Agenda packet, regular meeting — Dublin City Council, March 19, 2024 (part 2 of 5)

with mitigation.

Greenhouse Gas Emissions
There were no potentially significant impacts identified for greenhouse gas emissions and, therefore, no mitigation is required.

Hazards and Hazardous Materials
It has been recommended that a subsurface investigation be completed in the vicinity of the onsite areas for chemical use, storage, and handling to assess whether a release occurred in the past.

If soil or groundwater has been previously contaminated at levels that exceed regulatory thresholds, this would represent a significant human health and environmental hazard because excavation work would be required during construction that could release these hazardous materials. Furthermore, demolition of the existing building could expose workers and the environment to hazardous materials such as lead paint and/or asbestos.

Therefore, these construction-related impacts are considered potentially significant and require mitigation. Prior to earthmoving activities, a Phase II Environmental Site Assessment must be completed and the building must be sampled for lead paint and/or asbestos. With the implementation of these mitigation measures, potential construction-related impacts from accidental exposure to hazardous materials would be less than significant with mitigation.

Hydrology and Water Quality
There were no potentially significant impacts identified for hydrology and water quality and, therefore, no mitigation is required.

Land Use Planning
There were no potentially significant impacts identified for land use planning and, therefore, no mitigation is required.

Mineral Resources
There were no potentially significant impacts identified for mineral resources and, therefore, no mitigation is required.

Noise
There were no potentially significant impacts identified for noise and, therefore, no mitigation is required.

Population and Housing
There were no potentially significant impacts identified for population and housing and, therefore, no mitigation is required.

Public Services
There were no potentially significant impacts identified for public services and, therefore, no mitigation is required.

Recreation
There were no potentially significant impacts identified for recreation and, therefore, no 149

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mitigation is required.

Transportation
There were no potentially significant impacts identified for transportation and, therefore, no mitigation is required.

Tribal Cultural Resources
The proposed project would include excavation of the parking lot to the south of the existing Hexcel building, which is adjacent to the marked boundary of the Pioneer Cemetery. Marked grave sites in the cemetery are within five feet of the property line shared with the project site. Historic documents suggest that the cemetery was larger than the currently marked boundary.

Additionally, there is anecdotal evidence that the cemetery location was first used by the Ohlone and may also include burials of Native American and Mexican farm laborers who worked for Jose Maria Amador, interred prior to formal consecration of the cemetery in 1859. It is likely that the cemetery extends beneath the Hexcel parking lot, and possible that the cemetery includes Native American human remains. If so, the impact on tribal cultural resources would be potentially significant during earthmoving and excavation activities. Inadvertent/unanticipated discovery protocols would be implemented, ensuring tribal cultural resources encountered during construction would be treated in a culturally appropriate manner in consultation with Tribal Representatives and, therefore, the impact on tribal cultural resources would be less than significant with mitigation.

Utilities and Service Systems
There were no potentially significant impacts identified for utilities and service systems and, therefore, no mitigation is required.

Wildfire
There were no potentially significant impacts identified for wildfire and, therefore, no mitigation is required.

The City Council resolution certifying the Final Environmental Impact Report is included as Attachment 1. To approve the project, the City Council must make findings regarding significant impacts and mitigation measures (Attachment 3), findings concerning infeasibility of alternatives and potential additional mitigation measures (Attachment 4), and will need to adopt a Statement of Overriding Considerations (SOC) (Attachment 5) that identifies all environmental impacts that cannot be mitigated and explains why the benefits of the project outweigh its unavoidable environmental impacts. The Mitigation Monitoring and Reporting Program is included as Attachment 6. The SOC is required in order to approve the project, if desired by a majority of the City Council.

PLANNING COMMISSION REVIEW:

On December 12, 2023, the Planning Commission held a public hearing to consider the proposed project. Two members of the public addressed the Commission regarding the project. After closing the public hearing and deliberating, the Planning Commission voted 3-2 to recommend approval of the Hexcel Redevelopment Project and adopted Resolution No. 23-11 (Attachment 11). In their 150

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motion, the Planning Commission recommended that the Applicant consider incorporating more design elements found in the Dublin Village Historic Area Specific Plan area.

Since the Planning Commission meeting, the Applicant has made the following changes to the project plans to address the Commission’s comments:
 Revised building colors to include muted earth tones to soften the building allowing it to blend more naturally with the landscape and the color schemes used on buildings in the Historic Area.
 Modified the windows and glazing to reflect a stronger vertical orientation with simple frames in keeping with the Historic Area.
 Provided more pronounced trellis awnings along windows.  Added a contrast color at the top of the building to reduce the massing.  Integrated stone monumentation within the landscape area near the front of the building, which is similar to what can be found in the Historic Area.  Incorporated light standards that reflect a similar design employed in other areas of the Historic Area.
 Matched the plant pallet found in the Historic Area along the project frontage.

STRATEGIC PLAN INITIATIVE:

None.

NOTICING REQUIREMENTS/PUBLIC OUTREACH:

Two City-led Community Meetings were held on October 25 and 26, 2023, to provide Dublin residents with information about the proposed Hexcel Redevelopment project. Staff provided a presentation that included an overview of the City’s development review process and the proposed project. Questions were asked about the project’s impact on infrastructure capacity and the general contractor that would be used for the project. Comments were also provided regarding the EIR and project design.

In accordance with State law, a public notice was mailed to all property owners and occupants within 300 feet of the proposed project to advertise the project and upcoming public hearing. A public notice was also published in the East Bay Times and posted at several locations throughout the City. A Planning Application sign was posted on the project site and the project was also included on the City’s Development Projects webpage. A copy of this Staff Report has been provided to the applicant.

ATTACHMENTS:
1) Attachment 1 – Resolution Certifying an Environmental Impact Report and Adopting Environmental Impact Findings, Findings Regarding Alternatives, a Statement of Overriding Considerations and a Mitigation Monitoring and Reporting Program for the Hexcel Redevelopment Project
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2) Attachment 2 – Exhibit A to the Resolution – Final Environmental Impact Report 3) Attachment 3 – Exhibit B to the Resolution – Findings Concerning Significant Impacts and Mitigation Measures
4) Attachment 4 – Exhibit C to the Resolution – Findings Concerning Infeasibility of Alternatives and Potential Additional Mitigation Measures
5) Attachment 5 – Exhibit D to the Resolution – Statement of Overriding Considerations 6) Attachment 6 – Exhibit E to the Resolution – Mitigation Monitoring and Reporting Program 7) Attachment 7 – Ordinance Amending the Zoning Map and Approving a Planned Development Zoning District with Stage 1 and Stage 2 Development Plan for the Hexcel Redevelopment Project
8) Attachment 8 – Resolution Approving a Site Development Review Permit and Heritage Tree Removal Permit for the Hexcel Redevelopment Project
9) Attachment 9 – Exhibit A to the Resolution – Hexcel Redevelopment Project Plans 10) Attachment 10 – Arborist Report
11) Attachment 11 – Planning Commission Resolution No. 23-11 152
Attachment 1
Reso. No. XX-24, Item X.X, Adopted XX/XX/2024 Page 1 of 3 RESOLUTION NO. XX – 24

A RESOLUTION OF THE CITY COUNCIL

OF THE CITY OF DUBLIN

CERTIFYING AN ENVIRONMENTAL IMPACT REPORT AND ADOPTING ENVIRONMENTAL

IMPACT FINDINGS, FINDINGS REGARDING ALTERNATIVES, A STATEMENT OF

OVERRIDING CONSIDERATIONS AND A MITIGATION MONITORING AND REPORTING

PROGRAM FOR THE HEXCEL REDEVELOPMENT PROJECT
PLPA 2022-00038
(APNS 941-1560-009-01 AND 941-1560-003-04)
WHEREAS, the property owner, Overton Moore Properties, proposes to redevelop an 8.81- acre site located at 11711 Dublin Boulevard. The project would demolish the existing 62,175- square-foot Hexcel research and development building and construct a new 125,304-square-foot light industrial building to appeal to advanced manufacturing and life science uses with 217 parking stalls and related site improvements. Requested approvals include a Planned Development Rezone Stage 1 and Stage 2 Development Plan, Site Development Review Permit and Heritage Tree Removal Permit. These planning and implementing actions are collectively known as the “Hexcel Redevelopment Project” or the “Project;” and
WHEREAS, the Project site includes two parcels totaling approximately 8.81 acres located north of the I-580, south of Dublin Boulevard and residential and commercial uses, east of existing office buildings, and west of the U.S. Bank Branch, Dublin Heritage Park and Museums and Dublin Pioneer Cemetery; and
WHEREAS, the California Environmental Quality Act (CEQA), together with the CEQA Guidelines and City of Dublin CEQA Guidelines and Procedures require that certain projects be reviewed for environmental impacts and that environmental documents be prepared. It was determined that an Environmental Impact Report (EIR) was required for the Project; and WHEREAS, the City circulated a Notice of Preparation, dated May 15, 2023, to public agencies and interested parties for consultation on the scope of the EIR. The City also conducted a public scoping meeting on May 25, 2023; and
WHEREAS, the City prepared a Draft EIR, dated August 2023, for the proposed Project that reflected the City’s independent judgment and analysis of the potential environmental impacts of the Project (SCH No. 2023050372). The Draft EIR is included in the Final EIR attached as Exhibit A and is incorporated herein by reference; and
WHEREAS, the Draft EIR was circulated for a 45-day public review period from August 21, 2023, through October 5, 2023; and
WHEREAS, the City received three comment letters from State, regional, and local agencies during the public review period and one additional letter from the public after the close of the comment period. In accordance with the requirements of CEQA, the City prepared written responses to all the comments received during the public comment period and also included the letter from the public; and
WHEREAS, the City conducted tribal consultation as requested by the Confederated Villages of Lisjan Nation; and
153
Reso. No. XX-24, Item X.X, Adopted XX/XX/2024 Page 2 of 3 WHEREAS, the City prepared a Final EIR, dated November 2023, for the proposed Project, which includes an annotated copy of each comment letter identifying specific comments, responses to each specific comment, and clarifications and minor corrections to information presented in the Draft EIR. The Final EIR is attached as Exhibit A to this Resolution and is incorporated herein by reference. The Draft EIR, comments and associated responses, and changes and clarifications to the Draft EIR constitute the Final EIR. The responses to comments provide the City’s good faith, reasoned analysis of the environmental issues raised by the comments; and
WHEREAS, the Draft EIR identified potentially significant environmental effects anticipated as a result of the Project such as air quality, biological resources, cultural and tribal cultural resources, energy, geology and soils, and hazards/hazardous materials, most of which can be substantially reduced through mitigation measures; therefore, approval of the Project must include impact and mitigation findings as set forth in attached Exhibit B; and WHEREAS, some of the impacts cannot be lessened to a level of less than significant; therefore, approval of the Project must include findings regarding alternatives as set forth in attached Exhibit C, and must include a Statement of Overriding Considerations as set forth in attached Exhibit D; and
WHEREAS, the Planning Commission held a public hearing on the project on December 12, 2023, at which time they reviewed and considered the Draft and Final EIRs, and all reports, recommendations and testimony before them. Following the public hearing, the Planning Commission adopted Resolution No. 23-11 recommending the City Council approve the project and certify the Final EIR; and
WHEREAS, the City Council considered the Planning Commission minutes and recommendation, a staff report, the Draft and Final EIRs, and all written and oral testimony at a duly noticed public hearing on March 19, 2024; and
WHEREAS, a Staff Report dated March 19, 2024, and incorporated herein by reference, described and analyzed the Project and Draft and Final EIR for the City Council; and WHEREAS, the Draft and Final EIRs reflect the City’s independent judgment and analysis on the potential for environmental impacts and constitute the Environmental Impact Report for the Hexcel Redevelopment Project; and
WHEREAS, the Draft and Final EIRs are bounded as one document, incorporated herein by reference, and are available for review in the City of Dublin Community Development Department, file PLPA-2022-00038. The custodian of the documents and other materials which constitute the record of proceedings for the Hexcel Redevelopment Project is the City of Dublin Community Development Department, 100 Civic Plaza, Dublin CA 94568; and WHEREAS, a Mitigation Monitoring and Reporting Program, as required by CEQA, is contained in attached Exhibit E.

NOW, THEREFORE, BE IT RESOLVED THAT the foregoing recitals are true and correct and made a part of this resolution.

BE IT FURTHER RESOLVED that the Dublin City Council certifies the following. 154
Reso. No. XX-24, Item X.X, Adopted XX/XX/2024 Page 3 of 3 A. The EIR for the Hexcel Redevelopment project has been completed in compliance with CEQA, the CEQA Guidelines and the City of Dublin CEQA Guidelines and Procedures.

B. The EIR for the Hexcel Redevelopment project was presented to and reviewed by the City Council prior to taking action on the Hexcel Redevelopment project.

C. The EIR reflects the City’s independent judgment and analysis as to the potential environmental effects of the Hexcel Redevelopment project. The EIR provides information to the decision-makers and the public on the environmental consequences of the Project.

D. The EIR adequately describes the Project, its significant environmental impacts, mitigation measures and a reasonable range of alternatives to the Project.

BE IT FURTHER RESOLVED that the Dublin City Council certifies the EIR consisting of the Draft EIR and the Final EIR as set forth in Exhibit A, adopts the impact and mitigation findings set forth in Exhibit B, the findings regarding alternatives set forth in Exhibit C, the Statement of Overriding Considerations set forth in Exhibit D, and the Mitigation Monitoring and Reporting Program set forth in Exhibit E, which Exhibits A, B, C, D and E are incorporated herein by reference.

PASSED, APPROVED AND ADOPTED this 19th day of March 2024, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
______________________________
Mayor
ATTEST:
_________________________________
City Clerk
155
Hexcel Redevelopment Project
Focused Final EIR
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PROJECT APPLICATION PLPA-2022-00038
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City of Dublin HEXCEL REDEVELOPMENT PROJECT
Table of Contents | Page i
Table of Contents
1 Introduction .......................................................................................................... 1

1.1 Document Organization and Framework ........................................................................... 1

1.2 CEQA Requirements Regarding Comments and Responses ............................................... 2 2 Responses to Comments ....................................................................................... 3

2.1 Comments on the Draft EIR ................................................................................................ 3

2.2 Responses to Comments on the Draft EIR .......................................................................... 3

2.2.1 COMMENT LETTER 1 (DSRSD) ...................................................................................... 3

2.2.2 COMMENT LETTER 2 (ZONE 7 WATER AGENCY) .......................................................... 3

2.2.3 COMMENT LETTER 3 (CALTRANS) ................................................................................ 5

2.2.4 COMMENT LETTER 4 (STEVE MINNIEAR) ..................................................................... 6

2.3 Comments Received on the Draft EIR ................................................................................. 7 3 Changes to the Draft EIR ...................................................................................... 15 4 Mitigation Monitoring and Reporting Program .................................................... 19 Appendices
A Draft EIR
B Appendices to Draft EIR
List of Tables
Table 2-1: Comment Letters Received .............................................................................. 3 Table 4-1. Mitigation Monitoring Reporting Program Table ........................................... 20 158
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HEXCEL REDEVELOPMENT PROJECT
Table of Contents | Page ii
City of Dublin
Acronyms
ACDEH
ADA
BAAQMD
Caltrans
CCR
CEQA
,Z/^
City
dBA
Draft EIR DSRSD
EIR
ESA
Final EIR
FTA
GPR
HABS
HAER
HALS
Iin/sec
Leq
Lincoln
Highway MBTA
MLD
MMRP
mph
NPDES
NPS
NWIC
OPR
PM10
PM2.5
PPV
PRC
Project
R&D
ROW
RWQCB
SVP
SWRCB
TMP
VMT
Alameda County Department of Environmental Health
American Disabilities Act
Bay Area Air Quality Management District
California Department of Transportation
California Code of Regulations
California Environmental Quality Act
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City of Dublin
A-weighted decibel
Draft Environmental Impact Report
Dublin San Ramon Services District
Environmental Impact Report
Environmental Site Assessment
Final Environmental Impact Report
Federal Transit Administration
Ground Penetrating Radar
Historic American Building Survey
Historic American Engineering Record
Historic American Landscapes Survey
Interstate
inches per second
equivalent sound level
later known as US Highway 50
Migratory Bird Treaty Act
Most Likely Descendant
Mitigation Monitoring and Reporting Program
miles per hour
National Pollutant Discharge Elimination System
National Parks Service
Northwest Information Center
Governor’s Office of Planning and Research
particulate matter with aerodynamic diameter less than 10 microns particulate matter with aerodynamic diameter less than 2.5 microns peak particle velocity
Public Resources Code
Hexcel Redevelopment Project
research and development
Right-of-Way
Regional Water Quality Control Board
Society of Vertebrate Paleontology
State Water Resources Control Board
Transportation Management Plan
vehicle miles travelled
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City of Dublin HEXCEL REDEVELOPMENT PROJECT
Final EIR | Page 1
Hexcel Redevelopment Project
Final Environmental Impact Report
1 Introduction
The Hexcel Redevelopment Project (Project) Draft Environmental Impact Report (Draft EIR) was circulated for a 45-day public review period from August 21, 2023, through October 5, 2023, as assigned by the State of California Governor’s Office of Planning and Research (OPR) State Clearinghouse and consistent with California Environmental Quality Act (CEQA) regulations.

Copies of the document were distributed to federal, state, regional and local agencies, as well as organizations and individuals, for their review and comment. This Final Environmental Impact Report (Final EIR) has been prepared in accordance with CEQA, the CEQA Guidelines, and the City of Dublin (City) CEQA Guidelines and Procedures. This document represents the independent judgment of the City of Dublin as CEQA Lead Agency. This document, together with the Draft EIR, technical appendices, and other written documentation prepared during the EIR process, will constitute the Final EIR. This includes any modifications to those documents made by the City Council at the time of certification. This is in accordance with CEQA Guidelines Section 15132 and the City’s CEQA Guidelines and Procedures. The Draft EIR and appendices to the Draft EIR are included in this Final EIR as Appendix A and Appendix B.

1.1 Document Organization and Framework
This Final EIR is organized as follows: Chapter 1 provides a brief introduction to this document.

Chapter 2 provides a list of agencies and interested persons who commented on the Draft EIR.

This chapter provides responses to substantive comments related to CEQA and the Draft EIR that were received during the 45-day review period. To facilitate review of the responses, an index number has been assigned to each comment letter and each individual comment within the comment letter. This identifier is used to identify both the comment and the corresponding response. Chapter 2 also contains copies of all public comments received on the Draft EIR.

Chapter 3 contains text changes to the Draft EIR that have been made in response to the comments received. Chapter 4 contains a Mitigation, Monitoring and Reporting Program, a required component of the EIR process. CEQA Guidelines Section 15097 and Public Resources Code §21081.6 require a public agency to adopt a monitoring and reporting program to ensure efficacy and enforceability of any mitigation measures applied to a proposed project.

City staff has reviewed the comment letters and information generated in the course of preparing responses and has determined that none of this material constitutes significant new information that requires a recirculation period for further public comment under CEQA Guidelines Section 15088.5. None of this 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 would not be mitigated, or that there would be any of the other circumstances requiring recirculation as described in Section 15088.5. 162
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1.2 CEQA Requirements Regarding Comments and Responses
CEQA Guidelines Section 15204(a) outlines parameters for submitting comments and reminds persons and public agencies that the focus of review and comment of Draft EIRs should be, “on the sufficiency of the document in identifying and analyzing possible impacts on the environment and ways in which significant effects of the project might be avoided or mitigated.

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

CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.”
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Final EIR | Page 3
2 Responses to Comments

2.1 Comments on the Draft EIR
This section includes a list of all written comments received on the Draft EIR and the City’s response to each comment. Comment letters and specific comments are given identifying numbers for reference purposes. Responses to comments are provided in Section 2.2, and copies of each comment letter received are provided in Section 2.3. Changes to the text of the Draft EIR, made in response to the comments received, are provided in Chapter 3. Table 2-1 contains the list of agencies and persons that submitted comments on the Draft EIR during the public review period:

Table 2-1: Comment Letters Received
Comment Letter No. Commenting Agency Date
1 Dublin San Ramon Services District (DSRSD) 9/19/2023
2 Zone 7 Water Agency 10/4/2023
3 California Department of Transportation (Caltrans) 10/4/2023 4 Steve Minniear 10/26/2023

2.2 Responses to Comments on the Draft EIR

2.2.1 COMMENT LETTER 1 (DSRSD)
Response to Comment 1-1: Thank you for your letter. The City has reviewed your comment regarding the requirement to contact DSRSD to coordinate the removal of any water meters on the Project site, if needed. The Draft EIR has been revised on pages 10 and 11 to reflect this requirement, as detailed in Chapter 3 of this Final EIR.

2.2.2 COMMENT LETTER 2 (ZONE 7 WATER AGENCY)
Response to Comment 2-1: Thank you for your comment. This comment is regarding a lost well (3S1W02K001) and a destroyed well (3S1W02K012) on the Project site and drilling permit requirements. The City was not previously aware of these wells on the Project site. However, Zone 7 will be notified if these wells are found on the Project site. As discussed on pages 86 and 90 of the Initial Study, Appendix B of the Draft EIR, the Project site does not include any groundwater wells, nor does the Project propose drilling for new wells. While no drilling or boring for new water wells is proposed, the City acknowledges that any water well or soil boring work will require a drilling permit from Zone 7. Revisions have been made to pages 10 and 12 of the Draft EIR to clarify this potential requirement, as detailed in Chapter 3 of this Final EIR.

Response to Comment 2-2: This comment is related to groundwater resources. The City acknowledges that the Project site is located within the basin area under sustainable groundwater management by Zone 7 and that the Project is subject to all relevant sustainable groundwater management actions set forth in the Alternative Groundwater Sustainability Plan. 164
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Hydrology and water quality impacts were evaluated in the Initial Study, Appendix B of the Draft EIR. As discussed on page 90 of the Initial Study, no water wells are being proposed and water needs for the proposed Project would continue to be met by DSRSD, as they are now.

Additionally, page 90 states that while the proposed Project would result in a higher amount of impervious surface at the site as compared to existing conditions, bioretention areas have been sized accordingly and, therefore, the Project would not result in a substantial decrease in the surface area of permeable soils that would allow rainwater to reach the aquifer. Therefore, less than significant impacts to groundwater supplies are expected. No revisions to the Draft EIR are required in response to this comment.

Response to Comment 2-3: This comment relates to potential hydrology and water quality impacts of development adjacent to a creek. Hydrology and water quality impacts of the Project, including impacts related to the proximity of the Project site to Dublin Creek, are discussed in Section 8 of the Initial Study, Appendix B, on pages 89 through 92. The Initial Study found that the Project would have less than significant impacts to hydrology and water quality.

During project construction, the Project would be required to comply with California State Water Resources Control Board (SWRCB) statewide National Pollutant Discharge Elimination System (NPDES) Construction General Permit as discussed on page 89. No construction would occur on the southern approximately 0.56 acre of the Project site (Parcel 2), which is adjacent to Dublin Creek. During Project operation, the proposed on-site stormwater drainage system would be sufficient to detain and treat operational stormwater runoff generated by the proposed Project and runoff would not be discharged into Dublin Creek, as discussed on page

91. Development is prohibited within 30 feet of the centerline of any creek or 20 feet of the top of a bank, per Dublin Municipal Code Section 7.74.110[B], as stated on page 87. Page 91 states that no development associated with the Project would occur within 30 feet of the centerline of Dublin Creek or within 20 feet of the top of the creek bank. Therefore, the Project would be consistent with Zone 7’s proposed methodology and potential failure of the creek bank would not be expected to impact infrastructure on the site. No revisions to the Initial Study are required in response to this comment.

Response to Comment 2-4: This comment relates to assessment of impact fees for development projects that create new impervious areas. The City acknowledges development projects creating new impervious areas within the Livermore-Amador Valley are subject to the assessment of the Development Impact Fee for Flood Protection and Storm Water Drainage.

Revisions have been made to the Draft EIR under Project Approvals on page 12, to identify Zone 7 as an additional agency whose approval may be required, as shown in Chapter 3 of this Final EIR.

Response to Comment 2-5: This comment requests the use of drought-tolerant and climate adapted landscape. As discussed on page 9 of the Draft EIR, the Project would utilize native and drought tolerant plants, which would conserve water at the site. Therefore, the Project would 165
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Final EIR | Page 5
satisfy Zone 7’s recommendation for water wise landscaping. No revisions to the Draft EIR are required in response to this comment.

2.2.3 COMMENT LETTER 3 (CALTRANS)
Response to Comment 3-1: Thank you for your letter. This comment describes the commenter’s understanding of the Project and their agreement that the vehicle miles travelled (VMT) analysis and significance determination within the Initial Study were undertaken in a manner consistent with the OPR’s Technical Advisory and the City’s Traffic Impact Analysis Guidelines, and would contribute to meeting the State’s VMT reduction goals. The City thanks the commenter for their concurrence.

Response to Comment 3-2: This comment is related to construction impacts from the Project.

The comment requests that potential impacts to the State Right-of-Way (ROW) from projectrelated temporary access points should be analyzed and that mitigation measures related to construction and noise should be identified for significant impacts. Additionally, this comment notes that coordination with Caltrans prior to construction to develop a Transportation Management Plan (TMP) and a transportation permit may be required.

Transportation (Section 16) and noise (Section 12) impacts are evaluated in the Initial Study, Appendix B, of the Draft EIR. As described in the Transportation section on page 128, all construction and staging activities would occur on the Project site with no encroachment or alterations of public ROW, including State ROW. There is no direct access to the Project site from nearby State ROWs of Interstates 580 and 680 (I-580 and I-680). However, it is assumed that access to the site would be via the I-580 Foothill Road/San Ramon Road exit (Exit 44 A) to connect to Dublin Boulevard to the west. I-680 also could be used to connect to the I-580 Exit 44 A to the west. Since State highways and their interchanges are designed to accommodate large trucks and higher traffic volumes than local roads, there would be less than significant impacts to State ROWs from project-related construction traffic, as these highways would be able to accommodate the slight temporary increase in construction vehicles. As discussed on page 129, Project construction would result in up to 128 traffic trips per day to and from the Project site from construction workers and deliveries of equipment and materials, and approximately 51 of these trips would be from trucks during peak construction periods. These trips would not be an incompatible use to the highways. Since the Initial Study concluded that these impacts would be less than significant, mitigation is not required.

Impacts from construction noise and vibration were evaluated in the Noise section of the Initial Study and were determined to be less than significant. A construction noise assessment was conducted using construction prediction methodologies based on the Federal Transit Administration (FTA) manual. Tables 10 and 11 on pages 107 and 108 of the Initial Study show that Project construction activities would not exceed the FTA general assessment construction noise criteria of 90 dBA (A-weighted decibel), Leq (equivalent sound level) at the nearest noisesensitive receptor. Furthermore, noise from construction vehicles is expected to be less than the construction activities analyzed in Tables 10 and 11. 166
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As discussed on page 111 of the Initial Study, vibration associated with Project construction activities would occur most notably during major ground-disturbing activities, such as site grading. The piece of construction equipment generating the strongest vibration would be the dozer which, per the FTA Manual, can generate a vibration level of up to 0.089 peak particle velocity (PPV) inches per second (in/sec) at 25 feet. State ROW was not considered to be a sensitive receptor due to the already high levels of noise associated with vehicle traffic.

Because the Project would have a less than significant impact from noise and vibration, mitigation is not required.

The City acknowledges that the Project may require a TMP and that any required oversized or excessive load vehicles during construction operations would require a transportation permit from Caltrans before construction commences. Revisions have been made to the Project approvals list on page 12 of the Draft EIR, to acknowledge the need for such a permit, as shown in Chapter 3 in this Final EIR.

Response to Comment 3-3: This comment is related to potential impacts to Caltrans facilities and American Disabilities Act (ADA) standards. As discussed in Section 16 of the Initial Study, no impact to Caltrans facilities would result from the proposed Project. No revisions to the Draft EIR are required in response to this comment.

2.2.4 COMMENT LETTER 4 (STEVE MINNIEAR)
Response to Comment 4-1: Thank you for your letter. This comment requests that the EIR acknowledge the potential for unmarked graves along the eastern edge of the Project site. The Draft EIR on page 55 acknowledges that Pioneer Cemetery is adjacent to the Hexcel property, and that historic documents suggest the cemetery could extend into the Project site. On page 62 in Section 3, Cultural Resources (Impact c), it is discussed that historic documents suggest that the cemetery was larger than the currently marked boundary, and that there is a high probability that portions of the cemetery extend to the west of the marked cemetery, beneath the Hexcel parking lot. On this page, it also states that if unmarked portions of the cemetery extend beneath the Hexcel property, the Project has the potential to disturb human remains during earthmoving and excavation activities to implement the Project. On page 97 in Section 7, Tribal Cultural Resources (Impact b), similar information to Section 3 is included regarding the extent of the cemetery, as well as an acknowledgement that the cemetery possibly includes Native American human remains. Mitigation measures identified in the Draft EIR, including archaeological and tribal monitoring, and protocols for inadvertent/unanticipated tribal cultural resources discovery, would reduce potential impacts to less than significant.

Please note that the exact location of potential unmarked gravesites was not specified in the Draft EIR, as they could extend well beyond the eastern edge of the Project site. No revisions to the Draft EIR are required in response to this comment.

Response to Comment 4-2: This comment requests that the EIR acknowledge that the western portion of the property is the original Lincoln Highway route from Dublin to what is now Dublin 167
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Canyon Road. This statement has been added to the Draft EIR on page 42 in Section 3, Cultural Resources, as detailed in Chapter 3 of this Final EIR.

Response to Comment 4-3: This comment requests that photographs and historical material should be given to the City of Dublin (Parks and Community Services), not the Dublin Historical Society as stated on page 57 in Section 3, Cultural Resources, of the Draft EIR. This statement in the Draft EIR has been revised to identify the correct entity to receive these materials, as detailed in Chapter 3 of this Final EIR.

Response to Comment 4-4: This comment requests that the proposed light industrial building comply with the Dublin Village Historic Area Specific Plan architectural guidelines. As the commenter states, the applicant envisions wood paneling on exterior walls as an architectural element to honor the historic character of the area. Additionally, as noted in the Draft EIR on page 9, proposed landscaping would provide buffers between the site and adjacent properties, and plants would be strategically placed to screen the site’s aboveground utilities from public streets. While the architectural design of the proposed building would not fully be consistent with the architectural guidelines outlined in Dublin Village Historic Area Specific Plan, it would still be in conformance with the Specific Plan. This is because the Dublin Village Historic Area Specific Plan provides discretion when implementing the guidelines as specified on page 31 in Section 7.1 of the Specific Plan, which states the following:

During their review of proposed development projects, City Staff, the Planning Commission, and the City Council may use discretion in applying various provisions in the design guidelines to specific projects. It is not anticipated that each guideline will apply equally to every project. In some cases, one or more of the guidelines may be relaxed to facilitate compliance with a more important or appropriate guideline for that project. When implementing the guidelines, the overall objective is to ensure that the intent and spirit of the design guidelines are followed and that the project respects its surroundings and honors the heritage and desired character of the area.

City Staff has determined that the proposed Project would be in conformance with the Dublin Village Historic Area Specific Plan and will be recommending approval to the Planning Commission and City Council. No revisions to the Draft EIR are required in response to this comment.

2.3 Comments Received on the Draft EIR
The following pages include copies of all comments received on the Draft EIR. Comment letters are presented in the same order as responses provided in Section 2.2 above. 168
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COMMENT LETTER 1 (DSRSD)

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COMMENT LETTER 2 (ZONE 7 WATER AGENCY)
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COMMENT LETTER 3 (CALTRANS)
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COMMENT LETTER 4 (STEVE MINNIEAR)
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3 Changes to the Draft EIR
Changes to the Draft EIR are shown on the following pages in the order that they appear in the EIR. New text is shown in underline, and removed text is shown in strikethrough. These text changes do not constitute substantial new information and do not result in a new significant new impact or increase the severity of an impact already disclosed in the Draft EIR.

The following text is revised on page 9 of the Draft EIR due to minor changes in the number of trees identified on the Project site and number of trees being proposed for removal.

EŽƚĞ͗ƚŚĂƚƚŚĞĂŶĂůǇƐŝƐǁŝƚŚŝŶƚŚĞ/ŶŝƚŝĂů^ƚƵĚǇĂƐƐƵŵĞĚƚŚĂƚϴϱƚƌĞĞƐǁŽƵůĚďĞƌĞŵŽǀĞĚ͕ ďĂƐĞĚŽŶƚŚĞƉƌŽũĞĐƚĚĞƐĐƌŝƉƚŝŽŶĂƚƚŚĞƚŝŵĞŽĨĂŶĂůǇƐŝƐ͘dŚĞƉƌŽƉŽƐĞĚƌĞĚƵĐƚŝŽŶŝŶƚƌĞĞ ƌĞŵŽǀĂůĚĞƐĐƌŝďĞĚďĞůŽǁĐŽŵƉĂƌĞĚƚŽǁŚĂƚǁĂƐĂŶĂůǇǌĞĚǁŝƚŚŝŶƚŚĞ/ŶŝƚŝĂů^ƚƵĚǇǁŽƵůĚŶŽƚ ĂůƚĞƌƚŚĞĂŶĂůǇƐŝƐŽƌĐŽŶĐůƵƐŝŽŶƐŽĨƚŚĞ/ŶŝƚŝĂů^ƚƵĚǇ͘ Parcel 1 of the Project site contains 89 87 trees, four of which are heritage trees. A total of 65 trees are proposed for removal, including one heritage tree. All trees within this parcel would be removed except for two of the heritage trees; The heritage trees that would remain include one in the northeast corner along the project frontage; one in the southwest portion of the site; and one in the northwest portion of the site. A heritage tree directly in the southern portion of the site would be removed. Parcel 2 of the Project site contains 108 trees within the Dublin Creek riparian corridor. All trees in Parcel 2 would be retained, 19 of which are heritage trees.

The following text is revised on page 10 of the Draft EIR in response to DSRSD Comment 1-2 and Zone 7 Comment 2-1.

Utilities Systems
The Project site is currently served by existing utilities for water, sanitary sewer, electricity, and gas. As discussed in the Initial Study in Section 18: Utilities and Service Systems, Dublin San Ramon Services District provides water and wastewater services to the site, and East Bay Community Energy provides electricity and gas to the site, which is distributed by Pacific Gas and Electric Company. Sanitary sewer, sanitary sewer manholes, a water meter, and electrical lines and cables would be removed and replaced with new lines that would connect to existing offsite service lines. If any water meters require removal, the applicant shall contact DSRSD to coordinate their removal.

Additionally, an existing electrical cabinet, storm drain pipe, electrical transformer, and air conditioner unit are proposed for removal and would be replaced. Some of the existing stormwater lines will be left in place but abandoned. New utility lines would be buried below ground. No wells are known to be present on the Project site, however, the Zone 7 Water Agency has indicated that there is one lost well (3S1W02K001) and one destroyed well (3S1W02K012) in the Project area, but that the exact location of the wells is unknown. If any wells are encountered during construction, they would be destroyed in accordance with Zone 7 well destruction standards. 180
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The following text is revised on page 11 of the Draft EIR in response to DSRSD Comment 1-2.

Demolition – This stage would include the demolition of the existing facility, asphalt pavement (140,724 square feet), concrete curbs, landscape including trees and bushes, irrigation system, drainage system, sewer system, site lights, electrical boxes and other electrical equipment, gas, and water meters, fence, shed and gate. All water meters onsite are owned by DSRSD and shall not be demolished. If the water meters need to be removed, then the applicant shall contact DSRSD to coordinate their removal.

Anticipated construction equipment to be used would include concrete saws, excavators, loaders, tractors, backhoes, and rubber-tired dozers.

The following text is revised on page 12 of the Draft EIR in response to DSRSD Comment 1-1, Zone 7 Comments 2-1 and 2-4, and Caltrans Comment 3-1.

1. Project Approvals
The City of Dublin is the Lead Agency for the proposed Project under CEQA. The City is responsible for considering the Project’s impacts as part of the Project approval. The City would require the applicant to obtain the following approvals and permits: approval of a Planned Development Rezone with a related Stage 1 and Stage 2 Development Plan; Site Development Review Permit; Heritage Tree Removal Permit; and demolition, building, grading, and encroachment permits.

Other agencies whose approval may be required include:
x Bay Area Air Quality Management District (BAAQMD); and x Regional Water Quality Control Board (RWQCB);
x Caltrans;
x Zone 7; and
x Dublin San Ramon Services District (DSRSD)
The following text is added on page 42 just before the History of the Hexcel Property and Hexcel Products, Inc. subsection of the Draft EIR in response to Steve Minniear Comment 4-2.

Lincoln Highway (1913 to 1927)
The Lincoln Highway (later known as US Highway 50) was the major east/west land route from the San Francisco Bay Area to the Central Valley and the rest of the county. The western portion of the Project site is the original Lincoln Highway route from Dublin to what is now Dublin Canyon Road (Lincoln Highway Association 2023).

The following text is revised on page 57 of the Draft EIR in response to Steve Minniear Comment 4-3.

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shall be placed on file with the City of Dublin Planning Division, and the Dublin Historical Society at the Dublin Heritage Park and Museums (Parks and Community Services ) as the operator of the Dublin Heritage Park and Museums.

The following text is revised on page 59 of the Draft EIR and in the Mitigation Monitoring and Reporting Program (MMRP) in response to consultation with the Confederated Villages of Lisjan Nation. ůƐŽ͕ĂŶĞƌƌŽƌƌĞůĂƚĞĚƚŽǁŚĂƚĂŐĞŶĐǇƐŚŽƵůĚƌĞĐĞŝǀĞĂƌĐŚĂĞŽůŽŐŝƐƚƌĞƉŽƌƚŚĂƐďĞĞŶƌĞǀŝƐĞĚ͘ MM CUL-3: Archaeological and Tribal Monitoring
A. A qualified archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards for archaeology shall be retained by the applicant prior to implementing construction or soil remediation activities that involve earthmoving or soil excavation, and the archaeologist shall be available for consultation or evaluation of any cultural resources uncovered by such activities. Prior to the start of excavation, the archaeologist shall produce an Archaeological Testing Plan and an Archaeological Treatment and Monitoring Plan Treatment and Monitoring Plan, in consultation with the City of Dublin, and through them, with any consulting Native American tribes.

L The Archaeological Testing Plan will define the following:
x Methods and scope of archaeological testing to be done prior to the start of construction (e.g., GPR, hand excavated test units, trenching with flat edged bucket).
x Treatment of any discoveries during testing.

LL The Treatment and Monitoring Plan will comply with mitigation measures 4, 5, 6, and 7, set forth in the Dublin Village Historic Area Specific Plan, Appendix B, and will specify the following:
x Archaeological testing to be done prior to the start of construction. x Archaeological and Tribal monitoring requirements, which will be based on the results of archaeological testing and consultation with Native American tribes. x Procedures and considerations for handling, documenting, analyzing, and curation of any historic-era or pre-contact era artifacts encountered during project activities.
x Procedures and considerations for handling, documenting, analyzing, and curation of any human remains from the historic era. (For human remains of Native Americans from any time period, treatment protocols would be established with the designated MLD).
/ĨĂŶĂƌĐŚĂĞŽůŽŐŝĐĂůƌĞƐŽƵƌĐĞŽƌŚƵŵĂŶďƵƌŝĂůƐĂƌĞĚŝƐĐŽǀĞƌĞĚĚƵƌŝŶŐĂƌĐŚĂĞŽůŽŐŝĐĂů ƚĞƐƚŝŶŐ͕ĐŽŶƐŝĚĞƌĂƚŝŽŶǁŝůůďĞŐŝǀĞŶƚŽŽƉƚŝŽŶƐƚŚĂƚĂǀŽŝĚŽƌŵŝŶŝŵŝǌĞŝŵƉĂĐƚ͘ /ĨĂŶĂƌĐŚĂĞŽůŽŐŝĐĂůƌĞƐŽƵƌĐĞ;ŽƌƐƵƐƉĞĐƚĞĚƌĞƐŽƵƌĐĞͿŝƐĚŝƐĐŽǀĞƌĞĚĚƵƌŝŶŐŵŽŶŝƚŽƌŝŶŐŽĨ ƉƌŽũĞĐƚĂĐƚŝǀŝƚŝĞƐ͕ĐŽŶƐƚƌƵĐƚŝŽŶŽƌĞǆĐĂǀĂƚŝŽŶĂĐƚŝǀŝƚŝĞƐǁŝƚŚŝŶĂϱϬͲĨŽŽƚƌĂĚŝƵƐŽĨƚŚĞĨŝŶĚƐŚĂůů ďĞƚĞŵƉŽƌĂƌŝůǇŚĂůƚĞĚŽƌĚŝƌĞĐƚĞĚƚŽŽƚŚĞƌĂƌĞĂƐ͕ƉĞŶĚŝŶŐƚŚĞĂƌĐŚĂĞŽůŽŐŝƐƚΖƐĞǀĂůƵĂƚŝŽŶŽĨŝƚƐ ƐŝŐŶŝĨŝĐĂŶĐĞ͘/ĨƚŚĞƌĞƐŽƵƌĐĞŝƐƐŝŐŶŝĨŝĐĂŶƚ͕ĚĂƚĂĐŽůůĞĐƚŝŽŶ͕ĞǆĐĂǀĂƚŝŽŶ͕ŽƌŽƚŚĞƌƐƚĂŶĚĂƌĚ ͘
͘
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ĂƌĐŚĂĞŽůŽŐŝĐĂů or historical procedures shall be implemented to mitigate impacts, pursuant to the Treatment and Monitoring Plan and the archaeologist’s direction. If any human remains are encountered, the archaeologist shall contact the appropriate County Coroner immediately, and security measures shall be implemented to ensure that burials are not vandalized until the decision of burial deposition has been made pursuant to California law. If human remains are determined to be Native American interments, the Coroner shall contact the Native American Heritage Commission pursuant to Public Resources Code Section 5097.98 and follow the procedures stated herein and other applicable laws. A report by the archaeologist evaluating the find and identifying mitigation actions taken shall be submitted to the WhƚŚĞŝƚǇĂŶĚĨŝůĞĚǁŝƚŚƚŚĞĂůŝĨŽƌŶŝĂ,ŝƐƚŽƌŝĐZĞƐŽƵƌĐĞƐ/ŶĨŽƌŵĂƚŝŽŶ^ǇƐƚĞŵ ;,Z/^Ϳ. Where appropriate to protect the location and sensitivity of the cultural resources, the report may be submitted under Public Utilities Code Section 583 or other appropriate confidentiality provisions.

New References to be added to the sources on page 89 of the Draft EIR.

Lincoln Highway Association. 2023. The Lincoln Highway in California. Available:
https://www.lincolnhighwayassoc.org/info/ca/. Accessed on November 13, 2023.
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4 Mitigation Monitoring and Reporting Program
A Mitigation Monitoring and Reporting Program (MMRP) is a CEQA-required component of an EIR. CEQA Guidelines Section 15097 and Public Resources Code §21081.6 requires a public agency to adopt a monitoring and reporting program to ensure efficacy and enforceability of any mitigation measures applied to a proposed project. The Lead Agency must adopt an MMRP for mitigation measures incorporated into the project or proposed as conditions of approval. As stated in Public Resources Code §21081.6 (a)(1):
“The public agency shall adopt a reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment. The reporting or monitoring program shall be designed to ensure compliance during project implementation.”
Table 4-1 represents the MMRP for the Project. This table lists each of the mitigation measures proposed in the EIR, including mitigation refined or updated in the Final EIR in Chapter 3, Changes to the Draft EIR, and specifies the timing and responsible party for each mitigation measure.
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Table 4-1. Mitigation Monitoring Reporting Program Table Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
Air Quality During construction
MM AQ-1. Implement Basic Construction Emission Control Practices.The construction contractor shall comply with the following BAAQMD Basic Construction Measures, as applicable, for reducing construction emissions of uncontrolled fugitive dust (PM10 and PM2.5):
x All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two timesper day. x All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
x All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once perday. The use of dry power sweeping is prohibited. x All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph).
x All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon aspossible after grading unless seeding or soil binders are used. x Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes(as required by the California airborne toxics control measure Title13, Section 2485 of California Code of Regulations [CCR]). Clearsignage shall be provided for construction workers at all accesspoints. x All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall Responsible for
approval: City ofDublin
Implementation:

Project applicant
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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
be checked by a certified mechanic and determined to be running in proper condition prior to operation. x Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

Biological Resources During construction
MM BIO-1: Nesting Bird Avoidance Measures A. To the extent practicable, construction activities and any tree trimming/removal shall be performed from September 16 through February 15 to avoid the general nesting period for birds. If construction or tree trimming/removal cannot be performed during this period, nesting bird surveys and active nest buffers (as necessary) shall be implemented as follows:
i. Nesting Bird Surveys: If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15 for other raptors), a qualified biologist shall conduct a survey for active nests of such birds within 7 days prior to the beginning of Project construction. Appropriate minimum survey radii surrounding the work area shall be determined by the qualified biologist, but should be at least: i) 50 feet for passerines; ii) 300 feet for raptors. Surveys shall be conducted at the appropriate times of day and during appropriate nesting times, as determined by the qualified biologist. ii. Active Nest Buffers: If the qualified biologist documents active nests within the survey area, an appropriate buffer between the nest and active construction shall be established. The buffer shall Responsible for
approval: City of Dublin
Implementation:

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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
be clearly marked and maintained until the young have fledged and are foraging independently. Prior to construction, the qualified biologist shall conduct baseline monitoring of the nest to characterize “normal” bird behavior and establish a buffer distance which allows the birds to exhibit normal behavior. The qualified biologist shall monitor the nesting birds daily during construction activities and shall increase the buffer if the birds show signs of unusual or distressed behavior (e.g., defensive flights and vocalizations, standing up from a brooding position, and/or flying away from the nest). If buffer establishment is not possible, the qualified biologist shall have the authority to cease all construction work in the area until the young have fledged and the nest is no longer active. Construction shall only be allowed to impact a migratory bird or its nest, including its young, if a permit from U.S. Fish and Wildlife Service is obtained in accordance with the MBTA and all permit conditions are adhered to.

Prior to construction
MM BIO-2: Roosting Bat Surveys and Avoidance A. The Project Applicant shall retain a qualified biologist to conduct a bat habitat assessment in all project areas that require tree removal. The qualified biologist shall identify and document the location of potentially suitable bat roosting habitat prior to construction activities. If no suitable bat habitat is observed, the biologist shall inform the Project Applicant, and no further considerations are required. If bat roosting habitat is observed, the location of such habitat areas shall be provided to the Project Applicant, and the following requirements shall be implemented throughout the construction period:
Responsible for
approval: City of Dublin
Implementation:

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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
i. Removal of trees that provide suitable bat roosting habitat shall be conducted outside of the bat maternity season (April 15 to August 31) and overwintering season (October 16 to January 15) to the extent feasible. ii. Presence/absence surveys shall be conducted 2 to 3 days prior to removal of any trees in suitable bat habitat, at any time of year. If presence/absence surveys are negative, work may proceed with no restrictions. If presence/absence surveys detect bats within trees planned for removal, work should proceed in accordance with the following restrictions: x If a maternity colony of bats is observed during maternity season (April 15 to August 31), tree removal shall not occur until August 31 or when maternity season has ended based on surveys conducted by a qualified biologist. x If bats are observed during overwintering season (October 16 to January 15), tree removal shall not occur until January 15 or until bats are no longer present based on surveys conducted by a qualified biologist. x If bats are present outside of maternity or overwintering seasons, construction shall follow a two-phase tree removal system conducted over 2 consecutive days. On the first day (in the afternoon), limbs and branches will be removed using chainsaws or other hand tools. Limbs with cavities, crevices, or deep bark fissures will be avoided, and only branches or limbs without those features will be removed. On the second day, the entire tree shall be removed.

Cultural Resources Prior to building demolition
MM CUL-1: HABS Recordation In consultation with the City of Dublin Planning Division, the Project applicant shall document the Hexcel Corporation R&D facility prior to Responsible for
approval: City of Dublin
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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
demolition. Documentation shall be performed by a Secretary of Interior-qualified professionals (in history or architectural history) and be consistent with the standards of the National Parks Service (NPS) Historic American Building Survey (HABS) and shall consist of the following elements:

1. Historical Report: A qualified historian or architectural historian shall assemble historical background information relevant to the Hexcel Corporation R&D facility in short format Historic American Building Survey (HABS), based on HABS guidelines for historical reports. Much of this information may be drawn from the previous Historical Resource Evaluation and would detail critical information such as the property’s significance, physical description, history, and a summary of information sources.

2. Photographs: Large-format, black and white photographs of the Hexcel Corporation R&D facility shall be taken and processed for archival permanence in accordance with HABS, Historic American Engineering Record (HAER), and HALS (Historic American Landscapes Survey) Photography Guidelines in effect at the time of recording. The standards require large-format black-and-white photography, with the original negatives having a minimum size of 4”x5”. Digital photography, roll film, film packs, and electronic manipulation of images are not acceptable.

The photographs shall be taken by a professional with HABS photography experience. A minimum of 10 and a maximum of 24 photographs must be taken, detailing the site, building exteriors, and interiors, specifically the R&D portion of the building. Photographs must be identified and labeled using HABS/HALS standards. Following completion of the HABS documentation, including the short form historical report and large-format photographs, and approval by the City of Dublin, the materials shall be placed on file with the City of Implementation:

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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
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Completion
Date Initials
Dublin Planning Division, and the Dublin Historical Society at the Dublin Heritage Park and Museums.

