Mountain View City Council
January 24, 2023

Attachment 1
-1-

CITY OF MOUNTAIN VIEW
RESOLUTION NO.

SERIES 2023

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MOUNTAIN VIEW CERTIFYING THE 2023-2031 HOUSING ELEMENT UPDATE ENVIRONMENTAL IMPACT REPORT

AND ADOPTING FINDINGS RELATED TO ENVIRONMENTAL IMPACTS, MITIGATION MEASURES,

AND ALTERNATIVES AND ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS AND A

MITIGATION MONITORING AND REPORTING PROGRAM IN COMPLIANCE WITH THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT

WHEREAS, in accordance with the California Environmental Quality Act (CEQA), Public Resources Code Section 21000, et seq. , the City of Mountain View (“City”) has prepared an Environmental Impact Report ( EIR) for the 2023-2031 Housing Element Update , including General Plan, Zoning, and Precise Plan amendments necessary for the Housing Element sites inventory (hereinafter “Project”); and

WHEREAS, the City prepared and circulated a Draft EIR for the requisite 45 -day public comment period, which ended on September 6, 2022, and gave all public notices in the manner and at the times required by law; and

WHEREAS, the City prepared responses to comments received on the Draft EIR as reflected in the Response to Comments/ Final EIR document dated November 2022 , which address all written and verbal comments on the environmental issues raised during the public review and comment period for the Draft EIR, and was made available to all commenters and the public on November 4, 2022; and

WHEREAS, the Response to Comments/Final EIR document dated November 2022 , together with the Draft EIR, comprise the Final EIR; and

WHEREAS, the Final EIR identifies certain significant effects on the environment that would result from the implementation of the proposed Project; and

WHEREAS, the Final EIR identifies mitigation measures which, when implemented, will substantially lessen or avoid the significant effects on the environment caused by the proposed Project, with the exception of the significant unavoidable impacts related to generation of a cumulatively considerable net increase in emissions of reactive organic gases (ROG), nitrogen oxides (NOx), and particulate matter in a region that is considered nonattainment under an applicable Federal or State ambient air quality standard; and

WHEREAS, the Final EIR identifies and analyzes a reasonable range of alternatives to the proposed Project; and
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WHEREAS, the Mitigation Monitoring and Reporting Program has been prepared pursuant to CEQA to monitor the Project and to mitigate or avoid significant effects on the environment ; and

WHEREAS, the Environmental Planning Commission held a public hearing on December 7, 2022 on said Project and recommended that the City Council certify the EIR, adopt findings as set forth in this Resolution in accordance with CEQA, and approve the General Plan, Zoning, and Precise Plan amend ments necessary for the Housing Element sites inventory subject to the required findings; and

WHEREAS, the City Council held a public hearing on January 24, 2023 on the Final EIR and the Project , and received and considered all evidence presented at said hearing, including all associated staff reports, meeting minutes, testimony, and evidence constituting the record of proceedings (as defined in the CEQA Findings) and the recommendation for appro val from the Environmental Planning Commission; now, therefore, be it

RESOLVED: that the City Council of the City of Mountain View , having independently considered the Final EIR and the potentially significant environmental effects of the Project as shown in the Final EIR:

1. Certifies that the Final EIR , attached hereto as Exhibit A, has been completed in compliance with CEQA, reflects the independent judgment and analysis of the City, and has been presented to the City Council , which reviewed and considered the information in it , along with other relevant information in the Record of Proceedings, including, without limitation, public testimony, written correspondence, and staff reports and responses, before approving the Project.

2. Adopts the CEQA findings for the Project, attached hereto as Exhibit B.

3. Adopts the Mitigation Monitoring and Reporting Program for the Project, attached hereto as Exhibit C.

4. Adopts all of the feasible mitigation measures identified and described in the Final EIR and determines that the Project, as mitigated, will avoid or reduce all of the significant adverse impacts to a less-than-significant level, with the exception of the significant unavoidable impacts related to generation of a cumulatively considerable net increase in emissions of reactive organic gases (ROG), nitrogen oxides (NOx), and particulate matter in a region that is considered nonattainment under an applicable Federal or State ambient air quality standard.

5. Finds that a reasonable range of potentially feasible alternatives were identified and evaluated in the Final EIR and further finds that none of the alternatives identified and evaluated in the Final EIR w ill achieve the Project objectives to the same degree as the proposed Project -3-
and do not represent substantial environmental benefits over the proposed Project and are, therefore, rejected as infeasible, within the meaning of CEQA, in favor of the proposed Project.

– – – – – – – – – – –

EY/1/RESO
810-12-07-22r-3

Exhibits: A. Final EIR
B. CEQA Findings
C. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE
Response to Comments / Final Environmental Impact Report SCH# 202 2020129
Prepared by November 2022

In conjunction with

Exhibit A

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE
Response to Comments / Final Environmental Impact Report SCH# 2022020129
Prepared by November 2022

In conjunction with

787 The Alameda
Suite 250
San Jose, CA 95126
408.660.4000
esassoc.com

Bend
Camarillo
Delray Beach
Destin
Irvine
Los Angeles
Oakland
Orlando
Pasadena
Petaluma
Portland
Sacramento
San Diego
San Francisco
San José
Santa Monica
Sarasota
Seattle
Tampa
D202000806

City of Mountain View Housing Element Update i ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

TABLE OF CONTENTS
City of Mountain View Housing Element
Update, Response to Comments/Final
Environmental Impact Report
Page
Chapter 1, Introduction ...................................................................................................... 1-1

1.0 CEQA Process................................................................................................... 1-1

1.1 Intended Use of the Final EIR ............................................................................ 1-2

1.2 Mitigation Monitoring and Reporting Program ................................................... 1-3

1.3 New Information in the Final EIR ....................................................................... 1-3

1.4 Organization of This Final EIR ........................................................................... 1-4 Chapter 2, Updated Project Information .......................................................................... 2-1

2.0 Introduction ........................................................................................................ 2-1

2.1 Updates Related to the Project .......................................................................... 2-1 Chapter 3, Comments and Responses ............................................................................. 3-1

3.1 Introduction ........................................................................................................ 3-1

3.2 List of Commenters ............................................................................................ 3-1

3.3 Responses to Individual Comment Letters ........................................................ 3-3

3.4 Responses to Public Hearing Comments ........................................................ 3-61 Chapter 4, Errata to the Draft EIR ..................................................................................... 4-1

4.0 Introduction ........................................................................................................ 4-1

4.1 Text Changes to the Draft EIR ........................................................................... 4-1

4.2 Implication of Changes to the Draft EIR ............................................................. 4-1

4.3 Changes to Chapter 3: Project Description ........................................................ 4-2

4.4 Changes to Section 4.4: Cultural and Tribal Cultural Resources ....................... 4-8

4.5 Changes to Section 4.8: Hazards and Hazardous Materials ............................. 4-9

4.6 Changes to Section 4.13: Public Services and Recreation .............................. 4-10

4.7 Changes to Section 4.14: Transportation ........................................................ 4-12 Appendices
A. Mitigation Monitoring and Reporting Program ..........................................................A-1 List of Figures
3-3 Housing Site Locations Overview ............................................................................ 4-4 List of Tables
3-1 Comment Letters Received Concerning the Draft EIR ............................................ 3-2 3-2 Environmental Planning Commission Public Speakers and Commissioners ........... 3-2

City of Mountain View Housing Element Update 1-1 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 CHAPTER 1
Introduction
This Final Environmental Impact Report (EIR) has been prepared by the City of Mountain View (“City”) (Lead Agency) pursuant to the California Environmental Quality Act (CEQA) and the State CEQA Guidelines to present the environmental analysis of the proposed City of Mountain View Housing Element Update Project (“HEU” or “Project”) to the public for review and for agency decision -makers to use in their consideration of the HEU. 1 This chapter summarizes the CEQA process for the HEU, explains the CEQA context for this Final EIR and new information provided herein, and describes the organization of this document.

1.0 CEQA Process

1.0.1 Notice of Preparation
Pursuant to the requirements of CEQA for the initiation of environmental review, on February 4, 2022, the City sent a Notice of Preparation (NOP) to the State Clearinghouse, responsible and trustee government agencies, organizations, and individuals potentially interested in the Project.

The NOP requested that agencies with regulatory authority over any aspect of the Project describe that authority and identify relevant environmental issues that should be addressed in the EIR.

Interested members of the public were also invited to comment. The comment period for the NOP extended from February 4, 2022 to March 7, 2022, during which time, the City accepted written comments on the scope of the EIR.
2 A scoping meeting was held by the City on February 24, 2022 to accept oral comments. Oral and written comments received during the comment period addressed a range of topics including biological resources, cultural resources and tribal cultural resources, hazards and hazardous materials, land use and planning, population and housing, public services and recreation, and transportation.

1.0.2 Notice and Public Review of the Draft EIR
The City issued a Notice of Availability (NOA) of the Draft EIR on July 22, 2022, announcing the availability of the Draft EIR for public review and comment. The NOA noticed a 45-day public review and comment period on the Draft EIR, starting Friday July 22, 2022, ending on Monday September 5, 2022.
3 During the public review and comment period on the Draft EIR, a

1 The California Environmental Quality Act can be found in the California Public Resources Code, Section 21000 et seq. The State CEQA Guidelines, formally known as the Guidelines for California Environmental Quality Act, can be found in the California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15000 et seq. 2 Late comments were also accepted and received through March 14, 2022. 3 Due to the Labor Day holiday on September 5, 2022, comments were accepted through September 6, 2022.

1. Introduction
City of Mountain View Housing Element Update 1-2 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 public hearing at the City of Mountain View Environmental Planning Commission (EPC) was held on Wednesday, August 3, 2022.

The City encouraged agencies and interested parties to submit written comments on the Draft EIR to the City Community Development Department by email or U.S. mail. By the end of the comment period, the City received 7 comment letters. A list of the commenters is provided in Chapter 3, Section 3.2, List of Commenters, of this Final EIR.

1.0.3 Response to Comments / Final EIR
The City has prepared written responses to comments received during the public review and comment period for the Draft EIR. These comments and the “Response to Comments” are provided in Chapter 3 of this Final EIR. Chapter 3 provides all written comments (submitted by email) together with oral comments received at the hearing conducted by the EPC.

In addition to providing the comments and responses to comments on the Draft EIR, this document includes necessary updates and other modifications and clarifications to the text and exhibits in the Draft EIR in Chapter 4, Errata to the Draft EIR. The Draft EIR, together with the comments, responses to comments, and other information included in this Response to Comments document constitutes the Final EIR, consistent with State CEQA Guidelines Section 15132, Contents of Final Environmental Impact Report. Due to the large volume of text contained in the Draft EIR and its appendices, this Response to Comments/ Final EIR does not contain the full text of the Draft EIR, which remains available in a separate volume and is included here by reference.

The Draft EIR, this Response to Comments / Final EIR, and all supporting technical documents can be found on the Project website at: https://www.mvhousingelement.org/ and on the State Clearinghouse Website at: https://ceqanet.opr.ca.gov/Project/2022020129.

1.1 Intended Use of the Final EIR
The City of Mountain View, as Lead Agency, will make the decision whether to certify the Final EIR in accordance with Section 15090 of the State CEQA Guidelines. Before the City may approve the proposed Project, it must independently review and consider the information contained in the Final EIR, certifying that the Final EIR adequately discloses the environmental effects of the HEU, that the Final EIR has been completed in conformance with CEQA, and that the decision-making body of the Lead Agency independently reviewed and considered the information contained in the Final EIR. Certification of the Final EIR would indicate the City’s determination that the Final EIR adequately evaluated the environmental impacts that could be associated with the HEU.

Once complete and certified, the Final EIR will provide the CEQA compliance documentation upon which the City of Mountain View’s consideration of, and action on, all applicable land use permits and other approvals (collectively, “approvals”) for the proposed Project may be based.

1. Introduction
City of Mountain View Housing Element Update 1-3 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 The Final EIR will also provide the CEQA compliance to be relied upon by Responsible Agencies and Trustee Agencies in considering and acting upon other project approvals under their jurisdiction.

1.2 Mitigation Monitoring and Reporting Program
Public Resources Code Section 21081.6 and State CEQA Guidelines Section 15097 (Mitigation Monitoring or Reporting) require public agencies to establish monitoring or reporting programs for projects approved by a public agency whenever approval involves the adoption of specified environmental findings related to an EIR (also mitigated negative declarations). Accordingly, as Lead Agency, the City has prepared a MMRP for the proposed HEU; the MMRP is included as Appendix A to this document.

The intent of the MMRP is to track and successfully implement the mitigation measures identified within the Final EIR and adopted as part of the Project to avoid or mitigate significant effects on the environment. The MMRP is designed to ensure compliance with the mitigation measures during and after Project implementation. If the City decides to approve the Project, it would adopt the MMRP at the time of Project approval and would be responsible for conducting the monitoring included in the MMRP for the life of the Project. An introduction describing the components of the MMRP and terms used therein is included as part of Appendix A.

1.3 New Information in the Final EIR
Responses to comments received on the Draft EIR focus on comments that pertain to the adequacy of the analysis in the Draft EIR or to other aspects pertinent to the potential effects of the Project on the environment pursuant to CEQA. Comments that address topics beyond the purview of the EIR or CEQA are noted as such for the public record. Where comments have triggered changes to text or exhibits in the Draft EIR, these changes appear as part of the specific response and are consolidated in Chapter 4, Errata to the Draft EIR.

If “significant new information” is added to an EIR after a notice of public review of the Draft EIR document has been given (in this case, July 22, 2022, for the Draft EIR), but before final certification of the EIR, the Lead Agency must issue a new notice and recirculate the Draft EIR for further comment and consultation. State CEQA Guidelines Section 15088.5 (Recirculation of an EIR Prior to Certification), specifies the following:
“Significant new information” requiring recirculation include, for example, a disclosure showing that:
(1) A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;
(2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;

1. Introduction
City of Mountain View Housing Element Update 1-4 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it; or (4) The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.” None of the changes to the Draft EIR identified in this document meet any of the above conditions. Therefore, recirculation of any part of this Final EIR not required. The information presented in the Draft EIR and this document support this determination by the City.

1.4 Organization of This Final EIR
Following this Chapter 1, Introduction, this Response to Comments / Final EIR is organized as described below:
• Chapter 2, Updated Project Information – This chapter presents updates to information that pertains to the HEU.
• Chapter 3, Comments and Responses – This chapter presents a roster showing each public agency, organization, or individual that provided comments on the Draft EIR generally during the public review and comment period for the Draft EIR. This chapter also includes copies of the written comments received by email during the public review and comment period on the Draft EIR. Specific responses to the individual comments in each correspondence are provided after each letter. Finally, this chapter includes responses to verbal comments received on the Draft EIR at the City of Mountain View EPC meeting held on Wednesday, August 3, 2022. Responses are presented to summarize verbal comments, grouped by topic.
• Chapter 4, Errata to the Draft EIR – This chapter presents all updates made to provide clarification, amplification, and corrections to the text and exhibits in the Draft EIR - changes either initiated by City staff or responses to comments received during the public review and comment period on the Draft EIR. Changes that respond to specific comments are also stated or referenced in the corresponding response provided in Chapter 3, Consolidated Comments and Responses.
• Appendices –The appendices include the MMRP for the HEU.

City of Mountain View Housing Element Update 2-1 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 CHAPTER 2
Updated Project Information

2.0 Introduction
This section discusses new or updated information that the City has determined relates to the City of Mountain View Housing Element Update (HEU or Project) , related approvals or requirements, or other information mentioned in the Draft EIR. Although none of the updates discussed here are changes to the Project or the Draft EIR that could result in changes to the environmental analysis in the Draft EIR under CEQA, the City has decided that these changes warrant disclosure in this Response to Comments document for informational purposes for the public and decision-makers of the HEU.

None of the information in this chapter is considered “significant new information” defined in State CEQA Guidelines Section 15088.5 and requiring recirculation of any part of this Final EIR (see Chapter 1, Introduction).

2.1 Updates Related to the Project

2.1.1 Updates to the HEU
Based on comments received on the Draft Housing Element Update from the California Department of Housing and Community Development (HCD) , changes have been made to the HEU. The changes are mainly related to the provision of programs or recategorization of information presented in the Draft HEU. None of these changes materially affect or alter the analysis or conclusions of the Draft EIR.

The sites inventory has been updated and is now 17,779 units. This change is based on several factors, which do not have a meaningful effect on the environmental impacts of the growth:
- Projects that started construction before January 2022 have been added (approximately 1,381 units). These units would have already been considered in any environmental analysis.
- Other newly submitted projects were added to the “Pipeline” list (approximately 900 units). These units comply with existing zoning and general plan designations. - Two additional sites were added to the opportunity sites in the inventory. One site (1500 North Shoreline Boulevard) complies with existing zoning and General Plan designation,

2. Updated Project Information
City of Mountain View Housing Element Update 2-2 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 the other (1250 Grant Road) is consistent with the rezoning adopted concurrent with the Housing Element (amendments to the Grant Phyllis Precise Plan),and is within the growth projected for its environmental analysis. The addition of these two sites results in a gain of approximately 2,000 units.
- Methodology changes and removal of some opportunity sites in the sites inventory result in a loss of approximately 1,220 units. This includes the removal of three APNs associated with 500 W El Camino Real. The other, more significant change involve the further discounting on large multi-tenant retail sites whereby an 80 percent reduction has been applied towards the realistic unit capacity. This takes a more conservative unit capacity estimate should these sites develop at lower densities than projected or with non- housing uses.

The updates to the Housing Sites Inventory fall within the growth envelope analyzed in the Draft EIR. While the number of units in the Housing Sites Inventory did increase somewhat, much of this increase is due to the inclusion of additional units that are under construction in the City and other newly submitted projects. With the removal of some opportunity sites and other development capacity-related changes, a balancing effect occurs. The Draft EIR focused on changes in development potential in the City based on amendments to the General Plan, rezonings, and programs anticipated to be adopted with the proposed HEU. The updates to the proposed HEU and Housing Sites Inventory are consistent with that development potential increase, although it is acknowledged that some additional capacity could be realized during the HEU-period that was anticipated beyond 2031 in the Draft EIR. However, the analysis considers the growth potential as a whole, so these changes would not materially affect or alter the analysis or conclusions of the Draft EIR.

City of Mountain View Housing Element Update 3-1 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 CHAPTER 3
Comments and Responses

3.1 Introduction
This section contains the comment letters, emails, and oral comments received on the Draft EIR.

Following each comment letter is a response by the City intended to supplement, clarify, or amend information provided in the Draft EIR or refer the reader to the appropriate place in the document where the requested information can be found. Responses focus on comments that pertain to the adequacy of the analysis in the EIR or to other aspects pertinent to the potential effects of the HEU on the environment pursuant to CEQA. Comments that address topics beyond the purview of the EIR or CEQA are noted as such for the public record. Where comments have triggered changes to the Draft EIR, these changes appear as part of the specific response and are consolidated in Chapter 4, Errata to the Draft EIR, where they are listed in the order that the revision would appear in the Draft EIR document.

3.2 List of Commenters
Table 3-1, below, lists each public agency, organization, and individual that provided comments on the Draft EIR generally during the public review and comment period for the Draft EIR, which began on July 22, 2022,. September 5, 2022.1 The comments addressed in this Final EIR are presented in the order of the commenters listed below. Commenters have an alphabetic designation that corresponds to the category of commenter, such as “A” for public agencies. A number follows the alphabetic designation to indicate the sequence of the comment submissions.

For example, “A-1” is the first public agency comment submission identified, as shown below.

Specific comments within each correspondence also are identified by a numeric designator that reflects the numeric sequence of the specific comment within the correspondence (e.g., “A-3-3” for the third comment in Comment Letter A-3). Section 3.4, which follows later in this chapter, reproduces each letter with the numeric comment brackets indicated, followed by the responses to each comment.

1 Due to the Labor Day holiday on September 5, 2022, comments were accepted through September 6, 2022.

3. Comments and Responses

City of Mountain View Housing Element Update 3-2 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 TABLE 3-1

C OMMENT LETTERS RECEIVED CONCERNING THE DRAFT EIR
Designator Name/Entity
Author(s) of Comment Letter/e-
mail Date Received
Agencies
A-1 Santa Clara Valley Transportation
Authority (VTA)
Robert Swierk, AICP, Principal
Transportation Planner September 1, 2022
A-2 California Department of Toxic
Substances Control (DTSC)
Gavin McCreary, Project Manager,
Site Evaluation and Remediation Unit September 2, 2022 A-3 Mountain View Los Altos High School
District (MVLA) Nellie Meyer, Ed.D., Superintendent September 2, 2022 A-4 Santa Clara Valley Water District
(Valley Water)
Kevin Thai, CFM, Associate Engineer
– Civil, Community Projects Review
Unit
September 6, 2022
Organizations
O-1 Mountain View YIMBY David Watson July 31, 2022
O-2 Santa Clara Valley Audubon Society
(SCVAS) & GreenSpacesMV
Shani Kleinhaus, Environmental
Advocate, SCVAS & Bruce England,
GreenSpacesMV
September 5, 2022
Individuals
I-1 Hala Alshahwany September 3, 2022
A public hearing to receive verbal comments on the Draft EIR was held at the City of Mountain View Environmental Planning Commission (EPC) meeting on Wednesday, August 3, 2022.

Table 3-2 below lists persons who provided verbal comments at the City of Mountain View EPC Public Hearing on the Draft EIR. No members of the public provided comments on the Draft EIR during the meeting. A summary of comments raised by members of the EPC during the EPC Public Hearing and responses to comments are provided in Section 3.5 below.

TABLE 3-2

ENVIRONMENTAL PLANNING COMMISSION PUBLIC SPEAKERS AND COMMISSIONERS Environmental Planning Commission Public Hearing – August 3, 2022 Public Speakers
• No members of the public provided comments
Environmental Planning Commissioners
• Chair William Cranston
• Vice Chair Joyce Yin
• Chris Clark
• Hank Dempsey
• Jose Gutierrez
• Preeti Hehmeyer
• Alex Nunez

3. Comments and Responses

City of Mountain View Housing Element Update 3-3 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

3.3 Responses to Individual Comment Letters
This section includes copies of the written comments received by email during the public review and comment period on the Draft EIR. Specific responses to the individual comments in each correspondence are provided after each letter.

As described in Section 3.2 above, each correspondence is identified by an alphabetic designation that corresponds to the category of commenter, such as “O” for organizations, and a number follows the alphabetic designation to designate the sequence of the comment submissions (e.g., “O-2” for the second organization comment letter). Specific comments within each correspondence also are identified by a numeric designator that reflects the numeric sequence of the specific comment within the correspondence (e.g., “O-2-3” for the third comment in Comment Letter O-2).

Responses focus on comments that pertain to the adequacy of the analysis in the EIR or to other aspects pertinent to the potential effects of the HEU on the environment pursuant to CEQA.

Comments that address topics beyond the purview of the EIR or CEQA are noted as such for the public record. Where comments have triggered changes to the Draft EIR, these changes appear as part of the specific response and are consolidated in Chapter 4, Errata to the Draft EIR, where they are listed in the order that the revision would appear in the Draft EIR document.

September 1, 2022

City of Mountain View
Community Development Department
Attention: Ellen Yau, Senior Planner
500 Castro Street, P.O. Box 7540
Mountain View, CA 94039-7540

RE: Mountain View Housing Element Update DEIR and Draft Document

Dear Ellen,

VTA appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Mountain View Housing Element Update (HEU), as well as the draft HEU document. VTA has reviewed the DEIR and draft HEU document and has the following comments:

Consistency of Draft HEU Document with VTA Land Use & Development Review Policy VTA has reviewed the draft HEU document at a high level for consistency with the VTA Board- adopted Land Use & Development Review Policy (see https://www.vta.org/programs/land-use- transportation-luti-program). The VTA Land Use & Development Review Policy establishes a framework for VTA’s involvement in local comprehensive planning and development review processes. Overall, VTA believes that the draft HEU exemplifies several of the guiding principles in VTA’s policy, including “Support Transit-Supportive Development in Close Proximity to Transit” and “Prioritize Sustainable Travel Behavior.” These topics are discussed further in the sections below.

VTA Guiding Principle to Support Transit-Supportive Development VTA supports the direction of the HEU to concentrate many of the Opportunity Sites in the Inventory within walking distance of frequent transit services (including Caltrain, VTA light rail, and VTA Rapid and local bus service along El Camino Real) as well as shops and services.

This will help increase opportunities for residents to walk, bike and take transit for daily activities, resulting in reduced Vehicle Miles Traveled (VMT) and Greenhouse Gas (GHG) emissions.

VTA notes that a substantial percentage of the housing capacity in the draft HEU Inventory is in the North Bayshore area, which is not located on the core transit network and is not as well served by shops and services as other areas of the city. VTA is supportive of the City’s efforts to balance jobs and housing within the City, and VTA encourages the City to continue its efforts to make North Bayshore a place where daily trips can be accomplished without a car, including supporting the Mountain View TMA and MVgo shuttle, supporting the City of Mountain View
Housing Element Update DEIR and Draft Document

Mountain View Community Shuttle, continuing to prioritize transit on Shoreline Boulevard and Charleston Boulevard, and including strong Transportation Demand Management (TDM) requirements with new development in North Bayshore.

VTA Guiding Principle to Prioritize Sustainable Travel Behavior VTA supports the inclusion of several policies in draft HEU Chapter 3 that prioritize the use of sustainable travel behavior including walking, bicycling and taking transit. This includes:
• Policy 1.1 to “Ensure that adequate residential land is available to accommodate the City’s RHNA, with special focus on Precise Plan areas near transit, employment centers, and services”;
• Policy 1.3 to “Maintain or improve the character and quality of neighborhoods through upgrades to existing developments, sensitively designed new developments, improved streetscapes, and better access to schools, parks, goods, services, jobs, transportation, and other needs”; and
• Policy 1.6 to “Provide incentives, such as reduced parking standards and/or reductions in other development standards and fees, to facilitate the development of housing that is affordable to lower- and moderate-income households.” VTA notes that reduced parking standards will also help incentivize the use of sustainable travel modes by residents.

DEIR Mitigation Measure TRA-1, Implement VMT Reduction Measures VTA supports the inclusion of Mitigation Measure TRA-1, Implement VMT Reduction Measures, to address VMT generated by residential projects in the Housing Element Update that do not “screen out” of VMT analysis requirements. This mitigation measure should help incentivize sustainable travel behavior, building on the draft HEU polices noted above. VTA notes that the discussion of potential VMT mitigation measures in the City’s VMT guidelines in Mitigation Measure TRA-1 (on pages 4.14-23 to 4.14-24 of the DEIR) includes some measures that may primarily apply to employment projects, or where the studies supporting the VMT reductions may only provide evidence for employment projects. VTA recommends that the EIR text be revised to note this caveat.

Preservation of Local Retail in Village Center Locations VTA notes that the draft HEU Inventory includes a number of “Village Centers” across the City, including some along El Camino Real and some in other locations such as the Blossom Valley shopping center at Cuesta & Miramonte. VTA supports the concept of intensifying land uses at Village Centers if they are located close to frequent transit, shops and services. However, adding housing must be done carefully at these locations to prevent the loss of retail and services. The loss of these other uses could make it more difficult to walk, bike and take transit, both for residents of the newly-constructed housing and residents in nearby neighborhoods. This could increase VMT and GHG per capita, working against transportation and climate goals.

City of Mountain View
Housing Element Update DEIR and Draft Document

VTA staff has discussed this issue with City staff recently and understands that the risk of displacement or loss of local retail in these Village Center locations originates from their inclusion in the City’s General Plan itself, coupled with recent housing laws which, when layered together, may have unintended consequences in terms of retail displacement. VTA encourages the City to continue to explore strategies to preserve local retail services even as needed housing development is proposed and approved in Mountain View, and VTA staff is open to further discussions on this topic.

Thank you again for the opportunity to review this project. Please do not hesitate to contact me at 408-321-5949 or [email protected] to discuss any questions you may have on this letter.

Sincerely,

Robert Swierk, AICP
Principal Transportation Planner

3. Comments and Responses

City of Mountain View Housing Element Update 3-7 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter A-1 Response: VTA, September 1, 2022

A-1-1 This is a general comment that includes introductory remarks and serves to introduce the more specific comments that are responded to in detail below.

A-1-2 Comments regarding the merits of the HEU do not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

A-1-3 Comments regarding the merits of the HEU do not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

A-1-4 Comments regarding the merits of the HEU do not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

It is noted that the City is working on transit projects, including a reversible bus lane along the Shoreline Boulevard corridor, to improve transit access to and from the North Bayshore Precise Plan area. Protected bike lanes on Shoreline Boulevard between Middlefield Road and Terra Bella Avenue and additional bike lane safety improvements are also planned to encourage non-vehicle trips.

Phases 2 and 3 of the
Charleston Bus Boulevard will also prioritize movement of high-occupancy modes over single occupancy vehicles in North Bayshore to incentivize higher utilization of mass transit. Additionally, the North Bayshore Master Plan will include robust Transportation Demand Management (TDM) measures and aggressive mode share targets to facilitate mode shift and meet gateway trip caps.

A-1-5 Comments regarding the merits of the HEU do not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

3. Comments and Responses

City of Mountain View Housing Element Update 3-8 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 A-1-6 The City notes this distinction and has added following footnote to the bottom of p.

4.14-24 of the Draft EIR (new text is underlined):
1 Some of the measures may primarily apply to employment projects or have studies supporting the VMT reductions that only provide evidence for employment projects. These measures are included for consideration for mixed-use residential projects.

A-1-7 Comments regarding the merits of the HEU do not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

As discussed in Draft EIR Section 4.14, on General Plan Village Center and El Camino Real Village Center retails sites, the retail development would be replaced on-site as part of a mixed-use residential/retail development. The zoning updates at these sites would require the provision of retail or similar neighborhood-serving uses, at a minimum, an amount to replace the existing commercial floor area or as determined by an analysis of typical amounts of such uses in the underlying zone.

Printed on Recycled Paper

SENT VIA ELECTRONIC MAIL
September 2, 2022
Ms. Ellen Yau
Senior Planner
City of Mountain View
500 Castro Street, P.O. Box 7540
Mountain View, CA 94039-7540
[email protected]

DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE CITY OF MOUNTAIN VIEW HOUSING ELEMENT – DATED JULY 2022 (STATE CLEARINGHOUSE NUMBER:
2022020129)
Dear Ms. Yau:

The Department of Toxic Substances Control (DTSC) received a Draft Environmental Impact Report (EIR) for the City of Mountain View Housing Element (Project). The Lead Agency is receiving this notice from DTSC because the Project includes one or more of the following: groundbreaking activities, work in close proximity to a roadway, presence of site buildings that may require demolition or modifications, importation of backfill soil, and/or work on or in close proximity to an agricultural or former agricultural site.

DTSC recommends that the following issues be evaluated in the Hazards and Hazardous Materials section of the EIR:

1. A State of California environmental regulatory agency such as DTSC or Regional Water Quality Control Board (RWQCB), or a qualified local agency that meets the requirements of Assembly Bill 304 (AB304) should provide regulatory concurrence that any of the sites proposed for housing are safe for construction and the proposed use.

2. The EIR acknowledges that historic and future activities on or near the proposed housing sites have resulted in the release of hazardous wastes/substances and are documented on DTSC’s Envirostor and the RWQCB’s Geotracker databases.

Ms. Ellen Yau
September 2, 2022

The EIR also identifies other past and future activities, including past agricultural practices and removal of existing structures, that could potentially result in the release of hazardous wastes/substances. In instances in which releases have occurred or may occur, at sites not already overseen by DTSC, RWQCB, or other AB304 approved agencies, further studies should be carried out to delineate the nature and extent of the contamination, and the potential threat to public health and/or the environment should be evaluated. The EIR should also identify the mechanism(s) to initiate any required investigation and/or remediation and the government agency who will be responsible for providing appropriate regulatory oversight.

3. Refiners in the United States started adding lead compounds to gasoline in the 1920s in order to boost octane levels and improve engine performance.

This practice did not officially end until 1992 when lead was banned as a fuel additive in California. Tailpipe emissions from automobiles using leaded gasoline contained lead and resulted in aerially deposited lead (ADL) being deposited in and along roadways throughout the state. ADL-contaminated soils still exist along roadsides and medians and can also be found underneath some existing road surfaces due to past construction activities. Due to the potential for ADL-contaminated soil DTSC, recommends collecting soil samples for lead analysis prior to performing any intrusive activities for the project described in the EIR.

4. If buildings or other structures are to be demolished on any project sites included in the proposed project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of the above-mentioned chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s 2006 Interim Guidance Evaluation of School Sites with Potential Contamination from Lead Based Paint, Termiticides, and Electrical Transformers.

5. If any projects initiated as part of the proposed project require the importation of soil to backfill any excavated areas, proper sampling should be conducted to ensure that the imported soil is free of contamination. DTSC recommends the imported materials be characterized according to DTSC’s 2001 Information Advisory Clean Imported Fill Material.

6. If any sites included as part of the proposed project have been used for agricultural, weed abatement or related activities, proper investigation for Ms. Ellen Yau
September 2, 2022

organochlorinated pesticides should be discussed in the EIR. DTSC recommends the current and former agricultural lands be evaluated in accordance with DTSC’s 2008 Interim Guidance for Sampling Agricultural Properties (Third Revision).

DTSC appreciates the opportunity to comment on the EIR. Should you choose DTSC to provide oversight for any environmental investigations, please visit DTSC’s Site Mitigation and Restoration Program page to apply for lead agency oversight. Additional information regarding voluntary agreements with DTSC can be found at DTSC’s Brownfield website.

If you have any questions, please contact me at (916) 255-3710 or via email at [email protected].

Sincerely,

Gavin McCreary
Project Manager
Site Evaluation and Remediation Unit
Site Mitigation and Restoration Program
Department of Toxic Substances Control
cc: ( via email)
Governor’s Office of Planning and Research
State Clearinghouse
[email protected]
Mr. Dave Kereazis
Office of Planning & Environmental Analysis
Department of Toxic Substances Control
[email protected]

3. Comments and Responses

City of Mountain View Housing Element Update 3-12 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter A-2 Response: DTSC, September 2, 2022

A-2-1 This is a general comment that includes introductory remarks and serves to introduce the more specific comments that are responded to in detail below. The comments regarding the components of the proposed Project are noted and are consistent with the discussion in Chapter 3, Project Description, of the Draft EIR. This comment raises neither significant environmental issues nor specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088.

A-2-2 The City agrees that in the event that hazardous materials are identified at a given development site at concentrations above regulatory action levels, the appropriate regulatory agency should be engaged to oversee investigation and cleanup. This is consistent with the regulations summarized in Section 4.8.3, Regulatory Setting, in Section 4.8, Hazards and Hazardous Materials.

A-2-3 Consistent with the above Response to Comment A-2-2, the City agrees that for sites where information is identified that indicates the potential to encounter hazardous materials at concentrations above regulatory action levels, those sites will require investigation consistent with the regulations and Mitigation Measure HAZ-1 described in Section 4.8, Hazards and Hazardous Materials. In the event that hazardous materials are identified at concentrations above regulatory action levels, cleanup would be required to address the hazardous materials. The Draft EIR identifies mechanisms to initiate investigation and remediation, if needed, as discussed below. No edits for the Draft EIR are needed to respond to this comment.

The City of Mountain View Standard Conditions of Approval require the project applicant to prepare a Toxic Assessment report as part of the building permit submittal, demonstrating that hazardous materials do not exist on the site or that construction activities and the proposed use of this site are approved by any regulatory agencies with jurisdiction. No building permits will be issued until each agency and/or department with jurisdiction has released the site as clean or a site toxics mitigation plan has been approved.

Mitigation Measure HAZ-1, Phase I Environmental Site Assessment, requires that the project applicant prepare a Phase I environmental site assessment in accordance with American Society for Testing and Materials Standard E1527 for listed hazardous materials sites. The Phase I assessment would evaluate whether a proposed development site has or may have environmental issues that could affect the development of the site.

3. Comments and Responses

City of Mountain View Housing Element Update 3-13 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 A-2-4 As discussed above in Responses to Comment A-2-3, the City has established mechanisms that require project applicants to evaluate proposed development sites for hazardous materials, which would include testing for aerially-deposited lead in the event that the proposed project proposes ground-disturbing work in roadways.

A-2-5 See Responses to Comments A-2-2 and A-2-3. No edits for the Draft EIR are needed to respond to this comment.

A-2-6 The City agrees that project applicants must demonstrate that imported fill does not contain hazardous materials at concentrations above regulatory action levels. This information would be required as part of the building permit submittal discussed above in the Response to Comment A-2-3.

A-2-7 See Responses to Comments A-2-2 and A-2-3. No edits for the Draft EIR are needed to respond to this comment.

A-2-8 This is a general comment that includes concluding remarks and provides resources for future consultation and program review. The City appreciates this information and looks forward to working with DTSC on future projects.

1299 Bryant Avenue, Mountain View, California 94040-4599 Phone: (650)940-4650

Serving the communities of Mountain View,
Los Altos and Los Altos Hills

September 2, 2022

City of Mountain View
Community Development Department
Attn: Ellen Yau
500 Castro Street, PO Box 7540
Mountain View, CA 94039-7540
[email protected]

RE: Mountain View-Los Altos Union High School District Comment Letter on the Draft EIR for the City of Mountain View Housing Element Update

Dear Ms. Yau:

The Mountain View-Los Altos Union High School District (“District”) hereby submits its comments on the City of Mountain View’s (“City”) Draft Environmental Impact Report (“Draft EIR”) for the City of Mountain View Housing Element Update (“Project”). The District’s comments concern the need to provide assurances that funding for new schools to serve the Project area will be in place and the unstudied Project impacts on the Districts’ schools will be analyzed. As a result, the Draft EIR needs revision and recirculation to disclose the significant new information to the public and allow comment on the new information and realistic mitigations for already-known unmitigated impacts from the Project.

The District must mention that it has actively collaborated with the City for years, but the City has not reciprocated with that same level of collaboration. In fact, the District feels it has been repeatedly ignored. That is especially true, now, when the City is considering housing that will generate 2,930 students to the District’s schools. The District’s alarm over the years has now reached a panic level. In order for the Project to be successful, the City must understand that school infrastructure is not an afterthought and must be a forethought and considered now. Many of the District’s concerns in this letter could have been resolved earlier had the City consulted long ago with the District.

The District is comprised of (i) two comprehensive high schools, Los Altos High School and Mountain View High School, which have consistently been ranked in the top 500 high schools nationally; (ii) an alternative high school, Alta Vista, that the State Department of Education has repeatedly honored as a Model Continuation High School; and (iii) an Adult School that provides vital educational and social

BOARD OF TRUSTEES
Sanjay Dave
Phil Faillace, Ph.D.

Debbie Torok
Catherine Vonnegut
Fiona Walter

SUPERINTENDENT
Dr. Nellie Meyer

MOUNTAIN VIEW LOS ALTOS HIGH SCHOOL DISTRICT

1299 Bryant Avenue, Mountain View, California 94040-4599 Phone: (650)940-4650 services that enable residents to improve their lives and prepare for well -paying and fulfilling careers.

The District prides itself on ensuring the best quality education for all its students. With the City’s assistance, the District can ensure a high -quality education for incoming students generated by the Project.

Although this letter is technical in nature due to the subject matter, the District wishes to emphasize that its comments are meant to help the City fully evaluate and mitigate the potential impacts to the schools.

The District desires mutual cooperation and collaboration with the City to ensure the continued high quality of life in the City and education in its schools.

Draft EIR Comments

Although the Project is expected to generate 15,000 new residences and 2,930 new students to the District’s schools, the Draft EIR fails to analyze any impacts on the District’s schools except to say that the school developer fees will mitigate any impacts. SB 50 declares that the payment of the developer fees (“Developer Fees”) authorized by Education Code section 17620 constitutes “full and complete mitigation of the impacts of any legislative or adjudicative act on the provision of adequate school facilities.” (Gov. Code § 65995(h); see, Id . § 65996(a).) However, California courts have since acknowledged that Developer Fees do not constitute full and complete mitigation for school -related impacts unrelated to school capacity. (Chawanakee Unified Sch. Dist. v. Cty. Of Madera (2011) 196 Cal.App.4th 1016.) For example, the Court identified traffic, air quality, and noise impacts that must be considered in the Draft EIR. (Id. at p. 1029.) Since school facilities are a critical part of any residential development and are a critical part of this Project, the City must consider the impacts on the District’s schools throughout the Draft EIR impact categories.

I. Hazards and Hazardous Materials

On page 4.8-22, the Draft EIR attempts to analyze whether the Project would emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. The Draft EIR only identifies and analyzes the impacts on 10 schools, but it omits the District’s Mountain View High School site. Thus, the Draft EIR must also analyze the hazards and hazardous materials impacts on the District’s Mountain View High School site and revise this section accordingly.

II. Public Services

The Draft EIR states that adherence to General Plan Policies POS -5.3 and POS-5.4 would reduce the potential effects to school facilities associated with increased enrollment as a result of the population growth. POS-5.3 is to ensure school facilities are constructed to serve community needs to the extent allowed by state law. POS-5.4 requires the City to collaborate with local school districts on their facility needs and provide information on development and growth trends. Additionally, General Plan Policy POS-5.2 requires collaboration with the District on new school development and intensification to accommodate population growth while preserving and protecting public parks and playgrounds.

Because the District is already over capacity and the Project will increase capacity, in line with the

1299 Bryant Avenue, Mountain View, California 94040-4599 Phone: (650)940-4650 above policies, the City must consult with the District to ensure that school facilities that need to be expanded or created are identified in the Project and adequately funded to meet these General Plan policies.

Further, the Draft EIR underestimated the capacity impacts of the Project on the District’s schools. The Draft EIR states that the District’s student enrollment was approximately 4,563 students for the 2020- 2021 school year and the existing capacity at the schools is 3,287, which according to the Draft EIR puts the District over capacity, currently, by 1,276 students. Per the Draft EIR, the Project will then add an additional 2,930 students, which would put the District over capacity by 4,206 students.

To put how impactful the added students is into perspective, the enrollment at the District’s two comprehensive high schools is 2,220 students at Mountain View High School and 2,125 students at Los Altos High School, so the additional 2,930 students generated by the Project could support an entirely new high school site, with potential redistribution of students among those three comprehensive high schools. Therefore, the City must revise this section to correctly analyze the capacity impacts from the Project and the resulting environmental impacts of that redistribution (e.g., traffic).

To reiterate, the Draft EIR simply states that payment of Developer Fees constitutes full and complete mitigation of school impacts from development. Even though payment of Developer Fees legally mitigates capacity needs at schools, the reality is Developer Fees are insufficient to construct new classrooms and school sites. This is due largely to the facts that statutory Developer Fees are set by statute (Gov. Code § 65995) and fail to acknowledge the differences in costs of school construction from one school district to another. This particularly burdens school districts in high cost of living areas, like the City, where both land and construction costs drastically exceed other parts of the state.

Developer Fees fail to contemplate the special facilities needs of the districts experiencing rapid growth.

Without adequate funding, the increase in students, combined with the already over capacity schools may require the District to spend valuable resources on temporary solutions to the District’s facilities problems, such as the purchase or lease of portable classrooms to house the new students.

Further, payment of Developer Fees does not mitigate the Project’s significant impacts on the District’s schools concerning air quality, noise, pedestrian safety, traffic and transportation, utilities, and any other environmental impacts. ( Chawanakee Unified Sch. Dist. v. Cty. Of Madera (2011) 196 Cal.App.4th 1016.) These must be analyzed and provided for in a recirculated draft EIR.

III.

District Consultation

Pursuant to Government Code sections 65352 and 65352.2, the City is required to coordinate planning of school facilities with school districts. Specifically, Government Code section 65352 (a) (2) states “before a legislative body takes action to adopt or substantially amend a general plan, the planning agency shall refer the proposed action to . . . . an elementary, high school, or unified school district within the area covered by the proposed action.” Government Code section 65352.2 (d)(2) advises the local agency and school district to review and consider “[o]ptions for the siting of new schools whether or not the local city or counties existing land use element appropriately reflects the demand for public

1299 Bryant Avenue, Mountain View, California 94040-4599 Phone: (650)940-4650 school facilities and ensures that new planned development reserves location for public schools in the most appropriate locations.” The legislature’s intent was clear that local agency planning should include siting of school sites and coordination between the City and District.

Further, over the past few years, the District has consulted with the City on the potential siting of a new high school site at the 17-acre parcel of land located at West Middlefield Road and Moffett Boulevard (the “Shenandoah Property”), currently owned by the United States Department of Army (“Army”).

Since District’s schools are already over capacity, the District has a substantial need for the Shenandoah Property. Thus, although the City and Army may also have needs for the Shenandoah Property, the City should identify this site in its Draft EIR as a potential new high school site, regardless of recent, unbinding comments from the property owners.

IV. Transportation

Although the California Environmental Quality Act (“CEQA”) no longer considers vehicle delay as a significant impact, potential educational disruption and safety impacts are still required where increased traffic and congestion causes secondary impacts to students’ education and safety hazards for pedestrians, bicyclists, and other traffic. The Draft EIR did not analyze the Project’s potential addition to, and delay of, bus and automobile drop-off and pick-up activities at the District’s schools. The added delay could disrupt the educational day and contribute to more frequent absences. Such disruptions would detract from the most effective educational program. The District understands that this is only a Program EIR, but the City must ensure that prior to approving any of the 15,000 housing units, the above transportation impacts have been analyzed and mitigated, where necessary. The City should also include the following mitigation measure or a similar one to mitigate traffic impacts to the District’s schools: “Payment of fair share costs by a developer for traffic and transportation impacts shall be made prior to issuance of a building permit.”

Further, because the Project anticipates an increase of 15,000 new residences to the City and 2,930 new students into the District, the Draft EIR must include analysis of the safety impacts of increased vehicle traffic and student pedestrian traffic to and from the District’s school sites, especially considering that the District’s schools and surrounding infrastructure and housing, were not built to sustain an additional 2,930 students. Thus, the Draft EIR must be revised with an analysis of the Project’s impacts on the vehicle movements to and from the District’s schools, impacts on pedestrian traffic to and from the District’s schools and circulation and congestion during student drop-off and pickup.

Although the Draft EIR articulates a General Plan Policy MOB-6.1 to promote Safe Routes to Schools programs for schools serving the City, it does not actually analyze whether there are impacts on the school routes and safety of students traveling to and from the school sites during construction and Project operation. (Draft EIR, p. 4.14-19.) The Draft EIR must include this analysis and whether there are adequate safety features, such as sufficiently sized sidewalks, bike lanes, crosswalks, stop signs, traffic signals, etc. Without additional analysis, there is no way to confirm whether the Project will have less than significant transportation and secondary impacts upon the District’s school operations.

1299 Bryant Avenue, Mountain View, California 94040-4599 Phone: (650)940-4650 The City should also include the following mitigation measure or a similar one to mitigate pedestrian safety impacts: “Payment of fair share costs by a developer for pedestrian wayfaring improvements that adhere to Safe Routes to Schools shall be made prior to issuance of a building permit.”

V. Conclusion

The District desires that the Project’s potential significant impacts to the students, parents, faculty, and staff of the District’s schools are fully analyzed and mitigated. Given the lack of analyses in the Draft EIR, the District respectfully requests that the Draft EIR be revised to include those analyses and mitigation measures, as set forth herein and recirculated per the requirements of CEQA.

Sincerely,
Nellie Meyer, Ed.D.

Superintendent

cc: City of Mountain View City Council
City of Mountain View Environment Planning Commission
City of Mountain View City Manager
MVLA Board of Trustees

3. Comments and Responses

City of Mountain View Housing Element Update 3-19 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter A-3 Response: MVLA, September 2, 2022

A-3-1 This is a general comment that includes introductory remarks and serves to introduce the more specific comments that are responded to in detail below. To the extent the comment relates to the merits of the Project it is forwarded to the decision makers for consideration.

Based on the City’s Regional Housing Needs Assessment (RHNA) allocation mandated by the State, the HEU plans for an additional 11,135 dwelling units plus a sizeable “buffer.” The Draft EIR evaluated the potential for approximately 15,000 multi-family housing units (including approximately 96 accessory dwelling units) during the HEU planning period as a maximum scenario for purposes of the CEQA evaluation, understanding that the buffer size and the final sites selected for inclusion in the Housing Element will be determined by the City Council upon adoption of the HEU. Of this, approximately 13,600 units are already allowed under the City’s adopted General Plan, zoning, and Precise Plans and the remaining 1,400 units would be created through rezonings and General Plan amendments. In addition, the EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately 2,700 units beyond 2031. The City is required by State law to adopt a HEU to meet the RHNA.

This EIR is a Program EIR, which has been prepared to evaluate the anticipated environmental effects of the proposed HEU in conformance with the provisions of CEQA and the CEQA Guidelines. As a program EIR, this EIR analyzes potential impacts of development that would be allowed by the HEU without having site- specific development proposals in hand, and broadly considers proposed sites, their environmental setting, and potential impacts that could stem from their development.

Readers will note that the level of detail is different than in a project-specific EIR, which generally considers a single, specific proposal on an individual site. Future discretionary actions that would be facilitated by the HEU’s adoption, such as those related to the development of housing, would be assessed to determine consistency with the analysis provided in this program EIR.

The Draft EIR discussed school facilities for MVLA in Section 4.13, Public Services and Recreation. Consistent with the comment and as described in the Draft EIR, all 15,000 units projected during the HEU planning period would conservatively generate approximately 2,930 students for MVLA schools, using the RHNA allocation percentages for above and below market-rate units (Draft EIR p. 4.13-16).

However, as explained more in Response to Comment A-3-6 below, the capacity increase is also analyzed in the Draft EIR in context of the changes to development capacity in the City proposed as part of the HEU. Of the new units, only a small percentage (approximately 1,250 units in the sites inventory and 2,850 units beyond 2031) would result from changes in City policy, zoning, or Precise Plans, and the

3. Comments and Responses

City of Mountain View Housing Element Update 3-20 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans.

As also discussed further in Response to Comment A-3-2 below, Senate Bill (SB) 50 authorizes school districts to levy developer fees to finance the construction or reconstruction of school facilities and restricts the ability of the City to deny project approvals on the basis that public school facilities are inadequate. Payment of school fees is required by SB 50 for all new residential development projects and is considered full and complete mitigation of any school impacts. As such, the City cannot require additional mitigation for any impacts on school facilities or due to the inadequacy of school facilities. Nonetheless, the City will continue to collaborate with the District on their facility needs and provide information on development and growth trends as well as ensuring school facilities are constructed to serve community needs to the extent allowed by State law.

This comment raises neither new significant environmental issues nor specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088.

A-3-2 Potential impacts of the HEU on schools, including MVLA schools, were discussed in Section 4.13, Public Services and Recreation, of the Draft EIR in accordance with the requirements of CEQA. Importantly, and as discussed in the Draft EIR, CEQA’s treatment of public services impacts is narrowly defined to include only those impacts that would arise from the provision of new or physically altered governmental facilities, the construction of which could cause significant environmental effects (emphasis added). The precise significance criteria used in Section 4.13 of the Draft EIR, and also in CEQA Guidelines Appendix G (XV)(a) asks:

Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: 1) Fire protection; 2) Police protection; 3) Schools; 4) Parks; and 5) Other public facilities?
CEQA regulations and applicable case law on this issue demonstrate the threshold concerns only the environmental effects associated with the provision of new or altered physical public service facilities.
2 School capacities, service ratios, and other
performance objectives are relevant to the analysis only within the context of whether or not new or expanded facilities would be required to meet defined criteria related to

2 CEQA Guidelines Section 15382 restricts the effects that CEQA mitigation addresses to those “significant effects on the environment” which are defined to include “adverse change in any of the physical conditions within the area affected by the project” “An economic or social change by itself shall not be considered a significant effect on the environment.” 14 Cal. Code Regs. §15382.

3. Comments and Responses

City of Mountain View Housing Element Update 3-21 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 those service objectives, and what the environmental effects would be of providing those facilities.

The Draft EIR addressed impacts to public services within this legally-defined context in Section 4.13 of the Draft EIR. The Draft EIR described that the HEU would result in an increase in school-aged children enrollment in MVLA schools which would worsen an existing capacity exceedance. As such, facility updates to increase capacity would also likely be required. However, the new students would be added to the district-wide enrollment of MVLA schools incrementally over time, if and when development occurs, and any expansion of school facilities would be required to undergo environmental review as they are identified. Appropriate measures would be identified and implemented as applicable to reduce any construction-related or operational environmental effects of those facilities.

Compliance with General Plan policies and payment of school impact fees were also acknowledged in the Draft EIR (p. 4.13-16) to reduce the social and economic impacts of the HEU (that is, the non-CEQA impacts of the HEU).

As discussed in Section 4.13.3 of the Draft EIR, the Leroy F. Greene School Facilities Act of 1998, or SB 50, authorizes school districts to levy developer fees to finance the construction or reconstruction of school facilities, and restricts the ability of local agencies to deny project approvals on the basis that public school facilities (classrooms, auditoriums, etc.) are inadequate. School impact fees are collected at the time when building permits are issued. Payment of school fees is required by SB 50 for all new residential development projects and is considered full and complete mitigation of any school impacts. School impact fees are payments to offset capital cost impacts associated with new developments, which result primarily from costs of additional school facilities, related furnishings and equipment, and projected capital maintenance requirements. As such, agencies cannot require additional mitigation for any impacts on school facilities or due to the inadequacy of school facilities.

However, indirect impacts related to school attendance or construction of new facilities must still be considered under CEQA (e.g., indirect impacts on traffic, air quality, noise).

Indirect impacts to schools were considered throughout the Draft EIR. Schools were included as “sensitive receptors” in the air quality section of the Draft EIR (see Draft EIR Section 4.2) and as “noise-sensitive land uses” in the noise section of the Draft EIR (Draft EIR Section 4.11). Impacts related to hazardous materials, substances, or waste in proximity to schools were also analyzed in Section 4.8, Hazards and Hazardous Materials, of the Draft EIR. Section 4.14, Transportation, analyzed impacts relative to conflicts with a program, plan, ordinance or policy addressing the circulation system, including City General Plan Policy MOB-6.1, which promotes Safe Routes to Schools (SRTS) programs for all schools serving the City (Draft EIR p. 4.14-18-19). Additionally, residential-generated VMT includes vehicle travel for school trips, and trip reduction measures are included in Mitigation Measure TRA-1.

