attach_3_final_eir_gp_update_aug_2022 — Lathrop City Council, September 19, 2022

FINAL

ENVIRONMENTAL IMPACT REPORT

FOR THE

LATHROP GENERAL PLAN UPDATE
(SCH: 2021100139)
AUGUST 2022
Prepared for:

City of Lathrop
Community Development Department, Planning Division
City of Lathrop
390 Towne Centre Drive
Lathrop, CA 95330
Prepared by:

De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
(916) 949-3231
D e N o v o P l a n n i n g G r o u p
A L a n d U s e P l a n n i n g , D e s i g n , a n d E n v i r o n m e n t a l F i r m

FINAL

ENVIRONMENTAL IMPACT REPORT

FOR THE

LATHROP GENERAL PLAN UPDATE
(SCH: 2021100139)
AUGUST 2022
Prepared for:

City of Lathrop
Community Development Department, Planning Division
City of Lathrop
390 Towne Centre Drive
Lathrop, CA 95330
Prepared by:

De Novo Planning Group
1020 Suncast Lane, Suite 106
El Dorado Hills, CA 95762
(916) 949-3231

TABLE OF CONTENTS TOC
Final Environmental Impact Report – Lathrop General Plan Update TOC-1

FINAL EIR
Chapter Page Number
Executive Summary .....................................................................................................................ES-1

1.0 Introduction..........................................................................................................................1.0-1

1.1 Purpose and Intended Uses of the EIR....................................................................1.0-1

1.2 Environmental Review Process ...............................................................................1.0-2

1.3 Organization of the Final EIR ...................................................................................1.0-4

2.0 Comments on Draft EIR and Responses...............................................................................2.0-1

2.1 Introduction.............................................................................................................2.0-1

2.2 List of Commenters .................................................................................................2.0-1

2.3 Comments and Responses ......................................................................................2.0-1

3.0 Errata ....................................................................................................................................3.0-1

3.1 Revisions to the Draft EIR........................................................................................3.0-1 Table Page Number
Table 2-1: List of Commenters on Draft EIR ...............................................................................2.0-1 Table 3.12-11: Baseline (2020) vs. Proposed General Plan (Roadway Noise) ...........................3.0-5

TOC TABLE OF CONTENTS
TOC-2 Final Environmental Impact Report – Lathrop General Plan Update This page left intentionally blank.

EXECUTIVE SUMMARY ES
Final Environmental Impact Report – Lathrop General Plan Update ES-1

INTRODUCTION
The City of Lathrop (City) has determined that a program-level environmental impact report (EIR) is required for the proposed General Plan (General Plan, or project) pursuant to the requirements of the California Environmental Quality Act (CEQA). CEQA requires the preparation of an EIR prior to approving any project, which may have a significant impact on the environment. For the purposes of CEQA, the term "Project" refers to the whole of an action, which has the potential for resulting in a direct physical change or a reasonably foreseeable indirect physical change in the environment (CEQA Guidelines Section 15378[a]).

A Program EIR is an EIR which examines the environmental impacts of an agency plan, policy, or regulatory program, such as a general plan update. Program EIRs analyze broad environmental impacts of the program, with the acknowledgement that site-specific environmental review may be required for particular aspects of the program, or particular development projects that may occur in the future.

Lathrop circulated a Notice of Preparation (NOP) of an EIR for the proposed project on October 8, 2021 to trustee and responsible agencies, the State Clearinghouse, and the public. A scoping meeting was held on October 27, 2021 at the City of Lathrop City Hall Council Chambers.

Subsequently, Lathrop published a public Notice of Availability (NOA) for the Draft EIR on May 27, 2022, inviting comment from the general public, agencies, organizations, and other interested parties. The NOA was filed with the State Clearinghouse (SCH# 2021100139) and was published in the San Joaquin County Clerk’s office and the Manteca Bulletin, pursuant to the public noticing requirements of CEQA. The Draft EIR was available for public review from May 27, 2022 through July 11, 2022. The Public Draft General Plan was also available for public review and comment during this time period.

This Final EIR was prepared to address comments received in response to the Draft EIR. The City has prepared a written response to the Draft EIR comments, and made textual changes to the Draft EIR where warranted. The responses to the comments are provided in this Final EIR in Section 2.0, and all changes to the text of the Draft EIR are summarized in Section 3.0. Responses to comments received during the comment period for the Draft EIR do not involve any new significant impacts or “significant new information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.

PROJECT DESCRIPTION
The Lathrop General Plan Update is the overarching policy document that guides land use, housing, transportation, open space, public safety, community services, and other policy decisions throughout Lathrop. The General Plan includes the seven elements mandated by State law, to the extent that they are relevant locally, including: Circulation, Conservation, Housing, Land Use, Noise, Open Space, and Safety. The City may also address other topics of interest. The Lathrop General Plan includes all of the State-mandated topics and elements, as well as optional elements and issue

ES EXECUTIVE SUMMARY
ES-2 Final Environmental Impact Report – Lathrop General Plan Update areas, including, Public Facilities and Services, Economic Development, and Health and Environmental Justice. The General Plan sets out the goals, policies, and actions in each of these areas, serves as a policy guide for how the City will make key planning decisions in the future, and guides how the City will interact with San Joaquin County, surrounding cities, and other local, regional, State, and Federal agencies.

The General Plan contains the goals and policies that will guide future decisions within the City. It also identifies implementation programs, in the form of actions, that will ensure the goals and policies in the General Plan are carried out. As part of the Lathrop General Plan Update, the City and the consultant team prepared several support documents that serve as the building blocks for the General Plan and analyze the environmental impacts associated with implementing the General Plan.

Refer to Chapter 2.0 (Project Description) of the Draft EIR for a more comprehensive description of the details of the proposed project.

ALTERNATIVES TO THE PROPOSED PROJECT
Section 15126.6 of the CEQA Guidelines requires an EIR to describe a reasonable range of alternatives to the project or to the location of the project which would reduce or avoid significant impacts, and which could feasibly accomplish the basic objectives of the proposed project. The alternatives analyzed in this EIR are briefly described as follows:
• Alternative 1: No Project Alternative. Under Alternative 1, the City would not adopt the General Plan Update. The existing Lathrop General Plan would continue to be implemented and no changes to the General Plan, including the Land Use Map, Circulation Diagram, goals, policies, or actions would occur. Subsequent projects, such as amending the Municipal Code (including the zoning map) and the City’s Design Guidelines, would not occur. The Existing General Plan Land Use Map is shown on Figure 5.0-1.
• Alternative 2: Modified Project Alternative. Under Alternative 2, the City would adopt the updated General Plan policy document, but would retain the existing land use map. This alternative would result in the same growth as the existing General Plan and Alternative 1, but would implement the updated goals, policies, and actions found in the General Plan Update. This Alternative would result in more residential growth, and less non-residential development than the proposed Project. This alternative was developed to potentially reduce the severity of impacts associated with noise, air quality, and workforce VMT. • Alternative 3: Balanced Density Residential Focused Alternative. Alternative 3 would adopt the General Plan Update, including the proposed General Plan Land Use Map and updated goals, policies, and actions. However, Alternative 3 would place more emphasis on residential development, increasing the allowed densities for the residential land uses, while reducing the intensity of non-residential development. For comparison it is assumed that this Alternative would result in a 25 percent increase in the number of new residential dwelling units, and a 10 percent decrease in jobs and non-residential square footage when

EXECUTIVE

SUMMARY
ES
ES-3 Final Environmental Impact Report – Lathrop General Plan Update compared to the proposed Project. This Alternative would result in the most dwelling units compared to all other Alternatives. This Alternative would also result in more nonresidential growth than Alternatives 1 and 2, but 10% less non-residential growth than the proposed Project. This alternative was developed to create a more equal jobs/housing balance, potentially reducing the severity of impacts related to greenhouse gas emissions and VMT, as new development would be within close proximity to the new job generating uses, which would help to reduce per capita employment VMT. Figure 2.0-2 of Chapter 2 (Project Description) shows the proposed General Plan Land Use Map.

Alternatives are described in detail in Section 5.0 of the Draft EIR. As summarized in Table 5.0-4 of the Draft EIR, Alternative 3 is the environmentally superior alternative, as it is the most effective in terms of overall reductions of impacts compared to the proposed General Plan and all other alternatives. As such, Alternative 3 is the environmentally superior alternative for the purposes of this EIR analysis. Information related to alternatives and their respective impacts are described in Chapter 5.0 of this DEIR.

COMMENTS RECEIVED
The Draft EIR addresses environmental impacts associated with the proposed project that were known to the City, raised during the Notice of Preparation (NOP) process, or raised during preparation of the Draft EIR. The Draft EIR discusses potentially significant impacts associated with aesthetics, agriculture and forest resources, air quality, biological resources, cultural and tribal cultural resources, geology, greenhouse gas emissions and energy, hazards and hazardous materials, hydrology and water quality, land use planning and population/housing, mineral resources, noise, public services and recreation, transportation, utilities and service systems, wildfire, and cumulative impacts.

NOP Comments
During the NOP process, the City received comments from the following public agencies, organizations, or individuals:
• California Department of Conservation (November 1, 2021) • California Valley Miwok Tribe (October 26, 2021)
• Central Valley Water Quality Control Board (November 8, 2021) • Native American Heritage Commission (October 12, 2021) • San Joaquin Valley Air Pollution Control District (November 4, 2021)

ES EXECUTIVE SUMMARY
ES-4 Final Environmental Impact Report – Lathrop General Plan Update Draft EIR Comments
During the Draft EIR review process, the City received comments from the following public agencies, organizations, or individuals:
• Tom Dumas, California Department of Transportation (June 20, 2022) • Carmen J. Borg, Winter King, SHUTE, MIHALY & WEINBERGER LLP (July 11, 2022) • Aldara Salinas, San Joaquin County Environmental Health Department (July 11, 2022) • Jeff Henderson, Delta Stewardship Council (July 11, 2022) • James and Brenda Hystad, Residents (July 11, 2022)
• J.D. Hightower, City of Manteca (July 11, 2022)
• Mark Montelongo, San Joaquin Valley Air Pollution Control District (July 11, 2022) Acting as lead agency, the City of Lathrop has prepared a response to the Draft EIR comments. The responses to the comments are provided in this Final EIR in Section 2.0 (Comments on Draft EIR and Responses) and all changes to the text of the Draft EIR and Recirculated Draft EIR are summarized in Section 3.0 (Errata).

INTRODUCTION 1.0
Final Environmental Impact Report – Lathrop General Plan Update 1.0-1 This Final Environmental Impact Report (FEIR) was prepared in accordance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines (Section 15132). The City of Lathrop is the lead agency for the environmental review of the Lathrop General Plan (General Plan, General Plan Update, or Project) and has the principal responsibility for approving the project. This FEIR assesses the expected environmental impacts resulting from approval and adoption of the Lathrop General Plan and responds to comments received on the Draft EIR.

The Lathrop General Plan Update is the overarching policy document that guides land use, housing, transportation, open space, public safety, community services, and other policy decisions throughout Lathrop. The General Plan includes the seven elements mandated by State law, to the extent that they are relevant locally, including: Circulation, Conservation, Housing, Land Use, Noise, Open Space, and Safety. The City may also address other topics of interest. The Lathrop General Plan includes all of the State-mandated topics and elements, as well as optional elements and issue areas, including, Public Facilities and Services, Economic Development, and Health and Environmental Justice. The General Plan sets out the goals, policies, and actions in each of these areas, serves as a policy guide for how the City will make key planning decisions in the future, and guides how the City will interact with San Joaquin County, surrounding cities, and other local, regional, State, and Federal agencies.

Refer to Chapter 2.0 (Project Description) of the Draft EIR for a more comprehensive description of the details of the proposed project.

1.1 PURPOSE AND INTENDED USES OF THE EIR

CEQA REQUIREMENTS FOR A FINAL EIR
This FEIR for the Lathrop General Plan has been prepared in accordance with the California Environmental Quality Act (CEQA) and State CEQA Guidelines. State CEQA Guidelines Section 15132 requires that an FEIR consist of the following:
• the Draft Environmental Impact Report (Draft EIR) or a revision of the draft; • comments and recommendations received on the Draft EIR, either verbatim or in summary; • a list of persons, organizations, and public agencies commenting on the Draft EIR; • the responses of the lead agency to significant environmental concerns raised in the review and consultation process; and
• any other information added by the lead agency.

1.0 INTRODUCTION

1.0-2 Final Environmental Impact Report – Lathrop General Plan Update In accordance with State CEQA Guidelines Section 15132(a), the Draft EIR is incorporated by reference into this Final EIR.

An EIR must disclose the expected environmental impacts, including impacts that cannot be avoided, growth-inducing effects, impacts found not to be significant, and significant cumulative impacts, as well as identify mitigation measures and alternatives to the proposed project that could reduce or avoid its adverse environmental impacts. CEQA requires government agencies to consider and, where feasible, minimize environmental impacts of proposed projects, and obligates them to balance a variety of public objectives, including economic, environmental, and social factors.

PURPOSE AND USE
The City of Lathrop, as the lead agency, has prepared this Final EIR to provide the public and responsible and trustee agencies with an objective analysis of the potential environmental impacts resulting from approval and implementation of the General Plan. Responsible and trustee agencies that may use the EIR are identified in Chapter 1.0 of the Draft EIR.

The environmental review process enables interested parties to evaluate the proposed project in terms of its environmental consequences, to examine and recommend methods to eliminate or reduce potential adverse impacts, and to consider a reasonable range of alternatives to the project.