Prior to building demolition
MM CUL-2: Interpretive Displays In concert with HABS documentation (MM CUL-1), the Project applicant shall install permanent interpretive displays or signage for public exhibition detailing the history and significance of the Hexcel Corporation R&D facility at the Project site. The interpretive displays or signage could be based on the photographs produced in the HABS documentation and the historic archival research previously prepared as part of the Project.

The interpretive displays or signage shall be prepared by an architectural historian or historian who meets the Secretary of the Interior’s Professional Qualification Standards, in coordination with an exhibit designer.Interpretive displays or signage at the Project site shall be located outside of the new building, near the publicly accessible sidewalk and/or inside the new building in a prominent space, such as the lobby, where they may be viewed by employees and visitors. Responsible for
approval: City of Dublin
Implementation:

Project applicant with assistance from qualified historian or architectural historian Prior to construction
MM CUL-3: Archaeological and Tribal Monitoring
A. A qualified archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards for archaeology shall be retained by the applicant prior to implementing construction or soil remediation activities that involve earthmoving or soil excavation, and the archaeologist shall be available for consultation or evaluation of any cultural resources uncovered by such activities. Prior to the start of excavation, the archaeologist shall produce an Archaeological Testing Plan and an Archaeological Treatment and Monitoring Plan, in consultation with the City of Dublin, and through them, with any consulting Native American tribes. Responsible for
approval: City of Dublin
Implementation:

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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
i. The Archaeological Testing Plan will define the following:
x Methods and scope of archaeological testing to be done prior to the start of construction (e.g., GPR, hand excavated test units, trenching with flat edged bucket). x Treatment of any discoveries during testing.
ii. The Treatment and Monitoring Plan will comply with mitigation measures 4, 5, 6, and 7, set forth in the Dublin Village Historic Area Specific Plan, Appendix B, and will specify the following:
x Archaeological testing to be done prior to the start of construction.
x Archaeological and Tribal monitoring requirements, which will be based on the results of archaeological testing and consultation with Native American tribes. x Procedures and considerations for handling,
documenting, analyzing, and curation of any historic-era or pre-contact era artifacts encountered during project activities. x Procedures and considerations for handling,
documenting, analyzing, and curation of any human remains from the historic era. For human remains of Native Americans from any time period, treatment protocols would be established with the designated MLD.

B. If an archaeological resource or human burials are discovered during archaeological testing, consideration will be given to options that avoid or minimize impact.

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Timing Project Design Feature / Condition of Approval / Mitigation Measure Responsible for
Approval / Monitoring /
Implementation
Completion
Date Initials
archaeologist's evaluation of its significance. If the resource is significant, data collection, excavation, or other standard archaeological or historical procedures shall be implemented to mitigate impacts, pursuant to the Treatment and Monitoring Plan and the archaeologist’s direction. If any human remains are encountered, the archaeologist shall contact the appropriate County Coroner immediately, and security measures shall be implemented to ensure that burials are not vandalized until the decision of burial deposition has been made pursuant to California law. If human remains are determined to be Native American interments, the Coroner shall contact the Native American Heritage Commission pursuant to Public Resources Code Section 5097.98 and follow the procedures stated herein and other applicable laws. A report by the archaeologist evaluating the find and identifying mitigation actions taken shall be submitted to the ƚŚĞŝƚǇĂŶĚĨŝůĞĚǁŝƚŚƚŚĞĂůŝĨŽƌŶŝĂ,ŝƐƚŽƌŝĐZĞƐŽƵƌĐĞƐ/ŶĨŽƌŵĂƚŝŽŶ^ǇƐƚĞŵ;,Z/^Ϳ. Where appropriate to protect the location and sensitivity of the cultural resources, the report may be submitted under Public Utilities Code Section 583 or other appropriate confidentiality provisions.

Prior and during construction
MM CUL-4: Inadvertent Discovery Protocols
A. Prior to the start of ground disturbing activities, the applicant shall retain a qualified archaeologist that meets the Secretary of theInterior’s Professional Qualification Standards for archaeology toimplement archaeological awareness training for all constructionpersonnel involved with ground disturbing or excavation activities.The training shall include information regarding the possibility ofencountering buried cultural resources, the appearance and typesof resources likely to be seen during construction, notificationprocedures, and proper protocols to be followed should suspectedor confirmed resources be encountered by the crew. This training Responsible for
approval: City ofDublin
Implementation:

Project applicantwith assistance fromqualifiedarchaeologist 193
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shall be provided once to each worker involved in ground-disturbing activities before they begin work, and shall be documented in training records.

B. In the event that precontact or historic-age resources (or suspected resources) are inadvertently discovered during Project implementation, all activity within a 50-foot radius of the find shall be stopped, the City of Dublin’s Project Manager shall be notified, and a qualified archaeologist shall be retained by the City of Dublin to examine the find, pursuant to Mitigation Measure 7 set out in the Dublin Village Historic Area Specific Plan, Appendix B. Project personnel shall not collect or move any historic material. The archaeologist shall evaluate the find(s) within 48 hours to determine if it meets the definition of a historical or unique archaeological resource and follow the procedures outlined below: i. If the find(s) does not meet the definition of a tribal cultural resource, a historical resource or a unique archaeological resource, no further study or protection is necessary prior to resuming Project implementation. ii. If the find(s) does meet the definition of a historical resource or unique archaeological resource, then it shall be avoided by Project activities and preserved in place. If avoidance is not feasible, as determined by the City of Dublin, the qualified archaeologist shall make appropriate recommendations regarding the treatment and disposition of such find(s), and significant impacts to such resources shall be mitigated in accordance with the recommendations of the archaeologist prior to resuming construction activities within the 50-foot radius. iii. If the find(s) does meet the definition of both a tribal cultural resource and a historical or unique archaeological resource, then it shall be treated in accordance with MM CUL-3. 194
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C. Recommendations for treatment and disposition of find(s) could include, but are not limited to, archaeological monitoring, collection, recordation, and analysis of any significant cultural materials. A report of findings documenting any data recovery shall be submitted to NWIC. i. In the event that archaeological resource(s) are discovered during Project implementation, an archaeological monitor shall be retained to monitor all ground- disturbing activities in the vicinity (i.e., within 50 feet) of the find. Archaeological monitors have the authority, upon the finding of a potential resource, to request that work be slowed, diverted, or stopped if archaeological resources are identified within the direct impact area. If the resource is determined by an archaeologist to be a historical or unique archaeological resource, the archaeologist shall amend the Treatment and Monitoring Plan, with measures to avoid or reduce impacts to the resource. The treatment plan measures may include, but not be limited to, avoidance and preservation in place (the preferred method if feasible), capping, incorporation of the site within a park or other open space, or data recovery. If the resource is also a tribal cultural resource, then designated representatives from the consulting tribe(s) shall make appropriate recommendations regarding the treatment and disposition of such find(s) in accordance with MM CUL-3 and these recommendations shall be incorporated into the treatment plan.

Geology and Soils During construction
MM GEO-1: Avoid Impacts to Unique Paleontological Resources To minimize the potential for destruction of or damage to previously unknown unique, scientifically important paleontological resources Responsible for
approval: City of Dublin
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during earthmoving activities at the Project site, the Project applicant shall do the following:Prior to the start of earthmoving activities, retain either a qualified archaeologist or paleontologist to inform all construction personnel involved with earthmoving activities regarding the possibility of encountering fossils, the appearance and types of fossils likely to be seen during construction, and proper notification procedures should fossils be encountered.If paleontological resources are discovered during earthmoving activities, the construction crew shall immediately cease work within 50 feet of the find and notify the Project applicant and the City. The Project applicant shall retain a qualified paleontologist to evaluate the resource and prepare a recovery plan, based on SVP Guidelines. The recovery plan may include, but is not limited to, a field survey, construction monitoring, sampling and data recovery procedures, museum curation for any specimen recovered, and a report of findings. Recommendations in the recovery plan that are determined by the City (as the CEQA lead agency) to be necessary and feasible shall be implemented before construction activities can resume within 50 feet of the site where the paleontological resource or resources were discovered. Implementation:

Project applicant with assistance from qualified archaeologist or paleontologist Hazards and Hazardous Materials Prior to construction
MM HAZMAT-1: Perform a Phase II Environmental Site Assessment • Prior to the start of earthmoving activities at the Project site, the Project applicant shall retain the services of a qualified remediation firm to perform a Phase II Environmental Site Assessment (ESA). The Phase II ESA shall be limited to only those areas where chemical use, storage, and handling have previously occurred. Soil borings shall be obtained as part of the Phase II ESA, along with groundwater samples if necessary. The samples shall be submitted to a laboratory Responsible for
approval: City of Dublin
Implementation:

Project applicant with assistance from qualified remediation firm 196
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for environmental testing and the results shall be reported in the Phase II ESA, copies of which shall be provided to the Alameda County Department of Environmental Health (ACDEH) and the City of Dublin Building Department. If there are no detections of constituents of concern, or the amounts are below regulatory agency threshold levels, no further actions shall be required. • If the results of laboratory analyses from the Phase II ESA demonstrate that constituents of concern are present at levels that exceed regulatory agency threshold levels, the Project applicant shall consult with ACDEH (and other regulatory agencies such as the SWRCB if necessary) regarding the necessary actions for remediation. All necessary remedial activities shall be completed by the Project applicant, with a certification by the lead agency with remedial oversight (e.g., ACDEH or SWRCB) that no further action is required, prior to the start of construction activities at the Project site.

Transportation and Traffic Project design Condition of Approval:
• Requires vegetation maintenance for sight distance to achieve a minimum sight distance of 250 feet at each driveway access point • Prohibits trucks from accessing the eastern driveway
Responsible: City of
Dublin
Implementation:

Project applicant
Tribal Cultural Resources Prior to and during construction MM TR-1: Inadvertent/Unanticipated Tribal Cultural Resources Discovery Protocols The City of Dublin shall require the following steps to be taken, including as a part of all contracts related to construction of the Project, as applicable: A. Prior to the start of ground disturbing activities, the applicant shall retain representatives from consulting tribe(s), if available, to Responsible for
approval: City of Dublin
Implementation:

Project applicant with assistance from
197
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implement Tribal Cultural Resources Sensitivity Training for all construction personnel involved with ground disturbing or excavation activities. The training shall include information regarding the possibility of encountering buried tribal cultural resources, the appearance and types of tribal cultural resources that could potentially be seen during construction, notification procedures, and proper protocols to be followed should suspected or confirmed tribal cultural resources be encountered. This training shall be provided once to each worker involved in ground-disturbing activities before they begin work and shall be documented in training records.

If avoidance is not feasible, as determined by the City of Dublin, Tribal Representatives from the consulting tribe(s) if available, shall make recommendations regarding the culturally representatives from consulting tribe(s)
198
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appropriate treatment and disposition of such find(s) and significant impacts to such tribal cultural resources shall be mitigated in accordance with the recommendations of the consulting tribe(s), if they are available, prior to resuming construction activities within the 50-foot radius. iii. If the find meets the definition of both a tribal cultural resource and a historical or unique archaeological resource, then it shallbe treated in accordance with the measures described in SectionC. below and MM CUL-4.

C. Culturally appropriate treatment may include, but is not limited to, minimal processing of materials for reburial, minimizing handling of tribal cultural resources objects, leaving objects in place within thelandscape, or returning tribal cultural resources objects to a locationwithin the Project area where they would not be subject to futuredisturbance. No cultural soil maybe removed from the Project site.Permanent curation, testing, or data collection of tribal culturalresources will not take place unless requested in writing by theconsulting tribe(s).

D. All fill soils imported and used for this Project must be clean, engineered fill.

E. The applicant shall enter into a tribal monitoring agreement with the consulting tribe(s) prior to the start of ground disturbing activities.The tribal monitoring agreement shall form the terms andcompensation for the tribal monitoring with the consulting tribe(s)and be utilized in combination with the tribal cultural resourcetreatment. Tribal Monitors have the authority to identify sites orobjects of cultural significance and to request, upon the finding of apotential tribal cultural resource, that work be slowed, diverted, orstopped if such sites or objects are identified within the direct impactarea. Only the consulting tribe(s) can recommend culturally 199
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appropriate treatment of such sites or objects, via their Tribal Monitor. Work within 50 feet of the discovery location cannot resume until all necessary investigation and evaluation of the discovery under the requirements of the tribal monitoring agreement have been implemented.

Energy Conservation During construction
See Air quality mitigation measure MM AQ-1. Implement Basic Construction Emission Control Practices. Responsible for
approval: City of Dublin
Implementation:

Project applicant
200
dŚŝƐƉĂŐĞŝŶƚĞŶƚŝŽŶĂůůǇůĞĨƚďůĂŶŬ
201
Appendix AŽĨ&ŝŶĂů
/Z͗Draft EIR
202
dŚŝƐƉĂŐĞŝŶƚĞŶƚŝŽŶĂůůǇůĞĨƚďůĂŶŬ
203
Hexcel Redevelopment Project
Focused EIR
August 21, 2023
PROJECT APPLICATION 000688
204
dŚŝƐƉĂŐĞŝŶƚĞŶƚŝŽŶĂůůǇůĞĨƚďůĂŶŬ
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Table of Contents | Page i
Table of Contents
Project Summary .......................................................................................................... 1 Project Description ....................................................................................................................... 1 Alternatives .................................................................................................................................. 1 Issues of Concern ......................................................................................................................... 1 Environmental Review Process .................................................................................................... 3 Notice of Preparation of an Environmental Impact Report and Scoping Period ..................... 4 Draft EIR and Public Review Period ......................................................................................... 5 Final EIR and Responses to Comment ..................................................................................... 5 Mitigation Monitoring and Reporting Program ....................................................................... 5 Scope of EIR .................................................................................................................................. 6 Topics Addressed in this EIR .................................................................................................... 6 Topics Not Addressed in Detail in this EIR Based on Preparation of the Initial Study ................. 6 Project Description ....................................................................................................... 7 Project Site and Vicinity ............................................................................................................... 7 Project Objectives ........................................................................................................................ 7 Surrounding Land Uses ................................................................................................................ 7 Project Characteristics ................................................................................................................. 8 Proposed Building .................................................................................................................... 8 Project Approvals ....................................................................................................................... 12 Environmental Analysis .............................................................................................. 13 Introduction ............................................................................................................................... 13 Environmental Topics ............................................................................................................ 13 Impact Levels ......................................................................................................................... 13 Environmental Baseline ......................................................................................................... 14 Source(s) ................................................................................................................................ 14 Section 1: Air Quality .................................................................................................................. 15 Environmental Setting ........................................................................................................... 15 Air Pollutants of Concern ....................................................................................................... 16 Regulatory Framework .......................................................................................................... 16 Project Impacts and Mitigation Measures ............................................................................. 18 Source(s) ................................................................................................................................ 23 Section 2: Biological Resources .................................................................................................. 25 Environmental Setting ........................................................................................................... 25 Regulatory Framework .......................................................................................................... 26 Project Impacts and Mitigation Measures ............................................................................. 28 Source(s) ................................................................................................................................ 35 206
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Section 3: Cultural Resources .................................................................................................... 37 Environmental Setting ........................................................................................................... 37 Regulatory Framework .......................................................................................................... 48 Project Impacts and Mitigation Measures ............................................................................. 56 Source(s) ................................................................................................................................ 63 Section 4: Energy ........................................................................................................................ 67 Environmental Setting ........................................................................................................... 67 Regulatory Framework .......................................................................................................... 68 Project Impacts and Mitigation Measures ............................................................................. 70 Source(s) ................................................................................................................................ 72 Section 5: Geology and Soils ...................................................................................................... 75 Environmental Setting ........................................................................................................... 76 Regulatory Framework .......................................................................................................... 77 Project Impacts and Mitigation Measures ............................................................................. 79 Source(s) ................................................................................................................................ 81 Section 6: Hazards and Hazardous Materials............................................................................. 83 Environmental Setting ........................................................................................................... 83 Regulatory Framework .......................................................................................................... 85 Project Impacts and Mitigation Measures ............................................................................. 87 Source(s) ................................................................................................................................ 89 Section 7: Tribal Cultural Resources .......................................................................................... 91 Environmental Setting ........................................................................................................... 91 Regulatory Framework .......................................................................................................... 92 Context for Project Impacts and Mitigation Measures ......................................................... 95 Project Impacts and Mitigation ............................................................................................. 97 Significance after Mitigation .................................................................................................. 99 Source(s) .............................................................................................................................. 100 Other CEQA Considerations ...................................................................................... 101 Cumulative Context .................................................................................................................. 101 Cumulative Impact Analysis ................................................................................................. 102 Growth Context ........................................................................................................................ 108 Growth Inducing Analysis .................................................................................................... 109 Significant Irreversible Changes Context ................................................................................. 109 Significant Irreversible Changes ........................................................................................... 110 Significant and Unavoidable Environmental Context .............................................................. 111 Significant and Unavoidable Environmental Analysis .......................................................... 111 Source(s) .................................................................................................................................. 111 Alternatives .............................................................................................................. 113 Introduction ............................................................................................................................. 113 207
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Factors Considered in the Selection of Alternatives ................................................................ 113 Description and Analysis of Alternatives Retained .................................................................. 114 No Project Alternative ......................................................................................................... 114 Reduced Grading Alternative ............................................................................................... 115 Alternatives Considered but Rejected ..................................................................................... 117 Partial Preservation Alternative ........................................................................................... 117 Environmentally Superior Alternative ..................................................................................... 119 Report Preparers ...................................................................................................... 121 Lead Agency ............................................................................................................................. 121 Consultant – AECOM ................................................................................................................ 121 Appendices ............................................................................................................... 133 Appendices
A Initial Study
B Notice of Preparation and Scoping Comments
C Historical Resources Evaluation
D CalEEMod Output Sheets
E Final Transportation Impact Study
List of Figures
Note: All figures are included at the end of the document.

Figure 1. Project Location
Figure 2. Project Site
Figure 3. Site Plan
Figure 4. Elevations
Figure 5. Overall Floor Plan
Figure 6A. Landscape Plan
Figure 6B. Landscape Plan Detail
Figure 7. Fire Access Route
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Table of Contents | Page iv
List of Tables
Table 1: Summary of Impacts and Mitigation ................................................................... 2 Table 2: Building Composition by Level ............................................................................. 9 Table 3: Anticipated Construction Schedule ................................................................... 11 Table 4: Total and Average Daily Construction Emissions ............................................... 21 Table 5: Annual and Average Daily Operational Emissions ............................................. 22 Table 6: Special-Status Species Potential to Occur in the Project Area ........................... 30 Table 7: Construction and Operational Energy Consumption ......................................... 71 Table 8: Cumulative Projects in the City of Dublin ........................................................ 105 Table 9: Comparison of Proposed Project and Alternatives .......................................... 120

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Acronyms
1,1,1-TCA 1,1,1-trichloroethane
AB Assembly Bill
ACDEH Alameda County Department of Environmental Health ACMs asbestos-containing materials
A.D. Anno Domini
ADA American With Disabilities
Alquist-Priolo Act Alquist-Priolo Earthquake Fault Zoning Act APE Area of Potential Effects
APN Assessor Parcel Numbers
Ardent Ardent Environmental Group
B.C. before present
BAAQMD Bay Area Air Quality Management District
bgs below the ground surface
BL1 Green Buildings
BL2 Decarbonize Buildings
BMPs Best Management Practices
Business Plans Hazardous Materials Release Response Plans and Inventories CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
cal B.C. calibrated years before the present
Cal/OSHA California Occupational Safety and Health Administration CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards Code
Caltrans California Department of Transportation
CAP Climate Action Plan
CAP 2030 Climate Action Plan 2030
CARB California Air Resources Board
CBC California Building Standards Code
CCR California Code of Regulations
CCTS Central California Taxonomic System
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CFR Code of Federal Regulations
CGS California Geological Survey
CHP California Highway Patrol
City City of Dublin
CNDDB California Natural Diversity Data Base
CO carbon monoxide
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CO2 carbon dioxide
Cornerstone Cornerstone Earth Group
county County of Alameda
CRHR California Register of Historical Resources
CUPA Certified Unified Program Agency
CY cubic yard
DOC California Department of Conservation
DPR Department of Parks and Recreation
DTSC California Department of Toxic Substances Control
EBCE East Bay Community Energy
EDR Environmental Database Report
EIR Environmental Impact Report
EPA United States Environmental Protection Agency
ESA Environmental Site Assessment
ESA Federal Endangered Species Act of 1973
EV electric vehicle
GGEs gasoline gallon equivalents of petroleum
GHG greenhouse gas
HABS Historic American Building Survey
HAER Historic American Engineering Record
HALS Historic American Landscapes Survey
Hexcel Hexcel Products, Inc.

Hi Bay laboratories were used for small-scale testing, while the building located south of the offices/laboratories
HRI Historic Resources Inventory
I- Interstate
IPaC Information for Planning and Consulting
IS Initial Study
LED light emitting diode
light industrial zoned M-1
MBTA Migratory Bird Treaty Act
MLD most likely descendant
MLT Middle-to-Late Transition
MMRP Mitigation Monitoring and Reporting Plan
MND Mitigated Negative Declaration
mph miles per hour
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NASA National Aeronautics and Space Administration
NHL National Historic Landmark
NHPA National Historic Preservation Act
NHSTA National Highway Traffic Safety Administration
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NO2 nitrogen dioxide
NOP Notice of Preparation
NOX nitrogen oxides
NPS National Parks Service
NRCS Natural Resource Conservation Service
NRHP National Register of Historic Places
NWIC Northwest Information Center
OES Office of Emergency Services
PD Planned Development
PG&E Pacific Gas & Electric Company
PM particulate matter
PM10 PM equal to or less than 10 micrometers in diameter PM2.5 PM equal to or less than 2.5 micrometers in diameter Porter-Cologne Act Porter-Cologne Water Quality Control Act PRC Public Resources Code
proposed project The proposed actions that would involve replacing existing building with a new building and other site improvements R&D research and development
ROGs reactive organic gases
Royal Research Royal Research Corporation
RWQCB Regional Water Quality Control Board
SFBAAB San Francisco Bay Area Air Basin
SIP State Implementation Plan
SO2 sulfur dioxide
SVP Society of Vertebrate Paleontology
SWPPP Stormwater Pollution Prevention Plan
SWRCB California State Water Resources Control Board
TACs toxic air contaminants
TCE trichloroethene
UBC Uniform Building Code
UCMP University of California Museum of Paleontology
USFWS U.S. Fish and Wildlife Service
UST Underground Storage Tank
VOCs volatile organic compounds
WSA William Self Associates, Inc.

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Focused EIR | Page 1
Hexcel Redevelopment Project
Environmental Impact Report
Project Summary
Project Description
Dublin Boulevard Owner, LP is proposing to construct a new 125,304 square foot building on the 8.81- acre project site located at 11711 Dublin Boulevard in the City of Dublin, Alameda County, California.

The project site is composed of two parcels (Assessor Parcel Numbers [APN] 941-1560-009-01 [Parcel 1] and 941-1560-003-04 [Parcel 2]) with an existing 62,715 square foot building on Parcel 1. The existing Hexcel research and development (R&D) building would be demolished and replaced with the proposed building. The proposed building would cater to future tenants in the R&D and life sciences field. Other site improvements would include landscaping; parking; a fire access road; circulation improvements for truck access and loading and unloading materials; utilities; pavement and grading to treat site drainage.

Alternatives
x No Project Alternative (existing conditions, no change) x Alternative 1: Reduced Grading Alternative
The alternatives discussion of this Environmental Impact Report (EIR) was prepared in accordance with Section 15126(d) of the California Environmental Quality Act (CEQA) Guidelines and focuses on alternatives that are capable of eliminating or reducing significant adverse effects associated with the proposed project while feasibly attaining most of the basic objectives.

This EIR identifies the No Project Alternative as the “environmentally superior” alternative, because it would eliminate the significant and unavoidable impacts to the Project site’s historic resource, and would also eliminate less than significant (or less than significant with mitigation) impacts on other resource topics. While the No Project Alternative would eliminate the significant adverse effect of the proposed Project, it would not achieve the Project objectives.

When the No Project Alternative is the environmentally superior alternative, CEQA requires that an additional alternative be identified. In this case, Alternative 1 (Reduced Grading) would be the environmentally superior alternative, because it would accomplish most of the Project’s objectives while reducing potential impacts to buried archeological and paleontological resources as described in the Alternatives section.

Issues of Concern
The main issue of concern regarding the proposed Project is the demolition of the site’s historic resource, which is the existing building. This issue is fully addressed in the Environmental Analysis of this EIR. Table 1: Summary of Impacts and Mitigation below summarizes potentially significant environmental impacts of the proposed project. The table includes a list of impacts and mitigation measures identified in this EIR. The table lists impacts and mitigation measures in two major 214
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Focused EIR | Page 2
categories: significant impacts that would remain significant even with mitigation (significant and unavoidable), and potentially significant impacts that could be mitigated to a less than significant level.

Mitigation measures descriptions provided in Table 1 are abbreviated; for the complete description of these mitigation measures, please refer to their associated sections in this EIR. Refer to the Initial Study in Appendix A for further discussion of impacts that would have no impact or be less than significant without mitigation.

Table 1: Summary of Impacts and Mitigation
Impact Mitigation Level of
Significance
After Mitigation
Impact AQ-1: The proposed
Project could be inconsistent with
BAAQMD’s Basic Construction
Mitigation during demolition and
construction.

Mitigation Measure AQ-1. Implement Basic Construction
Emission Control Practices: The construction contractor shall comply with the following BAAQMD Basic Construction Measures, as applicable, for reducing construction emissions of uncontrolled fugitive dust (PM10 and PM2.5). See Section 1 for complete description.

Less Than
Significant with
Mitigation
Impact AQ -2: The proposed
Project could result in a
cumulatively considerable net
increase of any criteria pollutant
for which the region is nonattainment under an applicable federal or state ambient air quality
standard during construction and
operation.

See Mitigation Measure AQ-1 in Impact AQ-1 above. See Section 1 for complete description.

Less Than
Significant with
Mitigation
Impact BIO-1: The proposed
Project could result in nest
destruction and failure to nesting
birds during construction activities.

Mitigation Measure BIO-1. Nesting Bird Avoidance Measures: To the extent practicable, construction activities and any tree trimming/removal shall be performed from September 16 through February 15 to avoid the general nesting period for birds. If construction or tree trimming/removal cannot be performed during this period, nesting bird surveys and active nest buffers. If the qualified biologist documents active nests within the survey area, an appropriate buffer between the nest and active construction shall be established. The buffer shall be clearly marked and maintained until the young have fledged and are foraging independently. See Section 2 for complete description.

Less Than
Significant with
Mitigation
Impact BIO-2: The proposed
Project could result in mortality to
bats during construction activities.

Mitigation Measure BIO-2. Roosting Bat Surveys and Avoidance:

The Project Applicant shall retain a qualified biologist to conduct a bat habitat assessment in all project areas that require tree removal. The qualified biologist shall identify and document the location of potentially suitable bat roosting habitat prior to construction activities. If no suitable bat habitat is observed, the biologist shall inform the Project Applicant, and no further considerations are required. If bat roosting habitat is observed, the location of such habitat areas shall be provided to the Project Applicant. See Section 3 for the complete description.

Less Than
Significant with
Mitigation
Impact CR-1: The proposed
Project would result in the
demolition of the existing Hexcel
Corporation R&D facility, which is
a historical resource for the
purposes of CEQA.

Mitigation Measure CUL-1: HABS Recordation:

The Project applicant shall document the Hexcel Corporation R&D facility prior to demolition. See Section 3 for the complete description.

Mitigation Measure CUL-2: Interpretive Displays:

The Project applicant shall install permanent interpretive displays for public exhibition detailing the history and significance of the Hexcel Corporation R&D facility at the Project site. See Section 3 for the complete description.

Significant and
Unavoidable
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Impact Mitigation Level of
Significance
After Mitigation
Impact CR-2: The proposed
Project could cause substantial
adverse change in the significance
of an archaeological resources
during excavation activities.

Mitigation Measure CUL-3: Archaeological and Tribal Monitoring:

A qualified archaeologist shall be retained by the applicant prior to implementing construction. See Section 3 for the complete description.

Mitigation Measure CUL-4: Inadvertent Discovery Protocols: a number of protocols would be followed in the case of the discovery of archeological and tribal resources. See Section 3 for the complete description.

Less Than
Significant with
Mitigation
Impact EN-1: The proposed
Project could consume energy in a
wasteful or inefficient way.

See Mitigation Measure AQ-1 in Impact AQ-1 above. Less Than Significant with
Mitigation
Impact GEO-1: The proposed
Project could accidentally cause
damage to, or destruction of
unique paleontological resources
during earthmoving activities.

Mitigation Measure GEO-1. Avoid Impacts to Unique
Paleontological Resources: To minimize the potential for destruction of or damage to previously unknown unique, scientifically important paleontological resources during earthmoving activities at the Project site, the Project applicant shall do the following:

Prior to the start of earthmoving activities, retain either a qualified archaeologist or paleontologist to inform all construction personnel.

If paleontological resources are discovered during earthmoving activities, the construction crew shall immediately cease work within 50 feet of the find and notify the Project applicant and the City. See Section 5 for the complete description.

Less Than
Significant with
Mitigation
Impact HAZMat-1: The proposed
Project could expose people to
contaminated soil or groundwater
that exceed regulatory thresholds.

Mitigation Measure HAZMAT-1. Perform a Phase II Environmental Site Assessment: Prior to the start of earthmoving activities at the Project site, the Project applicant shall retain the services of a qualified remediation firm to perform a Phase II Environmental Site Assessment (ESA).

If the results of laboratory analyses from the Phase II ESA demonstrate that constituents of concern are present at levels that exceed regulatory agency threshold levels, the Project applicant shall consult with ACDEH (and other regulatory agencies such as the SWRCB if necessary) regarding the necessary actions for remediation.

See Section 6 for complete description.

Less Than
Significant with
Mitigation
Impact TR-1: The Project could
disturb Native American human
remains during excavation
activities.

Mitigation Measure TR-1: Inadvertent/Unanticipated Tribal Cultural Resources Discovery Protocols: a number of protocols would be followed in the case of the discovery of tribal resources.

See Mitigation Measures CUL-3 and CUL-4 in Impact CR-2 above.

Less Than
Significant with
Mitigation
Notes:

ACDEH = Alameda County Department of Environmental Health, BAAQMD = Bay Area Air Quality Management District, City = City of Dublin, ESA = Environmental Site Assessment, PM10 = PM equal to or less than 10 micrometers in diameter, PM2.5 = PM equal to or less than 2.5 micrometers in diameter, Project = The proposed actions that would involve replacing existing building with a new building and other site improvements, Project Applicant = Dublin Boulevard Owner, LP, Project site = 11711 Dublin Boulevard in the City of Dublin, Alameda County, California, SWRCB = California State Water Resources Control Board
Environmental Review Process
The City of Dublin (the City) is the lead agency responsible for administrating the environmental review under CEQA. After preparing an Initial Study, the City has determined that an EIR must be prepared to evaluate potentially significant effects that could result from implementation of the proposed Project.

A Notice of Preparation was prepared and a scoping period held from May 15, 2023 to Jun 15, 2023.

The full CEQA Guidelines Appendix G checklist is provided in the Initial Study (see Appendix A). 216
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CEQA requires that, before a project with potentially significant environmental effects may be approved, an EIR must be prepared that fully describes the environmental effects of the project, identifies mitigation measures to lessen or eliminate adverse impacts, and examines feasible alternatives to the project. The information contained in the EIR is to be reviewed and considered by the lead agency prior to the ultimate decision to approve, disapprove, or modify the proposed project.

Consistent with CEQA guidelines sections 15080 through 15097, the CEQA process has multiple phases, many of which require notification to the public and opportunity for public comments. The environmental review process for a focused EIR includes the following steps: publication of a notice of preparation (NOP) of an EIR and public scoping; publication of a Draft EIR for public review and comment; preparation and publication of responses to public and agency comments on the draft EIR; and certification of the final EIR. The EIR process provides an opportunity for the public to review and comment on the proposed Project’s potential environmental effects and to further inform the environmental analysis. These steps are described in more detail in the following sections.

Notice of Preparation of an Environmental Impact Report and Scoping Period An initial study is an analysis conducted by a lead agency to determine whether a project may have a significant effect on the environment and aids in determining what type of environmental document the lead agency is required to prepare. An initial study was prepared for the proposed Project (see Appendix A). It analyzed the environmental topics included in CEQA Guidelines Appendix G checklist to determine which topics would be less than significant. This EIR further evaluates environmental topics which would have significant impacts that could be mitigated to less-than-significant levels and other topics that would have significant and unavoidable impacts.

Consistent with the requirements of CEQA guidelines sections 15063 and 15082, the City has made a good-faith effort during the preparation of the Draft EIR to contact all responsible and trustee agencies; organizations and persons who may have an interest in the proposed Project; and all applicable government agencies, including the Governor’s Office of Planning and Research, State Clearinghouse. This outreach effort included the circulation of a NOP on May 15, 2023, which began a 30-day comment period that ended on June 15, 2023. The NOP requested that agencies and interested parties comment on environmental issues that should be addressed in the Draft EIR. A copy of the NOP is provided in Appendix B.

The City sent out NOP and scoping period notices as follows:

1. Sent NOP via certified mail to the County clerk and public agencies on May 15, 2023.

2. Sent email blast to contacts on the City’s universal mailing list on May 15, 2023.

3. Copy of NOP and noticing posted at Dublin Library and at the City Hall

4. Publication of NOP in the East Bay Times on May 17, 2023

5. Posting the NOP and noticing to the City website at https://dublin-development.icitywork.com/ The City held a virtual public scoping meeting on May 25, 2023, at 7:00 pm, with options for joining by phone or computer. The purpose of the scoping meeting was to inform the public about the proposed Project, explain the environmental review process, and provide an opportunity for the public to make 217
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comments and express concerns related to the Project’s environmental issues. No one called into the meeting and the meeting ended at 7:15 pm. Two comment letters were received during the public scoping period: one from the Native American Heritage Commission and one from the City of Pleasanton. Copies of these letters are contained in Appendix B.

Draft EIR and Public Review Period
This Draft EIR is available for a 45-day public review period as indicated on the Public Notice of Availability of this document, which ends on October 5, 2023. The purpose of public review of the EIR is to receive comments on the adequacy of the document in addressing adverse physical effects of the Project. This Draft EIR is being circulated to relevant local, regional and/or state agencies, and to interested organizations and individuals who may wish to review and comment on the report.

During the public review period, written comments on the adequacy of the Draft EIR may be submitted to the City of Dublin at the following address:

Gaspare Annibale, Associate Planner & Anne Hersch, Assistant Community Development Director City of Dublin
Community Development Department
100 Civic Plaza
Dublin, CA 94568
Written comments may also be submitted via email to [email protected] and [email protected] with “Hexcel Redevelopment Project Draft EIR” noted in the subject line.

Final EIR and Responses to Comment
Responses to all substantive comments received on the adequacy of the Draft EIR and submitted within the specified review period will be prepared and included in the Responses to Comments/Final EIR, including any revisions to the EIR required in response to the comments. If the City decides to approve the Project, the City must first certify the Final EIR and adopt a Mitigation Monitoring and Reporting Program for mitigation measures identified in the EIR, in accordance with the requirements of California Public Resources Code (PRC) Section 21001.

Mitigation Monitoring and Reporting Program
At the time of Project approval, CEQA and the CEQA guidelines require agencies to adopt a mitigation monitoring and reporting program and to make that program a condition of project approval, to mitigate or avoid significant impacts on the environment (CEQA section 21081.6; CEQA guidelines section 15097). Mitigation measures that have been recommended in this EIR to reduce the environmental impacts of the proposed Project in relation to the above topics will be included in the Mitigation Monitoring and Reporting Plan (MMRP) that the City of Dublin will prepare and adopt (pursuant to the CEQA Guidelines Section 15097) if the City determines that the proposed Project or one of the proposed alternatives should be approved.
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Scope of EIR
Topics Addressed in this EIR
Pursuant to section 15143 of the state CEQA guidelines, a lead agency may focus an EIR’s discussion on specific issue areas where significant impacts on the environment may occur: “[e]ffects dismissed in an Initial Study as clearly insignificant and unlikely to occur need not be discussed further in the EIR unless the Lead Agency subsequently receives information inconsistent with the finding in the Initial Study. A copy of the Initial Study may be attached to the EIR to provide the basis for limiting the impacts discussed.” The initial study for the proposed Project is included in Appendix A of this Draft EIR.

Pursuant to CEQA guidelines section 15063(c)(3), and based on its review of existing information and the initial study completed for the proposed Project, the City determined that the proposed Project would have significant or potentially significant impacts in the following resource areas that require further analysis and are therefore discussed in this Draft EIR:
x Air Quality
x Biological Resources
x Cultural Resources
x Energy
x Geology and Soils
x Hazards and Hazardous Materials
x Tribal Cultural Resources
Topics Not Addressed in Detail in this EIR Based on Preparation of the Initial Study The information and analysis presented in the Initial Study provides substantial evidence for the conclusion, for all the issues listed below (i.e., those not addressed in detail in this EIR), that: 1) CEQA standards triggering preparation of further environmental review do not exist for those issues; and 2) impacts under these topics would have no impact or be less than significant. Topics not addressed in this EIR in detail are listed below by impact determination category identified in Appendix G, the Environmental Checklist Form. These topics are, however, analyzed for full disclosure of the environmental determination, in the Initial Study, included within Appendix A of this EIR. In addition to the list below, impacts from the CEQA checklist that have a less than significant impact related to air quality, biological resources, energy, geology and soils, and hazards and hazardous materials are also included in the Initial Study.
x Aesthetics
x Agricultural and Forestry Resources
x Greenhouse Gas Emissions
x Hydrology and Water Quality
x Land Use and Planning
x Mineral Resources
x Noise
x Population and Housing
x Public Services
x Transportation
x Utilities and Service Systems
x Wildfire
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Project Description
Project Site and Vicinity
The Project site is located at 11711 Dublin Boulevard in the City of Dublin, Alameda County, California.

See Figure 1. Project Location. The site includes two parcels totaling 8.81 acres; APN 941-1560-009-01 [Parcel 1] is the larger parcel at 8.30 acres and is located adjacent to Dublin Boulevard, and [APN] 941- 1560-003-04 [Parcel 2] is the smaller parcel at 0.51 acre and is located toward the back (south) of the Project site adjacent to I-580. The site slopes from a maximum elevation of approximately 395 feet above mean sea level near the southwest corner to about 382 feet at the northern corner. Parcel 1 is zoned M-1 (light industrial) and Planned Development (PD) (Ordinance No. 80-60) and Parcel 2 is zoned M-1 (light industrial).

The site is also located in the Dublin Village Historic Area Specific Plan boundary. The Specific Plan intends to protect and preserve historical resources and further enhance this area with development that is compatible with the extant historic buildings and remnants in the area. The original historic buildings in this area include St. Raymond’s church, the Murray Schoolhouse, Pioneer Cemetery, Green’s Store, and two bungalow homes. These resources function together as the Dublin Heritage Center, a local history museum and cultural center. The Specific Plan boundary extends from Cronin Circle to Interstate (I-)580 and San Ramon Road to Hansen Drive, including portions west of Hansen Drive along Dublin Boulevard. The Dublin Village Historic Area encompasses approximately 40 acres (City of Dublin 2014).

Parcel 1 (the northern and main portion of the site) is developed with a 62,715 square foot building, atgrade parking, underground and aboveground utilities, pavement, and ornamental landscaping. The existing building is being used as a R&D facility. The landscape consists of grass areas and mature trees.

Parcel 2 (the southern parcel) is undeveloped and is surrounded by dense riparian vegetation including mature trees. The Dublin Creek runs along the approximate southern boundary and is approximately 13 to 18 feet below the adjacent site elevations.

Project Objectives
The proposed Project has the following objectives:

1. To redevelop the Hexcel site with a new and upgraded facility that appeals to the life sciences and manufacturing field.

2. To rezone Parcels 1 and 2 as a Planned Development, which provide development standards beyond those of the M-1 zoning, and adopt a new ordinance.

Project Characteristics
The proposed Project would result in the existing 62,715 square foot industrial building being demolished and a new 125,304 square foot building being developed on the 8.81-acre Project site. The new building would cater to future tenants in the R&D and life sciences field. Other site improvements would include landscaping; parking; a fire access road; circulation improvements for truck access and loading and unloading materials; utilities; pavement and grading to treat site drainage. Figure 3. Site Plan shows the proposed site layout. The following sections describe the proposed Project and project components.

The outside of the building would be made of concrete tilt-up panels painted in various colors including blue, white and gray. The north side (front) of the building would have separate entrances to the lower level of each of the four separate tenant spaces (i.e., Units A, B, C and D). Access to the upper mezzanine office spaces would be provided from the interior of the building via stairways. The double doors to the entrance would have aluminum framing with insulated tempered glazed windows. Units B and C would also have doors on the front of the building that would provide access to the industrial and warehouse spaces. Large, glazed windows with aluminum framing would be installed on both lower and upper levels of the building to provide for maximum light filtering from the outside into the office spaces. The west and northwest side of the building would provide for six separate points of ingress/egress into the Unit A industrial and warehouse space, and from the inside provide access outside to adjacent parking stalls and a large landscaped area at the west corner of the site. The east side of the building would provide for four points of ingress/egress into Unit D and would have large vision glass that would allow light to flow into the space from outside while keeping the inside of the building cool and private. The south side (rear) of the building would have 4 to 5 dock doors per unit for loading and unloading of materials from the warehouses. There would be four drive-in doors for truck access inside the warehouse.

The interior design of the building would maximize natural light with mezzanine offices on the second floor overlooking the ground floor. The total square footage of the first floor would be 119,304 square feet and the second floor would be 6,000 square feet. As indicated in Table 2: Building Composition by Level, the space would be configured for different uses related to life sciences and advanced manufacturing. The overall building square footage could potentially be divided into four separate units (Units A, B, C and D), each with separate entrances, for four future tenants (see Figure 5. Overall Floor Plan). Each of the units would be between 26,000 to 34,000 square feet consisting of office, industrial, and warehouse space.
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Table 2: Building Composition by Level
Level Use Square Footage
Level 1 Office 12,000
Level 1 Light industrial 30,000
Level 1 Warehouse 77,304
Level 2 Office 6,000
Other features of the building would include an interior bike rack, interior roof drain with pipe overflow, and an electrical room. All walking surfaces would be non-slip types. The floors would be a flat/tilt concrete slab and interior walls would be concrete. The building would be designed in compliance with fire codes related to fire access, internal sprinkler systems, electrical systems and fireretardant materials. Additionally, the building would comply with American With Disabilities (ADA) standards related to access, ramps, breakrooms and bathrooms.

Landscape Improvements
Most of the existing landscape would be replaced, as illustrated in Figure 6A. Landscape Plan, except within the southern portion of the site (Parcel 2) where existing vegetation within the riparian corridor of Dublin Creek and along the I-580 boundary would be retained. The total site landscape area would be 99,106 square feet, which includes new and existing landscape. A variety of evergreen shrubs, ornamental trees, grasses, and perennials would be planted around the perimeter of the site and at parking lot areas as listed in Figure 6B: Landscape Plan Details. A total of 85 trees would be added to the site along with other plant materials. Some of the proposed plants include sweet bay, strawberry tree, toyon, hopbush, coffeeberry, red yucca, agave, fort night lily, ceanothus and atlas fescue. Bark mulch would be placed in planters around shrubs.

Native and drought tolerant plants would be utilized to enhance biodiversity and conserve water. Large ornamental trees planned for parking lot areas would provide shade and minimize radiating heat. The landscape would be designed to provide buffers between the site and adjacent properties, and plants would be strategically placed to screen the site’s aboveground utilities from public streets. Temporary and permanent irrigation systems would be installed to establish plants. A 3,827 square foot grass bioswale surrounded by trees and shrubs is proposed in the west corner of the site. Additional bioswales/bioretention planters are proposed in the northeast and southeast areas of the site. The total bioretention areas would be 9,819 square feet.

Parcel 1 of the Project site contains 87 trees, four of which are heritage trees. All trees within this parcel would be removed except for two of the heritage trees; one in the northeast corner along the project frontage and one in the southwest portion of the site. The heritage trees that would be removed in Parcel 1 include one in the northwest portion of the site and one near the center of the site. Parcel 2 of the Project site contains 109 trees within the Dublin Creek riparian corridor. All trees in Parcel 2 would be retained, 19 of which are heritage trees.

Access, Circulation and Parking
Vehicular access would be provided from two existing driveways off Dublin Boulevard, one near the center of the site frontage and the other at the eastern boundary. These driveways would be 222
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connected by a 30 to 40-foot-wide fire access route around the perimeter of the proposed building (Figure 7. Fire Access Route). A total of six fire hydrants would be installed along this fire access road.

The road would be designed to accommodate emergency response vehicles (i.e., fire trucks), delivery box trucks, and trash trucks. A 26-foot-wide fire access route along the northern side of the building would allow for aerial apparatus access.

A total of 217 parking spaces would be provided for the Project. The parking spaces would be located around the perimeter of the building and at the edges of the site, and would include stalls for compact vehicles, standard vehicles, electric vehicle (EV) charging stations, and accessible parking. Compact parking would account for 27 percent of the overall parking spaces, while EV parking would account for 45 percent of the overall parking spaces. Additionally, 12 long-term and 12 short-term bicycle stalls would be provided onsite. Offsite loading spaces would be provided in the back (south) of the proposed building adjacent to the dock doors and facing Highway 580. No truck parking or loading will be facing the street.

Utilities Systems
The Project site is currently served by existing utilities for water, sanitary sewer, electricity, and gas. As discussed in the Initial Study in Section 18: Utilities and Service Systems, Dublin San Ramon Services District provides water and wastewater services to the site, and East Bay Community Energy provides electricity and gas to the site, which is distributed by Pacific Gas and Electric Company. Sanitary sewer, sanitary sewer manholes, a water meter, and electrical lines and cables would be removed and replaced with new lines that would connect to existing offsite service lines. Additionally, an existing electrical cabinet, storm drain pipe, electrical transformer, and air conditioner unit are proposed for removal and would be replaced. Some of the existing stormwater lines will be left in place but abandoned. New utility lines would be buried below ground.

A fire service line would connect to a public water line, which would provide water to the fire hydrants located around the site. Irrigation lines would also connect to public water lines. Stormwater would be treated onsite via five bioretention treatment planter areas that would be implemented in the western corner, southeast corner and south and northeast portions of the site. The site would be graded to have water flow into these biorientation areas. Approximately 9,819 square feet of bioretention areas on the Project site would be used for stormwater control. The proposed Project would include catch basins and storm drains throughout the project site. Full trash capture devices would be installed in all storm drain catch basins.

Other Improvements
An approximately 6-foot-high retaining wall would be installed along the southern edge of the parking lot and bioretention area in the southwest portion of the site, and lower (approximately 1- to 2-feethigh) retaining walls would be constructed adjacent to the bioretention areas in the southeast and northeast portions of the site. Additional retaining walls would be constructed to create loading dock ramps along the southern façade of the building.

A trash enclosure is proposed immediately adjacent to the backside of the building to the west. The trash enclosure would be 10.5 feet tall and 25.75 feet wide. A metal screen would be installed on the top of the enclosure to prevent illegal dumping. Double doors to move dumpsters in and out of the 223
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enclosure and an accessible gate would be provided in the front of the enclosure. The enclosure would store two 6-cubic yard (CY) dumpsters and one 2-CY bin for green waste.

A pathway would be constructed that would extend from the front of the proposed building to the side of the building providing access to doors along the building, parking spaces and the trash enclosure. A trash container for trash, recycle and compost would be installed near the front entrance of the proposed building.

Construction Activities and Schedule
A detailed construction schedule has not been determined at this phase; however, all construction of the Project is anticipated to occur over a 12-month period with some of the phases overlapping. Work would occur during weekdays from 7 am to 4 pm. The anticipated (preliminary) construction schedule is provided in Table 3: Anticipated Construction Schedule, which may be updated subject to market conditions, regulatory approvals, and other factors. The number of onsite workers would vary depending on the construction phase, but it is anticipated for a Project of this scope to range from 7 to 64 workers. Typical grading depths throughout the site would be less than 2 to 3 feet below ground level. The maximum depth of excavation would be between 12 to 20 feet below the existing ground level at the storm drain pump, which would be located in the southern portion of Parcel 1. In the parking lot near the southwest corner, grading would extend to approximately 4.5 feet below ground level.

Table 3: Anticipated Construction Schedule
Construction Phase Schedule Duration
Demolition Late fall 2023 to winter 2024 3 months
Site preparation/grading Early spring 2024 1 month
Trenching and foundation Spring 2024 1 month
Exterior building construction Late spring 2024 to fall 2024 6 months Interior building construction Late fall 2024 2 months
Paving/landscape Late fall 2024 to early winter 2 months Construction phases would include demolition, site preparation and grading, trenching and foundation work, exterior building construction, interior building construction, and outside paving/landscaping. A summary of each construction phase is described below.

Demolition – This stage would include the demolition of the existing facility, asphalt pavement (140,724 square feet), concrete curbs, landscape including trees and bushes, irrigation system, drainage system, sewer system, site lights, electrical boxes and other electrical equipment, gas and water meters, fence, shed and gate. Anticipated construction equipment to be used would include concrete saws, excavators, loaders, tractors, backhoes, and rubber-tired dozers.

Site preparation/grading – After the demolition phase, the site would be cleared of all demolition waste and earthmoving activities such as excavation, grading and leveling would take place to prepare the site for the proposed building and other site improvements. Utility line trenching would also occur 224
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during this stage. Anticipated construction equipment to be used would include graders, rubber-tired dozers, tractors, loaders, and backhoes.