3. Comments and Responses

City of Mountain View Housing Element Update 3-22 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Trip reduction measures are intended to apply broadly in the City and include goals to reduce transportation-related impacts to schools.

A-3-3 Section 4.8, Hazards and Hazardous Materials, has been revised to include Mountain View High School and other public schools inadvertently left off of the list of public schools. The Draft EIR on p. 4.8-6 has been corrected consistent with the above (new text is underlined):

Proximity to Schools
The following public schools are located in Mountain View:
• Stevenson Elementary School at 750 San Pierre Way
• Theuerkauf Elementary School at 1625 San Luis Avenue
• Waldorf School of the Peninsula at 180 North Rengstorff Avenue • Landels Elementary School at 115 West Dana Street
• Mariano Castro Elementary School at 500 Toft Street
• St. Joseph Mountain View at 1120 Miramonte Avenue
• Monta Loma Elementary at 460 Thompson Avenue
• Springer Elementary School at 1120 Rose Avenue
• Benjamin Bubb Elementary School at 525 Hans Avenue
• Amy Imai Elementary School (previously Huff) at 253 Martens Avenue • Mountain View High School at 3535 Truman Avenue
• Alta Vista High School at 1325 Bryant Avenue
• Vargas Elementary School at 220 N Whisman Road
• Mistral Elementary School at 505 Escuela Avenue
• Graham Middle School at 1175 Castro Street
• Crittenden Middle School at 1701 Rock Street
A number of private schools including Waldorf School of the Peninsula (180 North Rengstorff Avenue), St. Joseph Mountain View (1120 Miramonte Avenue), St. Francis High School (1885 Miramonte Avenue), German International School of Silicon Valley (310 Easy Street), Mountain View Academy (360 S Shoreline Blvd), St. Stephen Lutheran School (320 Moorpark Way), and Khan Lab School (1200 Villa Street) are also located in the City.

There is also a proposed new school site for the Los Altos School District located at the corner of California Street and Showers Drive.

3. Comments and Responses

City of Mountain View Housing Element Update 3-23 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 The Draft EIR on p. 4.8-22 has also been corrected consistent with the above (new text is underlined; deleted text is shown in strikethrough):

As discussed in Section 4.8.2, Environmental Setting, Proximity to Schools, there are ten 14 public schools and a number of private schools located within Mountain View. The accidental release or spill of hazardous materials transported through the vicinity near schools could expose school children and staff to hazardous materials.

See Final EIR Chapter 4, Errata to the Draft EIR, for the revised language. These editorial changes do not alter the conclusions of the EIR.

A-3-4 The comment references City General Plan policies POS-5.2, POS-5.3, and POS-5.4.

The policies are listed in the Regulatory Setting of Section 4.13, Public Services and Recreation, of the Draft EIR (p. 4.13-9). As discussed in the Draft EIR, the City’s adherence to General Plan Policy POS-5.3 and POS-5.4, described under Section

4.13.3 would reduce the potential social and economic effects to school facilities associated with increased enrollment as a result of population growth (Draft EIR p.

4.13-16).

Pursuant to these polices, and as noted in Section 4.13.3 of the Draft EIR, the City will cooperate with the school districts to:
• ensure that school facilities are constructed to serve community needs to the extent allowed by state law
• collaborate with school districts on their facilities needs and provide information on development and growth trends.

A-3-5 As discussed in Section 4.13, the Draft EIR acknowledges that school year 2020- 2021 MVLA enrollment exceeded the capacity described in the 2020 MVLA Developer Fee Study, and that the addition of potential school-aged children enrollment as a result of the HEU would worsen this existing capacity exceedance (Draft EIR p. 4.13-16). As such, the Draft EIR does not underestimate the capacity impacts on MVLA schools. See also Response to Comment A-3-6 below, which explains the capacity increase in context of the changes to development capacity unit the City proposed as part of the HEU. Of the new units, only a small percentage (approximately 1,250 units in the sites inventory and 2,850 units beyond 2031) would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans.

3. Comments and Responses

City of Mountain View Housing Element Update 3-24 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 A-3-6 As discussed in Response to Comment A-3-2, CEQA regulations and applicable case law on this issue demonstrate the threshold concerns only the environmental effects associated with the provision of new or altered physical public service facilities.3 School capacities, service ratios, and other performance objectives are relevant to the analysis only within the context of whether or not new or expanded facilities would be required to meet defined criteria related to those service objectives, and what the environmental effects would be of providing those facilities.

As discussed in Chapter 3, Project Description, future development on identified sites identified in the HEU would continue to be at the discretion of individual property owners and will be largely dependent on market forces and -- in the case of affordable housing -- available funding and/or other incentives (Draft EIR p. 3-12).

The Draft EIR analyzes the impacts associated with the site inventory to 2031, an increase in approximately 15,000 dwelling units, focused primarily along the commercial corridors and in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing. Of this, approximately 13,600 units are already allowed under the City’s adopted General Plan, zoning, and Precise Plans and the remaining 1,400 units would be created through rezonings and General Plan amendments. The EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately 2,700 units beyond 2031 (Draft EIR p. 3-11). As such, the Draft EIR acknowledges two student generation scenarios: (1) new units enabled by changes in development capacity via rezoning which would conservatively generate approximately 1,279 new students for MVLA schools, assuming the use the MVLA’s below market rate multifamily unit student generation rate for all units; and (2) all 15,000 units projected during the HEU planning period which would conservatively generate approximately 2,930 students. 4 Of the new units, only a small percentage (approximately 1,250 units in the sites inventory and 2,850 units beyond 2031) would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans. As noted above, the 1,279 new students estimated as a result of 4,100 new units enabled by changes in development capacity via rezoning presented the most conservative scenario through the assumption that all of these units would generate students at MVLA’s below market rate multifamily unit student generation rate for all units.

3 CEQA Guidelines Section 15382 restricts the effects that CEQA mitigation addresses to those “significant effects on the environment” which are defined to include “adverse change in any of the physical conditions within the area affected by the project” “An economic or social change by itself shall not be considered a significant effect on the environment.” 14 Cal. Code Regs. §15382.
4 It is noted that per the updates to the HEU and Housing Sites Inventory (described in Chapter 2 of this FEIR), that the sites inventory has been updated and is now 17,779 units. While the number of units in the Housing Sites Inventory did increase somewhat, much of this increase is due to the inclusion of additional units that are under construction in the City and other newly submitted projects. With the removal of some opportunity sites and other development capacity-related changes, a balancing effect occurs. The Draft EIR focused on changes in development potential in the City based on amendments to the General Plan, rezonings, and programs anticipated to be adopted with the proposed HEU which remains 4,100 units. As such, these changes do not materially affect or alter the analysis or conclusions of the Draft EIR

3. Comments and Responses

City of Mountain View Housing Element Update 3-25 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 However, it is noted that multifamily units would likely include a portion of what the MVLA would consider market rate units, resulting in slightly lower student generation rates. For example, assuming 85 percent of the 4,100 units develop as below market rate units, approximately 1,117 students would be anticipated as a result of new units enabled by changes in development capacity via rezoning. 5 Additionally, 2,850 of the units would represent the increase in housing production from rezonings and General Plan Amendments beyond 2031, or outside of the planning period of the HEU (considered more long-term). The 1,250 units enabled by changes in development capacity via rezoning within the HEU planning period (considered more near-term) would generate approximately 390 new students for MLVA schools, conservatively using the MVLA’s below market rate multifamily unit student generation rate for all units.

The Draft EIR described that the HEU would result in an increase in school-aged children enrollment in MVLA schools which would worsen an existing capacity exceedance. As such, facility updates to increase capacity would also likely be required. However, the new students would be added to the district-wide enrollment of MVLA schools incrementally over time, if and when development occurs, and any expansion of school facilities would be required to undergo environmental review as they are identified. Appropriate measures would be identified and implemented as applicable to reduce any construction-related or operational effects of those facilities (Draft EIR p. 4.13-16). As such, facility updates to increase capacity are acknowledged in the Draft EIR as likely to occur. However, due to the incremental nature of development under the proposed HEU and that the District’s most recent long-term Facilities Master Plan
6 does not identify the need for a new school site
given its forecast peak enrollment of 5,023 students in school year 2021-22, it would be speculative to assume where a new school site may be needed to accurately depict potential environmental impacts resulting from a new school site.

As discussed in Response to Comment A-3-2 above, indirect impacts to schools, including transportation, were considered throughout the Draft EIR. See also Responses to Comments A-3-11 through A-3-13 for specific responses to transportation-related comments raised below.

Regardless, any additional residential development in the City would proceed with the full expectation of the District’s involvement in the development process in a manner that meets the needs of the District and the students it serves.

A-3-7 The commenter’s assertion that SB 50 fees are financially inadequate is an economic consideration which is outside of CEQA’s purview. As discussed in Response to

5 As described on Draft EIR p. 4.13-16, the MVLA uses a student generation rate of 0.047 9-12 grade students for market rate multifamily residential units and a student generation rate of 0.312 9-12 grade students for below market rate multifamily residential units based on the Mountain View Los Altos Union High School District Response to the Notice of Preparation for the EIR, March 8, 2022. 6 MLVA, 2018. Mountain View Los Altos High School District Master Plan, March 3, 2018. Available at:
https://www.mvla.net/documents/About-MVLA/District-Plans--Reports/MVLA-Facilities-Master-Plan-Final.pdf.

3. Comments and Responses

City of Mountain View Housing Element Update 3-26 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Comment A-3-2 above, SB 50 authorizes school districts to levy developer fees to finance the construction or reconstruction of school facilities and restricts the ability of the City to deny project approvals on the basis that public school facilities are inadequate. Payment of school fees is required by SB 50 for all new residential development projects and is considered full and complete mitigation of any school impacts. As such, the City cannot require additional mitigation for any impacts on school facilities or due to the inadequacy of school facilities. The City will continue to collaborate with the District on their facility needs and provide information on development and growth trends as well as ensuring school facilities are constructed to serve community needs to the extent allowed by State law.

A-3-8 See Response to Comment A-3-2 regarding indirect impacts related to schools that were analyzed in the Draft EIR, including those related to air quality, noise, transportation, and hazards and hazardous materials. See also Responses to Comments A-3-11 through A-3-13 for specific responses to transportation-related comments raised below. Additionally, as discussed in Section 4.2, Air Quality, the air quality analysis prepared in the Draft EIR related to criteria air pollutants was a plan- level analysis, consistent with Bay Area Air Quality Management District (BAAQMD) recommendations. As such, the significance of the impact of criteria air pollutant emissions generated were based on consistency with regional air quality planning, including an evaluation of population growth and growth in VMT. Any resulting indirect impacts on schools would therefore be subsumed in this analysis. Additionally, project applicants proposing projects that exceed BAAQMD screening levels would be required to prepare a project-level criteria air pollutant assessment of construction and operational emissions at the time the project is proposed. Regarding utilities, any increased demand for utilities service related to schools would be considered incremental and would not rise to a level where a service provider could not provide service or where new utility facilities would be constructed that would result in significant environmental effects due to construction or relocation.

Regarding the statement that the Draft EIR should be revised and recirculated, while information has been added to the Draft EIR in response to comments and as City- initiated updates (see Chapter 4 of this document), no significant new information (e.g., as defined in CEQA Guidelines Section 15088.5 as information leading to identification of a new significant impact or a substantial increase in the severity of an impact) has been identified since publication of the Draft EIR and, consequently, there is no basis for the District’s request that the Draft EIR be recirculated.

A-3-9 See Response to Comment A-3-4 regarding City policies that require consultation with school districts. As noted in Response to Comment A-3-4, pursuant to these polices, and as noted in Section 4.13.3 of the Draft EIR, the City will continue to cooperate with the school districts to: (1) ensure that school facilities are constructed to serve community needs to the extent allowed by state law; and (2) collaborate with school districts on their facilities needs and provide information on development and growth trends. Notice of the proposed HEU and a 45-day comment period was

3. Comments and Responses

City of Mountain View Housing Element Update 3-27 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 provided pursuant to Government Code §65352 to the MVLA. It is the City’s continued expectation that any additional residential development in the City would proceed in partnership with MVLA.

A-3-10 Identification of a school site is not part of the purview of this EIR. A school district through its school facilities planning process may identify a site, and at such point, the City (pursuant to the General Plan policies listed in Response to Comment A-3-4 and discussed in the Draft EIR under Section 4.13.3) will continue to collaborate with the schools district on their facility needs and provide information on development and growth trends as well as ensuring school facilities are constructed to serve community needs to the extent allowed by state law. Furthermore, the referenced “Shenandoah Property” is located outside of city limits and is not under control of the City, as it is owned by the United States Department of the Army. As such, it is not appropriate for the City to identify this site as a potential school site in the Draft EIR.

MVLA would be expected to lead the siting of any new school location and the City would collaborate with the District to achieve its facilities goals, as outlined in the City’s General Plan policies. If and when a proposal is formalized to develop the site (or any other site) for the District’s use, appropriate environmental review would be required to determine the environmental effects of the undertaking, in compliance with CEQA and other applicable regulations.

A-3-11 Traffic congestion or measures of vehicular delay are not an environmental impact under CEQA per State CEQA Guidelines Section 15064.3. As discussed in Response to Comment A-3-2, Draft EIR Section 4.14, Transportation, analyzed impacts relative to conflicts with a program, plan, ordinance or policy addressing the circulation system, including City General Plan Policy MOB-6.1, which promotes Safe Routes to Schools programs for all schools serving the City. Implementation of the HEU would be subject to and implement General Plan policies applicable to transit, bicycle, and pedestrian facilities and service, and development projects under the HEU would be subject to all applicable City guidelines, standards, and specifications related to transit, bicycle, or pedestrian facilities (Draft EIR p. 4.14-18- 19).

As also discussed in Response to Comment A-3-2 and Response to Comment A-3-6, performance objectives for schools are relevant to the analysis only within the context of whether or not new or expanded facilities would be required to meet defined criteria related to those service objectives, and what the environmental effects would be of providing those facilities.

Regarding the suggested mitigation measure, the City’s Standard Conditions of Approval (Transportation Impact Fee) require that project applicants pay the City’s Transportation Impact Fee for the development prior to the issuance of any building permits and prior to approval of the parcel or final map. The City’s Transportation Impact Fee (City Code Chapter 43) is based on the City of Mountain View

3. Comments and Responses

City of Mountain View Housing Element Update 3-28 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Multimodal Improvement Plan Traffic Impact Fee Nexus Study (2018) which established the required nexus between anticipated future development in the City and the need for certain improvements to the local transportation facilities.

Transportation improvements are intended to provide adequate transportation infrastructure that is needed to protect the health, safety, and general welfare of the citizens to facilitate access to jobs, homes, schools, goods, and services (see Section

43.3).

Regarding the request for a specific transportation fee “to mitigate traffic impacts to the District’s schools”, the City does not have an adopted fee for this issue, nor is it aware of any precedent for such a fee. Establishment of a fee would require identification of an impact, a nexus study, and determination of proportionality.

Due to the nature of the proposed Project and lack of detail on specific projects that could be developed under the HEU, the extent of any potentially necessary improvements is not known, and as such it is unclear whether such a fee would be legal under the Mitigation Fee Act (Gov’t Code §§ 66000 – 66025) and Assembly Bill 602 (2021).

See also Response to Comment A-3-13 regarding specific transportation analysis required for development projects during the City’s entitlement process.

A-3-12 As discussed in Response to Comment A-3-11, development projects under the HEU would be subject to all applicable City guidelines, standards, and specifications related to transit, bicycle, or pedestrian facilities, including General Plan Policy MOB-6.1, and Policy MOB 1.6, which provides traffic calming, especially in neighborhoods and around schools, parks and gathering places. Traffic congestion or measures of vehicular delay are not an environmental impact under CEQA per State CEQA Guidelines Section 15064.3.

A-3-13 See Responses to Comments A-3-11 and A-3-12. Development projects proposed under the HEU that generate at least 20 net new peak-hour trips (or those within a Precise Plan area) would require completion of a Multi-modal Transportation Analysis (MTA) during the entitlement process. The MTA would ensure that the proposed development conforms with City policies (including traffic calming, neighborhood intrusion, and enhancing publicly accessible bicycle, pedestrian, and transit connections), that adequate multimodal site access and circulation are provided to local schools serving the proposed residential projects, appropriate fair- share fees are identified, and that operational improvements support pedestrian, bicycle, and transit quality of service.

Additionally, the City has an ongoing commitment to fund the Safe Routes To School (STRS) program and have been working with the school districts to ensure that students receive safety training. The City's SRTS program also include ongoing infrastructure planning and improvement in the vicinity of schools, including walking audits. Proposed projects will also comply with the City’s Comprehensive Modal

3. Comments and Responses

City of Mountain View Housing Element Update 3-29 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Plan, AccessMV, to ensure proper analysis of the potential impacts on the bicycle level of traffic stress, pedestrian quality of service, potential transit demand, and vehicle conditions under existing and planned development scenarios. Additionally, the City’s commitment to ending traffic fatalities and serious injuries on Mountain View roadways through Vision Zero is reflected in the STRS program, the Local Road Safety Plan, and forthcoming Active Transportation Plan (ATP)—all of which focus on delivering roadway improvements and safety counter-measures along the Safe Routes to School network.

A-3-14 This is a general comment that includes concluding remarks, and reiterates comments made above. As a result, no specific response is given here. Pursuant to the impacts related to the scope of the EIR, these have been adequately analyzed.

Regarding the statement that the Draft EIR should be revised and recirculated, while information has been added to the Draft EIR in response to comments and as City- initiated updates (see Chapter 4 of this document), no significant new information (e.g., as defined in CEQA Guidelines Section 15088.5 as information leading to identification of a new significant impact or a substantial increase in the severity of an impact) has been identified since publication of the Draft EIR and, consequently, there is no basis for the District’s request that the Draft EIR be recirculated.

The City will continue to collaborate with the District on their facility needs and provide information on development and growth trends as well as ensuring school facilities are constructed to serve community needs to the extent allowed by State law, pursuant to the General Plan policies discussed above and in the Draft EIR under Section 4.13.3.

From: Kevin Thai <[email protected]>
Sent: Tuesday, September 6, 2022 3:28 PM
To: Yau, Ellen <[email protected]>
Subject: RE: DEIR for the City of Mountain View's Housing Element Update Project

CAUTION: EXTERNAL EMAIL - Ensure you trust this email before clicking on any links or attachments.

Hi Ellen,

Here is Valley Water’s comment:

As noted in the Water Supply Assessment and draft EIR, there is the potential for water shortages in multiple dry years. Water conservation is an important component of the county’s future water supply and the draft EIR lists a number of measures the City requires of new development; Valley Water appreciates Mountain View’s commitment to water conservation. To meet future needs as allowed in the proposed Housing Element, additional water demand management and conservation measures will need to be implemented. Consistent with General Plan Policy INC 5.2: Citywide water conservation, Valley Water suggests that all new multifamily development be required to install separate submeters to each unit to encourage efficient water use. Studies have shown that adding submeters can reduce water use 15 to 30 percent.

Thanks,
Kevin

KEVIN THAI, CFM

ASSOCIATE ENGINEER - CIVIL
Community Projects Review Unit
Tel. (408) 630-3157 / CPRU Hotline: (408) 630-2650

Santa Clara Valley Water District is now known as:

Clean Water • Healthy Environment • Flood Protection

5750 Almaden Expressway, San Jose CA 95118
www.valleywater.org

3. Comments and Responses

City of Mountain View Housing Element Update 3-31 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter A-4 Response: Valley Water, September 6, 2022

A-4-1 As discussed in Section 4.15, Utilities and Service Systems, of the Draft EIR, projects developed as a result of the HEU would be required to comply with Part 11 of the Title 24 Building Energy Efficiency Standards, referred to as the California Green Building Standards Code (CALGreen Code). The supplement to the 2019 CALGreen Code (effective July 1, 2021) requires that submeters be installed to measure water usage of individual rental dwelling units for multifamily and dwelling units in mixed- use residential/commercial buildings. The comment does not raise any new environmental issues that have not already been adequately described and evaluated in the Draft EIR, and no further response is required.

July 31, 2022
Ellen Yau, Senior PlannerCity of Mountain View, Community Development DepartmentP.O. Box 7540Mountain View, CA 94039 Re: Comments on Draft Environmental Impact Report for Mountain View’sHousing Element Update (SCH #2022020129) Dear Senior Planner Yau,
Mountain View YIMBY, an organization with members who live, work, and/or do business inthe city, is submitting these comments on the Draft Environmental Impact Report (DEIR) forMountain View’s Housing Element Update. We hope our comments will help the CommunityDevelopment Department craft a final EIR that supports a robust, fully compliant housingelement, and that serves as the foundation for tiered, efficient environmental review ofsubsequent rezonings and housing approvals.

1. The EIR should analyze alternatives that would fully accommodate the city’sRHNA Mountain View’s RHNA for the 2023-2030 planning period (11,135 units) translates intoroughly 1,400 units/year, or 1.6x the current rate of production contemplated by the NoProject Alternative (derived from 5th Cycle APRs).

The Housing Sites Inventory concludes that rezoning for merely 1,400 above-baseline units by2030—units that would not be built if the regulatory status quo remained in place—will suffice.Yet as thecomment letterfrom Mountain View YIMBYdated July 13 shows, ahistorically-grounded assessment of pipeline capacity suggests that the city should aim torezone for about4,900 above-baseline units by 2030.

It is imperative that the final EIR analyze alternatives that provide additional rezoning scenarios.Without this, there is a real risk that the housing element update will go off the rails, as follows:
●Train Wreck #1. In this scenario, HCD would rejectthe pipeline/status-quo capacityanalysis of the current housing element draft, and require the city to commit to a muchmore ambitious rezoning plan. The city would find itself unable to complete the requisiteenvironmental review for a compliant plan prior to the deadline for housing elementadoption. The city would thus fall out of compliance, resulting in loss of affordablehousing funds and exposure to thebuilder’s remedy. 1 ●Train Wreck #2. In this scenario, HCD would provisionally accept the city’spipeline/status-quo capacity analysis, but require the housing element to include aprogram for mid-cycle rezoning in case the pipeline’s yield falls short of projections.(HCD has imposed similar requirements on other cities that made sunny forecasts ofADU production.) Then, in this scenario, the pipeline yield does fall short, but the city isunable to pull off a timely mid-cycle rezoning because the housing element EIR didn’tlay the groundwork for it. HCD responds by decertifying the housing element, cutting offaffordable housing funds and exposing the city to the builder’s remedy.

2. The EIR should acknowledge the legal effect of a housing element The Housing Accountability Act generally prohibits cities from denying or “rendering infeasible”an affordable housing project, as defined, if the project “is proposed on a site that is identifiedas suitable … for very low, low-, or moderate-income households in the jurisdiction’s housingelement, and [is]consistent with the density specifiedin the housing element, even though it isinconsistent with both the jurisdiction’s zoning ordinance and general plan land usedesignation.” (Gov Code 65589.5(d)(5)(A) (emphasisadded).) The upshot is that while Mountain View would still have discretion after adopting its housingelement to enact a different rezoning plan (with conforming housing-element amendments),the city’sfailureto complete a legally adequaterezoning would not leave the zoning statusquo in place. Rather, the city would be legally compelled to waive zoning and other forms oflocal land-use control that prevent the development of inventory sites at “post-rezoning”densities contemplated by the housing element.

The EIR should forthrightly acknowledge the legal effect of the housing element in order tofully disclose the consequences of the housing element’s adoption.

3. The analysis of the No Project Alternative should discuss environmentalimpacts of noncompliance with the Housing Element Law Under 5.4.1 (Land Use and Planning Impacts of the No Project Alternative), the DEIR states“The land use and zoning designations currently in place would continue under the land usedecisions and development parameters that currently exist in the City” (5-10). This is false. Ifthe city does not adopt a substantially compliant housing element, it will forfeit authority to denyor “render infeasible” 20% low-income and 100% moderate-income projects on the basis of thecity’s zoning code and general plan land-use designations. (Gov Code 65589.5(d)(5);Elmendorf,“A Primer on California's ‘Builder's Remedy’ for Housing-Element Noncompliance”(UCLA Lewis Center for Regional Policy Studies, April 2022)) There is also the possibility of acourt order suspending the city’s authority to issue certain classes of building permits (GovCode 65755(a)), and, eventually, a court-led rewriting of the city’s housing element (Gov Code65585(l)).

Inherently, it is very hard to predict how these consequences of noncompliance would affectthe amount, type and distribution of housing development in Mountain View. The EIR thereforeneedn’t address this topic in great detail. But if the EIR is to serve its function as an 2 informational document, it should provide the responsible decision makers with at least arudimentary outline of the potential environmental effects of noncompliance.

4. The final EIR should discuss statewide and regional environmental benefits ofhigher growth alternatives The DEIR asserts that the Reduced Sites Alternative is the “environmentally superioralternative” because “this lesser-intensity development would presumably emit fewer overallemissions” than the other alternatives (5-17). This statement about the environmental effectsof curtailing development in Mountain View may be formally true within the artificial world thatCEQA has created, but it bears little resemblance to the real world.

Increasing the size of Mountain View’s housing stock is an unequivocal environmental (andeconomic) win from national, statewide, and regional perspectives. The more people whosepreference to live in Mountain View can be accommodated, the fewer people will end up livingin places where they produce more CO2, displace wildlife, fill wetlands, bulldoze scenic vistas,disrupt the management of wildfire, and congest highways. CEQA may be blind to theenvironmental impacts of people whom Mountain View would fence out by restricting housingdevelopment, but CEQA’s elision does not launch them off Planet Earth. If there’s a feasiblealternative that would allow them to live in Mountain View—an already urbanized area in a mildclimate with many job opportunities—that alternative is almost surely the actual environmentallysuperior alternative.

It would be a welcome change for the final EIR to honor CEQA’s purpose of “inform[ing] thegovernment and public about a proposed activity's potential environmental impacts” (CaliforniaBuilding Industry Association v. Bay Area Air Quality Management District (2015)62 Cal. 4th369, 382) by addressing thesubstantial environmentalbenefits, not just the localdownsides, of higher growth alternatives.

Thank you for considering these comments.

Regards,
David WatsonOn behalf of Mountain View YIMBY
3 3. Comments and Responses

City of Mountain View Housing Element Update 3-35 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter O-1 Response: Mountain View YIMBY, July 31, 2022

O-1-1 This is a general comment that includes introductory remarks and serves to introduce the more specific comments that are responded to in detail below. This comment raises neither significant environmental issues nor specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088.

O-1-2 As noted on p. 5-1 of the Draft EIR, Chapter 5, Alternatives to the Project, is provided to “describe and evaluate alternatives to the Project” with the primary purpose of providing “decision-makers and the public with a qualitative review of alternatives to the Project that eliminate or substantially reduce any identified adverse environmental impacts while, at the same time, attaining most of the basic objectives of the Project.” Section 15126.6(a) states that “an EIR need not consider every conceivable alternative to a project. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation.” Section 15126.6(f) describes a “rule of reason,” stating that an EIR “set forth only those alternatives necessary to permit a reasoned choice,” and “the EIR need examine in detail only the ones that the Lead Agency determines could feasibly attain most of the basic objectives of the project.” An EIR is not required to consider alternatives to a component of a project, but only alternatives to the project as a whole. (See State CEQA Guidelines Section 15126.6(a); California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 993.) Variations of the same alternative are also not required; “what is required is the production of information sufficient to permit a reasonable choice of alternatives so far as environmental aspects are concerned.” (Residents Ad Hoc Stadium Comm. v. Board of Trustees (1979) 89 Cal.App.3d 274, 286; see also Cherry Valley Pass Acres & Neighbors v. City of Beaumont (2010) 190 Cal.App.4th 316, 355-56 [rejecting need to analyze every variation on the alternative continuum for housing project].) Comments regarding the merits of the Project, including requested variations of housing and rezoning scenarios, do not raise a significant environmental issue or specific question about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

O-1-3 This comment does not raise a significant environmental issue or specific questions about the analyses or information in the Draft EIR that would require response pursuant to State CEQA Guidelines Section 15088. The comment will be included as a part of the record and made available to the decision makers prior to a final decision on the proposed HEU.

3. Comments and Responses

City of Mountain View Housing Element Update 3-36 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 O-1-4 Chapter 5, Alternatives to the Project, identifies the consequences of not adopting a housing element that is not compliant with State law. This alternative is analyzed consistent with Section 15126.6(e) of the CEQA Guidelines, which state that the No Project Alternative must include the assumption that conditions at the time the NOP of an EIR was circulated for public review would not be changed because the Project would not be implemented, as well as the events or actions that would reasonably be expected to occur in the foreseeable future if the Project were not approved.

The Draft EIR described that the No Project Alternative would also introduce a new significant and unavoidable impact related to land use and planning. The No Project Alternative would not meet any of the objectives of the HEU, nor is it legally feasible to implement. The No Project Alternative would not provide housing to fulfill the requirements of State law or meet the City’s RHNA requirements, which result in a significant and unavoidable land use and planning impact, as compared to the less- than-significant impacts associated with the proposed HEU and the Reduced Sites Alternative (Draft EIR pp. 5-18 – 5-19).

Additionally, it is impossible to currently predict whether any applications for development under the “Builders’ Remedy” would be submitted, where such development would be proposed, how many applications there would be, and the development potential associated with any proposal. Therefore, the No Project Alternative need not analyze such speculative outcomes.

O-1-5 See Response to Comment O-1-2 regarding the requirements and purpose of the analysis of alternatives in the Draft EIR. As stated in CEQA Guidelines Section 15126.6, the principal purpose of an EIR’s analysis of alternatives is to describe and consider a range of reasonable alternatives to the project that would avoid or substantially lessen any of the identified significant effects of the project.

Alternatives with higher growth assumptions would be unlikely to avoid or substantially lessen any of the identified significant effects of the Project on the environment, and were therefore not considered.

September 5, 2022
Ellen YauCommunity Development Department, First Floor500 Castro Street, PO Box 7540, Mountain View, CA [email protected] Re:City of Mountain View Housing Element Update DraftEIR, SCH# 2022020129 Dear Ms. Yau
The Santa Clara Valley Audubon Society (SCVAS) is oneof thelargest National AudubonSocietychapters inCalifornia.Ourmissionistopromotetheenjoyment,understanding,andprotectionofbirdsandotherwildlifeby engaging people of all ages in birding, education, and conservation. We appreciate the opportunity tocomment on the Draft Environmental Impact report (DEIR) for theCityof MountainViewHousingElementUpdate. GreenspacesMV is a community group in Mountain View, CA striving for healthy communitiesthriving with urban tree canopy, nature, and native biodiversity.

Our organizations’ interest in this project focuses on potential impacts to biological resources. We areespeciallyinterestedinNorthBayshore, where(basedonthe2017NorthBayshorePrecisePlan)theHousingElement Updateallows for upto9,850newmulti-familyresidentialunitsand3.6millionsquarefeetofofficeand commercial development.

We believe that the North Bayshore Precise Plan requirements and development standards should beupdated toreflect newscientific knowledgeregardinglighting. Thenear-extirpation conditionof burrowingowlpopulationsinourregionisalsoofconcern.NorthBayshoreandtheadjacentShorelineParksarecriticallyimportant tomanyspecies of birds, andof great importancetothepublic.Birdwatchersoftendocumentthepresence and abundance of birds on eBird 1 .
1 Launched in 2002, eBird is a citizen science-based,national database administered by the Cornell Lab ofOrnithology and the National Audubon Society. eBird provides rich data sources for basic information on birdabundance and distribution at a variety of spatial and temporal scales. Reports to eBird help deepen ourunderstanding of local, regional and international trends in bird populations and bird migration. For example:● Charleston Retention Basin: http://ebird.org/ebird/hotspot/L284760● Charleston Slough/Coast Casey Forebay: http://ebird.org/ebird/hotspot/L730351● Shoreline Park: http://ebird.org/ebird/hotspot/L271482● Shoreline Lake: http://ebird.org/ebird/hotspot/L594012

We submit the following comments:

1. Artificial Light at NightSince the adoption of the North Bayshore Precise Plan, newscientific studies haverevealedthepervasiveandharmful impacts of most availableLEDlight fixtures onecosystems andonalllivingorganisms: plants, insects, mammals, birds and more. This is because life on Earthevolvedwithlight as aprimarycueforbiologicalfunctionandecologicalwebs.Thelengthofdaylighthours,andchanges inthelengthof daylighthours,bothcontrollifecyclesandbehaviorinalllivingorganisms.This pervasive influence of light is augmented by the attraction or aversionresponses tolight inmany animals, where light canattract themtoharmful situations or deprives themfromhabitatsand blocks habitat connectivity, increasing fragmentation. Because of the inherent control ofhormonal pathways by light, exposure to outdoor light at night alsoexacerbates illness (cancer,obesity, mental health) in humans 2 .

The International Dark Sky Association State of the Science 2022 report 3 and theattached2021compilation by the Sierra Club both includemanyreferences toscientific studies publishedsince2020 that highlight the injury to ecosystems, species, and human health associated with brightlighting, especiallyinthebluelightofthespectrum.Scientistsnowrecommendthatlightingshouldbe always kept to the minimumbrightness andaCorrelatedColor Temperatureof nomorethan2400 Kelvin. The Housing Element should include new standards that reflect theserecommendations.

TheadoptedNorthBayshorePrecisePlanshouldbeamendedsothat, atleast inNorthBayshore,theHousingElement can1) eliminateminimumlightingrequirements; 2) requirelightingtobeofminimal feasible brightness, and trespass of no more than 0.1 food candle; 3) require lightingfixtures of 2400 Kelvin or less for all outdoor lighting. In addition, all outdoor lighting fixturesshould be capable of accepting 7-pin controls that can enable use of dimmers, timers, motionsensors, and networking. Lighting should be actively controlled through means suchas dimmersand motion-sensing switches so as to reduceilluminances or extinguishlightingaltogether whenthe light is not needed.

2. Canopy, Trees and the Urban ForestTrees and the urban forest provide multiple environmental benefits to the city, includingreducing heat-island effects, absorbing CO2 and harmful air-polluting particulates, providingshade and beauty, and contributing positively to health and cognition 4 . The City of Mountain
4 Urban trees and human health (a scoping review):https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7345658/ 3 https://www.darksky.org/wp-content/uploads/2022/06/IDA-State-of-the-Science-2022-EN.pdf 2 For example, Outdoor light at night, overweight,and obesity in school-aged children and adolescents,https://www.sciencedirect.com/science/article/abs/pii/S0269749122005206 View, and the DEIR, allowdevelopment projects to pay fees or donatetrees whenthereis nosuitable on-site locationfor replacement trees. Theoverall loss of trees andcanopytohousingdevelopment, however, has been highly noticeable and controversial in Mountain View.

Please analyze a realistic forecast of the impact of the project on the city’s urban canopy,including the identification of places wherereplacement trees canbeplantedas mitigationfortheimpact. If thecumulativeloss of trees andcanopycannot beadequatelyreplaced(duetoashortageof appropriateplantingsites), orthecanopycannotbereplacedinareasonableperiodof time, then the loss of trees and canopy should be considered a significant, unavoidablebiological impact.

3. Burrowing OwlsShorelinePark’sBurrowingOwlbreedingpopulationhasdeclinedsignificantlysincetheadoptionof the North Bayshore Precise Plan. In 2017, the focus was still on conservation of thepopulation, whereas the current focus is on recovery of the population. Population declineispartiallyattributedtoencroachment anddisturbancecausedbyhumans (andoften,theirdogs)that use Shoreline grasslands for recreation. Disruptive behaviors occur despite signage andday-time ranger patrol. The only mitigation that is currently successful is fencing.Withtheincreaseinpopulationexpectedin NorthBayshore,theencroachmentcanbeexpectedduringthedayandat night. Weaskfor amitigationmeasurethat will install fencingtoextendexisting fences and allow the park to close and become inaccessible after closing hours, seeFigure 1 for recommended fencing below..

Effects of nature on cognitive functioning, emotional well-being, and other dimensions of mental health:https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6656547/ Effects of trees on academic success:https://aslathedirt.files.wordpress.com/2016/01/li-sullivan.pdf Nature conservancy benefits of urban trees:https://www.nature.org/content/dam/tnc/nature/en/documents/Public_Health_Benefits_Urban_Trees_FINAL.pdf Urban forests and climate change (discusses benefits of urban forests to physical and mental health):https://www.fs.usda.gov/ccrc/topics/urban-forestsand Effects of vegetation on reducing frustration levels for drivers: https://journals.sagepub.com/doi/abs/10.1177/0013916503256267 Figure 1: recommended fencing for Shoreline park (existing fencing in blue, first priority foradditional fencing in red, second priority for additional fencing in yellow) Thank you for the opportunity to provide comments,
Shani KleinhausEnvironmental AdvocateSanta Clara VAlley Audubon [email protected] Bruce EnglandGreenSpacesMVgreenspacesmv.org

1 Resources and References that helped inform
Sierra Club’s Light Pollution Policy Update
(Last updated 3/7/2021)

Over 70 resources and references (including websites, articles, publications, and reports) were reviewed during Sierra Club’s March 2021 update to its light pollution national policy. The list is only provided to document resources used during policy development. Inclusion of any given resource in this list should not be construed as an endorsement by Sierra Club. The main resources consulted are listed below, organized by a relevant category. Several resources cover multiple issues, but each is only listed once.

Sierra Club Advocacy

Sierra Club AddUp Petition to City Mayors: Protect the Night Against Light Pollution (started in Feb 2018) https://addup.sierraclub.org/campaigns/protect-the-night

Sierra Club Articles

On the Hunt for Stars: In Search of a Truly Dark Night Sky. Heather Smith, Feb 27, 2018. SIERRA magazine, March/April 2018 edition. https://www.sierraclub.org/sierra/2018-2-march-april/feature/hunt-for-stars-dark-skies-preserves-and-parks

Reclaiming the Night. SIERRA magazine. Katie O'Reilly. https://www.sierraclub.org/sierra/slideshow/reclaiming-night

General Educational Resources

National Park Service Night Skies, www.nps.gov/subjects/nightskies

Light pollution - a global discussion. Schulte-Römer, N., Dannemann, E., Meier, J. (2018): Helmholtz Centre for Environmental Research - UFZ, Leipzig, 248 pp.
http://www.lightpollutiondiscussion.net

The Right to Dark Skies, 2016, United Nations Educational, Scientific and Cultural Organization (UNESCO Mexico) https://unesdoc.unesco.org/ark:/48223/pf0000246131

Our nights are getting brighter, and Earth is paying the price, by Nadia Drake, National Geographic, published April 3, 2019 https://www.nationalgeographic.com/science/2019/04/nights-are-getting-brighter-earth-paying-the-price-light-pollution-dark- skies/

Treat artificial light like other forms of pollution, say scientists. Jonathan Watts, The Guardian. Nov 2, 2020. https://www.theguardian.com/environment/2020/nov/02/treat-artificial-light-form-pollution-environment Excerpt: “What stands out is how pervasive the effects are. The effects were found everywhere – microbes, invertebrates, animals and plants,” said the lead author, Kevin Gaston, a professor at the university’s Environment and Sustainability Insti tute. “We need to start thinking about lighting in the way we think of other big systemic pressures like climate change.”

Light pollution – extent, effects and approaches. TAB-Fokus no. 25, Jun 2020, Office of Technology Assessment at the German Bundestag. Christoph Schröter-Schlaack, et al.
http://www.tab-beim-bundestag.de/en/news/20200828.html
Summary: In addition to the intended effects, the increasing use of artificial outdoor lighting also entails a number of unde sirable side effects referred to as light pollution. Artificial lighting can disturb the circadian rhythms of humans and animals, whi ch are controlled by the change of day and night, and is suspected of being involved in the development of various diseases. Moreo ver, the increasing illumination of the night influences the natural behaviour of animals. Besides habitat changes, the consequenc es are ranging from changes in hunting or reproductive behaviour to the deadly attraction effect of light sources, e. g. for i nsects.

However, the longterm consequences of these changes for entire populations, communities or landscapes are still poorly understood. Options for reducing light pollution exist both technologically and in terms of regulation and approval of lighti ng installations.

Light Pollution Is Taking Away Our Night Skies. Here’s Why That Matters. 11/13/2019. HuffPost. By Kyla Mandel https://www.huffpost.com/entry/city-light-pollution-night-sky-star-protection_n_5dc9d1fee4b00927b2381233 Some cities and states are trying to protect our night sky “for the health and wellbeing for all living things.”

2 Light Pollution Trends

Artificially lit surface of Earth at night increasing in radiance and extent, by Christopher C. M. Kyba, Theres Kuester, Alejandro Sánchez de Miguel, Kimberly Baugh, Andreas Jechow, Franz Hölker, Jonathan Bennie, Christopher D. Elvidge, Kevin J. Gaston, and Luis Guanter. Science Advances 22 Nov 2017: Vol. 3, no. 11, e1701528, DOI: 10.1126/sciadv.1701528 http://advances.sciencemag.org/content/3/11/e1701528
Abstract: A central aim of the “lighting revolution” (the transition to solid-state lighting technology) is decreased energy consumption. This could be undermined by a rebound effect of increased use in response to lowered cost of light. We use the first-ever calibrated satellite radiometer designed for night lights to show that from 2012 to 2016, Earth’s artificially lit outdoor area grew by 2.2% per year, with a total radiance growth of 1.8% per year. Continuously lit areas brightened at a rate of 2.2 % per year. Large differences in national growth rates were observed, with lighting remaining stable or decreasing in only a few countries. These data are not consistent with global scale energy reductions but rather indicate increased light pollution, w ith corresponding negative consequences for flora, fauna, and human well-being.

The new world atlas of artificial night sky brightness. Falchi, F., Cinzano, P., Duriscoe, D., Kyba, C.C.M., Elvidge, C.D., Baugh, K., Portnow, B.A., Rybnikova, N.A., & Furgoni, R. (2016). Science Advances, 2:e1600377. https://advances.sciencemag.org/content/2/6/e1600377
Abstract: Artificial lights raise night sky luminance, creating the most visible effect of light pollution —artificial skyglow. Despite the increasing interest among scientists in fields such as ecology, astronomy, health care, and land -use planning, light pollution lacks a current quantification of its magnitude on a global scale. To overcome this, we present the world atlas of artificial sky luminance, computed with our light pollution propagation software using new high -resolution satellite data and new precision sky brightness measurements. This atlas shows that more than 80% of the world and more than 99% of the U.S. and European populations live under light-polluted skies. The Milky Way is hidden from more than one-third of humanity, including 60% of Europeans and nearly 80% of North Americans. Moreover, 23% of the world’s land surfaces between 75°N and 60°S, 88% of Europe, and almost half of the United States experience light-polluted nights.

Light pollution in USA and Europe: The good, the bad and the ugly. F. Falchi, R. Furgoni, T.A. Gallaway, N.A. Rybnikova, B.A. Portnov, K. Baugh, P. Cinzano, C.D. Elvidge, Elsevier Journal of Environmental Ma nagement, Volume 248, 2019, 109227, 15 October 2019
http://www.sciencedirect.com/science/article/pii/S0301479719309296 Abstract: Light pollution is a worldwide problem that has a range of adverse effects on human health and natural ecosystems.

Using data from the New World Atlas of Artificial Night Sky Brightness, VIIRS -recorded radiance and Gross Domestic Product (GDP) data, we compared light pollution levels, and the light flux to the population size and GDP at the State and County levels in the USA and at Regional (NUTS2) and Province (NUTS3) levels in Europe. We found 6800 -fold differences between the most and least polluted regions in Europe, 120-fold differences in their light flux per capita, and 267-fold differences in flux per GDP unit. Yet, we found even greater differences between US counties: 200,000 -fold differences in sky pollution, 16,000-fold differences in light flux per capita, and 40,000-fold differences in light flux per GDP unit. These findings may inform policy- makers, helping to reduce energy waste and adverse environmental, cultural and health consequences associated with light pollution.

Global Trends in Exposure to Light Pollution in Natural Terrestrial Ecosystems. Bennie, J.; Duffy, J.P.; Davies, T.W.; Correa- Cano, M.E.; Gaston, K.J. Remote Sens. 2015, 7, 2715-2730. https://www.mdpi.com/2072-4292/7/3/2715
Abstract: The rapid growth in electric light usage across the globe has led to increasing presence of artificial light in natural and semi-natural ecosystems at night. This occurs both due to direct illumination and skyglow - scattered light in the atmosphere.

There is increasing concern about the effects of artificial light on biological processes, biodiversity and the functioning of ecosystems. We combine intercalibrated Defense Meteorological Satellite Program’s Operational Linescan System (DMSP/OLS) images of stable night-time lights for the period 1992 to 2012 with a remotely sensed landcover product (GLC2000) to assess recent changes in exposure to artificial light at night in 43 global ecosystem types. We find that Mediterranean -climate ecosystems have experienced the greatest increases in exposure, followed by temperate ecosystems. Boreal, Arctic and montane systems experienced the lowest increases. In tropical and subtropical regions, the greatest increases are in mangroves and subtropical needleleaf and mixed forests, and in arid regions increases are mainly in forest and agricultural areas. The global ecosystems experiencing the greatest increase in exposure to artificial light are already localized and fragmented, and often of particular conservation importance due to high levels of diversity, endemism and rarity. Night time remote sensing can play a key role in identifying the extent to which natural ecosystems are exposed to light pollution.

Direct measurement of the contribution of street lighting to satellite observations of nighttime light emissions from urban areas. Kyba, C, et al. Lighting Research & Technology. October 2020. https://doi.org/10.1177/1477153520958463
Abstract: Nighttime light emissions are increasing in most countries worldwide, but which types of lighting are responsible for the increase remains unknown. Also unknown is what fraction of outdoor light emissions and associated energy use are due to 3 public light sources (i.e. streetlights) or various types of private light sources (e.g. advertising). Here we show that it is possible to measure the contribution of street lighting to nighttime satellite imagery using ‘smart city’ lighting infrastructure. The ci ty of Tucson, USA, intentionally altered its streetlight output over 10 days, and we examined the change in emissions observed by satellite. We find that streetlights operated by the city are responsible for only 13% of the total radiance (in the 500 –900 nm band) observed from Tucson from space after midnight (95% confidence interval 10–16%). If Tucson did not dim their streetlights after midnight, the contribution would be 18% (95% confidence interval 15–23%). When streetlights operated by other actors are included, the best estimates rise to 16% and 21%, respectively. Existing energy and lighting policy related to the sustainability of outdoor light use has mainly focused on street lighting. These results suggest an urgent need for consideration of other type s of light sources in outdoor lighting policy.

Anthropogenic Light Disrupts Natural Light Cycles in Critical Conservation Area s, Seymoure, B, et al. (August 19, 2019). https://ssrn.com/abstract=3439670
Abstract: Anthropogenic lighting drastically alters nocturnal environments, threatening a wide range of species by disrupting light regimes that regulate fundamental biological processes such as reproduction, foraging, and predator defense. We translate sat ellite measures of anthropogenic light radiating from the earth to a biologically relevant measurement – the amount of light scattered back to the earth (horizontal illuminance). Anthropogenic light exceeding the natural level produced by stars, galactic light , and airglow on a clear moonless night (i.e., new moon conditions) affects 22.9% of the Earth’s terrestrial surface, as well as 51.0% of Key Biodiversity Area units, 77.1% of Global Protected Area units, and approximately 20% of the most biodiverse areas for mammals, birds, and amphibians. Thus, due to anthropogenic sources, these environments experience at least double the levels of natural illuminance during half of the night hours in a year. To facilitate biological interpretation of these levels of anth ropogenic illuminance observed globally, we undertook a systematic literature review of animal responses to changing nocturnal light levels.

Known biological effects from the current anthropogenic illuminance levels range from behavioral and physiological alteration s to increased mortality, which have been documented in 117 species from 23 orders and 8 classes. These findings provide a biological perspective on global light pollution, and they identify regions where reductions in anthropogenic illuminance wou ld yield the greatest benefits for conserving biodiversity.

Effects of the COVID-19 Lockdown on Urban Light Emissions: Ground and Satellite Comparison. Bustamante-Calabria, M, Sánchez de Miguel, A, et al. Remote Sensing. Jan 2021, Vol 13, Issue 2, 258. https://www.mdpi.com/2072-4292/13/2/258
Abstract Excerpt: ‘Lockdown’ periods in response to COVID-19 have provided a unique opportunity to study the impacts of economic activity on environmental pollution (e.g., NO2, aerosols, noise, light)... Here, to analyze the effect of lockdown on urban light emissions, we use ground and satellite data for Granada, Spain, during the COVID-19 induced confinement of the city’s population from 14 March until 31 May 2020. We find a clear decrease in light pollution due both to a decrease in ligh t emissions from the city and to a decrease in anthropogenic aerosol content in the atmosphere which resulted in less light being scattered. A clear correlation between the abundance of PM10 particles and sky brightness is observed, such that the more polluted the atmosphere the brighter the urban night sky.

Environmental and Social Justice

Light pollution inequities in the continental United States: A distributive environmental justice analysis. Nadybal S.M., Collins T.W., Grineski S.E.. Environmental Research, Vol 189, 2020, 109959. http://www.sciencedirect.com/science/article/pii/S0013935120308549 Abstract: Excessive exposure to ambient light at night is a well-documented hazard to human health, yet analysts have not examined it from an environmental justice (EJ) perspective. We conducted the first EJ study of exposure to light pollution by testing for socially disparate patterns across the continental United States (US)... We found evidence of disparities in exposures to light pollution based on racial/ethnic minority and low-to-mid socioeconomic statuses. Americans of Asian, Hispanic or Black race/ethnicity had population-weighted mean exposures to light pollution in their neighborhoods that were app roximately two times that of White Americans... neighborhoods composed of higher proportions of Blacks, Hispanics, Asians, or renter - occupants experienced greater exposures to ambient light at night. Stratified analyses indicated that those patterns of ine quity did not substantially vary based on urban-rural context. Findings have implications for understanding environmental influences on health disparities, raise concerns about the potential for a multiple environmental jeopardy situation, and highlight th e need for policy actions to address light pollution.

An incandescent truth: Disparities in energy-efficient lighting availability and prices in an urban U.S. county. Reames, Tony G., Michael A. Reiner, and M. Ben Stacey. (2018) Applied Energy 218:95 -103. https://www.sciencedirect.com/science/article/abs/pii/S0306261918302769 Abstract Excerpt: In the U.S. lighting represents about 9% of the average household's primary e nergy consumption and 20% of the average household's energy bill. Lighting in U.S. homes is in a state of transition with steady growth in the adoption of more energy-efficient lighting technology, such as, compact florescent lamps (CFL) and light -emitting diodes (LEDs). However, the adoption of energy-efficient lighting is not equitably distributed across socioeconomic groups, with poorer households less likely to adopt than higher-income households... We found that (1) energy-efficient bulbs were less available in high-poverty areas and 4 smaller stores; (2) energy-efficient bulbs were more expensive in high-poverty areas and smaller stores; (3) upgrade costs from incandescent and halogen lamps (IHLs) to CFLs or LEDs were higher in high poverty areas; and (4 ) both poverty and store type were significant predictors of LED availability, while store type was the most significant predictor of LED price variability . We suggest several ways that the development and implementation of energy efficiency policies and p rograms may consider these disparities that affect access and affordability, in order to achieve a more just energy -efficient transition.

Up in smoke: Characterizing the population exposed to flaring from unconventional oil and gas development in the contiguous US. Cushing Lara J, et al. Feb 2021. Environmental Research Letters. Vol. 16, No 3. https://iopscience.iop.org/article/10.1088/1748-9326/abd3d4 Abstract Excerpt: The disposal of waste gas via intentional combustion (flaring) from unconventional oil and gas (UOG) development has also been on the rise, and may expose nearby residents to toxic air pollutants, light pollution and noise. .. We found that three basins accounted for over 83% of all UOG flaring activity in the contiguous US over the 8 year study period. We estimated that over half a million people in these basins reside within 5 km of a flare, and 39% of them lived near more than 100 nightly flares. Black, indigenous, and people of color were disproportionately exposed to flaring.

Light Pollution in San Antonio, TX: An Environmental Justice Issue. Alvarez, V, et al. May 2020. Environmental Studies Student Works. Trinity University.
https://digitalcommons.trinity.edu/env_studocs/2
Abstract Excerpt: the environmental justice movement often overlooks the issue of light pollution, even though light pollution is higher in urban low-income areas. There is a lack of studies examining how light pollution varies between communities on a regional, state, or municipal scale... The mid-income neighborhoods had the greatest median and maximum light pollution levels, while high-income neighborhoods had the lowest median illuminance. These results indicate that mid -income neighborhoods are subject to the greatest amount of light pollution by area and intensity.

Ecological, Wildlife and Human Impacts

Ecological light pollution. Longcore, T. and Rich, C. (2004), Frontiers in Ecology and the Environment, 2: 191 -198. https://esajournals.onlinelibrary.wiley.com/doi/abs/10.1890/1540-9295%282004%29002%5B0191%3AELP%5D2.0.CO%3B2 Abstract: Ecologists have long studied the critical role of natural light in regulating species interactions, but, with limit ed exceptions, have not investigated the consequences of artificial night lighting. In the past century, the extent and intensity of artificial night lighting has increased such that it has substantial effects on the biology and ecology of species in the wil d. We distinguish “astronomical light pollution”, which obscures the view of the night sky, from “ecological light pollution”, which alters natural light regimes in terrestrial and aquatic ecosystems. Some of the catastrophic consequences of light for certai n taxonomic groups are well known, such as the deaths of migratory birds around tall lighted structures, and those of hatchling sea turtles disoriented by lights on their natal beaches. The more subtle influences of artificial night lighting on the behavior and community ecology of species are less well recognized, and constitute a new focus for research in ecology and a pressing conservation challenge.

Ecological consequences of artificial night lighting. Rich, C. and T. Longcore. (eds.). 2006. Island Press, Washington, D.C. https://www.urbanwildlands.org/ecanlbook.html
The first book to consider the environmental effects of the intentional illumination of the night. It brings together leading scientists from around the world to review the state of knowledge on the subject and to describe specific effects that have been observed across a full range of taxonomic groups, including mammals, birds, reptiles and amphibians, fishes, invertebrates, a nd plants… provides a scientific basis to begin addressing the challenge of conserving the nighttime environment. It cogently demonstrates the vital importance of this until-now neglected topic and is an essential new work for conservation planners, researchers, and anyone concerned with human impacts on the natural world.

