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conservation and requires new buildings to reduce water consumption by twenty percent through more water efficient plumbing fixtures and fittings. The mandatory provisions of the California Green Building Code Standards became effective January 1, 2011. The building efficiency standards are enforced through the local building permit process.
General Waste Discharge Requirement
On May 2, 2006, the SWRCB adopted a General Waste Discharge Requirement (Order No. 2006-0003) for all publicly owned sanitary sewer collection systems in California with more than one mile of sewer pipe. The order provides a consistent statewide approach to reducing sanitary sewer overflows (SSOs) by requiring public sewer system operators to take all feasible steps to control the volume of waste discharged into the system, to prevent sanitary sewer waste from entering the storm sewer system, and to develop a Sewer System Management Plan (SSMP). The General Waste Discharge Requirement also requires that storm sewer overflows be reported to the SWRCB using an online reporting system. The SWRCB has delegated authority to nine Regional Water Quality Control Boards to enforce these requirements within their region. The City of Pacifica is within the jurisdiction of the San Francisco Regional Water Quality Control Board (SFRWQCB).
California Integrated Waste Management Act
The California Integrated Waste Management Act, also known as AB 939 requires cities and counties to divert fifty percent of solid waste from landfills beginning in 2000 and each year thereafter through source reduction, composting, and recycling, with the highest priority given to source reduction, which is defined as the reduction of solid waste generation. The Act requires that cities and counties identify ways in which they will achieve reductions in an integrated waste management plan (IWMPs) that is also required to include a Source Reduction and Recycling Element. These elements are designed to develop recycling services to achieve diversion goals, stimulate local recycling in manufacturing, and stimulate the purchase of recycled products.
Solid Waste Disposal Measurement System Act
The Solid Waste Disposal Measurement System Act, also known as SB 1016, amends the California Integrated Waste Management Act compliance requirements for measuring and reporting fifty percent solid waste diversion requirements. Beginning in 2009, the Act requires that diversion rates be measured in terms of per-capita disposal expressed as pounds per person per day. Every year CalRecycle calculates each jurisdiction’s per capita (per resident and per employee) disposal rates and reviews jurisdiction compliance on a
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case-by-case basis. Jurisdictions are not compared to other jurisdictions or the statewide average but compared to their own fifty percent per capita disposal target.
Senate Bill 1383
As described in Section 3.7, Greenhouse Gas Emissions, SB 1383 was signed in September 2016 to reduce emissions of short-lived climate pollutants. As it pertains to CalRecycle, SB 1383 establishes targets to achieve a fifty percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2020 and a seventy-five percent reduction by 2025. The law grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than twenty percent of currently disposed edible food is recovered for human consumption by 2025. SB 1383 further supports California’s efforts to achieve the statewide seventy-five percent recycling goal by 2020 established in AB 341.
Local
North Coast County Water District 2020 Urban Water Management Plan The NCCWD delivers water to residential, commercial, and governmental customers in the City of Pacifica and purchases all its potable water supplies from the San Francisco Public Utilities Commission. As noted in the 2020 Urban Water Management Plan (UWMP), adopted June 2021, the NCCWD serves approximately 12,260 water connections within its service area. In addition, the NCCWD provides recycled water for landscape irrigation users. The intent of the UWMP is to provide a long-range planning document for water supply and system planning as well as provide data on population, housing, water supply and demand, and capital improvement projects identified at the state, regional, and local levels.
San Mateo Countywide Integrated Waste Management Plan
The San Mateo Countywide Integrated Waste Management Plan adopted January 8, 1999 serves as the IWMP for all jurisdictions in San Mateo County, including Pacifica. Consistent with the requirements of the California Integrated Waste Management Act, the Plan includes a Source Reduction Recycling Element and Household Hazards Waste Element. The IWMP identifies goals, objectives, and policies that are intended to document progress toward the 25 and 50 percent diversion rates, educate the public on the intent of the Plan, increase awareness and participation in diversion programs, seek high participation in recycling and composting programs, and increase diversion programs in the commercial sector. The most recent available five-year review of the county’s IWMP is from 2014 and identifies that the
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Plan remains adequate. Subsequently, in 2019, the San Mateo County Grand Jury issued findings and recommendations related to the IWMP, concluding the San Mateo County Office of Sustainability should replace the existing 1999 Countywide Integrated Waste Management Plan, including the Summary Plan, landfill Siting Element, and Non-Disposal Facilities Element with a revised plan by January 1, 2021. As of the writing of this report, an updated Plan has not been prepared.
San Mateo Countywide Water Pollution Prevention Program The San Mateo County Water Pollution Prevention Program (SMCWPPP) was established in 1990 with the assistance of the San Mateo County City/County Association of Governments.
The primary goal of the SMCWPPP is to reduce pollution carried by stormwater throughout San Mateo County into local creeks, San Francisco Bay, and the Pacific Ocean, and to maintain compliance with the NPDES permit. The program is managed and maintained by San Mateo County and the 20 participating cities, including Pacifica.
Pacifica Municipal Code
Title 6 (Sanitation and Health), Chapter 5 (Garbage, Collection, and Recycling) of the Pacifica Municipal Code sets forth regulations related to solid waste and recycling including collection, recyclable materials, recycling spaces required in development projects, and mandatory organic waste disposal requirements, among others. Title 6, Chapter 13 (Wastewater Control), Article 2 (Regulation of Wastewater Discharges) sets forth permissible and prohibited discharges to the sewer system. Title 8 (Building Regulations), Chapter 7 (Green Building Code) specifies that the requirements of the California Department of Water Resources Model Water Efficient Landscape Ordinance (MWELO) shall apply.
4.14.2 Environmental Setting
Water Supply Services
As previously discussed, the City of Pacifica, receives water from the NCCWD who delivers water to residential, commercial, and governmental customers and purchases all its potable water supplies from the San Francisco Public Utilities Commission (SFPUC) Regional Water System (RWS). Water distribution, water conservation, and maintenance of water quality are the NCCWD’s main water resource functions, as treated water purchased from the SFPUC RWS does not require further water treatment. Additionally, the NCCWD serves recycled water to customers for landscape irrigation via its recycled water system. NCCWD is a special district and a separate agency from the City of Pacifica.
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Wastewater
Sewer utilities for the proposed project would be provided by the City of Pacifica. The City operates a wastewater treatment and recycling plant, sewage lift stations, and stormwater pump stations, as well as the citywide system of sewer mains and lateral pipes that connect to homes and businesses. Wastewater flows through approximately 82 miles of main pipes to six sewer pump stations and then to the Calera Creek Water Recycling Plant (CCWRP), located at 700 Coast Highway. The CCWRP can treat 4 million gallons of sewage per day, and up to 20 million gallons per day during storm events.
On May 11, 2011 the Regional Water Quality Control Board issued Cease and Desist Order No. R2-2011-00311 which required the City to eliminate insufficient capacity-caused Sanitary Sewer Overflows from the sanitary sewer collection system. To comply with the Cease and Desist Order, the City of Pacifica constructed a 2.1 million gallon wet weather flow Equalization Basin, which is intended to avoid the occurrence of sewer overflows during the rainy season.
Stormwater
Pacifica’s storm drainage system consists of a collection system and two pump stations. This drainage system conveys drainage to area creeks or the ocean. Two areas in the City, Linda Mar and lower Sharp Park, are too low to allow drainage to a creek or the ocean, and are served by pump stations to prevent street flooding. The Streets Division of Pacifica's Public Works Department maintains 290,000 linear feet of storm drain pipes with 989 storm drain inlets within the City right-of-way and easements.
2 In 2004, the City completed the Pacifica
State Beach Improvement Project, a complex initiative requiring the cooperation of many agencies and funding sources. Among the project’s key elements was the diversion of stormwater from the City’s pump stations to two constructed wetland treatment swales. The project has successfully redirected polluted water from first-flush release into the ocean, resulting in improved water quality.
Solid Waste
Solid waste collection and recycling services in Pacifica are provided by Recology of the Coast, a division of Recology. Based in San Francisco, Recology operates a number of landfills, waste 1 San Francisco Regional Water Quality Control Board, Revised Tentative Order, Amendment of Cease and Desist Order for City of Pacifica Calera Creek Water Recycling Plant and Wastewater Collection System in Pacifica, San Mateo County 2 City of Pacifica, Departments, Public Works, Streets, Storm Drains:
https://www.cityofpacifica.org/depts/pw/field_services/streets/storm_drains.asp, accessed April 2022.
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transfer and materials recovery facilities throughout the Bay Area, including the recycling yard at 1046 Palmetto Avenue in Pacifica and the Ox Mountain Landfill, located east of the City of Half Moon Bay in unincorporated San Mateo County. Recology emphasizes waste reduction and diversion and is the largest compost facility operator by volume in the United States. In Pacifica, Recology of the Coast currently provides curbside pick-up of garbage, recyclables, and green waste for both residential and commercial customers. In 2009, the City Council adopted Ordinance No. 767 which is codified in Title 6, Chapter 5, Article 4 and enacted an ordinance requiring all food vendors to use biodegradable or compostable service ware. Both Pacifica and San Mateo County provide information to help residents and businesses reduce and divert waste from landfills.
Gas and Electricity
Peninsula Clean Energy is a community-led electricity provider serving San Mateo County.
Peninsula Clean Energy provides 100 percent carbon-free energy with a goal of being 100 percent renewable by 2025 at lower prices than PG&E and invests proceeds back into the community. Peninsula Clean Energy is a California Community Choice Aggregation (CCA) organization and provides flexibility and local control to use innovative options for purchasing and generating electricity for residents and businesses. Customers have two options including the default option, Ecoplus which has lower rates and nearly double the percentage of renewable energy as compared to PG&E, and ECO100, which is 100 percent renewable energy. A variety of resource types, including solar, wind, geothermal, and hydro are procured by Peninsula Clean Energy from a variety of sources.
Pacific Gas & Electric (PG&E) also provides gas and electric services to Pacifica homes and businesses, with energy obtained from power plants, natural gas fields, and renewable energy sources in northern California. One natural gas transmission line feeds into the City.
4.14.3 Thresholds of Significance
According to the CEQA Guidelines Appendix G, the proposed project would result in a significant impact related to utilities and service systems if it would:
1. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
2. Not have sufficient water supplies available to serve the project and reasonably
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foreseeable future development during normal, dry and multiple dry years.
3. Result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.
4. Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.
5. Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.
4.14.4 Analysis, Impacts, and Mitigation Measures
Impact UTIL-1: Implementation of the proposed project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects (less than significant impact).
Water, wastewater treatment, storm water drainage, electric power, natural gas, and telecommunications services will be provided to the project by way of connection to existing infrastructure in the vicinity of the project site. Water service would be provided by the NCCWD, wastewater treatment and storm water drainage would be provided by the City of Pacifica, and electricity would be provided by Peninsula Clean Energy or PG&E. A variety of private entities provide telecommunications services in the City of Pacifica.
Water
Potable water is provided by the NCCWD by way of the SFPUC RWS, which is obtained by the treatment of water at the Harry Tracy Water Treatment Plant (HTWTP) in San Bruno. This facility has been recently improved to enhance the plant’s treatment capacity by including seismic retrofits and electrical upgrades. The improved facility has the capacity to provide 140 million gallons of water per day (MGD) for 60 days within 24 hours of a major earthquake.