Trenching and foundation – This phase would consist of excavating and trenching for footings, laying down reinforcing bars (rebar) for retaining walls, drilling piers, preparing beams for foundation, and pouring the foundation slab. Anticipated construction equipment to be used would include tractors, loaders, backhoes, and excavators.

Exterior building construction – This phase would include construction of framing, roof, and siding and installation of exterior windows and doors. Anticipated construction equipment to be used would include cranes, forklifts, generator sets, welders and tractors, loaders, backhoes and excavators.

Interior building construction – This stage would involve the interior rough out and interior finishes of the building. Walls, flooring, stairs, ceiling, windows, doors, interior electrical and plumbing would be developed at this phase. Anticipated construction equipment to be used would include air compressors and aerial lift.

Paving and landscape – This stage would include laying down the pavement for the parking, driveways, fire access road, and walkway areas. This stage also includes installation of landscaping and irrigation around the site. Anticipated construction equipment to be used would include cement and mortar mixers, pavers, pavement equipment, rollers, tractors, loaders, and backhoes.

Project Approvals
The City of Dublin is the Lead Agency for the proposed Project under CEQA. The City would be responsible for considering the Project’s impacts as part of the Project approval. The City would require the applicant to obtain the following approvals and permits: approval of a Planned Development Rezone with a related Stage 1 and Stage 2 Development Plan; Site Development Review Permit; Heritage Tree Removal Permit; and demolition, building, grading, and encroachment permits.

Other agencies whose approval may be required include:
x Bay Area Air Quality Management District (BAAQMD); and x Regional Water Quality Control Board (RWQCB).
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Environmental Analysis
Introduction
The Environmental Analysis chapter contains the analysis of the potential effects to environmental topics considered under CEQA from construction and operation of the proposed Project. This chapter describes the existing setting, relevant plans and policies that would minimize or avoid potential adverse environmental effects, the significance criteria used to determine environmental impacts, the approach to the analysis, and the potential impacts that could result from development of the property. This chapter also identifies mitigation measures necessary to reduce the potential impacts of the proposed Project.

Environmental Topics
This document is a Focused EIR in that it evaluates potential impacts on a limited number of environmental issue areas that the lead agency determined to be significant (CEQA Guidelines Section 15063(c)(3)). After preparation of the Initial Study Checklist (see Initial Study in Appendix A), the City of Dublin determined that the EIR would focus on the potentially significant impacts of the proposed Project including Cultural Resources and Tribal Resources and other impacts that could result in a less than significant impact with mitigation.

Impact Levels
The EIR uses the following terms to characterize environmental impacts of the proposed Project:
x No impact indicates that the construction, operation, and maintenance of the proposed Project would not have any direct or indirect effects on the physical environment. This designation means the proposed Project would not result in a change to existing conditions. This impact level does not need mitigation.
x A less-than-significant impact is one that would not result in a substantial or potentially substantial adverse change in the physical environment. This designation means that the Project would result in some degree of change to existing conditions, but that change would not be considered “significant,” as explained in the next impact designation. This impact level does not require mitigation under CEQA.
x A significant impact is defined by California Public Resources Code Section 21068 as “a substantial, or potentially substantial, adverse change in the environment.” Levels of significance can vary by project, based on the setting and the nature of the change in the existing physical condition. CEQA Guidelines Section 15382 defines a significant effect as a “substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment. A social or economic change related to a physical change may be considered in determining whether the physical change is significant.” A designation of an impact as significant requires that feasible mitigation measures or alternatives to the proposed project must be identified, where necessary and applicable, to eliminate or reduce the magnitude of the significant impact.
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x A potentially significant impact is one that, if it were to occur, would be considered a significant impact as described above; however, the occurrence of the impact cannot be immediately determined with certainty. For CEQA purposes, a potentially significant impact is treated as if it were a significant impact. Therefore, under CEQA, feasible mitigation measures or alternatives to the proposed project must be provided, where necessary and applicable, to eliminate or reduce the magnitude of potentially significant impacts.
x A potentially significant and unavoidable impact or significant and unavoidable impact is one that would result in a potentially substantial or substantial adverse effect on the environment, and that could not be reduced to a less-than-significant level even with implementation of feasible mitigation. Under CEQA, a project with significant and unavoidable impacts could still be approved, but the lead agency would be required to: (i) conclude in findings that there are no feasible means of substantially lessening or avoiding the significant impact in accordance with CEQA Guidelines Section 15091(a)(3); and (ii) prepare a statement of overriding considerations, in accordance with State CEQA Guidelines Section 15093, explaining why the lead agency would proceed with a project, in spite of the potential for significant impacts.

Environmental Baseline
Pursuant to CEQA Guidelines Section 15125(a), this EIR measures the physical impacts of the proposed project against a “baseline” of physical environmental conditions at and in the vicinity of the Project site. The environmental “baseline” is the combined circumstances existing at the time the NOP of the EIR was published; unless otherwise specified, this is considered the “existing” condition for this EIR.

For this Project, the baseline is May 15, 2023. The baseline also includes the policy and planning context for the proposed Project, such as the existing design review policies and procedures that currently govern proposed development.

Source(s)
City of Dublin Community Development Department. 2014 (updated). Dublin Village Historic Area Specific Plan. Adopted by the Dublin City Council on August 1, 2006, Resolution No. 149-06.

Available online: https://www.dublin.ca.gov/DocumentCenter/View/7780/DVHASP-FULL-PDF10714?bidId=. Accessed April 2023. 227
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Section 1: Air Quality

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

1. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan? X
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
X
c) Expose sensitive receptors to substantial pollutant
concentrations?
X
d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
X
Environmental Setting
Air quality is defined by the concentration of pollutants in relation to their impact on human health and the environment. Concentrations of air pollutants are determined by the rate and location of pollutant emissions released by pollution sources, and the atmosphere’s ability to transport and dilute such emissions. Natural factors that affect transport and dilution include terrain, wind, and sunlight. Therefore, ambient air quality conditions within the local air basin are influenced by natural factors such as topography, meteorology, and climate, in addition to the amount of air pollutant emissions released by existing air pollutant sources.

The proposed Project is located in the San Francisco Bay Area Air Basin (SFBAAB), which is comprised of complex terrain types, including coastal mountain ranges, inland valleys, and bays, which distort normal wind flow patterns. Along the County of Alameda’s (the county) western coast, temperatures are moderated by the bay, which can act as a heat source during cold weather or cool the air by evaporation during warm weather. It is generally sunnier farther from the coast, although partly cloudy skies are common throughout the summer. Average summer temperatures are mild overnight and moderate during the day. Winter temperatures are typically cool overnight and mild during the day. Highest temperatures are more common inland. Wind speeds vary throughout the county, with the strongest gusts along the western coast, often aided by dominant westerly winds and a bay-breeze effect. Rainfall totals average about 14 to 23 inches per year, with the highest totals in the northern end of the county and atop the Oakland-Berkeley hills (BAAQMD 2021).
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Air Pollutants of Concern
Individual air pollutants at certain concentrations may adversely affect human or animal health, reduce visibility, damage property, and reduce the productivity or vigor of crops and natural vegetation. Six air pollutants have been identified by the United States Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) as being of concern both on a nationwide and statewide level: ozone; carbon monoxide (CO); nitrogen dioxide (NO2); sulfur dioxide (SO2); lead; and particulate matter (PM), which is subdivided into two classes based on particle size: PM equal to or less than 10 micrometers in diameter (PM10) and PM equal to or less than 2.5 micrometers in diameter (PM2.5). Because the air quality standards for these air pollutants are regulated using human health and environmentally based criteria, they are commonly referred to as “criteria air pollutants.” Ozone is not emitted directly into the air but is formed through a series of reactions involving reactive organic gases (ROGs) and nitrogen oxides (NOX) in the presence of sunlight. ROG and NOX are referred to as “ozone precursors.”
Toxic Air Contaminants
In addition to criteria air pollutants, EPA and CARB regulate hazardous air pollutants, also known as toxic air contaminants (TACs). TACs collectively refer to a diverse group of air pollutants that can cause chronic (i.e., long-duration) and acute (i.e., severe but short-term) adverse effects on human health, including carcinogenic effects. TACs can be separated into carcinogens and noncarcinogens based on the nature of the effects associated with exposure to the pollutant. For regulatory purposes, carcinogens are assumed to have no safe threshold below which health impacts would not occur. Noncarcinogens differ in that there is generally assumed to be a safe level of exposure below which no negative health impact is believed to occur. These levels are determined on a pollutant-by-pollutant basis.

Sensitive Receptors
Sensitive receptors are facilities that house or attract children, the elderly, people with illnesses, or others who are especially sensitive to the effects of air pollutants. Hospitals, schools, convalescent facilities, and residences are examples of sensitive receptors. The nearest sensitive receptors include residences located across Dublin Boulevard, approximately 200 feet north of the Project site, a daycare located approximately 300 feet north of the Project site, and residences located approximately 570 feet east of the Project site.

Regulatory Framework
Federal Clean Air Act and National Ambient Air Quality Standards (NAAQS). Pursuant to the Clean Air Act, the EPA has established ambient air quality standards to protect public health and welfare with an adequate margin of safety. These federal standards, known as NAAQS, were developed for the six criteria pollutants described above. NAAQS represent safe levels of each pollutant to avoid specific adverse effects to human health and the environment. Two types of NAAQS have been established, primary and secondary standards. Primary standards set limits to protect public health, especially that of sensitive populations such as asthmatics, 229
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children, and seniors. Secondary standards set limits to protect public welfare, including protections against decreased visibility and damage to animals, crops, and buildings.

The Clean Air Act was amended in 1977 to require each state to maintain a State Implementation Plan (SIP) for achieving compliance with the NAAQS. In 1990, the Clean Air Act was amended again to strengthen regulation of both stationary and mobile emission sources.

California Clean Air Act and California Ambient Air Quality Standards (CAAQS). In 1988, the state legislature adopted the California Clean Air Act, which established a statewide air pollution control program. The California Clean Air Act requires all air districts in the state to make progress towards meeting the CAAQS by the earliest practical date. The California Clean Air Act establishes increasingly stringent requirements over time. CAAQS are generally more stringent than NAAQS and incorporate additional standards for sulfates, hydrogen sulfide, visibility-reducing particles, and vinyl chloride.

The California Clean Air Act substantially adds to the authority and responsibilities of air districts. The California Clean Air Act designates air districts as lead air quality planning agencies, requires air districts to prepare air quality plans, and grants air districts authority to implement transportation control measures.

Bay Area Air Quality Management District (BAAQMD). BAAQMD is the agency responsible for protecting public health and welfare through the administration of federal and state air quality laws and policies in the SFBAAB. BAAQMD’s tasks include air pollution monitoring, preparing air quality plans, and promulgating rules and regulations. BAAQMD rules and regulations relevant to the proposed Project include but are not limited to: Regulation 6 (Particulate Matter); Regulation 7 (Odorous Substances); Regulation 8, Rule 3 (Architectural Coatings); Regulation 11, Rule 2 (Asbestos Demolition, Renovation and Manufacturing). Additional rules and regulations may be applicable dependent upon the future specific tenants of the building.

BAAQMD also maintains multiple air quality monitoring stations that continually measure the ambient concentrations of major air pollutants throughout the SFBAAB. Under the California Clean Air Act, BAAQMD is required to develop an air quality attainment plan for nonattainment criteria pollutants within the air district. The 2017 Bay Area Clean Air Plan: Spare the Air and Cool the Climate was adopted on April 19, 2017, and provides a regional strategy to protect public health and protect the climate. To fulfill state ozone planning requirements, the 2017 control strategy includes all feasible measures to reduce emissions of ozone precursors and reduce transport of ozone and its precursors to neighboring air basins. In addition, the 2017 Clean Air Plan builds upon and enhances BAAQMD’s efforts to reduce emissions of fine PM and TACs (BAAQMD 2017a).

City of Dublin General Plan. The City of Dublin General Plan, adopted in 1985 and amended in 2022, includes an Environmental Resources Management: Conservation Element. The following policies related to air quality would be applicable to the proposed Project (City of Dublin 2022):
x Request that the Bay Area Air Quality Management District establish an air quality monitoring station in Dublin.
x Require an air quality analysis for new development projects that could generate significant air emissions on a project and cumulative level. Air quality analyses shall include specific feasible measures to reduce anticipated air quality emissions to a less-than-significant CEQA level.

Project Impacts and Mitigation Measures
(a) Consistent with air quality plans (Less Than Significant Impact with Mitigation Incorporated)
Air quality plans describe air pollution control strategies to be implemented by a city, county, or regional air district. The primary purpose of an air quality plan is to bring an area that does not attain NAAQS and CAAQS into compliance with those standards pursuant to the requirements of the Clean Air Act and California Clean Air Act. The most recent air quality plan is the BAAQMD 2017 Clean Air Plan (BAAQMD 2017a). The 2017 Clean Air Plan identifies potential control measures and strategies, including rules and regulations that could be implemented to reduce air pollutant emissions from industrial facilities, commercial processes, on- and off-road motor vehicles, and other sources. BAAQMD implements these strategies through rules and regulations, grant and incentive programs, public education and outreach, and partnerships with other agencies and stakeholders.

A project is determined to be consistent with the 2017 Clean Air Plan if it supports the goals of the Clean Air Plan, includes applicable control measures from the Clean Air Plan, and would not disrupt or hinder implementation of any control measures from the Clean Air Plan (BAAQMD 2017a). Consistency with the Clean Air Plan also is determined through evaluation of projectrelated air quality impacts and demonstration that project-related emissions would not increase the frequency or severity of existing violations or contribute to a new violation of the NAAQS or CAAQS. The BAAQMD CEQA Air Quality Guidelines include thresholds of significance that are applied to evaluate regional impacts of project-specific emissions of air pollutants and their impact on the BAAQMD’s ability to reach attainment (BAAQMD 2017c). Emissions that are above these thresholds have not been accommodated in the air quality plans and would not be consistent with the air quality plans.

Demolition activities and construction of the proposed Project would involve the use of offroad equipment, haul trucks, and worker commute trips that would generate short-term 231
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criteria air pollutant emissions. Operation of the proposed Project would generate long-term emissions associated with daily employee vehicle trips, building energy consumption, reapplication of architectural coatings, use of consumer products, and maintenance/testing of the fire pump. As discussed in Impact (b) below, construction-related emissions of the proposed Project would not exceed the thresholds of significance recommended by BAAQMD. In addition, consistent with Stationary Source Control Measures SS36 (PM from Trackout) and SS38 (Fugitive Dust) of the 2017 Clean Air Plan, the proposed Project would implement BAAQMD’s Basic Construction Mitigation Measures as noted in Mitigation Measure AQ-1 and be subject to BAAQMD Rules and Regulations for controlling fugitive dust emissions (Regulation 6 [Particulate Matter]), which would reduce fugitive dust emissions during demolition and construction. Further, as discussed in Impact (b) below, the proposed Project would result in a net reduction of emissions compared to existing conditions for NOx, PM10, and PM2.5, and ROG emissions would not exceed the BAAQMD thresholds of significance. The proposed Project would also comply with Dublin Municipal Code, Chapter 7.94.100 (Green Building Code), which requires that new construction buildings are all-electric buildings. Compliance with the Green Building Code would also be consistent with building control measures included in the 2017 Clean Air Plan, such as BL2 (Decarbonize Buildings). Furthermore, the proposed Project electrical and plumbing fixtures would be Title 24 and California Green Building Standards Code (CALGreen) compliant, which would be consistent with Building Control Measure BL1 (Green Buildings). Therefore, the proposed Project would not conflict with or obstruct implementation of the applicable air quality plan and this impact would be less than significant with mitigation. (b) Project emissions (Less than Significant with Mitigation Incorporated) By its very nature, air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development within the SFBAAB, and this regional impact is cumulative rather than being attributable to any one source. A project’s emissions may be individually limited, but cumulatively considerable when taken in combination with past, present, and future development projects.

BAAQMD published the May 2017 CEQA Air Quality Guidelines, which provides lead agencies assistance in evaluating air quality impacts of projects and plans proposed in the SFBAAB (BAAQMD 2017c). The guidelines provide recommended procedures for evaluating potential air impacts during the environmental review process, consistent with CEQA requirements, and include recommended thresholds of significance, mitigation measures, and background air quality information. BAAQMD has stated that the CEQA Guidelines are for informational purposes only and should be followed by local governments at their own discretion (BAAQMD 2017c). The BAAQMD CEQA Guidelines may inform environmental review for development projects in the Bay Area, but do not commit local governments or BAAQMD to any specific course of regulatory action. The thresholds for criteria pollutants were developed through a quantitative examination of the efficacy of fugitive dust mitigation measures and a quantitative examination of statewide nonattainment emissions and are used for the analysis of projectgenerated emissions. 232
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Construction emissions are short term but have the potential to result in a significant impact on air quality. Demolition and construction activities would generate temporary emissions of precursors to ozone (ROG and NOX), CO, PM10, and PM2.5. ROG, NOX, and CO emissions are associated primarily with mobile equipment exhaust, including off-road construction equipment and on-road motor vehicles. Fugitive particulate matter dust emissions are associated primarily with site preparation and travel on unpaved roads and vary as a function of parameters such as soil silt content, soil moisture, wind speed, acreage of disturbance area, and miles traveled by construction vehicles.

Demolition and construction activities are anticipated to begin in late fall 2023 and last approximately 12 months. Emissions associated with construction and operational activities were modeled using the California Emissions Estimator Model (CalEEMod) version 2020.4.

CalEEMod allows the user to enter project-specific construction and operational information, such as types, number and horsepower of construction equipment, number and length of offsite motor vehicle trips, project square footage, daily vehicle trips, and anticipated energy consumption details. Demolition of the existing building is anticipated to require approximately 608 total loaded haul truck trips. Construction activities would require the use of concrete/industrial saws, excavators, rubber-tired dozers, graders, tractors/loaders/backhoes, cement and mortar mixers, pavers, paving equipment, rollers, air compressors, aerial lifts, cranes, welders, and generator sets. Approximately 6,800 cubic yards of material are anticipated to be excavated and re-used onsite. The proposed Project would also require removal of approximately 141,000 square feet of asphalt pavement, which would be reused onsite. Additional modeling assumptions and details are provided in Appendix D.

Operation of the proposed Project would generate criteria air pollutant emissions associated with mobile, area, and stationary sources. Mobile sources would include vehicle activity from employee commutes and miscellaneous truck deliveries associated with the proposed office, light industrial, and warehousing land uses. Area source emissions were based on CalEEMod default data and would be associated with landscaping equipment usage, consumer product usage (i.e., cleaning supplies, parking surface degreasers), and periodic reapplication of architectural coatings. Stationary sources of emissions would include maintenance and testing of the diesel-fired 175-horsepower fire pump. As described previously, the building would be all-electric (i.e., no natural gas); therefore, there would be no onsite energy-related emissions.

Additional modeling assumptions and details are provided in Appendix D.

Table 4: Total and Average Daily Construction Emissions shows the total and average daily emissions associated with construction of the proposed Project. 233
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Table 4: Total and Average Daily Construction Emissions Source/Description ROG NOX PM10 (Exhaust) PM2.5 (Exhaust) Total Construction Emissions (tons) 1 0.90 1.96 0.08 0.07 Average Daily Emissions (lbs/day) 2 6.92 14.98 0.60 0.57 Threshold of Significance (lbs/day) 3 54 54 82 54
Exceeds Threshold? No No No No
Notes: lbs/day = pounds per day; NOX = nitrogen oxides; PM10 = particulate matter less than 10 micrometers in diameter; PM2.5 = particulate matter less than 10 micrometers in diameter; ROG = reactive organic gases 1 The construction emissions modeling assumed the proposed Project would include 227 parking spaces. Based on the latest site plan, the proposed Project would include 217 parking spaces. As such, the emissions presented above related asphalt paving and striping activities are conservative and actual emissions are anticipated to be slightly lower. 2 Average daily emissions estimated assuming 261 construction workdays based on a 5-day construction workweek and 12 months of construction.
3 BAAQMD 2017c
As shown in Table 4, construction-related emissions of ROG, NOx, PM10 exhaust, and PM2.5 exhaust would not exceed the applicable thresholds of significance established by BAAQMD.

Therefore, the impacts from emission of these criteria air pollutants during construction would be less than significant.

BAAQMD does not have quantitative mass emissions thresholds for fugitive PM10 and PM2.5 dust. Instead, BAAQMD recommends that all projects, regardless of the level of average daily emissions, implement applicable Best Management Practices (BMPs), including those listed as Basic Construction Measures in the BAAQMD CEQA Guidelines (BAAQMD 2017c). Without implementation of BAAQMD’s Basic Construction Measures, the impact of fugitive dust emissions during Project construction would be potentially significant.

In order to comply with the BAAQMD threshold for fugitive dust emissions, the following mitigation measure is needed:

Mitigation Measure AQ-1. Implement Basic Construction Emission Control Practices. The construction contractor shall comply with the following BAAQMD Basic Construction Measures, as applicable, for reducing construction emissions of uncontrolled fugitive dust (PM10 and PM2.5):
x All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. x All haul trucks transporting soil, sand, or other loose material off-site shall be covered. x All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
x All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph). x All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
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x Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]).

Clear signage shall be provided for construction workers at all access points. x All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. x Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

With implementation of Mitigation Measure AQ-1, the proposed Project would be consistent with BAAQMD guidance and the generation of fugitive dust emissions from Project construction would be reduced to less than significant with mitigation.

As shown in Table 5: Annual and Average Daily Operational Emissions, operation of the proposed Project would result in a net reduction in emissions of NOX, PM10, and PM2.5 compared to existing conditions, and emissions of ROG would not exceed the BAAQMD thresholds of significance. Therefore, the impact of operational emissions would be less than significant.

Table 5: Annual and Average Daily Operational Emissions Source/Description ROG NOx PM10 PM2.5
Proposed Project Annual Emissions (tons/year) 1 0.68 0.26 0.54 0.15 Existing Conditions Annual Emissions (tons/year) 0.61 0.47 0.65 0.18 Net Emissions (tons/year) 0.08 (0.22) (0.12) (0.04)
Threshold of Significance (tons/year) 2 10 10 15 10
Exceeds Annual Threshold? No No No No
Average Daily Emissions (lbs/day)3 0.60 (1.69) (0.90) (0.27) Threshold of Significance (lbs/day) 2 54 54 82 54
Exceeds Average Daily Threshold? No No No No
Notes: lbs/day = pounds per day; NOx = nitrogen oxides; PM10 = particulate matter less than 10 micrometers in diameter; PM2.5 = particulate matter less than 10 micrometers in diameter; ROG = reactive organic gases; tons/year = tons per year 1 The operational emissions modeling assumed the proposed Project would include 18,000 square feet of office space, 36,500 square feet of light industrial space, and 70,804 square feet of warehousing space. Based on the latest site plan, the proposed Project would actually include 18,000 square feet of office space, 30,000 square feet of light industrial space, and 77,304 square feet of warehousing space. As light industrial land uses generate higher daily vehicle trips than warehousing land uses, daily vehicle trips and the associated mobile source emissions are anticipated to be lower (i.e., the emissions modeling assumed the proposed Project would generate 494 daily trips, based on the 2022 Transportation Impact Study (W-Trans 2022); however, under the revised site plan, the proposed Project is anticipated to generate 473 daily trips). As such, the emissions presented above are conservative and actual emissions are anticipated to be lower. Implementation of the proposed Project would result in a higher net reduction in emissions compared to existing conditions. 2 BAAQMD 2017c 3 Average daily emissions estimated 260 working days per year, based on a Monday through Friday operational schedule. 235
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Therefore, with implementation of Mitigation Measure AQ-1, construction and operation of the proposed Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the region is non-attainment under an applicable federal or state ambient air quality standard. This impact would be less than significant with mitigation. (c) Expose sensitive receptors to pollutant concentrations (Less Than Significant Impact) Impact c was determined to be a less than significant impact, as the Project would not increase air emissions from existing conditions. Therefore, the full analysis for this impact is discussed in the Initial Study provided in Appendix A.
(d) Odors (Less Than Significant)
Impact d was determined be a less than significant impact. Since the proposed Project involves the redevelopment of an existing industrial building with a new industrial building, the proposed Project would not introduce a new odor-generating source. Therefore, the full analysis for this impact is discussed in the Initial Study provided in Appendix A.

Source(s)
Bay Area Air Quality Management District (BAAQMD). 2017a. Final 2017 Clean Air Plan: Spare the Air: Cool the Climate. Available online:
https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-airplan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed February 2023. ____. 2017b. Air Quality Standards and Attainment Status. Available online:
https://www.baaqmd.gov/about-air-quality/research-and-data/air-quality-standardsand-attainment-status. Accessed February 2023. ____. 2017c. California Environmental Quality Act: Air Quality Guidelines. Available online:
https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed February 2023. ____. 2021. In Your Community: Alameda County. Available online:
https://www.baaqmd.gov/about-the-air-district/in-your-community/alameda-county.

Accessed January 2021.

City of Dublin. 2022. General Plan. Available online:
https://www.dublin.ca.gov/DocumentCenter/View/30287/General-Plan-Update04192022-WEB. Accessed March 2023.

W Traffic Engineering Transportation Planning (W-Trans). 2022. Final Transportation Impact Study for the Hexcel Redevelopment Project. December.

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Section 2: Biological Resources

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

2. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
X
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
X
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
X
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
X
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
X
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
X
Environmental Setting
This section describes the existing biological setting within the Project site, which consists of two adjacent parcels, Parcel 1 and Parcel 2. The focus of the analysis was based on the areas potentially directly or indirectly affected by construction of the Project, referred to herein as the Project footprint. The Project footprint is exclusively in Parcel 1.

The City of Dublin is characterized by a diverse array of wildlife and plant species, with two discrete habitat types—the flatter urbanized portion of the City and the surrounding oak 238
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woodland and California annual grassland. The Project site is located within the urbanized area, which exhibits plant and animal species typical of urbanized areas including a combination of native and introduced trees, grasses and shrubs used for landscaping purposes.

The proposed Project footprint is completely developed with buildings, hardscape, and landscaped areas. Vegetation within landscaped areas of the footprint is comprised of sod, various ornamental shrubs, various ornamental tree species, as well as native trees such as California Bay (Umbellularia californica), coast live oak trees (Quercus agrifolia), and California buckeye (Aesculus californica). No natural habitats (habitats with naturally occurring vegetation) occur within the Project footprint.

The Project site is primarily developed with buildings, hardscape, and landscaped areas associated with the existing Hexcel buildings; however, Dublin Creek is located to the south of the Project footprint approximately along the boundary of Parcel 1 and Parcel 2. Dublin Creek in this location contained less than 1 foot of water during AECOM’s site visit on December 12, 2022. The banks of this feature are natural, but this feature runs underground for long stretches immediately east and west of the project.

Vegetation Communities
Vegetation communities within the Project footprint are limited to landscaped areas comprised of sod, various ornamental shrubs, various ornamental tree species, as well as a large number of native trees such as coast live oak trees, California Bay, and California buckeye. To the south of the Project footprint and on Parcel 2, is riparian habitat associated with Dublin Creek.

Wildlife
Wildlife in the Project site is likely to be limited to those species easily habituated to human activity, and which typically occupy urban areas or interfaces between urban and open space areas. Larger fauna may include raccoon (Procyon lotor) and skunk (Mephitis mephitis), while smaller fauna would include species such as western fence lizards (Sceloporus occidentalis), southern alligator lizard (Elgaria multicarinata), deer mice (Peromyscus maniculatus), and Botta’s pocket gopher (Thomomys bottae).

A wide variety of bird species likely utilizes the riparian corridor of Dublin Creek to the south of the Project footprint, as well as the ornamental vegetation and trees within the Project footprint. These species include red-tailed hawk (Buteo jamaicensis), house finch (Haemorhous mexicanus), mourning dove (Zenaida macroura), bushtit (Psaltriparus minimus), western bluebird (Sialia mexicana), American robin (Turdus migratorius), Anna’s hummingbird (Calypte anna), among others.

Regulatory Framework
Migratory Bird Treaty Act
The Migratory Bird Treaty Act of 1918 makes it illegal to take, possess, import, export, transport, sell, purchase, barter, or offer for sale, purchase, or barter any migratory bird, or the 239
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parts, nests, or eggs of such bird, except under the terms of a valid federal permit. Migratory bird species protected by the act are listed in the Code of Federal Regulations (CFR) in 50 CFR Part 10.13. The U.S. Fish and Wildlife Service (USFWS) has statutory authority for enforcing the Migratory Bird Treaty Act (16 United States Code Sections 703-712).

Federal Endangered Species Act
The Federal Endangered Species Act of 1973 (ESA) (16 United States Code Section 1531 et seq.) provides a regulatory program for the conservation of threatened and endangered plants and animals and the habitats in which they are found. The USFWS and National Marine Fisheries Service are the lead agencies responsible for implementing the ESA. The USFWS maintains a list of endangered species that includes birds, insects, fish, reptiles, mammals, crustaceans, plants, and trees. The USFWS and/or National Marine Fisheries Service requires authorization for any actions that they authorize, carry out, or fund, that may jeopardize the continued existence of any listed species or result in the destruction or adverse modification of designated critical habitat.

California Endangered Species Act
The California Endangered Species Act (CESA) conserves and protects animals at risk of extinction. Plants and animals may be designated as threatened or endangered under CESA after a formal listing process by the California Fish and Game Commission. A CESA-listed species may not be killed, possessed, purchased, or sold without authorization from the California Department of Fish and Wildlife.

California Fish and Game Code Fully Protected Species
Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code designate 37 species of wildlife as Fully Protected in California. Fully Protected species may not be taken or possessed at any time, and no licenses or permits may be issued for their take, except for the authorized collection of these species for necessary scientific research and relocation of bird species for the protection of livestock.

California Fish and Game Code Section 2081 Incidental Take Permits Section 2081(b) of the California Fish and Game Code allows the California Department of Fish and Wildlife to authorize take of CESA-listed species categorized as endangered, threatened, candidate, or rare plant species if that take is incidental to otherwise lawful activities, and if certain conditions are met. Section 2081(b) permits are commonly referred to as an Incidental Take Permit.

City of Dublin Municipal Code
The City of Dublin Municipal Code Chapter 5.60: “the Heritage Tree Ordinance” (Ord. 5-02 § 2 (part): Ord. 29-99 § 1 (part)), requires that a Tree Removal permit from the Director be acquired prior to the removal of heritage trees. Heritage trees include:
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1. “Any oak, bay, cypress, maple, redwood, buckeye and sycamore tree having a trunk or main stem of twenty-four (24) inches or more in diameter measured at four (4) feet six (6) inches above natural grade;

2. A tree required to be preserved as part of an approved development plan, zoning permit, use permit, site development review or subdivision map;

3. A tree required to be planted as a replacement for an unlawfully removed tree.” In addition, all applications for demolition, grading, or building permits on property containing one or more heritage trees shall prepare a tree protection plan pursuant to Section 5.60.090.

City of Dublin General Plan
The City of Dublin General Plan Chapter 7 Environmental Resources Management Conservation Element provides guidance for the protection of biological resources in Dublin and includes objectives, goals, and policies regarding biological resources.

The following goals and policies from the City’s General Plan relating to biological resources apply to the Project:
x Guiding Policy 7.2.1A1: Protect riparian vegetation as a protective buffer for stream quality and for its value as a habitat and aesthetic resource
x Implementing Policy 7.3.2B1: Require erosion control plans for proposed development.

Special-Status Wildlife
A desktop analysis was conducted to identify special-status wildlife species that may be present in the vicinity of the Project site. Google Maps, Google Earth, and photographs of the site were used to identify potential habitats that may be impacted by the Project. In addition, the following online resources were used to identify special-status wildlife species with the potential to occur on or near the Project site:
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x USFWS: Information for Planning and Consulting (IPaC) (USFWS 2023) x California Department of Fish and Wildlife (CDFW): California Natural Diversity Data Base (CNDDB): The search area consisted of a 5-mile buffer on the Project site. (CDFW 2023) As described in the Environmental Setting, natural habitats are absent from the Project footprint. None of the special-status species identified in the desktop analysis have life history requirements associated with buildings, hardscape, and landscape areas present in the Project footprint. As summarized in Table 6: Special-Status Species Potential to Occur in the Project Area, the Project footprint does not provide suitable habitat for any of the special-status wildlife species identified during the records search. The riparian corridor associated with Dublin Creek that runs immediately south of the Project footprint may provide suitable habitat for San Francisco dusky-footed woodrat and/or pallid bat. Because the Project would not involve direct disturbance within the riparian corridor, it would not directly destroy or alter such habitat, and there would be no impact to special-status species with potential to occur within the Project footprint area.

The Project footprint is located within 5 feet of the riparian corridor associated with Dublin Creek; however, construction activities would occur on existing paved areas (parking lot), and no construction equipment will enter Dublin Creek and associated habitat. Disturbance from noise and vibration (see Section 12) on wildlife could result during construction activities.

However, these impacts would be minimal and only for a temporary period of time during construction. Furthermore, construction of the Project does not have the potential to result in introduction of non-native weeds to the riparian corridor of Dublin Creek since no construction equipment would enter the creek.

In the event that runoff from the Project or accidental spills entered species habitat within Dublin Creek, sedimentation or the introduction of pollutants to habitat within Dublin Creek would constitute a potentially significant impact. As discussed further in the Initial Study in Section 9, Hydrology (see Appendix A) the Project would avoid sedimentation or the introduction of pollutants to habitat within Dublin Creek through the required implementation of erosion and sediment control measures and the implementation of BMPs specified in the Stormwater Pollution Prevention Plan (SWPPP) during construction, which would protect habitat within Dublin Creek. Thus, no substantial indirect impacts to status species would occur. 242
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Table 6: Special-Status Species Potential to Occur in the Project Area Scientific Name Common Name Class Status Habitat Present Danaus plexippus Monarch Butterfly Invertebrate Federal Candidate None Branchinecta lynchi Vernal Pool Fairy Shrimp Invertebrate FT None Hypomesus transpacificus Delta Smelt Invertebrate FT, SE None Ambystoma californiense pop. 1 California tiger salamander - central California DPS
Amphibian FT, ST None
Rana draytonii California red-legged frog Amphibian FT, SSC None Emys marmorata western pond turtle Reptile SSC None
Masticophis lateralis
euryxanthus
Alameda whipsnake Bird FT, ST None
Agelaius tricolor tricolored blackbird Bird ST, SSC None Aquila chrysaetos golden eagle Bird BGEPA, FP None
Athene cunicularia burrowing owl Bird SSC None
Contopus cooperi olive-sided flycatcher Bird SSC None
Elanus leucurus white-tailed kite Bird FP None
Falco peregrinus anatum American peregrine falcon Bird FP None Gymnogyps californianus California Condor Bird FE, SE, FP None Sterna antillarum browni California Least Tern Bird FE, SE, FP None Haliaeetus leucocephalus bald eagle Bird BGEPA, SE, FP None Antrozous pallidus pallid bat Mammal SSC None in project footprint. Possible
in riparian corridor.

Neotoma fuscipes annectens San Francisco dusky-footed
woodrat
Mammal SSC None in project
footprint. Possible
in riparian corridor.

Taxidea taxus American badger Mammal SSC None
Vulpes macrotis mutica San Joaquin kit fox Mammal FE, ST None Centromadia parryi ssp.
congdonii
Congdon’s tarplant Plant 1B.1 None
Eryngium jepsonii Jepson’s coyote-thistle Plant 1B.2 None Extriplex joaquinana San Joaquin spearscale Plant 1B.2 None Extriplex joaquinana San Joaquin spearscale Plant 1B.2 None Helianthella castanea Diablo helianthella Plant 1B.2 None Navarretia prostrata prostrate vernal pool
navarretia
Plant 1B.2 None
Status:

Federal
FE – listed as Endangered under the Federal Endangered Species Act FT – listed as Threatened under the Federal Endangered Species Act BGEPA – Bald and Golden Eagle Protection Act
State
SE – Listed as Endangered under the California Endangered Species Act ST – Listed as Threatened under the California Endangered Species Act SSC – State species of special concern
FP – Fully protected under California Fish and Game Code California Rare Plant Rank
1B.1 - Rare or endangered in California and elsewhere – seriously threatened in California (more than 80 percent of occurrences threatened) 1B.2 - Rare or endangered in California and elsewhere – moderately threatened in California (20 to 80 percent of occurrences threatened) 243
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Migratory Birds
The various shrubs, ornamental trees, and native trees in the Project footprint may provide suitable habitat for common nesting birds, such as house finch, mourning dove, common raven, and other birds that typically occupy urban environments. The USFWS IPaC tool also lists the following migratory bird species that could occur in the Project area: Allen’s hummingbird (Selasphorus sasin), bald eagle (Haliaeetus leucocephalus), Belding’s savannah sparrow (Passerculus sandwichensis beldingi), Bullock’s oriole (Icterus bullockii), California gull (Larus californicus), California thrasher (Toxostoma redivivum), common yellowthroat (Geothlypis trichas sinuosa), golden eagle, (Aquila chrysaetos), Lawrence’s goldfinch (Carduelis lawrencei), Nuttall’s woodpecker (picoides nuttallii), oak titmouse (Baeolophus inornatus), olive-sided flycatcher (Contopus cooperi), tricolor blackbird (Agelaius tricolor), Western grebe (Aechmophorus occidentatis), wrentit (Chamaea fasciata), and yellow-billed magpie (Pica nuttalli).

As discussed in the regulatory section, these birds, their nests, and eggs are protected under the Migratory Bird Treaty Act. Noise and vibration from proposed construction activities associated with the Project could disturb birds that are nesting on and near the Project site, for both common nesting birds and American peregrine falcon. Although nesting birds in this urban setting are typically habituated to human activity and associated noise, the increased level of human activity at the site during construction could temporarily disturb nesting birds.

In addition, the Project would involve the removal of approximately 85 landscape trees within the Project footprint, which could be used by birds during the nesting season. If a tree containing an active nest were to be removed during construction, such removal would result in nest destruction and failure. Due to this potential for loss of nests, and due to potential disturbance of nesting birds from noise and vibration during Project construction, the impact to nesting birds would be potentially significant.

Mitigation Measure BIO-1, detailed below, is recommended to address this potentially significant impact to nesting birds.

Mitigation Measure BIO-1: Nesting Bird Avoidance Measures A. To the extent practicable, construction activities and any tree trimming/removal shall be performed from September 16 through February 15 to avoid the general nesting period for birds. If construction or tree trimming/removal cannot be performed during this period, nesting bird surveys and active nest buffers (as necessary) shall be implemented as follows:
i. Nesting Bird Surveys: If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15 for other raptors), a qualified biologist shall conduct a survey for active nests of such birds within 7 days prior to the beginning of Project construction.

Appropriate minimum survey radii surrounding the work area shall be 244
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determined by the qualified biologist, but should be at least: i) 50 feet for passerines; ii) 300 feet for raptors. Surveys shall be conducted at the appropriate times of day and during appropriate nesting times, as determined by the qualified biologist.
ii. Active Nest Buffers: If the qualified biologist documents active nests within the survey area, an appropriate buffer between the nest and active construction shall be established. The buffer shall be clearly marked and maintained until the young have fledged and are foraging independently. Prior to construction, the qualified biologist shall conduct baseline monitoring of the nest to characterize “normal” bird behavior and establish a buffer distance which allows the birds to exhibit normal behavior. The qualified biologist shall monitor the nesting birds daily during construction activities and shall increase the buffer if the birds show signs of unusual or distressed behavior (e.g., defensive flights and vocalizations, standing up from a brooding position, and/or flying away from the nest). If buffer establishment is not possible, the qualified biologist shall have the authority to cease all construction work in the area until the young have fledged and the nest is no longer active. Construction shall only be allowed to impact a migratory bird or its nest, including its young, if a permit from U.S. Fish and Wildlife Service is obtained in accordance with the MTBA and all permit conditions are adhered to.

Mitigation Measure BIO-1 would protect nesting birds by ensuring that all active nests with the potential to be impacted by tree removal, construction noise, or human presence would be identified, appropriate avoidance buffers would be applied to active nests, and biologists would monitor active nests and bird behavior during construction so that the effectiveness of the buffer zone can be determined and the buffer distance can be adjusted if needed. Given the urban setting of the Project and presence of visual barriers such as other buildings and vegetation in the vicinity of the construction zone, the minimum search radii specified in Mitigation Measure BIO-1 (50 feet for passerines and 300 feet for raptors) are considered appropriate to reduce potential disturbance of nesting birds to a less than significant level.

With the implementation of Mitigation Measure BIO-1, proposed construction and associated activities would not disturb nesting birds or destroy their nests; therefore, potential Project impacts to candidate, sensitive, or special status species would be reduced to less than significant with mitigation.
(b) Substantial adverse effect on any riparian habitat or other natural community (Less Than Significant Impact)
No riparian habitat or other sensitive natural communities are located within the Project footprint; therefore, Project construction or operation would not directly impact riparian habitat or other sensitive natural communities and is not expected to affect Dublin Creek. The Project would have less than significant impact on riparian habitat and sensitive natural communities. See Initial Study for the full analysis in Appendix A. 245
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(c) Substantial adverse effect on wetlands (Less Than Significant Impact) No wetlands or other waters of the U.S. or state are located within the Project footprint; therefore, Project construction or operation would not directly impact wetlands and other waters. Furthermore, no substantial indirect impacts would occur to Dublin Creek from the Project. Therefore, the Project would have less than significant impact on wetlands and waters of the U.S. or state. See Initial Study for the full analysis in Appendix A. (d) Interfere or impede the movement of migratory fish or wildlife (Less Than Significant Impact with Mitigation Incorporated)
There are no documented migratory wildlife corridors, wildlife nursery sites, or large waterbodies or rivers in the vicinity of the Project site. The Project site is located between commercial and residential development, and the I-580 freeway. Resident and migratory waterfowl are not anticipated to use the Project site because it is already developed and contains no open waterbodies or other habitat frequented by such species. Therefore, the project would not interfere with or impede the movement of migratory waterfowl.

As discussed previously under Impact BIO-1, above, the riparian habitat associated with Dublin Creek could be used as habitat for migratory birds. However, Dublin Creek is a highly urbanized creek that generally parallels I-580. The creek supports a riparian canopy of trees, but there is no understory vegetation in the vicinity of the project. The feature runs to the west of the project with no riparian canopy before going underground, and runs underground to the east of the project before emerging with wide concrete banks. As such, this section of Dublin Creek is less likely to be used as a migratory corridor for common and special-status wildlife species.

Because the project would not impact the riparian habitat, it would not directly interfere with or impede the movement of common and special-status wildlife species. Indirect impacts to migratory birds from construction noise is addressed under Impact BIO-1, above.

The riparian corridor associated with Dublin Creek could be used as foraging habitat for common bats. As such, trees that would be removed as part of the Project outside of riparian areas may provide suitable day or night roosting habitat for bat species. Given the availability of alternative natural habitat for hibernaculum in the vicinity of the Project and based on planned tree replacement, impacts to habitat for bats are not expected to be significant. However, if construction were to remove trees containing bats during the maternity or winter season, bat mortality could occur, and the impact to common bat species would be potentially significant.

Mitigation Measure BIO-2, detailed below, is recommended to address this potentially significant impact to roosting bats.

Mitigation Measure BIO-2: Roosting Bat Surveys and Avoidance A. The Project Applicant shall retain a qualified biologist to conduct a bat habitat assessment in all project areas that require tree removal. The qualified biologist shall identify and document the location of potentially suitable bat roosting habitat prior to construction activities. If no suitable bat habitat is observed, the biologist shall inform the Project Applicant, and no further considerations are required. If bat 246
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roosting habitat is observed, the location of such habitat areas shall be provided to the Project Applicant, and the following requirements shall be implemented throughout the construction period:
i. Removal of trees that provide suitable bat roosting habitat shall be conducted outside of the bat maternity season (April 15 to August 31) and overwintering season (October 16 to January 15) to the extent feasible. i. Presence/absence surveys shall be conducted 2 to 3 days prior to removal of any trees in suitable bat habitat, at any time of year. If presence/ absence surveys are negative, work may proceed with no restrictions. If presence/absence surveys detect bats within trees planned for removal, work should proceed in accordance with the following restrictions:
x If a maternity colony of bats is observed during maternity season (April 15 to August 31), tree removal shall not occur until August 31 or when maternity season has ended based on surveys
conducted by a qualified biologist.
x If bats are observed during overwintering season (October 16 to January 15), tree removal shall not occur until January 15 or until bats are no longer present based on surveys conducted by a qualified biologist.
x If bats are present outside of maternity or overwintering seasons, construction shall follow a two-phase tree removal system conducted over 2 consecutive days. On the first day (in the afternoon), limbs and branches will be removed using chainsaws or other hand tools. Limbs with cavities, crevices, or deep bark fissures will be avoided, and only branches or limbs without those features will be removed. On the second day, the entire tree shall be removed.

Mitigation Measure BIO-2 would ensure that construction activities do not have the potential to result in significant impacts to roosting bats, by avoiding tree removal during times of the year when bats are most sensitive to disruption (maternity and overwintering seasons) to the extent feasible and by either confirming that bats are absent prior to tree removal and/or following protocols that provide an opportunity for bats to relocate prior to tree removal. With the implementation of Mitigation Measure BIO-2, potential Project impacts to wildlife movement, migration, or nursery sites would be reduced to less than significant with mitigation.
(e) Conflict with local policies or ordinance include tree preservation (Less Than Significant Impact)
The proposed Project would adhere to the tree removal permit conditions, the Project would not conflict with the City’s tree ordinance or the Dublin General Plan, and potential impacts would be less than significant.
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(f) Conflict with adopted habitat conservation or natural community conservation plans (No Impact)
There would be no impact since there are no Habitat Conservation Plans or Natural Communities Conservation Plans that apply to the Project site. See Initial Study in Appendix A.

Source(s)
California Department of Fish and Wildlife Service (CDFW), 2023. Rarefind 5, a program created by the California Department of Fish and Wildlife that allows access to the California Natural Diversity Database. Reviewed January 17, 2023.

United States Fish and Wildlife Service (USFWS), 2023. IPaC Information for Planning and Consultation. Available online at: https://ecos.fws.gov/ipac/. Accessed on January 17, 2023.

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Section 3: Cultural Resources

ENVIRONMENTAL IMPACTS
Issues
Significant
and
Unavoidable
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

3. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines
section 15064.5?
X
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5? X
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
X
Environmental Setting
The Project site is at 11711 Dublin Boulevard in the City of Dublin, Alameda County, California and is approximately 8.81 acres. The project site is located south of Dublin Boulevard with the Dublin Heritage Park and Museums and Dublin Pioneer Cemetery to the east; I-580 to the south; and a business park to the west.

Historic-age built environment resources on the Project site consist of the Hexcel Corporation R&D facility, landscaping, and parking. The Contemporary/Brutalist style facility has a roughly Lshaped plan and was largely constructed in two phases dating to 1962 and 1967, with small additions and alterations in the mid-1980s.

Pre-contact Cultural Context
Archaeological evidence demonstrates that people have lived in the San Francisco Bay Area for at least the past 10,000 years. The pre-contact history of the San Francisco Bay archaeological region is most commonly understood as a series of cultural and temporal periods defined by the Central California Taxonomic System (CCTS). The CCTS was developed by Beardsley (1948) and Gerow (Gerow with Force 1968), based on observations in the San Francisco Bay Area, the Sacramento Valley, and the Delta region. This system was further refined by Bennyhoff and Hughes (1987) and Groza (2002). The CCTS includes an Early Period, Middle Period, Middle-toLate Transition (MLT), and a Late Period, defined by a combination of changes in climate, artifact types, habitation patterns, and mortuary patterns. The following discussion will briefly describe each of these cultural-temporal periods, following Milliken et al. (2007).

Early Holocene (Lower Archaic): 8000-3500 B.C.

The people of the Early Holocene were mobile foragers, with seasonal, temporary camps located near food resources. The earliest archaeological site in the San Francisco Bay Area is CACCO-696 at Los Vaqueros Reservoir in Contra Costa County, dating to 7920 calibrated years 250
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before the present (cal B.C.) This site included millingslabs (metates) and handstones (manos), used together to grind seeds, nuts, or other foods. Large wide-stemmed projectile points of Napa Valley obsidian were also found at the site. This assemblage is typical of Early Holocene sites in the San Francisco Bay Area.

Early Period (Middle Archaic): 3,500-500 B.C.

During the Early Period, new milling technology is introduced, and shell beads first made their appearance. In addition to millingslabs and handstones, assemblages now include mortars and pestles, suggesting greater reliance on acorns. Grooved stone net sinkers are also present, pointing to new fishing technology. Shell beads made from abalone (Haliotis sp.) and olive snails (Olivella sp.) were placed in burials as tokens of tribute or prestige, along with red ochre and ceremonial and ornamental artifacts. Settlement patterns were semi-sedentary, featuring long-term villages with organized cemeteries.

Lower Middle Period (Initial Upper Archaic): 500 B.C. - A.D. 430 During the Lower Middle Period, shell bead forms change abruptly, with new forms replacing the old. Bone tools were common, including awls made from deer bones, which were used for basketry. Barbless fish spears replace the net sinkers of the previous period. Mortars and pestles are more common than millingslabs and handstones. Large shell mounds are constructed, indicating further sedentism.

Upper Middle Period (Late Upper Archaic): A.D. 430-1050 Major change occurred in 430 A.D. Half of the known settlement sites were abandoned. The trade in saucer shaped shell beads from southern California collapsed, but were replaced with saddle bead forms. Hunting of sea otters intensified. More stylized forms appear, including ear spools, obsidian show blades, and fishtail charmstones. A new population seems to have moved into the area, with elaborate grave goods and distinct, extended, burial styles, which contrasted with the flexed burial positions seen in earlier periods. This new pattern is called the Meganos complex, and may be a sign of invasion or of multi-cultural communities.

