for the project:
 All construction operations shall comply with local noise standards and be limited to normal daylight hours. All stationary equipment shall be adequately muffled and located away from sensitive receptors. The construction contractor shall limit all on-site noise-producing construction activities, including deliveries and warming up of equipment, to the daytime hours of 7:00 a.m. to 7:00 p.m., Monday through Saturday, and non-City holidays.
18 Kariel, H. G., Noise in Rural Recreational Environments, Canadian Acoustics 19(5), 3-10, 1991. 19 Elliott H. Berger, Rick Neitzel, and Cynthia A. Kladden. Noise Navigator Sound Level Database with Over 1700 Measurement Values, July 6, 2010.
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 The construction contractor shall ensure that all internal combustion engine-driven equipment is equipped with mufflers that are in good condition and appropriate for the equipment.
 The construction contractor shall locate stationary noise-generating equipment as far as possible from sensitive receptors when sensitive receptors adjoin or are near a construction project area. In addition, the project contractor shall place such stationary construction equipment so that emitted noise is directed away from sensitive receptors nearest the project site.
 The construction contractor shall prohibit unnecessary idling of internal combustion engines.
 The construction contractor shall, to the maximum extent practical, locate on-site equipment staging areas so as to maximize the distance between construction- related noise sources and noise-sensitive receptors nearest the project site during all project construction.
 The construction contractor shall designate a noise disturbance coordinator who would be responsible for responding to any local complaints about construction noise. When a complaint is received, the disturbance coordinator shall notify the City within 24 hours of the complaint and determine the cause of the noise complaints (starting too early, bad muffler, etc.) and institute reasonable measures warranted to correct the problem, as deemed acceptable by the City of Dublin Community Development Department. The construction contractor shall conspicuously post the contact name and telephone number for the noise disturbance coordinator at the construction site.

MM N-1.2 Noise Attenuation
As part of the Site Development Review Permit process for Planning Areas 2, 3, and 4, a detailed acoustical study based on architectural plans shall be prepared by a qualified acoustical consultant and submitted to the City of Dublin Community Development Department to demonstrate that all residential units would meet the City’s 60 dBA exterior noise standard for all common outdoor living areas. In addition, the acoustical study shall demonstrate that interior noise levels at all residential units at the project site would meet the City’s 45 dBA threshold. This mitigation measure complies with the applicable sections of the California Building Code (Title 24 of the California Code of Regulations) and Implementing Policy 9.2.1.B.6.

The necessary noise reduction may be achieved by implementing noise control measures at the receiver locations. Where closed windows are required to achieve the interior 45 dBA CNEL limit, project plans and specifications shall include ventilation as required by the California Building Code. The final grading and building plans shall incorporate the required noise barriers (patio enclosure, wall, berm, or combination wall/berm), and the property owner/developer shall install these barriers and enclosures.
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Impact N-2: Would the Project generate excessive groundborne vibration or groundborne noise levels? (Class III)

14.5.5 Construction
Increases in groundborne vibration levels attributable to the project would be primarily associated with construction-related activities. Construction on the project site would have the potential to result in varying degrees of temporary groundborne vibration, depending on the specific construction equipment used and the operations involved. Ground vibration generated by construction equipment spreads through the ground and diminishes in magnitude with increases in distance. The effect on buildings located in the vicinity of the construction site often varies depending on soil type, ground strata, and construction characteristics of the receiver building(s). The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels. Groundborne vibrations from construction activities rarely reach levels that damage structures.

Construction-related ground vibration is normally associated with impact equipment such as pile drivers, jackhammers, and the operation of some heavy-duty construction equipment, such as dozers and trucks. Vibration decreases rapidly with distance.

The Federal Transit Administration (FTA) has published standard vibration velocities for construction equipment operations. In general, depending on the building category of the nearest buildings adjacent to the potential pile driving area, the potential construction vibration damage criteria vary. For example, for a building that is constructed with reinforced concrete with no plaster, the FTA guidelines show that a vibration level of up to 0.50 inch per second (inch/sec) peak particle velocity (PPV) is considered safe and would not result in any construction vibration damage.

The FTA architectural damage criterion for continuous vibrations for non-engineered timber and masonry buildings (i.e., 0.20 inch/second) appears to be conservative. The types of construction vibration impact include human annoyance and building damage. Human annoyance occurs when construction vibration rises significantly above the threshold of human perception for extended periods of time. Building damage can be cosmetic or structural.

Ordinary buildings that are not particularly fragile would not experience any cosmetic damage (e.g., plaster cracks) at distances beyond 30 feet. This distance can vary substantially depending on the soil composition and underground geological layer between vibration source and receiver.

In addition, not all buildings respond similarly to vibration generated by construction equipment. The City of Dublin does not provide numerical vibration standards for construction activities. Therefore, this impact discussion uses FTA standard of 0.20 inch/second PPV with respect to the prevention of structural damage for normal buildings and human annoyance. 1166
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Construction of the project could potentially include impact-pile driving or drilling. The nearest structures to project construction activities, with the exception of pile driving, would be the residential buildings located approximately 30 feet to the north. Additionally, pile driving activities may occur during construction of the multi-family parking garage. As such, the nearest structures (residential buildings) may be located as close as 100 feet east of potential pile driving activities. Table 14-9: Typical Construction Equipment Vibration Levels, identifies vibration levels feet for typical construction equipment.

Based on FTA data, vibration velocities from typical heavy construction equipment operations that would be used during project construction would range from 0.003 to 0.644 inch/second PPV at 25 feet from the source of activity. It is also acknowledged that construction activities would occur throughout the project site and would not be concentrated at the point closest to the nearest structure.

At the closest structures and sensitive receptors are located approximately 30 feet away, vibration from typical equipment for construction activities (i.e., excluding pile drivers) would range from 0.002 to 0.068 inch/second PPV. At 100 feet (i.e., the closest distance for structures and sensitive receptors to pile driving activities) vibration generated from pile driving would range from 0.021 to 0.081 inch/second PPV. Therefore, vibration from construction activities experienced at the nearest structure and sensitive receptor would not exceed the 0.20 inch/second PPV significance threshold.

Table 14-9: Typical Construction Equipment Vibration Levels Equipment Type
Reference Peak Particle
Velocity at 25 Feet
(inches per second)
Peak Particle Velocity at
30 Feet (inches per
second)2
Peak Particle Velocity at
100 Feet (inches per
second)2
Pile Driver (impact)1 0.644 -- 0.081
Pile Driver (sonic)1 0.170 -- 0.021
Large Bulldozer 0.089 0.068 0.011
Caisson Drilling 0.089 0.068 0.011
Loaded Trucks 0.076 0.058 0.010
Rock Breaker 0.059 0.045 0.007
Jackhammer 0.035 0.027 0.004
Small Bulldozer/Tractor 0.003 0.002 <0.001
Notes: -- = not applicable

1. Pile driving activities would not occur within 100 feet of existing structures.

2. Calculated using the following formula:

PPV equip = PPVref x (25/D)1.5, where:

PPV (equip) = the peak particle velocity in inch per second of the equipment adjusted for the distance PPV (ref) = the reference vibration level in inch per second from Table 7-4 of the FTA Transit Noise and Vibration Impact Assessment Manual (September 2018)
D = the distance from the equipment to the receiver
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As noted above, the 0.20 inch/second PPV threshold is conservative because the construction vibration damage criteria for non-engineered timber and masonry buildings. Buildings would be better represented by the 0.50 inch/second PPV significance threshold (construction vibration damage criteria for reinforced concrete, steel or timber buildings). Because construction equipment vibration levels would not exceed the significance thresholds, impacts would be less than significant.

14.5.6 Operations
The project would not generate groundborne vibration that could be felt at surrounding uses.

Project operations would not involve railroads or substantial heavy truck operations, and therefore would not result in vibration impacts at surrounding uses. As a result, impacts from vibration associated with project operation would be less than significant.

Impact N-3: 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? (Class III)
The nearest public airport is the Livermore Municipal Airport located approximately 2.5 miles southeast of the project site. The ALUCP shows the project within the Airport Influence Area, Airport Safety Zone 7 as shown in Figure 11-1: Livermore Municipal Airport Safety Compatibility Zones. According to the ALUC, no restrictions on residential development shall apply to portions of Zone 7 that extend beyond the boundary of the Airport Protection Area.

Although, the project is partially within the Airport Influence Area, it is not within the airport protection Area and is outside of the 55 CNEL noise contour. There are no private airstrips near the project site. Impacts would be less than significant in this regard.

14.5.7 Cumulative Impacts
The geographic area for the analysis of cumulative impacts to noise is the City of Dublin.

Impact N-4: Contribute to cumulatively considerable impacts on noise? (Class II) Cumulative Construction Noise
The project’s construction activities would result in a substantial temporary increase in ambient noise levels. There would be periodic, temporary, significant noise impacts that would cease upon completion of construction activities. The project would contribute to construction noise impacts if other developments proximate to the project site occur concurrent with the project.

However, based on the noise analysis above, the project’s construction noise impacts would be less than significant with implementation of MM N-1.1: Construction Noise Reduction. Based on the fact that noise dissipates as it travels away from its source, noise impacts from on-site construction activities would be limited to the project site and vicinity. Thus, cumulative 1168
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operational noise impacts from related projects, in conjunction with project-specific noise impacts, would not be cumulatively significant.

Cumulative Operational Noise
Cumulative noise impacts describe how much noise levels are projected to increase over existing conditions with the development of the project and other foreseeable projects.

Cumulative noise impacts would occur primarily as a result of increased traffic on local roadways due to buildout of the project and other projects in the vicinity. Cumulative increases in traffic noise levels were estimated by comparing the Cumulative Without Project and Cumulative With Project scenarios to existing conditions. The transportation analysis considers cumulative traffic from future growth assumed in the traffic model, as well as cumulative projects identified by the City of Dublin.

A project’s contribution to a cumulative traffic noise increase would be considered significant when the combined effect exceeds perception level (i.e., auditory level increase) threshold.

The following criteria is used to evaluate the combined effect of the cumulative noise increase.  Combined Effect. The cumulative with project noise level (“Cumulative With Project”) would cause a significant cumulative impact if a 3.0 dB increase over “Existing” conditions occurs and the resulting noise level exceeds the applicable exterior standard at a sensitive use. Although there may be a significant noise increase due to the project in combination with other related projects (combined effects), it must also be demonstrated that the project has an incremental effect. In other words, a significant portion of the noise increase must be due to the project.

The following criteria have been used to evaluate the incremental effect of the cumulative noise increase.
 Incremental Effects. The “Cumulative With Project” causes a 1.0 dBA increase in noise over the “Cumulative Without Project” noise level.

A significant impact would result only if both the combined and incremental effects criteria have been exceeded. Noise by definition is a localized phenomenon, and reduces as distance from the source increases. Consequently, only the project and growth due to occur in the general area would contribute to cumulative noise impacts. Table 14-10: Cumulative Plus Project Conditions Predicted Traffic Noise Levels identifies the traffic noise effects along roadway segments in the vicinity of the project site for “Existing,” “Cumulative Without Project,” and “Cumulative With Project,” conditions, including incremental and net cumulative impacts.

First, it must be determined whether the “Cumulative With Project” 3.0 dB increase above existing conditions (Combined Effects) is exceeded. Next, under the Incremental Effects criteria, cumulative noise impacts are defined by determining if the forecast ambient (“Cumulative 1169
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Without Project”) noise level is increased by 1 dB or more. As shown in Table 14-10, the proposed project would exceed the combined effects criterion of 3.0 dB along the following roadways: Brannigan Street, Central Parkway, and Dublin Boulevard. However, the incremental effects criterion of 1 dB would not be exceeded along any of the roadway segments in the project vicinity.

As indicated in Table 14-10, the cumulative increase in traffic noise levels, as a result of the proposed project and cumulative projects, would not exceed the combined and incremental effects criteria along any of the surrounding roadways. Therefore, the project, in combination with cumulative background traffic noise levels, would result in a less than significant cumulative impact. The project’s contribution to traffic noise would not be cumulatively considerable.
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Table 14-10: Cumulative Plus Project Conditions Predicted Traffic Noise Levels Roadway Segment
Existing
Cumulative
Without
Project
Cumulative
With
Project
Combined
Effects
Incremental
Effects
Cumulatively
Significant
Impact?
dBA @
100 Ft
from
Centerline
dBA @ 100
Ft from
Centerline
dBA @ 100
Ft from
Centerline
dBA
Difference:

Existing
and
Cumulative
With
Project
dBA
Difference:

Cumulative
Without
and With
Project
Hacienda Drive
Central Parkway to Dublin
Boulevard 62.3 63.7 63.6 1.3 -0.1 No
Dublin Boulevard to I-580
WB Off Ramp 66.4 67.7 67.7 1.3 0.0 No
I-580 WB Off Ramp to I-580
EB Off Ramp 66.6 67.3 67.3 0.7 0.0 No
I-580 EB Off Ramp to Owens
Drive 68.9 69.3 69.3 0.4 0.0 No
Tassajara Road
Fallon Road to Gleason Drive 67.3 68.5 68.4 1.1 -0.1 No Gleason Drive to Aviano
Way 67.0 67.4 67.4 0.4 0.0 No
Aviano Way to Project
Driveway 67.0 67.4 67.4 0.4 0.0 No
Project Driveway to Central
Parkway 67.0 67.4 67.4 0.4 0.0 No
Central Parkway to Project
Driveway (South Entry Level
Townhomes)

67.8 67.7 67.5 -0.3 -0.2 No
Project Driveway (South
Entry Level Townhomes) to
Finnian Way

67.9 67.7 67.6 -0.3 -0.1 No
Finnian Way to Project
Driveway (Affordable
Housing)

67.9 68.0 67.8 -0.1 -0.2 No
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Roadway Segment
Existing
Cumulative
Without
Project
Cumulative
With
Project
Combined
Effects
Incremental
Effects
Cumulatively
Significant
Impact?
dBA @
100 Ft
from
Centerline
dBA @ 100
Ft from
Centerline
dBA @ 100
Ft from
Centerline
dBA
Difference:

Existing
and
Cumulative
With
Project
dBA
Difference:

Cumulative
Without
and With
Project
Project Driveway (Affordable
Housing) to Dublin
Boulevard

67.9 68.0 67.9 0.0 -0.1 No
Dublin Boulevard to
Northside Drive 69.2 70.1 70.2 1.0 0.1 No
Northside Drive to I-580 WB
Off-Ramp 69.2 70.6 70.5 1.3 -0.1 No
I-580 WB Off-Ramp to
Pimlico Drive 70.1 71.0 70.9 0.8 -0.1 No
Saint Rita Road
I-580 WB Off-Ramp to
Pimlico Drive 69.0 69.1 69.1 0.1 0.0 No
Brannigan Street
Gleason Drive to Aviano
Way 53.4 54.8 54.7 1.3 -0.1 No
Aviano Way to Central
Parkway 54.0 56.1 55.5 1.5 -0.6 No
Central Parkway to Finnian
Way 51.8 54.3 54.4 2.6 0.1 No
Finnian Way to Project
Driveway (South Family
Homes)

53.3 55.2 55.7 2.4 0.5 No
Project Driveway (South
Family Homes) to Dublin
Boulevard

53.3 55.2 55.8 2.5 0.6 No
Dublin Boulevard to Project
Driveway (Commercial) 51.4 55.4 54.7 3.3 -0.7 No
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Roadway Segment
Existing
Cumulative
Without
Project
Cumulative
With
Project
Combined
Effects
Incremental
Effects
Cumulatively
Significant
Impact?
dBA @
100 Ft
from
Centerline
dBA @ 100
Ft from
Centerline
dBA @ 100
Ft from
Centerline
dBA
Difference:

Existing
and
Cumulative
With
Project
dBA
Difference:

Cumulative
Without
and With
Project
Fallon Road
Tassajara Road to Gleason
Drive 63.6 64.9 64.9 1.3 0.0 No
Gleason Drive to Central
Parkway 65.5 66.9 66.9 1.4 0.0 No
Central Parkway to Dublin
Boulevard 67.4 68.1 68.1 0.7 0.0 No
Dublin Boulevard to I-580
WB Off Ramp 67.9 69.4 69.4 1.5 0.0 No
I-580 WB Off Ramp to I-580
EB Off Ramp 67.1 69.0 69.0 1.9 0.0 No
I-580 EB Off Ramp to W Jack
London Boulevard 65.9 68.1 68.1 2.2 0.0 No
Gleason Drive
Tassajara Road to Project
Driveway 61.7 63.7 63.6 1.9 -0.1 No
Project Driveway to
Brannigan Street 61.7 63.7 63.6 1.9 -0.1 No
Brannigan Street to Grafton
Street 60.6 62.5 62.5 1.9 0.0 No
Grafton Street to Fallon
Road 60.5 61.6 61.5 1.0 -0.1 No
Central Parkway
Hacienda Drive to Tassajara
Road 59.2 63.1 63.0 3.8 -0.1 No
Tassajara Road to Project
Driveway (North Side) 60.3 63.0 62.9 2.6 -0.1 No
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Roadway Segment
Existing
Cumulative
Without
Project
Cumulative
With
Project
Combined
Effects
Incremental
Effects
Cumulatively
Significant
Impact?
dBA @
100 Ft
from
Centerline
dBA @ 100
Ft from
Centerline
dBA @ 100
Ft from
Centerline
dBA
Difference:

Existing
and
Cumulative
With
Project
dBA
Difference:

Cumulative
Without
and With
Project
Project Driveway (North
Side) to Brannigan Street 60.3 63.1 62.8 2.5 -0.3 No
Brannigan Street to
Montalcino Street/Chancery
Lane

59.7 62.6 62.5 2.8 -0.1 No
Montalcino Street/Chancery
Lane to Grafton Street 59.3 62.9 62.8 3.5 -0.1 No
Grafton Street to Fallon
Road 58.9 63.1 63.0 4.1 -0.1 No
Dublin Boulevard
Hacienda Drive to Tassajara
Road 68.0 70.5 70.5 2.5 0.0 No
Tassajara Road to Project
Driveway) 67.3 71.0 71.0 3.7 0.0 No
Project Driveway (South
Family Homes) to Brannigan
Street

67.3 71.0 71.0 3.7 0.0 No
Brannigan Street to Grafton
Street 66.9 70.9 70.8 3.9 -0.1 No
Grafton Street to Keegan
Street 66.5 70.7 70.7 4.2 0.0 No
Keegan Street to Lockhart
Street 64.9 70.2 70.1 5.2 -0.1 No
Lockhart Street to Fallon
Road 65.2 70.4 70.4 5.2 0.0 No
East of Fallon Road1 0.0 69.8 69.8 69.8 0.0 No
Notes:

1. The Dublin Boulevard extension, east of Fallon Road, will be constructed as part of the proposed project.

Source: Noise modeling is based on traffic data within the transportation analysis for the SCS Dublin Project, prepared by Kimley-Horn, 2022. 1174
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14.5.8 Level of Significance after Mitigation
Table 14-11: Summary of Impacts and Mitigation Measures – Noise summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to noise.

Table 14-11: Summary of Impacts and Mitigation Measures – Noise Impact Impact Significance Mitigation
Impact N-1: Would the Project
generate a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the Project in
excess of standards established in the
local general plan or noise ordinance,
or applicable standards of other
agencies? (Class II)
Less than Significant
with Mitigation
MM N-1.1: Construction Noise Reduction
MM N-1.2: Noise Attenuation
Impact N-2: Would the Project
generate excessive groundborne
vibration or groundborne noise levels?
(Class III)
Less than significant None required.

Impact N-3: 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? (Class III)
Less than significant None required.

Impact N-4: Contribute to
cumulatively considerable impacts on
noise? (Class II)
Less than Significant
with Mitigation
MM N-1.1: Construction Noise Reduction
MM N-1.2: Noise Attenuation

14.6 References
California Department of Transportation (Caltrans). 2009. Technical Noise Supplement. pp. 248 – 249. Available at: http://www.dot.ca.gov/hq/env/noise/pub/tens_complete.pdf.

Accessed April 4, 2022.

California Department of Transportation (Caltrans). 2013. Technical Noise Supplemental to the Traffic Noise Analysis Protocol. Available at: https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/tens-sep2013-a11y.pdf Accessed April 4, 2022.
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FHWA (Federal Highway Administration). 2006. FHWA Highway Construction Noise Handbook. (FHWAHEP‐06‐015; DOT‐VNTSC‐FHWA‐06‐02). Available at:
https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/index.cf m. Accessed April 4, 2022.

FICON (Federal Interagency Committee on Noise). 1992. Federal Agency Review of Selected Airport Noise Analysis Issues. August. Available at:
http://www.gsweventcenter.com/GSW_RTC_References/1992_0801_FICON.pdf.

Accessed April 4, 2022.

FTA (Federal Transit Administration). 2006. Transit Noise and Vibration Impact Assessment Final Report. Available at:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/FTA_Noise_and_Vibration_Ma nual.pdf. Accessed April 4, 2022.

FTA. Transit Noise and Vibration Impact Assessment Manual. 2018, Table 7-2, Page 179.

USEPA (United States Environmental Protection Agency). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. Available at:
https://nepis.epa.gov/Exe/ZyNET.exe/2000L3LN.TXT?ZyActionD=ZyDocument&Client=E PA&Index=Prior+to+1976&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRe strict=n&Toc=&TocEntry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQFiel dOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5Czyfiles%5CIndex%20Data%5C70thr u75%5CTxt%5C00000001%5C2000L3LN.txt&User=ANONYMOUS&Password=anonymou s&SortMethod=h%7C-
&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i4 25&Display=hpfr&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc= Results%20page&MaximumPages=1&ZyEntry=1&SeekPage=x&ZyPURL. Accessed April 4, 2022.
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Not to scale
Source: Google Earth, 2021
Figure 14-1: Noise Measurement Locations
SCS Dublin Project
Environmental Impact Report
Legend
Short Term Noise Measurement Location
Project Site
ST-2
ST-1
ST-4
ST-3
Dublin Blvd
Tassajara Drive
Gleason Drive
Brannigan Street
I-580
Central Pkwy
1177
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15 Population & Housing

15.1 Introduction
This section describes effects on population and housing that would be caused by implementation of the project. Information used to prepare this section came from the following resources:
 City of Dublin, General Plan, 1985 amended 2022
 City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022  City of Dublin, 6th Cycle Public Review Draft Housing Element, 2022  Association of Bay Area Governments (ABAG) and Metropolitan Transportation Commission (MTC), Plan Bay Area 2050, 2021

15.2 Scoping Issues Addressed
During the public comment scoping period for the project, comments requesting analysis of the number of school children generated were received.

15.3 Environmental Setting
This section presents information on population and housing conditions in the project area.

15.3.1 Population Characteristics
Alameda County
Alameda County has a current population of approximately 1,656,591 persons (DOF, 2021a).

The 6th Cycle Public Review Draft Housing Element estimates that the population of Alameda County will increase to 2,092,370 (an increase of 42 percent compared to population in 2010) by 2040 (City of Dublin, 2022a). Table 15-1: City of Dublin and Alameda County Existing and Forecasted Population shows population numbers for the County as determined by the City as determined by the City General Plan Housing Element.

City of Dublin
As of January 1, 2021, the City of Dublin has a population of 64,695 persons representing approximately four percent of Alameda County’s population (DOF, 2021a). As shown in Table 15-1: City of Dublin and Alameda County Existing and Forecasted Population, the population in Dublin is expected to increase to 83,595 by 2040 (a 82 percent increase compared to population in 2010).
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Table 15-1: City of Dublin and Alameda County Existing and Forecasted Population 2010 2020 2025 2030 2035 2040
Percent
Increase
2010-
2040
Dublin 46,036 72,589 54,780 71,870 78,140 83,595 82%
Alameda
County
1,477,980 1,682,353 1,776,495 1,868,635 1,960,630 2,092,370 42% Sources: City of Dublin 6th Cycle Draft Housing Element, 2022.

15.3.2 Housing Characteristics
Alameda County
As shown in Table 15-2: Housing Units for City of Dublin and Alameda County, the County has an estimated 617,415 housing units with an average of 2.84 persons per household (DOF, 2021c and City of Dublin, 2022a).

As reported by the Housing Element, the vacancy rate is a measure of the availability of housing in a community. It also demonstrates how well the types of units available meet the market demand. A low vacancy rate suggests that households may have difficulty finding housing within their price range; a high supply of vacant units may indicate either the existence of a high number of desired units, or an oversupply of units. The vacancy rate for housing in Alameda County is estimated to be 5.4 percent (City of Dublin, 2022a).

Table 15-2: Housing Units for City of Dublin and Alameda County 2021 Persons per Household Vacancy Rate
Dublin 23,891 2.99 2.9 %
Alameda County 617,415 2.84 5.4 %
Source: DOF, 2021c and City of Dublin, 2022a.

City of Dublin
According to the Department of Finance, the City of Dublin has approximately 23,891 housing units with an average of 2.99 persons per household in 2021. The vacancy rate for housing in the City is 2.9 percent.

The Association of Bay Area Governments (ABAG) determines the regional housing needs allocation (RHNA) by income category for each community in the region based on employment activities, community patterns, types and tenure of housing needs, and others every eight years. The City of Dublin’s allocation and approved units for the 5th RHNA cycle and the City’s allocation for the 6th RHNA cycle that will begin on January 1,2023 are shown in Table 15-3:

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sites that are planned and zoned for housing are available to accommodate its need and to implement proactive programs that facilitate and encourage the production of housing commensurate with its housing needs.

Table 15-3: City of Dublin Regional Housing Needs Allocation Income Category 5th Cycle RHNA Units Approved Remaining 5th Cycle RHNA 6th Cycle RHNA Extremely Low Income
796 26 770 1,085
Very Low Income
Low Income 446 39 407 625
Moderate Income 425 79 346 560
Above Moderate
Income 618 4,878 -4,260 1,449
Total 2,285 5,022 -2,737 3,719
Sources: City of Dublin, 2022, ABAG, 2021

15.4 Applicable Regulations, Plans, and Standards

15.4.1 Federal
There are no applicable federal regulations applicable to the project.

15.4.2 State
California Housing Element Law
Government Code Sections 65580–65589.8include provisions related to the requirements for housing elements of local government general plans. Among these requirements, some of the necessary elements include an assessment of housing needs and an inventory of resources and constraints relevant to the meeting of these needs. Additionally, to assure that counties and cities recognize their responsibilities in contributing to the attainment of the State housing goals, the statute calls for local jurisdictions to plan for, and allow the construction of, a share of the region’s projected housing needs. The share is known as the Regional Housing Needs Allocation (RHNA). The RHNA for the Bay Area is based on a Regional Housing Needs Plan (RHNP) developed by ABAG for a nine-county area that includes Alameda County and the City of Dublin. The City’s RHNA that covers the period from 2015 through 2023 includes 2,285 units and the City’s RHNA that covers the period from 2023-2031 includes 3,719 units.

15.4.3 Local
Association of Bay Area Governments
Association of Bay Area Governments (ABAG) is the official comprehensive regional planning agency for the San Francisco Bay Area, which is composed of nine counties, including Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Solano, and Sonoma. ABAG 1180
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produces growth forecasts on four-year cycles so that other regional agencies, including the Metropolitan Transportation Commission (MTC) and the Bay Area Air Quality Management District (BAAQMD), can use the forecast to make funding and regulatory decisions. ABAG projections are also the basis for the Regional Transportation Plan and regional Ozone Attainment Plan. The general plans, zoning regulations, and growth management programs of local jurisdictions inform the ABAG projections. The ABAG projections are also developed to reflect the impact of “smart growth” policies and incentives that could be used to shift development patterns from historical trends toward a better jobs-housing balance, increased preservation of open space, and greater development and redevelopment in urban core and transit-accessible areas throughout the ABAG region.

In October 2021, ABAG and MTC adopted Plan Bay Area 2050 and its associated Environmental Impact Report (EIR). The third such regional housing and transportation plan adopted by MTC and ABAG, Plan Bay Area 2050 is a long-range blueprint to guide transportation investments and land-use decisions through 2050, while meeting the requirements of California’s landmark 2008 Senate Bill 375, which calls on each of the state’s 18 metropolitan areas to develop a Sustainable Communities Strategy to accommodate future population growth and reduce greenhouse gas emissions from cars and light trucks.

City of Dublin General Plan 6th Cycle Public Review Draft Housing Element The City of Dublin is in the process of updating and adopting its Housing Element. Dublin’s 6th Cycle Draft Housing Element, which focuses on the regional housing needs for the period between 2023 and 2031, includes all the mandatory sections as identified by California law, including an inventory of land parcels that could accommodate its Regional Housing Needs Allocation (RHNA) as set by ABAG. The Housing Element outlines housing production objectives, describes strategies to achieve those objectives, examines the local need for special needs populations, identifies adequate sites for housing production serving various income levels, analyzes constraints to new development, and evaluates the Housing Element’s consistency with other General Plan elements. A list of Housing Element policies and programs that are relevant to the project are provided below.

Policy A.1: Ensure the provision of a variety of housing types to fulfill the City’s RHNA.

Policy D.3: Encourage the provision of housing to meet the needs of households of all sizes.

Program B.1 Mixed-Use Development
Program B.6: Housing Type and Size Variations
The Affordable Housing Program
The City of Dublin has Inclusionary Zoning Regulations that require residential development to include a certain percentage of affordable housing. Developers may choose to satisfy a portion of the obligation through the payment of a fee in-lieu of construction, with the funds being deposited into the City’s affordable housing fund. As of May 2, 2022, the fund had an available 1181
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balance of $6.1 million. The City also adopted a nonresidential development affordable housing impact fee to fund affordable housing to serve the workforces of new nonresidential development. The proceeds are deposited into the affordable housing fund program.

Eastern Dublin Specific Plan
The Eastern Dublin Specific Plan (EDSP) and EIR were adopted in May 1993 to evaluate the potential environmental effects of urbanizing eastern Dublin over a 20 to 30-year period. The buildout potential of the EDSP is 32,023 residents, 13,913 dwelling units, and 29,424 jobs. The project is located in the EDSP area.

15.5 Environmental Impacts and Mitigation Measures

15.5.1 Significance Criteria
The following significance criteria for population & housing were derived from the Environmental Checklist in CEQA Guidelines Appendix G. These significance criteria have been amended or supplemented, as appropriate, to address Lead Agency requirements and the full range of potential impacts related to this project.

An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria.
 Induce substantial 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.)
 Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere.
 Displace substantial numbers of people, necessitation the construction of replacement housing elsewhere.

The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.
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15.5.2 Summary of No and/or Beneficial Impacts
Displace existing housing or substantial people.

The project site does not include any existing housing and therefore would not displace existing housing or people. Implementation of the project would not displace substantial people, nor would it require the construction of replacement housing elsewhere. As a result, no impacts would occur.

15.5.3 Impacts of the Proposed Project
Impact POP-1: Induce substantial population growth in an area, either directly or indirectly (Class III).