3 As discussed further below, the water demand generated by project residents of 4.74 MG per year would be relatively minimal to the overall capacity of the facility and the water demand projections identified in the 2020 UWMP. Additionally, as previously noted 3 The Harry Tracy Water Treatment Plant, Fact Sheet 2017.
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the project will connect proposed onsite water laterals to existing water connections.
Therefore, the project would not require relocation or further expansion of existing water facilities and impacts of the project would be less than significant.
Wastewater treatment
The City of Pacifica’s CCWRP treats wastewater within the city and can provide advancedtertiary treatment for an average daily dry weather design flow of 4.0 MGD and a peak wet weather discharge capacity of 20 MGD, as discussed in Section 4.14.2. Additionally, the City has constructed a 2.1-million-gallon wet weather equalization basin approximately two miles upstream of the headworks to avoid the occurrence of sewer overflows during the rainy season. As such, adequate capacity is available to serve the increase in demand resulting from the proposed project impacts of the project would be less than significant.
Storm water drainage
The proposed project is not expected to significantly increase runoff relative to the existing condition since the site will be improved with an onsite storm drain system that conveys runoff to the existing storm drain system, consistent with the storm water requirements set forth in Title 6, Chapter 12 of the City’s Municipal Code, San Mateo Countywide Water Pollution Prevention Program, and as required by the Municipal Regional Stormwater Permit. These regulations require that storm water on a project site be detained and treated before release to the off-site city storm water system, which will result in an equivalent or reduced amount of storm water discharges from the project site. Through compliance with applicable regulations and standard conditions of approval, the project is will result in less than significant impacts due to the expansion of existing storm water drainage facilities or construction of new facilities.
Natural gas, electric, and telecommunications
Electricity, natural gas, and telecommunications utilities would be provided via connections to existing infrastructure located within the immediate project vicinity. The project would not necessitate major upgrades to, or extension of, existing natural gas, electric and telecommunications infrastructure and as such impacts of the project will be less than significant.
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Impact UTIL-2: Implementation of project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years (less than significant impact).
In accordance with the SFPUC’s perpetual obligation to the NCCWD’s Supply Assurance, the NCCWD has a water supply, known as an Individual Supply Guarantee (ISG) of 3.84 MGD, or 1,402 million gallons (MG) per year. The SFPUC is obligated to provide NCCWD with up to 100 percent of the District’s ISG during normal years. The population served by the NCCWD is closely represented by the population within the boundaries of the City of Pacifica. According to the 2020 Urban Water Management Plan, the NCCWD is estimated to have excess capacity to serve the City through the year 2045 during normal years, as shown in Table 4.14-1. The UWMP estimates a daily usage of 65 gallons per capita per day (GPCD), which is based on water use for the District in 2020. The project proposes to construct 70 residential units.
Based on an average household size of 2.86 persons4, the estimated daily water usage by project residents (approximately 200 persons) would be 4.74 MG per year, which can be accommodated within the water supply available through the year 2045 during normal years.
TABLE 4.14-1: NORMAL YEAR WATER SUPPLY AND DEMAND COMPARISON5 2025
(in MG)
2030
(in MG)
2035
(in MG)
2040
(in MG)
2045
(in MG)
Supply Total 1,411 1,411 1,411 1,411 1,411
Demand Total 855 838 827 826 828
Difference 556 572 584 585 583
Note: Supplies and demand include potable and recycled water with 1,402 MG in potable water supply and projected recycled water demand, represented in MG for each year.
During single or multiple dry years, the yield of water supply would be considerably less. The 2020 UMWP includes projected supply and demand totals for the single dry year, assuming implementation of the Bay Delta Plan Amendment6, which would require rationing of water 4 2015-2019 American Community Survey, U.S. Census Bureau 5 North Coast County Water District, 2020 UWMP, Table 7-4, page 99 6 In December 2018, the State Water Resources Control Board (SWRCB) adopted amendments to the Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary (Bay-Delta Plan Amendment) to establish water quality objectives to maintain the health of the Bay-Delta ecosystem. The SWRCB is required by law to regularly review this plan. The adopted Bay-Delta Plan Amendment was developed with the stated goal of increasing salmonid populations in three San Joaquin River tributaries (the Stanislaus, Merced, and Tuolumne Rivers) and the Bay-Delta. The Bay-Delta Plan Amendment requires the release of 30-50% of the “unimpaired flow” on the three tributaries from February through June in every year
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supply, as well as without implementation of the Bay-Delta Amendment, referred to as Scenario 2. Single dry year supply and demand for each scenario are shown in the tables below.
TABLE 4.14-2: SINGLE DRY YEAR WATER SUPPLY AND DEMAND COMPARISON (BAY-DELTA PLAN AMENDMENT)
7 2025
(in MG)
2030
(in MG)
2035
(in MG)
2040
(in MG)
2045
(in MG)
Supply Total 552 549 552 552 476
Demand Total 855 838 827 826 828
Difference -303 -289 -274 -273 -352
TABLE 4.14-3: SINGLE DRY YEAR WATER SUPPLY AND DEMAND COMPARISON (WITHOUT BAY-DELTA PLAN AMENDMENT)
8 2025
(in MG)
2030
(in MG)
2035
(in MG)
2040
(in MG)
2045
(in MG)
Supply Total 863 863 863 863 863
Demand Total 855 838 827 826 828
Difference 8 25 36 37 35
According to the 2020 UWMP, implementation of the Bay-Delta Plan Amendment will require rationing in all single dry years and multiple dry years. The SFPUC has initiated an Alternative Water Supply Planning Program (AWSP) to ensure that San Francisco can meet its Retail and Wholesale Customer water needs, address projected dry years shortages, and limit rationing to a maximum 20 percent system-wide in accordance with adopted SFPUC policies. This program is in early planning stages and is intended to meet future water supply challenges and vulnerabilities such as environmental flow needs and other regulatory changes; earthquakes, disasters, and emergencies; increases in population and employment; and climate change. As the region faces future challenges – both known and unknown – the SFPUC is considering this suite of diverse nontraditional supplies and leveraging regional partnerships to meet Retail and Wholesale Customer needs through 2045. With implementation of the impending AWSP water supply programs, as well as the minimal type. In SFPUC modeling of the new flow standard, it is assumed that the required release is 40% of unimpaired flow. 7 North Coast County Water District, 2020 UWMP, Table 7-5, page 99 8 North Coast County Water District, 2020 UWMP, Table 7-6, page 100
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increase in water demand, the project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years and impacts of the project would be less than significant.
Impact UTIL-3: Implementation of the project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments (less than significant impact).
The City of Pacifica is the wastewater treatment provider for the project. The existing Calera Creek Water Recycling Plant has sufficient capacity to serve additional wastewater generated by the project. Furthermore, the City’s equalization basin provides for additional capacity to avoid the occurrence of sewer overflows during the rainy season. As such, existing wastewater treatment facility capacity is sufficient to serve the project’s projected demand and impacts of the project would be less than significant.
Impact UTIL-4: Implementation of the project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals (less than significant impact).
As previously discussed, solid waste collection services, including curbside pick-up of garbage, recyclables, and green waste within the City of Pacifica are provided by Recology of the Coast, a Division of Recology. Solid waste is disposed of at the Ox Mountain Landfill, and is planned for closure in 2034. As of 2015, the Ox Mountain Landfill had 22,180,000 cubic yards of remaining available capacity, or approximately 36.7 percent of the facility’s maximum permitted capacity of 60,500,000 cubic yards9.
The City of Pacifica Climate Action Plan10 addresses solid waste by setting a goal to achieve 75 percent diversion community-wide (which would include the project) by 2020. This goal includes programmatic actions that include increasing participation in recycling programs and ensuring weekly collection of recyclables and organic waste. To achieve this, Pacifica approved a new solid waste management contract with Recology of the Coast in 2016 to establish comprehensive commercial and residential recycling, compost, and solid waste management programs. Additionally, Recology continues to implement and promote resource recovery to reduce the amount of waste that is placed in a landfill, with the overall 9 CalRecycle. SWIS Facility/Site Activity Details: Corinda Los Trancos Landfill (Ox Mtn) (41-AA-0002), https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223, last accessed January 20, 2022 10 City of Pacifica Climate Action Plan Implementation Report, October 2017, page 2, page 7
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goal to make the best and highest use of all resources that are manufactured, consumed, discarded and re-manufactured. In 2017 Recology of the Coast recorded a diversion rate of 76 percent of solid wastes in Pacifica with the driving factor being the increase of curbside recycling from every other week to weekly. According to CalRecyle Per Capita Disposal Trends for the City of Pacifica, the per capita disposal rate in 2020 was 3.5 pounds per day (PPD) per person. Based on an estimated population of 200 people, the project would generate approximately 128 tons per year
11, which represents less than one percent of the remaining capacity of the Ox Mountain Landfill. Based on the anticipated minimal waste generation associated with the project as well as ongoing waste diversion and reduction efforts, the project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure and as such impacts of the project would be less than significant.
Impact UTIL-5: Implementation of the project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste (less than significant impact).
The project is expected to generate solid waste typical of residential uses. The applicant will be required to adhere to all federal, state, and local regulations governing the disposal of solid waste. Furthermore, although the project will generate a waste stream during construction activities, the project will be required to demonstrate reductions in waste generation through the development of a construction waste management plan. As such, the project would not result in violations of federal, state, or local statutes and regulations related to solid waste, and implementation of the project would result in less than significant impacts.
4.14.5 References
1. CalRecycle Jurisdiction Per Capita Disposal Trends, Pacifica, 2020
2. CalRecycle. SWIS Facility/Site Activity Details: Corinda Los Trancos Landfill (Ox Mtn) (41- AA-0002)
3. City of Pacifica Climate Action Plan Implementation Report, October 2017
4. City of Pacifica, Wastewater Treatment, Wastewater Collection, Sanitary Sewer System, https://www.cityofpacifica.org/departments/public-works/wastewatertreatment/wastewater-collection/sanitary-sewer-system 11 (3.5 PPD)(200 residents) = 700 PPD; (700 PPD)(365 days) = 255,500 PPY; 255,500 PPY/2,000 tons = 128 tons per year
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5. City of Pacifica Wet Weather Equalization Basin Project Information Sheet
6. County of San Mateo, 2014 Five-Year Countywide Integrated Waste Management Plan Review Report, October 2014
7. North Coast County Water District, 2020 Urban Water Management Plan, June 2021
8. San Mateo County Integrated Waste Management Plan, Final Draft, January 8, 1999
9. San Francisco Regional Water Quality Control Board, Revised Tentative Order, Amendment of Cease and Desist Order for City of Pacifica Calera Creek Water Recycling Plant and Wastewater Collection System in Pacifica, San Mateo County,
10. Superior Court of California, County of San Mateo, Planning for the County’s Waste Management Challenges, 2018-2019 San Mateo County Civil Grand Jury, 2019
11. The Harry Tracy Water Treatment Plant Fact Sheet, February 2017
12. U.S. EPA, Understanding the Safe Drinking Water Act, June 2004
4.15-1
W ildfire
This section summarizes the regulatory framework for wildfire, summarizes the wildfire risk factors affecting the project site, and discusses the potential impacts resulting from implementation of the proposed project. The following documents were used to analyze the potential impacts that could occur:
• Vegetation Management Plan Memorandum, prepared by Richard Johnson, Retired Fire Marshal North County Fire Authority, February 28, 2022
4.15.1 Regulatory Context
Federal
Federal Emergency Management Act
In March 2003, the Federal Emergency Management Agency (FEMA) became part of the U.S. Department of Homeland Security. FEMA's continuing mission is to lead the effort to prepare the nation for all hazards and effectively manage federal response and recovery efforts following any national incident. FEMA also initiates proactive mitigation activities, trains first responders, and manages the U.S. Fire Administration. The City of Pacifica is under the jurisdiction of FEMA Region 9, which covers Arizona, California, Hawaii, Nevada, Guam, American Samoa, Commonwealth of Northern Mariana Islands, Republic of Marshall Islands, Federated State of Micronesia, and more than 150 sovereign tribal entities.
