ATT 1 - Resolution for the Final EIR — Mountain View City Council, November 4, 2025 (part 1 of 9)

ATTACHMENT 1
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CITY OF MOUNTAIN VIEW
RESOLUTION NO. ________
SERIES 2025

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF MOUNTAIN VIEW

ADOPTING FINDINGS RELATED TO ENVIRONMENTAL IMPACTS, MITIGATION MEASURES, AND ALTERNATIVES; ADOPTING A STATEMENT OF OVERRIDING CONSIDERATIONS AND A MITIGATION MONITORING AND REPORTING PROGRAM; AND CERTIFYING THE MOUNTAIN

VIEW PUBLIC SAFETY BUILDING ENVIRONMENTAL IMPACT REPORT 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 MOUNTAIN VIEW PUBLIC SAFETY BUILDING, (hereinafter “Project”); and
WHEREAS, the City prepared and circulated a Draft EIR for the requisite 45-day public comment period, which ended on August 15, 2025, and gave all public notices in the manner and at the times required by law; and
WHEREAS, no public comments were received on the Draft EIR; and WHEREAS, the Final EIR document dated October 2025, together with the Draft EIR, comprises 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, including impacts to a historical resource on the project site that is eligible for listing in the California Register under Criterion 3; and
WHEREAS, there are specific economic, legal, social, technological, or other benefits that outweigh the project’s significant unavoidable impact and support approval of the proposed project, and the City’s analysis of the impacts and benefits are articulated in Exhibit D, Statement of Overriding Considerations; 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 historic resources; and
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WHEREAS, the Final EIR identifies and analyzes a reasonable range of alternatives to the proposed Project; and
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 City Council held a public hearing on November 4, 2025, 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); 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 EIR, attached hereto in Exhibit A and Exhibit B, 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 Mitigation Monitoring and Reporting Program for the Project, attached hereto as Exhibit B.

3. Adopts the CEQA findings for the Project, attached hereto as Exhibit C.

4. Adopts the Statement of Overriding Considerations for the project, attached hereto as Exhibit D.

5. 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 remove the historical resource on the project site that is eligible for listing in the California Register under Criterion 3 as a significant example of thework of master architect Goodwin Steinberg.
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6. 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 will achieve the Project objectives to the same degree as the proposed Project 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. – – – – – – – – – – –
Exhibits: A. Draft EIR
B Final EIR and Mitigation Monitoring and Reporting Program C. CEQA Findings
D. Statement of Overriding Considerations
City of Mountain View

MOUNTAIN VIEW PUBLIC SAFETY BUILDING
July 2025 | Draft Environmental Impact Report
State Clearinghouse No. 2024120444
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EXHIBIT A
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July 2025 | Draft Environmental Impact Report
State Clearinghouse No. 2024120444

MOUNTAIN VIEW PUBLIC SAFETY BUILDING
for the City of Mountain View
City of Mountain View
Public Works Department
Contact: Naveen Govind, Senior Project Manager
500 Castro Street
Mountain View, California 94041
650.903.6527
Prepared by:

PlaceWorks
2040 Bancroft Way, Suite 400
Berkeley, California 94704
510.848.3815
www.placeworks.com
In Association with:

Forget Me Not History
Woodreeve Consulting
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TABLE OF CONTENTS

1. Executive Summary ........................................................................................ 1-1

1.1 Introduction ........................................................................................................ 1-1

1.2 Environmental Procedures ................................................................................. 1-1

1.3 Project Location.................................................................................................. 1-3

1.4 Project Summary ................................................................................................ 1-3

1.5 Summary of Project Alternatives........................................................................ 1-4

1.6 Issues to Be Resolved.......................................................................................... 1-4

1.7 Areas of Controversy .......................................................................................... 1-5

1.8 Summary of Significant Environmental Impacts ................................................. 1-5

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

2.1 Purpose of the Environmental Impact Report .................................................... 2-1

2.2 Environmental Review Process........................................................................... 2-2

2.3 Scope of this Draft EIR ........................................................................................ 2-3

2.4 Incorporation by Reference ................................................................................ 2-5

2.5 Mitigation Monitoring ........................................................................................ 2-5

3. Project Description ......................................................................................... 3-1

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

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

3.3 Statement of Objectives..................................................................................... 3-5

3.4 Project Characteristics........................................................................................ 3-5

3.5 Intended Uses of the EIR .................................................................................. 3-12

4. Environmental Analysis .................................................................................. 4-1 Organization of Environmental Analysis......................................................................... 4-1 Levels of Significance...................................................................................................... 4-2 Cumulative Impacts........................................................................................................ 4-2

4.1 Air Quality........................................................................................................4.1-1

4.2 Biological Resources........................................................................................4.2-1

4.3 Cultural and Tribal Cultural Resources.............................................................4.3-1

4.4 Geology and Soils ............................................................................................4.4-1

4.5 Greenhouse Gas Emissions..............................................................................4.5-1

4.6 Hazards and Hazardous Materials ...................................................................4.6-1

4.7 Noise ...............................................................................................................4.7-1

4.8 Transportation ................................................................................................. 4.8-1

5. Alternatives to the Proposed Project .............................................................. 5-1

5.1 Introduction ........................................................................................................ 5-1

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5.2 Factors Considered when Developing Alternatives............................................. 5-2

5.3 Alternatives Considered and Rejected................................................................ 5-3

5.4 Alternatives Selected for Analysis....................................................................... 5-4

5.5 Alternative A: No Project Alternative.................................................................. 5-4

5.6 Alternative B: Historic Preservation Alternative ................................................. 5-8

5.7 Summary of Alternatives Evaluation................................................................. 5-12

5.8 Environmentally Superior Alternative............................................................... 5-14

6. Other CEQA Considerations ............................................................................ 6-1

6.1 Effects Found Not to Be Significant..................................................................... 6-1

6.2 Significant Unavoidable impacts......................................................................... 6-3

6.3 Significant Irreversible Changes.......................................................................... 6-4

6.4 Growth-Inducing Effects..................................................................................... 6-5

7. Organizations and Persons Consulted ............................................................. 7-1 Lead Agency—City of Mountain View ............................................................................ 7-1 Consultant Team............................................................................................................. 7-1 List of Figures
Figure 3-1 Regional and Local Vicinity Map ................................................................... 3-3 Figure 3-2 Aerial Photograph......................................................................................... 3-4 Figure 3-3 Proposed Site Plan........................................................................................ 3-7 Figure 3-4 First Floor Plan.............................................................................................. 3-8 Figure 3-5 Second Floor Plan ......................................................................................... 3-9 Figure 3-6 Third Floor Plan .......................................................................................... 3-10 List of Tables
Table 4.1-1 Criteria Air Pollutant Health Effects Summary ...........................................4.1-2 Table 4.1-2 Attainment Status of Criteria Air Pollutants in the San Francisco Bay Area Air Basin ..........................................................................................4.1-14 Table 4.1-3 Ambient Air Quality Monitoring Summary ..............................................4.1-15 Table 4.1-4 Construction-Related Criteria Air Pollutant Emissions Estimates.............4.1-19 Table 4.1-5 Operational Criteria Air Pollutant Emissions Estimates............................4.1-21 Table 4.1-6 Construction Health Risk Assessment Results – Unmitigated ..................4.1-22 Table 4.1-7 Construction Health Risk Assessment Results – Mitigated ......................4.1-24 Table 4.3-1 Mountain View 2030 General Plan Policies Relevant to Cultural Resources and the Proposed Project .........................................................4.3-4 Table 4.5-1 Construction-Related GHG Emissions......................................................4.5-16 Table 4.5-2 Consistency Analysis with the Air District’s GHG Best Management Practices ..................................................................................................4.5-16

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Table 4.5-3 Consistency Analysis with the Municipal Operations Climate Action Plan..........................................................................................................4.5-19 Table 4.6-1 Mountain View 2030 General Plan Policies Relevant to Hazardous Materials and the Proposed Project ..........................................................4.6-5 Table 4.7-1 Typical Noise Levels...................................................................................4.7-4 Table 4.7-2 Human Reaction to Typical Vibration Levels..............................................4.7-5 Table 4.7-5 Project-Related Construction Noise.........................................................4.7-12 Table 4.7-6 Construction Equipment Vibration Levels for Architectural Damage.......4.7-16 Table 5-1 Comparison of Project Alternative Impacts................................................ 5-12 Table 5-2 Ability to Meet Proposed Project Objectives.............................................. 5-13 Appendices
Appendix A: Notice of Preparation, Initial Study, and Scoping Comments Appendix B: Air Quality and Greenhouse Gas Emissions Data Appendix C: Historic Resources Evaluation
Appendix D: Phase I Environmental Site Assessment
Appendix E: Noise Data

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1. Executive Summary

1.1 INTRODUCTION
This Draft Environmental Impact Report (EIR) addresses the environmental effects associated with the implementation of the proposed Mountain View Public Safety Building (proposed project). The California Environmental Quality Act (CEQA) requires that local government agencies consider the environmental consequences before taking action on projects over which they have discretionary approval authority. An environmental impact report (EIR) analyzes potential environmental consequences in order to inform the public and support informed decisions by local and state governmental agency decision makers. This document focuses on impacts determined to be potentially significant in the Initial Study completed for this project (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments).

This Draft EIR has been prepared pursuant to the requirements of CEQA. The City of Mountain View, as the lead agency, has reviewed and revised all submitted drafts, technical studies, and reports as necessary to reflect its own independent judgment, including reliance on City technical personnel from other departments and review of all technical subconsultant reports.

Data for this Draft EIR derive from on-site field observations, discussions with affected agencies, analysis of adopted plans and policies, review of available studies, reports, data and similar literature, and specialized environmental assessments (air quality, biological resources, cultural resources, geological resources, greenhouse gas emissions, hazards and hazardous materials, noise, transportation, and tribal cultural resources).

1.2 ENVIRONMENTAL PROCEDURES
This Draft EIR has been prepared pursuant to CEQA to assess the environmental effects associated with implementation of the proposed project, as well as anticipated future discretionary actions and approvals. CEQA established six main objectives for an EIR:

1. Disclose to decision makers and the public the significant environmental effects of proposed activities.

2. Identify ways to avoid or reduce environmental damage.

3. Prevent environmental damage by requiring implementation of feasible alternatives or mitigation measures.

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4. Disclose to the public reasons for agency approval of projects with significant environmental effects.

5. Foster interagency coordination in the review of projects.

6. Enhance public participation in the planning process.

An EIR is the most comprehensive form of environmental documentation in CEQA and the CEQA Guidelines; it is intended to provide an objective, factually supported analysis and full disclosure of the environmental consequences of a proposed project with the potential to result in significant, adverse environmental impacts.

An EIR is one of various decision-making tools used by a lead agency to consider the merits and disadvantages of a project that is subject to its discretionary authority. Before approving a proposed project, the lead agency must consider the information in the EIR; determine whether the EIR was prepared in accordance with CEQA and the CEQA Guidelines; determine that it reflects the independent judgment of the lead agency; adopt findings concerning the project’s significant environmental impacts and alternatives; and adopt a statement of overriding considerations if significant impacts cannot be avoided.

1.2.1 Draft EIR Organization
Chapter 1: Executive Summary. Summarizes the background and description of the proposed project, the format of this EIR, project alternatives, any critical issues remaining to be resolved, and the potential environmental impacts and mitigation measures identified for the project.

Chapter 2: Introduction. Describes the purpose of this EIR, background on the project, the notice of preparation, the use of incorporation by reference, and Final EIR certification.

Chapter 3: Project Description. A detailed description of the project, including its objectives, its area and location, approvals anticipated to be required as part of the project, necessary environmental clearances, and the intended uses of this EIR.

Chapter 4: Environmental Analysis. Each environmental topic is analyzed in a separate section that discusses: the applicable regulatory framework; existing conditions; the significance criteria used to determine if a significant impact would occur; the methodology to identify and evaluate the potential impacts of the project; the potential adverse and beneficial effects of the project; the level of impact significance with and without mitigation; and the potential cumulative impacts of the proposed project and other existing, approved, and proposed projects in the area.

Chapter 5: Alternatives to the Proposed Project. Describes the alternatives and compares their impacts to the impacts of the proposed project. Alternatives include the No Project Alternative

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and the Historic Preservation Alternative. The environmentally superior alternative would be the Historic Preservation Alternative.

Chapter 6: Other CEQA Considerations. Provides a discussion of effects found not to be significant, significant and unavoidable impacts, significant irreversible changes to the environment, and growth-inducing effects.

Chapter 7: Report Preparers. Includes a list of people that prepared or were contacted during the preparation of this Draft EIR.

Appendices: The appendices for this document consist of these supporting documents:
 Appendix A: Notice of Preparation, Initial Study, and Scoping Comments  Appendix B: Air Quality and Greenhouse Gas Emissions Data  Appendix C: Historic Resources Evaluation
 Appendix D: Phase I Environmental Site Assessment
 Appendix E: Noise Data

1.2.2 Type and Purpose of This Draft EIR
This Draft EIR has been prepared as a “Project EIR,” defined by Section 15161 of the CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3). This type of EIR examines the environmental impacts of a specific development project and should focus primarily on the changes in the environment that would result from the development project.

The EIR shall examine all phases of the project including planning, construction, and operation.

1.3 PROJECT LOCATION
The project site is at 1000 Villa Street in the City of Mountain View in Santa Clara County. To the north of Mountain View is San Francisco Bay, to the east is Sunnyvale, to the south is Cupertino, and to the west is Palo Alto and Los Altos. Mountain View is approximately 40 miles southeast of San Francisco and approximately 14 miles west of San José.

The project site is bound by Central Expressway and the Caltrain Railroad to the north, Franklin Street to the east, Villa Street to the south, and South Shoreline Boulevard to the west. The site is assigned Assessor’s Parcel Number 158-15-027. Regional access to the project site is from State Route (SR) 82, SR 85, and US 101.

1.4 PROJECT SUMMARY
The City intends to develop the project site in two phases. The proposed project would replace the existing building and associated parking lot. The proposed project includes a new Public

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Safety Building, parking garage, shooting range, surface parking, and K-9 training area. In the eastern corner of the project site, 0.6-acre would remain undeveloped for future potential use by the City. The City of Mountain View is the lead agency for the proposed project.

1.5 SUMMARY OF PROJECT ALTERNATIVES
This Draft EIR analyzes alternatives to the proposed project that are designed to reduce the significant environmental impacts of the proposed project and feasibly attain most of the proposed project objectives. There is no set methodology for comparing the alternatives or determining the environmentally superior alternative under CEQA. Identification of the environmentally superior alternative involves weighing and balancing all of the environmental resource areas by the City. The following alternatives to the proposed project were considered and analyzed in detail:
 Alternative A: No Project Alternative. Consistent with Section 15126.6(e)(2) of the CEQA Guidelines, the No Project Alternative presents the No Project scenario. Accordingly, under this alternative, the proposed project would not be approved. No development activities would occur on the project site, which would remain in its existing condition.  Alternative B: Historic Preservation Alternative. Under the Historic Preservation Alternative, the existing, 44,914-square-foot Mountain View Police Services - Fire Administration building would not be demolished and the proposed project would occur within the existing building. This alternative assumes that the existing parking garage would be reconfigured and/or expanded to accommodate the increased parking supply included in the proposed project, but no personnel or facility changes would occur within the existing building.

Chapter 5, Alternatives, of this Draft EIR, includes a complete discussion of these alternatives.

As discussed in Chapter 5, the Historic Preservation Alternative is the Environmentally Superior Alternative pursuant to CEQA Guidelines Section 15126.6.

1.6 ISSUES TO BE RESOLVED
Section 15123(b)(3) of the CEQA Guidelines requires that an EIR contain issues to be resolved, including the choice among alternatives and whether or how to mitigate significant impacts.

With regard to the proposed project, the major issues to be resolved include decisions by the lead agency as to:

1. Whether this Draft EIR adequately describes the environmental impacts of the project.

2. Whether the benefits of the project override those environmental impacts which cannot be feasibly avoided or mitigated to a level of insignificance.

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3. Whether there are other mitigation measures that should be applied to the project besides the Mitigation Measures identified in the Draft EIR.

4. Whether there are any alternatives to the project that would substantially lessen any of the significant impacts of the proposed project and achieve most of the basic project objectives.

1.7 AREAS OF CONTROVERSY
In accordance with Section 15123(b)(2) of the CEQA Guidelines, the EIR summary must identify areas of controversy known to the lead agency, including issues raised by agencies and the public. Prior to preparation of the Draft EIR, the City of Mountain View issued a Notice of Preparation (NOP) on December 10, 2024. The CEQA-mandated scoping period for this EIR was between December 10, 2024 and January 15, 2025, during which interested agencies and the public could submit comments about the potential environmental impacts of the proposed project. During this time, the City received one comment letter, from the Native American Heritage Commission. This comment letter described regulatory information regarding the tribal consultation process and provided recommendations for cultural resources assessments.

Appendix A, Notice of Preparation, Initial Study, and Scoping Comments, of this Draft EIR contains the NOP as well as the comment letter received by the City in response to the NOP.

1.8 SUMMARY OF SIGNIFICANT ENVIRONMENTAL IMPACTS
Table 1-1, Summary of Significant Environmental Impacts and Mitigation Measures, presents significant impacts and mitigation measures, including the impact’s level of significance with the imposition of mitigation measures. For a complete description of potential impacts, including those where no mitigation measures are required, please refer to the specific discussions in Sections 4.1 through 4.8.

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LTS = Less than Significant; S = Significant; SU = Significant and Unavoidable

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation

4.1 AIR QUALITY
Impact AIR-1: Without mitigation,
construction activities for the
proposed project could generate
fugitive dust that exceeds State
standards.

S Mitigation Measure AIR-1: The project contractor shall comply with the Bay Area Air District’s basic best management practices for reducing construction-related emissions of uncontrolled fugitive dust (coarse inhalable particulate matter [PM10] and fine inhalable particulate matter [PM2.5]):
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt trackout onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.
 All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics LTS

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation
control measures Title 13, Section 2485, of the California Code of Regulations). Clear signage shall be provided for construction workers at all access points.
 All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and
determined to be running in proper condition prior to
operation.
 All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
 All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12- inch layer of compacted layer of wood chips, mulch, or
gravel.
 Publicly visible signs shall be posted with the telephone number and name of the person to contact at the City
regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations.

These measures shall be noted on grading plans prepared by the

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation
applicant submitted to the City of Mountain View Building Division. The construction contractor shall implement these measures during ground disturbing activities. The City shall verify compliance that these measures have been implemented during normal construction site inspections.

Impact AIR-2: Construction
activities for the proposed project
could generate cancer risks above
acceptable levels for the
maximally exposed residential
receptor.

S Mitigation Measure AIR-2: The City of Mountain View shall specify in the construction bid that the project construction contractor(s) and subcontractor(s) comply with the following requirements for all off-road equipment used over the entire duration of the construction activities at the site:
 Use engines that meet either US EPA or California Air Resources Board (CARB) Tier 4 Final emission standards for engines that are greater than 25 horsepower. Ensure that all construction plans submitted to the City of Mountain View Building Division clearly show the selected emission
reduction strategy for construction equipment over 25
horsepower.
 If Tier 4 Final equipment is not available for use for the project for a specific piece of off-road construction
equipment, documentation shall be provided to the City of Mountain View demonstrating that such equipment is not
available for the project. If Tier 4 Final equipment is not available, the construction contractor(s) and
subcontractor(s) affected shall use Tier 4 Interim equipment LTS

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation
instead. If Tier 4 Interim equipment is not available for use for the project for a specific piece of off-road construction equipment, documentation shall be provided to the City
demonstrating that such equipment is not available for the project. If Tier 4 Interim equipment is not available, the construction contractor(s) and subcontractor(s) affected shall use Tier 3 equipment outfitted with a level 3 diesel particulate filter instead.
 Prohibit the use of generators except for electric
alternatives. The City shall ensure that all construction plans submitted to the City of Mountain View Building Division clearly show the requirement to use power storage
equipment or electric generators in lieu of fossil fuel powered generators.
 Maintain a list of all operating equipment in use on the project site for verification by the City or their designee. The construction equipment list shall state the makes, models, fuel type, and number of construction equipment on-site. All equipment shall be properly serviced and maintained in
accordance with the manufacturer’s recommendations.
 Communicate with all sub-contractors in contracts and construction documents that all non-essential idling of construction equipment is restricted to 5 minutes or less in compliance with California Air Resources Board Rule 2449 and is responsible for ensuring that this requirement is met.

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation

4.2 BIOLOGICAL RESOURCES
Impact BIO-1: Tree removal and
demolition activities during site
clearance could destroy active
nests, and/or otherwise interfere
with nesting of birds protected
under federal and State law.

S Mitigation Measure BIO-1: Nests of raptors and other birds shall be protected when in active use, as required by the federal Migratory Bird Treaty Act and the California Fish and Game Code.

The construction contractor shall indicate the following on all construction plans, if construction activities and any required tree removal occur during the breeding season (February 1 and August 31). Preconstruction surveys shall:
 Be conducted by a qualified biologist prior to tree removal or grading, demolition, or construction activities. Note that preconstruction surveys are not required for tree removal or construction, grading, or demolition activities outside the nesting period.
 Be conducted no more than 14 days prior to the start of tree removal or construction.
 Be repeated at 14-day intervals until construction has been initiated in the area after which surveys can be stopped.  Document locations of active nests containing viable eggs or young birds.

LTS

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation
 Establishment of clearly delineated exclusion zones (i.e., demarcated by identifiable fencing, such as orange
construction fencing or equivalent) around each nest
location as determined by the qualified biologist, taking into account the species of birds nesting, their tolerance for disturbance and proximity to existing development. In
general, exclusion zones shall be a minimum of 300 feet for raptors and 75 feet for passerines and other birds.
 Monitoring active nests within an exclusion zone on a weekly basis throughout the nesting season to identify signs of disturbance and confirm nesting status.
 An increase in the radius of an exclusion zone by the qualified biologist if project activities are determined to be adversely affecting the nesting birds. Exclusion zones may be reduced by the qualified biologist only in consultation with California Department of Fish and Wildlife.
 The protection measures shall remain in effect until the young have left the nest and are foraging independently or the nest is no longer active.

Impact BIO-2: The proposed
development would result in
removal of trees protected under
City’s Municipal Code.

S Mitigation Measure BIO-2: The proposed project shall comply with the City of Mountain View’s Municipal Code requirements for the provision of the removal of heritage trees in Chapter 32, Trees, Shrubs and Plants, Article II, Protection of The Urban Forest. A tree removal permit shall be obtained for the removal of LTS

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Table 1-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Impact
Level of
Significance
without Mitigation Mitigation Measures
Level of
Significance
with Mitigation
any “heritage” tree, and replacement plantings shall be provided as approved by the City. If permitted, any replacement trees be placed off-site or an appropriate in-lieu tree replacement fee may be paid to the City of Mountain View as compensation for “heritage” trees removed by the proposed project, where sufficient land area is not available on-site for adequate replacement and when approved by the City.

In addition, a Tree Protection and Replacement Program
(Program) shall be developed by a Certified Arborist prior to project approval and implemented during project construction to provide for adequate protection and replacement of “heritage” trees, as defined by the City’s Municipal Code. The Program shall include, but is not limited to, the following provisions:
 Adequate measures shall be defined to protect all trees to be preserved. These measures should include the establishment of a tree protection zone (TPZ) around each tree to be
preserved, in which no disturbance is permitted. For design purposes, the TPZ shall be located at the dripline of the tree or 10 feet, whichever is greater. If necessary, the TPZ for construction-tolerant species (i.e., coast live oaks) may be reduced to 7 feet.
 Temporary construction fencing shall be installed at the perimeter of TPZs prior to demolition, grubbing, or grading.

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Fences shall be 6-foot chain link or equivalent, as approved by the City of Mountain View. Fences shall remain until all construction is completed. Fences shall not be relocated or removed without permission from the consulting arborist.  No grading, excavation, or storage of materials shall be permitted within TPZs. Construction trailers, traffic, and storage areas shall remain outside fenced areas at all times.