While CEQA requires that consideration be given to avoiding adverse environmental effects, the lead agency must balance adverse environmental effects against other public objectives, including the economic and social benefits of a project, in determining whether a project should be approved.

This EIR will be used as the primary environmental document to evaluate all subsequent planning and permitting actions associated with the proposed project. Subsequent actions that may be associated with the proposed project are identified in Chapter 2.0 (Project Description) of the Draft EIR. This EIR may also be used by other agencies within San Joaquin County, including the San Joaquin Local Agency Formation Commission (LAFCO), which may use this EIR during the preparation of environmental documents related to annexations, Municipal Service Reviews, and Sphere of Influence decisions in the Lathrop Planning Area.

1.2 ENVIRONMENTAL REVIEW PROCESS
The review and certification process for the EIR has involved, or will involve, the following general procedural steps:

NOTICE OF PREPARATION
The City of Lathrop circulated a Notice of Preparation (NOP) of an EIR for the proposed project on October 8, 2021 to trustee and responsible agencies, the State Clearinghouse, and the public. A scoping meeting was held on October 27, 2021 at the City of Lathrop City Hall Council Chambers.

Thirteen public and agency comments on the NOP related to the EIR analysis were presented or submitted during the scoping meeting. In addition, during the 30-day public review period for the NOP, which ended on November 8, 2021, six comment letters were received on the NOP. A INTRODUCTION 1.0
Final Environmental Impact Report – Lathrop General Plan Update 1.0-3 summary of the NOP comments is provided in Section 1.8 of the Draft EIR. The NOP and all comments received on it are presented in Appendix A of the Draft EIR.

NOTICE OF AVAILABILITY AND DRAFT EIR
The City of Lathrop published a public Notice of Availability (NOA) for the Draft EIR on May 27, 2022 inviting comment from the general public, agencies, organizations, and other interested parties. The NOA was filed with the State Clearinghouse (SCH# 2021100139) and was published in the San Joaquin County Register pursuant to the public noticing requirements of CEQA. The Draft EIR was available for public review from May 27, 2022 through July 11, 2022. The Public Draft General Plan was also available for public review and comment during this time period.

The Draft EIR contains a description of the project, description of the environmental setting, identification of project impacts, and mitigation measures for impacts found to be significant, as well as an analysis of project alternatives, identification of significant irreversible environmental changes, growth-inducing impacts, and cumulative impacts. The Draft EIR identifies issues determined to have no impact or a less than significant impact, and provides detailed analysis of potentially significant and significant impacts. Comments received in response to the NOP were considered in preparing the analysis in the Draft EIR.

RESPONSE TO COMMENTS/FINAL EIR
The City of Lathrop received seven comment letters regarding the Draft General Plan and Draft EIR from public agencies, organizations, and members of the public during the 45-day review period.

In accordance with CEQA Guidelines Section 15088, this Final EIR responds to the written comments received on the Draft EIR. The Final EIR also contains minor edits to the Draft EIR, which are included in Chapter 3.0 (Errata). This document and the Draft EIR, as amended herein, constitutes the Final EIR.

CERTIFICATION OF THE EIR/PROJECT CONSIDERATION
The Lathrop City Council will review and consider the Final EIR. If the City Council finds that the Final EIR is "adequate and complete," then it may certify it in accordance with CEQA. The rule of adequacy generally holds that an EIR can be certified if:
1) The EIR shows a good faith effort at full disclosure of environmental information; and 2) The EIR provides sufficient analysis to allow decisions to be made regarding the proposed project in contemplation of environmental considerations.

Upon review and consideration of the Final EIR, the Lathrop City Council may take action to approve, revise, or reject the project. A decision to approve the Lathrop General Plan, for which this EIR identifies significant environmental effects, must be accompanied by written findings in accordance with State CEQA Guidelines Sections 15091 and 15093.

1.0 INTRODUCTION

1.0-4 Final Environmental Impact Report – Lathrop General Plan Update Policies and actions to minimize potential environmental impacts have been incorporated into the project, to the extent feasible. No additional mitigation is feasible or available, as described in Chapters 3.1 through 4.0 of the Draft EIR. The annual report on general plan status required pursuant to the Government Code will serve as the monitoring and reporting program for the project.

1.3 ORGANIZATION OF THE FINAL EIR
This Final EIR has been prepared consistent with Section 15132 of the State CEQA Guidelines, which identifies the content requirements for Final EIRs. This Final EIR is organized in the following manner:

CHAPTER 1.0 – INTRODUCTION
Chapter 1.0 briefly describes the purpose of the environmental evaluation, identifies the lead agency, summarizes the process associated with preparation and certification of an EIR, and identifies the content requirements and organization of the Final EIR.

CHAPTER 2.0 – COMMENTS ON DRAFT EIR AND RESPONSES
Chapter 2.0 provides a list of commenters, copies of written comments made on the Draft EIR (coded for reference), and responses to those written comments.

CHAPTER 3.0 – ERRATA
Chapter 3.0 consists of minor revisions to the Draft EIR in response to comments on the Draft EIR.

The revisions to the Draft EIR do not change the intent or content of the analysis or mitigation.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-1

2.1 INTRODUCTION
No new significant environmental impacts or issues, beyond those already covered in the Draft EIR for the Lathrop General Plan Environmental Impact Report (DEIR), were raised during the comment period.

Responses to comments received during the comment period do not involve any new significant impacts or add “significant new information” that would require recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5.

CEQA Guidelines Section 15088.5 states that: New information added to an EIR is not “significant” unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement.

Sections 2.0 and 3.0 of this Final EIR include information that has been added to the EIR since the close of the public review period in the form of responses to comments and revisions.

2.2 LIST OF COMMENTERS
Table 2.0-1 lists the comments on the Draft EIR that were submitted to the City of Lathrop (City) during the 45-day public review period for the Draft EIR. The assigned comment letter or number, letter date, letter author, and affiliation, if presented in the comment letter or if representing a public agency, are also listed. Letters received are coded with letters (A, B, etc.).

TABLE 2.0-1 LIST OF COMMENTERS ON DRAFT EIR

RESPONSE
LETTER

INDIVIDUAL OR SIGNATORY AFFILIATION
LETTER
DATE
A Tom Dumas California Department of Transportation 6/20/22 B
Carmen J. Borg,
Winter King, SHUTE, MIHALY & WEINBERGER LLP. 7/11/22
C Aldara Salinas San Joaquin County Environmental Health Department 7/11/22 D Jeff Henderson Delta Stewardship Council 7/11/22
E
James and Brenda
Hystad Residents 7/11/22
F J.D. Hightower City of Manteca 7/11/22
G Mark Montelongo San Joaquin Valley Air Pollution Control District 7/11/22

2.3 COMMENTS AND RESPONSES

REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT EIR
CEQA Guidelines Section 15088 requires that lead agencies evaluate and respond to all comments on the Draft EIR that regard an environmental issue. The written response must address the significant environmental issue raised and provide a detailed response, especially when specific comments or suggestions (e.g., additional mitigation measures) are not accepted. In addition, the written response must be a good faith and reasoned analysis. However, lead agencies need only to respond to significant environmental issues associated with the project and do not need to provide all the information requested by the commenter, as long as a good faith effort at full disclosure is made in the EIR (CEQA Guidelines Section 15204).

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-2 Final Environmental Impact Report – Lathrop General Plan Update CEQA Guidelines Section 15204 recommends that commenters provide detailed comments that focus on the sufficiency of the Draft EIR in identifying and analyzing the possible environmental impacts of the project and ways to avoid or mitigate the significant effects of the project, and that commenters provide evidence supporting their comments. Pursuant to CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence.

CEQA Guidelines Section 15088 also recommends that revisions to the Draft EIR be noted as a revision in the Draft EIR or as a separate section of the Final EIR. Chapter 3.0 of this Final EIR identifies all revisions to the Sunrise Tomorrow Specific Plan Draft EIR.

RESPONSES TO COMMENT LETTERS
Written comments on the Draft EIR are reproduced on the following pages, along with responses to those comments. To assist in referencing comments and responses, the following coding system is used:

Each letter is lettered or numbered (i.e., Letter A) and each comment within each letter is numbered (i.e., comment A-1, comment A-2).

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-3 A-1
A-2
A-3
A-4

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-4 Final Environmental Impact Report – Lathrop General Plan Update Response to Letter A: California Department of Transportation Response A-1: The commenter requests that future development projects that may impact state transportation facilities be submitted to Caltrans for review and comment. The City of Lathrop is committed to working with the California Department of Transportation to improve the transportation system and to address future transportation impacts. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response A-2: The commenter suggests that the City consider zoning high density residential near the planned North Lathrop ACE station, and create a station area specific plan.

Page 429 ends

uses as defined by the County Assessor’s Office. The future Valley Link Station is designated for TOD-RI:

Transit-Oriented Development. The existing and future ACE Stations are located in areas designated by the General Plan’s Land Use Map for industrial uses. These sites may have site constraints including potential land use conflicts and contamination for past site uses, and may not be suitable for residential developments.

These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response A-3: The commenter references page 504 of the DEIR, and notes that the 2019 ACS journey to work mode split data is pre-COVID and suggests using more recent post-COVID travel behavior pattern data source if available.

At the time of DEIR publication, ACS 2019 and 2020 were currently available at https://data.census.gov/. as such, the 2019 ASC 5-year estimates represent the best available data at the publication of this DEIR.

Future individual Project will utilize the best available data to reflect travel behavioral changes. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response A-4: The commenter recommends a Complete Streets approach to planning that promotes transit, bicycle, and pedestrian connectivity.

The General Plan supports complete streets and includes the following policies and actions that promote complete streets throughout the community:
• CIR-1.2 Complete Streets. Consider all modes of travel in planning, design, and construction of all transportation projects to create safe, livable, and inviting environments for pedestrians, bicyclists, motorists and public transit users of all ages and capabilities. • CIR-1a Review and revise roadway standards to accommodate complete streets, addressing the following factors as applicable: number of travel lanes, lane width, medians, drainage COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-5 control, shoulder width, parking lanes, bike lanes, fire and emergency response standards, curb and gutter design, landscaped strips, and sidewalk width. • CIR-1d Use traffic calming tools to assist in implementing complete street principles; possible tools include roundabouts, raised intersections, curb extensions, reduced roadway width, and high visibility crosswalks.
• CIR-1e Review and update the City’s standard plans to ensure that the plans reflect the City’s complete streets goals, incorporate best practices for traffic safety, and accommodate all users.

Features may include narrower lanes (less than 12 feet), pedestrian bulb-outs, traffic calming, separated bike paths and other features.
• EJ-6.2 Active Transportation. Support walking and bicycling by requiring complete streets (i.e. bike lanes, sidewalks separated from the roadway with trees and planted landscaping) in transit priority areas, in environmental justice communities, and in new communities and developments, wherever practicable.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-6 Final Environmental Impact Report – Lathrop General Plan Update B-1
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-7 B-1 Cont.

B-2
B-3

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-8 Final Environmental Impact Report – Lathrop General Plan Update B-3 Cont.

B-4
B-5
B-6
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-9 B-7
B-6 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-10 Final Environmental Impact Report – Lathrop General Plan Update B-7 Cont.

B-8
B-9
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-11 B-10
B-11
B-9 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-12 Final Environmental Impact Report – Lathrop General Plan Update B-11 Cont.

B-12
B-13
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-13 B-13 Cont.

B-14

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-14 Final Environmental Impact Report – Lathrop General Plan Update B-15
B-14 Cont.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-15 B-16
B-15 Cont.

B-17

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-16 Final Environmental Impact Report – Lathrop General Plan Update B-17 Cont.

B-18
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-17 B-18 Cont.

B-19

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-18 Final Environmental Impact Report – Lathrop General Plan Update B-20
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-19

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-20 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-21

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-22 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-23

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-24 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-25

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-26 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-27

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-28 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-29

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-30 Final Environmental Impact Report – Lathrop General Plan Update COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-31 Response to Letter B: Concerned Citizens
Response B-1: The commenter provides introductory remarks and asserts that the Draft EIR fails to meet the requirements of CEQA. The commenter states that the proposed land use map would result in significant impacts related to air quality, noise and safety. This comment is noted. The commenter is correct that the Draft EIR identifies significant and unavoidable impacts related to the topics listed above.

The commenter further states that sensitive receptors located south of Dos Reis Road would be significantly impacted by potential future light industrial development north of Dos Reis Road, however, the commenter provides no details or supporting information for this statement in this paragraph, other than to vaguely state that the General Plan policies and actions cited in the Draft EIR fail to comply with CEQA. The concerns raised by the commenter in this paragraph (air quality impacts to sensitive receptors, noise, and safety impacts) are addressed in greater detail and specificity in the comments and responses below.

Response B-2: The commenter notes the importance of General Plan Updates and the planning process, notes the requirements to address air quality and environmental justice in General Plans, and summarizes some of the outreach efforts and workshops that the City conducted as part of the overall General Plan Update process. The commenter states that the DEIR failed to disclose that Lathrop is one of the most disproportionately impacted communities, and expresses concern over the proposed redesignation of land located north of Dos Reis Road to Limited Industrial. The commenter states that the proposed Limited Industrial land noted above would have short and long term air quality and health effects.