According to the latest population numbers from the City, the average Dublin household has

2.99 persons per unit (City of Dublin, 2022a). Therefore, the proposed Project is estimated to add a maximum population of approximately 1,944 residents. As shown in Table 15-4:

Additional Population Generated by Project, this increase would constitute a three percent increase as compared to the City’s 2021 population. A three percent increase would still be within the range of population growth forecast by the City, which is 83,595 by 2040. Therefore, the project’s population growth would be consistent with the City’s population projections.

Table 15-4: Additional Population Generated by Project
Dublin 2021 Population Population generated by
Project1 Percent of Total Population
64,695 1,944 3%
Source: DOF, 2021c, City of Dublin, 2022a.

Note:
1- Based on 2.99 people per unit from City of Dublin, 2022a.

Table 15-5: Buildout Potential of the Eastern Dublin Specific Plan, shows the forecasted growth of the EDSP area and the project site within the EDSP area. The project would provide 265,000 square feet of general commercial land use. This comprises 2.5 percent of the planned general commercial for the EDSP area and 30 percent of the planned commercial area for the project site. Three percent of the anticipated commercial growth for the area would not result in a direct population increase beyond what is anticipated. The project would comprise four percent of the forecasted residential units for the EDSP but increase the number of residential units planned for the project site by 1,095 units (an increase of 155%). While the project would increase the population projections for the City, by increasing the number of units allowed from 261 to 650, the project still represents a small fraction of the planned buildout for the EDSP overall; would be consistent with the nature of surrounding development; and would be within the estimate of population growth estimated by and the City’s Housing Element. For all of these reasons, impacts associated with increased population growth would be less than significant and no mitigation measures are required.
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Table 15-5: Buildout Potential of the Eastern Dublin Specific Plan EDSP
EDSP Project
Site
Proposed
Project
% of EDSP
overall
% of EDSP
Project site
Residential (units) 17,970 261 650 4% 249%
Commercial (square
feet)
10,575,000 902,563 265,000 2.5% 30%
Population 42,669 705 1,800 4% 255%
Source: Eastern Dublin Specific Plan, 1994, as updated.

15.5.4 Cumulative Impact Analysis
The geographic context for the analysis of cumulative population and housing impacts includes the City of Dublin.

Impact POP-2: Contribute to cumulatively considerable impacts on population and housing (Class III).

The project would have a maximum of 1,944 residents. Table 15-1: City of Dublin and Alameda County Existing and Forecasted Population estimates the City of Dublin would have a population of 83,595 by 2040, and the project population growth is within City population forecasts. Therefore, the project would not cause a cumulatively considerable impact on population and housing and no mitigation is required.

15.5.5 Level of Significance after Mitigation
Table 15-6: Summary of Impacts and Mitigation Measures – Population & Housing summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to population & housing.

Table 15-6: Summary of Impacts and Mitigation Measures – Population & Housing Impact
Impact
Significance Mitigation
Impact POP-1: Induce substantial
population growth in an area, either
directly or indirectly (Class III).

Less than
significant
None required.

Impact POP-2: Contribute to
cumulatively considerable impacts
on population and housing (Class III).

Less than
significant
None required.
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15.6 References
ABAG (Association of Bay Area Governments). 2021. Final regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031. Available at https://abag.ca.gov/sites/default/files/documents/2021- 12/Final_RHNA_Allocation_Report_2023-2031-approved_0.pdf. Accessed April 5, 2022.

City of Dublin. 2023-2031 Draft Housing Element. 2022a Available at https://www.dublin.ca.gov/2241/Housing-ElementUpdate#:~:text=The%20Housing%20Element%20is%20one,process%20as%20further%2 0described%20below. Accessed May 12, 2022.

City of Dublin. Annual Progress Report on the Status of the General Plan and Housing Element for the Calendar Year 2021. 2022b Available at
https://dublin.ca.gov/DocumentCenter/View/29893/General-Plan-and-HousingElement-Annual-Progress-Report-for-2021. Accessed April 5, 2022.

DOF (California Department of Finance). 2021a. Demographic Research Unit. E-1 Population Estimates for Cities, Counties, and the State January 1, 2020 and 2021. Available at https://dof.ca.gov/forecasting/demographics/estimates-e1/. Accessed April 4, 2022.

DOF (California Department of Finance). 2021b. Demographic Research Unit. P-2A Total Population for California and Counties. Available at
https://dof.ca.gov/forecasting/demographics/projections/. Accessed April 5, 2022.

DOF (California Department of Finance). 2021c. Demographic Information. E‐5 Population and Housing Estimates for Cities, Counties and the State, January 2011 - 2021, with 2010 Benchmark. Available at:
https://dof.ca.gov/forecasting/demographics/estimates/estimates-e5-2010-2021/.

Accessed April 4, 2022.
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16 Public Services, Utilities & Service Systems

16.1 Introduction
This section describes effects on public services, utilities, and service systems that would be caused by implementation of the project. The discussion addresses existing environmental conditions in the affected area, identifies and analyzes environmental impacts, and recommends measures to reduce or avoid adverse impacts anticipated from project construction and operation. In addition, existing laws and regulations relevant to public services, utilities, and service systems are described. In some cases, compliance with these existing laws and regulations would serve to reduce or avoid certain impacts that might otherwise occur with the implementation of the project.

Information used to prepare this section came from the following resources:
 Project application and related materials
 City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022  City of Dublin, General Plan, 1985 amended 2022
 City of Dublin, Parks and Recreation Master Plan, 2022  Dublin Police Services, 2020-2021 Annual Report, 2021  Dublin San Ramon Services District, SCS Dublin Development Project Water Supply Assessment and Water Supply Verification, 2022 (see Appendix G)  Dublin San Ramon Services District, Wastewater Treatment and Biosolids Facilities Master Plan, 2017
 Dublin San Ramon Services District, Water System Master Plan, 2016  Dublin San Ramon Services District, 2020 Urban Water Management Plan, 2021  Dublin Unified School District, 2020/2021 Demographics and Alternative Enrollment Projections, May 2021
 Dublin Unified School District, School Facilities Needs Analysis, May 2021  Dublin Unified School District, 7-Year Student Population Projections Packet by Residence Fall 2019-2025, March 2019
 Zone 7 Water Agency, 2020 Urban Water Management Plan, 2021

16.2 Scoping Issues Addressed
During the public comment scoping period for the project, comments requesting analysis of the project impact on schools, potable water supply, wastewater connection, and stormwater management were received.
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16.3 Environmental Setting
This section presents information on public services, utilities, and service systems in the project area. Physical impacts to public services, utilities, and service systems are usually associated with population in‐migration and growth in an area, which increase the demand for a particular service, leading to the need for expanded or new facilities.

16.3.1 Public Services
Police Protection
The Alameda County Sheriff’s Office provides law enforcement to the City of Dublin on a contract basis (known locally as “Dublin Police Services”). Criminal investigations, crime prevention, and some business office functions are performed at the Dublin Civic Center (100 Civic Center), while dispatch and some data processing functions are handled at Sheriff’s Office facilities in Oakland and San Leandro. Dublin Police Services has 59 sworn personnel assigned to duty in the City of Dublin. Eight City of Dublin civilian employees provide support services for Dublin Police Services (Dublin Police Services, 2021). Dublin Police Services responded to 30,706 calls for service in 2020 with an average patrol response time of approximately 5.3 minutes (Dublin Police Services, 2021). This response time meets the Alameda County Sheriff’s Office standards and the industry average of five minutes.

Fire Protection and Emergency Response Services
The Alameda County Fire Department (“Fire Department”) provides fire protection, emergency medical services, and public assistance to the City of Dublin. The Fire Department serves approximately 508 square miles and has a service population of 394,000 people in their entire service area (Alameda County Fire Department, 2022a). The Fire Department employs over 400 personnel and 100 reserve firefighters who staff four battalions consisting of 35 companies in 27 fire stations. Fire Department services also include three specialized response teams:

Hazardous Materials Unit, Urban Search and Rescue Unit, and Water Rescue Team Unit. The Fire Department also staffs specialized response teams for hazardous materials, urban search and rescue, and water rescue.

As shown in Table 16-1: Alameda County Fire Department Stations in the City of Dublin, the Fire Department has three stations and one fire bureau in the City of Dublin, all are staffed.

Stations 16 and 18 are staffed with one engine company and three personnel. Station 17, closest to the project site, houses an engine and a truck company, one Type 3 engine, and a water rescue boat. The station is staffed by a total of six personnel. 1187
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Table 16-1: Alameda County Fire Department Stations in the City of Dublin Station
Number Address Distance toProject Station Details
16 7494 Donohue Drive 3.4 miles
This station has one engine company, a patrol, a
water tender, and an air support unit. The response
area is primarily west and central Dublin.
17 6200 Madigan Avenue 0.6 miles
This station houses an engine and a truck company,
one Type 3 engine, and a water rescue boat. Central
Dublin is its primary response area but also responds
to the west, central core, and eastern most sections
of the City.
18 4800 Fallon Road 0.8 miles
This station has an engine company, one patrol, and
a bulldozer. Its response area covers the
easternmost portions of Dublin, urban wildland
interface areas, and Highway 580.

Fire
Prevention
Bureau
100 Civic Plaza 2.5 miles
Performs plan reviews and inspections of new
construction. The Bureau reviews building plans to
ensure compliance with applicable fire codes and
regulations.

Source: Alameda County Fire Department, 2022b.

In 2020-2021, the Fire Department responded to 3,698 calls from the City of Dublin. The Fire Department’s average response times are reported to the City of Dublin on a quarterly basis.

For fiscal year 2020-2021 the Fire Department responded to 92% of all emergency calls in less than 5 minutes.

Aid Agreements
The Fire Department has mutual and automatic mutual aid agreements with the LivermorePleasanton Fire Department, the San Ramon Valley Fire Department, and the Camp Parks Fire Department. These agreements help to ensure service is sent based on shortest response times and may result in a mix of different agencies responding to a particular call. In the case of a wildland fire within the State Responsibility Areas of the County, CAL FIRE’s ground and air resources are also available. The Fire Department also participates in the California Master Mutual Aid Plan that allows source requests to be filled from an agency outside Alameda County.

Schools
Dublin Unified School District (DUSD) provides Transitional Kindergarten (TK) through grade 12 educational services to the City of Dublin. During the 2020-2021 school year, DUSD had a total enrollment of 12,604 students, 689 certified staff members, 359 classified staff, and 65 administrators (DUSD, 2021a and DUSD, 2022a). DUSD operates 12 schools; seven elementary (TK‐5), oneTK-8 school, two middle (grade 6‐8), and two high schools (one comprehensive, one alternative) (DUSD, 2022a). Emerald High is also under construction and Phase I is anticipated 1188
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to open in 2024, giving the district three total high school sites (DUSD, 2022b). DUSD also offers Pathways, an alternative option for elementary students; Independent Study; Dublin Adult School; Home/Hospital Instruction for those with serious physical or mental health issues; Home Schooling for K-6th grade; Online Program for Students; and various programs for students with disabilities.

As noted in the DUSD2021 School Facilities Needs Analysis, in order to be consistent with the State Allocation Board (SAB) reporting requirements, the enrollment school level configuration was adjusted to represent grades transitional kindergarten through 6 at the elementary level and grades 7 and 8 at the middle school level. Available facilities capacity is calculated by subtracting the October 2020 student enrollment from existing school facilities capacity for each school level. As a result and as shown in Table 16-2: Dublin School District Existing Student Capacity, this operation results in deficit capacity at the Elementary School and High School levels and available capacity at the Middle School level.

Table 16-2: Dublin School District Existing Student Capacity Grade Level Existing Facilities Capacity
Student Enrollment
(October 2020)
Available/ (Deficit)
Capacity
Elementary School (TK-6) 6,994 7,483 (489)
Middle School (7-8) 1,909 1,906 3
High School (9-12) 2,499 3,381 (882)
Total 11,402 12,770 (1,368)
Source: DUSD, 2021b.

Elementary Schools
DUSD comprises eight elementary schools (including Cottonwood Creek Elementary (TK-8)) serving 7,483 TK-5 students as of Fall 2020. The project site is served by Kolb Elementary School (0.5 miles east) and Cottonwood Creek Elementary (1.5 miles west).

Middle School
DUSD comprises three middle schools (including Cottonwood Creek Elementary (TK-8)) serving 1,906 grade 6-8 students as of Fall 2020. The project site is served by Fallon Middle School (0.5 miles northeast) and Cottonwood Creek Elementary (1.5 miles west).

High School
The DUSD currently operates one comprehensive high school, Dublin High School, located four miles west of the project site. As of Fall 2017, there were 3,381 grade 9-12 high school 1189
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students enrolled in the District with Dublin High School serving 3,286 students, and Valley Continuation High serving the remaining students.

Parks
The City of Dublin’s Parks and Recreation Master Plan establishes the goals, standards, policies, and action programs to guide the City of Dublin in the acquisition, development and management (operations and maintenance) of Dublin’s park and recreation facilities through the ultimate build-out of the City in accordance with the General Plan.

As shown in Table 16-3: Dublin Parks and Sport Facilities Existing Service Levels and Standards, the Master Plan establishes park standards for neighborhood and community parks and sport facilities. Comparisons to the National Recreation and Park Association (NRPA) standards are also shown for reference.

Table 16-3: Dublin Parks and Sport Facilities Existing Service Levels and Standards Park & Sport Facilities
Current Supply
(Number of Facilities) NRPA Standard
City of Dublin
Standard
Existing Level of
Service 1,2
Parks 24 8.5 per 1,000 5 per 1,000 3.27
Baseball/Softball Fields 18 1 per 7,500 1 per 9,350 8.32 Soccer Fields 16 1 per 19,000 1 per 3,500 12.18
Tennis Courts 20 1 per 5,500 1 per 2,700 6.80
Basketball Courts 13 1 per 8,570 1 per 4,300 4.53
Cricket Fields 2 -- 1 per 40,000 0.193
Volleyball Courts 9 1 per 19,800 1 per 17,000 5.33
Notes:

1. Acres per 1,000 population

2. Based on current population

3. Based on 2015 population
Source: City of Dublin Parks and Recreation Master Plan, 2022.

The City currently provides 24 parks, which include 18 neighborhood parks/square, five community parks, and one nature park totaling a combined 237.04 acres. These parks range from passive to active and are a mix of small neighborhood parks to a large aquatic complex. In addition to these facilities, Dublin maintains over 26.26 miles of greenways and trails. The series of trails sprawls throughout the City ranging from recreational trails to shared use paths.

The City of Dublin envisions 116.84 additional acres of parks in the future. One potential future site for a two-acre Neighborhood Square is near the project site south of Dublin Boulevard between Tassajara Road and Fallon Road.
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The nearest community park is Emerald Glen Park located directly adjacent to the project site on the west side of Tassajara Road. The closest neighborhood parks are Bray Commons (0.4 miles east) and Ted Fairfield Park (0.5 miles north).

Community Facilities
As shown in Table 16-4: City of Dublin Community Facilities, the Parks and Community Services Department operates five community centers.

Table 16-4: City of Dublin Community Facilities
Name Address
Distance from
Project Site Facilities
Dublin Civic
Center
100 Civic Plaza 2.5 miles Council Chambers: Theater-style seating for 142, panel seating for 11, two podiums, and two built-in
screens.

Regional Meeting Room: 80 for dining and 125 for
assembly.

Dublin Public
Library
Community
Room
200 Civic Plaza 2.55 miles 1,830 square foot Community Room that is available for rent for up to 122 people.

Dublin Senior
Center
7600 Amador Valley
Boulevard

3.3 miles Ballroom seats 248 for dining, raised stage, casual seating nook, and two patios
Lounge area with fireplace and furniture
Shannon
Community
Center
11600 Shannon Avenue 3.8 miles 6,000 square foot room that fits 300 for dining Heritage Park
and Museums
6600 Donlon Way 3.7 miles The Old St. Raymond Church and Sunday School Barn are available for rentals
Source: Dublin Parks & Community Services, 2022.

16.3.2 Utilities and Service Systems
Water
Dublin San Ramon Services District (DSRSD) provides potable water and non‐potable recycled water service to the City of Dublin and the Dougherty Valley portion of the City of San Ramon.

As of 2020, DSRSD’s water service population is approximately 92,409 (DSRSD, 2021).

Potable Water
DSRSD obtains its water supply from Alameda County Flood Control and Water Conservation District, Zone 7 (“Zone 7”), a multi‐purpose agency that oversees water‐related issues in the Livermore‐Amador Valley. Zone 7 is a State Water Project contractor that wholesales treated water to four retail water agencies in the Tri‐Valley area (DSRSD, City of Livermore, City of 1191
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Pleasanton, and California Water Service Company‐Livermore District). It also retails non‐ potable water supplies for irrigated agricultural use, treated water to several direct customers, provides and maintains flood control facilities, and manages groundwater and surface water supplies in its service area. In addition to other water sources listed below, DSRSD has a groundwater pumping quota (GPQ) of 645 acre‐feet/year in the Livermore Valley Main Groundwater Basin (Main Basin), which Zone 7 pumps on DSRSD’s behalf as part of its water contract.

Zone 7 uses a combination of water supplies and water storage facilities to meet the municipal and industrial demands of its retailers. These include the following:
 Imported surface water from the State Water Project;
 Imported surface water transferred from the Byron Bethany Irrigation District;  Local surface water runoff captured in Del Valle Reservoir;  Local groundwater extracted from the Livermore Valley Groundwater Main Basin;  Local storage in the Chain‐of‐Lakes; and
 Non‐local groundwater storage in the Semitropic Water Storage District and Cawelo Water District.

A full discussion of these water supply sources can be found in the Zone 7’s 2020 Urban Water Management Plan (2021).

Recycled Water
DSRSD’s water supply is augmented with recycled water from its Recycled Water Treatment Facilities. DSRSD owns and operates a wastewater treatment plant that treats wastewater from Dublin, South San Ramon, and Pleasanton. The wastewater treatment plant includes conventional secondary treatment facilities, as well as tertiary and advanced recycled water treatment facilities. The DSRSD ‐ East Bay Municipal Utility Recycled Water Authority (DERWA) operates the San Ramon Valley Recycled Water Program, a multi‐phased project that distributes recycled water from the Recycled Water Treatment Facilities to portions of DSRSD’s and East Bay Municipal Utility District (EBMUD) service areas.

DSRSD began its recycled water program in the early 1990's by adopting Resolution No. 42-92 in August 1992. The resolution set priorities and policies for the use and promotion of recycled water service within and outside DSRSD's water service area. DSRSD then adopted the "Water Recycling Business Plan Framework" in 1993, to establish the DSRSD Recycled Water Enterprise.

Since that time, recycled water has been an important part of water planning at DSRSD.

In that same year, the City of Dublin certified an EIR for the Eastern Dublin General Plan Amendment and Specific Plan. The DSRSD service plan for eastern Dublin is predicated upon the use of recycled water for landscape irrigation. Potable water supply requests to Zone 7 by 1192
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DSRSD for Eastern Dublin under the "Contract between Zone 7 and DSRSD for a Municipal & Industrial Water Supply," are the net of the eastern Dublin total water demands, less the recycled water provided by DSRSD.

In 1995, DSRSD began providing recycled water to Dougherty Valley. Similar to eastern Dublin, the DSRSD service plan for Dougherty Valley is also predicated upon the use of recycled water for landscape irrigation. In 2018, DSRSD commenced delivery of recycled water to Pleasanton.

DSRSD currently has a moratorium on any new recycled water connections.

Current and Projected Water Supply and Demand
Table 16-5: DSRSD Current and Projected Water Supply and Demand, provides a summary of DSRSD’s current and projected future water supply and demand as presented in the 2020 UWMP.

Table 16-5: DSRSD Current and Projected Water Supply and Demand 2020
Actual 2025 2030 2035 2040 2045
Demand
Potable Water 10,330 11,993 13,363 13,807 13,820 14,034 Recycled Water 3,044 3,044 3,004 3,044 3,044 3,044
Total Demand 13,374 15,037 16,407 16,851 16,864 17,078
Supply
Potable Water 10,966 11,993 13,363 13,807 13,820 14,034 Recycled Water 2,888 3,044 3,044 3,044 3,044 3,044
Total Supply 13,854 15,037 16,407 16,851 16,864 17,078
Notes: All values are in acre feet per year
Source: DSRSD, 2021.

Project Site Facilities
A series of water lines ranging from 12 inches (along Brannigan Street) to as large as 20 inches (along Dublin Boulevard) surround the project site.

Wastewater
DSRSD provides wastewater collection and treatment service to the City of Dublin as well as to the southern portion of the City of San Ramon and Pleasanton making its wastewater service area larger than its water service area.

Collection System
DSRSD’s wastewater infrastructure includes a wastewater collection system and the wastewater treatment plant (WWTP). The collection system conveys wastewater primarily by 1193
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gravity to the WWTP. Generally, wastewater flows by gravity from the northwest to the south and from the east to the west and then to the south within the wastewater collection service area. The collection system consists of approximately 207 miles of gravity mains, 26 feet of force main, one permanent lift station, and one temporary lift station (DSRSD, 2017).

The project would connect to existing underground DSRSD sewer lines located within the rightof-way of the adjacent roadways. Major sanitary sewer facilities include a 30-inch pipe on Dublin Boulevard, a 15-inch pipe on Tassajara Road, and 10-inch pipes on both Brannigan Street and Gleason Drive.

Treatment Facility
DSRSD owns and operates the Regional Wastewater Treatment Plant in the City of Pleasanton, which treats wastewater from the cities of Dublin, South San Ramon, and Pleasanton. The WWTP includes conventional secondary treatment facilities, as well as tertiary and advanced recycled water treatment facilities.

The WWTP includes conventional secondary treatment facilities, as well as tertiary and advanced recycled water treatment facilities. The conventional secondary wastewater treatment facilities include primary sedimentation, activated sludge secondary treatment, secondary sedimentation, chlorine disinfection, and effluent pumping. The secondary treatment facilities currently have an average dry weather flow (ADWF) capacity of 17.0 MGD.

A portion of the secondary effluent from the WWTP is treated further to produce Title 22 disinfected tertiary recycled water (“recycled water”). Recycled water is produced using sand filtration and ultraviolet disinfection facilities (SFUV) during the dry season when demands are high. The sand filtration tertiary treatment facility capacity is approved by RWQCB for 16.2 MGD, and the ultraviolet disinfection system has been approved to be operated at up to 17.6 MGD. The WWTP also includes microfiltration and ultraviolet disinfection facilities (MFUV) with a treatment capacity of 3.0 MGD. These facilities currently act as backup facilities for the SFUV facilities and are used during times of low and high demand.

Wastewater that is not recycled is discharged into the San Francisco Bay through a pipeline owned by the Livermore Amador Valley Water Management Agency (LAVWMA), a joint powers agency created in 1974 by DSRSD, Livermore, and Pleasanton. Operations began in September 1979, with an expansion in 2005, for a current design capacity of 41.2 MGD. The wastewater effluent from the Livermore and DSRSD wastewater treatment facilities are conveyed to the LAVWMA pump station in Pleasanton. The wastewater effluent is then pumped out of the Livermore-Amador Valley via a 16-mile pipeline from Pleasanton to San Leandro and enters the East Bay Regional Discharge Authority system for de-chlorination and discharge through a deep-water outfall to the San Francisco Bay (DSRSD, 2021).

Storm Drainage
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property are maintained by private property owners. Private drainage facilities may include (but are not limited to) V-ditches or channels on residential or commercial property and drain inlets in parking lots.

Runoff that leaves the project site enters either a 42‐inch‐diameter line in Arnold Road or an 84‐inch‐diameter line into a storm drainage structure on the north side of I‐580. From there, runoff is conveyed south under I‐580 via a triple set of 54‐inch‐diameter storm drains to Chabot Canal. Chabot Canal conveys stormwater to Arroyo Mocho, which outlets into South San Ramon Creek, which becomes Arroyo de La Laguna, and ultimately Alameda Creek, which is tributary to San Francisco Bay.

Solid Waste
The City of Dublin has an existing franchise agreement with Amador Valley Industries for residential and commercial garbage, recycling, and organics collection. Single family residences are provided with recycling and organics service with their garbage subscription and must be subscribed to all three streams. Multi-family residences must have access to recycling, organics, and garbage services. Commercial businesses must subscribe to recycling and organics service the same way they subscribe to garbage collection. Solid waste generated within the City is received at Altamont Landfill & Resource Recovery facility which has a total permitted capacity of 124 million cubic yards. The Altamont Landfill has approximately 65.4 million cubic yards of capacity remaining and is permitted to operate through 2070 (CalRecycle, 2022a).

Electricity
Electricity in City of Dublin is provided by East Bay Community Energy (EBCE) and is conveyed to customers through Pacific Gas and Electric’s (PG&E) existing infrastructure. In January 2022, standard residential accounts moved from an automatic default service “Bright Choice” which is 80 percent carbon free to EBCE’s product “Renewable 100” which is sourced from California wind and solar facilities. Non-residential customers will default to Renewable 100 beginning in October 2022.

Natural Gas
PG&E operates one of the largest natural gas distribution networks in the country, including 48,700 miles of natural gas transmission and distribution pipelines (PG&E, 2022c). Service is provided to 15 million accounts. A transmission gas pipeline runs parallel to the southern boundary of the City, south of Interstate 580, and small-diameter pipelines serve the City (PG&E, 2022c).
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16.4 Applicable Regulations, Plans, and Standards

16.4.1 Federal
Wastewater
Clean Water Act
The Federal Water Pollution Control Act of 1972, more commonly known as the Clean Water Act (CWA), regulates the discharge of pollutants into watersheds throughout the U. S. under the CWA, the United States Environmental Protection Agency (U.S. EPA) implements pollution control programs and sets wastewater treatment standards.

National Pollutant Discharge Elimination System
Pursuant to Section 402 of the Clean Water Act (CWA) and the Porter‐Cologne Water Quality Control Act, municipal stormwater discharges in the City of Dublin are regulated under the San Francisco Bay Region Municipal Regional Stormwater National Pollutant Discharge Elimination System (NPDES) Permit, Order No. R2‐2009‐0074, NPDES Permit No. CAS612008, adopted October 14, 2009, and revised November 28, 2011. The Municipal Regional Permit is overseen by the Regional Water Board.

The City of Dublin is a member agency of the Alameda Countywide Clean Water Program, which assists municipalities and other agencies in Alameda County with implementation of the Municipal Regional Permit. Provision C.3 addresses post‐construction stormwater management requirements for new development and redevelopment projects that add and/or replace 10,000 square feet or more of impervious area. Provision C.3 requires the incorporation of site design, source control, and stormwater treatment measures into development projects to minimize the discharge of pollutants in stormwater runoff and non‐ stormwater discharges and to prevent increases in runoff flows. Low Impact Development (LID) methods are to be the primary mechanism for implementing such controls.

Municipal Regional Permit Provision C.3.g pertains to hydromodification management. This Municipal Regional Permit provision requires that stormwater discharges not cause an increase in the erosion potential of the receiving stream over the existing condition. Increases in runoff flow and volume must be managed so that the post‐project runoff does not exceed estimated pre‐project rates and durations, where such increased flow and/or volume is likely to cause increased potential for erosion of creek beds and banks, silt pollutant generation, or other adverse impacts on beneficial uses due to increased erosive force. The Hydromodification Management Susceptibility Map, developed by the Alameda Countywide Clean Water Program, indicates that the Community Plan area drains primarily to earthen channels and therefore projects implemented under the Community Plan that create and/or replace one acre or more of impervious surface and increase impervious surface over pre‐project conditions are subject to hydromodification management requirements.
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16.4.2 State
Police Services
All law enforcement agencies within California are organized and operate in accordance with the applicable provisions of the California Penal Code. This code sets forth the authority, rules of conduct, and training for police officers.

Fire Protection
California Occupational Safety and Health Administration In accordance with California Code of Regulations Title 8 Sections 1270 "Fire Prevention" and 6773 "Fire Protection and Fire Equipment" the California Occupational Safety and Health Administration (Cal/OSHA) has established minimum standards for fire suppression and emergency medical services. The standards include, but are not limited to, guidelines on the handling of highly combustible materials, fire hose sizing requirements, restrictions on the use of compressed air, access roads, and the testing, maintenance, and use of all fire-fighting and emergency medical equipment.

Fire Protection
The California Fire Code contains regulations relating to construction and maintenance of buildings and the use of premises. Fire hazards are addressed mainly through the application of the State Fire Code that addresses access, including roads, and vegetation removal in high fire hazard areas, fire hydrants, automatic sprinkler systems, fire alarm systems, fire and explosion hazards safety, and many other general and specialized fire safety requirements for new and existing buildings and premises.

California Health and Safety Code
State fire regulations are set forth in Sections 13000 et seq. of the California Health and Safety Code. This includes regulations for building standards (as also set forth in the California Building Code), fire protection and notification systems, fire protection devices such as extinguishers and smoke alarms, high-rise building and childcare facility standards, and fire suppression training.

Emergency Response
The State passed legislation authorizing the Office of Emergency Services (OES) to prepare a Standard Emergency Management System (SEMS) program, which sets forth measures by which a jurisdiction should handle emergency disasters. Non-compliance with SEMS could result in the State withholding disaster relief from the non-complying jurisdiction in the event of an emergency disaster.
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Schools
Senate Bill 50
Senate Bill (SB) 50 (1998), which is funded by Proposition 1A, limits the power of cities and counties to require mitigation of developers as a condition of approving new development and provides instead authorizes school districts to impose fees in amounts limited by law. SB 50 anticipated that the state would fund a portion of new school facilities construction and the remainder would be funded by the local school district. SB 50 provides for three levels of statutory impact fees. The level depends on whether state funding is available; whether the school district is eligible for state funding; and whether the school district meets certain additional criteria involving bonding capacity, year-round schools, and the percentage of moveable classrooms in use. Consistent with this authority, the DUSD as of June 14, 2022 implements a Level 2 fee of $7.96 per square foot of new residential development and $0.78 per square foot of new commercial development.

California Government Code sections 65995-65998 sets forth provisions to implement SB 50 and limits the City’s discretion to mitigate for development’s impact on schools. Specifically, in accordance with Section 65995(h), the payment of statutory fees is “deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization…on the provision of adequate school facilities.” The school district, rather than the City, is responsible for implementing the specific methods for mitigating school impacts under the Government Code.

Furthermore, Government Code section 65995(i) provides that: “A state or local agency may not deny or refuse to approve a legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization as defined in Section 56021 or 56073 on the basis of a person's refusal to provide school facilities mitigation that exceeds the amounts authorized pursuant to this section or pursuant to Section 65995.5 or 65995.7, as applicable.” California Education Code Section 17620(a)(1) states that the governing board of any school district is authorized to levy a fee, charge, dedication, or other requirement against any construction within the boundaries of the district, for the purpose of funding the construction or reconstruction of school facilities.