No excess soil, chemicals, debris, equipment, or other
materials shall be dumped or stored within the TPZ.
 Underground services including utilities, sub-drains, water or sewer shall be routed around the TPZ. Where encroachment cannot be avoided, special construction techniques such as hand digging or tunneling under roots shall be employed where necessary to minimize root injury. Irrigation systems must be designed so that no trenching will occur within the TPZ.
 Construction activities associated with structures and underground features to be removed within the TPZ shall use the smallest equipment and operate from outside the TPZ. The consulting arborist shall be on-site during all operations within the TPZ to monitor demolition activity.  All grading, improvement plans, and construction plans shall clearly indicate trees proposed to be removed, altered, or otherwise affected by development construction. The tree

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information on grading and development plans should
indicate the number, size, species, assigned tree number, and location of the dripline of all trees that are to be
retained/preserved. All plans shall also include tree
preservation guidelines prepared by the consulting arborist.  The demolition contractor shall meet with the consulting arborist before beginning work to discuss work procedures and tree protection. Prior to beginning work, the
contractor(s) working in the vicinity of trees to be preserved shall be required to meet with the consulting arborist at the site to review all work procedures, access routes, storage areas, and tree protection measures.
 All contractors shall conduct operations in a manner that will prevent damage to trees to be preserved. Any grading,
construction, demolition or other work that is expected to encounter tree roots shall be monitored by the consulting arborist. If injury should occur to any tree during
construction, it should be evaluated as soon as possible by the consulting arborist so that appropriate treatments can be applied.
 Any plan changes affecting trees shall be reviewed by the consulting arborist with regard to tree impacts. These
include, but are not limited to, site improvement plans, utility and drainage plans, grading plans, landscape and

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irrigation plans, and demolition plans.
 Trees to be preserved may require pruning to provide
construction clearance. All pruning shall be completed by a State of California Licensed Tree Contractor (C61/D49). All pruning shall be done by Certified Arborist or Certified Tree Worker in accordance with the current Best Management
Practices for Pruning published by the International Society of Arboriculture, and adhere to the current editions of the American National Standard for Tree Care Operations
(Section Z133.1) and Pruning (Section A300).
 Any root pruning required for construction purposes shall receive the prior approval of and be supervised by the
consulting arborist.
 Any demolition or excavation, such as grading, pad
preparation, excavation, and trenching, within the dripline or other work that is expected to encounter tree roots should be approved and monitored by the consulting arborist. Any root pruning required for construction purposes shall receive prior approval of, and by supervised by, the consulting arborist. Roots shall be cut by manually digging a trench and cutting exposed roots with a sharp saw.
 Tree(s) to be removed that have branches extending into the canopy of tree(s) to remain must be removed by a qualified arborist and not by construction contractors. The qualified

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arborist shall remove the tree in a manner that causes no damage to the tree(s) and understory to remain. Tree stumps shall be ground 12 inches below ground surface.
 All tree work shall comply with the Migratory Bird Treaty Act as well as California Fish and Game Code Sections 3503
through 3513 to not disturb nesting birds. To the extent feasible, tree pruning, and removal shall be scheduled
outside of the breeding season. Breeding bird surveys shall be conducted prior to tree work. Qualified biologists shall be involved in establishing work buffers for active nests. (See Mitigation Measure BIO-1.)
 The vertical and horizontal locations of all the trees identified for preservation shall be established and plotted on all plans. These plans shall be forwards to the consulting arborist for review and comment.
 Foundations, footings, and pavements on expansive soils near trees shall be designed to withstand differential
displacement to protect the soil surrounding the tree roots.  Any liming within 50 feet of any tree shall be prohibited, as lime is toxic to tree roots. Any herbicides placed under paving materials shall be safe for use under trees and labeled for that use.
 Brush from pruning and trees removal operations shall be chipped and spread beneath the trees within the TPZ. Mulch

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shall be between 2 inches and 4 inches in depth and kept at a minimum of 3 feet from the base of the trees.
 All recommendations for tree preservation made by the applicant’s consulting arborist shall be followed.

4.3 CULTURAL AND TRIBAL CULTURAL RESOURCES
Impact CUL-1: The proposed
project would remove the
historical resource on the project
site that is eligible for listing in the
California Register under Criterion
3 as a significant example of the
work of master architect Goodwin
Steinberg.

S Mitigation Measure CUL-1.1: The City shall have Historic American Building Survey Level II documentation completed for the Mountain View Police Services - Fire Administration building and its setting. To ensure public access, the City shall submit copies of the documentation to Mountain View Historical Association’s History Center and the California Historical Resources Information System Northwest Information Center.

This documentation shall include drawings, photographs, and a historical narrative:
 Drawings: Existing historic drawings of the historical resource shall be photographed with large-format negatives or photographically reproduced on Mylar. In the absence of existing drawings, full-measured drawings of the building’s plan and exterior elevations shall be prepared prior to demolition.
 Photographs: Photo-documentation of the historical
resource shall be prepared to Historic American Building Survey standards for archival photography, prior to
demolition. Historic American Building Survey standards SU

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require large-format black-and-white photography, with the original negatives having a minimum size of four inches by five inches. Digital photography, roll film, film packs, and electronic manipulation of images are not acceptable. All film prints, a minimum of four inches by five inches, must be hand-processed according to the manufacturer’s
specifications and printed on fiber-base, single-weight paper and dried to a full gloss finish. A minimum of 12 photographs shall be taken, detailing the site, building exterior, building interior, and character-defining features. Photographs must be identified and labeled using Historic American Building Survey standards.
 Historical Overview: A professional meeting the Secretary of the Interior’s Professional Qualification Standards in
Architectural History or History shall assemble historical background information relevant to the historical resource.

The City of Mountain View shall verify compliance with this mitigation measure prior to the initiation of any site or building demolition or construction activities.

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Public Safety Building. The display shall be developed with the assistance of one or more professionals experienced in creating such historical exhibits or displays.

Impact CUL-2: Construction
activities for the proposed project
have the potential to cause a
substantial adverse change in the
significance of an archaeological
resource pursuant to California
Environmental Quality Act (CEQA)
Guidelines Section 15064.5.

S Mitigation Measure CUL-2: Project supervisors, contractors, and equipment operators shall participate in an Archaeological Resource Awareness Training, conducted by a Secretary of Interior-qualified archaeologist, to become familiar with the type of artifacts and features that could be encountered during project-related ground disturbing activities, as well as the procedures to follow if archaeological resources are unearthed during construction. If indigenous, prehistoric or historic-period cultural materials are unearthed during ground-disturbing activities, all work within 100 feet of the find shall halt until a qualified archaeologist and Native American representative can assess the significance of the find. The City and a qualified archaeologist, defined as one meeting the U.S. Secretary of the Interior’s Professional Qualifications Standards for Archaeology, and a Native American representative shall be immediately informed of the discovery. Prehistoric and indigenous materials might include obsidian and chert-flaked stone tools (e.g., projectile points, knives, scrapers) or tool-making debris; culturally darkened soil [“midden”] containing heat-affected rocks and artifacts; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered-stone tools, such as hammerstones and pitted stones. Historic-period materials might LTS

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include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If the find is determined to be potentially significant, the archaeologist, in consultation with the Native American representative, shall develop a treatment plan that could include site avoidance, capping, or data recovery. If avoidance is not feasible, project impacts shall be mitigated in accordance with the recommendations of the archeologist, in coordination with the City, Native American representative, and pursuant to CEQA Guidelines Section 15126.4 (b)(3)(C), which requires
implementation of a data recovery plan. Once the recovery plan has been reviewed and approved by the City, implemented, and any appropriate resource recovery completed, project
construction activity within the area of the find may resume.

Impact CUL-3: Construction
activities for the proposed project
have the potential to result in
unanticipated discovery of human
remains interred outside of
dedicated cemeteries.

S Mitigation Measure CUL-3: In the event of the discovery of human remains during demolition, excavation, or construction, there shall be no further excavation or disturbance of the site within a 50-foot radius of the location of such discovery, or any nearby area reasonably suspected to overlie adjacent remains, and the area shall be secured to prevent further disturbance. The City and the Santa Clara County Coroner shall be notified and shall make a determination as to whether the remains are Native American. If the Coroner determines that the remains are not subject to their authority, the Coroner shall notify the Native LTS

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with Mitigation
American Heritage Commission within 24 hours, which shall attempt to identify descendants of the deceased Native
American. If no satisfactory agreement can be reached as to the disposition of the remains pursuant to this State law, then the landowner, in consultation with a qualified archaeologist, shall formulate an appropriate treatment plan for the find, which might include, but not be limited to, respectful scientific recording and removal, being left in place, removal and reburial on-site, or elsewhere. Associated grave goods are to be treated in the same manner. A final report shall be submitted to the City’s Community Development Director prior to release of a Certificate of Occupancy. This report shall contain a description of the mitigation programs and its results, including a description of the monitoring and testing resources analysis methodology and conclusions, and a description of the disposition/curation of the resources. The report shall verify completion of the mitigation program to the satisfaction of the City’s Community Development Director.

Impact CUL-4: Construction
activities for the proposed project
have the potential to cause a
significant impact to an unknown
tribal cultural resource as defined
in Public Resources Code 21074.

S Mitigation Measure CUL-4: Implement Mitigation Measures CUL2 and CUL-3.LTS

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with Mitigation

4.4 GEOLOGY AND SOILS
Impact GEO-1: The construction
activities, increased site
occupancy, and development of
new structures under the
proposed project could exacerbate
an existing hazard associated with
liquefaction due to seismic events.

S Mitigation Measure GEO-1: Prior to the issuance of building permits, the project sponsor shall retain the services of a certified engineering geologist and/or geotechnical engineer to prepare a site-specific geotechnical study based on the most recent draft of the conceptual site plans. The geotechnical study shall address, but is not limited to, the effects of seismically induced liquefaction, and include recommendations to ensure any potential hazards related to the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction would not occur. The geotechnical study shall be approved by the City of Mountain View's Building Inspection Department prior to the issuance of building permits.

LTS
Impact GEO-2 The construction
activities, development, and
increased site occupancy involved
in the proposed project could
exacerbate an existing hazard
associated with unstable soils due
to seismically induced
liquefaction.

S Mitigation Measure GEO-2: Implement Mitigation Measure GEO1.LTS

4.5 GREENHOUSE GAS EMISSIONS
No significant impacts

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Level of
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4.6 HAZARDS AND HAZARDOUS MATERIALS
Impact HAZ-1: The proposed
project could create a hazard to
future site occupants due to the
release of hazardous materials
originating from off-site land uses.

S Mitigation Measure HAZ-1: Prior to issuance of demolition or grading permits, shallow soil samples and groundwater samples shall be taken in the near surface soil and tested for
tetrachloroethylene to determine if contaminants from previous operations on the former Fremont Laundry or Evelyn Avenue parking lot sites are present at concentrations above established regulatory construction worker safety and commercial
environmental screening levels. The results of the soil sampling and testing must be provided to the City of Mountain View Community Development Department.

If contaminated soils or groundwater are found in concentrations above the appropriate regulatory environmental screening levels for the proposed project, the project sponsor shall obtain regulatory oversight from the Santa Clara County Department of Environmental Health, Department of Toxic Substances Control, or Regional Water Quality Control Board to mitigate the contamination found. A Site Management Plan (SMP), Removal Action Plan (RAP), or equivalent document must be prepared by a qualified hazardous materials consultant. The plan must establish remedial measures and/or soil management practices to ensure construction worker safety and the health of future workers and visitors to the project site during operation of the proposed LTS

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project. Evidence of regulatory oversight and a regulatory approved plan shall be provided to the City of Mountain View Community Development Department.

In the event that vapor encroachment is discovered, the proposed project shall develop a vapor management plan. The vapor management plan shall be prepared in consultation with applicable regulatory agencies, including the Department of Toxic Substances Control and the Regional Water Quality Control Board, and shall be reviewed and accepted by the City of Mountain View prior to the issuance of demolition and grading permits.

4.7 NOISE
Impact NOI-1: The proposed
project would generate a
substantial temporary increase in
ambient noise levels during
construction.

S Mitigation Measure NOI-1: The project sponsor shall incorporate the following practices into the construction contract
specifications to be implemented by the construction contractor during the entire construction phase of the project. The project sponsor and contractors shall prepare a Construction Noise Control Plan that includes the following measures:
 Limit construction to the hours of 8:00 a.m. to 6:00 p.m., Monday through Friday, and between 9:00 a.m. to 5:00 p.m. on weekends.
 Construct temporary noise barriers, where feasible, to screen receptors to the west, south, and east from the
LTS

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construction area. Temporary noise barrier fences would provide a 5 dBA noise reduction if the noise barrier
interrupts the line-of-sight between the noise source and receptor and if the barrier is constructed in a manner that eliminates any cracks or gaps.
 At least 21 days prior to the start of construction activities, property owners within a 500-foot radius of the project site shall be notified of the planned construction. The
notification shall include a brief description of the project, a description of the construction phases to occur, the
construction hours noted above, and the overall
construction duration. The notification shall include the telephone numbers of the City’s and contractor’s authorized representatives that are assigned to respond in the event of a noise or vibration complaint.
 At least 10 days prior to the start of construction activities, a sign shall be posted at the entrance(s) to the job site, clearly visible to the public, that includes permitted construction days and hours, as well as the telephone numbers of the City’s and contractor’s authorized representatives that are assigned to respond in the event of a noise or vibration complaint. If the authorized contractor’s representative receives a complaint, they shall investigate, take appropriate corrective action, and report the action to the City.
 Prior to the start of construction, the project sponsor shall

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retain a qualified acoustical consultant to conduct
construction noise monitoring during the major phases of project construction at select locations in the surrounding neighborhood. The number and location of monitoring
positions, and the construction phases during which
monitoring shall occur, shall be determined by City staff in consultation with the acoustical consultant. All sound level meters used during monitoring shall satisfy the American National Standards Institute (ANSI) standard of Type 1
instrumentation. All measurements shall be at least 5 feet above the ground and away from reflective surfaces. The noise monitoring data and results shall be submitted in a memorandum to the City on a weekly basis during the
construction phases requiring monitoring, along with
comparison to the 80 dBA Leq (8-hr) construction noise limit.

If exceedances of the construction noise limit are found, the applicant’s construction contractor shall modify construction techniques and equipment to reduce the construction noise below the 80 dBA Leq (8-hr) limit.
 Signs shall be posted at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. The signs shall note that all other equipment shall be turned off if not in use for more than 5 minutes. The construction manager shall be responsible for enforcing these noise

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reduction requirements.
 Construction trucks and equipment shall utilize the best available noise control techniques including improved
mufflers, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds, wherever feasible.
 The contractor shall use impact tools that are hydraulically or electrically powered wherever possible. Where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools.
 Stationary noise sources (e.g., generators and air
compressors) shall be located as far from sensitive receptors as possible, and they shall be muffled and enclosed within temporary sheds, insulation barriers, or other measures to reduce noise levels to the extent feasible.
 Stockpiling of materials shall be located as far as feasible from nearby noise-sensitive receptors.
 During the entire active construction period, the use of noise-producing signals—including horns, whistles, alarms, and bells—shall be for safety warning purposes only. The construction manager shall require the use of smart back-up alarms on equipment. (These devices automatically adjust the alarm level based on the background noise level.)

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Alternately, equipment back-up alarms may be turned off and replaced with human spotters in compliance with all safety requirements and laws.

4.8 TRANSPORTATION
No significant impacts
JULY 2025 Page 2-1

2. Introduction

2.1 PURPOSE OF THE ENVIRONMENTAL IMPACT REPORT
The California Environmental Quality Act (CEQA) requires that all state and local governmental agencies consider the environmental consequences of projects over which they have discretionary authority before taking action on those projects. This Draft Environmental Impact Report (EIR) has been prepared to satisfy CEQA and the CEQA Guidelines. The EIR is the public document designed to provide decision makers and the public with an analysis of the environmental effects of the proposed project, to indicate possible ways to reduce or avoid environmental damage and to identify alternatives to the project. The EIR must also disclose significant environmental impacts that cannot be avoided; growth inducing impacts; effects not found to be significant; and significant cumulative impacts of all past, present, and reasonably foreseeable future projects.

The lead agency means “the public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect upon the environment” (CEQA Section 21067). The City of Mountain View (City) has the principal responsibility for approval of the proposed Mountain View Public Safety Building project (proposed project). For this reason, the City is the CEQA lead agency for this project.

The intent of the Draft EIR is to provide sufficient information on the potential environmental impacts of the proposed project to allow the City to make an informed decision regarding approval of the proposed project. Specific discretionary actions to be reviewed by the City are described in Section 3.4, Intended Uses of the EIR.

This Draft EIR has been prepared in accordance with requirements of the:
 California Environmental Quality Act (CEQA) of 1970, as amended (Public Resources Code, Sections 21000 et seq.)
 State Guidelines for the Implementation of the CEQA of 1970 (CEQA Guidelines), as amended (California Code of Regulations, Sections 15000 et seq.) The overall purpose of this Draft EIR is to inform the lead agency, responsible agencies, decision makers, and the general public about the environmental effects of the development and operation of the proposed project. This Draft EIR addresses effects that may be significant and adverse; evaluates alternatives to the project; and identifies mitigation measures to reduce or avoid adverse effects.

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2.2 ENVIRONMENTAL REVIEW PROCESS

2.2.1 Notice of Preparation and Initial Study
The City determined that an EIR would be required for this project and issued a notice of preparation (NOP) and initial study on December 10, 2024 (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments, of this Draft EIR). The CEQA-mandated scoping period for this EIR was between December 10, 2024 and January 15, 2025, during which interested agencies and the public could submit comments about the potential environmental impacts of the proposed project. During this time, the City received one comment letter, from the Native American Heritage Commission, dated December 13, 2024.

The NOP process helps determine the scope of the environmental issues to be addressed in the Draft EIR. Based on this process and the initial study for the project, certain environmental categories were identified as having the potential to result in significant impacts. Issues considered potentially significant are addressed in this Draft EIR, but issues identified as less than significant or no impact are not. Refer to the initial study in Appendix A for discussion of how these initial determinations were made.

2.2.2 Draft EIR
This Draft EIR will be available for review by the public and interested parties, agencies, and organizations for a 45-day comment period starting July 1, 2025, and ending August 15, 2025.

During the comment period, the public is invited to provide written comments on the Draft EIR via mail or email to the City of Mountain View Public Works Department by 5:00 p.m. on August 15, 2025. Comments should be submitted as follows:
 Written: Naveen Govind, Senior Project Manager
City of Mountain View
500 Castro Street
Mountain View, California, 94041
 Phone: (650) 903-6527
 Email: [email protected] with “Public Safety Building EIR” as the subject line.

2.2.3 Final EIR Certification
Upon completion of the public review period for the Draft EIR, the City will review all written comments received and prepare written responses for each. A Final EIR will incorporate the received comments, responses to the comments, and any changes to the Draft EIR that result

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from comments. The Final EIR will be presented to the City for potential certification as the environmental document for the project.

2.3 SCOPE OF THIS DRAFT EIR
The scope of the Draft EIR was determined based on the City’s initial study and comments received in response to the NOP. Pursuant to Sections 15126.2 and 15126.4 of the CEQA Guidelines, the Draft EIR should identify any potentially significant adverse impacts and recommend mitigation that would reduce or eliminate these impacts to levels of insignificance.

2.3.1 Impacts Considered Less than Significant
During preparation of the initial study, the City determined that 11 environmental impact categories were not significantly affected by the proposed project. These categories are not discussed in detail in this Draft EIR.
 Aesthetics
 Agriculture and Forestry Resources
 Energy
 Hydrology and Water Quality
 Land Use and Planning
 Mineral Resources
 Population and Housing
 Public Services
 Recreation
 Utilities and Service Systems
 Wildfire

2.3.2 Potentially Significant Adverse Impacts
Through the initial study process, the City determined that further analysis was needed for some of the significance criteria for five environmental topics (air quality, biological resources, geology and soils, hazards and hazardous conditions, noise, and transportation) and all of the significance criteria for three environmental topics (cultural resources, greenhouse gas emissions, and tribal cultural resources) to determine whether the proposed project would result in potentially significant impacts. These topics and specific significance criteria are evaluated in detail in Chapter 4, Environmental Analysis, of this Draft EIR.  Air Quality
a) 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.
b) Expose sensitive receptors to substantial pollutant concentrations. c) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

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 Biological Resources
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
b) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.
 Cultural Resources
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.
c) Disturb any human remains, including those interred outside of dedicated cemeteries.  Geology and Soils
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction. b) 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.
 Greenhouse Gas Emissions
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.
 Hazards and Hazardous Materials
a) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.
 Noise
a) 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.
b) Generate excessive groundborne vibration or groundborne noise levels.  Transportation
a) Conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b).  Tribal Cultural Resources
a) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

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 i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or
 ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

2.4 INCORPORATION BY REFERENCE
Some documents are incorporated by reference into this Draft EIR, consistent with Section 15150 of the CEQA Guidelines, and they are available for review at the City of Mountain View website.
 Mountain View 2030 General Plan, City of Mountain View Community Development Department, July 2012.
 City Of Mountain View Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report, LSA Associates, September 2012.

2.5 MITIGATION MONITORING
Public Resources Code Section 21081.6 requires that agencies adopt a monitoring or reporting program for any project for which it has made findings pursuant to Public Resources Code Section 21081 or adopted a Negative Declaration pursuant to Section 21080(c). Such a program is intended to ensure the implementation of all mitigation measures adopted through the preparation of an EIR or Negative Declaration.

The Mitigation Monitoring Program for the proposed project will be completed as part of the Final EIR, prior to consideration of the project by the City of Mountain View.

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3. Project Description

3.1 INTRODUCTION
This chapter of the Draft Environmental Impact Report (EIR) describes the proposed Mountain View Public Safety Building Project (proposed project) to the public, reviewing agencies, and decision makers. Pursuant to the California Environmental Quality Act (CEQA) and the State CEQA Guidelines (State CEQA Guidelines Section 15124), an environmental impact report (EIR) should contain a description of the proposed project that includes:
 The precise location and boundaries of the proposed project;  A statement of the objectives sought by the proposed project, including the underlying purpose of the project;
 A general description of the project’s technical, economic, and environmental characteristics; and
 A statement briefly describing the intended uses of the EIR, including a list of the agencies that are expected to use the EIR in their decision making, a list of permits and other approvals required to implement the project, and a list of related environmental review and consultation requirements required by federal, state, or local laws, regulations, or policies.

An adequate project description should not supply extensive detail beyond that needed for evaluation and review of environmental impacts. Accordingly, this chapter describes the necessary details of the proposed project that are critical in assessing the direct, indirect, longterm, and temporary impacts associated with project implementation. This project description identifies key elements of the proposed project including information about the location, setting, and characteristics of the project site; the principal project features; project objectives; and required permits and approvals. The City of Mountain View (City) is the lead agency for the proposed project.

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3.2 PROJECT SITE LOCATION AND SETTING

3.2.1 Regional and Local Location
The project site is at 1000 Villa Street in the city of Mountain View in Santa Clara County. To the north of Mountain View is San Francisco Bay, to the east is Sunnyvale, to the south is the city of Cupertino, and to the west are the cities of Palo Alto and Los Altos (see Figure 3-1, Regional and Local Vicinity Map). Mountain View is approximately 40 miles southeast of the city and county of San Francisco and approximately 14 miles west of the city of San José.

As shown on Figure 3-1, the 4.3-acre project site is bounded by West Evelyn Avenue to the north, Franklin Street and Oak Street to the south, and South Shoreline Boulevard to the west.

The site is assigned Assessor’s Parcel Number 158-15-027. Regional access to the project site is from United States (US) Highway 101, State Route 82 (SR-82), and SR-85.

3.2.2 Existing Site and Surrounding Conditions
The project site is the location of the existing Mountain View Police Department. As shown on Figure 3-2, Aerial Photograph, the project site is currently occupied by the Mountain View Police Services - Fire Administration building; a 42-stall public parking lot; a 110-stall, restrictedaccess parking lot; a pump station; and a K-9 training area.

As shown on Figure 3-2, the project site is mainly surrounded by single- and multi-family residential, commercial, and institutional land uses. The project site is surrounded by one and two-story residential buildings to the north across the Caltrain railroad tracks and then Central Expressway; two four-story apartment buildings and two-story offices to the east; one- and two-story residential buildings to the south; and one- and two-story residential buildings directly west, with the Kahn Lab School located west across South Shoreline Boulevard. The Khan Lab School is approximately 0.15 miles west of the project site. The Mountain View Fire Department Station No. 1 is 0.1 miles southwest of the project site along Oak Street.

3.2.3 General Plan Land Use and Zoning
The project site has a General Plan land use designation of Parks, Schools and City Facilities with a corresponding zoning designation of Public Facility (PF). According to the Mountain View General Plan land use designation map, low density residential neighborhoods are to the north, downtown mixed use is to the east, low density residential neighborhoods are to the south, and medium-density residential and office uses are to the west.1 1 Mountain View General Plan Land Use Designation, 2020, https://mountainview.prod.govaccess.org/home/showdocument?id=2268.