The proposed Lathrop General Plan Update includes a comprehensive approach to reducing air quality impacts and implementing environmental justice requirements established by SB 1000. For example, the proposed Lathrop General Plan includes a stand-alone Environmental Justice Element, which addresses state-mandated topics including:
• Reduce GHG Emissions through Land Use Patterns
• Reduce Pollution Exposure and Improve Air Quality
• Promote Access to Public Facilities
• Healthy Food Access
• Safe and Sanitary Homes
• Promote Physical Activity and Connectivity
• Improve Fitness and Health
• Promote Civil Engagement
• Prioritize Improvements and Programs for Environmental Justice Communities Additionally, the proposed General Plan Recreation and Resources Element includes numerous policies and actions related to air quality and the protection of sensitive receptors, and includes performance-

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-32 Final Environmental Impact Report – Lathrop General Plan Update based actions that require future projects to comply with all applicable Air District rules and emissions thresholds (see Goal RR-6 and supporting policies and actions).

The potential for the proposed project to result in significant impacts related to air quality and health risks to sensitive receptors is addressed in extensive detail in Chapter 3.3, Air Quality, of the Draft EIR.

For example, DEIR pages 3.3-1 through 3.3-3 describe the San Joaquin Valley Air Basin in detail, including climate, wind patterns, temperatures, precipitation, fog, and inversions. Pages 3.3-3 through 3.3-8 describe criteria pollutants that are regulated by the SJVAPCD, and identifies the potential health risks associated with exposure to these criteria pollutants. Table 3.3-2 identifies San Joaquin County’s attainment status for each regulated criteria pollutant. Chapter 3.3 of the DEIR also includes a detailed summary of applicable air quality regulations at the local, state, and federal level, and describes ongoing efforts to address air pollution throughout the San Joaquin Valley.

The commenter states, without providing details or supporting information, that “Limited Industrial development adjacent to Lathrop High school and the community will have both short-term and longterm air quality and health effects.” The commenter is referred to Impacts 3.3-1 and 3.3-2, which address pollution generation associated with General Plan buildout and the potential for sensitive receptors to be exposed to substantial pollutant concentrations. The concerns raised by the commenter have been thoroughly addressed in the DEIR. The commenter does not provide any specific examples of alleged deficiencies or errors in the DEIR. As such, a more detailed response to this comment is not required.

Response B-3: The commenter summarizes information contained in the DEIR related to existing air quality conditions in the San Joaquin Valley, and summarizes information in the DEIR related to health impacts associated with exposure to air quality emissions. The commenter states that “Rather than clearly guide industrial development away from established schools and residential neighborhoods, this updated land use change would place industrial uses immediately adjacent to homes and schools, exacerbating the community’s existing burden.” This comment does not directly address the adequacy of the DEIR and its air quality analysis. As noted above, the DEIR includes a detailed analysis of air quality emissions and sensitive receptors.

The City of Lathrop respects and appreciates the commenter’s concerns related to air quality and the potential for sensitive receptors to be exposed to harmful levels of pollution. As such, the City has taken a thoughtful and holistic approach to the proposed land use map, including the proposed changes to land uses located north of Dos Reis Road. While the commenter has not specifically identified an alleged error or omission in the DEIR analysis related to this topic, the City feels it is important to describe several important factors and considerations that went into the drafting of the proposed land use map and the policies and actions in the Draft General Plan.

The area in question includes approximately 670 acres of predominantly vacant land, located north of Dos Reis Road, west of Interstate 5, within the northern portion of the Central Lathrop Specific Plan. It is designated Limited Industrial on the proposed Land Use Map. It is currently designated primarily as Variable Density Residential on the existing Land Use Map. Senate Bill 5 requirements by the State to complete the newly defined 200-year flood improvements by 2028, estimated to cost in excess of $250 COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-33 million, will make residential development in this area risky and generally infeasible. It will take several years to entitle and construct infrastructure to serve the northern Central Lathrop Specific Plan area. Residential building permits cannot be issued after 2028 unless the 200-year flood improvements are complete, and will be stopped earlier if Lathrop cannot guarantee Adequate Progress toward completing the improvements by 2028. In other words, residential development within this area is generally considered to be infeasible, and may expose future residences to significant flood risks. The proposed change to Limited Industrial in this area provides opportunities for increased local employment, the generation of tax revenues for the City, a higher degree of certainty for the development community, and would not place homes or residents in an area at risk for flooding.

The area in question is located in the northwestern portion of Lathrop. Lands to the north and east are comprised of agricultural lands located in San Joaquin County, and do not include sensitive receptors.

The area is bordered by Manthey Road, Interstate 5, and South Harlan Road to the east. The closest sensitive receptors to the area in question are existing and planned residential uses and Lathrop High School, located south of Dos Reis Road.

In order to ensure that the potential for pollution exposure to existing and future sensitive receptors is reduced to the greatest extent feasible, the proposed General Plan includes numerous goals, policies and implementation actions which would further the fundamental goals of the SJVAPCD in reducing emissions of criteria pollutants associated with vehicle miles traveled, reducing building energy usage, and would increase opportunities for transit ridership in Lathrop and the surrounding areas. The list provided on DEIR pages 3.3-27 through 3.3-36 identifies those General Plan policies and actions that would work to further criteria pollutant emissions reductions, including reviewing projects for conformance with applicable air quality plans and regulations, reducing energy demands, and implementing methods to reduce vehicle miles traveled, including providing adequate pedestrian, bicycle, and transit facilities and opportunities, promoting non-vehicle travel modes, requiring employers with 100 or more employees to implement TDM programs, and ensuring regional coordination on trip and VMT reduction efforts..

In addition to the policies and actions described above, and on pages 3.3-27 through 3.3-36 of the DEIR, the following are of particular note:

Action LU-5c When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions are proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors, the City shall require the preparation of a Health Risk Assessment (HRA) that meets the standards established by the Office of Environmental Health Hazard Assessment (OEHHA), and the San Joaquin Valley Air Pollution Control District (SJVAPCD). Projects shall not be approved until it can be demonstrated that the project would not result in an exceedance of the established thresholds of significance for public health risks at nearby sensitive receptors.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-34 Final Environmental Impact Report – Lathrop General Plan Update and thresholds established by the Office of Environmental Health Hazard Assessment (OEHHA), and the San Joaquin Valley Air Pollution Control District (SJVAPCD). Projects that would exceed an established threshold cannot be approved until such time that it can be demonstrated that design modifications or other mitigation measures imposed upon the project would reduce health risks below the established thresholds of significance. This is a specific, enforceable, performance-based measure that would ensure that sensitive receptors are not exposed to excessive levels of pollutant concentrations or toxic air contaminants from future development projects.

Another notable action related to this topic includes:

LU-5d When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions are proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors, the City shall require the implementation of best management practices (BMPs) to reduce pollution exposure to sensitive receptors, particularly diesel particulate matter (DPM). The appropriate BMPs shall be established on a case-by-case basis, and should consider the following tools, methods, and approaches:
• Creating physical, structural, and/or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks. • Providing adequate areas for on-site parking, on-site queuing, and truck checkin that prevent trucks and other vehicles from parking or idling on public streets.
• Placing facility entry and exit points from the public street away from sensitive receptors, e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. Exceptions can be made for emergency vehicle access (EVA) points.
• Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors.
• Screening dock doors and onsite areas with significant truck traffic and noise with physical, structural, and/or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors.
• Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-35 This action requires all future industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions, proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors to implement a range of best practices to reduce pollution exposure to sensitive receptors, particularly diesel particulate matter (DPM), regardless of whether or not the project would exceed an established threshold of significance for air quality or toxic air contaminant emissions. This action was developed to implement the best practices identified in the Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, published by the Attorney General’s Office in 2021 (which the commenter has attached to their comment letter as Appendix A). The commenter is referred to Section IV. Warehouse Siting and Design Considerations, located on pages 4-5 of the above referenced document. Lathrop General Plan Action LU-5d implements these best practices requirements from the California Attorney General’s Office publication nearly verbatim. The Attorney General guidance document noted above also references four “good neighbor” policies in California. The City reviewed these referenced policies, and has included Action LU-5e, which requires the City to update its Municipal Code to establish Good Neighbor Guidelines for Warehouse Distribution Facilities, consistent with the examples and guidance provided by the Attorney General’s Office.

The City recognizes that truck trips and truck traffic associated with future warehouse, logistics, and distribution projects that may be proposed within the area in question have the potential to result in adverse environmental impacts, including pollutant exposure and noise exposure to sensitive receptors located south of Dos Reis Road. In order to address this concern, the proposed General Plan includes Action LU-5f, which requires the City to update the Central Lathrop Specific Plan. One of the requirements of this Specific Plan update is to “Establish a circulation network that keeps future truck trips as far from existing and planned sensitive receptors as feasible.” Upon further review of this General Plan Action, the City proposes to make the following changes to this action (shown in strikethrough and underline format), and to include a new action (Action LU-5g), in order to provide more specificity and enforceability to the City’s plans to direct all future truck traffic within the Central Lathrop Specific Plan Area away from existing and planned sensitive receptors.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-36 Final Environmental Impact Report – Lathrop General Plan Update ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA). iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.
c. Establish site design standards for new industrial projects; d. Identify financing and cost-recovery methods to fund roadway and infrastructure improvements.
e. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I-5.
f. Infrastructure improvements to improve roadway operations g. Opportunities to provide employee-serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals.

LU-5g: During the interim period following adoption of this General Plan, and the adoption of the updates to the Central Lathrop Specific Plan, identified in Action LU-5f, the City shall enforce the following requirements for all Limited Industrial development projects, including warehouse, distribution, and logistics projects, within the Central Lathrop Specific Plan Area:
a. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway. b. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
c. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

Implementation of the two actions listed above, as revised and updated, would help ensure that future sensitive receptors south of Dos Reis Road, which includes existing and planned residential uses, as well as Lathrop High School, would be exposed to reduced levels of air quality emissions and toxic air contaminants associated with future truck trips to the greatest extent feasible. These actions would ensure that truck trips associated with future development within the Limited Industrial areas of the Central Lathrop Specific Plan would not pass through residential neighborhoods, or travel on roadways adjacent to Lathrop High School.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-37 It is also important to note that the proposed Land Use designation of Limited Industrial allows for a wide range of uses and development typology, not all of which is typically considered to be “industrial” development. As noted under Policy LU-1.2 of the Proposed General Plan: The Limited Industrial designation accommodates a wide range of jobs-generating uses, including business parks; clean light industrial; research and development (R&D); science, technology, engineering, and math (STEM); tech/biotech manufacturing; high-tech services that incorporate some combination of assembly, warehousing, and/or sales, hospitals and other health care-related uses, warehouses and distribution centers.

In addition to General Plan Actions LU-5c and LU-5d, listed above, which require the preparation of health risk assessments and the implementation of best practices for projects located within 1,000 feet of sensitive receptors, the Draft General Plan also includes the following two actions, which would further ensure that incompatible uses are not placed in close proximity to sensitive receptors.

LU-5.a: Through the development review process, screen development proposals for land use and transportation network compatibility with existing surrounding or abutting development or neighborhoods.

LU-5b: Through the development review process, analyze land use compatibility and require adequate buffers and/or architectural enhancements to protect sensitive receptors from intrusion of development activities that may cause unwanted nuisances and health risks.

As individual development applications are received, the City will screen these projects for compatibility, potential for adverse health risks, and other nuisance factors, such as noise, prior to any project approval or entitlement that may adversely impact a sensitive receptor. It is important to note that adoption of the General Plan does not directly approve or entitle any development projects. The City has included broad and extensive policies and actions in the General Plan to ensure that sensitive receptors are protected to the greatest extent feasible.

Response B-4: The commenter states that the proposed project would transform a residential community into an industrial corridor, and that trucks would travel throughout established residential areas and adjacent to schools. The commenter is referred to Response B-3 above. As noted above, the City has included specific policies and actions that prohibit new truck trips generated within the Central Lathrop Specific Plan area from travelling through residential neighborhoods, or adjacent to Lathrop High School, via prohibitions on truck traffic and driveway access points on Dos Reis Road, west of Golden Valley Parkway. The commenters concerns are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required.

Response B-5: The commenter states that trucks would pose a threat to public safety as they interact with vehicles, pedestrians and bicyclists. The commenter is referred to Impact 3.14-3 on pages 3.14-42 through 3.14-46 of the Draft EIR. This impact discussion analyzes the potential for the proposed General Plan to result in roadway safety hazards related to incompatible uses, and specifically analyzes potential

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-38 Final Environmental Impact Report – Lathrop General Plan Update safety impacts related to increases in truck traffic on area roadways. The commenters concerns are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required.

Response B-6: The commenter states that the proposed General Plan would create long-term environmental damage, and states that a revised Draft EIR must implement the guidance provided in the Attorney General’s Warehouse Best Practices document (which is referenced above under Response B3). This comment is noted. The commenter does not identify any alleged deficiencies in the Draft EIR analysis, but rather, states opposition to the proposed project. This comment will be forwarded to the City Council for review and consideration. The commenter is also referred to Response B-3, which describes how the City of Lathrop has already incorporated many of the Attorney General’s warehouse best practices recommendations into the proposed General Plan (such as Actions LU-5.d and LU-5.e).

The commenter further states that the City should consider an alternative to the proposed Land Use Map that creates a buffer zone between the Central Lathrop area and the community. This comment is noted.

Response B-7: The commenter states that the Draft EIR analysis is deficient, and that a program EIR must include a detailed analysis, rather than relying on analyses of subsequent projects. The commenter does not identify specific impact analyses that are alleged to be deficient in the Draft EIR, as such, a detailed response is not possible. However, it is noted that the Draft EIR for the proposed General Plan includes an extremely detailed and quantified analysis of impacts associated with full buildout of the General Plan.