California Government Code, Section 65995(b), and Education Code Section 17620 SB 50 amended California Government Code Section 65995, which contains limitations on Education Code Section 17620, the statute that authorizes school districts to assess development fees within school district boundaries. Government Code Section 65995(b)(3) requires the maximum square footage assessment for development to be increased every two years, according to inflation adjustments. On February 23, 2022, the State Allocation Board (SAB) approved increasing the allowable amount of statutory school facilities fees (Level I School Fees) from $4.08 to $4.79 per square foot of assessable space for residential 1198
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development of 500 square feet of more, and from $0.66to $0.78 per square foot of chargeable covered and enclosed space for commercial/industrial development (SAB, 2022). School districts may levy high fees if they apply to the SAB and meet certain conditions.

The Kindergarten-University Public Education Facilities Bond Act of 2002 (Proposition 47) This act was approved by California voters in November 2002 and provides for a bond issue of $13.05 billion to fund necessary education facilities to relieve overcrowding and to repair older schools. Funds will be targeted at areas of greatest need and must be spent according to strict accountability measures. Funds will also be used to upgrade and build new classrooms in the California Community Colleges, the California State University, and the University of California to provide adequate higher education facilities to accommodate growing student enrollment.

Parks and Recreation
Quimby Act
The Quimby Act (California Government Code Section 66477) states that “the legislative body of a City or county may, by ordinance, require the dedication of land or impose a requirement of the payment of fees in lieu thereof, or a combination of both, for park or recreational purposes as a condition to the approval of a tentative or parcel map.” Requirements of the Quimby Act apply only to the acquisition of new parkland and do not apply to the physical development of new park facilities or associated operations and maintenance costs. The Quimby Act seeks to preserve open space needed to develop parkland and recreational facilities; however, the actual development of parks and other recreational facilities is subject to discretionary approval and is evaluated on a case-by-case basis with new residential development. The City of Dublin has adopted park fees as allowed by the Quimby Act, as described in greater detail below.

Water Supply
Senate Bill 610
SB 610 amended the Public Resources and Water Codes as they pertain to consultation with water supply agencies and water supply assessments. SB 610 requires Water Supply Assessments (WSA) for “projects” as that term is defined by Water Code Section 10912, which are subject to CEQA. The project does meet the definition of a project as specified in Water Code Section 10912 and has not been the subject of a previously adopted WSA or included in a WSA for a larger project; thus, a WSA is required and included as Appendix G.

Senate Bill 221
Whereas SB 610 requires a written assessment of water supply availability, SB 221 requires lead agencies to obtain an affirmative written verification of sufficient water supply prior to approval of certain specified subdivision projects. For this purpose, water suppliers may rely on an Urban Water Management Plan (if the project is accounted for within the UWMP), a Water 1199
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Supply Assessment prepared for the project, or other acceptable information that constitutes “substantial evidence.”
“Sufficient water supply” is defined in SB 221 as the total water supplies available during normal, single-dry and multiple-dry water years within the 20-year (or greater) projection period that are available to meet the projected demand associated with a project, in addition to existing and planned future uses. The project would develop more than 500 dwelling units and is therefore subject to the requirements of SB 221. The WSA provides verification of sufficient water supply to serve the project.

California Urban Water Management Planning Act
The California Urban Water Management Planning (UWMP) Act requires urban water suppliers to prepare an UWMP every five years and to file this plan with the Department of Water Resources, the California State Library, and any city or county within which the supplier provides water supplies. All urban water suppliers, either publicly or privately owned, providing water for municipal purposes either directly or indirectly to more than 3,000 customers or supplying more than 3,000 acre-feet annually are required to prepare an UWMP (CWC §10617).

The UWMP Act was enacted in 1983. Over the years, it has been amended in response to water resource challenges and planning imperatives confronting California. A significant amendment was made in 2009 as a result of the governor’s call for a statewide 20 percent reduction in urban water use by 2020. Colloquially known as 20x2020, the Water Conservation Act of 2009 (also referred to as SB X7-7) required urban retail water suppliers to establish water use targets for 2015 and 2020 that would result in statewide water savings of 20 percent by 2020. Beginning in 2016, urban retail water suppliers are required to comply with the water conservation requirements in SB X7-7 to be eligible for state water grants or loans.

Wastewater
San Francisco Bay Regional Water Quality Control Board
The San Francisco Bay RWQCB is the local division of the SWRCB that has oversight authority over the project. SWRCB is a State department that provides a definitive program of actions designed to preserve and enhance water quality and to protect beneficial uses of water in California. NPDES permits allow RWQCB to collect information on where the waste is disposed, what type of waste is being disposed, and what entity is disposing of the waste. RWQCB is also charged with conducting inspections of permitted discharges and monitoring permit compliance.

Solid Waste
California Integrated Waste Management Act
California’s Integrated Waste Management Act of 1989 (AB 939) requires that cities and counties divert 50 percent of all solid waste from landfills as of January 1, 2000, through source 1200
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reduction, recycling, and composting. AB 939 also establishes a goal for all California counties to provide at least 15 years of ongoing landfill capacity.

To help achieve this goal, the Act requires that each city and county prepare a Source Reduction and Recycling Element to be submitted to the Department of Resources Recycling and Recovery (CalRecycle), a department within the California Natural Resources Agency, which administers programs formerly managed by the State’s Integrated Waste Management Board and Division of Recycling.

As part of CalRecycle’s Zero Waste Campaign, regulations affect what common household items can be placed in the trash. Household materials—including fluorescent lamps and tubes, batteries, electronic devices and thermostats—that contain mercury are no longer permitted in the trash and must be disposed separately.

In 2007, SB 1016 amended AB 939 to establish a per capita disposal measurement system. The per capita disposal measurement system is based on a jurisdiction’s reported total disposal of solid waste divided by a jurisdiction’s population. CalRecycle sets a target per capita disposal rate for each jurisdiction. Each jurisdiction must submit an annual report to CalRecycle with an update of its progress in implementing diversion programs and its current per capita disposal rate.

California Solid Waste Reuse and Recycling Access Act of 1991 The California Solid Waste Reuse and Recycling Access Act of 1991 requires adequate space in all developments to be set aside for collecting and loading recyclable materials and organics.

The Act requires CalRecycle to develop a model ordinance for adoption by any local agency relating to adequate areas for collection and loading of recyclable materials as part of development projects. Local agencies are required to adopt the model, or an ordinance of their own, governing adequate areas in development programs for collection and loading of recyclable materials.

CALGreen Building Code
The California Green Building Standards Code (CALGreen) came into effect for all projects beginning after January 1, 2011. Effective January 1, 2017, Section 4.408, Construction Waste Reduction Disposal and Recycling, mandates that, in the absence of a more stringent local ordinance, a minimum of 65 percent of non-hazardous construction and demolition debris must be recycled or salvaged. The Code requires the applicant to have a waste management plan for on-site sorting of construction debris.

The City of Dublin has a more stringent requirement and requires that at least 65 percent for remodels and 75 percent for new construction by weight of the total construction and demolition debris generated by a project via reuse or recycling excluding asphalt and concrete debris of which 100 percent must be diverted, unless the applicant has been granted an infeasible exemption. The modified diversion requirement is equal to the maximum feasible 1201
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diversion rate established by the WMP Compliance Official for the project (Dublin Municipal Code Chapter 7.30).

16.4.3 Regional
Zone 7 Water Agency
Zone 7 is responsible for providing flood protection to the residents of Eastern Alameda County. Zone 7 owns and maintains drainage facilities within the Dublin city limits. Drainage plans for development projects must be reviewed by Zone 7 to ensure that the project does not propose any impacts to downstream facilities. In addition, development projects that involve work within Zone 7’s right‐of‐way or that involve construction, modification, or connection to a Zone 7 facility are required to obtain an Encroachment Permit and comply with Zone 7 standards and specifications.

Dublin San Ramon Services District
The Dublin San Ramon Services District (DSRSD) provides potable water and recycled water service within its service area. DSRSD’s 2020 Urban Water Management Plan UWMP was adopted by the DSRSD Board of Directors in June 2021. The 2020 UWMP includes existing and projected water demands for existing and projected future land uses within DSRSD’s service area.

The Water Shortage Contingency Plan (WSCP) describes the DSRSD’s strategic plan to prepare and respond to water shortage conditions resulting from a drought, regulatory action, emergency, or other types of events. It also includes defined actions to reduce demand over six shortage condition levels, from 10 percent to more than 50 percent demand reductions. The WSCP provides a guide for DSRSD to prevent catastrophic service disruptions and has been updated to be consistent with the 2018 Water Conservation Legislation requirements.

Alameda County Emergency Operations Plan
The purpose of the Alameda County Emergency Operations Plan (EOP) is to establish policies and procedures and assign responsibilities for effective management of emergency operations within Alameda County.

The County’s responses to disasters is based on five phases:

1. Prevention

2. Preparedness

3. Response

4. Recovery

5. Mitigation
During each phase, there are specified activities, operational capabilities and effective responses to a given disaster. The County’s Primary Emergency Operating Centers (EOC) is in Dublin at 4985 Broder Blvd approximately one-mile northwest of the project site. The EOC is 1202
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equipped with emergency power generators, radios, telephones, maps, and can be staffed 24- hours per day.

16.4.4 Local
City of Dublin General Plan
The City of Dublin General Plan establishes the following policies associated with public services and utilities that are relevant to the project:

Guiding Policy 3.4.2.1: Provide active parks and facilities which are adequate to meet citywide needs for open space, cultural, and sports facilities, as well as the local needs of the Eastern Extended Planning Area.

Guiding Policy 3.4.2.2: Establish a trail system with connections to planned regional and sub‐ regional systems, including north‐south corridors such as East Bay Regional Park District’s trail along Tassajara Creek north to Mt. Diablo State Park.

Implementing Policy 3.4.2.B.1: Require land dedication and improvements for the parks designated in the General Plan for the Eastern Extended Planning Area and based on a standard of 5 net acres per 1,000 residents. Collect in‐lieu park fees as required by City policies.

Guiding Policy 4.4.1.A.1: Ensure that adequate solid waste disposal capacity is available, to avoid constraining development, consistent with the Dublin General Plan.

Implementing Policy 4.4.1.B.3: Prior to project approval, the applicant shall demonstrate that capacity will exist in solid waste disposal facilities for their project prior to the issuance of building permits.

Implementing Policy 4.4.1.B.4: Large scale projects should be required to submit a plan that demonstrates how they will contribute toward the City’s State mandated diversion requirement.

Guiding Policy 4.5.1.A.1: Expand sewage treatment and disposal capacity to avoid constraining development consistent with the Dublin General Plan.

Implementing Policy 4.5.1.B.1: Prior to project approval, developers shall demonstrate that adequate capacity will exist in sewage treatment and disposal facilities for their projects prior to the issuance of building permits.

Guiding Policy 4.6.1.A.1: Base General Plan proposals on the assumption that water supplies will be sufficient and that local wells could be used to supplement imported water if necessary.

Guiding Policy 7.3.1.A.1: Maintain natural hydrologic systems. 1203
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Implementing Policy 7.3.1.B.1: Enforce the requirements of the Municipal Regional Permit for stormwater issued by the San Francisco Bay Regional Water Quality Control Board or any subsequent permit as well as Chapter 7 (Public Works) and Chapter 9 (Subdivisions) of the Dublin Municipal Code for maintenance of water quality and protection of stream courses.

Implementing Policy 7.3.1.B.2: Review development proposals to ensure site design that minimizes soil erosion and volume and velocity of surface runoff.

Guiding Policy 12.3.1.A.1: Work with Zone 7 and DSRSD to secure an adequate water supply for, and provide water delivery to, existing and future customers in Dublin.

Implementing Policy 12.3.1.B.1: In anticipation of planned future growth, continue working with DSRSD and Zone 7 to plan and provide for sufficient future water supplies.

Guiding Policy 12.3.2.A.1: Increase water conservation efforts and strive to maximize water use efficiency in existing residential, commercial, and industrial buildings and grounds.

Guiding Policy 12.3.2.A.2: Support DSRSD in extending recycled water service to established areas of Dublin.

Guiding Policy 12.3.3.A.1: Promote the conservation of water resources in new development Implementing Policy 12.3.3.B.1: Continue implementation of the Water Efficient Landscape Regulations, which requires grouping plants with the same water requirements together (hydrozoning), the installation of water‐efficient irrigation systems and devices, such as soil moisture‐based irrigation controls, and the minimal use of turf.

Implementing Policy 12.3.3.B.2: Support DSRSD’s ongoing efforts to extend recycled water infrastructure (“purple pipe”) to new locations.

Guiding Policy 12.3.5.A.1: Protect the quality and quantity of surface water and groundwater resources that serve the community.

Guiding Policy 12.3.5.A.2: Protect water quality by minimizing stormwater runoff and providing adequate stormwater facilities.

Guiding Policy 12.3.5.A.3: To minimize flooding in existing and future development, design stormwater facilities to handle design‐year flows based on buildout of the General Plan.

Implementing Policy 12.3.5.B.1: Support Zone 7’s efforts to complete planned regional storm drainage improvements.

Implementing Policy 12.3.5.B.2: With the goal of minimizing impervious surface area, encourage design and construction of new streets to have the minimum vehicular travel lane width possible while still meeting circulation, flow, and safety requirements for all modes of transportation.
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Implementing Policy 12.3.5.B.3: Discourage additional parking over and above the required minimum parking standards for any land use unless the developer can demonstrate a need for additional parking.

Implementing Policy 12.3.5.B.5: Review design guidelines and standard details to ensure that developers can incorporate clean water runoff requirements into their projects.

Implementing Policy 12.3.5.B.6: Maximize the runoff directed to permeable areas or to stormwater storage by appropriate site design and grading, using appropriate detention and/or retention structures, and orienting runoff toward permeable surfaces designed to manage water flow.

Implementing Policy 12.3.5.B.7: Review development plans to minimize impervious surfaces and generally maximize infiltration of rainwater in soils, where appropriate. Strive to maximize permeable areas to allow more percolation of runoff into the ground through such means as bioretention areas, green strips, planter strips, decomposed granite, porous pavers, swales, and other water‐permeable surfaces. Require planter strips between the street and the sidewalk within the community, wherever practical and feasible.

Implementing Policy 12.3.5.B.8: Continue conducting construction site field inspections to ensure proper erosion control and materials/waste management implementation to effectively prohibit non‐stormwater discharges.

Eastern Dublin Specific Plan
The City of Dublin’s Eastern Dublin Specific Plan establishes the following goals, policies and programs associated with public services, utilities and service systems that are relevant to the project:

GOAL: To ensure that fire protection services in eastern Dublin are consistent with standards maintained in the rest of the city.

Policy 8‐5: Time the construction of new facilities to coincide with new service demand in order to avoid periods of reduced service efficiency. The first station will be sited and construction completed prior to completion of initial development in the planning area.

Program 8F: Establish appropriate funding mechanisms (e.g., Mello Roos District, developer financing with reimbursement agreements, etc.) to cover upfront costs of capital improvements (i.e., fire stations and related facilities and equipment).

Program 8H: Based on approval by the City, incorporate applicable Dougherty Regional Fire Authority (DRFA) recommendations on project design relating to access, water pressure, fire safety and prevention into the requirements for development approval. Require that the following DPFA design standards are incorporated where appropriate:
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 Available capacity of 1,000 GPM at 20 PSI fire flow from project fire hydrants on public water mains. For groupings of one‐family and small two‐family dwellings not exceeding two stories in height, the fire flow requirements are a minimum of 1,000 GPM. Fire flow requirements for all other buildings will be calculated based on building size, type of construction, and location.
 Automatic fire alarm systems and sprinklers in all non‐residential structures for human use.
 Compliance with DRFA and City minimum road widths, maximum street slopes, parking recommendations, and secondary access road requirements.

GOAL: Provide adequate police services to the eastern Dublin planning area to ensure the health, safety and welfare of existing and future residents, workers, and visitors.

Policy 8‐4: Provide additional personnel and facilities and revise “beats” as needed in order to establish and maintain City standards for police protection service in eastern Dublin.

Program 8E: Incorporate into the requirements of project approval Police Department recommendations on project design that affects traffic safety and crime prevention.

GOAL: To provide an adequate water system for the Eastern Dublin Specific Plan area.

Policy 9‐1: Water Conservation. Require the following as conditions of project approval in eastern Dublin:
 Use of water‐conserving devices such as low‐flow showerheads, faucets, and toilets.  Support implementation of the DSRSD Water Use Reduction Plan and implementation of Best Management Practices (BMPs) for water conservation.  Require all developments to meet the BMPs of the Memorandum of Understanding regarding Urban Water Conservation in California, of which DSRD is a signatory.  Water efficient irrigation systems within public rights‐of‐way, median islands, public parks, recreation areas and golf course areas (see Program 9B on Water Reclamation).  Drought resistant plant palettes within public rights‐of‐way, median islands, public parks, recreation areas and golf course areas.
 Ensure that highly invasive plant species that could out‐compete native species and threaten wildlife habitat are not used in these areas. Species which should be prohibited include, but are not limited to: Acacia, Algerian Ivy, Bamboo, Mattress Vine, Black Locust, Blue Gum Eucalyptus, Castor Bean, Cotoneaster, English Ivy, French Broom, Fountain Grass, Giant Reed, German Ivy, Gorse, Ice Plant, Pampas Grass, Periwinkle, Pyracantha, Scotch Broom, Spanish Broom, Tamarisk, Tree of Heaven, and Tree Tobacco.
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 Water efficient irrigation and landscaping systems for residential, commercial, institutional, and industrial areas in accordance with AB325.  Adoption of a water efficient landscape ordinance by the City of Dublin that will apply to eastern Dublin development.
 Encourage the use of recycled water during construction for compaction and dust control.

Program 9B: Water Reclamation. Require the following as conditions of project approval in eastern Dublin:
 Implementation of DSRSD and Zone 7 findings and recommendations on uses of reclaimed water to augment existing water supplies.
 Construction of a recycled water distribution system in eastern Dublin as well as necessary offsite facilities to support recycled water use. Construction of such a recycled water system will require approval of the use of recycled water for landscape irrigation by DSRSD, Zone 7 and the San Francisco Bay Area Regional Water Quality Control Board.

Program 9E: DSRSD Standards. Require that design and construction of all water and recycled water system facility improvements be in accordance with DSRSD policies, standards and master plans.

Program 9F: Consistency With Resource Management Policies. Require the siting of water system infrastructure to be consistent with the Resource Management Policies of this plan.

Program 9G: Implementation Responsibilities. Require the Developer to obtain proper approvals; refer to attached Table 9.1, Water Service Matrix of Implementation responsibilities.

Program 9H: DSRSD Service. Require a “will‐serve” letter from DSRSD prior to grading permit approval.

GOAL: To provide adequate wastewater collection, treatment and disposal for the Eastern Dublin Specific Plan area.

Program 9K: Recycled Water Distribution System. Require development within the project to fund a recycled water distribution system computer model reflecting the proposed Specific Plan land uses and verify the conceptual backbone reclaimed water distribution system presented on Figure 9.3.

Program 9M: Design Level Wastewater Investigation. Require eastern Dublin applicants to prepare (in coordination with DSRSD) a detailed wastewater capacity investigation or supplement the information in the Specific Plan, which reflects the phased development approach matched against the allocation of sewer permits. Such an investigation shall include, at a minimum, a thorough estimate of planned land uses at the site and estimated wastewater 1207
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flows to be generated at the site. Base the estimation of the wastewater flows for sewer permits on the DSRSD approved wastewater flow factors.

Program 9N: DSRSD Service. Require a “will‐serve” letter from DSRSD prior to grading permit approval.

Program 9O: DSRSD Standards. Coordination with DSRSD Policies, Standards and Master Plans.

Require design and construction of all wastewater systems to be in accordance with DSRSD service policies, procedures, design and construction standards and master plans.

Program 9P: Onsite Wastewater Treatment. In conjunction with DSRSD, discourage onsite wastewater treatment systems such as package plants and septic systems in accordance with the policies of the San Francisco Bay Regional Water Quality Control Board.

Program 9Q: Connection to Public Sewers. Require all developments in the Specific Plan be connected to public sewers. Exceptions to this requirement, in particular septic tank systems, will only be allowed upon receipt of written approval from Alameda County Environmental Health Department and DSRSD.

Program 9R: Implementation Responsibilities. Require developers obtain proper approvals; refer to attached Table 9.2, Wastewater Service Matrix of Implementation Responsibilities.

GOAL: To provide adequate storm drainage facilities for the Eastern Dublin Specific Plan area.

Policy 9‐7: Require drainage facilities that will minimize any increased potential for erosion or flooding.

GOAL: To reduce the total flow of waste to landfill by promoting waste reduction, source separation, curbside collection, and other recycling alternatives to landfilling.

Policy 8‐8: Encourage the separation of recyclable materials from the general waste stream by supporting the development of a recycling collection system and facilities.

Program 8K: Prepare a solid waste management plan for eastern Dublin which includes the following:
 Specific areas designated for the collection of recyclable materials in multifamily and commercial areas, with coordination as needed for pick‐up.

GOAL: To provide a full complement of community services and facilities as needed in eastern Dublin.

Policy 8‐9: Coordinate with Pacific Gas and Electric and Pacific Bell in planning and scheduling future facilities which will serve eastern Dublin.
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Program 8‐L: Require project applicants to provide documentation that electric, gas, and telephone service can be provided to all new development.

City of Dublin Municipal Code
The City of Dublin Municipal Code contains all ordinances for the City. The Municipal Code is organized by Title, Chapter, and Section.

The City’s Fire Code, which is Section 5.08.020, regulates permit processes, emergency access, hazardous material handling, and fire protection systems, including automatic sprinkler services, fire extinguishers, and fire alarms. The Fire Code contains specialized technical regulations related to fire and life safety in the City.

City of Dublin Parks and Recreation Master Plan
The City of Dublin Parks and Recreation Master Plan was adopted in April 2022 by the City Council. The goal of the plan is to build and maintain parks and facilities that both enhance the positive image of the City and meet the needs of the City into the future. The Plan establishes goals, standards, guiding policies, and action programs to guide the City of Dublin in the acquisition, development, and management (operations and maintenance) of Dublin’s park and recreation facilities through the ultimate build-out of the City in accordance with the General Plan.

Local Impact Fees
Pursuant to SB 50 and Government Code Section 65994, Dublin Unified School District charges development fees on a per-square-foot basis for commercial and industrial uses.

Additionally, the City has fire, public facilities, noise mitigation and traffic impact fees.

16.5 Environmental Impacts and Mitigation Measures

16.5.1 Significance Criteria
The following significance criteria for public services, utilities, & service systems were derived from the Environmental Checklist in CEQA Guidelines Appendix G. These significance criteria have been amended or supplemented, as appropriate, to address Lead Agency requirements and the full range of impacts of the project.

An impact of the project would be considered significant and would require mitigation if it would meet one of the following criteria.
 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 1209
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other performance objectives for any of the following public services: Fire protection, Police protection, schools, parks, other public facilities.  Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board.
 Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects.
 Require or result in the construction of a new water storm drainage facilities or expansion of existing facilities, the construction of which could cause significant effects.  Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed.  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?
 Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste disposal needs.
 Comply with federal, state, and local statutes and regulations related to solid waste.  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.
 Includes recreational facilities or requires the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

The significance of each impact is identified according to the classifications listed below.

Class I: Significant impact; cannot be mitigated to a level that is less than significant.

Class II: Significant impact; can be mitigated to a level that is less than significant through implementation of recommended mitigation measures.

Class III: Adverse impact but less than significant; no mitigation recommended.

Class IV: Beneficial impact; mitigation is not required.

No Impact.

Public Services
Police and fire service providers were contacted to ascertain the current average response times, estimated response times, and current service levels that would be utilized in this impact 1210
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analysis. Impacts to these public services would be considered significant if average response times, service ratios or other performance standards could not be met, such that the construction of new or expanded facilities would be required to maintain said ratios, response times and/or other performance standards. The evaluation of school impacts is limited to those effects with the potential to result in the need for construction of new classrooms or placement of portable classrooms.

Utilities
Utility providers were contacted to ascertain utility services available to the project. Impacts to these utilities would be considered significant if utility service standards could not be met, such that the construction of new or expanded facilities would be required to maintain availability of utilities.

16.5.2 Summary of No and/or Beneficial Impacts
Compliance with Solid Waste Regulations
The project would be located within City limits and would be provided solid waste collection and disposal services by a licensed contractor requiring compliance with federal, state, and local solid waste regulations. Therefore, there would be no impact.

16.5.3 Impacts of the Proposed Project
Impact PSU-1: Introduce in a new service population requiring the construction of new or altered police, fire protection, or emergency medical services facilities (Class III).

Fire Protection and Emergency Medical Services
The nearest fire station (Station No. 17) is located 0.6 mile from the project site. Using an average travel speed of 25 miles per hour, a fire engine dispatched from the station would reach the project in less than two minutes, which is less than their eight-minute average for 90 percent of all incidents and well within the allowable travel time to meet the Fire Department's response time objective of five minutes for single unit and 10 minutes for multiple unit responses to the source. The Fire Department indicated that it expects to be able to serve the project with existing stations. The project site would be served with vehicle access point from all surrounding roadways and thus would meet California Fire Code requirements for emergency access.

Although the addition of new residents and commercial services to the project site would increase the demand for fire services, implementation of the project is not anticipated to have an adverse effect on response times for fire protection and emergency services and would not affect the Fire Department’s ability to serve the project or City at large.

The project would be required to comply with all applicable State building and fire codes.

These codes require a development plan that provides for fire protection systems, ingress and egress, maximum occupancy limitations, and construction techniques and materials dictated by 1211
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the proposed use of the structure (refer to the City of Dublin’s Municipal Code, Chapter 5.08, Fire Code).

Specifically, the Fire Department would review the development plan for conformance with locally-defined performance standards, including the California Fire Code, as adopted by the Fire Department, and California Building Code standards. Site access, capacity of the water mains, road widths and turning radii, road grades, surfacing, load bearing capability, sprinkler systems, stand pipes, smoke detectors, and fire alarms would also be reviewed for consistency with Fire Department standards.

The project will be required to fund on-site and off-site improvements consistent with existing City regulations and requirements. The City would collect public facilities fees (per Chapter

7.78 of the City of Dublin Municipal Code) from the project applicant to help off-set fire protection-related capital improvements and on-going maintenance expenses incurred by the project prior to issuance of a Building Permit.

Police Services
The Alameda County Sheriff’s Office, acting as Dublin Police Services, would serve the project with law enforcement services. The project would require additional police protection services associated with additional residential dwelling units and commercial uses. The project would be expected to generate 400 to 500 emergency calls annually.

Although the addition of new residents and commercial services to the project site would increase the demand for police services, implementation of the project is not anticipated to have an adverse effect on response times for police services and would not affect the Sheriff’s Office ability to serve the project.

The project would be required to comply with Chapter 7.32.300 (Building Security) and Chapter

7.32.310 (Nonresidential building security) of the City’s Building Code, which includes building standards aimed at reducing law enforcement calls within the City. In addition, the City would collect public facilities fees (Chapter 7.78 of the City of Dublin Municipal Code) to help off-set police service capital improvements and on-going maintenance expenses incurred by the project prior to issuance of a building permit to ensure that the project will not cause impacts on law enforcement services.

For these reasons, the project would not trigger the need to construct new police, fire, or emergency facilities or alter existing facilities. Therefore, impacts would be Class III, less than significant.

Impact PSU-2: Require the construction of new or expanded educational facilities (Class III).

Project Student Generation vs. Projected Student Generation Using the student generation rates identified in Table 16-6: Dublin Unified School District Student Generation Rates by Housing Type, the total number of students that would be 1212
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generated by the project were calculated. There would be 200 elementary students, 83 middle school students, and 71 high school students, for a total of 354 new students, generated by the project. The estimated number of students to be generated is shown in comparison to the number of students projected to be generated by the project site in the 7-Year Student Population Projections; see Table 16-7: Estimated Project Student Generation vs. DUSD Projections.

The DUSD’s 7-Year Student Population Projections (DUSD, 2019) projected future student population by Study Area based on future anticipated residential development between 2019 and 2025. The project site comprises all of Study Areas 120A and 106 and part of Study Areas 102 and 127. Therefore, the estimated student populations for those Study Areas are analyzed below.

Table 16-6: Dublin Unified School District Student Generation Rates by Housing Type School Level
Housing Type
Single Family Detached Single Family Attached Multi Family Elementary School (K-5) 0.427 0.303 0.152
Middle School (6-8) 0.156 0.128 0.086
High School (9-12) 0.141 0.095 0.106
Source: DUSD, 2019.

Table 16-7: Estimated Project Student Generation vs. DUSD Projections Residential Type
Students Generated
Total
Elementary
School Middle School High School
150 Single Family Units (Detached) 64 23 21 108
400 Medium-High Density Units (Single
Family Attached) 121 51 39 211
100 Multifamily Units 15 9 11 35
Total (A) 200 83 71 354
DUSD Projected Increase for the Project Site 1
(B) 212 110 172 494
Difference (A-B) (12) (27) (101) (140)
Notes:

1. Includes Study Areas 127, 120A, 106, and 102.

Source: DUSD, 2021b and DUSD, 2019.

As shown in Table 16-7: Estimated Project Student Generation vs. DUSD Projections, the project would generate 140 fewer students than those projected to be generated by Study 1213
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Areas 127, 120A, 106, and 102. However, as shown in Table 16-2: Dublin School District Existing Student Capacity and detailed below, DUSD is experiencing school capacity constraints, to which the project would contribute.

School Capacity
Elementary and high school DUSD facilities as a whole are operating over capacity as of Fall of 2020 while middle school facilities have a remaining capacity of three additional students. The project site is specifically served by Cottonwood Creek Elementary (1.5 miles west), Kolb Elementary School (0.5 miles east), Fallon Middle School (0.5 miles northeast), and Dublin High School (four miles west). Capacity and enrollment projections are discussed for each facility in detail below.

Cottonwood Creek Elementary School (K-5)
The existing elementary facilities at Cottonwood Creek Elementary School are currently 86.1 percent utilized. Total school enrollment is projected to increase to 1,115 students by 2025, an increase of 20.5 percent compared to Fall of 2018 enrollment. The elementary facilities are anticipated to be 92.0 percent utilized for the 2026/2027 school year. Therefore, Cottonwood Creek Elementary School is anticipated to have sufficient capacity to serve the projected elementary student population through at least Spring 2027.

Kolb Elementary School
Kolb Elementary School is projected to have a total enrollment of 925 students by 2025, an increase of 30.2 percent compared to Fall of 2018 enrollment. The school facilities are currently 89.2 percent utilized; however, they are projected to be 100.4 percent utilized by the 2026/2027 school year. Given this greater than 100 percent utilization, the school does not have sufficient capacity to support projected student growth. Portable classrooms may be needed to support future operation.

Elementary Schools District-Wide
There is an expected overall increase in elementary school (TK-5) enrollment of approximately 760 students by Fall of 2025 (a 12.2 percent increase compared to Fall of 2018 enrollment).

The existing elementary schools within the District are not anticipated to be able to absorb this projected student growth with Kolb and Murray Elementary Schools projected to operate at 100.4 percent and 135.9 percent utilization during the 2026/2027 school year. Development projections indicate the potential need for an additional flexible K-8 site to be constructed within the eastern or central portion of the District where most of the student growth is expected to occur.