Initial Late Period (Lower Emergent): A.D. 1050-1550
The Late Period was a time of increased social complexity. Status was earned, not inherited.

Status objects became more elaborate, including large mortars with shell applique and straight sides (“flower pot” mortars) and many new forms of abalone shell ornaments. Mortuary practices included cremation and grave goods associated with social status. The bow and arrow was added to the hunting toolkit, and small projectile points were seen for the first time.

Settlements were permanent, year-round villages.

Terminal Late Period (Protohistoric): A.D. 1550-1776
During the Terminal Late Period, lives were already influenced by the arrival of European explorers. Disease spread in advance of newcomers, impacting the Native populations as they came into contact with pathogens they had never encountered before. Populations thinned, and grave goods were less plentiful. Clam shell beads were introduced and made locally. The 251
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forms of projectile points shifted from elaborate Stockton serrated points to simpler cornernotched forms.

In 1776, the first California Mission in the area was established by the Spanish in San Francisco, as well as a presidio. This was followed by the founding of Mission Santa Clara de Asís in 1777 and Mission San José in 1797. These marked the first European settlements in the San Francisco Bay Area, and led to major changes in the lives of Native Californians.

Ethnographic Context
An Ethnographic Context is provided within the Tribal Cultural Resources section of this EIR.

Historic Cultural Context
European Exploration (1542-1776 A.D.)
During the period of exploration, Europeans from Spain and England visited the coastline of California and a few inland areas, but did not visit the Amador Valley until Sergeant Pedro Amador passed through in 1795. Amador was the first to use the word “Alameda” to describe the area, meaning “place where cottonwoods grow”. Later that same year, Hermenegildo Sal and Father Antonio Danti began searching for locations to establish new Spanish Missions (Kyle et al. 2002).

However, even before Europeans set foot in the Amador Valley, their presence affected the Native people through spread of trade and disease. The first European ship to explore the coast of California was captained by Juan Rodriguez Cabrillo in 1542. Cabrillo’s party sailed as far north as Point Reyes, but only reported encounters with the Native population in Southern California. In 1579, the English explorer and pirate, Sir Francis Drake, anchored his ship, the Golden Hind, north of San Francisco in a small cove now known as Drake’s Bay. During their five week stay, Drake and his crew interacted extensively with the local residents, the Coast Miwok.

Sebastian Rodríguez Cermeño led an expedition to scout the California coast for safe ports in 1594, again anchoring in Drake’s Bay. Cermeño’s ship was wrecked by a storm as they left, and survivors walked south as far as San Luis Obispo before there was any account of their interactions with the Native people. In 1602, Sebastian Vizcaino led another expedition along the coast, searching for a good location for a port to support trade between New Spain (Mexico plus Alta and Baja California) and the Philippines. On finding Monterey Bay, Vizcaino proclaimed it “all that one could hope for” (Beebe and Senkewicz 2001:44-45). Nevertheless, King Felipe III of Spain issued a royal order prohibiting further exploration of Alta California, due to the presence of established ports in Baja California. The Spanish did not return to the Alta California Coast for 160 years (Beebe and Sekewicz 2001, Kyle et al. 2002).

In 1770, the Spanish returned to establish a presidio (military base) and mission in Monterey, and then began to explore in search of other potential Mission locations. Expeditions set out in 1772, led by Captain Pedro Fages, in 1774, led by Captain Fernando Rivera, in 1775, led by Father Vincente Santa Maria, and in 1776, led by Juan Bautista de Anza and Pedro Font. While these expeditions reached Santa Clara, San Francisco, and portions of Alameda and Contra Costa Counties, they did not reach the Amador Valley (Beebe and Sekewicz 2001). 252
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The Spanish Period (1776-1821 A.D.)
Seven Spanish missions were founded in Ohlone territory from 1776 to 1797, the closest being Mission San José, 14 miles south of the Project and founded in 1797. The Ohlone were recruited to the Mission through trade and offering of foods. However, once baptized, they were not allowed to leave the Mission, and became the workforce to grow food and raise livestock to support the new Spanish settlements. Anyone who tried to leave the mission to return to their old way of life or even visit their villages was considered a runaway, and was tracked down and forcibly returned to the missions. Due to harsh living conditions, devastating disease, and reduced birth rates, the population of Native Americans living in Mission San José rapidly dwindled, and the Spanish needed to range further to recruit new neophytes. According to Mission baptismal records, the Pelnen came to Mission San Jose between 1798 and 1805 and the Seunen, being further north, joined between 1801 and 1804 (Milliken 1995).

The Amador Valley was used as grazing land for livestock to support Mission San José. The introduction of cattle, horses, and sheep, and inadvertent introduction of invasive plant seeds, interrupted and changed the local ecosystem, depleting the resources that the Native Americans relied upon.

The Mexican Period (1821-1848 A.D.)
In 1821, Mexico gained independence from Spain, and Alta California became a Mexican province. By 1834, the Mexican government had begun a process of secularization of the Missions. Jose Maria Amador, having lived in the valley that would be named for him since at least 1830 (possibly 1826), received an official land grant from the Mexican governor of California in 1835. This vast grant of over 4 leagues (30,500 acres), became known as Rancho San Ramon. Amador’s adobe home was constructed on the northwest side of the modern crossroad of Dublin Boulevard and San Ramon Road, within 0.25-miles of the Project location, and next to a natural spring called Almilla Springs (Kyle et al. 2002, VerPlanck 2003a). Amador’s estate raised livestock, grew crops, and manufactured goods such as soap, leather goods, farm tools, and furniture, with the help of 150 Mexican and Native American employees (Minniear 2018). It is rumored that the burial ground for his workers was in the vicinity of the Pioneer Cemetery, although the cemetery was not officially consecrated until 1860 (VerPlanck 2003b).

California Statehood and the Development of the City of Dublin (1848 A.D. to Present) Following the Mexican-American War (1846-1848), the Treaty of Guadalupe was signed, transferring control of Alta California officially from Mexico to the United States. California statehood soon followed in 1850. During the interim, gold was discovered in El Dorado County in 1848, leading to the California Gold Rush and a great influx of settlers (Kyle et al. 2002).

Amador tried his hand at gold prospecting but was largely unsuccessful. By 1852, he began selling off some of his property to ease some financial stress. Michael Murray and Jeremiah Fallon were two of the first to purchase land from Amador, south of Dublin Boulevard. The farmsteads soon grew into a settlement, and the settlement into a town, which was organized in 1853 as Murray Township, but in the late 1850s was also referred to as Amador’s or Amador 253
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Valley. James Witt Dougherty, partnering with William Glaskins, purchased ten thousand acres from Amador in 1862 (Minniear 2018).

In 1859, St. Raymond’s Church was built in the location where it still stands on Donlan Way between Dublin Boulevard and I-580. During construction of the church, Tom Donlan fell to his death. A Catholic cemetery was established immediately west of the church, and Tom was the first to be officially buried there. However, historian Virginia Smith Bennett notes that the cemetery location had been used for burials before Donlan’s interment (Bennett 1978:2). The land for the church and the Catholic portion of the cemetery was donated by Michael Murry and Jeremiah Fallon. The land for the Protestant portion of the cemetery was donated by James W. Dougherty (Kyle et al. 2002, VerPlanck 2003b, 2003c). Existing grave markers give testament to the ongoing usage of the cemetery until present day. However, a fire in 1917 destroyed several wooden grave markers, which were not replaced (VerPlanck 2003b). Old St. Raymond’s Church (P-01-010635) was listed on the National Register of Historic Places in 2006 (NPS 06000242), as eligible under Criteria A and C, with Pioneer Cemetery (P-01010637) as a contributing element (NPS 2006). St. Raymond’s Church has also been found eligible for listing on the California Register of Historical Resources (CRHR) under Criteria 1 and 3 (VerPlanck 2003c).

The Old Murray School (P-01-010636) was built on land owned by Dougherty in 1856, and served all of Dublin and Pleasanton. When I-580 was widened in 1975, the schoolhouse was moved to its present location, just south of Old St. Raymond’s Church, and east of Pioneer Cemetery. It was restored by the Dublin Historic Preservation Association, and is now used as the Dublin Heritage Center (VerPlanck 2003d).

In the 1860s, the portion of the town to the south of the road to Stockton (now the I-580 corridor) was referred to as Dublin, reportedly based on a comment from James Witt Dougherty, saying that there were so many Irishmen south of the road to Stockton, it might as well be called Dublin (Kyle et al. 2003). By the 1870s, the name Dublin became common usage, however the name was not used officially until a post office was established in 1963. The City of Dublin was officially incorporated in 1982 (Minniear 2018).

John Green established a store in 1860 at the southeast corner of what is now Dublin Boulevard and Donlan Way, within 0.25-miles of the project location; Green’s Store (P-01-08150) was remodeled in the 1930s, but was restored to its 1914 condition in 1981 and now serves as the Tri-Valley Church of Christ (VerPlanck 2003e).

Dublin was primarily an agricultural community through the early twentieth century, with much of the land tied up in just a few large farms. But in 1942 the community changed, as the U.S.

Government purchased over 3,000 acres of land to establish Camp Parks, Camp Shoemaker, Shoemaker Naval Hospital, and a military prison, which later was relocated and became Santa Rita Jail (Minniear 2018). Hundreds of thousands of service members and their families passed through or moved into the Dublin area. Growth of Dublin took off in the 1960s, when the houses in the San Ramon Village area of Dublin were built, and supporting commercial development soon followed.
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History of the Hexcel Property and Hexcel Products, Inc.

The following historic context, specific to the Project location, was prepared as part of the Historical Resources Evaluation technical memorandum of the Hexcel Corporation R&D facility at 11711 Dublin Boulevard, prepared by AECOM for the City of Dublin. The historic context, relevant figures, and full evaluation for eligibility for listing in the CRHR are in the memorandum appended to this Focused EIR as Appendix C.

Property Development
In October 1961, Royal Research Corporation (Royal Research), a scientific research and development enterprise, purchased 13 acres of undeveloped, agricultural-zoned land between Dublin Boulevard and Highway 50 from William T. and Alice K. Marsh. That same month Alameda County approved Royal Research’s request to rezone the property into a special industrial zone to build a new research and development facility. At the time, Dublin was a small agricultural community with one school and one church, but a new 9,500-home development called San Ramon Village was underway on the north side of town. Royal Research surveyed the entire county to select a site to build their facility and chose this property because of the somewhat remote location. The company was already leasing a small office across the street at 11824 Dublin Avenue and were relying on the budding labor pool of new San Ramon Village residents (Hydro Geo Chem, Inc. 1994 July 1: Appendix A; Oakland Tribune 1960 September 4; Oakland Tribune 1961 October 27; Oakland Tribune 1960 August 7).

In 1962, Royal Research which manufactured enclosures for safe handling of radioactive and hazardous materials, commissioned construction of a 25,000-square-foot research and development facility on the subject property. The building housed offices and small laboratory spaces with a central courtyard in the north end, and the main laboratory area in the taller south end. Construction of the facility totaled nearly $350,000 with an additional $350,000 for equipment and was completed by the end of the year (Stockton Daily Evening Record 1962 July 31; Daily Review 1962 August 22).

Royal Research continued to occupy the facility until 1966 when it was sold to Hexcel Products, Inc. (Hexcel). Based in Berkeley, Hexcel was the largest developer and manufacturer of honeycomb, a structural material used in a number of applications, primarily associated with the aeronautics and aerospace industries. When looking to relocate from Berkeley, the executives at Hexcel sought a site somewhere between Carquinez Strait and Palo Alto, preferably near a college campus to draw from a technical labor pool for research and development, with the former Royal Research facility fitting its needs. Soon after the purchase, Hexcel announced a million-dollar, 20,000-square foot expansion of the research and development facility with a new administrative headquarters designed by San Francisco architecture firm Lackey, Knorr, Elliott & Associates. Hexcel closed their headquarters in Berkeley and relocated to Dublin and moved their manufacturing plants in Berkeley and Oakland to plants in Arizona, Texas, and Maryland (Hydro Geo Chem, Inc. 1994 July 1: Appendix A; Oakland Tribune 1966 May 18; Oakland Tribune 1967 November 12; San Francisco Examiner 1966 May 18; Contra Costa Times 1967 February 24).
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Hexcel’s new headquarters addition, completed in early 1967, housed the engineering, marketing, finance, and general administrative staff. The original 1962 section was utilized as laboratory space for further research and development. Hexcel president William S. Powell understood that technical employees were in great demand and wanted to entice new hires, so the building design included full-height tinted glass windows, courtyards, enclosed breezeways, and patios to provide outdoor views along with comfortable, carpeted workspaces, air conditioning, and taped music piped through an internal speaker system (Contra Costa Times 1967 March 26; Contra Costa Times 1967 February 24; Oakland Tribune 1967 November 12).

The Hexcel facility remained the same until the 1980s. In 1984 construction of a two-story hyphen connected the 1962 and 1967 buildings, resulting in a central courtyard. A small lab and chemical storage addition was constructed at the southeast corner of the facility the following year (Oakland Tribune 1984 May 16; Oakland Tribune 1984 July 11; Oakland Tribune 1985 November 13).

Royal Research Corporation
Royal Research Corporation, originally called Dublin Industries, was founded in Berkeley in 1959 by former Lawrence Radiation Laboratory staff (now known as the Lawrence Berkeley National Laboratory). The company focused on producing custom-made mechanical devices to handle radioactive materials. General Electric served as their primary customer for handling material at the Vallecitos Atomic Laboratory in nearby Sunol. In 1960, the company expanded into research, hiring Dr. William W.T. Crane, who headed heavy elements processing at Lawrence Radiation Laboratory from 1948 to 1958. Crane would later become president of the company.

Dublin Industries merged with the Pasadena-based Royal Industries in August 1960, which was an engineering firm. After the merger, Dublin Industries was renamed Royal Research Corporation, operating as a subsidiary to Royal Industries (Daily Review 1962 August 22; Los Angeles Times 1957 October 11).

The first major research contract obtained by Royal Research was to develop an isotopic power supply for the Atomic Energy Commission that resulted in the creation of thermo-electric generators for underwater seismic stations that could last several years. Within two years, Royal Research expanded research into vacuum devices to handle reactive materials, energy conversion, and microwave technology; 90 percent of their contracts were with the U.S. government (Daily Review 1962 August 22).

In June 1963, Royal Industries, Inc. sold Royal Research to General Technology Corporation which included use of the Dublin plant (subject facility). Royal Industries, Inc. retained ownership of the plant before selling the facility to Hexcel Products, Inc. in 1966 (Pasadena Independent 1963 June 5; Hydro Geo Chem, Inc. 1994 July 1: Appendix A).

Hexcel Corporation
Hexcel Corporation can trace its formation to 1946 when two University of California alumni, Roger C. Steele and Roscoe T. “Bud” Hughes decided to experiment with new construction material technologies developed during World War II, including plastics, in Hughes’ basement 256
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at his house in Berkeley. Steele’s experimentation led to the creation of structural honeycomb, which he demonstrated at a government-sponsored plastics conference as the California Reinforced Plastics Company. This demonstration secured a research and development contract of his expandable honeycomb for use in military aircraft radar domes in 1948. That same year, the company hired chemist Ken Holland to oversee resin research and development. The company furthered their ties with the military in 1949 when they won a low-bid contract to develop honeycomb fuel cell support panels for B-36 bombers (Pederson, ed. 1999: 193; Oakland Tribune 1967 May 22; Hexcel.com 2023; Contra Costa Times 1967 March 26).

In 1954, the company changed its name to Hexcel Products Inc. and continued creating honeycomb in a variety of materials including plastic, aluminum, fiberglass and paper, resulting in the highest strength-to-weight ratio material on the market with excellent energy absorption properties. Although the technology was initially used in aerospace, implementation of paper materials expanded use into commercial and residential building materials for use in interior partitions and mobile homes, and well as furniture manufacturing. By the end of the decade, Hexcel ran its headquarters out of Berkeley in a shared warehouse building at 2332 Fourth Street and had opened manufacturing plants in Berkeley, Oakland, and Havre de Grace in Maryland (Contra Costa Times 1967 March 26; Pederson, ed. 1999: 193; Oakland Tribune 1959 September 17; San Francisco Examiner 1962 July 2).

In the 1960s, Hexcel had several large contracts with the National Aeronautics and Space Administration (NASA), military, and commercial aviation clients. In 1968 Hexcel acquired Coast Manufacturing and Supply Company in Livermore and diversified the company’s product range beyond structural honeycomb to include reinforced plastics, industrial glass fabrics, structural adhesives, industrial resin compounds, and diffusion bonded assemblies. This shift occurred as the Federal government began to divest large-scale pursuits and the public’s interest in government programs shifted following the moon landing and withdrawal from Vietnam in 1969. Using the new materials procured from the Coast acquisition, Hexcel designed and produced high-performance snow skis. These were the first commodity made for the direct retail market (Times Record News 1970 April 10; Hexcel.com 2023; Pederson, ed. 1999: 193- 194).

Hexcel continued to diversify its portfolio in the 1970s with the acquisition of a graphite weaving company and a knee, hip, and shoulder joint replacement manufacturer. By the end of the decade only half of their sales were from honeycomb (Pederson, ed. 1999: 194).

An economic downturn and oil crisis at the end of the 1970s led to the sale of the ski and medical products and a returned focus on aviation and aerospace. The company secured a number of high value contracts, for example with NASA for components in the Columbia Space Shuttle, with Boeing, their largest customer accounting for 20 percent of total sales, and with the U. S. Air Force for its new B-2 bomber program that prompted construction of a new 160,000-square-foot manufacturing plant in Arizona. However, deregulation of the airline industry by President Ronald Reagan cut airline profits, leading to reductions of Hexcel’s Boeing and Airbus orders (Hexcel.com 2023; Oakland Tribune 1988 June 6). 257
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The early 1990s were tumultuous for the company starting with a Chapter 11 bankruptcy protection filing in 1993. After layoffs and plant and asset sales, the company avoided bankruptcy. In 1996 Hexcel merged with two composites companies to improve vertical integration; the new combined firm had a total of 4,700 employees with 19 manufacturing plants in seven countries (Pederson, ed. 1999: 194-195).

Since the late 1990s, Hexcel continued to lead research and development in honeycomb, carbon fiber, and resin structural materials. The company has contracts with a number of aerospace companies including Airbus, Boeing, SpaceX, Blue Origin, and Lockheed Martin. In May 2021, a groundbreaking ceremony was held in West Valley City, Utah for the company’s new research and technology headquarters with plans to vacate the Dublin facility in 2023 (Hexcel.com 2023).

Hexcel and NASA
In 1958, NASA utilized Hexcel honeycomb in their first spacecraft, Pioneer 1. The satellite probe included eight square feet of fiberglass reinforced Hexcel honeycomb plastic that only weighed 15 ounces. At a press conference hosted by Hexcel president Roger C. Steele in October 1958, he lauded the company’s honeycomb “structural sandwich” construction as the “highest strength to weight ratio of any material known to man” and could be used “to build a space vehicle of extraordinary strength with an absolute minimum of weight” (Oakland Tribune 1958 October 23). The special fiberglass reinforced plastic honeycomb was developed for radio and electrical transmission properties, and the structural sandwich construction created a heat resistant barrier to protect the internal instrumentation. Although Pioneer 1 was meant to orbit the moon, a programming error resulted in the satellite only traveling 71,300 of the 222,000 miles, but did collect data of the extent of the Earth's radiation belts (Concord Transcript 1958 December 8).

Success of the structural integrity of Pioneer 1 led to more contracts between Hexcel and NASA.

By the early 1960s, Hexcel developed cutting-edge materials for several space programs and missions including the Mariner Program satellites (1960-1975); Project Mercury spacecraft (1958-1961); Project Gemini spacecraft (1961-1966); and Apollo Program command and lunar module spacecraft (1960-1972). Hexcel honeycomb protected John Glen as he became the first American to orbit the earth in February 1962 in Friendship 7, part of the Mercury program (Oakland Tribune 1962 September 23; Hexcel.com 2023; Contra Costa Times 1970 June 21).

Hexcel continued research and development for NASA through the 1960s and created several types of honeycomb for NASA spacecraft. The Apollo 8 capsule held three astronauts when it left Earth’s and orbited the Moon ten times in December 1968 and contained layers of honeycomb to create the lightweight but high-strength structural capsule shell. A cylindrical honeycomb called “tube-core” was installed under the astronauts’ seats to help absorb G-force energy loads. A heatshield made of stainless-steel honeycomb and steel alloy sheets and an internal reinforced plastic honeycomb ablative heat shield were placed on the inside and outside of the capsule (Contra Costa Times 1968 December 4). This same structural and heat protection honeycomb was used in subsequent capsules in the Apollo program, including 258
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Apollo 9 and Apollo 11. Hexcel also developed a new honeycomb used on the Apollo 11 lunar module landing struts and footpads for the first moon landing in July 1969. This specific honeycomb design crushed and folded-in on itself to a absorb the impact of the landing and prevent bouncing (Contra Costa Times 1967 March 26; Contra Costa Times 1969 March 28; Times Record News 1970 April 10). After the moon landing, a local newspaper interviewed proud Hexcel employees at the headquarters in Dublin. While the newspaper noted that 300,000 people from 20,000 companies were involved in some capacity with the moon landing, Hexcel stood out because they “developed the best material NASA has found for use in spacecraft” (Argus 1969 July 24).

Hexcel continued its NASA relationship into the 1970s and development of the Space Shuttle program. Hexcel honeycomb was used in the nose cap, payload doors, and wings in the first space shuttle Columbia that launched in April 1981. Columbia flew 28 missions during its 22 years in service (NASA.gov 2023; Hexcel.com 2023).

Hexcel also supplied $1 million worth of materials for the Discovery Space Shuttle launched in August 1984. Honeycomb was used in the cargo bay doors, a new carbon composite heat shield material that could be used on several missions before needing to be replaced and wove hightemperature resistant ceramic fabric to line the flight crew’s cabin to protect them from extreme heat upon earth re-entry (Seguin Gazette Enterprise 1988 September 30; Hexcel.com 2023).

Lackey, Knorr & Elliott (1967 Hexcel addition)
Hexcel commissioned the large headquarters addition to the 1962 former Royal Research facility in 1967 from architects Lackey, Knorr & Elliott, based out of San Francisco. Donald R.

Knorr and Edward P. Elliott formed their first partnership Knorr-Elliott & Associates in 1958. The firm received awards of excellence from Architectural Record for residential designs in 1958 and 1963; a citation for the Dux Incorporated furniture company headquarters and warehouse in South San Francisco in 1963; a merit award for a dental plaza in Stanford in 1963; and an environmental award for the Koret of California distribution plant in South San Francisco in 1968 (PCAD 2023b; AIA 1970: 516). In 1967, the partnership included architect Lawrence Lackey, with the 1967 Hexcel addition appearing to be the only design produced by the collaboration (Oakland Tribune 1967 November 12). Lackey was an urban planner, architect, and landscape architect based out of San Francisco, active between the late 1950s and 1970s.

He was best known for the Master Plan he designed for the University of Fairbanks in Alaska in 1965 (PCAD 2023a; Contra Costa Times 1967 March 26).

Man in Space National Historic Landmark Theme Study
Congress passed Public Law 96-344 in 1980 which directed the Secretary of the Interior to produce a study that identified events and locations associated with the “Man in Space” theme to be brought into the National Park system and ways to present these significant locations, structures, and objects to the public. It also required evaluation of the resources identified with the Man in Space theme for recommendation as National Historic Landmarks (NHLs). The resulting study was first published in 1984 as “Man in Space: A National Historic Landmark 259
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Theme Study,” prepared by Dr. Harry A. Butowsky. In it, Butowsky identified 23 research and development facilities, testing facilities and stands, astronaut training facilities, tracking stations, mission control centers, a launch pad, and the Saturn 5 Space Vehicle that he recommended as NHLs and prepared NRHP Nomination Forms for each resource (Butowsky 1984 May: passim). Butowsky acknowledges that undoubtedly contractor-owned facilities and sites played significant roles in the United States’ pursuit to the moon and subsequent space programs, however this document in its first phase does not identify or provide guidance about these properties.

The original report does however identify four significant themes for the Man in Space context which resources would be considered historically significant. They include: 1. Technical Foundations before 1958; 2. The Effort to Land a Man on the Moon; 3. The Exploration of the Planets and the Solar System; and 4. The Role of Scientific and Communications Satellites.

These four subthemes provided a foundation for identification of significant properties.

However, this early report lacks the details to clearly spell out what types of properties would or would not be significant under these subthemes for modern National Register of Historic Places (NRHP) analysis.

A second phase of the report was published later in 1984 that identified another launch pad as well as three spacecrafts, which were not previously identified in the first report. The three spacecrafts, Mercury Friendship 7 (1962), Gemini 4 (1964), and the Apollo 11 Command Module (1969) were all located in the National Air and Space Museum at the Smithsonian Institution in Washington, D.C. Butowsky declared the three spacecrafts as “nationally significant historic objects … it is important to recognize the national significance of the objects having internal integrity which have contributed critically to the success of the space program and, together, form an integral chapter in that program’s history” (Butowsky 1984 August:1-2).

These spacecrafts represented a first, or breakthrough, for each program’s mission. While the first phase of the report stated that the second phase would examine the importance of contractors, it was not included. Butowsky did not specifically call out any private company, but he described the use of Hexcel fiberglass honeycomb in the description of the Apollo 11 Command Module. All three of these spacecrafts contain honeycomb developed by Hexcel for NASA (Butowsky 1984 August: passim).

Based on the results of AECOM’s historical resource evaluation, the Hexcel Corporation R&D facility at 11711 Dublin Avenue (P-01-010656) is eligible for listing in the CRHR under Criterion 1 because it is significant at the national level for its association with the Man in Space historic context under subtheme 2. The Effort to Land a Man on the Moon and retains sufficient integrity to its period of significance (1967 and 1969). The property has been evaluated in accordance with Section 15064.5(a)(2)-(3) of the CEQA Guidelines, using the criteria outlined in Section 5024.1 of the California Public Resources Code and is a historical resource for the purposes of CEQA.
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Regulatory Framework
Cultural resources in California are protected by a number of regulations. The following provides a brief outline of the regulations, policies, and ordinances that are applicable to the proposed project.

Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) (16 United States Code 470) and its implementing regulations (36 CFR 800) establish a program for the preservation of historic properties throughout the United States and provides a framework for identifying and treating historical and archaeological resources under the CEQA. Section 106 of the NHPA requires that federal projects or projects under federal jurisdiction consider the effect of an undertaking on properties eligible for or included in the NRHP. Historic properties that are listed in or eligible for the NRHP are considered historical resources for the purposes of CEQA.

National Register of Historic Places
Historic properties are those significant cultural resources that are listed in or are eligible for listing in the NRHP per the criteria listed below (36 CFR 60.4):

The quality of significance in American, state, and local history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and meet one or more of the following criteria:
a. Are associated with events that have made a significant contribution to the broad patterns of our history;
b. Are associated with the lives of persons significant in our past; c. Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction;
d. Have yielded, or may be likely to yield, information important in prehistory or history.

Ordinarily, cemeteries, birthplaces, or graves of historic figures; properties owned by religious institutions or used for religious purposes; structures that have been moved from their original locations; reconstructed historic buildings; and properties that are primarily commemorative in nature are not considered eligible for the NRHP, unless they satisfy certain conditions. In general, a resource must be 50 years of age to be considered for the NRHP, unless it satisfies a standard of exceptional importance.

Listing in the NRHP does not entail specific protection of, or assistance for a property. However, listing does guarantee the property’s recognition during planning for federal or federally assisted projects, eligibility for federal tax benefits, and qualification for federal historic 261
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preservation assistance. Additionally, project effects on properties listed in the NRHP must be evaluated under CEQA.

Secretary of the Interior’s Standards for the Treatment of Historic Properties The “Secretary of the Interior’s Standards for the Treatment of Historic Properties” (Secretary’s Standards), codified in 36 CFR 67, provide guidance for working with historic properties. The Secretary’s Standards are used by lead agencies to evaluate proposed rehabilitative work on historic properties. The Secretary’s Standards are a useful analytic tool for understanding and describing the potential impacts of proposed changes to historic resources. Projects that comply with the Secretary’s Standards benefit from a regulatory presumption that they would not result in a significant impact to a historic resource. Projects that do not comply with the Secretary’s Standards may or may not cause a substantial adverse change in the significance of a historic property.

In 1992, the Secretary’s Standards were revised so they could be applied to all types of historic resources, including landscapes. They were reduced to four sets of treatments to guide work on historic properties: Preservation, Rehabilitation, Restoration, and Reconstruction.

Rehabilitation acknowledges the need to alter or add to a historic property to meet continuing or changing uses while retaining the property’s historic character and is most applicable to this Project. The Rehabilitation standards are as follows:

1. A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.

2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.

3. Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.

4. Changes to a property that have acquired historic significance in their own right will be retained and preserved.

5. Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.

6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.

8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.
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9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work will be differentiated from the old and will be compatible with the historic materials, features, size, scale, and proportion, and massing to protect the integrity of the property and its environment.

10. New additions and adjacent or related new construction will be undertaken in such a manner that, if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.

Generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties shall be considered as mitigated to a level of less than a significant impact on the historical resource per CEQA Guidelines section 15064.5(b).

State
California Environmental Quality Act
CEQA requires public agencies to consider the effects of their actions on “historical resources,” “unique archeological resources,” and “tribal cultural resources.” Pursuant to PRC Section 21084.1, a “project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.” Section 21083.2 requires agencies to determine whether proposed projects would have effects on unique archeological resources.

Historical Resources
“Historical resource” is a term with a defined statutory meaning (PRC § 21084.1; determining significant impacts to historical and archeological resources is described in the CEQA Guidelines, § 15064.5[a] and [b]). Per the CEQA Guidelines, section 15064.5(a), historical resources include the following:
(1) A resource listed in or determined to be eligible by the State Historical Resources Commission, for listing in the CRHR (PRC § 5024.1).
(2) A resource included in a local register of historical resources, as defined in PRC § 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC § 5024.1(g), will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. 263
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(4) The fact that a resource is not listed in or determined to be eligible for listing in the CRHR, not included in a local register of historical resources (pursuant to Cal. Pub. Resources Code § 5020.1(k)), or identified in a historical resources survey (meeting the criteria in Cal. Pub.

Resources Code § 5024.1(g)) does not preclude a lead agency from determining that the resource may be a historical resource as defined in Cal. Pub. Resources Code§§ 5020.1(j) or 5024.1.

Non-Unique Archeological Resources
Under CEQA, archeological resources are presumed non-unique unless they meet the definition of “unique archeological resources” (Cal. Pub. Resources Code § 21083.2[g]). Under CEQA, an impact on a non-unique archeological resource is not considered a significant environmental impact.

Unique Archeological Resources
Archeological resources can sometimes qualify as “unique archeological resources” that are not “historical resources.” (CEQA Guidelines, Section 15064.5(c)(3)). PRC, Section 21083.2(g) defines a unique archeological resource as an artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; or

2. Has a special and particular quality such as being the oldest of its type or the best available example of its type; or

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

California Register of Historical Resources
The CRHR is a guide to cultural resources that must be considered when a government agency undertakes a discretionary action subject to CEQA. The CRHR helps government agencies identify, evaluate, and protect California’s historical resources, and indicates which properties are to be protected from substantial adverse change (Pub. Resources Code, Section 5024.1(a)).

The CRHR is administered through the California Office of Historic Preservation (OHP) which is part of the California State Parks system. A cultural resource is evaluated under four CRHR criteria to determine its historical significance. A resource must be significant at the local, state, or national level in accordance with one or more of the following criteria set forth in the CEQA Guidelines Section 15064.5(a)(3) and Public Resources Code section 5024.1:
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1. It is associated with events that have made a significant contribution to the broad pattern of California’s history and cultural heritage;

2. It is associated with the lives of persons important in our past;

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. It has yielded, or may be likely to yield, information important in prehistory or history.

In addition to meeting one or more of the above criteria, the CRHR requires that sufficient time must have passed to allow a “scholarly perspective on the events or individuals associated with the resource.” The CRHR also requires a resource to possess integrity, which is defined as “the authenticity of a historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance. Integrity is evaluated with regard to the retention of location, design, setting, materials, workmanship, feeling, and association.

Codes Governing Human Remains
Human remains are protected by several laws in the State of California, including Health and Safety Codes (HRC) 7050.5, 7051, 7052, and 7055. Together these laws define criminal consequences for disturbing, disinterring, mutilating, or removing human remains from their place of rest or discovery.

Section 7050.5 of the Health & Safety Code requires that construction or excavation be stopped in the vicinity of discovered human remains until the county coroner can determine whether the remains are those of a Native American. If the remains are determined to be Native American, the coroner must then contact the California Native American Heritage Commission (NAHC), which has jurisdiction pursuant to Public Res. Code § 5097. The NAHC, pursuant to PRC Section 5097.98, will immediately notify the person it believes to be most likely descendant (MLD), of the deceased Native American person so they can inspect the burial site and make recommendations for appropriate treatment or disposition.

Section 7051 makes it a crime, punishable by imprisonment, to remove any human remains from the place where they have been interred or deposited without authority of law. Section 7052 protects human remains from mutilation and disinterment. Section 7055 makes it a crime to remove interred human remains from a cemetery.

Local
City of Dublin General Plan
The City of Dublin General Plan, Chapter 7 Environmental Resources Management Conservation Element, provides guidance for the protection of archaeological and historic resources in Dublin and guiding policies related to historic and cultural resources are as follows:

Guiding Policy 7.7.1A.1: Preserve Dublin’s historic structures. 265
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Seven sites in the Primary Planning Area are listed in the California Archaeological Inventory, Northwest Information Center, at Sonoma State University including the church and school on the grounds of the Dublin Heritage Park and Museums. As many as a dozen potentially significant historic and prehistoric sites have been identified in the Eastern Extended Planning Area.

Guiding Policy 7.7.1A.2: Follow State regulations as set forth in Public Resources Code Section 21083.2 regarding discovery of archaeological sites, and Historical Resources, as defined in Section 5020.1 of the Public Resources Code.

Guiding Policy 7.7.1A.3: Preserve the Green Store.

The Green Store is a recognized historical resource and has been used as a church since 1989.

This use can remain as long as the landowner(s) wish to continue its operation. The Parks/ Public Recreation designation on the General Plan Land Use Map illustrates the long-term potential for expansion of the Dublin Heritage Park and Museums to include this historic structure and the property it is on and is not intended to affect or change the current church use or its continued operation as a religious land use under a valid conditional use permit.

Dublin Village Historic Area Specific Plan
The Project site is located within the Dublin Village Historic Area Specific Plan boundary. The Dublin Village Historic Area Specific Plan (SP) was adopted in 2006 and updated in 2014.

Applicable goals and objectives of the Dublin Village Historic Area Specific Plan related to historic and cultural resources are as follows:

Goal 1: Preserve and protect the valuable historic resources within the Dublin Village Historic Area.

Objective 1.1: Identify Dublin’s historic resources and adopt a formal Historic Resources Inventory.

Objective 1.2: Identify mechanisms to protect properties on the Historic Resources Inventory from being destroyed or altered to the point of removing their historic value.

Objective 1.3: Identify incentives to encourage the preservation and enhancement of privatelyowned historic resources.

Objective 1.4: Pursue formal designation and recognition of Dublin’s historic resources through the California State Office of Historic Preservation and National Registry.

Objective 1.5: Work cooperatively with property owners to rehabilitate Alamilla Springs.

Objective 1.6: Ensure that improvements and renovations to publicly-owned historic resources are done according to the Secretary of the Interior’s Standards for the Treatment of Historic Properties.
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Goal 2: Guide the design of future development to reinforce the unique historic qualities and design elements that once defined Dublin Village.

Objective 2.1: Create design guidelines for residential, commercial, and mixed-use development on private property.

Objective 2.2: Create design guidelines that provide direction for future streetscape improvements in the public right of way.

Objective 2.3: Create guidelines that provide direction on the preferred preservation and rehabilitation techniques for properties on the Historic Resources Inventory.

Additionally, the SP includes mitigation measures that apply to the treatment of historic resources within the Dublin Village Historic Area, drawn from the Initial Study and Mitigated Negative Declaration (IS/MND) prepared by the City in 2006 (City of Dublin 2006). The mitigation measures for the Project will meet the requirements set forth in the SP and the associated IS/MND (City of Dublin 2014: Appendix B; City of Dublin 2006).

SP Mitigation Measure 4: In High Archeological Probability Areas (including a 150 meter (493 foot) corridor centered on Dublin Creek and within the general vicinity of St.

Raymond’s Church, Pioneer Cemetery, and the Dublin Square Shopping Center site), the permitting of future ground disturbance shall include provisions for further archival and field study by an archeologist, archeological testing and, and, if necessary, archeological monitoring during construction.

SP Mitigation Measure 5: Should preconstruction excavation or borings be conducted outside of the High Archeological Probability Areas, but within the project area, a qualified archeologist shall monitor the work to define the presence or absence of buried resources in order to promote advance planning for mitigation purposes.

SP Mitigation Measure 6: If a Native American artifact or human remains are identified during any demolition or construction in the project area, work on the project shall cease immediately until those steps outlined in CEQA Guidelines Section 15064.5 (e) can be taken to the satisfaction of the Dublin Community Development Director. Project work may be resumed in compliance with the requirements of Section 15064.5 (e).

Additionally, the County Coroner shall be contacted immediately and Section 7050.5(b) of the California Health and Safety Code (relating to the discovery of Native American remains) should be implemented.

SP Mitigation Measure 7: If an archeological, prehistoric, or paleontological resource is discovered during any demolition or construction in the project area, work on the project shall cease immediately until a resource protection plan conforming to CEQA Guidelines Section 15064.5 (f) is prepared by a qualified archeologist and approved by the Dublin Community Development Director. Project work may be resumed in compliance with such plan.
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Dublin Historic Resources Inventory
The Dublin Historic Resources Inventory (HRI) was created when the Dublin Village Historic Area Specific Plan was adopted by the Dublin City Council in 2006. The HRI was established to “recognize those few remaining resources that have a place in Dublin’s history, including those resources that might be significant to the immediate community but not significant at the state or federal level” (City of Dublin Community Development Department 2014: 27).

The HRI consists of resources that were found eligible for listing in the NRHP and the CRHR, or only having local significance, from the survey efforts undertaken in Dublin Historic Resources Identification Project that was finalized in 2004 by Page & Turnbull, Inc. The HRI includes only seven resources, three of which are near the 6600 block of Donlon Way: St. Raymond’s Church, Murray Schoolhouse, and the Pioneer Cemetery, which have been combined as the “Dublin Heritage Center.” The Pioneer Cemetery is adjacent to the Hexcel property, and historic documents suggest it extends into the Project parcel (VerPlanck 2003b).

The Dublin Village Historic Area Specific Plan did not establish goals or policies for maintaining or adding properties to the HRI. No guidelines were provided to reevaluate properties in the Dublin Village Historic Area that were less than 50 years old at the time the survey was conducted in 2004, nor any significance criteria or mechanisms for nominating or adding properties to the HRI.

Previous CEQA Documents
The City of Dublin hired the archaeological firm William Self Associates, Inc. (WSA) in 2003 to prepare an Archaeological Assessment Report of the Donlon Way Specific Plan (later renamed the Dublin Village Historic Area Specific Plan area). A record search at the Northwest Information Center (NWIC), conducted by WSA, did not identify any previously recorded archaeological sites within the Specific Plan area boundaries, but one new archaeological site was recorded during the pedestrian survey and Archeological High Probability areas were also identified within the Specific Plan area boundaries. The Archaeological Assessment Report concluded that there is a moderate-to-high-probability of identifying Native American archeological resources and a high-probability of encountering historic-period archeological resources within the Specific Plan area boundaries.

The City of Dublin hired the architectural firm Page & Turnbull, Inc. in 2003 to prepare the Dublin Historic Resources Identification Project that was finalized in 2004. The city contracted with Page & Turnbull to identify and map historic resources in an approximately 38-acre area for a future Specific Plan for the Donlon Way area (later renamed the Dublin Village Historic Area Specific Plan) and to prepare preservation recommendations. Page & Turnbull prepared a historic context of the Dublin Village area and recorded all of the properties in the survey area on Department of Parks and Recreation (DPR) 523 A and B forms. The Hexcel Corporation R&D facility on the Project site was recorded as part of this effort on December 10, 20003 (VerPlanck 2003f). At that time, the facility was not considered old enough (at least 50 years old) to be considered a potential historical resource under CEQA. Additionally, while the historic evaluation did contain a thorough historic context statement, it did not address the four 268
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eligibility criteria for either the NRHP or the CRHR, but merely concluded that the property lacked architectural or historical significance to be eligible.

The Dublin Village Historic Area Specific Plan was adopted by the Dublin City Council on August 1, 2006, under Resolution No. 149-06 and relied on the findings of the Archaeological Assessment Report of the Donlon Way Specific Plan and the Dublin Historic Resources Identification Project. The approximately 38-acre Specific Plan area included the two project site parcels. Subsequently, three Specific Plan addendum and amendments have been prepared for the Specific Plan. City Council determined that no new significant impacts were identified by the addendums or amendments, and no further environmental analysis was required.

Project Impacts and Mitigation Measures
(a) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines section 15064.5 (Significant and Unavoidable Impact) A historical resource evaluation was prepared for the Hexcel Corporation’s 1960s-constructed R&D facility on the Project site to assess its eligibility for listing in the CRHR as a potential historical resource for the purposes of CEQA (see Appendix C). The facility was determined to be eligible for listing in the CRHR under Criterion 1, because it is significant at the national level for its associations within the Man in Space historic context published by the National Park Service and is, therefore, considered a historical resource for the purposes of CEQA.

The significance of an historical resource is considered to be “materially impaired” when a project demolishes or materially alters the physical characteristics that justify the determination of an historical resources’ significance. Because the proposed Project would result in the demolition of the existing Hexcel Corporation R&D facility, which is a historical resource for the purposes of CEQA, the Project would have a significant and unavoidable impact on a historical resource.

CEQA requires that all feasible mitigation must be completed even if it does not mitigate project impacts below a level of significance. CEQA Guidelines Section 15126.4(b), states that “In some circumstances, documentation of an historical resource, by way of historic narrative, photographs or architectural drawings, as mitigation for the effects of demolition of the resource will not mitigate the effects to a point where clearly no significant effect on the environment would occur.” Therefore, recordation of a resource prior to demolition does not typically mitigate the physical impact on the environment caused by demolition or destruction of an historical resource; however, it does serves a legitimate archival purpose. Therefore, the following mitigation measures are required , even though they would not fully offset the loss of the resource, and the impact would remain significant and unavoidable.

Mitigation Measure CUL-1: HABS Recordation
In consultation with the City of Dublin Planning Division, the Project applicant shall document the Hexcel Corporation R&D facility prior to demolition. Documentation shall be performed by a Secretary of Interior-qualified professionals (in history or architectural 269
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history) and be consistent with the standards of the National Parks Service (NPS) Historic American Building Survey (HABS) and shall consist of the following elements:

Photographs must be identified and labeled using HABS/HALS standards.

Following completion of the HABS documentation, including the short form historical report and large-format photographs, and approval by the City of Dublin, the materials shall be placed on file with the City of Dublin Planning Division, and the Dublin Historical Society at the Dublin Heritage Park and Museums.

Mitigation Measure CUL-2: Interpretive Displays
In concert with HABS documentation (Mitigation Measure CUL-1), the Project applicant shall install permanent interpretive displays or signage for public exhibition detailing the history and significance of the Hexcel Corporation R&D facility at the Project site. The interpretive displays or signage could be based on the photographs produced in the HABS documentation and the historic archival research previously prepared as part of the Project.

Interpretive displays or signage at the Project site shall be located outside of the new building, near the publicly accessible sidewalk and/or inside the new building in a prominent space, such as the lobby, where they may be viewed by employees and visitors.
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Even with implementation of the mitigation measures identified above, the Project would still result in a significant and unavoidable impact to the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5, as it would result in its demolition. Therefore, the Project would have a Significant and Unavoidable Impact with Mitigation Incorporated. A discussion of alternatives that would involve the partial preservation and adaptive reuse of the portion of the building where the NASA research took place is presented in Alternatives Considered but Rejected section of this EIR.
(b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5 (Less Than Significant With Mitigation Incorporated) The proposed Project would include excavation of much of the Hexcel Corporation R&D facility property, which is adjacent to the Dublin Village Historic Settlement. The Dublin Village Historic Settlement is recorded as a historical resource for the purposes of CEQA (P-01-002127) and includes Old St. Raymond’s Church, the Pioneer Cemetery, the Old Murray School, Green’s Store, the site of the Green Mansion and Murray Homestead, and Donlon Way. St. Raymond’s Church is listed on the National Register of Historic Places (NPS 06000242), eligible under criteria A and C, with the Pioneer Cemetery listed as a contributing element. Additionally, the Hexcel property falls within the Dublin Village Historic Area Specific Plan, therefore the project must abide by the mitigation measures proposed in the associated IS/MND (City of Dublin 2014; City of Dublin 2006).

Based on the existence of archeological resources within and adjacent to the Project area, there is a high probability of encountering historic-period archeological resources during ground disturbance at the Project site, particularly within those portions of the property closest to St.

Raymond's Church and Pioneer Cemetery, and a high probability of identifying Native American archeological resources, particularly within a 150 meter (493 foot) corridor centered on Dublin Creek.

Section 15126.4 of the CEQA Guidelines directs public agencies to avoid damaging effects on an archeological resource whenever possible. For a project that could impact an archeological resource, Section 15064.5 (Determining the Significance of Impacts on Historical and Unique Archeological resources) of the CEQA Guidelines applies and all requirements of this section shall be met in the course of reviewing and implementing the Project. In order to mitigate any potential impacts to resources in the Project area, further archival and field study by an archeologist shall be undertaken prior to the construction of any development projects in the area in accordance with the recommendations of the Dublin Village Historic Area Specific Plan and associated IS/MND (City of Dublin 2014; City of Dublin 2006).

In sum, there is a high potential for previously unrecorded archaeological resources associated with the historic settlement to be within the Hexcel Property. Additionally, the Hexcel property is adjacent to the marked boundary of the Pioneer Cemetery, a contributing element to the NRHP listed resource, St. Raymond’s Church (P-01-010635 / CA-ALA-521H / NPS 06000242). 271
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The High Archeological Probability Areas identified for this Project, per the guidance of the Dublin Village Historic Area Specific Plan and associated IS/MND, are the areas most proximate to St. Raymond’s Church and Pioneer Cemetery, and a 150 meter corridor centered on Dublin Creek. This includes the portion of the Project site to the east of the existing Hexcel building and much of the southern parking lot, approximately 115,763 square feet of the total project area of 383,764 square feet (30 percent). Per the proposed design, excavation within this High Archaeological Probability Area would exceed 1 foot below ground surface (bgs) in an area of approximately 61,850 square feet (53 percent) of the area, with a maximum depth of approximately 12 feet bgs.

The possibility of encountering buried archaeological resources in the Project area outside of the High Archeological Probability Area, remains a concern as well, and per the mitigation measures in the Dublin Village Historic Area Specific Plan and associated IS/MND, requires mitigation to avoid adverse impact.

If previously unrecorded archaeological resources associated with historical resources are present within the Hexcel property and/or if burials extend beyond the marked boundary of the adjacent Pioneer Cemetery, earthmoving and excavation activities to implement the Project could damage or destroy these buried resources, and the Project impact to archaeological resources would be potentially significant.

Mitigation Measure CUL-3: Archaeological and Tribal Monitoring A. A qualified archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards for archaeology shall be retained by the applicant prior to implementing construction or soil remediation activities that involve earthmoving or soil excavation, and the archaeologist shall be available for consultation or evaluation of any cultural resources uncovered by such activities. Prior to the start of excavation, the archaeologist shall produce a Treatment and Monitoring Plan, in consultation with the City of Dublin, and through them, with any consulting Native American tribes.

The Treatment and Monitoring Plan will comply with mitigation measures 4, 5, 6, and 7, set forth in the Dublin Village Historic Area Specific Plan, Appendix B, and will specify the following:
i. Archaeological testing to be done prior to the start of construction. ii. Archaeological and Tribal monitoring requirements, which will be based on the results of archaeological testing and consultation with Native American tribes. iii. Procedures and considerations for handling, documenting, analyzing, and curation of any historic-era or pre-contact era artifacts encountered during project activities.
iv. Procedures and considerations for handling, documenting, analyzing, and curation of any human remains from the historic era. (For human remains of 272
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Native Americans, treatment protocols would be established with the designated MLD).

B. If an archaeological resource (or suspected resource) is discovered during monitoring of project activities, construction or excavation activities within a 50-foot radius of the find shall be temporarily halted or directed to other areas, pending the archaeologist's evaluation of its significance. If the resource is significant, data collection, excavation, or other standard archaeological or historical procedures shall be implemented to mitigate impacts, pursuant to the Treatment and Monitoring Plan and the archaeologist’s direction. If any human remains are encountered, the archaeologist shall contact the appropriate County Coroner immediately, and security measures shall be implemented to ensure that burials are not vandalized until the decision of burial deposition has been made pursuant to California law. If human remains are determined to be Native American interments, the Coroner shall contact the Native American Heritage Commission pursuant to Public Resources Code Section 5097.98 and follow the procedures stated herein and other applicable laws. A report by the archaeologist evaluating the find and identifying mitigation actions taken shall be submitted to the CPUC. Where appropriate to protect the location and sensitivity of the cultural resources, the report may be submitted under Public Utilities Code Section 583 or other appropriate confidentiality provisions.