FEMA Region 9 specifically plans for hazards, including wildfires.
State
California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) protects people and safeguards property from wildland fires in California. Prevention is a key component of CAL FIRE’s mission including pre-fire engineering, vegetation management, fire planning, education, and law enforcement. It provides statewide direction for fire prevention in wildland areas and reviews regulations and building standards. CAL FIRE maps Fire Hazard Severity Zones (FHSZs) sitewide based on fuel, slope, and weather. It also designates land as either Federal, State, or Local Responsibility Area (FRA, SRA, or LRA).
California Fire Code
The California Fire Code (CFC) is Part 9 of Title 24, California Code of Regulations, also referred to as the California Building Standards Code. The CFC incorporates the 2018
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International Fire Code of the International Code Council with necessary California amendments. The purpose of the CFC is to establish the minimum requirements consistent with nationally recognized best practices to safeguard the public health, safety, and general welfare from the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises, and to provide safety and assistance to fire fighters and emergency responders during emergency operations.
California Building Code
Chapter 7A of the California Building Code (CBC) establishes specific requirements for construction of new buildings located within areas designated as wildland urban interface (WUI). This chapter of the CBC is intended to increase fire resistance of buildings and structures located within the WUI and includes regulations related to vegetation management, non-combustible materials, and the location of vents, among other requirements.
AB 747: General Plans – Safety Element
Adopted in 2019, AB 747 revised Government Code section 65302(g) to require cities and counties to address evacuation routes related to identified fire and geologic hazards in the safety element of general plans. Cities that contain a Very High Fire Hazard Severity Zone and counties that contain a SRA must submit a safety element for review by the California Board of Forestry and Fire Protection and any applicable local fire protection agency. Local agencies are also required to prepare a local hazard mitigation plan (LHMP) every five years and can work together on a multi-jurisdictional basis.
Public Resources Code 4291
The Public Resources Code was amended in 2005 to include regulations related to defensible vegetation clearing around structures located within a State Responsibility Area. Specifically, property owners with structures adjoining a mountainous area, forest, or grassland must provide and maintain a 100-foot defensible space to minimize potential fuel around structures with the intent of minimizing risk of loss and to improve the safety of firefighters.
The 100-foot defensible space area is comprised of two zones: a home defense zone within 30 feet of the structure with more intensive fuel management and the reduced fuel zone extending to 70 feet or the property line.
1 1 Fire Safe San Mateo County, “Defensible Space,” Website, available:
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Local
North County Fire Authority
The North County Fire Authority (NCFA) is a joint powers authority that was established in 2003. NCFA provides fire protection and emergency medical response services to Pacifica, Brisbane, and Daly City. Two of the NCFA’s nine fire companies are in Pacifica. Fire Station 72, with one fire company, is located at 1100 Linda Mar Boulevard, approximately 1.6 miles from the project site. NCFA also provides code enforcement, plan review, and construction inspection through its Fire Prevention Services Division. 2021 Multijurisdictional Local Hazard Mitigation Plan
The City of Pacifica, in conjunction with the County of San Mateo and other cities and special districts in the County, prepared an update to the Multijurisdictional Local Hazard Mitigation Plan, initially developed in 2005 and later updated in 2010 and 2016. The Plan identifies local policies and actions intended to reduce the risk to life and property from natural hazards including wildland fires. The plan also complies with federal planning regulations which require local governments to develop a hazard mitigation plan as a condition for receiving certain types of non-emergency disaster assistance, including funding for hazard mitigation plans. The 2021 update of the San Mateo County Multijurisdictional Local Hazard Mitigation Plan was adopted by the Pacifica City Council on November 22, 2021.
City of Pacifica General Plan 1980
The Seismic Safety and Safety Element of the General Plan identifies known hazards in the City of Pacifica including fire hazards. Policies applicable to the proposed project include the following:
• Prohibit development in hazardous areas, including flood zones, unless detailed site investigations ensure that risks can be reduced to acceptable levels and the structure will be protected for its design life. Development shall be designed to withstand a minimum of a 100-year hazard event, regardless of the specific nature of the hazard. This concept applies to both on-site and off-site hazards.
• Maintain an emergency plan which provides adequate response to disasters, including emergency ingress and egress communitywide and for individual neighborhoods. • Emphasize fire prevention measures.
• Continue to increase public education about various localized fire hazard problems, such as wildfires and areas with limited access.
https://firesafesanmateo.org/preparedness/defensible-space, accessed February 2022.
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• Identify neighborhood evacuation routes. Routes may have to be pedestrian in those areas where access is limited and egress will conflict with fire and other emergency equipment.
4.15.2 Environmental Setting
Wildland fires typically start in an undeveloped area such as a forest or grassland. While wildfires occur infrequently, their effects typically cause more damage than urban fires. In California, most wildfire damage occurs in WUI areas, or areas where homes abut undeveloped forests or grasslands. Most wildfires are started by human activity such as faulty electrical infrastructure, equipment use, campfires, fireworks, and arson. The most recent deadly fire in San Mateo County, the CZU Lighting Complex in August 2020, was started by lightning. The CZU Lightning Complex fires burned over 85,000 acres resulting in 1 fatality, 1 injury, and 1,490 structures destroyed.
2 Terrain, weather, wind, and vegetation all affect the location, frequency, and severity of wildfires. According to the 2021 Multijurisdictional Local Hazard Mitigation Plan, it is highly likely that wildfires will continue to occur in San Mateo County.
CAL FIRE maps areas of significant wildfire hazards based on weather, terrain, and fuel types and designates responsibility areas as either SRA or LRA, based on population density, land use, and land ownership. Areas within the City of Pacifica are designated as LRA while small areas of the Planning Area outside City limits are designated as SRA. In addition, lands owned by the federal government and the County, including the Golden Gate National Recreational Area (GGNRA) lands and San Pedro Valley County Park, are designated as FRA.
The majority of the Planning Area, including the project site are classified as having a minimal fire hazard within the LRA. Areas designated as high and very high fire hazard severity are primarily located in the SRA adjacent to the south and eastern edges of the City. In addition, the NCFA establishes areas within the City designated as WUI, which includes the project site.
As such, the proposed project is subject to the requirements set forth in Chapter 7A of the California Building Code which is intended to increase fire resistance of buildings.
4.15.3 Thresholds of Significance
As provided in Appendix G of the CEQA Guidelines, the project would result in a significant impact to wildfire if it would:
2 2021 Multijurisdictional Local Hazard Mitigation Plan Volume 2 Planning Partner Annexes, October 2021
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1. Substantially impair an adopted emergency response plan or emergency evacuation plan
2. Exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire
3. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment
4. Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes
4.15.4 Analysis, Impacts, and Mitigation Measures
Impacts to wildfire resulting from implementation of the proposed project are discussed below. The impact analysis contained herein is based on the Vegetation Management Plan Memorandum prepared for the project (Appendix 4.15-A). Impacts to wildfire are assessed using the significance criteria listed in 4.15.3, above. This analysis identifies the potential direct and indirect impacts to wildfire from construction, operation, and maintenance activities related to the proposed project.
Impact FIRE-1: The project would not substantially impair an adopted emergency response plan or emergency evacuation plan (less than significant impact).
The residential portion of the project site will be accessed by a two-way driveway along the Oddstad Boulevard frontage. Oddstad Boulevard is identified as a collector roadway and serves the southeast residential areas of Pacifica. A collector roadway is a lower speed street that provides connections between local streets and arterial roadways. As detailed in the Traffic Analysis Oddstad Boulevard has a capacity of approximately 12,000 vehicle per day and is expected to operate substantially below the capacity given its location within a single family residential area without adjacent high traffic-generating uses. As further detailed in the Traffic Analysis, the proposed project will generate fewer trips as compared to the previous school use, and the addition of vehicles to adjacent roadways during peak periods will be minimal and will not substantially impair roadway operations.
The project site is located within 1.6 miles of the nearest fire station, and as discussed in further detail in the Public Services section of this EIR, is within the four-minute response time established by the NCFA. In addition, the City of Pacifica maintains information on the City’s website (www.CityofPacifica.org) on wildfire preparedness for residents of the City including access to Zone Haven, which allows residents to look up their evacuation zone. The
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project site is in evacuation zone PAC-E018. In a wildfire event, residents can look up their evacuation zone and the evacuation status (e.g. evacuation warning, evacuation order, etc.).
Residents can also sign up for alerts (San Mateo County “SMC” Alert) through the San Mateo County Sheriff’s Office of Emergency Services to be apprised of evacuation orders in the event of a wildfire. Furthermore, the proposed site plan has been reviewed by the City’s Public Works and Fire Departments who determined that emergency access would be adequate. As shown on the Fire Department Access Plan (Sheet C7.0), and Fire Hydrant Spacing Plan (Sheet C7.1) of the submitted plans, fire apparatus and emergency response equipment can be deployed to all buildings on site in the event of fire.
Prior to any work within the public right-of-way during construction, including any temporary lane closures, review of the proposed scope of work and approval of an encroachment permit by the Pacifica Public Works Department will be required, which would also be reviewed by the Fire Department to ensure adequate emergency access would be available.
Based on the available capacity of surrounding roadways to serve the nominal increase in trips associated with the project, the project site’s proximity to a fire station, as well as available resources intended to keep residents informed during a wildfire event, the project would not interfere with an emergency response or action plan during construction or at operation and impacts resulting from the project would be less than significant.
Impact FIRE-2: The project would not exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby would not expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire (less than significant impact).
The project site is located within the Wildland Urban Interface. The topography, climate, and vegetation of the project site and surrounding area to the east are conducive to the spread of wildland fires once started. Wildfires in the project area are a potential hazard, particularly during the fall seasons, when warm and dry winds combined with the dry vegetation have the potential to exacerbate ignition sources. As detailed in the Vegetation Management Plan Memorandum prepared for the project, the NCFA site access and steep slopes as factors impeding fire response at the site.