Cottonwood Creek Elementary School (6-8)
The existing middle school facilities at Cottonwood Creek Elementary School are currently 80.2 percent utilized. Total school enrollment is projected to increase to 1,115 students by 2025, an increase of 20.5 percent compared to Fall of 2018 enrollment. The middle school facilities are anticipated to be 134.4 percent utilized for the 2026/2027 school year. Therefore, Cottonwood 1214
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Creek Elementary School is not anticipated to have sufficient capacity to serve the projected middle school student population. This projected demand supports the potential need to construct one more flexible K-8 site within the eastern or central portion of DUSD, which is planned in the Dublin Crossing Specific Plan.

Fallon Middle School
Fallon Middle School is projected to have a total enrollment of 1,583 students by 2025, an increase of 6.6 percent compared to Fall of 2018 enrollment. The school facilities are currently

95.4 percent utilized; however, they are anticipated to be 133.5 percent utilized by the 2026/2027 school year. Given this greater than 100 percent utilization, the school does not have sufficient capacity to support projected student growth. This projected demand supports the potential need to construct one more flexible K-8 site within the eastern or central portion of DUSD.

Middle-Schools District-Wide
Over the next seven years, the DUSD’s grade 6-8 student population is expected to continue to grow. There is an expected overall increase in enrollment of about 627 students by Fall of 2025 (a 23 percent increase compared to Fall of 2018 enrollment). All three existing middle schools are projected to operate at greater than 100 percent capacity for the 2026/2027 school year.

Therefore, projected demand indicates the potential need to construct one more flexible K-8 site within the eastern or central portion of the District where most of the resident student growth is expected to occur.

Dublin High School
It is projected that DUSD enrollment will increase by 1,248 students by Fall of 2025 (an increase of 40.9 percent compared to Fall of 2018 enrollment). The District indicates that much of this projected growth is due to the addition of approximately 650 new residential units per year that are projected for construction through 2023 and the number of larger class sizes currently at the elementary and middle school grades that are due to graduate through to high school in the next seven years.

Dublin High School is projected to have a student enrollment of 4,157 by 2025, 1,658 students more than its current capacity of 2,499. The high school facility is projected to operate at 131.9 percent capacity for the 2026/2027 school year. This projected high school facility demand supports the current construction of the new Emerald High School located at 3600 Central Parkway. According to the latest construction newsletter update, construction has commenced and will be complete by December 2023 with closeout in April 2024. Once fully operational, Emerald High School would have an enrollment of up to 2,500 students which would relieve the projected over-enrollment for Dublin High in 2025.

School Impact Fees
In accordance with Section 65995(h) of the California Government Code, the project would be required to pay school impact fees at the time of the building permit issuance. The DUSD 1215
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currently implements a Level 2 fee of $7.96 per square foot of residential development and $0.78 per square foot for commercial and industrial uses. These fees are used by the DUSD to mitigate impacts associated with long-term operation and maintenance of school facilities.

The project applicant’s fees would be determined at the time of the building permit issuance and would reflect the most current fee amount established by the DUSD. School fees from residential and commercial uses would help fund necessary school service and facilities improvements to accommodate anticipated population and school enrollment growth within the DUSD service area and would allow for the DUSD to allocate these funds as deemed necessary. Pursuant to Government Code Section 65995, payment of development fees is “full and complete mitigation” for impacts on schools. Therefore, the demand on the DUSD as a result of the project is considered a less than significant impact (Class III) on school services, and no mitigation is required.

Impact PSU-3: Create a need for new or expanded park and recreational facilities (Class III).

Implementation of the project would increase the demand for neighborhood and community parks due to the projected increase in the residential population generated by the project. As shown in Table 16-8: Community and Neighborhood Park Requirements, the project would not provide enough neighborhood or community parks.

Table 16-8: Community and Neighborhood Park Requirements Park Type
City Standard
(acres/ 1,000 population)
Park
Requirement 1 Parks Provided Net Difference
Community Park 3.3 5.94 0 (5.94)
Neighborhood Park 1.7 3.06 2.5 (0.56)
Total 5.0 9 2.5 (6.5)

1. Based on a total of 650 residential units at 2.77 persons per household (CA Department of Finance, 2021).

The Parks and Community Services Department Public Facilities Fee would be applied to development at the project site. The Public Facilities Fees would vary according to the size of residential units, the location of the development, and a credit for the dedication of land and funding for construction of the parks. With payment of the City’s public facilities fees (Chapter

7.78 of the City of Dublin Municipal Code), the project would have a less than significant impact (Class III) on park and recreation facilities in the City, and no mitigation is required.

Impact PSU- 4: Require new or expanded water supplies or water treatment facilities (Class III).

The project would connect to the existing water lines located within the surrounding roadways.

Connections would be looped for redundancy.

DSRSD provides both potable water and recycled water within its service area. However, on March 25, 2019, DERWA found that it cannot meet the combined peak demands and projected 1216
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demands of its member agencies (DSRSD and EBMUD) and the City of Pleasanton. DERWA approved Resolution No. 19-3 requesting that its member agencies take action to reduce recycled water demands and implement a connection moratorium due to limited recycled water supply during the peak months. Under this resolution, DSRSD implemented a connection moratorium for new recycled water connections starting March 25, 2019.

As described in the SCS Dublin Development Project Water Supply Assessment (WSA) (see Appendix G), the unit potable water demand factors used by DSRSD are shown in Table 16-9:

Project Potable Water Demand. These standard water use factors were developed for use in the DSRSD 2016 Water System Master Plan (WSMP) and have been refined based on actual water use trends observed in DSRSD’s water service area, and were used for water supply planning purposes in the DSRSD 2020 UWMP to project future potable water demands within DSRSD’s water service area.

The exterior water use factors presented in the WSMP assume extensive irrigation with recycled water and minimal potable water use. The WSA assumed exterior water use factors based on the current Model Water Efficient Landscape Ordinance (MWELO) guidelines.

However, if sufficient recycled water supplies become available in the future, then recycled water can be used to meet the project’s irrigation demands and potable water demand would be reduced to the WSMP exterior water use factors.

As shown in Table 16-9: Project Potable Water Demand, the project would generate a potable water demand of approximately 225 acre-feet per year (afy).

Table 16-9: Project Potable Water Demand
Use
Interior Water Use
Factor
Exterior Water Use
Factor (gpd)
Potable Water
Demand (afy)
General Commercial 1

0.14 7,217 52.29
255 -- 12.15
Medium Density Residential 255 5,100 51.29
Medium-High Density Residential 160 4,220 73.37
Public/Semi Public 1

0.05 1,555 1.74
255 30.39
Parks / Public Recreation 125 3,273 3.67
Total 224.9
Notes:

1. Conservatively assumes that the dwelling units associated with the general commercial and public/semi-public land use are medium density.

Source: DSRSD, SCS Dublin Project Water Supply Assessment, July 2022. 1217
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DSRSD operates an extensive water recycling program. Recycled water is produced from DSRSD’s regional wastewater treatment facilities and distributed to water customers in its service area. However, because recycled water supplies are unavailable for use at the project site, irrigation water demands for the project were assumed to be met with potable water.

Should sufficient recycled water supplies become available in the future, recycled water can be used to meet the project’s irrigation demands.

According to the DSRSD 2020 UWMP, sufficient potable water supply is available to meet the projected demand for the DSRSD in all hydrologic conditions including five-year droughts beginning in the time period analyzed (2025-2045). The UWMP determined projected water demand based on projected growth within the DSRSD service area, which includes the City of Dublin and the project site. Growth projections used by the UWMP for the City of Dublin were provided by the CA Department of Finance. The Regional Housing Needs Allocation (RHNA) for the City of Dublin was also used to project City growth. The project was analyzed in comparison to both of these growth projections in Chapter 15, Population and Housing in this document.

The UWMP also accounted for the build out of the EDSP, which includes the project site, as a major driver of water demand in the next 20 years.

As discussed in Chapter 15, Population and Housing, the project would not cause an increase in population growth beyond what is anticipated for the City of Dublin by the DOF or required by the 5th or 6th cycle RHNA. Additionally, DSRSD plans to continue to manage potable water demands within its service area through conservation efforts and its recycled water program for non-potable uses.

Though not anticipated, if water supply shortages should occur, DSRSD may invoke its Water Shortage Contingency Plan as described in the UWMP. Therefore, DSRSD would be able to supply potable water for the project with no water supply shortage or the requirement for expanded water supplies. Therefore, project impacts to water supply would be Class III, less than significant.

Impact PSU-5: Require the construction or expansion of new wastewater treatment facilities (Class III).

Conservatively, if all of the project’s potable water use exits the project site as wastewater, the project would generate 201 acre-feet per year. This wastewater would exit this site via existing connections to the wastewater line installed beneath Gleason Drive, Dublin Boulevard, Brannigan Street and Tassajara Road. Wastewater lines would be constructed as a part of the project beneath Central Avenue.

The project’s wastewater would be accommodated within the DSRSD Wastewater Treatment Plant. Per the DSRSD 2017 Wastewater Treatment and Biosolids Facilities Master Plan, DSRSD’s Wastewater Treatment Plant has a total capacity of 75 million gallons per day (mgd). As discussed in Impact PSU-4, the project would not result in the need for additional water supply. 1218
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Thus, the wastewater generated by the project site is also accounted for in DSRSD’s wastewater projection. Therefore, construction and operational impacts would be Class III, less than significant.

Impact PS-6: Require the construction or expansion of stormwater drainage facilities (Class III).

The rate and amount of surface runoff is determined by multiple factors, including the amount and intensity of precipitation; amount of other imported water that enters a watershed; and amount of precipitation and imported water that infiltrates to the groundwater. Infiltration is determined by several factors, including soil type, antecedent soil moisture, rainfall intensity, the amount of impervious surfaces within a watershed, and topography. The rate of surface runoff is largely determined by topography and the intensity of rainfall over a given period of time.

In accordance with MRP C.3 Requirements and Zone 7 flood control requirements, drainage for the project site would be designed to maintain the existing watershed drainage pattern and avoid any impact to downstream watersheds by reducing the post development runoff for the site to the predevelopment condition by incorporating low impact development features such as bioretention and Silva Cells to treat and reduce stormwater pollutants from entering into the municipal separate storm drain system. The grading design would maintain the north/south sloping layout of the land, matches existing grades along project perimeters, minimizes the use of retaining walls, while minimizing the earthwork cut and fill.

Although the project would increase the amount of impervious surface area within the project site, the use of on-site treatment and detention would prevent a substantial increase in stormwater flows. Furthermore, stormwater discharges from the project and other new developments in the City would be required to comply with the Construction General Permit, MRP Provision C.3 requirements, and incorporate appropriate site-specific LID and source and treatment control measures. Thus, the project would not result in an increase in stormwater runoff due to an increase in impervious surfaces and therefore would not require the construction or expansion of stormwater drainage facilities. Impacts would be less than significant (Class III).

Given that post stormwater run-off would not exceed existing pre stormwater runoff conditions, impacts from the project would be less than significant (Class III).

Impact PSU-7: Generate solid waste that would exceed the capacity of area landfills (Class III).

Solid waste generated by operation of the project is shown in Table 16-10: Proposed Project Estimated Daily Solid Waste Generation.
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Table 16-10: Proposed Project Estimated Daily Solid Waste Generation Land Use Unit lbs. per Unit per Day1 Total lbs. per Day Commercial Retail 265,000 sf 0.046 12,190
Residential 650 du 12.23 7,950
Hotel 140 rooms 4.00 560
Total -- -- 20,700
Notes:

1. U.S. Census 2009–2013 American Community Survey and CalRecycle, 2015b Source: Kimley-Horn, 2018
The 20,700 pounds of daily solid waste generated by the project would represent 0.18 percent of the Altamont Landfill permitted maximum daily throughput of 11,150 tons per day. As described above, the Altamont Landfill has adequate capacity.

The project would also generate waste during the construction phase. As stated above, CalGREEN Section 4.408, Construction Waste Reduction Disposal and Recycling, mandates that in the absence of a more stringent local ordinance, a minimum of 65 percent of non-hazardous construction (and demolition) debris must be recycled or salvaged. Adherence to the Building Code would reduce total waste generated by demolition and construction, and the waste would be appropriately sorted disposed at landfills with adequate capacity.

Construction and operational impacts would be Class III, less than significant.

16.5.4 Cumulative Impact Analysis
The geographic area for the analysis of cumulative public service and utility service impacts is the service area of provider.

Impact PSU-8: Contribute to cumulatively considerable public services, utilities and service system impacts (Class III).

Public Services
Regarding police and fire protection services, the General Plan includes provisions to provide adequate public services at projected buildout. The project, combined with past, present, and reasonably foreseeable future projects, would not exceed those projections, and impacts to police and fire protection services would be less than significant.

Regarding schools, the Dublin Unified School District is nearing capacity for the majority of its schools by 2024. State law deems new developments’ payment of the fees imposed by the DUSD, the amounts of which are restricted by law, adequate mitigation to address impacts to public schools. Developers of present and reasonably foreseeable future projects would be required to pay these fees and therefore, by law, impacts to schools would be less than significant.
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Utilities
Regarding water demand, the DSRSD has analyzed water demand for their service area through 2045—inclusive of past, present, and reasonably foreseeable future projects—and finds that adequate entitlement and water supply exists to serve development of the area.

Wastewater generation from cumulative projects would similarly be accommodated within the DSRSD’s Wastewater Treatment Facility’s total capacity of 17 million gallons per day (mgd), well above their current average treatment rates of 10.5 mgd during dry‐weather and 10.9 mgd during wet‐weather.

Regarding stormwater, the project would ensure that no net increase in stormwater would leave the project site during a peak storm event and would avoid cumulatively significant stormwater impacts to downstream waterways at times when capacity is most constrained.

The project would implement standard pollution prevention measures during construction to ensure that downstream water quality impacts are minimized to the greatest extent possible.

In addition, the project would provide water quality measures to prevent pollution during project operations.

Stormwater facilities in the project vicinity either have or will be required to have capacity to serve both the project and planned future development in the service area. Increases in runoff flow and volume from future development must be managed so that the post-project runoff does not exceed estimated pre-project rates and durations, in accordance with Municipal Regional Permit Provision C.3.g. Therefore, the project, in conjunction with other planned and approved projects, would not have a cumulatively significant impact related to storm drainage.

Regarding electricity and gas, energy impacts are addressed in Chapter 17 Energy Consumption.

Lastly, the Altamont Landfill has estimated a closure year of 2070, which is based upon anticipated tipping tonnage and volume, as well as capacity. Solid waste generation from past, present, and reasonably foreseeable future projects would be accommodated within those capacities.

In conclusion, cumulative impacts to public services, utilities and service systems would be less than significant (Class III).

16.5.5 Level of Significance after Mitigation
Table 16-11: Summary of Impacts and Mitigation Measures – Public Services summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to public services.
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Table 16-11: Summary of Impacts and Mitigation Measures – Public Services, Utilities & Service Systems Impact
Impact
Significance Mitigation
Impact PSU-1: Introduce in a new
service population requiring the
construction of new or altered
police, fire protection, or emergency
medical services facilities (Class III).

Less than
Significant
None required.

Impact PSU-2: Require construction
of new or expanded educational
facilities (Class III).

Less than
Significant
None required.

Impact PSU-3: Create a need for
new or expanded park and
recreational facilities (Class III).

Less than
Significant
None required.

Impact PSU-3: Require new or
expanded water supplies or water
treatment facilities (Class III).

Less than
Significant
None required.

Impact PSU- 4: Require new or
expanded water treatment facilities
(Class III).

Less than
Significant
None required.

Impact PSU-5: Require the
construction or expansion of new
wastewater treatment facilities
(Class III).

Less than
Significant
None required.

Impact PS-6: Require the
construction or expansion of
stormwater drainage facilities (Class
III).

Less than
Significant
None required.

Impact PSU-7: Generate solid waste
that would exceed the capacity of
area landfills (Class III).

Less than
Significant
None required.

Impact PSU-8: Contribute to
cumulatively considerable public
services, utilities and service system
impacts (Class III).

Less than
Significant
None required.

16.6 References
Alameda County Fire Department. 2022a. About Us webpage. Available at https://fire.acgov.org/AboutUs/aboutus.page?. Accessed April 7, 2022.

Alameda County Fire Department. 2022b. Service Area webpage. Available at https://fire.acgov.org/AboutUs/servicearea.page?. Accessed April 7, 2022. 1222
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CalRecycle. 2022a. Solid Waste Facilities, Sites, and Operation. Available at http://www.calrecycle.ca.gov/SWFacilities/. Accessed April 4, 2022.

CalRecycle. 2022b. Waste Characterization. Service Sector: Estimate Solid Waste Generation and Disposal Rates. Available at:
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates. Accessed April 4, 2022.

Ciceron, Ferdinand. 2008. Sanitary Sewer Design Standards. City of Oakland. Engineering Design & ROW Management Division. Department of Engineering and Construction.

Community & Economic Development Agency.

Citygate Associates. 2017. Alameda County Fire Department Standards of Coverage Review, Volume 2 of 3 – Technical Report. Available at https://fire.acgov.org/index.page.

Accessed April 7, 2022.

DERWA Board Meeting Agendas and Minutes. 2019. March 25, 2019 Agenda. Available at http://www.srvrwp.org/pdf/Agenda_032519.pdf. Accessed July 19, 2022.

Dublin Parks & Community Services. 2022. Parks & Community Services webpage. Available at https://www.dublin.ca.gov/90/Parks-Community-Services. Accessed April 7, 2022.

Dublin Police Services. 2021. 2020-2021 Annual Report. Available at https://dublin.ca.gov/2309/Annual-Report. Accessed April 7, 2022.

DSRSD (Dublin San Ramon Services District). 2022. SCS Dublin Development Project Water Supply Assessment.

DSRSD (Dublin San Ramon Services District). 2016. Water System Master Plan. Available at http://www.dsrsd.com/about-us/library/plans-studies. Accessed April 4, 2022.

DSRSD (Dublin San Ramon Services District). 2017. Wastewater Treatment and Biosolids Facilities Master Plan. Available at: http://www.dsrsd.com/about-us/library/plansstudies. Accessed April 4, 2022.

DSRSD (Dublin San Ramon Services District). 2018. AT Dublin Project Utilities Analysis.

DSRSD (Dublin San Ramon Services District). 2021. 2020 Urban Water Management Plan.

Available at https://www.dsrsd.com/about-us/library/plans-studies. Accessed April 4, 2022.

DUSD (Dublin Unified School District). 2019. 7-year Student Population Projections Packet by Residence, Fall 2019-2025. Available at
https://www.dublin.k12.ca.us/ourpages/auto/2020/10/19/54013061523437567031/7- 1223
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Year%20Student%20Population%20Projects%20Packet%20by%20Residence%20Fall%20 2019-2025.pdf. Accessed June 24, 2022.

DUSD (Dublin Unified School District). 2021a. 2020/21 Demographics and Alternative Enrollment Projections. Available at
https://go.boarddocs.com/ca/dublinusd/Board.nsf/files/C3JRGD6DE8FD/$file/Dublin%2 0Demographics%202020%20Alt%20updated.pdf. Accessed April 4, 2022.

DUSD (Dublin Unified School District). 2021b. School Facilities Needs Analysis. Available at https://www.dublin.k12.ca.us/ourpages/auto/2021/5/3/98608398437547812/DUSD_SF NA_Report_2021_FINAL_2021_05_03.pdf. Accessed April 4, 2022.

DUSD (Dublin Unified School District). 2022a. Overview webpage. Available at https://www.dublinusd.org/m/pages/index.jsp?uREC_ID=466634&type=d. Accessed April 7, 2022.

DUSD (Dublin Unified School District). 2022b. Emerald High School Construction Newsletter.

Available at
https://ehs.dublinusd.org/apps/news/show_news.jsp?REC_ID=780556&id=0. Accessed April 7, 2022.

Pacific Gas & Electric. 2022a. Company Profile. Available online http://www.pge.com/en/about/company/profile/index.page. Accessed April 4, 2022.

Pacific Gas & Electric. 2022b. Gas Transmission Pipeline. Available at http://www.pge.com/en/safety/systemworks/gas/transmissionpipelines/index.page.

Accessed April 4, 2022.

California State Allocation Board Meeting Agenda, February 23, 2022. Available at https://www.dgs.ca.gov/OPSC/Resources/Page-Content/Office-of-Public-School-ConstructionResources-List-Folder/State-Allocation-Board-Agendas. Accessed June 24, 2022.

Waste Management, Inc., 2022. Sustainability. Available at:
http://altamontlandfill.wm.com/sustainability/index.jsp. Accessed April 4, 2022.

Zone 7 Water Agency. 2021. 2020 Urban Water Management Plan. Available at https://www.zone7water.com/sites/main/files/fileattachments/0_final_2020_uwmp.pdf?1624903044. Accessed April 4, 2022. 1224
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17 Transportation

17.1 Introduction
This chapter evaluates the potential effects of the SCS Dublin project on the circulation system including vehicle miles traveled (VMT), transit, safety, bicycle and pedestrian facilities, and emergency access. Information used to prepare this section is referenced from the following resources:
 Aerial photography
 Project application and related materials
 Replica website (https://my.replicahq.com)
 Alameda County Transportation Commission, Congestion Management Program 2021
 Caltrans, Guide for the Preparation of Traffic Impact Studies, 2002  Caltrans, Vehicle Miles Traveled-Focused Transportation Impact Study Guide, 2020  City of Dublin, Bicycle and Pedestrian Master Plan, 2014  City of Dublin, Eastern Dublin Specific Plan, 1994, updated 2022  City of Dublin, General Plan, 1985 amended 2022
 City of Dublin, Impact Fees FY 2021-22
 City of Dublin, Resolution No. 199-12 Adopting a Complete Streets Policy  City of Dublin, Transportation Impact Analysis Guidelines, 2021  City of Livermore, General Plan,2004 amended 2021
 City of Pleasanton, General Plan, 2009 amended 2019
 City of Pleasanton, Pedestrian and Bicycle Master Plan, 2018  Fehr and Peers, Transportation Impact Study Report for North Central Roseville Specific Plan – Parcel 49, January 2015
 Kittelson & Associates, City of Dublin Citywide Travel Model Update, 2021 Model Update, July 2021
 Senate Bill 743 (regarding VMT)
 Transportation Research Board, Highway Capacity Manual 6th Edition (HCM 6)  Caltrans, Highway Design Manual, (HDM) 7th Edition
 Tri-Valley Transportation Council, Tri-Valley Transportation Plan and Action Plan for Routes of Regional Significance, 2017
Relative to level of service (LOS) analysis, Section 15064.3 was added to the State CEQA Guidelines effective December 28, 2018 as part of a comprehensive guidelines update and addresses the determination of significance for transportation impacts under CEQA. This section requires that transportation impact analysis be based on VMT instead of a congestion metric (such as LOS) and states that a project’s effect on automobile delay shall not constitute a 1225
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significant environmental impact. Per the City’s TIA Guidelines, projects which generate more than 50 peak hour trips or propose to amend a General Plan land use designation and substantially increase potential traffic generation must provide an analysis of the project at current planned land use versus proposed land use in the build out condition for the project area, including future cumulative conditions. Therefore, a separate transportation impact analysis that evaluates the project’s effect on traffic operations and intersection LOS will be provided in a separate document.

17.2 Scoping Issues Addressed
During the scoping period for the project, one letter from Caltrans and one letter from the City of Pleasanton regarding transportation and circulation was received. A meeting between City of Dublin Staff and City of Pleasanton Staff on May 10, 2022 clarified their comments. Concerns raised included the following:

17.2.1 Caltrans
 Provide justification if the project’s VMT is presumed to have a less-than significant VMT impact and is exempt from a detailed VMT analysis
 Provide a detailed VMT analysis if the project does not meet the screening criteria and include the following:
o Identify a VMT mitigation if necessary, which should support the use of transit and active transportation modes. Potential mitigation measures that include the requirements of other agencies such as Caltrans are fully enforceable through permit conditions, agreements, or other legally-binding instruments under the control of the City.
o Schematic illustration of walking, biking, and auto conditions at the project site and study area roadways.
o The project’s primary and secondary effects on pedestrians, bicycles, travelers with disabilities and transit performance should be evaluated, including countermeasures and trade-offs resulting from mitigating VMT increases. Access to pedestrians, bicycle, and transit facilities must be maintained.  Evaluate increased conflicts between bicyclists/pedestrians and vehicles at the Tassajara Road/Santa Rita Road/I-580 interchange area.
 Recommendation to upgrade bike/pedestrian facilities across the interchange to enhance bike and pedestrian safety. Consider the proposed Class II buffered bike lane project on Tassajara Road across the I-580 interchange (Project Ala-580-X10 in the Caltrans District 4 Bike Plan) as a potential project improvement to meet the needs of additional anticipated bicyclists generated by the project. 1226
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17.2.2 City of Pleasanton
 Require the developer to contribute its pro-rata share of the improvements to the I580 interchange pedestrian and bicycle improvements through the City of Dublin’s Traffic Impact Fee or by other means.

17.3 Environmental Setting
This section presents information on transportation and circulation conditions in the project area.

17.3.1 Existing Roadway Network
The project area is shown in Figure 17-1: Study Intersections. Regional access to the project site is from Interstate 580 (I-580). Regional project traffic is anticipated to primarily use the I580 ramps at Hacienda Drive, Tassajara Road, and Fallon Road. Local roadways serving the project site include Dublin Boulevard, Tassajara Road, Central Parkway, Brannigan Street, and Gleason Drive. Project driveways would be located on Gleason Drive, Central Parkway, Finnian Way, Dublin Boulevard, Tassajara Road, and Brannigan Street. Additional details are provided below for the existing street and highway system including transit, bicycle, and pedestrian facilities.

State Highways
Interstate 580 (I-580)
I-580 is part of the interstate freeway system and is located directly to the south of the project site. I-580 extends east-west connecting the project to the San Francisco Bay Area in the west and the City of Livermore and Interstate 5 in the east. The posted speed limit on I-580 is 65 miles per hour (mph) in the project area.

I-580 express lanes were opened in 2016 and are in operation Monday through Friday from 5:00 AM to 8:00 PM. I-580 is a designated route of regional significance in the Tri-Valley Transportation Plan and Action Plan for Routes of Regional Significance.

Arterials
Dublin Boulevard
Dublin Boulevard is an east-west roadway that bisects the southern portion of the project site.

It is classified as an arterial west of Tassajara Road and a collector east of Tassajara Road. This roadway serves existing residential, office, and retail land uses. Phase 1A of the Kaiser medical office building was constructed on the parcel south of Dublin Boulevard between Keegan Street/Kaiser Road and Lockhart Street. A portion of Phase 1B is under construction and is located on the vacant parcels south of Dublin Boulevard between Carnmore Place and Kaiser Road. The remaining Phase 2 to Phase 3 will be located on the parking area south of the 1227
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existing Kaiser Medical Center and the vacant parcels south of Dublin Boulevard between Kaiser Road and the existing Fallon Gateway retail center.

In addition, the Emerald High School is currently under construction and will be located to the east of the project site bounded by Central Parkway to the north, Dublin Boulevard to the south, Chancery Lane and Finnian Way to the west, and residential homes to the east. Primary vehicle access will be provided via Central Parkway with secondary access to the athletic field parking lot off Dublin Boulevard.

On-street parking is not permitted along this roadway and the posted speed limit is 45 mph in the project area. Dublin Boulevard is a divided roadway with five to six lanes in the project area.

Sidewalks exist along both sides of the roadway in the project area, except for along the project frontage. Class II bike lanes also exist along Dublin Boulevard.

The Dublin Boulevard Extension project to extend Dublin Boulevard 1.5 miles from Fallon Road to North Canyons Parkway in Livermore is currently in the design phase. The extension is planned to have four to six travel lanes with a median, Class II buffered bike lanes, sidewalks, a shared use path on the north, curb and gutter, traffic signals, street lighting, landscaped raised median islands, bus stops, and all city street utilities.

Fallon Road
Fallon Road is a north-south arterial extending east of the project site near the City of Dublin eastern border. The roadway primarily serves residential land uses, with retail located at the south end near the I-580 ramps. Westbound and eastbound ramps provide access to I-580.

On-street parking is not permitted along this roadway and the posted speed limit is 45 mph north of the I-580 ramps. The speed limit is 40 mph north of Bent Tree Drive (through Tassajara Road). Fallon Road is a divided roadway in the project area and varies from four lanes in between the I-580 ramps and Central Parkway, six lanes from Central Parkway to Gleason Drive, and four lanes from Gleason Drive to Tassajara Road.

Sidewalks exist along both sides of Fallon Road from south of Central Parkway to Signal Hill Drive/Kingsmill Terrace. Gaps exist in the sidewalk on Fallon Road including north of Signal Hill Drive/Kingsmill Terrace, and near Dublin Boulevard to south of Stoneridge Drive/Jack London Boulevard. Class II bike lanes exist along this roadway from north of the I-580 ramps to Tassajara Road. A Class IB sidepath also exists along this roadway between Gleason Drive and Tassajara Road. No bike lanes exist south of the I-580 ramps.

Tassajara Road
Tassajara Road is a north-south principal arterial extending along the project site (west side). It provides access to Camino Tassajara to the north, which connects to the City of San Ramon and 1228
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unincorporated Contra Costa County. I-580 eastbound and westbound ramps are located on this roadway.

On-street parking is not permitted on this road and the posted speed limit is 45 mph in the project area. North of Somerset Lane, the roadway varies between four divided lanes and two undivided lanes. It is a five-lane divided roadway from Somerset Lane to Cascade Creek Lane/Dublin Ranch Drive (two northbound lanes, three southbound lanes), a four-lane divided roadway from Cascade Creek Lane/Dublin Ranch Drive to Central Parkway, a five-lane divided roadway (two northbound lanes, three southbound lanes) from Central Parkway to I-580 ramps, and a six-lane divided roadway from I-580 ramps south into Pleasanton.

Sidewalks and Class II bike lanes exist along most of Tassajara Road. No sidewalks exist along the project frontage.

Minor Arterials
Brannigan Street
Brannigan Street is a two-lane, north-south minor arterial extending along the project site (east side). The roadway extends approximately 0.75 miles and primarily serves residential land uses, with a Lowes Home Improvement center and retail located south of Dublin Boulevard.

On-street parking is striped and permitted along approximately 0.25 miles of this roadway and the posted speed limit is 25 mph in the project area.

Sidewalk exists along Brannigan Street, except along the project frontage and along the undeveloped parcel south of Dublin Boulevard where Brannigan Street is a private street. A Class IB Sidepath exists along this roadway between Dublin Boulevard and Kohnen Way.

Central Parkway
Central Parkway is a three-mile two-lane divided east-west minor arterial that extends through the northern portion of the project site and serves residential land uses, as well as the offices located at the west end, Emerald Glen Park just west of Tassajara Road, James Dougherty Elementary School located east of Hacienda Drive, and Cottonwood Creek Elementary at the east end.

On-street parking is not permitted along this roadway except for a few short segments near residential uses on the east end of the roadway and in front of James Dougherty Elementary School. The posted speed limit is 35 mph in the project area.