As the commenter is certainly aware, adoption of the General Plan Update and certification of the Final EIR would not approve or otherwise entitle any development projects within Lathrop. The Draft EIR includes projections for full buildout of the Land Use Map, including future population levels, housing units, jobs, square footage of non-residential development, etc. See Tables 2.0-2 and 2.0-3 in Chapter

2.0 of the Draft EIR. These buildout projections are the basis of the Draft EIR impact analysis, and have been analyzed in detail throughout the Draft EIR. For example, impacts related to circulation and VMT, noise, water supply, air quality, etc., are addressed in detail in the Draft EIR, and are based on a “worstcase” scenario analysis of full buildout of the proposed Land Use Map. In instances where the Draft EIR references General Plan policies or actions that require project-level review of future development applications, the policies and actions identify the performance-based standards that must be used when analyzing future projects. This is not deferred mitigation. Rather, it is a cohesive approach to ensuring that future development projects’ impacts are reduced to the greatest extent feasible through the implementation of performance-based measures at the time an application for entitlement is submitted.

One such example is Action LU-5c, which states that: When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions are proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors, the City shall require the preparation of a Health Risk Assessment (HRA) that meets the standards established by the Office of Environmental Health Hazard Assessment (OEHHA), and the San Joaquin Valley Air Pollution Control District (SJVAPCD). Projects shall not be approved until it can be demonstrated that the project would not result in an exceedance of the established thresholds of significance for public health risks at nearby sensitive receptors.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-39 In the example of Action LU-5c provided above, the City has identified when a subsequent analysis would be triggered (industrial projects within 1,000 feet of a sensitive receptor); what standard of review is required (a health risk assessment that meets the requirements of OEHHA and the SJVAPCD), and that projects cannot be approved until it is demonstrated that it would not exceed the applicable adopted threshold. As noted previously in this response, this is not deferred mitigation. This is a requirement for future specific and performance-based analysis and mitigation for future projects, the details of which cannot be known or speculated about at this time.

Given the lack of detail and specificity in this comment, no further response is warranted.

Response B-8: The commenter states the importance of the DEIR in analyzing impacts of future land use development decisions, rather than deferring analysis to a later point. The commenter specifically cites Action LU-5.f, which references future updates to the Central Lathrop Specific Plan. The commenter is referred to Response B-7, above. As noted in Response B-7, the General Plan includes numerous performance-based standards under which future development applications will be reviewed. The City has done a detailed analysis of impacts associated with full buildout of the General Plan, and no changes to the Draft EIR are warranted. It is further noted that Action LU-5.f has been modified to provide greater specificity regarding future truck routes within the Central Lathrop Specific Plan area, as described in greater detail under Response B-3.

Response B-9: The commenter states that the DEIR’s air quality analysis is deficient because the environmental setting did not include information from CalEnviroScreen related to existing pollution burden.

The Air Quality chapter of the Draft EIR includes extensive information about existing air quality conditions throughout the San Joaquin Valley Air Basin, and the City of Lathrop. For example, DEIR pages

3.3-1 through 3.3-3 describe the San Joaquin Valley Air Basin in detail, including climate, wind patterns, temperatures, precipitation, fog, and inversions. Pages 3.3-3 through 3.3-8 describe criteria pollutants that are regulated by the SJVAPCD, and identifies the potential health risks associated with exposure to these criteria pollutants. Table 3.3-2 identifies San Joaquin County’s attainment status for each regulated criteria pollutant. Chapter 3.3 of the DEIR also includes a detailed summary of applicable air quality regulations at the local, state, and federal level, and describes ongoing efforts to address air pollution throughout the San Joaquin Valley. The commenter is correct that specific information from the CalEnviroScreen source was not included in the Draft EIR, however, the commenter’s statement that “the Central Lathrop area is identified in the CalEnviroscreen data as having 98% pollution burden, yet the DEIR fails to disclose this information” is misleading.

According to CalEnviroScreen 4.0, the Central Lathrop Specific Plan Area, which the commenter references, is located in Census Tract #6077005119, and has a CalEnviroScreen 4.0 percentile of 86; a Pollution Burden percentile of 98, and a Population Characteristics percentile of 58. The composite CalEnviroScreen scores noted above are aggregated from the scores of 21 individual indicators. Scores between 0 to 100 are assigned to each indicator representing the degree of pollution exposure and

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-40 Final Environmental Impact Report – Lathrop General Plan Update vulnerability, or “burdens,” facing each census tract. Scores between 75 to 100 are considered a high burden, scores between 25 to 74 are a medium burden, and scores between 0 to 24 are a low burden.

In terms of how this information may relate to the environmental setting in the Draft EIR, there are 21 individual indicators that have separate scores for each indicator. Of these 21 indicators, four are specifically related to air quality. These include Ozone, PM 2.5, DPM, and Asthma. According to the CalEviroScreen 4.0 data, Census Tract #6077005119 has the following scores for these four categories:

Ozone=57, PM2.5=53, DPM=54, and Asthma=69. As noted above, scores between 25 to 74 are a medium burden, which is the case for all of the air quality indicators in the CalEnviroScreen 4.0 data in the area of Lathrop noted by the commenter.

The fact that the specific datasets referenced by the commenter were not included in the Draft EIR environmental setting discussion does not alter or otherwise change the conclusions contained in the Draft EIR related to air quality impacts, nor does it preclude the City of Lathrop from understanding the potential for the proposed General Plan to result in significant and unavoidable impacts related to air quality. No further response is required.

Response B-10: The commenter states that the DEIR fails to propose adequate mitigation for significant air quality impacts and fails to evaluate an alternative that locates industrial land uses away from sensitive receptors.

The potential for the proposed project to result in air quality impacts or to expose sensitive receptors to significant pollutant concentrations are addressed in extensive detail under Impacts 3.3-1 and 3.3-2. The Draft EIR identifies dozens of proposed General Plan policies and actions, that when implemented, would reduce these impacts to the greatest extent feasible. The City has determined that there is no additional feasible mitigation available that would reduce these impacts to a less than significant level, and still achieve the project objectives. As such, the City has correctly concluded and disclosed that these impacts would be significant and unavoidable.

In terms of project alternatives, the commenter is referred to Chapter 5.0 of the Draft EIR. Specifically, the commenter is referred to Alternative 1, No Project Alternative, wherein the City would not adopt the General Plan Update, and the Land Use Map would remain unchanged. Additionally, the commenter is referred to Alternative 2, Modified Project Alternative, wherein the City would adopt the updated General Plan policy document, but would not alter or otherwise change the existing Land Use Map.

Under both of these alternatives, the portion of the Central Lathrop Specific Plan north of Dos Reis Road would remain primarily Variable Density Residential on the Land Use Map, and the 670+/- acres in question would not be designated for Limited Industrial land uses. The commenter’s assertion that the Draft EIR does not include an analysis of alternatives that would place industrial land uses further from sensitive receptors is false. No changes to the Draft EIR are warranted.

Response B-11: The commenter states that the DEIR fails to analyze the impacts of toxic air contaminants (TACs) on sensitive receptors, including Lathrop High School, the existing community, and future planned COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-41 residences. The commenter is referred to Impact 3.3-2, which includes a detailed and quantified analysis of the proposed project’s potential to expose sensitive receptors to TACs.

As noted in previous responses, approval of the proposed General Plan update would not approve or otherwise entitle any development projects, including projects that could generate TACs. TAC exposure and the associated health risks are analyzed at the project level, via the preparation of a Health Risk Assessment (HRA). As described under Response B-3, General Plan Action LU-5c requires any industrial project proposed within 1,000 feet of an existing or planned sensitive to prepare an HRA, and demonstrate that TAC exposure levels would not exceed the thresholds of significance adopted by the Office of Environmental Health Hazard Assessment (OEHHA), and the San Joaquin Valley Air Pollution Control District (SJVAPCD). Projects that exceed the applicable thresholds cannot be approved.

The commenter states that the HRA in the Draft EIR should have analyzed TACs from both stationary and mobile sources. Given that there are no specific projects proposed at this time, there is no way that the City could prepare a project-specific HRA that looks at stationary sources, due to the fact that an analysis of stationary sources requires detailed information about the site and operational characteristics of a specific project. Information such as refrigeration units, site layout, orientation of loading docks, operational components, etc., are all project-specific inputs that are analyzed in a project-level HRA. In this instance, the project is a General Plan, and there is no project-level emissions data available to analyze in an HRA.

The commenter further states that the Draft EIR omits TACs from mobile sources in the analysis. The commenter is incorrect. The HRA in the Draft EIR focuses primarily on mobile source TACs, given that the City has projected heavy truck traffic volumes associated with General Plan buildout. The City recognizes, and the Draft EIR explicitly discloses, that proposed changes to the Land Use Map would result in new future limited industrial development within the Central Lathrop Specific Plan area, north of Dos Reis Road. In order to provide as much information as possible, the Draft EIR utilized the AERMOD 2021 and HARP-2 Air Dispersion and Risk Tool to prepare a modified HRA that analyzed TAC risk exposure from DPM, based on projected increases in truck trips associated with full buildout of the General Plan.

As part of this TAC exposure analysis, the road segment with the highest net increase in daily heavy-duty truck trips at full General Plan buildout was identified, along with its adjacent and nearby roadways, as having the most potential for impacting sensitive receptors. Specifically, the road segment with the highest potential net increase in daily heavy-duty truck trips at full General Plan buildout was identified at Spartan Way between I-5 and Golden Valley Parkway1(Fehr & Peers, 2022). According to Fehr & Peers, 1 Note this analysis was included as a case study of potential Health Impacts related to heavy duty truck trips, and assumed a worse-case-scenario if all routes were unrestricted for heavy trucks. It should be noted that trucks within Lathrop are restricted in some areas of the city, and new future truck routes and circulation improvements that would reduce air toxics at sensitive receptors have been addressed via new policies and actions in the Updated General Plan. However, out of an abundance of caution, these new truck routes and restrictions were not included as part of this worst-case-scenario HRA analysis.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-42 Final Environmental Impact Report – Lathrop General Plan Update Spartan Way between I-5 and Golden Valley Parkway road segment could generate approximately 7,742 net new heavy-duty truck trips upon full General Plan buildout. Therefore, new heavy-duty truck traffic along this road segment, combined with the heavy-duty truck traffic anticipated along adjacent and other nearby roadway segments associated with the new areas for light industrial development north of Dos Reis Road, west of I-5 (i.e. I-5, Golden Valley Parkway, Manthey Road, Dos Reis Road, De Lima Road, etc.), were analyzed for their total potential localized TAC impacts at full buildout. The SJVAPCD thresholds of significance for public health risks are shown in Table 3.3-9 of the Draft EIR.

Table 3.3-10 in the Draft EIR displays the residential cancer risk and acute and chronic incidence rate results at the receptors that were shown to bear the highest TAC risks (including the cumulative impacts associated with the combined impact of proposed segments and interacting segments together). The results of the risk analysis indicate that cancer and non-cancer risks vary depending on the exposure scenario and location. As would be expected, sensitive receptors nearest the roadway segments where truck traffic would be greatest have the greatest exposure, and the associated risks are considerably lower as the distance from the high truck traffic roadway segments increases. The northeastern corner of the proposed Residential Mixed Use land use area located at the southwest corner of Dos Reis Road and Golden Valley Parkway was identified as having the highest TAC risk (i.e. 36.96 per million persons residential cancer risk over a 70-year exposure). Other areas where residential cancer risk exceeded the residential cancer risk threshold of 20 per million persons over a 70-year exposure include:
• The far northeastern corner of the residential community located at the southwestern corner of Spartan Way and Golden Valley Parkway;
• Residences located at the intersection of Manthey Road and De Lima Road; • Residences located along the far side of I-5 (along South Harlan Road), north of Shilling Avenue and south of Stonebridge lane.

Table 3.3-10 provided the maximum health risks associated with the road segments at full buildout of the General Plan. As shown, the highest residential cancer risk would exceed the applicable significance threshold (at some locations).

As noted in footnote #1, and under Response B-3, the General Plan includes multiple policies and actions specifically aimed at reducing TAC exposure to residents and other sensitive receptors located south of Dos Reis Road. Specifically, Actions LU-5.f and LU-5.g require the following truck route and site plan restrictions:
i. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway. ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-43 Implementation of these truck route restrictions would significantly decrease the volume of trucks, and thus the level of TAC emissions, near sensitive receptors in Lathrop. This represents the most effective mitigation available to the City. However, out of an abundance of caution, the Draft EIR concludes that this impact would remain significant and unavoidable.

In terms of the project’s potential to expose students at Lathrop High School to substantial TAC concentrations, the Draft EIR analyzed the potential for acute (short-term) or chronic non-cancer health risks. As described on Draft EIR page 3.3-40, the health risks that are evaluated in this study include:
• Residential Cancer Risk (70-year exposure; start at third trimester); and • Acute and Chronic Hazard Indices.

The 70-year risk applies to residential areas where exposure may potentially occur 24 hours/day, 365 days/year. Non-cancer risks can be described as acute (short-term, exposure) or chronic health impacts.

Given that students at Lathrop High School are typically present on campus for four years, the 70-year exposure threshold does not apply. Rather, the Chronic and Acute non-cancer hazard Indices were utilized as the risk metric, and the Non-cancer health hazard exposure index of 1.0 was used as the significance threshold, per SJVAPCD guidance. The TAC risk analysis in the Draft EIR focused on the segment of Spartan Way between I-5 and Golden Valley Parkway, which is approximately 570 yards from the eastern edge of the Lathrop High School campus. Due to the fact that new heavy truck traffic in Lathrop was projected to be highest at this location, this location represents the spot in the City with the greatest potential for acute and chronic health risks, and would have a greater potential for impacts than those that may occur at Lathrop High School.