Mitigation Measure CUL-4: Inadvertent Discovery Protocols A. Prior to the start of ground disturbing activities, the applicant shall retain a qualified archaeologist that meets the Secretary of the Interior’s Professional Qualification Standards for archaeology to implement archaeological awareness training for all construction personnel involved with ground disturbing or excavation activities. The training shall include information regarding the possibility of encountering buried cultural resources, the appearance and types of resources likely to be seen during construction, notification procedures, and proper protocols to be followed should suspected or confirmed resources be encountered by the crew. This training shall be provided once to each worker involved in ground-disturbing activities before they begin work, and shall be documented in training records.

C. Recommendations for treatment and disposition of find(s) could include, but are not limited to, archaeological monitoring, collection, recordation, and analysis of any significant cultural materials. A report of findings documenting any data recovery shall be submitted to NWIC.
i. In the event that archaeological resource(s) are discovered during Project implementation, an archaeological monitor shall be retained to monitor all ground- disturbing activities in the vicinity (i.e., within 50 feet) of the find.

Archaeological monitors have the authority, upon the finding of a potential resource, to request that work be slowed, diverted, or stopped if archaeological resources are identified within the direct impact area.

If the resource is determined by an archaeologist to be a historical or unique archaeological resource, the archaeologist shall amend the Treatment and Monitoring Plan, with measures to avoid or reduce impacts to the resource. The treatment plan measures may include, but not be limited to, avoidance and preservation in place (the preferred method if feasible), capping, incorporation of the site within a park or other open space, or data recovery. If the resource is also a tribal cultural resource, then designated representatives from the consulting tribe(s) shall make appropriate recommendations regarding the treatment and disposition of such find(s) in accordance with Mitigation Measure CUL-3 and these recommendations shall be incorporated into the treatment plan.

The mitigation measures require training for all construction workers so that they are aware of the potential for encountering buried resources and the procedures that need to be followed if potential precontact or historic period archaeological resources are encountered during on-site activities, as well as the regulations pertaining to discovery of human burials. Because the mitigation measures require stopping work within the area of any potential find(s), and require 274
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that a qualified archaeologist inspect the find and make recommendations for avoiding or reducing impacts (in collaboration with tribal representatives), implementation of mitigations CUL-3 and CUL-4, would reduce the potential impact on archeological and buried resources to less-than-significant with mitigation.
(c) Disturb any human remains, including those interred outside of dedicated cemeteries (Less Than Significant)
The proposed Project would include excavation of the parking lot to the south of the Hexcel Corporation R&D facility, which is adjacent to the marked boundary of the Pioneer Cemetery.

Marked grave sites in the cemetery are within five feet of the Hexcel property fence. Historic documents suggest that the cemetery was larger than the currently marked boundary, and was used as an Ohlone burial site and as a burial ground for Native American and Mexican farm workers on José María Amador’s Ranchero San Ramón prior to consecration of the official cemetery in 1860 (Bennett 1978, VerPlanck 2003b).

For these reasons, there is a high probability that portions of the cemetery extend to the west of the marked cemetery, beneath the Hexcel parking lot. As designed, excavation depths in the area outside the existing building footprint would range up to 10 feet below surface along the southern boundary of the Hexcel property. If unmarked portions of the cemetery extend beneath the Hexcel property, the Project has the potential to disturb human remains during earthmoving and excavation activities to implement the Project. The disturbance of human remains could be a potentially significant impact if measures are not taken to protect the remains from damage, destruction, or discretion.

Human burials, in addition to being potential archaeological resources, have specific provisions for treatment in Section 5097 of the California Public Resources Code. The California Health and Safety Code (Sections 7050.5, 7051, 7052, and 7055) also has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, protect them from disturbance, vandalism, or destruction, and established procedures to be implemented if Native American skeletal remains are discovered.

Public Resources Code Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and established the NAHC to resolve any related disputes.

Compliance with these regulations is mandatory for all projects; therefore, if human remains are encountered during Project implementation, work at the project site would stop, the Alameda County Coroner would be notified immediately, and no further disturbance would occur until the county coroner has made a determination of origin and disposition pursuant to PRC Section 5097.98. The remains would be protected from disturbance, vandalism, or destruction until such decision is made. If the human remains are determined to be from the historic-era, treatment, including excavation, documentation, analysis, and curation, will follow the archaeological Treatment and Monitoring Plan, as per CUL-3.A.iv. If the human remains are determined to be Native American, the coroner is required to notify the NAHC, which would determine and notify a most likely descendant (MLD) within 24 hours. The MLD must complete the inspection of the site within 48 hours of notification and may recommend scientific removal 275
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and non-destructive analysis of Native American human remains and items associated with Native American burials. Pre-activity archaeological testing is to be included as part of the Archaeological Treatment and Monitoring Plan, per CUL-3.A.i. Archaeological testing prior to any ground disturbing activities would reduce the potential for disturbance of human remains during construction. However, it should be noted, archaeological testing would not eliminate the potential or degree to impact human remains, but would give the contractor more information on whether the resources are present and at what depths they could be encountered. The Reduced Grading Alternative, described in the Alternatives section, would be the most effective way to reduce the potential for adverse impacts. In addition, Mitigation Measure CUL-4 specifically requires training for all construction workers on the required regulations and procedures to be followed in the event that human burials are encountered.

Compliance with the mandatory regulations pertaining to human burials would reduce the potential for destruction or desecration of human remains, if encountered during project construction. Compliance with procedures defined in the archaeological Treatment and Monitoring Plan and/or in negotiation with the MLD will ensure that the treatment of human remains will be respectful, and will be mitigated to the satisfaction of consulting descendent populations. As a result, the impact would be less than significant with mitigation.

Source(s)
AIA Historical Directory of American Architects (AIA). 1970. “Knorr, Don Robert.” Available at:
https://content.aia.org/sites/default/files/2018-09/Bowker_1970_K.pdf. Accessed January 2023.

Argus. 1969 July 24. “Honeybee Plays A Part In Apollo Moon Voyage.” 5.

Beardsley, Richard K. 1948. Culture Sequences in Central California Archaeology. American Antiquity 14(1):1-28.

Beebe, Rose Marie, and Robert M. Senkewicz. 2001. Lands of Promise and Despair: Chronicles of Early California, 1535-1846. Berkeley: Heydey Books.

Bennett, Virginia Smith. 1978. Dublin Reflections and Bits of Valley History. Published by Dublin Friends of the Library. Union City, CA: Mill Creek Press.

Bennyhoff, James A., and Richard E. Hughes. 1987. Shell Bead and Ornament Exchange Networks Between California and the Western Great Basin. Anthropological Papers of the American Museum of Natural History 64(2):79-175.

Butowsky, Dr. Harry A. 1984 May. Man in Space: National Historic Landmark Theme Study. n.p.

Available at:
https://historicproperties.arc.nasa.gov/downloads/man_in_space_butowsky.pdf.

Accessed January 2023.
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________. 1984 August. Man in Space: National Historic Landmark Theme Study, Phase II. n.p.

Available at: http://npshistory.com/publications/nhl/theme-studies/man-in-space2.pdf. Accessed January 2023.

City of Dublin. 2006. Initial Study and Mitigated Negative Declaration for the Draft Dublin Village Historic Area Specific Plan and General Plan Amendment, Draft Parks and Recreation Master Plan 2006 Update, Dublin Historic Park Draft Mater Plan, and Dublin Village Historic Area Rezoning. Planning Application File No. PA 02-074. On file with the City of Dublin.

City of Dublin Community Development Department. 2014 (updated). Dublin Village Historic Area Specific Plan. Adopted by the Dublin City Council on August 1, 2006, Resolution No. 149-06. Available online:
https://www.dublin.ca.gov/DocumentCenter/View/7780/DVHASP-FULL-PDF10714?bidId=. Accessed April 2023. ____. 2022 (amended). General Plan. Available online:
https://www.dublin.ca.gov/DocumentCenter/View/30287/General-Plan-Update04192022-WEB. Accessed April 2023.

Concord Transcript. 1958 December 8. “Moon Rocket Fails, But Space Science Gains.” 1.

Contra Costa Times. 1967 February 24. “New Research Facility Set for SR Valley.” 1-2. ________. 1967 March 26. “Hexcel in Dublin – Honeycomb Goes to Work.” 30. ________. 1968 December 4. “Hexcel Honeycomb To Cushion Apollo 8.” 4C. ________. 1969 March 28. ”Honeycomb Cocoon” [caption]. 8. ________. 1970 June 21. “SR Valley Sets Pattern For County’s New Space-Age Industry.” 7.

Daily Review (Hayward, CA). 1962 August 22. “Dublin Research Firm – New Industry Plan $350,000 Plant.” 8.

Gerow, Bert A., with Roland W. Force. 1968. An Analysis of the University Village Complex with a Reappraisal of Central California Archaeology. Stanford: Stanford University Press.

Groza, Randall Gannon. 2002. An AMS Chronology for Central California Olivella Shell Beads.

Master’s thesis, Department of Anthropology, San Francisco State University.

Hexcel.com. 2023. “History & Timeline.” Available at: https://www.hexcel.com/About/Historyand-Timeline. Accessed January 2023. 277
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Hydro Geo Chem, Inc. 1994 July 1. Results of a Phase I Environmental Site Assessment of the Hexcel Research and Development Facility, 11711 Dublin Boulevard, Dublin, California, Prepared for Hexcel Corporation.

Kyle, Douglas E., Mildred Brooke Hoover, Hero Eugene Rensch, Ethel Grace Rensch, and William N. Abeloe. 2002. Historic Spots in California, Fifth Edition. Stanford, California: Stanford University Press.

Los Angeles Times. 1957 October 11. “Century Eng. Wil Change Name to Royal Industries.” Part Five, Page 9.

Minnear, Steven. 2018. Dublin California: A Brief History. Charleston, S.C.: The History Press.

NASA.gov. 2023. “NASA Orbiter Fleet.” Available at:
https://www.nasa.gov/centers/kennedy/shuttleoperations/orbiters/columbia_info.htm.

Accessed January 2023.

National Park Service (NPS). 2006. National Register of Historic Places Registration Form for St.

Raymond’s Church, Record Number 06000242. Available at:
https://catalog.archives.gov/search?page=1&q=%22national%20register%20of%20histo ric%20places%22%2006000242. Accessed June 2023.

NPS. 2006. See National Park Service.

Oakland Tribune. 1958. October 23. “Berkeley Form Has Tole in First Moon Probe Vehicle.” 34. ________. 1959 September 17. “Notes on Bay Commerce.” 62. ________. 1960 August 7. “Two Eastbay Atomic Firms Merge, Plan for Expansion.” 26. ________. 1960 September 4. “San Ramon Village Grand Opening: Celebration Starts Today at Model City. 2-R.
________. 1961 October 27. “Supervisors OK Expansion in Dublin Area.” 11-E. ________. 1962 September 23. “Button Pusher: Canaveral Just Fires Cal Creations.” 43. ________. 1966 May 18. “$1 Million Headquarters For Hexcel in Dublin.” 46. ________. 1967 May 22. “News of Business, Industry.” 13. ________. 1967 November 12. “Courtyards and Patios Upgrade Environment.” 10-CM – 11-CM. ________. 1984 July 11. “Building Permits – Dublin.” 62. ________. 1984 May 16. “Building Permits – Dublin.” 64. 278
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________. 1985 November 13. “Building Permits – Dublin.” 16. ________. 1988 June 6. “Hexcel.” B-3.

Pasadena Independent. 1963 June 5. “Royal Industries Sells Subsidiary.” 19.

Pacific Coast Architecture Database (PCAD). 2023a. “Lawrence Lackey.” Available at:
https://pcad.lib.washington.edu/person/3022/. Accessed January 2023. ________. 2023b. “Knorr – Elliott and Associates, Architects (Partnership).” Available at:
https://pcad.lib.washington.edu/firm/1030/. Accessed January 2023.

Pederson, Jay P., Editor. 1999. International Directory of Company Histories, Volume 28. San Francisco, CA: St. James Press.

San Francisco Examiner. 1962 July 2. “Industrial Engineer” [classified advertisement]. 36. ________. 1966 June 26. “Big Koret Shipping Center.” 25. ________. 1966 May 18. “$1 Million Bay Unit for Hexcel.” 71.

Seguin Gazette-Enterprise (Seguin, Texas). 1988 September 30. “Discovery Carries Hexcel Products.” 1-2.

Stockton Daily Evening Record. 1962 July 31. “Work Starts on Bay Area Plant.” 4.

Times Record News (Wichita Falls, Texas). 1970 April 10. “Apollo 13 Flight Materials Produced In Graham Plant.” 5A.

VerPlanck, Christopher. 2003a. “Department of Parks and Recreation form: 7100 San Ramon Road, The Springs Apartments, Alamilla Springs.” P-01-010634, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. ________. 2003b. “Department of Parks and Recreation form: Dublin Pioneer Cemetery.” P-01- 010637, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. ________. 2003c. “Department of Parks and Recreation form: Old St. Raymond’s Church.” P-01- 010635, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. ________. 2003d “Department of Parks and Recreation form: Old Murray School.” P-01- 010636, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. ________. 2003e “Department of Parks and Recreation form: Green’s Store.” P-01-008150, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. ________. 2003f “Department of Parks and Recreation form: 11711 Dublin Boulevard.” P-01- 010656, on file at Northwest Information Center, Sonoma State University, Sonoma, CA. 279
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Section 4: Energy

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

4. ENERGY. Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
X
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
X
Environmental Setting
The proposed Project is located in the City of Dublin within Alameda County. Electric and natural gas services to Alameda County are provided by Pacific Gas & Electric Company (PG&E).

In 2021, PG&E delivered approximately 78,588 gigawatt-hours of electricity within its service area (California Energy Commission 2023a). PG&E’s total natural gas throughput was approximately 4,467 million therms in 2021 (California Energy Commission 2023b). PG&E provides power from a variety of sources: biomass and biowaste, geothermal, small and large hydroelectric, solar, wind, natural gas, and nuclear (PG&E 2021).

In 2018, East Bay Community Energy (EBCE) began serving Dublin residential, business, and municipal electricity customers. To help meet the greenhouse gas (GHG) emissions reductions goals set in the City of Dublin’s Climate Action Plan 2030 and Beyond (discussed below), the Dublin City Council voted in January 2021 to set the default electricity option for Dublin residences to EBCE’s Renewable 100 service, which began in January 2022, and is sourced from California wind and solar facilities, including a new wind farm in Livermore. Customers can change their EBCE service or return to PG&E service at any time. All municipal electric accounts in Dublin have been powered by Renewable 100 since July 2019 (City of Dublin 2023).

Transportation, such as gasoline and diesel fuel consumption, is also an energy-consuming sector, and applicable to the proposed Project (diesel and gasoline fuel consumption during construction and operational activities). Transportation is the largest energy-consuming sector in California, accounting for approximately 34 percent of all energy use in the state in 2020 (EIA 2022a). Historically, gasoline and diesel fuel accounted for nearly all transportation-related energy demand; now, however, numerous transportation power options are available, including ethanol, natural gas, electricity, and hydrogen. Nonetheless, despite advancements in alternative fuels and clean-vehicle technologies, gasoline and diesel remain the primary fuels used for transportation in California, with 12.7 billion gasoline gallon equivalents of petroleum (GGEs) consumed in 2021 and 3.7 billion GGEs of diesel consumed in 2020 (DOE 2023). 280
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Regulatory Framework
Energy Policy and Conservation Act of 1975. The Energy Policy and Conservation Act of 1975 established the first fuel economy standards for on-road motor vehicles sold in the United States. The National Highway Traffic and Safety Administration is responsible for establishing standards for vehicles and revising the existing standards. The Corporate Average Fuel Economy (CAFE) program was created to determine vehicle manufacturers’ compliance with the fuel economy standards. The EPA administers the testing program that generates the fuel economy data.

Energy Policy Acts of 1992 and 2005. The Energy Policy Act of 1992 was enacted to reduce dependence on imported petroleum and improve air quality by addressing all aspects of energy supply and demand, including alternative fuels, renewable energy, and energy efficiency. This law requires certain federal, state, and local government and private fleets to purchase alternate fuel vehicles. The act also defines “alternative fuels” to include fuels such as ethanol, natural gas, propane, hydrogen, electricity, and biodiesel.

The Energy Policy Act of 2005 was enacted on August 8, 2005. This law set federal energy management requirements for energy-efficient product procurement, energy savings performance contracts, building performance standards, renewable energy requirements, and use of alternative fuels. The Energy Policy Act of 2005 also amends existing regulations, including fuel economy testing procedures.

Energy Independence and Security Act of 2007. Signed into law in December 2007, the Energy Independence and Security Act was enacted to increase the production of clean renewable fuels; increase the efficiency of products, buildings, and vehicles; improve the federal government’s energy performance; and increase U.S. energy security, develop renewable fuel production, and improve vehicle fuel economy. The Energy Independence and Security Act included the first increase in fuel economy standards for passenger cars since 1975. The act also included a new energy grant program for use by local governments in implementing energyefficiency initiatives, as well as a variety of green building incentives and programs.

Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards. On May 7, 2010, the final Light-Duty Vehicle GHG Emissions Standards and CAFE Standards were published in the Federal Register. Phase 1 of the emissions standards required that model year 2012–2016 vehicles meet an estimated combined average emissions level of 250 grams of carbon dioxide (CO2) per mile, which is equivalent to 35.5 miles per gallon, if the automobile industry were to meet this CO2 level solely through fuel economy improvements.

On March 31, 2022, the National Highway Traffic Safety Administration finalized the CAFE Standards for model years 2024-2026. The final rule establishes standards that would require an industry-wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8 percent annually for model years 2024 and 2025, and 10 percent annually for model year 2026. 281
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Heavy-Duty Engine and Vehicle Standards. In September 2011, in response to a Presidential Memorandum issued in May 2010, EPA in coordination with National Highway Traffic Safety Administration (NHSTA) issued GHG emissions and fuel economy standards for medium and heavy duty trucks manufactured in model years 2014-2018, known as Phase 1 GHG Rule.

In October 2016, EPA and NHTSA jointly finalized Phase 2 standards for medium- and heavyduty vehicles through model year 2027 that will improve fuel efficiency and cut carbon pollution to reduce the impacts of climate change, while bolstering energy security and spurring manufacturing innovation.

On December 20, 2022, EPA adopted a final rule, “Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards,” that sets stronger emissions standards to further reduce air pollution, including pollutants that create ozone and particulate matter, from heavy-duty vehicles and engines starting in model year 2027. The final program includes new, more stringent emissions standards that cover a wider range of heavy-duty engine operating conditions compared to today's standards, and it requires these more stringent emissions standards to be met for a longer period of time of when these engines operate on the road.

This final rule is consistent with President Biden’s Executive Order, “Strengthening American Leadership in Clean Cars and Trucks” and is the first step in the Clean Trucks Plan.

City of Dublin General Plan. The City of Dublin General Plan, adopted in 1985 and amended in 2022, includes an Environmental Resources Management: Energy Conservation Element. The following implementing policies related to energy efficiency and conservation in new development would be applicable to the proposed Project (City of Dublin 2022):
x 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, [light emitting diode] 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.
x New development projects shall install LED streetlights in compliance with the City’s LED light standard.
x In new commercial and residential parking lots, require the installation of conduit to serve EV parking spaces to enable the easier installation of future charging stations. x 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). x 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.
x 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.
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x Promote and encourage photovoltaic demonstration projects in association with new development.

City of Dublin Climate Action Plan 2030. The City of Dublin adopted its Climate Action Plan 2030 and Beyond (CAP 2030) in September 2020, as a guiding document to identify ways in which the community and City can reduce GHG emissions, meet Dublin’s long-term climate action goals, and promote a healthy, prosperous community. The CAP 2030 focuses on the following strategies: 100 percent renewable and carbon-free electricity; building efficiency and electrification; sustainable mobility and land use; materials and waste management; and municipal leadership measures (City of Dublin 2020).

Project Impacts and Mitigation Measures
(a) Wasteful, inefficient, or unnecessary consumption of energy resources (Less Than Significant Impact With Mitigation Incorporated)
Energy efficiency is a possible indicator of environmental impacts. The actual adverse physical environmental effects of energy use and the efficiency of energy use are detailed throughout this EIR and the Initial Study in Appendix A in the environmental topic-specific sections. For example, the use of energy for transportation sources (including construction equipment and haul trucks) leads to GHG emissions, the impacts of which are addressed in Section 3.9, Greenhouse Gas Emissions. There is no physical environmental effect associated with energy use that is not addressed in the environmental topic-specific sections of this EIR and the Initial Study in Appendix A.

The proposed Project activities would increase energy consumption for the duration of construction in the form of fossil fuels (e.g., gasoline, diesel fuel). Transportation energy use during construction would come from the transport and use of construction equipment (offroad), delivery and haul trucks (on-road), and construction employee passenger vehicles (onroad). Construction-related transportation energy use depends on the type and number of trips, vehicle miles traveled, fuel efficiency of vehicles, and travel mode. Most of the construction equipment used during demolition and construction activities would be gas- or diesel-powered equipment. The use of fuel by on-road and off-road vehicles would be temporary and would fluctuate according to the phase of construction. Construction fuel use under the proposed Project would cease upon completion of construction activities.

The annual energy consumption was estimated using the CalEEMod CO2 emissions calculations for the proposed construction activities, application of the U.S. Energy Information Administration’s CO2 emissions coefficients (EIA 2022b) to estimate fuel consumption for construction activities, and The Climate Registry’s 2022 Default Emission Factors (The Climate Registry 2022) to estimate the energy content per fuel type. Additional modeling assumptions and more details are provided in Section 3.4, Air Quality, and Appendix D. Construction and operational energy consumption associated with the proposed Project is summarized in Table 7: Construction and Operational Energy Consumption.
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Table 7: Construction and Operational Energy Consumption Energy Consuming Activity Energy
Requirement
Unit Annual Energy
Consumption
(MMBtu)
Construction Diesel Consumption (amortized)1 1,278 gal/year 176 Construction Gasoline Consumption (amortized)1 201 gal/year 25 Construction Fuel Subtotal (amortized) - - 202
Building Electricity Consumption 2 1,209,922 kWh/year 4,128 Building Operations Energy Subtotal - - 4,128
Transportation Electricity Consumption 2 32,528 kWh/year 111 Transportation Diesel Consumption 2 6,174 gal/year 852
Transportation Gasoline Consumption 2 49,324 gal/year 6,166 Transportation Subtotal - - 7,128
Total Project Energy Requirement - - 11,458
Existing Land Uses Energy Requirement - - 12,236
Net Project Total - - (778)
Notes: gal/year = gallons per year; kWh/year = kilowatt hours per year; MMBtu = million British thermal units 1 Since construction-related energy demand would cease upon completion of construction, energy demand associated with construction of the proposed Project was amortized over the proposed Project lifetime. The assumed amortization period is 30 years, based on the typically assumed project lifetime based on other air districts (e.g., South Coast Air Quality Management District [2008]). 2 The operational energy consumption estimates assumed the proposed Project would include 18,000 square feet of office space, 36,500 square feet of light industrial space, and 70,804 square feet of warehousing space. Based on the latest site plan, it is anticipated the proposed Project would include 18,000 square feet of office space, 30,000 square feet of light industrial space, and 77,304 square feet of warehousing space. As light industrial land uses generate higher daily vehicle trips than warehousing land uses, daily vehicle trips and the associated energy consumption due to fuel usage is anticipated to be lower (i.e., the energy estimates assumed the proposed Project would generate 494 daily trips, based on the 2022 Transportation Impact Study (W-Trans 2022); however, the proposed Project based on the updated site plan is anticipated to generate approximately 468 daily trips). Similarly, based on California Emissions Estimator Model (CalEEMod) default data, building energy consumption rates for light industrial land uses are higher than building energy consumption rates for warehousing space. As such, the energy consumption presented above is conservative since fuel consumption and electricity consumption would be lower.

Therefore, implementation of the proposed Project would result in a higher net reduction in energy consumption compared to existing conditions.

Based on the anticipated phasing of the construction activities, the anticipated equipment and construction work staff, the temporary nature of construction, and the project type, the proposed Project would not include unusual characteristics that would necessitate the use of construction equipment that is less energy-efficient than the equipment used at comparable construction sites.

In addition, construction contractors are required, in accordance with Mitigation Measure AQ1 and the CARB Airborne Toxic Control Measure for Diesel-Fueled Commercial Motor Vehicle Idling, to minimize the idling time of construction equipment and trucks by shutting equipment off when it’s not in use or reducing the idling time to 5 minutes. Per Mitigation Measure AQ-1, construction contractors would also be required to maintain and properly tune all construction equipment in accordance with the manufacturer’s specification. These required practices would limit wasteful and unnecessary energy consumption.
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The proposed Project would redevelop an existing industrial building consisting of research and development land uses, with a new building approximately double the size of the existing building, consisting of office, warehouse, and light industrial land uses. Although the proposed Project is approximately double the size of the existing building, as shown in Table 7 the proposed Project would result in a net reduction in energy consumption, primarily related to improved building energy standards and eliminating natural gas infrastructure.

Therefore, energy consumption associated with construction and operation of the proposed Project would not be inefficient, wasteful, or unnecessary with Mitigation Measure AQ-1 incorporated. This impact would be less than significant with mitigation. (b) Conflict with local plan for renewable energy (No Impact) The proposed Project would not conflict with or obstruct any state or local plans for renewable energy or energy efficiency and there would be no impact. See the Initial Study in Appendix A for the complete analysis.

Source(s)
California Energy Commission (CEC). 2023a. 2021 Electricity Consumption by Entity: Pacific Gas & Electric Company. Available online: http://www.ecdms.energy.ca.gov/elecbyutil.aspx.

Accessed February 2023.
____. 2023b. 2021 Gas Consumption by Entity: Pacific Gas & Electric Company. Available online:
http://www.ecdms.energy.ca.gov/gasbyutil.aspx. Accessed February 2023.

City of Dublin. 2020. Climate Action Plan 2030 and Beyond. September. Available online:
https://dublin.ca.gov/DocumentCenter/View/24447/Climate-Action-Plan-2030-AndBeyond. Accessed March 2023. ____. 2022. General Plan. Available online:
https://www.dublin.ca.gov/DocumentCenter/View/30287/General-Plan-Update04192022-WEB. Accessed March 2023. ____. 2023. Energy. Available online: https://dublin.ca.gov/2032/Energy. Accessed March 2023.

Pacific Gas & Electric Company (PG&E). 2021. Power Content Label. Available online:
https://www.energy.ca.gov/filebrowser/download/4653. Accessed February 2023.

South Coast Air Quality Management District. 2008. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold. Available online:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)- ceqa-significance-thresholds/ghgboardsynopsis.pdf?sfvrsn=2. Accessed February 2023.

The Climate Registry. 2022. Default Emission Factor Document. May. Available online:
https://theclimateregistry.org/wp-content/uploads/2022/11/2022-Default-EmissionFactors-Final.pdf. Accessed February 2023. 285
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United States Department of Energy (DOE). 2023. Alternative Fuels Data Center: California Transportation Data for Alternative Fuels and Vehicles. Available online:
https://afdc.energy.gov/states/ca. Accessed April 2023.

United States Energy Information Administration (EIA). 2022a. State Profile and Energy Estimates: California. Available online: https://www.eia.gov/state/?sid=CA#tabs-2.

Accessed February 2023.
____. 2022b. Carbon Dioxide Emissions Coefficients. October. Available online:
https://www.eia.gov/environment/emissions/co2_vol_mass.php. Accessed February 2023.

W Traffic Engineering Transportation Planning (W-Trans). 2022. Final Transportation Impact Study for the Hexcel Redevelopment Project. December.

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Section 5: Geology and Soils

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

5. GEOLOGY AND SOILS. Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death
involving:
i) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault?
X
ii) Strong seismic ground shaking? X
iii) Seismic-related ground failure, including
liquefaction?
X
iv) Landslides? X
b) Result in substantial soil erosion or the loss of topsoil? X c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
X
d) Would the project be located on expansive soil, as
defined in Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or indirect risks to life or property?
X
e) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available
for the disposal of waste water?
X
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
X
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Environmental Setting
Seismic Hazards
The Project site is situated in a seismically active area within the Diablo Range, along the margin of the eastern Diablo Hills and the western edge of the Livermore Valley. The fault trace of the active Calaveras Fault is approximately 965 feet east of the Project site, and the Alquist-Priolo Earthquake Fault Zone associated with the Calaveras Fault is approximately 450 feet east of the Project site (DOC 2023). The active Pleasanton Fault is approximately 2.4 miles east of the Project site (Jennings and Bryant 2010). Other active faults in the Project region include a portion of the Las Positas Fault (approximately 11.7 miles to the southeast), the Greenville Fault (approximately 12.5 miles to the northeast), and the Hayward Fault Zone (approximately 7.3 miles to the southwest).

The Project site is located within an Earthquake Zone of Required Investigation for liquefaction as delineated by the California Geological Survey (CGS) (DOC 2023).

Soils
Based on a review of Natural Resource Conservation Service (NRCS) soil survey data, native soil at the Project site consists of the Yolo loam (calcareous substratum, 0 to 6 percent slopes) soil type (NRCS 2022).

A preliminary geotechnical investigation was prepared for the proposed Project, which included four soil borings in the developed portion of the Project site north of Dublin Creek (Cornerstone Earth Group [Cornerstone] 2022). The results of soil borings indicated that the near-surface soils consist of undocumented artificial fill consisting of clay with variable amounts of sand and gravel, and clayey sand with gravel, to depths ranging from 1.5 to 5 feet below the ground surface (bgs). Below the artificial fill, clay with sand and silt was present to the maximum soil boring depth of 40 feet bgs.

Paleontological Resources
The near-surface soils at the Project site consist of artificial fill material to depths ranging from

1.5 to 5 feet bgs (Cornerstone 2022). Native sediments at the Project site beneath the artificial fill consist of the late Miocene to early Pliocene-age Contra Costa Group, which includes the Orinda and Moraga Formations. The Contra Costa Group is comprised of nonmarine sedimentary rocks including sandstone, conglomerate, shale, and minor claystone, limestone, and tuff (Wagner et al. 1991).

A search of the University of California Museum of Paleontology (UCMP) database indicates there are over 40 recorded vertebrate fossil sites from within the Contra Costa Group (UCMP 2023). Most of these sites are in Contra Costa County; however, five of the sites are within Alameda County. The closest recorded vertebrate fossil site from within the Contra Costa Group is Bolenas Creek, approximately 6.5 miles northwest of the Project site (UCMP 2023). 289
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Paleontological Sensitivity Analysis
A paleontologically sensitive geologic formation is one that is rated high for potential paleontological productivity (i.e., the recorded abundance and types of fossil specimens, and the number of previously recorded fossil sites) and is known to have produced unique, scientifically important fossils. Exposures of a specific geologic formation at any given Project site are most likely to yield fossil remains representing particular species or quantities similar to those previously recorded from that geologic formation in other locations. Therefore, the paleontological sensitivity determination of a rock formation is based primarily on the types and numbers of fossils that have been previously recorded from that formation.

In its standard guidelines for assessment and mitigation of adverse impacts on paleontological resources, the Society of Vertebrate Paleontology (SVP 2010) established four categories of sensitivity for paleontological resources: high, low, no, and undetermined. Areas where fossils have been previously found are considered to have a high sensitivity and a high potential to produce fossils. Areas that are not sedimentary in origin and that have not been known to produce fossils in the past typically are considered to have low sensitivity. Areas consisting of high-grade metamorphic rocks (e.g., gneisses and schists) and plutonic igneous rocks (e.g., granites and diorites) are considered to have no sensitivity. Areas that have not had any previous paleontological resource surveys or fossil finds are considered to be of undetermined sensitivity until surveys are performed. After reconnaissance surveys, a qualified paleontologist can determine whether the area of undetermined sensitivity should be categorized as having high, low, or no sensitivity. In keeping with the SVP significance criteria, all vertebrate fossils are generally categorized as being of potentially significant scientific value.

The near-surface artificial fill consists of materials that were excavated from another location, transported to the Project site, and then graded and compacted. During the excavation and subsequent construction process, any fossils that may have been present in the original materials would have been destroyed. Therefore, the artificial fill is not paleontologically sensitive.

Because of the large number of vertebrate fossils that have been recovered from the Contra Costa Group, it is considered to be of high paleontological sensitivity.

Regulatory Framework
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act (Alquist-Priolo Act) (PRC Sections 2621–2630) was passed in 1972 to reduce the hazard of surface faulting to structures designed for human occupancy. The Alquist-Priolo Act requires the State Geologist to establish regulatory zones known as Earthquake Fault Zones around the surface traces of active faults and to issue appropriate maps. Before a project can be permitted in a designated Alquist-Priolo Earthquake Fault Zone, cities and counties must require a geologic investigation to demonstrate that proposed structures would not be constructed across active faults. 290
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Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act of 1990 (PRC Sections 2690–2699.6) addresses earthquake hazards from non-surface fault rupture, including liquefaction and seismically induced landslides. The act established a mapping program for areas that have the potential for liquefaction, landslide, strong ground shaking, or other earthquake and geologic hazards. The act also specifies that the lead agency for a project may withhold development permits until geologic or soils investigations are conducted for specific sites and mitigation measures are incorporated into plans to reduce hazards associated with seismicity and unstable soils.

California Building Standards Code
The California Building Standards Code (CBC) (Title 24 of the California Code of Regulations) provides minimum standards for building design in California. The CBC applies to building design and construction in the state and is based on the federal Uniform Building Code (UBC) used widely throughout the country (generally adopted on a state-by-state or district-by-district basis). The CBC has been modified for California conditions with numerous more detailed or more stringent regulations. The State earthquake protection law (California Health and Safety Code, Section 19100 et seq.) requires that structures be designed to resist stresses produced by lateral forces caused by earthquakes. The CBC requires that any structure designed for a project site undergo a seismic design evaluation that assigns the structure to one of six categories, A–F; Category F structures require the most earthquake-resistant design. The CBC philosophy focuses on “collapse prevention,” meaning that structures are to be designed to prevent collapse during the maximum level of ground shaking that could reasonably be expected to occur at a site. CBC Chapter 16 specifies exactly how each seismic-design category is to be determined on a site-specific basis, based on site-specific soil characteristics and proximity to potential seismic hazards. CBC Chapter 18 regulates the analysis of expansive soils, slope instability, liquefaction, and surface rupture attributable to faulting or lateral spreading, along with an evaluation of lateral pressures on basement and retaining walls, liquefaction and loss of soil strength, and lateral movement or reduction of the foundation’s soil-bearing capacity.

Dublin Municipal Code Section Chapter 7.16, Grading Regulations The City of Dublin Grading Ordinance (Municipal Code Chapter 7.16) requires a geologic/soil investigation report, preliminary grading plans, proposed provisions for storm drainage control, and any existing or proposed flood control in the vicinity of the grading. A conceptual plan for erosion and sediment control is also required, including both temporary facilities and long-term site stabilization features such as planting or seeding for the area affected by the proposed grading. Chapter 7.16 prohibits grading operations during the rainy season except upon a clear demonstration, to the satisfaction of the Director of Public Works, that at no stage of the work will there be any substantial risk of increased sediment discharge from the site. Should grading be permitted during the rainy season, the smallest practicable area of erodible land must be exposed at any one time during grading operations and the time of exposure must be minimized.
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City of Dublin General Plan
Chapter 8.0 of the City of Dublin General Plan outlines policies and programs related to seismic safety, safety and emergency preparedness. The following policies related to geology and soils are applicable to the proposed project:
x Guiding Policy 8.2.1.A.1. Geologic hazards shall be mitigated or development shall be located away from geologic hazards in order to preserve life, protect property, and reasonably limit the financial risks to the City of Dublin and other public agencies that would result from damage to poorly located public facilities. x Implementing Policy 8.2.1.B.1. Structural and Grading Requirements a. All structures shall be designed to the standards delineated in the Dublin Building Code and Dublin’s Grading Ordinance. A “design earthquake” shall be established by an engineering geologist for each structure for which ground shaking is a significant design factor.
b. Structures intended for human occupancy shall be at least 50 feet from any active fault trace; freestanding garages and storage structures may be as close as 25 feet. These distances may be reduced based on adequate exploration to accurately locate the fault trace. Generally, facilities should not be built astride potential rupture zones, although certain low risk facilities may be considered. Critical facilities that must cross a fault, such as oil, gas, and water lines, shall be designed to accommodate the maximum expected offset from fault rupture. Site specific evaluations shall determine the maximum credible offset.

Project Impacts and Mitigation Measures
(a) Seismic hazards (No Impact to Less than Significant Impact) The impact from seismic hazards such as seismic ground shaking, liquefaction, lateral spreading, landslides and settlement would be less than significant. There would be no impact related to surface fault rupture as the Project site is not in an Alquist-Priolo Earthquake Fault Zone. See the Initial Study in Appendix A for the complete analysis. (b) Erosion/topsoil loss (Less than Significant)
The Project applicant is required by law to prepare a SWPPP and implement site-specific BMPs specifically designed to prevent erosion. Furthermore, the Project applicant is required to implement the provisions of City Municipal Code Chapter 7.16, which require grading and drainage plans that identify measures to reduce erosion, and which generally prohibits grading activities during the winter rainy season. Therefore, impacts from construction-related soil erosion would be less than significant. See the Initial Study in Appendix A for the complete analysis.
(c-d) Soil stability (Less Than Significant Impact)
Design review performed through the City’s permitting process would ensure compliance with the requirements of the CBC and the City’s building standards. Therefore, because the Project 292
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would implement measures to comply with the CBC and the City’s building standards, impacts from construction and operation related to unstable soils and soil expansion would be less than significant. See the Initial Study in Appendix A for the complete analysis. (e) Soil capability to support wastewater disposal, including septic (No Impact) The proposed Project would not require installation of a septic system or alternative wastewater disposal system; therefore, there would be no impact from Project construction or operation. See the Initial Study in Appendix A for the complete analysis. (f) Unique geologic feature/paleontological resources (No Impact to Less Than Significant With Mitigation)
Unique Geologic Feature
A unique geologic feature consists of a major natural element that stands out in the landscape, such as a large and scenic river, gorge, waterfall, volcanic cinder cone, lava field, or glacier.

There are no unique geologic features at the Project site or within the Project viewshed. Thus, there would be no impact to unique geologic features from Project construction or operation.

Paleontological Resources – Construction
As discussed previously, the Project site is composed of artificial fill to depths ranging from 1.5 to 5 feet, with native Contra Costa Group sediments below the fill. Most grading and earthmoving activities at the Project site would extend to a maximum depth of 2 to 3 feet below the ground surface, and therefore would generally be confined to the artificial fill material, which is not paleontologically sensitive. However, in areas where the artificial fill only extends to 1.5 feet, excavation and grading would encounter the native Contra Costa Group materials, which are of high paleontological sensitivity. Furthermore, excavation to a maximum depth of approximately 12 feet would occur at the proposed on-site stormwater drainage pumps, which would also encounter the paleontologically sensitive Contra Costa Group materials. Therefore, project-related earthmoving activities could result in accidental damage to, or destruction of unique paleontological resources, and this impact would be potentially significant.

Mitigation Measure GEO-1: Avoid Impacts to Unique Paleontological Resources.

To minimize the potential for destruction of or damage to previously unknown unique, scientifically important paleontological resources during earthmoving activities at the Project site, the Project applicant shall do the following:
• Prior to the start of earthmoving activities, retain either a qualified archaeologist or paleontologist to inform all construction personnel involved with earthmoving activities regarding the possibility of encountering fossils, the appearance and types of fossils likely to be seen during construction, and proper notification procedures should fossils be encountered.
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• If paleontological resources are discovered during earthmoving activities, the construction crew shall immediately cease work within 50 feet of the find and notify the Project applicant and the City. The Project applicant shall retain a qualified paleontologist to evaluate the resource and prepare a recovery plan, based on SVP Guidelines. The recovery plan may include, but is not limited to, a field survey, construction monitoring, sampling and data recovery procedures, museum curation for any specimen recovered, and a report of findings.

Recommendations in the recovery plan that are determined by the City (as the CEQA lead agency) to be necessary and feasible shall be implemented before construction activities can resume within 50 feet of the site where the paleontological resource or resources were discovered.

Mitigation Measure GEO-1 would reduce potential impacts to unique paleontological resources because construction workers would be alerted to the possibility of encountering paleontological resources and, in the event that resources were discovered, construction would be halted, and fossil specimens would be recovered and recorded and would undergo appropriate curation. Therefore, with implementation of Mitigation Measure GEO-1, potential construction-related impacts to unique paleontological resources would be less than significant with mitigation.

Paleontological Resources – Operation
Because Project operation would not involve ground-disturbing activities, there would be no impact to unique paleontological resources.

Source(s)
California Department of Conservation (DOC). 2023. DOC Maps Data Viewer—Earthquake Zones of Required Investigation, and Alquist-Priolo Earthquake Fault Zones. Available:
https://maps.conservation.ca.gov/cgs/DataViewer/. Accessed January 11, 2023.

Cornerstone Earth Group (Cornerstone). 2022. Geotechnical Investigation, Dublin Boulevard Industrial, 11711 Dublin Boulevard, Dublin, California. Cornerstone Project No. 681-12-1.

Sunnyvale, CA.

Jennings, C.W. and W.A. Bryant. 2010. 2010 Fault Activity Map of California. Available:
https://maps.conservation.ca.gov/cgs/fam/App/index.html. Accessed January 11, 2022.

Natural Resources Conservation Service (NRCS). 2022. Web Soil Survey. Available:
http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm. Accessed January 11, 2022.

Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. Society of Vertebrate Paleontology, Impact Mitigation Guidelines Revision Committee. 294
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University of California Museum of Paleontology (UCMP). 2023. Paleontological Collections Database. Available: https://ucmpdb.berkeley.edu/about.shtml. Accessed January 25, 2022.

Wagner, D.L., E.J. Bortugno, and R.D. McJunkin. 1991. Geologic Map of the San Francisco-San Jose Quadrangle, California, 1:250,000. Regional Geologic Map Series, Map No. 5A.

California Division of Mines and Geology. Sacramento, CA. 295
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Section 6: Hazards and Hazardous Materials

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

6. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
X
b) 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?
X
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within ¼ mile of an existing or proposed school?
X
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
X
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
X
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
X
g) Expose people or structures, either directly or indirectly, 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?
X
Environmental Setting
The Project site has been used since the 1960s as a research and development facility, which tests epoxy resins and composites primarily for aerospace and other applications. The laboratories were used for small-scale testing, while the building located south of the offices/laboratories (referred to by Hexcel as the “Hi Bay”) was used to test larger quantities of carbon fiber plates. Part of the research activities include testing prefabricated prototype 296
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carbon fiber plates. The research activities include chemical testing and reactions of the carbon fiber plates, as well as climate or extreme condition testing of the plates including extreme heat, cold, pressure, and electrical conditions, and stress testing. A Phase I Environmental Site Assessment (ESA) was performed by Ardent Environmental Group (Ardent) in 2022. The main chemicals used at the site include petroleum oils and lubricants, non-chlorinated solvents, metals (such as chromium and aluminum), and acids. According to waste records and a 1994 chemical inventory, historical chemical uses included halogenated solvents, including 1,1,1- trichloroethane (1,1,1-TCA) and trichloroethene (TCE). Small containers of the different testing chemicals were stored in approximately 10 fire cabinets in a designated Hazardous Waste and Storage Area, while larger quantities of virgin chemicals and wastes were stored in 55-gallon drums in the Hazardous Waste and Storage Area. The following areas of concern were noted in the Phase I ESA (Ardent 2022).
x Area of Chemical Use, Storage, and/or Handling. Chemicals are used, stored, and/or handled in the laboratories (existing and historical), Hi Bay area, and within the hazardous waste and storage area of the site.
x Former 500-Gallon Waste Chromic Acid Underground Storage Tank (UST, Abandoned InPlace in 1988). This Underground Storage Tank (UST) was located immediately east of the Hi Bay portion of the building and was used to containerize waste acid wash reportedly consisting of deionized water, sulfuric acid, and sodium dichromate generated from the etching of aluminum panels. Soil and groundwater in the vicinity of this UST were investigated in the late 1980s under the direction and oversight of the Alameda County Department of Environmental Health (ACDEH). Laboratory results indicated no detectable to low concentrations of hexavalent chromium, trivalent chromium, and aluminum. Based on these results, ACDEH allowed Hexcel to abandon the UST in-place by filling the tank with a cement slurry.
x Recently Removed 520-Gallon Waste Chromic Acid UST (2021). This UST was formerly located immediately east of the on-site hazardous waste and storage area and accepted waste from accidental spills from this area. Floor drains in the hazardous waste and storage area directed any accidental spills of chemicals to the tank. The UST was removed in April 2021 under the direction and oversight of the ACDEH. Following removal, two soil samples were collected from within the UST excavation. Laboratory results indicated no detectable concentrations of total petroleum hydrocarbons, and no detectable to low concentrations of volatile organic compounds (VOCs), namely acetone, at levels that were well below federal and state thresholds. Based on these results, the ACDEH issued a No Further Action letter dated July 20, 2021.
x Asbestos and Lead-Based Paint. The eastern portion of the existing building was constructed in 1962, with subsequent additions over the years. Based on the age of the building, Ardent (2022) concluded that asbestos-containing materials (ACMs) and leadbased paint are likely present.

As part of the Phase I ESA, Ardent (2022) retained Environmental Database Report (EDR) to perform a search of federal, State, and tribal hazardous materials databases, and retained Antea Group to perform a review of identified hazardous materials sites near the Project site. 297
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The database searches included those sites that are identified as part of the Cortese List. The Project is listed in the SWRCB’s GeoTracker database as a Cleanup Program Site; however, cleanup program sites are not considered part of the Cortese List. No hazardous materials sites were determined to represent a hazard for the proposed Project (Ardent 2022).

Regulatory Framework
California Occupational Safety and Health Administration The California Occupational Safety and Health Administration (Cal/OSHA) has the primary responsibility for developing and enforcing workplace safety regulations within California. The California Occupational Safety and Health Administration enforces hazard communication program regulations that contain training and information requirements, including procedures for identifying and labeling hazardous substances, communicating hazard information related to hazardous substances and their handling, and preparation of health and safety plans to protect workers and employees at hazardous waste sites. Cal/OSHA regulations also include requirements for protective clothing, training, and limits on exposure to hazardous materials.

Cal/OSHA also enforces occupational health and safety regulations specific to lead (CCR Title 8 Section 1532.1) and asbestos (CCR Title 8 Section 1529) investigation and abatement.

California Department of Toxic Substances Control
The California Department of Toxic Substances Control (DTSC) implements the State’s hazardous waste management program for the California Environmental Protection Agency.

DTSC has the primary regulatory responsibility, with delegation of enforcement to local jurisdictions that enter into agreements with DTSC, for the management of hazardous materials (including remediation) and the generation, transport, and disposal of hazardous waste under the authority of California’s Hazardous Waste Control Law (California Health and Safety Code Section 25100, et seq.).

San Francisco Bay Regional Water Quality Control Board
The San Francisco Bay RWQCB is authorized by the State Water Resources Control Board to enforce provisions of the Porter-Cologne Water Quality Control Act of 1969. This act gives the San Francisco Bay RWQCB authority to require groundwater investigations when the quality of groundwater or surface waters of the state is threatened and to require remediation of the site, if necessary.

Hazardous Waste Transportation
Statutory requirements governing hazardous waste transportation in California are contained in the California Health and Safety Code, Division 20, Chapter 6.5, Articles 6.5, 6.6, and 13.

Hazardous waste transporters must have a valid registration permit issued by DTSC. In addition, hazardous waste transporters must comply with a variety of other State and federal regulations, including the California Vehicle Code (CCR Title 13); California State Fire Marshal Regulations (CCR Title 19); U.S. Department of Transportation regulations (Title 49 Code of Federal Regulations); and USEPA regulations (Title 40 Code of Federal Regulations). 298
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Bay Area Air Quality Management District
BAAQMD Regulation 11, Rule 2, adopted December 15, 1976, regulates hazardous pollutants from asbestos demolition, renovation, and manufacturing activities. The purpose of the rule is to control emissions of asbestos to the atmosphere during demolition, renovation, milling and manufacturing and establish appropriate waste disposal procedures. The rule sets out specific procedures to be followed and methods for reducing hazards from asbestos-containing materials during such activities.

Senate Bill 1082 – California Environmental Protection Agency’s Unified Program In 1993, Senate Bill 1082 gave the California Environmental Protection Agency (CalEPA) the authority and responsibility to establish a unified hazardous waste and hazardous materials management and regulatory program, commonly referred to as the Unified Program. The Unified Program is overseen by CalEPA with support from DTSC, RWQCBs, the Office of Emergency Services (OES), and the State Fire Marshal. The purpose of this program is to consolidate and coordinate hazardous materials and hazardous waste programs, and to ensure that they are consistently implemented throughout the state. The Unified Program includes:

Hazardous Materials Release Response Plans and Inventories (Business Plans), California Accidental Release Prevention Program, Underground Storage Tank Program, Aboveground Petroleum Storage Act Program, Hazardous Waste Generator and Onsite Hazardous Waste Treatment (tiered permitting) Programs, and California Uniform Fire Code Hazardous Material Management Plans and Hazardous Material Inventory Statements.