Light Pollution Is a Driver of Insect Declines, by Owens, A, et al. (April 26, 2019) https://ssrn.com/abstract=3378835
Abstract: Insects around the world are rapidly declining. Concerns over what this loss means for food security and ecological communities have compelled a growing number of researchers to search for the key drivers behind the decline. Habitat loss, pesticide use, invasive species, and climate change all have likely played a role, but we pos it here that artificial light at night (ALAN) is another important — but often overlooked — bringer of the insect apocalypse. We first discuss the history and extent of ALAN, and then present evidence that ALAN has led to insect declines through its interf erence with the development, movement, foraging, and reproductive success of diverse insect species, as well as its positive effect on insectivore predati on. We conclude with a discussion of how artificial lights can be tuned to reduce their impacts on vul nerable populations. ALAN is unique among anthropogenic habitat disturbances in that it is fairly easy to ameliorate, and leaves behind no residual effect s.

Greater recognition of the ways in which ALAN impacts insects can help conservationists reduce or e liminate one of the major drivers of insect declines.

5 A meta-analysis of biological impacts of artificial light at night. Nature Ecology & Evolution (2020), Dirk Sanders, Enric Frago, Rachel Kehoe, Christophe Patterson & Kevin J. Gaston
https://doi.org/10.1038/s41559-020-01322-x
https://datadryad.org/stash/dataset/doi:10.5061/dryad.wpzgmsbjn Abstract: Natural light cycles are being eroded over large areas of the globe by the direct emissions and sky brightening that result from sources of artificial night-time light. This is predicted to affect wild organisms, particularly because of the central role that light regimes play in determining the timing of biological activity. Although many empirical studies have reported such effects, these have focused on particular species or local communities and have thus been unable to provide a general evaluat ion of the overall frequency and strength of these impacts. Using a new database of published studies, we show that exposure to artificial light at night induces strong responses for physiological measures, daily activity patterns and life history trait s. We found particularly strong responses with regards to hormone levels, the onset of daily activity in diurnal species and life history traits, such as the number of offspring, predation, cognition and seafinding (in turtles). So far, few studies have focused on the im pact of artificial light at night on ecosystem functions. The breadth and often strength of biological impacts we reveal highlight the need for outdoor artificial night-time lighting to be limited to the places and forms—such as timing, intensity and spectrum—where it is genuinely required by the people using it to minimize ecological impacts.

Longer photoperiods through range shifts and artificial light lead to a destabilizing increase in host –parasitoid interaction strength. Kehoe, R, Sanders, D, Cruse, D, et al. Journal of Animal Ecology. 2020; 89: 2508–2516. https://doi.org/10.1111/1365-2656.13328
Excerpts: Many organisms are experiencing changing daily light regimes due to latitudinal range shifts driven b y climate change and increased artificial light at night (ALAN). Activity patterns are often driven by light cycles, which will have important consequences for species interactions... Here we demonstrate that ALAN impact interacts with daylength and temper ature by changing the interaction strength between a common day‐active consumer species and its host in a predictable way. Our results further suggest that range expansion or ALAN‐induced changes in light regimes experienced by insects and their natural en emies will result in unstable dynamics beyond key tipping points in daylength... Finally, the strong response of a diurnal host –parasitoid system reported here also emphasizes the importance of focussing on the impact of ALAN not just on nocturnal species but also on those that are chiefly diurnal, on which the effects of ALAN may be just as profound, if not as intuitive.

Artificial nightlight alters the predator–prey dynamics of an apex carnivore. Ditmer, MA, et al. (2020). Ecography https://doi.org/10.1111/ecog.05251
Abstract Excepts: Our results indicate that deer used the anthropogenic environments to access forage and were more active at night than their wildland conspecifics. Despite higher nightlight levels, cougars killed deer at the wildland–urban interface, but hunted them in the relatively darkest locations. Light had the greatest effect of all covariates on where cougars killed deer at the wildland–urban interface. Both species exhibited functional responses to light pollution at fine scales; individual cougars and deer with less light exposure increasingly avoided illuminated areas when exposed to greater radiance, whereas deer living in the wildland–urban interface selected elevated light levels. We conclude that integrating estimates of light pollution into ecological studies provides crucial insights into how the dynamic human footprint can alter animal behavior and ecosystem function acros s spatial scales.

Coral Gametogenesis Collapse under Artificial Light Pollution. Ayalon et al. Current Biology. Nov 2020 https://doi.org/10.1016/j.cub.2020.10.039
Excerpts: Marine organisms, including coral reefs in particular, rely on the natural lig ht cycles of sunlight and moonlight to regulate various physiological, biological, and behavioral processes. Here, we demonstrate that light pollution caused delayed gametogenesis and unsynchronized gamete release in two coral species, Acropora millepora and Acropora digitifera, from the Indo-Pacific Ocean… With the global transition toward LED lighting, which tends to have higher emissions in the blue spectrum, more coral reefs could be affected by artificial light, as blue light penetrates deeper into th e water column. This spectral shift is expected to be amplified by the current rapid population growth in coastal regions... Our experimental results are corroborated by in situ observations, which have shown disruption of gametogenesis and loss of spawni ng synchrony in corals occurring at sites that are heavily polluted by artificial lights. These results demonstrate that artificial light must be considered in c onservation plans for coral reefs near areas of human activity.

Sensory pollutants alter bird phenology and fitness across a continent. Senzaki, M., Barber, J.R., Phillips, J.N. et al. Nature 587, 605–609 (2020)
https://doi.org/10.1038/s41586-020-2903-7
Abstract: Expansion of anthropogenic noise and night lighting across our planet is of increasing conservation concern. Despite growing knowledge of physiological and behavioural responses to these stimuli from single -species and local-scale studies, whether these pollutants affect fitness is less clear, as is how and why species vary in their sensitivity to these anthropic stressors.

Here we leverage a large citizen science dataset paired with high-resolution noise and light data from across the contiguous United States to assess how these stimuli affect reproductive success in 142 bird species. We find responses to both sensory pollutants linked to the functional traits and habitat affiliations of species. For example, overall nest success was negativ ely correlated with noise among birds in closed environments. Species-specific changes in reproductive timing and hatching success 6 in response to noise exposure were explained by vocalization frequency, nesting location and diet. Additionally, increased li ght- gathering ability of species’ eyes was associated with stronger advancements in reproductive timing in response to light exposure, potentially creating phenological mismatches. Unexpectedly, better light-gathering ability was linked to reduced clutch failure and increased overall nest success in response to light exposure, raising important questions about how responses to sensory pollutants counteract or exacerbate responses to other aspects of global change, such as climate warming. These findings demonstrate that anthropogenic noise and light can substantially affect breeding bird phenology and fitness, and underscore the need to consider sensory pollutants alongside traditional dimensions of the environment that typically inform biodiversity conservation.

Bright lights in the big cities: migratory birds’exposure to artificial light. Horton, KG., Nilsson, C., et al, 2019. Frontiers in Ecology and the Environment, April 2019.
https://doi.org/10.1002/FEE.2029
https://www.youtube.com/watch?v=_gXSN2GmI8M
Abstract: Many species of migratory birds have evolved the ability to migrate at night, and the recent and rapid expansion of artificial light at night has markedly altered the nighttime sky through which they travel. Migrating birds regularly pass through heavily illuminated landscapes, and bright lights affect avian orientation. But risks to migrating birds from artificial ligh t are not spatially or temporally uniform, representing a challenge for mitigating potential hazards and developing action plans to catalog risks at continental scales. We leveraged over two decades of remote‐sensing data collected by weather surveillance radar and satellite‐based sensors to identify locations and times of year when the highest numbers of migrating birds are exposed to light pollution in the contiguous US. Our continental‐scale quantification of light exposure provides a novel opportunity for dynam ic and targeted conservation strategies to address the hazards posed by light pollution to nocturnally migrating birds.

High-intensity urban light installation dramatically alters nocturnal bird migration. Van Doren BM, Horton KG, et al.

Proceedings of the National Academy of Sciences, Oct 2017, 114 (42) 11175-11180 https://www.pnas.org/content/114/42/11175
Abstract Excerpt: Billions of nocturnally migrating birds move through increasingly photopo lluted skies, relying on cues for navigation and orientation that artificial light at night (ALAN) can impair… We studied effects of ALAN on migrating birds by monitoring the beams of the National September 11 Memorial & Museum's “Tribute in Light” in New York, quantifying behavioral responses with radar and acoustic sensors and modeling disorientation and attraction with simulatio ns… When the installation was illuminated, birds aggregated in high densities, decreased flight speeds, followed circular flight paths, and vocalized frequently… However, behavioral disruptions disappeared when lights were extinguished, suggesting that selective removal of light during nights with substantial bird migration is a viable strategy for minimizing potentially fatal inte ractions among ALAN, structmelures, and birds. Our results also highlight the value of additional studies describing behavioral patterns of nocturnally migrating birds in powerful lights in urban areas as well as conservation implications for such lighting installations.

The ecological impacts of nighttime light pollution: a mechanistic appraisal. Gaston, K. J., Bennie, J., Davies, T. W. and Hopkins, J., Biological Reviews, Vol 88, Issue 4, 2013, Cambridge Philosophical Society https://onlinelibrary.wiley.com/doi/full/10.1111/brv.12036 Abstract: The ecological impacts of nighttime light pollution have been a longstanding source of concern, accentuated by rea lized and projected growth in electrical lighting. As human communities and lighting technologies develop, artificial light increas ingly modifies natural light regimes by encroaching on dark refuges in space, in time, and across wavelengths. A wide variety of ecological implications of artificial light have been identified. However, the primary research to date is largely focused on the disruptive influence of nighttime light on higher vertebrates, and while comprehensive reviews have been compiled along taxonomic lines and within specific research domains, the subject is in need of synthesis within a common mechanistic framework. Here we propose such a framework that focuses on the cross -factoring of the ways in which artificial lighting alters natural light regimes (spatially, temporally, and spectrally), and the ways in which light influences biological systems, particularly the distinction between light as a resource and light as an information source. We review the evidence for each of the combinations of this cross-factoring. As artificial lighting alters natural patterns of light in space, time and across wavelengths, natural patterns of resource use and information flows may be disrupted, with downstream effects to the structure and functio n of ecosystems. This review highlights: (i) the potential influence of nighttime lighting at all levels of biological organisation (from cell to ecosystem); (ii) the significant impact that even low levels of nighttime light pollution can have; and (iii) the exi stence of major research gaps, particularly in terms of the impacts of light at population and ecosystem levels, identification of inte nsity thresholds, and the spatial extent of impacts in the vicinity of artificial lights.

Light Pollution, Circadian Photoreception, and Melatonin in Vertebrates. Grubisic M, Haim A, Bhusal P, Dominoni DM, Gabriel KMA, Jechow A, Kupprat F, Lerner A, Marchant P, Riley W, Stebelova K, van Grunsven RHA, Zeman M, Zubidat AE, Hölker F. Sustainability. 2019; 11(22):6400.
https://www.mdpi.com/2071-1050/11/22/6400
Abstract: Artificial light at night (ALAN) is increasing exponentially worldwide, accelerated by the transition to new effici ent lighting technologies. However, ALAN and resulting light pollution can cause unintended physiological consequences. In vertebrates, production of melatonin—the “hormone of darkness” and a key player in circadian regulation—can be suppressed by 7 ALAN. In this paper, we provide an overview of research on melatonin and ALAN in vertebrates. We discuss how ALAN disrupts natural photic environments, its effect on melatonin and circadian rhythms, and different photoreceptor systems acro ss vertebrate taxa. We then present the results of a systematic review in which we identified studies on melatonin under typical light- polluted conditions in fishes, amphibians, reptiles, birds, and mammals, including humans. Melatonin is suppressed by extreme ly low light intensities in many vertebrates, ranging from 0.01–0.03 lx for fishes and rodents to 6 lx for sensitive humans. Even lower, wavelength-dependent intensities are implied by some studies and require rigorous testing in ecological contexts. In many studies, melatonin suppression occurs at the minimum light levels tested, and, in better-studied groups, melatonin suppression is reported to occur at lower light levels. We identify major research gaps and conclude that, for most groups, crucial informat ion is lacking. No studies were identified for amphibians and reptiles and long-term impacts of low-level ALAN exposure are unknown.

Given the high sensitivity of vertebrate melatonin production to ALAN and the paucity of available information, it is crucial to research impacts of ALAN further in order to inform effective mitigation strategies for human health and the wellbeing and fitness of vertebrates in natural ecosystems.

Melatonin: a possible link between the presence of artificial light at night and reductions in biological fitness. Jones TM, Durrant J, Michaelides EB, Green MP. 2015, Phil. Trans. R. Soc. B 370: 20140122. https://royalsocietypublishing.org/doi/10.1098/rstb.2014.0122 Abstract: The mechanisms underpinning the ecological impacts of the presence of artificial night lighting remain elusive. One suspected underlying cause is that the presence of light at night (LAN) supresses nocturnal production of melatonin, a key dr iver of biological rhythm and a potent antioxidant with a proposed role in immune function. Here, we briefly review the evidence for melatonin as the link between LAN and changes in behaviour and physiology. We then present preliminary data supporting the potential for melatonin to act as a recovery agent mitigating the negative effects of LAN in an invertebrate. Adult crickets (Teleogryllus commodus), exposed to constant illumination, were provided with dietary melatonin (concentrations: 0, 10 or 100 µg ml−1) in their drinking water. We then compared survival, lifetime fecundity and, over a 4-week period, immune function (haemocyte concentration, lysozyme-like and phenoloxidase (PO) activity). Melatonin supplementation was able only partially to mitigate the detrimental effects of LAN: it did not improve survival or fecundity or PO activity, but it had a largely dose- dependent positive effect on haemocyte concentration and lysozyme-like activity. We discuss the implications of these relationships, as well as the usefulness of invertebrates as model species for future studies that explore the effects of LAN.

Waters under Artificial Lights: Does Light Pollution Matter for Aquatic Primary Producers? Grubisic, M. (2018), Limnology and Oceanography Bulletin, 27: 76-81.
https://aslopubs.onlinelibrary.wiley.com/doi/abs/10.1002/lob.10254 Abstract: Bright night lights have become a symbol of development and prosperity in the modern world. But have you ever wondered how artificial light at night (ALAN) may be affecting living beings in our cities, and how it may be affecting us? As artificial illumination is transforming nocturnal environments around the world, light pollution associated with its use is b ecoming a topic of increasing interest in the scientific and public communities. Light pollution disrupts natural light regimes in many regions of the world, raising concerns about ecological and health impacts of this novel anthropogenic pressure. Most obvious ly, ALAN can influence night‐active animals in urban and suburban areas, and most research in this growing field focuses on terrestrial organisms such as bats, birds, and insects. Effects on aquatic ecosystems are much less known. In particular, aqu atic primary producers, such as microalgae, cyanobacteria, and plants, have rarely been studied despite their critical positioning in the base of aquatic food webs and the fundamental role that light plays in their ecology. For primary producers, light is a key s ource of both energy and environmental information; it influences their growth, production, and community structure. ALAN has therefore a large potential to influence their communities and induce bottom‐up changes to aquatic ecosystems and ecosystem functions.

Global climate change and invariable photoperiods: A mismatch that jeopardizes animal fitness. Walker, WH, Meléndez- Fernández, OH, Nelson, RJ, Reiter, RJ. Ecol Evol. 2019; 9: 10044–10054. https://onlinelibrary.wiley.com/doi/full/10.1002/ece3.5537 Abstract: The Earth's surface temperature is rising, and precipitation patterns throughout the Earth are changing; the source of these shifts is likely anthropogenic in nature. Alterations in temperature and precipitation have obvious direct and indirect effects on both plants and animals. Notably, changes in temperature and precipitation alone can have both advantageous and detrimenta l consequences depending on the species. Typically, production of offspring is timed to coincide with optimal food availability; thus, individuals of many species display annual rhythms of reproductive function. Because it requires substantial time to establish or re-establish reproductive function, individuals cannot depend on the arrival of seasonal food availability to begin breeding; thus, mechanisms have evolved in many plants and animals to monitor and respond to day length in order to anticipat e seasonal changes in the environment. Over evolutionary time, there has been precise fine-tuning of critical photoperiod and onset/offset of seasonal adaptations. Climate change has provoked changes in the availability of insects and plants which shi fts the timing of optimal reproduction. However, adaptations to the stable photoperiod may be insufficiently plastic to allow a shift in the seasonal timing of bird and mammal breeding. Coupled with the effects of light pollution which prevents these species fro m determining day length, climate change presents extreme evolutionary pressure that can result in severe deleterious consequences for individual species reproduction and survival. This review describes the effects of climate change on plants and animals, 8 defines photoperiod and the physiological events it regulates, and addresses the consequences of global climate change and a stable photoperiod.

Effects of street lighting technologies on the success and quality of pollination in a nocturnally pollinated plant. Macgregor, C.

J., M. J. O. Pocock, R. Fox, and D. M. Evans. 2019. Ecosphere 10(1):e02550 https://esajournals.onlinelibrary.wiley.com/doi/abs/10.1002/ecs2.2550 Abstract: Artificial light at night (ALAN) is an increasingly important dr iver of global change. Lighting directly affects plants, but few studies have investigated indirect effects mediated by interacting organisms. Nocturnal Lepidoptera are globally importan t pollinators, and pollen transport by moths is disrupted by lighting. Many street lighting systems are being replaced with novel, energy‐efficient lighting, with unknown ecological consequences. Using the wildflower Silene latifolia, we compared pollinati on success and quality at experimentally lit and unlit plots, testing two major changes to street lighting technology: in lamp type, from high‐pressure sodium lamps to light‐emitting diodes, and in lighting regime, from full‐night (FN) to part‐night (PN) lig hting.

We predicted that lighting would reduce pollination. S. latifolia was pollinated both diurnally and nocturnally. Contrary to our predictions, flowers under FN lighting had higher pollination success than flowers under either PN lighting or unlit controls , which did not significantly differ from each other. Lamp type, lighting regime, and distance from the light all significantly affected aspects of pollination quality. These results confirm that street lighting could affect plant reproduction through i ndirect effects mediated by nocturnal insects, and further highlight the possibility for novel lighting technologies to mitigate the effects of ALAN on ecosystems.

Cascading effects of artificial light at night: resource-mediated control of herbivores in a grassland ecosystem. Bennie J, Davies TW, Cruse D, Inger R, Gaston KJ. 2015. Phil. Trans. R. Soc. B 370: 20140131. https://royalsocietypublishing.org/doi/10.1098/rstb.2014.0131 Abstract: Artificial light at night has a wide range of biological effects on both plants and animals. Here, we review mechan isms by which artificial light at night may restructure ecological communities by modifying the interactions between species. Such mechanisms may be top-down (predator, parasite or grazer controlled), bottom-up (resource-controlled) or involve non-trophic processes, such as pollination, seed dispersal or competition. We present results from an experiment investigating both top -down and bottom-up effects of artificial light at night on the population density of pea aphids Acyrthosiphon pisum in a diverse artificial grassland community in the presence and absence of predators and under low -level light of different spectral composition. We found no evidence for top-down control of A. pisum in this system, but did find evidence for bottom -up effects mediated through the impact of light on flower head density in a leguminous food plant. These results suggest that physiologi cal effects of light on a plant species within a diverse plant community can have detectable demographic effects on a specialist herbivore.

Artificial night light alters ecosystem services provided by biotic components. Singhal, R.K., Chauhan, J., Jatav, H.S. et al.

Biologia Futura (2021).
https://doi.org/10.1007/s42977-020-00065-x
Abstract Excerpt: This review highlights the impact of ALAN on the ecosystem and its living and non -living components, emphasizing to the terrestrial and aquatic ecosystem. Further, we summarize the means of minimizing strategies of ALAN in the environment, which are very crucial to reduce the further spread of night light contamination in the environment and can be u seful to minimize the drastic impacts on the ecosystem.

City lights and urban air. Stark, H., Brown, S., Wong, K. et al. Nature Geoscience, Vol 4, Nov 2011. https://doi.org/10.1038/ngeo1300
https://s3.amazonaws.com/wbez-assets/curiouscity/ngeo_1300_NOV11_auproof2.pdf https://cires.colorado.edu/news/bright-city-lights-affect-air-pollution Here we show that city lights can also alter the concentration of nitrate radicals, an important atmospheric oxidant. These alterations have potential — albeit small — consequences for pollution levels the following day… We converted satellite data on light intensity into nitrate radical loss, using our aircraft measurements, and show that the infuence of city lights on nitrate radical loss can be large in regions outside Los Angeles... We also fnd that satellite-derived estimates of light levels tend to correlate positively with independent satellite-derived estimates of nitrogen dioxide. We therefore suggest that city lights are likely to infuence nitrogen dynamics in other regions of the globe.

Nighttime photochemistry: nitrate radical destruction by anthropogenic light sources. Stark, H, etal. CIRES, NOAA. 2010. https://www.academia.edu/23527679/Nighttime_photochemistry_nitrate_radical_destruction_by_anthropogenic_light_sources Abstract extract: show airborne and ground measurements of absolute light intensities from anthropogenic and natural light sources (e.g. industrial and street lighting, full moon) as a newly discovered NO3 loss process. This loss process has implic ations for nighttime pollutant levels and next-day ozone production.

9 Light Flicker from LED Lighting Systems-An Urgent Problem to Solve. GIES, T.H. (2016). https://www.led-professional.com/resources-1/articles/lighting-flicker-from-led-lighting-systems/LpR53_p50-p59.pdf Recent research has shown that fluctuations of short wavelength emissions are perceived to a higher extent and light flic ker may have a huge influence on the well-being of end users.

Blue light excited retinal intercepts cellular signaling. Ratnayake, K., Payton, J.L., Lakmal, O.H. et al. Scientific Reports 8, 10207 (2018).
https://doi.org/10.1038/s41598-018-28254-8
Photoreceptor chromophore, 11-cis retinal (11CR) and the photoproduct, all-trans retinal (ATR), are present in the retina at higher concentrations and interact with the visual cells. Non-visual cells in the body are also exposed to retinal that enters the circulation. … we uncovered that blue light-excited ATR and 11CR irreversibly change/distort plasma membrane (PM) bound phospholipid; phosphatidylinositol 4,5 bisphosphate (PIP2) and disrupt its function. … The change in PIP2 was followed by an increase in the cytosolic calcium, excessive cell shape change, and cell death… These findings suggest that retinal exerts light sensitivity to both photoreceptor and non-photoreceptor cells, and intercepts crucial signaling events, altering the cellular fate.

Blue light from phone screens accelerates blindness, study finds. The Guardian. 8/9/2018 https://www.theguardian.com/society/2018/aug/09/blue-light-from-phone-screens-accelerates-blindness-study-finds Research… has revealed that prolonged exposure to blue light triggers poisonous molecules to be generated in the eye’s light - sensitive cells that can cause macular degeneration – an incurable condition that affects the middle part of vision. Blue light, which has a shorter wavelength and more energy compared with other colours, can gradually cause damage to the eyes.

How the marvel of electric light became a global blight to health. Dr. Richard G ‘Bugs’ Stevens. Aeon. August 3, 2018. https://aeon.co/ideas/how-the-marvel-of-electric-light-became-a-global-blight-to-health Excerpts: Light at night constitutes a massive assault on the ecology of the planet, including us… The electric light bulb is touted as one of the most significant technological advancements of human beings… But as with any new and spectacular technology, there are invariably unintended consequences… The current ‘lightmare’ traces back to the 1950s, when a road-building frenzy, including construction of the Interstate Highway System, aimed to solve the problem of congestion in the United States. But t he roads turned out to increase congestion and pollution, including light pollution, too… More efficient energy-production and use, without concerted public education on reduction of use, can make the pollution problem worse… The hyper-aggressive marketing of bright, white LED street lighting to cities and towns has advanced to a breathtaking level. The US Department of Energy (DoE) and a group of international partners have launched an effort called ‘Rise and Shine: Lighting the World with 10 Billion LED Bulbs’ in ‘a race to deploy 10 billion high-efficiency, high-quality and affordable lighting fixtures and bulbs (like LEDs) as quickly as possible’… In response to this relentless attack on night, the American Medical Association (AMA) stepped up and adopted an official policy statement in 2016... The reaction from the DoE and the Illuminating Engineering Society of North America (IES) was swift and highly critical of the AMA’s audacity, asserting that the AMA was not qualified to make any statements on lighting. But this reaction was disingenuous because without the AMA statement, the nationwide retrofit would have continued unabated without regard to the environment or human health. Electric light can be a great benefit to people when used wisely. To get to the ‘used wisely’ part requires all the science happening now. But there must also be a desire for effective use of electric lighting on the part of government and the public… few people will leave the faucet running much longer than necessary. Yet some people think nothing of using more electricity than they actually need… In the life of the planet, destruction of night is as important an issue as the poisoning of water and air.

Artificial Light at Night (ALAN): A Potential Anthropogenic Component for the COVID -19 and HCoVs Outbreak. Khan ZA, Yumnamcha T, Mondal G, et al. Frontiers in endocrinology. 2020;11:622. Published 2020 Sep 10. https://www.frontiersin.org/articles/10.3389/fendo.2020.00622/full Abstract Excerpt: In this article, we tried to focus on the possible influence of this anthropogenic factor in human coronavirus (HCoV) outbreak. The relationship between the occurrences of coronavirus and the ascending curve of the night -light has also been delivered. The ALAN influences the physiology and behavior of bat, a known nocturnal natural reservoir of many Coronaviridae. The “threatened” and “endangered” status of the majority of bat species is mainly because of the destruction o f their proper habit and habitat predominantly through artificial illumination. The stress exerted by ALAN leads to the impaired body functions, especially endocrine, immune, genomic integration, and overall rhythm features of different physiological variables and behaviors in nocturnal animals. Night-light disturbs “virus–host” synchronization and may lead to mutation in the genomic part of the virus and excessive virus shedding. We also proposed some future strategies to mitigate the repercussions of ALAN and for the protection of the living system in the earth as well.

Light pollution linked to preterm birth increase. Jan 25, 2021. Lehigh University. Science Daily. https://www.sciencedaily.com/releases/2021/01/210125191821.htm Scientists conducted the first study to examine the fetal health impact of light pollution based on a direct measure of skyglow, an important aspect of light pollution. Using an empirical regularity discovered in physics, called Walker's Law, a team found evidence of reduced birth weight, shortened gestational length and preterm births.

10 Association of Outdoor Artificial Light at Night With Mental Disorders and Sleep Patterns Among US Adolescents . Paksarian D, Rudolph KE, Stapp EK, et al. JAMA Psychiatry. 2020;77(12):1266–1275. https://jamanetwork.com/journals/jamapsychiatry/article-abstract/2767698 https://edition.cnn.com/2020/07/08/health/night-light-pollution-disrupt-sleep-wellness/index.html In this study, area-level outdoor ALAN was associated with less favorable sleep patterns and mood and anxiety disorder in adolescents. Future studies should elucidate whether interventions to reduce exposure to ALAN may positively affect mental and sleep health.

Astronomy Impacts

Light Pollution In California And Arizona. Walker, Merle F. Publications of The Astronomical Society of The Pacific, Vol. 85, No. 507, 1973, pp. 508–519. Jstor
http://www.jstor.org/stable/40675430
The present and future effect of artificial illumination on ground-based optical astronomical observations in California and Arizona is discussed. It is concluded that the effectiveness of all major observatories in these states is presently or potentially limited by light pollution. Consequently, it is essential that immediate efforts be undertaken to: (1) Control outdoor illumi nation to lengthen the useful life of existing observatory sites, and (2) Identify and protect the best remaining sites both within and outside the United States. The characteristics and probable locations of the best sites for ground -based optical astronomical observations are discussed.

Light Pollution: Outdoor lighting is a growing threat to astronomy. Riegel, Kurt W. Science, Vol. 179, No. 4080, Mar 1973, pp. 1285–1291.
https://pubmed.ncbi.nlm.nih.gov/17835929/
Abstract Excerpt: The level of skylight caused by outdoor lighting systems is growing at a very high rate, about 20 percent per year nationwide. In addition, the spectral distribution of man-made light pollution may change in the next decade from one containing a few mercury lines to one containing dozens of lines and a significantly increased continuum level. Light pollution is presently damaging to some astronomical programs, and it is likely to become a major factor limiting progress in the next decade... Some is due to promotional campaigns, in which questionable arguments involving public safety are presented. There are protective measures which might be adopted by the government; these would significantly aid observational astronomy, without compromising the legitimate outdoor lighting needs of society.

Flagstaff's Battle for Dark Skies. Portree D.S.F. Oct 2002, Griffith Observer, Vol 66 No 10 http://www2.lowell.edu/users/wes/GriffithObserver1crop.pdf http://www.flagstaffdarkskies.org/international-dark-sky-city/flagstaffs-battle-for-dark-skies/

Public Safety

Blinded by the Lights: Levi's Stadium Lights May Be Airport Safety Hazard. By Stephen Stock, Michael Bott and Jeremy Carroll. NBC Bay Area. Sept 22, 2015
https://www.nbcbayarea.com/news/local/blinded-by-the-lights-levi-stadium-lights-may-be-airport-safety-hazard/102234/ Some pilots say powerful lights above and around the new Levi’s Stadium can cause safety hazards for flights in and out of Sa n Jose Mineta International Airport.

Why Lighting Claims Might Well Be Wrong, Paul Marchant, International Journal of Sustainable Lighting: Vol. 19 No. 1 (2017) http://lightingjournal.org/index.php/path/article/view/71/79 This paper gives some background to claims of benefit from road lighting and why large beneficial claims may be suspect.

Feeling Safe in the Dark: Examining the Effect of Entrapment, Lighting Levels, and Gender on Feelings o f Safety and Lighting Policy Acceptability. Boomsma C, et al. Environmental and Behavior, Vol 46 Issue 2, pp 193 -212. Sept 2012. https://journals.sagepub.com/doi/10.1177/0013916512453838 Importantly, as hypothesized, perceived safety mediated the effect of lighting on acceptability levels, suggesting that peopl e can accept lower lighting levels when social safety is not threatened.

The effect of reduced street lighting on road casualties and crime in England and Wales: controlled interrupted time series analysis. Steinbach R, Perkins C, Tompson L, et al, J Epidemiol Community Health 2015;69:1118 -1124. https://jech.bmj.com/content/69/11/1118
Conclusions: This study found little evidence of harmful effects of switch off, part -night lighting, dimming, or changes to white light/LEDs on road collisions or crime in England and Wales.

11 Light Pollution Mitigation

National Light Pollution Guidelines for Wildlife Including Marine Turtles, Seabirds and Migratory Shorebirds , Commonwealth of Australia, Jan 2020
https://www.environment.gov.au/biodiversity/publications/national-light-pollution-guidelines-wildlife

Audubon’s Lights Out program
https://www.audubon.org/conservation/project/lights-out

LoNNe, Loss of the Night Network
http://www.cost-lonne.eu/recommendations/

Human and Environmental Effects of Light Emitting Diode (LED) Community Lighting , 2016, American Medical Association, CSAPH Report 2-A-16, Policy H-135.927
https://policysearch.ama-assn.org/policyfinder/detail/H-135.927?uri=%2FAMADoc%2FHOD-135.927.xml https://www.ama-assn.org/sites/ama-assn.org/files/corp/media-browser/public/about-ama/councils/Council%20Reports/council- on-science-public-health/a16-csaph2.pdf
supports the proper conversion to community-based Light Emitting Diode (LED) lighting, which reduces energy consumption and decreases the use of fossil fuels.. encourages minimizing and controlling blue-rich environmental lighting by using the lowest emission of blue light possible to reduce glare... should be properly shielded to minimize glare and detrimental human and environmental effects, and... utilize the ability of LED lighting to be dimmed for off-peak time periods.

Advocating and Support for Light Pollution Control Efforts and Glare Reduction for Both Public Safety and Energy Savings , 2012, Policy H-135.937
https://policysearch.ama-assn.org/policyfinder/detail/light%20pollution?uri=%2FAMADoc%2FHOD.xml -0-308.xml Our AMA: (1) will advocate that all future outdoor lighting be of energy efficient designs to reduce waste of energy and production of greenhouse gasses that result from this wasted energy use; (2) supports light pollution reduction efforts and g lare reduction efforts at both the national and state levels; and (3) supports efforts to ensure all future streetlights be of a fully shielded design or similar non-glare design to improve the safety of our roadways for all, but especially vision impaired and older drivers.

International Dark-Sky Association, https://darksky.org, https://darksky.org/light-pollution IDA Guidance for Electronic Message Centers (EMCs) – Digital billboards https://www.darksky.org/wp-content/uploads/2019/10/EMC-Guidelines-IDA2019-1.1.pdf IDA Criteria for Community-Friendly Outdoor Sports Lighting https://www.darksky.org/wp-content/uploads/2018/03/IDA-Criteria-for-Community-Friendly-Outdoor-Sports-Lighting.pdf

Model Lighting Ordinances – Dark Sky Impacts, Flagstaff Dark Skies Coalition http://www.flagstaffdarkskies.org/model-lighting-ordinances-dark-sky-impacts/

Led Lighting And Dark Skies: Are LEDs good for dark skies? Flagstaff Dark Skies Coalition. http://www.flagstaffdarkskies.org/led-lighting-dark-skies/

Light Pollution and Lighting Codes: An Analysis of the Light Pollution Control Effectiveness of the IDA-IES Model Lighting Ordinance and the IDA Pattern Outdoor Lighting Code, Christian B. Luginbuhl, U.S. Naval Observatory Flagstaff Station, 15 January 2013
http://www.flagstaffdarkskies.org/wp-content/uploads/2013/02/Lighting-Codes-and-LP-Luginbuhl-130115.pdf Excerpts: Under MLO standards, outside of MLO Lighting Zones 0 and 1, the total lumen allowances, direct uplight allowances, and amount of sky glow are notably greater than expected under POLC standards; in MLO Lighting Zones 3 and 4 they are dramatically greater. These lighting amounts and sky glow impacts are greater than what can be expected even when lighting is unregulated. The MLO Performance Method Option B provides notably poor control of direct upl ight and therefore sky glow.

Under the MLO Performance Method Option B there are no effective limitations on glare. MLO does not address lamp spectrum, and thus leaves this crucial aspect of light pollution unaddressed. Finally, the analysis shows that the MLO Prescriptive Hardscape Area and Performance Methods do not provide similar results in terms of total lumen a mounts, uplight amounts, glare, or “offsite” impacts, an undesirable characteristic of a model regulation purporting to control light pollution. The Performa nce Method particularly allows for the most egregious forms of polluting lighting fixtures and designs. We find no evidence that communities adopting MLO can expect reduction in light pollution over that produced by typical unregulated lighting, despite the claims of MLO to be a method to “drastically reduce” light pollution.

12 Model Lighting Ordinance: Is the BUG rating method effective at limiting light trespass?, April/May 2012 issue of LEDs Magazine
https://www.ledsmagazine.com/architectural-lighting/outdoor-lighting/article/16698628/model-lighting-ordinance-is-the-bug- rating-method-effective-at-limiting-light-trespass-magazine Excerpts: The MLO allows for the use of BUG ratings along with the performance method as long as there is no uplight used.

This scenario would not only allow for more lumens on the site as compared to the prescriptive method, but also would allow f or a greater amount of light spilling from the site than would be seen from sites that restrict the spill by using the calculation method.

As proven from the studies done for this article, the BUG rating method cannot effectively control these extra lumens of spil l light.

Hazard or Hope? LEDs and Wildlife. Longcore, Travis. (2018). LED Professional Review. 70. 52-57. https://www.led-professional.com/resources-1/articles/hazard-or-hope-leds-and-wildlife Conclusions: The efficiency benefits of LEDs and the resulting economic incentives will drive further conversion of outdoor a nd indoor lighting to the technology. If the tendency to light more when light is cheaper can be overcome, th e other attributes of LEDs hold significant promise for reducing environmental effects. Realizing that promise requires designers and manufacturers to learn about and embrace the guidance that wildlife scientists can provide. In some instances it will be c hallenging - resisting the desire to up-light, using no more light than necessary, and educating clients on the benefits of spectral choices that do not look like daylight. In other contexts, environmental regulations are likely to dictate lighting choices and offer an opportunity if the industry is prepared to seize it. On each of the mitigation approaches - duration, direction, intensity, and spectrum - LEDs will inherently or can be designed to perform well. Whether they do in practice will be up to the LED professional.

Artificial Night Lighting and Protected Lands: Ecological Effects and Management Approaches (Revised August 2017).

Longcore, T., and C. Rich. Natural Resource Report NPS/NRSS/NSNS/NRR—2017/1493. National Park Service, Fort Collins, Colorado.
https://irma.nps.gov/DataStore/DownloadFile/582058
Artificial night lighting represents a growing challenge for managers of parks and protected lands. The disruption of natural patterns of light and dark, which have been more or less reliable for millions of years, has a range of adverse consequences for wildlife across taxonomic groups and landscape types. This document reviews effects of artificial night lighting by habitat t ype and discusses the approaches available to land managers to mitigate and avoid certain adverse effects of artificial night lighting .

Rapid assessment of lamp spectrum to quantify ecological effects of light at night. Longcore, T., A. Rodríguez, B.

Witherington, J. F. Penniman, L. Herf, and M. Herf. 2018. Journal of Experimental Zoology A 329:511 -521. https://onlinelibrary.wiley.com/doi/abs/10.1002/jez.2184 Abstract: For many decades, the spectral composition of lighting was determined by the type of lamp, which also influenced potential effects of outdoor lights on species and ecosystems. Light-emitting diode (LED) lamps have dramatically increased the range of spectral profiles of light that is economically viable for outdoor lighting. Because of the array of choices, it is necessary to develop methods to predict the effects of different spectral profiles without conducting field studies, especially because older lighting systems are being replaced rapidly. We describe an approach to predict responses of exemplar organisms and groups to lamps of different spectral output by calculating an index based on action spectra from behavioral or visual characteristics of organisms and lamp spectral irradiance. We calculate relative response indices for a range of lamp types and light sources and develop an index that identifies lamps that minimize predicted effects as measured by ecological, physiological, and astronom ical indices. Using these assessment metrics, filtered yellow-green and amber LEDs are predicted to have lower effects on wildlife than high pressure sodium lamps, while blue-rich lighting (e.g., K ≥ 2200) would have greater effects. The approach can be updated with new information about behavioral or visual responses of organisms and used to test new lighting products based on spectrum. Together with control of intensity, direction, and duration, the approach can be used to predict and then minimize the adverse effects of lighting and can be tailored to individual species or taxonomic groups.

The LED Paradox: How Light Pollution Challenges Experts to Reconsider Sustainable Lighting. Schulte-Römer, N.; Meier, J.; Söding, M.; Dannemann, E.; Sustainability 2019, 11, 6160. https://www.mdpi.com/2071-1050/11/21/6160
Abstract: In the 21st century, the notion of “sustainable lighting” is closely associated with LED technology. In the past te n years, municipalities and private light users worldwide have installed light-emitting diodes in urban spaces and public streets to save energy. Yet an increasing body of interdisciplinary research suggests that supposedly sustainable LED installations are in fa ct unsustainable, because they increase light pollution. Paradoxically, blue-rich cool-white LED lighting, which is the most energy- efficient, also appears to be the most ecologically unfriendly. Biologists, physicians and ecologists warn that blue -rich LED light disturbs the circadian day-and-night rhythm of living organisms, including humans, with potential negative health effects on individual species and whole ecosystems. Can the paradox be solved? This paper explores this question based on our transdisciplinary research project Light Pollution—A Global Discussion. It reveals how light pollution experts and lighting professionals see the challenges and potential of LED lighting from their different viewpoints. This expert feedback shows th at “sustainable LED lighting” goes far beyond energy efficiency as it raises complex design issues that imply stakeholder negotiation. It also suggests that the LED paradox may be solved in context, but hardly in principle. 13 Tuning the white light spectrum of light emitting diode lamps to reduce attraction of noc turnal arthropods. Longcore Travis, Aldern Hannah L., Eggers John F., Flores Steve, Franco Lesly, Hirshfield -Yamanishi Eric, Petrinec Laina N., Yan Wilson A. and Barroso André M. 2015, Phil. Trans. R. Soc. B37020140125 https://royalsocietypublishing.org/doi/abs/10.1098/rstb.2014.012 5 Abstract: Artificial lighting allows humans to be active at night, but has many unintended consequences, including interferen ce with ecological processes, disruption of circadian rhythms and increased exposure to insect vectors of diseases. Although ultraviolet and blue light are usually most attractive to arthropods, degree of attraction varies among orders. With a focus on future indoor lighting applications, we manipulated the spectrum of white lamps to investigate the influence of spectral composition on number of arthropods attracted. We compared numbers of arthropods captured at three customizable light - emitting diode (LED) lamps (3510, 2704 and 2728 K), two commercial LED lamps (2700 K), two commercial compact fluorescent lamps (CFLs; 2700 K) and a control. We configured the three custom LEDs to minimize invertebrate attraction based on published attraction curves for honeybees and moths. Lamps were placed with pan traps at an urban and two rural study sites in Los Angeles, California. For all invertebrate orders combined, our custom LED configurations were less attractive than the commercial LED lamps or CFLs of similar colour temperatures. Thus, adjusting spectral composition of white light to minimize attracting nocturnal arthropods is feasible; not all lights with the same colour temperature are equally attractive to arthro pods.

Evaluating Potential Spectral Impacts of Various Artificial Lights on Melatonin Suppression, Photosynthesis, and Star Visibility. Aubé M, Roby J, Kocifaj M (2013). PLOS ONE 8(7): e67798. https://doi.org/10.1371/journal.pone.0067798
Abstract Excerpt: Artificial light at night can be harmful to the environment, and interferes with fauna and flora, star visibility, and human health. To estimate the relative impact of a lighting device, its radiant power, angular photometry and detailed sp ectral power distribution have to be considered. In this paper we focus on the spectral power distribution. .. In this paper we propose three new indices to characterize lamp spectra. These indices have been designed to allow a quick estimation of the potential impact of a lamp spectrum on melatonin suppression, photosynthesis, and star visibility. We used these new indices to compare various lighting technologies objectively. We also considered the transformation of such indices according to the propagation of light into the atmosphere as a function of distance to the observer. Among other results, we found that low pressure sodium, phosphor-converted amber light emitting diodes (LED) and LED 2700 K lamps filtered with the new Ledtech’s Equilib filter showed a lower or equivalent potential impact on melatonin suppression and star visibility in comparison to high pressure sodium lamps. Low pressure sodium, LED 5000 K-filtered and LED 2700 K-filtered lamps had a lower impact on photosynthesis than did high pressure sodium lamps. Finally, we propose these indices as new standards for the lighting industry to be used in characterizing their lighting technologies.

Solid-State Roadway Lighting Design Guide: Volume 1: Guidance. National Academies of Sciences, Engineering, and Medicine. 2020. https://doi.org/10.17226/25678

Solid-State Roadwazy Lighting Design Guide: Volume 2: Research Overview. National Academies of Sciences, Engineering, and Medicine. 2020. https://doi.org/10.17226/25679

Assessment of Citizens’ Actions against Light Pollution with Guidelines for Future Initiatives. Zielińska-Dabkowska, K.M.; Xavia, K.; Bobkowska, K. Sustainability. June 2020, 12, 4997. https://doi.org/10.3390/su12124997
Abstract excerpt: This paper therefore investigates the various actions taken by citizens, as well as the challenges, methods, and tools involved, regarding good practices initiated by grass roots activism on how to reduce existing and potential light pollution.

The results of a comparative analysis of 262 international case studies (lawsuits and online petitions) reveal that, since th e 1990s, there has been an increase in the number of legal cases related to light pollution due to the rise in public awareness, the availability of scientific knowledge via the Internet, and the ability to take accurate lighting measurements and perform lig hting simulations. Also, in the last decade a new tool for digital participation in the form of online petitions has established a new movement of citizen action to mitigate the effects of light pollution. Based on this information, a seven -step framework involving recommendations for citizen action has been developed. It is expected that this new knowledge will benefit those citizens planning future efforts involving the development, implementation, and monitoring processes of outdoor lighting. Additionally , it might support the evolution of planning and policy approaches that are sustainable and necessary to improve the application and installation of ecologically/biologically responsible illumination for towns, cities, and natural habitats.

Nevada Senate passes bill to form ‘dark sky places’ program. Feb 22, 2021. By Sam Metz, AP News https://apnews.com/article/legislature-nevada-light-pollution-coronavirus-pandemic-kate-marshall- eb0f69ee3c5895b1f7dd4d89b1ea3ebc
Nevada’s state Senate took a step toward ensuring stargazers will continue to enjoy picture -perfect constellations on Monday, passing a bill to recognize “dark sky places” with unobstructed views of galaxies hundreds of thousands of light years away.

14 Urban Lighting Research Transdisciplinary Framework—A Collaborative Process with Lighting Professionals. Pérez Vega, C.; Zielinska-Dabkowska, K.M.; Hölker, F. Int. J. Environ. Res. Public Health. 2021, 18, 624. https://doi.org/10.3390/ijerph18020624
Abstract Excerpt: Over the past decades, lighting professionals have influenced the experience of the night by brightly illuminating streets, buildings, skylines, and landscapes 24/7... a dual perspective on night-time was shaped and the visual enjoyment of visitors after dusk was prioritized over natural nightscapes (nocturnal landscapes). During this time, researche rs of artificial light at night (ALAN) observed and reported a gradual increase in unnatural brightness and a shift in color of the night - time environment. As a consequence, ALAN has been identified as a relevant pollutant of aquatic and terrestrial habitats, and an environmental stressor, which may adversely affect a wide range of organisms, from micro -organisms to humans... This paper presents a framework to help reduce the existing gap of knowledge, because appropriate lighting applications depend upon it.

Access to less light polluted nightscapes in urban environments is just as important as access to unpolluted water, food, and air.

On-line Workshop “Dark and Quiet Skies for Science and Society", Report and Recommendations , Dec 2020, coordinated by the United Nations Office for Outer Space Affairs
https://unoosa.org/oosa/en/ourwork/psa/schedule/2020/2020_dark_skies.html to propose to COPUOS [United Nations Committee on the Peaceful Uses of O uter Space]... recommendations, to be acted upon either by local governments or agreed to at an international level... This report analyses all artificial interference that c an have a negative impact on the visibility of the night sky. These interferences can be logically grouped into three categories... effect caused by the artificial emission of visible light during the night,... impact that the very large number of communication sa tellites in Low Earth Orbit... to the interference that radio broadcasting... have on observations by radio telescopes.

Grasping darkness: the dark ecological network as a social-ecological framework to limit the impacts of light pollution on biodiversity. Challéat, S., et al. 2021. Ecology and Society 26(1):15. https://doi.org/10.5751/ES-12156-260115
Abstract excerpt: Artificial light at night (ALAN)... is increasingly recognized as a major threat to global biodiversity, which ultimately alters the amount, the quality, and the connectivity of available habitats for taxa... Here we present the concept of “dark ecological network.” We show this concept is able to grasp the effects of ALAN in terms of habitat disturbances and integrate s temporal dimensions of ecological processes into biodiversity conservation planning... we propose a course of action that consists of building an interdisciplinary repertoire of contextualized knowledge (e.g., impacts on wildlife, human/lightscape relation ship, existing legal tools, etc.), in order to deduce from it a number of practical supports for the governance of the dark ecological network in response to societal and ecological issues.

3. Comments and Responses

City of Mountain View Housing Element Update 3-55 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter O-2 Response: SCVAS & GreenSpacesMV, September
5, 2022

O-2-1 The City of Mountain View appreciates input from the SCVAS and GreenSpacesMV concerning their interest in potential impacts to biological resources, especially in the North Bayshore planning area. The comment states that the North Bayshore Precise Plan requirements and development standards should be updated to reflect new scientific knowledge in three topic areas that are described in subsequent comments:
lighting, loss of trees, and protection of burrowing owls at Shoreline Park. The introductory comment does not cite a deficiency in the Draft EIR and is noted.

O-2-2 Citing several credible sources, the comment states that the adopted North Bayshore Precise Plan should be amended to greater regulate outdoor LED light fixtures and thereby minimize the impacts of night lighting on wildlife. Through provided citations, the comment frames a discussion that certain types of lighting, specifically some LED lights, can negatively affect wildlife species. Several lighting management recommendations are provided which include eliminating minimum lighting requirements, reducing light brightness, requiring low Kelvin color temperature bulbs on outdoor lighting (2400 Kelvin or less), and the use of dimmers on outdoor lights.

The comment only generally states that outdoor lighting can have negative effects on wildlife without specific mention of deficiencies in the DEIR analysis or a description of a specific mechanism by which wildlife species would be negatively affected by lighting. As the DEIR discloses, much of the planned new housing would be infill development that is away from avian movement corridors and distant from areas with natural wildlife habitat. The North Bayshore Precise Plan presently requires the incorporation of bird safe design measures for new construction and major renovations in the North Bayshore Precise Plan (Draft EIR, p. 4.3-26); however, the City does not have a “bird safe and dark sky” ordinance that addresses the topic of light pollution. Given the infill nature of the Project within developed portion of the City and the absence of a local ordinance that provides a nexus for impact significance, potential impacts to wildlife related to lighting would be less than significant and would not require mitigation. The suggestions from SCVAS and GreenSpacesMV and copies of the International Dark-Sky Association article, “Artificial Light at Night: State of the Science 2022” have been included in the record, where they may be considered by the City as part of the decision-making process.

O-2-3 The comment is concerned that the Project will impact urban trees and that there are inadequate locations to plant replacement trees, which it concludes will result in a loss of trees and tree canopy within the City. The comment further requests an analysis of potential impacts to trees and replacement sites, stating that if trees and canopy cannot be replaced in a reasonable timeframe, then the impact should be considered significant and unavoidable. The City plans to preserve and manage the

3. Comments and Responses

City of Mountain View Housing Element Update 3-56 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 existing urban forest, with no substantial changes in urban tree canopy under the proposed Project. The City of Mountain View’s Forestry Division recognizes urban trees as a valuable community resource. As such, the City closely regulates the removal of heritage trees, which it defines as any tree with a trunk circumference of 48” or more, measured at 54” above the natural grade, and any oak, redwood, or cedar tree with a circumference of 12” or more when measured 54” above natural grade. The City maintains a detailed process to remove trees, which requires approval by a certified arborist and a required planting plan. In keeping with the City’s commitment to preserve its urban forest, the review of new developments under the HEU will include an evaluation of open space and landscaping plans. Tree removals performed under approved HEU projects would be done on a case-by-case basis in compliance with existing City policies protecting heritage trees under the direction of a qualified arborist and with an approved replanting plan.

O-2-4 The comment relates to the management and recovery of the burrowing owl population at Shoreline Park. It states that despite informational signage and ranger patrols, disruptive behaviors by humans and dogs continue to have a detrimental effect on owls. With the planned additional residences in the North Bayshore area, the comment speculates that encroachments into owl habitat will continue. As a remedy, the comment suggests the use of fencing around the park to make the area inaccessible to the public after hours. The North Bayshore Precise Plan area is the closest planning area to Shoreline Park. As noted in the Draft EIR (p. 4.3-9), the City supports an ongoing burrowing owl monitoring and management program in the park. The DEIR also recognized that the increased presence of people, pets (dogs and cats), and children related to residential development could have indirect impacts to burrowing owls at Shoreline Park (Draft EIR p. 4.3-15). The City of Mountain View Parks Division manages Shoreline Park as a recreational multi-use area for the benefit of burrowing owls. City biologists continue to identify and resolve potential wildlife management conflicts at Shoreline Park as they occur, including the ongoing monitoring, management, and protection of burrowing owls. Should park staff identify recreational conflicts with burrowing owls, they will respond accordingly in keeping with the 2017-2023 Parks, Recreation & Open Space Plan, and the forthcoming Shoreline Wildlife Management Plan. In summer 2022, the City solicited comments on the Shoreline Wildlife Management Plan, which was the appropriate vehicle to suggest fencing options for owl protection. With these protections in place, even with a potential increase in local recreational pressure at Shoreline Park, the existing park management plans provide an appropriate means to manage burrowing owl populations within the City of Mountain View. No additional impacts were identified in the comment and no mitigation is required to address this indirect, less than significant impact.

From: Hala Alshahwany
To: Yau, Ellen; , Planning Division
Cc: , City Manager; City Council
Subject: Housing Element EIR Input
Date: Saturday, September 3, 2022 7:00:10 PM
CAUTION: EXTERNAL EMAIL - Ensure you trust this email before clicking on any links or attachments.

Hello Ms. Yau, City Staff, and Council Members,
Thanks for the opportunity to comment on the draft EIR for the Housing Element proposal.

The project’s goal is to add 15,000 new residential units in MV to meet the next RHNA cycle requirements, adding significant population (30,000+ individuals), buildings and infrastructure to support this large increase.

I found the report lacking in addressing the serious adverse impacts of this project on existing residential population and natural resources and habitats in the city. The listed objectives on p.2-6 do call for protection of existing housing, encouraging new ones, removing constraints and providing fair housing, but when I looked at the potential impacts of various aspects of this big undertaking, the impacts descriptions were unrealistic and unsound, leading to very few mitigations, if any, to be presented.

The critical impacts in many sections were nearly all described as “non-conflicting” ones, listing no significant or adverse effects. This was clearly the approach in p.2-9 section 4.2 Air Quality, p.2-12, section 4.3 Biological Resources, p.2-17 section 4.7 GHG Emissions, p.2- 19 section 4.10 Land Use and Planning, p.2-20 section 4.11 Noise, and p.2-12 section 4.13 Public Services and Recreation.

Typically impacts are listed and then evaluated through assessment and mitigation columns.

Listing most of the above impacts as “non conflicting” is very misleading, because it’s making an assumption that may or may be accurate. This evaluation seems ludicrous to me. The impacts should clearly be listed and then evaluated accordingly, without assumptions.

The magnitude of this project is logistically huge on a city our size. Constructing significant number of buildings and bringing nearly 40% more people with all the infrastructure needs should have significant impacts on every section listed above. This doesn’t even include the Transportation section 4.14 p.2-23. The mitigations listed for the latter have shown to be ineffective in the past, and there is no guarantee they will work on this large scale proposal.

Please re-evaluate the significance of these impacts using better consultants and tools, and present an accurate and realistic assessment of how it can be accomplished while keeping us and our environment healthy and sustainable.

Thank you.