As noted in Draft EIR Table 3.3-10, the maximum risk (per million persons) was calculated to be <0.01, which is significantly below the SJVAPCD’s significance threshold of >1. As such, the City can conclude that students at Lathrop High School would not be exposed to non-cancer health hazards in excess of the SJVAPCD’s adopted standards.

The commenter’s assertion that the Draft EIR HRA omits an on-site analysis for the sensitive receptors south of Dos Reis Road is incorrect. As noted above, the HRA focused on sensitive receptors located at multiple locations south of Dos Reis Road, and focused on the areas with the highest potential for impacts. This topic has been thoroughly addressed in the Draft EIR, and no changes are warranted.

Response B-12: The commenter states that the Draft EIR fails to analyze particulate emissions from increased truck trips. The commenter is referred to the emissions calculations contained in Appendix F to the Draft EIR. Particulate emissions data is included in this appendix, and was an input factor for the analysis under Impact 3.3-2.

The commenter further states that the Draft EIR should have analyzed emissions increases on local streets and Interstate 5. The commenter is referred to Draft EIR page 3.3-23. As noted on this page, the San Joaquin Valley is in State-level non-attainment for ozone, PM10, and PM2.5. The SJVAPCD does not provide criteria pollutant thresholds for General Plans (such as the proposed Project). Thresholds of significance for criteria pollutants are established at the project-level by the SJVAPCD. As such, there is

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-44 Final Environmental Impact Report – Lathrop General Plan Update no programmatic threshold of significance established for criteria pollutants for which to compare the proposed General Plan.

This EIR explicitly acknowledges that the proposed General Plan will allow notable amounts of new residential and non-residential growth in Lathrop, as described in detail in Chapter 2.0 (Project Description). This new growth will undoubtedly result in increases in the emissions of criteria pollutants, most notably from mobile-source and area-source emissions increases associated with increased growth and development in Lathrop. However, with no threshold against which to measure an increase in criteria pollutant emissions associated with General Plan implementation, the Draft EIR has correctly followed the guidance provided by the SJVAPCD. No changes to the Draft EIR are warranted.

Response B-13: The commenter notes that the Draft EIR concludes that there would be significant and unavoidable impacts related to roadway noise, and provides incorrect summaries of noise data and results related to future traffic noise levels at Lathrop High School.

The commenter asserts that baseline noise conditions for sensitive receptors in Central Lathrop and Lathrop High School are 60.7 dB, and that the project would increase noise levels by 13.6 dB. The commenter cites Draft EIR page 3.12-19. The numbers that the commenter has cited apply to a specific roadway segment, which is Spartan Way between Golden Valley Parkway and Interstate 5. This roadway segment is approximately 1,700-3,000 feet east of Lathrop High School.

Table 3.12-11 in the Draft EIR provides baseline (2020) and future (buildout) roadway noise level calculations for the segment of Spartan Way between Golden Valley Parkway and Lathrop High School.

As shown in the table, the baseline traffic noise level is 56.6 dB, and the future traffic noise level is 60.7 dB. This 4.1 dB increase is less than significant for this particular roadway segment immediately in front of and adjacent to Lathrop High School. The commenter appears to have mis-read the table, and no further response to this comment is warranted.

The commenter also states that the General Plan policies and actions that minimize roadway noise impacts are insufficient. For example, the commenter states that the Draft EIR fails to evaluate the efficacy of a policy that calls for locating automobile and truck access to industrial and commercial properties at the maximum practical distance from residential zones. This policy language would apply during the City’s review of future development applications. It would require an analysis of a specific site, surrounding uses, a specific driveway access proposal, and a specific internal circulation network.

These future project-specific details are not, and cannot, be known at this time. This policy represents one of many best practices the City will implement when reviewing and considering future development applications.

The Draft EIR correctly takes a quantified and program-level approach to analyzing future traffic noise levels associated with General Plan buildout. Forty-one roadway segments, distributed throughout the City, were selected and quantitatively analyzed for future (buildout) traffic noise impacts.

The Draft EIR also identifies numerous specific policies and actions included in the Draft General Plan that would reduce roadway noise impacts to the greatest extent feasible. For example, the proposed General COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-45 Plan includes Policy N-1.4, which requires the preparation of acoustical studies for new discretionary developments and transportation improvements that have the potential to affect existing noise-sensitive uses such as schools, hospitals, libraries, care facilities, and residential areas; and for projects that would introduce new noise-sensitive uses into an area where existing noise levels may exceed the thresholds identified in the Noise Element. This policy continues, and provides specific quantified thresholds of significance for transportation noise sources, which include:

1. Where existing traffic noise levels are less than 60 dB Ldn at the outdoor activity areas of noise-sensitive uses, a +5 dB Ldn increase in roadway noise levels will be considered significant;

2. Where existing traffic noise levels range between 60 and 65 dB Ldn at the outdoor activity areas of noise-sensitive uses, a +3 dB Ldn increase in roadway noise levels will be considered significant; and

3. Where existing traffic noise levels are greater than 65 dB Ldn at the outdoor activity areas of noise-sensitive uses, a + 1.5 dB Ldn increase in roadway noise levels will be considered significant.

Policy N-1.5 provides specific guidelines and criteria for the preparation of acoustical studies, and includes a requirement that mitigation measures be identified to achieve compliance with the adopted noise standards in the Noise Element. This policy also calls for post-project assessment programs, if necessary, to monitor the effectiveness of the proposed mitigation measures.

The Draft EIR explicitly acknowledges that upon full buildout of the proposed General Plan, traffic noise levels on several roadway segments in Lathrop are projected to increase to significant levels that exceed the City’s adopted standards and thresholds. As described in Chapter 3.12 of the Draft EIR, the City has included numerous policies and actions in the General Plan that, when implemented, would reduce roadway noise levels to the greatest extent feasible, but not to a less than significant level. Policies N1.4 and N-1.5, described above, include specific performance-based measures that must be analyzed as thresholds of significance when future development applications and roadway improvement projects are proposed, and requires projects to identify and incorporate mitigation measures to reduce roadway noise level exposure in order to meet the standards and thresholds identified in the Noise Element. This is not deferred mitigation. This issue has been adequately addressed in the Draft EIR and no changes are warranted.

Response B-14: The commenter states that noise from warehouse uses can cause intrusive impacts to nearby sensitive receptors. The commenter states that the Draft EIR should include more robust mitigation and/or analysis of alternative land use designations in the Central Lathrop area. This comment is noted. In terms of project alternatives, the commenter is referred to Chapter 5.0 of the Draft EIR.

Specifically, the commenter is referred to Alternative 1, No Project Alternative, wherein the City would not adopt the General Plan Update, and the Land Use Map would remain unchanged. Additionally, the commenter is referred to Alternative 2, Modified Project Alternative, wherein the City would adopt the updated General Plan policy document, but would not alter or otherwise change the existing Land Use Map. Under both of these alternatives, the portion of the Central Lathrop Specific Plan north of Dos Reis Road would remain primarily Variable Density Residential on the Land Use Map, and the 670+/- acres in

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-46 Final Environmental Impact Report – Lathrop General Plan Update question would not be designated for Limited Industrial land uses. The commenter’s request that the Draft EIR analyze alternative land use maps has already been addressed.

The commenter does not provide any specific recommendations for “more robust mitigation.” As noted above under Response B-13, the General Plan includes very specific policies that establish quantified thresholds of significance for noise exposure and requirements for analysis and mitigation at the projectlevel, when specific projects are proposed. The commenter is also referred to General Plan Actions LU5.d and LU-5.e, which are described in greater detail under Response B-3. While these actions would assist in reducing health risks associated toxic air contaminants, they would also assist in notably reducing noise levels from proposed projects. For example, Action LU-5.d identifies the following best practices that should be considered and implemented at the project level:
• Creating physical, structural, and/or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks. • Providing adequate areas for on-site parking, on-site queuing, and truck checkin that prevent trucks and other vehicles from parking or idling on public streets.
• Placing facility entry and exit points from the public street away from sensitive receptors, e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. Exceptions can be made for emergency vehicle access (EVA) points.
• Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors.
• Screening dock doors and onsite areas with significant truck traffic and noise with physical, structural, and/or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors.
• Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

The Draft EIR has fully and correctly analyzed traffic related noise impacts associated with buildout of the proposed General Plan. The General Plan includes numerous policies and actions that would reduce future noise levels and exposure of sensitive receptors to significant noise levels to the greatest extent feasible. As described in Chapter 3.12 of the Draft EIR, there is no additional feasible mitigation available.

No changes to the Draft EIR are warranted.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-47 Response B-15: The commenter states that an increase in truck trips would result in safety impacts.

However, the commenter provides no supporting information or substantial evidence, other than to cite a 2017 newspaper article about two trucks hitting backyard sound walls. The commenter is referred to Draft EIR Impact 3.14-3, which includes a detailed and quantified analysis of potential hazards associated with truck trip accidents and injuries/deaths. As noted under Impact 3.14-3, there is no feasible mitigation available that would fully ensure that future truck traffic would not result in accidents on local roadways.

Response B-16: The commenter cites the text of a goal from the City of Lathrop’s Bicycle Transportation Plan, which is referenced in the regulatory setting section of Chapter 3.14 of the Draft EIR (page 3.14-25) and states that this goal, which is not a General Plan goal, is not adequate mitigation. The text referenced by the commenter is not alleged to be mitigation in the Draft EIR. It is provided for context and background in the regulatory setting of the Circulation chapter of the Draft EIR.

The commenter states that proposed General Plan Action CIR-1j should be a requirement with specific performance standards identified prior to certification of the EIR. This action is not specifically identified as a mitigation measure in the Draft EIR. It is one of dozens of General Plan policies/actions that have been noted to potentially minimize potential impacts related to hazards due to a design feature, incompatible uses, and inadequate emergency access.

Action CIR-1j states:

Create a Local Roadway Safety Plan with the goal of reducing traffic fatalities and serious injuries on public roads and to support funding safety improvements. The plan may consider collision history; vehicle, bicycle, and pedestrian volumes; vehicle speeds; and other improvements.

Complete this plan within four years of adoption of this General Plan.

This action is an appropriate and useful inclusion in the proposed Lathrop General Plan, and calls on the City to create a local roadway safety plan. The Draft EIR has not relied on this action as a specific mitigation measure. No changes are warranted.

Response B-17: The commenter notes that the Draft EIR concludes that impacts related to policies and programs for safe transit, bicycle and pedestrian mobility would be significant and unavoidable, and states that the Draft EIR doesn’t include any additional policies, plans and mitigations to avoid or minimize these impacts. This comment is noted. The commenter is referred to the analysis under Impact

3.14-2. As noted on Draft EIR page 3.14-41, the General Plan includes numerous policies and actions that help make the circulation system, including transit, bicycle, and pedestrian facilities, consistent with applicable programs, plans, policies, and ordinances and address the needs of growth accommodated by the proposed General Plan. Although the General Plan Update policies and actions help make the circulation system, including transit, bicycle, and pedestrian facilities, consistent with applicable programs, plans, policies, and ordinances and address the needs of growth accommodated by the proposed General Plan, increasing vehicle traffic may increase the number of collisions on Lathrop roadways, including collisions involving transit users, bicyclists, and pedestrians. The City cannot

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-48 Final Environmental Impact Report – Lathrop General Plan Update demonstrate definitively at this time that implementation of these policies would maintain the number of collisions for vehicles, pedestrians, and bicyclists at current or lower levels.

Proposed General Plan Action CIR-2a requires the City to create an active transportation plan supporting the development of bicycle and pedestrian networks across the City and funding applications for bicycle and pedestrian improvements. Proposed General Plan Action CIR-2g requires the City to ensure that development and infrastructure projects are designed to provide pedestrian and bicycle access and leave no gaps in the bicycle and pedestrian networks.

The commenter requests additional detailed information be included in the Draft EIR, such as detailed maps of existing sidewalk gaps, grade separated bicycle paths, etc. This level of detail exceeds the scope of the analysis for the proposed General Plan Update. The City has demonstrated a commitment to improving transit, bicycle, and pedestrian connectivity and safety throughout Lathrop via the numerous policies and actions included in the General Plan, which are listed and analyzed under Impacts 3.14-2 and

3.14-3 of the Draft EIR. As described in greater detail under Response B-3, the City has taken a comprehensive approach to planning for future limited industrial development in appropriate locations in the City, and has established numerous requirements related to the existing and future circulation network in order to reduce truck trips near sensitive receptors.

These environmental issues have been thoroughly addressed in the Draft EIR, and the General Plan includes all feasible policies and actions to reduce potential impacts to the greatest extent feasible. There is no additional feasible mitigation that would reduce potential impacts to a less than significant level.

Response B-18: The commenter states that potential safety impacts associated with new limited industrial development must be adequately addressed in the Draft EIR. The commenter is referred to Response B-17 above, and Impacts 3.14-2 and 3.14-3 in the Draft EIR. These topics have been thoroughly addressed in the Draft EIR.

The commenter suggests several alternatives and mitigation measures. Responses to these are provided below.

The commenter suggests a mitigation measure requiring a cap on the number of acres of light industrial uses in the Central Lathrop area, especially warehouses and distribution centers. As noted in the responses provided above, the City has proposed a comprehensive approach to roadway safety and truck travel that would reduce potential safety impacts to the greatest extent feasible. Additionally, the Draft EIR includes two alternatives that would remove future limited industrial uses from the Central Lathrop area. The City has incorporated best practices for warehouse siting, as recommended by the Attorney General’s office, into the General Plan. The commenter has provided no supporting evidence that an arbitrary reduction in acreage of limited industrial uses would reduce any significant impacts to a less than significant level.