State law requires county and local agencies to implement the Unified Program. The agency in charge of implementing the program is called the Certified Unified Program Agency (CUPA). The Alameda County Department of Environmental Health is the designated CUPA for the county. In addition to the CUPA, other local agencies, such as the City of Dublin, help to implement the Unified Program.

City of Dublin General Plan
Section 8.3.4 of the General Plan outlines policies and programs related to hazards and hazardous materials. The following policies related to hazardous materials are applicable to the proposed Project:
x Guiding Policy 8.3.4.1.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.
x Guiding Policy 8.3.4.1.A.2. Minimize the risk of exposure to hazardous materials from contaminated sites.
x Implementing Policy 8.3.4.1.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. 299
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Project Impacts and Mitigation Measures
(a) Exposure to hazardous materials (Less than Significant Impact) Since local, state and federal regulations will be complied with during project construction and operation, these impacts will be less than significant. See the Initial Study in Appendix A for the complete analysis.
(b) Upset/Accident (Less Than Significant with Mitigation Incorporated) GeoTracker case no. T0600191495 for Hexcel Corporation was related to the former 500-gallon waste chromic acid UST that was abandoned in place in 1988 (discussed above in the Environmental Setting). The case was closed in 2008. Per the ACDEH, when this UST is encountered during demolition it can be removed and disposed of as construction debris (Ardent 2022).

With regards to the 520-gallon waste chromic acid UST that was removed in 2021, because contaminants in soil samples in the tank vicinity were very low (well below regulatory thresholds), the ACDEH issued a No Further Action letter. Thus, the very minor soil contamination does not represent a human health or environmental hazard.

Ardent (2022) recommended that a subsurface investigation should be completed in the vicinity of the on-site areas of chemical use, storage, and handling to assess whether a release has occurred. If soil or groundwater have been previously contaminated at levels that exceed regulatory thresholds, this would represent a significant human health and environmental hazard because excavation work would be required during construction that could release these hazardous materials. Furthermore, the demolition of the existing building could expose workers and the environment to hazardous materials such as lead paint and/or asbestos.

Therefore, these construction-related impacts are considered potentially significant.

Mitigation Measure HAZMAT-1: Perform a Phase II Environmental Site Assessment. • Prior to the start of earthmoving activities at the Project site, the Project applicant shall retain the services of a qualified remediation firm to perform a Phase II Environmental Site Assessment (ESA). The Phase II ESA shall be limited to only those areas where chemical use, storage, and handling have previously occurred. Soil borings shall be obtained as part of the Phase II ESA, along with groundwater samples if necessary. The samples shall be submitted to a laboratory for environmental testing and the results shall be reported in the Phase II ESA, copies of which shall be provided to the Alameda County Department of Environmental Health (ACDEH) and the City of Dublin Building Department. If there are no detections of constituents of concern, or the amounts are below regulatory agency threshold levels, no further actions shall be required.
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• If the results of laboratory analyses from the Phase II ESA demonstrate that constituents of concern are present at levels that exceed regulatory agency threshold levels, the Project applicant shall consult with ACDEH (and other regulatory agencies such as the SWRCB if necessary) regarding the necessary actions for remediation. All necessary remedial activities shall be completed by the Project applicant, with a certification by the lead agency with remedial oversight (e.g., ACDEH or SWRCB) that no further action is required, prior to the start of construction activities at the Project site.

Mitigation Measure HAZMAT-2: Perform Sampling of Materials To Be Demolished.

Prior to demolition of any building in the project area, the building shall be sampled to determine if the building contains lead paint and/or asbestos. If either of the materials are determined to be present, they shall be handled and disposed of as a hazardous material and in compliance with all applicable local, state, and federal regulations.

Mitigation Measure HAZMAT-1 would reduce potential impacts from exposure to on-site hazardous materials because soil (and groundwater, if necessary) testing would be performed, and if contamination is found to be present, any necessary remediation would be completed prior to the start of Project-related earthmoving activities. Mitigation Measure HAZMAT-2 would sample materials before demolition would occur, and if hazardous materials such as lead paint and asbestos are to be found, the would be handled and disposed in compliance to applicable regulations. Therefore, with implementation of Mitigation Measure HAZMAT-1 and HAZMAT-2, potential construction-related impacts from accidental exposure to hazardous materials would be less than significant with mitigation.

Any use of hazardous materials during project operation would be required to comply with the manufacturer’s labeling instructions and (if applicable) would be required to prepare Hazardous Materials Release Response Plans and Inventories (Business Plans) comply with the requirements of Hazardous Waste Generator (tiered permitting) Programs. Therefore, upset and accident conditions involving the release of hazardous materials into the environment during Project operation would be less than significant during project operation. (c) Hazardous materials near schools (No Impact)
There are no K-12 schools within 0.5 mile of the Project site. Thus, Project construction and operation would result in no impact from handling of hazardous materials near a school. See Initial Study in Appendix A.
(d) Hazardous materials list (No Impact)
Because the Project site is not listed on the Cortese list, there would be no impact. See Initial Study in Appendix A.
(e) Proximity to a public airport (No Impact)
The Livermore Municipal Airport is approximately 6 miles east of the Project site and outside of the airport’s Airport Influence Area (Alameda County 2012). Thus, Project construction and 301
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operation would result in no impact from airport safety or noise hazards. See Initial Study in Appendix A.
(f) Impair implementation of an emergency response plan or emergency evacuation plan (No Impact)
All construction materials would be staged on-site, and therefore no temporary lane closures along Dublin Boulevard would be required during Project construction that could impede emergency access or hinder emergency evacuation. For Project operation, planned emergency access throughout the Project site would be reviewed by the City of Dublin Building Department and the Fire Department to ensure that appropriate widths and turning radii area are provided for emergency vehicles. Thus, Project construction and operation would result in no impact from impairment of emergency response or evacuation plans. See Initial Study in Appendix A.
(g) Expose people or structures to wildland fires (Less Than Significant Impact) The proposed building would be constructed according to CBC, the California Fire Code and City of Dublin codes, and ordinances and regulations to minimize fire hazards, including fire prevention and suppression measures; fire hydrants and sprinkler systems; emergency access; and other similar requirements. Therefore, impacts would be less than significant. See Initial Study in Appendix A.

Source(s)
Alameda County. 2012. Livermore Executive Airport. Airport Land Use Compatibility Plan.

Ardent Environmental Group, Inc. 2022. Phase I Environmental Site Assessment, Hexcel Corporation Facility, 11711 Dublin Boulevard, Dublin, California. Ardent Project No. 101327001.

State Water Resources Control Board (SWRCB). 2023. GeoTracker. Available:
https://geotracker.waterboards.ca.gov/. Accessed January 17, 2023.

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Section 7: Tribal Cultural Resources

ENVIRONMENTAL IMPACTS
Issues
Significant
and
Unavoidabl
e
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

7. TRIBAL CULTURAL RESOURCES. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section
5020.1(k), or
X
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision I of Public Resources Code Section 5024.1. In applying the
criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native
American tribe.

X
The analysis in this section considers impacts to tribal cultural resources associated with the implementation of the proposed Project. This section includes a brief summary of available ethnographic background information, the results of consultation with two California Native American tribes that are traditionally and culturally affiliated with the proposed Project area, and the Project’s potential impacts on tribal cultural resources.

Environmental Setting
The Project site is located in the Amador Valley, along the north bank of Dublin Creek. The modern address is 11711 Dublin Boulevard, located in the City of Dublin, Alameda County, California. The property is approximately 8.81 acres. The project site is located within the Dublin Village Historic Area Specific Plan, with the Dublin Heritage Park and Museums and Dublin Pioneer Cemetery to the east; I-580 to the south; and a business park to the west.

Dublin Creek borders the north side of the property.

Ethnographic Context
The project area is within the tribal territory of the Chochenyo Ohlone (Milliken et al. 2007).

The Ohlone are a linguistically defined group, comprised of several autonomous groups that spoke at least eight different but related languages. The territory of the Ohlone people extends along the coast from the San Francisco Bay to the Big Sur River and 50 to 60 miles east, 304
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including the valleys that make up the Tri-Valley area, where the City of Dublin is now located (Levy 1978:485–486).

At the time of contact, the Ohlone were semi-sedentary hunters and gatherers. Controlled burning was regularly conducted to modify the landscape and optimize resource production.

The Ohlone used tule balsas for watercraft, and bows and arrows, cordage, and bone and groundstone tools to procure and process foodstuffs. They hunted terrestrial game, such as mule deer, tule elk, and pronghorn antelope. Traps were set for smaller game, such as rabbit and quail. Grasshoppers and other insect foods were collected during group drives. Waterfowl were a very important part of the diet and were trapped along the tidal marshes. Freshwater fish and marine resources, such as salmon, steelhead, school fish, shellfish, and kelp, were harvested and traded. Plant foods were also very important, including acorns, buckeyes, nuts, seeds, roots, tubers, berries, and fruits (Levy 1978:491-493, Lightfoot and Parrish 2009).

The Ohlone were politically organized in autonomous, extended communities of approximately 200 to 400 people, each having a designated territory. Each group typically included three to five semi-permanent villages (Milliken et al. 2007). Kroeber referred to these groups as “tribelets” (Kroeber 1925). At the time of contact, the Pelnen Tribe lived in the western Livermore Valley, in the area of Pleasanton and south Dublin. The Seunen Tribe lived in north Dublin, up to the San Ramon area (Milliken 1995). Both the Pelnen and Seunen are part of the larger Chochenyo Ohlone linguistic group (Milliken et al. 2007).

Despite independent governance, these “triblets” were a network for trade and were often interlinked by marriage. The role of chief could be held by a man or a woman. Duties of the chief included providing for visitors, directing ceremonial activities, and leading fishing, hunting, gathering, and warfare expeditions. The chief served as the leader of a council of elders, who were advisors to the community (Levy 1978).

Ohlone villages in the Late Period included domed houses with central hearths, thatched with tule, grass, or other vegetal material and bound with strong, flexible willow branches.

Permanent settlements were usually placed on high ground. Sweathouses were built along streambanks, and were semi-subterranean with a thatched domed roof. Dance houses were large, circular or oval domed structures, also with thatched walls and roof. Villages also typically included an assembly house which was large enough to accommodate all the inhabitants of the village (Levy 1978).

Regulatory Framework
Tribal cultural resources include sites, features, places, cultural landscapes, sacred places, and objects, with cultural value to a California Native American tribe, that are also included in or determined to be eligible for inclusion in the California Register of Historical Resources or included in a local register of historical resources. (PRC 21074 (a)(1)). Tribal cultural resources may also be resources that are determined by a lead agency such as the City of Dublin, in its discretion and supported by substantial evidence, to be significant pursuant to the historical register criteria. (PRC 21074 (a)(2), citing (PRC 5024.1). In those cases, the lead agency 305
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considers the significance of the resource to a California Native American tribe in making its determination. Tribal cultural resources may contain physical cultural items or may be places or contributing elements within a tribal cultural resources landscape, such as gathering places, sacred sites, landscape features, culturally significant plants, or other locations that are related to the religious and cultural practices, traditions, beliefs, lifeways, arts, crafts, or social institutions of a living tribal community. This category of resources under CEQA recognizes that tribes may have unique knowledge, expertise, and information about tribal cultural resources that are important to the self-identity of tribal nations that can only be identified by the relevant tribe, thus requiring consultation under CEQA pursuant to Assembly Bill (AB) 52.

Historical resources, unique archaeological resources, or non-unique archaeological resources may also be tribal cultural resources if they meet the criteria of PRC 21074.

State
California Environmental Quality Act (“CEQA”)
California Environmental Quality Act (CEQA) requires lead agencies to consider whether projects would impact tribal cultural resources as a separate category of environmental analysis. Tribal cultural resources may or may not also be archaeological or historical resources.

For clarity, archaeological and historical resources are addressed in the cultural resources chapter. In some cases, tribal cultural resources are viewsheds, cultural landscapes, plant gathering areas, or other sacred spaces that are not readily identifiable to people outside of the Tribe. In many cases, tribal cultural resources also include an archaeological component, such as artifacts, features, and sites (with or without human remains). PRC section 21074 states the following:
a) “Tribal cultural resources” are either of the following:
(1) Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either of the following:
(A) Included or determined to be eligible for inclusion in the California Register of Historical Resources.
(B) Included in a local register of historical resources as defined in subdivision (k) of Section 5020.1.
(2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Section 5024.1. In applying the criteria set forth in subdivision (c) of Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe. b) A cultural landscape that meets the criteria of subdivision (a) is a tribal cultural resource to the extent that the landscape is geographically defined in terms of the size and scope of the landscape.
c) A historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource” 306
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as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision (a).

California Health and Safety Code
California law protects Native American burials, skeletal remains, and associated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains. Health and Safety Code section 7050.5 requires that if human remains are discovered in any place other than a dedicated cemetery, no further disturbance or excavation of the site or nearby area reasonably suspected to contain human remains can occur until the county coroner has examined the remains (Section 7050.5b). PRC sections 5097.94 and 5097.98 also outline the process to be followed in the event that human remains are discovered. If the coroner determines or has reason to believe the remains are those of a Native American, the coroner must contact the California NAHC within 24 hours (Section 7050.5c). The NAHC is responsible for the notification of the MLD. With the permission of the landowner, the MLD may inspect the site of discovery. The inspection must be completed within 48 hours of notification of the MLD by the NAHC. The MLD may recommend means of treating or disposition of, with appropriate dignity, the Native American human remains, and any cultural or funerary items associated with Native American people.

Assembly Bill 52
AB 52 (effective July 1, 2015) added PRC sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, and 21084.3 to CEQA, relating to consultation with California Native American tribes, consideration of tribal cultural resources, and confidentiality. AB 52 provides procedural and substantive requirements for lead agency consultation with California Native American tribes and consideration of impacts on tribal cultural resources, as well as examples of mitigation measures to avoid or minimize impacts to tribal cultural resources. AB 52 establishes that if a project may cause a substantial adverse change in the significance of a tribal cultural resource, that project may have a significant effect on the environment. Lead agencies must avoid damaging impacts to tribal cultural resources, when feasible, and shall keep information submitted by tribes confidential unless the information is deemed publicly available by the tribe.

AB 52 requires a lead agency to consult with California Native American tribes that are traditionally and culturally affiliated with the geographic area of the proposed project, if the tribe requested to the lead agency, in writing, to be informed by the lead agency of proposed projects in that geographic area and the tribe requests consultation. Section 21080.3.1(d) states that within 14 days of determining that an application for a project is complete or a decision by a public agency to undertake a project, the lead agency shall provide formal notification to the designated contact of, or tribal representative of, traditionally and culturally affiliated California Native American tribes that have requested notice, which shall be accomplished by means of at least one written notification that includes a brief description of the proposed project and its location, the lead agency's contact information, and a notification that the California Native American tribe has 30 days to request consultation.
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Previous CEQA Documents
The City of Dublin hired the archaeological firm WSA in 2003 to prepare an Archaeological Assessment Report of the Donlon Way Specific Plan (later renamed the Dublin Village Historic Area Specific Plan area). A record search at the NWIC, conducted by WSA, did not identify any previously recorded archaeological sites within the Specific Plan area boundaries, but one new archaeological site was recorded during the pedestrian survey and Archeological High Probability areas were also identified within the Specific Plan area boundaries. The Archaeological Assessment Report concluded that there is a moderate-to-high-probability of identifying Native American archeological resources within the Specific Plan area boundaries.

The Dublin Village Historic Area Specific Plan was adopted by the Dublin City Council on August 1, 2006 under Resolution No. 149-06 and relied on the findings of the Archaeological Assessment Report of the Donlon Way Specific Plan and the Dublin Historic Resources Identification Project. The approximately 38-acre Specific Plan area included the two project site parcels. Subsequently, three Specific Plan addendum and amendments have been prepared for the Specific Plan. City Council determined that no new significant impacts were identified by the addendums or amendments, and no further environmental analysis was required.

Context for Project Impacts and Mitigation Measures
The impact analysis for tribal cultural resources for this proposed Project is based on government-to-government consultation with the City of Dublin and the Confederated Villages of Lisjan and Ione Band of Miwok Indians tribes, both of whom had previously requested notification about projects within the City of Dublin, pursuant to AB 52. Additionally, the results of the records search and archaeological field survey were considered to help establish whether tribal cultural resources may be present in the proposed Project area and if so, if they would be impacted by Project development and implementation. The analysis is also informed by the provisions and requirements of federal and state laws and regulations that apply to tribal cultural resources. This section includes the thresholds of significance used in evaluating the impacts, the methods used in conducting the analysis, and the evaluation of proposed Project impacts. If significant impacts are identified, then appropriate mitigation measures are provided.

Methods
A records search was conducted on December 20, 2022, at the California Historical Resources Information System’s NWIC in Rohnert Park, California to identify updates to previously 308
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completed cultural resources reports or studies within a 0.25-mile radius of the proposed Project site. No tribal cultural resources or pre-contact archaeological resources were identified by the records search within the proposed Project site or within the 0.25-mile search buffer.

An archaeological survey of the proposed Project site was conducted on December 16, 2022, by AECOM Archaeologist Karen Gardner. The survey focused on unpaved areas of proposed disturbance, to determine if pre-European contact, surficial resources (e.g., dark midden soils, processed shell or bone, lithics, or groundstone artifacts) were present. The backdirt of animal burrows was also examined for cultural constituents. No pre-European contact cultural resources were identified by the archaeological survey.

Consultation with California Native American Tribes
AB 52 provides procedural and substantive requirements for lead agency consultation with California Native American tribes and consideration of impacts on tribal cultural resources, as well as examples of mitigation measures to avoid or minimize impacts to tribal cultural resources. Conducting consultation early in the CEQA process allows Tribal Governments and lead agencies to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. The intent of consultation is to provide an opportunity for interested California Native American Tribal Governments to work together with the City of Dublin during the proposed Project planning process to identify, avoid, protect and mitigate impacts to tribal cultural resources.

On April 10, 2023, the City of Dublin sent inquiry letters to the following Native American Tribal Governments, who had previously requested notification about projects in the City of Dublin, pursuant to AB 52:
x The Confederated Villages of Lisjan
x The Ione Band of Miwuk Indians
Neither tribe responded to the invitation to consultation on tribal cultural resources.

Thresholds of Significance
The significance criteria used to evaluate a Project’s impacts to tribal cultural resources under CEQA are based on Appendix G of the CEQA Guidelines, commonly known as the Initial Study Checklist. An impact is considered significant if development under the proposed Project would result in one or more of the following conditions:
• Cause a substantial adverse change in the significance of a tribal cultural resource, defined in PRC § 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
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₋ Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in PRC § 5020.1(k), or ₋ A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Project Impacts and Mitigation
(a) Listed or eligible for listing in the California Register of Historical Resources (No Impact) On December 7, 2022, AECOM sent a request to the NAHC for a search of the Sacred Lands File, asking if there was any record of traditional cultural resources within the project area. On December 13, 2022, a response was received from the NAHC, indicating that the search had negative results.

No listed Tribal Cultural Resources are within the Project Area of Potential Effects (APE)1, therefore there will be no impact to listed Tribal Cultural Resources, as discussed in the Initial Study in Appendix A.
(b) Significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1 (Less Than Significant With Mitigation Incorporated) The proposed Project would include excavation of the parking lot to the south of the Hexcel Corporation R&D facility, which is adjacent to the marked boundary of the Pioneer Cemetery.

Marked grave sites in the cemetery are within five feet of the Hexcel property fence. Historic documents suggest that the cemetery was larger than the currently marked boundary (Freudenhem 1977). Additionally, there is anecdotal evidence that the cemetery location was first used by the Ohlone, and may also include burials of Native American and Mexican farm laborers who worked for Jose Maria Amador, interred prior to formal consecration of the cemetery in 1859 (VerPlanck 2003). It is likely that the cemetery extends beneath the Hexcel parking lot, and possible that the cemetery includes Native American human remains. If so, the impact to Tribal Cultural Resources would be potentially significant during earthmoving and excavation activities to implement the Project.

Mitigation Measure TR-1: Inadvertent/Unanticipated Tribal Cultural Resources Discovery Protocols
The City of Dublin shall require the following steps to be taken, including as a part of all contracts related to construction of the Project, as applicable:
1 The APE means the geographic area or areas within which an undertaking may directly or indirectly cause alterations in the character or use of historic properties, if any such properties exist. 310
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A. Prior to the start of ground disturbing activities, the applicant shall retain representatives from consulting tribe(s), if available, to implement Tribal Cultural Resources Sensitivity Training for all construction personnel involved with ground disturbing or excavation activities. The training shall include information regarding the possibility of encountering buried tribal cultural resources, the appearance and types of tribal cultural resources that could potentially be seen during construction, notification procedures, and proper protocols to be followed should suspected or confirmed tribal cultural resources be encountered. This training shall be provided once to each worker involved in ground-disturbing activities before they begin work and shall be documented in training records.

B. If tribal cultural resources or potential tribal cultural resources are discovered during Project implementation, all activity within a 50-foot radius of the find shall be stopped, the City of Dublin’s Project Manager shall be notified, and Tribal Representatives from the consulting tribe(s) shall be immediately notified. The Tribal Representative(s) shall evaluate the find(s) within 48 hours to determine if it meets the definition of a tribal cultural resource (PRC §21074) and follow the procedures outlined below:
i. If the find(s) does not meet the definition of a tribal cultural resource, no further study or protection is necessary prior to resuming Project implementation (but see Mitigation Measures CUL-3 and CUL-4)
ii. If the find(s) does meet the definition of a tribal cultural resource, then it shall be avoided by Project activities and preserved in place. The contractor shall implement any measures deemed by the City of Dublin to be necessary and feasible to preserve in place, avoid, or minimize impacts to the tribal cultural resource. If avoidance is not feasible, as determined by the City of Dublin, Tribal Representatives from the consulting tribe(s) if available, shall make recommendations regarding the culturally appropriate treatment and disposition of such find(s) and significant impacts to such tribal cultural resources shall be mitigated in accordance with the recommendations of the consulting tribe(s), if they are available, prior to resuming construction activities within the 50-foot radius.
iii. If the find meets the definition of both a tribal cultural resource and a historical or unique archaeological resource, then it shall be treated in accordance with the measures described in Section C. below and Mitigation Measure CUL-4.

C. Culturally appropriate treatment may include, but is not limited to, minimal processing of materials for reburial, minimizing handling of tribal cultural resources objects, leaving objects in place within the landscape, or returning tribal cultural resources objects to a location within the Project area where they would not be subject to future disturbance. No cultural soil maybe removed from the Project site. 311
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Permanent curation, testing, or data collection of tribal cultural resources will not take place unless requested in writing by the consulting tribe(s).

D. All fill soils imported and used for this Project must be clean, engineered fill.

E. The applicant shall enter into a tribal monitoring agreement with the consulting tribe(s) prior to the start of ground disturbing activities. The tribal monitoring agreement shall form the terms and compensation for the tribal monitoring with the consulting tribe(s) and be utilized in combination with the tribal cultural resource treatment. Tribal Monitors have the authority to identify sites or objects of cultural significance and to request, upon the finding of a potential tribal cultural resource, that work be slowed, diverted, or stopped if such sites or objects are identified within the direct impact area. Only the consulting tribe(s) can recommend culturally appropriate treatment of such sites or objects, via their Tribal Monitor. Work within 50 feet of the discovery location cannot resume until all necessary investigation and evaluation of the discovery under the requirements of the tribal monitoring agreement have been implemented.

Regarding human remains, as described above, the adjacent Pioneer Cemetery likely extends beyond the currently marked property boundary into the Hexcel lot to the west. There is anecdotal evidence that the cemetery location was first used by the Ohlone, and may also include burials of Native American and Mexican farm laborers who worked for Jose Maria Amador, interred prior to formal consecration of the cemetery in 1859 (VerPlanck 2003).

Therefore, human remains are likely to be encountered. Project implementation would involve tree and vegetation removal, grading, trenching, undergrounding of utilities, and potentially other earthmoving activities. In the event that human remains are discovered during grounddisturbing activities, they could be inadvertently damaged. This impact would be potentially significant.

If human remains are found during Project implementation, the State of California Health and Safety Code section 7050.5 states that no further disturbance shall occur until the county coroner has made a determination of origin and disposition pursuant to PRC section 5097.98. In the event of an unanticipated discovery of human remains, the Alameda County Coroner must be notified immediately. If the human remains are determined to be Native American, the coroner is required to notify the NAHC, which would determine and notify a most likely descendant (MLD) within 24 hours. The MLD must complete the inspection of the site within 48 hours of notification and may recommend scientific removal and non-destructive analysis of Native American human remains and items associated with Native American burials.

Significance after Mitigation
With the incorporation of Mitigation Measure TR-1 and adherence to State regulations, any tribal cultural resources encountered during construction would be treated in a culturally appropriate manner in consultation with Tribal Representatives, and the impact to tribal cultural resources would be less than significant with mitigation. 312
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In regards to human remains, compliance with California Health and Safety Code section 7050.5 and California PRC would reduce potential impacts on previously undiscovered human remains.

Implementing this mitigation measure ensures that any potential human remains encountered during construction would be treated in an appropriate manner under CEQA and other applicable laws and regulations. By providing consultation with the MLD, this impact would be reduced to a less than significant level.

Source(s)
Freudenheim, Richard. 1977. National Register of Historic Places Inventory – Nomination Form, Dublin Village Historic Settlement (CA-ALA-521H, P-01-002127). On file at the Northwest Information Center in Rohnert Park, California.

Kroeber, A. L. 1925. Handbook of the Indians of California. New York: Dover Publications, Inc.

Levy, Richard. 1978. Costanoan. In Handbook of North American Indians, Volume 8, edited by Robert F. Heizer, 485-495. Washington D.C.: Smithsonian Institute.

Lightfoot, Kent G., and Otis Parrish. 2009. California Indians and Their Environment: An Introduction. Berkeley, CA: University of California Press.

Milliken, Randall T. 1995. A Time of Little Choice: the disintegration of tribal culture in the San Francisco Bay Area, 1769-1810. Menlo Park, CA: Malki-Ballena Press.

Milliken, Randall, Richard T. Fitzgerald, Mark G. Hylkema, Randy Groza, Tom Origer, David Bieling, Alan Leventhal, Randy S. Wiberg, Andrew Gottsfield, Donna Gillette, Viviana Bellifemine, Eric Strother, Robert Cartier, and David A. Fredrickson. 2007. Punctuated Culture Change in the San Francisco Bay Area. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, 99-124. New York:

AltaMira Press.

VerPlanck, Christopher. 2003. Pioneer Cemetery Site Record (P-01-010637). On file at the Northwest Information Center in Rohnert Park, California. 313
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Other CEQA Considerations
Cumulative Context
Cumulative impacts do not refer to project-related impacts, but to the impacts of a proposed project when considered with the impacts of past, present, and probable future projects producing related impacts, as required by Section 15130 of the CEQA Guidelines. Other past, present, and future projects that would contribute to environmental impacts of the proposed project are referred to as “related projects.”
As stated in CEQA Section 21083(b)(2), a project may have a significant effect on the environment if “its effects are individually limited but cumulatively considerable.” According to the CEQA Guidelines Section 15355:
“Cumulative impacts” refer to two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. a) The individual effects may be changes resulting from a single project or a number of separate projects.
b) The cumulative impact from several projects is the change in the environment, which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time.

In addition, as per the CEQA Guidelines: “The mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable.” The analysis in this section includes:
x A determination of whether the long-term impacts of all related past, present, and future plans and projects would cause a cumulatively significant impact; and x A determination as to whether implementation of the proposed project would have a “cumulatively considerable” contribution to any significant cumulative impact. (See CEQA Guidelines Sections 15130[a]-[b], Section 15355[b], Section 15064[h], and Section 15065[c]).

In other words, the required analysis intends to first create a broad context through which to assess the project’s incremental contribution to anticipated cumulative impacts, viewed on a geographic scale well beyond the proposed project itself, and then to determine whether the project’s incremental contribution to any significant cumulative impacts from all related projects is itself significant (i.e., “cumulatively considerable” according to CEQA). 314
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Cumulative Impact Analysis
The City’s Development Project website and map provides a snapshot of projects that are at various stages of the development process around the limits (City of Dublin 2023). All proposed, recently constructed or foreseeable projects in the City that would contribute to cumulative impacts related to air quality, biological resources, cultural resources, energy, geology and soils (paleontological resources), hazards and hazardous materials and tribal resources are identified in Table 8: Cumulative Projects in the City of Dublin below. 26 cumulative projects were identified in the City.

The Project’s potential impacts, with respect to air quality, could extend beyond the Project area to potentially combine with impacts from the other projects listed in Table 8: Cumulative Projects in the City of Dublin. This is because air pollutants are emitted into the atmosphere and drift to other locations, which can increase pollutant levels in those areas. Nonetheless, the BAAQMD considered the emission levels at which a Project’s individual emissions would be cumulatively considerable in developing its CEQA significance thresholds. The BAAQMD considers projects that result in emissions that exceed its CEQA significance thresholds to result in individual impacts that are cumulatively considerable and significant. As discussed in the Air Quality section of this EIR, the Project’s emissions would be below the BAAQMD cumulatively considerable thresholds. Furthermore, Mitigation Measure AQ-1: Implement Basic Construction Emission Control Practices would be implemented in compliance with the BAAQMD threshold for fugitive dust emissions (PM10 and PM2.5) during construction. During operation, the proposed Project would result in a net reduction of emissions compared to existing conditions for NOx, PM10, and PM2.5, and ROG emissions would not exceed the BAAQMD thresholds of significance. Because the emissions would be minimized during construction with mitigation incorporated and reduced during operation, the Project would not result in substantial cumulative impacts and the impact would be less than significant with mitigation.

With respect to biological resources, a significant cumulative impact could occur if other cumulative projects identified in Table 8 would affect the same biological resources as the Project (e.g., nesting birds and roosting bats).

The cumulative projects that may result in potential impacts to nesting birds would be subject to applicable federal, state, regional, and local regulations discussed previously in Section 2, including the Endangered Species Act and Migratory Bird Treaty Act, and, therefore, would also be required to implement typical nesting bird avoidance measures, similar to those described for the Project in mitigation measure BIO-1. Because these standard avoidance measures would reduce the impacts of all cumulative projects, the overall cumulative impact to nesting birds in the City would be less than significant.

Because common bat species are not protected by other regulations such as the Endangered Species Act, it is possible that some cumulative projects could include removal of trees or structures that are used as bat roosting habitat without appropriate precautions being taken to prevent bat mortality. The overall cumulative impact could be potentially significant. However, 315
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because the Project would include mitigation measure BIO-2 to avoid bat mortality, the Project’s contribution to the cumulative impact would be less than cumulatively considerable with mitigation.

The Project could contribute to cumulative impacts on cultural resources and tribal resources, if projects listed in Table 8: Cumulative Projects in the City of Dublin also contributed to a substantial loss of historical and tribal resources in the City. As described in Section 3, Cultural Resources, the Project would result in the complete demolition of the existing Hexcel Corporation R&D facility, which is a historical resource as defined in CEQA Guidelines section 15064.5. This would be a significant and unavoidable impact. However, none of the other projects listed in Table 8: Cumulative Projects in the City of Dublin would result in the loss of a historical resource; therefore, the overall cumulative impact to historical resources in the City would be less than significant.

As discussed in Sections 3 and 7, Cultural Resources and Tribal Cultural Resources, respectively, based on the existence of the archeological resources within and adjacent to the Project area, there is a moderate to high probability of identifying Native American archeological resources and a high probability of encountering historic-period archeological resources in the vicinity of the Pioneer Cemetery and Dublin Creek. With the implementation of Mitigation Measures CUL3 through CUL-4, impacts to these resources would be less than significant with mitigation.

Therefore, the contribution of the Project to cumulative projects would be minimal and cumulative impacts are expected to be less than significant related to these resources.

With respect to energy resources, the geographic context for cumulative energy impacts is the state of California, as standards for energy efficiency are promulgated at the state level.

Past, present, and probable future projects throughout the state would result in the irreversible use of diesel and gasoline resources during construction, as well as the incremental increase in energy consumption from operational building energy and traffic associated with those projects. However, the use of such resources would be subject to the same regulatory framework relating to energy and fuel efficiency as the Project and would be anticipated to become more energy efficient over time as regulatory requirements change and technological advancements are made. Due to the urbanized nature of the City, future projects are expected to result in a similar development pattern—while the overall use of electricity and natural gas on the site and surrounding areas may increase, the energy use per square foot is expected to decrease due to compliance with modern standards and incorporation of modern technologies and design standards. Specifically, regarding petroleum use during construction, the Project and other future projects would consume energy associated with the off-road equipment, truck trips, and worker vehicle trips. However, construction of the Project and future projects would be temporary, and compliance with increasingly stringent local and state regulations for fleet efficiency, and construction best practices limiting vehicle idling would help reduce construction-related fuel usage. During operation of the Project and future projects, increased land use intensity would result in additional vehicles miles traveled in the area. However, over the lifetime of the Project and past, present, and future projects, the fuel efficiency of vehicles is expected to increase. Similarly, with increasingly stringent local and state regulations for 316
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energy efficiency in buildings, such as Title 24 of the California Administrative Code and the Appliance Efficiency Regulations, operational building energy consumption is also expected to decrease. Therefore, the overall cumulative impact relating to energy consumption and consistency with energy plans would be less than significant.

Impacts from the Project relating to hazardous materials could also potentially cause offsite impacts that could potentially combine with impacts from other past, present or foreseeable future projects. Impact could result from the release of hazardous materials into the environment such as the soil and water during demolition and construction activities. If this release was to cause widespread contamination to areas in addition to contamination from cumulative projects, the Project could result in significant cumulative impacts. However, with the implementation of Mitigation Measure HAZMAT-1: Perform a Phase II Environmental Site Assessment, the potential for existing contamination at the site would be investigated, and if present at levels exceeding regulatory agency thresholds, would be remediated under the oversight of the appropriate agency. Such remediation actions, if necessary, would take into account both on- and off-site receptors and potential for cumulative impacts with other nearby projects or other contaminated sites. Furthermore, all cumulative projects, including the proposed Project, are required to comply with local, state, and federal regulations for transport, use, disposal, and accidental release of hazardous materials, which would address impacts associated with both construction- and operation-related handling of hazardous materials. Although compliance with applicable regulations would not completely remove the potential for accidental releases, it would reduce the likelihood of such a spill and would generally mean that any spill would be limited in size and/or spread. Therefore, the effect of such incidents would not likely be additive to effects from other, similar incidents occurring elsewhere on different project sites. Application of these regulations is mandatory; therefore, cumulative impacts related to hazardous materials are expected to be less than significant.

With respect to paleontological resources, due to the large number of vertebrate fossils that have been recovered from the Contra Costa Group, it is considered to be of high paleontological sensitivity. Therefore, earthmoving activities associated with the projects considered in this cumulative analysis could damage or destroy unique paleontological resources that may be present in these rock formations, and potentially within other paleontologically sensitive formations as well, if those projects do not include appropriate paleontological resource avoidance measures. Therefore, the overall cumulative impact to paleontological resources could be potentially significant. Implementation of Mitigation Measure GEO-1: Avoid Impacts to Unique Paleontological Resources would reduce the potential of the proposed Project to directly impact paleontological resources and, if resources are encountered during construction, would require measures to ensure that any fossil specimens are recovered and recorded and undergo appropriate curation. Therefore, the Project’s contribution to the overall cumulative impact would be less than cumulatively considerable with mitigation.
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Table 8: Cumulative Projects in the City of Dublin
Name Description Location
(Distance from
Project Site)
Land Use Status
BASIS
Independent
School
Construct façade improvements to
existing construct façade
improvements to the existing
81,985 square foot office building
which will be converted to a school,
and construct a 9,134 square foot
gymnasium building, outdoor
recreational play field, trash
enclosure, and associated site
improvements that would serve up
to 800 middle and high school
students
7950 Dublin Blvd.
(1,660 feet)
School Approved.

Awaiting building
permit submittal
Francis Ranch
(East Ranch)
Development of a 573-unit
residential project, 11.5 acres of
public parks, a 2.6-acre, two-acre
Semi-Public Site
4038 Croak Rd.
(5.6 miles)
Residential Approved. The
building permit is
currently under
review. Grading
permits issued.

Downtown
Hines North
Demolition of the two existing
commercial buildings totaling
35,427 square feet and
construction of a new 34,995
square foot multi-tenant
commercial building
7200 Amador
Plaza Rd.
(3,630 feet)
Commercial Application under
review
Dublin Fallon
580
Vesting Tentative Tract Map to
subdivide the 192-acre parcel,
Planned Development Rezone and
Development Agreement. 238 units
and up to 4,400,605 square feet of
General Commercial/Campus Office
uses.

Corner of
Croak Road and
Future Central Pkwy.
(5.5 miles)
Subdivision that
could lead to
future
residential,
commercial,
public
development
Application under
review. NOTE: No
SDR, so no timing
on construction.

Quarry Lane
School –
Performing Arts
Center
Construct a new 13,800-square foot
building comprised of a performing
arts center and other support
spaces, including a new parking lot,
immediately south of the existing
Quarry Lane School facilities
6237 Tassajara Rd.
(2 miles)
School Application under
review
The Whitford of
Dublin (Dublin
Senior Living)
152-unit senior living project
consisting of 114 assisted living
units, 38 memory care units and
174 beds
5751 Arnold Rd.
(2.8 miles)
Commercial Approved. The
sitework permit
and building
permit are
currently under
review
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Name Description Location
(Distance from
Project Site)
Land Use Status
Grafton Plaza
Daycare & Retail
(Tivoli Plaza)
Construct three commercial
buildings with a total of 31,860
square feet (sf), including two retail
buildings (16,038 sf and 6,055 sf)
and one daycare building (9,767 sf)
on a 3.68-acre site
Corner of Grafton St.
and Dublin Blvd.
(4 miles)
Commercial Constructed
Ashton at
Dublin Station
Construct a 220-unit apartment
community and related amenities
which include a fitness center, pool,
roof top lounge, and 331 structured
parking spaces
DeMarcus Blvd.
(2 miles)
Residential Constructed
Regional Street
Senior
Affordable
Housing
Senior affordable housing project
with 113 units
6541 Regional St.
(2,540 feet)
Residential Approved. The
sitework permit
and building
permit are
currently under
review
H Mart
Supermarket
An expansion to an existing 27,237
square foot commercial tenant
space to construct an 8,552 square
foot addition for a food hall, 3,187
square foot outdoor seating area
with play area, façade
modifications, new trash enclosure
and related site improvements and
repaint the existing warehouse
building
7884 Dublin Blvd.
(2,900 feet)
Commercial Approved. The
building permit is
currently under
review.

Inspiration
Drive Assisted
Living
Construct an assisted living facility
of 84 beds on Parcel 3 of the Valley
Christian Center property.
7500 Inspiration Dr.
(3,700 feet)
Commercial Approved.

Awaiting building
permit submittal
Avalon West (St.

Patrick Way)
Construction of a 499-unit
residential apartment complex.
6700 Golden
Gate Dr.
(2,890 feet)
Residential Under
construction
The Dublin
Center “The
DC” Plus SCS
Mix-use development on 54-acres
of the SCS Dublin site. 650 units
and up to 265,000 sf of commercial
Between Brannigan
St. and Tassajara Rd.
(4 miles)
Commercial and
residential
Application under
review
Righetti
Property
Establish zoning regulations and
development standard for future
development of up to 96 homes,
approximately 372,350 square feet
of industrial uses and
approximately 321,125 square feet
of campus office/light industrial
Collier Canyon Rd.
(5 miles)
Planned
residential and
light industrial
development
Application under
review. NOTE: No
SDR, so no timing
on construction.
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Name Description Location
(Distance from
Project Site)
Land Use Status
uses. The proposed project would
also subdivide the 49.6-acre site
into four parcels to accommodate
proposed residential and industrial
development.

Branaugh
Property
PD Rezone, Tentative Map and
Development Agreement for 78-97
units and approximately 527,773
square feet of industrial
development
1881 Collier
Canyon Rd.
(5 miles)
Residential and
industrial
Approved. No
SDR, so no timing
on construction.

Kaiser
Commercial –
Nissan
Construct a Nissan auto dealership Corner of Dublin
Blvd. and Keegan St.
(4.4 miles)
Commercial Under
construction
Inspiration
Drive Memory
Care
Construct a 35,089 square
foot memory care facility consisting
of 55-beds
7500 Inspiration Dr.
(3,740 feet)
Commercial Approved.

Awaiting building
permit submittal
Infiniti
Dealership
Construct a 10,461 square foot
Infiniti automobile showroom and
service center
3200 Dublin Blvd.
(4.6 miles)
Commercial Under
construction
Hacienda
Crossings DriveThrough
Restaurant
(Chick-fil-A)
Demolition of an existing building
and construction of a new 2,781-
square-foot drive-through
restaurant and related site
improvements
4814 Dublin Blvd.
(3 miles)
Commercial Application under
review
Amador Station Development of an affordable
housing project consisting of up to
300 affordable units
6501 Golden
Gate Dr.
(4,000 feet)
Residential Approved.

Awaiting sitework
permit and
building permit
submittal
Schaefer Ranch
Unit 3
Proposal results in a total of 418
homes (a net increase of 12
homes) within the Schaefer Ranch
project
9595 Dublin Blvd.
(1 mile)
Residential Constructed
Moller
Ranch/Tassajara
Hills
Construct 370 single family
detached dwellings and a private
clubhouse on 80 acres
6861 Tassajara Road
(4.7 miles)
Residential Constructed
Boulevard
(Dublin
Crossing)
Development of approximately
1,753 single and multi-family
residential units
Corner of Dublin
Blvd. and Scarlett Dr.
(1.9 miles)
Residential Under
construction
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Name Description Location
(Distance from
Project Site)
Land Use Status
McDonald’s SDR Demolition of existing McDonald's
restaurant, and construction of
anew 4,394 sf building
7145 Dublin Blvd.
(5,000 feet)
Commercial Application under
review
Dublin Transit
Center Parking
Garage
Construct parking garage with a
capacity approximately 500 parking
spaces
Campus Dr.
(2.5 miles)
Parking Under
construction
Nissan
Commercial Car
Wash
Construct a 3,574 square foot selfservice car wash
3200 Dublin Blvd.
(4 miles)
Commercial Approved. The
building permit is
currently under
review
Notes
DC = Dublin Center, SCS = name of developer, SDR = site development review, sf-= square feet Growth Context
The CEQA Guidelines (Section 15126.2[d]) requires an examination of the direct and indirect impacts of the proposed project, including the potential of the project to induce growth leading to changes in land use patterns and population densities and related impacts on environmental resources.

Direct growth-inducement would result if a project involved construction of new housing.

Indirect growth-inducement would result, for instance, if implementing a project resulted in any of the following:
x Substantial new permanent employment opportunities (e.g., commercial, industrial, or governmental enterprises);
x A construction effort with substantial short-term employment opportunities that indirectly stimulates the need for additional housing and services to support the new temporary employment demand; or,
x Removal of an obstacle to additional growth and development, such as removing a constraint on a required public utility or service (e.g., construction of a major sewer line with excess capacity through an undeveloped area) or adding development adjacent to undeveloped land.

Growth-inducement itself is not an environmental effect, but it may foreseeably lead to environmental effects. These environmental effects may include increased demand on other community and public services and infrastructure, increased traffic and noise, degradation of air or water quality, degradation or loss of plant or animal habitats, or conversion of agricultural and open space land to urban uses.
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Growth Inducing Analysis
The proposed Project would not directly or indirectly induce unplanned population growth in the City of Dublin, as discussed in Section 13, Population and Housing of the Initial Study (Appendix A). Project construction activities would generate temporary and short-term employment, but these construction jobs are anticipated to be filled from the existing local employment pool. The number of onsite workers would vary depending on the construction phase, but it is anticipated for a Project of this scope to range from 7 to 64 workers over a 12- month period. Based on the availability of nearby construction workers, Project construction would not cause a substantial influx of construction personnel that would result in unplanned population growth in the region.

Implementation of the Project would result in permanent employment opportunities. The existing employees onsite each day is 150 to 200. The proposed building would cater to future tenants in the R&D and life sciences field, and it is estimated that the proposed Project would have 200 employees 2 onsite each day. Therefore, it is expected that similar number of employees would be working at the Project site as compared to existing conditions.

Furthermore, the Project would not remove any barriers to population growth such as providing housing, constructing transportation modes, increasing capacity of roadways or developing new roadways. Thus, the Project would not result in unplanned population growth or induce substantial growth in the City of Dublin. Therefore, there would be no impact from the Project.

Significant Irreversible Changes Context
CEQA (Public Resources Code Section 21100[B][2]) provides that an EIR shall include a detailed statement setting forth “[i]n a separate section…[a]ny significant effects on the environment that would be irreversible if the project is implemented.” State CEQA Guidelines Section 15126.2(c) provides the following guidelines for analyzing the significant irreversible environmental changes of a project:

Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses.

Also irretrievable damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.
2 Based on ABAG average square feet per employee rates for each “principal building activity” (ABAG 2011). 322
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Significant Irreversible Changes
During Project implementation, the use of nonrenewable resources such as fossil fuels in the form of electricity, gasoline and diesel fuel from construction equipment and delivery trucks would occur. 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 other parts of the City. Therefore, it is not expected that construction fuel consumption associated with the proposed Project would be more inefficient, wasteful, or unnecessary than at other construction sites in the region.

Other nonrenewable and slowly-renewable resources consumed as a result of Project development would include, but not necessarily be limited to, lumber and other forest products, sand and gravel, asphalt, petrochemical construction materials, and water.

The use of these nonrenewable resources would account for only a small portion of the region’s resources and would not affect the availability of these resources for other needs in the region.

Furthermore, the proposed Project would not result in irreversible damage from environmental accidents, such as an accidental spill or explosion of a hazardous material. During construction, hazardous materials such as gasoline, paint, adhesives and other materials classified as hazardous, would be subject to federal, state, and local health and safety requirements. Transportation of hazardous materials on area roadways is regulated by the California Highway Patrol (CHP) and the California Department of Transportation (Caltrans), and use of these materials is regulated by DTSC, as outlined in CCR Title 22. The Project applicant and its construction contractors would be required to use, store, and transport hazardous materials in compliance with applicable federal and State regulations during Project construction. Furthermore, as discussed in Section 9: Hydrology and Water Quality of the Initial Study (Appendix A), a SWPPP would be required for the Project. The SWPPP would contain Spill Response Plan to address minor spills of hazardous materials. The nature of construction – that for a conventional industrial/commercial building– would not involve unusual amounts or types of hazardous materials that could result in irreversible damage from an accidental release.

Operation of the Project may involve the transport, use, and disposal of limited quantities of hazardous materials associated with the R&D and life sciences industry. If any hazardous materials are stored or handled at the Project site, either as a result of on-site businesses (similar to Hexcel) or from basic maintenance activities such as herbicides and cleaning products, the building tenants and maintenance staff would be required to follow manufacturer’s instructions and (if applicable) would be required to prepare Hazardous Materials Release Response Plans and Inventories (Business Plans) and comply with the requirements of Hazardous Waste Generator (tiered permitting) Programs.
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Implementation of the Project would not provide access to a previously inaccessible area, and the proposed infill redevelopment of an existing R&D facility would be expected to indirectly result in a reduction in the use of nonrenewable resources compared to new greenfield development.

The Project would result in the permanent, irreversible loss of a historical resource, due to the demolition of the existing Hexcel facility, which would be a significant and unavoidable impact, as discussed in Section 3. While this loss would be permanent and irreversible, implementation of Mitigation Measure CUL-1: HABS Recordation and Mitigation Measure CUL-2: Interpretive Displays would require the historical resource to be recorded for archival purposes and that an interpretive display be created for public education. Whilst such mitigation cannot reverse or mitigate the loss of the historical resource, such interpretative and archival materials would memorialize the contribution of the Hexcel facility to the Man in Space historic context for future generations.

Significant and Unavoidable Environmental Context
California Code of Regulations Section 15216.2(b) of the State CEQA Guidelines requires an EIR to include a discussion of any significant environmental impacts that cannot be avoided if the project is implemented. Chapter 3 of this EIR provides a detailed analysis of all significant and potentially significant environmental impacts related to implementing the proposed Project; identifies feasible mitigation measures, where available, that could avoid or reduce these significant and potentially significant impacts; and presents a determination whether these mitigation measures would reduce these impacts to less-than-significant levels. Section 4.1 above identifies the significant cumulative impacts resulting from the combined effects of the proposed Project and related projects. If a specific impact in either of these sections cannot be fully reduced to a less-than-significant level, it is considered a significant and unavoidable adverse impact.

Significant and Unavoidable Environmental Analysis
Implementing the proposed Project would result in the following significant adverse impacts:
x Impact CR-1: The proposed Project would result in a substantial adverse change in the significance of a historical resource. As discussed in the Cultural section of this EIR, the Project would result in the complete demolition of the existing Hexcel Corporation R&D facility, which is a historical resource as defined in CEQA Guidelines section 15064.5. The demolition of this facility would result in a significant direct impact even with the identified mitigation measures. Thus, this impact would be significant and unavoidable.

Source(s)
ABAG. 2011. ABAG Non Residential Buildings Analysis. Obtained March 8, 2023 from NonResidentialAnalysis_120511.pdf (ca.gov).
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City of Dublin. 2023. Development Projects. Obtained June 6, 2023 from https://dublindevelopment.icitywork.com/.
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Alternatives
Introduction
CEQA Guidelines Section 15126.6(a) requires that an EIR describe a range of reasonable alternatives to a project, or the location of a project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather, a range of potentially feasible alternatives, governed by the “rule of reason,” must be considered. This is intended to foster informed decision making and public participation (CEQA Guidelines Section 15126.6[f]).