Sidewalks exist along both sides of Central Parkway for a majority of the roadway except along both sides of the project frontages. Class II bike lanes exist along both sides of Central Parkway and a Class IB Sidepath exists exist along the roadway between Brannigan Street and Lockhart Street.
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Gleason Drive
Gleason Drive is two-mile east-west minor arterial extending north along the project site. The roadway primarily serves residential land uses, as well as the offices located at the west end of the road and Emerald Glen Park west of Tassajara Road.

On-street parking is not permitted along this roadway and the posted speed limit is 40 mph.

Gleason Drive is a four-lane divided roadway, except for a one-block stretch along the project frontage, where it is a two-lane divided roadway.

Sidewalks and Class II bike lanes exist along Gleason Drive, except for along the project frontage, where no sidewalks or bike facilities exist.

Hacienda Drive
Hacienda Drive is a north-south collector located west of the project site and extends approximately two and a half miles from the City of Dublin in the north, to the City of Pleasanton in the south. Hacienda Drive is classified as an arterial south of Dublin Boulevard.

The roadway connects nearby offices, corporate campuses, and retail to local single family and multifamily residential land uses. I-580 eastbound and westbound ramps are located on this roadway. A new IKEA store was approved in 2018 (not constructed) west of Hacienda Drive, east of Arnold Road, and between Martinelli Way to the north and I-580 to the south.

On-street parking is not permitted on this road and the posted speed limit is 35 mph. It is a three-lane divided roadway (two northbound lanes, one southbound lane) from Gleason Drive to Central Parkway, a five-lane divided roadway (two northbound lanes, three southbound lanes) from Central Parkway to Dublin Boulevard, and a six-lane divided roadway from Dublin Boulevard south into Pleasanton.

Sidewalks and Class II bike lanes exist along both sides of this roadway.

17.3.2 Pedestrian Facilities
Existing pedestrian facilities in the project area include sidewalks along the west side of Tassajara Road and on the east side of Brannigan Street from Dublin Boulevard to beyond the northern project site boundary. Sidewalks also exist on both sides of Gleason Drive, Central Parkway, and Dublin Boulevard from Tassajara Road to the east and from Brannigan Street to the west. No sidewalks currently exist along the project frontage

17.3.3 Bicycle Facilities
Bicycle facilities are divided into four classes. Class I bike paths are physically separated from motor vehicle lanes and is further divided into Class IA Multi-use Paths and Class IB sidepaths.

Class II bike lanes on roadways are marked by signage and pavement striping. Painted buffers may separate the vehicle travel lanes from the bike lane and green bike lane pavement coloring are used to highlight potential conflict zones between vehicles and cyclists. Class III bike routes share the travel lane with motor vehicles and have signs and sharrow striping to guide bicyclists 1230
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on paved routes. Class IV bike facilities are protected cycle tracks that provide a physical barrier between motor vehicles and cyclists. Figure 17-2: Existing Bicycle Facilities shows the bicycle facilities in the project area.

Direct access to bicycle facilities is provided adjacent to the project site including Class IB sidepaths along Brannigan Street, Finnian Way, Central Parkway, and Dublin Boulevard and Class II bike lanes along Tassajara Road, Gleason Drive, Central Parkway, and Dublin Boulevard.

17.3.4 Transit Facilities
Tri-Valley Wheels has multiple transit routes in the cities of Pleasanton, Dublin, and Livermore.

Many routes (such as Route 1, 3, 10R, etc.) operate within the project area, but do not operate near the project site. Only routes that service the nearby area of the project are described in this section. Figure 17-3: Existing Transit Facilities shows the transit facilities in the project area. Schedules for each route are current as of May 2022, but may change due to COVID-19 or other external factors.

Route 2 is a local bus route that operates between the East Dublin/Pleasanton BART Station to Positano Hill. In the project area, Route 2 operates on Central Parkway, Tassajara Road, Brannigan Street, and Gleason Drive. On weekdays, Route 2 operates between 7:33 AM to 8:20 AM and between 3:15 PM to 3:45 PM. Route 2 only operates a single trip in the morning and afternoon to serve Fallon Middle School and does not operate on Saturdays or Sundays. The closest bus stop is on Central Parkway at Glynnis Rose Drive.

Route 30R is a local bus route that operates between the West Dublin/Pleasanton BART Station to the Sandia Laboratory in Livermore, CA. In the vicinity of the project site, Route 30R operates on Dublin Boulevard. On weekdays, Route 30R operates between 5:14 AM to 10:50 PM in 30-minute headways. On weekends, Route 30R operates between 5:16 AM to 10:53 PM in 60-minute headways. The closest bus stop is on Dublin Boulevard at Glynnis Rose Drive and Grafton Street.

Route 501a, 501b, and 501c are Dublin School Routes that operate between Dublin High School to Positano Hill. In the vicinity of the project site, Route 501a operates on Gleason Drive, Tassajara Road, and Fallon Road, Route 501b operates on Gleason Drive, Tassajara Road, Central Parkway, and Fallon Road, and Route 501c operates on Dublin Boulevard and Fallon Road. In the morning, it operates between 7:38 AM to 8:10 AM. On Monday, Tuesday, and Thursday afternoons, it operates between 4:05 PM to 4:40 PM. On Wednesday afternoons, it operates between 3:06 PM to 3:41 PM. On Friday afternoons, it operates between 2:41 PM to 3:16 PM. The service is only provided on school days. The closest bus stop area is at the intersections along Gleason Street at Central Parkway and Tassajara Road and Central Parkway at Glynnis Rose Drive.

Route 502 is a Dublin School Route that operates between Dublin High School to the intersection of Central Parkway and Panorama Drive. In the vicinity of the project site, Route 502 operates on Tassajara Road, Dublin Boulevard, and Central Parkway. In the morning, it 1231
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operates between 7:32 AM to 8:10 AM. On Monday, Tuesday, and Thursday afternoons, it operates between 4:05 PM to 4:44 PM. On Wednesday afternoons, it operates between 3:06 PM to 3:45 PM. On Friday afternoons, it operates between 2:41 PM to 3:20 PM. The service is only provided on school days. Near the project site, there is a bus stop at the intersections along Central Parkway at Glynnis Rose Drive and Dublin Boulevard at Brannigan Street.

Route 504 is a Dublin School Route that operates between Dublin High School to the intersection of Gleason Drive and Brannigan Street. In the vicinity of the project site, Route 504 operates on Dublin Boulevard, Tassajara Road, Fallon Road, and Gleason Drive. In the morning, it operates between 7:41 AM to 8:10 AM. On Monday, Tuesday, and Thursday afternoons, it operates between 4:05 PM to 4:36 PM. On Wednesday afternoons, it operates between 3:06 PM to 3:37 PM. On Friday afternoons, it operates between 2:41 PM to 3:12 PM. The service is only provided on school days. The closest bus stops are along Gleason Drive at Tassajara Road and Brannigan Street.

17.4 Applicable Regulations, Plans, and Standards

17.4.1 Federal
Americans with Disabilities Act
The Americans with Disabilities Act (ADA) of 1990 prohibits discrimination toward people with disabilities and guarantees that they have equal opportunities as the rest of society to become employed, purchase goods and services, and participate in government programs and services.

The ADA includes requirements pertaining to transportation infrastructure. The Department of Justice’s revised regulations for Titles II and III of the ADA, known as the 2010 ADA Standards for Accessible Designs, set minimum requirements for newly designed and constructed or altered State and local government facilities, public accommodations, and commercial facilities to be readily accessible to and usable by individuals with disabilities. These standards apply to accessible walking routes, curb ramps, and other facilities.

Surface Transportation Assistance Act Routes (STAA – Federal Designation) The Surface Transportation Assistance Act (STAA) of 1982 allows large trucks, referred to as STAA trucks that comply with maximum length and width requirements, to operate on routes that are part of the National Network. The National Network includes the Interstate System and other designated highways that were a part of the Federal-Aid Primary System on June 1, 1991; states are encouraged, however, to allow access for STAA trucks on all highways.

17.4.2 State
Senate Bill 743 – Transportation Impacts
Adopted in 2013, Senate Bill (SB) 743 changes how transportation impacts are evaluated under CEQA. Previously, CEQA analysis was conducted using an LOS measurement that evaluated traffic delay. As specified under SB 743 and implemented under Section 15064.3 of the State 1232
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CEQA Guidelines (effective December 28, 2018), VMT is the required metric to be used for identifying CEQA impacts and mitigation. In December 2018, the Governor’s Office of Planning and Research (OPR) published a Technical Advisory on Evaluating Transportation Impacts, including guidance for VMT analysis. The Office of Administrative Law approved the updated CEQA Guidelines and lead agencies were given until July 1, 2020 to implement the updated guidelines for VMT analysis.

VMT was chosen as the primary metric to better integrate land use and multimodal transportation choices, to encourage alternative transportation, promote greater efficiency, and reduce GHG emissions. The most recent technical guidance on analyzing the transportation impacts under CEQA, released by OPR in December of 2018, provides recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. OPR offered a generalized recommendation of a 15 percent reduction below existing VMT as a threshold of CEQA significance.

For the VMT analysis, OPR recommends using a trip-based assessment of VMT that captures the full extent of the vehicle trip length – even the portion that extends beyond the jurisdictional boundary (trips that extend into another county). This differs from the traditional boundary- based assessment of VMT impacts that quantifies only the length of the vehicle trips that occurs within the boundaries of a jurisdiction.

Additionally, SB 743 also amended the State congestion management program statutes lifting the sunset clause for the designation of infill opportunity zones, where CMP LOS standards would no longer apply.

California Complete Streets Act of 2008
This act requires that the circulation elements of local general plans accommodate a balanced, multimodal transportation network that meets the needs of all users of streets, roads, and highways in a manner that is suitable to the rural, suburban, or urban context of the jurisdiction. Users are defined to include motorists, pedestrians, bicyclists, children, persons with disabilities, seniors, movers of commercial goods, and riders of public transportation.

California Transportation Development Act
The Mills-Alquist-Deddeh Act (SB 325) (also known as the Transportation Development Act [TDA]) was enacted in 1971 to improve public transportation services and encourage regional transportation coordination. This law provides funding to be allocated to transit- and nontransit-related purposes that comply with regional transportation plans. The TDA provides two funding sources: 1) the Local Transportation Fund (LTF), which is derived from a ¼ cent of the general sales tax collected statewide, and 2) the State Transit Assistance fund (STA), which is derived from the statewide sales tax on diesel fuel.

California Environmental Quality
The Steinberg Act (SB 743) (also known as the Environmental Act) was enacted in 2013 to shift the focus of transportation analysis from driver delay to reducing greenhouse gas emissions, 1233
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creating multimodal networks, and promoting mixed land uses. SB 743 requires the Governor’s Office of Planning and Research to amend the CEQA Guidelines to provide alternative level of service metrics for transportation impact evaluations. The alternative criteria must encourage greenhouse gas emissions reductions, support the development of multimodal transportation networks, and promote a diversity of land uses. In August 2014, OPR released a preliminary discussion draft of changes to the CEQA Guidelines for review and comment. Starting on July 1, 2020, agencies analyzing the transportation impacts of new projects must now look at a metric known as vehicle miles traveled (VMT) instead of LOS. VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto our roads, the project may cause a significant transportation impact.

Under the new guidelines, measurements of transportation impacts may include vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.

17.4.3 Local
City of Dublin General Plan
The City of Dublin General Plan establishes the following policies associated with transportation that are relevant to the project:

Guiding Policy 5.2.2.A.1: Design streets to (1) include sufficient capacity for projected traffic, (2) minimize congested conditions during peak hours of operation at intersections, (3) serve a variety of transportation modes including vehicles, bicycles, pedestrians and transit, and variety of users including people with disabilities, children, and seniors, (4) provide continuity with existing streets, and (5) allow convenient access to planned land uses.

Guiding Policy 5.2.2.A.3: The goals, policies, and implementation measures for street design in Section 10.8 of the Community Design and Sustainability Element should be consulted when new streets are being designed and/or existing streets are being modified.

Guiding Policy 5.2.2.A.4: Reserve right-of-way and construct improvements necessary to allow streets to accommodate projected vehicular traffic with the least friction.

Guiding Policy 5.2.2.A.6: The City shall strive to phase development and roadway improvements so that the operating Level of Service (LOS) for intersections in Dublin does not exceed LOS D.

However, intersections within the Downtown Dublin Specific Plan area (including the intersections of Dublin Boulevard/San Ramon Road and Village Parkway/Interstate 680 onramp) are excluded from this requirement and may operate at LOS E or worse as long as the safety for pedestrians and bicyclists is maintained and impacts to transit travel speeds are minimized.
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Guiding Policy 5.2.2.A.7: The City will comply with all provisions of the Alameda County Congestion Management Program and will review proposed development projects to ensure compliance with this Program.

Implementing Policy 5.2.2.B.1: Design streets according to the forecasted demand and maximum design speeds listed above, and to the detailed standards set forth in the City of Dublin’s Street Design Standards and Standard Plans which are maintained by the Public Works Department, as well as the listed Additional Policies.

Implementing Policy 5.2.2.B.2: Design and construct all roads in the City’s circulation network as defined in Figure 5-1 [Exhibit 3.6-4a] as well as bicycle and pedestrian networks as defined in the City of Dublin Bicycle and Pedestrian Master Plan.

Guiding Policy 5.2.3.A.1: Provide an integrated multi-modal circulation system that provides efficient vehicular circulation while providing a design that allows safe and convenient travel along and across streets for all users, including pedestrians, bicyclists, persons with disabilities, seniors, children, youth, and families; and encourages pedestrian, bicycle, transit, and other non-automobile transportation alternatives.

Implementing Policy 5.2.3.B.1: Provide continuity with existing streets, include sufficient capacity for projected traffic, and allow convenient access to planned land uses.

Guiding Policy 5.3.1.A.1: Support improved local transit as essential to a quality urban environment, particularly for residents who do not drive.

Guiding Policy 5.3.1.A.2: Support the development of a community that facilitates and encourages the use of local and regional transit systems.

Guiding Policy 5.3.1.A.3: Encourage improvements in the Enhanced Pedestrian Areas to improve the walkability of these areas.

Guiding Policy 5.3.1.A.4: Maintain enhanced signal coordination and limit intersection delays on major and RAPID transit routes to minimize delays to transit service.

Implementing Policy 5.3.1.B.2: Require dedication of land and the construction of improvements to support the use of public transit in the community. Improvements could consist of bus turnouts, shelters, benches, real time arrival information, and other facilities that may be appropriate.

Implementing Policy 5.3.1.B.4: Capitalize on opportunities to connect into and enhance ridership on regional transit systems including BART, LAVTA and any future light rail systems.

Guiding Policy 5.4.3.A.1: Plan for all users by creating and maintaining Complete Streets that provide safe, comfortable, and convenient travel along and across streets (including streets, roads, highways, bridges, and other portions of the transportation system) through a 1235
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comprehensive, integrated transportation network that meets the requirements of currently adopted transportation plans and serves all categories of users.

Guiding Policy 5.4.3.A.2: Be context aware by maintaining sensitivity to local conditions and needs in both residential and business districts as well as urban, suburban, and rural areas, and will work with residents, merchants, and other stakeholders to ensure that a strong sense of place ensues.

Guiding Policy 5.4.3.A.6: Encourage developers to implement Complete Streets in private transportation infrastructure by providing guidance during the development approval process.

Guiding Policy 5.5.1.A.1: Provide safe, continuous, comfortable and convenient bikeways throughout the City.

Guiding Policy 5.5.1.A.2: Improve and maintain bikeways and pedestrian facilities and support facilities in conformance with the recommendations in the Dublin Bicycle and Pedestrian Master Plan.

Guiding Policy 5.5.1.A.3: Enhance the multi-modal circulation network to better accommodate alternative transportation choices including BART, bus, bicycle, and pedestrian transportation.

Guiding Policy 5.5.1.A.4: Provide comfortable, safe, and convenient walking routes throughout the City and, in particular, to key destinations such as Downtown Dublin, the BART Stations, schools, parks, and commercial centers.

Implementing Policy 5.5.1.B.2: Improve bikeways, bicycle support facilities, and pedestrian facilities in accordance with the Dublin Bicycle and Pedestrian Master Plan in conjunction with development proposals.

Implementing Policy 5.5.1.B.3: Ensure on-going maintenance of bikeways, bicycle support facilities and pedestrian facilities that are intended for public use and located on private property in conjunction with development proposals.

Guiding Policy 5.6.1.A.1: Designate and accommodate truck routes to minimize noise nuisance on residential arterial streets.

Implementing Policy 5.6.1.B.2: Take advantage of opportunities to provide long-term truck parking facilities.

Guiding Policy 5.9.1.A.1: Continue the city’s program of requiring developers to contribute fees and/or improvements to help fund off-site improvements related to their projects.

City of Dublin Eastern Dublin Specific Plan
The Eastern Dublin Specific Plan establishes the following policies associated with transportation that are relevant to the project:
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Policy 4-24: Require all employment-related development to provide convenient and attractive pedestrian, bicycle, and transit-related facilities to encourage alternate modes of commuting to and from work.

Policy 4-31: Establish a convenient, multi-use, all-weather network of trails, including bike lanes, to link planning area parks, recreation facilities, schools, employment centers and major open space areas to each other and to the surrounding community.

Policy 5-2: Require all development to provide a balanced orientation toward pedestrian, bicycle, and automobile circulation.

Policy 5-3: Plan development in eastern Dublin to maintain Level of Service D or better as the average intersection level of service at all intersections within the Specific Plan area during AM, PM and midday peak periods. The average intersection level of service is defined as the hourly average.

Policy 5-12: BART service to the eastern Dublin/Pleasanton station orients local transit service to provide transit connections between the BART station and all portions of the Specific Plan area.

Policy 5-13: Establish design guidelines for residential and commercial development so that there are clear and safe pedestrian paths between building entrances and transit service stops.

Policy 5-14: Provide transit shelters at major limit stops and bus pullouts on major collector, arterial and major arterial streets.

Policy 5-18: Provide convenient and secure bicycle parking and support facilities at key destinations in eastern Dublin, such as schools, recreation areas, transit stops and commercial centers.

Policy 5-19: Parking requirements in eastern Dublin shall be kept to a minimum consistent with actual parking needs. Allowance shall be made for shared parking in mixed-use areas. Parking requirements may be reduced wherever it can be demonstrated that use of alternative transportation will reduce parking demand.

Policy 5-21: Require all non-residential projects with 50 or more employees to participate in a Transportation Systems Management (TSM) program.

City of Dublin Bicycle and Pedestrian Master Plan
The City of Dublin Bicycle and Pedestrian Master Plan establishes the following guiding and implementing policies associated with transportation that are relevant to the project:

Policy 2-1: Implement and maintain an integrated transportation network that allows safe and convenient travel along and across streets for all users, including pedestrian and bicyclists’ 1237
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needs and access at key destinations, such as Downtown Dublin, transit stations, and other major destinations.

Policy 2-2: Expand the existing bicycle network on the basis of access to key destinations as per Policy 2-1 above to provide low-stress, bicycle facilities if right of way allows such as buffered bicycle lanes on arterial and collector roadways where appropriate and bicycle routes with sharrows on low-volume residential streets.

Policy 2-3: Require short-term and long-term bicycle parking consistent with the latest version of the California Green Building Standards Code.

Policy 3-1: As a condition of project approval, require private development projects to construct bicycle and pedestrian facilities on site and in the adjacent public right-of-way included in the proposed bicycle system as well as bicycle parking and amenities in accordance with the California Green Building Standards Code. Consider requiring large development projects to provide accessible mid-block cut throughs (or “paseos”).

Policy 3-2: Consult the recommended bicycle and pedestrian network maps and project lists prior to implementation of traffic signals, signal upgrades, and resurfacing/restriping projects.

Policy 3-3: Install pedestrian countdown signals, modify pedestrian clearance intervals on actual walking speed observed in the field, implement density operations (Flash Do Not Walk timing extension for slow walkers, etc.), and install, replace, and upgrade bicycle signal detectors, as necessary, per the California Manual Uniform of Traffic Control Devices (CA MUTCD) with new signal installation and signal modification projects, whenever possible.

Policy 3-4: Implement the City’s Complete Streets Policy by reviewing the transportation network, block size, and development patterns of all proposed projects for consistency with this Plan, the Downtown Dublin Specific Plan, and the Dublin Complete Streets Policy.

Policy 3-7: Continue to implement the City Bicycle and Pedestrian Guidelines on all City capital and private development projects as required by the City. Allow the update of the design guidelines to incorporate the latest MUTCD standards.

In addition to the policies above, the City is currently updating their Bicycle and Pedestrian Master Plan with the following additional proposed projects near the project site:
 Conduct a Complete Streets study to identify bicycle and pedestrian improvements on Tassajara Road, Dublin Boulevard, and Gleason Drive along the project frontage and to determine the feasibility of Class I or Class IV bicycle facilities along these roadways.
 Construct a Class I bicycle path along Central Parkway.  Construct a Class II buffered bicycle lane and evaluate opportunities to lower the speed limit along Central Parkway and Gleason Drive.
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 Improve bicycle and pedestrian access at the intersections of Tassajara Road/Gleason Drive, Brannigan Street/Central Parkway, Brannigan Street/Dublin Boulevard, and Gleason Drive/Brannigan Street, which may include evaluating and designing appropriate protected intersection elements.
 Redesign I-580 interchange ramp terminals at Tassajara Road and Fallon Road to provide safe crossings.

It should be noted that the above projects have not been formally adopted yet and therefore this project would only need to be consistent with the adopted City of Dublin Bicycle and Pedestrian Master Plan in 2014.

Resolution No. 199-12 Adopting a Complete Streets Policy The City adopted Resolution No. 199-12 on December 4, 2012, which states that the City will create and maintain Complete Streets to provide a safe, comfortable, and convenient travel across streets through a comprehensive, integrated transportation network that meets the adopted current transportations plans and General Plan. The City shall maintain, plan, and design projects affecting the transportation system to be consistent with the City’s General Plan, as well as bicycle, pedestrian, transit, multimodal, and other relevant plans. The Complete Streets Policy shall also serve all categories of users including pedestrians, bicycles, persons with disabilities, motorist, movers of commercial goods, users and operations of public transportation, emergency responders, seniors, children, youth, and families.

Developers and private land owners will be encouraged to implement complete streets in private developments through the consistent application of the complete streets elements.

City of Dublin Impact Fees FY 2021-22
The City of Dublin has developed impact fees to be paid by developers for all or a portion of the costs of the construction and acquisition of transportation facilities. These facilities mitigate impacts of developments within the City and assists in implementing the goals and objectives of the City’s General Plan and the Eastern Dublin Specific Plan. The proposed project will be subject to the Eastern Dublin Transportation Impact Fee residential and non-residential rates and the Tri-Valley Transportation Development Fee. Residential impact fees are based on the project’s density (i.e., the number of units per acre). Non-residential impact fees are based on the land use measurement units (e.g., per student for schools or per bed for hotels) or based on the fee rate, PM peak hour trip rate multiplier, and square feet of the project.

City of Dublin Local Roadway Safety Plan (in progress)
The City is currently developing a Local Roadway Safety Plan (LRSP). The project’s consistency with the LRSP will be reviewed during the Site Development Review Permit process, as needed.

City of Dublin Transportation Impact Analysis Guidelines The City’s Transportation Impact Analysis (TIA) Guidelines (July 2021) provides guidance to City staff, applicants, and consultants on the requirements to evaluate transportation impacts for 1239
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projects in the City of Dublin. For projects subject to CEQA, the TIA must include an evaluation that addresses the CEQA statute. In addition, the TIA must include a local operational evaluation. The level of analysis will vary based on the size, type and location of the project. A TIA for a simple project may include trip generation estimates, brief documentation of VMT for CEQA compliance, and a site plan review. More complex projects may require a detailed VMT analysis, and an intersection operations analysis documenting the project’s effect on the local transportation infrastructure.

17.5 Environmental Impacts and Mitigation Measures

17.5.1 Significance Criteria
CEQA Criteria
The following significance criteria for transportation and circulation were derived from the Environmental Checklist in CEQA Guidelines Appendix G. These significance criteria have been amended or supplemented, as appropriate, to address lead agency requirements and the full range of potential impacts related to this project.

The CEQA Transportation Guidelines were reviewed to determine the level of impact (potentially significant impact, less than significant with mitigation incorporated, less than significant impact, or no impact). A mitigation would be required if the project resulted in a significant impact for one of the following criteria:
 Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.  Conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).  Result in inadequate emergency access.

City of Dublin Transportation Impact Analysis Guidelines Implementation of the project would have a significant transportation impact if it would result in VMT exceeding the thresholds defined in the City of Dublin Transportation Impact Analysis (TIA) Guidelines. Section 4.3.4 of the Guidelines defines the thresholds of significance by land use type as:
 Residential Projects: A significant impact occurs if a Proposed Project VMT/capita is greater than 15 percent below the existing Planning Area 4.  Office Projects: A significant impact occurs if a Proposed Project VMT/employee is greater than 15 percent below the existing Planning Area 4 average. 1240
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 Retail Projects: A significant impact occurs if a Proposed Project causes a net increase in total VMT. The total VMT for Planning Area 4 without and with the project is calculated. The difference between the two scenarios is the net change in total VMT that is attributable to the project.
 Other Development Projects: The City will make a determination of the applicable thresholds on a case-by-case basis based on the land use type, project description and setting. Generally, these projects will be analyzed based on how similar they are to residential, office, and retail projects.
o Student housing and senior housing land uses for example should be treated as residential for screening and detailed VMT analysis. o Research and development, industrial, medical offices, and hospital projects may be evaluated as office projects using the VMT/employee metric. o Project such as hotels, private schools, religious institutions, and regional parks, should be treated as retail for detailed VMT analysis.  Mixed-Use Projects: Evaluate each component of a mixed-use project independently and apply the significance threshold for each land use type.

Alternatively, the evaluation would apply only to the project’s dominant use if it generated 80 percent of total daily trips.

17.5.2 Summary of No and/or Beneficial Impact
There are no “no” impacts nor “beneficial” impacts.

17.5.3 Impacts of the Proposed Project
TRANS-1: Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities (Class III).

The following describes the project’s potential impact on transit, bicycle, and pedestrian circulation as it relates to City programs, plans, ordinances, or policies.

Transit Access and Circulation
The project proposes access for pedestrians to use public transit. Sidewalks and crosswalks are proposed adjacent to the project site to allow for pedestrians to access to existing and future bus stops nearby. Route 2 has its closest bus stop on Central Parkway at Glynnis Rose Drive.

Route 30R has its closest bus stop on Dublin Boulevard at Glynnis Rose Drive and Grafton Street. Route 501 has its closest bus stop area at the intersections along Gleason Street at Central Parkway and Tassajara Road and Central Parkway at Glynnis Rose Drive. Route 502 has its closest bus stop along Central Parkway at Glynnis Rose Drive and Dublin Boulevard at Brannigan Street. Route 504 has its closest bus stops on Gleason Drive at Tassajara Road and Brannigan Street.
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It is anticipated that in coordination with LAVTA on the future Site Development Review Permit, additional bus stops along the project frontage including but not limited to the frontage along Dublin Boulevard. Each of these existing and future bus stops are accessible to the project site via pedestrian walkways. Therefore, the project would result in a less than significant impact related to City’s transit programs, plans, ordinances, or policies.

Bicycle Access and Circulation
The project is proposing to construct Class II bicycle lanes along Gleason Drive between Tassajara Road and Brannigan Street to fill in the gaps in the bicycle facility. The project is not proposing nor responsible for providing any bicycle facilities on Tassajara Road between the I580 westbound and eastbound ramps to connect the City of Dublin bicycle network to the City of Pleasanton bicycle network. This is consistent with the proposed bicycle network outlined in the City’s Bicycle and Pedestrian Master Plan. In addition, the project is not proposing to alter existing bicycle facilities. Therefore, the project would result in a less than significant impact related to City’s bicycle programs, plans, ordinances, or policies.

Pedestrian Access and Circulation
The project is proposing to construct sidewalks along its frontage to fill in the gaps in the pedestrian facility. These proposed sidewalks connect to the existing sidewalks and crosswalks adjacent the site to allow residents, employees, and patrons access to nearby transit facilities, as well as residential and commercial uses surrounding the project site. In addition, the project is not proposing to alter existing pedestrian facilities. Therefore, the project would not conflict with plans, ordinances, or policies as it relates to pedestrian facilities and would result in a less than significant impact.

TRANS-2: Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b) regarding Vehicle Miles Traveled (Class I).

Per City of Dublin TIA Guidelines, each unique land use for the mixed-use project was analyzed separately to determine if the land use would result in a significant VMT impact. Section 4.2 of the City of Dublin TIA Guidelines also provides criteria for land use types and intensities that screen out from requiring a detailed VMT analysis because the nature of these land uses is presumed to have a less than significant VMT impact.

Table 17-1: VMT Analysis Results by Project Land Use provides a summary of proposed Project land uses, the analysis methodology for determining a VMT impact, and the significance findings by land use type. The remainder of this section details specific assumptions, justifications, analysis methodologies, and results for each Project land-use type. 1242
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Table 17-1: VMT Analysis Results by Project Land Use
Land Use Type Description
Analysis
Methodology Significance Finding
Residential Multi-family and Single-family Housing
(market-rate)
Travel Demand
Model Analysis Less than Significant
Affordable
Housing Below market rate dwelling units Screen-Out Less Than Significant Hotel 140-room hotel Screen-out Less than Significant
Local Retail Strip retail plaza, casual dining, drive-thru restaurant, bowling/entertainment venue Screen-out Less than Significant Regional Retail 120-bay Topgolf facility Off-Model
Analysis Significant Impact
Park/Recreation 0.8- and 1.7-acre park and green space Screen-out Less than Significant Residential (Market rate)
Consistent with City TIA Guidelines, the City of Dublin Travel Demand Model was used as the principal tool to determine VMT impacts for the project’s market-rate residential land uses.

The City of Dublin Travel Demand Model is an area specific version of the Alameda County Transportation Commission (ACTC) Travel Demand Model which has a base year of 2020 and a future year of 2040. The base year of the model was used to determine existing residential households and population, as well as residential associated VMT. This was used to calculate the average VMT per capita for Planning Area 4, to establish the threshold of significance defined at 15 percent below the average. Table 17-2: Dublin Travel Demand Model Residential VMT Threshold shows the results of this analysis including the target residential per capita VMT threshold of 24.7.