The commenter suggests an alternative that prohibits industrial land uses near established residential neighborhoods and schools. The commenter is referred to Response B-10. Two such alternatives are included in the Draft EIR.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-49 The commenter suggests a mitigation measure that prohibits heavy-duty truck routes within residential areas and schools. The commenter is referred to Response B-3. As required by Actions LU-5.f and LU5.g, trucks shall be prohibited from travelling on Dos Reis Road, and shall be directed north towards De Lima Road and Manthey Road, away from existing sensitive receptors in the Central Lathrop area. This City has already incorporated this recommendation into the General Plan and Draft EIR.

The commenter suggests a mitigation measure that requires implementation of sidewalks, streetlights, crosswalks, transit stops….and other pedestrian infrastructure on heavily travelled routes prior to development near schools and residential areas. These suggestions have already been incorporated into the Draft General Plan and Draft EIR. For example, prior to any limited industrial development within the Central Lathrop area, the City shall prepare a comprehensive update to the Central Lathrop Specific Plan, as required by Action LU-5.f. This action requires the City to update the Specific Plan to:
a. Bring the Specific Plan’s land use map into consistency with the General Plan Land Use Map (Figure LU-1)
b. Establish a circulation network that keeps future truck trips as far from existing and planned sensitive receptors as feasible; this includes, but is not limited to, the following requirements, which shall be incorporated into the Specific Plan:
iv. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway. v. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
vi. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5. c. Establish site design standards for new industrial projects; d. Identify financing and cost-recovery methods to fund roadway and infrastructure improvements.
e. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I-5.
f. Infrastructure improvements to improve roadway operations g. Opportunities to provide employee-serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals.

The City has also committed to the implementation of several roadway safety plans and improvements, including but not limited to the adoption of an Active Transportation Plan (Action CIR-2a); adding planned bicycle and pedestrian facilities in conjunction with road rehabilitation, reconstruction, or re-striping

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-50 Final Environmental Impact Report – Lathrop General Plan Update projects (Action CIR-2b); enhancing sidewalks to create a high-quality pedestrian environment, including wider sidewalks and improved pedestrian crossings, landscaping, buffers between sidewalks and vehicle travel lanes, enhanced pedestrian lighting, wayfinding signage, shade trees, and canopies, increased availability of benches, and other features (Action CIR-2c); improving bicycle facilities to include attractive and secure bicycle parking, bicycle lanes, bike paths, and wayfinding signage along appropriate roadways (Action CIR-2d); and ensuring that development and infrastructure projects are designed to provide pedestrian and bicycle access and leave no gaps in the bicycle and pedestrian networks (Action CIR-2g).

These actions are just some of the many policies and actions that comprise the City’s comprehensive approach to bicycle and pedestrian safety. The commenter is referred to the policies and actions listed under Impact 3.14-1 in the Draft EIR for a full list of the relevant General Plan policies and actions that address this topic.

The commenter suggests a mitigation measure requiring the preparation of an engineering strategic plan to eliminate all traffic fatalities and severe injuries within the City. As noted in the response above, the City has committed to numerous tangible steps to improve roadway safety within Lathrop. There is no additional feasible mitigation available to fully ensure that future traffic injuries and fatalities do not occur in Lathrop.

The commenter states that the DEIR’s conclusion of significance does not relieve the City from avoiding and minimizing impacts to the bicycle and pedestrian network. The commenter is referred to the responses above. The City has proposed a comprehensive approach to bicycle and pedestrian safety, and there is no additional feasible mitigation available.

Response B-19: The commenter asserts that the Draft EIR is deficient and must be revised and recirculated. This comment is noted. As demonstrated throughout the responses provided above, the Draft EIR correctly and fully analyzes the full range of environmental impacts associated with adoption and implementation of the proposed General Plan. The City of Lathrop has incorporated extensive policies and actions into the General Plan in order to reduce all potential impacts to the greatest extent feasible. As demonstrated throughout the Draft EIR, and as described in the responses above, there is no additional feasible mitigation that would reduce the identified significant impacts to a less than significant level. The Draft EIR fully meets the requirements of CEQA, and recirculation is not required or warranted.

Response B-20: The commenter provides closing remarks, and requests that the City consider alternatives that relocate industrial uses and truck routes away from residential neighborhoods. As noted throughout the responses provided above, the City has taken numerous steps, through proposed General Plan policies and actions, that would ensure that truck trips associated with potential new limited industrial development within the Central Lathrop Specific Plan would not travel through residential neighborhoods and adjacent to Lathrop High School. As noted in Response B-3, the City proposes to make the following changes to Action LU-5f (shown in strikethrough and underline format), and to include a new action (Action LU-5g), in order to provide more specificity and enforceability to the City’s COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-51 plans to direct all future truck traffic within the Central Lathrop Specific Plan Area away from existing and planned sensitive receptors.

LU-5f: Update the Central Lathrop Specific Plan (CLSP) to accomplish the following objectives:
a. Bring the Specific Plan’s land use map into consistency with the General Plan Land Use Map (Figure LU-1)
b. Establish a circulation network that keeps future truck trips as far from existing and planned sensitive receptors as feasible; this includes, but is not limited to, the following requirements, which shall be incorporated into the Specific Plan:
i. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway.
ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA). iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.
c. Establish site design standards for new industrial projects; d. Identify financing and cost-recovery methods to fund roadway and infrastructure improvements.
e. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I-5.
f. Infrastructure improvements to improve roadway operations g. Opportunities to provide employee-serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-52 Final Environmental Impact Report – Lathrop General Plan Update e. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
f. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

The City appreciates the comments and input provided by the commenter. As demonstrated throughout the responses provided above, the Draft EIR thoroughly analyzes and addresses all of the comments and issues raised in this comment letter, and recirculation of the Draft EIR is not required or warranted. The City has made revisions to actions within the Proposed General Plan to further ensure that the commenters primary concerns related to truck traffic in the Central Lathrop Specific Plan area have been addressed.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-53 C-1
C-2
C-3
C-4

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-54 Final Environmental Impact Report – Lathrop General Plan Update C-4 Cont.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-55 Response to Letter C: San Joaquin County Environmental Health Department
Response C-1: The commenterstates that all Onsite Water Treatment Systems (OWTS) must comply with San Joaquin County Local Agency Management Program (LAMP) and current OWTS standards.

This comment is noted. The City of Lathrop requires septic systems to be approved under a permit and inspection through the San Joaquin County EHD. Specifically General Plan Policy PFS-3.8 requires Septic Systems to meet the of the San Joaquin County Health Department standards.

These comments are noted. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response C-2: The commenter states that any existing wells or septic systems to be abandoned shall be destroyed under permit and inspection by the EHD (San Joaquin County Development Title, Section 9- 1110.3 & 9-1110.4).

This comment is noted. The City of Lathrop requires all existing wells and septic systems to be approved, abandoned or destroyed under a permit and inspection through the San Joaquin County EHD. Specifically General Plan Policy PFS-3.8 requires Septic Systems to meet the of the San Joaquin County Health Department standards. Additionally General Plan Action PS-1i ensures that all abandoned wells are permitted through the County.

These comments are noted. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response C-3: This comment states that any geotechnical drilling shall be conducted under permit and inspection by The Environmental Health Department (San Joaquin County Development Title, Section 9- 1115.3 and 9-1115.6).

These comments present information on Environmental Health Department requirements. The City of Lathrop is committed to working with the San Joaquin County Environmental Health Department in review of future Projects.

Response C-4: This comment lists agency program requirement for the use and storage of hazardous materials and lists laws and regulations related to hazardous materials.

These comments are noted. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-56 Final Environmental Impact Report – Lathrop General Plan Update D-1
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-57 D-1 Cont.

D-2
D-3

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-58 Final Environmental Impact Report – Lathrop General Plan Update D-3 Cont.

D-4
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-59 D-5
D-4 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-60 Final Environmental Impact Report – Lathrop General Plan Update Response to Letter D: Delta Stewardship Council
Response D-1: This comment serves as an introduction to the comment letter, providing a summary of the Project, and the Delta Stewardship Councils role in implementing the Delta Plan.

This comment is introductory and no further response is necessary.

Response D-2: This comment provides a summary of the Delta Stewardship Council’s role in implementing the Delta Plan, including review of local and regional planning documents.

This comment is introductory and no further response is necessary.

Response D-3: The commenter notes that the General Plan Update may meet the definition of a covered action under the Delta Plan, and cites relevant sections of the Public Resources Code. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response D-4: The commenter notes filing requirements and exemption criteria for projects subject to the Delta Plan. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

Response D-5: The commenter extends an offer to discuss Delta Plan consistency with the City. The City appreciates this offer and will continue to work collaboratively with the Delta Stewardship Council. It is further noted that the City and the Delta Stewardship Council have had open dialogue during preparation of the General Plan Update. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-61 E-1

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-62 Final Environmental Impact Report – Lathrop General Plan Update Response to Letter E: James and Brenda Hystad, Public Comment Submission
Response E-1: The commenter notes receipt of City correspondence regarding proposed Land Use Map changes in the vicinity of their property. The commenter does not address the adequacy of the Draft EIR.

It is noted that City staff made direct contact with the commenter immediately after receiving this letter, and provided the commenter with detailed information regarding the project. The commenter verbally indicated to City staff that all outstanding questions and issues of concerns were addressed during that conversation. No further response is required.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-63 F-1

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-64 Final Environmental Impact Report – Lathrop General Plan Update Response to Letter F: City of Manteca, Development Services Department Response F-1: The commenter notes receipt and review of the Draft EIR, and states that the City of Manteca looks forward to continued collaboration with Lathrop on regional and sub-regional issues of concern. The City of Lathrop appreciates these comments. These comments are noted, and will be forwarded to the City Council for review and consideration. This comment does not address the adequacy of the Draft EIR, and no further response is required. No changes to the Draft EIR text are required.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-65 G-1
G-2

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-66 Final Environmental Impact Report – Lathrop General Plan Update G-2 Cont.

G-3
G-4
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-67 G-4 Cont.

G-5

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-68 Final Environmental Impact Report – Lathrop General Plan Update G-5 Cont.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-69 G-5 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-70 Final Environmental Impact Report – Lathrop General Plan Update G-6
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-71 G-6 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-72 Final Environmental Impact Report – Lathrop General Plan Update G-6 Cont.

G-7
G-8
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-73 G-8 Cont.

G-9
G-10

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-74 Final Environmental Impact Report – Lathrop General Plan Update G-10 Cont.

G-11
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-75 G-11 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-76 Final Environmental Impact Report – Lathrop General Plan Update G-11 Cont.

G-12
COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-77 G-12 Cont.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-78 Final Environmental Impact Report – Lathrop General Plan Update Response to Letter G: San Joaquin Valley Air Pollution Control District Response G-1: This comment provides an introduction to the comment letter, and presents some summary characteristics of the proposed Project. No response to this comment is warranted.

Response G-2: The commenter suggests the DEIR include land use strategies to reduce VMT, support clean vehicle emissions for heavy duty trucks, and include techniques for siting and construction that further air quality goals and reduce health impacts. This comment is noted. The General Plan includes a wide range of policies and actions that support land use compatibility, and air quality goals. Additionally Policy RR-6.1 calls for the City to coordinate planning efforts with the San Joaquin Valley Air Pollution Control District (SJVAPCD), San Joaquin Council of Governments, and the California Air Resource Board to meet local and regional air quality standards and ensure attainment of established goals. These comments provide information on air resources and best practices within the region. The commenter is also referred to the responses to Letter B, above, which include detailed information regarding the numerous policies and actions included throughout the General Plan that would effectively reduce future air quality emissions. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-3: The commenter notes that future development under the Project may contribute to negative impacts on air quality due to increased traffic and operational emissions.

The General Plan includes a wide range of policies and actions that support land use compatibility, and air quality goals.

During development of the General Plan goals, policies, and actions, a variety of resources were used to guide and craft new policy, including CARB’s Air Quality and Land Use Handbook. As stated on DEIR pg.

3.3-39 the Air Quality and Land Use Handbook: A Community Health Perspective, adopted by CARB, May 2005 was prepared to address the siting of sensitive land uses in close proximity to sources of TAC emissions that include the following sources within the City:
• Within 500 feet of Interstate 5 and Highway 120;
• Within 300 feet of dry cleaning operations that use perchloroethylene; and • Within 50 feet of a typical gas station.

The proposed General Plan includes policies and programs aimed to limit exposure to TAC and PM concentrations within the city. These policies and actions are included within various elements of the General Plan. For example, Policy RR-6.2 requires that community exposure to toxic and harmful emissions and odors is minimized by required adequate buffer or distance between residential or other sensitive receptors and industrial, manufacturing, and processing facilities, highways and rail lines, and similar uses that typically generate air pollutants, toxic air contaminants, and/or obnoxious fumes or odors. Policy RR-6.3 requires new construction to minimize fugitive dust and construction vehicle emissions. Furthermore, Implementing Measure RC-6a requires that planning projects are reviewed for their consistency with SJVAPCD requirements during the CEQA review process.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-79 In order to ensure that the potential for pollution exposure to existing and future sensitive receptors is reduced to the greatest extent feasible, the proposed General Plan includes numerous goals, policies and implementation actions which would further the fundamental goals of the SJVAPCD in reducing emissions of criteria pollutants associated with vehicle miles traveled, reducing building energy usage, and would increase opportunities for transit ridership in Lathrop and the surrounding areas. The list provided on DEIR pages 3.3-27 through 3.3-36 identifies those General Plan policies and actions that would work to further criteria pollutant emissions reductions, including reviewing projects for conformance with applicable air quality plans and regulations, reducing energy demands, and implementing methods to reduce vehicle miles traveled, including providing adequate pedestrian, bicycle, and transit facilities and opportunities, promoting non-vehicle travel modes, requiring employers with 100 or more employees to implement TDM programs, and ensuring regional coordination on trip and VMT reduction efforts..