Hala Alshahwany
Cuesta Park Resident

3. Comments and Responses

City of Mountain View Housing Element Update 3-58 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Letter I-1: Hala Alshahwany, September 3, 2022

I-1-1 This is a general comment and does not identify specific issues other than general assertions of inadequacy, and, thus, no response is required. Throughout Chapter 4 the Draft EIR evaluates over 80 project-specific impacts as well as cumulative impacts and identifies 11 mitigation measures to avoid or reduce the severity or magnitude of significant impacts (also see Chapter 2, Summary).

The Draft EIR evaluated the potential for approximately 15,000 multi-family housing units (including approximately 96 accessory dwelling units) during the HEU planning period as a maximum scenario for purposes of the CEQA evaluation, understanding that the buffer size and the final sites selected for inclusion in the Housing Element will be determined by the City Council upon adoption of the HEU.

It is important to note that approximately 13,600 units are already allowed under the City’s adopted General Plan, zoning, and Precise Plans, and this development potential has been studied previously for potential environmental impacts in the larger Precise Plan EIRs and/or the City’s General Plan EIR. The remaining 1,400 units would be created through rezonings and General Plan amendments. In addition, the EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately 2,700 units beyond 2031.

As such, only a small percentage of increased development potential (approximately 4,100 units) would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans. While State law requires the Housing Element to include an inventory of housing sites and requires the City to appropriately zone sites for multifamily housing, the City is not required to actually develop/construct housing on these sites. Future development on identified sites would be at the discretion of individual property owners and would be largely dependent on market forces and -- in the case of affordable housing -- available funding and/or other incentives. Nonetheless, this EIR considers potential impacts of development that may result from adoption of the HEU, focusing on proposed actions to encourage housing production such as changes in allowable densities, changes in development standards, and adoption of incentives.

This EIR is a Program EIR, which has been prepared to evaluate the anticipated environmental effects of the proposed HEU in conformance with the provisions of CEQA and the CEQA Guidelines. As a program EIR, this EIR analyzes potential impacts of development that would be allowed by the HEU without having site- specific development proposals in hand, and broadly considers proposed sites, their environmental setting, and potential impacts that could stem from their development.

Readers will note that the level of detail is different than in a project-specific EIR, which generally considers a single, specific proposal on an individual site. Future discretionary actions that would be facilitated by the HEU’s adoption, such as those

3. Comments and Responses

City of Mountain View Housing Element Update 3-59 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 related to the development of housing, would be assessed to determine consistency with the analysis provided in this program EIR.

I-1-2 It is unclear what the commenter is referring to as “non-conflicting” impacts. As discussed in Section 4.0 of the Draft EIR, impacts are classified as significant or less than significant. A Project impact is considered less than significant when the physical change caused by the project would not exceed the applicable significance threshold. A Project impact is considered significant if the Project would result in a substantial adverse change in the physical conditions of the environment. Significant impacts are identified by the evaluation of Project-related physical changes compared to specified significance thresholds, which may be qualitative or quantitative (Draft EIR p. 4.0-2). After mitigation is applied, impacts are classified as less than significant with mitigation or significant and unavoidable with mitigation.

The commenter then lists various pages and topics in the Summary Chapter of the Draft EIR (Chapter 2), but does not identify specific issues other than general assertions of inadequacy. As provided by Section 15123 of the CEQA Guidelines, Chapter 2 of the Draft EIR provides a brief summary of the HEU and its consequences. Chapter 2 is intended to summarize in a stand-alone section the Project described in Draft EIR Chapter 3, Project Description, the impacts and mitigation measures discussed in Draft EIR Chapter 4, Environmental Setting, Impacts, and Mitigation Measures, and the alternatives analysis presented in Draft Chapter 5, Alternatives to the Project.

The commenter is directed to the Draft EIR Chapter 4, Environmental Setting, Impacts, and Mitigation Measures, which is divided into technical sections (e.g., Section 4.2, Air Quality) that present the physical environmental setting, regulatory setting, significance criteria, methodology and assumptions, and impacts on the environment for each environmental resource issue area. Where required, potentially feasible mitigation measures are identified to lessen or avoid potentially significant impacts. Each section includes an analysis of project-specific and cumulative impacts for each issue area. Specifically, see Draft EIR Section 4.2, Air Quality; Section 4.3, Biological Resources; Section 4.7, Greenhouse Gas Emissions; Section 4.10, Land Use and Planning; Section 4.11, Noise; and Section 4.13, Public Services and Recreation.

I-1-3 This is a general comment and does not identify specific issues other than general assertions of inadequacy. See Response to Comment I-1-2 that directs the commenter to the information presented in the Draft EIR for the topics identified in the previous comment. With regard to impacts related to transportation, Section 4.14, Transportation, of the Draft EIR presents the physical environmental setting, regulatory setting, significance criteria, methodology and assumptions, and impacts on the environment for this topic.

3. Comments and Responses

City of Mountain View Housing Element Update 3-60 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Based on the adopted transportation policy, most residential projects will reduce vehicle miles traveled (VMT), the metric for measuring CEQA transportation impact and will meet the City’s adopted thresholds. This measure of transportation impact measures the benefit of much needed housing in the region and quantifies the benefit in reduced vehicle travel by reducing the vehicle miles between housing and employment.

However, projects that do not meet the City adopted policy, Mitigation Measure TRA-1, Implement VMT Reduction Measures, was identified to reduce potentially significant VMT impacts associated with implementation of the proposed HEU.

Individual multifamily housing development proposals that do not screen out from VMT impact analysis would be required to provide a quantitative VMT analysis using the methods outlined by the City’s most recent VMT guidelines. Projects that result in a significant impact would be required to include travel demand management measures and/or physical measures (i.e. improving multimodal transportation network, improving street connectivity) to reduce VMT. The City’s VMT guidelines identify four tiers of mitigation measures, all of which can be quantified within the VTA VMT tool. The measures contained within VTA’s VMT tool are based on supporting studies which demonstrate the effectiveness of the VMT reductions.

Additionally, development projects proposed under the HEU that generate at least 20 net new peak-hour trips (or those within a Precise Plan area) would require completion of a Multi-modal Transportation Analysis (MTA) during the entitlement process, which would address many non-CEQA transportation concerns. The MTA would ensure that the proposed development conforms with City policies (including traffic calming, neighborhood intrusion, and enhancing publicly accessible bicycle, pedestrian, and transit connections), that adequate multimodal site access and circulation are provided, appropriate fair-share fees are identified, and that operational improvements support pedestrian, bicycle, and transit quality of service.

I-1-4 This is a general comment and does not identify specific issues other than general assertions of inadequacy. The Draft EIR meets all requirements of CEQA, including detailed analyses of potential direct, indirect, and cumulative impacts on the environment supported by a long list of references and exercise of appropriate methodologies and professional judgement, and provides enforceable mitigation measures for the significant impacts identified (Draft EIR Chapter 4).

3. Comments and Responses

City of Mountain View Housing Element Update 3-61 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

3.4 Responses to Public Hearing Comments
This section presents responses to verbal comments received on the Draft EIR at the City of Mountain View EPC meeting held on Wednesday, August 3, 2022. Responses are presented to summarized verbal comments, grouped by topic. Rather than responding individually and repetitively, grouped responses by topic have been developed to address such comments comprehensively. Responses focus on comments raised that pertain to the adequacy of the analysis in the EIR or to other aspects pertinent to the potential effects of the Project on the environment pursuant to CEQA.

EPC Comment Response 1: Water Supply
A number of comments were provided on the HEU’s effects on water supply and whether adequate water supply would be available to accommodate the growth anticipated by the proposed HEU in addition to existing commitments and drought-related conditions.

Potential impacts on water supply were discussed in Section 4.15, Utilities and Service Systems, of the Draft EIR. The thresholds used to determine the significance of impacts related to water supply were based on Appendix G of the CEQA Guidelines. Implementation of the HEU could have a significant impact on the environment related to water supply if there are not sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years (Draft EIR p. 4.15-15).

As discussed in the Draft EIR, implementation of the HEU would result in increased demand for potable water. The total number of dwelling units exceed the previously anticipated housing units studied in the City’s 2020 Urban Water Management Plan (UWMP) by approximately 11,100 dwelling units. As such, a water supply assessment (WSA) was prepared for the HEU by Schaaf & Wheeler on behalf of the City of Mountain View (Draft EIR Appendix D). The total water demand projected for the HEU at build-out beyond what was included in the City’s 2020 UWMP was estimated to be approximately 1.1 million gallons per day (mgd) or 1,244 acre-feet per year (AFY) and represents the estimated increase beyond the City’s 2020 UWMP as a result of the HEU, including the water demands of the residential buildings and surrounding landscaping.

These estimates are conservative as they do not account for existing water use credits for redevelopment sites, on-site water conservation efforts such as landscaping with low water use plants, the use of recycled water for irrigation, dual plumbing and low flow sanitary fixtures, and technologies associated with LEED construction (Draft EIR p. 4.15-19). As such the WSA presented a “worst-case scenario” with regard to the projected water demand anticipated as a result of the proposed HEU.

The Draft EIR concluded that the City of Mountain View water system has sufficient existing water supply to fully support development under the HEU above what was considered in the 2020 UWMP under normal, single dry, or multiple dry water years (Draft EIR p. 4.15-19). “Single and multiple dry year” conditions account for the “drought conditions” that were raised as an issue of concern during the EPC hearing. The WSA described that shortfalls of up to 20% are projected for single dry-years and for multiple dry-years. Under all conditions, the City may need to impose water conservation measures, per Mountain View Municipal Code, Section 35.28, to reduce

3. Comments and Responses

City of Mountain View Housing Element Update 3-62 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 demand. Additionally, depending on the final outcome and implementation of the State Water Resources Control Board’s Bay Delta Water Quality Control Plan, Mountain View’s primary water supply from the San Francisco Public Utilities Commission may be reduced significantly during dry years. Although the status of the Bay Delta Plan is still undetermined, Mountain View plans to utilize local groundwater wells as needed during dry years in order to limit cutbacks to 20 percent, and implement the City’s Water Shortage Contingency Plan to reduce water demand during droughts (Draft EIR p. 4.15-19).

It is also noted that the new construction anticipated as a result of the proposed HEU, would comparatively be more water efficient than existing construction in the City. As described in the Draft EIR, projects developed as a result of the HEU would be required to comply with the CALGreen Code, which requires that new construction use high-efficiency plumbing fixtures, such as high-efficiency toilets, urinals, showerheads, and faucet fixtures. For outdoor water use, the CALGreen Code requires that irrigation controllers be weather- or soil moisture–based and automatically account for rainfall, or be attached to a rainfall sensor. Additionally, the projects would be required to comply with Standard Condition of Approval (Landscaping) and the City of Mountain View Water Conservation in Landscaping Regulations and the Mountain View Green Building Code (MVGBC) which include water conservation requirements. Under the MVGBC, new buildings must use water-efficient plumbing fixtures or demonstrate a 20 percent reduction from a baseline water use. City Standard Conditions of Approval also require projects to install plants with low water requirements and include efficient irrigation systems in landscape design.

Implementation of water conservation and efficiency measures would minimize the potable water demand generated (Draft EIR p. 4.15-20).

Additionally in response to comments regarding increasing the use of recycled water, projects developed within the North Bayshore Precise Plan area would be required to use recycled water for irrigation and projects developed within the East Whisman Precise Plan area would be required to construct recycled water compatible irrigation systems for connection to future extension of the recycled water system to the area, which would also reduce the potable water demand (Draft EIR p. 4.15-20). The City’s 2022 Recycled Water Feasibility Study, analyzed the feasibility of providing recycled water supply to areas not currently served by recycled water, including the East Whisman area and other areas of the City including the commercial areas of Castro Street, the San Antonio Precise Plan area, and Downtown. The study recommended near- term recycled water expansion throughout the North Bayshore area and a future expansion, via Middlefield Road, to serve the East Whisman area. Expansion to areas outside of North Bayshore and East Whisman is considered very long term and should not be considered until additional supply is procured, and the system is expanded to East Whisman. 7 None of the comments that were submitted during the Draft EIR’s circulation period related to water supply have raised any new environmental issues or presented any significant new information that has not already been adequately described and evaluated in the Draft EIR, or effectively supplemented and clarified in this response. Therefore, no further response is required.

7 City of Mountain View, 2022. Recycled Water Feasibility Study, March 2022. Available at:
https://www.mountainview.gov/civicax/filebank/blobdload.aspx?BlobID=37451.

3. Comments and Responses

City of Mountain View Housing Element Update 3-63 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 All water supply-related comments and issues of concern, however, will be forwarded to the applicable decisionmakers as they consider whether or not to approve the HEU.

EPC Comment Response 2: Parks and Recreation
A number of comments expressed concern over the adequacy of existing and future parkland in the City to support the increase in population as a result of the HEU. Comments also expressed concern that a significant parks and recreation impact could occur due to the level of growth and the overestimation of parkland in the City due to the inclusion of Shoreline at Mountain View Regional Park in the calculations.

Potential impacts related to parks and recreation were discussed in Draft EIR Section 4.13, Public Services and Recreation. Potential direct impacts to parks were discussed relative to potential substantial adverse physical impacts associated with the provision of new or physically altered park facilities, or the need for new or physically altered park facilities, as directed by the Significance Thresholds defined in Appendix G of the CEQA Guidelines. Similarly, potential direct impacts to recreation are discussed related to the accelerated substantial physical deterioration of recreational facilities and the construction/expansion of recreational facilities.

Implementation of the HEU could have a significant impact on schools if: (1) it would require the construction of new or physically altered parks and recreation facilities in order to maintain acceptable levels of school services; and (2) the construction or alteration of such parks and recreation facilities would result in a substantial adverse physical impact on the environment (Draft EIR p. 4.13-12). CEQA regulations and applicable case law on this issue demonstrate the threshold concerns only the environmental effects associated with the provision of new or altered physical public service facilities.
8 While comments also questioned the feasibility of achieving the General Plan goal of 3 acres of parkland per 1,000 residents due to space limitations in the City. Parkland service goals and other performance objectives are relevant to the analysis only within the context of whether or not new or expanded facilities would be required to meet defined criteria related to those service objectives, and what the environmental effects would be of providing those facilities.

The Draft EIR disclosed information pertaining to the City’s goal of 3.00 acres of open space per 1,000 residents with and without inclusion of the North Bayshore Planning Area open space (containing Shoreline at Mountain View Regional Park). The Draft EIR found that the HEU would worsen existing parkland deficiencies in the City when the North Bayshore Planning Area is excluded. As the residential population of Mountain View increases as a result of the HEU, the construction of new parks and recreation facilities in the City would occur and individual projects under the HEU would be subject to the City’s Parkland Dedication Ordinance, which requires land dedication or payment of a fee in lieu thereof. The park projects developed as a result of the Park Land Dedication Ordinance would be required to undergo environmental review as they are identified. Appropriate measures would be identified and implemented as applicable to reduce any

8 CEQA Guidelines Section 15382 restricts the effects that CEQA mitigation addresses to those “significant effects on the environment” which are defined to include “adverse change in any of the physical conditions within the area affected by the project” “An economic or social change by itself shall not be considered a significant effect on the environment.” 14 Cal. Code Regs. §15382.

3. Comments and Responses

City of Mountain View Housing Element Update 3-64 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 construction-related or operational effects of those facilities. As such parkland impacts were determined to be less than significant (Draft EIR p.4.13-18-19). As a matter of information, when the North Bayshore Planning Area containing the regional open space is included the City well exceeds its established goal.

Regarding impacts to existing parks and recreational facilities, the Draft EIR found that the Project’s impacts related to accelerated substantial physical deterioration of parks and recreational resources would be less than significant and no mitigation would be required (Draft EIR p. 4.13-17). While no specific development proposals are directly associated with the HEU, theoretical development would result in an increase in population and thus an increased use in existing neighborhood and regional parks, and recreational facilities; however, there is no evidence to suggest that the potential increase in recreational users would substantially increase or accelerate the physical deterioration or degradation of nearby recreational facilities, such that mitigation would be required for physical impacts related to the construction/expansion of existing recreational facilities.

Comments also expressed concern in general over the cumulative impact on parks. As discussed in the Draft EIR, the HEU, in combination with cumulative projects in the City would incrementally increase the demand for and use of existing parks and recreation facilities. Similar to the HEU, cumulative development would be subject to the City’s standard conditions of approval and Park Land Dedication Ordinance that contribute to long-term parks and recreational facilities planning and capacity improvements. The park projects developed as a result of the Park Land Dedication Ordinance would be required to undergo environmental review as they are identified. The City would also be required to ensure compliance with General Plan Policies POS-

1.1 and POS-1.2 related to the demand for parks and recreational facilities (Draft EIR p. 4.13-20).

Comments were also raised expressing concern over the joint-use agreements with local school districts to share the use of recreational resources. As discussed in the Draft EIR, school sites are an important part of the City’s park system as many residents rely on nearby schools to provide neighborhood recreational resources (Draft EIR p. 4.13-4). Consistent with General Plan Policy POS-5.1, the City will continue cooperative arrangements with school districts to use open space and facilities at schools for public parks, playgrounds and recreation programs and establish new arrangements as conditions evolve in the City.

None of the comments that were submitted during the Draft EIR’s circulation period related to parks and recreation have raised any new environmental issues or presented any significant new information that has not already been adequately described and evaluated in the Draft EIR, or effectively supplemented and clarified in this response. Therefore, no further response is required.

All parks and recreation-related comments and issues of concern, however, will be forwarded to the applicable decisionmakers as they consider whether or not to approve the HEU.

3. Comments and Responses

City of Mountain View Housing Element Update 3-65 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 EPC Comment Response 3: Cumulative Impacts
A number of comments also expressed general concern regarding cumulative impacts of the Project on public services, transportation, and utilities.

Public Services
Comments also included concern over the cumulative impacts on fire and police services, and whether the impacts of a new fire or police station should be studied. As also described in EPC Comment Response 2, CEQA regulations and applicable case law on public services impacts demonstrate the threshold concerns only the environmental effects associated with the provision of new or altered physical public service facilities. As discussed in Draft EIR Section 4.13, additional fire and police protection facilities are not expected to be required to serve the population as a result of the HEU. However, if and when the construction or expansion of facilities to accommodate additional personnel or equipment should become necessary, CEQA review, General Plan provisions, Municipal Code regulations, and payment of impact fees would all be required. It is noted that the Mountain View Police and Fire Departments are working on plans for a new headquarters building, which would likely replace the facility on the current site with a new two-story building. Fire stations in the City could also potentially require remodeling, expansion, or rebuilds in the future to serve cumulative demand. While the proposed HEU would contribute to the need for these facilities, potential impacts would remain less than significant.

Consistent with the analysis in the Draft EIR, if and when the construction or expansion of facilities to accommodate additional personnel or equipment should become necessary, CEQA review, General Plan provisions, Municipal Code regulations, and payment of impact fees would all be required.

Specific concerns regarding cumulative impacts related to schools and specifically the high school district were also raised. See Responses to Comment Letter A-3 from MVLA with regard to impacts on schools and MVLA specifically.

Transportation
Concern regarding cumulative traffic impacts in general were also raised. Cumulative impacts related to transportation were discussed in Section 4.14, Transportation. The Draft EIR found that with implementation of the HEU, in combination with cumulative development, cumulative impacts related to conflicts with circulation-related plans, VMT, traffic safety hazards, and emergency access would all be less than significant (Draft EIR p. 4.14-25-26). It is also noted that traffic congestion or measures of vehicular delay are not an environmental impact under CEQA per State CEQA Guidelines Section 15064.3.b. However, as described in Response to Comment A-3-13 above, development projects proposed under the HEU that generate at least 20 net new peak-hour trips (or those within a Precise Plan area) would require completion of a Multi-modal Transportation Analysis (MTA) during the entitlement process. The MTA would ensure that the proposed development conforms with City policies (including traffic calming, neighborhood intrusion, and enhancing publicly accessible bicycle, pedestrian, and transit connections), that adequate multimodal site access and circulation are provided, appropriate fair-share fees are

3. Comments and Responses

City of Mountain View Housing Element Update 3-66 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 identified, and that operational improvements support pedestrian, bicycle, and transit quality of service.

Utilities and Service Systems
General concern regarding cumulative impacts to the City’s utility systems and payment of fair- share fees were also expressed. The Draft EIR found that with implementation of the HEU, in combination with cumulative development, cumulative impacts related to construction of utility infrastructure, water supply (see also EPC Comment Response 1), wastewater treatment capacity, and solid waste would be less than significant (Draft EIR p. 4.15-23-25).

As discussed in the Draft EIR, the scope of the City’s utility master plans includes development anticipated as a result of the City’s General Plan land use strategy, and recent certified Environmental Impact Reports and Precise Plans. This development includes General Plan growth estimates, plus growth affiliated with the North Bayshore, El Camino Real, East Whisman and San Antonio Precise Plans and approved recent Rezoning and General Plan Amendment projects, as these all have associated utility impact studies. As such, utility infrastructure and improvements as part of HEU for pipeline projects and opportunity sites that do not require rezoning would be included in the scope of the City’s utility master plans. However, development potential at the housing sites identified in the HEU for rezoning were not included in these projections. The City is currently preparing utilities studies for the water, sewer, and stormwater drainage systems for the areas proposed for rezoning to identify needed improvements, provide cost estimates associated with the needed improvements, establish funding mechanism(s), and/or incorporate into the City’s Capital Improvement Program (CIP). To ensure that subsequent development projects contribute their fair share toward CIPs identified by the City, based on the project’s determined contribution, Mitigation Measure UTL-1, Fair-Share Contributions Toward Utility Improvements, was identified (Draft EIR p. 4.15-16). Additionally, the City is currently updating its Water and Sewer Master Plans, which will identify and prioritize utility needs in the City and will help determine the level of investment needed over the next 10 years.

However, it is important to clarify that the impact under CEQA for utilities infrastructure is if implementation of the HEU would require or result in the relocation or construction of new or expanded utility infrastructure, the construction or relocation of which could cause significant environmental effects. The Draft EIR found that overall, the potential improvements or extension of utility infrastructure to serve development as a result of the HEU would be installed primarily in existing roadways and utility rights-of-way. Aside from short-term construction disturbance, no unusual or further environmental impacts would be generated beyond those identified elsewhere in this Draft EIR for overall construction activity for the project. As such, the implementation of the HEU would not require or result in the relocation or construction of new or expanded utility infrastructure, such that significant environmental effects would occur. As such Program-level and cumulative impacts were found to be less than significant.

3. Comments and Responses

City of Mountain View Housing Element Update 3-67 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 EPC Comment Response 4: Groundwater
Comments included concern over the treatment of groundwater as a resource for City water supply differing throughout the Draft EIR, specifically in Section 4.9, Hydrology and Water Quality, which was alleged to not include groundwater as a source of water supply for the City, and Section 4.15, Utilities and Service Systems, where the use of groundwater is acknowledged.

Contrary to the comment, Section 4.9 of the Draft EIR, contains information about the City’s water supply that includes the usage of water from groundwater supply wells (see Draft EIR p.

4.9-2-3) and the discussion under Impact HYD-2 includes information that while the City of Mountain View does not rely primarily on groundwater for its water supply, groundwater is used as a source for dry year supply (Draft EIR p. 4.9-19-20).

EPC Comment Response 5: No Project Alternative
Comments also included a question about the implications of not approving the proposed HEU.

Chapter 5, Alternatives to the Project, identifies the consequences of not adopting a housing element that is not compliant with State law. This alternative is analyzed consistent with Section 15126.6(e) of the CEQA Guidelines, which state that the No Project Alternative must include the assumption that conditions at the time the NOP of an EIR was circulated for public review would not be changed because the Project would not be implemented, as well as the events or actions that would reasonably be expected to occur in the foreseeable future if the Project were not approved.

The Draft EIR described that the No Project Alternative would also introduce a new significant and unavoidable impact related to land use and planning. The No Project Alternative would not meet any of the objectives of the HEU, nor is it legally feasible to implement. The No Project Alternative would not provide housing to fulfill the requirements of State law or meet the City’s RHNA requirements, which result in a significant and unavoidable land use and planning impact, as compared to the less-than-significant impacts associated with the proposed HEU and the Reduced Sites Alternative (Draft EIR pp. 5-18 – 5-19).

EPC Comment Response 6: Electric Vehicle (EV) Charging
Comments also included questions about the amount of required EV charging spaces and the desire for additional EV charging in general beyond 10% of spaces. EV charging requirements were discussed in Draft EIR Section 4.7, Greenhouse Gas Emissions. As discussed in Section 4.7, the City’s Reach Codes require multifamily residential buildings with more than three dwelling units to have at least 15% of the parking spaces to be installed with Level 2 EV chargers and a Level 3/DV Fast charger for every 100 spaces. The remaining parking spaces are required to be EV Ready.

3. Comments and Responses

City of Mountain View Housing Element Update 3-68 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 EPC Comment Response 7: Project Description
A number of comments requested clarification for items in Draft EIR Chapter 3, Project Description.

A comment was made specific to the HEU program related to housing on religious sites and whether this program was included in the analysis as a “back-pocket” site or program and how these were all addressed in the Draft EIR. As discussed in Chapter 3, the “Project” analyzed in the Draft EIR includes adoption of a General Plan amendment to add or modify goals, objectives, policies, and implementation programs related to housing in the Housing Element of the City’s General Plan. This includes potential impacts related to implementation of all HEU policies and programs, as well as housing sites included in the housing inventory. Draft EIR Chapter 5, explains that non-historic churches and other private non-profit institutions in residential (R) zoning districts were not included in the housing sites inventory. However, City staff has included a program in the Housing Plan (1.2 Community Sites for Housing) to evaluate changes to the City Code to allow for affordable residential uses on these sites to respond to Council interest in reviewing such sites.

Comments also requested clarification on the retail replacement provisions that would be applied in the updates to the zoning code as a result of the HEU. The following has been added to the Project Description in response to this comment on p. 3-14 of the Draft EIR (new text is underlined):
- Projects must provide minimum retail or similar neighborhood-serving uses, at a minimum, an amount to replace the existing commercial floor area or determined by an analysis of typical amounts of such uses in the underlying zone.

There was also a comment requesting to add specificity to the rezoning language in the Project Description related to parks. The following change was made in response to this comment in Chapter 3 of the Draft EIR on p. 3-14 (new text is underlined):

At least one public gathering/open space/plaza shall be provided, with a minimum area to be determined based on site size. Provide potential exemptions to one or more standards to facilitate provision of open space to maintain residential density with the goal of addressing neighborhood open space needs.

City of Mountain View Housing Element Update 4-1 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 CHAPTER 4
Errata to the Draft EIR

4.0 Introduction
This chapter describes changes made to the Draft EIR in response to comments received on the Draft EIR. The changes shown in this chapter update, refine, clarify, and amplify Project information and analyses presented in the Draft EIR.

4.1 Text Changes to the Draft EIR
This section summarizes text changes made to the Draft EIR either in response to a comment, initiated by City staff, or in response to a modification to the proposed HEU. New text is indicated in underline and text to be deleted is reflected by a strike through. Text changes (including changes to tables and figures in the Draft EIR) are presented in the page order in which they appear in the Draft EIR.

As indicated in Chapter 1, Introduction, the entirety of the HEU Final EIR consists of the Draft EIR, together with this Response to Comments document, including all appendices. Therefore, the Draft EIR changes presented in this chapter are incorporated in and supersede corresponding original text in the Draft EIR.

4.2 Implication of Changes to the Draft EIR
Under CEQA, recirculation of all or part of an EIR is required if significant new information is added after public review and prior to certification. According to State CEQA Guidelines Section 15088.5(a), new information is not considered 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.” More specifically, as discussed in Chapter 1, Introduction, of this document, pursuant to CEQA Guidelines Section 15088.5(a), recirculation of a Draft EIR is required only if:
“1) a new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented;
2) a substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance;

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-2 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 3) a feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the environmental impacts of the project, but the project’s proponents decline to adopt it; or
4) the draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.” None of the changes to the Draft EIR identified in this document meet any of the above conditions. Therefore, recirculation of any part of the Draft EIR is not required. The information presented in the Draft EIR and this document support this determination by the City. ______________________________

4.3 Changes to Chapter 3: Project Description

1. Based on updates to the Project (see Chapter 2 of this FEIR), the following text has been revised on p. 3-7 of the Draft EIR:

The HEU is required to identify housing sites to meet the City’s RHNA at specified levels of affordability. HCD recommends that jurisdictions plan for their RHNA plus a buffer of additional units equivalent to 15-30 percent. To be conservative, the City intends to identify a buffer of at least 2015 to 30 percent of units at all income levels and a total unit capacity of up to approximately 15,00018,000 units.

2. Based on updates to the Project (see Chapter 2 of this FEIR), the following text has been revised on p. 3-9 of the Draft EIR:

Existing Zoning and General Plan Capacity
Pipeline Projects. The City has approved a number of housing and mixed-use projects that are likely to result in production of multifamily housing during the housing element planning period. The City also has active applications on file for single family and multifamily housing and/or mixed use developments that may be approved, constructed, and occupied during the housing element planning period. These types of “pipeline projects” would count towards the City’s RHNA, and could collectively total at least 8,60011,418 units by 2031, not including pipeline rezoning projects (described below).

Accessory Dwelling Units. The City may assume that the development of accessory dwelling units (ADUs) during the planning period is equivalent to that in recent years. Based on information contained in the City’s annual production reports to HCD, approximately 96 ADUs are assumed over the eight year planning period.

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-3 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Existing Opportunity Sites. The City’s existing precise plans, General Plan Land Use designations, and zoning permit a range of residential densities in different areas of the City that can accommodate development of multifamily housing without adjustment. A preliminary analysis estimates that there may be sufficient sites to accommodate approximately 4,7006,265 units. Most of these sites are within Precise Plan areas, including El Camino Real, San Antonio, North Bayshore, Grant-Phyllis, and East Whisman, although there are sites identified for inclusion in the inventory in other areas of the City as well. See Figure 3-2 for a map showing City neighborhoods and precise plan locations.

3. Draft EIR Figure 3-3 on p. 3-10 has been revised to reflect changes to the Housing Sites Inventory since publication of the Draft EIR:

SOURCE: ESRI, 2022 City of Mountain View Housing Element Update

Figure 3-3
Housing Site Locations Overview

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-5 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

4. Based on updates to the Project (see Chapter 2 of this FEIR), the following text has been revised on p. 3-11 of the Draft EIR:

General Plan, Zoning and Precise Plan Amendments
Pipeline Sites Requiring Rezoning and General Plan Amendment. There are a limited number of sites that could accommodate multifamily housing – and in some cases specifically affordable housing for lower income households – if rezoned to allow residential use at appropriate densities. These sites, which include development projects under review and under discussion are located at, 1265 Montecito Avenue, 1020 Terra Bella Avenue, 1010 Linda Vista Avenue and East Evelyn Avenue between Highway 85 and Pioneer Way, and could accommodate approximately 580 units.

Rezonings Adopted with the Housing Element. T
he City proposes to adopt
Zoning and Precise Plan Amendments concurrent with this Housing Element Update, to clarify standards for allowed uses and densities at General Plan Village Centers and El Camino Real Village Centers. These amendments accommodate approximately 800664 units in the site inventory, but the total additional capacity of these areas is greater – approximately 2,500units1.

Opportunity Sites Requiring Rezonings and/or General Plan Amendments (“Back-Pocket" Areas). In the event that the above opportunities are inadequate to accommodate the RHNA, either at the time of Housing Element adoption or over the course of the 6th Cycle due to the “no net loss” law, the proposed Housing Element will also include programs to adopt additional rezonings and General Plan amendments in targeted urban infill areas (areas on previously developed sites and/or completely surrounded by urban uses):
• Moffett Boulevard
• Other shopping areas, such as Leong Drive, Bailey Park shopping center, Monta Loma Plaza
• A Joint Development at the Mountain View Transit Center • Other non-residential sites south of El Camino Real, such as 1949 Grant Road and offices near Blossom Valley Shopping Center
These rezoning opportunities could accommodate approximately 1,000 additional units, depending on the densities adopted.

Total Inventory. This EIR analyzes the impacts associated with the site inventory to 2031, an increase in approximately 15,00017,779 dwelling units, focused primarily along the commercial corridors and in areas that currently

1 This number is less than the total amount of units that could be allowed across these sites, since it is unreasonable to assume replacement of all existing uses over the horizon of this study. The number does consider the sites most likely to be redeveloped.

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-6 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 accommodate commercial/industrial uses, mixed uses, and/or multifamily housing.2 Of this, approximately 13,60016,530 units3 are already allowed under the City’s adopted General Plan, zoning, and Precise Plans and the remaining 1,400 1,250 units would be created through rezonings and General Plan amendments. In addition, the EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately 2,700 2,850 units beyond 2031 (described in detail above). More information is provided in Section 3.4.3 below.

5. Based on updates to the Project (see Chapter 2 of this FEIR), the following text has been revised on p. 3-12 of the Draft EIR:
4 The HEU is planning for the period from January 31, 2023 through January 31, 2031, and is expected to plan for approximately 15,00018,000 new housing units within this period, although the actual pace of development will depend on market conditions, property owner interest, and other factors. Also, of the approximately 15,00018,000 new units, only a small percentage would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans. However, development of these units may be accelerated compared to the theoretical No Project scenario, due to programs in the Housing Element that streamline, incentivize or remove constraints for housing.

6. Based on updates to the Project (see Chapter 2 of this FEIR), the Table 3-2 has been revised on p. 3-13 of the Draft EIR:

2 The actual site inventory in the current draft is closer to 14,80017,779. However, 15,00018,000 is a conservatively large round number and small changes to the site inventory are expected up to adoption, based on newly submitted applications.
3 Approximately 13,400 units in the current draft. See previous footnote. 4 Note that descriptions referencing 15,000 units in the technical topic sections of the Draft EIR have not been revised to reduce the volume of this chapter and FEIR, as they are typically for descriptive purposes only and revision would not meaningfully affect the analysis or conclusions of the Draft EIR.

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-7 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 TABLE 3-2
M OUNTAIN VIEW GROWTH PROJECTIONS FOR 2040

Existing
Baseline
(2020)
Under
Construction
Proposed HEU
(2021-2031)4
2031 Conditions
with Proposed
HEU
Cumulative
Growth no HEU
HEU
Contribution
to
Cumulative
Growth3
Cumulative
Growth with HEU
Dwelling Units 37,820 1,847 15,00018,000 54,70056,000 63,00066,000 4,100 67,10070,100 Population1 82,826 3,740 30,00036,000 116,600119,000 134,000140,000 8,200 142,200148,200 Jobs 101,965 8,800 02 120,000 133,000 02 133,000
NOTES:
1 Assumes an average of 2 persons per housing unit, based on the City’s projections. 2 Job growth is considered as background and is not part of the proposed HEU 3 Includes the Project’s contribution due to Rezoning and General Plan Amendments considered as part of the HEU. 4 Many of the units under construction are included in the 18,000 unit count.

SOURCE: City of Mountain View, MarchNovember 2022.

7. In response to verbal comments raised at the Environmental Planning Commission (EPC) public hearing on the Draft EIR, the following text has been added on p. 3-14 of the Draft EIR:
- At least one public gathering/open space/plaza shall be provided, with a minimum area to be determined based on site size. Provide potential exemptions to one or more standards to facilitate provision of open space to maintain residential density with the goal of addressing neighborhood open space needs.

8. In response to verbal comments raised at the EPC public hearing on the Draft, the following text has been added on p. 3-14 of the Draft EIR:
- Projects must provide minimum retail or similar neighborhood-serving uses, at a minimum, an amount to replace the existing commercial floor area or determined by an analysis of typical amounts of such uses in the underlying zone.
______________________________

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-8 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

4.4 Changes to Section 4.4: Cultural and Tribal
Cultural Resources

1. In order to update the intent of General Plan Action LUD 11.5.1 to the current data sources and procedures pertaining to cultural resources, Mitigation Measure CUL-2b has been revised to require a non-confidential records search from the NWIC. This search will document if there are previously recorded resources within or adjacent to the proposed project site and provide recommendations to the City as to whether a cultural resources study should be conducted to assess previously recorded resources and/or determine if there is archaeological sensitivity for unknown cultural resources in the proposed project area. The revisions to this mitigation measure do not affect or alter the analysis of impacts or conclusions identified in the Draft EIR.

The following text has been revised on pp. 4.4-23 of the Draft EIR:

To address this potentially significant impact, Mitigation Measure CUL-2a, Inadvertent Discovery of Cultural Resources revises the Discovery of Archaeological Resources Standard Condition to require a stop-work boundary around cultural material finds and establish protocol for avoidance or preservation in place of significant cultural resources, and Mitigation Measure CUL-2b, Cultural Resources Study Requirements establishes a requirement for a cultural resource study for all multifamily housing projects that require ground disturbance and are located within 0.25-mile of known cultural resources based upon review of the most recent and updated a NWIC non-confidential records search of the proposed project site list, consistent with General Plan Action LUD 11.5.1. These mitigation measures would address potential impacts to archaeological resources and reduce the potential of the HEU to impact archaeological resources to a less-than-significant level.

In accordance with the changes noted above, the following text has been revised on pp.

4.4-24-25 of the Draft EIR:

Mitigation Measure CUL-2b: Cultural Resources Study Requirements.

Prior to approval of development permits for multifamily projects that include ground-disturbing activities, City staffindividual project applicants shall review the most recent and updated request a non-confidential records search from the Northwest Information Center (NWIC) list: Historic Property Directory for the County of Santa Clara, to determine if known archaeological sites underlie the proposed project site has archaeological sensitivity. If the NWIC recommends that the proposed project site be reviewed by an archaeologist, it is determined that known cultural resources are within 0.25-mile of the project site, the City shall require a site-specific cultural resources study by an archaeologist meeting the U.S. Secretary of the Interior’s Standards (SOIS) for Archeology. The study shall consist of a cultural report that includes the results of: a cultural resources records search performed at the NWIC of the California Historical Resources

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-9 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 Information System for the project area, a pedestrian survey of the project area, a historic context, an assessment of the sensitivity of the project area for buried precontact and historic-era resources, and identify if the project would potentially impact cultural resources. If the archaeologist determines that known cultural resources or potential archaeological sensitivity areas may be impacted by the project, additional research or treatment, potentially including subsurface testing, and/or a cultural resources awareness training may be required to identify, evaluate, and mitigate impacts to cultural resources, as recommended by the SOIS qualified archaeologist. If avoidance is not feasible, the City shall consult with appropriate Native American tribes (if the resource is pre-contact or indigenous), and other appropriate interested parties to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3). The cultural report detailing the results of the research shall be prepared and submitted for review by the City and a final draft shall be submitted to the NWIC.
______________________________

4.5 C hanges to Section 4.8: Hazards and Hazardous
Materials

1. In response to Comment A-3-3, the following text has been added on p. 4.8-6 of the Draft EIR:

Proximity to Schools
The following public schools are located in Mountain View:
• Stevenson Elementary School at 750 San Pierre Way
• Theuerkauf Elementary School at 1625 San Luis Avenue
• Waldorf School of the Peninsula at 180 North Rengstorff Avenue • Landels Elementary School at 115 West Dana Street
• Mariano Castro Elementary School at 500 Toft Street
• St. Joseph Mountain View at 1120 Miramonte Avenue
• Monta Loma Elementary at 460 Thompson Avenue
• Springer Elementary School at 1120 Rose Avenue
• Benjamin Bubb Elementary School at 525 Hans Avenue

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-10 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 • Amy Imai Elementary School (previously Huff) at 253 Martens Avenue • Mountain View High School at 3535 Truman Avenue
• Alta Vista High School at 1325 Bryant Avenue
• Vargas Elementary School at 220 N Whisman Road
• Mistral Elementary School at 505 Escuela Avenue
• Graham Middle School at 1175 Castro Street
• Crittenden Middle School at 1701 Rock Street
A number of private schools including Waldorf School of the Peninsula (180 North Rengstorff Avenue), St. Joseph Mountain View (1120 Miramonte Avenue), St. Francis High School (1885 Miramonte Avenue), German International School of Silicon Valley (310 Easy Street), Mountain View Academy (360 S Shoreline Blvd), St. Stephen Lutheran School (320 Moorpark Way), and Khan Lab School (1200 Villa Street) are also located in the City.

There is also a proposed new school site for the Los Altos School District located at the corner of California Street and Showers Drive.

2. Also in response to Comment A-3-3, the following text has been revised on p. 4.8-22 of the Draft EIR:

As discussed in Section 4.8.2, Environmental Setting, Proximity to Schools, there are ten14 public schools and a number of private schools located within Mountain View. The accidental release or spill of hazardous materials transported through the vicinity near schools could expose school children and staff to hazardous materials.
______________________________

4.6 Changes to Section 4.13: Public Services and
Recreation

1. The following information has been corrected on page 4.13-1 of the Draft EIR based on input from the Mountain View Fire Department. These editorial changes do not affect or alter the analysis of impacts or conclusions identified in the Draft EIR.

Mountain View Fire Department
The Mountain View Fire Department (MVFD) exists to save lives and property, protect the environment, and minimize the risk of fire and natural disaster. The MVFD has a fire prevention division and environmental division which aim to precent prevent fires and injuries and limit the effects of fires and accidents. The Environmental Safety Section of the Fire Department implements State mandated water pollution control programs to minimize pollutant discharges into Mountain View creeks and the Bay. The MVFD has a multi-family inspection program to ensure proper maintenance of multi-family housing. MVFD firefighters are often the first responders and provide valuable services to the City including fire

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-11 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022 suppression, emergency medical treatment, technical rescue services, and response to hazardous materials releases (City of Mountain View, 2022a).

MVFD currently maintains 5 fire stations throughout the City. The MVFD fleet includes seven five type 1 engines (two additional type engines are reserve units), one rescue, one Haz Mat vehicle, and one aerial ladder truck (one additional aerial ladder truck as a reserve unit shared with the City of Palo Alto Fire Department) (City of Mountain View, 2022a). Station 1, located at 251 South Shoreline Boulevard, has an engine company, aerial ladder truck company, rescue company, and a battalion chief. Station 2, located at 160 Cuesta Drive, has two one engine company ies and a second 4x4 unit type 6 engine stored. Station 3, located at 301 North Rengstorff Avenue, has two one engine company ies,. A second engine is stored one of which is a California Office of Emergency Services (Cal OES) company. Station 4, located at 229 North Whisman Road, has three one type 1 engine 11ompanies (two additional engines are stored here as of which are reserves units), one reserve battalion chief, and one utility company pickup truck stored. Station 5, located at 2195 North Shoreline Boulevard, has an engine company, hazmat company unit stored, an aerial ladder truck company (reserve stored), and a utility terrain vehicle stored. All the stations have 3 members staff per shift, except for Station 1 which has 9 staff per shift (MVFD, 2021).

In 2021-2022, the MVFD had a total of 10,406 unit responses, which included 489
unit responses for fire-related call and 7,288 unit responses for rescue and EMS-related calls (MVFD, 2022). The MVFD regularly frequently achieves its goal of responding to each emergency call within six four minutes of dispatched time (City of Mountain View, 2021).

2. The following setting information on page 4.13-2 of the Draft EIR has been corrected based on input from the Mountain View Police Department. This editorial change does not affect or alter the analysis of impacts or conclusions identified in the Draft EIR.

Mountain View Police Department
The Mountain View Police Department (MVPD) provides police services in the City of Mountain View. Services include crime suppression, investigation, traffic enforcement, youth services, community education, neighborhood and event services, and a K-9 patrol. In 2020, the MVFD employed 181 full (143 full-time), regular, and limited period positions to serve the City population of 82,739. The MVFDMVPD has 1 police chief and 1 deputy police chief; the rest of the staffing falls into the categories of administration, field operations, special operations, or public safety support services. In 2020, the MVPD had 3 K9 teams (MVPD, 2020). There is one police station in the City, located at 1000 Villa Street (City of Mountain View, 2022b).

6. Errata to the Draft EIR
City of Mountain View Housing Element Update 4-12 ESA / 202000806 Response to Comments / Final Environmental Impact Report November 2022

3. The following information has been added to the setting section on page 4.13-3 of the Draft EIR related to public schools and parks. This editorial change does not affect or alter the analysis of impacts or conclusions identified in the Draft EIR.

Los Altos School District
The LASD operates nine schools serving the communities of Los Altos, Mountain View, Palo Alto, Los Altos Hills and unincorporated areas. There are seven elementary (K to 6th Grade) and two intermediate schools (grades 7 to 8).

District-wide enrollment during the 2021 to 2022 school year was 3,576 students (CDE, 2022c). The only LASD school located in Mountain View is Springer Elementary. Total enrollment at Springer Elementary during the 2021 to 2022 school year was 346 students in grades K-6 (CDE, 2022d). Additionally, there is also a proposed new school site for the LASD located in the City at the corner of California Street and Showers Drive, with a City park adjacent.

4. The following changes have been made on page 4.13-13 of the Draft EIR based on input from the Mountain View Fire Department. These editorial changes do not affect or alter the analysis of impacts or conclusions identified in the Draft EIR.

Implementation of the HEU would provide for the development of additional housing units and would result in an increase in the City’s population. While no specific development proposals are directly associated with the HEU, theoretical development would result in an increase in population and thus an increase in demand for fire protection and emergency medical response services from the MVFD. As discussed in Section 4.13.2, the MVFD regularly frequently (FY 21- 22 the goal of arriving in 4 minutes was met 42% of the time) achieves its goal of responding to each emergency call within 64 minutes of being dispatched. The MVFD target response time of 64 minutes is more stringent than the NFPA 1710 Standard, which stipulates that the first fire engine should arrive to 90 percent of emergency calls within a range of 6:15 and 6:45 minutes. It is likely that the increase in population as a result of HEU will affect current response times.

Travel time performance by region is variable and influenced by factors such as individual response unit workload, the size of the station, and the street system serving it.

4.7 Changes to Section 4.14: Transportation

1. In response to Comment A-1-6, the following footnote has been added to the bottom of p.

4.14-24 of the Draft EIR:
1 Some of the measures may primarily apply to employment projects or have studies supporting the VMT reductions that only provide evidence for employment projects. These measures are included for consideration for mixed-use residential projects.

______________________________
City of Mountain View Housing Element Update 1 ESA / 202000806 Final Environmental Impact Report November 2022

APPENDIX A
Mitigation Monitoring and Reporting Program
Purpose of this Document
This chapter contains the Mitigation Monitoring and Reporting Program (MMRP) prepared in compliance with Public Resources Code Section 21081.6(a). The MMRP will be considered for adoption by the Environmental Planning Commission (EPC) and/or the City Council and will aid the City in its implementation and monitoring of measures included in the EIR and adopted by the EPC and/or City Council.

A. Mitigation Monitoring and Reporting Program

City of Mountain View Housing Element Update 2 ESA / 202000806 Final Environmental Impact Report November 2022

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

M ITIGATION MONITORING AND REPORTING PROGRAM
Implemented By When Implemented Monitored By Verified By Air Quality
Mitigation Measure AIR-1: Emission Reduction Measures for Projects Exceeding the Significance Thresholds for Criteria Pollutants.

Project applicants proposing projects that exceed BAAQMD screening levels shall prepare a project-level criteria air pollutant assessment of construction and operational emissions at the time the project is proposed. The project-level assessment shall either include a comparison of the project with other similar projects where a quantitative analysis has been conducted, or shall provide a project-specific criteria air pollutant analysis to determine whether the project exceeds the BAAQMD’s criteria air pollutant thresholds.

In the event that a project-specific analysis finds that the project could result in criteria air pollutant emissions that exceed BAAQMD significance thresholds, the project applicant shall implement the following emission reduction measures to the degree necessary to reduce the impact to less than the significance thresholds, and shall implement additional feasible measures if necessary to reduce the impact to less than the significance thresholds.

Clean Construction Equipment.

1. The project applicant shall use electric construction equipment when feasible.

2. The project applicant shall ensure that all diesel off-road equipment shall have engines that meet the Tier 4 Final off-road emission standards, as certified by CARB, except as provided for in this section. This requirement shall be verified through submittal of an equipment inventory that includes the following information: (1) Type of Equipment, (2) Engine Year and Age, (3) Number of Years Since Rebuild of Engine (if applicable), (4) Type of Fuel Used, (5) Engine HP, (6) Verified Diesel Emission Control Strategy (VDECS) information if applicable and other related equipment data. A Certification Statement is also required to be made by the Contractor for documentation of compliance and for future review by the BAAQMD as necessary. The Certification Statement must state that the Contractor agrees to compliance and acknowledges that a violation of this requirement shall constitute a material breach of contract.

The City may waive the requirement for Tier 4 Final equipment only under the following unusual circumstances: if a particular piece of off-road equipment with Tier 4 Final standards is technically not feasible or not commercially available; the equipment would not produce desired emissions reduction due to expected operating modes; installation of the equipment would create a safety hazard or impaired visibility for the operator; or there is a compelling emergency need to use other alternate off-road equipment. For purposes of this mitigation measure, “commercially available” shall mean the availability of Tier 4 Final engines similar to the availability for other large-scale construction projects in the region occurring at the same time and taking into consideration factors such as (i) potential significant delays to critical-path timing of construction for the project and (ii) geographic proximity to the project site of Tier 4 Final equipment.

3. The project applicant shall require the idling time for off-road and on-road equipment be limited to no more than 2 minutes, except as provided in exceptions to the applicable state regulations regarding idling for off-road and on-road equipment. Legible and visible signs shall be posted in multiple languages (English, Spanish, Chinese) in designated queuing areas and at the construction site to remind operators of the 2-minute idling limit.

Project applicant During construction Community
Development
Department
Community
Development
Department

A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

M ITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 3 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By Operational Emission Reductions

1. Projects shall be constructed without natural gas infrastructure and shall be “all electric.”

2. As required by Mitigation Measure GHG-1, projects shall provide EV charging infrastructure consistent with the applicable Tier 2 CALGreen standards in effect at the time.

3. Project applicants that do not screen out from VMT impact analysis shall implement VMT reduction measures as required by Mitigation Measure TRA-1.

Mitigation Measure AIR-2: Emission Reduction Measures for Subsequent Projects Exceeding the Significance Thresholds for Health Risks from Construction.

Project applicants within the HEU area proposing projects within 1,000 feet of existing or approved sensitive receptors shall prepare a project-level HRA of construction impacts at the time the project is proposed. The HRA shall be based on project-specific construction schedule, equipment and activity data and shall be conducted using methods and models approved by the BAAQMD, CARB, OEHHA and U.S. EPA. Estimated project-level health risks shall be compared to the BAAQMD’s health risk significance thresholds for projects.

In the event that a project-specific HRA finds that the project could result in significant construction health risks that exceed BAAQMD significance thresholds, the project applicant shall implement Mitigation Measure AIR-1’s requirement for the use of all Tier 4 Final construction equipment to reduce project-level health risks to a less-than-significant level. In addition, all tower cranes, forklifts, man- and material- lifts shall be electric powered.

Project applicant Prior to construction Community
Development
Department
Community
Development
Department
Biological Resources
Mitigation Measure BIO-1: Special-Status Bat Protection Measures.

In coordination with the City, a preconstruction survey for special-status bats shall be conducted by a qualified biologist in advance of tree and structure removal within the subsequent project sites to characterize potential bat habitat and identify active roost sites. Should potential roosting habitat or active bat roosts be found in trees and/or structures to be removed under the project, the following measures shall be implemented:
• Removal of trees shall occur when bats are active, approximately between the periods of March 1 to April 15 and August 15 to October 15; outside of bat maternity roosting season (approximately April 16 – August 14) and outside the months of winter torpor (approximately October 16 – February 28), to the extent feasible.
• If removal of trees during the periods when bats are active is not feasible and active bat roosts being used for maternity or hibernation purposes are found on or in the immediate vicinity of the project site where tree and building removal is planned, a no-disturbance buffer of 100 feet shall be established around these roost sites until they are determined to be no longer active by a qualified biologist. A 100-foot no-disturbance buffer is a typical protective buffer distance; however, this may be modified by the qualified biologist depending on existing screening around the roost site (such as dense vegetation) as well as the type of construction activity which would occur around the roost site. • The qualified biologist shall be present during tree removal if potential bat roosting habitat or active bat roosts are present. Trees with active roosts shall only be removed when no rain is occurring or is forecast to occur for 3 days and when daytime temperatures are at least 50°F.

Qualified project staff
biologist
Prior to construction Community
Development
Department
Community
Development
Department
A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

MITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 4 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By • Removal of trees with potential bat roosting habitat or active bat roost sites shall follow a two- step removal process:
- On the first day of tree removal and under supervision of the qualified biologist, branches and limbs not containing cavities or fissures in which bats could roost, shall be cut only using chainsaws.
- On the following day and under the supervision of the qualified biologist, the remainder of the tree may be removed, either using chainsaws or other equipment (e.g., excavator or backhoe).

Cultural Resources and Tribal Cultural Resources
Mitigation Measure CUL 1a: Historic Resource Evaluation.

Prior to issuance of a demolition permit for any previously unevaluated building 45-years of age or older on a site included in the housing sites inventory, the City shall require an evaluation of historical significance that includes consideration of the criteria for listing in the National Register of Historic Places, the California Register of Historical Resources, and the Mountain View Register of Historic Resources. This evaluation shall be completed by a professional who meets the Secretary of the Interior’s Professional Qualifications for History, Architecture, Architectural History, or Historic Architecture.

In accordance with Section 5024.1, if the building has been previously evaluated for eligibility as a historic resource under CEQA and that evaluation or survey is more than five-years old, the findings of that evaluation should be confirmed by a professional who meets the Secretary of the Interior’s Professional Qualifications as stated above.

Qualified project staff
professional
Prior to demolition
permit issuance
Community
Development
Department
Community
Development
Department
Mitigation Measure CUL 1b: Historic Resource Avoidance.

If, after implementation of Mitigation Measure CUL 1a, the subject property is found to qualify as a historic resource and the proposed project includes demolition of the historic resource, the project shall be redesigned to remove or avoid demolition. Any redesign that includes significant alteration of the historic resource, as defined by Section 36.54.55(e) of the City of Mountain View Zoning Code, shall be required to comply with City Standard Condition of Approval (Secretary of the Interior Standards).

Qualified project staff
professional
Prior to demolition
permit issuance
Community
Development
Department
Community
Development
Department
A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

MITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 5 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By Mitigation Measure CUL 2a: Inadvertent Discovery of Cultural Resources.

If pre-contact or historic-era archaeological resources are encountered during project construction and implementation, all construction activities within 100 feet shall halt and the City shall be notified. Pre-contact archaeological materials might include obsidian and chert flaked- stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; and stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones. Historic-era materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. An archaeologist meeting the U.S. Secretary of the Interior’s Standards (SOIS) for Archeology shall inspect the findings within 24 hours of discovery.