The project is required to comply with building and fire code requirements applicable to project’s located within the WUI as set forth in Chapter 7A of the California Building Code. In particular, this section of the CBC sets forth regulations related to vegetation management, non-combustible materials, and the location of vents, which are intended to increase fire resistance of buildings located within the WUI. As a standard condition of approval, project
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plans will be required to demonstrate compliance with applicable building and fire code regulations which will be reviewed by City staff to ensure that the new construction and its fire and life safety systems are designed, installed, and tested to the most current code requirements. In addition to building and fire code requirements, as set forth in the Vegetation Management Plan Memo, as a condition of project approval, the NCFA will require a minimum 100-foot defensible zone around all structures and a Vegetation Management Plan consistent with the Fire Safe San Mateo County Defensible Space Guidelines. Through compliance with building and fire code requirements for sites located within the WUI as well as implementation of conditions of approval set forth by the NCFA, the project will not exacerbate wildfire risks and would not expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire and impacts of the project would be less than significant.
Impact FIRE-3: The project would not require installation or maintenance of infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment (less than significant impact).
The proposed project can be served by existing public water, sewer, and storm drain infrastructure. While existing overhead electrical transmission lines exist along the west side of Oddstad Boulevard, the project will obtain electric, gas, and communication service via an underground joint trench. Therefore, no overhead electric lines associated with the project will be installed. As shown on the project plans, a 100-foot defensible space will be established along the site’s eastern boundary adjacent to Frontierland Park. In the case of a wildfire, this defensible space would help to slow or stop the spread of wildfire and protect residences from catching fire. Therefore, the proposed project would not require the installation or maintenance of associated infrastructure that would exacerbate fire risk or result in temporary or ongoing impacts to the environment and impacts resulting from the project would be less than significant.
Impact FIRE-4: The project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes (less than significant impact).
The project proposes to retain the existing, concrete drainage ditch located adjacent to the steep slope on the eastern portion of the project site. Additionally, the project will comply with stormwater runoff requirements including installation of self-retaining areas which will retain and receive runoff from adjacent impervious areas of the site and will not result in
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changes to the site’s existing volume of off-site storm water flows. The project proposes to retain the steepest slopes onsite and will concentrate development on the flat portions of the site in areas currently developed. As a previously developed project site, improved with buildings and infrastructure, the proposed redevelopment will not substantially alter the site in a manner that would result in post fire slope instability or drainage changes. Furthermore, as described in the Geology and Soils section of this EIR, the potential for slope failures impacting the project site is low and concluded that there is no evidence of significant instability from adjacent slopes that could impact the project site. Therefore, impacts associated with post-fire slope instability will be less than significant.
4.15.5 Appendices
• Appendix 4.15-A: Vegetation Management Plan Memorandum, prepared by Richard Johnson, Retired Fire Marshal North County Fire Authority, February 28, 2022
4.15.6 References
1. 2021 Multijurisdictional Local Hazard Mitigation Plan Volume 2 Planning Partner Annexes, October 2021
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Section 15126 of the California Environmental Quality Act (CEQA) Guidelines require that all phases of a project be considered when evaluating its impact on the environment, including during construction and operation. Further, the evaluation of significant impacts must consider direct and reasonably foreseeable indirect impacts of the project over the shortterm and long-term. As detailed in CEQA Guidelines Section 15126, the EIR must discuss the following:
• Significant environmental effects of the proposed project • Mitigation measures proposed to minimize significant effects • Significant environmental effects that cannot be avoided if the proposed project is implemented
• Significant irreversible environmental changes that would result from implementation of the proposed project
• Growth-inducing impacts of the proposed project
• Alternatives to the proposed project.
Chapter 4, Environmental Evaluation, Sections 4.1 through 4.15 provide a comprehensive discussion and analysis of the proposed project’s environmental impacts, proposed mitigation measures, and conclusions regarding the level of significance of each impact before and after mitigation. Chapter 5, Alternatives, presents a comparative analysis of alternatives to the proposed project. All other CEQA-required topics are presented herein.
In addition, this Chapter of the EIR also includes a discussion of the Mandatory Findings of Significance as provided in Appendix G of the CEQA Guidelines.
This section identifies significant impacts associated with implementation of the proposed project that cannot be mitigated to less than significant. As part of the certification process, the City Council will make a final decision as to the significance of impacts and the feasibility of mitigation measures in this Draft EIR. As detailed in Chapter 4, Section 4.13, implementation of the proposed project would result in significant and unavoidable impacts as it relates to the project’s vehicle miles traveled (VMT) generation (Impact TRA-2), which exceeds the established threshold of 15% below the citywide average. Mitigation Measure
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TRA-1 and TRA-2 have been identified to reduce potential VMT impacts and resulting GHG emissions to the maximum extent practicable, but impacts resulting from a conflict with CEQA Guidelines section 15064.3, subdivision (b) would remain significant and unavoidable.
Section 15126.2(d) of the CEQA Guidelines states that an EIR must include a discussion of any significant irreversible environmental changes that would be caused by a proposed project. Generally, a project would result in significant irreversible environmental changes if:
• The primary and secondary impacts would generally commit future generations to similar uses;
• The proposed consumption of resources is not justified (e.g., the project involves the wasteful use of energy);
• The project would involve a large commitment of nonrenewable resources; or • The project involves uses in which irreversible damage could result from any potential environmental accidents associated with the project.
Implementation of the proposed project would require demolition of the existing school buildings and associated site improvements and construction of 70 residential units in 7 buildings. The project will retain the existing recreational field onsite as part of the project and could therefore be developed as a separate use in the future, . A portion of the project would commit the site as a residential development, which would exclude other uses of the project site for the lifespan of the project.
The proposed project involves construction of 70 residential units in 7 buildings as well as amenity and accessory buildings and other associated site improvements. Resources such as lumber and other forest products are generally considered renewable resources and would be replenished over the life of the project. As such, development of the project would not result in irreversible commitment of renewable resources. Non-renewable resources, such as natural gas, petroleum-based products, asphalt, petrochemical construction materials, steel, copper, and other metals, are resources that are available in finite supply as the processes that create these resources occur over a long period of time. Therefore, the replacement of these materials would not likely occur over the lifetime of the project and represents and irreversible commitment of non-renewable resources. The proposed project
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would commit the site to a new type of land use as compared to the existing conditions and would involve an irreversible commitment through the use of renewable in the near term and non-renewable resources in the long term.
If these renewable and non-renewable resources are not consumed by the proposed project, they will likely be committed to other residential projects to meet the anticipated need for housing in the City of Pacifica. Furthermore, the investment of resources in this project would be typical of the level of investment normally required for residential developments of this size.
CEQA requires a discussion of the potential for irreversible environmental damage caused by an accident associated with the project. As a residential use, the proposed project would not introduce a land use that requires the transport, storage, or on-site use of hazardous materials which, if inadvertently released, could result in irreversible damage to the environment. Therefore, the proposed project would not have the potential for irreversible damage from environmental accidents.
As required by Section 15126.2(e), an EIR must discuss ways in which a proposed project could foster economic or population growth or the construction of additional housing, either directly or indirectly, in the surrounding environment. The EIR must also discuss the characteristics of the project that could encourage and facilitate other activities that could significantly impact the environment, either individually or cumulatively.
Growth can be induced in several ways, including through elimination of obstacles to growth, stimulation of economic activity within the region, or through establishment of policies or precedents that directly or indirectly encourage additional growth.
In general, a project may induce growth in a geographic area if it removes an impediment to growth (e.g., establishment of an essential public service, the provision of new access to an area, a change in zoning or general plan approval), provides opportunities for economic expansion in response to the project (e.g., employment expansion etc.), or proposes development in an isolated area or an area adjacent to open space (being distinct from an “infill” type of project). If a project meets any of these criteria, it can be considered growth inducing. An evaluation of the project against these growth-inducing criteria is provided below.
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In general, growth in an area may result from the removal of physical impediments or restrictions to growth. In this context, physical growth impediments would include nonexistent or inadequate access to an area, as well as the lack of essential public services and utilities. In addition to these physical impediments, land use regulations, ordinances and codes, may restrict or deter growth and can be considered an impediment to growth.
The project site is currently developed and is within an established residential neighborhood served by existing roadways and public utilities. As discussed in Section 4.14, all utilities needed to serve the proposed development will be provided via existing infrastructure that will extend onto the project site. Based on the current developed status of the site as well as existing roadways and infrastructure that serve the site, implementation of the proposed project would not provide new access to an inaccessible area, and thus the project would not result in growth inducing impacts. Furthermore, the site is designated for residential development in the City’s General Plan 2040 and as such would not result in a change in the site’s designation that would allow for growth that has not previously been planned.
The proposed project would result in a temporary increase in construction-related job opportunities in the area. However, employment opportunities provided by construction would not likely result in household relocation by construction workers to the project area.
Construction workers would likely be drawn from the labor force already residing in the City of Pacifica, surrounding communities, and the Bay Area region. Employment opportunities provided during the construction period would be temporary and would not constitute a substantial growth in employment.
Future residents on the project site would be comprised of Pacifica School District employees as well as a portion of new residents that could represent an addition to the region’s labor force; however, it is not known to what extent people would move to the project site from other sites within the region or would be new residents in the region. The number of employed residents on the project site would be minimal in relation to the regional work force.
Given that implementation of the proposed project would not result in an increase in population beyond what has been considered in the City of Pacifica’s General Plan, and provided that the city is primarily built out, opportunities for growth are limited. The increase in population and economic growth associated with the proposed project would not
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contribute substantially to growth in the City of Pacifica and thus would not result in growth inducing impacts under this criterion.
The project site is located in an urbanized area and surrounded by existing residential uses.
As a project is consistent with the existing residential character of the surrounding area and is in line with residential growth envisioned in the City of Pacifica General Plan 2040. Given that implementation of the proposed project would not result in the urbanization of land in an isolated locality, it would not result in growth inducing impacts based on this criterion.
Appendix G of the CEQA Guidelines (Environmental Checklist) contains a list of mandatory findings of significance that may be considered significant impacts if any of the following occur:
1. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of California history or prehistory?
2. Does the project have impacts that are individually limited, but cumulatively considerable?
3. Does the project have environmental effects which will cause substantial adverse effects on human beings either directly or indirectly?
The following includes a discussion of the mandatory findings of significance for the proposed project.
Implementation of the project could lead to adverse impacts to biological and cultural/tribal cultural resources, as discussed in sections 4.3, and 4.4 of this EIR. However, impacts of the project would be reduced to less than significant levels through incorporation of mitigation.
Therefore, implementation of the project would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or
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animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of California history or prehistory provided all policies, rules, and regulations of all relevant governing bodies are adhered to, and the mitigation measures set forth in Sections 4.1, Aesthetics, 4.3 Biological Resources, and 4.4 Cultural and Tribal Cultural Resources are implemented.
In addition to the specific impacts of individual projects, CEQA requires EIRs to consider potential cumulative impacts of the proposed project. CEQA defines “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts. Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed project and other nearby projects. For example, transportation impacts of two nearby projects may be less than significant when analyzed separately but could result in a significant impact when analyzed together. An analysis of cumulative impacts allows the EIR to provide a reasonable forecast of future environmental conditions and can more accurately ascertain the effects of a series of projects.