In addition to the policies and actions described above, and on pages 3.3-27 through 3.3-36 of the DEIR, the following are of particular note:

This action requires all future industrial development proposals located within 1,000 feet of existing or planned sensitive receptors to prepare a health risk assessment (HRA) that meets established standards and thresholds established by the Office of Environmental Health Hazard Assessment (OEHHA), and the San Joaquin Valley Air Pollution Control District (SJVAPCD). Projects that would exceed an established threshold cannot be approved until such time that it can be demonstrated that design modifications or other mitigation measures imposed upon the project would reduce health risks below the established thresholds of significance. This is a specific, enforceable, performance-based measure that would ensure that sensitive receptors are not exposed to excessive levels of pollutant concentrations or toxic air contaminants from future development projects.

Another notable action related to this topic includes:

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-80 Final Environmental Impact Report – Lathrop General Plan Update LU-5d When industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions are proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors, the City shall require the implementation of best management practices (BMPs) to reduce pollution exposure to sensitive receptors, particularly diesel particulate matter (DPM). The appropriate BMPs shall be established on a case-by-case basis, and should consider the following tools, methods, and approaches:
• Creating physical, structural, and/or vegetative buffers that adequately prevent or substantially reduce pollutant dispersal between warehouses and any areas where sensitive receptors are likely to be present, such as homes, schools, daycare centers, hospitals, community centers, and parks. • Providing adequate areas for on-site parking, on-site queuing, and truck checkin that prevent trucks and other vehicles from parking or idling on public streets.
• Placing facility entry and exit points from the public street away from sensitive receptors, e.g., placing these points on the north side of the facility if sensitive receptors are adjacent to the south side of the facility. Exceptions can be made for emergency vehicle access (EVA) points.
• Locating warehouse dock doors and other onsite areas with significant truck traffic and noise away from sensitive receptors.
• Screening dock doors and onsite areas with significant truck traffic and noise with physical, structural, and/or vegetative barriers that adequately prevent or substantially reduce pollutant dispersal from the facility towards sensitive receptors.
• Posting signs clearly showing the designated entry and exit points from the public street for trucks and service vehicles.
• Posting signs indicating that all parking and maintenance of trucks must be conducted within designated on-site areas and not within the surrounding community or public streets.

This action requires all future industrial projects, including warehouse projects, fulfillment centers, and other projects that may generate high volumes of truck trips and/or air quality emissions, proposed within 1,000 feet of existing or planned residential uses or other sensitive receptors to implement a range of best practices to reduce pollution exposure to sensitive receptors, particularly diesel particulate matter (DPM), regardless of whether or not the project would exceed an established threshold of significance for air quality or toxic air contaminant emissions. This action was developed to implement the best practices identified in the Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, published by the Attorney General’s Office in 2021.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-81 This comment is noted. Future Projects will be reviewed and required to meet relevant General Plan and Air District standards, and future projects in Lathrop will be referred to the District for review and comment. These comments provide information on air resources and best practices within the region.

These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-4: The commenter recommends that the DEIR stipulate that future development projects identify and characterize project construction and operational air emissions. The commenter recommends the air emissions be compared to the District significance thresholds, and states that the DEIR should include a discussion of policies, which when implemented, will require assessment and characterization of project-level emissions, and subsequently require mitigation of air quality impacts to the extent feasible at the individual project-specific level.

Future projects will be reviewed for compliance with relevant General Plan and Air District standards, and future projects will be provided to the district for review and comment. General Plan Action RR-6a requires the review of development, infrastructure, and planning projects for consistency with SJVAPCD requirements during the CEQA review process. This action requires project applicants to prepare air quality analyses to address SJVAPCD and General Plan requirements, which include analysis and identification of:

A. Air pollutant emissions associated with the project during construction, project operation, and cumulative conditions.

B. Potential exposure of sensitive receptors to toxic air contaminants.

C. Significant air quality impacts associated with the project for construction, project operation, and cumulative conditions.

D. Mitigation measures to reduce significant impacts to less than significant or the maximum extent feasible where impacts cannot be mitigated to less than significant.

This comment is noted. These comments provide information on air resources and best practices within the region. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-5: The commenter provides additional information on Health Risk Assessment best practices. Additionally, the commenter notes that prioritization and/or a HRA should not be limited solely to industrial projects and should be required for future development projects, regardless of development type (i.e. commercial, mixed-use, etc.), due to the potential impact on sensitive receptors.

These comments are noted. The City has provided specific policy guidance for development projects that are of high concern regionally, including projects that have the potential to result in additional DPM emissions. These specific policies are meant to provide for additional policy direction for industrial type uses, however, during development review process all future projects will be reviewed for the potential to result in TAC impacts, and all projects requiring CEQA review will be specifically analyzed for air quality impacts, including the potential for Health Risks.

Health risks are addressed on pages 3.3-37 through 3.3-48 of the DEIR. As described on DEIR page 3.3- 42, individual projects will be required to provide their own environmental assessments to determine health impacts from the construction and operation of their projects. In the event that future individual

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-82 Final Environmental Impact Report – Lathrop General Plan Update projects may result in exposure to TACs by sensitive receptors, these future projects would be required to analyze TAC impacts on an individual project level, per SJVAPCD requirements, and in accordance with California Office of Environmental Health Hazard Assessment (OEHHA) guidance. Additionally, General Plan Policy RR-6.2 states: Sensitive Receptors. Minimize the community’s exposure to toxic and harmful air emissions and odors by requiring an adequate buffer or distance between residential and other sensitive receptors and industrial-type uses that typically generate air pollutants, toxic air contaminants, and/or obnoxious fumes or odors.

The General Plan, as written, addresses the issues raised by the commenter. This comment is noted.

These comments provide information on air resources and best practices related to Health Risk Assessments. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-6: The commenter recommends a variety of emission reduction strategies to reduce emissions from future development projects including: Industrial/Warehouse Project Emission Reduction Strategies, Voluntary Emission Reduction Agreements, On-Site Solar Deployment, and Electric Vehicle Chargers. The District recommends the City consider the feasibility of incorporating emission reduction strategies that can reduce potential harmful health impacts and provides a list of best practices.

The General plan includes Policies and Actions, that when implemented, support a wide range of emissions reduction strategies. Specifically Policy RR-6.1 calls for coordinating planning efforts with the San Joaquin Valley Air Pollution Control District (SJVAPCD), and the California Air Resource Board to meet local and regional air quality standards and ensure attainment of established goals. Additionally, Policy RR-6.7 requires the implementation of relevant mitigation measures for all future development upon identification of potential air quality impacts. The commenter is referred to Response B-3, above, which provides a detailed description of land use and air quality policies that would reduce emissions from future projects. Many of the best practices listed by the commenter are included under General Plan Action LU-5d
A determination on including onsite mitigation is based, in part, on the specific characteristics of the site, end user, and the building(s) that would be constructed on each individual lot. Those characteristics would help determined the need and applicability of future development requirements. Each future project will be reviewed for air quality impacts and opportunities for emission reduction strategies to reduce emissions.

The commenter recommends the DEIR include a feasibility discussion on implementing a Voluntary Emission Reduction Agreement (VERA) as a mitigation measure for future development projects that are determined to exceed the District’s CEQA significance thresholds.

A determination on including site specific mitigation is based, in part, on the specific characteristics of the site, end user, and the building(s) that would be constructed on each individual lot. Those characteristics would help determined the need and applicability of future development requirements, each future project will be reviewed for air quality impacts and opportunities for emission reduction strategies to reduce emissions. Future projects will be reviewed and required to meet relevant General Plan and Air District standards, and future projects will be referred to the District for review and COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-83 comment. General Plan Action RR-6a requires the review development, infrastructure, and planning projects be reviewed for consistency with SJVAPCD requirements during the CEQA review process. This action requires project applicants to prepare air quality analyses to address SJVAPCD and General Plan requirements, which include analysis and identification of mitigation measures to reduce significant impacts to less than significant or the maximum extent feasible where impacts cannot be mitigated to less than significant.

Given that a VERA is a “Voluntary Agreement,” the feasibility of entering into such an agreement cannot be measured because the terms of the agreement and the party’s willingness to “agree” to such terms is not known. A “voluntary agreement” cannot be mandated through CEQA because it cannot be guaranteed that the terms of the agreement would be agreeable to both parties. Nevertheless, the City recognizes that a VERA is one method that can be used to try to reduce emissions. The City can educate applicants on the benefits of a VERA, and recommend consulting with the Air District to see if such “voluntary agreement” can be reached.

These comments are noted. These comments provide information on air emission reduction strategies.

These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

The commenter suggests that the City consider incorporating solar power systems as an emission reduction strategy for the Project.

This comment is noted. The proposed Project is already required to implement solar deployment as required by the State of California. Moreover, Action PS-6g call of the City to evaluate the feasibility for government-constructed and/or operated new development to exceed the CalGreen Tier 1, or successor program, standards. Additionally as described in Action RR-6d, the City will continue to review development projects to ensure that all new public and private development complies with the California Code of Regulations (CCR), Title 24 standards as well as the energy efficiency standards established by the Lathrop Municipal Code.

These comments are noted. These comments provide information on air emission reduction best practices. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

The commenter recommends that the City and project proponents install electric vehicle chargers at project sites, and at strategic locations.

The General Plan includes a wide range of policies and actions that support EV charging stations. These include but are not limited to the following Policies and Actions:
• RR-6i Support the establishment and expansion of a regional network of electric vehicle charging stations and encourage the expanded use of electric vehicles. • RR-6j Establish and adopt standards and requirements for electric vehicle parking, including minimum requirements for the installation of electric vehicle charging stations in new multifamily residential and commercial, office, and light industrial development.

2.0 COMMENTS ON DRAFT EIR AND RESPONSES

2.0-84 Final Environmental Impact Report – Lathrop General Plan Update • CIR-4.4 Electric Vehicle Charging. Support the creation of electric vehicle charging stations at multifamily residential, commercial, government, and other employment and community destinations.
• CIR-4k Require new development to incorporate electric vehicle charging in accordance with the California Green Building Standards Code. Encourage installation of electric vehicle charging stations at existing development.

Response G-7: The Commenter provides information related to the District’s Bikeway Incentive Program.

These comments are noted. These comments provide information on District programs and funding opportunities. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-8: The commenter provided information on health impacts related to the operation of under-fired charbroilers, and recommends that the DEIR include a measure requiring the assessment and potential installation, as technologically feasible, of particulate matter emission control systems for new large restaurants operating under-fired charbroilers.

These comments are noted. General Plan Action LU-5.b requires, through the development review process, that land use compatibility is analyzed, and requires adequate buffers and/or architectural consideration to protect residential areas, or other sensitive receptors developed or undeveloped, from intrusion of development activities that may cause unwanted nuisances and health risks. Additionally, Policy RR-6.5 requires appliances and equipment, including wood-burning devices, in development projects to meet current standards for controlling air pollution, including particulate matter and toxic air contaminants, while Policy RR-6.7 requires the implementation of relevant mitigation measures for all future development upon identification of potential air quality impacts.

These comments are noted. These comments provide information on air quality issues and funding opportunities. These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-9: The commenter provides information on the District’s Clean Green Yard Machines (CGYM) program and recommends the Project proponent consider the District’s Clean Green Yard Machines (CGYM) program, which provides incentive funding for replacement of existing gas powered lawn and garden equipment.

This comment is noted. The proposed Project is a long -range planning document and does not specifically include lawn care equipment. The City supports individual efforts by future projects to incorporate clean yard equipment as feasible, and will review future projects for clean energy requirements. Specifically, Policy RR-6.5 requires appliances and equipment in development projects to meet current standards for controlling air pollution, including particulate matter and toxic air contaminants.

COMMENTS ON DRAFT EIR AND RESPONSES 2.0
Final Environmental Impact Report – Lathrop General Plan Update 2.0-85 These comments are noted. These comments provide information on air quality program opportunities.

These comments do not address the adequacy of the Draft EIR. No further response to this comment is warranted.

Response G-10: The commenter provides information on San Joaquin Valley Air Pollution Control District Rules and Regulations.

This comment is noted. Future development projects are subject to the District’s rules and regulations, many of which are presented in the Regulatory Setting of the Air Quality Chapter on DEIR pages 3.3-17 through 3.3-21.

These comments provide information on air quality programs and rules. These comments do not address the adequacy of the Draft EIR. No additional response to this comment is warranted.

Response G-11: The commenter provides additional information on San Joaquin Valley Air Pollution Control District Rules and Regulations.

These comments provide information on air quality programs and rules. These comments do not address the adequacy of the Draft EIR. No additional response to this comment is warranted.

Response G-12: The commenter states that future development projects may require an environmental review and air emissions mitigation. The commenter notes that a project’s referral documents and environmental review documents provided to the District for review should include a project summary, the land use designation, project size, air emissions quantifications and impacts, and proximity to sensitive receptors and existing emission sources, and air emissions mitigation measures. Additionally, the comment provides the commenter’s contact information.