CEQA generally defines “feasible” to mean capable of being accomplished in a successful manner within a reasonable period of time, taking into account environmental, social, technological, and legal factors. The following factors may also be taken into consideration when assessing the feasibility of alternatives: site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and the ability of a project proponent to attain site control (CEQA Guidelines Section 15126.6[f][1]).

CEQA also requires that a No Project Alternative be evaluated (CEQA Guidelines Section 15126.6[e]). The analysis of a No Project Alternative is based on the assumption that a project would not be approved. In addition, an environmentally superior alternative must be identified among the alternatives considered. The environmentally superior alternative is generally defined as the alternative that would result in the least adverse environmental impacts to a project site and affected environment. If the No Project Alternative is found to be the environmentally superior alternative, the EIR must also identify an environmentally superior alternative among the other alternatives.

The analysis of alternatives is of benefit to decision makers, because it provides more complete information about the potential impacts of land use decisions. Consequently, there is a better understanding of the interrelationship among all of the environmental topics under evaluation.

Decision makers must consider approval of an alternative if it would substantially lessen or avoid significant environmental impacts identified for a proposed project and if it is determined to be feasible.

Factors Considered in the Selection of Alternatives
The CEQA Guidelines recommend that an EIR briefly describe the rationale for selecting the alternatives to be discussed, identify any alternatives that were considered by the lead agency but were rejected as infeasible, and briefly explain the reasons underlying the lead agency’s determination (CEQA Guidelines Section 15126.6(c)). The following factors were considered in identifying the range of reasonable alternatives to the Project for this Focused EIR:
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x The extent to which the alternative would accomplish most of the basic objectives of the Project;
x The extent to which the alternative would avoid or lessen the identified significant and/or unavoidable environmental effects of the Project;
x The feasibility of the alternative; and
x The extent to which an alternative contributes to a “reasonable range” of alternatives necessary to permit a reasoned choice.

Per Section 15126.6(b) of the CEQA Guidelines, the discussion of alternatives shall focus on alternatives to a project (or its location) that are capable of avoiding or substantially lessening significant impacts of a project, even if the alternatives would impede to some degree the attainment of the project objectives or would be more costly.

As discussed in the Initial Study (Appendix A), the proposed Project would result in significant adverse impacts on historical resources at the Project level. Mitigation measures are identified to reduce these Project impacts; however, none would reduce impacts to less than significant.

Consequently, the loss of the historical resource associated with the proposed Project would be significant and unavoidable. This alternatives analysis, therefore, focuses on Project alternatives that could avoid or substantially lessen impacts of the proposed Project on historical resources.

The following alternatives that may avoid or substantially lessen impacts on the historical resource were identified:
x No Project Alternative
x Reduced Grading Alternative
These alternatives are analyzed in turn below, followed by a brief discussion of those alternatives considered but rejected from further analysis.

Description and Analysis of Alternatives Retained
No Project Alternative
The No Project Alternative assumes no development would occur on the Project site. The Hexcel Corporation R&D facility would not be demolished, the site would not be redeveloped with a new facility that appeals to the life sciences and manufacturing field, and Parcels 1 and 2 would not be rezoned.

Analysis of No Project Alternative
Compliance with Project Objectives
The No Project Alternative would not meet any of the proposed Project’s objectives because it would not redevelop the site with a new and upgraded facility that appeals to the life sciences and manufacturing field and would not rezone Parcels 1 and 2 as a Planned Development. 327
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Analysis of Impacts
With the No Project Alternative, the Project would not occur and the existing conditions would remain. The Hexcel Corporation R&D facility would not be demolished, therefore, there would be no impact to the historical resource. There also would be no ground disturbance, so there would be no potential impacts related to the discovery of previously unknown archaeological resources or human remains and paleontological resources. Furthermore, there would be no construction impacts associated with the Project on other resource areas evaluated in this EIR, including air quality, biological resources, energy, and hazards and hazardous materials.

Reduced Grading Alternative
The Reduced Grading Alternative would be similar to the proposed Project as it would still demolish the existing building and construct a new facility with other site improvements, as described in the Project Description. Where it differs from the proposed Project, is the depth and area of grading that would be required in the south and southeast portion of the site, which would be substantially reduced compared to the proposed Project.

The reduced grading would be accomplished by importing soil to build up the southern periphery of the property and by treating stormwater onsite with a valley gutter catch basin and a Silva cell of approximately 3280 square feet rather than having to grade for stormwater to be gravity fed into bioretention planters. The Silva cell is a modular suspended pavement system that utilizes soil volumes to support large tree growth and provide onsite stormwater management. The Silva cell would replace 3280 square feet of the two bioretention planters proposed in the southeast corner of the site adjacent to the south parking areas (see Figure 6A.

Landscape Plan and Figure 6B: Landscape Plan Details); thereby, providing the same treatment area as the bioretention areas proposed in the proposed Project. Stormwater drainage would be provided by a shallow gutter, parallel to the south edge of the new structure, and a gentle slope along the eastern driveway of the new structure, both leading to conduits, which would drain to the Silva cell. The conduits would be installed by mechanical trenching at a minimum grade leading to the top of the Silva cell, which is 2 feet below ground surface. The top of the Silva cell dirt and landscape could be placed over it or asphalt to provide more parking space.

Excavation depths for this Alternative would generally be limited to less than 1 foot below current grade, except for the following three locations:
a) the Silva cell, which would be excavated to 7 feet below surface, with a surface area of approximately 468 feet (specific width and length are yet to be determined); b) two trenches to install culverts leading to the Silva cell, each approximately 2 feet wide, a maximum of 2 feet deep, and less than 100 feet long; and c) the southwest edge of the property, which would be excavated to a maximum of 7 feet below current surface, which is 2.5 feet less than in the original design.

The Reduced Grading Alternative also eliminates the need for the wall, and associated footings, along the south edge of the property.
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Analysis of Reduced Grading Alternative
Compliance with Project Objectives
The Reduced Grading Alternative would meet all of the proposed Project’s objectives while minimizing the area, degree, and significance of potential impact to buried archaeological resources and possible human remains associated with the adjacent Pioneer Cemetery, in addition to reducing potential impacts to paleontological resources and air quality, and reducing energy consumption.

Analysis of Impacts
The Reduced Grading Alternative would still involve the demolition of the existing Hexcel building in its entirety, and therefore, for the same reasons discussed for the proposed Project in Section 3, would have a significant and unavoidable impact to historical resources, even with the implementation of mitigation measures Mitigation Measure CUL-1: HABS Recordation and Mitigation Measure CUL-2: Interpretive Displays.

The use of a Silva cell for stormwater treatment is only being considered for this Reduced Grading Alternative, not for the proposed Project. The use of the Silva cell would dramatically reduce the amount of grading needed for stormwater management on the site, as described in the proceeding paragraphs. However, from an operational standpoint, the City has expressed concerns with the use of a Silva cell for this Project. The City is aware of other projects implementing Silva cells for stormwater treatment and those cells malfunctioning. Operational failure of these Silva cells can result in sewage getting mixed in to the stormwater treatment systems. Therefore, the City believes there is a risk implementing a Silva cell for stormwater treatment for this Project.3

With respect to buried cultural resources and tribal cultural resources, this analysis is focused on the area of the Project site with the highest sensitivity for buried historic era and pre-contact era archaeological resources (the High Archeological Probability Area), along the eastern property line and through the southern parking lot, an area of approximately 115,763 square feet (approximately 53 percent of the total project area).

The maximum depth of excavation for this alternative would be approximately 7 feet below ground surface, which is reduced from up to 10 feet below surface for the proposed Project.

Moreover, under this alternative only approximately 26,000 square feet of the High Archeological Probability Area (approximately 23 percent) would include excavation greater than 1 foot below the current ground surface, compared to 61,850 square feet (approximately 53 percent of the High Archaeological Probability Area) for the proposed Project. Therefore, this alternative would reduce the risk of impacts to buried cultural resources within the High Archeological Probability Area by more than 120 percent. While this design does not completely eliminate the risk of impact to archaeological resources or human remains, the area 3 Information provided during a phone call with Gaspare Annibale, Associate Planner at City of Dublin, on July 24, 2023.
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and degree of potential impact are significantly reduced with the Reduced Grading Alternative.

Nevertheless, the Project would still have the potential to impact archaeological resources and the potential disturb human remains, both of which could be potentially significant. All cultural and tribal mitigation measures would still apply, but the scope of archaeological testing and monitoring, and the potential for work stoppage due to archaeological discoveries, would all be significantly reduced. For the same reasons discussed for the proposed Project in Sections 3 and 7, implementation of mitigation measures Mitigation Measure CUL-3: Archaeological and Tribal Monitoring; Mitigation Measure CUL-4: Inadvertent Discovery Protocols; and Mitigation Measure TR-1: Inadvertent/Unanticipated Tribal Cultural Resources Discovery Protocols would reduce the impact to less than significant with mitigation.

The Reduced Grading Alternative would also reduce the potential to impact paleontological resources, as it would be reducing the depths of excavation where these resources could occur.

As discussed in the description of the Reduced Grading Alternative section above, the Alternative would avoid excavation of more than 1 foot below current grade in most of the locations in the south portion of the site. Since artificial fill ranges from depths of 1.5 to 5 feet, reducing the depth of excavation to less than 1 foot would greatly reduce the risk of damage to these resources (see Section 5). However, since there are areas where excavation would still exceed 1 foot, this Alternative would not completely avoid potential impacts to paleontological resources. Therefore, the impact would remain potentially significant and mitigation measure GEO-1 would still apply. For the same reasons discussed for the proposed Project in Section 5, implementation of mitigation measure GEO-1 would reduce the impact to less than significant with mitigation.

Furthermore, by reducing the amount of grading, there would be less total construction equipment usage during the grading phase, which would reduce NOx, ROG, PM10 Exhaust and PM2.5 Exhaust emissions. This Alternative would also reduce the potential for fugitive PM compared to the proposed Project, but fugitive dust PM10 and PM2.5 is not quantified in BAAQMD since there are no quantitative thresholds for fugitive dust. Less grading equipment usage would also reduce energy-consumption during construction. Therefore, this Alternative would reduce impacts to air quality and reduce energy consumption compared to the proposed Project. Nonetheless, impacts would remain less than significant with mitigation incorporated, as fugitive dust control measures would still be required.

Alternatives Considered but Rejected
Two potential alternatives were considered for the Project but rejected from further consideration. They are described below.

Partial Preservation Alternative
The Partial Preservation Alternative would demolish the 1967-constructed administration area of the Hexcel Corporation R&D facility and 1980s building additions, but would retain the approximately 25,000-square foot, 1962-constructed research and development laboratory building where the NASA research on the honeycomb took place. A new 114,141 square foot 330
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building would be constructed in place of the demolished portions of the existing building and be used by future tenants in the life sciences and manufacturing field. The 25,000 square foot laboratory building would be adaptively reused as a commercial self-storage facility, resulting in a mixed-used site, rather than a site used for solely life sciences and manufacturing.

With the Partial Preservation Alternative, the amount of square footage available for manufacturing/industrial uses would be greatly reduced from the proposed Project. This is because the City requires a certain amount of parking for different types of uses, and this Alternative would reduce the parking area by approximately 13,830 square feet to accommodate both the retained 25,000 square foot-lab and new 114,141 square foot-building.

Because the retained laboratory with the new building would take up more space on the site than the Proposed project, there would be less space for the City-required parking, necessitating a shift in the proposed balance of manufacturing uses (which require higher levels of parking) and warehouse/distribution uses (which require less parking). Because of the decreased size of the new building and a slight shift towards greater warehouse/distribution uses from industrial uses, the new building would only accommodate two future tenants, opposed to four tenants for the proposed Project.

The Partial Preservation Alternative would not meet the Project objective to redevelop the site with a new and upgraded facility that appeals to the life sciences and manufacturing field because it would be developed as a mixed-used site with the introduction of the commercial self-storage facility in the retained 1962-constructed research and development laboratory building, which would not be as appealing to future life sciences/manufacturing tenants. It is also very important to note that this Alternative would not be economically feasible for the Project applicant due to the reduction in the number of tenants, and the reduction in value of commercial self-storage and warehousing floorspace compared to life sciences/manufacturing.

The applicant prepared a Pro Forma for financial feasibility of Partial Preservation Alternative (Dublin Boulevard Owner LP, 2023) and found that this Alternative would result in a loss of approximately $10.8 million over the life of the Project, while the total upfront costs (capitalization) would be approximately $55.7 million, which is approximately 40 percent higher than the proposed project. Therefore, this Alternative would result in a loss of profit to the applicant and as a result, would be financially infeasible. Whilst economic/financial matters are not considered to be an environmental impact under CEQA, Section 15126.6(a) of the CEQA Guidelines requires that an EIR consider “a reasonable range of potentially feasible alternatives” to the proposed project and Section 15126.6(f)(1) of the Guidelines specifically lists economic viability among the factors that may be taken into account when addressing the feasibility of alternatives.

Furthermore, it is unlikely that the Partial Preservation Alternative would avoid the significant and unavoidable impact on the historical resource. Although this alternative would retain the most important portion of the Hexcel Corporation R&D facility contributing to its eligibility as a historical resource, and would therefore have a reduced level of impact compared to the proposed Project, the alternative would still demolish more than half of the original structure and would also involve substantial changes to the setting of the historical resource. It is 331
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considered unlikely that feasible mitigation measures could be implemented to fully mitigate the potentially significant impacts to a less than significant level.

For all of these reasons, this Alternative has been rejected from further consideration within this EIR.

Alternative Location
An alternative site location was considered and rejected because the purpose of the proposed Project is specific to this property. The use of another site for this Project would not meet the project’s purpose and need. As described in the Project Description, the purpose and need for this Project is to redevelop the Hexcel site with a new and upgraded facility that appeals to the life sciences and manufacturing field and to rezone Parcels 1 and 2 of this site as a Planned Development. Furthermore, the Project applicant already owns this site, which works for the scale and type of project that the applicant has proposed. Development of the Project on the proposed site will help ensure the construction of the Project is affordable and accomplished in a timely manner. A new site option would require applicant to sell this site and then find a new site in the City limits of a similar size designated for this type of use. Therefore, an alternative location was rejected from further consideration in this EIR.

Environmentally Superior Alternative
CEQA requires that, among the alternatives, an “environmentally superior” alternative be selected and that the reasons for such selection be disclosed. In general, the environmentally superior alternative is the alternative that would generate the fewest or least severe adverse impacts. Table 9: Comparison of Proposed Project and Alternatives below provides a comparison of the Project to the alternatives with respect to the potential to avoid or substantially reduce environmental impacts.
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Table 9: Comparison of Proposed Project and Alternatives Environmental Topic Proposed Project No Project Alternative Reduced Grading Alternative Air Quality LTSM No Impact LTSM
Biological Resources LTSM No Impact LTSM
Historical Resources S&U No Impact S&U
Archaeological Resources LTSM No Impact LTSMEnergy LTSM No Impact LTSM Geology & Soils LTSM No Impact LTSMHazardous Materials LTSM No Impact LTSM Tribal Cultural Resources LTSM No Impact LTSMNumber of topics with increased impact N/A 0 0
Number of topics with
decreased impact N/A All 4
Source: compiled by AECOM in 2023. For each alternative, the significance determination shown in the table for a particular impact is the most severe of the construction or operational-phase impact.

Acronyms: N/A = Not Applicable; LTSM = Less than Significant with Mitigation; S&U = Significant and Unavoidable.

Bold indicates that impact is different level of significance than the Project. - indicates that although the overall level of significance for the Alternative would be the same as the proposed Project, the duration or intensity of the impact would be less, and/or fewer mitigation measures would be required.

The No Project Alternative would be the environmentally superior alternative as it would avoid any impacts related to the construction of the proposed Project, including impacts related to air quality, biological resources, cultural and tribal resources, energy, hazardous materials, and paleontological resources. However, when the No Project Alternative is the environmentally superior alternative, CEQA requires that an additional alternative be identified. In this case, the Reduced Grading Alternative is the environmentally superior build alternative, as it would reduce the potential to impact archeological and other buried resources such as paleontological resources due to reduced grading depths, while still meeting all of the Project objectives. All the other resource areas analyzed in this EIR and Initial Study in Appendix A would be the same or similar.

Source(s)
Dublin Boulevard Owner, LP. 2023. Pro Forma for Financial Feasibility of Partial Preservation Alternative. Provided by email from applicant on June 13, 2023. 333
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Report Preparers
Lead Agency
Gaspare Annibale, Associate Planner
Anne Hersch, Assistant Community Development Department Director Consultant – AECOM
Emma Rawnsley, Project Director
Stephanie Osby, Project Manager
Paola Pena, Air Quality Scientist
Peter Boice, Biologist
Deborah Jew, Word Processor
Trina Meiser, Senior Architectural Historian
Karen Gardner, Archaeologist
Wendy Copeland, Environmental Planner

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Figures

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Figure 1. Project Location
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Figure 2. Project Site
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Figure 3. Site Plan
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.Figure 4. Elevations
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Figure 5. Overall Floor Plan
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Figure 6A. Landscape Plan
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Figure 6B. Landscape Plan Details
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Figure 7. Fire Access Route
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Appendix BŽĨ&ŝŶĂů
/Z͗ Appendices to
Draft EIR
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Appendices
Appendix A: Initial Study
Appendix B: Notice of Preparation and Scoping Comments
Appendix C: Technical Memorandum – Historical Resources Evaluation Report Appendix D: CalEEMod Output Sheets
Appendix E: Final Transportation Impact Study
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Appendix AŽĨƌĂĨƚ
/Z: Initial Study
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Hexcel Redevelopment Project
Initial Study
July 26, 2023
PROJECT APPLICATION PLPA-2022-00038
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Table of Contents
Background & Project Description.................................................................................. 1 Project Title ............................................................................................................................ 1 Lead Agency Name and Address ............................................................................................. 1 Contact Person and Phone Number ........................................................................................ 1 Project Location ...................................................................................................................... 1 Project Applicant/Sponsor Name and Address ........................................................................ 1 General Plan Designation ........................................................................................................ 2 Zoning .................................................................................................................................... 2 Project Description ................................................................................................................. 2 Proposed Project ..................................................................................................... 2 Project Approvals ................................................................................................................... 6 Environmental Setting .................................................................................................... 7 Project Site and Existing Facilities ........................................................................................... 7 Surrounding Land Uses ........................................................................................................... 7 Environmental Checklist ................................................................................................. 8 Environmental Factors Potentially Affected by the Project ...................................................... 8 Determination .............................................................................................................. 11 Explanation of Environmental Checklist Responses ..................................................... 13 Aesthetics ..............................................................................................................................13 Environmental Setting............................................................................................ 13 Regulatory Framework ........................................................................................... 16 Project Impacts and Mitigation Measures .............................................................. 19 Source(s) ................................................................................................................ 24 Agricultural and Forestry Resources .......................................................................................25 Environmental Setting............................................................................................ 25 Regulatory Framework ........................................................................................... 25 Project Impacts and Mitigation Measures .............................................................. 26 Source(s) ................................................................................................................ 27 Air Quality .............................................................................................................................29 Environmental Setting............................................................................................ 29 Regulatory Framework ........................................................................................... 30 Project Impacts and Mitigation Measures .............................................................. 32 Source(s) ................................................................................................................ 35 362
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Biological Resources ..............................................................................................................37 Environmental Setting............................................................................................ 37 Regulatory Framework ........................................................................................... 38 Project Impacts and Mitigation Measures .............................................................. 40 Source(s) ................................................................................................................ 43 Cultural Resources .................................................................................................................45 Environmental Setting............................................................................................ 45 Regulatory Framework ........................................................................................... 45 Previous CEQA Documents ..................................................................................... 50 Project Impacts and Mitigation Measures .............................................................. 51 Source(s) ................................................................................................................ 52 Energy ...................................................................................................................................53 Environmental Setting............................................................................................ 53 Regulatory Framework ........................................................................................... 54 Project Impacts and Mitigation Measures .............................................................. 56 Source(s) ................................................................................................................ 56 Geology and Soils ..................................................................................................................59 Environmental Setting............................................................................................ 60 Regulatory Framework ........................................................................................... 61 Project Impacts and Mitigation Measures .............................................................. 63 Source(s) ................................................................................................................ 66 Greenhouse Gas Emissions ....................................................................................................67 Environmental Setting............................................................................................ 67 Regulatory Framework ........................................................................................... 68 Project Impacts and Mitigation Measures .............................................................. 71 Source(s) ................................................................................................................ 76 Hazards and Hazardous Materials ..........................................................................................77 Environmental Setting............................................................................................ 77 Regulatory Framework ........................................................................................... 79 Project Impacts and Mitigation Measures .............................................................. 81 Source(s) ................................................................................................................ 83 Hydrology and Water Quality.................................................................................................85 Environmental Setting............................................................................................ 85 Regulatory Framework ........................................................................................... 86 Project Impacts and Mitigation Measures .............................................................. 89 Source(s) ................................................................................................................ 92 Land Use and Planning ...........................................................................................................95 Environmental Setting............................................................................................ 95 Regulatory Framework ........................................................................................... 95 363
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Project Impacts and Mitigation Measures .............................................................. 97 Source(s) ................................................................................................................ 98 Mineral Resources .................................................................................................................99 Environmental Setting............................................................................................ 99 Regulatory Framework ........................................................................................... 99 Project Impacts and Mitigation Measures ............................................................ 100 Source(s) .............................................................................................................. 100 Noise ...................................................................................................................................101 Environmental Setting.......................................................................................... 101 Regulatory Framework ......................................................................................... 104 Project Impacts and Mitigation Measures ............................................................ 106 Source(s) .............................................................................................................. 112 Population and Housing .......................................................................................................113 Environmental Setting.......................................................................................... 113 Project Impacts and Mitigation Measures ............................................................ 113 Source(s) .............................................................................................................. 114 Public Services .....................................................................................................................117 Environmental Setting.......................................................................................... 117 Regulatory Framework ......................................................................................... 118 Project Impacts and Mitigation Measures ............................................................ 118 Source(s) .............................................................................................................. 120 Recreation ...........................................................................................................................121 Environmental Setting.......................................................................................... 121 Regulatory Framework ......................................................................................... 121 Project Impacts and Mitigation Measures ............................................................ 122 Source(s) .............................................................................................................. 122 Transportation .....................................................................................................................123 Environmental Setting.......................................................................................... 123 Regulatory Framework ......................................................................................... 125 Project Impacts and Mitigation Measures ............................................................ 127 Source(s) .............................................................................................................. 131 Tribal Cultural Resources .....................................................................................................133 Environmental Setting.......................................................................................... 133 Regulatory Framework ......................................................................................... 134 Previous CEQA Documents ................................................................................... 135 Project Impacts and Mitigation Measures ............................................................ 136 Source(s) .............................................................................................................. 137 Utilities and Service Systems ................................................................................................139 Environmental Setting.......................................................................................... 139 364
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Regulatory Framework ......................................................................................... 141 Project Impacts and Mitigation Measures ............................................................ 143 Source(s) .............................................................................................................. 147 Wildfire ...............................................................................................................................149 Environmental Setting.......................................................................................... 149 Regulatory Framework ......................................................................................... 150 Project Impacts and Mitigation Measures ............................................................ 152 Source(s) .............................................................................................................. 154 Mandatory Findings of Significance ......................................................................................155 (a) Significant Impacts to Biological Resources or Important Examples of History or Prehistory ............................................................................................................ 155 (b) Cumulative Impacts ........................................................................................ 155 (c) Substantial Adverse Effects on Human Beings ................................................. 156 Source(s) .............................................................................................................. 156 List of Figures
Note: All figures are included at the end of the document.

Figure 1 Project Location
Figure 2 Project Site
Figure 3 Site Plan
Figure 4 Elevations
Figure 5 Overall Floor Plan
Figure 6A Landscape Plan
Figure 6B Landscape Plan Details
Figure 7 Fire Access Route
Figure 8 Proposed Project Area, Noise Monitoring Locations and Worst-Case Noise-Sensitive Receptors
Figure 9 Distribution of Modeled Noise Sources Assumed for Project Operations
Figure 10 Perspective 1
Figure 11 Perspective 2
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) List of Tables
Table 1: Building Composition by Level ........................................................................... 3 Table 2: Anticipated Construction Schedule .................................................................... 6 Table 3: Project Consistency with Applicable CAP 2030 GHG Emissions Reduction Measures ..................................................................................................... 71 Table 4: GHG Emissions Summary ................................................................................. 74 Table 5: Summary of Measured Sound Levels ............................................................. 103 Table 6: Construction Vibration Damage Criteria ......................................................... 104 Table 7: FTA General Assessment Noise Criteria .......................................................... 104 Table 8: City of Dublin Land Use/Noise Compatibility Standards (dBA, CNEL) .............. 105 Table 9: Alameda County Exterior Noise Level Standards ............................................ 106 Table 10: Proposed Project Construction Equipment Reference Sound Pressure Levels ......................................................................................................... 107 Table 11: Combined Construction Noise Levels per Construction Phase ...................... 108 Table 12: Modeled Noise Sources ............................................................................... 108 Table 13: Predicted Proposed Facility Operational Sound Levels (dBA) ........................ 109 Table 14: Peak-Hour Traffic Volumes........................................................................... 110 Table 15: Predicted Existing and Future-with-Project Worst-Hour Traffic Noise Levels ......................................................................................................... 110 366
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Acronyms
1,1,1-TCA 1,1,1-trichloroethane
AB Assembly Bill
ABAG Association of Bay Area Governments
ACDEH Alameda County Department of Environmental Health ACFCWCD Alameda County Flood Control and Water Conservation District ACFD Alameda County Fire Department
ACMs asbestos-containing materials
ADA American With Disabilities
ADWF average dry weather flow
AFY acre-feet per year
Alameda CTC Alameda County Transportation Commission
Alquist-Priolo Act Alquist-Priolo Earthquake Fault Zoning Act APN Assessor Parcel Numbers
Ardent Ardent Environmental Group
AUF acoustical usage factor
AVI Amador Valley Industries
BAAQMD Bay Area Air Quality Management District
Basin Plan Water Quality Control Plan
bgs below the ground surface
BMPs Best Management Practices
Business Plans Hazardous Materials Release Response Plans and Inventories C&D construction and demolition
CAAQS California Ambient Air Quality Standards
CAFE Corporate Average Fuel Economy
Cal/OSHA California Occupational Safety and Health Administration CalEEMod California Emissions Estimator Model
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards Code
Caltrans California Department of Transportation
CAP Climate Action Plan
CARB California Air Resources Board
CBC California Building Standards Code
CCR California Code of Regulations
CDMG California Department of Mines and Geology
CEQA California Environmental Quality Act
CESA California Endangered Species Act
CF Carbon-Free Energy
CFR Code of Federal Regulations
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) CGS California Geological Survey
CH4 methane
CHP California Highway Patrol
City City of Dublin
CMP Congestion Management Program
CNDDB California Natural Diversity Data Base
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide-equivalents
Cornerstone Cornerstone Earth Group
county County of Alameda
CUPA Certified Unified Program Agency
CWA federal Clean Water Act
CY cubic yard
dB decibels
dBA A-weighted decibel
DBH diameter breast height
DOC California Department of Conservation
DOF California Department of Finance
DSRSD Dublin San Ramon Services District
DTSC California Department of Toxic Substances Control
EBCE East Bay Community Energy
EBMUD East Bay Municipal Utility District
EBRPD East Bay Regional Park District
EDR Environmental Database Report
EE Efficiency and Electrification
EIR Environmental Impact Report
EO Executive Order
EPA United States Environmental Protection Agency
ESA Environmental Site Assessment
ESA Federal Endangered Species Act of 1973
EV electric vehicle
FEMA Federal Emergency Management Agency
FHWA Federal Highway Administration
FTA Federal Transit Administration
FTA Manual Federal Transit Administration Manual
g gravity
GGEs gasoline gallon equivalents of petroleum
GHG greenhouse gas
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) gpd/ksf gallons of water per day per 1,000 square feet
GWP Global warming potential
Hi Bay laboratories were used for small-scale testing, while the building located south of the offices/laboratories
HVAC heating, ventilation and air conditioning
Hz Hertz
I- Interstate
in/sec inches per second
IPaC Information for Planning and Consulting
IS Initial Study
ISO International Organization for Standardization
LED light emitting diode
Leq Equivalent Sound Level
Lmax Maximum Noise Level
LID Low Impact Development
light industrial zoned M-1
LOS level of service
LRAs local responsibility areas
mg million gallons
MGD million gallons per day
MM Materials and Waste Management
MND Mitigated Negative Declaration
mph miles per hour
MRZs Mineral Resource Zones
MTC Metropolitan Transportation Commission
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NFPA National Fire Protection Association
NHSTA National Highway Traffic Safety Administration
NO2 nitrogen dioxide
NOA Naturally Occurring Asbestos
NOX nitrogen oxides
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resource Conservation Service
OES Office of Emergency Services
OPR Governor’s Office of Planning and Research
PD Planned Development
PG&E Pacific Gas & Electric Company
PM particulate matter
PM10 PM equal to or less than 10 micrometers in diameter 369
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) PM2.5 PM equal to or less than 2.5 micrometers in diameter Porter-Cologne Act Porter-Cologne Water Quality Control Act PPV peak particle velocity
PRC Public Resources Code
proposed project The proposed actions that would involve replacing existing building with a new building and other site improvements R&D research and development
R-5 single-family residence
RCNM Roadway Construction Noise Model
ROGs reactive organic gases
RWQCB Regional Water Quality Control Board
SB Senate Bill
SFBAAB San Francisco Bay Area Air Basin
SIP State Implementation Plan
SM Sustainable Mobility and Land Use
SMARA Surface Mining and Reclamation Act of 1974
SO2 sulfur dioxide
SRVRWP San Ramon Valley Water Program
ST Short-term
STAA Surface Transportation Assistance Act
SVP Society of Vertebrate Paleontology
SWPPP Stormwater Pollution Prevention Plan
SWRCB California State Water Resources Control Board
TACs toxic air contaminants
TCE trichloroethene
TIA Traffic Impact Analysis
UBC Uniform Building Code
UCMP University of California Museum of Paleontology
UST Underground Storage Tank
UWMP Urban Water Management Plan
VHFHSZ Very High Fire Hazard Severity Zones
VMT vehicle miles traveled
VOCs volatile organic compounds
WB-62 Interstate Semi-Trailer
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Initial Study
Background & Project Description
Project Title
Hexcel Redevelopment Project
Lead Agency Name and Address
City of Dublin
Community Development Department
100 Civic Plaza
Dublin, CA 94568
Contact Person and Phone Number
Gaspare Annibale
Associate Planner
Phone: 925/833-6610
[email protected]
Project Location
The Project site is located at 11711 Dublin Boulevard in the City of Dublin, Alameda County, California. The site includes two parcels totaling 8.81 acres (Assessor Parcel Numbers [APN] 941-1560-009-01 [Parcel 1] and 941-1560-003-04 [Parcel 2]). Parcel 1 is the developed portion of the site and consists of the existing Hexcel research and development (R&D) building, landscaping and parking. Parcel 2 is located south of the Hexcel building and consists of a landscape area and the Dublin Creek riparian corridor. See Figure 1. Project Location.

As shown in Figure 2. Project Site, the Project site is approximately 8.81 acres located south of Dublin Boulevard in the Dublin Village Historic Area Specific Plan with the U.S. Bank Branch and Dublin Heritage Park and Museums and Dublin Pioneer Cemetery to the east; Interstate (I-)580 to the south; and a business park to the west. Regional access to the project site is provided by I-580 and I-680, with local access provided by Dublin Boulevard.

Project Applicant/Sponsor Name and Address
Dublin Boulevard Owner, LP
19700 S. Vermont Ave
Suite 101
Torrance, CA 90502
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) General Plan Designation
Business Park/Industrial
Zoning
M-1 – Light Industrial and Planned Development (PD) (Ordinance No. 80-60) Project Description
This Initial Study, pursuant to the California Environmental Quality Act (CEQA), describes the proposed project and the project’s potential impacts on the surrounding environment. The City of Dublin (the City) is the Lead Agency for review of the proposed project under CEQA.

Proposed Project
The proposed Project would result in the existing 62,715 square foot industrial building being demolished and a new 125,304 square foot building being developed on the 8.81-acre Project site. The new building would cater to future tenants in the R&D and life sciences field. Other site improvements would include landscaping; parking; a fire access road; circulation improvements for truck access and loading and unloading materials; utilities; pavement and grading to treat site drainage. Figure 3. Site Plan shows the proposed site layout. The following sections describe the proposed Project and project components.

Proposed Building
The proposed building would cover approximately 33 percent of Parcel 1 (see Figure 3. Site Plan). The building would be set back approximately 135 feet from Dublin Boulevard, separated by landscaped areas, parking stalls and a fire access route for aerial apparatus access (described in succeeding sections). As shown in Figure 4. Elevations, the building would be a single-story building with the potential addition of a second floor mezzanine office and would have a maximum height of 40 feet. The outside of the building would be made of concrete tilt-up panels painted in various colors including blue, white and gray. The north side (front) of the building would have separate entrances to the lower level of each of the four separate tenant spaces (i.e., Units A, B, C and D). Access to the upper mezzanine office spaces would be provided from the interior of the building via stairways. The double doors to the entrance would have aluminum framing with insulated tempered glazed windows. Units B and C would also have doors on the front of the building that would provide access to the industrial and warehouse spaces. Large, glazed windows with aluminum framing would be installed on both lower and upper levels of the building to provide for maximum light filtering from the outside into the office spaces. The west and northwest side of the building would provide for six separate points of ingress/egress into the Unit A industrial and warehouse space, and from the inside provide access outside to adjacent parking stalls and a large landscaped area at the west corner of the site. The east side of the building would provide for four points of ingress/egress into Unit D and would have large vision glass that would allow light to flow into the space from outside while keeping the inside of the building cool and private. The south side (rear) of the building would have 4 to 5 dock doors per unit for loading and unloading of materials from the warehouses. There would be four drive-in doors for truck access inside the warehouse. 373
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) The interior design of the building would maximize natural light with mezzanine offices on the second floor overlooking the ground floor. The total square footage of the first floor would be 119,304 square feet and the second floor would be 6,000 square feet. As indicated in Table 1:

Building Composition by Level, the space would be configured for different uses related to life sciences and advanced manufacturing. The overall building square footage could potentially be divided into four separate units (Units A, B, C and D), each with separate entrances, for four future tenants (see Figure 5. Overall Floor Plan). Each of the units would be between 26,000 to 34,000 square feet consisting of office, industrial, and warehouse space.

Table 1: Building Composition by Level
Level Use Square Footage
Level 1 Office 12,000
Level 1 Light industrial 30,000
Level 1 Warehouse 77,304
Level 2 Office 6,000
Other features of the building would include an interior bike rack, interior roof drain with pipe overflow, and an electrical room. All walking surfaces would be non-slip types. The floors would be a flat/tilt concrete slab and interior walls would be concrete. The building would be designed in compliance with fire codes related to fire access, internal sprinkler systems, electrical systems and fire-retardant materials. Additionally, the building would comply with American With Disabilities (ADA) standards related to access, ramps, breakrooms and bathrooms.

Native and drought tolerant plants would be utilized to enhance biodiversity and conserve water. Large ornamental trees planned for parking lot areas would provide shade and minimize radiating heat. The landscape would be designed to provide buffers between the site and adjacent properties, and plants would be strategically placed to screen the site’s aboveground utilities from public streets. Temporary and permanent irrigation systems would be installed to establish plants. A 3,827 square foot grass bio-swale surrounded by trees and shrubs is proposed in the west corner of the site. Additional bio-swales/bioretention planters are 374
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) proposed in the northeast and southeast areas of the site. The total bioretention areas would be 9,819 square feet.

Access, Circulation and Parking
Vehicular access would be provided from two existing driveways off Dublin Boulevard, one near the center of the site frontage and the other at the eastern boundary. These driveways would be connected by a 30 to 40-foot-wide fire access route around the perimeter of the proposed building (Figure 7. Fire Access Route). A total of six fire hydrants would be installed along this fire access road. The road would be designed to accommodate emergency response vehicles (i.e., fire trucks), delivery box trucks, and trash trucks. A 26-foot-wide fire access route along the northern side of the building would allow for aerial apparatus access.

Additionally, 12 long-term and 12 short-term bicycle stalls would be provided onsite. Offsite loading spaces would be provided in the back (south) of the proposed building adjacent to the dock doors and facing Highway 580. No truck parking or loading will be facing the street.

Utilities Systems
The Project site is currently served by existing utilities for water, sanitary sewer, electricity, and gas. As discussed in Section 18: Utilities and Service Systems, Dublin San Ramon Services District provides water and wastewater services to the site, and East Bay Community Energy provides electricity and gas to the site, which is distributed by Pacific Gas and Electric Company. Sanitary sewer, sanitary sewer manholes, a water meter, and electrical lines and cables would be removed and replaced with new lines that would connect to existing offsite service lines.

A fire service line would connect to a public water line, which would provide water to the fire hydrants located around the site. Irrigation lines would also connect to public water lines.

Stormwater would be treated onsite via five bioretention treatment planter areas that would be implemented in the western corner, southeast corner and south and northeast portions of the site. The site would be graded to have water flow into these biorientation areas. 375
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Approximately 9,819 square feet of bioretention areas on the Project site would be used for stormwater control. The proposed Project would include catch basins and storm drains throughout the project site. Full trash capture devices would be installed in all storm drain catch basins.

Other Improvements
An approximately 6-foot-high retaining wall would be installed along the southern edge of the parking lot and bioretention area in the southwest portion of the site, and lower (approximately 1- to 2-feet-high) retaining walls would be constructed adjacent to the bioretention areas in the southeast and northeast portions of the site. Additional retaining walls would be constructed to create loading dock ramps along the southern façade of the building.

A trash enclosure is proposed immediately adjacent to the backside of the building to the west.

The trash enclosure would be 10.5 feet tall and 25.75 feet wide. A metal screen would be installed on the top of the enclosure to prevent illegal dumping. Double doors to move dumpsters in and out of the enclosure and an accessible gate would be provided in the front of the enclosure. The enclosure would store two 6-cubic yard (CY) dumpsters and one 2-CY bin for green waste.

The number of onsite workers would vary depending on the construction phase, but it is anticipated for a Project of this scope to range from 7 to 64 workers. Typical grading depths throughout the site would be less than 2 to 3 feet below ground level. The maximum depth of excavation would be between 12 to 20 feet below the existing ground level at the storm drain pump, which would be located in the southern portion of Parcel 1. In the parking lot near the southwest corner, grading would extend to approximately 4.5 feet below ground level.

Construction phases would include demolition, site preparation and grading, trenching and foundation work, exterior building construction, interior building construction, and outside paving/landscaping. A summary of each construction phase is described below.

Demolition – This stage would include the demolition of the existing facility, asphalt pavement (140,724 square feet), concrete curbs, landscape including trees and bushes, irrigation system, drainage system, sewer system, site lights, electrical boxes and other electrical equipment, gas 376
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) and water meters, fence, shed and gate. Anticipated construction equipment to be used would include concrete saws, excavators, loaders, tractors, backhoes, and rubber-tired dozers.

Site preparation/grading – After the demolition phase, the site would be cleared of all demolition waste and earthmoving activities such as excavation, grading and leveling would take place to prepare the site for the proposed building and other site improvements. Utility line trenching would also occur during this stage. Anticipated construction equipment to be used would include graders, rubber-tired dozers, tractors, loaders, and backhoes.

Table 2: Anticipated Construction Schedule
Construction Phase Schedule Duration
Demolition Late fall 2023 to winter 2024 3 months
Site preparation/grading Early spring 2024 1 month
Trenching and foundation Spring 2024 1 month
Exterior building construction Late spring 2024 to fall 2024 6 months Interior building construction Late fall 2024 2 months
Paving/landscape Late fall 2024 to early winter 2 months Project Approvals
The City of Dublin is the Lead Agency for the proposed Project under CEQA. The City would be responsible for considering the Project’s impacts as part of the Project approval. The City would require the applicant to obtain the following approvals and permits: approval of a Planned Development Rezone with a related Stage 1 and Stage 2 Development Plan; Site Development 377
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Review Permit; Heritage Tree Removal Permit; and demolition, building, grading, and encroachment permits.

Other agencies whose approval may be required include:
x Bay Area Air Quality Management District (BAAQMD); and x Regional Water Quality Control Board (RWQCB).

Environmental Setting
Project Site and Existing Facilities
The Project site is located at 11711 Dublin Boulevard in the City of Dublin, Alameda County, California. The site includes two parcels totaling 8.81 acres; APN 941-1560-009-01 [Parcel 1] is the larger parcel at 8.30 acres and is located adjacent to Dublin Boulevard, and [APN] 941-1560- 003-04 [Parcel 2] is the smaller parcel at 0.51 acre and is located toward the back (south) of the Project site adjacent to I-580. The site slopes from a maximum elevation of approximately 395 feet above mean sea level near the southwest corner to about 382 feet at the northern corner.

Parcel 1 is zoned M-1 (light industrial) and PD (Ordinance No. 80-60) and Parcel 2 is zoned M-1 (light industrial).

The site is also located in the Dublin Village Historic Area Specific Plan boundary. The Specific Plan intends to protect and preserve historical resources and further enhance this area with development that is compatible with the extant historic buildings and remnants in the area. The original historic buildings in this area include St. Raymond’s church, the Murray Schoolhouse, Pioneer Cemetery, Green’s Store, and two bungalow homes. These resources function together as the Dublin Heritage Center, a local history museum and cultural center. The Specific Plan boundary extends from Cronin Circle to I-580 and San Ramon Road to Hansen Drive, including portions west of Hansen Drive along Dublin Boulevard. The Dublin Village Historic Area encompasses approximately 40 acres (City of Dublin 2014).

Parcel 1 (the northern and main portion of the site) is developed with a 62,715 square foot building, at-grade parking, underground and aboveground utilities, pavement, and ornamental landscaping. The existing building is being used as a R&D facility. The landscape consists of grass areas and mature trees.

Surrounding Land Uses
As shown in Figure 2. Project Site, the Project site is immediately surrounded by commercial office uses including an R&D facility, medical and professional offices to the west, US Bank, Dublin Pioneer Cemetery, and the Dublin Heritage Park and Museums to the east; I-580 to the south; and Dublin Boulevard to the north. To the north of Dublin Boulevard and to the east of the Dublin Heritage Park and Museums and cemetery are single-family houses. Approximately a mile to the west is Dublin Hills Regional Open Space Preserve. 378
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Environmental Checklist
Environmental Factors Potentially Affected by the Project The environmental factors checked below would be potentially affected by this Project, involving at least one impact that is a “Potentially Significant Impact” and/or a potentially significant impact that could be reduced to “Less than Significant with Mitigation”, as indicated by the checklist on the following pages. Impact summaries for all CEQA impacts with a less than significant impact with mitigation and a potentially significant impact are provided in this Initial Study and analyzed further in the Focused EIR.

Aesthetics Agricultural and Forestry Resources X Air Quality X Biological Resources X Cultural Resources X Energy
X Geology / Soils Greenhouse Gas Emissions X Hazards & Hazardous Materials
Hydrology / Water Quality Land Use / Planning Mineral Resources Noise Population / Housing Public Services
Recreation Transportation / Traffic X Tribal Cultural Resources Utilities / Service Systems Wildfire X Mandatory Findings of Significance
Instructions

1. A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question (see Source List, attached). A "No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that any effect may be significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required.

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated: applies where incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must 379
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level.

5. Earlier Analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case a discussion should identify the following on attached sheets:
a. Earlier analysis used. Identify earlier analyses and state where they are available for review.
b. Impacts adequately addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c. Mitigation measures. For effects that are "Less than Significant with Mitigation Incorporated," describe the mitigation measures, which were incorporated or refined from the earlier document and the extent to which they address sitespecific conditions for the project.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances).

Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project's environmental effects in whatever format is selected.

9. The explanation of each issue should identify:
o the significance criteria or threshold, if any, used to evaluate each question; and
o the mitigation measure identified, if any, to reduce the impact to less than significance

10. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, has consultation begun?
Note: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See 380
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Public Resources Code section 21083.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Determination
On the basis of this initial evaluation:

I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

I find that the proposed project MAY have a significant effect on the environment and an ENVIRONMENTAL IMPACT REPORT is required.

X
I find that the proposed project MAY have a potentially significant or a potentially significant unless mitigated impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets.

An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

CITY OF DUBLIN
_____________________________
Date
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_____________________________
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Explanation of Environmental Checklist Responses
Aesthetics

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

1. AESTHETICS. Would the project:
a) Have a substantial adverse effect on a scenic vista? X b) Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway?
X
c) Substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from
publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with
applicable zoning and other regulations governing scenic quality
X
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the
area?
X
Environmental Setting
The Project site is in the southwest portion of the City of Dublin surrounded by commercial and residential uses. The site includes two parcels totaling 8.81 acres. Parcel 1 (the northern and main portion of the site) is the larger parcel at 8.30 acres and is developed with a 62,715- square-foot building, at-grade parking, and underground and aboveground utilities. Photo 1 shows a view of the Project site from the intersection of Dublin Boulevard and Hansen Drive.

The existing structure is one and two stories and generally white in color. The building setback varies from approximately 75 feet to 175 feet from Dublin Boulevard. 384
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Photo 1: View of the Project site from the Intersection of Dublin Boulevard and Hansen Drive The Contemporary/Brutalist architectural style building has a roughly L-shaped plan and was largely constructed in two phases in 1962 and 1967, with small additions and alterations in the mid-1980s. The original 1962 portion of the facility is on the east half, has a roughly rectangular plan, and is constructed of tilt-up concrete panels in a north-south orientation. The north end of the building rests on a concrete foundation and is one story tall. The exterior is clad with scored concrete, and the flat roof parapet is lined with a louvered metal equipment screen. A privacy screen that uses vertically oriented, narrow wood slats lines the west side of the east half of the facility and terminates near the secondary entry, which consists of a pair of glazed, metal double doors.

The 1967-constructed portion of the facility abuts the west side of the two-story building hyphen. This single-story building section has a T-shaped plan and an east-west orientation. The building is characterized by a flat roof with deep eaves and fascia that is supported by repeating narrow, concrete pylons with wood sheathing on all sides.

A two-story building hyphen built in 1984 connects the 1962-constructed east half with the 1967-constructed west half. The hyphen has a flat roof and is clad with scored concrete. A single-story chemical storage addition, constructed in 1985, is at the southeast corner of the facility. The addition has a square plan, a flat roof, with scored panel lines in the concrete exterior.

Parcel 1 of the Project site contains 87 trees, four of which are heritage trees. Landscaped areas within Parcel 1 are comprised of sod, various ornamental shrubs, various ornamental tree species, as well as a large number of native trees such as coast live oak trees, California Bay, and California buckeye.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Dublin Creek is located to the south of the Project footprint on Parcel 2 and runs between the Project footprint and I-580. Parcel 2 (the southern parcel) is undeveloped and is surrounded by dense riparian vegetation and contains 109 trees within the Dublin Creek riparian corridor.

Dublin Creek is approximately 13 to 18 feet below the adjacent site elevations.

The Project site is immediately surrounded by commercial office uses including an R&D facility, medical and professional offices to the west, and US Bank, Dublin Pioneer Cemetery, and the Dublin Heritage Park and Museums to the east. To the north of Dublin Boulevard and to the east of the Dublin Heritage Park and Museums and cemetery are single-family houses.

Approximately a mile to the west is Dublin Hills Regional Open Space Preserve. The buildings in the Project vicinity are generally one to three stories. These buildings vary in architectural style, height, color, and bulk. Landscaping associated with these buildings generally consists of mature trees, shrubs, and grass that provide visual contrast in terms of form, color, mass, and scale. Viewers of the Project site from these locations include motorists, employees and patrons of local businesses, residents, pedestrians, and bicyclists.

Scenic Highways, Routes, and Corridors
The California Department of Transportation (Caltrans) manages the State’s Scenic Highways Program. According to Caltrans’ California Scenic Highway Mapping System, the nearest officially designated State scenic highway is I-680, approximately 1 mile east of the Project site (Caltrans 2018). I-580, located just south of the Project site, is an eligible State scenic highway (Caltrans 2018).

I-580, I-680, and San Ramon Road were designated scenic routes by Alameda County in 1966.

These are the places from which people traveling through Dublin gain their impression of the City (City of Dublin 2022). I-580 is elevated higher than the Project site, and motorists traveling both directions on I-580 would have peripheral views of the vegetation on Parcel 2 and motorists traveling westbound would have intermittent peripheral views of Parcel 1.

Regional corridors are routes of regional significance and are generally defined as routes that connect Dublin to surrounding communities. Dublin has 12 features (including roadways, trails, and public transportation) that are considered regional corridors. In the vicinity of the Project site, Dublin Boulevard and San Ramon Road are identified by the City as a regional corridor (City of Dublin 2022).

Scenic Vistas
Scenic vistas consist of expansive, panoramic views of important, unique, or highly valued visual features that are seen from public viewing areas. This definition combines visual quality with information about view exposure to describe the level of interest or concern that viewers may have for the quality of a particular view or visual setting.

There are no designated scenic vistas in Dublin. However, the City of Dublin General Plan identifies the visually sensitive ridgelines located in the open space areas in the Western and Eastern Extended Planning Areas of the City as scenic resources (City of Dublin 2022). In the vicinity of the Project site, ridgelines and open space areas are visible from Dublin Boulevard and I-580.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Light and Glare
The Project area is located in a highly urbanized environment and is surrounded by existing sources of light and glare. These sources of light and glare include streetlights along Dublin Boulevard and I-580; exterior lighting on office and residential buildings; outdoor lighting on surface parking lots; illuminated signage; reflective building material; and vehicular headlights.