Table 17-2: Dublin Travel Demand Model Residential VMT Threshold Location
Total
Population
Total Household
VMT VMT/Capita
Regional Average (Planning Area 4) 238,459 6,931,247 29.1 Significance Threshold (15% Below average) 24.7
Project residential VMT was calculated using the City Travel Demand Model for both 2020 and 2040 model years. Project land uses were converted into household, employment, and population data to be included in the model. Project traffic analysis zones (TAZs) within the model were updated with this household, employment, and population data per guidelines provided in the Draft City of Dublin Citywide Travel Model Update (2021). These TAZs included 1016, 1021, and 1041. Assumptions regarding conversion from dwelling units to household population were based on existing ratios for adjacent model TAZs present in the model. Splits between service and retail employees were calculated at the following rates:
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 Hotel: 1 service employee per 5 rooms
 Commercial: 1 retail employee per 500 square feet
Model outputs including the total VMT per population were aggregated for the three TAZs from the model associated with the project and were used to calculate average VMT per capita for the project in the 2020 and 2040 model scenarios. Table 17-3: Dublin Travel Demand Model Residential Project VMT shows that the project residential VMT per capita in 2020 and 2040 is anticipated to be below the established threshold of 24.7. Therefore, the impact on VMT from the residential component of the project is considered to be less than significant.

Table 17-3: Dublin Travel Demand Model Residential Project VMT Location
Total
Population
Total Household
VMT VMT/Capita
Regional Average (Planning Area 4) 238,459 6,931,247 29.1 Significance Threshold (15% Below average) 24.7
2020 Project Residential VMT 1,779 43,536 24.5
2040 Project Residential VMT 1,779 40,264 22.6
Affordable Housing
Per City of Dublin TIA Guidelines section 4.2.2, if a project contains less than 100 percent affordable housing, the portion that is affordable housing should be screened out of needing a detailed VMT analysis. Therefore, the impact on VMT from the affordable housing component of the project is less than significant.

Hotel
Per City of Dublin TIA Guidelines section 4.3.4, a hotel land use should be assessed using the same thresholds as retail land uses. Therefore, the hotel portion of the project would have a significant impact if it caused a net increase in total VMT. Since this hotel would not be a destination hotel, its level of VMT impact can be determined without a detailed VMT analysis.

Similar to retail and grocery stores, typical hotels such as the proposed project hotel most often serve pre-existing needs when their client-base is staying at the hotel not because of the amenities, but because of the area surrounding the hotel. Alternatively, destination hotels do not serve pre-existing needs as they offer special amenities that are not offered elsewhere, and guests typically spend the majority of their time on the destination hotel property.

The hotel component of the proposed project will be a typical hotel and it is likely that guests are choosing the hotel because they are traveling to Dublin for a variety of reasons such as business in the area, visiting family and friends, or visiting other local attractions. 1244
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Typical hotels most often can be presumed to reduce trip lengths when a new hotel is introduced within a cluster of existing hotels located near a local destination or attraction.

Essentially, a trip to a hotel is expected to occur due to someone planning to travel to Dublin, or the immediate area, but the proximity of the hotel to the surrounding attractions would drive the length of that trip and the resultant impact to the overall transportation system. Most often this means that the impact to the transportation system would be negligible or reduced by the introduction of a new hotel to an area, where people are already traveling and planning on staying unless the hotel significantly affects the local supply of rooms or introduces a significant new attraction.

While a specific market study for the hotel component of the proposed project is not being provided, a map showing the proximity of other similar hotels is provided in Figure 17-4:

Proximity of Project Hotel to Existing Hotels. Both a quarter- and half-mile buffers were placed around the existing hotels in the area, as well as the proposed project, to visually represent the service area between the proposed project and the existing hotels. As shown in Figure 17-4:

Proximity of Project Hotel to Existing Hotels, “adding hotel opportunities into the local area, further improving hotel destination proximity. Accordingly, it is appropriate that the proposed project development be presumed, in accordance with OPR’s Technical Advisory, that it would not result in a net increase in VMT and support the goals of SB 743. Therefore, the impact on VMT from the hotel component of the project is less than significant.

Local Retail
OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA specifically addresses some of the key issues surrounding how a local-serving retail store should be evaluated in terms of its VMT impact. As described, the threshold for significance for retail uses is “a net increase.” This means that if a proposed retail use results in additional VMT, it would result in a finding of significance. Note that this threshold is only applicable should the retail components of the project not be screened out for being local serving.

Local-serving retail primarily serves preexisting needs (i.e., it does not generate new trips because it meets existing demand). Because of this, local-serving retail uses can be presumed to reduce trip lengths when a new store is proposed. Essentially, the assumption is that someone would travel to a newly constructed local-serving store because of its proximity, rather than that the proposed retail store is fulfilling an unmet need (i.e., the person had an existing need that was met by the retail located farther away and is now traveling to the new retail use because it is closer to the person’s origin location). This results in a trip on the roadway network becoming shorter, rather than adding a new trip to the roadway network, which would result in an impact on the overall transportation system. Conversely, residential and office land uses often drive new trips, given that they introduce new participants to the transportation system.

The proposed commercial and recreational uses (excluding Topgolf) are all destinations within Dublin that have comparable alternatives in the form of other competing commercial and recreational uses. Therefore, the additional retail uses provided by the Project would most 1245
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likely provide shorter trip options to pre-existing and on-site Project induced needs for these goods and services. Therefore, the impact on VMT from the local retail component of the project would be less than significant.

Regional Retail/Recreation
The project is proposing a 120-bay Topgolf recreational facility. Topgolf is a recreation/entertainment destination that provides a gamified driving range experience coupled with HDTVs, climate-controlled hitting bays, a sports bar, and restaurant. Because of the limited number of these large Topgolf locations in the greater Bay Area, they draw from a regional and multi-regional network of users.

The City of Dublin TIA Guidelines state that a significant impact occurs for a regional retail project if the project were to cause a net increase in total VMT for the region. For land uses included in the City of Dublin travel demand model, the total VMT for Planning Area 4 can be calculated in the model with and without the regional retail project to determine the net effect of the regional retail project on total VMT. However, the City of Dublin transportation demand model cannot model unique land uses such as the proposed Topgolf, and therefore an “offmodel” approach was used to determine the potential impact.

Per City TIA Guidelines Section 4.3.2, for development projects that use total VMT to determine impacts, the total VMT may be calculated using an off-model method that is backed by substantial evidence:
 Smaller projects may use the total daily vehicle trip generation multiplied by an average trip length determined from the travel demand model or a market research analysis.

Average Trip Length
Market research analysis was conducted to determine the average trip length for Topgolf facilities located in the cities of San Jose, Roseville, and Ontario in California; and Scottsdale, Arizona.

Data from the data company Replica was aggregated for user trips to each Topgolf location for a typical weekday in Fall 2019 in order to use pre-COVID-19 data. Replica data uses an aggregate of cell phone, credit card, transaction, vehicle, census, and built environment data to create mega regional travel demand models that provide metrics of trips categorized by trip purpose, length, time, and other trip attributes. For the purpose of this analysis, only recreation trips to the census blocks containing the four Topgolf locations were considered.

The average lengths for these trips were aggregated and are shown in Table 17-4: Average Topgolf Destination Trip Length.
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Table 17-4: Average Topgolf Destination Trip Length
Location Average Trip Length (miles)
San Jose, CA 14.6
Roseville, CA 17.7
Scottsdale, AZ 16.1
Ontario, CA 14.3
Average 15.7
Source: Kimley-Horn & Associates and Replica, 2022.

Daily Trips
The estimated daily trips for the proposed Topgolf Facility were calculated based on the Transportation Impact Study Report for North Central Roseville Specific Plan dated January 2015. That study identified a rate of 18 daily trips per hitting bay. The proposed 120-bay facility would then be expected to generate 2,160 daily trips (18 daily trips per bay * 120 bays = 2,160 daily trips).

However, not all trips to the new Topgolf facility would be new trips. A portion of the trips would be existing recreation trips in the region that would select Topgolf instead of their existing planned trip to other recreational facilities. These are considered existing trips, and thus existing VMT, on the regional roadway network that are being changed as a result of the project. The remaining Topgolf trips would then be expected to be new trips to the regional roadway network and introduce an increase (net delta) in VMT.

Topgolf user data showing the split between existing trips and new trips was not available.

Therefore, two scenarios (i.e. 100 percent new trips and 100 percent existing trips) were analyzed to determine the potential range of net change in VMT as a result of the project. 100 Percent New Trips
This scenario assumes 100 percent of the Topgolf daily trips are new trips in the region. This would occur if there were a very large latent demand for entertainment and recreation venues that is not being served in the region. Thus, potential customers to the new Topgolf facility currently do not make recreation trips as there is not a viable option for them to do so.

Assuming this is the case, Topgolf would be adding the full length of a customer trip to the network and increasing the overall regional VMT. Using the methodology outlined in the City TIA guidelines, the estimated VMT production for the proposed Topgolf facility would be 33,912 daily VMT (2,160 daily trips * 15.7 miles per trip).
100 Percent Existing Trips
This scenario assumes 100 percent of the Topgolf daily trips are existing recreation trips in the region. These trips represent households that are already budgeting and spending recreation 1247
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dollars in the region elsewhere. With the introduction of a new Topgolf, it is assumed that these households now select to travel to Topgolf instead of a different recreational venue (movie theater, park, event venue, etc.). Therefore, Topgolf would only be altering an existing trip in the region and would only be responsible for the VMT associated with the net change in length of recreation trips to their facility.

To analyze this comparison, market data from Replica was aggregated for Planning Area 4 of the Alameda County Transportation Commission Countywide Transportation Plan to determine the average recreation trip length in the region. This was compared to the average Topgolf trip length in Table 17-5: Regional Recreation Trip Length Comparison, which shows that the regionwide average trip length is currently lower than the average Topgolf trip length. This means that on average, an existing recreation trip in the region is 1.9 miles shorter than a trip to Topgolf. Using the methodology outlined in the City of Dublin TIA guidelines, the estimated VMT production for the proposed Topgolf facility under this scenario would be 4,104 daily VMT (2,160 daily trips * 1.9 miles per trip).

Table 17-5: Regional Recreation Trip Length Comparison
Use Average Trip
Length (mi)
Recreation Trip Ends in Planning Area 4
(Dublin, Livermore, Pleasanton, Sunol) 13.8
Topgolf 15.7
Net Change in Trip Length 1.9
Source: Kimley-Horn & Associates, 2022.

Topgolf Daily VMT
These two scenarios represent the minimum and maximum potential of VMT production for the Topgolf portion of the project depending on the percent of the trips to the venue that are existing versus new trips. This analysis provides a bounding range for the daily VMT of the Topgolf, which is calculated to be between 4,104 to 33,912 increased daily VMT for the region, depending on if the Topgolf trips are either all new trips or all existing recreation trips. This is shown in Table 17 6: VMT Range for Topgolf.

Table 17-6: VMT Range for Topgolf
Scenario % New Trips Daily Trips
Trip Length
(miles) Daily VMT
Topgolf (low range) 0% 2,160 1.9 4,104
Topgolf (high range) 100% 2,160 15.7 33,912
Source: Kimley-Horn & Associates, 2022.
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Using either method, the proposed Topgolf would result in a net increase in VMT to the planning area. Per City TIA Guidelines significance criteria, any net increase in VMT to the planning area would constitute a significant impact.

Mitigation for Impact TRANS-2
AQ 2.5: Vehicle Trip Reduction requires the development of a qualifying Commute Trip Reduction (CTR)/ Transportation Demand Management (TDM) plan to reduce mobile emissions for all uses, including the Topgolf development. The TDM plan shall be approved by the City of Dublin prior to the issuance of building permits and incorporated into the project’s Codes Covenants and Restrictions (CC&Rs). The TDM plan shall discourage single-occupancy vehicle trips and encourage alternative modes of transportation such as carpooling, taking transit, walking, and biking through TDM measures, incentives, strategies and policies.

TDM plans are typically most effective when implemented in the employment setting, specifically with large employers who can take advantage of the collective interests of a large group. For the Topgolf use, the majority of the VMT generated by this use would be VMT from the customer trips and not the employment trips and therefore, a TDM plan would have a minimal effect on reducing the VMT and would not reduce the regional VMT to result in a net decrease. However, even with a minimal effect on VMT, the Topgolf project should still implement a TDM program for its own employees. In addition, the Topgolf could encourage local trips instead of regional trips to their locations by providing promotions or discounts to residents of Dublin or the nearby cities to help reduce the overall VMT by customers being produced by the project.

In addition, the City of Dublin does not yet have a VMT banking fee program or exchange program for the project to potentially fund off-site multimodal improvements within the region that would help to reduce the net overall VMT. In the absence of such a program, the additional VMT for the Topgolf component of the project would result in a significant and unavoidable impact.

Additionally, implementation of MM TRANS 2-1: Implement Bicycle and Pedestrian Improvements, would help to further reduce VMT impacts. However, despite the implementation MM AQ 2.5: Vehicle Trip Reduction and MM TRANS 2-1: Implement Bicycle and Pedestrian Improvements, impacts would remain significant and unavoidable (Class I).

MM TRANS 2-1 Implement Bicycle and Pedestrian Improvements To encourage mode shift and reduce VMT, prior to approval of the Site Development Review Permit, the project applicant shall work with the Community Development and Public Works Departments to identify and design construct bicycle and pedestrian improvements in the vicinity of the project site (generally within a quarter mile from the project site boundary) as identified in the City’s most recently adopted Bicycle & Pedestrian Master Plan. 1249
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Perform a complete streets study to identify the appropriate bicycle and pedestrian improvements along Tassajara Road and Dublin Boulevard in the vicinity of the project as identified in the City’s most recently adopted Bicycle and Pedestrian Master Plan. The completed street study will include but not be limited to development of street cross-sections to implement Class I or Class IV bike lanes along Tassajara Road between Gleason Drive and I580.

In addition, prior to issuance of the first building permit for Planning Area 1, the project applicant shall contribute its pro-rata share of the planned improvements to the I-580 interchange pedestrian and bicycle improvements through the City of Dublin’s Traffic Impact Fee or by other means. The Project Developer shall enter into an agreement with the City to contribute the Project’s pro-rata share of the planned improvements.

Parks and Recreation
Per City of Dublin TIA Guidelines section 4.2.3 public services (e.g., police, fire stations, public utilities, neighborhood parks, and public schools) generally do not increase VMT. Instead, these land uses are often built-in response to developments from other land uses (e.g., office and residential). Therefore, these land uses can be presumed to have a less than significant impact on VMT. Therefore, the impact on VMT from the public parks component of the project which are designed to be neighborhood-serving is less than significant.

TRANS 3 – Increase hazards due to a geometric feature or incompatible uses (Class II).

Project plans were reviewed to determine if there could be any geometric design features that would substantially increase hazards for residents, employees, and patrons accessing the site.

Pedestrian Facilities
Mid-Block Crosswalk Across Central Parkway Between Tassajara Road and Brannigan Street The project is proposing a mid-block crosswalk across Central Parkway between Tassajara Road and Brannigan Street, connecting Planning Areas 2 and 3. Residents in Planning Area 3 are expected to use this crosswalk to access the retail shops and restaurants in Planning Area 2 and increase pedestrian activity across Central Parkway. Since this mid-block crossing is uncontrolled, there is potential for an increase in pedestrian and vehicle conflicts. A mid-block pedestrian crosswalk is also proposed along Finnian Way within Planning Area 2. Residents north of Finnian Way would use the mid-block crossing to access the retail shops and restaurants located south of Finnian Way.

Due to the limited full access driveways in this planning area, many vehicles are expected to use Finnian Way at Tassajara Road and at Brannigan Street to access the site as these intersections allow for full access (i.e., left turns into and out of the project site). With high pedestrian volumes at the mid-block crossing and high vehicular volumes along Finnian Way, there is 1250
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potential for an increase in pedestrian and vehicle conflicts. Therefore, the project would result in a potentially significant impact at these pedestrian crossings.

Implementation of MM TRANS 3-1: Pedestrian & Bicycle Safety Improvements would reduce impacts to less than significant (Class III).

Mid-Block of Dublin Boulevard
The project’s residential units are located north of Dublin Boulevard while retail shops, restaurants, the bowling alley, and Topgolf are located south of Dublin Boulevard. The location of these uses would increase pedestrian activity across Dublin Boulevard.

North of Dublin Boulevard, there are pedestrian facilities that encourage north/south pedestrian movement down the middle or “spine” of the project. The conceptual design shows these pedestrian and bicycle facilities terminating at Dublin Boulevard between Tassajara Road and Brannigan Street, which may encourage pedestrians to illegally jaywalk across Dublin Boulevard mid-block. Therefore, the project may increase vehicular and pedestrian conflicts and result in a potentially significant impact.

Implementation of MM TRANS 3-1: Pedestrian & Bicycle Safety Plan would reduce impacts to less than significant (Class III).

Mitigation for Impact TRANS 3-1
MM TRANS 3-1: Pedestrian & Bicycle Safety Improvements
To increase pedestrian and bicycle safety and reduce vehicle conflicts at the mid-block crossings along Central Parkway and Finnian Way between Tassajara Road and Brannigan Street, as well as along Dublin Boulevard; the applicant shall submit pedestrian and bicycle safety improvements as part of the Site Development Review Permit. These improvements shall include detailed plans and associated information that identify the recommended appropriate pedestrian crossing treatments. Specific recommended improvements include but are not limited to:
 Mid-Block Crosswalk Across Central Parkway Between Tassajara Road and Brannigan Street: Applicant shall work with the City to provide an uncontrolled crosswalk study per California MUTCD and FHWA guidance to determine the appropriate improvements that should be installed at this location. Improvements shall include Rectangular Rapid Flashing Beacon (RRFB), High Intensity Activated Crosswalk (HAWK), or similar device that would increase pedestrian and bicycle safety and reduce vehicle conflicts.  Dublin Boulevard: The design of the pedestrian and bicycle facilities in Planning Area 2 shall consider the potential pedestrian and bicycle safety conflicts and discourage a midblock crossing. Design solutions may include, but not limited to:
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o Placement and layout of pedestrian and bicycle facilities so as not to lead pedestrians and/or bicyclists to cross at an uncontrolled mid-block crossing. o Formal and informal barriers integrated into the design to deter pedestrians and bicyclists from crossing a roadway mid-block.
o Wayfinding and signage directing pedestrians and bicycles where to safely cross Dublin Boulevard.

Vehicle Access
Project driveways are proposed midblock along the major arterials of Tassajara Road, Gleason Drive, Central Parkway, and Dublin Boulevard. Many of these driveways are unsignalized and limited to a right-in and right-out movement to reduce vehicle conflicts and delays that would arise from vehicles making a left-turn onto the major arterial with high volumes and speeds over multiple travel lanes. Internal to the project site, multiple drive aisles and access points are provided to allow several points of ingress and egress to the different land uses and to limit potential vehicle queuing from the internal drive aisles onto the major arterials. Further evaluation will be completed in the Site Development Review Permit process to confirm that vehicle queuing will not be a safety issue. The project would result in a less than significant impact as it relates to vehicular safety.

TRANS 4: Result in inadequate emergency access (Class III).

Emergency vehicles can access the project site using all project driveways. However, since many driveways are limited to a right-in right-out movement as there are raised medians along Tassajara Road, Gleason Drive, Central Parkway, and Dublin Boulevard, full access is only provided at four locations with one location in Planning Area 1 (Brannigan Street/Lowe’s Driveway), two locations in Planning Area 2 (Finnian Way/Tassajara Road and Finnian Way/Brannigan Street) and one location in Planning Area 3 (Brannigan Street/Project Driveway). In addition, the adjacent raised medians consist of landscaping and are not mountable by emergency vehicles. The project would not provide direct access for emergency vehicles to many uses within each Planning Area and would result in a potentially significant impact.

Section 5.08.020 of the City’s Fire Code, regulates permit processes, including emergency access. As part of subsequent Site Development Review Permit process, all plans would be reviewed by the City of Dublin Fire Prevention Bureau to ensure there is adequate emergency access consistent with Section 5.08.020. This requirement would reduce potential emergency access impacts to less than significant (Class III).
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17.5.4 Level of Significance After Mitigation
Table 17-7: Summary of Impacts and Mitigation Measures – Transportation summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to transportation.

Table 17-7: Summary of Impacts and Mitigation Measures – Transportation Impact Impact Significance Mitigation
TRANS-1: Conflict with a program, plan, ordinance or
policy addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities
(Class III).

Less than Significant None required.

TRANS-2: Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b) regarding
Vehicle Miles Traveled (Class I).

Significant and
Unavoidable with
Mitigation
MM AQ 2-5: Vehicle
Trip Reduction
MM TRANS 2-1:

Implement Bicycle and
Pedestrian
Improvements
TRANS 3:Increase hazards due to a geometric feature
or incompatible uses (Class II).

Less than Significant with
Mitigation
MM TRANS 3-1:

Pedestrian & Bicycle
Safety Improvements
TRANS 4: Result in inadequate emergency access
(Class III).

Less than Significant None required.

17.6 References
Alameda County Transportation Commission, Congestion Management Program, October 2021.

Caltrans, Guide for the Preparation of Traffic Impact Studies, December 2002.

Caltrans, Vehicle Miles Traveled-Focused Transportation Impact Study Guide, May 20, 2020.

Caltrans, Highway Design Manual, 7th Edition, updated 2020.

City of Dublin, Bicycle and Pedestrian Master Plan, October 7, 2014.

City of Dublin, Eastern Dublin Specific Plan 1985; updated2022.

City of Dublin, General Plan, 1985 amended 2022.

City of Dublin, Impact Fees FY 2021-22, 2021.

City of Dublin, Resolution No. 199-12 Adopting a Complete Streets Policy, December 4, 2012. 1253
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City of Dublin, Transportation Impact Analysis Guidelines, July 15, 2021.

City of Livermore, General Plan, 2004 amended July 2021.

City of Pleasanton, General Plan, July 21, 2009 amended 2019.

City of Pleasanton, Bicycle and Pedestrian Master Plan, 2018.

Fehr and Peers, Transportation Impact Study Report for North Central Roseville Specific Plan – Parcel 49, January 23, 2015.

Governor’s Office of Planning and Research State of California, Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018.

Kittelson & Associates, Draft City of Dublin Citywide Travel Model Update, 2021 Model Update, July 2021.

Replica. 2022. Replica. Retrieved May 12, 2022 from http://www.my.replicahq.com Transportation Research Board, HCM Highway Capacity Manual 6th Edition, October 2016.

Tri-Valley Transportation Council, Final Tri-Valley Transportation Plan and Action Plan for Routes of Regional Significance, September 2017.
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PLEASANTON
DUBLIN
LEGEND
Project Area
# City of Dublin Study Intersections
# City of Pleasanton Study Intersections
# Caltrans Study Intersections
#* City of Dublin Project Driveways
1 2
5 17
3 4
15 16
36 37
38 34
35 13 28 30
6 24
9 26
31 33
32 39
40 41
7*
8* 42
19* 20* 21*
10*
12* 43*
11* 27*
22*
25*
43*
23*
14* 29*
12*
10*
18*
11* 27*
W Jack London Blvd
Gleason Dr
Dublin Blvd
Dublin
Corporate Wy
Central Pkwy
Source: Kimley-Horn, 2022
Figure 17-1: Study Intersections
SCS Dublin Project
Environmental Impact Report 1255
Not to scale Not to scale

PLEASANTON LEGEND
Project Area
# Existing Study Intersections
# Project Driveways
Class I Bicycle Path
Class II Bicycle Lane
Class III Bicycle Route
DUBLIN
1 2
5 17
3 4
15 16
36 37
38 34
35 13 28 30
6 24
9 26
31 33
32 39
40 41
7 8 42
43 11
10 12
27 43
19 20 21
23 12
10 18
22 25
11 27
14 29
W Jack London Blvd
Gleason Dr
Dublin Blvd
Dublin
Corporate Wy
Central Pkwy
Figure 17-2: Existing Bicycle Facilities
SCS Dublin Project
Environmental Impact Report
Source: Kimley-Horn, 2022
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20X 580X
14 604
610
605
10R
3 3 604
8 14
503
503
503
502
70X 30R
502
2 1
30R
1 2
501
502
20X 580X
504
2 501
504
502
2 2
2 501
501
2 30R
54 54
605
608
14 PLEASANTON
DUBLIN
LEGEND
Project Area
# Existing Study Intersections
# Project Driveways
XX Wheels Bus Route
1 2
5 17
3 4
15 16
36 37
38 34
35 13 28 30
6 24
9 26
31 33
32 39
40 41
7 8 42
43 23
12 10
18 22
11 10
12 27
43 19 20 21
25 11 27
14 29
W Jack London Blvd
Gleason Dr
Dublin Blvd
Dublin
Corporate Wy
Central Pkwy
Source: Kimley-Horn, 2022
Figure 17-3: Existing Transit Facilities
SCS Dublin Project
Environmental Impact Report 1257
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Source: Kimley-Horn, 2022
Figure 17-4: Proximity of Project Hotel to Existing Hotels SCS Dublin Project
Environmental Impact Report 1258
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18 Energy Conservation

18.1 Introduction
According to Appendix F of the State CEQA Guidelines, the goal of conserving energy implies the wise and efficient use of energy including decreasing reliance on natural gas and oil and increasing reliance on renewable energy sources. The project would be constructed to Title 24 standards, which would reduce energy demand as compared to traditional development.

Therefore, the project would not result in substantial or wasteful consumption of energy.

This section describes the existing setting of the project site as it relates to energy conservation; identifies associated regulatory conditions and requirements; presents the criteria used to evaluate potential impacts related to use of fuel and energy upon implementation of the project; and identifies mitigation measures to reduce or avoid each significant impact. The significance of each impact after the incorporation of identified mitigation measures is included at the end of this section. Information used to prepare this section is referenced from the following resources:
 Kimley-Horn, Energy Conservation Technical Data, 2022.

18.2 Scoping Issues Addressed
During the public comment scoping period for the project, no comments regarding energy conservation were received.

18.3 Environmental Setting
This section presents information on the existing energy consumption in the region and project vicinity. This information serves as the baseline for assessing the project’s impacts related to energy conservation.

18.3.1 California’s Energy Use and Supply
Californians consumed 279,510 gigawatt hours (GWh)20 of electricity in 2020, which is the most recent year for which data is available. Of this total, Alameda County consumed 10,247 GWh (CEC, 2020a). In 2020, the California electricity mix included natural gas (48.35 percent), coal 20 A watt hour is a unit of energy equivalent to one watt of power expended for one hour. For example, a typical light bulb is 60 watts, meaning that if it is left on for one hour, 60-watt hours have been used. One kilowatt equals 1,000 watts. The consumption of electrical energy by homes and businesses is usually measured in kilowatt hours (kWh). Some large businesses and institutions also use megawatt hours (MWh), where one MWh equals 1,000 kWh. One gigawatt equals 1,000 megawatts, or 1,000,000 kilowatts. The energy output of large power plants over long periods of time, or the energy consumption of jurisdictions, can be expressed in gigawatt hours (GWh). 1259
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(0.17 percent), large hydroelectric plants (9.40 percent), and nuclear (8.53 percent). The remaining 33.55 percent was supplied from renewable resources, such as wind, solar, geothermal, biomass, and small hydroelectric facilities (CEC, 2020b). In 2015, the state consumed 2 trillion cubic feet21 of natural gas (EIA, 2022).

Energy usage is typically quantified using the British Thermal Unit (BTU). Total energy usage in California was 7,802 trillion BTU in 2019 (the most recent year for which this specific data is available), which equates to an average of 198 million BTU per capita. Of California’s total energy usage, the breakdown by sector is 39 percent transportation, 23 percent industrial, 19 percent commercial, and 19 percent residential. Electricity and natural gas in California are generally consumed by stationary users such as residences and commercial and industrial facilities, whereas petroleum consumption is generally accounted for by transportation-related energy use.22
In 2002, California established its Renewable Portfolio Standard program23 with the goal of increasing the annual percentage of renewable energy in the state’s electricity mix by the equivalent of at least 1 percent of sales, with an aggregate total of 20 percent by 2017. The California Public Utilities Commission subsequently accelerated that goal to 2010 for retail sellers of electricity (Public Utilities Code Section 399.15(b)(1)). Then-Governor Schwarzenegger signed Executive Order S-14-08 in 2008, increasing the target to 33 percent renewable energy by 2020.

In September 2009, then‐Governor Schwarzenegger continued California’s commitment to the Renewable Portfolio Standard by signing Executive Order S‐21‐09, which directs the California Air Resources Board under its Assembly Bill (AB) 32 authority to enact regulations to help the State meet its Renewable Portfolio Standard goal of 33 percent renewable energy by 2020. In September 2010, the California Air Resources Board adopted its Renewable Electricity Standard regulations, which require all of the state’s load-serving entities to meet this target. In October 2015, Governor Jerry Brown signed into legislation Senate Bill 350, which requires retail sellers and publicly owned utilities to procure 50 percent of their electricity from eligible renewable energy resources by 2030.
21 100 cubic feet (CCF) is approximately the energy equivalent to burning 100 cubic feet of natural gas. 100 CCF of natural gas equals 103,700 a British Thermal Unit (BTU). A BTU is the amount of energy needed to raise the temperature of one pound of water by one degree Fahrenheit. A kBTU is 1,000 BTUs. A therm is 100,000 BTUs. 22 EIA (US Energy Information Administration), California State Profile and Energy Estimates, updated May 19, 2022, http://www.eia.gov/state/data.cfm?sid=CA#ConsumptionExpenditures and https://www.eia.gov/state/seds/data.php?incfile=/state/seds/sep_fuel/html/fuel_te.html&sid=US&sid=CA, accessed May 2, 2022. 23 The Renewable Portfolio Standard is a flexible, market-driven policy to ensure that the public benefits of wind, solar, biomass, and geothermal energy continue to be realized as electricity markets become more competitive. The policy ensures that a minimum amount of renewable energy is included in the portfolio of electricity resources serving a state or country. 1260
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Additional energy efficiency measures beyond the current regulations are needed to meet these goals as well as the AB 32 greenhouse gas (GHG) reduction goal of reducing statewide GHG emissions to 1990 levels by 2020 (see Chapter 6: Air Quality, and Chapter 10: Greenhouse Gases, for a discussion of AB 32). Part of the effort in meeting California’s long-term reduction goals include reducing petroleum use in cars and trucks by 50 percent, increasing from onethird to one-half of California’s electricity derived from renewable sources, doubling the efficiency savings achieved at existing buildings and making heating fuels cleaner; reducing the release of methane, black carbon, and other short-lived climate pollutants, and managing farm and rangelands, forests, and wetlands so they can store carbon (CEC, 2022a).

18.3.2 Current Energy Providers
Electricity
East Bay Community Energy and Pacific Gas & Electric
In 2018, Alameda County and the City of Dublin shifted to local Community Choice Energy (CCE) program East Bay Community Energy (EBCE). EBCE was formed as a Joint Power Authority (JPA) by Alameda County and 11 of its cities and operates as a not-for-profit public agency. In January 2022, standard residential accounts moved from an automatic default service “Bright Choice” which is 80 percent carbon free to EBCE’s product “Renewable 100” which is sourced from California wind and solar facilities. Non-residential customers will default to Renewable 100 beginning in October 2022. The electric energy provided by EBCE is conveyed to customers through Pacific Gas and Electric’s (PG&E) existing infrastructure. PG&E continues to maintain the grid, repair lines, and conduct customer billing within the EBCE service area.