If the City determines that the resource qualifies as a historical resource or a unique archaeological resource (as defined pursuant to the CEQA Guidelines) and that the project has potential to damage or destroy the resource, mitigation shall be implemented in accordance with PRC Section 21083.2 and CEQA Guidelines Section 15126.4, with a preference for preservation in place. If preservation in place is feasible, this may be accomplished through one of the following means: (1) siting improvements to completely avoid the archaeological resource; (2) incorporating the resource into a park or dedicated open space, by deeding the resource into a permanent conservation easement; (3) capping and covering the resource before building the project on the resource site after the resource has been thoroughly studied by a SOIS qualified archaeologist and a report written on the findings.

If avoidance is not feasible, the City shall consult with appropriate Native American tribes (if the resource is pre-contact or indigenous), and other appropriate interested parties to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3).

Construction
contractors, City staff,
Qualified archaeologist
During project
construction
Community
Development
Department
Community
Development
Department
A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

MITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 6 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By Mitigation Measure CUL 2b: Cultural Resources Study Requirements.

Prior to approval of development permits for multifamily projects that include ground-disturbing activities, individual project applicants shall request a non-confidential records search from the Northwest Information Center (NWIC) to determine if the proposed project site has archaeological sensitivity. If the NWIC recommends that the proposed project site be reviewed by an archaeologist, the City shall require a site-specific cultural resources study by an archaeologist meeting the U.S. Secretary of the Interior’s Standards (SOIS) for Archeology. The study shall consist of a cultural report that includes the results of: a cultural resources records search performed at the NWIC of the California Historical Resources Information System for the project area, a pedestrian survey of the project area, a historic context, an assessment of the sensitivity of the project area for buried precontact and historic-era resources, and identify if the project would potentially impact cultural resources. If the archaeologist determines that known cultural resources or potential archaeological sensitivity areas may be impacted by the project, additional research or treatment, potentially including subsurface testing, and/or a cultural resources awareness training may be required to identify, evaluate, and mitigate impacts to cultural resources, as recommended by the SOIS qualified archaeologist. If avoidance is not feasible, the City shall consult with appropriate Native American tribes (if the resource is pre- contact or indigenous), and other appropriate interested parties to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3). The cultural report detailing the results of the research shall be prepared and submitted for review by the City and a final draft shall be submitted to the NWIC.

City staff, Qualified
archaeologist
Prior to approval of
development permits
for multifamily projects
that include ground-
disturbing activities
Community
Development
Department
Community
Development
Department
Greenhouse Gas Emissions
Mitigation Measure GHG-1: Require Compliance with EV Requirements in CALGreen Tier

2. Subsequent development projects proposed as part of the HEU shall comply with EV requirements in the most recently adopted version of CALGreen Tier 2 at the time that a building permit application is filed.

Project sponsor When building permit
application is filed
Community
Development
Department
Community
Development
Department
A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

M ITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 7 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By Hazards and Hazardous Materials
Mitigation Measure HAZ-1: Phase I Environmental Site Assessment.

Prior to the initiation of any construction requiring ground-disturbing activities on listed active hazardous materials cleanup sites, the project applicant shall complete a Phase I environmental site assessment for that property in accordance with American Society for Testing and Materials Standard E1527 for those active hazardous materials sites to ascertain their current status. Any recommended follow up sampling (i.e., Phase II activities) set forth in the Phase I assessment shall be implemented prior to construction. The results of Phase II studies, if necessary, shall be submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction.

Prior to final project design of any individual project that includes any earth-disturbing activities, the project applicant shall conduct a Phase I Environmental Site Assessment (Phase I assessment). The Phase I assessment shall be prepared in general accordance with ASTM Standard E1527-21, Standard Practice for Environmental Site Assessment: Phase I Environmental Site Assessment Process (or most current edition that is in force at the time of final project design), which is the current industry standard. The Phase I assessment shall include a records review of appropriate federal, State, and local databases within ASTM-listed search distances regarding hazardous materials use, storage, or disposal at the given site, a review of historical topographic maps and aerial photographs, a site reconnaissance, interviews with persons knowledgeable about the sites historical uses, and review of other relevant existing information that could identify the potential existence of Recognized Environmental Conditions, including hazardous materials, or contaminated soil or groundwater. If no Recognized Environmental Conditions are identified, then no further action would be required.

If Recognized Environmental Conditions are identified and the Phase I assessment recommends further action, the project applicant shall conduct the appropriate follow-up actions, which may include further records review, sampling of potentially hazardous materials, and possibly site cleanup. In the event that site cleanup is required, the project shall not proceed until the site has been cleaned up to the satisfaction of the appropriate regulatory agency (e.g., DTSC, RWQCB, or SCCEHD) such that the regulatory agency issues a No Further Action letter or equivalent.

Project applicant Prior to final project
design and initiation of
any construction
requiring ground-
disturbing activities
Oversight by the City’s
Community
Development
Department, DTSC,
RWQCB, and/or
SCCEHD
Community
Development
Department
A. Mitigation Monitoring and Reporting Program

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE

MITIGATION MONITORING AND REPORTING PROGRAM (CONTINUED) City of Mountain View Housing Element Update 8 ESA / 202000806 Final Environmental Impact Report November 2022
Implemented By When Implemented Monitored By Verified By Transportation
Mitigation Measure TRA-1: Implement Vehicle Miles Traveled (VMT) Reduction Measures.

Individual multifamily housing development proposals that do not screen out from VMT impact analysis shall provide a quantitative VMT analysis using the methods outlined by the City’s most recent VMT guidelines. Projects that result in a significant impact shall include travel demand management measures and/or physical measures (i.e. improving multimodal transportation network, improving street connectivity) to reduce VMT. The City’s VMT guidelines identify four tiers of mitigation measures, all of which can be quantified within the Santa Clara Valley Transportation Authority (VTA) VMT tool:
• Tier 1— Project Characteristics. Although it may be difficult to revise a project during environmental review, Tier 1 strategies allow the user to increase the project density, diversity of land uses, and add affordable and/or below-market-rate housing to the residential and employment projects to reduce VMT.
• Tier 2—Multi-Modal Network Improvements. These improvements include implementing bicycle lanes, improving the pedestrian network, implementing traffic calming, increasing transit accessibility, and improving network connectivity. These improvements require coordination with Mountain View staff and additional studies (signal warrant studies, traffic calming studies, etc.) to determine feasibility.

Consultants should prioritize public improvements included in the City’s approved plans which contain various transportation improvements to bicycle, pedestrian, and roadway facilities as VMT mitigation. (See above for list of adopted plans and policies.)
• Tier 3—Parking. Parking strategies shown to effectively reduce VMT include reduced parking, increased bike parking or end-of-trip bike facilities. In order to be most effective, the areas surrounding the projects with reduced parking should have parking permit programs.
• Tier 4—Travel Demand Management (TDM) There are a multitude of TDM measures to reduce VMT. The VMT Tool includes all allowable TDM measures and their relative effectiveness. Based on the percentage of participation selected by the user, the VMT Tool calculates the resulting VMT reduction. The various TDM measures in the VMT Tool include school carpool programs, bike-sharing programs, car-sharing programs, trip reduction marketing/educational campaigns, parking cash-out, subsidized transit, telecommuting, alternative work schedules, shuttles, pay to park, ride-sharing, unbundled parking, and subsidized vanpools.

Consultants and City
Staff
During environmental
review
Community
Development
Department and Public
Works Department
Community
Development
Department and Public
Works Department
Utilities and Service Systems
Mitigation Measure UTL-1: Fair-Share Contributions Toward Utility Improvements.

Subsequent development projects shall contribute the fair share amount identified by the City of Mountain View Public Works Department to fund capital improvements to the water, sanitary sewer, and stormwater drainage systems prior to issuance of a building permit.

Project applicant Prior to building permit
issuance
Community
Development
Department and Public
Works Department
Community
Development
Department and Public
Works Department

CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE
Draft Environmental Impact Report
SCH# 202 2020129
Prepared by July 2022

In conjunction with

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CITY OF MOUNTAIN VIEW HOUSING ELEMENT UPDATE
Draft Environmental Impact Report
SCH# 2022020129
Prepared by July 2022

In conjunction with

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City of Mountain View Housing Element Update i ESA / 202000806 Draft Environmental Impact Report July 2022

TABLE OF CONTENTS
City of Mountain View Housing Element
Update
Page
Chapter 1, Introduction ...................................................................................................... 1-1

1.1 Project Overview ................................................................................................ 1-1

1.2 Purpose and Use of this EIR ............................................................................. 1-2

1.3 This is a Program EIR ........................................................................................ 1-2

1.4 Environmental Review Process ......................................................................... 1-3

1.5 Organization of the Draft EIR ............................................................................. 1-4 Chapter 2, Summary .......................................................................................................... 2-1

2.1 Project Summary ............................................................................................... 2-1

2.2 Project Summary ............................................................................................... 2-2

2.3 Environmental Impacts and Mitigation Measures .............................................. 2-7

2.4 Summary of Alternatives .................................................................................... 2-7

2.5 Areas of Controversy Raised in Scoping Comments ........................................... 2-7

2.6 Issues to Be Resolved ....................................................................................... 2-8 Chapter 3, Project Description .......................................................................................... 3-1

3.1 Introduction ........................................................................................................ 3-1

3.2 Project Location and Setting .............................................................................. 3-2

3.3 Background ....................................................................................................... 3-2

3.4 Project Description ............................................................................................. 3-8

3.5 Project Objectives ............................................................................................ 3-15

3.6 Intended Uses of this EIR ................................................................................ 3-15

3.7 References ...................................................................................................... 3-17 Chapter 4, Environmental Setting, Impacts, and Mitigation Measures ...................... 4.0-1

4.0 Introduction to the Environmental Analysis ..................................................... 4.0-1

4.1 Aesthetics ....................................................................................................... 4.1-1

4.2 Air Quality ....................................................................................................... 4.2-1

4.3 Biological Resources ...................................................................................... 4.3-1

4.4 Cultural Resources and Tribal Cultural Resources ......................................... 4.4-1

4.5 Energy ............................................................................................................ 4.5-1

4.6 Geology, Soils, and Paleontological Resources ............................................. 4.6-1

4.7 Greenhouse Gas Emissions ........................................................................... 4.7-1

4.8 Hazards and Hazardous Materials .................................................................. 4.8-1

4.9 Hydrology and Water Quality .......................................................................... 4.9-1

4.10 Land Use and Planning ................................................................................ 4.10-1

4.11 Noise and Vibration ...................................................................................... 4.11-1

4.12 Population and Housing ................................................................................ 4.12-1

4.13 Public Services and Recreation .................................................................... 4.13-1

4.14 Transportation .............................................................................................. 4.14-1 Table of Contents

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City of Mountain View Housing Element Update ii ESA / 202000806 Draft Environmental Impact Report July 2022

4.15 Utilities and Service Systems ....................................................................... 4.15-1

4.16 Effects Found Not to Be Significant .............................................................. 4.16-1 Chapter 5, Alternatives to the Project .............................................................................. 5-1

5.1 CEQA Requirements ......................................................................................... 5-1

5.2 Factors in the Selection of Alternatives .............................................................. 5-3

5.3 Description of Alternatives Selected for Analysis ............................................... 5-5

5.4 Comparative Analysis of the Alternatives .......................................................... 5-7

5.5 Overall Comparison of the Alternatives ........................................................... 5-15 Chapter 6, Other CEQA Considerations ........................................................................... 6-1

6.1 Significant Environmental Effects ...................................................................... 6-1

6.2 Significant Irreversible Environmental Changes ................................................ 6-1

6.3 Growth-Inducing Impacts ................................................................................... 6-2

6.4 Cumulative Impacts ........................................................................................... 6-5 Chapter 7, Report Preparers ............................................................................................. 7-1

7.1 Lead Agency ...................................................................................................... 7-1

7.2 EIR Consultants ................................................................................................. 7-1

Appendices
A. Notice of Preparation, Scoping Materials, and Scoping Comment Letters ..............A-1 B. Draft City of Mountain View 2023-2031 Housing Element .......................................B-1 C. Noise Supporting Information ................................................................................. C-1 D. Water Supply Assessment ...................................................................................... D-1 List of Figures
Figure 3-1 Project Location Map ................................................................................... 3-3 Figure 3-2 Neighborhoods and Precise Plan Locations ................................................ 3-5 Figure 3-3 Housing Site Locations Overview .............................................................. 3-10 Figure 4.8-1 Hazardous Materials Cleanup Sites ......................................................... 4.8-3 Figure 4.8-2 FAR Part 77 Surface ................................................................................ 4.8-7 Figure 4.11-1 2022 Noise Contours for Moffett Federal Airfield .................................. 4.11-16 Figure 4.14-1 Roadway Classifications ......................................................................... 4.14-2 Figure 4.14-2 Existing Bicycle Facilities ........................................................................ 4.14-4 Figure 4.14-3 Existing Transit Services ........................................................................ 4.14-6 Figure 4.14-4 HEU Housing Sites and VMT Per Capita ............................................. 4.14-21

List of Tables
Table 2-1 Mountain View Regional Housing Needs Allocation 6th Housing Element Cycle (2023-2031) ......................................................................... 2-3 Table 2-2 Summary of Impacts and Mitigation Measures for the Project ..................... 2-9 Table 3-1 Mountain View Regional Housing Needs Allocation 6th Housing Element Cycle (2023-2031) ......................................................................... 3-7 Table 3-2 Mountain View Growth Projections for 2040 .............................................. 3-13 Table 4.0-1 2040 Housing and Employment Projections with and without the City of Mountain View HEU ...................................................................... 4.0-6 Table of Contents

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City of Mountain View Housing Element Update iii ESA / 202000806 Draft Environmental Impact Report July 2022
Table 4.0-2 Cumulative Non-Residential Development Projects in the City ................ 4.0-8 Table 4.2-1 Sources, Environmental and Health Effects of Criteria Air Pollutants ....... 4.2-3 Table 4.2-2 State and Federal Ambient Air Quality Standards .................................... 4.2-4 Table 4.2-3 Summary of Ambient Air Quality Data in the Project Area ........................ 4.2-7 Table 4.2-4 Air Quality Index Statistics for the SFBAAB .............................................. 4.2-9 Table 4.2-5 State And National Ambient Air Quality Standards and Major Sources .................................................................................................. 4.2-11 Table 4.2-6 San Francisco Bay Area Air Basin Attainment Status ............................ 4.2-13 Table 4.2-7 Recommendations for Siting New Sensitive Land Uses ......................... 4.2-15 Table 4.2-8 Recommendations for Siting New Sensitive Land Uses ......................... 4.2-16 Table 4.2-9 Consistency with Potentially Applicable Control Measures in 2017 Clean Air Plan Control Measures ........................................................... 4.2-27 Table 4.2-10 Increase in VMT versus Population Growth ............................................ 4.2-31 Table 4.3-1 Special-Status Species Potential to Occur in the HEU Study Area .......... 4.3-7 Table 4.4-1 Known Historic Resources ........................................................................ 4.4-8 Table 4.4-2 Previously Recorded Archaeological Resources .................................... 4.4-10 Table 4.5-1 Existing Annual State and Regional Energy Use ...................................... 4.5-2 Table 4.7-1 State of California Greenhouse Gas Emissions ........................................ 4.7-6 Table 4.7-2 City of Mountain View Greenhouse Gas Emissions ................................. 4.7-7 Table 4.7-3 Consistency with Applicable GHG Reduction Actions in 2017 Scoping Plan Update .............................................................................. 4.7-36

Table 4.8-1 Federal Laws and Regulations Related to Hazardous Materials Management ............................................................................................. 4.8-8 Table 4.8-2 State Laws and Regulations Related to Hazardous Materials Management ........................................................................................... 4.8-10 Table 4.8-3 Indoor Air Cleanup Levels for Long-term Exposure for the MEW Site - Residential Buildings ..................................................................... 4.8-15 Table 4.9-1 Designated Beneficial Uses for Water Bodies in the Study Area .............. 4.9-8 Table 4.11-1 Sound Levels That Protect Public Health (dBA) ..................................... 4.11-2 Table 4.11-2 Reference Construction Equipment Noise Levels (50 feet from source) ............................................................................ 4.11-10

Table 4.11-3 Vibration Levels for Construction Equipment ........................................ 4.11-12 Table 4.11-4 Baseline and Projected Peak Hour Traffic Noise Levels Along Streets Housing Element Update ......................................................... 4.11-14

Table 4.12-1 Population Trends, 2010-2020 ............................................................... 4.12-1 Table 4.12-2 Housing Trends, 2010-2020 ................................................................... 4.12-2 Table 4.12-3 Mountain View Regional Housing Needs Allocation 6th Housing Element Cycle (2023-2031) .................................................................... 4.12-4 Table 4.13-1 Existing City-Owned Parks ..................................................................... 4.13-4 Table 4.14-1 Existing Transit Services ........................................................................ 4.14-7 Table 4.14-2 Mountain View Growth Projections ....................................................... 4.14-17 Table 5-1 Alternative Impact Summary and Comparison .......................................... 5-16

Table of Contents

City of Mountain View Housing Element Update iv ESA / 202000806 Draft Environmental Impact Report July 2022

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City of Mountain View Housing Element Update 1-1 ESA / 202000806 Draft Environmental Impact Report July 2022
CHAPTER 1
Introduction
This Draft Environmental Impact Report (EIR) has been prepared pursuant to the California Environmental Quality Act (CEQA) and the State CEQA Guidelines to analyze potential physical environmental impacts of the proposed City of Mountain View Housing Element Update (HEU), referred to in this EIR as “Project”.
1 A brief overview of the Project and the environmental review process, and a description of the purpose of this Draft EIR and opportunities for public comment, are provided below, along with an explanation of how this Draft EIR is organized.

1.1 Project Overview
The Project analyzed in the EIR would include adoption of a General Plan amendment to add or modify goals, objectives, policies, and implementation programs related to housing in the Housing Element of the City’s General Plan. The Housing Element itself would contain: an updated housing needs assessment; updated goals, policies, and programs that address the maintenance, preservation, improvement, and development of housing and that affirmatively further fair housing; and a housing inventory that meets the City’s Regional Housing Needs Assessment (RHNA) allocation and provides a buffer of additional housing development capacity. The Project would also include modifications to provisions in the City’s General Plan Land Use Map, zoning ordinance, zoning map, and adopted Precise Plans, as needed, to reflect the housing sites inventory, as described in Chapter 3, Project Description.

Based on the City’s Regional Housing Needs Assessment (RHNA) allocation, the HEU plans for an additional 11,135 dwelling units plus a sizeable “buffer.” This EIR evaluates the potential for approximately 15,000 multi-family housing units (including approximately 96 accessory dwelling units) during the HEU planning period as a maximum scenario for purposes of the CEQA evaluation, understanding that the buffer size and the final sites selected for inclusion in the Housing Element will be determined by the City Council upon adoption of the HEU. Of this, approximately 13,600 units are already allowed under the City’s adopted General Plan, zoning, and Precise Plans and the remaining 1,400 units would be created through rezonings and General Plan amendments. In addition, the EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately 2,700 units beyond 2031.

In addition to the amendments that would take place within the General Plan’s Housing Element, the HEU could require amendments to other elements of the General Plan to ensure internal

1 The California Environmental Quality Act can be found in the California Public Resources Code, Section 21000 et seq. The State CEQA Guidelines, formally known as the Guidelines for California Environmental Quality Act, can be found in the California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15000 et seq.

1. Introduction
City of Mountain View Housing Element Update 1-2 ESA / 202000806 Draft Environmental Impact Report July 2022
consistency and constancy between the General Plan and zoning/Precise Plans. Please see Chapter 3, Project Description, for more information.

1.2 Purpose and Use of this EIR
CEQA requires a public agency to prepare an EIR describing the environmental effects of a project before a public agency can approve a project that may have potentially significant, adverse physical effects on the environment. The EIR is a public information document that identifies and evaluates potential environmental impacts of a project, recommends mitigation measures to lessen or eliminate significant adverse impacts, and examines feasible alternatives to the project. The information contained in the EIR must be reviewed and considered by the City of Mountain View and by any responsible agencies (as defined in CEQA) prior to a decision to approve or modify the project.

1.3 This is a Program EIR
This EIR is a program EIR, as provided for in CEQA Guidelines Section 15168, and consistent with Section 15168(b) of the CEQA Guidelines, allows the City “to consider broad policy alternatives and program-wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts.” As a program EIR, this EIR analyzes potential impacts of development that would be allowed by the HEU without having site-specific development proposals in hand, and broadly considers proposed sites, their environmental setting, and potential impacts that could stem from their development. Readers will note that the level of detail is different than in a project-specific EIR, which generally considers a single, specific proposal on an individual site.

Future discretionary actions that would be facilitated by the HEU’s adoption, such as those related to the development of housing, would be assessed to determine consistency with the analysis provided in this program EIR. Potential future actions would also be subject to the mitigation measures established in this program EIR unless superseded by a subsequent environmental document that is required to analyze significant environmental impacts not foreseen in this program EIR.

It is important to note that while the law requires the HEU to include an inventory of housing sites and requires the City to zone those sites for multifamily housing, the City is not required to actually develop housing on these sites. Future development on identified sites would be at the discretion of individual property owners and would be largely dependent on market forces and -- in the case of affordable housing -- available funding and/or other incentives. Nonetheless, this EIR considers potential impacts of development that may result from adoption of the HEU, focusing on proposed actions to encourage housing production such as changes in allowable densities, changes in development standards, and adoption of incentives.

1. Introduction
City of Mountain View Housing Element Update 1-3 ESA / 202000806 Draft Environmental Impact Report July 2022

1.4 Environmental Review Process

1.4.1 Notice of Preparation and EIR Scoping
Pursuant to the requirements of CEQA for the initiation of environmental review, on February 4, 2022, the City sent a Notice of Preparation (NOP) to the State Clearinghouse, responsible and trustee government agencies, organizations, and individuals potentially interested in the Project.

The NOP requested that agencies with regulatory authority over any aspect of the Project describe that authority and identify relevant environmental issues that should be addressed in the EIR.

Interested members of the public were also invited to comment. The comment period for the NOP extended from February 4, 2022 to March 7, 2022, during which time, the City accepted written comments on the scope of the EIR.2 A scoping meeting was held by the City on February 24, 2022 to accept oral comments.

The NOP and the comments received on the NOP are included in Appendix A of this EIR. As discussed in the NOP and pursuant to the provisions of CEQA, the City did not prepare a CEQA Initial Study prior to preparation of the EIR, because the City determined that it was clear at the time of the issuance of the NOP that an EIR was required (CEQA Guidelines Section 15060[d]).

1.4.2 Public Review of this Draft EIR
This Draft EIR is available for public review and comment as set forth in the Notice of Availability and Notice of Completion circulated by the City. During the review and comment period, written comments (including email) regarding the Draft EIR may be submitted to the City at the address below.

City of Mountain View
Community Development Department
Attention: Ellen Yau, Senior Planner
500 Castro Street, P.O. Box 7540
Mountain View, CA 94039-7540
[email protected]
The Draft EIR, Notice of Availability, and other supporting documents, are available for public review on
the City’s website at :
www.mountainview.gov/CEQA or on the Project website at:
https://www.mvhousingelement.org/ and on the State Clearinghouse Website at:
https://ceqanet.opr.ca.gov/Project/2022020129
.

The City Environmental Planning Commission will hold a public hearing on Wednesday, August 3, 2022 at 7:00 p.m., during which verbal comments on the Draft EIR will be accepted. The meeting will be held virtually via Zoom webinar, and members of the public and public agencies may participate remotely. All interested persons may participate by joining the video conference and may access the meeting information at the f
ollowing website: https://mountainview.legistar.com/Calendar.aspx. 2 Late comments were also accepted and received through March 14, 2022.

1. Introduction
City of Mountain View Housing Element Update 1-4 ESA / 202000806 Draft Environmental Impact Report July 2022

1.4.3 Final EIR
Following the public review and comment period for the Draft EIR, the City will prepare responses that address all substantive written and oral comments on the Draft EIR’s environmental analyses that are received within the specified review period. The City will also identify any clarifying revisions to the Draft EIR that are necessary to address the comments received. When taken together, the responses to comments and the Draft EIR (as amended if necessary) will constitute the Final EIR for the project. The City (following a recommendation by the City’s Environmental Planning Commission) will consider certification of the Final EIR prior to making a decision on adoption of the HEU and related approval actions.

1.4.4 Mitigation Monitoring and Reporting Plan
Throughout this EIR, mitigation measures are identified where applicable and presented in language that will facilitate preparation of a Mitigation Monitoring and Reporting Plan (MMRP).

As required under CEQA, a MMRP will be prepared and presented to the City Council for adoption at the same time they consider approval of the Project, and will identify the timing and roles and responsibilities for implementation of adopted mitigation measures.

1.5 Organization of the Draft EIR
This Introduction (Chapter 1) presents an overview of the process by which this EIR will be reviewed and used by the decision-makers in their consideration of the project.

The Summary (Chapter 2) includes a brief project description and a summary table that lists the environmental impacts, proposed mitigation measures, and the level of significance after mitigation. Detailed analysis of these impacts and mitigation measures is provided in Chapter 4, Environmental Setting, Impacts, and Mitigation Measures. The Summary also provides a summary of the alternatives to the project.

The Project Description (Chapter 3) describes the project location and boundaries; lists the project objectives; and provides a general description of the technical, economic, and environmental characteristics of the project. This chapter also includes a list of required approvals for the project and other agencies that may be responsible for approving aspects of the project.

The Environmental Setting, Impacts, and Mitigation Measures (Chapter 4) contains a description of the environmental setting (existing physical environmental conditions), the regulatory framework, and the environmental impacts (including cumulative impacts) that could result from the project. It includes the thresholds of significance used to determine the significance of adverse environmental effects. This chapter also identifies the mitigation measures that would avoid or substantially lessen these significant adverse impacts. The impact discussions disclose the significance of each impact both with and without implementation of mitigation measures.

Alternatives to the Project (Chapter 5) evaluates a range of reasonable alternatives to the project and identifies an environmentally superior alternative, consistent with the requirements of CEQA.

1. Introduction
City of Mountain View Housing Element Update 1-5 ESA / 202000806 Draft Environmental Impact Report July 2022
The alternatives analysis evaluates each alternative’s ability to meet the project objectives and its ability to reduce environmental impacts.

Other CEQA Considerations (Chapter 6) addresses growth-inducing effects, significant irreversible environmental changes, and significant unavoidable environmental effects of the Project.

Report Preparers (Chapter 7) identifies the authors of the EIR. Persons and documents consulted during preparation of the EIR are listed at the end of each analysis section.

Appendices. The appendices include environmental scoping information and technical reports and data used in the preparation of the Draft EIR. These documents are included on the City’s Project website.

1. Introduction
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City of Mountain View Housing Element Update 2-1 ESA / 202000806 Draft Environmental Impact Report July 2022
CHAPTER 2
Summary

2.1 Project Summary
As provided by Section 15123 of the California Environmental Quality Act (CEQA) Guidelines (CEQA Guidelines), this chapter provides a brief summary of the City of Mountain View Housing Element Update (HEU) and its consequences. This chapter is intended to summarize in a stand-alone section the Project described in Chapter 3, Project Description, the impacts and mitigation measures discussed in Chapter 4, Environmental Setting, Impacts, and Mitigation Measures, and the alternatives analysis presented in Chapter 5, Alternatives to the Project.

This Draft Environmental Impact Report (Draft EIR) has been prepared to evaluate the anticipated environmental effects of the HEU in conformance with the provisions of CEQA and the CEQA Guidelines. The lead agency, the City of Mountain View (City), is the public agency that has the principal responsibility for approving the HEU.

This EIR is a Program EIR, as provided for in CEQA Guidelines Section 15168. Section 15168(a) of the CEQA Guidelines states that a Program EIR is appropriate for projects which are “… a series of actions that can be characterized as one large project and are related either:

1. Geographically;

2. A logical part in the chain of contemplated actions;

3. In connection with issuance of rules, regulations, plans or other general criteria to govern the conduct of a continuing program; or

4. As individual activities carried out under the same authorizing statutory or regulating authority and having generally similar environmental effects which can be mitigated in similar ways.”
Section 15168(b) of the CEQA Guidelines further states: “Use of a Program EIR can provide the following advantages. The Program EIR can:

1. Provide an occasion for a more exhaustive consideration of effects and alternatives than would be practical in an EIR on an individual action;

2. Ensure consideration of cumulative impacts that might be slighted in a case-by-case analysis;

3. Avoid duplicate consideration of basic policy considerations;

2. Summary
City of Mountain View Housing Element Update 2-2 ESA / 202000806 Draft Environmental Impact Report July 2022

4. Allow the Lead Agency to consider broad policy alternative and program-wide mitigation measures at an early time when the agency has greater flexibility to deal with basic problems or cumulative impacts, and

5. Allow reduction in paperwork.”
Future discretionary actions that would be facilitated by the HEU’s adoption, particularly those related to the development of housing, would require additional assessment to determine consistency with the analysis provided in this Program EIR. Potential future actions would also be subject to the mitigation measures established in this Program EIR unless superseded by a subsequent environmental document that is required to analyze significant environmental impacts not foreseen in this Program EIR.

2.2 Project Summary

2.2.1 Project Location
The City of Mountain View is located in the southern San Francisco Bay area, approximately 11 miles northwest of San José, California. The City is located in northern Santa Clara County, and is bordered by the San Francisco Bay to the north, the City of Palo Alto to the west, the City of Los Altos to the south and southwest, and Moffett Federal Airfield and the City of Sunnyvale to the east. The City encompasses approximately 12.24 square miles with a population of approximately 82,376 people. The geographic extent of environmental analysis included in the EIR for the proposed project will be the City limits.

2.2.2 Project Site
The HEU would identify specific sites appropriate for the development of multifamily housing, and the City would rezone those areas if/as necessary to meet the requirements of State law. The proposed sites that can accommodate development of multifamily housing are primarily located within the boundaries of adopted Precise Plans and along commercial corridors, though sites are also included from other parts of the City.

2.2.3 Background
State law requires the City to have and maintain a general plan with specific contents in order to provide a vision for the City’s future, and inform local decisions at land use and development, including issues such as circulation, conservation, and safety. The City’s current General Plan was adopted in 2012 and contains eight chapters or “elements,” including one about housing. The City’s Housing Element was last updated in 2014, and covers the “5th Cycle” Housing Element planning period from 2014 through 2022. Because this period is drawing to a close, State law [Government Code Section 65588] requires the City to update its Housing Element and provides a deadline of January 31, 2023 for submission of an adopted Housing Element. In accordance with State law, the planning period for the updated Housing Element will extend from January 31, 2023 to January 31, 2031, and is referred to as the “6 th cycle”.

2. Summary
City of Mountain View Housing Element Update 2-3 ESA / 202000806 Draft Environmental Impact Report July 2022
In addition to including goals, policies, and implementation programs regarding housing issues, Housing Elements must include an inventory or list of housing sites at sufficient densities to accommodate a specific number of units at various levels of affordability (very low income, low income, moderate income, and above moderate income) assigned to the City by the Association of Bay Area Governments (ABAG). This assignment is referred to as a Regional Housing Needs Allocation (RHNA).

The City’s existing 5th Cycle Housing Element includes housing sites inventory sufficient to accommodate the 2015 RHNA allocation of 2,926 units In the 2018 annual progress report (APR), the City utilized the recently-updated North Bayshore Precise Plan to replace lower and moderate income sites lost to redevelopment, as well as to create a significant buffer. On December 16, 2021, ABAG adopted the Final RHNA, which distributed the regional housing need issued by the Department of Housing and Community Development (HCD). The HCD allocated 441,176 housing units to the nine-county Bay Area (“bulk allocation”).

The City of Mountain View’s RHNA is 11,135 units, distributed among four income categories as shown in Table 2-1, below.

TABLE 2-1

M OUNTAIN VIEW REGIONAL HOUSING NEEDS ALLOCATION
6TH HOUSING ELEMENT CYCLE (2023-2031)
Very Low
Income Units
(0-50% AMI)
Low Income
Units
(51-80% AMI)
Moderate
Income Units
(81-120% AMI)
Above Mod
Units
(>120% AMI)
Total New
Units
6th Cycle RHNA 2,773 1,597 1,885 4,880 11,135
% of Total 25% 14% 17% 44% 100%
SOURCE: Association of Bay Area Governments (ABAG), Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031 adopted December 2021.

The HEU is required to identify housing sites to meet the City’s RHNA at specified levels of affordability. HCD recommends that jurisdictions plan for their RHNA plus a buffer of additional units equivalent to 15-30 percent. To be conservative, the City intends to identify a buffer of at least 20 to 30 percent of units at all income levels and a total unit capacity of up to approximately 15,000 units.

In addition, the HEU would identify sites appropriate for the development of multifamily housing, and the City would rezone those sites as necessary to meet the requirements of State law.

The City will need to maintain internal consistency between various elements of the General Plan and zoning ordinance, therefore, changes to elements of the General Plan Land Use Map, Zoning Ordinance, Zoning Map, and Precise Plans may be needed to ensure that the General Plan as a whole remains consistent with the HEU.

2. Summary
City of Mountain View Housing Element Update 2-4 ESA / 202000806 Draft Environmental Impact Report July 2022

2.2.4 Project Description
The Project analyzed in this EIR would include adoption of a General Plan amendment to add or modify goals, objectives, policies, and implementation programs related to housing in the Housing Element of the City’s General Plan.

The Housing Element itself would contain:
• An updated housing needs assessment;
• Updated goals, policies, and programs that address the maintenance, preservation, improvement, and development of housing and that affirmatively further fair housing; • A housing inventory that meets the City’s RHNA and provides a buffer of additional housing development capacity.

The Project would also include modifications to provisions in the City’s zoning ordinance, zoning map, and adopted Precise Plans, as needed, to reflect the housing sites inventory, which is described below.

Housing Needs Assessment & Updated Goals, Policies, and Programs
The proposed Project would adopt updated goals, policies, and programs to address the maintenance, preservation, improvement, and development of housing and to affirmatively further fair housing in the City. Proposed updates to the goals, policies, and programs in the 5th Cycle Housing Element were informed by a review of the implementation and effectiveness of that document, as well as updated information on demographic and economic trends, existing housing and market conditions, and special housing needs experienced by disabled persons, elderly households, large family households, single female-headed households, and homeless persons. The proposed goals, policies, and programs were also crafted to address an updated assessment of non-governmental and governmental constraints to the development, conservation, and rehabilitation of housing in the City, and to affirmatively further fair housing. For more information, including the definition of these terms, and the proposed updates to goals, policies, and programs, please see the Public Review Draft Housing Element Update available on the City’s website at https://www.mvhousingelement.org/.

Housing Sites Inventory
The proposed Project would address the requirements for a housing inventory and meet the City’s 6th Cycle RHNA plus a buffer via a number of strategies as provided for in State law and HCD guidance.

Existing Zoning and General Plan Capacity
Pipeline Projects. The City has approved a number of housing and mixed-use projects that are likely to result in production of multifamily housing during the housing element planning period.

The City also has active applications on file for single family and multifamily housing and/or mixed use developments that may be approved, constructed, and occupied during the housing element planning period. These types of “pipeline projects” would count towards the City’s RHNA, and could collectively total at least 8,600 units by 2031.

2. Summary
City of Mountain View Housing Element Update 2-5 ESA / 202000806 Draft Environmental Impact Report July 2022
Accessory Dwelling Units. The City may assume that the development of accessory dwelling units (ADUs) during the planning period is equivalent to that in recent years. Based on information contained in the City’s annual production reports to HCD, approximately 96 ADUs are assumed over the eight year planning period.

Existing Opportunity Sites. T
he City’s existing precise plans, General Plan Land Use designations, and zoning permit a range of residential densities in different areas of the City that can accommodate development of multifamily housing without adjustment. A preliminary analysis estimates that there may be sufficient sites to accommodate approximately 4,700 units. Most of these sites are within Precise Plan areas, including El Camino Real, San Antonio, North Bayshore, and East Whisman, although there are sites identified for inclusion in the inventory in other areas of the City as well. See Figure 3-2 for a map showing City neighborhoods and precise plan locations.

General Plan, Zoning and Precise Plan Amendments
Pipeline Sites Requiring Rezoning and General Plan Amendment. There are a limited number of sites that could accommodate multifamily housing – and in some cases specifically affordable housing for lower income households – if rezoned to allow residential use at appropriate densities.

These sites, which include development projects under review and under discussion are located at 1265 Montecito Avenue, 1020 Terra Bella Avenue, 1010 Linda Vista Avenue and East Evelyn Avenue between Highway 85 and Pioneer Way, and could accommodate approximately 580 units.

Rezonings Adopted with the Housing Element. The City proposes to adopt Zoning and Precise Plan Amendments concurrent with this Housing Element Update, to clarify standards for allowed uses and densities at General Plan Village Centers and El Camino Real Village Centers. These amendments accommodate approximately 800 units in the site inventory, but the total additional capacity of these areas is greater – approximately 2,500 units

1. Opportunity Sites Requiring Rezonings and/or General Plan Amendments (“Back-Pocket" Areas). In the event that the above opportunities are inadequate to accommodate the RHNA, either at the time of Housing Element adoption or over the course of the 6th Cycle due to the “no net loss” law, the proposed Housing Element will also include programs to adopt additional rezonings and General Plan amendments in targeted urban infill areas (areas on previously developed sites and/or completely surrounded by urban uses):
• M
offett Boulevard
• Other shopping areas, such as Leong Drive, Bailey Park shopping center, Monta Loma Plaza • A Joint Development at the Mountain View Transit Center • Other non-residential sites south of El Camino Real, such as 1949 Grant Road and offices near Blossom Valley Shopping Center

1 This number is less than the total amount of units that could be allowed across these sites, since it is unreasonable to assume replacement of all existing uses over the horizon of this study. The number does consider the sites most likely to be redeveloped.

2. Summary
City of Mountain View Housing Element Update 2-6 ESA / 202000806 Draft Environmental Impact Report July 2022
These rezoning opportunities could accommodate approximately 1,000 additional units, depending on the densities adopted.

Total Inventory. T he HEU is planning for the period from January 31, 2023 through January 31, 2031, and is expected to plan for approximately 15,000 new housing units within this period, although the actual pace of development will depend on market conditions, property owner interest, and other factors. Also, of the approximately 15,000 new units, only approximately 1,400 would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans. However, development of these units may be accelerated compared to the theoretical No Project scenario, due to programs in the Housing Element that streamline, incentivize or remove constraints for housing.

Adoption of the HEU would potentially result in 4,100 more dwelling units in the in the City’s c
umulative capacity beyond 2031 than would otherwise occur. This is due to the additional development potential that would be created the General Plan, Zoning and Precise Plan Amendments described above. The balance of the units included in the proposed HEU represent existing development potential that is already reflected in the City’s cumulative growth capacity.

2.2.5 Project Objectives
CEQA Guidelines Section 15124(b) requires the description of the project in an EIR to state the objectives sought by the project.
“A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project.” The primary purpose of the HEU is to comply with the requirements of State law by analyzing existing and projected housing needs, and updating goals, policies, objectives, and implementation programs for the preservation, improvement, and development of housing. The proposed Project is intended to ensure the City’s conformance with State housing requirements and seeks to:
• Protect existing housing;
• Encourage new housing for households at all income levels and for households with a range of diverse housing needs;
• Remove undue constraints on new housing development, including for affordable housing development;
• Affirmatively further fair housing; and
• Identify specific sites that could accommodate required housing units to meet the City’s RHNA.

Conducting community engagement and soliciting feedback to inform the contents of the HEU is a critical component of the planning process and will help to shape the HEU that is ultimately adopted by the City Council.

2. Summary
City of Mountain View Housing Element Update 2-7 ESA / 202000806 Draft Environmental Impact Report July 2022

2.3 Environmental Impacts and Mitigation Measures
As provided by the CEQA Guidelines Section 15123(b)(1), an EIR must provide a summary of the impacts, mitigation measures and significant impacts after mitigation for a proposed project. This information is presented in the various subsections within Chapter 4, Environmental Setting, Impacts, and Mitigation Measures, of this EIR, and summarized in Table 2-2 at the end of this chapter.

2.3.1 Significant and Unavoidable Impacts
The Project would result in the following significant and unavoidable impact:

Impact AIR-2: Implementation of the HEU would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. (Significant and Unavoidable with Mitigation)

2.4 S ummary of Alternatives

2.4.1 Environmentally Superior Alternative
Chapter 5, Alternatives to the Project, analyzes a range of reasonable alternatives to the proposed HEU, including the No Project Alternative and the Reduced Sites Alternative. The analysis of the alternatives, including a comparison of alternatives to the proposed HEU, is presented in Chapter 5, which provides a summary of impact levels within all environmental topic areas.

Overall, the analysis shows that neither the No Project Alternative nor the Reduced Sites Alternatives would reduce the proposed HEU’s significant impact related to air quality, but may reduce its severity due to lesser development overall. The No Project would also result in a new significant land use and planning-related impact and not meet project objectives.

Based on the evaluation described in Chapter 5, the Reduced Sites Alternative would be the Environmentally Superior Alternative for the purpose of this analysis based on its potential reduction in overall criteria air pollutant emissions and air quality-related health risk and the ability of the alternative to meet all of the basic project objectives of the proposed HEU (albeit to a lesser degree than the proposed HEU).

2.5 Areas of Controversy Raised in Scoping
Comments
Section 15123(b)(2) of the CEQA Guidelines requires that an EIR summary identify areas of controversy known to the lead agency, including those issues raised by other agencies and the public. Issues raised by the public have included concerns regarding biological resources, cultural resources and tribal cultural resources, hazards and hazardous materials, land use and planning, population and housing, public services and recreation, and transportation. As a result, these issues are potential areas of controversy.

2. Summary
City of Mountain View Housing Element Update 2-8 ESA / 202000806 Draft Environmental Impact Report July 2022

2.6 Issues to Be Resolved
Section 15123(b)(3) of the CEQA Guidelines requires that an EIR present the issues to be resolved including the choice among alternatives and whether or how to mitigate identified significant effects. The major issues to be resolved for the Project include decisions by the City of Mountain View, as the Lead Agency, as to whether:
• This EIR adequately describes the environmental impacts of the Project; • Recommended mitigation measures should be adopted or modified; • Additional mitigation measures need to be applied to the Project; • Feasible alternatives exist that would achieve the objectives of the Project and reduce significant environmental impacts;
• Significant and unavoidable impacts would occur if the Project is adopted and implemented; and
• The Project should or should not be approved.

2. Summary
City of Mountain View Housing Element Update 2-9 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Section 4.1, Aesthetics
Impact AES-1: Implementation of the HEU would not have a substantial adverse effect on a scenic vista. (Less than Significant) None required Less Than Significant
Impact AES-2: Implementation of the HEU would not substantially degrade the existing visual character or quality of public views of the site and its surroundings or conflict with applicable zoning and other regulations governing scenic quality. (Less than Significant) None required Less Than Significant
Impact AES-3: Implementation of the HEU would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Less than Significant) None required Less Than Significant
Impact AES-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not have a substantial adverse effect on a scenic vista. (Less than Significant)
None required Less Than Significant
Impact AES-2.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not substantially degrade the existing visual character or quality of public views of the site and its surroundings or conflict with applicable zoning and other regulations governing scenic quality. (Less than Significant)
None required Less Than Significant
Impact AES-3.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Less than Significant)
None required Less Than Significant
Section 4.2, Air Quality
Impact AIR-1: Implementation of the HEU would not conflict with or obstruct implementation of the applicable air quality plan. (Less than Significant)
None required Less Than Significant

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2. Summary
City of Mountain View Housing Element Update 2-10 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact AIR-2: Implementation of the HEU would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. (Significant and Unavoidable with Mitigation)
Mitigation Measure AIR-1: Emission Reduction Measures for Projects Exceeding the Significance Thresholds for Criteria Pollutants.

Project applicants proposing projects that exceed BAAQMD screening levels shall prepare a project-level criteria air pollutant assessment of construction and operational emissions at the time the project is proposed. The project-level assessment shall either include a comparison of the project with other similar projects where a quantitative analysis has been conducted, or shall provide a project-specific criteria air pollutant analysis to determine whether the project exceeds the BAAQMD’s criteria air pollutant thresholds.

In the event that a project-specific analysis finds that the project could result in criteria air pollutant emissions that exceed BAAQMD significance thresholds, the project applicant shall implement the following emission reduction measures to the degree necessary to reduce the impact to less than the significance thresholds, and shall implement additional feasible measures if necessary to reduce the impact to less than the significance thresholds.

Clean Construction Equipment.

1. The project applicant shall use electric construction equipment when feasible.

2. The project applicant shall ensure that all diesel off-road equipment shall have engines that meet the Tier 4 Final off-road emission standards, as certified by CARB, except as provided for in this section. This requirement shall be verified through submittal of an equipment inventory that includes the following information: (1) Type of Equipment, (2) Engine Year and Age, (3) Number of Years Since Rebuild of Engine (if applicable), (4) Type of Fuel Used, (5) Engine HP, (6) Verified Diesel Emission Control Strategy (VDECS) information if applicable and other related equipment data. A Certification Statement is also required to be made by the Contractor for documentation of compliance and for future review by the BAAQMD as necessary. The Certification Statement must state that the Contractor agrees to compliance and acknowledges that a violation of this requirement shall constitute a material breach of contract.

The City may waive the requirement for Tier 4 Final equipment only under the following unusual circumstances: if a particular piece of off-road equipment with Tier 4 Final standards is technically not feasible or not commercially available; the equipment would not produce desired emissions reduction due to expected operating modes; installation of the equipment would create a safety hazard or impaired visibility for the operator; or there is a compelling emergency need to use other alternate off-road equipment. For purposes of this mitigation measure, “commercially available” shall mean the availability of Tier 4 Final engines similar to the availability for other large-scale construction projects in the region occurring at the same time and taking into consideration factors such as (i) potential significant delays to critical-path timing of construction for the project and (ii) geographic proximity to the project site of Tier 4 Final equipment.

3. The project applicant shall require the idling time for off-road and on-road equipment be limited to no more than 2 minutes, except as provided in exceptions to the applicable state regulations regarding idling for off-road and on-road equipment. Legible and visible signs shall be posted in multiple languages (English, Spanish, Chinese) in designated queuing areas and at the construction site to remind operators of the 2-minute idling limit.

Significant and Unavoidable

2. Summary
City of Mountain View Housing Element Update 2-11 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Operational Emission Reductions

1. Projects shall be constructed without natural gas infrastructure and shall be “all electric.”

2. As required by Mitigation Measure GHG-1, projects shall provide EV charging infrastructure consistent with the applicable Tier 2 CALGreen standards in effect at the time.

3. Project applicants that do not screen out from VMT impact analysis shall implement VMT reduction measures as required by Mitigation Measure TRA-1.

Impact AIR-3: Implementation of the HEU would not expose sensitive receptors to substantial pollutant concentrations. (Less than Significant with Mitigation)
Mitigation Measure AIR-2: Emission Reduction Measures for Subsequent Projects Exceeding the Significance Thresholds for Health Risks from Construction.

Project applicants within the HEU area proposing projects within 1,000 feet of existing or approved sensitive receptors shall prepare a project-level HRA of construction impacts at the time the project is proposed. The HRA shall be based on project-specific construction schedule, equipment and activity data and shall be conducted using methods and models approved by the BAAQMD, CARB, OEHHA and U.S. EPA. Estimated project-level health risks shall be compared to the BAAQMD’s health risk significance thresholds for projects.

In the event that a project-specific HRA finds that the project could result in significant construction health risks that exceed BAAQMD significance thresholds, the project applicant shall implement Mitigation Measure AIR-1’s requirement for the use of all Tier 4 Final construction equipment to reduce project-level health risks to a less than significant level. In addition, all tower cranes, forklifts, man- and material- lifts shall be electric powered.

Less Than Significant
Impact AIR-4: Implementation of the HEU would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people. (Less than Significant) None required Less Than Significant
Impact AIR-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not result in exposure of sensitive receptors to substantial levels of fine particulate matter (PM2.5) and TACs under cumulative conditions. (Less than Significant Impact with Mitigation) Mitigation Measure AIR-2: Emission Reduction Measures for Subsequent Projects Exceeding the Significance Thresholds for Health Risks from Construction. See above.

Less Than Significant
Impact AIR-2.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not combine with other sources of odors that would adversely affect a substantial number of people. (Less than Significant) None required Less Than Significant

2. Summary
City of Mountain View Housing Element Update 2-12 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Section 4.3, Biological Resources
Impact BIO-1: Implementation of the HEU would have a
substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS. (Less than Significant with Mitigation)
Mitigation Measure BIO-1: Special-Status Bat Protection Measures.

In coordination with the City, a preconstruction survey for special-status bats shall be conducted by a qualified biologist in advance of tree and structure removal within the subsequent project sites to characterize potential bat habitat and identify active roost sites. Should potential roosting habitat or active bat roosts be found in trees and/or structures to be removed under the project, the following measures shall be implemented:
• Removal of trees shall occur when bats are active, approximately between the periods of March 1 to April 15 and August 15 to October 15; outside of bat maternity roosting season (approximately April 16 – August 14) and outside the months of winter torpor (approximately October 16 – February 28), to the extent feasible.
• If removal of trees during the periods when bats are active is not feasible and active bat roosts being used for maternity or hibernation purposes are found on or in the immediate vicinity of the project site where tree and building removal is planned, a no-disturbance buffer of 100 feet shall be established around these roost sites until they are determined to be no longer active by a qualified biologist. A 100-foot no-disturbance buffer is a typical protective buffer distance; however, this may be modified by the qualified biologist depending on existing screening around the roost site (such as dense vegetation) as well as the type of construction activity which would occur around the roost site.
• The qualified biologist shall be present during tree removal if potential bat roosting habitat or active bat roosts are present. Trees with active roosts shall only be removed when no rain is occurring or is forecast to occur for 3 days and when daytime temperatures are at least 50°F. • Removal of trees with potential bat roosting habitat or active bat roost sites shall follow a two- step removal process:
- On the first day of tree removal and under supervision of the qualified biologist, branches and limbs not containing cavities or fissures in which bats could roost, shall be cut only using chainsaws.
- On the following day and under the supervision of the qualified biologist, the remainder of the tree may be removed, either using chainsaws or other equipment (e.g., excavator or backhoe).

Less Than Significant
Impact BIO-2: Implementation of the HEU would not interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites. (Less than Significant)
None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-13 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact BIO-3: Implementation of the HEU would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance. (Less than Significant)
None required Less Than Significant
Impact BIO-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on Biological Resources. (Less than Significant with Mitigation)
Mitigation Measure BIO-1: Special-Status Bat Protection Measures. See above.

Less Than Significant
Section 4.4, Cultural Resources and Tribal Cultural Resources Impact CUL 1: Implementation of the HEU would not cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5. (Less than Significant with Mitigation)
Mitigation Measure CUL 1a: Historic Resource Evaluation.

Prior to issuance of a demolition permit for any previously unevaluated building 45-years of age or older on a site included in the housing sites inventory, the City shall require an evaluation of historical significance that includes consideration of the criteria for listing in the National Register of Historic Places, the California Register of Historical Resources, and the Mountain View Register of Historic Resources. This evaluation shall be completed by a professional who meets the Secretary of the Interior’s Professional Qualifications for History, Architecture, Architectural History, or Historic Architecture.

In accordance with Section 5024.1, if the building has been previously evaluated for eligibility as a historic resource under CEQA and that evaluation or survey is more than five-years old, the findings of that evaluation should be confirmed by a professional who meets the Secretary of the Interior’s Professional Qualifications as stated above.

Mitigation Measure CUL 1b: Historic Resource Avoidance.

If, after implementation of Mitigation Measure CUL 1a, the subject property is found to qualify as a historic resource and the proposed project includes demolition of the historic resource, the project shall be redesigned to remove or avoid demolition. Any redesign that includes significant alteration of the historic resource, as defined by Section 36.54.55(e) of the City of Mountain View Zoning Code, shall be required to comply with City Standard Condition of Approval (Secretary of the Interior Standards).

Less Than Significant
Impact CUL 2: Implementation of the HEU may cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5. (Less than Significant with Mitigation) Mitigation Measure CUL 2a: Inadvertent Discovery of Cultural Resources.

If pre-contact or historic-era archaeological resources are encountered during project construction and implementation, all construction activities within 100 feet shall halt and the City shall be notified. Pre-contact archaeological materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; and stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones. Historic-era materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. An archaeologist meeting the U.S. Secretary of the Interior’s Standards (SOIS) for Archeology shall inspect the findings within 24 hours of discovery.

Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-14 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
If the City determines that the resource qualifies as a historical resource or a unique archaeological resource (as defined pursuant to the CEQA Guidelines) and that the project has potential to damage or destroy the resource, mitigation shall be implemented in accordance with PRC Section 21083.2 and CEQA Guidelines Section 15126.4, with a preference for preservation in place. If preservation in place is feasible, this may be accomplished through one of the following means: (1) siting improvements to completely avoid the archaeological resource; (2) incorporating the resource into a park or dedicated open space, by deeding the resource into a permanent conservation easement; (3) capping and covering the resource before building the project on the resource site after the resource has been thoroughly studied by a SOIS qualified archaeologist and a report written on the findings.

If avoidance is not feasible, the City shall consult with appropriate Native American tribes (if the resource is pre-contact or indigenous), and other appropriate interested parties to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3).

Mitigation Measure CUL 2b: Cultural Resources Study Requirements.

Prior to approval of development permits for multifamily projects that include ground-disturbing activities, City staff shall review the most recent and updated Northwest Information Center (NWIC) list: Historic Property Directory for the County of Santa Clara, to determine if known archaeological sites underlie the proposed project site. If it is determined that known cultural resources are within 0.25-mile of the project site, the City shall require a site-specific cultural resources study by an archaeologist meeting the U.S. Secretary of the Interior’s Standards (SOIS) for Archeology. The study shall consist of a cultural report that includes the results of: a cultural resources records search performed at the NWIC of the California Historical Resources Information System for the project area, a pedestrian survey of the project area, a historic context, an assessment of the sensitivity of the project area for buried precontact and historic-era resources, and identify if the project would potentially impact cultural resources. If the archaeologist determines that known cultural resources or potential archaeological sensitivity areas may be impacted by the project, additional research or treatment, potentially including subsurface testing, and/or a cultural resources awareness training may be required to identify, evaluate, and mitigate impacts to cultural resources, as recommended by the SOIS qualified archaeologist. If avoidance is not feasible, the City shall consult with appropriate Native American tribes (if the resource is pre-contact or indigenous), and other appropriate interested parties to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2, and CEQA Guidelines Section 15126.4. This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3). The cultural report detailing the results of the research shall be prepared and submitted for review by the City and a final draft shall be submitted to the NWIC.