PlaceWorks

MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
Figure 2
Local Vicinity
Source: PlaceWorks 2023
-

CITY OF MOUNTAIN VIEW

MOUNTAIN VIEW PUBLIC SAFETY BUILDING
Los Altos
Sunnyvale
Mountain View
0 2,000
Feet
Palo Alto
Sunnyvale
Fremont
San Jose
Cupertino
Santa
Clara
Menlo Park
Mountain
View
Los Altos
Hills
Los
Altos
Atherton East
Palo Alto
Newark
Portola
Valley
0 5
Miles
Sunnyvale
101
85 CALIFORNIA
237

CALIFORNIA
101 Permanente Creek
Villa St
Franklin St
S Shoreline Blvd
Central Expy
Castro St
Easy St
E Middlefield Rd
Miramonte Ave
El Camino Real
Springer Rd
S El Monte Ave
Rengstorff Ave
N Shoreline Blvd
California St
Cuesta Dr
Stevens Creek
SP Railroad
Grant Rd
San Francisco
Bay
Project Site
Los Altos
101
101
85 CALIFORNIA
237

CALIFORNIA
87 CALIFORNIA
280
0 5
Scale (Miles)
0 2,000
Scale (Feet)
Source: Generated using ArcMap 2023. Figure 3-1
Regional and Local Vicinity Map
0 2,000
Scale (Feet)
Note: Unincorporated county areas are
shown in white.

Project Boundary

CITY OF MOUNTAIN VIEW
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MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
Source: Generated using ArcMap 2025. Figure 3-2
Aerial Photograph
W Evelyn Ave
Villa St
Franklin St
Oak St
W Dana St
Bryant St
S Shoreline Blvd
Central Expy
Central Expy
Washington St
Residential
Commercial
Residential
Residential
Residential
Mountain View
Fire Station #1
Khan Lab School
SP Railroad
Oak St
0 80
Project Boundary Scale (Feet)

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3.3 STATEMENT OF OBJECTIVES
The objectives for the proposed project include:
 General Plan Consistency. Provide for the development of the site consistent with City’s General Plan.
 Enhance Public Safety Infrastructure. Construct a modern, state-of-the-art Public Safety Building that meets the operational needs of the Mountain View Police Department (MVPD) and other public safety personnel.
 Improve Operational Efficiency. Provide upgraded facilities, including offices, an auditorium, sleep quarters, lockers, and fitness areas, to enhance the functionality and efficiency of police and fire department operations.
 Increase Parking Capacity. Develop a three-story parking garage and reconfigure surface parking to accommodate approximately 244 parking spaces, improving access for personnel and visitors.
 Enhance Site Access and Circulation. Improve vehicular and pedestrian access with designated secured and public entry points from Oak Street and Franklin Street while maintaining connectivity to major transportation routes.  Preserve Flexibility for Future City Uses. Reserve 0.6 acres of the project site for potential future municipal development to accommodate evolving community needs.  Site Reuse. Utilize the site that currently houses the Mountain View Police Services - Fire Administration building at 1000 Villa Street due to its central location and parcel size that allows for the size and mix of facilities envisioned for the proposed project.

3.4 PROJECT CHARACTERISTICS
“Project,” as defined by the CEQA Guidelines, means:
... the whole of an action, which has a potential for resulting in either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment, and that is any of the following: (1)…enactment and amendment of zoning ordinances, and the adoption and amendment of local General Plans or elements thereof pursuant to Government Code Sections 65100–65700. (14 California Code of Regulations Section 15378[a])

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The proposed project would remove the existing Mountain View Police Services - Fire Administration building and associated parking lot and K-9 training area, and construct a new Public Safety Building, parking garage, indoor shooting range, surface parking, and K-9 training area at the same location. In the eastern corner of the project site, 0.6-acre would remain undeveloped for future potential use by the City. See Figure 3-3, Proposed Site Plan.

3.4.1 Public Safety Building
Table 3-1, Existing and Proposed Project Site Conditions, compares the existing conditions to those of the proposed project. As shown in Table 3-1, the current building, which serves as the headquarters for the police and fire departments, is 44,914 square feet, and the proposed Public Safety Building would be approximately 75,000 square feet, three stories high and a floor area ratio of 0.49. The proposed Public Safety Building would have a variety of offices and associated service rooms for police and fire activities. Some of the designated areas include an auditorium, offices, sleeping quarters, lockers, and a fitness room (see Figure 3-4, First Floor Plan; Figure 3-5, Second Floor Plan; and 3-6, Third Floor Plan). All new facilities would meet current State building standards and would be Leadership in Energy and Environmental Design (LEED) Gold certified, as required in the Mountain View Municipal Code Section 8.20.12. Once built, the proposed Public Safety Building would have an immediate personnel increase of thirteen (13) environmental health staff who would be relocated to the proposed project, for an on-site employee population of 182 employees compared to the existing on-site employee population of 169 employees. At maximum capacity, the proposed Public Safety Building could accommodate up to 242 personnel; however, this number is not the staffing level that is proposed as part of the project.

Table 3-1 Existing and Proposed Project Site Conditions Existing Conditions Proposed Project
Site Area 4.3 acres 4.3 acres
Building Size 44,914 square feet 75,000 square feet
Building Height 1 to 2 stories,
with 45-foot clock tower 3 stories
Surface Parking Spaces 42 spaces 76 spaces
Garage Parking Spaces 110 spaces 168 spaces
Total Parking Spaces 152 spaces 244 spaces
Employment 169 employees 182 employees
Source: City of Mountain View, 2025.

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MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
UP

PUMP HOUSE
TXFR
TANK
DW
VAN
VAN

3.3%
K9 TRAINING
SITE
OAK ST

VILLA ST

FRANKLIN ST

PUBLIC SAFETY

BUILDING
75,000 SF

REMAINDER
PARCEL
26,000 SF
(0.6 ACRES)
3-STORY
GARAGE
(168 SPACES)

COLD SHELL FOR
10-LANE RANGE
@ 3RD LEVEL

VISITOR PARKING
(34 SPACES)

SECURE PARKING
(42 SPACES)
Source: SVA Architects 2024. Figure 3-3
Proposed Site Plan
W Evelyn Ave
Franklin St
Oak St
Villa St
0 Scale (Feet)
100

CITY OF MOUNTAIN VIEW
Figure 3-4
First Floor Plan
Auditorium
Evidence
Field Operations
Intake
Public Safety Support
Support
2,752 SF
4,133 SF
1,890 SF
4,614 SF
2,652 SF
3,396 SF
19,437 SF
1st Floor - Net Areas
0 Scale (Feet)
30 1st Floor Gross - 24,756 SF
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MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
Source: SVA Architects 2024.

CITY OF MOUNTAIN VIEW
Field Operations
Lockers & Fitness
Field Operations
Support
5,459 SF
4,260 SF
5,321 SF
1,568 SF
16,608 SF
2nd Floor - Net Areas
2nd Floor Gross - 21,951 SF
Figure 3-5
Second Floor Plan
PlaceWorks

MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
Source: SVA Architects 2024.
0 Scale (Feet)
30 CITY OF MOUNTAIN VIEW
Figure 3-6
Third Floor Plan
3rd Floor - Net Areas
3rd Floor Gross - 22,144 SF
Support
Sleeping Quarters
Police Administration
IT
Fire Administration
EOC
Dispatch
17,074 SF
1,776 SF
5,207 SF
3,665 SF
1,677 SF
2,868 SF
1,189 SF
690 SF
PlaceWorks

MOUNTAIN VIEW PUBLIC SAFETY BUILDING DRAFT EIR
Source: SVA Architects 2024.
0 Scale (Feet)
30 CITY OF MOUNTAIN VIEW

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3.4.2 K-9 Training Area
The K-9 training area would be in the same location as the existing K-9 training area in the western portion of the project site and would be similar in size. The K-9 training area would be designed and utilized in a very similar fashion to its existing use, and no large upgrades are proposed.

3.4.3 Indoor Shooting Range
The proposed project includes a new indoor shooting range on the top level of the proposed parking garage. The shooting range would be approximately 12,215 square feet in size and would follow industry standards and regulations to address air quality effects, noise, reverberation, and echoes.

3.4.4 Site Access and Circulation
The proposed project would have two vehicular access points. One would be along Oak Street and would be secured, while the other access point would be along Franklin Street and would be open to the public.

Major arterials that can be used to access the project site are Highway 101 and the Central Expressway to the north, State Route 85 to the east, and West El Camino Real and Interstate 280 to the south. Additionally, the site can be accessed via the Caltrain railroad, which is directly north of the site with a station located 0.2 miles to the east.

3.4.5 Vehicular Parking
The proposed project includes a three-story parking garage that would include approximately 168 parking spaces. As previously described, the top level of the parking garage would contain the proposed indoor shooting range. The existing, 152-space surface parking lot would be reconfigured/relocated to other surface parking spaces for City personnel and a surface lot for future visitors to the proposed Public Safety Building. Currently, the current building site accommodates 152 parking spaces in total, including public/visitor parking and restrictedaccess employee parking areas. With the addition of the parking garage and surface parking lot reconfigurations, the proposed project would accommodate approximately 244 parking spaces, including the public/visitor parking lot. Out of the 244 total parking spaces across the site, 210 parking spaces would have restricted access and 34 spaces would be open to the public. Of the total parking spaces, 168 would be garage parking and the remaining 76 parking spaces would be dedicated to surface parking. All parking will meet the California Green Building Standards Code (24 CCR, Part 11, known as “CALGreen”) Tier 2 parking standards for electric vehicles.

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3.4.6 Landscape
The proposed project would include improved landscaping around the project site. Site improvements would include ornamental landscaping and benches, an outdoor event space, shade structures, hardscape areas, and utility upgrades. Additional outdoor uses would include a public event plaza and a staff outdoor area. During development of the project site, 38 heritage trees would need to be removed; these include Coast redwood and Raywood ash trees.

3.4.7 Utilities
The proposed project would include a pump house and production well, and communications tower. The production well and pump house would be located on the northern eastern portion of the project site within the secure surface parking lot.

The project would be designed as an all-electric building and would not include any natural gas usage.

3.4.8 Project Construction
The project is preliminarily scheduled to start in late 2025 and be completed in early 2028. The project would be completed in three development phases. In the first phase, the site would be prepared and selective demolition would occur to allow for construction of the proposed Public Safety Building; in the second phase, the Public Safety Building would be constructed; in the third phase, the remainder of the existing building would be removed and the proposed parking garage and shooting range would be developed.

Construction activities would include building and asphalt demolition, trenching for utilities, site preparation and rough grading, building construction, paving, and architectural coating. No pile driving, rock blasting, crushing or excavation would occur during the construction phase.

Construction would take place from 7:00 a.m. to 4:00 p.m., Monday through Friday, as allowed by the Mountain View Municipal Code Section 8.70, Construction Noise. The active construction and staging areas would be on the project site.

3.5 INTENDED USES OF THE EIR
It is the intent of this Draft EIR to evaluate the environmental impacts of the proposed project, thereby enabling the City of Mountain View, other responsible agencies, and interested parties to make informed decisions with respect to the requested entitlements. This Draft EIR is a project-level Draft EIR that examines the environmental impacts of the proposed project. This Draft EIR also addresses various actions by the City and others to adopt and implement the proposed project.

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The Draft EIR is intended to disclose to the public, agencies, and decision makers the proposed project’s details, analyses of the proposed project’s potential environment impacts, and identification of feasible mitigation or alternatives that would lessen or reduce significant environmental impacts.

This Draft EIR will serve as the primary environmental document for all actions associated with the Mountain View Public Safety Building, including any discretionary approvals requested or required to implement the proposed project. The City of Mountain View is the lead agency under CEQA and has the principal approval authority over the proposed project.

In order to implement the proposed project, the City of Mountain View would issue the following permits and approvals:
 Certification of this EIR
 Permits required to implement the proposed project, including, but not limited to:
 Demolition permit
 Tree removal permit
 Grading permit
 Utility permits
 Building permits
 Other agreements or actions of the City in furtherance of the proposed project To approve the proposed project, the City of Mountain View City Council must first certify the Final EIR. The City Council will consider the information in the EIR when making its decision to approve or deny the proposed project, or in directing modifications to the proposed project in response to the EIR’s findings and mitigation measures.

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4. Environmental Analysis
Chapter 4 examines the environmental setting of the proposed project, analyzes its effects and the significance of its impacts, and recommends mitigation measures to reduce or avoid impacts. This chapter has a separate section for each environmental issue area that was determined to need further study in the EIR. This scope was determined in the initial study and notice of preparation (NOP), which were published December 2024 (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments), and through public and agency comments received during the NOP comment period from December 10, 2024 to January 15, 2025.

Environmental topics and their corresponding sections and abbreviations are:
 4.1 Air Quality (AIR)
 4.2 Biological Resources (BIO)
 4.3 Cultural and Tribal Cultural Resources (CUL)
 4.4 Geology and Soils (GEO)
 4.5 Greenhouse Gas Emissions (GHG)
 4.6 Hazards and Hazardous Materials (HAZ)
 4.7 Noise (NOI)
 4.8 Transportation (TRA)
Sections 4.1 through 4.8 provide a detailed discussion of the environmental setting, impacts associated with the proposed project, and mitigation measures designed to reduce significant impacts where required and when feasible. The residual impacts following the implementation of any mitigation measure are also discussed.

The initial study also determined that certain issues under an environmental topic would not be significantly affected by implementation of the project; these issues are not discussed further in this EIR.

ORGANIZATION OF ENVIRONMENTAL ANALYSIS
To assist the reader with comparing information between environmental issues, each section is organized under these major headings:
 Regulatory Background offers an overview of applicable laws, regulations, plans, and policies relevant to each environmental topic.

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 Existing Conditions offers a description of the existing environmental conditions, providing a baseline against which the impacts of the proposed project can be compared.  Significance Criteria refer to the quantitative or qualitative standards, performance levels, thresholds, or criteria used to evaluate whether an impact is significant. These standards are based primarily on the CEQA Guidelines unless otherwise noted.  Project Impact Analysis provides a detailed discussion of the potential direct and indirect impacts of the proposed project. Mitigation measures are included as necessary.  Cumulative Impact Analysis provides an overview of the geographic setting and cumulative projects considered in the cumulative impact assessment. Significant cumulative impacts are identified and mitigation measures are included as necessary.

LEVELS OF SIGNIFICANCE
The level of significance is identified for each impact in this Draft EIR. Although the criteria for determining significance are different for each topic area, the environmental analysis applies a uniform classification of the impacts based on definitions consistent with CEQA and the CEQA Guidelines:
 No impact. The project would result in no adverse effect on the environment.  Less than significant. The project would not exceed the established significance criteria.  Significant. The project would exceed the established significance criteria. For each significant impact, the EIR identifies mitigation measures to reduce, eliminate, or avoid the adverse effect. If one or more mitigation measures would reduce the impact to a less-thansignificant level successfully, this is stated in the EIR.  Significant and unavoidable. The project would exceed the established significance criteria, and no feasible mitigation measures are available to reduce the impact to a less-thansignificant level.

CUMULATIVE IMPACTS
A cumulative impact consists of an impact created as a result of the combination of the project evaluated in the EIR, together with other reasonably foreseeable projects causing related impacts. CEQA Guidelines Section 15130 requires an EIR to discuss cumulative impacts of a project when the project’s incremental effect is “cumulatively considerable.” Cumulative effects could occur when future development under the project is combined with development in the surrounding area or, in some instances, in the entire region.

Pursuant to CEQA Guidelines Section 15130(a)(3), where a cumulative impact is significant when compared to baseline conditions, the analysis must address whether the project’s

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contribution to the significant cumulative impact is “considerable.” If the contribution of the project is considerable, then the EIR must identify 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 for the project’s contribution is required.

CEQA Guidelines Section 15130[b][1] states that the information used in the analysis of cumulative impacts should come from one or two sources:

A. A list of past, present, and probable future projects producing related cumulative impacts, including, if necessary, those projects outside the control of the agency; or B. A summary of projections contained in an adopted local, regional, or statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect. Such plans may include: a general plan, regional transportation plan, or plans for the reduction of greenhouse gas emissions. A summary of projections may also be contained in an adopted or certified prior environmental document for such a plan. Such projections may be supplemented with additional information such as a regional modeling program. Any such document shall be referenced and made available to the public at a location specified by the lead agency.

The cumulative impact analyses in this EIR use method A and considers the two planning projects and 14 development projects listed in Table 4-1, Cumulative Projects List.

Table 4-1 Cumulative Projects List
Name/Location Description Status
Approximate
Distance from
Project Site
Downtown Precise Plan
Comprehensive Update
Comprehensive update to 1988 Precise
Plan
Planning Process in
Progress
0 miles
(adjacent to
project site)
Moffett Boulevard Precise
Plan New Precise Plan Planning Process in Progress 0.1 miles 333 Franklin Street Residential projects with 14 housing units Under Review 0.1 miles
701 West Evelyn Avenue
4-story commercial building with 6,500
square feet of retail space and 28,090
square feet of office space
Approved 0.2 miles
705 West Dana Street
3-story commercial building with 18,800
square feet of commercial, restaurant,
and office space with parking
Approved 0.2 miles
City Lot 12 (West Side of
Bryant Street between
5-story mixed-use development with
120 housing units and 2,300 square feet Approved 0.2 miles

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Table 4-1 Cumulative Projects List
Mercy and California
Streets)
of commercial space
231-235 Hope Street 4-story residential development with 9 housing units Under Construction 0.2 miles
747 West Dana Street
Commercial development with 7,000
square feet of office space and 1,600
square feet of retail space
Under Construction 0.2 miles
756 California Street 3-story commercial building with 6,997 square feet of retail and office space Approved 0.3 miles 400 Moffett Boulevard
6-story residential development with
175 housing units; 2,373 square feet of
commercial/retail space; 7,000 square
feet of residential amenities; and
parking
Under Review 0.4 miles
590 Castro Street
4-story office development with
105,255 square feet of office space and
parking
Approved 0.4 miles
1265 Montecito Avenue 5-story residential development with 84 housing units and parking Under Construction 0.4 miles
777 West Middlefield Road Residential development with 716 housing units Under Construction 0.5 miles
555 West Middlefield Road
Residential addition to add 323 housing
units, a new amenity/leasing building,
parking, and a public park
Approved 0.5 miles
969 Hope Street and 679
Fairmont Avenue
7-story residential project with 36
housing units and parking Under Review 0.6 miles
881 Castro Street
8-story mixed-use development with
140 housing units; 13,352 square feet of
commercial space; and below-grade
parking
Under Review 0.6 miles
Source: City of Mountain View, January 2025,
https://www.mountainview.gov/home/showpublisheddocument/10653/638735936825030000.

The cumulative discussions in Sections 4.1 through 4.8 explain the geographic scope of the area affected by each cumulative effect (e.g., immediate project vicinity, county, watershed, air basin), which depends on the environmental topic being analyzed. For example, in assessing macroscale air quality impacts, all development in the air basin contributes to regional emissions of criteria pollutants, and basinwide projections of emissions are the best tool for determining the cumulative impact. In assessing aesthetic impacts, on the other hand, only development in the local area of change would contribute to a cumulative visual effect because the area of change is only visible near that area.

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4.1 AIR QUALITY
This section of the Draft Environmental Impact Report (EIR) describes the potential impacts to air quality due to adoption and implementation of the proposed project. This section describes the regulatory framework and existing conditions, identifies criteria used to determine impact significance, provides an analysis of the potential air quality impacts, and identifies feasible mitigation measures that could minimize any potentially significant impacts. This evaluation is based on the methodology recommended by the Bay Area Air District (Air District), formally the Bay Area Air Quality Management District, for project-level analyses. Cumulative impacts related to air quality are based on the regional boundaries of the San Francisco Bay Area Air Basin (SFBAAB). Criteria air pollutant emissions modeling is included in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft Environmental Impact Report (EIR).

Terminology
The following are definitions for terms used throughout this chapter:
 AAQS. Ambient Air Quality Standards.
 CES. CalEnviroScreen. CES is a mapping tool that helps identify the California communities most affected by sources of pollution and where people are often especially vulnerable to pollution’s effects.
 Concentrations. The amount of pollutant material per volumetric unit of air. Concentrations are measured in parts per million (ppm), parts per billion (ppb), or micrograms per cubic meter (µg/m3).
 Criteria Air Pollutants. Air pollutants under the Federal Clean Air Act (carbon monoxide, nitrogen oxides, lead, sulfur oxides, ozone, and coarse and fine particulates).  DPM. Diesel particulate matter.
 Emissions. The actual quantity of pollutant, measured in pounds per day or tons per year.  Impacted Community. Unincorporated communities in Santa Clara County that are disproportionately burdened by pollution as defined by the County in the proposed General Plan using CES data.
 Overburdened Community. Defined by the Air District as an area located within a census tract identified by CES, Version 4, having an overall CES score at or above the 70th percentile, or located within 1,000 feet of any such census tract.  ppm. Parts per million.
 Sensitive receptor. Land use types that are considered more sensitive to air pollution than others due to the types of population groups or activities involved. These land uses include residential, retirement facilities, hospitals, and schools.  TAC. Toxic air contaminant.
 µg/m3. Micrograms per cubic meter.
 VMT. Vehicle miles traveled.

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AIR POLLUTANTS OF CONCERN
Criteria Air Pollutants
The pollutants emitted into the ambient air by stationary and mobile sources are categorized as primary and/or secondary pollutants. Primary air pollutants are emitted directly from sources.

Carbon monoxide (CO), volatile organic compounds (VOC), nitrogen oxides (NOX), sulfur dioxide (SO2), coarse inhalable particulate matter (PM10), fine inhalable particulate matter (PM2.5), and lead (Pb) are primary air pollutants. Of these, CO, SO2, NO2, PM10, and PM2.5 are “criteria air pollutants,” which means that AAQS have been established for them. VOC and NOX are criteria pollutant precursors that form secondary criteria air pollutants through chemical and photochemical reactions in the atmosphere. Ozone (O3) and nitrogen dioxide (NO2) are the principal secondary pollutants. Table 4.1-1, Criteria Air Pollutant Health Effects Summary, summarizes the potential health effects associated with the criteria air pollutants.

Table 4.1-1 Criteria Air Pollutant Health Effects Summary Pollutant Health Effects Examples of Sources
Carbon Monoxide
(CO)
Chest pain in heart patients
Headaches, nausea
Reduced mental alertness
Death at very high levels
Any source that burns fuel such as cars,
trucks, construction and farming equipment,
and residential heaters and stoves
Ozone (O3) Cough, chest tightness
Difficulty taking a deep breath
Worsened asthma symptoms
Lung inflammation
Atmospheric reaction of organic gases with
nitrogen oxides in sunlight
Nitrogen Dioxide
(NO2)
Increased response to allergens
Aggravation of respiratory illness
Same as carbon monoxide sources
Particulate Matter
(PM10 and PM2.5)
Hospitalizations for worsened heart
diseases
Emergency room visits for asthma
Cars and trucks (particularly diesels)
Fireplaces and woodstoves
Windblown dust from overlays, agriculture,
Sulfur Dioxide
(SO2)
Aggravation of respiratory disease (e.g.,
asthma and emphysema)
Reduced lung function
Combustion of sulfur-containing fossil fuels,
smelting of sulfur-bearing metal ores, and
industrial processes
Lead (Pb) Behavioral and learning disabilities in
children

Contaminated soil
Source: California Air Resources Board, 2018, Reduce Your Exposure to Particle Pollution, https://ww2.arb.ca.gov/resources/fact-sheets/reduce-your-exposure-particle-pollution, accessed on May 20, 2024. South Coast Air Quality Management District, 2005, Guidance Document for Addressing Air Quality, Issues in General Plans and Local Planning, https://www.aqmd.gov/docs/default-source/planning/air-qualityguidance/complete-guidance-document.pdf?sfvrsn=4, accessed on May 20, 2024.

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Toxic Air Contaminants
People exposed to TACs at sufficient concentrations and durations may have an increased chance of getting cancer or experiencing other serious health effects. These health effects can include damage to the immune system as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems.1 By the last update to the TAC list in December 1999, CARB had designated 244 compounds as TACs.2 Additionally, CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. There are no air quality standards for TACs. Instead, TAC impacts are evaluated by calculating the health risks associated with a given exposure. The majority of the estimated health risks from TACs can be attributed to relatively few compounds, the most relevant to the proposed project being particulate matter from diesel-fueled engines.

Diesel Particulate Matter
In 1998, CARB identified DPM as a TAC. Almost all diesel exhaust particles are 10 microns or less in diameter. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs. Long-term (chronic) inhalation of DPM is likely a lung cancer risk. Short-term (i.e., acute) exposure can cause irritation and inflammatory symptoms and may exacerbate existing allergies and asthma symptoms.3 Placement of New Sensitive Receptors
Because placement of sensitive land uses falls outside CARB’s jurisdiction, CARB developed and approved the Air Quality and Land Use Handbook: A Community Health Perspective (2005) to address the siting of sensitive land uses in the vicinity of freeways, distribution centers, rail yards, ports, refineries, chrome-plating facilities, dry cleaners, and gasoline-dispensing facilities.

This guidance document was developed to assess compatibility and associated health risks when placing sensitive receptors near existing pollution sources.

In 2017, CARB provided a supplemental technical advisory to the handbook for near-roadway air pollution exposure, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways.