Natural Gas
PG&E operates one of the largest natural gas distribution networks in the country, including 42,141 miles of natural gas transmission and distribution pipelines (PG&E, 2022). In all, PG&E delivers gas to approximately 4.5 million customer accounts in Northern and Central California, including in Alameda County.

As shown in Table 18-1: Electricity Consumption in Alameda County 2010-2020 and Table 18-2:

Natural Gas Consumption in Alameda County 2010-2020, both electricity and natural gas consumption in Alameda County has remained relatively constant between 2010 and 2020. 1261
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Table 18-1: Electricity Consumption in Alameda County 2010-2020 Year
Electricity Consumption
(in millions of kilowatt hours)
2010 10,722
2011 10,979
2012 11,593
2013 10,622
2014 10,305
2015 10,243
2016 10,791
2017 11,090
2018 10,573
2019 10,922
2020 10,247
Source: CEC, 2020a. https://ecdms.energy.ca.gov/elecbycounty.aspx Table 18-2: Natural Gas Consumption in Alameda County 2010-2020 Year
Natural Gas Consumption
(in millions of therms)
2010 422
2011 423
2012 411
2013 423
2014 362
2015 359
2016 362
2017 379
2018 377
2019 384
2020 366
Source: CEC, 2020a. https://ecdms.energy.ca.gov/gasbycounty.aspx 1262
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Transportation Fuel
California’s transportation sector uses roughly 39 percent of the energy consumed in the state.

In 2016, Californians consumed approximately 13.6 billion gallons of gasoline and 3.5 billion gallons of diesel fuel (EMFAC2021, 2022).

Fuel Consumption
As shown in Table 18-3: Automotive Fuel Consumption in Alameda County 2010-2020, on-road automotive fuel and heavy-duty diesel fuel consumption in Alameda County has remained steady since 2010.

Table 18-3: Automotive Fuel Consumption in Alameda County 2010-2020 Year
On-Road Automotive Fuel
Consumption (Gallons)
Heavy-Duty Vehicle/Diesel Fuel
Consumption (Gallons)
2010 546,108,000 122,139,000
2011 534,708,000 127,202,000
2012 532,188,000 127,749,000
2013 534,200,000 130,467,000
2014 544,124,000 125,911,000
2015 559,640,000 126,586,000
2016 573,529,000 134,589,000
2017 562,071,000 135,711,000
2018 551,105,000 136,591,000
2019 539,782,000 137,597,000
2020 493,721,300 151,955,624
Source: California Air Resources Board, EMFAC2021.

18.4 Applicable Regulations, Plans, and Standards
This section presents legislation and regulations specifically related to energy conservation. See also Chapter 6: Air Quality, Chapter 11: Greenhouse Gas Emissions, and Chapter 17:

Transportation & Circulation, for other policies related to energy use. See Chapter 16: Public Services, Utilities, and Service Systems for policies related to water consumption.

18.4.1 Federal
National Energy Conservation Policy Act
The National Energy Conservation Policy Act serves as the underlying authority for Federal energy management goals and requirements. Signed into law in 1978, it has been regularly 1263
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updated and amended by subsequent laws and regulations. This act is the foundation of most Federal energy requirements.

Energy Policy Act of 2005
The Energy Policy Act of 2005 sets equipment energy efficiency standards and seeks to reduce reliance on non-renewable energy resources and provide incentives to reduce current demand on these resources. For example, under the Act, consumers and businesses can attain Federal tax credits for purchasing fuel-efficient appliances and products, including hybrid vehicles; constructing energy-efficient buildings; and improving the energy efficiency of commercial buildings. Additionally, tax credits are available for the installation of qualified fuel cells, stationary micro-turbine power plants, and solar power equipment.

Executive Order 13693 (Planning for Federal Sustainability in the Next Decade), signed in 2015, seeks to maintain Federal leadership in sustainability and GHG emission reductions. Its goal is to reduce agency Scope 1 and 2 GHG emissions24 by at least 40 percent by 2025, foster innovation, reduce spending, and strengthen communities through increased efficiency and improved environmental performance. Sustainability goals are set for building efficiency and management, energy portfolio, water use efficiency, fleet efficiency, sustainable acquisition and supply chain GHG management, pollution prevention, and electronic stewardship.

Energy and Independence Security Act of 2007
The Energy and Independence Security Act of 2007 sets Federal energy management requirements in several areas, including energy reduction goals for Federal buildings, facility management and benchmarking, performance standards for new buildings and major renovations, high-performance buildings, energy savings performance contracts, metering, energy-efficient product procurement, and reduction in petroleum use and increase in alternative fuel use. This act also amends portions of the National Energy Policy Conservation Act.

18.4.2 State
Assembly Bill 32
California’s major initiative for reducing GHG emissions is outlined in Assembly Bill 32 (AB 32), the “California Global Warming Solutions Act of 2006.” AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020 (essentially a 15 percent reduction below 2005 emission levels; the same requirement as under S-3-05) and requires CARB to prepare a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline. In 24 In GHG inventories, direction emissions are Scope 1; indirect emissions from consumption of purchased electricity, heat or steam are Scope 2; and other indirect emissions (such as extraction and production of purchases materials and fuels, transport in vehicles not controlled by the reporting entity, outsourced activities) are Scope 3. 1264
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addition, AB 32 requires CARB to adopt regulations to require reporting and verification of statewide GHG emissions. Reductions in overall energy consumption have been implemented to reduce emissions. See Chapter 10 (Greenhouse Gas Emissions) for a further discussion of AB

32. 2008 California Energy Action Plan Update
The 2008 Energy Action Plan Update provides a status update to the 2005 Energy Action Plan II, which is the State’s principal energy planning and policy document (CPUC and CEC, 2008). The plan continues the goals of the original Energy Action Plan, describes a coordinated implementation plan for State energy policies, and identifies specific action areas to ensure that California’s energy is adequate, affordable, technologically advanced, and environmentally sound. First-priority actions to address California’s increasing energy demands are energy efficiency, demand response (i.e., reduction of customer energy usage during peak periods in order to address system reliability and support the best use of energy infrastructure), and the use of renewable sources of power. If these actions are unable to satisfy the increasing energy and capacity needs, the plan supports clean and efficient fossil-fired generation.

California Green Building Standards Code
The 2019 California Green Building Standards Code, as specified in Title 24, Part 11 of the California Code of Regulations, specifies building standards to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices in five categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental quality. The provisions of this code apply to the planning, design, operation, construction, replacement, use and occupancy, location, maintenance, removal, and demolition of every building or structure or any appurtenances connected or attached to such building structures throughout California. The latest California Green Building Standards Code will take effect on January 1, 2023.

Building Energy Efficiency Standards
The Energy Efficiency Standards for Residential and Nonresidential Buildings, as specified in Title 24, Part 6, of the California Code of Regulations, were established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. The California Energy Commission (CEC) adopted a new update in 2022, and these new standards became effective on January 1, 2023. 2006 Appliance Efficiency Regulations
The California Energy Commission adopted Appliance Efficiency Regulations (Title 20, CCR Sections 1601 through 1608) on October 11, 2006. The regulations were approved by the California Office of Administrative Law on December 14, 2006. The regulations include standards for both Federally regulated appliances and non-Federally regulated appliances. 1265
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While these regulations are now often viewed as “business-as-usual,” they exceed the standards imposed by all other states and they reduce GHG emissions by reducing energy demand.

Senate Bill 1078 and 107; Executive Order S-14-08, S-21-09, and SB 2X SB 1078 (Chapter 516, Statutes of 2002) requires retail sellers of electricity, including investorowned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. SB 107 (Chapter 464, Statutes of 2006) changed the target date to 2010. In November 2008, then-Governor Schwarzenegger signed Executive Order S-14-08, which expands the state’s Renewable Portfolio Standard to 33 percent renewable power by 2020. In September 2009, then-Governor Schwarzenegger continued California’s commitment to the Renewable Portfolio Standard by signing Executive Order S-21- 09, which directs the CARB under its AB 32 authority to enact regulations to help the state meet its Renewable Portfolio Standard goal of 33 percent renewable energy by 2020. In April 2011, Governor Brown signed SB 2X, which legislated the prior Executive Order S-14-08 renewable standard.

Executive Order B-30-15 and Senate Bill 350
In April 2015, the Governor issued Executive Order B-30-15, which established a GHG reduction target of 40 percent below 1990 levels by 2030. SB 350 (Chapter 547, Statutes of 2015) advanced these goals through two measures. First, the law increases the renewable power goal from 33 percent renewables by 2020 to 50 percent by 2030. Second, the law requires the CEC to establish annual targets to double energy efficiency in buildings by 2030. The law also requires the California Public Utilities Commission (CPUC) to direct electric utilities to establish annual efficiency targets and implement demand-reduction measures to achieve this goal.

Senate Bill 32
In September 2016, the Governor signed into legislation SB 32, which builds on AB 32 and requires the state to cut GHG emissions to 40 percent below 1990 levels by 2030. With SB 32, the Legislature also passed AB 197, which provides additional direction for updating the Scoping Plan to meet the 2030 GHG reduction target codified in SB 32. CARB has published a draft update to the Scoping Plan and has received public comments on this draft, but has not released the final version.

Recent CEQA Litigation
In California, Clean Energy Committee v. City of Woodland (2014) 225 Cal.App.4th 173 (“CCEC”), the Court observed that CEQA Guidelines Appendix F lists environmental impacts and mitigation measures that an EIR may include. Potential issues that may require EIR discussion include:
 The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance, and/or removal. If appropriate, the energy intensiveness of materials may be discussed. 1266
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 The effects of the project on local and regional energy supplies and on requirements for additional capacity.
 The degree to which the project complies with existing energy standards.  The effects of the project on energy resources.
 The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

The Save Lake Tahoe Mountain Area Preservation Foundation v. County of Placer case found an EIR should address the project’s potential to increase its use of renewable energy sources for at least two purposes. First, when the EIR analyzes the project’s energy use to determine if it creates significant effects, it should discuss whether any renewable energy features could be incorporated into the project. The EIR’s determination of whether the potential impact is significant is to be based on this discussion. Second, if the EIR concludes the project’s impact on energy resources is significant, it should consider mitigating the impact by requiring uses of alternate fuels, particularly renewable ones, if applicable.

18.4.3 Local
City of Dublin General Plan
The City of Dublin General Plan includes goals, policies, and actions that encourage the conservation of energy in the Community Design and Sustainability Element and the Energy Conservation Element. The following are goals, policies and implementation measures specifically related to energy that are relevant to the project.

Goal 10.9.2: Encourage Sustainability to provide a high quality of life and to preserve resources and opportunities.

Policy 10.9.3(C): Consider environmentally sensitive and energy-efficient building siting, which minimize impacts from wind, provides shade, reduces stormwater runoff, and maximizes opportunities for passive solar design, where feasible.

Policy 10.9.3(F): Encourage alternative modes of transportation by providing priority parking for carpool and alternative energy vehicles, bicycle racks/lockers, showers for employees, and easy access to adjacent regional trails and transit stops.

Implementation Measure 10.9.4(A): Facilitate environmental and energy-efficient design guidelines that promote good design for new construction.

Implementation Measure 10.9.4(H): Investigate modifications to the Building Code to require integrated, comprehensive, and well-designed sustainable building practices (i.e. water and energy efficiency, resource allocations, and site planning).

Guiding Policy 13.3.2(A)(1): Encourage the installation of alternative energy technology in new residential and commercial development.
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Guiding Policy 13.3.2(A)(2): Encourage designing for solar access.

Guiding Policy 13.3.2(A)(3): Encourage energy efficient improvements be made on residential and commercial properties.

Implementing Policy 13.3.2(B)(1): New development proposals shall be reviewed to ensure lighting levels needed for a safe and secure environment are provided—utilizing the most energy-efficient fixtures (in most cases, LED lights)—while avoiding over-lighting of sites. Smart lighting technology (e.g. sensors and/or timers) shall also be employed in interior and exterior lighting applications where appropriate.

Implementing Policy 13.3.2(B)(2): New development projects shall install LED streetlights in compliance with the City’s LED light standard.

Implementing Policy 13.3.2(B)(3): In new commercial and residential parking lots, require the installation of conduit to serve electric vehicle parking spaces to enable the easier installation of future charging stations.

Implementing Policy 13.3.2(B)(4): Encourage the installation of charging stations for commercial projects over a certain size and any new residential project that has open parking (i.e. not individual, enclosed garages).

Implementing Policy 13.3.2(B)(5): Encourage buildings (and more substantially, whole neighborhoods) to be designed along an east-west axis to maximize solar exposure. Where feasible, require new development projects to take advantage of shade, prevailing winds, landscaping and sun screens to reduce energy use; and to use regenerative energy heating and cooling source alternatives to fossil fuels.

Implementing Policy 13.3.2(B)(6): Continue to implement parking lot tree planting standards that would substantially cool parking areas and help cool the surrounding environment.

Encourage landscaping conducive to solar panels in areas where appropriate.

Implementing Policy 13.3.2(B)(7): Promote and encourage photovoltaic demonstration projects in association with new development.

Implementing Policy 13.3.2(B)(8): Consider creating a recognition program for commercial or residential projects that install large-scale solar or wind energy systems and to publicly commend and acknowledge businesses or individuals that construct or remodel buildings that save more energy than required by Title 24 or by the Cal Green Building Code.

Eastern Dublin Specific Plan
The Specific Plan features a comprehensive multi-modal transportation and circulation system.

The intent is to achieve important environmental benefits, such as reduced air and noise pollution, and increased energy conservation, through the reduction in the number and length of daily vehicle trips associated with new development. 1268
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Additionally, through the recycling of organic and man-made materials the total amount of solid waste that needs to be disposed of in landfills can be greatly reduced, saving not only land but also energy and natural resources.

The City of Dublin’s Eastern Dublin Specific Plan establishes the following policies associated with transportation and building energy conservation that are relevant to the project:

Policy 4.1: Maintain a reasonable balance in residential and employment-generating land uses by adhering to the distribution of land uses depicted in Figure 4-1, Land Use Map.

Policy 4-13: Locate community-oriented commercial development in the "Town Center" within walking distance or a short ride from most residents, and conveniently served by transit.

Policy 4-14: Encourage the development of neighbor-hood serving retail and service uses in the "Village Centers" in order to reduce daily vehicle trips, and contribute to the identity and character of the outlying residential areas.

Policy 4-17: Avoid dispersion of commercial uses along major collectors and arterials in a linear (i.e., "strip") development pattern that is oriented solely to vehicular traffic.

Policy 4-18: Encourage the creation of a pedestrian-oriented shopping environment in the Town and Village Centers, while still accommodating the safe movement of vehicular traffic.

Policy 4-19: Encourage mixed-use development in the commercial areas of the Town and Village Centers that contributes to the social, cultural, and economic vitality of the commercial districts.

Policy 5-2: Require all development to provide a balanced orientation toward pedestrian, bicycle, and automobile circulation.

Policy 5-17: Establish a bicycle circulation system which helps to serve the need for nonmotorized transportation and recreation in eastern Dublin that is consistent with the Dublin Bicycle and Pedestrian Master Plan.

Policy 8-7: Support ACWMA efforts to develop alternate disposal facilities for organic waste in the Tri-Valley area, particularly for composting and reuse of organic material.

Policy 8-8: Encourage the separation of recyclable materials from the general waste stream by supporting the development of a recycling collection system and facilities.

18.5 Environmental Impacts and Mitigation Measures
The analysis below generally follows Appendix F of the State CEQA Guidelines, which states that the goal of conserving energy implies the wise and efficient use of energy, including decreasing overall per capita energy consumption, decreasing reliance on fossil fuels, and increasing reliance on renewable energy sources.
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According to Appendix F, the analysis should include a description of energy conservation measures included as part of the project and should consider whether a project would result in inefficient, wasteful, and unnecessary consumption of energy.

18.5.1 Significance Criteria
Based upon the criteria derived from Appendix F of the State CEQA Guidelines, the project would result in a significant impact related to energy conservation if it would:
 Result in the inefficient, wasteful or unnecessary consumption of energy during project construction or operation.

18.5.2 Summary of No and/or Beneficial Impact
There are no “no” impacts nor “beneficial” impacts.

18.5.3 Impact Assessment Methodology
In determining whether implementation of the project would result in the inefficient, wasteful or unnecessary consumption of fuel or energy, this analysis considers the recommendations of Appendix F (as described above), which states that environmental impact analyses of energy conservation may include:

1. The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project’s life cycle including construction, operation, maintenance and/or removal. If appropriate, the energy intensiveness of materials maybe discussed.

2. The effects of the project on local and regional energy supplies and on requirements for additional capacity.

3. The degree to which the project complies with existing energy standards.

4. The effects of the project on energy resources.

5. The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

This section analyzes energy consumption on three sources of energy that are relevant to the project: electricity, natural gas, and transportation fuel for vehicle trips associated with new development, as well as the fuel necessary for project construction. The analysis of project electricity/natural gas usage is based on California Emissions Estimator Model (CalEEMod) modeling, which quantifies energy use for occupancy. The results of the CalEEMod modeling are included in Appendix B: Air Quality and Greenhouse Gas Emissions Analysis of this Draft EIR.

Modeling related to project energy consumption was based primarily on the default settings in 1270
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the computer program for Alameda County. The amount of operational fuel use was estimated using CalEEMod outputs for the project and the California Air Resources Board’s Emissions Factor 2021 (EMFAC2021) computer program for typical daily fuel usage in Alameda County.

Construction fuel consumption was calculated based on CalEEMod emissions outputs and conversion ratios from the Climate Registry.

Energy consumption impacts are analyzed below according to topic. Mitigation measures directly correspond with an identified impact.

Impact ER-1: Would implementation of the project result in the inefficient, wasteful or unnecessary consumption of energy during project construction or operation. (Class III) Construction (Short-Term)
The energy consumption associated with buildout of the project includes electricity usage associated with water usage for dust control, diesel fuel consumption from on-road hauling trips and off-road construction diesel equipment, and gasoline consumption from on-road worker commute and vendor trips. The methodology for each category is discussed below.

This analysis relies on the construction equipment list and operational characteristics, as stated in Chapter 6 (Air Quality) and Chapter 10 (Greenhouse Gas Emissions), as well as Appendix B:

Air Quality and Greenhouse Gas Emissions Analysis. Quantifications of construction energy consumption are provided for the project.

Electricity Usage
Water Consumption for Construction Dust Control
Electricity usage associated with water consumption for construction dust control is calculated based on total water consumption and the energy intensity for supply, distribution, and treatment of water.

The total number of gallons of water usage is calculated based on acreage disturbed during grading and site preparation, as well as the daily water consumption rate per acre disturbed.  The total acres disturbed are calculated using the methodology described in Chapter 4.2 of Appendix A of the CalEEMod® User’s Guide (Grading Equipment Passes).  The water application rate of 3,020 gallons per acre per day is from Air and Waste Management Association’s Air Pollution Engineering Manual.

The energy intensity value is based on the CalEEMod® default energy intensity per gallon of water for Alameda County.

As summarized in Table 18-4: Project Energy Consumption During Construction, the total electricity consumption associated with water consumption for construction dust control would be approximately 72,487,475 kWh (72,487.5 megawatt hours [MWh]) over the duration of buildout of the project.
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Table 18-4: Project Energy Consumption During Construction Source
Project
Construction Usage
Alameda County Annual
Energy Consumption
Percentage
Increase
Countywide
Electricity Use Megawatt Hours (MWh)
Water Consumption 72,487 10,247,410 0.7074%
Diesel Use Gallons
On-Road Construction Trips 1 687,192
155,890,839

0.4408%
Off-Road Construction Equipment 2 1,272,611 0.8163%
Construction Diesel Total 1,959,803 1.2572%
Gasoline Gallons
On-Road Construction Trips 1 913,700 553,890,645 0.1650%

1. On-road mobile source fuel use based on vehicle miles traveled (VMT) from CalEEMod and fleet-average fuel consumption in gallons per mile from EMFAC2021 in Alameda County for construction year 2023 through 2028.

2. Off-road mobile source fuel usage based on a fuel usage rate of 0.05 gallons of diesel per horsepower (hp)-hour from USEPA.

Abbreviations:

CalEEMod: California Emission Estimation Model; EMFAC: Emission Factor Model 2021; Sources: Appendix B: Air Quality and Greenhouse Gas Emissions Analysis Diesel Usage
On-Road Construction Trips
The diesel usage associated with on-road construction mobile trips is calculated based on vehicle miles traveled (VMT) from vehicle trips (i.e., worker, vendor, and hauling), the CalEEMod default diesel fleet percentage, and vehicle fuel efficiency in miles per gallon. VMT for the entire construction period is calculated based on the total (See Chapter 6: Air Quality and Chapter 10: Greenhouse Gas Emissions). Construction fuel consumption was calculated based on CalEEMod emissions outputs and conversion ratios from the Climate Registry.

As summarized in Table 18-4: Project Energy Consumption During Construction, the total diesel consumption associated with on-road construction trips would be approximately 687,192 gallons over the duration of buildout of the project.

Off-Road Construction Equipment
The construction diesel usage associated with the off-road construction equipment is calculated based on CalEEMod emissions outputs and conversion ratios from the Climate Registry. As summarized in Table 18-4: Project Energy Consumption During Construction, the total diesel consumption associated with off-road construction equipment is approximately 1,272,611 gallons for duration of buildout the project.
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Gasoline Usage
On-Road Construction Trips
The gasoline usage associated with on-road construction mobile trips is calculated based on VMT from vehicle trips (i.e., worker, vendor, and hauling), the CalEEMod default gasoline fleet percentage, and vehicle fuel efficiency in miles per gallon using the same methodology as the construction on-road trip diesel usage calculation discussed above. As summarized in Table 18- 4: Project Energy Consumption During Construction, the total gasoline consumption associated with on-road construction trips would be approximately 913,700 gallons over the duration of buildout the project.

Analysis
In total, construction of the project would consume approximately 72,487,475 kWh (72,487 MWh) of electricity, 1,959,803 gallons of diesel, and 913,700 gallons of gasoline.

As indicated in the environmental setting above, Californians consumed 279,510 GWh of electricity in 2020, of which Alameda County consumed 10,247 GWh. Therefore, construction electricity consumption would represent approximately 0.03 percent of the electricity consumption in the state, and 0.7 percent of the electricity consumption in Alameda County.

In 2023, Californians are estimated to consume approximately 15,355,377,116 gallons of gasoline and approximately 3,683,414,417 gallons of diesel fuel. Alameda County annual diesel consumption was 155,890,839 gallons and gasoline consumption was 553,890,645 gallons.

Project construction gasoline consumption would represent 0.2 percent of gasoline consumption in the County, and construction diesel consumption would represent 1.3 percent of diesel consumption in the County over the approximately six-year construction period.

Therefore, based on the project’s relatively low construction fuel use proportional to State and County consumption, the project would not substantially affect existing energy or fuel supplies or resources. New capacity/additional sources of construction fuel are not anticipated to be required.

Furthermore, there are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy-efficient than at comparable construction sites in the region or state. In addition, some incidental energy conservation would occur during construction through compliance with State requirements that equipment not in use for more than five minutes be turned off. Project construction equipment would also be required to comply with the latest EPA and CARB engine emissions standards. These engines use highly efficient combustion engines to minimize unnecessary fuel consumption.

The project would entail construction activities that would consume energy, primarily in the form of diesel fuel (e.g., mobile construction equipment) and electricity. MM AQ-2.1:

BAAQMD Basic Construction Mitigation Measures requires that engine idling for construction equipment is to be limited and that all equipment is properly tuned and maintained to the 1273
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manufacturer’s specifications. Additionally, the City’s Construction and Demolition Debris Ordinance requires that 100 percent of asphalt and concrete be recycled and a minimum of 50 percent of all other materials be recycled. Recycling construction and demolition waste not only keeps it from being transported to the landfill, but also reduces the “upstream” energy consumption from the manufacturing of virgin material in the first place. The project would be required to comply with this ordinance.

Construction activities would be required to monitor air quality emissions using applicable regulatory guidance such as the BAAQMD CEQA Guidelines. This requirement indirectly relates to construction energy conservation because when air pollutant emissions are reduced as a result of monitoring and the efficient use of equipment and materials, this results in reduced energy consumption. There are no aspects of the project that would foreseeably result in the inefficient, wasteful, or unnecessary consumption of energy during construction activities.

As described above, project construction would represent 0.2 percent of gasoline consumption and 1.3 percent of diesel consumption in the County over a six-year period. It should be noted that the CEQA Guideline Appendix F criteria requires the project’s effects on local and regional energy supplies and on the requirements for additional capacity to be addressed. A 0.2 percent increase in gasoline and a 1.3 percent increase in diesel for construction fuel demand is not anticipated to trigger the need for additional capacity. Additionally, use of construction fuel would be temporary and would cease once the project is fully developed. As such, project construction would have a nominal effect on the local and regional energy supplies. It is noted that construction fuel use is temporary and would cease upon completion of construction activities.

As stated above, there are no unusual project characteristics that would necessitate the use of construction equipment that would be less energy-efficient than at comparable construction sites in the region or state. Therefore, it is expected that construction fuel consumption associated with the project would not be any more inefficient, wasteful, or unnecessary than other similar development projects of this nature. Therefore, potential impacts are considered less than significant.

Operations (Long-Term)
The energy consumption associated with operation of uses pursuant to the project would include building electricity, water, and natural gas usage, as well as fuel usage from on-road vehicles. The methodology for each category is discussed below. Note that this energy resources analysis is consistent with the analysis presented in Chapter 6 Air Quality and Chapter 10 Greenhouse Gas Emissions. Quantifications of operational energy consumption are provided for the project.

Transportation Energy Demand
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from EMFAC2021 model. The EMFAC2021 fuel efficiency data incorporate the Pavley Clean Car Standards and the Advanced Clean Cars Program.25 As summarized in Table 18-5: Project Annual Energy Consumption During Operations, the total gasoline and diesel consumption associated with on-road trips would be approximately 813,737 gallons per year and 1,514,686 gallons per year, respectively.

The EMFAC2021 model includes the fraction of electric vehicles projected to be in the on-road fleet during the assumed first year of operation; however, the fraction of the fleet that is electric is assumed to continue to increase, allowing a decrease in gasoline and diesel consumption. The electricity consumption related to electric vehicle traffic during operation was estimated based on the EMFAC2021 fleet mix and the model year 2028 average kWh/mile for current model electric vehicles. Total electricity usage from the on-road transportation during operation is approximately 15,496,300 kWh per year (15,496 MWh per year).

Table 18-5: Project Annual Energy Consumption During Operations Source Project Operational
Usage
Alameda County Annual Energy
Consumption
Percentage Increase
Countywide
Electricity Use Megawatt Hour/Year (MWh/year)
Area 1 14,490
10,247,410

0.1414%
Water 1 414.4 0.0040%
Mobile 591.9 0.0058%
Operational Electricity
Total 15,496.3 0.1512%
Natural Gas Use Therms/year
Area 1 0 366,465,038 0%
Diesel Use Gallons/Year
Mobile 2 1,514,686 152,160,799 0.9955%
Gasoline Use Gallons/Year
Mobile 2 813,737 510,772,956 0.1593%
Notes:

1. The electricity, natural gas, and water usage are based on project-specific estimates and CalEEMod defaults.

2. Calculated based on the mobile source fuel use based on vehicle miles traveled (VMT) and fleet-average fuel consumption (in gallons per mile) from EMFAC2021. For electric vehicles, model year 2028 electric vehicle fuel economy is used from the DOE Fuel Economy Guide.

Abbreviations: CalEEMod: California Emission Estimation Model; EMFAC2014: California Air Resources Board Emission Factor Model; kBTU:
thousand British Thermal Units; kWh: kilowatt-hour; MWh: Megawatt-hour. 25 The California Air Resources Board EMFAC 2017 Technical Documentation (March 2018) notes that emissions are estimated with all current controls active, except Low Carbon Fuel Standards (LCFS). The reason for excluding LCFS is that most of the emissions benefits due to the LCFS come from the production cycle (upstream emissions) of the fuel rather than the combustion cycle (tailpipe). As a result, LCFS is assumed to not have a significant impact on CO2 emissions from EMFAC’s tailpipe emission estimates. 1275
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Source Project Operational
Usage
Alameda County Annual Energy
Consumption
Percentage Increase
Countywide
Sources: DOE 2016; USEPA 1996.

Analysis
Operation of uses implemented pursuant to the project would consume approximately 15,496.3 MWh per year of electricity, 1,514,686 gallons of diesel, and 813,737 gallons of gasoline.

Californians consumed 279,510 GWh of electricity in 2020, of which Alameda County consumed 10,247 GWh. The project’s operational electricity consumption would represent 0.0055 percent of the electricity consumption in the state, and 0.1512 percent of the energy consumption in Alameda County.

In 2023, Californians are estimated to consume approximately 15,355,377,116 gallons of gasoline and approximately 3,683,414,417 gallons of diesel fuel. Alameda County 2028 annual diesel consumption was 152,160,799 gallons and gasoline consumption was 510,772,956 gallons. Project operational consumption of gasoline and diesel would represent 0.01 percent of gasoline and 0.04 percent of diesel consumption statewide. Project operational consumption of gasoline and diesel would represent 0.2 percent of gasoline and 0.99 percent of diesel consumption in the County.

Therefore, operation of uses under the project would not substantially affect existing energy or fuel supplies or resources. The project would comply with applicable energy standards and new capacity would not be required. Impacts would be less than significant in this regard.

Energy Efficiency and Renewable Energy Measures
As discussed above, California’s Energy Efficiency Standards for Residential and Non-residential Buildings create uniform building codes to reduce California’s energy consumption and provide energy efficiency standards for residential and non-residential buildings. These standards are incorporated within the California Building Code and are expected to substantially reduce the growth in electricity and natural gas use. For example, requirements for energy efficient lighting, heating and cooling systems, and green building materials are expected to save additional electricity and natural gas. These savings are cumulative, doubling as years go by.

The project would include additional energy efficiency measures per City’s Climate Action Plan 2030 and Beyond. For example, the project would install LED streetlights where streetlights are needed. The project also would include energy-efficient outdoor lighting for community and publicly accessible outdoor spaces where feasible. Full cut-off lights and automated outdoor lights on commercial buildings and in publicly accessible places, including open space and parking lots, that adjust for time and seasons would also be utilized.

Photovoltaic solar systems and on-demand water heating systems would be included as an option for home buyers. Photovoltaic systems would be installed on the rooftops of 1276
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commercial buildings. On-demand water heating systems would also be included where applicable. Additionally, all structures that do not include solar photovoltaic panels will be “solar ready,” as required by City Municipal Code sections 7.94.060 and 7.94.070. Energy Star appliances and low-flow toilets would be installed for the residential units and low-flow toilets and “smart” control systems would be installed for commercial uses. Light-colored cool roofs would be used for the apartments and commercial buildings and pavement and would be lightcolored throughout the project.

Regarding water energy conservation, the project would incorporate drought-tolerant landscaping in commonly-owned areas in the residential and commercial portions of the site.

Water-efficient irrigation controls would also be used in the landscape areas. A comprehensive water conservation strategy would be developed as applicable to each respective land use as part of the project plan development. Buildings would also incorporate water-efficient fixtures and appliances, in compliance with Title 24.