2. Summary
City of Mountain View Housing Element Update 2-15 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact CUL 3: Implementation of the HEU may disturb any human remains, including those interred outside of dedicated cemeteries. (Less than Significant)
None required Less Than Significant
Impact TCR-1: Implementation of the HEU may cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074. (Less than Significant with Mitigation)
Mitigation Measure CUL 2a: Inadvertent Discovery of Cultural Resources. See above.

Mitigation Measure CUL 2b: Cultural Resources Study Requirements. See above.

Less Than Significant
Impact CUL 1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on historic architectural resources. (Less than Significant with Mitigation) Mitigation Measure CUL 1a: Historic Resource Evaluation. See above.

Mitigation Measure CUL 1b: Historic Resource Avoidance. See above.

Less Than Significant
Impact CUL 2.CU: Implementation of the HEU, in combination with other cumulative development, would not cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5 or could disturb human remains, including those interred outside of formal cemeteries. (Less than Significant Impact, with Mitigation) Mitigation Measure CUL 2a: Inadvertent Discovery of Cultural Resources. See above.

Mitigation Measure CUL 2b: Cultural Resources Study Requirements. See above.

Less Than Significant
Impact TCR-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, could contribute considerably to cumulative impacts on tribal cultural resources. (Less than Significant with Mitigation)
Mitigation Measure CUL 2a: Inadvertent Discovery of Cultural Resources. See above.

Mitigation Measure CUL 2b: Cultural Resources Study Requirements. See above.

Less Than Significant
Section 4.5, Energy
Impact ENE-1: Implementation of the HEU would not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation or conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant)
None required Less Than Significant Impact ENE-1.CU: Implementation of the HEU would not result in wasteful, inefficient, or unnecessary consumption of energy resources during project construction and operation or conflict with or obstruct a state or local plan for renewable energy or energy efficiency. (Less than Significant)
None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-16 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Section 4.6, Geology, Soils, and Paleontological Resources Impact GEO-1: Implementation of the HEU would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault or strong seismic ground shaking. (Less than Significant)
None required Less Than Significant
Impact GEO-2: Implementation of the HEU would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction. (Less than Significant) None required Less Than Significant
Impact GEO-3: Implementation of the HEU would not directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides. (Less than Significant)
None required Less Than Significant
Impact GEO-4: Implementation of the HEU would not result in substantial soil erosion or the loss of topsoil. (Less than Significant)
None required Less Than Significant
Impact GEO-5: Implementation of the HEU would not be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse. (Less than Significant)
None required Less Than Significant
Impact GEO-6: Implementation of the HEU would not be located on expansive soil, creating substantial direct or indirect risks to life or property. (Less than Significant)
None required Less Than Significant
Impact GEO-7: Implementation of the HEU would not directly or indirectly destroy a unique paleontological resource or site or unique geologic feature. (Less than Significant with Mitigation) None required Less Than Significant
Impact GEO-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on geology, soils, or paleontological resources. (Less than Significant) None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-17 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Section 4.7, Greenhouse Gas Emissions
Impact GHG-1: Implementation of the HEU would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. (Less than Significant with Mitigation)
Mitigation Measure GHG-1: Require Compliance with EV Requirements in CALGreen Tier 2.

Subsequent development projects proposed as part of the HEU shall comply with EV requirements in the most recently adopted version of CALGreen Tier 2 at the time that a building permit application is filed.

Mitigation Measure TRA-1: Implement VMT Reduction Measures. See Section 4.14, Transportation, below.

Less Than Significant
Impact GHG-2: Implementation of the HEU would not conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. (Less than
Significant with Mitigation)
Mitigation Measure GHG-1: Require Compliance with EV Requirements in CALGreen Tier 2.

See above.

Mitigation Measure TRA-1: Implement VMT Reduction Measures. See Section 4.14, Transportation, below.

Less Than Significant
Impact GHG-1.CU: Implementation of the HEU, in combination with past, present, existing, approved, pending, and reasonably foreseeable future pro jects, would result in a cumulatively considerable contribution to GHG emissions that may have a significant impact on the environment or conflict with applicable plans, policies or regulations adopted for the purpose of reducing the emissions of greenhouse gases. (Less than Significant with Mitigation)
Mitigation Measure GHG-1: Require Compliance with EV Requirements in CALGreen Tier 2.

See above.

Mitigation Measure TRA-1: Implement VMT Reduction Measures. See Section 4.14, Transportation, below.

Less Than Significant
Section 4.8, Hazards and Hazardous Materials
Impact HAZ-1: Implementation of the HEU would not create a significant hazard to the public or the environment through the routine transport, use, disposal, or accidental release of hazardous materials. (Less than Significant)
None required Less Than Significant
Impact HAZ-2: Implementation of the HEU would not Emit
hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. (Less than Significant)
None required Less Than Significant
Impact HAZ-3: Implementation of the HEU would not be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code § 65962.5 and, as a result, would it create a significant hazard to the public or the environment. (Less than Significant with Mitigation)
Mitigation Measure HAZ-1: Phase I Environmental Site Assessment.

Prior to the initiation of any construction requiring ground-disturbing activities on listed active hazardous materials cleanup sites, the project applicant shall complete a Phase I environmental site assessment for that property in accordance with American Society for Testing and Materials Standard E1527 for those active hazardous materials sites to ascertain their current status. Any recommended follow up sampling (i.e., Phase II activities) set forth in the Phase I assessment shall be implemented prior to construction. The results of Phase II studies, if necessary, shall be Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-18 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
submitted to the local overseeing agency and any required remediation or further delineation of identified contamination shall be completed prior to commencement of construction.

Prior to final project design of any individual project that includes any earth-disturbing activities, the project applicant shall conduct a Phase I Environmental Site Assessment (Phase I assessment). The Phase I assessment shall be prepared in general accordance with ASTM Standard E1527-21, Standard Practice for Environmental Site Assessment: Phase I Environmental Site Assessment Process (or most current edition that is in force at the time of final project design), which is the current industry standard. The Phase I assessment shall include a records review of appropriate federal, State, and local databases within ASTM-listed search distances regarding hazardous materials use, storage, or disposal at the given site, a review of historical topographic maps and aerial photographs, a site reconnaissance, interviews with persons knowledgeable about the sites historical uses, and review of other relevant existing information that could identify the potential existence of Recognized Environmental Conditions, including hazardous materials, or contaminated soil or groundwater. If no Recognized Environmental Conditions are identified, then no further action would be required.

If Recognized Environmental Conditions are identified and the Phase I assessment recommends further action, the project applicant shall conduct the appropriate follow-up actions, which may include further records review, sampling of potentially hazardous materials, and possibly site cleanup. In the event that site cleanup is required, the project shall not proceed until the site has been cleaned up to the satisfaction of the appropriate regulatory agency (e.g., DTSC, RWQCB, or SCCEHD) such that the regulatory agency issues a No Further Action letter or equivalent.

Impact HAZ-4: Implementation of the HEU would not result in a safety hazard or excessive noise for people residing or working in the project area related to a public airport or public use airport. (Less than Significant)
None required Less Than Significant
Impact HAZ-5: Implementation of the HEU would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan. (Less than Significant)
None required Less Than Significant
Impact HAZ-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts relative to hazards and hazardous materials. (Less than Significant) None required Less Than Significant
Section 4.9, Hydrology and Water Quality
Impact HYD-1: Implementation of the HEU would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. (Less than Significant)
None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-19 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact HYD-2: Implementation of the HEU would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin. (Less than Significant) None required Less Than Significant
Impact HYD-3: Implementation of the HEU would not substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would: i) result in substantial erosion or siltation on- or off-site; ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or iv) impede or redirect flood flows. (Less than Significant)
None required Less Than Significant
Impact HYD-4: Implementation of the HEU would not risk release of pollutants due to project inundation due to being located in a flood hazard zone. (Less than Significant)
None required Less Than Significant
Impact HYD-5: Implementation of the HEU would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan. (Less than Significant) None required Less Than Significant
Impact HYD-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on hydrology and water quality. (Less than Significant)
None required Less Than Significant
Section 4.10, Land Use and Planning
Impact LUP-1: Implementation of the HEU would not physically divide an established community. (Less than Significant) None required Less Than Significant
Impact LUP-2: Implementation of the HEU would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. (Less than Significant) None required Less Than Significant
Impact LUP-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not physically divide an established community. (Less than Significant)
None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-20 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact LUP-2.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. (Less than Significant)
None required Less Than Significant
Section 4.11, Noise
Impact NOI-1: Implementation of the HEU would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant) None required Less Than Significant
Impact NOI-2: Stationary noise sources from development within the HEU area would not result in a substantial permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant) None required Less Than Significant
Impact NO-3: Implementation of the HEU would not generate excessive groundborne vibration or groundborne noise levels. (Less than Significant)
None required Less Than Significant
Impact NOI-4: Transportation increases along roadways under the HEU would not result in a substantial permanent increase in ambient noise levels in the project vicinity above baseline levels without the project. (Less than Significant)
None required Less Than Significant
Impact NOI-5: Implementation of the HEU would not expose people residing or working in the project area to excessive noise levels due to being located within the vicinity of a private airstrip or an airport land use plan or within two miles of a public airport or public use airport. (Less than Significant)
None required Less Than Significant
Impact NOI-1.CU: Construction activities associated with implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not result in generation of a substantial temporary increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant) None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-21 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact NOI-2.CU: Stationary noise sources from development within the HEU area, when combined with other past, present, or reasonably foreseeable projects, would not result in a substantial permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. (Less than Significant)
None required Less Than Significant
Impact NOI-3.CU: Construction activities associated with implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not result in exposure of persons to or generation of excessive ground borne vibration levels. (Less than Significant)
None required Less Than Significant
Impact NOI-4.CU: Transportation activities under the HEU, when combined with other past, present, or reasonably foreseeable projects, would not result in a substantial permanent increase in ambient noise levels in the project vicinity above baseline levels without the project and cumulative development. (Less than Significant)
None required Less Than Significant
Section 4.12, Population and Housing
Impact POP-1: Implementation of the HEU would not induce substantial unplanned population growth in an area, either directly or indirectly. (Less than Significant)
None required Less Than Significant
Impact POP-2: Implementation of the HEU would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. (Less than Significant)
None required Less Than Significant
Impact POP-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on population and housing. (Less than Significant)
None required Less Than Significant
Section 4.13, Public Services and Recreation
Impact PSR-1: Implementation of the HEU would not result in substantial adverse physical impacts associated with the provision of or need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-22 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
other performance objectives for fire protection. (Less than Significant)
Impact PSR-2: Implementation of the HEU would not result in substantial adverse physical impacts associated with the provision of or need for new or physically altered police facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police protection. (Less than Significant)
None required Less Than Significant
Impact PSR-3: Implementation of the HEU would not result in substantial adverse physical impacts associated with the provision of or need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools. (Less than Significant) None required Less Than Significant
Impact PSR-4: Implementation of the HEU would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. (Less than Significant) None required Less Than Significant
Impact PSR-5: Implementation of the HEU would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. (Less than Significant)
None required Less Than Significant
Impact PSR-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on public services that would require new or physically altered governmental facilities, construction of which could have significant physical environmental impacts. (Less than Significant)
None required Less Than Significant
Impact PSR-2.CU: Implementation of the HEU, combined with cumulative development in the vicinity and citywide, would not result in significant cumulative impacts to parks and recreation. (Less than Significant Impact)
None required Less Than Significant

2. Summary
City of Mountain View Housing Element Update 2-23 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Section 4.14, Transportation
Impact TRA-1: Implementation of The HEU would not conflict with an applicable program, plan, ordinance, or policy establishing measures of effectiveness for the performance of addressing the circulation system, including transit, bicycle, and pedestrian facilities. (Less than Significant)
None required Less Than Significant
Impact TRA-2: Implementation of the HEU would not exceed an applicable VMT threshold of significance. (Less than Significant with Mitigation)
Mitigation Measure TRA-1: Implement Vehicle Miles Traveled (VMT) Reduction Measures.

Individual multifamily housing development proposals that do not screen out from VMT impact analysis shall provide a quantitative VMT analysis using the methods outlined by the City’s most recent VMT guidelines. Projects that result in a significant impact shall include travel demand management measures and/or physical measures (i.e. improving multimodal transportation network, improving street connectivity) to reduce VMT. The City’s VMT guidelines identify four tiers of mitigation measures, all of which can be quantified within the Santa Clara Valley Transportation Authority (VTA) VMT tool:
• Tier 1— Project Characteristics. Although it may be difficult to revise a project during environmental review, Tier 1 strategies allow the user to increase the project density, diversity of land uses, and add affordable and/or below-market-rate housing to the residential and employment projects to reduce VMT.
• Tier 2—Multi-Modal Network Improvements. These improvements include implementing bicycle lanes, improving the pedestrian network, implementing traffic calming, increasing transit accessibility, and improving network connectivity. These improvements require coordination with Mountain View staff and additional studies (signal warrant studies, traffic calming studies, etc.) to determine feasibility. Consultants should prioritize public improvements included in the City’s approved plans which contain various transportation improvements to bicycle, pedestrian, and roadway facilities as VMT mitigation. (See above for list of adopted plans and policies.) • Tier 3—Parking. Parking strategies shown to effectively reduce VMT include reduced parking, increased bike parking or end-of-trip bike facilities. In order to be most effective, the areas surrounding the projects with reduced parking should have parking permit programs. • Tier 4—Travel Demand Management (TDM) There are a multitude of TDM measures to reduce VMT. The VMT Tool includes all allowable TDM measures and their relative effectiveness.

Based on the percentage of participation selected by the user, the VMT Tool calculates the resulting VMT reduction. The various TDM measures in the VMT Tool include school carpool programs, bike-sharing programs, car-sharing programs, trip reduction marketing/educational campaigns, parking cash-out, subsidized transit, telecommuting, alternative work schedules, shuttles, pay to park, ride-sharing, unbundled parking, and subsidized vanpools.

Less Than Significant
Impact TRA-3: Implementation of the HEU would not substantially increase hazards due to a geometric design feature or
incompatible uses. (Less than Significant)
None required Less Than Significant
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2. Summary
City of Mountain View Housing Element Update 2-24 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact TRA-4: Implementation of the HEU would not result in inadequate emergency access. (Less than Significant)
None required Less Than Significant
Impact TRA-1.CU: Implementation of the HEU, in combination with cumulative development, would not conflict with an applicable program, plan, ordinance or policy establishing measures of effectiveness for the performance of addressing the circulation system, including transit, bicycle, and pedestrian facilities. (Less than Significant)
None required Less Than Significant
Impact TRA-2.CU: Implementation of the HEU, in combination with cumulative development, would not exceed an applicable VMT threshold of significance. (Significant and Unavoidable with Mitigation)
Mitigation Measure TRA-1: Implement VMT Reduction Measures. See above. Significant and Unavoidable Impact TRA-3.CU: Implementation of the HEU, in combination with cumulative development, would not substantially increase hazards due to a geometric design feature or incompatible uses. (Less than Significant)
None required Less Than Significant
Impact TRA-4.CU: Implementation of the HEU, in combination with cumulative development, would not result in inadequate emergency access. (Less than Significant)
None required Less Than Significant
Section 4.15, Utilities and Service Systems
Impact UTL-1: Implementation of the HEU would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. (Less than Significant with Mitigation)
Mitigation Measure UTL-1: Fair-Share Contributions Toward Utility Improvements.

Subsequent development projects shall contribute the fair share amount identified by the City of Mountain View Public Works Department to fund capital improvements to the water, sanitary sewer, and stormwater drainage systems prior to issuance of a building permit.

Less Than Significant
Impact UTL-2: Implementation of the HEU would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. (Less than Significant)
None required Less Than Significant
Impact UTL-3: Implementation of the HEU would result in a determination by the wastewater treatment provider, which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. (Less than Significant)
None required Less Than Significant
I I

2. Summary
City of Mountain View Housing Element Update 2-25 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 2-2 (CONTINUED)

S UMMARY OF IMPACTS AND MITIGATION MEASURES FOR THE PROJECT Impacts Mitigation Measures
Significance
After Incorporation of
Mitigation
Impact UTL-4: Implementation of the HEU would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. (Less than Significant)
None required Less Than Significant
Impact UTL-5: Implementation of the HEU would not Comply with federal, state, and local management and reduction statutes and regulations related to solid waste. (Less than Significant) None required Less Than Significant
Impact UTL-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on utility infrastructure. (Less than Significant with Mitigation) Mitigation Measure UTL-1: Fair-Share Contributions Toward Utility Improvements. See above.

Less Than Significant
Impact UTL-2.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on water supply. (Less than Significant)
None required Less Than Significant
Impact UTL-3.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on wastewater treatment capacity. (Less than Significant)
None required Less Than Significant
Impact UTL-4.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable projects, would not contribute considerably to cumulative impacts on solid waste. (Less than Significant)
None required Less Than Significant

2. Summary
City of Mountain View Housing Element Update 2-26 ESA / 202000806 Draft Environmental Impact Report July 2022

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City of Mountain View Housing Element Update 3-1 ESA / 202000806 Draft Environmental Impact Report July 2022
CHAPTER 3
Project Description

3.1 Introduction
State law requires the City to have and maintain a general plan with specific contents in order to provide a vision for the City’s future. The general plan informs local decisions about land use and development, including issues such as circulation, conservation, and safety. The City of Mountain View’s 2030 General Plan was comprehensively updated in 2012 and identifies major themes and overarching strategies related to quality of life, sustainability, diversity, health and wellness, and economic prosperity. The 2030 General Plan update included six topical chapters or “elements” and one chapter summarizing the character of eight planning areas and identifying policies specific to each area. The City maintains
the Housing Element of its General Plan
as a separate document, although it
comprises an integral part of the overall
plan, providing goals, policies, and
programs regarding the preservation and
development of housing in the City.

The City’s Housing Element was last
updated in 2014, and covers the
“5
th Cycle” housing element planning
period from 2014 through 2022. Because
this period is drawing to a close, State
law [Government Code Section 65588]
requires the City to update its Housing Element by the deadline of January 31, 2023. In accordance with State law, the planning period for the updated Housing Element is from January 31, 2023 to January 31, 2031 and is referred to as the “6 th cycle.”
Concurrent with the Housing Element update, the City proposes to undertake any changes to the City’s General Plan Land Use Map, zoning ordinance, Zoning Map and Precise Plans that are needed to reflect the updated Housing Element and to maintain consistency with the General Plan. Over the course of implementing the Housing Element, the City may also update the General Plan Land Use Map, Zoning Ordinance, Zoning Map and Precise Plans as directed by the Housing Element. These proposed actions (updates to the Housing Element of the General Plan, General Plan Land Use Map, and conforming changes to the Zoning Ordinance, Zoning Map and Precise Plans) are the subject of this Environmental Impact Report (EIR), and are collectively referred to as the Housing Element Update (HEU) or “the Project.” The HEU is described in this Current Contents of the
Mountain View 2030 General Plan*

1. Planning Areas

2. Land Use and Design

3. Mobility

4. Infrastructure and Conservation

5. Parks, Open Space and Community Facilities

6. Noise

7. Public Safety

8. Housing Element (separately updated in
2014)

*As amended thru April 2021

3. Project Description

City of Mountain View Housing Element Update 3-2 ESA / 202000806 Draft Environmental Impact Report July 2022
chapter, which also provides background information, project objectives, and describes intended uses of the EIR, including approval actions required.

3.2 Project Location and Setting
The proposed Project would update the City of Mountain View’s Housing Element, which is a policy document that addresses housing issues and applies citywide. The housing sites inventory component of the housing element primarily identifies sites for development of multifamily housing that are principally located within the boundaries of adopted Precise Plans (see Section 3.3.1 below) and along commercial corridors, though sites are also included from other parts of the City.

The City includes approximately 12.24 square miles and is located in northern Santa Clara County; it borders the San Francisco Bay to the North, the City of Palo Alto to the West, the City of Los Altos to the South and Southwest, and Moffett Federal Airfield and the City of Sunnyvale to the East. (See Figure 3-1.)

3.3 Background
The City’s current General Plan land use designations, zoning, and precise plans provide for development of multifamily housing in many areas of the City and provides the context for the HEU and its inventory of housing sites. This section provides a summary of these existing land use controls as well as a summary of required components of the HEU.

3.3.1 Existing Planning and Zoning
2030 General Plan
The 2030 General Plan is the guiding document for the City's physical development and preservation. It includes goals, policies and graphics that convey a long-term vision and guide local decision-making to achieve that vision. Included in the 2030 General Plan are land use designations and a land use map. Land use designations define the type, intensity and density of development within the City, and include five general groups: Residential; Commercial; Office/ Industrial; Mixed-Use; and Public/Institutional. Multifamily residential uses are allowed under the Residential and Mixed-Use land use designations at varying densities ranging from 7 to 80 dwelling units per acre in residential designations or 1.05 to 3.0 FAR in mixed-use designations.

Zoning Ordinance
The City’s Zoning Ordinance plays a key role in regulating development type, density, and land use, and generally supports the vision of the 2030 General Plan. Development standards identified in the Zoning Ordinance include setbacks, lot area, lot width, density, floor area ratio, site coverage, landscaping and open area requirements, height limits, storage, and parking. The Zoning Ordinance organizes zoning districts into four broad categories: residential; commercial/professional; industrial; and special purpose. Multifamily residential units are permitted uses under the R3 (Residential—Multiple-Family), R4 (Residential—High-Density Multiple-Family), and Planned community (P) districts.

CENTRAL EXPY

W EL CAMINO REAL

N SHORELINE BLVD

CASTRO ST

CHARLESTON RD

E MIDDLEFIELD RD

E EL CAMINO REAL

OLD MIDDLEFIELD WAY

SAN ANTONIO RD
101
85 237

CITY OF

PALO ALTO
NASA Ames
Research Center
El Camino
Hospital

CITY OF

LOS ALTOS
Downtown
Shoreline Park
101 237

SAN MATEO
COUNTY

ALAMEDA
COUNTY

TOWN OF

LOS ALTOS
HILLS

CITY OF

SUNNYVALE
Moffett Field
San Antonio
Center

OREGON EXPY

FOOTHILL EXPY
280

SAN FRANCISCO
BAY

ALAMEDA
COUNTY
miles

1.00 .5
Sphere of Influence and Planning Area
Freeways
City Limits
Major Roads
Bodies of Water
24 17
1 9
9 880
680
101
580

REGIONAL

LOCATION

PROJECT LOCATION
Los Gatos
Mountain ViewMountain View
Palo AltoPalo Alto
Berkeley
San FranciscoSan Francisco
San MateoSan Mateo

PACIFIC OCEAN
San Jose
280
1 101
Palo AltoLos Altos
HaywardHayward
FIGURE III-1
SOURCE: CITY OF MOUNTAIN VIEW, 2011.

I:\CMT0801 Mtn View\figures\EIR\Fig_III1.ai (11/7/11)
City of Mountain View
Draft General Plan and
Greenhouse Gas Reduction Program EIR
Sphere of Influence and Planning Area
miles

1.00 .5
Sphere of Influence and Planning Area
Freeways
City Limits
Major Roads
Bodies of Water
City of Mountain View Housing Element Update
Figure 3-1
Project Location Map
SOURCE: City of Mountain View, 20112020\D202000806.00 - City of Mountain View Housing Element (2023-2031)\05 Graphics-GIS-Modeling\Illustrator r ESA
~
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----
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3. Project Description

City of Mountain View Housing Element Update 3-4 ESA / 202000806 Draft Environmental Impact Report July 2022
Precise Plans
To address site-specific development needs, the City has developed 25 Precise Plans covering various locations within the City. Precise Plans are a tool for coordinating future public and private improvements on specific properties where special conditions of size, shape, land owner- ship, or existing or desired development require particular attention. The Precise Plans provide detailed specifications for land uses, relationship to surrounding areas, use intensity, circulation, design, procedures for development review, and special conditions for development occurring within each Precise Plan area. The City’s Precise Plan areas are shown in Figure 3-2. In the City, Precise Plans range from a small 3-acre development to large neighborhoods. The Precise Plans covering the largest areas and with the highest development potential as relevant to the HEU are detailed below:

East Whisman Precise Plan
The East Whisman Precise Plan (adopted November 5, 2019, as amended through October 13, 2020) advances a sustainable, transit-oriented area with complete mixed-use neighborhoods and enhanced area mobility in an approximately 412-acre area on the eastern border of the City. It includes land use and development regulations for up to 2 million square feet of net new office uses, 100,000 square feet of retail uses, 200 hotel rooms, and 5,000 multi-family residential units (with goal of making 20 percent of the total residential units affordable).

North Bayshore Precise Plan
The North Bayshore Precise Plan (adopted November 25, 2014, as amended through December 7, 2021) supports transition of an approximately 650-acre area in the northern portion of the City into an innovative, sustainable, and complete mixed-use district that protects and stewards biological habitat and open space, and continues its role as a major high-technology employment center. The original North Bayshore Precise Plan did not include residential uses, but updates to the development standards and design guidelines of the plan adopted in December 2017 added residential uses in the areas designated for mixed-use development. The North Bayshore Precise Plan provides a vision and guiding principles, development standards, and design guidelines for up to 9,850 new multi-family residential units and 3.6 million square feet of office and commercial development. The North Bayshore Precise Plan has a target of approximately 20 percent of residential units being affordable.

El Camino Real Precise Plan
The El Camino Real Precise Plan (adopted November 17, 2014, as amended through April 13, 2021) provides planning priorities, development regulations, and an implementation strategy for the 3.9-mile stretch of the El Camino Real that runs through Mountain View. The El Camino Real Precise Plan contains direction for potential street improvements, and implementation actions, standards and guidelines for new residential densities and focused commercial areas.

UV237
RT 85
£¤101
UV85
North Bayshore
Moffett/Whisman Road
Central Neighborhoods
Grant Road
/Sylvan Park
Springer/Cuesta/Phyllis
Monta Loma/Farley
/Rock Street
San Antonio/Rengstorff
NASA Ames
(Federal)
North Bayshore
East Whisman
El Camino Real
San Antonio
Downtown
East Whisman
El Camino Real
Whisman Station
Sylvan - Dale
El Camino
Medical Park
Evandale
Mayfield
South Whisman
Villa Mariposa
Evelyn Avenue Corridor
San Antonio Station
Grant - Phyllis
111 Ferry-Morse Way
1101 Grant Road
Grant - Martens
Mora - Ortega
San Ramon
California - Ortega
Sylvan - Dale
460 North
Shoreline Boulevard
Castro - Miramonte Triangle
2100 California Street
Path: U:\GIS\GIS\Projects\2020xxx\D202000806_Mtn_View_Housing_Element\03_MXDs_Projects\NOP\Fig1_ProjectLocation.mxd, JNielsen 2/1/2022 SOURCE: ESRI, 2021.

N
0 2,000
Feet
City of Mountain View
Noticing Neighborhoods
Precise Plan
City of Mountain View
Figure 1
Project Location
City of Mountain View Housing Element Update
Figure 3-2
Neighborhoods and Precise Plan Locations
SOURCE: ESRI, 2021.
0-=-
r ESA
~
- CJ
CJ
D

3. Project Description

City of Mountain View Housing Element Update 3-6 ESA / 202000806 Draft Environmental Impact Report July 2022
San Antonio Precise Plan
The San Antonio Precise Plan (adopted December 2, 2014, as amended through November 17, 2020) guides the transformation of the existing regional commercial area into a mixed-use core within a broader existing residential neighborhood, taking into account the area’s proximity to transit services and location along two of the most heavily traveled corridors in the City:

El Camino Real and San Antonio Road. The San Antonio Precise Plan identifies planning principles and policies, development regulations, mobility improvements and an implementation strategy for approximately 123 acres of land including and surrounding the San Antonio Center shopping area. It also includes allowances for higher densities of housing, and an office cap of 600,000 square feet.

3.3.2 Housing Element Requirements
State law requires that the City’s Housing Element be updated by January 31, 2023 and that it contain specific contents, including: an updated assessment of housing need; updated goals, policies, and programs; and an inventory or list of housing sites at sufficient densities to accommodate a specific number of units at various levels of affordability assigned to the City by the Association of Bay Area Governments (ABAG). ABAG assigns unit amounts to Bay Area jurisdictions based on a regional housing production target set by the California Department of Housing and Community Development (HCD). This assignment is referred to as the Regional Housing Needs Allocation (RHNA).

The City’s existing 5th Cycle Housing Element for the period from 2015 to 2023 includes a housing sites inventory sufficient to accommodate the 2015 RHNA allocation of 2,926 units. In the 2018 annual progress report (APR), the City utilized the recently-updated North Bayshore Precise Plan to replace lower and moderate income sites lost to redevelopment, as well as to create a significant buffer. A buffer is necessary to ensure that if one or more of the identified sites are developed at lower densities than projected, or with non-housing uses, the inventory maintains sufficient capacity to provide an ongoing supply of sites for housing during the eight- year planning period/cycle of the Housing Element. If there were no buffer and an identified site developed with a non-housing project or developed at a density less than that anticipated in the Housing Element, then the City could be obliged to identify new sites and amend the Housing Element prior to the end of the cycle.

The need for a substantial buffer is even more important during the 6th Cycle Housing Element Update because of new rules in the Housing Accountability Act’s “no net loss” provisions.

California State Senate Bill 166 (2017) required that the land inventory and site identification programs in the Housing Element always include sufficient sites to accommodate the unmet RHNA. This means that if a site is identified in the Housing Element as having the potential for housing development that could accommodate lower‐income units is actually developed with units at a higher income level, then the locality must either identify and rezone, if necessary, an adequate substitute site or demonstrate that the land inventory already contains an adequate substitute site. An adequate buffer will be critical to ensure that the City remains compliant with these provisions without having to identify and rezone sites prior to the end of the housing cycle in early 2031.

3. Project Description

City of Mountain View Housing Element Update 3-7 ESA / 202000806 Draft Environmental Impact Report July 2022
On December 16, 2021, ABAG adopted the Final RHNA, which distributed the regional housing need of 441,176 units across all local jurisdictions in the nine-county Bay Area. Each jurisdiction’s RHNA includes an allocation of housing need (units) in four income-based categories: very low income, low income, moderate income, and above moderate income. The four categories are defined based on the household’s percentage of Area Median Income (AMI).

Specifically, very low income units accommodate households at 0-50 percent of AMI, low income units accommodate households at 51-80 percent of AMI, moderate income units accommodate households at 81-120 percent of AMI, and above moderate income units accommodate households at greater than 120 percent of AMI. As a point of reference, Santa Clara County’s 2021 Area Median Income (AMI) for a household of four persons is $151,300.

City’s HEU must plan for its RHNA allocation of housing units by income group, and a buffer is recommended by HCD to ensure that sufficient capacity exists in the Housing Element to accommodate the RHNA throughout the planning period. Table 3-2 shows the City’s RHNA across the four income categories.

TABLE 3-1

M OUNTAIN VIEW REGIONAL HOUSING NEEDS ALLOCATION
6TH HOUSING ELEMENT CYCLE (2023-2031)
Very Low
Income Units
(0-50% AMI)
Low Income
Units
(51-80% AMI)
Moderate
Income Units
(81-120% AMI)
Above Mod
Units
(>120% AMI)
Total New
Units
6th Cycle RHNA 2,773 1,597 1,885 4,880 11,135
% of Total 25% 14% 17% 44% 100%
SOURCE: Association of Bay Area Governments (ABAG), Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031 adopted December 2021.

The 11,135 total housing units required in the 6th Cycle RHNA are substantially higher than the City’s 5th Cycle RHNA of 2,926 units in part because the Bay Area region’s overall allocation of 441,176 units from HCD is more than double the last Housing Element cycle’s allocation, which was approximately 189,000 units.

The HEU is required to identify housing sites to meet the City’s RHNA at specified levels of affordability. HCD recommends that jurisdictions plan for their RHNA plus a buffer of additional units equivalent to 15-30 percent. To be conservative, the City intends to identify a buffer of at least 20 to 30 percent of units at all income levels and a total unit capacity of up to approximately 15,000 units. Inclusion of a generous buffer is in the City’s interest because:
• As the analysis of the Housing Element Update progresses through the preparation and adoption process, sites may be modified or removed from the inventory; and • A generous buffer would avoid the need to identify and potentially rezone additional sites if one or more sites included in the Housing Element to accommodate lower or moderate income housing later develops with fewer such units during the eight year planning period.

3. Project Description

City of Mountain View Housing Element Update 3-8 ESA / 202000806 Draft Environmental Impact Report July 2022
While a significant number of identified sites will already have adequate Zoning for the units identified, the City is also choosing to rezone some of the identified sites and amend applicable Precise Plans to create the desired buffer proposed in the inventory (the rezonings are not necessary to meet the RHNA). Over the course of the 6th Cycle, the City’s buffer may be exhausted and the City may need to amend the General Plan Map, the Zoning Map, and the Zoning Ordinance to accommodate any shortfalls. As noted below in Section 3.4, the number of sites likely to require rezoning represents a small percentage of the total inventory.

While State law requires the Housing Element to include an inventory of housing sites and requires the City to appropriately zone sites for multifamily housing, the City is not required to actually develop/construct housing on these sites. Future development on identified sites would be at the discretion of individual property owners and would be largely dependent on market forces and -- in the case of affordable housing -- available funding and/or other incentives.

Nonetheless, this EIR considers potential impacts of development that may result from adoption of the HEU, focusing on proposed actions to encourage housing production such as changes in allowable densities, changes in development standards, and adoption of incentives.

3.4 Proj ect Description
The Project analyzed in this EIR would include adoption of a General Plan amendment to add or modify goals, objectives, policies, and implementation programs related to housing in the Housing Element of the City’s General Plan.

The Housing Element itself would contain:
• An updated housing needs assessment;
• Updated goals, policies, and programs that address the maintenance, preservation, improvement, and development of housing and that affirmatively further fair housing; • A housing inventory that meets the City’s RHNA and provides a buffer of additional housing development capacity.

The Project would also include modifications to provisions in the City’s General Plan land use map, zoning ordinance, zoning map, and adopted Precise Plans, as needed, to reflect the housing sites inventory, which is described below.

3.4.1 Housing Needs Assessment & Updated Goals,
Policies, and Programs
The proposed Project would adopt updated goals, policies, and programs to address the maintenance, preservation, improvement, and development of housing and to affirmatively further fair housing in the City. Proposed updates to the goals, policies, and programs in the 5th Cycle Housing Element were informed by a review of the implementation and effectiveness of that document, as well as updated information on demographic and economic trends, existing housing and market conditions, and special housing needs experienced by disabled persons, elderly households, large family households, single female-headed households, and homeless

3. Project Description

City of Mountain View Housing Element Update 3-9 ESA / 202000806 Draft Environmental Impact Report July 2022
persons. The proposed goals, policies, and programs were also crafted to address an updated assessment of non-governmental and governmental constraints to the development, conservation, and rehabilitation of housing in the City, and to affirmatively further fair housing. For more information, including the definition of these terms, and the proposed updates to goals, policies, and programs, please see the HCD Draft Housing Element Update available on the City’s website at https://www.mvhousingelement.org/ and included as Appendix B.

3.4.2 Housing Sites Inventory
The proposed Project would address the requirements for a housing inventory and meet the City’s 6 th Cycle RHNA plus a buffer via a number of strategies as provided for in State law and HCD guidance. See Figure 3-3 for an overview of housing site locations included in the HEU.

Existing Zoning and General Plan Capacity
Pipeline Projects. The City has approved a number of housing and mixed-use projects that are likely to result in production of multifamily housing during the housing element planning period.

The City also has active applications on file for single family and multifamily housing and/or mixed use developments that may be approved, constructed, and occupied during the housing element planning period. These types of “pipeline projects” would count towards the City’s RHNA, and could collectively total at least 8,600 units by 2031, not including pipeline rezoning projects (described below).

Accessory Dwelling Units. The City may assume that the development of accessory dwelling units (ADUs) during the planning period is equivalent to that in recent years. Based on information contained in the City’s annual production reports to HCD, approximately 96 ADUs are assumed over the eight year planning period.

Existing Opportunity Sites. The City’s existing precise plans, General Plan Land Use designations, and zoning permit a range of residential densities in different areas of the City that can accommodate development of multifamily housing without adjustment. A preliminary analysis estimates that there may be sufficient sites to accommodate approximately 4,700 units.

Most of these sites are within Precise Plan areas, including El Camino Real, San Antonio, North Bayshore, and East Whisman, although there are sites identified for inclusion in the inventory in other areas of the City as well. See Figure 3-2 for a map showing City neighborhoods and precise plan locations.
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UV82
Miramonte Ave
Middlefield Rd
California St
Levin Ave
Rengstorff Ave
Bryant Ave
Ellis St
N Shoreline Blvd
Charleston Rd
Sylvan Ave
Calderon Ave
Shoreline Blvd
E Middlefield Rd
Old Middlefield Way
Central Expy
North Bayshore
Moffett/Whisman Road
Grant Road/Sylvan Park
Springer/Cuesta/Phyllis
Monta Loma/Farley/Rock Street
Central Neighborhoods
San Antonio/Rengstorff
NASA Ames
(Federal)
NASA Ames
(Federal)
Path: U:\GIS\GIS\Projects\2020xxx\D202000806_Mtn_View_Housing_Element\03_MXDs_Projects\HousingElement\Fig87_OverviewAllHousingSites.mxd,  JNielsen  5/4/2022 SOURCE: ESRI, 2022.

N
0 4,000
Feet
City of Mountain View
Neighborhoods
Pipeline Projects
100% Affordable Housing
Project
Approved, Under Review
(Formal), and Under
Review (Informal)
Pipeline Projects -
Rezoning Required
Opportunity Sites
Opportunity Sites - No
Rezoning Required
Opportunity Sites -
Rezoning Required
Rezone Area for General
Plan Village Center Sites
Rezone Area for El
Camino Real Village
Center Sites
City of Mountain View Housing Element Update
Figure 3-3
Housing Site Locations Overview
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3. Project Description

City of Mountain View Housing Element Update 3-11 ESA / 202000806 Draft Environmental Impact Report July 2022
General Plan, Zoning and Precise Plan Amendments
Pipeline Sites Requiring Rezoning and General Plan Amendment. There are a limited number of sites that could accommodate multifamily housing – and in some cases specifically affordable housing for lower income households – if rezoned to allow residential use at appropriate densities. These sites, which include development projects under review and under discussion are located at, 1265 Montecito Avenue, 1020 Terra Bella Avenue, 1010 Linda Vista Avenue and East Evelyn Avenue between Highway 85 and Pioneer Way, and could accommodate approximately 580 units.

Rezonings Adopted with the Housing Element. The City proposes to adopt Zoning and Precise Plan Amendments concurrent with this Housing Element Update, to clarify standards for allowed uses and densities at General Plan Village Centers and El Camino Real Village Centers. These amendments accommodate approximately 800 units in the site inventory, but the total additional capacity of these areas is greater – approximately 2,500 units

1. Opportunity Sites Requiring Rezonings and/or General Plan Amendments (“Back-Pocket" Areas). In the event that the above opportunities are inadequate to accommodate the RHNA, either at the time of Housing Element adoption or over the course of the 6th Cycle due to the “no net loss” law, the proposed Housing Element will also include programs to adopt additional rezonings and General Plan amendments in targeted urban infill areas (areas on previously developed sites and/or completely surrounded by urban uses):
• Moffett Boulevard
• Other shopping areas, such as Leong Drive, Bailey Park shopping center, Monta Loma Plaza • A Joint Development at the Mountain View Transit Center • Other non-residential sites south of El Camino Real, such as 1949 Grant Road and offices near Blossom Valley Shopping Center
These rezoning opportunities could accommodate approximately 1,000 additional units, depending on the densities adopted.

Total Inventory. This EIR analyzes the impacts associated with the site inventory to 2031, an increase in approximately 15,000 dwelling units, focused primarily along the commercial corridors and in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing.2 Of this, approximately 13,600 units3 are already allowed under the City’s adopted General Plan, zoning, and Precise Plans and the remaining 1,400 units would be created through rezonings and General Plan amendments. In addition, the EIR also analyzes a possible increase in housing production from rezonings and General Plan Amendments of approximately

1 This number is less than the total amount of units that could be allowed across these sites, since it is unreasonable to assume replacement of all existing uses over the horizon of this study. The number does consider the sites most likely to be redeveloped.
2 The actual site inventory in the current draft is closer to 14,800. However, 15,000 is a conservatively large round number and small changes to the site inventory are expected up to adoption, based on newly submitted applications.
3 Approximately 13,400 units in the current draft. See previous footnote.

3. Project Description

City of Mountain View Housing Element Update 3-12 ESA / 202000806 Draft Environmental Impact Report July 2022
2,700 units beyond 2031 (described in detail above). More information is provided in Section

3.4.3 below.

Future development on identified sites would continue to be at the discretion of individual property owners and will be largely dependent on market forces and -- in the case of affordable housing -- available funding and/or other incentives. Nonetheless, the analysis in this EIR conservatively assumes build-out of the sites inventory within the eight year planning period ending in January 2031, as discussed further in Section 3.4.3 below.

3.4.3 Growth Projections
As a program-level EIR, this EIR presents an analysis of potential impacts of the HEU by assessing proposed policy and zoning/Precise Plan changes and does not contain a site-specific analysis of development that may occur following adoption of the HEU.

Use of growth projections as a basis for analysis is appropriate when the project being analyzed is a proposed plan, and provides an envelope for the analysis of potential impacts. This approach recognizes that it is not possible to predict the details of development that may be proposed for construction on any individual site once the HEU is adopted. Also, as stated earlier, the precise location of housing inventory sites and densities may evolve based on public outreach during preparation of this EIR.

The HEU is planning for the period from January 31, 2023 through January 31, 2031, and is expected to plan for approximately 15,000 new housing units within this period, although the actual pace of development will depend on market conditions, property owner interest, and other factors. Also, of the approximately 15,000 new units, only a small percentage would result from changes in City policy, zoning, or Precise Plans, and the balance could theoretically occur with or without the Project because it is consistent with existing policy, zoning, and Precise Plans.

However, development of these units may be accelerated compared to the theoretical No Project scenario, due to programs in the Housing Element that streamline, incentivize or remove constraints for housing.

The Project scenario has an analysis year of 2031, since that is the horizon of the Housing Element, and all the site inventory units are expected to be built by that time. In addition, a cumulative scenario is also studied, which looks at the difference between the buildout of the City without and with the proposed General Plan, Zoning and Precise Plan Amendments. This includes anticipated growth beyond 2031. Table 3-2 below presents growth projections used in this analysis, and shows the amount of growth attributable to the Project and to cumulative growth and development.

3. Project Description

City of Mountain View Housing Element Update 3-13 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 3-2
M OUNTAIN VIEW GROWTH PROJECTIONS FOR 2040

Existing
Baseline
(2020)
Under
Construction
Proposed HEU
(2021-2031)
2031
Conditions with
Proposed HEU
Cumulative
Growth no
HEU
HEU
Contribution
to Cumulative
Growth3
Cumulative
Growth with
HEU
Dwelling Units 37,820 1,847 15,000 54,700 63,000 4,100 67,100 Population1 82,826 3,740 30,000 116,600 134,000 8,200 142,200 Jobs 101,965 8,800 02 120,000 133,000 02 133,000
NOTES:
1 Assumes an average of 2 persons per housing unit, based on the City’s projections. 2 Job growth is considered as background and is not part of the proposed HEU 3 Includes the Project’s contribution due to Rezoning and General Plan Amendments considered as part of the HEU.

SOURCE: City of Mountain View, March 2022.

As shown in Table 3-2, adoption of the HEU would potentially result in 4,100 more dwelling units in the cumulative growth capacity than would otherwise occur. This is due to the additional development potential that would be created the General Plan, Zoning and Precise Plan Amendments described in Section 3.4.1, Housing Sites Inventory, above (about 1,400 units in the site inventory and about 2,700 units beyond 2031). The balance of the units included in the proposed HEU represent existing development potential that is already reflected in the City’s cumulative growth capacity.

3.4.4 Other Elements of the General Plan
In addition to the amendments that would take place within the General Plan’s Housing Element, the City is concurrently adopting amendments to the General Plan Land Use Map to reflect changes in density and land use designations of sites that are included in the housing sites inventory. These include:
• Amend the General Plan Map at 1010 Linda Vista Avenue (APN 153-15-011) from General Industrial to High Density Residential
• Amend the General Plan Map at 57 through 87 East Evelyn Avenue (APNs 160-65-002, 160- 65-008 and 160-65-009) from High Intensity Office to High Density Residential

3.4.5 Zoning Map Amendments
The City is also concurrently adopting amendments to its Zoning Map to reflect changes in density of sites that are included in the housing sites inventory. These include:
• Amend the Zoning Map at 1010 Linda Vista Avenue (APN 153-15-011) from MM to R4 • Amend the Zoning Map at 57 through 87 East Evelyn Avenue (APNs 160-65-002, 160-65- 008 and 160-65-009) from MM to R4

3. Project Description

City of Mountain View Housing Element Update 3-14 ESA / 202000806 Draft Environmental Impact Report July 2022

3.4.6 Zoning Ordinance Amendments
The City is also concurrently adopting amendments to its Zoning Code to reflect and facilitate changes in density of sites that are included in the housing sites inventory. These include:
• Amend the R4 zone to allow lot sizes less than 1 acre at 100% affordable developments • Amend the Commercial Zones (CN and CS) to allow residential uses, with the following stipulations:
– Residential uses are only allowed within “mixed-use” designations in the General Plan. – Projects must provide minimum retail or similar neighborhood-serving uses as determined by an analysis of typical amounts of such uses in the underlying zone. – Street frontages shall be primarily lined with commercial (retail/neighborhood-serving) uses.
– At least one public gathering/open space/plaza shall be provided, with a minimum area to be determined based on site size. Provide potential exemptions to one or more standards to facilitate provision of open space to maintain residential density. – Residential uses shall use the development standards of the R3 Zoning District, CRA Zoning District, or El Camino Real Precise Plan, depending on the allowed density in the General Plan.

3.4.7 Precise Plan Amendments
The City is also concurrently adopting amendments to two Precise Plans to reflect and facilitate changes in density of sites that are included in the housing sites inventory. These include:
• Amendments to the El Camino Real Precise Plan to allow “Tier 1” approvals for residential projects up to 2.3 FAR in Village Centers and eliminating the “Tier 2” (overlay zoning) requirement for those projects.
• Amendments to the Grant/Phyllis Precise Plan to allow residential uses, with the following stipulations:
– Projects must provide minimum retail or similar neighborhood-serving uses consistent with the amount existing in the Plan area.
– Street frontages shall be primarily lined with commercial (retail/neighborhood-serving) uses.
– At least one public gathering/open space/plaza shall be provided, with a minimum area to be determined based on site size. Provide potential exemptions to one or more standards to facilitate provision of open space to maintain residential density. – Residential uses shall use the development standards of the El Camino Real Precise Plan.

3. Project Description

City of Mountain View Housing Element Update 3-15 ESA / 202000806 Draft Environmental Impact Report July 2022

3.5 Project Objectives
CEQA Guidelines Section 15124(b) requires the description of the project in an EIR to state the objectives sought by the project.
“A clearly written statement of objectives will help the lead agency develop a reasonable range of alternatives to evaluate in the EIR and will aid the decision makers in preparing findings or a statement of overriding considerations, if necessary. The statement of objectives should include the underlying purpose of the project.”
The primary purpose of the HEU is to comply with the requirements of State law by analyzing existing and projected housing needs, and updating goals, policies, objectives, and implementation programs for the preservation, improvement, and development of housing. The proposed Project is intended to ensure the City’s conformance with State housing requirements and seeks to:
• Protect existing housing;
• Encourage new housing for households at all income levels and for households with a range of diverse housing needs;
• Remove undue constraints on new housing development, including for affordable housing development;
• Affirmatively further fair housing; and
• Identify specific sites that could accommodate required housing units to meet the City’s RHNA.

Conducting community engagement and soliciting feedback to inform the contents of the HEU is a critical component of the planning process and will help to shape the HEU that is ultimately adopted by the City Council.

3.6 Intended Uses of this EIR
Because the Housing Element establishes policies, goals and guidelines, and describes potential housing development that may or may not be built on any particular site, environmental review of the HEU will necessarily be general. The CEQA Guidelines instruct that environmental review of a planning-level document need not contain the level of detail required for review of a specific construction project, for example. (CEQA Guidelines, Section 15146 (“[t]he degree of specificity required … will correspond to the degree of specificity involved in the underlying activity”).

The Housing Element’s inventory of sites is a State-mandated requirement to ensure that the City’s RHNA can be accommodated. In other words, the housing inventory demonstrates that there is enough land zoned at appropriate densities to accommodate the RHNA allocation.

However this inventory does not include all potential development sites within the City limits, and does not mean that sites in the inventory will be developed at the allowable densities. In addition, information about the design and placement of buildings on the sites will not be available unless/until a specific development is proposed.

3. Project Description

City of Mountain View Housing Element Update 3-16 ESA / 202000806 Draft Environmental Impact Report July 2022
Future discretionary development proposals will be reviewed to determine whether their impacts fall within the scope of the analysis in this EIR and additional site-specific environmental review will be required if new significant impacts would result. As provided for in CEQA Guidelines Sections 15152 and 15385, any subsequent environmental document that might be required could “tier” from this EIR and focus its analysis on any new potentially significant impacts.

3.6.1 Required Approvals
While the City’s proposed HEU is subject to review and certification by HCD, adoption and implementation of the HEU would require a series of interrelated planning and regulatory approvals by the City of Mountain View, as Lead Agency. Specifically, the City would take the following approval actions:
• Certification of the HEU EIR pursuant to CEQA;
• Adoption of a resolution amending the General Plan to update the Housing Element, and make any corresponding changes to other elements of the General Plan needed to maintain internal consistency and comply with State law;
• Adoption of an ordinance (two readings) amending the City’s zoning ordinance, and the City’s zoning map if/as needed to reflect the location and density of land uses permitted by the General Plan amendment.
• Adoption of resolutions amending applicable precise plans if/as needed to reflect the location and density of land uses permitted by the General Plan amendment.

All of these proposed actions would require review and recommendation by the Environmental Planning Commission, followed by consideration and action by the City Council.

3.6.2 Other Governmental Agency Approvals
As the Lead Agency and as appropriate under CEQA, the City also intends the EIR to serve as the CEQA-required environmental documentation for consideration of the HEU by other Responsible Agencies and Trustee Agencies which may have discretionary approval authority over the HEU or related actions. Under the CEQA Guidelines, the term “Responsible Agency” includes all public agencies, other than the Lead Agency, which have discretionary approval power over aspects of the project for which the Lead Agency has prepared an EIR (CEQA Guidelines Section 15381); and the term “Trustee Agency” means a state agency having jurisdiction by law over natural resources affected by the project which are held in trust by the people of California (Section 15386). Responsible Agencies and Trustee Agencies with approval actions associated with the project may include, but are not limited to, the following:
• California Department of Transportation (Caltrans)
• Santa Clara Valley Transportation Authority (VTA)
• California Department of Motor Vehicles
_________________________

3. Project Description

City of Mountain View Housing Element Update 3-17 ESA / 202000806 Draft Environmental Impact Report July 2022

3.7 References
Association of Bay Area Governments (ABAG), 2021. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031, Adopted December 16, 2021.

Available at: https://abag.ca.gov/sites/default/files/documents/2021-12/proposed%20Final_ RHNA_Allocation_Report_2023-2031.pdf. Accessed December 22, 2021.

California Department of Housing and Community Development (HUD) 2021. Revised State Income Limits for 2021, December 31, 2021.

City of Mountain View, 2021. Mountain View 2030 General Plan, adopted July 10, 2012, as amended through April 13, 2021. Available at: https://www.mountainview.gov/civicax/ filebank/blobdload.aspx?blobid=10702. Accessed January 21, 2022.

City of Mountain View, 2014. City of Mountain View 2015-2023 Housing Element, Adopted October 14, 2014. Available at: https://www.mountainview.gov/civicax/filebank/ blobdload.aspx?BlobID=15284. Accessed January 21, 2022.

3. Project Description

City of Mountain View Housing Element Update 3-18 ESA / 202000806 Draft Environmental Impact Report July 2022

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City of Mountain View Housing Element Update 4.0-1 ESA / 202000806 Draft Environmental Impact Report July 2022
CHAPTER 4
Environmental Setting, Impacts, and
Mitigation Measures

4.0 Introduction to the Environmental Analysis
This program environmental impact report (EIR) evaluates and documents the physical environmental effects that would potentially occur with the implementation of the proposed Housing Element Update (Project) in accordance with the California Environmental Quality Act (CEQA), Public Resources Code (PRC) Sections 21000, et seq., and the Guidelines for the California Environmental Quality Act (CEQA Guidelines), California Code of Regulations, Title 14, Chapter 3, Section 15000, et seq.).

Sections 4.1 through 4.16 in this chapter consider the existing conditions, regulatory background, and environmental impacts associated with implementation of the Project, as well as mitigation measures to reduce the impact of Project-specific and cumulative environmental impacts, and the level of significance of impacts following mitigation.

This EIR is a Program EIR, as provided for in CEQA Guidelines Section 15168 and will allow the City “to consider broad policy alternatives and program wide mitigation measures” as noted in Section 15168(b)(4). Section 15168(a) of the CEQA Guidelines states that a Program EIR is appropriate for projects which are “… a series of actions that can be characterized as one large project and are related either:

1. Geographically;

2. A logical part in the chain of contemplated actions;

3. In connection with issuance of rules, regulations, plans or other general criteria to govern the conduct of a continuing program; or

4. As individual activities carried out under the same authorizing statutory or regulating authority and having generally similar environmental effects which can be mitigated in similar ways.”
Future discretionary actions that would be facilitated by the HEU’s adoption, particularly those related to the development of housing, would generally require additional assessment to determine consistency with the analysis provided in this Program EIR. The potential future actions would also be subject to the mitigation measures established in this Program EIR, unless superseded by a subsequent environmental document prepared to analyze environmental impacts not foreseen in this Program EIR.