These comments provide information on District preferences and review requirements. As stated previously Policy RR-6.1 requires the City to coordinate planning efforts with the San Joaquin Valley Air Pollution Control District (SJVAPCD), San Joaquin Council of Governments, and the California Air Resource Board to meet local and regional air quality standards and ensure attainment of established goals.

Additionally, Action RR-6c calls for the City to work with San Joaquin County and the SJVAPCD to implement plans and programs aimed at improving regional air quality, and Action RR-6a requires the review of development, infrastructure, and planning projects for consistency with SJVAPCD requirements during the CEQA review process.

These comments do not address the adequacy of the Draft EIR. No additional response to this comment is warranted.

ERRATA 3.0
Final Environmental Impact Report – Lathrop General Plan Update 3.0-1 This chapter includes minor edits to the EIR. These modifications resulted from responses to comments received during the Draft EIR public review period.

Revisions herein do not result in new significant environmental impacts, do not constitute significant new information, and do not alter the conclusions of the environmental analysis that would warrant recirculation of the Draft EIR pursuant to State CEQA Guidelines Section 15088.5. Changes are provided in revision marks with underline for new text and strike out for deleted text.

3.1 REVISIONS TO THE DRAFT EIR

EXECUTIVE SUMMARY
No changes were made to the Executive Summary of the Draft EIR (DEIR).

1.0 INTRODUCTION
No changes were made to Chapter 1.0 of the DEIR.

2.0 PROJECT DESCRIPTION
No changes were made to Chapter 2.0 of the DEIR

3.1 AESTHETICS AND VISUAL RESOURCES
No changes were made to Section 3.1 of the DEIR.

3.2 AGRICULTURAL AND FOREST RESOURCES
No changes were made to Section 3.2 of the DEIR.

3.3 AIR QUALITY
The following changes were made to page 3.3-16 in Section 3.3 of the DEIR:

3.0 ERRATA

3.0-2 Final Environmental Impact Report – Lathrop General Plan Update ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.
c. Establish site design standards for new industrial projects; d. Identify financing and cost-recovery methods to fund roadway and infrastructure improvements.
e. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I-5.
f. Infrastructure improvements to improve roadway operations g. Opportunities to provide employee-serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals.

LU-5g: During the interim period following adoption of this General Plan, and the adoption of the updates to the Central Lathrop Specific Plan, identified in Action LU-5f, the City shall enforce the following requirements for all Limited Industrial development projects, including warehouse, distribution, and logistics projects, within the Central Lathrop Specific Plan Area:
a. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway.
b. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA). c. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

3.4 BIOLOGICAL RESOURCES
No changes were made to Section 3.4 of the DEIR.

ERRATA 3.0
Final Environmental Impact Report – Lathrop General Plan Update 3.0-3

3.5 CULTURAL AND TRIBAL RESOURCES
No changes were made to Section 3.5 of the DEIR.

3.6 GEOLOGY
No changes were made to Section 3.6 of the DEIR.

3.7 GREENHOUSE GAS, CLIMATE CHANGE AND ENERGY
No changes were made to Section 3.7 of the DEIR.

3.8 HAZARDS AND HAZARDOUS MATERIALS
No changes were made to Section 3.8 of the DEIR.

3.9 HYDROLOGY AND WATER QUALITY
No changes were made to Section 3.9 of the DEIR.

3.10 LAND USE PLANNING AND POPULATION/HOUSING
The following changes were made to page 3.10-16 in Section 3.10 of the DEIR:

LU-5f: Update the Central Lathrop Specific Plan (CLSP) to accomplish the following objectives:
h. Bring the Specific Plan’s land use map into consistency with the General Plan Land Use Map (Figure LU-1)
i. Establish a circulation network that keeps future truck trips as far from existing and planned sensitive receptors as feasible; this includes, but is not limited to, the following requirements, which shall be incorporated into the Specific Plan:
i. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway.
ii. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA).
iii. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.
j. Establish site design standards for new industrial projects;

3.0 ERRATA

3.0-4 Final Environmental Impact Report – Lathrop General Plan Update k. Identify financing and cost-recovery methods to fund roadway and infrastructure improvements.
l. Circulation design standards that promote safe transportation routes that limit impacts to developed areas to the south, and connectivity enhancements to provide better connectivity to I-5.
m. Infrastructure improvements to improve roadway operations n. Opportunities to provide employee-serving amenities onsite, such as parks and plazas, outdoor seating areas, fitness facilities, and daycare centers as a means to reduce vehicle trips, while supporting air quality, public health, and sustainability goals.

LU-5g: During the interim period following adoption of this General Plan, and the adoption of the updates to the Central Lathrop Specific Plan, identified in Action LU-5f, the City shall enforce the following requirements for all Limited Industrial development projects, including warehouse, distribution, and logistics projects, within the Central Lathrop Specific Plan Area:
d. Trucks shall be prohibited on Dos Reis Road, west of Golden Valley Parkway.
e. Future truck dependent development projects shall be prohibited from providing driveway access points off of Dos Reis Road, west of Golden Valley Parkway, other than emergency vehicle access (EVA). f. Truck traffic within the Limited Industrial Area of the Central Lathrop Specific Plan shall be limited to De Lima Road, and any future roadways north of Dos Reis Road, to connect to Manthey Road, Roth Road, and Interstate 5.

3.11 MINERAL RESOURCES
No changes were made to Section 3.11 of the DEIR.

ERRATA 3.0
Final Environmental Impact Report – Lathrop General Plan Update 3.0-5

3.12 NOISE
The following typo correction is made to Table 3.12-11 on page 3.12-19 of the DEIR:

TABLE 3.12-11: BASELINE (2020) VS. PROPOSED GENERAL PLAN

ROADWAY SEGMENT

NOISE LEVELS (LDN, DB) AT NEAREST SENSITIVE RECEPTORS

BASELINE
(2020)

PROPOSED
GP CHANGE CRITERIA1 SIGNIFICANT?
Roth Road I-5 to Harlan Road 70.1 73.8 3.7 +1.5 dB Yes
Harlan Road South of Roth Road 68.7 69.3 0.6 +1.5 dB No Roth Road Harlan Road to McKinley Avenue 67.1 73.3 6.2 +1.5 dB Yes Roth Road McKinley Avenue to City Limits 65.2 72.5 7.3 +1.5 dB Yes Lathrop Road I-5 to Harlan Road 67.1 69.1 2.0 +1.5 dB Yes Harlan Road North of Lathrop Road 64.4 66.7 2.3 >65 dB Yes Lathrop Road Harlan Road to 5th Street 66.1 70.0 3.9 +1.5 dB Yes Lathrop Road 5th Street to McKinley Avenue 66.9 71.1 4.2 +1.5 dB Yes Lathrop Road McKinley Avenue to City Limits 67.1 70.0 2.9 +1.5 dB Yes Spartan Way Golden Valley Parkway to Lathrop
Road High School 56.6 60.7 4.1 +5.0 dB No
Golden Valley
Parkway Spartan Way to River Island Parkway 63.3 71.9 8.6 >65 dB Yes Spartan Way I-5 to Golden Valley Parkway 60.7 74.3 13.6 >65 dB Yes Harlan Road South of Lathrop Road 67.0 68.3 1.3 +1.5 dB No Cambridge
Avenue South of Lathrop Road 53.6 56.4 2.8 +5.0 dB No
5th Street South of Lathrop Road 56.4 56.7 0.3 +5.0 dB No McKinley Avenue South of Lathrop Road 71.5 73.6 2.1 +1.5 dB Yes River Island
Parkway West of McKee Boulevard 58.2 67.6 9.4 >65 dB Yes River Island
Parkway
Golden Valley Parkway to McKee
Boulevard 59.4 66.2 6.8 >65 dB Yes
Golden Valley
Parkway
River Island Parkway to Towne Centre
Drive 57.0 67.3 10.3 >65 dB Yes
River Island
Parkway I-5 to Golden Valley Parkway 65.9 73.4 7.5 +1.5 dB Yes Louise Avenue I-5 to Harlan Road 71.6 73.4 1.8 +1.5 dB Yes Harlan Road North of Louise Avenue 56.7 58.0 1.3 +5.0 dB No Louise Avenue 5th Street to McKinley Avenue 64.9 68.6 3.7 >65 dB Yes Cambridge
Avenue North of Louise Avenue 54.8 54.8 0.0 +5.0 dB No
5th Street North of Louise Avenue 54.6 58.9 4.3 +5.0 dB No McKinley Avenue South of Louise Avenue 63.5 73.1 9.6 >65 dB Yes Louise Avenue McKinley Avenue to City Limits 66.5 71.2 4.7 +1.5 dB Yes McKee Boulevard River Island Parkway to Town Centre
Drive 55.7 59.4 3.7 +5.0 dB No

3.0 ERRATA

3.0-6 Final Environmental Impact Report – Lathrop General Plan Update TABLE 3.12-11: BASELINE (2020) VS. PROPOSED GENERAL PLAN

ROADWAY SEGMENT

NOISE LEVELS (LDN, DB) AT NEAREST SENSITIVE RECEPTORS

BASELINE
(2020)

PROPOSED
GP CHANGE CRITERIA1 SIGNIFICANT?
Towne Centre
Drive
Golden Valley Parkway to McKee
Boulevard 48.0 51.7 3.7 +5.0 dB No
Harlan Road Louise Avenue to D'Arcy Parkway 69.3 69.8 0.5 +1.5 dB No D'Arcy Parkway East of Harlan Road 66.4 66.9 0.5 +1.5 dB No Manthey Road Towne Centre Drive to Stewart Road 56.7 56.7 0.0 +5.0 dB No D'Arcy Parkway North of Yosemite Avenue 62.7 63.0 0.3 +3.0 dB No Yosemite Avenue D'Arcy Parkway to McKinley Avenue 64.8 72.0 7.2 >65 dB Yes Yosemite Avenue McKinley Avenue to City Limits 67.8 72.7 4.9 +1.5 dB Yes Somerston
Parkway North of Lakeside Drive 56.0 66.0 10.0 >65 dB Yes Lakeside Drive Stewart Road to Somerston Parkway 54.3 54.3 0.0 +5.0 dB No Stewart Road Manthey Road to Lakeside Drive 50.6 54.1 3.5 +5.0 dB No Yosemite Avenue South of SR 120 61.1 72.3 11.2 >65 dB Yes Yosemite Avenue SR 120 to D'Arcy Parkway 69.3 73.2 3.9 +1.5 dB Yes Paradise Road Stewart Road to City Limits 43.7 67.8 24.1 >65 dB Yes Golden Valley
Parkway South of Dos Reis Road N/A 75.0 N/A N/A N/A
Golden Valley
Parkway South of Inland Passage Way 46.3 74.4 28.1 >65 dB Yes Golden Valley
Parkway West of Somerston Parkway N/A 69.3 N/A N/A N/A
Golden Valley
Parkway South of Dell'Osso Drive N/A 63.9 N/A N/A N/A
Stanford Crossing West of Golden Valley Parkway N/A 57.2 N/A N/A N/A River Island
Parkway West of Somerston Parkway 56.1 68.8 12.7 >65 dB Yes Cambay Parkway West of Lakeside Drve N/A 64.6 N/A N/A N/A Cambay Parkway East of Paradise Road N/A 64.3 N/A N/A N/A Cambay Parkway West of Paradise Road N/A 67.2 N/A N/A N/A Paradise Road South of Cambay Parkway 47.2 69.5 22.3 >65 dB Yes McKinley Avenue South of Yosemite Avenue 65.1 77.9 12.8 +1.5 dB Yes 1WHERE EXISTING NOISE LEVELS ARE LESS THAN 60 DB AN INCREASE OF 5 DB WOULD BE A SIGNIFICANT INCREASE. WHERE EXISTING NOISE LEVELS EXCEED 60 DB BUT ARE LESS THAN 65 DB, AN INCREASE OF 3 DB OR MORE WOULD BE SIGNIFICANT. ADDITIONALLY, ANY INCREASE CAUSING NOISE LEVELS TO EXCEED THE CITY’S NORMALLY ACCEPTABLE 60 DB LDN NOISE LEVEL STANDARD AT AN EXISTING OUTDOOR ACTIVITY AREA OF A RESIDENTIAL USE WOULD ALSO BE SIGNIFICANT. WHERE EXISTING NOISE LEVELS EXCEED 65 DB, AN INCREASE OF 1.5 DB OR MORE WOULD BE SIGNIFICANT.

SOURCE: FHWA-RD-77-108 WITH INPUTS FROM FEHR & PEERS TRANSPORTATION CONSULTANTS, CALTRANS, AND SAXELBY ACOUSTICS 2022.

3.13 PUBLIC SERVICES AND RECREATION
No changes were made to Section 3.13 of the DEIR.

ERRATA 3.0
Final Environmental Impact Report – Lathrop General Plan Update 3.0-7

3.14 CIRCULATION
No changes were made to Section 3.14 of the DEIR.

3.15 UTILITIES AND SERVICE SYSTEMS
No changes were made to Section 3.15 of the DEIR.

3.16 WILDFIRE
No changes were made to Section 3.15 of the DEIR.

4.0 CUMULATIVE/OTHER CEQA-REQUIRED TOPICS
No changes were made to Section 4.0 of the DEIR.

5.0 ALTERNATIVES
No changes were made to Chapter 5.0 of the DEIR.

6.0 REPORT PREPARERS
No changes were made to Chapter 6.0 of the DEIR.

7.0 REFERENCES
The following references are added to Section 7.0 of the DEIR:

3.0 ERRATA

3.0-8 Final Environmental Impact Report – Lathrop General Plan Update This page left intentionally blank

Lathrop City CouncilSeptember 19, 2022

Lathrop City Council
September 19, 2022