Strategies include practices and technologies that reduce traffic emissions, increase dispersion of traffic pollution (or the dilution of pollution in the air), or remove pollution from the air.4 1 US Environmental Protection Agency, 2024, Health and Environmental Effects of Hazardous Air Pollutants. https://www.epa.gov/haps/health-and-environmental-effects-hazardous-air-pollutants, accessed on May 20, 2024. 2 California Air Resources Board, 1999, Final Staff Report: Update to the Toxic Air Contaminant List, https://ww2.arb.ca.gov/sites/default/files/classic/toxics/tac/update98/update98.htm, accessed on May 20, 2024. 3 US Environmental Protection Agency, May 2002, Health Assessment Document for Diesel Engine Exhaust, prepared by the National Center for Environmental Assessment, Washington, DC, for the Office of Transportation and Air Quality, EPA/600/8- 90/057F, https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=29060, accessed on May 20, 2024. 4 California Air Resources Board, April 2017, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways, https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf, accessed on May 20, 2024.

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4.1.1 Regulatory Background
AAQS have been adopted at the State and federal levels for criteria air pollutants. In addition, both the State and federal government regulate the release of TACs. Land uses in the City of Mountain View are subject to the rules and regulations imposed by the Air District, the California AAQS adopted by CARB, and National AAQS adopted by the US Environmental Protection Agency (EPA). Federal, State, regional, and local laws, regulations, plans, or guidelines that are potentially applicable to the proposed project are summarized in this section.

FEDERAL AND STATE
Ambient Air Quality Standards
The Clean Air Act (CAA) allows states to adopt more stringent standards or include other pollutants. The California CAA requires all areas of the state to achieve and maintain the California AAQS by the earliest practical date. The California AAQS tend to be more restrictive than the National AAQS.

The National and California AAQS are the levels of air quality considered to provide a margin of safety in the protection of the public health and welfare. They are designed to protect “sensitive receptors” most susceptible to further respiratory distress, such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed.

Both California and the federal government have established health-based AAQS for seven air pollutants. These pollutants are ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), coarse inhalable particulate matter (PM10), fine inhalable particulate matter (PM2.5), and lead (Pb). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles.
 California has also adopted a host of other regulations that reduce criteria pollutant emissions.
 AB 1493: Pavley Fuel Efficiency Standards.
 Heavy-Duty (Tractor-Trailer) Greenhouse Gas (GHG) Regulation.  California Code of Regulations (CCR) Title 20: Appliance Energy Efficiency Standards.  24 CCR, Part 6: Building and Energy Efficiency Standards.  24 CCR, Part 11: Green Building Standards Code.

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Tanner Air Toxics Act and Air Toxics Hot Spot Information and Assessment Act Public exposure to TACs is a significant environmental health issue in California. The California Health and Safety Code defines a TAC as “an air pollutant which 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” (17 CCR Section 93000). A substance that is listed as a hazardous air pollutant pursuant to Section 112(b) of the federal CAA (42 US Code Section 7412[b]) is a TAC. Under State law, the California EPA, acting through CARB, is authorized to identify a substance as a TAC if it is an air pollutant that may cause or contribute to an increase in mortality or serious illness, or may pose a present or potential hazard to human health.

California regulates TACs primarily through Assembly Bill (AB) 1807 (Tanner Air Toxics Act) and AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987). The Tanner Air Toxics Act set up a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an “airborne toxics control measure” for sources that emit that TAC. If there is a safe threshold for a substance (i.e., a point below which there is no toxic effect), the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate “toxics best available control technology” to minimize emissions.

To date, CARB has established formal control measures for 11 TACs that are identified as having no safe threshold.

Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High-priority facilities are required to perform a health risk assessment, and if specific thresholds are exceeded, are required to communicate the results to the public through notices and public meetings.

CARB has promulgated the following specific rules to limit TAC emissions:
 13 CCR Chapter 10 Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling. Generally restricts on-road diesel-powered commercial motor vehicles with a gross vehicle weight rating of greater than 10,000 pounds from idling more than five minutes.
 13 CCR Chapter 10 Section 2480: Airborne Toxic Control Measure to Limit School Bus Idling and Idling at Schools. Generally restricts a school bus or transit bus from idling for more than five minutes when within 100 feet of a school.
 13 CCR Section 2477 and Article 8: Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities Where TRUs Operate. Regulations established to control emissions associated with diesel-powered TRUs.

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REGIONAL
Bay Area Air District
The Air District is the agency responsible for ensuring that the National and California AAQS are attained and maintained in the SFBAAB. Air quality conditions in the SFBAAB have improved significantly since the Air District was created in 1955. The Air District prepares air quality management plans (AQMP) to attain AAQS in the SFBAAB. The Air District prepares ozone attainment plans for the National O3 standard and clean air plans for the California O3 standard.

The Air District prepares these AQMPs in coordination with Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) to ensure consistent assumptions about regional growth.

Bay Area Air District 2017 Clean Air Plan
The Air District adopted the 2017 “Clean Air Plan: Spare the Air, Cool the Climate” (2017 Clean Air Plan) on April 19, 2017, making it the most recently adopted comprehensive plan. The 2017 Clean Air Plan incorporates significant new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological episodes, and new air quality modeling tools. The 2017 Clean Air Plan serves as an update to the adopted Bay Area 2010 Clean Air Plan and continues to provide the framework for SFBAAB to achieve attainment of the California and National AAQS. The 2017 Clean Air Plan updates the Bay Area’s ozone plan, which is based on the “all feasible measures” approach to meet the requirements of the California CAA. It sets a goal of reducing health risk impacts to local communities by 20 percent between 2015 and 2020 and lays the groundwork for reducing GHG emissions in the Bay Area to meet the State’s 2030 GHG reduction target and 2050 GHG reduction goal. It also includes a vision for the Bay Area in a post-carbon year 2050 that encompasses the following:
 Construct buildings that are energy efficient and powered by renewable energy.  Walk, bicycle, and use public transit for the majority of trips and use electric-powered autonomous public transit fleets.
 Incubate and produce clean energy technologies.
 Live a low-carbon lifestyle by purchasing low-carbon foods and goods in addition to recycling and putting organic waste to productive use.

A comprehensive multipollutant control strategy was developed to be implemented in the next three to five years to address public health and climate change and to set a pathway to achieve the 2050 vision. The control strategy includes 85 control measures to reduce emissions of ozone, particulate matter, TACs, and GHG from a full range of emission sources. These control measures cover the following sectors: (1) stationary (industrial) sources, (2) transportation, (3)

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energy, (4) agriculture, (5) natural and working lands, (6) waste management, (7) water, (8) super-GHG pollutants, and (9) buildings.
 The proposed control strategy is based on the following key priorities:
 Reduce emissions of criteria air pollutants and TACs from all key sources.  Reduce emissions of “super-GHGs” such as methane, black carbon, and fluorinated gases.  Decrease demand for fossil fuels (gasoline, diesel, and natural gas).  Increase efficiency of the energy and transportation systems.  Reduce demand for vehicle travel, and high-carbon goods and services.  Decarbonize the energy system.
 Make the electricity supply carbon-free.
 Electrify the transportation and building sectors.5
Community Air Risk Evaluation Program
The Air District’s Community Air Risk Evaluation (CARE) program was initiated in 2004 to evaluate and reduce health risks associated with exposure to outdoor TACs in the Bay Area, primarily DPM. The last update to this program was in 2014. Based on findings of the latest report, DPM was found to account for approximately 85 percent of the cancer risk from airborne toxics. Carcinogenic compounds from gasoline-powered cars and light duty trucks were also identified as significant contributors: 1,3-butadiene contributed 4 percent of the cancer risk-weighted emissions, and benzene contributed 3 percent. Collectively, five compounds— DPM, 1,3-butadiene, benzene, formaldehyde, and acetaldehyde—were found to be responsible for more than 90 percent of the cancer risk attributed to emissions. All of these compounds are associated with emissions from internal combustion engines. The most important sources of cancer risk-weighted emissions were combustion-related sources of DPM, including on-road mobile sources (31 percent), construction equipment (29 percent), and ships and harbor craft (13 percent). Overall, cancer risk from TAC dropped by more than 50 percent between 2005 and 2015, when emissions inputs accounted for State diesel regulations and other reductions.

The major contributor to acute and chronic non-cancer health effects in the Air District is acrolein (C3H4O). Major sources of acrolein are on-road mobile sources and aircraft near freeways and commercial and military airports. Currently CARB does not have certified emission factors or an analytical test method for acrolein. Since the appropriate tools needed to implement and enforce acrolein emission limits are not available, the Air District does not conduct health risk screening analysis for acrolein emissions. 5 Bay Area Air District, April 19, 2017, Final 2017 Clean Air Plan. Spare the Air Cool the Climate, A Blueprint for Clean Air and Climate Protection in the Bay Area, https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-airplan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?rev=8c588738a4fb455b9cabb27360409529&sc_lang=en, accessed on May 20, 2024.

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Assembly Bill 617 Community Action Plans
AB 617 develops a new community-focused program to reduce exposure more effectively to air pollution and preserve public health in environmental justice communities. AB 617 directs CARB and all local air districts to take measures to protect communities disproportionally impacted by air pollution through monitoring and implementing air pollution control strategies.

On September 27, 2018, CARB approved the Air District’s recommended communities for monitoring and emission reduction planning. The State approved communities for year 1 of the program as well as communities that would move forward over the next five years. Bay Area recommendations included all the CARE areas, areas with large sources of air pollution (e.g., refineries, seaports, and airports), areas identified via statewide screening tools as having pollution and/or health burden vulnerability, and areas with low life expectancy.6 Bay Area Air District Rules and Regulations
Regulation 7, Odorous Substances
Sources of objectionable odors may occur within the unincorporated county. The Air District’s Regulation 7, Odorous Substances, places general limitations on odorous substances and specific emission limitations on certain odorous compounds. Odors are also regulated under Air District Regulation 1, Rule 1-301, Public Nuisance, which states that “no person shall discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or the public; or which endangers the comfort, repose, health or safety of any such persons or the public, or which causes, or has a natural tendency to cause, injury or damage to business or property.” Under the Air District’s Rule 1-301, a facility that receives three or more violation notices within a 30-day period can be declared a public nuisance.

Other Bay Area Air District Regulations
In addition to the plans and programs described above, the Air District administers a number of specific regulations on various sources of pollutant emissions that would apply to the proposed project:
 Regulation 2, Rule 2, Permits, New Source Review
 Regulation 2, Rule 5, New Source Review of Toxic Air Contaminants  Regulation 2, Rule 6, Permits, Major Facility Review
 Regulation 6, Rule 1, General Requirements
 Regulation 6, Rule 2, Commercial Cooking Equipment
 Regulation 8, Rule 3, Architectural Coatings
6 Bay Area Air District, April 19, 2019, AB 617 Fact Sheet. San Francisco Bay Area Community Health Protection Program, https://www.baaqmd.gov/~/media/files/ab617-community-health/2019_0325_ab617onepagerpdf.pdf?la=en&rev=9f6dcd6de8854fd9853ff0498c6bbdff, accessed on May 20, 2024.

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 Regulation 8, Rule 4, General Solvent and Surface Coatings Operations  Regulation 11, Rule 2, Asbestos, Demolition, Renovation and Manufacturing Plan Bay Area 2050
MTC and ABAG adopted Plan Bay Area 2050 on October 21, 2021.7 Plan Bay Area provides transportation and environmental strategies to continue to meet the regional transportationrelated GHG reduction goals of SB 375, which is described in Section 4.5, Greenhouse Gas Emissions, of this Draft EIR. Strategies to reduce GHG emissions include focusing housing and commercial construction in walkable, transit-accessible places; investing in transit and active transportation; and shifting the location of jobs to encourage shorter commutes. To achieve MTC’s/ABAG’s sustainable vision for the Bay Area, the Plan Bay Area land use concept plan for the region concentrates the majority of new population and employment growth in the region in Priority Development Areas (PDAs). PDAs are transit-oriented, infill development opportunity areas within existing communities. An overarching goal of the regional plan is to concentrate development in areas where there are existing services and infrastructure rather than allocate new growth to outlying areas where substantial transportation investments would be necessary to achieve the per capita passenger vehicle, VMT, and associated GHG emissions reductions.

LOCAL
Valley Transportation Authority 2021 Congestion Management Program Document The Valley Transportation Authority (VTA) Congestion Management Program (CMP) aims to adopt transportation improvement programs for Santa Clara County.8 The CMP provides a roadmap to reduce congestion, land use decision-making and air quality programs among local jurisdictions. The 2021 update also documents changes to VTA’s Transportation Demand Program (TDM), regional planning efforts by ABAG and MTC, and future updates to the Multimodal Improvement Plan (MIP). Consistent with State law and the MTC’s Regional Transportation Plan, the CMP contains a performance element to evaluate current and future multi-modal system performances, a seven-year capital improvement program (CIP), a program to analyze the impacts of land use decisions, and a travel demand element to promote more transportation alternatives. In addition, VTA’s updated CMP includes multi-modal performance standards and trip reduction and transportation demand management strategies consistent with the goal of reducing regional vehicle miles traveled in accordance with Senate Bill 375. The 2021 CMP also includes a discussion of Senate Bill 743 implementation and relationship to the CMP auto LOS standard.
7 Association of Bay Area Governments and the Metropolitan Transportation Commission., October 2021, Plan Bay Area 2050, https://abag.ca.gov/sites/default/files/documents/2021-11/Plan_Bay_Area_2050_October_2021.pdf, accessed on May 20, 2024.
8 Valley Transportation Authority, 2021, 2021 Congestion Management Program Document, https://www.vta.org/sites/default/files/2022-01/2021CMPDocumentV2_Reduced.pdf, accessed on May 13, 2024.

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Mountain View Code of Ordinances
The Mountain View Code of Ordinances includes various directives to minimize adverse impacts to air quality in the city of Mountain View. The following Ordinances would apply to the proposed project that would reduce air quality impacts:
 Section 8.20.12, Subsection 101.10.1.2.2 added, adopts the green building standards for nonresidential new construction. All nonresidential new construction must comply with the following:
 The mandatory measures of the 2022 California Green Building Standards Code and City of Mountain View Reach Code as modified.
 Shall meet the intent of LEED ® Gold certified;
 Shall meet the parking requirements per Table 101.10 and Table A5.106.5.3.2;  Shall demonstrate energy compliance to meet or exceed Title 24, Part 6.  Section 8.20.14, Table 101.10 added, adopts applicable California Green Building Standards Code.

Section 8.20.14, Subsection 5.106.5.3.2 amended and Table 5.106.5.3.2 added, adopts and amends applicable Tier 2 CALGreen electric vehicle (EV) parking standards.

4.1.2 Existing Conditions

SAN FRANCISCO BAY AREA AIR BASIN CONDITIONS
California is divided geographically into air basins for the purpose of managing the air resources of the State on a regional basis. An air basin generally has similar meteorological and geographic conditions throughout. The State is divided into 15 air basins, and the City of Mountain View is in the SFBAAB. The discussion below identifies the natural factors in the Air Basin that affect air pollution. Air pollutants of concern are criteria air pollutants and TACs. Federal, State, and local air districts have adopted laws and regulations intended to control and improve air quality.

The Air District is the regional air quality agency for the SFBAAB, which comprises all of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, and Santa Clara Counties; the southern portion of Sonoma County; and the southwestern portion of Solano County. Air quality in this area is determined by such natural factors as topography, meteorology, and climate, in addition to the presence of existing air pollution sources and ambient conditions.9 9 Bay Area Air District, May 2017, California Environmental Quality Act Air Quality Guidelines, http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf, accessed on May 20, 2024.

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Meteorology
The SFBAAB is characterized by complex terrain, consisting of coastal mountain ranges, inland valleys, and bays, which distort normal wind flow patterns. The Coast Range10 splits in the Bay Area, creating a western coast gap, the Golden Gate, and an eastern coast gap, the Carquinez Strait, which allows air to flow in and out of the Bay Area and the Central Valley. The climate is dominated by the strength and location of a semi-permanent, subtropical high-pressure cell.

During the summer, the Pacific high-pressure cell is centered over the northeastern Pacific Ocean, resulting in stable meteorological conditions and a steady northwesterly wind flow.

Upwelling of cold ocean water from below the surface because of the northwesterly flow produces a band of cold water off the California coast. The cool and moisture-laden air approaching the coast from the Pacific Ocean is further cooled by the presence of the coldwater band, resulting in condensation and the presence of fog and stratus clouds along the Northern California coast. In the winter, the Pacific high-pressure cell weakens and shifts southward, resulting in wind flow offshore, the absence of upwelling, and the occurrence of storms. Weak inversions coupled with moderate winds result in a low air pollution potential.

Wind Patterns
During the summer, winds flowing from the northwest are drawn inland through the Golden Gate and over the lower portions of the San Francisco Peninsula. Immediately south of Mount Tamalpais in Marin County, the northwesterly winds accelerate considerably and come more directly from the west as they stream through the Golden Gate. This channeling of wind through the Golden Gate produces a jet that sweeps eastward and splits off to the northwest toward Richmond and to the southwest toward San José when it meets the East Bay hills. Wind speeds may be strong locally in areas where air is channeled through a narrow opening, such as the Carquinez Strait, the Golden Gate, or the San Bruno gap.

The air flowing in from the coast to the Central Valley, called the sea breeze, begins developing at or near ground level along the coast in late morning or early afternoon and the sea breeze deepens and increases in velocity while spreading inland. Under normal atmospheric conditions, the air in the lower atmosphere is warmer than the air above it. In the winter, the SFBAAB frequently experiences stormy conditions with moderate to strong winds, as well as periods of stagnation with very light winds. Winter stagnation episodes (i.e., conditions where there is little mixing, which occurs when there is a lack of or little wind) are characterized by nighttime drainage flows in coastal valleys. Drainage is a reversal of the usual daytime air-flow patterns; air moves from the Central Valley toward the coast and back down toward the Bay from the smaller valleys within the SFBAAB.
10 The Coast Range traverses California’s west coast from Humboldt County to Santa Barbara County.

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Temperature
Summertime temperatures in the Air Basin are determined in large part by the effect of differential heating between land and water surfaces. Because land tends to heat up and cool off more quickly than water, a large-scale gradient (differential) in temperature is often created between the coast and the Central Valley, and small-scale local gradients are often produced along the shorelines of the ocean and bays. The temperature gradient near the ocean is also exaggerated, especially in summer, because of the upwelling of cold water from the ocean bottom along the coast. On summer afternoons, the temperatures at the coast can be 35 degrees Fahrenheit (°F) cooler than temperatures 15 to 20 miles inland; at night, this contrast usually decreases to less than 10°F. In the winter, the relationship of minimum and maximum temperatures is reversed. During the daytime the temperature contrast between the coast and inland areas is small, whereas at night the variation in temperature is large.

Precipitation
The Air Basin is characterized by moderately wet winters and dry summers. Winter rains (November through March) account for about 75 percent of the average annual rainfall. The amount of annual precipitation can vary greatly from one part of the Air Basin to another, even within short distances. In general, total annual rainfall can reach 40 inches in the mountains, but it is often less than 16 inches in sheltered valleys.

During rainy periods, ventilation (rapid horizontal movement of air and injection of cleaner air) and vertical mixing (an upward and downward movement of air) are usually high, and thus pollution levels tend to be low (i.e., air pollutants are dispersed more readily into the atmosphere rather than accumulate under stagnant conditions). However, during the winter, frequent dry periods do occur, where mixing and ventilation are low and pollutant levels build up.

Wind Circulation
Low wind speed contributes to the buildup of air pollution because it allows more pollutants to be emitted into the air mass per unit of time. Light winds occur frequently during periods of low sun (fall and winter, and early morning) and at night. These are also periods when air pollutant emissions from some sources are at their peak, namely, commuter traffic (early morning) and wood-burning appliances (nighttime). The problem can be compounded in valleys, when weak flows carry the pollutants up-valley during the day, and cold air drainage flows move the air mass down-valley at night. Such restricted movement of trapped air provides little opportunity for ventilation and leads to buildup of pollutants to potentially unhealthful levels.

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Inversions
An inversion is a layer of warmer air over a layer of cooler air. Inversions affect air quality conditions significantly because they influence the mixing depth (i.e., the vertical depth in the atmosphere available for diluting air contaminants near the ground). There are two types of inversions that occur regularly in the SFBAAB. Elevation inversions11 are more common in the summer and fall, and radiation inversions12 are more common during the winter. The highest air pollutant concentrations in the SFBAAB generally occur during inversions.

ATTAINMENT STATUS OF THE SFBAAB
The AQMP provides the framework for air quality basins to achieve attainment of the State and federal AAQS through the State Implementation Plan. Areas that meet AAQS are classified attainment areas, and areas that do not meet these standards are classified nonattainment areas. Severity classifications for O3 range from marginal, moderate, and serious to severe and extreme.
 Unclassified: A pollutant is designated unclassified if the data are incomplete and do not support a designation of attainment or nonattainment.
 Attainment: A pollutant is in attainment if the AAQS for that pollutant was not violated at any site in the area during a three-year period.
 Nonattainment: A pollutant is in nonattainment if there was at least one violation of an AAQS for that pollutant in the area.
 Nonattainment/Transitional: A subcategory of the nonattainment designation. An area is designated nonattainment/transitional to signify that the area is close to attaining the AAQS for that pollutant.

The attainment status for the SFBAAB is shown in Table 4.1-2, Attainment Status of Criteria Pollutants in the San Francisco Bay Area Air Basin. The SFBAAB is currently designated a nonattainment area for California and National O3, California and National PM2.5, and California PM10 AAQS.
11 When the air blows over elevated areas, it is heated as it is compressed into the side of the hill/mountain. When that warm air comes over the top, it is warmer than the cooler air of the valley. 12 During the night, the ground cools off, radiating the heat to the sky.

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Table 4.1-2 Attainment Status of Criteria Air Pollutants in the San Francisco Bay Area Air Basin
Pollutant State Federal
Ozone – 1-hour Nonattainment Classification revoked (2005) Ozone – 8-hour Nonattainment (serious) Nonattainment (marginal) 1 PM10 Nonattainment Unclassified/Attainment 2
PM2.5 Nonattainment Unclassified/Attainment
CO Attainment Attainment
NO2 Attainment Unclassified
SO2 Attainment Attainment
Lead Attainment Attainment
Sulfates Attainment Unclassified/Attainment
All others Unclassified/Attainment Unclassified/Attainment Source: California Air Resources Board, 2024, Maps of State and Federal Area Designations, https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations, accessed on May 13, 2024.

Notes:

1. Severity classification as of February 13, 2017.

2. In December 2014, US EPA issued final area designations for the 2012 primary annual PM2.5 National AAQS. Areas designated “unclassifiable/attainment” must continue to take steps to prevent their air quality from deteriorating to unhealthy levels. The effective date of this standard is April 15, 2015.

EXISTING AMBIENT AIR QUALITY
Existing levels of ambient air quality and historical trends and projections in the county are best documented by measurements taken by the Air District. The Air District has 30 permanent monitoring stations around the Bay Area. The nearest station is the Redwood City Monitoring Station, which monitors O3, NO2, and PM2.5. Redwood City does not monitor PM10, therefore, the nearest station for and PM10 is the San José-Jackson Street monitoring station. Data from this monitoring station is summarized in Table 4.1-3, Ambient Air Quality Monitoring Summary.

The data show that the area regularly exceeds the State and federal one-hour, eight-hour O3 standards and federal PM2.5, and occasionally exceeds the State and federal PM10 in the last three recorded years.

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Table 4.1-3 Ambient Air Quality Monitoring Summary
Pollutant/Standard a
Number of Days Thresholds Were
Exceeded
and Maximum Levels
2020 2021 2022
Ozone (O3) a
State 1-Hour ≥ 0.09 ppm (days exceed threshold)
State & Federal 8-hour ≥ 0.070 ppm (days exceed
threshold)
Max. 1-Hour Conc. (ppm)
Max. 8-Hour Conc. (ppm)
1 1

0.098

0.078
0 0

0.085

0.064
0 0

0.079

0.062
Nitrogen Dioxide (NO2) a
State 1-Hour ≥ 0.18 ppm (days exceed threshold)
Federal 1-Hour ≥ 0.100 ppm (days exceed threshold)
Max. 1-Hour Conc. (ppm)
0 0

0.046
0 0

0.041
0 0

0.044
Coarse Particulates (PM10) b
State 24-Hour > 50 µg/m3 (days exceed threshold)
Federal 24-Hour > 150 µg/m3 (days exceed threshold)
Max. 24-Hour Conc. (µg/m3
)
10 0
137.1
0 0

45.1 0
0 44.5
Fine Particulates (PM2.5) a
Federal 24-Hour > 35 µg/m3 (days exceed threshold)
Max. 24-Hour Conc. (µg/m3)
9 124.1
0 30.1
0 27.4
Source: California Air Resources Board, 2023, Air Pollution Data Monitoring Cards (2020, 2021, and 2022), https://www.arb.ca.gov/adam/topfour/topfour1.php, accessed February 21, 2024.