Given that the immediate vicinity of the project site is largely built out, the cumulative context for analysis in this EIR is limited to existing development as well as two known projects located approximately 2 miles from the project site including the 36 townhome unit development known as the Hillside Meadows Subdivision and the 125 single family residential development known as the Linda Mar Woods Subdivision. As detailed in Sections
4.1 through 4.15 of this DEIR, impacts of the project would be less than significant or less than significant with incorporation of mitigation for all topic areas with the exception of impacts related to vehicle miles traveled (VMT) which are being addressed through implementation of a Transportation Demand Management (TDM) Plan intended to reduce single occupancy vehicle trips across the Pacifica School District. A brief analysis of cumulative impacts for each topical area analyzed in the DEIR is provided below. • Aesthetics. The geographic scope for cumulative aesthetics impacts includes the immediate project vicinity. Development of the proposed project as well as projects considered in the cumulative context are required to adhere to all relevant local plans, Municipal Code regulations and proposed policies contained in the General Plan related to the preservation of aesthetic resources including design standards, landscape plans, and light regulations. Compliance with the City’s development standards ensures that new development is compatible with its existing surrounding area and visually
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compatible with existing land uses. As such, the project’s contribution to potentially significant cumulative aesthetic impacts is not cumulatively considerable. • Air Quality. The geographic scope for cumulative air quality impacts includes the Planning Area and the entire San Francisco Bay Area Air Basin (SFBAAB). The project would support the goals of the Bay Area 2017 Clean Air Plan adopted by BAAQMD, including all applicable control measures, and would not conflict with its implementation as detailed in Section 4.2 of this DEIR. Project-level air quality impacts will be mitigated through compliance with best management practices (BMPs) established by BAAQMD.
Therefore, the project’s contribution to potentially significant cumulative air quality impacts is not cumulatively considerable.
• Biological Resources. The geographic scope for cumulative biological resource impacts includes the project site, adjacent properties, and the broader Pacifica area.
Development of the site has the potential to result in direct and indirect impacts to biological resources onsite including impacts to special-status animal species, and jurisdictional waters. However, incorporation of mitigation measures identified in this EIR will protect resources in place, will offset the loss of habitat, or will require reestablishment of habitat (e.g. planting replacement trees for removal of heritage and protected trees, replanting wetland plants at a 1:1 replacement ratio, etc.) which will reduce potential impacts to less than significant. The project would not result in impacts to wildlife movement corridors, nor would it conflict with a Habitat Conservation Plan.
With incorporation of mitigation to reduce site-specific impacts to biological resources and due to the fact that there are no impacts to biological resources beyond the project site, the project’s contribution to potentially significant cumulative impacts will not be cumulatively considerable.
• Cultural and Tribal Cultural Resources. The geographic scope considered for the cumulative cultural resource effects is the Planning Area as the conversion of undeveloped land to developed can result from individually minor but collectively significant projects taking place over time. While individual projects can avoid or mitigate the direct loss of specific resources, the effects could be cumulatively considerable. The project does not contain any historic resources and as such impacts to historic resources will not be cumulatively considerable. Though there is a potential to uncover archaeological resources, human remains, and tribal cultural resources during project construction, compliance with mitigation measures set forth in this EIR as well as state laws will reduce project impacts to less than significant and therefore the project’s contribution to cumulative impacts will not be cumulatively considerable. • Geology and Soils. The geographic scope considered for cumulative geology and soils is the project site and the broader San Francisco Bay Area region. This region is considered seismically active and development of the proposed and future projects would expose additional people and structures to potentially adverse effects associated with earthquakes, including seismic ground shaking and seismic related ground failure.
However, the proposed and future projects are required to be constructed in accordance
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with the most current version of the California Building Code, existing ordinances, and local building codes for seismic safety requirements and recommendations contained in each site-specific geotechnical report for each project. Therefore, the project’s contribution to cumulative geology and soils impacts is not cumulatively considerable. • Greenhouse Gas Emissions. The analysis of greenhouse gas (GHG) impacts is inherently cumulative as climate change is a global issue, and GHGs are global pollutants, unlike criteria air pollutants. No single emitter of GHGs is large enough to trigger global climate change on its own. As detailed in this EIR, the project is below the screening criteria for operation GHG emissions as set forth by BAAQMD and is consistent with GHG reduction strategies outlined in the Pacifica Climate Action Plan (PCAP) and as such, operational emissions are not expected to conflict with the City’s ability to implement the GHG emissions reduction outlined in the PCAP. Additionally, the project would include mitigation measures identified in this EIR as well as incorporate energy-saving measures required by State and local energy policies, further reducing energy consumption, and thereby reducing GHG emissions. As such, the project’s incremental contribution to cumulative GHG impacts is not cumulatively considerable. • Hazards and Hazardous Materials. The geographic scope considered for cumulative hazards and hazardous materials impacts is the project area. Adverse effects of hazards and hazardous materials are localized and therefore, the area immediately surrounding the project site would be most affected by project activities. For the transport of hazardous materials, the geographic scope includes local and regional transportation facilities. While the project site likely contains asbestos, and lead, implementation of applicable federal, State, and local regulations as well as mitigation provided in this EIR would ensure impacts are reduced to less than significant. As with the proposed project, future projects would also be subject to compliance with applicable federal, State, and local regulatory requirements regarding the transport of hazardous materials, cleanup of hazardous materials, and the use and storage of hazardous materials during construction and operation. Though the project could result in exposure of people or structures to impacts involving wildland fires, compliance with State and local regulation as well as mitigation measures contained in this EIR will reduce impacts related to wildland fires to less than significant. Similarly, future projects would be subject to the same regulations. Through incorporation of mitigation measures and compliance with State and local regulations, the project, in conjunction with future projects would not result in cumulatively considerable hazards and hazardous materials impacts. • Hydrology and Water Quality. The geographic scope considered for cumulative hydrology and water quality impacts is the San Pedro Creek watershed, within which the project site is located. The project, in combination with future development, could increase impervious surfaces resulting in a greater chance of flood and potential impacts to water quality. However, due to the substantially developed nature of the project site and greater Planning Area, as well as policies intended to improve stormwater management, provide flood controls, and reduce stormwater pollution, such as
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stormwater permit requirements to retain and treat stormwater, the project’s contribution to cumulative hydrology and water quality impacts would not be cumulatively considerable.
• Land Use and Planning. The geographic scope for cumulative impacts related to land use includes projects within Pacifica and particularly those proximate to the project site.
Cumulative land use impacts would occur if other projects in the vicinity of the project site would result in land use impacts in conjunction with the proposed project. The project is consistent with the land use designation for site, which was changed to Low Density Residential as part of the recently adopted 2040 General Plan, and complies with all other land use plans, policies, and regulations. The project will not result in land use impacts and therefore, cumulative impacts to land use would not be cumulatively considerable.
• Noise. The geographic scope for cumulative noise impacts is the area immediately surrounding the project site. Though the project may result in temporary noise increases during construction, long term operational noise would result in less than significant impacts as the residential use would not generate noise in excess of established thresholds nor would it result in an increase in vehicular traffic such that it would increase existing ambient noise levels. As with the proposed project, future development would be subject to standard best management practices to reduce noise levels during construction and would similarly be required to quantify operational noise and provide mitigation as necessary to comply with established thresholds. As such, cumulative impacts to noise will not be cumulatively considerable. • Population and Housing. The geographic scope for population and housing impacts is the City of Pacifica. The project site was redesignated as part of the 2040 General Plan Update to Low Density Residential, which allows for residential development on the project site. The introduction of 70 residential units is within the planned growth and as stated previously the project is consistent with land use and zoning regulations. The project’s population increase is greater than the Hillside Meadows Subdivision project and less than the Linda Mar Woods Subdivision, but nevertheless is within the City’s projected population growth. Furthermore, the project will not result in population or housing displacement. As such, the project’s cumulative population and housing impacts will not be cumulatively considerable.
• Public Services. The geographic scope for cumulative impacts related to public services includes projects within Pacifica. Development of the project was determined to have a less than significant impact to public services. Though the project and cumulative projects would increase demands for police, fire, school, park, and library services due to the increase in residents, the demand for these services would not change significantly with implementation of the proposed project and cumulative projects. Similar to the proposed project, each of the cumulative projects would be individually subject to review by the police and fire departments and would be required to comply with all safety requirements to adequately address police and fire protection service demands. As with
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the proposed project, the applicants of the cumulative projects would be required to pay developer fees to the appropriate school districts as applicable; and payment of these fees would fully mitigate any impact that the cumulative projects would have on school services. As such, implementation of the project and cumulative projects would not require construction of new facilities or expand existing facilities to accommodate increased demand and impacts to public services will not be cumulatively considerable. • Transportation and Traffic. The geographic context for cumulative impacts related to transportation is the immediately surrounding area, the roadway network within the Planning Area, and the regional roadway network with connections to the Planning Area.
Transportation impacts in the immediate area surrounding the site including geometric design hazards would be reduced to less than significant levels with incorporation of mitigation measures and would not be cumulatively considerable impacts as such impacts are site specific. Impacts of the project related to vehicle miles traveled (VMT) was determined to be significant and unavoidable and are therefore cumulatively considerable, though the project will be required to incorporate mitigation measures that seek to reduce single-occupancy vehicle trips, thereby reducing VMT impacts. As noted in the Section 4.13, Transportation and Traffic, residential development at the project site is anticipated by the 2040 General Plan, and the resulting significant and unavoidable and cumulative impacts were therefore already analyzed and considered in the 2040 General Plan EIR.
• Utilities and Service Systems. The geographic scope for cumulative impacts related to utilities and service systems includes projects within Pacifica. As detailed in this EIR, impacts of the project on utilities and service systems would be less than significant.
Cumulative projects, as with the proposed project would be required to demonstrate available supply is present to support development. As the project would not result in impacts to utilities and service systems, resulting cumulative impacts would not be cumulatively considerable.
• Wildfire. The geographic scope for cumulative impacts related to wildfire includes projects within Pacifica. The project is not within a designated fire hazard severity zone, but is within the wildland urban interface (WUI). As detailed in this EIR, the project, with incorporation of State and local regulations to reduce the risk of wildfires would result in less than significant impacts. Similarly, cumulative projects located in the WUI and/or fire hazard severity zones would be subject to the same regulations. As such, cumulative wildfire impacts would not be cumulatively considerable.
As provided herein, residential development at the project site was considered in the recently adopted 2040 General Plan and General Plan EIR. The cumulative analyses provided in the 2040 General Plan EIR and herein demonstrate that the project, together with other development projects in the City of Pacifica will not result in cumulatively considerable impacts, with the exception of VMT.
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While human beings could be affected by a variety of impacts described above, the project would not result in environmental impacts that would cause substantial adverse effects on human beings, either directly or indirectly. Potential impacts on people include air quality emissions, site soils and seismic activity, routine hazardous materials use, and wildfire risk; however, these impacts were determined to be less than significant or less than significant with mitigation. As such, the project would not expose people to substantial new hazards and there would be no other adverse effects on human beings.