In addition, the Project site itself is developed and includes existing sources of light and glare from the parking lot and building façade lighting and interior illumination passing through windows.

Glare can emanate from many different sources, some of which include direct sunlight, sunlight reflecting from buildings, and bright outdoor or indoor lighting. Currently, the existing building does not generate substantial glare, as most of the building is constructed of non-reflective materials.

Regulatory Framework
City of Dublin General Plan
Per the City of Dublin General Plan policies, design review would be required for all projects visible from a designated scenic route in order to enhance a positive image of Dublin as seen by through travelers. The following policies related to visual resources are applicable to the proposed Project:
x Implementing Policy 5.7.1.A.1. Incorporate County-designated scenic routes, and the Fallon Road extension, in the General Plan as adopted City-designated scenic routes, and work to enhance a positive image of Dublin as seen by through travelers. x Implementing Policy 5.7.1.B.1. Exercise design review of all projects visible from a designated scenic route.

In addition, the Community Design and Sustainability Element of the City of Dublin General Plan contains goals and policies that provide a framework for community development and guidelines for new construction and improvements. The following policies are applicable to the proposed Project:
x Policy 10.5.3.C. Incorporate visual screening techniques such as berms, dense and/or fastgrowing landscaping, and appropriately designed fencing where feasible, to ensure that visually challenging features, such as parking lots, loading docks, storage areas, etc. are visually attractive as seen from regional corridors.
x Policy 10.5.3.D. Provide landscaping and articulated design to soften the visual appearance of existing and new walls and fences that are adjacent to regional corridors, wherever feasible (reference: Streetscape Master Plan).
x Policy 10.5.3.E. Encourage attractive and high-quality landscaping along the edge of the freeways and development surrounding on- and off-ramps to provide softer and more attractive views both to and from the freeways. Landscaping on private property should complement the buildings and overall site design.
x Implementation Measure 10.5.4.C. Review development through the Planned Development Regulations and/or the Site Development Review Permit process. 387
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) x Policy 10.7.3.1.A. Encourage diverse, high quality, attractive, and architecturally appealing buildings that create distinctive visual reference points, enrich the appearance of functional gathering spaces, and convey an excellence in architecture, workmanship, quality, and durability in building materials.
x Policy 10.7.3.1.C. Ensure that building height, scale and design are compatible with the character of the surrounding natural and built environment, and are varied in their massing, scale and articulation
x Policy 10.7.3.1.E. Avoid the use of long, continuous, straight (building) walls along roadways by designing appropriate articulation, massing, and architectural features x Policy 10.7.3.1.K. Minimize the visual impacts of service/loading areas, storage areas, trash enclosures, and ground mounted mechanical equipment. When feasible, these elements should be located behind or to the sides of buildings and screened from views through a combination of walls/ fencing, and/or landscaping.
x Policy 10.7.3.1.L. Minimize the visual impacts of roof mounted mechanical equipment.

When feasible, such elements should be consolidated and housed in architecturally articulated enclosures.
x Policy 10.7.3.2.H. Preserve mature trees and vegetation, with special consideration given to the protection of groups of trees and associated undergrowth and specimen trees (reference: Heritage Tree Ordinance).
x Policy 10.7.3.4.A. Ensure that perimeter areas incorporate appropriate planting, lighting, and signage.
x Policy 10.7.3.4.E. Design and locate outdoor lighting around buildings, in parking lots, and along streets that minimize the effects of glare on adjacent properties, particularly in residential areas
x Policy 10.7.3.5.A. Provide convenient but not visually dominating parking that incorporates extensive landscaping to provide shade, promote wayfinding, visually soften views from the street and surrounding properties, and reduce the heat island effect (generally characterized with large expanses of paved and under-landscaped surfaces). x Policy 10.7.3.5.B. Buffer and screen large expanses of parking areas from the street, where practical.

City of Dublin Municipal Code
Chapter 8.28, Industrial Zoning District
Parcel 1 and Parcel 2 are zoned as Light Industrial (M1). The M-1 zoning district is intended to provide for the continued use, expansion, and new development of light industrial use types in proximity to major transportation corridors, and to ensure compatibility with adjacent residential and commercial uses. A landscape buffer 10 feet wide is required to be provided along all roadways which shall be adequately watered and maintained. Open areas used for storage or for parking and loading of vehicles are required to be enclosed by a solid wall or fence not less than 6 feet in height with solid entrance and exit gates. 388
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Chapter 8.32, Planned Development Zoning District
Parcel 1 is further zoned as PD under Ordinance No. 80-60. The existing PD Ordinance No. 80-60 for the Project site was approved by the Alameda County Board of Supervisors on July 10, 1980.

The purpose of Chapter 8.32 is to establish a Planned Development Zoning District through which one or more properties are planned as a unit with development standards tailored to the site; provides maximum flexibility and diversification in the development of property; maintains consistency with, and implement the provisions of, the Dublin General Plan and applicable Specific Plans; protects the integrity and character of both residential and non-residential areas of the City; encourages efficient use of land for preservation of sensitive environmental areas such as open space areas and topographic features; encourages use of design features to achieve development that is compatible with the area; and allows for creative and imaginative design that will promote amenities beyond those expected in conventional developments.

Chapter 8.32 requires preparation of a Development Plan for the zoning district. The Development Plan shall establish regulations for the use, development, improvement, and maintenance of the property within the requested Planned Development Zoning District, and may be adopted in stages, as follows:
x Stage 1 Development Plan. A Stage 1 Development Plan shall be adopted for the entire Planned Development District site with the reclassification of the property to the Planned Development Zoning District. The plan shall establish the permitted, conditionally permitted, and accessory uses, Stage 1 site plan, site area and proposed densities, maximum number of residential units and non-residential square footages, a phasing plan and a Master Landscaping Plan; statements regarding consistency with General Plan and Specific Plans, and consistency with Inclusionary Zoning regulations, an aerial photo, other information necessary for the review of the proposed project. x Stage 2 Development Plan. A Stage 2 Development Plan for all or a portion of the entire Planned Development District site may be adopted with the Stage 1 Development Plan at the time of the Zoning Ordinance Amendment. A Stage 2 Development Plan shall establish permitted, conditionally permitted, and accessory uses, Stage 2 site plan, site area and maximum proposed densities, maximum numbers of residential units by type and nonresidential square footages for each use, development regulations, architectural standards, preliminary landscape plan, other information necessary for the review of the proposed project.

Chapter 8.36, Development Regulations
Chapter 8.36, Development Regulations, of the City of Dublin Municipal Code is intended to secure the necessary provision for light, air, privacy, and safety from fire hazards, and to ensure that development within the City of Dublin provides a high-quality living and working environment consistent with the policies of the City General Plan. It sets forth development regulations relating to lot area, lot square footage per residence, lot width, lot frontage, lot depth, residential use, setbacks, distance between residences, lot coverage, lot lines, yards and height limits.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Chapter 8.72, Landscaping and Fencing Regulations
Chapter 8.72, Landscaping and Fencing Regulations, of the City of Dublin Municipal Code is intended to enhance the aesthetic appearance of developments in all areas of the City by providing standards relating to quality, quantity, and functional aspects of landscaping and landscape screening; increase compatibility between residential and abutting commercial and industrial land uses; reduce the heat and glare generated by development; and minimize visual pollution.

Chapter 8.104, Site Development Review
Chapter 8.104, Site Development Review, of the City of Dublin Municipal Code establishes the procedure for approving, conditionally approving, or denying Site Development Review Permits to promote orderly, attractive, and harmonious development for new development projects that are compatible with surrounding properties and neighborhoods. Adopted Site Development Review Guidelines are used to guide Site Development Review Permit applications.

Project Impacts and Mitigation Measures
(a) Scenic vistas, views (No Impact)
A scenic vista can be impacted by development projects in two ways: (1) the project could directly diminish the scenic quality of the vista by introducing new visual elements that are incompatible with the balance of built and open space, that substantially alter the landform, or that detract from the qualities that contribute to the scenic vista, or (2) the project could block the view corridors or “vista” of the scenic resource from public vantage points. Important factors in determining whether a proposed project would block scenic vistas include the project’s proposed height, mass, and location relative to surrounding land uses and travel corridors, as well as to the number of viewers potentially affected and the length of exposure (e.g., residential land uses are typically more sensitive than land uses with only short-term occupants such as employees, students, or visitors).

There are no designated scenic vistas in Dublin. However, the City General Plan identifies the visually sensitive ridgelines located in the open space areas in the Western and Eastern Extended Planning Areas of the City as scenic resources. In the vicinity of the Project site, ridgelines and open space areas are visible from Dublin Boulevard and I-580.

The proposed Project would demolish the existing 62,715 square foot building and develop a new 125,304 square foot building. Because the topography of the Project site, I-580 is elevated above the Project site, and the surrounding area is generally flat, construction of the Project would not obstruct background views of scenic resources, such as views of ridgelines and open space.

Distant views of the Project site would be indistinguishable from the surrounding area due to the density of urban development and flat topography along this portion of Dublin Boulevard.

Overall, the Project would be consistent in height, size, and scale with existing buildings in the surrounding area. The new building would be taller and approximately double the size of the existing building. The proposed building may appear bigger and taller for motorists, 390
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) pedestrians, visitors to local businesses, or individual residents on neighboring properties; however, the increased building size and height would not substantially affect views of ridgelines located in the open space areas from public vantage points or for a substantial number of City residents. Therefore, the Project would not have a substantial adverse effect on a scenic vista and no impact would occur.
(b) Scenic resources (Less Than Significant Impact)
San Ramon Road and Dublin Boulevard are identified by the City as regional corridors. In addition, San Ramon Road is designated a scenic route by Alameda County. San Ramon Road is located approximately 0.3 mile east of the Project site; however, views of the Project site are not visible from this section of the roadway due to intervening urban development.

As shown in Photo 1 above, the Project site is visible from Dublin Boulevard to motorists, pedestrians, visitors to local businesses, or individual residents on neighboring properties. The proposed Project would demolish the existing 62,715 square foot industrial building and develop a new 125,304 square foot building. The building would be set back approximately 135 feet from Dublin Boulevard, separated by landscaped areas and parking stalls. Figure 10.

Perspective 1 shows an image of how the Project site would appear from Dublin Boulevard.

While the new building may appear bigger and taller for motorists, pedestrians, visitors to local businesses, or individual residents on neighboring properties, the Project would be consistent in height, size, and scale with existing buildings in the surrounding area. Much of the existing landscape and trees on Parcel 1, closest to Dublin Boulevard, would be removed during project construction. However, a total of 85 trees would be added to the site along with other plants, such as sweet bay, strawberry tree, toyon, hopbush, coffeeberry, red yucca, agave, fort night lily, ceanothus and atlas fescue. Over time, as landscaping and trees mature, they would soften and obscure the visibility of the proposed building and parking lot.

The nearest officially designated State scenic highway is I-680, approximately 1 mile east of the Project site. However, views of the Project site are not visible from this section of the roadway due to intervening urban development.

I-580, located approximately 65 feet to the south of the Project site, is an eligible State scenic highway. Photos 2 and 3 illustrate existing views of the Project site from eastbound I-580 and westbound I-580, respectively. As shown in Photos 2 and 3, motorists traveling both directions I-580 would have peripheral views of Parcel 2 and motorist traveling westbound would have intermittent peripheral views of Parcel 1. Existing vegetation on Parcel 2 within the riparian corridor of Dublin Creek and along the I-580 boundary would be retained. Therefore, views of Parcel 2 from I-580 would be the same as existing conditions. 391
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Photo 2: View of Parcel 2 by Motorists Traveling Eastbound on I-580 Photo 3: View of the Project site by Motorists Traveling Westbound on I-580 Views of Parcel 1 are peripheral to the viewer experience of motorists on I-580. Motorists experience direct views of the asphalt roadway, light rail tracks with associated chain link fence dividing the eastbound and westbound lanes of traffic, metal guardrails, overhead lighting, and interstate signage. Figure 11. Perspective shows a view of the Project site with the proposed building from one vantage point of motorists traveling in the westbound direction. As shown in the figure, the southwest corner of the proposed building would be partially visible from this portion of the highway. However, vegetation would provide a soft screen against the building. 392
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) As stated above, the Project would be consistent in height, size, and scale with the existing buildings in the surrounding area, and as landscaping and trees mature, they would soften and obscure the visibility of the building and parking lot. Views of the Project site from this location would be intermittent, viewed from above, and experienced at high speeds (generally 65 miles per hour). Therefore, the sensitivity of motorists along I-580 to visual change is low.

Thus, the proposed Project would not substantially damage scenic resources, and this impact would be less than significant.
(c) Substantially degrade the visual character of public views of the site or surrounding area (No Impact)
The threshold of significance for development in urbanized areas is limited to whether the Project would conflict with applicable zoning or other regulations governing scenic quality.

Impacts to scenic quality within urbanized areas do not include degradation to visual character or the quality of public views of the site and its surroundings.

The proposed Project would demolish the existing 62,715 square foot industrial building and development of a new 125,304 square foot building. Parcel 1 has split zoning with one half of the parcel zoned M-1 Light Industrial) and the other half zoned PD. Parcel 2 is zoned M-1 (Light Industrial). As discussed further in the Dublin Municipal Code (DM) Section 8.28.23, the M-1 zoning district is intended to provide for the continued use, expansion, and new development of light industrial use types. The proposed Project is a permitted use within the M-1 zoning district, however, is not a permitted use in the PD. A Planned Development Rezone would be required for Parcels 1 and 2, which provides development standards beyond those of the M-1 zoning, and a new ordinance would be adopted concurrently. In addition, the proposed Project would prepare Stage 1 and Stage 2 Development Plans simultaneously.1 With approval of a Planned Development Rezone with a related Stage 1 and Stage 2 Development Plan (DMC Chapter 8.32) and Site Development Review Permit (DMC 8.104), the proposed Project would not conflict with the zoning of the Project site.

The Project would be consistent with the development standards and design criteria provided in DMC Chapter 8.36, including standards for setbacks, lot area, lot width, lot frontage, lot depth, lot coverage, lot lines, and height limits. The building would be set back approximately 135 feet from Dublin Boulevard and cover approximately 31 percent of the site (see Figure 3.

Site Plan). The building would be two-stories, with a maximum height of 40 feet (see Figure 4.

Elevations). In addition, the proposed Project would not exceed the Dublin Area Village Specific Plan’s development potential for the Project site (maximum of 154,202 square feet). 1 The Stage 1 Development Plan establishes the permitted, conditionally permitted and accessory uses and discusses consistency with the General Plan. The Stage 2 Development Plan establishes development standards/regulations, as well as architectural/landscaping standards. The Planning Commission and the City Council would review the Development Plan, PD zoning district, and ordinance for approval (Gaspare pers. comm., 2023).
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) The Project would be consistent with General Plan policies regarding landscaping and visual screening (Policies 10.5.3.C, 10.5.3.D, 10.5.3.E, 10.7.3.2.H, 10.7.3.4.A, and 10.7.3.5.A of the Dublin General Plan) and the City’s municipal code Chapter 8.28. The total site landscape area would be 99,106 square feet, which includes new and existing landscape. A variety of evergreen shrubs, ornamental trees, grasses, and perennials would be planted around the perimeter of the site and at parking lot areas (see Figure 6B. Landscape Plan Detail). A total of 85 trees would be added to the site along with a variety of other plants. Some of the proposed plants include sweet bay, strawberry tree, toyon, hopbush, coffeeberry, red yucca, agave, fort night lily, ceanothus and atlas fescue. A 3,827 square foot grass bio-swale surrounded by trees and shrubs is proposed in the west corner of the site, and additional bio-swales/bioretention planters are proposed in the northeast and southeast areas of the site.

The Project would be consistent with General Plan policies regarding design of industrial buildings (Policies 10.7.3.1.A, 10.7.3.1.B, and 10.7.3.1.E of the Dublin General Plan). The outside of the building would be made of concrete tilt-up panels painted in various colors including blue, white, and gray. An approximately 6-foot-high retaining wall would be installed along the southern edge of the parking lot and bioretention area in the southwest portion of the site, and lower (approximately 1- to 2-feet-high) retaining walls would be constructed adjacent to the bioretention areas in the southeast and northeast portions of the site. Additional retaining walls would be constructed to create loading dock ramps along the southern façade of the building.

As discussed in more detail in Section 4, “Biological Resources,” the Project’s proposed tree removal and replacement on Parcel 1 would also comply with the requirements of the City’s Heritage Tree Ordinance (DMC Chapter 5.60). Although the proposed removal of trees would change the visual appearance of the Project site, the City’s Heritage Tree Ordinance allows for tree removal to accommodate proposed development, provided certain conditions are met.

With adherence to the tree removal permit conditions, the Project would not conflict with the City’s tree ordinance. All heritage trees in Parcel 2 would be retained.

There are no other regulations governing scenic quality that are applicable to the Project.

Because the proposed Project would not conflict with applicable zoning or other regulations governing scenic quality, there would be no impact.
(d) Create a new source of substantial light or glare (Less Than Significant) The light and glare created by development under the Project would be consistent with the levels of lighting and glare currently emitted by the on-site building and office buildings surrounding the Project site and street lighting. Exterior light sources would be designed so as not to create significant light and glare on adjacent properties through the use of concealed sources and/or downcast light fixtures. Because the Project would not introduce new sources of light substantially different from the existing on-site light and from surrounding uses and street lighting, the Project would not generate a substantial new source of light that would adversely affect day or nighttime views in the area.

Glare is caused by light reflections from pavement, vehicles, and building materials such as reflective glass and polished surfaces. During daylight hours, the amount of glare depends on 394
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) intensity and direction of sunlight. The outside of the building would be made of concrete tiltup panels painted in various colors including blue, white and gray. Glazed, non-reflective windows with aluminum framing would be installed on both lower and upper levels of the building. These non-reflective building materials would not result in potential glare impacts within the Project site or surrounding areas, and notably at the street level.

For the reasons described above, the proposed Project would not create substantial new sources of light and glare, and this impact would be less than significant.

Source(s)
California Department of Transportation. 2018. California State Scenic Highway Map. Available:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-communitylivability/lap-liv-i-scenic-highways. Accessed March 8, 2023.

City of Dublin. City of Dublin General Plan, 2022. Amended February 15, 2022.

Gaspare, Annibale. City of Dublin. Email with Stephanie Osby regarding Stage 1 and Stage 2 Development Plan process and approval of a Planned Development zoning district ordinance. March 20, 2023.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Agricultural and Forestry Resources

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

2. AGRICULTURE RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency,
to non-agricultural use?
X
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
X
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in PRC Section 12220(g)),
timberland (as defined by PRC Section 4526), or
timberland zoned Timberland Production (as defined by
Government Code Section 51104(g))?
X
d) Result in the loss of forest land or conversion of forest land to non-forest use?
X
Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of
forest land to non-forest use?
X
Environmental Setting
The Project site is not used for agricultural production and is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (NRCS 2019). The surrounding area is characterized by commercial and residential uses. There are no forest or timberland on or near the Project site.

Regulatory Framework
State Regulations
California Department of Conservation Farmland Mapping and Monitoring Program The California Department of Conservation (DOC) manages the Farmland Mapping and Monitoring Program to assess the location, quality, and quantity of agricultural lands and conversion of these lands over time. In each county, the land is analyzed for soil and irrigation 396
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) quality, and the highest quality land is designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Based on the results of these analyses, the DOC issues maps every two years with the use of a computer mapping system, aerial imagery, public review, and field reconnaissance.

Williamson Act
The Williamson Act, also known as the California Land Conservation Act of 1965, enables local governments and private landowners to enter into contracts that restrict specific parcels of land to agricultural or related open space use. As a result, landowners receive reduced property tax assessments because they are based upon farming and open space uses rather than market value.

Local Regulations
City of Dublin General Plan
x Guiding Policy A.1. States that the City will prevent the premature urbanization of agricultural lands.
x Implementing Policy B.1. Requires the City to make findings that the land is suitable for the proposed use and will have adequate urban services and that conversion to an urban use will not have significant adverse effects on adjoining lands remaining under Williamson Act contract. Due to the location of the Project site and its proximity to existing development, existing policies aimed at preserving agricultural uses in the City are not applicable to the proposed Project.

Project Impacts and Mitigation Measures
(a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (No Impact)
As described in the Environmental Setting above, the Project site is not used for agricultural production and is not designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. Therefore, the proposed Project would not convert Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or any other type of farmland to non-agricultural uses. Therefore, there would be no impact.
(b) Conflict with existing zoning for agricultural use or a William Act contract (No Impact) The Project site is currently zoned as M-1 (Light Industrial) and PD on the City of Dublin Zoning Map (City of Dublin 2022). The Project site is not currently used for agricultural purposes, not zoned for agricultural uses, and is not protected by, or eligible for, a Williamson Act contract.

Therefore, the proposed Project would not conflict with existing agricultural zoning or Williamson Act contracts. Therefore, there would be no impact. (c) Conflict with existing zoning for forest land or timberlands (No Impact) The Project site is currently zoned as M-1 (Light Industrial) and PD on the City of Dublin Zoning Map (City of Dublin 2022). The Project site is not currently used for forest or timberland 397
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) purposes, and is not zoned for forest land or timberland uses. Therefore, the proposed Project would not conflict with existing forest or timberland zoning and there would be no impact. (d) Result in loss of forest land or conversion to non-forest use (No Impact) No forest land exists on the Project site or in the surrounding area. Therefore, the proposed Project would not result in the loss of forest land or the conversion of forest land to non-forest use. Therefore, there would be no impact.
(e) Other changes that could result in conversion of farmland or forest land (No Impact) The proposed Project would not result in other changes to the environment that could indirectly result in the conversion of farmland to non-agricultural purposes or conversion of forest land to non-forest uses. The Project site is in a highly urbanized area and the Project would replace the existing industrial uses at the site with similar industrial uses. Therefore, there would be no impact.

Source(s)
City of Dublin. 2022. Dublin Zoning Map as amended through June 21, 2022. Obtained January 24, 2023 from https://www.dublin.ca.gov/DocumentCenter/View/31440/Zoning-MapJune-2022.

Natural Resources Conservation Service. 2019. Web Soil Survey. Obtained on February 2, 2023 from https://websoilsurvey.nrcs.usda.gov/app/.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Air Quality

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

3. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan? X
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
X
c) Expose sensitive receptors to substantial pollutant
concentrations?
X
d) Result in other emissions (such as those leading to odors adversely affecting a substantial number of people?
X
Environmental Setting
Air quality is defined by the concentration of pollutants in relation to their impact on human health and the environment. Concentrations of air pollutants are determined by the rate and location of pollutant emissions released by pollution sources, and the atmosphere’s ability to transport and dilute such emissions. Natural factors that affect transport and dilution include terrain, wind, and sunlight. Therefore, ambient air quality conditions within the local air basin are influenced by natural factors such as topography, meteorology, and climate, in addition to the amount of air pollutant emissions released by existing air pollutant sources.

The proposed Project is located in the San Francisco Bay Area Air Basin (SFBAAB), which is comprised of complex terrain types, including coastal mountain ranges, inland valleys, and bays, which distort normal wind flow patterns. Along the County of Alameda’s (the county) western coast, temperatures are moderated by the bay, which can act as a heat source during cold weather or cool the air by evaporation during warm weather. It is generally sunnier farther from the coast, although partly cloudy skies are common throughout the summer. Average summer temperatures are mild overnight and moderate during the day. Winter temperatures are typically cool overnight and mild during the day. Highest temperatures are more common inland. Wind speeds vary throughout the county, with the strongest gusts along the western coast, often aided by dominant westerly winds and a bay-breeze effect. Rainfall totals average about 14 to 23 inches per year, with the highest totals in the northern end of the county and atop the Oakland-Berkeley hills (BAAQMD 2021).
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Air Pollutants of Concern
Individual air pollutants at certain concentrations may adversely affect human or animal health, reduce visibility, damage property, and reduce the productivity or vigor of crops and natural vegetation. Six air pollutants have been identified by the United States Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) as being of concern both on a nationwide and statewide level: ozone; carbon monoxide (CO); nitrogen dioxide (NO2); sulfur dioxide (SO2); lead; and particulate matter (PM), which is subdivided into two classes based on particle size: PM equal to or less than 10 micrometers in diameter (PM10) and PM equal to or less than 2.5 micrometers in diameter (PM2.5). Because the air quality standards for these air pollutants are regulated using human health and environmentally based criteria, they are commonly referred to as “criteria air pollutants.” Ozone is not emitted directly into the air but is formed through a series of reactions involving reactive organic gases (ROGs) and nitrogen oxides (NOX) in the presence of sunlight. ROG and NOX are referred to as “ozone precursors.”
Toxic Air Contaminants
In addition to criteria air pollutants, EPA and CARB regulate hazardous air pollutants, also known as toxic air contaminants (TACs). TACs collectively refer to a diverse group of air pollutants that can cause chronic (i.e., long-duration) and acute (i.e., severe but short-term) adverse effects on human health, including carcinogenic effects. TACs can be separated into carcinogens and noncarcinogens based on the nature of the effects associated with exposure to the pollutant. For regulatory purposes, carcinogens are assumed to have no safe threshold below which health impacts would not occur. Noncarcinogens differ in that there is generally assumed to be a safe level of exposure below which no negative health impact is believed to occur. These levels are determined on a pollutant-by-pollutant basis.

Regulatory Framework
Federal Clean Air Act and National Ambient Air Quality Standards (NAAQS). Pursuant to the Clean Air Act, the EPA has established ambient air quality standards to protect public health and welfare with an adequate margin of safety. These federal standards, known as NAAQS, were developed for the six criteria pollutants described above. NAAQS represent safe levels of each pollutant to avoid specific adverse effects to human health and the environment. Two types of NAAQS have been established, primary and secondary standards. Primary standards set limits to protect public health, especially that of sensitive populations such as asthmatics, children, and seniors. Secondary standards set limits to protect public welfare, including protections against decreased visibility and damage to animals, crops, and buildings. 401
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) The Clean Air Act was amended in 1977 to require each state to maintain a State Implementation Plan (SIP) for achieving compliance with the NAAQS. In 1990, the Clean Air Act was amended again to strengthen regulation of both stationary and mobile emission sources.

Attainment of Federal and State Air Quality Standards
Areas are classified under the Federal Clean Air Act and California Clean Air Act as attainment, non-attainment, or maintenance (areas that were previously non-attainment but are currently attainment) for each criteria pollutant based on whether the federal and state air quality standards have been achieved. With respect to the NAAQS, the SFBAAB is designated as a nonattainment area for ozone and PM2.5, and as an attainment or unclassified area for all other pollutants. With respect to the CAAQS, the SFBAAB is designated as a nonattainment area for ozone, PM10, and PM2.5, and as an attainment or unclassified area for all other pollutants (BAAQMD 2017b).
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) City of Dublin General Plan. The City of Dublin General Plan, adopted in 1985 and amended in 2022, includes an Environmental Resources Management: Conservation Element. The following policies related to air quality would be applicable to the proposed Project (City of Dublin 2022):
x Request that the Bay Area Air Quality Management District establish an air quality monitoring station in Dublin.
x Require an air quality analysis for new development projects that could generate significant air emissions on a project and cumulative level. Air quality analyses shall include specific feasible measures to reduce anticipated air quality emissions to a less-than-significant CEQA level.

Project Impacts and Mitigation Measures
(a) Consistent with air quality plans (Less Than Significant Impact with Mitigation Incorporated)
The Project would implement Mitigation Measure AQ-1. Implement Basic Construction Emission Control Practices to comply with BAAQMD’s Basic Construction Mitigation Measures during demolition and construction. Therefore, this impact would be less than significant with mitigation. This impact is further analyzed in the Focused EIR. (b) Project emissions (Less than Significant with Mitigation Incorporated) The Project would implement Mitigation Measure AQ-1. Implement Basic Construction Emission Control Practices to comply with BAAQMD’s Basic Construction Mitigation Measures during demolition and construction. With the implementation of Mitigation Measure AQ-1, construction of the proposed Project would not result in a cumulatively considerable net increase of any criteria pollutant for which the region is non-attainment under an applicable federal or state ambient air quality standard. During project operation, the proposed Project would result in a net reduction of emissions compared to existing conditions for NOx, PM10, and PM2.5, and ROG emissions would not exceed the BAAQMD thresholds of significance. Thus, this impact would be less than significant with mitigation. This impact is further analyzed in the Focused EIR.
(c) Expose sensitive receptors to pollutant concentrations (Less Than Significant Impact) Criteria Air Pollutants
As previously discussed, criteria air pollutants may adversely affect human or animal health, reduce visibility, damage property, and reduce the productivity or vigor of crops and natural vegetation. As shown in Table 3: Project Consistency with Applicable CAP 2030 GHG Emissions Reduction Measures, construction activities would result in emissions of criteria air pollutants but at levels that would not exceed the BAAQMD thresholds of significance. Operation of the proposed Project would result in a net reduction in NOX, PM10, and PM2.5 emissions compared to existing conditions because the proposed Project is an energy-efficient, all-electric, building that would generate fewer daily vehicle trips, while the slight increase in ROG emissions would not exceed the BAAQMD thresholds of significance. The construction and operational 403
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) thresholds of significance were designed to identify those projects that would result in significant levels of air pollution and to assist the region in attaining the applicable state and federal ambient air quality standards, which were established using health-based criteria to protect the public with a margin of safety from adverse health impacts due to exposure to air pollution.

The proposed Project is estimated to generate approximately 2 tons of NOx emissions and less than 1 ton of ROG emissions during demolition and construction activities. As discussed above, NOx and ROG are ozone precursors. Individuals exercising outdoors, children, and people with lung disease, such as asthma and chronic pulmonary lung disease, are considered to be the most susceptible subgroups for ozone effects. Short-term ozone exposure (lasting for a few hours) can result in changes in breathing patterns, reductions in breathing capacity, increased susceptibility to infections, inflammation of lung tissue, and some immunological changes.

Chronic exposure to high ozone levels can permanently damage lung tissue (BAAQMD 2017a).

Because of the reaction time and other factors involved in ozone formation, ozone is considered a regional pollutant that is not linearly related to emissions (i.e., ozone impacts vary depending on the location of the emissions, the location of other precursor emissions, meteorology, and seasonal impacts). Peak ozone concentrations often occur far downwind of the precursor emissions. Thus, ozone is considered a regional pollutant that often affects large areas. There currently is no way to accurately quantify ozone-related health impacts from NOX and ROG emissions from small projects. These limitations are due to photochemistry and regional model limitations; it takes a large amount of additional precursor emissions to cause a modeled increase in ambient ozone levels (SCAQMD 2015). However, because the BAAQMD regional thresholds of significance for NOX and ROG were established with these factors in mind, the considering that the proposed Project’s emissions would be less than the BAAQMD thresholds indicates that the project’s NOX and ROG emissions would not expose sensitive receptors to substantial concentrations of ozone. In addition, the proposed Project would comply with applicable BAAQMD rules, including but not limited to Regulation 6 (Particulate Matter), which reduces the amount of PM entrained in the ambient air. Furthermore, the existing building would be replaced with an energy-efficient, all-electric, building that would generate fewer daily vehicle trips; thus, operation of the proposed Project would also result in a net reduction in regional energy and mobile source criteria air pollutant emissions. Therefore, criteria air pollutant emissions associated with construction and operation of the proposed Project would not expose sensitive receptors to substantial criteria pollutant concentrations.

Toxic Air Contaminants
The health effects associated with TACs are quite diverse and generally are assessed locally, rather than regionally. TACs can cause long-term health effects such as cancer, birth defects, neurological damage, asthma, bronchitis or genetic damage; or short-term acute affects such as eye watering, respiratory irritation (a cough), running nose, throat pain, and headaches. The greatest potential TAC emissions would be related to diesel PM emissions associated with activity by heavy-duty construction equipment. The total duration of construction activities is anticipated to be approximately 12 months; the exposure of sensitive receptors to construction emissions would be short term, intermittent, and temporary in nature. Health effects from TACs are often described in terms of individual cancer risk, which is based on a 30-year lifetime 404
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) exposure to TACs (OEHHA 2015). Therefore, the total exposure period for construction activities would be approximately 3 percent of the total exposure period used for typical health risk calculations (i.e., 30 years). As shown in Table 3, construction related PM2.5 exhaust, a proxy for diesel PM emissions, would be substantially below the thresholds of significance.

Construction activities would vary and span across 8.30 acres of Parcel 1. For example, although the nearest sensitive receptors are the surrounding residences located 200 feet and 570 feet away from the Project boundaries, as construction activity occurs across the 8.30 acres of Parcel 1 of the Project site, construction-related emissions would occur at varying distances as far as 1,380 feet from receptors (when construction activities are occurring at the southwestern end of the Project site) and as close as 200 feet (when construction activities are occurring at the northern end of the Project site). Concentrations of mobile-source diesel PM emissions are typically reduced by approximately 60 percent at a distance of 300 feet (100 meters) (Zhu et al. 2002). Therefore, trucks and off-road equipment would not operate in the immediate vicinity of any sensitive receptor for an extended period of time and the potential exposure to TAC emission concentrations would be limited.

Given the construction schedule, varying topography and buffer distances to the nearest sensitive receptors, and the highly dispersive nature of diesel PM emissions, construction of the proposed Project would not expose sensitive receptors to substantial TAC concentrations that could cause short- or long-term health effects. In addition, TAC emission exposure would also be reduced with implementation of CARB regulations, such as the Airborne Toxic Control Measure, which limits idling of diesel-fueled commercial motor vehicles. The demolition and hazardous waste abatement activities would also comply with BAAQMD Regulation 11, Rule 2 (Asbestos Demolition, Renovation and Manufacturing), which would control emissions of asbestos to the atmosphere and reduce exposure of receptors to this TAC.

As discussed previously, the proposed Project would result in fewer daily vehicle trips compared to existing conditions; thus, TAC emissions associated with mobile source emissions (e.g., diesel PM from diesel-fueled vehicles) would be lower than existing conditions. The proposed Project includes a diesel-fired fire pump, which would be a source of TAC emissions.

However, the fire pump would be permitted per BAAQMD rules and regulations and would not be operated for extended periods of time; thus, emissions would be limited to infrequent operation and during maintenance and testing activities. Therefore, the proposed Project would not result in an increase in TAC emissions beyond existing conditions and the proposed Project would not expose sensitive receptors to substantial pollutant concentrations.

Therefore, this impact would be less than significant.
(d) Odors (Less Than Significant)
The occurrence and severity of odor impacts depend on numerous factors, including the nature, frequency, and intensity of the source; wind speed and direction; and the presence of sensitive receptors. While offensive odors rarely cause any physical harm, they still can be very unpleasant, leading to considerable distress and often generating citizen complaints to local governments and regulatory agencies. Projects with the potential to frequently expose individuals to objectionable odors are deemed to have a significant impact. Typical facilities that generate odors include wastewater treatment facilities, sanitary landfills, composting 405
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Construction activities associated with the proposed Project could result in short-term odor emissions from asphalt paving activities and diesel exhaust associated with construction equipment. The proposed Project would use typical construction techniques; odors would be typical of most construction sites and limited to duration of construction. Furthermore, nuisance odors are regulated under the BAAQMD’s Regulation 7, Odorous Substances, which requires abatement of any nuisance generating an odor complaint. Regulation 7 places general limitations on odorous substances, and specific emission limitations on certain odorous compounds. Since the proposed Project involves the redevelopment of an existing industrial building with a new industrial building, the proposed Project would not introduce a new odorgenerating source. Thus, the proposed Project would not result in other emissions (such as those leading to odors) that would adversely affect a substantial number of people. This impact would be less than significant.

Accessed January 2021.

City of Dublin. 2022. General Plan. Available online:
https://www.dublin.ca.gov/DocumentCenter/View/30287/General-Plan-Update04192022-WEB. Accessed March 2023.

Office of Environmental Health Hazard (OEHHA). 2015. Air Toxics Hot Spots Program: Risk Assessment Guidelines. February. Available online:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. Accessed February 2023.

South Coast Air Quality Management District (SCAQMD). 2015. Sierra Club v. County of Fresno.

Brief amicus curiae of South Coast Air Quality Management District. April 6, 2015. 406
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Available online: https://www.courts.ca.gov/documents/9-s219783-ac-south-coast-airquality-mgt-dist-041315.pdf. Accessed February 2023.

W Traffic Engineering Transportation Planning (W-Trans). 2022. Final Transportation Impact Study for the Hexcel Redevelopment Project. December.

Zhu, Y., W. C. Hinds, S. Kim, and S. Shen. 2002. Study of Ultrafine Particles Near a Major Highway with Heavy-duty Diesel Traffic. Atmospheric Environment. 36:4323–4335. 407
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Biological Resources

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

4. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
X
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
X
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
X
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
X
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
X
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
X
Environmental Setting
This section describes the existing biological setting within the Project site, which consists of two adjacent parcels, Parcel 1 and Parcel 2. The focus of the analysis was based on the areas potentially directly or indirectly affected by construction of the Project, referred to herein as the Project footprint. The Project footprint is exclusively in Parcel 1. 408
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) The City of Dublin is characterized by a diverse array of wildlife and plant species, with two discrete habitat types—the flatter urbanized portion of the City and the surrounding oak woodland and California annual grassland. The Project site is located within the urbanized area, which exhibits plant and animal species typical of urbanized areas including a combination of native and introduced trees, grasses and shrubs used for landscaping purposes.

Regulatory Framework
Migratory Bird Treaty Act
The Migratory Bird Treaty Act of 1918 makes it illegal to take, possess, import, export, transport, sell, purchase, barter, or offer for sale, purchase, or barter any migratory bird, or the 409
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) parts, nests, or eggs of such bird, except under the terms of a valid federal permit. Migratory bird species protected by the act are listed in the Code of Federal Regulations (CFR) in 50 CFR Part 10.13. The U.S. Fish and Wildlife Service has statutory authority for enforcing the Migratory Bird Treaty Act (16 United States Code Sections 703-712).

The U.S. Fish and Wildlife Service maintains a list of endangered species that includes birds, insects, fish, reptiles, mammals, crustaceans, plants, and trees. The U.S. Fish and Wildlife Service and/or National Marine Fisheries Service requires authorization for any actions that they authorize, carry out, or fund, that may jeopardize the continued existence of any listed species or result in the destruction or adverse modification of designated critical habitat.

City of Dublin Municipal Code
The City of Dublin Municipal Code Chapter 5.60: “the Heritage Tree Ordinance” (Ord. 5-02 § 2 (part): Ord. 29-99 § 1 (part)), requires that a Tree Removal permit from the Director be acquired prior to the removal of heritage trees. Heritage trees include:
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2. A tree required to be preserved as part of an approved development plan, zoning permit, use permit, site development review or subdivision map;

Erosion control plans shall include recommendations for preventing erosion and scour of drainageways, consistent with biological and visual values. x Implementing Policy 7.4.1B2: Enact and enforce the Heritage Tree Ordinance Project Impacts and Mitigation Measures
(a) Substantial adverse effect on candidate, sensitive, or special status species (Less Than Significant Impact with Mitigation Incorporated)
Noise and vibration from proposed construction activities associated with the Project could disturb birds that are nesting on and near the Project site. In addition, the Project would involve the removal of approximately 85 landscape trees within the Project footprint, which could be used by birds during the nesting season. If a tree containing an active nest were to be removed during construction, such removal would result in nest destruction and failure. Due to this potential for loss of nests, and due to potential disturbance of nesting birds from noise and vibration during Project construction, the impact to nesting birds would be potentially significant. The implementation of Mitigation Measure BIO-1: Nesting Bird Avoidance Measures would bring this impact down to a less than significant impact. This impact is further analyzed in the Focused EIR.
411
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) (b) Substantial adverse effect on any riparian habitat or other natural community (Less Than Significant Impact)
No riparian habitat or other sensitive natural communities are located within the Project footprint; therefore, Project construction or operation would not directly impact riparian habitat or other sensitive natural communities. Dublin Creek is located approximately 5 feet south of the Project footprint on Parcel 2; however, proposed construction activities and continued operation of the site would not remove, fill, or hydrologically interrupt this feature.

Construction would occur within 5 feet of riparian trees within Dublin Creek; however, construction activities will occur on existing paved areas (parking lot), and no construction equipment will enter Dublin Creek and associated riparian habitat. No trees or vegetation along Dublin Creek would be disturbed during construction. In the event that runoff from the Project or accidental spills entered Dublin Creek, sedimentation or the introduction of pollutants to Dublin Creek would constitute a potentially significant impact. As discussed further in Section 9, Hydrology, the Project would avoid sedimentation or the introduction of pollutants to Dublin Creek through the required implementation of erosion and sediment control measures and the implementation of BMPs specified in the Stormwater Pollution Prevention Plan (SWPPP) during construction, which would protect water quality.

Disturbance from noise and vibration (see Section 12) on wildlife could result during construction activities. However, these impacts would be minimal and only for a temporary period of time during construction. Furthermore, construction of the Project does not have the potential to result in introduction of non-native weeds to the riparian corridor of Dublin Creek.

Thus, no substantial indirect effects to the Dublin Creek Riparian corridor are expected.

Therefore, the Project would have less than significant impact on riparian habitat and sensitive natural communities. No mitigation measures are required. (c) Substantial adverse effect on wetlands (Less Than Significant Impact) No wetlands or other waters of the U.S. or state are located within the Project footprint; therefore, Project construction or operation would not directly impact wetlands and other waters. Dublin Creek is a water of the U.S. and water of the State and is located immediately south of the Project footprint. However, the Project footprint adjacent to Dublin Creek is located in an existing paved parking lot. Proposed construction activities and continued operation of the site would not removal, fill, or hydrologically interrupt this feature. No development would occur within 5 feet of top of bank.

As discussed in Impact b above, the Project would avoid sedimentation or the introduction of pollutants to Dublin Creek through the required implementation of erosion and sediment control measures and the implementation of BMPs specified in the SWPPP during construction, which would protect water quality. Construction of the Project does not have the potential to result in introduction of non-native weeds to the riparian corridor of Dublin Creek.

Furthermore, vibration from construction would be minimal and temporary as described in Section 12.
412
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Therefore, the Project would have less than significant impact on wetlands and waters of the U.S. or state.
(d) Interfere or impede the movement of migratory fish or wildlife (Less Than Significant Impact with Mitigation Incorporated)
The riparian corridor associated with Dublin Creek could be used as foraging habitat for common bats. If construction were to remove trees containing bats during the maternity or winter season, bat mortality could occur, and the impact to common bat species would be potentially significant. With the implementation of Mitigation Measure BIO-2: Roosting Bat Surveys and Avoidance, potential Project impacts to wildlife movement, migration, or nursery sites would be reduced to a less than significant impact. This impact is further analyzed in the Focused EIR.
(e) Conflict with local policies or ordinance include tree preservation (Less Than Significant Impact)
Construction of the Project would require the removal of 85 trees. Of those trees, two trees are “Heritage Trees” as defined by the City of Dublin’s municipal code and “Heritage Tree Ordinance.” These trees are located at the northwest boundary of the Project footprint and at the center of the project footprint. The tree at the northwest boundary of the Project footprint is a valley oak (Quercus lobata) with a diameter breast height (DBH) of 31 inches, and the tree at the center of the Project footprint is a western sycamore (Platanus racemosa) with a DBH of

28.2 inches.

A tree removal permit would be required for the removal of these two heritage trees. The tree removal permit application would require an arborist’s report, tree preservation plan, and a tree replacement plan. The Project applicant has conducted an arborist survey and developed an arborist report, which will be attached to the application.

The tree protection plan will be developed to ensure that all other heritage trees on the Project footprint are adequately protected from potential harm during construction. The tree replacement plan will include a plan for replacement of removed Heritage Trees, including a plan for “1 or more replacement trees be planted of a designated species, size and location,” per the requirements of the Heritage Tree Ordinance.

The Dublin General Plan also requires that developers “protect riparian vegetation as a protective buffer for stream quality and for its value as a habitat and aesthetic resource.” The project would avoid the riparian corridor south of the Project footprint, and there would be no impact to riparian vegetation.

With adherence to the tree removal permit conditions, the Project would not conflict with the City’s tree ordinance or the Dublin General Plan, and potential impacts would be less than significant.
413
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) (f) Conflict with adopted habitat conservation or natural community conservation plans (No Impact)
The Project is not located within a Habitat Conservation Plan or Natural Communities Conservation Plan Permit Area. Because there are no Habitat Conservation Plans or Natural Communities Conservation Plans that apply to the Project site, the Project would not conflict with any such plans. Therefore, there would be no impact.

Source(s)
California Department of Fish and Wildlife Service (CDFW). 2023. Rarefind 5, a program created by the California Department of Fish and Wildlife that allows access to the California Natural Diversity Database. Reviewed January 17, 2023.

United States Fish and Wildlife Service (USFWS). 2023. IPaC Information for Planning and Consultation. Available online at: https://ecos.fws.gov/ipac/. Accessed on January 17, 2023.
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) Cultural Resources

ENVIRONMENTAL IMPACTS
Issues
Potentially
Significant
Impact
Less Than
Significant
Impact with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

5. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines
section 15064.5?
X
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to section 15064.5? X
c) Disturb any human remains, including those interred
outside of dedicated cemeteries?
X
Environmental Setting
The Project site is located south of Dublin Boulevard with the Dublin Heritage Park and Museums and Dublin Pioneer Cemetery to the east; Interstate (I-)580 to the south; and a business park to the west.

Historic-age built environment resources on the Project site consist of the Hexcel Corporation research and development (R&D) facility, landscaping, and parking. The Contemporary/Brutalist style facility has a roughly L-shaped plan and was largely constructed in two phases dating to 1962 and 1967, with small additions and alterations in the mid-1980s.

A full archaeological and historical context for the project site is provided in the Focused EIR.

Regulatory Framework
Cultural resources in California are protected by a number of regulations. The following provides a brief outline of the regulations, policies, and ordinances that are applicable to the proposed project.

Federal
National Historic Preservation Act
The National Historic Preservation Act (NHPA) (16 United States Code 470) and its implementing regulations (36 Code of Federal Regulations [CFR] 800) establish a program for the preservation of historic properties throughout the United States and provides a framework for identifying and treating historical and archaeological resources under the CEQA. Section 106 of the NHPA requires that federal projects or projects under federal jurisdiction consider the effect of an undertaking on properties eligible for or included in the National Register of Historic Places (NRHP). Historic properties that are listed in or eligible for the NRHP are considered historical resources for the purposes of CEQA. 416
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Historic properties are those significant cultural resources that are listed in or are eligible for listing in the NRHP per the criteria listed below (36 CFR 60.4):

The quality of significance in American, state, and local history, architecture, archeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association and meet one or more of the following criteria:
a. Are associated with events that have made a significant contribution to the broad patterns of our history;
b. Are associated with the lives of persons significant in our past; c. Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; d. Have yielded, or may be likely to yield, information important in prehistory or history.

Listing in the NRHP does not entail specific protection of, or assistance for a property. However, listing does guarantee the property’s recognition during planning for federal or federally assisted projects, eligibility for federal tax benefits, and qualification for federal historic preservation assistance. Additionally, project effects on properties listed in the NRHP must be evaluated under CEQA.

Historical Resources
“Historical resource” is a term with a defined statutory meaning (PRC § 21084.1; determining significant impacts to historical and archeological resources is described in the CEQA Guidelines, § 15064.5[a] and [b]). Per the CEQA Guidelines, section 15064.5(a), historical resources include the following:
417
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) (1) A resource listed in or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (CRHR) (PRC § 5024.1).
(2) A resource included in a local register of historical resources, as defined in PRC § 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC § 5024.1(g), will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant.
(3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be a historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. (4) The fact that a resource is not listed in or determined to be eligible for listing in the CRHR, not included in a local register of historical resources (pursuant to Cal. Pub. Resources Code § 5020.1(k)), or identified in a historical resources survey (meeting the criteria in Cal. Pub.

Resources Code § 5024.1(g)) does not preclude a lead agency from determining that the resource may be a historical resource as defined in Cal. Pub. Resources Code§§ 5020.1(j) or 5024.1.

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; or

2. Has a special and particular quality such as being the oldest of its type or the best available example of its type; or

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

If a project can be demonstrated to cause damage to a unique archeological resource, the lead agency may require reasonable efforts to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC Section 21083.2[a], [b], and [c]). 418
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Hexcel - Initial Study_7_26_23_Clean_Final.docx (7/26/23) California Register of Historical Resources
The CRHR is a guide to cultural resources that must be considered when a government agency undertakes a discretionary action subject to CEQA. The CRHR helps government agencies identify, evaluate, and protect California’s historical resources, and indicates which properties are to be protected from substantial adverse change (Pub. Resources Code, Section 5024.1(a)).

1. It is associated with events that have made a significant contribution to the broad pattern of California’s history and cultural heritage;

2. It is associated with the lives of persons important in our past;

3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. It has yielded, or may be likely to yield, information important in prehistory or history.

Codes Governing Human Remains
Section 7050.5 of the Health & Safety Code requires that construction or excavation be stopped in the vicinity of discovered human remains until the county coroner can determine whether the remains are those of a Native American. If the remains are determined to be Native American, the coroner must then contact the California Native American Heritage Commission (NAHC), which has jurisdiction pursuant to Public Res. Code § 5097. The NAHC, pursuant to PRC Section 5097.98, will immediately notify the person it believes to be most likely descendant (MLD), from the deceased Native American person so they can inspect the burial site and make recommendations for appropriate treatment or disposition.

Dublin City CouncilMarch 19, 2024

Dublin City Council
March 19, 2024