Notes: ppm = parts per million; ppb = parts per billion; µg/m3 = micrograms per cubic meter; * = Data not available a. Data for O3, NO2 and PM2.5 obtained from the Redwood City Monitoring Station. b. Data for PM10 obtained from the San José-Jackson Street Monitoring Station.

Sensitive Receptors
Some land use types are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardiorespiratory diseases.

The Air District defines sensitive receptors as “Facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples include schools, hospitals and residential areas”.13
13 Bay Area Air District, April 2023, California Environmental Quality Act Air Quality Guidelines, https://www.baaqmd.gov/plansand-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines.

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Residential areas are also considered sensitive receptors to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Other sensitive receptors include retirement facilities, hospitals, and schools. Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, exercise places a high demand on respiratory functions, which can be impaired by air pollution. In addition, noticeable air pollution can detract from the enjoyment of recreation. Industrial, commercial, retail, and office areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent, as the majority of the workers tend to stay indoors most of the time. In addition, the working population is generally the healthiest segment of the public.

Existing Emissions
The project site hosts the existing Mountain View Police Department on approximately 4.3 acres. As shown on Figure 3-2, Aerial Photograph, the project site is currently occupied by the Mountain View Police Department building, a 42-stall parking lot, a pump station, and a K-9 training area. As such, operations of the existing project site generate criteria air pollutants through the use of vehicles and on-site equipment, building natural gas consumption, and periodic application of paints and coatings.

4.1.3 Significance Criteria
The Initial Study prepared for this Draft EIR (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments) identified that the proposed project would not result in a significant impact for the following significance criterion:

Would the project conflict with or obstruct implementation of the applicable air quality plan?
The proposed project would have a significant impact under Appendix G, Environmental Checklist Form, of the California Environmental Quality Act (CEQA) Guidelines if it would:
a) 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.
b) Expose sensitive receptors to substantial pollutant concentrations. c) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

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4.1.4 Project Impact Analysis
The following impact analysis addresses thresholds of significance for which the Initial Study disclosed potentially significant impacts.
a) Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
The Air District has identified thresholds of significance for criteria pollutant emissions and criteria air pollutant precursors, including ROG, NOX, CO, PM10, and fine PM2.5. Development projects below these significant thresholds are not expected to generate sufficient criteria air pollutant emissions to violate any AAQS or contribute substantially to an existing or projected air quality violation.

Regional Short-Term Construction Impacts
Construction activities produce combustion emissions from various sources, such as on-site heavy-duty construction vehicles, vehicles hauling materials to and from the site, and motor vehicles transporting the construction crew. Demolition and site preparation activities produce fugitive dust emissions (PM10 and PM2.5). Air pollutant emissions from construction activities on site would vary daily as construction activity levels change. Construction activities associated with the project would result in emissions of ROG, NOX, CO, PM10, and fine PM2.5.

Construction Fugitive Dust
Ground-disturbing activities during construction would generate fugitive dust (PM10 and PM2.5).

The amount of dust generated during construction would be highly variable and would be dependent on the amount, type, and moisture content of material being disturbed, as well as on meteorological conditions. If uncontrolled, PM10 and PM2.5 levels downwind of actively disturbed areas could possibly exceed State standards, which would be a significant impact.

Impact AIR-1: Without mitigation, construction activities for the proposed project could generate fugitive dust that exceeds State standards.

Mitigation Measure AIR-1: The project contractor shall comply with the Bay Area Air District’s basic best management practices for reducing construction-related emissions of uncontrolled fugitive dust (coarse inhalable particulate matter [PM10] and fine inhalable particulate matter [PM2.5]):
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.

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 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt trackout onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 miles per hour.  All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to five minutes (as required by the California airborne toxics control measures Title 13, Section 2485, of the California Code of Regulations). Clear signage shall be provided for construction workers at all access points.
 All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.  All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 miles per hour.
 All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
 Publicly visible signs shall be posted with the telephone number and name of the person to contact at the City regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations.

These measures shall be noted on grading plans prepared by the applicant submitted to the City of Mountain View Building Division. The construction contractor shall implement these measures during ground disturbing activities. The City shall verify compliance that these measures have been implemented during normal construction site inspections.

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Significance with Mitigation: Less than significant.

Construction Exhaust Emissions
Because the proposed project would involve demolition activities for the removal of the existing building and surface parking, the Air District construction screening criteria cannot be used for analyzing potential air quality impacts resulting from construction of the proposed project.

Therefore, a quantified analysis of the proposed project’s construction emissions was conducted using the California Emissions Estimator Model (CalEEMod) Version 2022.1 based on information provided by the City of Mountain View and default equipment mix for each construction activity during the approximately 30-month construction period.

Potential construction-related air quality impacts are determined by comparing the average daily criteria air pollutants emissions generated by the proposed project-related construction activities to the Air District significance thresholds in Table 4.1-4, Construction-Related Criteria Air Pollutant Emissions Estimates. Average daily emissions are based on the annual construction emissions divided by the total number of active construction days. As shown in Table 4.1-4, criteria air pollutant emissions from construction equipment exhaust would not exceed the Air District average daily thresholds. Therefore, impacts from project-related construction activities to the regional air quality would be less than significant.

Table 4.1-4 Construction-Related Criteria Air Pollutant Emissions Estimates Year
Criteria Air Pollutants (tons/year) a

ROG NOX
Fugitive
PM10
b
Exhaust
PM10
Fugitive
PM2.5
b
Exhaust
PM2.5
b
1 <1 2 <1 <1 <1 <1
2 <1 1 <1 <1 <1 <1
3 <1 1 <1 <1 <1 <1
Total 1 4 1 <1 <1 <1
Criteria Air Pollutants (average lbs/day)a
Average Daily Emissions c 3 13 3 <1 1 <1
Air District Average Daily
Threshold 54 54 BMPs 82 BMPs 54
Exceeds Average Daily
Threshold No No N/A No N/A No

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Table 4.1-4 Construction-Related Criteria Air Pollutant Emissions Estimates Year
Criteria Air Pollutants (tons/year) a

ROG NOX
Fugitive
PM10
b
Exhaust
PM10
Fugitive
PM2.5
b
Exhaust
PM2.5
b
Source: California Air Pollution Control Officer’s Association, April 2022, CalEEMod, California Emissions Estimator Model User Guide, Version 2022.1, https://www.caleemod.com/user-guide. See Appendix B, Air Quality and Greenhouse Gas Emissions Data.

Notes: Emissions may not total to 100 percent due to rounding. BMP = Best Management Practices; N/A = not applicable a. Construction phasing and equipment mix are based on the preliminary information provided by the project applicant.

Where specific information regarding project-related construction activities was not available, construction assumptions were based on CalEEMod defaults, which are based on construction surveys conducted by South Coast Air Quality Management District of construction equipment and phasing for comparable projects. b. Includes implementation of BMPs for fugitive dust control required by the Air District as mitigation, including watering disturbed areas a minimum of two times per day and reducing speed limit to 25 miles per hour on unpaved surfaces. c. Average daily emissions are based on the total construction emissions divided by the total number of active construction days. The total number of construction days is estimated to be about 654 days.

Operational Impacts
Typical long-term air pollutant emissions are generated by area sources (e.g., landscape fuel use, aerosols, architectural coatings, and asphalt pavement), energy use (natural gas), and mobile sources (i.e., on-road vehicles). Emissions would also be generated from the shooting range; however, those emissions are anticipated to be highly controlled using high-efficiency indoor air filters due to their potential to contain lead. The primary source of long-term criteria air pollutant emissions generated by the proposed project would be emissions produced from project-generated vehicle trips. The proposed project would generate 602 daily vehicle trips, constituting an estimated increase of 88 new daily vehicle trips beyond existing conditions.

Table 4.1-5, Operational Criteria Air Pollutant Emissions Estimates, identifies the criteria air pollutant emissions associated with the proposed project. It should be noted that the emission estimates herein do not reflect the net increase in emissions because they do not account for existing emissions that are already generated from operation of the existing site. As such, the emissions impact analysis herein is a conservative assessment of potential air quality impacts resulting from the proposed project.

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Table 4.1-5 Operational Criteria Air Pollutant Emissions Estimates Category
Criteria Air Pollutants (average lbs/day)
ROG NOX PM10 PM2.5
Proposed Land Use 2024 Emissions
Area 3 <1 <1 <1
Energy (natural gas) - - - -
On-Road Mobile 2 2 4 1
Total 5 2 4 1
Air District Thresholds 54 54 82 54
Exceed Threshold? No No No No
Source: Appendix B, Air Quality and Greenhouse Gas Emissions Data.

As shown in Table 4.1-6, the proposed project would not exceed the Air District’s recommended operational criteria air pollutant emissions thresholds. As such, potential impacts resulting from operation of the proposed project would be less than significant. b) Would the proposed project expose sensitive receptors to substantial pollutant concentrations?
The proposed project could expose sensitive receptors to elevated pollutant concentrations if it would cause or contribute significantly to elevated pollutant concentration levels. Unlike regional emissions, localized emissions are typically evaluated in terms of air concentration rather than mass, so they can be more readily correlated to potential health effects.

Localized Short-Term Construction Impacts
The proposed project would elevate concentrations of TACs and fugitive dustin the vicinity of sensitive land uses (i.e., sensitive receptors) during construction activities. Because the proposed project would result in the operation of diesel-fueled construction equipment during project construction, diesel particulate matter (DPM) is the TAC of concern for this analysis. The nearest receptors to the project site include adjacent residents, students at Mountain View Academy approximately 785 feet southeast of the project site, and students at Khan Lab School adjacent to the western project boundary. Construction activities would occur near these sensitive receptor locations. Consequently, an HRA of DPM and PM2.5 concentration was prepared for the proposed project and is included in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR. Results of the analysis are shown in Table 4.1-6, Construction Health Risk Assessment Results – Unmitigated.

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Table 4.1-6 Construction Health Risk Assessment Results – Unmitigated Receptor
Project Level Risk a
Cancer Risk
(per million)
Chronic
Hazards b
Maximum Annual
Average PM2.5
Concentration
(µg/m3) a,b
MER – Resident 70 0.1 0.1
MER – Worker 1 <0.1 <0.1
MER – K-12 Student 8 0.1 0.1
Air District Threshold 10 1.0 0.3
Exceeds Threshold? Yes No No
Notes: MER = maximally exposed resident.

Cancer risk calculated using the 2015 Office of Environmental Health Hazard Assessment Health Risk Assessment guidance (Office of Environmental Health Hazard Assessment, February 2015, Air Toxics Hot Spots Program Guidance Manual for the Preparation of Health Risk Assessments, https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf) a. Construction phasing is based on the preliminary information provided by the City of Mountain View. Where specific information regarding project-related construction activities was not available, construction assumptions were based on CalEEMod defaults, which are based on construction surveys conducted by South Coast Air Quality Management District of construction equipment and phasing for comparable projects. b. Chronic Hazard is derived by dividing the pollutant (DPM; PM10 Exhaust) maximum annual average concentration by 5; however, the maximum annual average PM2.5 concentration shown in this table reflects PM2.5 Total (PM2.5 Exhaust and PM2.5 Dust).

Cancer risk for the residential maximally exposed resident (MER) from project-related construction emissions was calculated to be approximately 70 in one million, which would exceed the 10-in-one-million significance threshold. Cancer risk for the worker and K-12 student receptors were calculated to be approximately 1 and 8 in one million, respectively, which would not exceed the 10-in-one-million significance threshold. In accordance with the latest (2015) OEHHA guidance, the calculated total cancer risk conservatively assumes that the residential MER consists of a pregnant woman in the third trimester that subsequently gives birth to an infant during the duration of construction; therefore, all calculated residential risk values were multiplied by a factor of 10. In addition, it was conservatively assumed that the residents were outdoors 8 hours a day, 261 construction days per year and exposed to all of the daily construction emissions.

For non-carcinogenic effects, the chronic hazard index identified for each toxicological endpoint equaled less than one for each identified receptor. Therefore, chronic non-carcinogenic hazards are within acceptable limits. For all receptors, the maximum annual PM2.5 concentration would not exceed the Air District significance threshold.

As described above, prior to mitigation, cancer risk at the Residential MER would be potentially significant because the project would expose sensitive receptors to substantial concentrations of air pollutant emissions during construction.

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Impact AIR-2: Construction activities for the proposed project could generate cancer risks above acceptable levels for the maximally exposed residential receptor.

Mitigation Measure AIR-2: The City of Mountain View shall specify in the construction bid that the project construction contractor(s) and subcontractor(s) comply with the following requirements for all off-road equipment used over the entire duration of the construction activities at the site:
 Use engines that meet either US EPA or California Air Resources Board (CARB) Tier 4 Final emission standards for engines that are greater than 25 horsepower. Ensure that all construction plans submitted to the City of Mountain View Building Division clearly show the selected emission reduction strategy for construction equipment over 25 horsepower.
 If Tier 4 Final equipment is not available for use for the project for a specific piece of off-road construction equipment, documentation shall be provided to the City of Mountain View demonstrating that such equipment is not available for the project. If Tier 4 Final equipment is not available, the construction contractor(s) and subcontractor(s) affected shall use Tier 4 Interim equipment instead. If Tier 4 Interim equipment is not available for use for the project for a specific piece of off-road construction equipment, documentation shall be provided to the City demonstrating that such equipment is not available for the project. If Tier 4 Interim equipment is not available, the construction contractor(s) and subcontractor(s) affected shall use Tier 3 equipment outfitted with a level 3 diesel particulate filter instead.  Prohibit the use of generators except for electric alternatives. The City shall ensure that all construction plans submitted to the City of Mountain View Building Division clearly show the requirement to use power storage equipment or electric generators in lieu of fossil fuel powered generators.
 Maintain a list of all operating equipment in use on the project site for verification by the City or their designee. The construction equipment list shall state the makes, models, fuel type, and number of construction equipment on-site. All equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations.
 Communicate with all sub-contractors in contracts and construction documents that all non-essential idling of construction equipment is restricted to 5 minutes or less in compliance with California Air Resources Board Rule 2449 and is responsible for ensuring that this requirement is met.

Significance with Mitigation: Less than significant. As shown in Table 4.1-7, Construction Health Risk Assessment Result – Mitigated, implementation of Mitigation Measure AIR-2 would reduce

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DPM concentrations at nearby receptors to the extent that the Residential MER, the receptor type that would experience the greatest pollutant concentration and associated cancer risk, would not be exposed to pollutant concentrations which lead to a significant health impact. As such, implementation of Mitigation Measure AIR-2 would reduce impacts to sensitive receptors to a less-than-significant level.

Table 4.1-7 Construction Health Risk Assessment Results – Mitigated Receptor
Project Level Risk
Cancer Risk
(per million)
Chronic
Hazards
Maximum Annual
Average PM2.5
Concentration
(µg/m3)
MER – Resident 8 <0.1 <0.1
Air District Threshold 10 1.0 0.3
Exceeds Threshold? No No No
Note: Cancer risk calculated using 2015 OEHHA HRA Guidance Manual.

Risks incorporate Mitigation Measure AIR-1, which requires the use of construction equipment which meets USEPA Tier 4 Final engine requirements for equipment over 25 horsepower and prohibits fossil fuel powered generators.

Localized Long-Term Operational Impacts
Areas of vehicle congestion have the potential to create pockets of CO called hotspots. These pockets have the potential to exceed the State’s one-hour standard of 20 ppm or the eight-hour standard of 9.0 ppm. Hotspots are typically produced at intersections, where traffic congestion is highest because vehicles queue for periods of time and are subject to reduced speeds.

Congestion management plans must align with Plan Bay Area 2050, and an overarching goal of this regional plan is to concentrate development in areas where there are existing services and infrastructure. This strategy helps reduce the allocation of new growth in outlying areas where substantial transportation investments would be necessary to achieve the per capita passenger vehicle miles traveled and associated GHG emissions reductions under Senate Bill 375. The proposed project would be an infill redevelopment project and would be consistent with this overarching goal of the MTC/ABAG’s Plan Bay Area.

Furthermore, a project would have to increase traffic volumes at a single intersection to more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal air mixing is substantially limited (e.g., underpasses, bridges)—or result in a conflict with the local congestion management plan in order to have the potential to generate a CO hotspot.14 As previously mentioned, the proposed project would not result in a conflict with the local 14 Bay Area Air District. 2023, April. California Environmental Quality Act Air Quality Guidelines. https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines.

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congestion management plan because it would constitute the redevelopment of the existing facility and would not result in new uses that cause an expansion of the already urbanized area.

Consistent with the Institute of Transportation Engineers (ITE) 11th Edition Trip Generation Manual Rate 571 (Adult Detention Facility), which was determined to be the most representative of the transportation behavior of both the existing and proposed facility, operation of the proposed project would generate up to 14 AM peak hour vehicle trips and 15 PM peak hour vehicle trips beyond existing conditions. According to the Mountain View General Plan Environmental Impact Report’s Figure IV.C-9, Roadway Volumes and Levels of Service (2030),15 the two analyzed roadways nearest to the project site include Central Expressway with 30,000 daily vehicles and South Shoreline Boulevard with 53,400 daily vehicles forecasted for 2030. Dividing these daily vehicle trip volumes by 10, as an industry standard to approximate the peak hour volumes, results in an estimated 3,000 peak hour trips along Central Expressway and 5,340 peak hour trips along South Shoreline Boulevard. Therefore, the addition of up to 15 peak hour trips resulting from the proposed project would not cause nearby transportation facilities (e.g., roadway segments or intersections) to exceed the Air District’s screening thresholds and would therefore not result in generating a potential CO hotspot. Therefore, impacts from CO hotspots are considered less than significant. c) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Construction-Related Odors
During construction of the proposed project, construction equipment exhaust and application of asphalt and architectural coatings would temporarily generate odors. Any constructionrelated odor emissions would be temporary and intermittent. Additionally, noxious odors would be confined to the immediate vicinity of the construction equipment. By the time such emissions reach any sensitive receptor sites, they would be diluted to well below any level of air quality concern, and impacts would be less than significant.

Operational-Related Odors
The proposed project could result in the generation of outdoor odors capable of affecting offsite receptors such as landscaping equipment exhaust, garbage collection, and vehicle exhaust.

However, the proposed project is not considered a land use type that is a typical generator of odor that could affect a substantial number of people, such as a landfill or industrial process facility. In addition, by the time such emissions reach any off-site receptors, they would be diluted to well below any level of air quality concern and would not be concentrated such that a substantial number of off-site receptors would be affected. 15 Mountain View, City of. 2011. General Plan Environmental Impact Report. https://www.mountainview.gov/home/showpublisheddocument/2264/637957226857900000.

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Furthermore, nuisance odors are regulated under Air District Regulation 7, Odorous Substances, which requires abatement of any nuisance generating an odor complaint. In addition, odors are also regulated under Air District Regulation 1, Rule 1-301, Public Nuisance. Compliance with Air District Regulation 7 would ensure that odor impacts associated with the proposed project are minimized to a less-than significant level.

Significance without Mitigation: Less than significant.

4.1.5 Cumulative Impact Analysis
The cumulative area of analysis is the SFBAAB. Similar to GHG emissions impacts, air quality impacts are regional in nature as no single project generates enough emissions that would cause an air basin to be designated as a nonattainment area. Therefore, the impacts previously discussed are evaluated in the cumulative context.

As discussed in impact discussion (a), ground disturbing activities would generate PM10 and PM2.5; however, Mitigation Measure AIR-1 would ensure that the project implements the Air District’s dust control BMPs which would reduce fugitive dust emissions to a less-thansignificant level. Additionally, criteria air pollutants from construction equipment exhaust would not exceed the Air District average daily thresholds. The project’s operational emissions would also not exceed the Air District’s recommended operational criteria air pollutant emissions thresholds. Consequently, the proposed project would not cumulatively contribute to the nonattainment designations of the Air Basin and impacts would be less than significant.

The proposed project would also elevate concentrations of TACs in the vicinity of sensitive receptors during the construction activities, however, Mitigation Measure AIR-2, which would require the use of Tier 4 Final equipment and prohibit the use of fossil fuel powered generators during construction, would reduce cancer health risk for the affected sensitive receptors to below the Air District health risk thresholds. Additionally, as discussed in impact discussion (b), the proposed project’s contribution of 15 additional peak hour trips would not cause nearby transportation facilities (e.g., roadway segments or intersections) to exceed the Air District’s screening thresholds and would therefore not result in generating a potential CO hotspot.

Cumulative localized health risk impacts would therefore be less than significant.

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4.2 BIOLOGICAL RESOURCES
This section of the Draft Environmental Impact Report (EIR) evaluates the potential for implementation of the proposed project to impact biological resources. As described in Chapter 2, Introduction, of this Draft EIR, the only significance criteria identified in the California Environmental Quality Act (CEQA) Guidelines that are evaluated in this chapter include potential impacts to sensitive species and the potential to conflict with local policies protecting biological resources. Therefore, this chapter only addresses these two issues.

4.2.1 Regulatory Background

FEDERAL AND STATE
State and federal agencies have a lead role in the protection of biological resources under their permit authority set forth in statues and regulations. The United States Fish and Wildlife Service (USFWS) is responsible for administering the Migratory Bird Treaty Act (MBTA) and the federal Endangered Species Act (ESA).

At the State level, the California Department of Fish and Wildlife (CDFW) is responsible for administration of the California Endangered Species Act (CESA). Sections 3500-3516, 4700, 5050, and 5515 of the California Fish and Game Code (CFGC) address Fully Protected species.

Special-status species are plants and animals that are legally protected under the ESA/CESA or other laws and regulations, and also include other species considered rare enough by the scientific community and trustee agencies to warrant special consideration, particularly with regard to protection of isolated populations, nesting or denning locations, communal roosts, and other essential habitat. Species with legal protection under the ESA/CESA may present major constraints to development, particularly when they are wide-ranging or highly sensitive to habitat disturbance and where proposed development would result in a "take" of these species. “Take” is a term used in the ESA to include, "harass, harm, pursue, hunt, shoot, wound, kill trap, capture, or collect, or to attempt to engage in any such conduct."1 Protecting habitat on an ecosystem-level is increasingly recognized as vital to the protection of natural diversity in the State. A project would normally be considered to have a significant effect on the environment if it would substantially affect a sensitive natural community, such as a riparian woodland, native grassland, or coastal salt marsh. Further loss of a sensitive natural community could also be interpreted as substantially diminishing habitat, depending on the relative abundance, quality and degree of past disturbance, and the anticipated impacts. 1 United Stated Fish & Wildlife Services Endangered Species Act 40 Years of Conserving Endangered Species, https://www.fws.gov/endangered/esa-library/pdf/ESA_basics.pdf.

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LOCAL
Mountain View 2030 General Plan
The Mountain View 2030 General Plan includes goals and policies relevant to biological resources in the Infrastructure and Conservation Element, and the Parks, Open Space and Community Facilities Element. The policies relevant to the proposed project are described in Section 4.2.4, Project Impact Analysis, of this chapter.

Mountain View Municipal Code
The City of Mountain View Municipal Code contains all ordinances for the city. The Municipal Code is organized by Chapter, Article, and Section.

Chapter 36, Zoning, Article XI, Landscaping, Division 2, General Landscaping Regulations, sets forth the standards for landscaping in the city. Section 36.34.10, General Landscaping Standards, which amongst other things, describes the standards for plant size, spacing, parking lot landscaping, and drought-tolerant and/or native species. Section 36.34.20, Installation of Required Landscaping, sets forth the standards for the inspection of required landscaping.

Section 36.34.25, Removal of Trees, states that the removal of healthy trees of any size is discouraged and that "Heritage trees," as defined, shall be retained to the extent possible. The removal of a Heritage tree shall be done in compliance with the permit application and review provisions of Chapter 32, Trees, Shrubs and Plants, Article II, Protection of the Urban Forest.

Chapter 32, Trees, Shrubs and Plants, Article II, Protection of The Urban Forest, establishes regulations related to tree protection in the city. Section 32.23, Definitions, defines a heritage tree as any one of the following:
 A tree which has a trunk with a circumference of forty-eight (48) inches or more measured at fifty-four (54) inches above natural grade;
 A multi-branched tree which has major branches below fifty-four (54) inches above the natural grade with a circumference of forty-eight (48) inches measured just below the first major trunk fork.
 Any quercus (oak), sequoia (redwood), or cedrus (cedar) tree with a circumference of twelve (12) inches or more when measured at fifty-four (54) inches above natural grade;  A tree or grove of trees designated by resolution of the city council to be of special historical value or of significant community benefit.