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6.0 Alternatives
CEQA Requirements
6.1.1 Introduction
The California Environmental Quality Act (CEQA) requires that an Environmental Impact Report (EIR) describe a range of reasonable alternatives to the proposed project or to the location of the project that could feasibly avoid or lessen any significant impacts while substantially achieving the basic objectives of the proposed project. An EIR should also evaluate the comparative merits of the alternatives. This section sets forth potential alternatives to the proposed Pacifica School District Workforce Housing project and evaluates them, as required by CEQA.
Key provisions of the State CEQA Guidelines pertaining to the alternatives analysis are summarized below:
• The discussion of alternatives shall focus on alternatives to the project or its location that are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly.
• The range of alternatives required in an EIR is governed by a “rule of reason;” therefore, the EIR must evaluate only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project.
• The No Project alternative shall be evaluated along with its impacts. The No Project analysis shall discuss the existing conditions at the time the notice of preparation is published. Additionally, the analysis shall discuss what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. • For alternative locations, only locations that would avoid or substantially lessen any of the significant effects of the project need be considered for inclusion in the EIR. • An EIR need not consider an alternative whose effects cannot be reasonably ascertained and whose implementation is remote and speculative.
• The range of feasible alternatives should be selected and discussed in a manner intended to foster meaningful public participation and informed decision-making. Among the factors that may be taken into account when addressing the feasibility of alternatives are environmental impacts, site suitability, economic viability, availability of infrastructure,
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general plan consistency, regulatory limitations, jurisdictional boundaries, and whether the project proponent could reasonably acquire, control, or otherwise have access to an alternative site.
6.1.2 Project Objectiv es
CEQA requires an analysis of alternatives that would feasibly attain most of the basic objectives of the project. As detailed in Chapter 3.0, Project Description of this Draft EIR, project objectives include the following:
• Provide high-quality housing for current and future staff members of the Pacifica School District
• Provide rental rates and lease terms that enable and improve the District’s ability to retain and attract qualified faculty and staff
• Redevelop the underutilized site in response to the declining school-age population and provide workforce housing for the District’s staff
• Contribute to the City of Pacifica’s Regional Housing Needs Allocation (RHNA) goals by providing six (6) low income, five (5) moderate income, and 59 market rate units • Maintain and expand recreational opportunities on site for use by the surrounding neighborhood, future residents, and organized recreational groups • Optimize assets for the Pacifica School District to support its education mission Impacts of the Proposed Project
To develop project alternatives, the City of Pacifica, as Lead Agency, considered the project objectives and reviewed the significant impacts of the proposed project, identified those impacts that could be substantially avoided or reduced through an alternative, and determined the appropriate range of alternatives to be analyzed. Chapter 4.0, Environmental Evaluation, of this Draft EIR evaluates the potential for the proposed project to result in significant impacts to the following resource areas: aesthetics; air quality; biological resources; cultural and tribal cultural resources; geology and soils; greenhouse gas emissions; hazards and hazardous materials; hydrology and water quality; land use and planning; noise; population and housing; public services; transportation; utilities and service system; wildfire; and all other environmental topics which include agricultural resources, energy, mineral resources, and recreation. The analysis in Chapter 4.0 concludes that implementation of the proposed project will result in significant and potentially significant impacts in ten resource areas including aesthetics, air quality, biological resources, cultural and tribal cultural resources, geology and soils, greenhouse gas emissions, hazards and
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hazardous materials, noise, and transportation and traffic. With the exception of significant and unavoidable transportation impacts related to vehicle miles traveled (VMT), all significant and potentially significant impacts of the proposed project will be less than significant with incorporation of mitigation measures. A summary discussion of significant project impacts analyzed in the Draft EIR is presented below.
6.2.1 Aesthetics
The analysis in Section 4.1, Aesthetics identifies a potentially significant impact associated with degradation of the existing visual character and quality of public views of the site and surrounding area (Impact AES-3) as a result of project implementation. With implementation of mitigation, the analysis found this impact to be reduced to a less than significant level with mitigation. The analysis concludes that all other project impacts on aesthetics including impacts to a scenic vista, scenic resources within a state scenic highway, and light and glare will be less than significant. The project will not result in significant and unavoidable aesthetics impacts.
6.2.2 Air Quality
The analysis in Section 4.2, Air Quality identifies potentially significant impacts associated with violating air quality standards (Impact AQ-2) and from exposure of existing sensitive receptors to construction emissions of toxic air contaminants (Impact AQ-3). With incorporation of mitigation measures the analysis concludes that these impacts will be less than significant. Impacts associated with a conflict with an applicable air quality plan, and other emissions such as odors are identified as less than significant. The project will not result in significant and unavoidable air quality impacts.
6.2.3 Biological Resources
The analysis in Section 4.3, Biological Resources identifies potentially significant impacts of the proposed project on special-status species (Impact BIO-1) as well as potential conflicts with local policies or ordinances protecting biological resources (Impact BIO-5). With implementation of mitigation measures, the analysis concludes that impacts will be less than significant. The analysis concludes that impacts of the project to federally protected wetlands and wildlife movement and habitat connectivity will be less than significant, and the project will have no impact to sensitive natural communities or as a result of conflicting with an adopted habitat conservation plan. The project will not result in significant and unavoidable impacts to biological resources.
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6.2.4 Cultural and Tribal Cultural Resources
The analysis in Section 4.4, Cultural and Tribal Cultural Resources identifies potentially significant impacts associated with archaeological resources (Impact C/TCUL-2), human remains (Impact C/TCUL-3), and tribal cultural resources (Impact C/TCUL-4). For all potentially significant impacts, mitigation measures are identified and the analysis concludes that impacts will be less than significant. Impacts to historical resources will be less than significant. The project will not result in significant and unavoidable cultural and tribal cultural resources impacts.
6.2.5 Geology and Soils
The analysis in Section 4.5, Geology and Soils identifies potentially significant impacts associated with strong seismic ground shaking (Impact GEO-1), erosion from construction activities (Impact GEO-2), soil instability (Impact GEO-3), location on an unstable geologic unit and on expansive soils (Impact GEO-4), and paleontological resources (Impact GEO-6).
The analysis concludes that potentially significant impacts will be reduced to less than significant with incorporation of mitigation measures. The proposed project does not involve installation of septic tanks and therefore the analysis concludes that there will be no impact associated with the project being located on soils incapable of adequately supporting the use of septic tanks. The project will not result in significant and unavoidable impacts related to geology and soils.
6.2.6 Greenhouse Gas Emissions
The analysis in Section 4.6, Greenhouse Gas Emissions identifies potentially significant impacts associated with the generation of greenhouse gas (GHG) emissions (Impact GHG1). However, with implementation of mitigation measures, the analysis concludes that impacts resulting from project GHG emissions will be less than significant. Impacts resulting from a conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions will be less than significant. The project will not result in significant and unavoidable impacts related to greenhouse gas emissions.
6.2.7 Hazards and Hazardous Materials
The analysis in Section 4.7, Hazards and Hazardous Materials identifies potentially significant impacts associated with release of hazardous materials into the environment (Impact HAZ2), and as a result of exposure of people or structures to risk of loss, injury, or death involving wildland fires (Impact HAZ-7), however, with implementation of mitigation, impacts will be
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reduced to less than significant. The analysis concludes that impacts associated with the routine transport, use, or disposal of hazardous materials, emission of hazardous materials within one-quarter mile of a school, proximity to an airport, and interference with emergency response and evacuation will be less than significant. The project will have no impact as a result of being located on a hazardous materials site. The project will not result in significant and unavoidable impacts related to hazards and hazardous materials.
6.2.8 Hydrology and Water Quality
The analysis in Section 4.8, Hydrology and Water Quality does not identify any significant or potentially significant impacts to hydrology and water quality as a result of project implementation including the potential for site runoff to violate water quality standards, a decrease in groundwater supplies or interference with groundwater recharge, alteration of existing drainage patterns, pollutant release resulting from site inundation, or through conflict with a water quality control plan or sustainable groundwater management plan. The project will not result in significant and unavoidable impacts related to hydrology and water quality.
6.2.9 Land Use and Planning
The analysis in Section 4.9, Land Use and Planning demonstrates that the proposed project will not physically divide an established community nor will the project conflict with land use regulations established by the City of Pacifica including the General Plan, zoning ordinance, and Plan Bay Area. The project will not result in significant and unavoidable impacts related to land use and planning.
6.2.10 Noise
The analysis in Section 4.10, Noise identifies potentially significant impacts related to increases in ambient noise during project construction (Impact NOI-1), however with mitigation impacts will be less than significant. Impacts related to increases in ambient noise during project operation and groundborne vibration and noise will be less than significant.
The analysis concludes that there will be no impacts resulting from excessive noise associated with airport operations. The project will not result in significant and unavoidable impacts related to noise.
6.2.11 Population and Housing
The analysis in Section 4.11, Population and Housing concludes that the project will result in less than significant impacts related to substantial unplanned population growth and
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displacement of housing or people. The project will not result in significant and unavoidable impacts associated with population and housing.
6.2.12 Public Services
The analysis in Section 4.12, Public Services concludes that growth associated with the project has been planned for by the General Plan and will comply with applicable General Plan and Pacifica Municipal Code (PMC) regulations that ensure public services are adequately funded. Therefore, impacts of the project on public services including fire and police protection, schools, parks, and other public facilities will be less than significant. The project will not result in significant and unavoidable impacts to public services.
6.2.13 Transportation
The analysis in Section 4.13, Transportation and Traffic identifies potentially significant impacts from an increase in hazards due to geometric design (Impact TRA-3), however, mitigation measures will reduce the impact to less than significant. Additionally, this Draft EIR identifies a significant project impact on VMT (Impact TRA-2) and VMT impact under cumulative conditions as detailed in Chapter 5.0, Other CEQA Considerations. Mitigation measures identified will not reduce VMT impacts to less than significant, and therefore, VMT impacts will be significant and unavoidable. All other traffic-related impacts will be less than significant.
6.2.14 Utilities and Service Systems
The analysis in Section 4.14, Utilities and Service Systems concludes that impacts related to relocation or construction of new or expanded utilities, water supply, wastewater treatment capacity, solid waste generation, and violations of federal, state, or local statutes and regulations related to solid waste will be less than significant. The project will not result in significant and unavoidable impacts to utilities and service systems.
6.2.15 Wildfire
The analysis in Section 4.15, Wildfire concludes that impacts related to wildfire risk, evacuation, emergency plans, and post-fire landslide, runoff, slope instability, and drainage changes will be less than significant. The project will not result in significant and unavoidable impacts related to wildfire.
6.2.16 Other Resource Topics
Section 4.0, Environmental Evaluation provides a brief discussion of other resource topics
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including agricultural and forestry resources, energy, mineral resources, and recreation. The analysis concludes that the project will have no impact to these resource topic areas based on the project location and characteristics. Therefore, no additional analysis or discussion of these topics is needed.
Alternativ es Considered but Not Further Studied
An EIR must briefly describe the rationale for selection and rejection of alternatives. The lead agency may make an initial determination as to which alternatives are feasible, and therefore merit in-depth evaluation, and which alternatives are infeasible. The following alternatives were considered and found to be infeasible as discussed below.