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-2 ESA / 202000806 Draft Environmental Impact Report July 2022

4.0.1 Definition of Terms Used in this EIR
This EIR uses a number of terms that have specific meaning under CEQA. Among the most important of the terms used in the EIR are those that refer to the significance of environmental impacts. The following terms are used to describe environmental effects of the Project:
• Significance Thresholds: A set of standards used by the lead agency to determine whether an impact would be considered significant. (See CEQA Guidelines Section 15064.7.) Standards of significance used in this EIR were derived from Appendix G of the CEQA Guidelines unless otherwise noted. In determining the level of significance, the analysis assumes that the Project would comply with relevant federal, State, and local regulations and ordinances.
• Significant Impact: A Project impact is considered significant if the Project would result in a substantial adverse change in the physical conditions of the environment. Significant impacts are identified by the evaluation of Project-related physical changes compared to specified significance thresholds, which may be qualitative or quantitative. A significant impact is defined as “a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance” (CEQA Guidelines Section 15382).
• Less-than-Significant Impact: A Project impact is considered less than significant when the physical change caused by the project would not exceed the applicable significance threshold. • Significant and Unavoidable Impact: A Project impact is considered significant and unavoidable if it would result in a substantial adverse physical change in the environment that cannot be feasibly avoided or mitigated to a less-than-significant level. • Cumulative Impact: Under CEQA, a cumulative impact refers to “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts” (CEQA Guidelines Section 15355). A significant cumulative impact is one in which the cumulative adverse physical change would exceed the applicable significance criterion and the Project’s contribution is “cumulatively considerable” (CEQA Guidelines Section 15130(a)).
• Mitigation Measure: A mitigation measure is an action that could be taken to avoid or reduce the magnitude of a significant impact. Section 15370 of the CEQA Guidelines defines mitigation as:
a. Avoiding the impact altogether by not taking a certain action or parts of an action; b. Minimizing impacts by limiting the degree of magnitude of the action and its implementation;
c. Rectifying the impact by repairing, rehabilitating, or restoring the affected environment; d. Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and
e. Compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-3 ESA / 202000806 Draft Environmental Impact Report July 2022

4.0.2 Section Format
Chapter 4 is divided into technical sections (e.g., Section 4.1, Aesthetics) that present the physical environmental setting, regulatory setting, significance criteria, methodology and assumptions, and impacts on the environment for each environmental resource issue area. Where required, potentially feasible mitigation measures are identified to lessen or avoid potentially significant impacts. Each section includes an analysis of project-specific and cumulative impacts for each issue area.

The resource topic areas addressed in this EIR chapter are listed below, and the abbreviations for each resource topic that are used in the naming of impact statements and mitigation measures are shown in parentheses:
• Section 4.1: Aesthetics (AES)
• Section 4.2: Air Quality (AIR)
• Section 4.3: Biological Resources (BIO)
• Section 4.4: Cultural Resources and Tribal Cultural Resources (CUL & TCR) • Section 4.5: Energy (ENE)
• Section 4.6: Geology, Soils, Paleontological and Mineral Resources (GEO) • Section 4.7: Greenhouse Gas Emissions (GHG)
• Section 4.8: Hazards and Hazardous Materials (HAZ)
• Section 4.9: Hydrology and Water Quality (HYD)
• Section 4.10: Land Use and Planning (LUP)
• Section 4.11: Noise and Vibration (NOI)
• Section 4.12: Population and Housing (POP)
• Section 4.13: Public Services and Recreation (PSR)
• Section 4.14: Transportation and Circulation (TRA)
• Section 4.15: Utilities and Service Systems (UTL)
• Section 4.16: Effects Found Not to Be Significant
The technical environmental sections each begin with a description of the Project’s environmental setting and the regulatory setting as it pertains to a particular issue. The environmental setting provides a point of reference for assessing the environmental impacts of the Project and Project alternatives. The environmental setting discussion addresses the conditions that existed at the time of issuance on the EIR’s Notice of Preparation (NOP) in February 2022 and prior to implementation of the Project. This setting establishes the baseline by which the Project and Project alternatives are measured for environmental impacts. The regulatory setting presents relevant information about federal, state, regional, and/or local laws, regulations, plans or policies that pertain to the environmental resources addressed in each section.

Next, each section presents significance criteria, which identify the standards used by the City to determine the significance of the environmental effects of the Project.

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-4 ESA / 202000806 Draft Environmental Impact Report July 2022
An approach to analysis discussion in each section presents the analytical methods and key assumptions used in the evaluation of effects of the Project, and is followed by an impacts of the Project discussion. The impacts of the Project portion of each section includes impact statements, prefaced by a number in bold-faced type. An explanation of each impact is followed by an analysis of its significance. The subsection concludes with a statement that the impact, following implementation of the mitigation measure(s) and/or the continuation of existing policies and regulations, would be reduced to a less-than-significant level or would remain significant and unavoidable.

The analysis of environmental impacts considers potential impacts of the actions described as the “Project” in Chapter 3, Project Description, including potential impacts of future construction and occupancy of housing planned for in the HEU. As required by Section 15126.2(a) of the CEQA Guidelines, direct, indirect, short-term, long-term, onsite, and/or off-site impacts are addressed, as appropriate, for the environmental issue area being analyzed. Under CEQA, economic or social changes by themselves are not considered to be significant impacts, but may be considered in linking the implementation of a project to a physical environmental change, or in determining whether the physical change is significant.

Where enforcement exists and compliance can be reasonably anticipated, this EIR assumes that the Project would meet the requirements of applicable laws and other regulations.

Mitigation measures pertinent to each individual impact, if available, appear after the impact discussion section. The magnitude of reduction of an impact and the potential effect of that reduction in magnitude on the significance of the impact is also disclosed. An example of the format is shown below using the topic of air quality (AIR).

Impacts and Mitigation Measures
Impact AIR-1: Impact Statement.

A discussion of the potential impact of the Project on the resource is introduced in paragraph form. To identify impacts that may be site- or Project element-specific, where appropriate, the discussion differentiates between construction effects and operational effects. A statement of the level of significance before application of any mitigation measures is provided in bold.

Mitigation Measure
If the impact is determined to be less than significant, the text will say, “None required.” If the impact is determined to be significant or potentially significant, mitigation with be included in the following format:

Mitigation Measure AIR-1: Mitigation Measure Title.

Recommended mitigation measure, numbered in consecutive order.

Where appropriate, one or more potentially feasible mitigation measures are described. A statement of the significance of the impact following implemented mitigation measure(s) is included in bold, with an explanation of the measure(s) effectiveness if necessary.

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-5 ESA / 202000806 Draft Environmental Impact Report July 2022

4.0.3 Cumulative Impacts
An analysis of cumulative impacts follows the Project-specific impacts and mitigation measures evaluation in each section, and starts by describing the geographic context in which cumulative impacts are analyzed.

A cumulative impact consists of an impact that is created as a result of the combination of the project evaluated in the EIR together with other past, present and reasonably foreseeable projects causing related impacts (15355). Per CEQA Guidelines Section 15130(b)(1), cumulative impacts may be analyzed using either a “list of past, present, and probable future projects” or “a summary of projections contained in an adopted local, regional, or statewide plan or related planning document.” This EIR primarily uses the projections-based approach, as explained here.

The proposed HEU is a plan which provides the potential for increased residential development in specific locations across a broad geography. The use of growth projections as a basis for a cumulative analysis is appropriate when the project being analyzed is a proposed plan that involves a broad geography because specific information about development that may occur as a result of the plan is not available and other changes within and outside the planning area cannot be predicted with any specificity. In this case, the amount of development anticipated in the Housing Sites Inventory portion of the HEU is used to analyze Project impacts, but specific information about how and when those sites might develop is not available. Even the precise location of housing inventory sites and densities may evolve based on public outreach and the results of the sites analysis that will be conducted in parallel to preparation of this EIR.

Thus, this EIR analyzes Project-related growth in housing combined with other, cumulative growth using projections from Plan Bay Area 2040, which was the Bay Area’s Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS) until Plan Bay Area 2050 was adopted in October 2021. Plan Bay Area 2050 is not used because the plan is awaiting CARB’s determination and it does not at this point contain growth projections specific to individual jurisdictions. It will likely take up to three years for the regional agencies to develop a detailed growth forecast for Plan Bay Area 2050 and integrate that forecast into MTC’s transportation model, after which updates to each county’s transportation model will be required.

Thus Plan Bay Area 2040 represents the best available source of information to form the foundation for long range population, housing and employment projections.

Table 4.0-1 summarizes the levels of housing and employment that is projected with and without adoption of the City’s HEU and summarizes 2040 projections for housing units and employment in the City and the nine-county Bay Area. These projections are inherent in the county transportation model and form the foundation for the cumulative analyses in this EIR.

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-6 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 4.0-1
2040 HOUSING AND EMPLOYMENT PROJECTIONS WITH AND WITHOUT THE CITY OF MOUNTAIN VIEW HEUa 2020 2040
Growth
2020 to 2040
Dwelling Units - No HEU
City of Mountain View 37,820 63,000 25,180
Santa Clara County per Plan Bay Area 2040 706,565 881,655 175,090 Bay Area Region per Plan Bay Area 2040 2.88 M 3.43 M 544,735 Dwelling Units – With HEU
City of Mountain View with the HEUa 37,820 67,100 29,280 Santa Clara County with the HEU 706,565 885,755 179,190 Bay Area Region 2.88 M 3.43 M 548,835
Jobs
City of Mountain Viewa 110,765 133,000 22,235
Santa Clara County 1,120,420 1,289,870 169,450
Bay Area Region 4.14 M jobs 4.70 M jobs 562,185
NOTES:
a Dwelling units in the City reflect City data, rather than data in Plan Bay Area 2040, consistent with Table 3-2 in Chapter 3, Project Description. Growth with the HEU includes additional capacity created by general plan amendments, zoning amendments and precise plan amendments, whether or not it is in the site inventory. Housing growth anticipated as a result of the HEU has also been used to adjust the Plan Bay Area 2040 projections for Santa Clara County.

SOURCE: City of Mountain View and Metropolitan Transportation Commission/Association of Bay Area Governments, Plan Bay Area 2040, Final plan adopted July 26, 2017.

Of course, the City is not the only Bay Area jurisdiction that has received a RHNA allocation and is engaged in updating its housing element. All other local jurisdictions in Santa Clara County are doing the same, as are other local jurisdictions throughout the Bay region. However, based on past experience, it is highly unlikely that all of the units that are planned for in each housing element will be constructed between 2022 and 2040, and therefore using that total RHNA number for the region as the basis for the cumulative effects analysis would substantially overstate the level of impact. For this reason, and to more realistically assess the level of impact that could be reasonably foreseen during the HEUs planning period, for all jurisdictions other than the City, this EIR considers the regional projections presented in Plan Bay Area 2040 as a reasonable estimate of likely new housing construction and population and employment growth through 2040 despite planning efforts underway in other jurisdictions to address their housing needs.

There are, however, a number of ongoing activities that inform the cumulative analysis in this EIR, including the City’s ongoing Downtown Precise Plan Update, and other City development project applications, as described below.

Downtown Precise Plan Update
In December 2019, the City Council authorized city staff to update three sub-areas of the Downtown Precise Plan, including A, H, and G. The updates are focused on strengthening the existing character of Downtown Mountain View and promote active

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-7 ESA / 202000806 Draft Environmental Impact Report July 2022
ground-floor uses, through design standards, guidelines, and minor land use changes to administrative office uses.

Senate Bill (SB 9) Code Amendments
SB 9 requires ministerial approval of a proposed housing development containing two residential units on a single-family residential zoned (R1 zone) property if the proposed development meets certain standard requirements (referred to as “duo developments”).

SB 9 also requires ministerial approval of a lot subdivision in a single-family residential zone (R1 zone) if it meets certain lot requirements (these are referred to as “urban lot splits”). The City approved text amendments to the City Code to be consistent with SB 9 in March 2022.

Development Projects in the City
The City has approved or has pending applications on file for a number of projects that may be developed in the City between now and 2040 that are not included in the housing development pipeline. These include, but are not limited to those listed in Table 4.0-2.

With very few exceptions, these projects are employment-generating (rather than providing new housing), and some are near or adjacent to the housing inventory sites included in the HEU. The City’s cumulative projections show an increase in employment for the City, consistent with these developments, plus additional capacity available in the City. Potential cumulative impacts associated with development within the City are discussed broadly (i.e. without reference to specific projects) and qualitatively where relevant in this EIR, most notably in the consideration of potential cumulative impacts related to cultural and natural resources.

There are also a number of ongoing activities that are early in their development, so are not well enough defined to be included in the cumulative analysis, such as the City’s R3 Multi-family Residential Zoning District Update.

As noted above, where a cumulative impact is significant when compared to existing or baseline conditions, the analysis addresses whether the project’s contribution to the significant cumulative impact is “considerable.” If the contribution of the project is considerable, then the EIR identifies potentially feasible measures that could avoid or reduce the magnitude of the project’s contribution to a less-than-considerable level. If the project’s contribution is not considerable, it is considered less than significant and no mitigation of the project contribution is required (CEQA Guidelines Section 15130(a)(2).

4. Environmental Setting, Impacts, and Mitigation Measures City of Mountain View Housing Element Update 4.0-8 ESA / 202000806 Draft Environmental Impact Report July 2022
TABLE 4.0-2

C UMULATIVE NON-RESIDENTIAL DEVELOPMENT PROJECTS IN THE CITY Project Name Description of Project
Approved Development Projects
600 Ellis Street 259,595 square foot office building
369 North Whisman Road (The Quad / Lovewell) 70,846 square foot office building and 109,927 square foot office building
701 West Evelyn Avenue (Marwood) commercial building containing 6,500 square feet of ground-floor retail and 28,090 square feet of office
1860-2159 Landings Drive, 1014 - 1058 Huff
Avenue, 900 Alta Avenue, 2000 North Shoreline
Boulevard (Google Landings)
800,000 square foot office building
2019 Leghorn Street 12,050 square-foot office building
855 - 1023 West El Camino Real 60-bed senior memory care facility with 5,883 square feet of ground floor retail and restaurant use
2300 West El Camino Real 153-room hotel
747 West Dana Street 7,000 square feet of office and 1,600-square feet of ground-floor retail
Hope Street Lots (City Lots 4 and 8) 120,000 square foot hotel building and ground floor accessory commercial space, approximately 52,000 square foot mixed-use building
Development Projects Under Review
756 California Street 6,997 square-foot commercial building with ground-floor retail and office above
189 North Bernardo Avenue 80,000 square foot office building 590 Castro Street 106,000 square foot office building
365 - 405 San Antonio Road and 2585 - 2595
California Street (San Antonio Center Phase III)
182,352 square foot commercial building
301 East Evelyn Avenue 125,000 square foot office building 705 West Dana Street 19,017 square foot building with 1,100 square feet of ground- floor retail and upper floor office
2110 Old Middlefield Way gas station with 6 fueling stations, a drive-through car wash, and a 547 square foot convenience store
1057, 1059, 1061 El Monte Avenue 90-room senior care facility 1155 and 1185 Terra Bella Avenue 20,000 square foot office building 1040 Terra Bella Avenue public storage buildings
1885 Miramonte Avenue (St. Francis High School) add 12,800 square feet of administrative space SOURCE: City of Mountain View, February 2022. Development Update – February 2022. https://www.mountainview.gov/civicax/filebank/blobdload.aspx?BlobID=37124.

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City of Mountain View Housing Element Update 4.1-1 ESA / 202000806 Draft Environmental Impact Report July 2022

4.1 Aesthetics

4.1.1 Introduction
This section evaluates the potential for the Project to result in substantial adverse effects related to aesthetics. The Environmental Setting portion of this section includes descriptions of existing conditions relevant to aesthetics. Existing plans and policies relevant to aesthetics associated with implementation of the Project are provided in the Regulatory Setting section. Finally, the impact discussion evaluates potential impacts related to aesthetics that could result from implementation of the Project in the context of existing conditions.

The Notice of Preparation (NOP) for the EIR was circulated on February 4, 2022 and a scoping meeting was held on February 24, 2022. The NOP and the comments received during the public comment period can be found in Appendix A of this EIR. No comments relating to aesthetics were received during the NOP comment period.

4.1.2 Environmental Setting
Regional Setting
The City of Mountain View is located in northwestern Santa Clara County, in the San Francisco Bay Area. The City is located in close proximity to two prominent natural features: San Francisco Bay, which is located to the north, and the pronounced ridgelines of the Santa Cruz Mountain Range, located several miles to the west and south and which provides a visual backdrop to the City. The City takes its name from the vista of the Santa Cruz Mountains. The baylands, or marshlands, are located directly to the north of the City and, together with Shoreline Park, form a buffer between Mountain View and San Francisco Bay. The City is bordered by urbanized areas on all other sides, specifically, by the City of Palo Alto to the northwest, the City of Sunnyvale to the east, and the City of Los Altos to the south and west. These cities are visually characterized by generally low-rise development, tree-lined residential streets, and corporate office parks of generally modern construction.

City of Mountain View
The City of Mountain View is generally suburban in visual character, characterized by lower-rise buildings (mostly one to two stories in height), extensive landscaping, and a low to moderate intensity of uses. The City includes several visually distinct neighborhood areas that are separated by major roadways, highways, and transit corridors, and which generally correspond with the planning areas identified in the Mountain View 2030 General Plan. Each of the City’s geographic areas contains one or more commercial districts surrounded by residential land uses, with the exception of the North Bayshore area and the eastern portion of the Moffett/Whisman area, which contain predominantly office parks and light industrial and research and development uses. More dense and urban areas with taller buildings and more concentrated commercial activity are located in the Downtown area along Castro Street, as well as portions of El Camino Real. The visual characteristics of areas in the City with the highest development potential as relevant to the Project are described in more detail below.

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Gateways and Landmarks
As discussed in the Visual Resources section of the Mountain View 2030 General Plan Environmental Impact Report (EIR), gateways are the entries to a city, district, or neighborhood.

They act as a point of distinction between different areas and contribute to a sense of place by announcing a threshold or a passage into a place while also reinforcing the unique identity of that place. For the most part, gateways in Mountain View are associated with the City’s major transportation corridors, particularly those which cross the jurisdictional boundaries of Palo Alto, Los Altos, and Sunnyvale. Important gateways within the City also include rail stations along the Central Expressway. Shoreline Boulevard also serves as a gateway into downtown Mountain View from U.S. Highway 101 (US 101). East and west gateways to the City exist along El Camino Real and East Evelyn Avenue. Other gateways include the convergence of Old Middlefield Way and Middlefield Road at the City border with Palo Alto, Grant Road at the border with Los Altos, and transitions between bordering cities along the Central Expressway.

As defined in the Visual Resources section of the Mountain View 2030 General Plan Draft EIR, landmarks are external points of reference that are usually simply defined physical objects (e.g., a building or sign). The prominent visual features of a city are its landmarks. Some landmarks are very large and seen at great distances, and some landmarks are very small (e.g., a tree within an urban square) and can only be seen close up, Landmarks are an important element of urban form because they help people to orient themselves in the city and help identify an area. Landmarks and other gateways relevant to the Project are described in more detail below.

Scenic Views and Scenic Highways
Scenic vistas and viewsheds generally consist of expansive and high-quality views of natural features and landscapes that are visible from public locations. Views of features within and surrounding a city contribute to a feeling of community identity, visual enjoyment, and function as a resource for physical orientation. As previously noted, Mountain View takes its name from the views of the Santa Cruz Mountains to the south and west that are available throughout the City. Views of other natural features such as the Diablo Mountain Range to the southeast, Mission Peak to the east, San Francisco Bay to the north, and Stevens Creek in the eastern portion of the City are available from various locations within Mountain View. Views of the San Francisco Bay are generally only available from Shoreline Park in the North Bayshore Area.

California’s Scenic Highway Program was created by the Legislature in 1963 to preserve and protect scenic highway corridors from change that would diminish the aesthetic value of lands adjacent to highways. The State Scenic Highway Program includes a list of highways that either are eligible for designation as scenic highways or have been so designated. The State Scenic Highway Program identifies State Route (SR) 9 as the only officially designated State scenic highway in Santa Clara County. The program also identifies portions of SR 17, 35, and 152, and Interstate 280 as eligible for State scenic highway designation, but not officially designated as

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City of Mountain View Housing Element Update 4.1-3 ESA / 202000806 Draft Environmental Impact Report July 2022
such. No officially designated State scenic highways are located in or easily visible from the City of Mountain View.1
Creek Corridors
There are two main creek corridors in Mountain View: Stevens Creek and Permanente Creek, both of which include creek-side trails. Stevens Creek extends from Shoreline Regional Park south through the City and into Sunnyvale. Permanente Creek extends south from the Shoreline Regional Park area through the rest of the City and into the City of Los Altos. The multi-use, paved Stevens Creek Trail runs from Shoreline Park, four miles south through both tidal marshlands and riparian habitat along the western side of State Route 85 as far as Yuba Drive near El Camino Real.

The Stevens Creek Trail is wooded in some areas, opens onto the City’s urban landscape in other areas, offers views of the creek, groves of various types of trees, bridges, Whisman Park, wind tunnels near the NASA Ames Research Center, hangers at the Moffett Air Field, and open spaces like the Stevens Creek Tidal and Crittenden Marshes.

The Permanente Creek Trail also extends southward from Shoreline Regional Park and goes as far as the Central Expressway. The Permanente Creek trail is also paved, landscaped, and is more fragmented and is not heavily wooded like segments of the Stevens Creek Trail. 2 Visual Characteristics of Precise Plan Areas
As discussed in Chapter 3, Project Description, to address site-specific development needs, the City has developed 25 Precise Plans covering various locations within the City. Precise Plans are a tool for coordinating future public and private improvements on specific properties where special conditions of size, shape, land ownership, or existing or desired development require particular attention. Precise Plans provide detailed specifications for land uses, relationship to surrounding areas, use intensity, circulation, design, procedures for development review, and special conditions for development occurring within each Precise Plan area. The City’s Precise Plan areas are shown in Figure 3-2 in Chapter 3, Project Description. Precise Plans range from a small 3-acre development to large neighborhoods. The visual characteristics of the Precise Plan areas in the City with the highest development potential under the Project are described below.

East Whisman Precise Plan
The East Whisman Precise Plan area is generally bordered by US 101 and Moffett Federal Airfield/NASA Ames Research Center to the north, North Whisman Road to the west, Central Expressway to the south, and the City of Sunnyvale to the east. The area is visible from the immediate surrounding area and roadways, including North Whisman Road, Middlefield Road, SR 237, and US 101.

1 California Department of Transportation, 2022. California State Scenic Highways. Available: https://dot.ca.gov/ programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways. Accessed May 3, 2022.
2 City of Mountain View, 2012. Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report. September 2012.

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City of Mountain View Housing Element Update 4.1-4 ESA / 202000806 Draft Environmental Impact Report July 2022
The East Whisman Precise Plan area is relatively flat and located within a developed, urban area of Mountain View. The area is developed with single- to multi-story office buildings, as well as similar-looking research and development, light-industrial, and commercial buildings. Buildings tend to have a large front and side setbacks occupied by surface parking and landscaped areas.

The East Whisman Precise Plan area contains numerous mature trees in building parking lots, in various landscaped areas, and in the public right-of-way along streets and sidewalks. Office buildings in the East Whisman Precise Plan area exhibit a variety of styles. Older office buildings are one to two stories and made of brick, stucco, or concrete. Newer office buildings are more contemporary in style (with glass expanses, stone facades, and metal details) and are up to five stories. Older commercial and retail buildings in the Village Center neighborhood are brick and wood, one-story structures.
3 North Bayshore Precise Plan
The North Bayshore Precise Plan area is located in the northernmost portion of the City. This area is bordered by Shoreline at Mountain View Regional Park and San Francisco Bay to the north, the NASA Ames Research Center to the east, US 101 to the south, and Palo Alto to the west. The site is visible from the immediate surrounding area and roadways, including North Shoreline Boulevard, San Antonio Road, Charleston Road, Amphitheater Parkway, US 101, and Shoreline at Mountain View Regional Park. The Santa Cruz Mountains are visible to the south and west of the North Bayshore Precise Plan area, and the Diablo Range is visible to the east.

The approximately 650-acre Precise Plan area is relatively flat and is located within a developed, urban area of Mountain View. The area may be visible from the higher areas of the Santa Cruz Mountains but generally the area is not visible from other locations, apart from US 101. The Precise Plan area is comprised of large-scale office, research and development, and light industrial buildings. The area is characterized by almost entirely large building footprints that reflect the industrial and office uses in the area. Buildings tend to have large front and side setbacks occupied by surface parking and landscaped areas, with floor area ratios (FARs) of less than 0.3 (i.e., low-intensity). The North Bayshore Precise Plan area contains numerous (likely thousands) of mature landscaping trees and shrubs throughout the parking lots and landscaped areas.

Office buildings in the North Bayshore Precise Plan area exhibit a variety of styles depending on when they were constructed. Many of the older buildings from the 1960s and 1970s are one or two stories and made of brick and stucco, while newer buildings from the 1980s and 1990s are characterized by more streamlined architecture. Older retail uses along Shoreline Boulevard are characterized by fairly nondescript buildings with no identifiable architectural style. More recent retail uses at Shoreline Boulevard and Pear Avenue are more distinct, with a contemporary style and stone architectural detailing.

As defined in the Mountain View 2030 General Plan, two gateways into the City are located within the North Bayshore Precise Plan area. Shoreline Boulevard serves as a gateway into

3 City of Mountain View, 2020. East Whisman Precise Plan Integrated Final Environmental Impact Report. January 2020.

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City of Mountain View Housing Element Update 4.1-5 ESA / 202000806 Draft Environmental Impact Report July 2022
downtown Mountain View from US 101 and also acts as a gateway into the North Bayshore area.

Rengstorff Avenue also serves as a gateway into downtown and functions as a primary gateway to the North Bayshore area.

Four landmarks identified in the Mountain View 2030 General Plan are located adjacent to the North Bayshore Precise Plan area, are visible from various locations throughout the Precise Plan area, and are described below.
• Rengstorff House. The Rengstorff House is a significant historic building that serves as a landmark for the City. The house was one of the first to be built in Mountain View, by Henry Rengstorff. The house’s striking Victorian Italianate architecture and location within Shoreline Park make it a landmark for the City. The Rengstorff House is located north of the North Bayshore Precise Plan area, and tall buildings in the Precise Plan area might be seen from the vicinity of the Rengstorff House.
• Shoreline Amphitheatre. This amphitheater was built in 1985 by a private developer and a joint partnership agreement with the City of Mountain View as part of the Shoreline Park project. It is distinguished by its large white tent structures. • Moffett Federal Airfield Hangar One. Built during the Depression era, Hangar One at Moffett Federal Airfield remains one of the largest unsupported structures in the country. The unique shape and scale of the hangar makes it a visual landmark from US 101 and many neighborhoods in the City of Mountain View. Hanger One is located on the Moffett Federal Air Station, east of the Precise Plan area across Stevens Creek. • NASA Wind Tunnels. The world’s largest wind tunnel is housed in a large multi-roofed building at the NASA Ames Research Center, east of the Precise Plan area across Stevens Creek. This tunnel, which is used to test planes with wing spans of up to 100 feet, is over 1,400 feet long and 180 feet high.
4 El Camino Real Precise Plan
The El Camino Real Precise Plan area includes nearly all parcels immediately fronting on El Camino Real (between Del Medio Avenue and Crestview Drive), as well as some additional parcels adjacent to the street. El Camino Real carries high traffic volumes and functions as a commercial corridor through the El Camino Real Precise Plan area. Land uses include low- and medium-intensity retail and commercial, with some multi-family residential buildings. Chain stores and strip malls are common, in addition to some hotels/motels. Auto repair shops and auto dealerships are also located along the corridor.

Within the El Camino Real Precise Plan area, buildings tend to be set back from the street and separated by parking lots or driveways. Buildings are between two and four stories in height.

Most of the El Camino Real right-of-way is dedicated to vehicles, with six lanes of travel and two parking lanes. A significant portion of El Camino Real includes a center median that provides for landscaping and trees, as well as turning lanes. Sidewalks are located on both sides of El Camino

4 City of Mountain View, 2017. North Bayshore Precise Plan Draft Subsequent Environmental Impact Report.

March 2017.

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City of Mountain View Housing Element Update 4.1-6 ESA / 202000806 Draft Environmental Impact Report July 2022
Real, with an average width of between 8 and 10 feet. Stretches of El Camino Real include a planting strip that includes street trees.5
Located at a prominent location at the intersection of State Route 85 and El Camino Real, the Palo Alto Medical Foundation is identified as a City landmark in the Mountain View 2030 General Plan and is clearly visible and distinctive upon the entrance to Mountain View from Sunnyvale and on State Route 85. The three-story medical center opened in 2007 and is 250,000 square feet.

San Antonio Precise Plan
The San Antonio area is located along the City of Mountain View’s western edge, adjacent to the cities of Palo Alto and Los Altos, and currently includes a mix of predominantly commercial uses, with limited existing residential development. It is anchored by the San Antonio Center, a local and regional shopping destination that consists of one- and two-story buildings surrounded by large surface parking.

The San Antonio Center is identified as a City landmark in the Mountain View 2030 General Plan and is visible from various locations throughout the Precise Plan area. Large buildings, expansive parking lots, and a signage feature at the junction of San Antonio Road and El Camino Real distinguish the San Antonio Center. The signage feature is a columnar element that harkens to the establishment of the Center in the 1950s and 1960s, and is visible from a distance along both El Camino Real and San Antonio Road. While the appearance of the Center is not architecturally distinctive, its urban form and regional draw makes it an easy reference point in Mountain View.

The San Antonio Precise Plan area is comprised of 123 acres and surrounds the San Antonio Center. The area is characterized by medium to large building footprints reflecting the commercial and multi-unit residential developments characteristic of this area. Commercial buildings have the largest building footprints of the area and are generally located to the east and west of San Antonio Road. These buildings typically have side and large front setbacks. The open areas around buildings are occupied by large surface parking areas. These building footprints have different shapes, but they are typically boxy or rectangular. A few smaller commercial buildings have footprints that are closer to the street and sidewalk. These buildings have a distinct auto-orientation.
6 Light and Glare
Nighttime lighting is necessary to provide and maintain safe, secure, and attractive environments; however, these lights have the potential to produce spillover light and glare, and if designed incorrectly, could be considered unattractive. Although nighttime light is a common feature of urban areas, spillover light can adversely affect light-sensitive uses, such as residential units at nighttime.

5 City of Mountain View, 2014. El Camino Real Precise Plan Final Environmental Impact Report. December 2014. 6 City of Mountain View, 2014. San Antonio Precise Plan Final Environmental Impact Report. December 2014.

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Glare results when a light source directly in the field of vision is brighter than the eye can comfortably accept. Squinting or turning away from a light source is an indication of glare. The presence of a bright light in an otherwise dark setting may be distracting or annoying (discomfort glare) or may diminish the ability to see other objects in the darkened environment (disability glare). Reflective glare, such as the reflected view of the sun from a window or mirrored surface, can be distracting during the day.

Existing Light and Glare Conditions
Mountain View is a predominantly suburban city with a small number of more urbanized commercial corridors. For this reason, night lighting and glare mostly occur within and around these more densely developed areas, although residential and industrial areas produce limited amounts of nighttime lighting. Existing sources of ambient nighttime lighting generally include neon and fluorescent signs in developed areas; exterior lighting installed along buildings for safety, architectural accent, or to illuminate nighttime operations; lights within buildings that illuminate the exteriors of buildings through windows; landscape and wayfinding signage lighting; street and parking lot lighting; and vehicle headlights. The Shoreline Amphitheatre is also a prominent source of nighttime direct and ambient light. Glare is created by reflection of natural (i.e., sunlight) and artificial light off of existing windows and building surfaces. 7 4.1.3 Regulatory Setting
Federal
There are no federal regulations pertaining to aesthetics that are applicable to the Project.

State
Title 24 Outdoor Lighting Standards
As published in Section 6 of the California Code of Regulations, Title 24 is a broad set of requirements for energy conservation, green design, construction and maintenance, fire and life safety, and accessibility that apply to the structural, mechanical, electrical, and plumbing systems in a building. The code applies to all buildings in California. California updates its energy code every three years. Construction projects with permit applications applied for on or after January 1, 2023 must follow the 2022 Energy Code. If a permit is applied for before then, buildings follow the 2019 Building Efficiency Standards. The code includes energy efficiency standards for outdoor lighting for both the public and private sector. The standards regulate lighting characteristics such as, maximum power and brightness, shielding, and sensor controls to turn lighting on and off.

California Scenic Highway Program
California’s Scenic Highway Program was created by the Legislature in 1963 to preserve and protect scenic highway corridors from change that would diminish the aesthetic value of lands adjacent to highways. The State laws governing the Scenic Highway Program are found in the

7 City of Mountain View, 2012. Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report. September 2012.

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City of Mountain View Housing Element Update 4.1-8 ESA / 202000806 Draft Environmental Impact Report July 2022
Streets and Highways Code, Section 260 et seq. The State Scenic Highway System includes a list of highways that either are eligible for designation as scenic highways or have been so designated. These highways are identified in Section 263 of the Streets and Highways Code. As discussed above in the Environmental Setting, no officially designated State scenic highways are located in or easily visible from the City of Mountain View.8 Local
Mountain View 2030 General Plan
The Mountain View 2030 General Plan is the guiding document for the City's physical development and preservation. It includes goals, policies and graphics that convey a long-term vision and guide local decision-making to achieve that vision. The Land Use and Design Element of the 2030 General Plan contains the following goals and policies related to visual character, visual quality, scenic views, and light and glare that are applicable to the Project.

Goal LUD-6: Distinctive neighborhoods that preserve and enhance the quality of life for residents.

Policy LUD 6.1: Neighborhood character. Ensure that new development in or near residential neighborhoods is compatible with neighborhood character.

Policy LUD 6.3: Street Presence. Encourage street facades and frontages that create a presence at the street and along interior pedestrian paseos or pathways.

Goal LUD-7: A vibrant Downtown that serves as the center for Mountain View social and civic life.

Policy LUD 7.3: Human-scaled building details. Support new and renovated Downtown buildings that include human-scaled details such as transparent windows on the ground floor that face the street, awnings and architectural features to create a comfortable and interesting pedestrian environment.

Policy LUD 7.5: Compatible uses and design. Ensure compatible uses and building design Downtown along the boundaries between residential and commercial areas.

Policy LUD 8.1: City Gateways. Emphasize city gateways that create a distinct and positive impression
Goal LUD-9: Buildings that enhance the public realm and integrate with the surrounding neighborhood.

Policy LUD 9.1: Height and setback transitions. Ensure that new development includes sensitive height and setback transitions to adjacent structures and surrounding neighborhoods.

8 California Department of Transportation, 2022. California State Scenic Highways. Available online:
https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community-livability/lap-liv-i-scenic-highways.

Accessed May 3, 2022.

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Policy LUD 9.3: Enhanced public space. Ensure that development enhances public spaces through these measures:
• Encourage strong pedestrian-oriented design with visible, accessible entrances and pathways from the street.
• Encourage pedestrian-scaled design elements such as stoops, canopies and porches. • Encourage connections to pedestrian and bicycle facilities. • Locate buildings near the edge of the sidewalk.
• Encourage design compatibility with surrounding uses. • Locate parking lots to the rear or side of buildings. • Encourage building articulation and use of special materials to provide visual interest.
• Promote and regulate high-quality sign materials, colors and design that are compatible with site and building design.
• Encourage attractive water-efficient landscaping on the ground level.

Policy LUD 9.5: View preservation. Preserve significant viewsheds throughout the community.

Policy LUD 9.6: Light and glare. Minimize light and glare from new development.

Goal LUD-10: High-quality, sustainable and healthful building design and development.

Policy LUD 10.1: Sustainable design and materials. Encourage high-quality and sustainable design and materials.

Policy LUD 10.2: Low-impact development. Encourage development to minimize or avoid disturbing natural resources and ecologically significant land features.

City of Mountain Municipal Code
The City of Mountain View addresses visual considerations for development in many City documents, including the Municipal Code. The City Zoning Ordinance (Title 36) sets forth specific design guidelines, height limits, building density, building design and landscaping standards, architectural features, sign regulations, and open space and setback requirements.

The Zoning Ordinance promotes good design and careful planning of development projects to enhance the visual environment. The City’s development review process includes the review of preliminary plans, the consideration of public input at the Development Review Committee, Zoning Administrator, Environmental Planning Commission and the City Council. The City’s Planning Division reviews private and public development applications for conformance with City plans, ordinances, and policies related to zoning, urban design, subdivision, and CEQA. The Zoning Administrator makes recommendations to the City Council for large development projects and makes final decisions for permits and variances, and the Development Review Committee reviews the architecture and site design of new development and provides project

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-10 ESA / 202000806 Draft Environmental Impact Report July 2022
applicants with appropriate design comments. The development review process ensures that the architecture and urban design of new developments would protect the City’s visual environment.

Mountain View Standard Conditions of Approval
As part of discretionary review, the City has standard conditions for different types of approvals (as of October 25, 2021). The standard conditions of approval related to aesthetics include the following:

Building Design/Plan Modifications
Based on direction from the Development Review Committee (DRC), modifications shall be made to the architectural design, building materials, colors, landscaping, and/or other site or building design details prior to issuance of a building permit and shown on building permit drawings. The modifications are subject to review and approval by the Zoning Administrator to confirm compliance with the DRC’s recommendation.

Exterior Materials
High-quality materials and finishes shall be used throughout the project and shall remain in compliance with the materials identified in the approved plans, except as modified by the conditions of approval herein. Details regarding all color and architectural details shall be provided in the building permit plan submittal and shall be subject to review and approval by the Zoning Administrator prior to the issuance of building permits.

Lighting Plan
The applicant shall submit a lighting plan in building permit drawings. This plan should include photometric contours, manufacturer’s specifications on the fixtures, and mounting heights. The design and location of outdoor lighting fixtures shall ensure there will be no glare and light spillover to surrounding properties, which is demonstrated with photometric contours extending beyond the project property lines. The lighting plan submitted with building permit drawings must be approved by the Zoning Administrator prior to building permit issuance.

4.1.4 Significance Criteria
The thresholds used to determine the significance of impacts related to aesthetics are based on Appendix G of the CEQA Guidelines. Implementation of the Project could have a significant impact on the environment if it would:
• Have a substantial adverse effect on a scenic vista.
• Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
• In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings (public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, conflict with applicable zoning and other regulations governing scenic quality. • Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-11 ESA / 202000806 Draft Environmental Impact Report July 2022
Approach to Analysis
The analysis of potential impacts related to aesthetics in this EIR relies on qualitatively comparing the existing built and natural environment to the future built and natural environment that may result from implementation of the Project. Whether an adverse environmental effect on aesthetics occurs is based on whether development that would be allowed by the HEU would result in the substantial interference or obstruction of a scenic view from a public vantage point or have a substantial demonstrable negative aesthetic effect. The obstruction of an individual landowners’ view from private property is not considered a significant environmental impact under CEQA. As a result, the analysis generally does not consider or evaluate the Project’s impact on views from private residences or other private vantage points. A significance determination for impacts related to scenic vistas (e.g., broad expansive views of natural features and landscapes) and scenic resources (e.g., gateways, landmarks, or urban creeks) is based on whether development allowed by the Project would prominently obstruct or block the majority of the expanse of scenic vista or scenic resource as seen by most viewers from public locations while taking into account the view as a whole as well as the City’s land use policies. The analysis considers the sensitivity of the affected resource based on the prominence of its visibility and/or the viewpoint location, as well as the characteristics of the view. View characteristics include whether it is widely unobstructed, fleeting, intermittent, or transitory as viewed from roadways. Moreover, the significance is measured in light of the context in which the effect occurs. For example, an activity which may be significant in a rural area may not be significant in an urban area. With respect to visual character, for a project to have significant visual impacts, the project must either block views of an aesthetic resource, be located in an area that is itself considered to be an aesthetic resource, or have a substantial demonstrable negative aesthetic effect. The analysis also addresses whether the Project would conflict with applicable zoning and/or other regulations governing scenic quality or create a new source of substantial light or glare.

It should also be noted that CEQA Section 21099(d), which was added to the statute in 2019, states that “Aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” Thus, to the extent that this analysis identifies impacts to aesthetics resulting from infill sites within a transit priority area, its conclusions are provided for informational purposes only.

Issues Not Discussed in Impacts
As described above in Section 4.1.3, Regulatory Setting, there are no officially designated State scenic highways within or visible from the City of Mountain View. For this reason, the second significance criterion listed above is not addressed further in this section of the EIR.

4.1.5 Impacts of the Project
Impact AES-1: Implementation of the HEU would not have a substantial adverse effect on a scenic vista. (Less than Significant)
As described above in Section 4.1.2, Environmental Setting, scenic vistas generally consist of expansive and high-quality views of natural features and landscapes that are visible from public

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-12 ESA / 202000806 Draft Environmental Impact Report July 2022
locations. Views of features within and surrounding a city contribute to a feeling of community identity, visual enjoyment, and function as a resource for physical orientation. As previously noted, Mountain View takes its name from the views of the Santa Cruz Mountains to the south and west that are available throughout the City. Views of other natural features such as the Diablo Mountain Range to the southeast, Mission Peak to the east, San Francisco Bay to the north, and Stevens Creek in the eastern portion of the City are available from various locations within Mountain View. Views of the San Francisco Bay are generally only available from Shoreline Park in the North Bayshore Area.

This analysis also considers views of established City gateways and landmarks. As discussed above in the Environmental Setting, gateways are the entries to a city, district, or neighborhood.

They act as a point of distinction between different areas and contribute to a sense of place by announcing a threshold or a passage into a place while also reinforcing the unique identity of that place. For the most part, gateways in Mountain View are associated with the City’s major transportation corridors, particularly those which cross the jurisdictional boundaries of Palo Alto, Los Altos, and Sunnyvale. Important gateways within the City also include rail stations along the Central Expressway. Shoreline Boulevard also serves as a gateway into downtown Mountain View from US 101. East and west gateways to the City exist along El Camino Real and East Evelyn Avenue. As discussed above in the Environmental Setting, established City landmarks include the Rengstorff House, the San Antonio Center, the Palo Alto Medical Foundation, Shoreline Amphitheatre, Moffett Federal Airfield Hangar One, and NASA Wind Tunnels.

As presented in Chapter 3, Project Description, the Project would include adoption of a General Plan amendment to add or modify goals, objectives, policies, and implementation programs related to housing in the Housing Element of the City’s General Plan. The Housing Element itself would contain an updated housing needs assessment; updated goals, policies, and programs that address the maintenance, preservation, improvement, and development of housing and that affirmatively further fair housing; and a housing inventory that meets the City’s Regional Housing Needs Allocation (RHNA) and provides a buffer of additional housing development capacity. The Project would also include amendments to other elements of the General Plan in order to maintain internal consistency between the General Plan, the zoning ordinance, and adopted Precise Plans. The Project would also include modifications to provisions in the City’s General Plan Land Use map, zoning ordinance, zoning map, and adopted Precise Plans, as needed, to reflect the housing sites inventory.

As detailed in Section 3.4.1, Housing Sites Inventory, in Chapter 3, Project Description, the Project would include a number of strategies as provided for in State law and California Department of Housing and Community Development (HCD) guidance to address the requirements for a housing inventory and meet the City’s 6th Cycle RHNA plus a buffer. While strategies and sites included in the Project will be refined based on community input and analysis as the EIR is being prepared, this EIR analyzes the impacts associated with the possible increase in housing production assuming use of the aforementioned strategies to plan for up to approximately 15,000 units to the year 2031, focused primarily along the commercial corridors and in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing. Of the total units it is assumed that 1,400 units would be enabled by changes

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-13 ESA / 202000806 Draft Environmental Impact Report July 2022
in development capacity via rezoning. The balance of approximately 13,600 units represents development that is already permitted under the City’s adopted General Plan, zoning, and Precise Plans. Future development on identified sites would continue to be at the discretion of individual property owners and will be largely dependent on market forces and, in the case of affordable housing, available funding and/or other incentives. Nonetheless, the analysis in this EIR conservatively assumes build-out of the sites inventory. In addition, the analysis in this EIR also considers approximately 2,700 units beyond 2031 that would be enabled by changes in development capacity via rezoning.

New development that could occur under the Project would generally occur along commercial corridors; in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing; and other areas that are visually appropriate for increased development intensities. New development under the Project would generally not affect areas with a high degree of scenic value. However, implementation of the Project could potentially result in the construction of housing in a scenic vista visible from one or more locations within the City or in proximity to a scenic resource, such as a City landmark.

The City’s General Plan includes policies designed to ensure new development would not substantially adversely affect scenic vistas and scenic resources. Policy LUD 9.5 ensures preservation of significant viewsheds throughout the community. Policy LUD 10.2 encourages development to minimize or avoid disturbing natural resources and ecologically significant land features. Policy LUD 9.1 requires new development to include sensitive height and setback transitions to adjacent structures and surrounding neighborhoods. Policy LUD 9.3 encourages design compatibility with surrounding uses. Related policies under the City’s Precise Plans support the maintenance of high quality and compatible architectural and site design, gradual well-designed transitions between different land uses, and sensitivity and access to visual view corridors. In addition, as previously described, the City’s development review process, which includes the City Zoning Administrator and the Development Review Committee, would ensure that the architecture and urban design of new developments would protect the City’s visual environment, including scenic vistas and scenic resources. The Zoning Administrator makes recommendations to the City Council for large development projects and makes final decisions for permits and variances, and the Development Review Committee reviews the architecture and site design of new development and improvements, and provides project applicants with appropriate design comments. Required adherence to applicable City policies, regulations, and development standards governing scenic quality would ensure that impacts to scenic vistas and scenic resources would be less than significant.

Mitigation: None required.
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4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-14 ESA / 202000806 Draft Environmental Impact Report July 2022
Impact AES-2: Implementation of the HEU would not substantially degrade the existing visual character or quality of public views of the site and its surroundings or conflict with applicable zoning and other regulations governing scenic quality. (Less than Significant) As described above in Section 4.1.2, Environmental Setting, the City of Mountain View is generally suburban in visual character, characterized by lower-rise buildings (mostly one to two stories in height), extensive landscaping, and a low to moderate intensity of uses. The City includes several visually distinct neighborhood areas that are separated by major roadways, highways, and transit corridors. Each of the City’s geographic areas contains one or more commercial districts surrounded by residential land uses, with the exception of the North Bayshore Area and the eastern portion of the Moffett/Whisman Area, which contain predominantly office parks and light industrial/research and development uses. More dense and urban areas with taller buildings and more concentrated commercial activity are located in the Downtown area along Castro Street, as well as portions of El Camino Real.

Changes to the visual character or quality of a site affect each individual differently, and thus to some extent are based on subjective and individual perspectives. As discussed above in Impact AES-1 and detailed in Section 3.4.1, Housing Sites Inventory, in Chapter 3, Project Description, the Project would include a number of strategies as provided for in State law and HCD guidance to address the requirements for a housing inventory and meet the City’s 6th Cycle RHNA plus a buffer. While strategies and sites included in the Project will be refined based on community input and analysis as the EIR is being prepared, this EIR analyzes the impacts associated with the possible increase in housing production assuming use of the aforementioned strategies to plan for up to approximately 15,000 units to the year 2031, focused primarily along the commercial corridors and in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing. Of the total units it is assumed that 1,400 units would be enabled by changes in development capacity via rezoning. The balance of approximately 13,600 units represents development that is already permitted under the City’s adopted General Plan, zoning, and Precise Plans. In addition, the analysis in this EIR also considers approximately 2,700 units beyond 2031 that would be enabled by changes in development capacity via rezoning.

The development of new housing of increased density, greater scale, and higher height than currently exists in many areas of the City would result in changes to visual conditions where the new development occurs. In general, changes to the visual environment that could result with implementation of the Project would occur in areas characterized by infill parcels, vacant lots, and other underutilized areas within or immediately adjacent to existing developed areas in the City. New development would generally occur along commercial corridors; in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing; and other areas that are visually appropriate for increased development intensities. New development under the Project would generally not affect areas with a high degree of scenic value, including, natural environments such as Stevens Creek and Permanente Creek.

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-15 ESA / 202000806 Draft Environmental Impact Report July 2022
The City’s General Plan includes policies designed to ensure visual quality and compatible visual character:
• Policy LUD 6.1 ensures that new development in or near residential neighborhoods is compatible with neighborhood character.
• Policy LUD 9.1 requires new development to include sensitive height and setback transitions to adjacent structures and surrounding neighborhoods.
• Policy LUD 9.3 encourages design compatibility with surrounding uses. • Policy LUD 9.5 ensures preservation of significant viewsheds throughout the community. • Policy LUD 10.2 encourages development to minimize or avoid disturbing natural resources and ecologically significant land features.

Related policies under the City’s Precise Plans support the maintenance of high quality and compatible architectural and site design, gradual well-designed transitions between different land uses, and sensitivity and access to visual view corridors.

As noted above, a relatively small portion of the housing sites inventory (1,400 units out of 15,000 total) and approximately 2,700 units beyond 2031 would not be consistent with current zoning provisions and would be rezoned, allowing changes in use, density, and/or height. The General Plan amendment and zoning ordinance proposed for adoption as part of the Project would by definition resolve any conflicts with provisions of those documents. In addition, as previously described, the City’s development review process ensures that the architecture and urban design of new developments would protect the City’s visual environment. Required adherence to applicable City policies, regulations, and development standards governing scenic quality would ensure that adverse impacts related to visual character or quality of public views or conflicts with applicable zoning and other regulations governing scenic quality would be less than significant.

Mitigation: None required.
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Impact AES-3: Implementation of the HEU would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Less than Significant)
As discussed above in the Environmental Setting, Mountain View is a predominantly suburban city with a small number of more urbanized commercial corridors. For this reason, night lighting and glare mostly occur within and around these more densely developed areas, although residential and industrial areas produce limited amounts of nighttime lighting. Existing sources of ambient nighttime lighting generally include neon and fluorescent signs in developed areas; exterior lighting installed along buildings for safety, architectural accent, or to illuminate nighttime operations; lights within buildings that illuminate the exteriors of buildings through windows; landscape and wayfinding signage lighting; street and parking lot lighting; and vehicle

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-16 ESA / 202000806 Draft Environmental Impact Report July 2022
headlights. The Shoreline Amphitheatre is also a prominent source of nighttime direct and ambient light.

Development of new housing anticipated under the Project would result in increased amounts of lighting associated with new development (generally installed for security and safety reasons) and reflective building surfaces. New lighting and reflective building surfaces (including windows) would be similar to those that characterize existing urban development in the City. The City’s General Plan includes policies to ensure that new buildings and associated lighting would not substantially adversely affect daytime or nighttime views. Policy LUD 9.6 directs light and glare from new development to be minimized. Policies LUD 6.1, LUD 7.5, and LUD 9.1 would ensure that new development includes sensitive height and setback transitions to adjacent structures and surrounding neighborhoods and is compatible with neighborhood character. These policies would assist in reducing light and glare spillover into areas adjacent to new development. Potential glare from new developments also would be minimized with implementation of Policy LUD 10.1 encourages high-quality and sustainable design and materials that would be expected to generate little glare. In addition, as previously described, Standard Condition of Approval (Lighting Plan) and the City’s development review process would ensure that the architecture and urban design of new developments would protect the City’s visual environment including ensuring that new development does not generate adverse light and glare. Required adherence to applicable City policies, regulations, standard conditions of approval, and development standards would ensure that adverse impacts related light and glare would be less than significant.

Mitigation: None required.
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4.1.6 Cumulative Impacts
This section presents an analysis of the cumulative effects of the Project in combination with other past, present, and reasonably foreseeable future development that could cause cumulatively significant impacts. Significant cumulative impacts related to aesthetics could occur if the incremental impacts of the Project combined with the impacts of cumulative development identified in Section 4.0.3, Cumulative Impacts, would result in a significant cumulative impact and if the Project’s contribution would be “considerable.” Impact AES-1.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not have a substantial adverse effect on a scenic vista. (Less than Significant)
As presented above, Section 4.0.3, Cumulative Impacts, includes a discussion of cumulative development projections. Given development patterns in the region, cumulative development within the City and surrounding areas would predominately comprise infill projects in an already- developed urban environment. As with past projects, all current and future development within the City would be subject to applicable policies, development standards, discretionary permits, and development review processes, each of which has components designed to protect and enhance scenic quality. Evaluations of proposed projects according to these requirements take

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-17 ESA / 202000806 Draft Environmental Impact Report July 2022
into account cumulative conditions and consistency with existing surroundings. Where applicable, individual projects would adhere to conditions and/or mitigation measures, applicable design guidelines, and development standards to address potential adverse impacts related to scenic vistas.

As discussed above in Impact AES-1, the Project could result in new housing on developed and undeveloped pieces of land within the City. New development that could occur under the Project would generally occur along commercial corridors; in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing; and in other areas that are visually appropriate for increased development intensities. New development under the Project would generally not affect areas with a high degree of scenic value. The City’s General Plan includes policies (as described in Impact AES-1) designed to ensure new development would not substantially adversely affect scenic vistas. In addition, as previously described, the City’s development review process would ensure that the architecture and urban design of new developments would protect scenic vistas. For these reasons, the cumulative impact related to a substantial adverse effect on a scenic vista would less than significant.

Mitigation: None required.
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Impact AES-2.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not substantially degrade the existing visual character or quality of public views of the site and its surroundings or conflict with applicable zoning and other regulations governing scenic quality. (Less than Significant) As discussed above in Impact AES-1.CU, given development patterns in the region, cumulative development within the City and surrounding areas would predominately comprise infill projects in an already-developed urban environment, and thus these projects would not likely combine to create significant adverse effects to visual character and visual quality. As with past projects, all current and future projects would be subject to applicable policies, development standards, discretionary permits, and development review processes, each of which has components designed to protect and enhance visual character and the quality of public views. Evaluations of proposed projects according to these requirements take into account cumulative conditions and consistency with existing surroundings. Where applicable, individual projects would adhere to conditions and/or mitigation measures, applicable design guidelines, and development standards to address potential adverse impacts related to visual character and quality.