Section 32.25, Heritage Tree Preservation, enacts regulations for heritage tree preservation, and Section 32.28, Application for Removal Permit; Term of Permit, outlines the permits that are required to remove a heritage tree and the application process. Section 32.35, Criteria for Removal; Conditions; Findings, describes the criteria and conditions of approval for the removal of heritage trees and states that the decision-maker shall consider additional criteria, if

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applicable, in weighing the decision to remove a heritage tree, with an emphasis on the intent to preserve heritage trees. Section 32.35(d) describes the potential for any replacement trees to be placed off-site or that an applicant be permitted to pay a fee in lieu of replacement.

4.2.2 Existing Conditions
Habitat
The project site and surrounding area have been urbanized and now support roadways, structures, other impervious surfaces, areas of turf, and ornamental landscaping. Remnant native trees are scattered throughout the urbanized area, together with non-native trees, shrubs, and groundcovers. The site is currently occupied by the Mountain View Police Services - Fire Administration building, associated surface parking, a pump station, and a K-9 training area that is currently operating. The project site is bound by roadways on all sides and property, and land beyond the roadways is developed with residential, commercial uses, and educational land uses. Pursuant to the Mountain View General Plan EIR, the site is classified as a developed area.2 The CALVEG habitat mapping program describes urban areas as lands that tend to have low to poor wildlife habitat value due to replacement of natural communities, fragmentation of remaining open space areas and parks, and intensive human disturbance.3 Wildlife and Plants
The diversity of urban wildlife depends on the extent and type of landscaping and remaining open space, as well as the proximity to natural habitat. Trees and shrubs used for landscaping provide nest sites and cover for wildlife adapted to developed areas. Typical native bird species include the mourning dove, scrub jay, northern mockingbird, American robin, brown towhee, American crow, and Anna’s hummingbird, among others. Introduced species include the rock dove, European starling, house finch, and house sparrow. Urban areas can also provide habitat for several species of native mammals such as the California ground squirrel and striped skunk, as well as the introduced eastern fox squirrel and eastern red fox. Introduced pest species such as the Norway rat, house mouse, and opossum are also abundant in developed areas.

Numerous bat species are also known to be in the Mountain View area, most of which are relatively common and are not considered special-status species.

Given the urbanized and built-out nature of the site and the surrounding area, there is no essential habitat for special-status species on the site. However, there is a possibility that birds, including special-status birds, could nest in trees and other landscaping on the project site. The 2 City of Mountain View, 2012, Draft 2030 General Plan and Greenhouse Gas Reduction Program EIR, IV. Setting, Impacts, and Mitigation Measures, J. Biological Resources, page 410. 3 The CALVEG system was initiated in January 1978 by the Region 5 Ecology Group of the US Forest Service to classify California’s existing vegetation communities for use in statewide resource planning. CALVEG maps use a hierarchical classification on the following categories: forest; woodland; chaparral; shrubs; and herbaceous.

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nests of most bird species are protected under the MBTA when in active use, and there is a remote possibility that one or more raptor species protected under the MBTA and CFGC could nest on the project site. Bat species are also known to be in the Mountain View area, most of which are relatively common and are not considered special-status species. These species have no legal protected status under the ESA or CESA, but the Pallid bat and Western red bat are considered a Species of Special Concern by the CDFW. Bat species found in the Mountain View vicinity may forage and occasionally roost in the site vicinity, but because the buildings on the site are occupied, no suitable habitat for maternity roosts are on the site.

Protected Trees
A tree inventory was prepared for the proposed project by Woodreeve Consulting, LLC to assess the health and structural conditions of the trees on the project site, identify all “protected trees” as defined by Mountain View Municipal Code Chapter 32, Trees, Shrubs and Plants, described in the regulatory setting, assess the impacts of constructing the proposed project on the trees, and present guidelines for tree preservation.4 The Tree Report evaluated 105 trees, representing 17 species on the site. These trees represent the following species: Blackwood acacia (Acacia melanoxylon), Italian alder (Alnus cordata), Raywood ash (Fraxinus oxycarpa ‘Raywood’), Evergreen ash (Fraxinus uhdei), Honey locust (Gleditsia triacanthos f. inermis), Sweetgum (Liquidambar styraciflua), Olive (Olea europaea), Chinese Pistache (Pistacia chinensis), London plane (Platanus x hispanica), Purple-leaf plum (Prunus cerasifera ‘Atropurpurea’), Flowering cherry (Prunus serrulate), Callery pear (Pyrus calleryana), Evergreen pear (Pyrus kawakamii), Coast live oak (Quercus agrifolia), Valley oak (Quercus lobata), Coast redwood (Sequoia sempervirens), and Xylosma (Xylosma congestum).

The project site includes trees that are concentrated around the perimeter of the site, with a group of 48 trees (almost half the total) located south of the existing building along Villa Street.

The professional arborist evaluated the health and structural condition of the 105 trees on the project site, applying a scale of 1 to 5, with 1 being the poorest condition and 5 being excellent condition. These are defined as follows:
 5 = Excellent health and vitality. Good form and structure. No insect or disease problems of significance.
 4 = Good health and vitality. Minor dieback and/or decline in vigor. Insignificant structural defects or insects/disease issues that can be corrected. 4Woodreeve Consulting, May 2022, Draft Tree Inventory Report Public Safety Headquarters, Mountain View, CA.

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 3 = Moderate health and vitality. Moderate twig and branch dieback or chlorotic foliage. Fair structure, limited decay and/or insects/disease issues that would require a concerted effort to correct.
 2 = Poor health and vitality. Declining tree with extensive dieback or very thin crown.

Significant decay and/or structural defects that cannot be corrected.  1 = Very poor health and vitality. Tree is mostly dead or has extensive structural defects that cannot be corrected.

The northern portion of the site was a typical parking lot, with exotic species located around the perimeter and in parking lot islands. The southern portion of the site, in front of the existing building, was more park like, with a generous planting of coast redwood, sweetgum and flowering cherries.

Trees were generally in good (46 percent of the population) to fair (42 percent) condition. Tree condition at the site was directly related to the amount of growing space provided. Coast redwoods were well represented, with 31 trees, or almost 30 percent, of the population.

A total of 60 Heritage trees assessed on the site, including 31 coast redwoods, 6 coast live oaks, valley oak #251 and 22 exotic species.

4.2.3 Significance Criteria
The Initial Study prepared for this Draft EIR (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments) identified that the proposed project would not result in a significant impact for the following significance criteria:
 Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?  Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
 Would the project 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?  Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

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The proposed project would have a significant impact under Appendix G, Environmental Checklist Form, of the California Environmental Quality Act (CEQA) Guidelines if it would:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service.
b) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

4.2.4 Project Impact Analysis
The following impact analysis addresses thresholds of significance for which the Initial Study disclosed potentially significant impacts.
a) Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Nesting Birds
As stated above in the existing conditions discussion, there are no known occurrences of special-status plant or animal species and no suitable habitat for such species on the project site, but there is a possibility that birds that are protected by the MBTA and CFGC could nest in trees and other landscaping on the project site. However, no essential habitat for these or other special-status species is present on the site due to its developed condition. Without mitigation, this impact is considered significant.

Impact BIO-1: Tree removal and demolition activities during site clearance could destroy active nests, and/or otherwise interfere with nesting of birds protected under federal and State law.

Mitigation Measure BIO-1: Nests of raptors and other birds shall be protected when in active use, as required by the federal Migratory Bird Treaty Act and the California Fish and Game Code. The construction contractor shall indicate the following on all construction plans, if construction activities and any required tree removal occur during the breeding season (February 1 and August 31). Preconstruction surveys shall:
 Be conducted by a qualified biologist prior to tree removal or grading, demolition, or construction activities. Note that preconstruction surveys are not required for tree removal or construction, grading, or demolition activities outside the nesting period.

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 Be conducted no more than 14 days prior to the start of tree removal or construction.
 Be repeated at 14-day intervals until construction has been initiated in the area after which surveys can be stopped.
 Document locations of active nests containing viable eggs or young birds.

Protective measures for active nests containing viable eggs or young birds shall be implemented under the direction of the qualified biologist until the nests no longer contain eggs or young birds. Protective measures shall include:
 Establishment of clearly delineated exclusion zones (i.e., demarcated by identifiable fencing, such as orange construction fencing or equivalent) around each nest location as determined by the qualified biologist, taking into account the species of birds nesting, their tolerance for disturbance and proximity to existing development.

In general, exclusion zones shall be a minimum of 300 feet for raptors and 75 feet for passerines and other birds.
 Monitoring active nests within an exclusion zone on a weekly basis throughout the nesting season to identify signs of disturbance and confirm nesting status.  An increase in the radius of an exclusion zone by the qualified biologist if project activities are determined to be adversely affecting the nesting birds. Exclusion zones may be reduced by the qualified biologist only in consultation with California Department of Fish and Wildlife.
 The protection measures shall remain in effect until the young have left the nest and are foraging independently or the nest is no longer active.

Significance with Mitigation: Less than significant.

Roosting Bats
As described in the existing conditions, there are bat species are also known to be in the Mountain View area, most of which are relatively common and are not considered specialstatus species. Bat species found in the Mountain View vicinity may forage and occasionally roost in the site vicinity, but suitable habitat conditions for maternity roots is absent from the site. The potential for any special-status bat species to be present on the site is considered highly remote, given the urbanization of the site vicinity and intensity of human activity, which typically discourages possible occupation by special-status bats. Accordingly, the construction

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and operation of the proposed project would not result in the inadvertent loss of any bats and impacts would be less than significant.

Significance without Mitigation: Less than significant. b) Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? General Plan
As described below, the proposed project would not conflict with any goals and policies in the General Plan related to the protection of biological resources that are relevant to the proposed project:
 Policy INC 16.3 requires the protection and enhancement of nesting, foraging, and other habitat for special-status species and other wildlife. While the proposed project would be located in an infill, urban area, which does not contain any sensitive habitat of special concern, there is the potential for birds, including special-status birds, to nest in the on-site trees. The proposed project would include new landscaping including trees, shrubs, and groundcover as part of the on-site bioretention areas which would enhance urban ecosystem while also providing stormwater treatment that is beneficial to wildlife.  Policy INC 16.4 requires the containment and reduction of the amount of invasive species.

The proposed landscaping would be in compliance with the Mountain View Municipal Code Chapter 36, Zoning, Article XI, Landscaping, Division 2, General Landscaping Regulations, which amongst other things, requires landscape design and construction to include droughttolerant and/or native species in Section 36.34.10(f), General Landscaping Standards).  Policy INC 16.6 requires the integration of biological resources, such as green roofs and native landscaping, into the built environment. The proposed project would include new trees, plants, shrubs, and groundcover with drought tolerant and native species as part of the overall landscaping and on-site bioretention areas.  Policy POS 12.1 requires the protection of trees as an ecological and biological resource. The proposed project would remove some trees, including trees that qualify as “heritage” trees pursuant to Municipal Code Chapter 32, Trees, Shrubs and Plants. The project applicant would comply with the permit requirements for the removal of heritage trees pursuant to Municipal Code Section 32.28, Application for Removal Permit; Term of Permit. Additionally, the proposed project would include new trees, plants, shrubs, and groundcover with drought tolerant and native species as part of the overall landscaping and on-site bioretention areas.

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 Policy POS 12.2 requires increasing the tree canopy coverage to expand shaded areas, enhance aesthetics and help reduce greenhouse gases. The proposed project would remove some trees and shrubs as part of the new development, but would include new trees, plants, shrubs, and groundcover with drought tolerant and native species as part of the overall landscaping and on-site bioretention areas.
 Policy POS 12.4 requires increasing water-efficient, drought-tolerant and native landscaping where appropriate on public and private property. The proposed landscaping would be in compliance with the Mountain View Municipal Code Chapter 36, Zoning, Article XI, Landscaping, Division 2, General Landscaping Regulations, which amongst other things, requires landscape design and construction to include drought-tolerant and/or native species in Section 36.34.10(f), General Landscaping Standards).

Municipal Code
Municipal Code, Chapter 32, Trees, Shrubs and Plants, Article II, Protection of The Urban Forest, provides regulations for the protection, preservation, and maintenance of trees of certain species and sizes. The proposed project includes the removal of trees that meet the City’s requirements for qualifying as “heritage” trees. Removal of a protected tree is permitted by the City, with approval of a tree removal permit. In some circumstances, the City requires tree management plans and tree replacement. The removal of trees protected under the City’s Municipal Code is considered a significant impact.

Impact BIO-2: The proposed development would result in removal of trees protected under City’s Municipal Code.

Mitigation Measure BIO-2: The proposed project shall comply with the City of Mountain View’s Municipal Code requirements for the provision of the removal of heritage trees in Chapter 32, Trees, Shrubs and Plants, Article II, Protection of The Urban Forest. A tree removal permit shall be obtained for the removal of any “heritage” tree, and replacement plantings shall be provided as approved by the City. If permitted, any replacement trees be placed off-site or an appropriate in-lieu tree replacement fee may be paid to the City of Mountain View as compensation for “heritage” trees removed by the proposed project, where sufficient land area is not available on-site for adequate replacement and when approved by the City.

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 Adequate measures shall be defined to protect all trees to be preserved. These measures should include the establishment of a tree protection zone (TPZ) around each tree to be preserved, in which no disturbance is permitted. For design purposes, the TPZ shall be located at the dripline of the tree or 10 feet, whichever is greater. If necessary, the TPZ for construction-tolerant species (i.e., coast live oaks) may be reduced to 7 feet.
 Temporary construction fencing shall be installed at the perimeter of TPZs prior to demolition, grubbing, or grading. Fences shall be 6-foot chain link or equivalent, as approved by the City of Mountain View. Fences shall remain until all construction is completed. Fences shall not be relocated or removed without permission from the consulting arborist.
 No grading, excavation, or storage of materials shall be permitted within TPZs.

Construction trailers, traffic, and storage areas shall remain outside fenced areas at all times. No excess soil, chemicals, debris, equipment, or other materials shall be dumped or stored within the TPZ.
 Underground services including utilities, sub-drains, water or sewer shall be routed around the TPZ. Where encroachment cannot be avoided, special construction techniques such as hand digging or tunneling under roots shall be employed where necessary to minimize root injury. Irrigation systems must be designed so that no trenching will occur within the TPZ.
 Construction activities associated with structures and underground features to be removed within the TPZ shall use the smallest equipment and operate from outside the TPZ. The consulting arborist shall be on-site during all operations within the TPZ to monitor demolition activity.
 All grading, improvement plans, and construction plans shall clearly indicate trees proposed to be removed, altered, or otherwise affected by development construction. The tree information on grading and development plans should indicate the number, size, species, assigned tree number, and location of the dripline of all trees that are to be retained/preserved. All plans shall also include tree preservation guidelines prepared by the consulting arborist.
 The demolition contractor shall meet with the consulting arborist before beginning work to discuss work procedures and tree protection. Prior to beginning work, the contractor(s) working in the vicinity of trees to be preserved shall be required to meet with the consulting arborist at the site to review all work procedures, access routes, storage areas, and tree protection measures.

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 All contractors shall conduct operations in a manner that will prevent damage to trees to be preserved. Any grading, construction, demolition or other work that is expected to encounter tree roots shall be monitored by the consulting arborist. If injury should occur to any tree during construction, it should be evaluated as soon as possible by the consulting arborist so that appropriate treatments can be applied.  Any plan changes affecting trees shall be reviewed by the consulting arborist with regard to tree impacts. These include, but are not limited to, site improvement plans, utility and drainage plans, grading plans, landscape and irrigation plans, and demolition plans.
 Trees to be preserved may require pruning to provide construction clearance. All pruning shall be completed by a State of California Licensed Tree Contractor (C61/D49). All pruning shall be done by Certified Arborist or Certified Tree Worker in accordance with the current Best Management Practices for Pruning published by the International Society of Arboriculture, and adhere to the current editions of the American National Standard for Tree Care Operations (Section Z133.1) and Pruning (Section A300).
 Any root pruning required for construction purposes shall receive the prior approval of and be supervised by the consulting arborist.
 Any demolition or excavation, such as grading, pad preparation, excavation, and trenching, within the dripline or other work that is expected to encounter tree roots should be approved and monitored by the consulting arborist. Any root pruning required for construction purposes shall receive prior approval of, and by supervised by, the consulting arborist. Roots shall be cut by manually digging a trench and cutting exposed roots with a sharp saw.
 Tree(s) to be removed that have branches extending into the canopy of tree(s) to remain must be removed by a qualified arborist and not by construction contractors.

The qualified arborist shall remove the tree in a manner that causes no damage to the tree(s) and understory to remain. Tree stumps shall be ground 12 inches below ground surface.
 All tree work shall comply with the Migratory Bird Treaty Act as well as California Fish and Game Code Sections 3503 through 3513 to not disturb nesting birds. To the extent feasible, tree pruning, and removal shall be scheduled outside of the breeding season. Breeding bird surveys shall be conducted prior to tree work. Qualified biologists shall be involved in establishing work buffers for active nests. (See Mitigation Measure BIO-1.)

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 The vertical and horizontal locations of all the trees identified for preservation shall be established and plotted on all plans. These plans shall be forwards to the consulting arborist for review and comment.
 Foundations, footings, and pavements on expansive soils near trees shall be designed to withstand differential displacement to protect the soil surrounding the tree roots.
 Any liming within 50 feet of any tree shall be prohibited, as lime is toxic to tree roots.

Any herbicides placed under paving materials shall be safe for use under trees and labeled for that use.
 Brush from pruning and trees removal operations shall be chipped and spread beneath the trees within the TPZ. Mulch shall be between 2 inches and 4 inches in depth and kept at a minimum of 3 feet from the base of the trees.  All recommendations for tree preservation made by the applicant’s consulting arborist shall be followed.

Significance with Mitigation: Less than significant.

4.2.5 Cumulative Impact Analysis
The geographic scope of the cumulative analysis for biological resources considers the surrounding incorporated and unincorporated lands, and the region. The potential impacts of proposed development on biological resources tend to be site-specific, and the overall cumulative effect would be dependent on the degree to which significant vegetation and wildlife resources are protected on a particular site. At the same time, cumulative development can contribute incrementally to regionwide impacts, such as reductions in the amount of existing wildlife habitat, particularly for birds and larger mammals. Any cumulative development projects within the vicinity of the project are located in urbanized areas and contain limited biological resource value. Redevelopment and infill projects, including those in built-out urban areas, would remove vegetation that could be used for nesting by birds protected under various laws and would remove buildings and trees that could be used for roosting by sensitive bat species. However, these development projects would be required to comply with the federal Migratory Bird Treaty Act and the CFGC, which require pre-construction surveys and protective measures for active nests. Furthermore, cumulative projects would be required to obtain a tree removal permit and adhere to the tree removal requirements for protected trees under City’s Municipal Code.

The project site is previously disturbed, is developed for the same uses as the proposed project use, and is located within an urban area; therefore, it does not serve as a wildlife corridor.

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Potential impacts to nesting birds and the removal of protected trees would be mitigated to less-than-significant levels through the implementation of Mitigation Measure BIO-1 and BIO-2, respectively. Given the relatively low natural resource quality of the project site and the project’s mitigation of on-site impacts to less-than-significant levels, the proposed project would result in a less-than-significant cumulative impact on biological resources.

Significance with Mitigation: Less than significant.

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4.3 CULTURAL AND TRIBAL CULTURAL RESOURCES
This section of the Draft Environmental Impact Report (EIR) evaluates the potential for implementation of the Mountain View Public Safety Building to impact cultural resources.

Cultural resources comprise archaeological and historical resources. Archaeology studies human artifacts, such as places, objects, and settlements that reflect group or individual religious, cultural, or everyday activities. Historical resources include sites, structures, objects, or places that are at least 50 years old and are significant for their engineering, architecture, cultural use or association, etc. In California, historic resources cover human activities over the past 12,000 years. Cultural resources provide information on scientific progress, environmental adaptations, group ideology, or other human advancements. The analysis in this section is based in part on the following information:

Historic Resources Evaluation Mountain View Police Services – Fire Administration Building Mountain View California, Forget Me Not History, May 2023.

A complete copy of this study is provided in Appendix C, Historic Resources Evaluation, of this Draft EIR.

4.3.1 Regulatory Background

FEDERAL
National Historic Preservation Act
The National Historic Preservation Act of 1966 (NHPA) coordinates public and private efforts to identify, evaluate, and protect the nation’s historic and archaeological resources. The act authorized the National Register of Historic Places, which lists districts, sites, buildings, structures, and objects that are significant in American history, architecture, archaeology, engineering, and culture.

Archaeological Resources Protection Act
The Archaeological Resources Protection Act of 1979 regulates the protection of archaeological resources and sites on federal and Indian lands.

Native American Graves Protection and Repatriation Act
NAGPRA is a federal law passed in 1990 that mandates museums and federal agencies to return certain Native American cultural items—such as human remains, funerary objects, sacred objects, or objects of cultural patrimony—to lineal descendants or culturally affiliated Indian tribes.

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STATE
California Public Resources Code
Archaeological, paleontological, and historical sites are protected under a wide variety of State policies and regulations in the California Public Resources Code (PRC). In addition, cultural and paleontological resources are recognized as nonrenewable resources and receive protection under the PRC and California Environmental Quality Act (CEQA).

PRC Sections 5020 to 5029.5 continued the former Historical Landmarks Advisory Committee as the State Historical Resources Commission. The commission oversees the administration of the California Register of Historical Resources and is responsible for designating State Historical Landmarks and Historical Points of Interest.

PRC Sections 5079 to 5079.65 define the functions and duties of the Office of Historic Preservation (OHP), which administers federal- and State-mandated historic preservation programs in California as well as the California Heritage Fund.

PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources and sacred sites; identify the powers and duties of the Native American Heritage Commission (NAHC); require that descendants be notified when Native American human remains are discovered; and provide for treatment and disposition of human remains and associated grave goods.

California Register of Historic Resources
The California Register of Historic Resources (California Register) establishes a list of properties to be protected from substantial adverse change (Public Resources Code Section 5024.1). The State Office of Historic Preservation (OHP) has determined that buildings, structures, and objects 45 years or older may be of historical value. A historical resource may be listed in the California Register if it meets any of the following criteria.  It is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
 It is associated with the lives of persons important in California’s past.  It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic value.
 It has yielded or is likely to yield information important in prehistory or history.

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The California Register includes properties that are listed or have been formally determined eligible for listing in the National Register, State Historical Landmarks, and eligible Points of Historical Interest. Other resources that may be eligible for the California Register, and which require nomination and approval for listing by the State Historic Resources Commission, include resources contributing to the significance of a local historic district, individual historical resources, historical resources identified in historic surveys conducted in accordance with OHP procedures, historic resources or districts designated under a local ordinance consistent with the procedures of the State Historic Resources Commission, and local landmarks or historic properties designated under local ordinance.

California Health and Safety Code
California Health and Safety Code Section 7050.5 requires that in the event that human remains are discovered within the project site, disturbance of the site shall halt and remain halted until the coroner has conducted an investigation into the circumstances, manner, and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible for the excavation, or to his or her authorized representative. If the coroner determines that the remains are not subject to his or her authority and if the coroner recognizes or has reason to believe the human remains to be those of a Native American, he or she shall contact, by telephone within 24 hours, the NAHC.

State Laws Pertaining to Human Remains
Any human remains encountered during ground-disturbing activities are required to be treated in accordance with California Code of Regulations Section 15064.5(e) (CEQA), PRC Section 5097.98, and the California Health and Safety Code Section 7050.5. California law protects Native American burials, skeletal remains, and associated grave goods regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains. Specifically, Section 7050.5 of the California Health and Safety Code states that in the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent remains until the coroner of the county in which the remains are discovered has determined whether or not the remains are subject to the coroner’s authority. If the human remains are determined to be of Native American origin, the county coroner must contact the California NAHC within 24 hours of this identification. An NAHC representative will then identify a Native American Most Likely Descendant to inspect the site and provide recommendations for the proper treatment of the remains and associated grave goods. In addition, CEQA Guidelines Section 15064.5 specifies the procedures to be followed in case of the discovery of human remains on non-federal land. The disposition of Native American burials falls within the jurisdiction of the NAHC.

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Assembly Bill 52
AB 52 took effect July 1, 2015, and requires inclusion of a new section in CEQA documents titled Tribal Cultural Resources, which include heritage sites. Under AB 52, a tribal cultural resource is defined as sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either included or eligible for inclusion in the California Register of Historic Resources or included in a local register of historical resources. Or the lead agency, supported by substantial evidence, chooses at its discretion to treat the resource as a tribal cultural resource.

AB 52 requires consultation with tribes at an early stage to determine whether the project would have an adverse impact on TCRs and define mitigation to protect them. Per AB 52, within 14 days of deciding to undertake a project or determining that a project application is complete, the lead agency must provide formal written notification to all tribes who have requested it. The tribe then has 30 days of receiving the notification to respond if it wishes to engage in consultation. The lead agency must initiate consultation within 30 days of receiving the request from the tribe. Consultation concludes when both parties have agreed on measures to mitigate or avoid a significant effect to a tribal cultural resource, or a party, after a reasonable effort in good faith, decides that mutual agreement cannot be reached. Regardless of the outcome of consultation, the CEQA document must disclose significant impacts on tribal cultural resources and discuss feasible alternatives or mitigation that avoid or lessen the impact.