6.3.1 Adaptive Reuse of Existing School Complex
Based on the developed condition of the site, an alternative that would adaptively reuse the existing school building was considered. This alternative was determined to be infeasible based on the age and current condition of the building which, as detailed in the Hazards and Hazardous Materials discussion, contains asbestos and lead based paint, which would require full or partial abatement to ensure safety of future residents. In addition, reuse of the existing building would require modifications to increase energy efficiency and comply with seismic regulations. Furthermore, the objective of the project is to provide high quality housing for current and future staff members of the Pacifica School District. As proposed, the project includes 70 units. If the approximately 34,000 square foot school building were to be adaptively reused and converted to residential units, the resulting size of the units would be far less than that proposed by the project, with an average of only 485 square feet before considering common area, access, mechanical, and other needs. For reference, Pacifica Municipal Code section 9-4.2313(b) establishes a minimum dwelling unit size of 450 square feet for a studio unit (no bedrooms) and 600 square feet for a one-bedroom unit. In addition, other site modifications would be needed to accommodate parking, internal vehicular circulation, pedestrian and bicycle amenities, and other amenities associated with residential developments. Therefore, a project alternative that would adaptively reuse the existing school building is not evaluated in this Draft EIR.
6.3.2 Increased Density Development
An alternative that would increase density would be inconsistent with the site’s General Plan designation, which allows for a maximum density of 9 dwelling units per acre. The project proposes the highest density allowed by the General Plan Land Use Designation.
Furthermore, increased density at the site would result in increased activity and demand on
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public services, which would likely result in increased impacts. Based on the inconsistency with the General Plan as well as the likely increase in the severity of impacts, an increased density development alternative is not evaluated in this Draft EIR.
6.3.3 Alternative Site Location
As provided in CEQA Guidelines Section 15126.6, analysis of an infeasible off-site alternative is not required. The key consideration is whether an off-site location is available that would feasibly attain most of the basic objectives of the proposed project. The primary objectives of the Pacifica School District Workforce Housing project are to provide housing within the city, including housing affordable to lower income households, and to redevelop an underutilized site owned by the Pacifica School District. The proposed project is in an area surrounded by single-family residences to the west, north. In addition to providing residential uses, the project also proposes to maintain the recreational field at the southern portion of the project site and will construct a restroom facility, both of which will be publicly available. No off-site alternative project location would meet the key project objectives of providing housing affordable to school district employees and staff, redeveloping an underutilized site owned by the Pacifica School District, preserving and expanding recreational opportunities for use by the surrounding community, and optimizing assets for the Pacifica School District. Therefore, an off-site alternative is not evaluated in this Draft EIR.
Alternativ es Ev aluated
Alternatives considered in this Draft EIR are intended to meet most of the project’s objectives while eliminating or reducing significant and unavoidable impacts as identified in Section 4.0, Environmental Evaluation. Alternatives considered in this Draft EIR include:
• Alternative 1: No Project/No Development
• Alternative 2: Park Pacifica Highland Subdivision: 54 Single Family Residences • Alternative 3: Variation of Site Layout and Unit Mix
Pursuant to CEQA Guidelines Section 15126.6(d), any additional significant effects of the alternatives are discussed in less detail than the significant effects of the proposed project.
The following sections describe each alternative, analyze impacts of each alternative as compared to the proposed project, identify significant impacts of the proposed project that would be avoided or lessened by each alternative, assess each alternative’s ability to meet the project objectives, and evaluate the comparative merits of the alternative and the proposed project.
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6.4.1 Alternative 1: No Project/No Dev elopment
Description
Section 15125.6(e) of the State CEQA Guidelines requires the analysis of a No Project Alternative. This analysis must discuss existing conditions, as well as reasonably foreseeable future development if the proposed project were not to be approved, based on current plans, site zoning, and consistent with available infrastructure and community services. The purpose of describing and analyzing a No Project Alternative is to allow decision-makers to compare the impacts of approving the proposed project with the impacts of not approving the proposed project.
As shown in Figure 4-3 of the 2040 General Plan, which was approved by City Council on July 11, 2022, the site has a General Plan Land Use Designation of Low Density Residential, which allows a density range of 3 to 9 dwelling units per acre. The corresponding zoning designation of the site is Single-Family Residential (R-1), which permits single family residential uses, day cares, and other uses by-right, and conditionally permits uses such as churches, schools, parks, and visitor accommodations.
The No Project alternative is the continuation of existing conditions on the project site, which is developed with the former Oddstad School complex, closed by the Pacifica School District in 2005, and used for storage since 2019. The site includes a single-story school complex, circulation improvements such as driveways, parking areas, and pedestrian pathways, recreational fields and courts, landscaping, fencing, and an undeveloped hillside area along the eastern portion of the site. The existing recreational fields are publicly accessible and are used for both organized sports and individual recreation activities. Under the No Project alternative, no physical alterations would be made, and the site would continue to be used as storage and publicly accessible recreation.
Analysis
The following includes a discussion of the impacts of the No Project/No Development Alternative as compared to the proposed Pacifica School District Workforce Housing project.
Aesthetics
Under the No Project/No Development Alternative, no construction, grading, tree and vegetation removal, or development would occur on the project site and the existing aesthetic characteristics would remain unchanged. As such, the No Project/No Development Alternative would avoid all potentially significant and less than significant impacts related to
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aesthetics since the site would remain unchanged and in its current state.
Air Quality
Under the No Project/No Development Alternative, no construction activities would occur on the project site. Thus, this alternative would not generate any fugitive dust or other pollutant emissions. Furthermore, under the No Project/No Development Alternative, there would be no new area source emissions from the use of consumer products such as solvents, cleaners, paints, and operation of landscaping maintenance equipment nor would there be any new emissions associated with vehicles traveling to and from the project site by residents, delivery trucks, visitors, and recreational users. As such, relative to the proposed project, the No Project/No Development Alternative would avoid all potentially significant and less than significant air quality impacts.
Biological Resources
Under the No Project/No Development Alternative, no changes to the site, including removal of existing trees or vegetation, would occur. This alternative would avoid all impacts of the proposed project related to special-status species including impacts to the San Francisco dusky-footed woodrat, obscure bumblebee, California red-legged frog, bats, nesting birds, and the Choris’ popcornflower. Additionally, there would be no direct or indirect impacts to identified wetlands. As such, relative to the proposed project, the No Project/No Development Alternative would avoid all potentially significant and less than significant impacts to biological resources.
Cultural and Tribal Cultural Resources
Under the No Project/No Development Alternative, no construction activities would occur that could result in the accidental discovery of archaeological resources, tribal cultural resources, or human remains. Therefore, this alternative would avoid all potentially significant and less than significant impacts to cultural and tribal cultural resources.
Geology and Soils
Under the No Project/No Development Alternative, no new development would occur, and all existing structures would remain in place. As such, the current building would not be modified to comply with current seismic regulations and any existing seismic hazards and geologic and soil instabilities to the existing school complex and shed building would remain unchanged. Under this alternative, impacts resulting from seismic hazards would be greater than the proposed project as the existing buildings are of an age that do not incorporate current building code standards that set forth regulations for seismic safety.
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Greenhouse Gas Emissions
No new construction would occur under the No Project/No Development Alternative, and as such GHG emissions associated with construction activities would not occur. The existing school building would continue to be used by the School District for storage and operations would involve the same level of GHG emissions as currently exists, which are negligible. As such, relative to the proposed project, the all potentially significant and less than significant GHG impacts would be avoided under the No Project Alternative.
Hazards and Hazardous Materials
Under the No Project/No Development Alternative, the existing environmental conditions, including the presence of buildings containing lead-based paint and asbestos, would remain.
All impacts identified as potentially significant and less than significant including transportation, use, and disposal of hazardous materials, release of hazardous materials, safety hazards associated with excessive airport noise, interference with an adopted emergency plan, and risks associated with proximity to a wildfire area would be avoided.
Hydrology and Water Quality
This alternative would avoid impacts associated with construction activities including impacts to surface and groundwater water quality. Relative to the proposed project, the No Project/No Development Alternative would not implement design elements that could improve hydrology and water quality through installation of new drainage systems, bioretention features, and other low impact development design features.
Land Use and Planning
Under the No Project/No Development Alternative, there would be no impacts related to division of a community. Conversely, because no housing development would occur, the No Project/No Development Alternative would be inconsistent with the City of Pacifica General Plan, which designates the site for development of low-density housing at a range of 3 to 9 dwelling units per acre. Therefore, the land use conflict of this alternative would be greater than that of the proposed project.
Noise
No construction would occur under the No Project/No Development Alternative. As such, there would be no temporary increase in ambient noise associated with construction activities nor would there be any increase in operational noise. Similarly, this alternative would not generate groundborne vibration or noise as no construction activities would
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occur. As such, the No Project/No Development Alternative would avoid the project’s potentially significant and less than significant noise impacts.
Population and Housing
The No Project/No Development Alternative would not introduce housing to the project site and therefore, would not increase population or housing at the project site or in the City of Pacifica. As such, the No Project/No Development Alternative, like the proposed project would result in less than significant impacts to population and housing.
Public Services
This alternative would not induce additional demand for police or fire services beyond what currently exists. Because there would be no residents introduced under this alternative there would not be any induced additional demand on school services or other public facilities such as libraries. Under this alternative, the site would remain unchanged and as such use of the recreational fields would remain the same as current conditions. As with the proposed project, the No Project/No Development Alternative would result in a less than significant impact to public services.
Transportation and Traffic
Under the No Project/No Development Alternative, no development on the project site would occur and no new vehicle trips would be generated. Therefore, there would be no impacts related to VMT. Additionally, under this alternative, there would be no change to the existing site configuration, and as such there would be no impacts associated with a geometric design hazard nor result in inadequate emergency access. Under the No Project/No Development Alternative the project’s potentially significant and less than significant impacts related to traffic, including the significant and unavoidable traffic impacts (project-specific and cumulative) associated with VMT would be avoided.
Utilities and Service Systems
The No Project/No Development Alternative would not generate an increase in demand for utilities and service systems beyond what currently serves the former Oddstad School. As with the proposed project, this alternative would result in less than significant impacts related to water supply, wastewater treatment, stormwater drainage, natural gas, electric, and telecommunication services, and solid waste generation.
Wildfire
Under the No Project/No Development Alternative no development on the site would occur
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and all existing improvements including the single-story school complex, driveways, parking areas, pedestrian pathways, recreational fields and courts, landscaping, fencing, and undeveloped hillside would remain. The current building would not be modified to comply with Chapter 7A of the California Building Code for sites within the wildland urban interface (WUI) nor would the proposed project’s Vegetation Management Plan be implemented.
Under this alternative, there would be no impacts resulting from impairment of an adopted emergency response or evacuation plan or through installation of infrastructure that may exacerbate fire risk. Given that the site is adjacent to a steep hillside and within an area designated as WUI, under the No Project/No Development Alternative, impacts resulting from exposure of occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire would be greater than the proposed project as the existing buildings are of an age that do not incorporate current building code standards that set forth regulations related to vegetation management, non-combustible materials, and the location of vents, which are intended to increase fire resistance of buildings located within the WUI.