The project also reduces transportation energy usage by applying “smart growth” principles as an urban in-fill development with a mix of retail, entertainment, and residential uses adjacent to transit/multi-modal corridors and within two miles of a BART station. The project facilitates the use of existing bus routes with stops adjacent to the project site. The Livermore Amador Valley Transit Authority (LAVTA) runs bus service from the project site (Dublin Boulevard and Tassajara Road) to the BART station with 30-minute headways.

Additionally, the project would improve and complete pedestrian and bicycle connections around its perimeter and through the project site. Bicycle storage would be provided in the multifamily, as required and bicycle racks would be provided near the commercial uses. The project would also improve and complete bicycle lanes and facilities along the perimeter and through the project site that connect with existing bicycle routes.

The project includes landscaped paseos and pedestrian pathways that would directly connect residents and retail patrons with adjacent open space, surrounding neighborhoods and nearby Emerald Glen Park. Sidewalks on the streets surrounding the project site would be improved and a 10-foot public multi-use trail would be constructed on the north side of Central Parkway and an on-street bicycle lane along Dublin Boulevard, Tassajara Road, Central Parkway, and Gleason Drive.

Recent case law (League to Save Lake Tahoe, Mountain Area Preservation, et al./California Clean Energy Committee v. County of Placer, et al. (Sierra Pacific Industries, et al., Real Parties in Interest)) (2022) has indicated that an EIR’s analysis of a project’s impacts on energy resources must include a discussion of whether the project would increase its reliance on renewable energy sources to meet its energy demand as part of determining whether the project’s energy impacts are significant. The project would be designed in accordance with the applicable Title 24 Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations [CCR], Title 24, Part 6). These standards are updated, nominally every three years, to incorporate improved energy efficiency technologies and methods. The Building Official, or 1277
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designee shall ensure compliance prior to the issuance of each building permit. The Title 24 Energy Efficiency Standards (Section 110.10) require buildings to be designed to have 15 percent of the roof area “solar ready” that will structurally accommodate later installation of rooftop solar panels. If future building operators pursue providing rooftop solar panels, they would submit plans for solar panels prior to occupancy. As discussed above, the project includes several design features and mitigation measures that would minimize energy consumption. As the Project is required to minimize its energy consumption, its impacts in this regard would be less than significant.

Furthermore, both electricity providers in Alameda County, EBCE and PG&E, are subject to California’s Renewables Portfolio Standard (RPS). The RPS requires investor-owned utilities, electric service providers, and community choice aggregators to increase procurement to 50 percent of total procurement by 2030. Renewable energy is generally defined as energy that comes from resources which are naturally replenished within a human timescale such as sunlight, wind, tides, waves, and geothermal heat.

The project would be required to adhere to all Federal, State, and local requirements for energy efficiency, including the latest Title 24 standards. Considering these requirements in addition to the project design features described above, the project would not result in the inefficient, wasteful, or unnecessary consumption of building energy. Therefore, potential impacts are considered less than significant.

The project would generate less-than-significant impacts related to energy use. Additionally, the project would incorporate various building and transportation energy saving design features (described above) and comply with the latest State Building Code (Title 24, Part 6 of the California Code of Regulations). Title 24 requires the design of building shells and building components to conserve energy. The standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods.

On May 9, 2018, the CEC adopted the 2019 Building Energy Efficiency Standards, which took effect on January 1, 2020.

The 2019 Standards improve upon the 2016 Standards. Under the 2019 Title 24 standards, residential buildings are expected to be about 7 percent more energy efficient, and when the required rooftop solar is factored in for low-rise residential construction, residential buildings that meet 2019 Title 24 standards would use about 53 percent less energy than those built to meet the 2016 standards. Nonresidential buildings use about 30 percent less energy than those built to meet the 2016 standards. Additionally, the updated 2022 Building Energy Efficiency Standards take effect on January 1, 2023.

The California Green Building Standards Code (California Code of Regulations, Title 24, Part 11), commonly referred to as the CALGreen Code, is a statewide mandatory construction code that was developed and adopted by the California Building Standards Commission and the California Department of Housing and Community Development. CALGreen standards require new residential and commercial buildings to comply with mandatory measures under five topical 1278
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areas: planning and design; energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and environmental quality. CALGreen also provides voluntary measures (CALGreen Tier 1 and Tier 2) that local governments may adopt which encourage or require additional measures in the five green building topics. The most recent update to the CALGreen Code was adopted in 2019 and went into effect on January 1, 2020 and the updated 2022 CALGreen Code takes effect on January 1, 2023.

18.5.4 Cumulative Impacts
Construction and operations associated with implementation of the project would result in the consumption of fuel and energy, but it would not do so in a wasteful manner. The consumption of fuel and energy would not be substantial in comparison to statewide electricity, natural gas, gasoline, and diesel demand; refer to Table 18-4 and Table 18-5. New capacity or supplies of energy resources would not be required. Additionally, the project would be subject to compliance with all Federal, State, and local requirements for energy efficiency.

The anticipated project impacts, in conjunction with cumulative development in the site vicinity, would increase urbanization and result in increased energy consumption. Potential land use impacts are site-specific and require evaluation on a case-by-case basis. Each cumulative project would require separate discretionary approval and CEQA assessment, which would address potential energy consumption impacts and identify necessary mitigation measures, where appropriate.

As noted above, the project would not result in significant energy consumption impacts. The project would not be considered inefficient, wasteful, or unnecessary with regard to energy.

Thus, the project and identified cumulative projects are not anticipated to result in a significant cumulative impact. Therefore, potential impacts are considered less than significant.

18.5.5 Level of Significance After Mitigation
Table 18-6: Summary of Impacts and Mitigation Measures – Energy Conservation summarizes the environmental impacts, significance determinations, and mitigation measures for the project with regard to energy conservation.

Table 18-6: Summary of Impacts and Mitigation Measures – Energy Conservation Impact Impact Significance Mitigation
Impact ER-1: Encourage activities that result in the
use of large amounts of fuel or energy, or use these
resources in a wasteful manner (Class III)
Less than Significant None required

18.6 References
California Air Resources Board Emission Factor Model (EMFAC). 2021, 2022. Emissions Inventory. Available at: https://arb.ca.gov/emfac/. Accessed May 2, 2022. 1279
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California State Board of Equalization (BOE.) 2022. Net Taxable Gasoline Gallons. Available at:
https://www.cdtfa.ca.gov/taxes-and-fees/MVF-10-Year-Report.pdf. Accessed May 2, 2022.

California State Board of Equalization (BOE). 2018. Taxable Diesel Gallons 10-year Report.

Available at: http://www.cdtfa.ca.gov/taxes-and-fees/Diesel-10-Year-Report.pdf.

Accessed May 2, 2022.

California Emissions Estimator Model (CalEEMod). 2022. CalEEMod User’s Guide. Available at:
http://www.caleemod.com/.

California Energy Commission (CEC). 2022a. Integrated Energy Policy Report Update. Available at: https://www.energy.ca.gov/data-reports/reports/integrated-energy-policyreport/2022-integrated-energy-policy-report-update. Accessed May 2, 2022.

California Energy Commission (CEC). 2020a. Electricity Consumption by County. Available at:
htpp://www.ecdms.energy.ca.gov. Accessed May 2, 2022.

California Energy Commission (CEC). 2020b. Energy Almanac, California’s Electricity Data.

Available at:
http://www.energy.ca.gov/almanac/electricity_data/total_system_power.html.

Accessed May 2, 2022.

California Energy Commission (CEC). 2019. California’s Energy Efficiency Standards for Residential and Nonresidential Buildings. Available at:
http://www.energy.ca.gov/title24/2016standards/. Accessed May 2, 2022.

California Public Utilities Commission and California Energy Commission (CPUC and CEC). 2008. 2008 Update, Energy Action Plan. Available at:
http://www.energy.ca.gov/2008publications/CEC-100-2008-001/CEC-100-2008- 001.PDF.

Pacific Gas & Electric (PG&E). 2022. Company Profile. Available at:
https://www.pge.com/en_US/about-pge/company-information/profile/profile.page.

Accessed May 2, 2022.

United States Energy Information Administration (EIA). 2022. California Natural Gas Total Consumption. Available at: https://www.eia.gov/dnav/ng/hist/na1490_sca_2a.htm Accessed May 2, 2022.
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19 Alternatives
This section describes the CEQA requirements related to alternatives and describes the process used to define alternatives to the project. It describes three alternatives to the project and provides a comparative analysis for each of these alternatives to the project. It includes the evaluation of the No Project Alternative, as required by CEQA, and a comparison of alternatives.

Finally, it identifies the environmentally superior alternative.

19.1 CEQA Requirements for Alternatives
CEQA requires that an EIR “…describe a reasonable range of alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation.” (CEQA Guidelines §15126.6(a)).

To comply with this requirement, the City of Dublin evaluated possible alternatives based on the following factors:
 Does the alternative accomplish most of the basic project objectives?  Is the alternative potentially feasible (from economic, environmental, legal, social, technological standpoints)?
 Does the alternative avoid or substantially lessen any significant effects of the project? Alternatives need to be environmentally superior to the project in only some, not all, respects.
 Is the alternative reasonable and realistic? An EIR need not consider an alternative whose effect cannot reasonably be ascertained or whose implementation is remote and speculative, because unrealistic alternatives do not contribute to a useful analysis.

19.2 Consistency with Project Objectives
The basic purpose of an EIR's discussion of alternatives is to suggest ways project objectives might be achieved at less environmental cost. Accordingly, alternatives must be able to meet most project objectives, but they need not have to meet all of them. As stated in the CEQA Guidelines, the EIR’s alternatives analysis should focus on alternatives that can eliminate or reduce significant environmental impacts even if they would impede attainment of project objectives to some degree or be more costly (14 CCR §15126.6(b)). The alternatives discussed must, however, be able to attain most of the basic objectives of the project (14 CCR §15126.6(a)).
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The determination of whether to eliminate or retain alternatives in this EIR was based on each alternative’s ability to meet most or all of the project objectives (see Chapter 3: Project Description), even if the alternative may be more costly than the project.

19.3 Alternatives Eliminated from Further Consideration

19.3.1 Alternative Location
CEQA Guidelines Section 15126.6(f)(2) sets forth considerations to be used in evaluating an alternative location. The section states that the “key question” is whether any of the significant effects of the project would be avoided or substantially lessened by relocating the project. The CEQA Guidelines identify the following factors that may be taken into account when addressing the feasibility of an alternative location:
 Site suitability
 Economic viability
 Availability of infrastructure
 General Plan consistency
 Other plans or regulatory limitations
 Jurisdictional boundaries
 Whether the project applicant can reasonably acquire, control, or otherwise have access to the alternative site
The CEQA Guidelines establish that only locations that would avoid or substantially lessen the project’s environmental effects are feasible and would meet most of the project objectives should be considered as alternative locations for the project.

Because of Alameda County Measure D, which effectively prohibits new urban development outside of city limits in eastern Alameda County, only sites located within the current Dublin city limits are considered feasible.

Given the size of the project and the broad mix of uses proposed, it was determined that there are no other suitable undeveloped parcels that do not already have a pending application nor have existing entitlements in the City of Dublin that could accommodate the land uses envisioned for the project. Additionally, the project applicant does not own or otherwise control property of a similar size.

For these reasons, this alternative was eliminated from further consideration.

19.3.2 Commercial Only Project
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would fail to meet most of the basic project objectives as they relate to the development of a mixed use residential and commercial project with a range of types and densities of housing in a Priority Development Area residential uses. For these reasons, this alternative was eliminated from further consideration.

19.4 Alternative 1 – No Project Alternative

19.4.1 Description
In addition to studying a reasonable range of alternatives based on the criteria set forth above, CEQA requires the EIR to analyze a “no‐project” alternative. Consideration of the No Project Alternative is required by Section 15126.6(e) of the CEQA Guidelines. The analysis of the No Project Alternative must discuss the existing conditions at the time the Notice of Preparation was published (March 25, 2015), as well as: “what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services” (CEQA Guidelines Section 15126.6 (e)(2)).

The requirements also specify that: “If disapproval of the project under consideration would result in predictable actions by others, such as the proposal of some other project, this ‘no project’ consequence should be discussed” (CEQA Guidelines Section 15126.6 (e)(3)(B)). The No Project Alternative considers the Project site remaining in its current undeveloped state.

19.4.2 Impact Analysis
The No Project Alternative would not advance any of the project objectives and the project site would remain undeveloped for the foreseeable future. No disturbance or new development would occur, thereby eliminating the potential for impacts on any of the environmental resources analyzed in this EIR. Accordingly, this alternative would avoid all of the project’s significant impacts (including significant and unavoidable impacts), as well as the need to implement any mitigation measures.

19.5 Alternative 2 – Existing General Plan and Eastern Dublin Specific Plan

19.5.1 Description
Alternative 2 – Existing General Plan and Eastern Dublin Specific Plan would allow development consistent with existing land use designations and development densities as described in the General Plan and Eastern Dublin Specific Plan. As shown in Figure 3-3: Existing General Plan Land Use Designations, this includes designations of Neighborhood Commercial, General Commercial, Medium High Density Residential, High Density Residential, and Public/SemiPublic. Most the site is designated General Commercial. As shown in Table 3-1: Eastern Dublin Specific Plan Anticipated Project Site Development, the Eastern Dublin Specific Plan assumed a mid-density level of development of 261 residential units and 902,563 square feet of commercial.

As shown in Table 19-1: Alternative 2 Land Use Summary & Comparison, this alternative would have 389 fewer residential units and 637,563 more square feet of commercial uses in comparison to the project.
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Table 19-1: Alternative 2 Land Use Summary & Comparison Land Use Designations Gross Acres Res. Units Du/Acre
Floor Area
Ratio
Commercial
sq. ft.

General Commercial 60.3 -- -- .4 846,153
Neighborhood Commercial 3.7 -- -- .35 56,140
Medium Density Residential 4.3 43 10 -- --
Medium-High Density Residential 5.3 106 20 -- --
High Density Residential 3.2 112 109 -- --
Public / Semi-Public 3.3 -- -- -- --
Total 261 902,563
Proposed Project 76.9 650 -- -- 265,000
Difference (389) 637,563

19.5.2 Impact Analysis
Because the entirety of the project site is assumed to be disturbed, impacts to Cultural & Tribal Resources, Geology & Soils, Hazards & Hazardous Materials, Hydrology & Water Quality, and construction related Air Quality/GHG Emissions and Noise would be similar to the project. Also, because the types of land uses would be similar and subject to the site and architectural design review, impacts to aesthetics would also be similar.

Impacts to Public Services, Utilities, & Service Systems and Energy Conservation, would generally be similar as this alternative would be developing urban uses, similar to that proposed; with both needing infrastructure to service the site, as well as police, fire, and emergency services.

Because the number people living on the project site would be less, impacts to population and housing would be reduced; however, impacts would not be significant for this alternative, similar to the project.

As shown in Table 19-2: Alternative 2 Trip Generation Comparison, Alternative 2 would generate considerably more trips as compared to the project. 1284
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Table 19-2: Alternative 2 Trip Generation Comparison
Scenario
Trip Generation
Daily AM Peak Hour PM Peak Hour
Saturday Peak
Hour
Alternative 2 – Existing General Plan
and Eastern Dublin Specific Plan
27,721 740 2,387 3,486
Proposed Project 10,983 644 777 1,307
Difference 16,738 96 1,610 +2,179
Source: Kimley-Horn & Associates, 2022.

Because Alternative 2 would result in more traffic trips, operational impacts to air quality would be greater. The greater number of traffic trips would correspond to more operational noise impacts as well.

With respect to vehicle miles traveled (VMT), Alternative 2 would include 846,153 sf of General Commercial and 56,140 of Neighborhood Commercial, but would not include a Topgolf recreation center. As such, there would be no significant unavoidable impact associated with VMT.

19.6 Alternative 3 – Commercial Development Task Force Land Plan

19.6.1 Background & Context
This alternative is derived from recommendations made by the City of Dublin Commercial Development Task Force (CDTF), as documented in their Final Summary of Key Recommendations Report, July 2014. The CDTF was created by the Dublin City Council in March 2014 to examine the potential for additional commercial development throughout Dublin. City staff identified five “opportunity sites” that were the key focus of the CDTF, namely: 1) Downtown Dublin; 2) The Green at Park Place; 3) Dublin Land Company (the project site); 4) The Promenade/Grafton Plaza; and 5) the Chen property.

The purpose of the CDTF was to engage residents and seek their input regarding the remaining undeveloped commercial properties in Dublin. The CDTF was charged with the following three tasks:

1. Classify the desirability of existing commercial sites for future development

2. Define desirable design principles to shape the vision of future commercial development

3. Identify additional economic development incentives to attract and retain commercial uses
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The project site was identified as Dublin Land Company (DLC) – Parcel 1 (I-580 to Dublin Boulevard), Parcel 2 (Dublin Boulevard to Central Parkway, and Parcels 3 & 4 (Center Park to the northern boundary, north of Gleason Drive). The CDTF made following land use recommendations:

DCL Parcel 1
A4-1. There is support for the existing land use of General Commercial which allows both office and retail commercial.

A4-2. There is strong support for office uses at this site which should be a priority over retail.

A4-3. Office development should and would complement Dublin Corporate Center and Gateway Medical to the west across Tassajara Road.

A4-4. Do not consider an auto dealership at this location.

DCL Parcel 2
A4-5. Create a “main street” lifestyle experience which incorporates a sense of place, walkable, with gathering areas.

A4-6. Provide opportunities for retail, restaurant and neighborhood serving uses.

A4-7. This site provides a prime location for retail uses since it is on the “going home” side of Tassajara Road.

A4-8. Uses should complement, but not necessarily duplicate, those uses already located at The Shops at Waterford.

A4-9. Develop this parcel as a neighborhood commercial/lifestyle oriented walkable shopping center.

A4-10. A mixed-use residential development, similar in orientation to The Shops at Waterford, is supported here if it includes a strong retail component.

A4-11. The construction timing for the residential portion of a mixed-use development should be tied to the construction of any retail component.

DLC - Parcels 3 & 4
A4-12. These parcels are best suited for medium-density residential.

A4-13. Residential uses should be considered based on existing adjacent uses and the proximity to Emerald Glen Park.

A4-14. Residential development is supported on Parcels 3 and 4 if there is a strong commercial component on Parcel 2.
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19.6.2 Description
Based on the recommendations above, particularly recommendation A4-3, this alternative assumes the development of office use south of Dublin Boulevard. This 23-acre area would be developed at a 0.3 floor-area-ratio (FAR) for a total of 300,564 square feet. The land uses north of Dublin Boulevard would remain the same as the project. As shown in Table 19-3: Alternative 3 Land Use Summary & Comparison, this alternative would result in a reduction of 35,564 sf. of commercial land use.

Table 19-3: Alternative 3 Land Use Summary & Comparison Land Use Designations Gross Acres Res. Units Du/Acre
Floor Area
Ratio
Commercial
sq. ft.

General Commercial 29.4 40 -- .30 300,564
Medium Density Residential 17 150 8.8 --
Medium-High Density Residential 21.1 360 17.1 -- --
Public/Semi-Public 3.8 100 26.3 -- --
Parks/Public Recreation 2.5 -- -- -- --
Total -- 650 -- -- 300,564
Proposed Project 73.8 650 -- -- 265,000
Difference -- 0 -- -- (35,564)

19.6.3 Impact Analysis
Because the entirety of the project site is assumed to be disturbed, impacts to Cultural & Tribal Resources, Geology & Soils, Hazards & Hazardous Materials, Hydrology & Water Quality, and construction related Air Quality/GHG Emissions and Noise would be similar to the project. Also, because the types of land uses would be similar and subject to the site and architectural design review, impacts to aesthetics would also be similar.

Impacts to Public Services, Utilities, & Service Systems and Energy, would generally be similar as this alternative would be developing urban uses, similar to that proposed; with both needing infrastructure to service the project site, as well as police, fire, and emergency services.

Because there would be no change in the number of residential units on the project site, impacts to population and housing would be similar to the project.

As shown in Table 19-4: Trip Generation for Alternative 3, Alternative 3 would generate considerably less trips as compared to the project.
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Table 19-4: Alternative 3 Trip Generation Comparison
Scenario
Trip Generation
Daily AM Peak Hour PM Peak Hour
Saturday Peak
Hour
Alternative 3 – Commercial 12,765 764 1,027 909
Proposed Project 19,327 748 1,545 1,928
Difference -6,562 +16 -518 -1,019
Source: Kimley-Horn & Associates, 2022.

Because Alternative 3 would result in fewer traffic trips, operational impacts to air quality would be less, but would remain significant and unavoidable. The reduced number of traffic trips would correspond to less operational noise impacts as well.

19.7 Environmentally Superior Alternative
The qualitative environmental effect of each alternative in relation to the project are summarized in Table 19-5: Comparison of Alternatives.

Table 19-5: Comparison of Alternatives
Topic
Alternative 1
No Project
Alternative 2
Existing General Plan
and Eastern Dublin
Specific Plan
Alternative 3
Commercial
Development Task
Force Land Plan
Aesthetics Less impact Similar impact Similar impact
Air Quality Less impact Similar Impact Less impact
Biological Resources Less impact Similar impact Similar impact Cultural & Tribal Cultural
Resources Less impact Similar impact Similar impact
Geology & Soils Less impact Similar impact Similar impact Greenhouse Gas Emissions Less impact Greater impact Less impact Hazards & Hazardous Materials Less impact Similar impact Similar impact Hydrology & Water Quality Less impact Similar impact Similar impact Land Use & Planning Less impact Similar impact Similar impact Noise & Vibration Less impact Similar Impact Less impact Population & Housing Less impact Similar impact Similar impact Public Services, Utilities &
Service Systems Less impact Similar impact Similar impact 1288
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Topic
Alternative 1
No Project
Alternative 2
Existing General Plan
and Eastern Dublin
Specific Plan
Alternative 3
Commercial
Development Task
Force Land Plan
Transportation Less impact Less impact Less impact
Energy Less impact Similar Impact Similar impact
CEQA Guidelines Section 15126(e)(2) requires an EIR to identify an environmentally superior alternative. If the No Project Alternative is the environmentally superior alternative, the EIR must also identify an environmentally superior alternative from among the other alternatives.

In this case, the No Project Alternative has less impact on all topical subjects. Therefore, of the three remaining alternatives, Alternative 3 – Commercial Development Task Force Land Plan would be environmentally superior because it would not result in less impacts to Air Quality, Greenhouse Gas Emissions, Noise, and Transportation. This would result in the greatest reductions in the severity of the significant unavoidable transportation impacts, and a corresponding reduction in air quality and noise impacts. Therefore, Alternative 3 – Commercial Development Task Force Land Plan is the Environmentally Superior Alternative.

19.8 References
City of Dublin, Eastern Dublin Specific Plan 1985; updated2022.

City of Dublin, General Plan, 1985 amended 2022.

City of Dublin Commercial Development Task Force, Final Summary of Key Recommendations Report, 2014
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20 Other CEQA Considerations

20.1 Growth-Inducing Effects
Section 15126.2(d) of the State CEQA Guidelines provides the following guidance on growth‐ inducing impacts: a project is identified as growth inducing if it “could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.”
A project can have direct and/or indirect growth-inducement potential. Direct growth inducement would result if a project involves construction of new housing. A project can have indirect growth-inducement potential if it would establish substantial new permanent employment opportunities (e.g., commercial, industrial or governmental enterprises) or if it would involve a substantial construction effort, which would relate to labor requirements for construction, with substantial short-term employment opportunities and indirectly stimulate the need for additional housing and services to support the new employment demand.

However, as the project site is located within the City of Dublin, this growth has been planned as anticipated in the City’s General Plan.

Similarly, under CEQA, a project would indirectly induce growth if it would remove an obstacle to additional growth and development, such as removing a constraint on a required public service. Increases in population could tax existing community service facilities, requiring construction of new facilities that could cause significant environmental effects. The CEQA Guidelines also require analysis of the characteristics of projects that may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively.

The project’s 650 residential units would directly result in a population increase of 1,944 persons, based on the General Plan Public Review Draft Housing Element average of 2.99 persons per household. This population increase would not represent a substantial increase in housing and/or residents. Furthermore, this amount of growth would be within existing growth projections for the City. Equally, the increase in population would not represent a substantial indirect growth inducement factor. Residential development on the project site would not propose new infrastructure that would induce substantial growth in the project site vicinity that was not previously considered for development. Residential development on the project site, like other development in the project site vicinity, would connect to existing utilities and occur within an urbanized area adequately served by transportation systems and infrastructure.

The project would develop up to 265,000 sf. of new commercial uses. Using a standard employment estimate of one job per 500 sf., the project would employ an estimated 530 workers. This number of jobs is not large enough to induce significant population growth in the area. In addition, the California Employment Development Department indicates that the Alameda County labor force totaled 827,700 persons as of February 2022. Of this figure, 31,300 persons were unemployed. This indicates that there is a large enough pool of labor in Alameda 1290
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County to fill the project’s employment opportunities such that it would be unlikely that substantial numbers of people would relocate to the East Bay. Similarly, short-term construction jobs would likely be filled by existing residents of the City of Dublin and the region.

Based on the foregoing analysis, growth-inducing impacts would be less than significant.

20.2 Significant Irreversible Commitment of Resources
Section 15126.2(c) of the State CEQA Guidelines states that irreversible commitments of resources should be evaluated to assure that such consumption is justified. Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible because a large commitment of such resources makes removal or nonuse thereafter unlikely, and certain types of impacts may commit future generations to similar uses.

Changes that Commit Future Generations to Similar Uses
The project would change the current land use designation and zoning of the project site and commit future generations to similar land uses. Depending on market demand, the commercial uses could change or be replaced in the future. However, residential development, once constructed, is rarely replaced by new uses within the first few generations after construction.

Use of Nonrenewable Resources
Construction of the project would consume natural resources (gasoline, sand and gravel, asphalt, oil, etc.) during construction activities. During operation of both the commercial and the residential uses, energy would be consumed for lighting, heating/cooling, and transportation. Neither the construction nor operation would consume nonrenewable resources in amounts substantially different from or greater than typical urban development or similar land uses. The project would not affect agricultural resources or mineral resources or access to such resources. Therefore, the project would not involve a large commitment of nonrenewable resources.

Irreversible Damage from Environmental Accidents
The project may include storage of hazardous materials, such as cleaning products and other products, which would not be regarded as sufficient to create a significant hazard to the public.

All hazardous materials would be subject to existing storage, handling, and disposal regulations that limit the potential exposure to workers and the public.

20.3 Significant Unavoidable Impacts
The project would result in the following significant unavoidable impacts:
 Air Quality. The project would cause construction impacts associated with the release of nitrogen oxides (NOx) that would exceed BAAQMD significance thresholds. Despite implementation of MM AQ-2.2: Off-Road Diesel-Powered Construction Equipment, construction-related NOx emissions would remain significant and unavoidable. The project would also cause operational impacts associated with the release of reactive 1291
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organic gases (ROG) and NOx that would exceed BAAQMD significance thresholds.

Despite implementation of MM AQ-2.4: Wood Burning Fireplaces, operational emissions from ROG and NOx would remain significant and unavoidable. These impacts would occur through cumulative conditions.
 Transportation. Using either VMT scenario as described in Section 17.5.3, regional Retail/Recreation, including the proposed Topgolf, would result in a net increase in VMT to the planning area. Per City significance criteria, any net increase in VMT to the planning area would constitute a significant impact. Despite implementation of MM AQ-2.5: Vehicle Trip Reduction which requires the development of a qualifying Commute Trip Reduction (CTR)/ Transportation Demand Management (TDM) plan to reduce mobile GHG emissions as well as VMT for all uses (including the Topgolf development), VMT impacts would remain significant and unavoidable.

The EDSP EIR also included the impacts identified above as significant and unavoidable as follows:
 Air Quality. Project development as a result of dust deposition, construction equipment emissions, mobile source emissions of ROg and NOx, and stationary source emissions. (Impacts 3.11/A, B, C, E)
 Traffic and Circulation. I-580 (Impact 3.3/B, E), intersection of Santa Rita Road and I-580 EB Ramps (Impact 3.3/I), and the intersections of Dublin Boulevard and Hacienda Drive and Dublin Boulevard and Tassajara Road (Impact 3.3/M)
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21 EIR Preparers

21.1 City of Dublin
 Amy Million, Principal Planner
 Kristie Wheeler, Assistant Community Development Director  Pratyush Bhatia, Traffic Engineer

21.2 EIR Preparers
Kimley-Horn and Associates
 Bill Wiseman, Planning Practice Leader
 Sophia Lai, Environmental Planner
 Noemi Wyss, Environmental Planner
 Taylor Blanford, Environmental Planner
 Ben Huie, Transportation Practice Leader
 Connie Leung, Transportation Planner
WRA, Inc.
 Justin Simon, Senior Biologist
 Scott Batiuk, Associate Wetland Biologist
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State Clearinghouse No. 2022040022
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Table of Contents
1 Introduction 1
2 Response to Comments on the Draft EIR 2-1
3 Changes and Clarifications to the Draft EIR 3-1
List of Tables
Table 2-1: List of Written Comments Received on the Draft EIR ............................................... 2-1 1296
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10/14/22
1 Introduction
Upon completion of the SCS Dublin Draft Environmental Impact Report (Draft EIR), the City of Dublin filed a Notice of Completion (NOC) with the State Office of Planning and Research to begin the 45-day public review period from July 22, 2022, to September 6, 2022 (Public Resources Code, Section 21161). Concurrent with the NOC, the Draft EIR was distributed to responsible and trustee agencies, other affected agencies, surrounding cities, and interested parties, as well as all parties requesting a copy of the Draft EIR in accordance with Public Resources Code 21092(b)(3). During the public review period, the Draft EIR, including the technical appendices, was available for review on the City’s Development Activity webpage under the SCS Dublin project: https://dublin-development.icitywork.com/.

This SCS Dublin Final Environmental Impact Report (Final EIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) and state and local CEQA Guidelines and represents the independent judgment of the City, as CEQA lead agency. The Draft EIR, technical appendices, and other written documentation prepared during the EIR process, as those documents may be modified by the City Council at the time of certification, together with comments and associated responses, and changes and clarifications to the Draft EIR will constitute the Final EIR, as defined in the CEQA Guidelines Section 15132, and the City of Dublin CEQA Guidelines and Procedures.

1.1 Document Organization and Framework
This FEIR is organized as follows: Section 1 provides a brief introduction to this report. Section 2 provides a list of agencies and interested persons commenting on the Draft EIR. This section also contains individual comments followed thereafter by responses. To facilitate review of the responses, an index number (e.g., 1-1, 1-2, 2-1) has been assigned to each comment and to its corresponding responses. Section 3 contains changes and clarifications to the Draft EIR as a result of the comments by agencies and interested persons as well as staff-initiated changes.

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

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

1.2 CEQA Requirements Regarding Comments and Responses
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be, “on 1297
SCS Dublin City of Dublin