LOCAL
Mountain View 2030 General Plan
The Mountain View 2030 General Plan includes goals and policies relevant to cultural resources in Mountain View in the Land Use and Design Element. The policies relevant to the proposed project are listed in Table 4.3-1, Mountain View 2030 General Plan Policies Relevant to Cultural Resources and the Proposed Project.

Table 4.3-1 Mountain View 2030 General Plan Policies Relevant to Cultural Resources and the Proposed Project
Policy Number Policy Text
Chapter 3, Land Use and Design (LUD) Element
Policy LUD 11.1
Historical preservation. Support the preservation and restoration of structures and cultural resources listed in the Mountain View Register of Historic Resources, the California Register of Historic Places or National Register of Historic Places.

Policy LUD 11.2 Adaptive re-use. Encourage the adaptive re-use of historic buildings in ways that retain their historical materials and character-defining features.

Policy LUD 11.3: Incentives. Encourage historical preservation through incentives and opportunities.

Policy LUD 11.5 Archaeological and paleontological site protection. Require all new development to meet

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Table 4.3-1 Mountain View 2030 General Plan Policies Relevant to Cultural Resources and the Proposed Project
Policy Number Policy Text
state codes regarding the identification and protection of archaeological and paleontological deposits.

Policy LUD 11.6 Human remains. Require all new development to meet state codes regarding the identification and protection of human remains.

Source: City of Mountain View, 2012, Mountain View 2030 General Plan.

Mountain View Municipal Code
The Mountain View Municipal Code contains all ordinances for the city. The Municipal Code is organized by Chapter, Article, Division, and Section.

Division 15, Designation and Preservation of Historic Resources, establishes regulations related to how a resource is designated and the designation criteria. Section 36.54.70, Designation process for Historic Register, outlines the designation process and each step for a building to be placed on the Historic Register
Mountain View Register of Historic Resources
Last updated in 2022, the Mountain View Register of Historic Resources outlines the buildings in Mountain View that are historically significant. Within the register, there are 42 privately owned properties and 3 City-owned properties. The project site is not included on the list of properties.

This list is currently being updated along with a Citywide Historic Resources Survey being undertaken.

4.3.2 Existing Conditions

ARCHAEOLOGICAL RESOURCES
Tamien-speaking indigenous communities, later known as the Ohlone, lived in villages in what is now Mountain View. A large earthen mound created by the local tribes (near the present-day Monta Loma neighborhood) serves as a ceremonial and cultural center for the area. In 1777, most of the South Bay became part of the lands of Mission Santa Clara de Asis. Indigenous peoples were relocated to Mission Santa Clara and other nearby missions, where disease killed much of the population and traditional culture and autonomy were subverted.1 According to the City of Mountain View Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report (SCH No. 2011012069), fossiliferous deposits exist 1 Mountain View Historical Association, https://www.mountainviewhistorical.org/mountain-view-history-timeline/, accessed on January 29, 2025.

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in the general area. The City of Mountain View lies on alluvial plains at the southern end of the San Francisco Bay, which consists primarily of Quaternary Period (1,800,000 years B.P. to present) deposits. These Quaternary alluvial deposits were laid down by the Adobe, Permanente, and Steven’s creeks exiting the Santa Cruz Mountains south of Mountain View, and estuarine deposits created by these creeks and the San Francisco Bay. Older Pleistocene deposits typically occur as terraces incised by Holocene fluvial drainages. Locally, Late Pleistocene alluvium (126,000 to 10,000 years B.P.) contains invertebrate and extinct vertebrate fossils, many of which are representative of the Rancholabrean land mammal age. Fossils in alluvium of this age include bison, mammoth, ground sloths, saber-toothed cats, dire wolves, horses, cave bears, rodents, birds, reptiles, and amphibians.2

PROJECT SITE HISTORY
This section was prepared using information from the Historic Resource Evaluation Report that was prepared in May 2023 by Forget Me Not History (see Appendix C, Historic Resources Evaluation).

The Mountain View Police Services - Fire Administration building has not been previously documented and evaluated for listing in the National Register of Historic Places, California Register of Historical Resources, and Mountain View Register of Historic Resources.

From the 1890s to 1920s, the block on which the project site is located was developed with a mix of residential and light industrial properties. For a time, the northern section of the property (abutting the railroad tracks) contained Mrs. S. E. Bubb’s grain warehouse and a corral.

In 1915, a portion of the project site was a pickle works that expanded over time. By 1943, the entire block of the project site was a pickle and catsup factory. In 1963, the pickle and catsup factory were shut down and the property became vacant.

In 1977 the project site was identified as the location for the future Mountain View Police Services - Fire Administration building and the architecture firm Goodwin B. Steinberg Associates was retained to design the building. Steinberg served as the principal architect and collaborated with a team of architects, including Pete Dalton and Karl Coombs, on the building’s design. The new facility, which included the main building, sign and flagpole, landscaping, and parking lots, was dedicated in March 1980. In 1984, several features that had been eliminated from the proposed plans were completed. Based on a review of drawings and plans provided by the City of Mountain View and visual observation during a site visit, the subject property underwent minimal alterations over the next four decades. 2 City of Mountain View, September 2012, City of Mountain View Draft 2030 General Plan and Greenhouse Gas Reduction Program Final Environmental Impact Report (SCH No. 2011012069), https://www.mountainview.gov/home/showpublisheddocument/2262/637957226851270000, accessed on January 29, 2025.

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Goodwin Steinberg’s design for the building incorporated many of his signature elements for large-scale buildings. The building is situated at the southeast corner of the parcel within extensive landscaping. The main façade is one story in height and located at grade with a large entry plaza designed to provide an open feeling inviting community involvement. The lower story is partially embedded in the sloped terrain of the site, allowing the majority of the parking to be located to the rear and below grade, thus obscured from view when approaching the main entrance. The site’s topography also allows the north façade to expand to two stories in height, with wide expanses of skylights across the main story and day-to-day police and mechanical operations to occur at the lower story.

Prior to his death in 2010, Goodwin Steinberg was elevated to the American Institute of Architects Fellows, the highest honor for exceptional contributions to the architecture field.

TRIBAL CONSULTATION
In compliance with the requirements set forth in AB 52, the City of Mountain View provided formal notification of the proposed project and served an invitation for consultation to the following tribes:
 Amah Mutsun Tribal Band
 Amah Mutsun Tribal Band of Mission San Juan Bautista
 Indian Canyon Mutsun Band of Costanoan
 Muwekma Ohlone Indian Tribe of the SF Bay Area
 North Valley Yokuts Tribe
 Tamien Nation
 The Ohlone Indian Tribe
 Wuksachi Indian Tribe/Eshom Valley Band
These letters were sent based on a contact list provided by the Native American Heritage Commission on November 13, 2023. As of the time of publication of this Draft EIR, none of the contacted tribes responded to the invitation for consultation.

4.3.3 Significance Criteria
CEQA Guidelines Section 15064.5 provides direction on determining significance of impacts to archaeological and historical resources. Generally, a resource shall be considered “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (PRC Section 5024.1):
 Criterion 1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.  Criterion 2. Is associated with the lives of persons important in our past.

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 Criterion 3. Embodies the distinctive characteristics of a type, period, region or method of construction, or represents the work of an important creative individual, or possesses high artistic values.
 Criterion 4. Has yielded, or may be likely to yield, information important in prehistory or history.

The fact that a resource is not listed in the California Register of Historical Resources, not determined to be eligible for listing, or not included in a local register of historical resources does not preclude a lead agency from determining that it may be a historical resource.

The proposed project would have a significant impact under Appendix G, Environmental Checklist Form, of the California Environmental Quality Act (CEQA) Guidelines if it would:
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.
c) Disturb any human remains, including those interred outside of dedicated cemeteries. d) Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

4.3.4 Project Impact Analysis
The following impact analysis addresses thresholds of significance for which the Initial Study disclosed potentially significant impacts.

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a) Would the proposed project cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
The types of cultural resources that meet the definition of historical resources under CEQA Section 21084.1 generally consist of districts, sites, buildings, structures, and objects that are significant for their traditional, cultural, and/or historical associations. Under CEQA, both prehistoric and historic-period archaeological sites may qualify based on historical associations.

As such, the two main historical resources that are subject to impact, and that may be adversely affected by the proposed project, are historical archaeological deposits and historical architectural resources. Impacts to archaeological resources are discussed under impact discussion (b). Therefore, this discussion focuses on potential impacts to architectural resources.

Each criterion is discussed in more depth below based on the Historic Resource Evaluation Report that was prepared in May 2023 by Forget Me Not History and is in Appendix C, Historic Resources Evaluation, of this Draft EIR.

Criterion 1 (Events)
By the time the Mountain View Police Services - Fire Administration building was completed in 1980, the block and surrounding neighborhood had already been developed with a mix of residential, commercial, and light industrial buildings for nearly a century. Similarly, the building was the third iteration of Police and Fire Department buildings in the immediate area, including the fire station completed along Franklin Street in 1924, and the police and fire stations constructed at the intersection of Franklin and Villa streets in the early 1950s. Furthermore, the design and construction of the building from 1977 to 1980 was overshadowed by protracted labor negotiations between the City and Police and Fire Departments, culminating with a contentious 39-day strike by the Mountain View Fire Department in mid-1980. As such, the Mountain View Police Services - Fire Administration building did not play a significant role in the history of the Police and Fire Departments and the expansion of municipal facilities in the City of Mountain View in the late twentieth century, and it did not spur new development in the surrounding area. Therefore, the building is recommended as ineligible for listing in the California Register under Criterion 1.

Criterion 2 (People)
A wide array of City of Mountain View staff has worked at the Mountain View Police Services - Fire Administration building since it opened in 1980. None are known to have made significant contributions to local, State, or national history. While Police Chief Robert K. Schatz and Fire Chief Robert B. Burns held key positions in their respective departments when the building was dedicated, their leadership does not rise to a level of significance under this criterion. Thus, the subject property is recommended as ineligible for listing in the California Register under Criterion 2.

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Criterion 3 (Design/Construction)
Architect Goodwin Steinberg is recognized as a master architect, and the Mountain View Police Services - Fire Administration building is a representative example of the large-scale civic projects that he designed during his 50-year career with his namesake firm. The building blends Shed architecture, expressed in the soaring multi-directional shed roofs and varied fenestration, with elements of regional Spanish Colonial Revival architecture, including the white-painted slump stone brick walls and clay tile roofing that soften the building’s angularity. The prominent clock tower evokes mission-era bell towers. The incorporation of a broad entry plaza, extensive vegetation, and subtle transitions in the site’s topography reflect his intent to create an inviting, open building within a campus-like setting. Furthermore, he integrated experimental active and passive solar technology in the building’s design, while ultimately not successful, were nationally recognized as critical to addressing the 1970s energy crisis. The building’s design would subsequently be featured in Architectural Record. Although it is less than 50 years old, the building meets the threshold for special consideration for listing in the California Register because sufficient time has passed to understand Steinberg’s exemplary career and the history and significance of Shed architecture and experimental solar technology of that era. As such, the subject property is recommended as eligible for listing under Criterion 3 as the work of master architect Goodwin Steinberg.

Criterion 4 (Information Potential)
While Criterion 4 is generally applied to archaeological resources, it can be used to identify buildings with significant construction methods and other related physical information. The subject property is recommended as ineligible for listing in the California Register under this criterion because the experimental solar technology was removed from the building in the late 1980s. The majority of the building’s construction material, including the concrete slump blocks, fenestration, and clay tile roofing, do not themselves embody important physical information.

Conclusion
Based on the analysis above, the Mountain View Police Services - Fire Administration building is recommended as eligible for listing in the California Register under Criterion 3 as a significant example of the work of master architect Goodwin Steinberg. The period of significance dates to 1980 when the building was completed, and the property retains its integrity despite the removal of the rooftop solar collectors in the late 1980s. As such, the property qualifies as a historical resource under CEQA. Due to the proposed removal of the building, the proposed project would result in a significant impact.

Impact CUL-1: The proposed project would remove the historical resource on the project site that is eligible for listing in the California Register under Criterion 3 as a significant example of the work of master architect Goodwin Steinberg.

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Mitigation Measure CUL-1.1: The City shall have Historic American Building Survey Level II documentation completed for the Mountain View Police Services - Fire Administration building and its setting. To ensure public access, the City shall submit copies of the documentation to Mountain View Historical Association’s History Center and the California Historical Resources Information System Northwest Information Center. This documentation shall include drawings, photographs, and a historical narrative:
 Drawings: Existing historic drawings of the historical resource shall be photographed with large-format negatives or photographically reproduced on Mylar. In the absence of existing drawings, full-measured drawings of the building’s plan and exterior elevations shall be prepared prior to demolition.
 Photographs: Photo-documentation of the historical resource shall be prepared to Historic American Building Survey standards for archival photography, prior to demolition. Historic American Building Survey standards require large-format blackand-white photography, with the original negatives having a minimum size of four inches by five inches. Digital photography, roll film, film packs, and electronic manipulation of images are not acceptable. All film prints, a minimum of four inches by five inches, must be hand-processed according to the manufacturer’s specifications and printed on fiber-base, single-weight paper and dried to a full gloss finish. A minimum of 12 photographs shall be taken, detailing the site, building exterior, building interior, and character-defining features. Photographs must be identified and labeled using Historic American Building Survey standards.  Historical Overview: A professional meeting the Secretary of the Interior’s Professional Qualification Standards in Architectural History or History shall assemble historical background information relevant to the historical resource.

The City of Mountain View shall verify compliance with this mitigation measure prior to the initiation of any site or building demolition or construction activities.

Mitigation Measure CUL-1.2: The City shall incorporate an exhibit or display of the Mountain View Police Services - Fire Administration building and a description of its historical significance into a publicly accessible portion of the proposed Public Safety Building. The display shall be developed with the assistance of one or more professionals experienced in creating such historical exhibits or displays.

Significance with Mitigation: Significant and unavoidable. Due to the inherent design of the proposed project, implementation of the proposed project would remove the Mountain View Police Services - Fire Administration building. Therefore, impacts would therefore be significant and unavoidable.

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b) Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Archaeological deposits that meet the definition of historical resource under CEQA Section 21084.1 or CEQA Guidelines Section 15064.5 could be present within the project site and could be damaged or destroyed by ground-disturbing construction activities (e.g., site preparation and grading) associated with the proposed project. Should this occur, the ability of the deposits to convey their significance, either as containing information about prehistory or history, or as possessing traditional or cultural significance to Native American or other descendant communities, would be materially impaired.

The project site is not known to contain archeological resources, ethnographic sites, or Native American remains. However, ground-disturbing construction activities (e.g., site preparation, grading, excavation, and trenching for utilities) associated with the proposed project may result in unanticipated discoveries of cultural resources or the damage or destruction of previously undiscovered resources. Therefore, earth-disturbing activities conducted for the proposed project would have the potential to expose previously undiscovered subsurface archaeological resources, and the impact to archaeological resources has potential to be significant.

Impact CUL-2: Construction activities for the proposed project have the potential to cause a substantial adverse change in the significance of an archaeological resource pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15064.5.

Mitigation Measure CUL-2: Project supervisors, contractors, and equipment operators shall participate in an Archaeological Resource Awareness Training, conducted by a Secretary of Interior-qualified archaeologist, to become familiar with the type of artifacts and features that could be encountered during project-related ground disturbing activities, as well as the procedures to follow if archaeological resources are unearthed during construction. If indigenous, prehistoric or historic-period cultural materials are unearthed during ground-disturbing activities, all work within 100 feet of the find shall halt until a qualified archaeologist and Native American representative can assess the significance of the find. The City and a qualified archaeologist, defined as one meeting the U.S. Secretary of the Interior’s Professional Qualifications Standards for Archaeology, and a Native American representative shall be immediately informed of the discovery. Prehistoric and indigenous materials might include obsidian and chert-flaked stone tools (e.g., projectile points, knives, scrapers) or tool-making debris; culturally darkened soil [“midden”] containing heat-affected rocks and artifacts; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered-stone tools, such as hammerstones and pitted stones. Historic-period materials might include stone, concrete, or adobe footings and walls; filled wells or privies; and deposits of metal, glass, and/or ceramic refuse. If the find is determined to be potentially significant,

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the archaeologist, in consultation with the Native American representative, shall develop a treatment plan that could include site avoidance, capping, or data recovery. If avoidance is not feasible, project impacts shall be mitigated in accordance with the recommendations of the archeologist, in coordination with the City, Native American representative, and pursuant to CEQA Guidelines Section 15126.4 (b)(3)(C), which requires implementation of a data recovery plan. Once the recovery plan has been reviewed and approved by the City, implemented, and any appropriate resource recovery completed, project construction activity within the area of the find may resume.

Significance with Mitigation: Less than significant.
c) Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
Previously undiscovered human remains associated with pre-contact archaeological deposits may exist within the project site, as ground-disturbing activities sometimes uncover such previously unrecorded remains. As discussed under impact discussion (b), ground-disturbing activities and excavation for the proposed project would have the potential to uncover buried resources. It is possible that human remains may be present on the project site. Descendant communities may ascribe religious or cultural significance to such remains, making any such disturbances a significant impact.

Impact CUL-3: Construction activities for the proposed project have the potential to result in unanticipated discovery of human remains interred outside of dedicated cemeteries.

Mitigation Measure CUL-3: In the event of the discovery of human remains during demolition, excavation, or construction, there shall be no further excavation or disturbance of the site within a 50-foot radius of the location of such discovery, or any nearby area reasonably suspected to overlie adjacent remains, and the area shall be secured to prevent further disturbance. The City and the Santa Clara County Coroner shall be notified and shall make a determination as to whether the remains are Native American. If the Coroner determines that the remains are not subject to their authority, the Coroner shall notify the Native American Heritage Commission within 24 hours, which shall attempt to identify descendants of the deceased Native American. If no satisfactory agreement can be reached as to the disposition of the remains pursuant to this State law, then the landowner, in consultation with a qualified archaeologist, shall formulate an appropriate treatment plan for the find, which might include, but not be limited to, respectful scientific recording and removal, being left in place, removal and reburial on-site, or elsewhere. Associated grave goods are to be treated in the same manner. A final report shall be submitted to the City’s Community Development Director prior to release of a Certificate of Occupancy. This report shall contain a description of

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the mitigation programs and its results, including a description of the monitoring and testing resources analysis methodology and conclusions, and a description of the disposition/curation of the resources. The report shall verify completion of the mitigation program to the satisfaction of the City’s Community Development Director.

Significance with Mitigation: Less than significant.
d) Would the proposed project cause a substantial adverse change in the significance of a Tribal Cultural Resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe, and that is: 1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or 2) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resource Code Section 5024.1. In applying the criteria set forth in subdivision (c) of the Public Resource Code Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance to a California Native American tribe? As discussed in impact discussions (b) and (c), no known archeological resources, ethnographic sites, or Native American remains are located on the project site. However, as discussed under impact discussion (b), the project site could contain undiscovered subsurface archaeological deposits, including unrecorded Native American prehistoric archaeological materials. As discussed under impact discussion (b) and (c), ground-disturbing activities associated with the project have the potential to unearth unknown human remains. Therefore, although no known tribal cultural resources have been identified on the project site, the proposed project has the potential to disturb subsurface deposits possessing traditional or cultural significance to Native American or other descendant communities. This is considered a significant impact.

Impact CUL-4: Construction activities for the proposed project have the potential to cause a significant impact to an unknown tribal cultural resource as defined in Public Resources Code 21074.

Mitigation Measure CUL-4: Implement Mitigation Measures CUL-2 and CUL-3.

Significance with Mitigation: Less than significant.

4.3.5 Cumulative Impact Analysis
This analysis considers potential impacts of the proposed project when considered along with the potential impacts of the cumulative development projects listed in Table 4-1, Cumulative

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Projects List. Cumulative cultural resource impacts would occur when a series of actions leads to the loss of a substantial type of site, building, or resource. For example, while the loss of a single historic building may not be significant to the character of a neighborhood or streetscape, continued loss of such resources on a project-by-project basis could constitute a significant cumulative effect. This is most obvious in historic districts, where destruction or alteration of a percentage of the contributing elements may lead to a loss of integrity for the district overall.

For example, changes to the setting or atmosphere of an area by adding modern structures on all sides of a historically significant building, thus altering the aesthetics of the streetscape, would create a significant impact. Destruction or relocation of historic buildings would also significantly impact the setting.

As described in impact discussion (a), the proposed project would result in a significant and unavoidable impact due to project implementation removing the historical resource on the project site that is eligible for listing in the California Register under Criterion 3 as a significant example of the work of master architect Goodwin Steinberg. The proposed project could result in a cumulative impact to historic resources if other cumulative development projects would also result in impacts to historical resources.

The planning areas for the two planning projects listed in Table 4-1 (i.e., the Downtown Precise Plan Comprehensive Update and Moffett Boulevard Precise Plan) contain historic resources; however, none of the properties subject to current development sites (as listed in Table 4-1) are on the City of Mountain View’s Register of Historic Resources.3 Cumulative impacts to historic resources would be reduced through adherence to precise plan standards intended to protect historic resources, and would also be reduced through compliance with the City’s General Plan policies listed in Table 4.3-1, City of Mountain View 2030 General Plan Policies Relevant to Cultural Resources, and adherence to federal and State laws described in Section 4.3.1, Regulatory Background. The City’s 2030 General Plan EIR identifies less-than-significant impacts to historic resources as a result of implementation of the City’s policies and actions to reduce such impacts. Therefore, the proposed project’s project-level significant and unavoidable impact to the on-site historic resource would not, in combination with cumulative development projects, result in a significant cumulative impact.

Similar to the proposed project, cumulative development projects could result in impacts to known or unknown subsurface cultural resources that may be on-site. The construction from cumulative development could involve ground disturbance below the level of previous ground disturbance that could result in the discovery of archaeological resources or human remains.

Due to the built-out nature of the project area, cumulative development projects would occur in the form of infill/intensification on sites either already developed and/or underutilized; this reduces the likelihood of encountering potential archaeological resources or human remains on3 City of Mountain View, 2022, Mountain View Register of Historic Resources, https://www.mountainview.gov/home/showpublisheddocument/7915/638346084894870000, accessed April 1, 2025.

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site unless ground disturbance activities excavate to a greater extent than previously. The existing federal, State, and local regulations and policies described throughout this chapter serve to protect any as-yet-undiscovered cultural resources. Continued compliance with these regulations and implementation of existing policies and requirements, and site-specific protocols in the event of accidental recovery of cultural resources, would preclude cumulative impacts to the maximum extent practicable.

Therefore, in combination with past, present, and reasonably foreseeable projects, the proposed project would result in a less-than-significant cumulative impact with respect to all cultural resources.

Significance without Mitigation: Less than significant.

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4.4 GEOLOGY AND SOILS
This section of the Draft Environmental Impact Report (EIR) evaluates the potential for implementation of the proposed project to impact geological and soil resources. As described in Chapter 2, Introduction, of this Draft EIR, the only significance criteria identified in the California Environmental Quality Act (CEQA) Guidelines that are evaluated in this chapter include potential impacts related to seismic-related ground failure, including liquefaction, and unstable soils.

Therefore, this chapter only addresses these two issues.

4.4.1 Regulatory Background

FEDERAL AND STATE
Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act, which was passed by the California legislature in 1990, addresses earthquake hazards related to liquefaction and seismically induced landslides. Under the Act, seismic hazard zones are mapped by the State Geologist in order to assist local governments in land use planning. The Act states that “it is necessary to identify and map seismic hazard zones in order for cities and counties to adequately prepare the safety element of their general plans and to encourage land use management policies and regulations to reduce and mitigate those hazards to protect public health and safety.” Section 2697(a) of the act states that “cities and counties shall require, prior to the approval of a project located in a seismic hazard zone, a geotechnical report defining and delineating any seismic hazard.” California Building Code
The California Building Code (CBC), known as the California Building Standards Code, is found in Title 24 of the California Code of Regulations. The CBC incorporates the International Building Code, a model building code adopted in jurisdictions across the United States. Current State law requires every local agency enforcing building regulations, such as cities and counties, to adopt the provisions of the CBC within 180 days of its publication. The publication date of the CBC is established by the California Building Standards Commission. The CBC is updated every three years. The CBC provides minimum standards to protect property and the public welfare and safety by regulating the design and construction of excavations, foundations, building frames, retaining walls, and other building elements to mitigate the effects of seismic shaking and adverse soil conditions. The CBC contains provisions for earthquake safety based on factors including occupancy type, the types of soil and rock on-site, and the strength of ground motion with a specified probability of occurring at the site. Also, the CBC requires the preparation of project-specific geotechnical/engineering reports by a certified engineering geologist and/or geotechnical engineer prior to construction of proposed structures.