As discussed above in Impact AES-2, the development of new housing of increased density, greater scale, and higher height under the Project than currently exists in many areas of the City would result in changes to visual conditions where the new development occurs. In general, changes to the visual environment that could result with implementation of the Project would occur in areas characterized by infill parcels, vacant lots, and other underutilized areas within or immediately adjacent to existing developed areas in the City. New development would generally occur along commercial corridors; in areas that currently accommodate commercial/industrial uses, mixed uses, and/or multifamily housing; and other areas that are visually appropriate for

4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-18 ESA / 202000806 Draft Environmental Impact Report July 2022
increased development intensities. In addition, The City’s General Plan includes policies (as described in Impact AES-2) designed to ensure visual quality and compatible visual character in areas where new housing is developed. Finally, as previously described, the City’s development review process would ensure that the architecture and urban design of new developments would protect the City’s visual environment. For these reasons, the cumulative impact related to a substantial degradation of visual character or quality of public views or conflicts with applicable zoning and other regulations governing scenic quality would be less than significant.

Mitigation: None required.
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Impact AES-3.CU: Implementation of the HEU, when combined with other past, present, or reasonably foreseeable development, would not create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. (Less than Significant)
Cumulative development within the City and surrounding areas would predominately comprise infill projects in an already-developed urban environment that includes substantial amounts of existing nighttime ambient light. As with past projects, all current and future projects would be subject to applicable policies, development standards, discretionary permits, and development review processes, each of which has components designed minimize adverse light and glare.

Evaluations of proposed projects according to these requirements take into account cumulative conditions and consistency with existing surroundings. Where applicable, individual projects would adhere to conditions and/or mitigation measures, applicable design guidelines, and development standards to address potential adverse impacts related to light and glare.

As discussed above in Impact AES-3, development of new housing anticipated under the Project would result in increased amounts of lighting associated with new development (generally installed for security and safety reasons) and reflective building surfaces. New lighting and reflective building surfaces (including windows) would be similar to those that characterize existing urban development in the City. The City’s General Plan includes policies (as described in Impact AES-3) to ensure that new buildings and associated lighting would not substantially adversely affect daytime or nighttime views. In addition, as previously described, the City’s development review process would ensure that the architecture and urban design of new developments would ensure that new development does not generate adverse light and glare. For these reasons, the cumulative impact related to related light and glare would be less than significant.

Mitigation: None required.
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4. Environmental Setting, Impacts, and Mitigation Measures

4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-19 ESA / 202000806 Draft Environmental Impact Report July 2022

4.1.7 Summary of Aesthetics Impacts
Impact
Significance Before
Mitigation Mitigation
Significance After
Mitigation
Impact AES-1: Implementation of the HEU
would not have a substantial adverse effect on
a scenic vista.

Less than Significant None required -
Impact AES-2: Implementation of the HEU
would not substantially degrade the existing
visual character or quality of public views of the
site and its surroundings or conflict with
applicable zoning and other regulations
governing scenic quality.

Less than Significant None required -
Impact AES-3: Implementation of the HEU
would not create a new source of substantial
light or glare which would adversely affect day
or nighttime views in the area.

Less than Significant None required -
Impact AES-1.CU: Implementation of the HEU,
when combined with other past, present, or
reasonably foreseeable development, would
not have a substantial adverse effect on a
scenic vista.

Less than Significant None required -
Impact AES-2.CU: Implementation of the HEU,
when combined with other past, present, or
reasonably foreseeable development, would
not substantially degrade the existing visual
character or quality of public views of the site
and its surroundings or conflict with applicable
zoning and other regulations governing scenic
quality.

Less than Significant None required -
Impact AES-3.CU: Implementation of the HEU,
when combined with other past, present, or
reasonably foreseeable development, would
not create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area.

Less than Significant None required -

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4.1.8 References
California Department of Transportation (Caltrans), 2022. California State Scenic Highways.

Available: https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways. Accessed May 3, 2022.

City of Mountain View, 2012. Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report. September 2012.

City of Mountain View, 2014. El Camino Real Precise Plan Final Environmental Impact Report.

December 2014.

City of Mountain View, 2014. San Antonio Precise Plan Final Environmental Impact Report.

December 2014.

City of Mountain View, 2017. North Bayshore Precise Plan Draft Subsequent Environmental Impact Report. March 2017.

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4.1 Aesthetics
City of Mountain View Housing Element Update 4.1-20 ESA / 202000806 Draft Environmental Impact Report July 2022
City of Mountain View, 2020. East Whisman Precise Plan Integrated Final Environmental Impact Report. January 2020.

City of Mountain View, 2021. Mountain View 2030 General Plan, adopted July 10, 2012, as amended through April 13, 2021.

4. Environmental Setting, Impacts, and Mitigation Measures

4.2 Air Quality
City of Mountain View Housing Element Update 4.2-1 ESA / 202000806 Draft Environmental Impact Report July 2022

4.2 Air Quality

4.2.1 Introduction
This section assesses the potential for the Project to result in significant adverse impacts on air quality. This section first includes a description of the existing environmental setting as it relates to air quality and provides a regulatory framework that discusses applicable federal, state, and local regulations. This section also includes an evaluation of potential significant impacts of the Project on air quality.

The Notice of Preparation (NOP) for the EIR was circulated on February 4, 2022 and a scoping meeting was held on February 24, 2022. The NOP and the comments received during the public comment period can be found in Appendix A of this EIR. No comments relating to air quality were received during the NOP comment period.

4.2.2 Environmental Setting
Climate and Meteorology
The City of Mountain View is located in the San Francisco Bay Area Air Basin (SFBAAB), in the Santa Clara Valley. Air quality is influenced by such natural factors as topography, meteorology, and climate, in addition to the presence of existing air pollution sources and ambient conditions.

The Santa Clara Valley is bounded by the Bay to the north and by mountains to the east, south and west. Temperatures are warm on summer days and cool on summer nights, and winter temperatures are fairly mild. At the northern end of the valley, mean maximum temperatures are in the low-80's during the summer and the high-50's during the winter, and mean minimum temperatures range from the high-50's in the summer to the low-40's in the winter. Wind speeds are greatest in the spring and summer and weakest in the fall and winter. Nighttime and early morning hours frequently have calm winds in all seasons, while summer afternoons and evenings are quite breezy. Strong winds are rare, associated mostly with the occasional winter storm.

The ai r pollution potential of the Santa Clara Valley is high. High summer temperatures, stable air and mountains surrounding the valley combine to promote ozone formation. In addition to the many local sources of pollution, ozone precursors from San Francisco, San Mateo and Alameda Counties are carried by prevailing winds to the Santa Clara Valley. The valley tends to channel pollutants to the southeast. In addition, on summer days with low level inversions, ozone can be recirculated by southerly drainage flows in the late evening and early morning and by the prevailing northwesterly winds in the afternoon. A similar recirculation pattern occurs in the winter, affecting levels of carbon monoxide and particulate matter. This movement of the air up and down the valley increases the impact of the pollutants significantly. Pollution sources are plentiful and complex in this subregion. The Santa Clara Valley has a high concentration of industry at the northern end, in the Silicon Valley. Some of these industries are sources of air toxics as well as criteria air pollutants. In addition, Santa Clara Valley's large population and

4. Environmental Setting, Impacts, and Mitigation Measures

4.2 Air Quality
City of Mountain View Housing Element Update 4.2-2 ESA / 202000806 Draft Environmental Impact Report July 2022
many work-site destinations generate the highest mobile source emissions of any subregion in the SFBAAB (BAAQMD 2017a).

Criteria Air Pollutants
As required by the 1970 Federal Clean Air Act, the United States Environmental Protection Agency (U. S. EPA) initially identified six air pollutants that are pervasive in urban environments for which state and federal health-based ambient air quality standards were established. The U.S. EPA calls these pollutants “criteria air pollutants,” and the agency has regulated them by developing specific public health-based and welfare-based criteria as the basis for setting permissible levels. Ozone, CO, particulate matter (PM), nitrogen dioxide (NO2), sulfur dioxide (SO2), and lead are the six criteria air pollutants originally identified by the U.S. EPA. Later, subsets of PM were identified and permissible levels were established.

These include PM10, with a diameter of 10 microns, and PM2.5, with a diameter of 2.5 microns or less (PM2.5).

Table 4.2-1 briefly summarizes the sources and the most common health and environmental effects for each of the air pollutants for which there is a national and/or California ambient air quality standard (ambient air quality standards are discussed below and further under the Regulatory Setting).

Air Quality Standards
As discussed above, National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) for criteria air pollutants have been set at levels considered safe to protect public health and welfare and protect the environment. Table 4.2 -2 summarizes the current NAAQS and CAAQS for each of the criteria air pollutants. Although the federal Clean Air Act established standards, individual states retained the option to adopt more stringent standards and to include other pollution sources. California had already established its own air quality standards when federal standards were established, and as shown in Table 4.2-2, there are differences between the state and national ambient air quality standards. California ambient standards te nd to be at least as protective as national ambient standards or are often more stringent. In addition to the six criteria air pollutants, California has adopted ambient air quality standards for sulfates, hydrogen sulfide, visibility reducing particles, and vinyl chloride.

Toxic Air Contaminants
In addition to criteria air pollutants, individual projects may emit TACs. TACs collectively refer to a diverse group of air pollutants that may cause chronic (i.e., of long duration) and acute (i.e., severe but short-term) adverse effects on human health, including carcinogenic effects. Human health effects of TACs include birth defects, neurological damage, cancer, and death. There are hundreds of different types of TACs with varying degrees of toxicity. Thus, individual TACs vary greatly in the health risk they present; at a given level of exposure, one TAC may pose a hazard that is many times greater than another.

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4.2 Air Quality
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TABLE 4.2-1

SOURCES, ENVIRONMENTAL AND HEALTH EFFECTS OF CRITERIA AIR POLLUTANTS Criteria Air Pollutant Sources Environmental & Health Effects Ozone Formed when reactive organic gases
(ROG) and nitrogen oxides (NOX) react
in the presence of sunlight. Major
sources include on-road motor vehicles,
solvent evaporation, and commercial /
industrial mobile equipment.
• Respiratory symptoms
• Worsening of lung disease leading to
premature death
• Damage to lung tissue
• Crop, forest and ecosystem damage
• Damage to a variety of materials, including
rubber, plastics, fabrics, paint and metals
Carbon Monoxide Internal combustion engines, primarily
gasoline-powered motor vehicles.
• Chest pain in patients with heart disease
• Headache
• Light-headedness
• Reduced mental alertness
Nitrogen Dioxide Motor vehicles, petroleum refining
operations, industrial sources, aircraft,
ships, and railroads.
• Lung irritation
• Enhanced allergic responses
Sulfur Dioxide Fuel combustion, chemical plants,
sulfur recovery plants, and metal
processing.
• Worsening of asthma: increased symptoms,
increased medication usage, and emergency
room visits
Particulate Matter
(PM
10)
Dust and fume-producing industrial and
agricultural operations, combustion,
atmospheric photochemical reactions,
and natural activities (e.g., wind-raised
dust and ocean sprays).
• Premature death & hospitalization, primarily for
worsening of respiratory disease
• Reduced visibility and material soiling
Particulate Matter
(PM

2.5)
Fuel combustion in motor vehicles,
equipment, and industrial sources;
residential and agricultural burning; Also,
formed from photochemical reactions of
other pollutants, including NOX, sulfur
oxides, and organics.
• Premature death
• Hospitalization for worsening of cardiovascular
disease
• Hospitalization for respiratory disease
• Asthma-related emergency room visits
• Increased symptoms, increased inhaler usage
Lead Present sources: lead smelters, battery
manufacturing and recycling facilities.

Past source: combustion of leaded
gasoline.
• Impaired mental functioning in children
• Learning disabilities in children
• Brain and kidney damage
Sulfates Produced by the reaction in the air of
SO2.
• Same as PM2.5, particularly worsening of
asthma and other lung diseases
• Reduces visibility
Hydrogen Sulfide Geothermal power plants, petroleum
production and refining
• Nuisance odor (rotten egg smell)
• At high concentrations: headache & breathing
difficulties
Visibility Reducing
Particles
See PM2.5 • Reduced airport safety, scenic enjoyment, road safety, and discourages tourism
Vinyl Chloride Polyvinyl chloride and vinyl
manufacturing.
• Central nervous system effects, such as
dizziness, drowsiness & headaches
• Long- term exposure: liver damage & liver
cancer
SOURCE: CARB, 2022b; CARB, 2022c

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TABLE 4.2-2

STATE AND FEDERAL AMBIENT AIR QUALITY STANDARDS
Pollutant Averaging Time
State Standards
(CAAQS)a
Federal Standards
(NAAQS)b
Ozone
1 hour 0.09 ppm NA
8 hours 0.070 ppm 0.070 ppmc
Carbon Monoxide (CO)
1 hour 20 ppm 35 ppm
8 hours 9.0 ppm 9 ppm
Nitrogen Dioxide (NO2)
1 hour 0.18 ppm 0.100 ppm
Annual 0.03 ppm 0.053 ppm
Sulfur Dioxide (SO2)
1 hour 0.25 ppm 0.075 ppm
24 hours 0.04 ppm 0.14 ppm
Annual NA 0.03 ppm
Particulate Matter (PM10)
24 hours 50 µg/m3 150 µg/m3
Annuald 20 µg/m3 NA
Fine Particulate Matter
(PM2.5)
24 hours NA 35 µg/m3
Annual 12 µg/m3 12 µg/m3
Lead
30 days 1.5 µg/m3 NA
Calendar quarter NA 1.5 µg/m3
Rolling 3-month average NA 0.15 µg/m3
Sulfates 24 hours 25 µg/m3 NA
Hydrogen Sulfide 1 hour 0.03 ppm NA
Visibility reducing particles 8 hours --e NA
Vinyl Chloride 24 hours 0.01 ppm (26 µg/m3) NA
NOTES:

A = Attainment; N = Nonattainment; U = Unclassified; NA = Not Applicable, no applicable standard; ppm = parts per million; µg/m3 = micrograms per cubic meter
a CAAQS = California ambient air quality standards. CAAQS for ozone, CO (except Lake Tahoe), SO2 (one-hour and 24-hour), NO2, particulate matter, and visibility-reducing particles are values that are not to be exceeded. All other State standards shown are values not to be equaled or exceeded.
b NAAQS = national ambient air quality standards. NAAQS, other than ozone and particulates, and those based on annual averages or annual arithmetic means, are not to be exceeded more than once a year. The eight-hour ozone standard is attained when the three-year average of the fourth highest daily concentration is 0.08 ppm or less. The 24-hour PM10 standard is attained when the three-year average of the 99th percentile of monitored concentrations is less than the standard. The 24-hour PM2.5 standard is attained when the three-year average of the 98th percentile is less than the standard. c On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. An area will meet the standard if the fourth-highest maximum daily 8-hour ozone concentration per year, averaged over three years, is equal to or less than 0.070 ppm. EPA will make recommendations on attainment designations by October 1, 2016, and issue final designations October 1, 2017. Nonattainment areas will have until 2020 to late 2037 to meet the health standard, with attainment dates varying based on the ozone level in the area.
d State standard = annual geometric mean; national standard = annual arithmetic mean. e Statewide visibility-reducing particle standard (except Lake Tahoe Air Basin): Particles in sufficient amount to produce an extinction coefficient of 0.23 per kilometer when the relative humidity is less than 70 percent. This standard is intended to limit the frequency and severity of visibility impairment due to regional haze and is equivalent to a 10-mile nominal visual range.

SOURCE: BAAQMD, 2017b.

Unlike criteria air pollutants, TACs are not subject to ambient air quality standards but are regulated by air districts using a risk-based approach to determine which sources and which pollutants to control as well as the degree of control. A health risk assessment (HRA) is an

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City of Mountain View Housing Element Update 4.2-5 ESA / 202000806 Draft Environmental Impact Report July 2022
analysis that estimates human health exposure to toxic substances, and when considered together with information regarding the toxic potency of the substances, an HRA provides quantitative estimates of health risks.1
The Office of Environmental Hazard Health Assessment (OEHHA, 2015) and the BAAQMD (BAAQMD, 2016) provide guidelines for conducting HRAs. Exposure assessment guidance published by the BAAQMD in January 2016 adopts the assumption that residences would be exposed to air pollution 24 hours per day, 350 days per year, for 30 years (BAAQMD, 2016a).

Therefore, assessments of air pollutant exposure to residents typically result in the greatest adverse health outcomes of all population groups.

Exposure to fine PM (PM2.5) is strongly associated with mortality, respiratory diseases, and poor lung development in children, and other health effects, such as hospitalization for cardiopulmonary disease (San Francisco Department of Public Health, 2008). Diesel particulate matter (DPM), a byproduct of diesel fuel combustion, is also of concern. CARB identified DPM as a TAC in 1998, primarily based on evidence demonstrating cancer effects in humans (CARB, 1998). The estimated cancer risk from exposure to DPM is much higher than the risk associated with any other TAC routinely measured in the region. DPM is discussed further, below.

In a ddition to monitoring criteria air pollutants, the Bay Area’s air toxics network includes 16 monitoring sites, five of which were established by the CARB and are maintained by the BAAQMD. The remaining 11 sites are operated by the BAAQMD. These stations measure concentrations of volatile organic compounds (VOC), polycyclic aromatic hydrocarbons, and metals categorized as TACs. The TACs selected for monitoring are those that traditionally have been found in the highest concentrations in ambient air and therefore tend to produce the most significant risk. However, there are no monitoring stations in the immediate vicinity of the HEU area that measure ambient concentrations of carcinogenic TACs.

Roadway-Related Pollutants
Motor vehicles are responsible for a large share of air pollution, especially in California. Vehicle tailpipe emissions contain diverse forms of particles and gases, and vehicles also contribute to particulates by generating road dust and tire wear. Epidemiologic studies have demonstrated that people living close to freeways or busy roadways have poorer health outcomes, including increased asthma symptoms and respiratory infections, and decreased pulmonary function and poor lung development in children. Air pollution monitoring conducted in conjunction with epidemiologic studies has confirmed that roadway-related health effects vary with modeled exposure to PM and NO2. In traffic-related studies, the additional cancer health risk attributable to roadway proximity was seen within 1,000 feet of the roadway and was strongest within 300 feet (CARB, 2005). As a result, CARB recommends that new sensitive land uses not be located within 500 feet of a freeway or urban roads carrying more than 100,000 vehicles per day. CARB notes that these recommendations are advisory and should not be interpreted as defined “buffer zones,” and that

1 In general, an HRA is required if the BAAQMD concludes that projected emissions of a specific air toxic compound from a proposed new or modified source suggest a potential public health risk. The applicant is then subject to a HRA for the source in question. Such an assessment generally evaluates chronic, long-term effects, estimating the increased risk of cancer as a result of exposure to one or more TACs.

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City of Mountain View Housing Element Update 4.2-6 ESA / 202000806 Draft Environmental Impact Report July 2022
local agencies must balance other considerations, including transportation needs, the benefits of urban infill, community economic development priorities, and other quality of life issues. With careful evaluation of exposure, health risks, and affirmative steps to reduce risk where necessary, CARB’s position is that infill development, mixed use, higher density, transit-oriented development, and other concepts that benefit regional air quality can be compatible with protecting the health of individuals at the neighborhood level (CARB, 2005). Sometimes, suggesting project design changes or mitigation measures in the project review phase can also reduce or avoid potential impacts. This underscores the importance of addressing potential incompatible land uses as early as possible in the project review process, ideally in the general plan itself.

Diesel Particulate Matter
CARB identified DPM as a TAC in 1998, primarily based on evidence demonstrating cancer effects in humans. The exhaust from diesel engines includes hundreds of different gaseous and particulate components, many of which are toxic. Mobile sources such as trucks and buses are among the primary sources of diesel emissions, and concentrations of DPM are higher near heavily traveled highways. CARB estimated average bay area cancer risk from exposure to diesel particulate, based on a population-weighted average ambient diesel particulate concentration, at about 480 in one million as of the year 2000, which is much higher than the risk associated with any other toxic air pollutant routinely measured in the region.

In 2000, CARB approved a comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from both new and existing diesel-fueled vehicles and engines. Subsequent CARB regulations apply to new trucks and diesel fuel. With new controls and fuel requirements, 60 trucks built in 2007 would have the same particulate exhaust emissions as one truck built in 1988 (Pollution Engineering, 2006). The regulation was anticipated to result in an 80 percent decrease in statewide diesel health risk in 2020 as compared with the diesel risk in 2000. Many of the measures of the Diesel Risk Reduction Plan have been approved and adopted, including the federal on-road and off-road2 diesel engine emission standards for new engines, as well as adoption of regulations for low sulfur fuel in California. Subsequent regulations regarding on-road diesel truck retrofits with particulate matter controls, 2010 or later engine standards, and fleet average emission rate standards to increase vehicle turnover have resulted in much lower DPM and PM2.5 emissions over time. It is estimated that these regulations reduced diesel particulate emissions 78 percent from 1990 levels (Cal Matters, 2021). Despite notable emission reductions, CARB recommends that proximity to sources of DPM emissions be considered in the siting of new sensitive land uses.

Odors
Odors are generally regarded as an annoyance rather than a health hazard. The ability to detect odors varies considerably among the population and is subjective. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors. Odor impacts should be considered for any proposed new odor sources located near existing receptors, as well as any new sensitive receptors located near existing odor sources. Odor sources typically include wastewater treatment plants, landfills,

2 Non-road is the term EPA uses for vehicles and equipment that are not on-road, where in California this term is off-road.

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City of Mountain View Housing Element Update 4.2-7 ESA / 202000806 Draft Environmental Impact Report July 2022
confined animal facilities, composing stations, food manufacturing plants, refineries, and chemical plants (BAAQMD, 2017a).

Ambient Air Quality
The BAAQMD has jurisdiction to regulate air quality within the nine-county SFBAAB.

Accordingly, the region’s air quality monitoring network provides information on ambient concentrations of criteria air pollutants at various locations in the SFBAAB. Table 4.2-3 presents a five-year summary for 2016 to 2020 of the highest annual criteria air pollutant concentrations, recorded at the air quality monitoring station closest to the HEU area, operated and maintained by the BAAQMD at 897 Barron Avenue in Redwood City, approximately 9 miles northwest of the HEU area. The data collected at this monitoring station are representative of the ambient air quality in Mountain View. It also compares these concentrations with the most stringent applicable ambient air quality standards (whether state or federal). Concentrations shown in bold indicate an exceedance of that standard. CO is not included in this table as CO concentrations have been well below the standards throughout the Bay Area since the SFBAAB was designated as attainment with respect to the CO standards in 1998. Lead and SO2 are not included in this table because ambient lead concentrations are only monitored on an as-warranted basis, and the SFBAAB has never been designated as non-attainment for SO2. Lead levels in the air have decreased substantially since leaded gasoline was eliminated. The only l ead monitoring station in the Bay Area is located at Reid-Hillview Airport in San Jose (BAAQMD, 2021a). General aviation airports can be sources of lead because piston engine aircraft continue to use leaded fuel.

TABLE 4.2-3

SUMMARY OF AMBIENT AIR QUALITY DATA IN THE PROJECT AREA Pollutant Standard
Monitoring Data by Yeara
2016 2017 2018 2019 2020
Ozone
Maximum 1-Hour Concentration (ppm) >0.090 ppmb 0.075 0.115 0.067 0.083 0.098 Days 1-Hour Standard Exceeded 0 2 0 0 1
Maximum 8-Hour Concentration (ppm) 0.070 ppmc 0.061 0.087 0.050 0.077 0.078 Days 8-Hour Standard Exceeded 0 2 0 2 1
Fine Particulate Matter (PM2.5)
Maximum 24-Hour Concentration (µg/m3) >35 µg/m3 c 19.5 60.8 120.9 29.5 124.1 Annual Average (µg/m3) >12 µg/m3 b,c - 9.1 10.6 7.0 9.8 Days 24-Hour Standard Exceeded 0 6 13 0 9
Nitrogen Dioxide (NO2)
Maximum 1-Hour Concentration (ppm) >0.100 ppmc 45.7 67.4 77.3 54.9 45.9 Days 1-Hour Standard Exceeded 0 0 0 0 0
NOTES: ppm = parts per million; µg/m3 = micrograms per cubic meter a “—” indicates that data are not available.
b State standard, not to be exceeded; also a federal standard, not to be exceeded more than one per year. c Federal standard, not to be exceeded.

SOURCE: CARB, 2022d

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Compliance with the standards is on a regional basis. In the air basin, compliance is demonstrated by ongoing measurements of pollutant concentrations at more than 30 air quality monitoring stations operated by the BAAQMD in all nine bay area counties. An exceedance of an ambient air quality standard at any one of the stations counts as a regional exceedance.

As shown in Table 4.2-3, the most stringent applicable standards for ozone (the state one-hour standard of 0.09 ppm and the federal eight-hour standard of 0.07 ppm) were exceeded between 2017 and 2020. Table 4.2-3 also shows that the state 24-hour PM10 standard of 35 micrograms per cubic meter (µg/m3) was exceeded on 28 days between 2017 and 2020. The state annual average standard was not exceeded between 2016 and 2020. This station does not monitor PM10, but ambient levels of NO2 were well below the standards.

Air Quality Index
The U.S. EPA developed the Air Quality Index (AQI) scale to make the public health impacts of air pollution concentrations easily understandable. The index, much like an air quality “thermometer,” translates daily air pollution concentrations into a number on a scale between 0 and 500. The numbers in the scale are divided into six color-coded ranges, with numbers 0 through 500 as outlined below:
• G reen (0–50) indicates “good” air quality. No health impacts are expected when air quality is in the green range.
• Yellow (51–100) indicates air quality is “moderate.” Unusually sensitive people should consider limiting prolonged outdoor exertion.
• Orange (101–150) indicates air quality is “unhealthy for sensitive groups.” Active children and adults, and people with respiratory disease, such as asthma, should limit outdoor exertion. • Red (151–200) indicates air quality is “unhealthy.” Active children and adults, and people with respiratory disease, such as asthma, should avoid prolonged outdoor exertion; everyone else, especially children, should limit prolonged outdoor exertion. • Purple (201–300) indicates air quality is “very unhealthy.” Active children and adults, and people with respiratory disease, such as asthma, should avoid prolonged outdoor exertion; everyone else, especially children, should limit outdoor exertion. • Maroon (301–500) indicates air quality is “hazardous.” This would trigger health warnings of emergency conditions, and the entire population is more likely to be affected.

The AQI numbers refer to specific amounts of pollution in the air. They are based on the federal air quality standards for ozone, CO, NO2, SO2, PM10, and PM2.5. In most cases, the federal standard for these air pollutants corresponds to the number 100 on the index chart. Thus, if the concentration of any of these pollutants rises above its respective standard, the air quality can be unhealthy for the public. In determining the air quality forecast, local air districts use the anticipated concentration measurements for each of the major pollutants, convert them into index numbers, and determine the highest index for each zone in a district. A Spare the Air Alert is called for the Bay Area when air quality is expected to be unhealthy in any of the region’s five reporting zones.

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City of Mountain View Housing Element Update 4.2-9 ESA / 202000806 Draft Environmental Impact Report July 2022
Readings below 100 on the AQI scale would not typically affect the health of the general public (although readings in the moderate range of 50 to 100 may affect unusually sensitive people).

Levels above 300 rarely occur in the United States, and readings above 200 have not occurred in the Bay Area in decades, with the exception of the October 2017 and November 2018 wildfires north of San Francisco and the August/September 2020 complex wildfires that occurred throughout the Bay Area. As a result, the AQI in several neighboring counties reached the “very unhealthy” and “hazardous” designations, ranging from values of 201 to above 350. During those periods, the BAAQMD issued “Spare the Air” alerts and recommended that individuals stay inside with windows closed and refrain from significant outdoor activity. Wildfires appear to be occurring with increasing frequency in California and the Bay Area as a result of global warming and climate change. Eighteen of the state’s 20 largest wildfires and most destructive fires on record have occurred since the year 2000 (CALFIRE, 2022).

AQI statistics over recent years indicate that air quality in the South Central Bay which includes Mountain View is predominantly in the “Good” or “Moderate” categories and healthy on most days for most people. Historical BAAQMD data indicate that the SFBAAB experienced air quality in the red level (unhealthy) on 34 days between 2017 and 2021. As shown in Table 4.2-4, the air basin had a total of 110 red-level or orange-level (unhealthy or unhealthy for sensitive groups) days between 2017 and 2021. A number of these days are attributable to the increasing frequency of wildfires. This table also shows that the SFBAAB experienced a total of 9 purple level (very unhealthy) days in between 2017 and 2021.

TABLE 4.2-4

AIR QUALITY INDEX STATISTICS FOR THE SFBAAB
AQI Statistics
Number of Days per Year
2017 2018 2019 2020 2021
Unhealthy for Sensitive Groups (Orange) AQI: 151-200 9 8 10 34 3 Unhealthy (Red) AQI: 201-300 9 8 0 17 0
Very Unhealthy (Purple) AQI: 301-500 3 5 0 1 0
SOURCE: BAAQMD, 2022

Existing Sources of Air Pollution in the Project Area
The BAAQMD’s inventory of permitted stationary sources of emissions shows numerous permitted stationary emission facilities present within the HEU area boundaries. The vast majority of these sources are stationary diesel engines for power generators and fuel stations. The major freeways and roadways in the vicinity of the HEU areas are U.S. 101 and State Routes (SR) 82 (El Camino Real), 85 and 287. In addition, the Caltrain line runs through the center of Mountain View.

Sensitive Receptors
Air quality does not affect every individual in the population in the same way, and some groups are more sensitive to adverse health effects than others. More sensitive population groups include: the

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City of Mountain View Housing Element Update 4.2-10 ESA / 202000806 Draft Environmental Impact Report July 2022
elderly and the young; those with higher rates of respiratory disease, such as asthma and chronic obstructive pulmonary disease; and those with other environmental or occupational health exposures (e.g., indoor air quality) that affect cardiovascular or respiratory diseases. The BAAQMD defines sensitive receptors as children, adults, and seniors occupying or residing in residential dwellings, schools, daycare centers, hospitals, and senior-care facilities. Workers are not considered sensitive receptors because all employers must follow regulations set forth by the Occupation Safety and Health Administration to ensure the health and well-being of their employees (BAAQMD, 2011).

The proximity of sensitive receptors to motor vehicles is an air pollution concern, especially in urban areas where building setbacks are limited and roadway volumes are higher than suburban locations of the bay area. Vehicles also contribute to particulates by generating road dust and through tire wear. Existing sensitive receptors are present throughout the HEU areas.

4.2.3 Regulatory Setting
Regulation of air pollution is achieved through both national and state ambient air quality standards and through emissions limits on individual sources of air pollutants. Local Air Quality Management Districts and Air Pollution Control Districts are responsible for demonstrating attainment with state air quality standards through the adoption and enforcement of Attainment Plans.

Federal
Criteria Air Pollutants
The 1970 Clean Air Act (most recently amended in 1990) requires that regional planning and air pollution control agencies prepare a regional air quality plan to outline the measures by which both stationary and mobile sources of pollutants will be controlled in order to achieve all ambient air quality standards by the deadlines specified in the act. These ambient air quality standards are intended to protect the public health and welfare, and they specify the concentration of pollutants (with an adequate margin of safety) to which the public can be exposed without adverse health effects. They are designed to protect those segments of the public most susceptible to respiratory distress, including asthmatics, the very young, the elderly, people weakened from other illness or disease, or persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollution levels that are somewhat above ambient air quality standards before adverse health effects are observed. Table 4.2-5 presents current state (California Ambient Air Quality Standards, or CAAQS) and national (National Ambient Air Quality Standards, or NAAQS) ambient air quality standards.

NAAQS and CAAQS have been set at levels considered safe to protect public, including the health of sensitive populations such as asthmatics, children, and the elderly with a margin of safety; and to protect public welfare, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings. As explained by CARB, “An air quality standard defines the maximum amount of a pollutant averaged over a specified period of time that can be present in outdoor air without any harmful effects on people or the environment” (CARB, 2017). That is, if a region is in compliance with the ambient air quality standards, its regional air quality can be considered protective of public health. The NAAQS are statutorily required to be set by the U.S. EPA at levels that are

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City of Mountain View Housing Element Update 4.2-11 ESA / 202000806 Draft Environmental Impact Report July 2022
“requisite to protect the public health.”3 Therefore, the closer a region is to attaining a particular ambient air quality standard, the lower the human health impact is from that pollutant. See Section

4.2.2, above, for a brief description of the health effects of exposure to criteria air pollutants.

TABLE 4.2-5

STATE AND NATIONAL AMBIENT AIR QUALITY STANDARDS AND MAJOR SOURCES Pollutant
Averaging
Time CAAQS NAAQS Major Pollutant Sources
Ozone 1 hour 0.09 ppm --- Formed when reactive organic gases (ROG) and nitrogen oxides (NOX) react in the presence of
sunlight. Major sources include on-road motor
vehicles, solvent evaporation, and commercial /
industrial mobile equipment.
8 hour 0.070 ppm 0.070 ppm
Carbon Monoxide 1 hour 20 ppm 35 ppm Internal combustion engines, primarily gasoline- powered motor vehicles. 8 hour 9.0 ppm 9 ppm
Nitrogen Dioxide 1 hour 0.18 ppm 100 ppb Motor vehicles, petroleum refining operations, industrial sources, aircraft, ships, and railroads. Annual Avg.

0.030 ppm 0.053 ppm
Sulfur Dioxide 1 hour 0.25 ppm 75 ppb Fuel combustion, chemical plants, sulfur recovery plants, and metal processing. 3 hour --- 0.5 ppm 1
24 hour 0.04 ppm 0.14 ppm
Annual
Avg.
--- 0.030 ppm
Respirable
Particulate Matter
(PM10)
24 hour 50 ug/m3 150 ug/m3 Dust and fume-producing industrial and agricultural operations, combustion, atmospheric photochemical
reactions, and natural activities (e.g., wind-raised
dust and ocean sprays).

Annual
Avg.
20 ug/m3 ---
Fine Particulate
Matter
(PM2.5)
24 hour --- 35 ug/m3 Fuel combustion in motor vehicles, equipment, and industrial sources; residential and agricultural burning; Also, formed from photochemical reactions of other
pollutants, including NOX, sulfur oxides, and organics.

Annual
Avg.
12 ug/m3 12.0 ug/m3
Lead Monthly
Ave.

1.5 ug/m3 --- Present source: lead smelters, battery
manufacturing and recycling facilities. Past source:
combustion of leaded gasoline. Quarterly --- 1.5 ug/m3
Hydrogen Sulfide 1 hour 0.03 ppm No National
Standard
Geothermal power plants, petroleum production and
refining
Sulfates 24 hour 25 ug/m3 No National
Standard
Produced by the reaction in the air of SO2.

Visibility Reducing
Particles
8 hour Extinction of

0.23/km;
visibility of 10
miles or more
No National
Standard
See PM2.5.

Vinyl chloride 24 hour 0.01 ppm No National
Standard
Polyvinyl chloride and vinyl manufacturing.

NOTE:
ppb = parts per billion; ppm = parts per million; ug/m3 = micrograms per cubic meter. a Secondary national standard.

SOURCES: CARB, 2016.

3 See https://www.law.cornell.edu/uscode/text/42/7409.

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Pursuant to the 1990 Federal Clean Air Act Amendments (FCAAA), the US EPA classifies air basins (or portions thereof) as “attainment”, “nonattainment”, or “unclassified” for each criteria air pollutant, based on whether or not the national standards had been achieved. As shown in Table 4.2-5, at the federal level, the SFBAAB is designated as a nonattainment area for the 8-hour ozone standard and the federal 24-hour PM

2.5 standard. The SFBAAB is in attainment for all other federal ambient air quality standards. State-level attainment status of the SFBAAB is discussed further below.

The FCAA requires each state to prepare an air quality control plan referred to as the State Implementation Plan (SIP). The FCAA added requirements for states containing areas that violate the national standards to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is a living document that is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of air basins as reported by the agencies with jurisdiction over them. The U.S. EPA has the responsibility to review all SIPs to determine if they conform to the mandates of the FCAA and will achieve air quality goals when implemented.

Federal and State Attainment Designations for Criteria Air Pollutants Pursuant to the 1990 Federal Clean Air Act Amendments, the U.S. EPA classifies air basins (or portions thereof) as “attainment”, “nonattainment”, or “unclassified” for each criteria air pollutant, based on whether or not the national standards had been achieved. As shown in Table 4.2-6, at the federal level, the SFBAAB is designated as a nonattainment area for the 8- hour ozone standard and the federal 24-hour PM2.5 standard. The SFBAAB is in attainment for all other federal ambient air quality standards.

The California Clean Air Act (California Health and Safety Code section 39600 et seq.) passed in 1988, like its federal counterpart, calls for designation of areas as “attainment”, “nonattainment”, or “unclassified” with respect to the state standards. The SFBAAB is currently designated as nonattainment for the state 8-hour and 1-hour ozone standards, the state average and 24-hour PM10 standards, and the state average PM2.5 standards. The SFBAAB is designated as attainment or unclassified with respect to the other state standards.

The FCAA requires each state to prepare an air quality control plan referred to as the State Implementation Plan (SIP). The FCAA added requirements for states containing areas that violate the national standards to revise their SIPs to incorporate additional control measures to reduce air pollution. The SIP is a living document that is periodically modified to reflect the latest emissions inventories, planning documents, and rules and regulations of air basins as reported by the agencies with jurisdiction over them. The U.S. EPA has the responsibility to review all SIPs to determine if they conform to the mandates of the FCAA and will achieve air quality goals when implemented.

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TABLE 4.2-6

SAN FRANCISCO BAY AREA AIR BASIN ATTAINMENT STATUS
Pollutant Averaging Time
Designation/Classification
State Standards Federal Standards
Ozone 8 Hour Nonattainment Nonattainment
1 Hour Nonattainment --
Carbon Monoxide 8 Hour Attainment Attainment
1 Hour Attainment Attainment
Nitrogen Dioxide 1 Hour Attainment --
Annual Arithmetic Mean -- Attainment
Sulfur Dioxide 24 Hour Attainment --
1 Hour Attainment --
Annual Arithmetic Mean -- --
Respirable Particulate Matter (PM10) Annual Arithmetic Mean Nonattainment -- 24 Hour Nonattainment Unclassified
Fine Particulate Matter (PM2.5) Annual Arithmetic Mean Nonattainment Unclassified/Attainment 24 Hour -- Nonattainment
Sulfates 24 Hour Attainment --
Lead 30 Day Average -- Attainment
Calendar Quarter -- Attainment
Rolling Month Average -- --
Hydrogen Sulfide 1 Hour Unclassified --
Vinyl Chloride 24 Hour No information available --
Visibility Reducing Particles 8 Hour Unclassified --
NOTES:
µg/m3 = micrograms per cubic meter; Avg. = Average; PM2.5 = particulate matter 2.5 microns or less in diameter; PM10 = particulate matter 10 microns or less in diameter; ppb = parts per billion; ppm = parts per million SOURCE: Bay Area Air Quality Management District, Air Quality Standards and Attainment Status, updated January 5, 2017. Available at https://www.baaqmd.gov/about-air-quality/research-and-data/air-quality-standards-and-attainment-status. Accessed April 25, 2022.

State
Criteria Air Pollutants
Although the federal Clean Air Act established the NAAQS, individual states retained the option to adopt more stringent standards and to include other pollution sources. California had already established its own air quality standards when federal standards were established, and because of the unique meteorological challenges in California, there are differences between the state and national ambient air quality standards, as shown in Table 4.2-5. California ambient standards tend to be at least as protective as national ambient standards or are often more stringent.

In 1988, California passed the California Clean Air Act (California Health and Safety Code section 39600 et seq.), which, like its federal counterpart, called for designation of areas as “attainment”, “nonattainment”, or “unclassified” with respect to the state standards. The

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SFBAAB is currently designated as nonattainment for the state 8-hour and 1-hour ozone standards, the state average and 24-hour PM10 standards, and the state average PM2.5 standards.

The SFBAAB is designated as attainment or unclassified with respect to the other state standards.

Toxic Air Contaminants
The Health and Safety Code defines TACs as air pollutants that may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health. The State Air Toxics Program was established in 1983 under AB 1807 (Tanner). A total of 243 substances have been designated TACs under California law, including the 189 (federal) Hazardous Air Pollutants.

The CARB In-Use Off-Road Diesel-Fueled Fleets Regulation (Off-Road Regulation) applies to all self-propelled off-road diesel vehicles 25 horsepower or greater used in California and most two-engine vehicles (except on-road two-engine sweepers). This includes vehicles that are rented or leased (rental or leased fleets). CARB’s goal is to gradually reduce the state-wide construction vehicle fleet’s emissions through turnover, repower, or retrofits. New engine emissions requirements were grouped into tiers based on the year in which the engine was built (CARB 2022a). In 2014, new engines were required to meet Tier 4 Final standards, which to date are the most stringent emissions standards for off-road vehicle engines. The goal of the In-Use Off-Road Diesel-Fueled Fleets Regulation is to reduce particulate matter (PM10 and PM2.5) and NOx emissions from off-road heavy-duty diesel vehicles in California (CARB 2022e). This regulation also limits idling to 5 minutes, requires a written idling policy for larger vehicle fleets, and requires that fleet operators provide information on their engines to CARB and label vehicles with a CARB-issued vehicle identification number.

CARB recommends that proximity to sources of DPM emissions be considered in the siting of new sensitive land uses. As discussed above, CARB published Air Quality and Land Use Handbook: A Community Health Perspective in April 2005. This handbook is intended to give guidance to local governments in the siting of sensitive land uses near sources of air pollution.

Recent studies have shown that public exposure to air pollution can be substantially elevated near freeways and certain other facilities such as ports, rail yards, and distribution centers. Sensitive receptor siting recommendations for applicable uses in the City of Mountain View are listed in Table 4.2-7 below. CARB notes that these recommendations are advisory and should not be interpreted as defined “buffer zones,” and that local agencies must balance other considerations, including transportation needs, the benefits of urban infill, community economic development priorities, and other quality of life issues. With careful evaluation of exposure, health risks, and affirmative steps to reduce risk where necessary CARB’s position is that infill development, mixed use, higher density, transit-oriented development, and other concepts that benefit regional air quality can be compatible with protecting the health of individuals at the neighborhood level (CARB, 2005).

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TABLE 4.2-7

RECOMMENDATIONS FOR SITING NEW SENSITIVE LAND USES
Source Category Advisory Recommendations of Locations to Avoid Freeways and High-
Traffic Roads
500’ of a freeway or urban road with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day.

Dry Cleaners Using
Perchloroethylene
300’ of any dry cleaning operation. For operations with two or more machines, provide 500’.

For operations with three or more machines, consult the local air district. Also, do not site new sensitive receptors in the same building with perchloroethylene dry cleaning operations.

Gasoline Dispensing
Facilities
300’ of a large gas station, defined as a facility with a throughput of 3.6 million gallons per year or greater. A 50’ separation is recommended for typical gas dispensing facilities.

SOURCE: CARB, 2005.

Off-road Diesel Emissions
The CARB In-Use Off-Road Diesel-Fueled Fleets Regulation (Off-Road Regulation) applies to all self-propelled off-road diesel vehicles 25 horsepower or greater used in California and most two-engine vehicles (except on-road two-engine sweepers). This includes vehicles that are rented or leased (rental or leased fleets). CARB’s goal is to gradually reduce the state-wide construction vehicle fleet’s emissions through turnover, repower, or retrofits. New engine emissions requirements were grouped into tiers based on the year in which the engine was built (CARB 2022a). In 2014, new engines were required to meet Tier 4 Final standards, which to date are the most stringent emissions standards for off-road vehicle engines. The goal of the In-Use Off-Road Diesel-Fueled Fleets Regulation is to reduce particulate matter (PM10 and PM2.5) and NOx emissions from off-road heavy-duty diesel vehicles in California (CARB 2022b). This regulation also limits idling to 5 minutes, requires a written idling policy for larger vehicle fleets, and requires that fleet operators provide information on their engines to CARB and label vehicles with a CARB-issued vehicle identification number.

CARB recommends that proximity to sources of DPM emissions be considered in the siting of new sensitive land uses. As discussed above, CARB published Air Quality and Land Use Handbook: A Community Health Perspective in April 2005. This handbook is intended to give guidance to local governments in the siting of sensitive land uses near sources of air pollution.

Recent studies have shown that public exposure to air pollution can be substantially elevated near freeways and certain other facilities such as ports, rail yards, and distribution centers. Sensitive receptor siting recommendations for applicable uses in the HEU area are listed in Table 4.2-8 below. CARB notes that these recommendations are advisory and should not be interpreted as defined “buffer zones,” and that local agencies must balance other considerations, including transportation needs, the benefits of urban infill, community economic development priorities, and other quality of life issues. With careful evaluation of exposure, health risks, and affirmative steps to reduce risk where necessary CARB’s position is that infill development, mixed use, higher density, transit-oriented development, and other concepts that benefit regional air quality can be compatible with protecting the health of individuals at the neighborhood level (CARB, 2005).

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TABLE 4.2-8

RECOMMENDATIONS FOR SITING NEW SENSITIVE LAND USES
Source Category Advisory Recommendations of Locations to Avoid Freeways and High-
Traffic Roads
500’ of a freeway or urban road with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day.

Dry Cleaners Using
Perchloroethylene
300’ of any dry cleaning operation. For operations with two or more machines, provide 500’.

For operations with three or more machines, consult the local air district. Also, do not site new sensitive receptors in the same building with perchloroethylene dry cleaning operations.

Gasoline Dispensing
Facilities
300’ of a large gas station, defined as a facility with a throughput of 3.6 million gallons per year or greater. A 50’ separation is recommended for typical gas dispensing facilities.

SOURCE: CARB, 2005.

California Building and Energy Efficiency Standards (Title 24) The California Energy Commission (CEC) first adopted Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations Title 24, Part 6) in 1978 in response to a legislative mandate to reduce energy consumption in the state. Although not originally intended to reduce emissions of criteria pollutants or TACs, increased energy efficiency and reduced consumption of natural gas and other fuels would also result in lower criteria pollutant and TAC emissions from residential and non-residential buildings subject to these standards. The standards are updated periodically (typically every three years) to allow for the consideration and inclusion of new energy efficiency technologies and methods (CEC, 2018).

The most recent update to the Title 24 energy efficiency standards (2019 standards) went into effect on January 1, 2020. On August 11, 2021, the CEC adopted the next update, the 2022 Energy Code which was approved by the California Building Standards Commission for inclusion into the California Building Standards Code (CEC, 2022). The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic (PV) and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 Energy Code. The 2022 Update includes measures that will reduce energy use in single family, multifamily, and nonresidential buildings. These measures will:

1. Af fect newly constructed buildings by adding new prescriptive and performance standards for electric heat pumps for space conditioning and water heating, as appropriate for the various climate zones in California;

2. Require PV and battery storage systems for newly constructed multifamily and selected nonresidential buildings;

3. Update efficiency measures for lighting, building envelope, heating, ventilation, and air conditioning (HVAC); and

4. Make improvements to reduce the energy loads of certain equipment covered by (i.e., subject to the requirements of) the Energy Code that perform a commercial process that is not related to the occupant needs in the building (such as refrigeration equipment in refrigerated warehouses, or air conditioning for computer equipment in data processing centers).

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As future updates to the Title 24 standards are rolled out, development within the HEU area would be required to adhere to the current version of Title 24 at that time, as conditions of approval for subdivision maps, site development and planned development permits, grading permits, and demolition permits.

California Green Standards Building Code
Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGreen) Code. The CALGreen Code is intended to encourage more sustainable and environmentally friendly building practices, require low-pollution emitting substances that cause less harm to the environment, conserve natural resources, and promote the use of energy-efficient materials and equipment.

Since 2011, the CALGreen Code has been mandatory for all new residential and non-residential buildings constructed in the state. Such mandatory measures include energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality.

Like the Title 24 Part 6 standards, compliance with the CALGreen Code also reduces criteria pollutant and TAC emissions. The CALGreen Code was most recently updated in 2019 to include new mandatory measures for residential and non-residential uses; the new measures took effect on January 1, 2020 (California Building Standards Commission [CBSC], 2019). The 2019 standards prescribe Electric Vehicle (EV) charging requirements for residential and non- residential buildings.

The ne xt, 2022 CALGreen update simplifies the code and its application in several ways. It offers new voluntary prerequisites for builders to choose from, such as battery storage system controls and heat pump space, and water heating, to encourage building electrification. While the 2019 CALGreen Code only requires provision of EV Capable spaces with no requirement for chargers to be installed at multifamily dwellings, the 2022 CALGreen code mandates chargers (California Housing and Community Development, n.d).

Regional
BAAQMD
The BAAQMD is the regional agency with jurisdiction over the nine-county region located in the SFBAAB. The Association of Bay Area Governments (ABAG), the Metropolitan Transportation Commission (MTC), county transportation agencies, cities and counties, and various non- governmental organizations also participate in the efforts to improve air quality through a variety of programs. These programs include the adoption of regulations and policies, as well as implementation of extensive education and public outreach programs. The BAAQMD is responsible for attaining and/or maintaining air quality in the region within federal and state air quality standards. Specifically, the BAAQMD has the responsibility to monitor ambient air pollutant levels throughout the region and to develop and implement strategies to attain the applicable federal and state standards. The BAAQMD has permit authority over most types of stationary emission sources and can require stationary sources to obtain permits, and can impose emission limits, set fuel or material specifications, or establish operational limits to reduce air

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emissions. The BAAQMD also regulates new or expanding stationary sources of TACs and requires air toxic control measures for many sources emitting TACs.

Clean Air Plan
The most recent clean air plan was updated in 2017. The 2017 Clean Air Plan: Spare the Air, Cool the Climate (2017 Clean Air Plan; BAAQMD 2017c) was adopted on April 19, 2017 by the BAAQMD in cooperation with the MTC, the San Francisco Bay Conservation and Development Commission, and the ABAG to provide a regional strategy focusing on two closely-related goals:
protecting public health and protecting the climate.

To fulfill state ozone planning requirements, the 2017 Clean Air Plan includes all feasible measures to reduce emissions of ozone precursors ROG and NOx, and reduce transport of ozone and its precursors to neighboring air basins. In addition, the plan builds upon and enhances the BAAQMD’s efforts to reduce emissions of PM10, PM2.5, and TACs. The 2017 Clean Air Plan contains 85 control measures categorized based on the economic sector framework including stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, and water measures.

CEQA Guidelines and Thresholds of Significance
The BAAQMD CEQA Air Quality Guidelines is an advisory document that provides lead agencies, consultants, and project proponents with procedures for assessing air quality impacts and preparing environmental review documents. The document describes the criteria that BAAQMD uses when reviewing and commenting on the adequacy of environmental documents.

It recommends thresholds for use in determining whether projects and plans would have significant adverse environmental impacts, identifies methods for predicting project emissions and impacts, and identifies measures that can be used to avoid or reduce air quality impacts.

In M ay 2011, BAAQMD adopted an updated version of its thresholds of significance for use in determining the significance of environmental effects under CEQA and published its CEQA Guidelines for consideration by lead agencies. The 2011 CEQA Guidelines also included methods for evaluating risks and hazards for the siting of new sensitive receptors based on nearby, existing sources of risk (e.g. freeways).

The BAAQMD resolution adopting the significance thresholds in 2011 was set aside by the Alameda County Superior Court on March 5, 2012. On August 13, 2013, the California Court of Appeals issued a full reversal of the Superior Court’s judgment, and on December 17, 2015, the California Supreme Court reversed in part the appellate court’s judgment and remanded the case for further consideration consistent with the Supreme Court opinion. The California Supreme Court ruled unanimously that CEQA review is focused on a project’s impact on the environment “and not the environment’s impact on the project” (California Building Industry Association v.

Bay Area Air Quality Management District [December 17, 2015] 62 Cal.4th 369). The Supreme Court confirmed that “agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project’s future residents or users.” The Court also held that when a project has “potentially significant exacerbating effects on existing environmental hazards” those impacts are properly within the scope of CEQA because they can be viewed as

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impacts of the project on “existing conditions” rather than impacts of the environment on the project.

BAAQMD most recently updated its CEQA Air Quality Guidelines in May 2017 (BAAQMD, 2017b). These guidelines provide recommended quantitative significance thresholds along with direction on recommended analysis methods. BAAQMD states that the quantitative significance thresholds are “advisory and should be followed by local governments at their own discretion,” and that lead agencies are fully within their authority to develop their own thresholds of significance. However, BAAQMD offers these thresholds for lead agencies to use in order to inform environmental review for development projects in the Bay Area. Lead agencies may also reference the CEQA Thresholds Options and Justification Report developed by BAAQMD staff in 2009. This option provides lead agencies with a justification for continuing to rely on the BAAQMD 2011 thresholds.

BAAQMD Rules and Regulations
As discussed earlier, the BAAQMD is the regional agency responsible for rulemaking, permitting and enforcement activities affecting stationary sources in the Bay Area. Specific rules and regulations adopted by the BAAQMD limit the emissions that can be generated by various uses and/or activities and identify specific pollution reduction measures that must be implemented in association with various uses and activities. These rules regulate not only emissions of the six criteria air pollutants, but also toxic emissions and acutely hazardous non-radioactive materials emissions. Emissions sources subject to these rules are regulated through the BAAQMD’s permitting process and standards of operation. Through this permitting process, including an annual permit review, the BAAQMD monitors generation of emissions from stationary sources and uses this information in developing its air quality plans. Any stationary sources of emissions proposed as part of the HEU (e.g. backup generators) would be subject to applicable BAAQMD Rules and Regulations.

The B AAQMD Rules and Regulations applicable to the HEU include, but are not limited to, the following:
• Regulation 2, Rule 1 (General Permit Requirements), Rule 2 (New Source Review), and Rule 5 (New Source Review of Toxic Air Contaminants). Under these rules, all stationary sources that have the potential to emit TACs above a certain level are required to obtain permits from BAAQMD. These rules provide guidance for the review of new and modified stationary sources of TAC emissions, including evaluation of health risks and potential mitigation measures. Any proposed emergency generators and fire pumps proposed as part of the HEU would be subject to these rules. The California Building Code Section 2702.2.15 requires emergency and standby power to be provided in buildings with occupied floors located more than 75 feet above the lowest level of fire department vehicle access. The BAAQMD recently updated its BACT requirement for emergency generators greater than 1,000 horsepower (hp) to achieve EPA Tier 4 standards (BAAQMD, 2021b). Fire pumps are essential components of a building's fire protection system, especially in taller structures and are critical in distributing water through sprinkler systems where water pressure from water mains and firefighting equipment cannot reach.