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LOCAL
The Mountain View Municipal Code contains all ordinances for the city. The Municipal Code is organized by Chapter, Article, Division, and Section.

Article I, Building Code, of Chapter 8, Buildings, adopts the CBC by reference with specified modifications. The City of Mountain View's Building Inspection Department, which is part of the Community Development Department, is responsible for reviewing plans, issuing building permits and conducting field inspections.

4.4.2 Existing Conditions
Geological and soil conditions in an area can influence the shaking effects of an earthquake.

Seismic shaking (or ground shaking) is a general term referring to all aspects of motion of the earth’s surface resulting from an earthquake and is normally the major cause of damage in seismic events.

Liquefaction is the rapid transformation of saturated, loose, fine-grained sediment to a fluid-like state because of earthquake ground shaking. In the process, the soil undergoes transient loss of strength, which commonly causes ground displacement or ground failure to occur. In general, where there is any potential for liquefaction, site-specific studies are needed to determine the extent of the hazard if development were to occur in the area.

Lateral spreading is a form of horizontal displacement of soil toward an open channel or other “free” face, such as an excavation boundary. Lateral spreading can result from either the slump of low cohesion unconsolidated material or more commonly by liquefaction of either the soil layer or a subsurface layer underlying soil material on a slope, resulting in gravitationally driven movement. Lateral spreading (lurching) may also occur where open banks and unsupported cut slopes provide a free face. Ground shaking, especially when inducing liquefaction, may cause lateral spreading toward unsupported slopes. Areas most prone to lateral spreading are those that consist of fill material that has been improperly engineered, that have steep, unstable banks, and that have high groundwater tables.

Damage caused by liquefaction and lateral spreading is generally the most severe when liquefaction occurs within 15 to 20 feet of the ground surface. According to the Mountain View General Plan EIR, most of Mountain View, is underlain by materials that have moderate to very high liquefaction potential. A Seismic Hazard Zone for liquefaction has been determined for the areas adjacent to most creek channels and all portions of the city roughly one-half mile north of El Camino Real, which includes the project site.1
1 City of Mountain View, 2012, Draft 2030 General Plan and Greenhouse Gas Reduction Program Environmental Impact Report, State Clearinghouse No. 2011012069, pages 336 - 337.

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4.4.3 Significance Criteria
The Initial Study prepared for this Draft EIR (see Appendix A, Notice of Preparation, Initial Study, and Scoping Comments) identified that the proposed project would not result in a significant impact for the following significance criteria:
 Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
 Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map, issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.
 Strong seismic ground shaking?
 Landslides?
 Would the project result in substantial soil erosion or the loss of topsoil?  Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?  Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
 Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
The proposed project would have a significant impact under Appendix G, Environmental Checklist Form, of the California Environmental Quality Act (CEQA) Guidelines if it would:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction. b) 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.

4.4.4 Project Impact Analysis
The following impact analysis addresses thresholds of significance for which the Initial Study disclosed potentially significant impacts.

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a) Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction?
The proposed project would replace the existing Mountain View Police Services - Fire Administration building with a new Public Safety Building with the same local communityserving use and purpose for the residents of Mountain View. The proposed project would include demolition of the existing structures and surface parking facilities, and construction of new facilities and surface parking lots. No excavation is proposed except for trenching for utilities.

Because the project site, like much of California, is in a seismically active area and on a site with known liquefaction hazards, the project sponsor would be required to prepare a site-specific geologic technical study pursuant to the required mitigation identified in the General Plan EIR.

As found in the General Plan EIR, with the preparation of a site-specific geologic technical study by a certified engineering geologist and/or geotechnical engineer prior to construction of proposed structures, and implementation of the recommendations of the study, impacts would be less-than-significant.2
With respect to lateral spreading, as described in Section 4.4.2, Existing Conditions, ground shaking, especially when inducing liquefaction, may cause lateral spreading toward unsupported slopes. However, the proposed project does not propose any deep excavation such as a subterranean level for parking, or other uses, that would involve an unsupported slope and therefore the risk associated with lateral spreading would be low. However, the findings of the required geotechnical study would address any concerns from hazards due to lateral spreading.

Furthermore, the proposed project would be subject to compliance with the CBC, which is adopted with modifications by the City in Municipal Code Article I, Building Code, of Chapter 8, Buildings. The CBC provides minimum standards to protect property and the public welfare and safety by regulating the design and construction of excavations, foundations, building frames, retaining walls, and other building elements to mitigate the effects of seismic shaking and adverse soil conditions. The CBC contains provisions for earthquake safety based on factors including occupancy type, the types of soil and rock on-site, and the strength of ground motion with a specified probability of occurring at the site. Also, the CBC requires the preparation of project-specific geotechnical/engineering reports by a certified engineering geologist and/or geotechnical engineer prior to construction of proposed structures. The proposed project would be required to comply with the recommendations in these reports. Any structures built for the proposed project would adhere to the most recent version of the CBC. 2 City of Mountain View, 2012, Draft 2030 General Plan and Greenhouse Gas Reduction Program Environmental Impact Report, State Clearinghouse No. 2011012069, page 345.

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The proposed project involves on-site construction activities and development of new structures on a site with existing seismic and soils hazards. In addition, the proposed project involves an increase in the occupancy of the project site (due to the proposed increase in onsite employment), which would expose additional people to these existing hazards when compared to existing conditions. Because no site-specific geotechnical study has been prepared for the project, impacts are considered significant without mitigation.

Impact GEO-1: The construction activities, increased site occupancy, and development of new structures under the proposed project could exacerbate an existing hazard associated with liquefaction due to seismic events.

Mitigation Measure GEO-1: Prior to the issuance of building permits, the project sponsor shall retain the services of a certified engineering geologist and/or geotechnical engineer to prepare a site-specific geotechnical study based on the most recent draft of the conceptual site plans. The geotechnical study shall address, but is not limited to, the effects of seismically induced liquefaction, and include recommendations to ensure any potential hazards related to the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction would not occur. The geotechnical study shall be approved by the City of Mountain View's Building Inspection Department prior to the issuance of building permits.

Significance with Mitigation: Less than significant.
b) Would the project 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? As described in impact discussion (a), the project site is in a seismically active area, as is much of California, and on a site with known liquefaction hazards. Due to the low relief of the on- and off-site topography, earthquake-induced slope stability is not an issue on the project site.

Further, the proposed project would not include any subterranean levels and, as such, no deep excavation would occur. Accordingly, impacts associated with lateral spreading or subsidence, would not be an issue.

Implementation of Mitigation Measure GEO-1 requires the preparation of a project-specific geotechnical/engineering reports by a certified engineering geologist and/or geotechnical engineer prior to construction of proposed structures to ensure that any effects due to unstable soils would be mitigated to a less-than-significant level. As described under impact discussion (a), the proposed project involves on-site construction activities, development of new structures, and an increase in site occupancy that would expose additional people to existing liquefaction hazards. Without mitigation, this impact would be considered significant.

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Impact GEO-2 The construction activities, development, increased site occupancy involved in the proposed project could exacerbate an existing hazard associated with unstable soils due to seismically induced liquefaction.

Mitigation Measure GEO-2: Implement Mitigation Measure GEO-1.

Significance with Mitigation: Less than significant.

4.4.5 Cumulative Impact Analysis
The cumulative setting includes the projects listed in Table 4-1, Cumulative Projects List, in Chapter 4, Environmental Analysis. As discussed previously, construction and operation of the proposed project would not result in significant impacts related to geology and soils with implementation of Mitigation Measure GEO-1 and GEO-2. Although the project site and surrounding area include some hazards due to liquefaction soils, mandatory compliance with CBC and the Municipal Code would ensure these impacts would be addressed through sitespecific development requirements.

Cumulative development on the sites listed in Table 4-1 would be subject to the same regulations as the proposed project. Because impacts associated with geology and soils are by their nature focused on specific sites or areas, the less-than-significant impacts with implementation of Mitigation Measure GEO-1 and GEO-2 to avoid seismically induced hazards, and impacts from the proposed project would not contribute to a cumulative increase in hazards in the project vicinity or greater Mountain View area. Therefore, cumulative impacts associated with geology and soils would be less than significant.

Significance without Mitigation: Less than significant.

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4.5 GREENHOUSE GAS EMISSIONS
This section of the Draft Environmental Impact Report (EIR) evaluates the potential for the adoption and implementation of the proposed project to impact greenhouse gas (GHG) emissions in a local and regional context. Because no single project is large enough to result in a measurable increase in global concentrations of GHG, climate change impacts of a project are considered on a cumulative basis based on the GHG emissions reduction goals identified in the California Air Resources Board’s (CARB) 2022 Scoping Plan.

Modeling data is included in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft Environmental Impact Report (EIR).

Environmental Setting

TERMINOLOGY
The following are definitions for terms used throughout this chapter.  Greenhouse gases (GHG). Gases in the atmosphere that absorb infrared light, thereby retaining heat in the atmosphere and contributing to a greenhouse effect.  Global warming potential (GWP). Metric used to describe how much heat a molecule of a GHG absorbs relative to a molecule of carbon dioxide (CO2) over a given period of time (20, 100, and 500 years). CO2 has a GWP of 1.
 Carbon dioxide-equivalent (CO2e). The standard unit to measure the amount of GHGs in terms of the amount of CO2 that would cause the same amount of warming. CO2e is based on the GWP ratios between the various GHGs relative to CO2.  MTCO2e. Metric ton of CO2e.
 MMTCO2e. Million metric tons of CO2e.

GREENHOUSE GASES AND CLIMATE CHANGE
Scientists have concluded that human activities are contributing to global climate change by adding large amounts of heat-trapping gases, known as GHGs, to the atmosphere. The primary source of these GHGs is fossil fuel use. The Intergovernmental Panel on Climate Change (IPCC) has identified four major GHGs—water vapor, carbon dioxide (CO2), methane (CH4), and ozone (O3)—that are the likely cause of an increase in global average temperatures observed in the 20th and 21st centuries. Other GHGs identified by the IPCC that contributes to global warming to a lesser extent are nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons,

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perfluorocarbons, and chlorofluorocarbons.1,2,3 The major GHGs applicable to the proposed project are briefly described herein.
 Carbon dioxide (CO2) enters the atmosphere through the burning of fossil fuels (i.e., oil, natural gas, and coal), solid waste, trees and wood products, and respiration, and also as a result of other chemical reactions (e.g., manufacture of cement). Carbon dioxide is removed from the atmosphere (i.e., sequestered) when it is absorbed by plants as part of the biological carbon cycle.
 Methane (CH4) is emitted during the production and transport of coal, natural gas, and oil.

Methane emissions also result from livestock and other agricultural practices and from the decay of organic waste in landfills and water treatment facilities.  Nitrous oxide (N2O) is emitted during agricultural and industrial activities as well as during the combustion of fossil fuels and solid waste.

GHGs are dependent on the lifetime, or persistence, of the gas molecule in the atmosphere.

Some GHGs have stronger greenhouse effects than others. These are referred to as high GWP gases. The GWP is used to convert GHGs to CO2-equivalence (CO2e) to show the relative potential that different GHGs have to retain infrared radiation in the atmosphere and contribute to the greenhouse effect. For example, under the IPCC Fifth Assessment Report (AR5) GWP values for CH4, 10 MT of CH4 would be equivalent to 280 MT of CO2.

4.5.1 Regulatory Background

FEDERAL
The U.S. Environmental Protection Agency (USEPA) announced on December 7, 2009, that GHG emissions threaten the public health and welfare of the American people and that GHG emissions from on-road vehicles contribute to that threat. The USEPA’s final findings respond to the 2007 U.S. Supreme Court decision that GHG emissions fit within the Clean Air Act definition 1 Intergovernmental Panel on Climate Change, 2001, Third Assessment Report: Climate Change 2001, New York: Cambridge University Press.
2 Water vapor (H2O) is the strongest GHG and the most variable in its phases (vapor, cloud droplets, ice crystals); however, water vapor is not considered a pollutant because it is considered part of the feedback loop rather than a primary cause of change. 3 Black carbon contributes to climate change both directly, by absorbing sunlight, and indirectly, by depositing on snow (making it melt faster) and by interacting with clouds and affecting cloud formation. Black carbon is the most strongly lightabsorbing component of particulate matter (PM) emitted from burning fuels such as coal, diesel, and biomass. The share of black carbon emissions from transportation is dropping rapidly and is expected to continue to do so between now and 2030 as a result of California’s air quality programs. The remaining black carbon emissions will come largely from woodstoves/fireplaces, off-road applications, and industrial/commercial combustion (CARB, December 2022, 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf). However, State and national GHG inventories do not include black carbon due to ongoing work resolving the precise global warming potential of black carbon. Guidance for CEQA documents does not yet include black carbon.

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of air pollutants. The findings do not impose any emission reduction requirements but allowed the USEPA to finalize the GHG standards proposed in 2009 for new light-duty vehicles as part of the joint rulemaking with the Department of Transportation.4 To regulate GHGs from passenger vehicles, the USEPA was required to issue an endangerment finding.5 The finding identified emissions of six key GHGs—CO2, CH4, N2O, hydrofluorocarbons, perfluorocarbons, and SF6—that have been the subject of scrutiny and intense analysis for decades by scientists in the United States and around the world. The first three are applicable to the proposed project’s GHG emissions inventory because they constitute the majority of GHG emissions and, according to guidance by the Bay Area Air District (Air District), are the GHG emissions that should be evaluated as part of a project’s GHG emissions inventory.

US Mandatory Report Rule for GHGs (2009)
In response to the endangerment finding, the USEPA issued the Mandatory Reporting of GHG Rule that requires substantial emitters of GHG emissions (e.g., large stationary sources) to report GHG emissions data. Facilities that emit 25,000 MT or more of CO2e per year are required to submit an annual report.

Update to Corporate Average Fuel Economy Standards (2017 to 2026) The federal government issued new Corporate Average Fuel Economy (CAFE) standards in 2012 for vehicle model years 2017 to 2025, requiring a fleet average of 54.5 miles per gallon (MPG) in 2025. However, on March 30, 2020, the USEPA finalized updated CAFE and GHG emissions standards for passenger cars and light trucks, covering model years 2021 through 2026, known as the Safer Affordable Fuel Efficient (SAFE) Vehicles Final Rule for Model Years 2021 to 2026.

Under SAFE, the fuel economy standards will increase 1.5 percent per year compared to the 5 percent per year under the CAFE standards established in 2012. Overall, SAFE requires a fleet average of 40.4 MPG for model year 2026 vehicles (85 Federal Register 24174 (April 30, 2020)).

On December 21, 2021, under the direction of Executive Order (EO) 13990 issued by President Biden, the National Highway Traffic Safety Administration (NHTSA) repealed SAFE Vehicles Rule Part One, which had preempted state and local laws related to fuel economy standards. In addition, the NHTSA announced new proposed fuel standards on March 31, 2022. Fuel efficiency under the new standards proposed will increase 8 percent annually for model years 2024 to 2025 and 10 percent for model year 2026. Overall, the new CAFE standards require a 4 US Environmental Protection Agency, December 2009, EPA: Greenhouse Gases Threaten Public Health and the Environment:

Science Overwhelmingly Shows Greenhouse Gas Concentrations at Unprecedented Levels due to Human Activity, https://archive.epa.gov/epapages/newsroom_archive/newsreleases/08d11a451131bca585257685005bf252.html 5 US Environmental Protection Agency, 2009, USEPA: Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act, https://www.epa.gov/climate-change/endangerment-and-cause-or-contributefindings-greenhouse-gases-under-section-202a.

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fleet average of 49 MPG for passenger vehicles and light trucks for model year 2026, which would be a 10 MPG increase relative to model year 2021. 6 STATE
Current State of California guidance and goals for reductions in GHG emissions are generally embodied in EO S-03-05, EO B-30-15, EO B-55-18, Assembly Bill (AB) 32, AB 1279, Senate Bill (SB) 32, and SB 375.

Executive Order S-03-05
EO S-03-05 was signed June 1, 2005, and set the following GHG reduction targets for the State:2000 levels by 2010, 1990 levels by 2020, and 80 percent below 1990 levels by 2050.

Assembly Bill 32, the Global Warming Solutions Act (2006) AB 32 was passed by the California State legislature on August 31, 2006, to place the state on a course toward reducing its contribution of GHG emissions. AB 32 follows the 2020 tier of emissions reduction targets established in EO S-03-05. CARB prepared the 2008 Scoping Plan to outline a plan to achieve the GHG emissions reduction targets of AB 32.

Executive Order B-30-15
EO B-30-15, signed April 29, 2015, set a goal of reducing GHG emissions in the state to 40 percent of 1990 levels by year 2030. EO B-30-15 also directed CARB to update the Scoping Plan to quantify the 2030 GHG reduction goal for the State and requires State agencies to implement measures to meet the interim 2030 goal as well as the long-term goal for 2050 in EO S-03-05. It also requires the Natural Resources Agency to conduct triennial updates of the California adaption strategy, Safeguarding California, in order to ensure climate change is accounted for in State planning and investment decisions.

Senate Bill 32 and Assembly Bill 197
In September 2016, SB 32 and AB 197 were signed into law, making the EO goal for year 2030 into a statewide mandated legislative target. AB 197 established a joint legislative committee on climate change policies and requires CARB to prioritize direct emissions reductions rather than the market-based cap-and-trade program for large stationary, mobile, and other sources. 6 National Highway Traffic Safety Administration, April 2022, USDOT Announces New Vehicle Fuel Economy Standards for Model year 2024-2026, https://www.nhtsa.gov/press-releases/usdot-announces-new-vehicle-fuel-economy-standards-modelyear-2024-2026, accessed May 20, 2024.

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Executive Order B-55-18
EO B-55-18, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.” EO B-55-18 directs CARB to work with relevant State agencies to ensure future scoping plans identify and recommend measures to achieve the carbon neutrality goal. The goal of carbon neutrality by 2045 is in addition to other State goals, meaning not only should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045, the remaining emissions be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.

Assembly Bill 1279
AB 1279, signed in September 2022, codifies the carbon neutrality targets of EO B-55-18 for year 2045 and sets a new legislative target for year 2045 of 85 percent below 1990 levels for anthropogenic GHG emissions. CARB was required to update the Scoping Plan to identify and recommend measures to achieve the net-zero and GHG emissions-reduction goals. 2022 Climate Change Scoping Plan
CARB adopted the 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) on December 15, 2022, which lays out a path to achieve carbon neutrality by 2045 or earlier and to reduce the state’s anthropogenic GHG emissions.7 The Scoping Plan was updated to address the carbon neutrality goals of EO B-55-18 and the ambitious GHG reduction target as directed by AB 1279. Previous scoping plans focused on specific GHG reduction targets for industrial, energy, and transportation sectors—to meet 1990 levels by 2020, and then the more aggressive 40 percent below that for the 2030 target. This Plan expands upon earlier scoping plans with a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. Carbon neutrality takes it one step further by expanding actions to capture and store carbon, including through natural and working lands and mechanical technologies, while drastically reducing anthropogenic sources of carbon pollution at the same time. The path forward was informed by the recent IPCC AR6; the measures would achieve 85 percent below 1990 levels by 2045 in accordance AB 1279.

Senate Bill 375
SB 375, the Sustainable Communities and Climate Protection Act, was adopted in 2008 to connect the GHG emissions reduction targets established in the 2008 Scoping Plan for the transportation sector to local land use decisions that affect travel behavior. Its intent is to reduce GHG emissions from light-duty trucks and automobiles (i.e., excluding emissions 7 California Air Resources Board, December 2022, 2022 Scoping Plan for Achieving Carbon Neutrality, https://ww2.arb.ca.gov/sites/default/files/2023-04/2022-sp.pdf.

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associated with goods movement) by aligning regional long-range transportation plans, investments, and housing allocations to local land use planning to reduce VMT and vehicle trips.

Specifically, SB 375 required CARB to establish GHG emissions reduction targets for each of the 18 metropolitan planning organizations (MPO). The Metropolitan Transportation Commission (MTC) is the MPO for the Bay Area region, which includes the City of Mountain View. Pursuant to the recommendations of the Regional Transportation Advisory Committee, CARB adopted per capita reduction targets for each of the MPOs rather than a total magnitude reduction target.

CARB is required to update the targets for the MPOs every eight years. In June 2017, CARB released updated targets and technical methodology, and then released another update in February 2018, which became effective in October 2018. CARB adopted the updated targets and methodology on March 22, 2018. All SCSs adopted after October 1, 2018, are subject to these new targets. The updated targets consider the need to further reduce VMT, as identified in the 2017 Scoping Plan Update, while balancing the need for additional and more flexible revenue sources to incentivize positive planning and action toward sustainable communities.

The updated SB 375 targets are in units of percent per capita reduction in GHG emissions from automobiles and light trucks compared to 2005. This excludes reductions anticipated from implementation of State technology and fuels strategies and any potential future State strategies such as statewide road user pricing. The updated targets call for greater per-capita GHG emission reductions from SB 375 than were currently in place, which for 2035 translates into updated targets that either match or exceed the emission reduction levels in the MPOs’ currently adopted SCSs. CARB’s updated targets result in an additional reduction of over 8 MMTCO2e in 2035 compared to the prior targets.8
Transportation Sector Specific Regulations
Advanced Clean Fleets and Advanced Clean Trucks
CARB adopted the Advanced Clean Fleets (ACF) regulation in 2023 to accelerate the transition to zero-emission medium- and heavy-duty vehicles. In conjunction with the Advanced Clean Trucks (ACT) regulation, the ACF regulations helps to ensure that medium- and heavy-duty ZEVs are brought to the market, by requiring certain fleets to purchase ZEVs. The ACF ZEV phase-in approach provides initial focus where the best fleet electrification opportunities exist, sets clear targets for regulated fleets to make a full conversion to ZEVs, and creates a catalyst to accelerate development of a heavy-duty public charging infrastructure network.

Assembly Bill 1493
California vehicle GHG emission standards were enacted under AB 1493 (Pavley I). Pavley I is a clean-car standard that reduces GHG emissions from new passenger vehicles (light-duty auto to 8 California Air Resources Board, February 2018, Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets. https://ww2.arb.ca.gov/sites/default/files/2020-06/SB375_Updated_Final_Target_Staff_Report_2018.pdf.

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medium-duty vehicles) from 2009 through 2016 and was anticipated to reduce GHG emissions from new passenger vehicles by 30 percent in 2016. California implements the Pavley I standards through a waiver granted to California by the USEPA. In 2012, the USEPA issued a Final Rulemaking that set even more stringent fuel economy and GHG emissions standards for model years 2017 through 2025 light-duty vehicles. (See also the discussion in federal regulations under “Update to Corporate Average Fuel Economy Standards [2017 to 2026].”) In January 2012, CARB approved the Advanced Clean Cars program (formerly known as Pavley II) for model years 2017 through 2025. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of ZEVs into a single package of standards. Under California’s Advanced Clean Car program, by 2025 new automobiles will emit 34 percent less GHG emissions and 75 percent less smog-forming emissions.

Executive Order S-01-07
On January 18, 2007, the State set a new low carbon fuel standard (LCFS) for transportation fuels sold in the state. EO S-01-07 set a declining standard for GHG emissions measured in CO2e gram per unit of fuel energy sold in California. The LCFS required a reduction of 2.5 percent in the carbon intensity of California’s transportation fuels by 2015 and a reduction of at least 10 percent by 2020. The standard applied to refiners, blenders, producers, and importers of transportation fuels, and used market-based mechanisms to allow these providers to choose the most economically feasible methods for reducing emissions during the “fuel cycle.” Executive Order B-16-2012
On March 23, 2012, the State directed CARB, the California Energy Commission (CEC), the Public Utilities Commission, and other relevant agencies to work with the Plug-in Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to accommodate ZEVs in major metropolitan areas, including infrastructure to support them (e.g., EV charging stations). EO B-16-2012 also directed the number of ZEVs in California’s State vehicle fleet to increase through the normal course of fleet replacement so that at least 10 percent of fleet purchases of light-duty vehicles are ZE by 2015 and at least 25 percent by 2020. The EO also established a target for the transportation sector of reducing GHG emissions to 80 percent below 1990 levels.

Executive Order N-79-20
On September 23, 2020, Governor Newsom signed EO N-79-20, establishing a goal that 100 percent of in-state sales of new passenger cars and trucks will be ZE by 2035. Additionally, the fleet goals for trucks are that 100 percent of drayage trucks are ZE by 2035, and 100 percent of medium- and heavy-duty vehicles in the state are ZE by 2045, where feasible. The EO’s goal for the State is to transition to 100 percent ZE off-road vehicles and equipment by 2035, where feasible.

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Mountain View City CouncilNovember 4, 2025

Mountain View City Council
November 4, 2025