Other Resource Topics
Similar to the proposed project, the No Project/No Development Alternative would not affect agricultural resources as the site is not designated nor currently used as agricultural land, would not result in impacts related to wasteful, inefficient, or unnecessary consumption of energy resources or conflicts with plans for renewable and energy efficiency, would not result in loss of availability of known mineral resources as none are located on or adjacent to the site, and would not result in impacts to recreational facilities as the use of existing recreational facilities onsite would remain unchanged.
Conclusion
The following summarizes impacts of the No Project/No Development Alternative as compared to the proposed project and the alternative’s ability to meet the stated project objectives.
Avoid or Substantially Lessen Project Impacts
The No Project/No Development Alternative would avoid or reduce project impacts related to aesthetics, air quality, biological resources, archaeological resources, human remains, geology and soils, greenhouse gas emissions, hydrology and water quality, land use and planning, noise, public services, transportation, and utilities and service systems. Relative to the proposed project, the No Project/No Development Alternative would avoid construction related impacts as no physical development would occur. However, as discussed above, this
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alternative would not abate hazards associated with lead based paint and asbestos contained within the existing building and would present greater wildfire hazards as compared to the project as it would not incorporate fire resistant building techniques or implement the Vegetation Management Plan of the proposed project. Furthermore, the No Project/ No Development Alternative would conflict with the General Plan as it would not achieve the property’s, highest and best use or realize residential development as provided by the land use designation.
Attain Project Objectives
The No Project/No Development Alternative would fail to meet all stated project objectives, would be inconsistent with the General Plan objectives and land use designations, and would not provide housing needed to meet the city’s RHNA obligation.
6.4.2 Alternative 2: Park Pacifica Highland Subdivision: 54 Single Family Residences Description
The Park Pacifica Highland Subdivision: 54 Single Family Residences alternative represents an alternative that could occur based on the existing Low Density Residential General Plan Land Use designation, R-1 zoning designation, and underlying single family residential subdivision, originally recorded in 1965 with the County of San Mateo. The subdivision includes 56 single family lots, two remainder lots adjacent to the city-owned Frontierland Park, and four dedicated public rights-of-way. Since recordation of the subdivision in 1965, Lots 54 and 55, along Big Bend Drive to the north of the project site, have been developed.
As such, lots 54 and 55 are presumed to no longer be part of the subdivision and are therefore not considered in this alternative.
Under this alternative, the existing lots on the project site would be used for development rather than a re-subdivision of the land as proposed with the project. The entire 12.49-acre site, with the exception of the approximately 2.02-acre hillside area to the east (referred to as Lot D on the subdivision map), would be developed with single-family residences, including the existing recreational field at the southern portion of the site. Of the 54 single family residences, this alternative assumes construction of 16 accessory dwelling units (ADUs) for a total of 70 units on 54 lots. Development of the single-family residences and ADUs would be subject to regulations contained in Section 9-4.402 of the Pacifica Municipal Code, which permits a maximum of 40% lot coverage, and maximum building height of 35- feet. In addition, development of 54 single family residences and 16 ADUs would be subject to the minimum setbacks, landscaping, and parking requirements of the Municipal Code.
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Under this alternative, new water, sewer, and storm drain facilities would be installed to accommodate the residential units and the four dedicated rights-of-way shown on the subdivision map would be paved, and curb, gutter, and sidewalks would be installed.
Analysis
The following includes a discussion of the impacts of the Park Pacifica Highland Subdivision:
54 single family Residences Alternative as compared to the proposed Pacifica School District Workforce Housing project.
Aesthetics
Under the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative, the entire site, apart from the undeveloped hillside area along the eastern portion of the property, would be developed with single-family residences and associated improvements such as landscaping, fencing, sidewalks, curbs, gutters, and the four public rights-of-way shown on the Park Pacifica Highland Subdivision Map. As compared to the proposed project, this alternative would increase the overall site disturbance as it would result in development of the recreational field at the southern portion of the site, however, given the existing singlefamily residential character of the surrounding area, distance from eligible State Scenic Highways, limits on height established by the zoning designation, and general city regulations to reduce offsite light and glare, impacts under this alternative would be the same as the proposed project.
As compared to the proposed project, this alternative would result in a greater impact to the existing visual character as additional protected trees along Oddstad Boulevard and throughout the project site would be removed to accommodate the four public rights-of-way and individual single family-residences. Similar to the proposed project, Mitigation Measures AES-1 would be required to address removal of protected trees.
Air Quality
Air quality impacts resulting from the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would be the same as the proposed project. As with the proposed project, this alternative would be consistent with the 2017 Bay Area Clean Air Plan (CAP) as it would include (1) infill development on a previously developed site within existing urban limits and consequently would limit urban sprawl, (2) would implement best management practices (BMPs) set forth by the Bay Area Air Quality Management District (BAAQMD) to protect air quality during construction, and (3) would fall below the screening criteria level for single-family residential uses (325 du for operation and 114 du for construction) and thus
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would not be result in significant air quality impacts. Similar to the proposed project, this alternative would not conflict with the regional air quality plan and with implementation of Mitigation Measures AQ-1 and AQ-2 would not result in a cumulatively considerable increase in criteria pollutants during construction or at operation or result in significant impacts to sensitive receptors. As a residential use, similar to the proposed project, localized odors during construction would be temporary and not likely noticeable beyond the limits of the site and would not generate odors during operation. As such, air quality impacts of this alternative would be the same as the proposed project.
Biological Resources
The Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would increase the area of disturbance on the site and would consequently result in an increase in impacts to biological resources as compared to the proposed project. In addition to increasing the severity of impacts, under this alternative, additional potentially significant impacts would occur to special-status plant species, sensitive natural communities, seasonal wetlands, and jurisdictional features. As shown in Figure 6-1, additional impacts would potentially occur to the San Francisco dusky-footed woodrat and sensitive natural communities as compared to the proposed project. Specifically, development at the southern portion of the site would result in disturbance to additional middens observed during the site survey conducted for the Biological Resources Analysis as well as along the eastern portion of the site which currently contains inaccessible dense scrub that supports habitat for the woodrat. Similarly, this alternative would result in removal of sensitive natural communities at the southern and northern portions of the project site. As shown in Figure 6-1, this alternative would also result in additional impacts to seasonal wetlands and jurisdictional features.
As with the proposed project, impacts to the San Francisco dusky-footed woodrat, obscure bumblebee, California red-legged frog, bats, and birds would be reduced to less than significant with implementation of Mitigation Measures BIO-1 through BIO-6, however, impacts to the Choris’ popcornflower, seasonal wetlands, and jurisdictional features would be more impactful under this Alternative relative to the proposed project. Similar to the proposed project, this alternative would result in removal of protected trees, however, with implementation of Mitigation Measure AES-1 impacts to protected trees would be the same as the proposed project. Impacts to wildlife movement would be the same as the proposed project, and as there is no adopted Habitat Conservation plans within the project area, like the proposed project, there would be no impacts under this alternative.
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FIGURE 6-1: ALTERNATIVE 2 - ADDITIONAL IMPACTS TO SPECIAL-STATUS SPECIES AND HABITATS
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FIGURE 6-2: ALTERNATIVE 2 - ADDITIONAL IMPACTS TO WETLANDS
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Cultural and Tribal Cultural Resources
Under the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative, impacts to cultural and tribal cultural resources would be the same as the proposed project.
Potentially significant impacts to archaeological resources, human remains, and tribal cultural resources could result if such resources were encountered during construction. As with the proposed project, under this alternative, implementation of Mitigation Measures C/TCUL-1 and C/TCUL-2 would be required.
Geology and Soils
Given that this alternative would be subject to the same geologic conditions and setting as the proposed project, impacts resulting from substantial direct or indirect risks to life or property as a result of strong seismic ground shaking, liquefaction, landslides, lateral spreading, subsidence, and erosion as well as direct or indirect impacts to paleontological or unique geologic features would be the same as the proposed project. This alternative would be subject to the same mitigation measures as the proposed project including preparation of a design level geotechnical analysis and incorporation of all recommendations provided therein (Mitigation Measure GEO-1), compliance with regulations set forth in the Municipal Code as it relates to implementation of stormwater control measures (Mitigation Measure GEO-2), and steps to take in the event that paleontological resources are encountered during construction (Mitigation Measure GEO-3). As with the proposed project, the 54 single family residences under this alternative would connect to the existing sewer system. As such impacts related to septic tanks would be the same as the proposed project.
Greenhouse Gas Emissions
Though the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would result in construction of fewer dwelling units as compared to the proposed project, a greater portion of the site would be disturbed, and it is assumed that more building materials would be utilized as the detached single-family residences would be larger than the proposed townhome and flat units proposed by the project. As with the proposed project, this alternative would be subject to Mitigation Measures AQ-2 and GHG-1, which are aimed at reducing construction-related GHG emissions. At operation, GHG impacts would be similar to the proposed project and would not require additional mitigation. This alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases and as such would result in the same impacts as the proposed project.
Hazards and Hazardous Materials
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Under the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative, impacts resulting from the routine transport, use, or disposal of hazardous materials, use of hazardous materials within one-quarter mile of a school, exposure of people residing on the site to airport noise, interference with an emergency response or evacuation plan, and risk of loss, injury or death involving wildland fires would be the same as the proposed project.
As with the proposed project, under this alternative the existing buildings onsite would be demolished to accommodate construction of 54 single-family residences which could result in the release of hazardous materials into the environment. As such, this alternative would be subject to Mitigation Measure HAZ-1 to ensure the proper demolition and disposal of asbestos containing material and lead-based paint. The project site is not identified as a hazardous materials site and as such, impacts resulting from being located on such a site would be the same as the proposed project. With implementation of mitigation measures impacts resulting from hazards and hazardous materials under this alternative would be the same as the proposed project and no additional mitigation measures would be required.
Hydrology and Water Quality
The Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would result in an increase in impervious areas as compared to the proposed project. As such, impacts related to water quality, groundwater recharge, soil erosion, runoff, and flooding would be greater as compared to the proposed project. As with the proposed project, this alternative would be subject to regulations intended to protect water quality and reduce soil erosion and runoff such as implementation of BMPs during construction, and preparation of a stormwater control plan and stormwater pollution prevention plan. Through compliance with standard regulations, impacts to water quality, groundwater recharge, soil erosion, runoff, and flooding would be reduced to less than significant, as with the proposed project.
Land Use and Planning
Under the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative, no physical division of an established community would occur as this alternative would result in construction of 54 single-family residences in an established residential area. Under this alternative, single-family residence would be established on a site zoned for single-family uses and would therefore not conflict with applicable land use regulations. As with the proposed project, land use and planning related impacts would be less than significant.
Noise
Similar to the proposed project, the Park Pacifica Highland Subdivision: 54 Single Family
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Residences Alternative would result in temporary noise and vibration during construction.
To address potential impacts Mitigation Measure NOI-1 imposes noise abatement strategies which would reduce impacts to less than significant. Though this alternative would result in a greater project footprint, the same noise abatement measures would be required during construction and as such impacts would be the same as the proposed project. At operation, the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would generate noise typical of a single-family residential subdivision and similar to the proposed project would result in less than significant impacts. Under this alternative, the site would be subject to the same impacts as the proposed project as it relates to exposing people residing in the project area to excessive noise levels as a result of being locating in an airport land use plan.
Population and Housing
Under this alternative, the same number of residential units would be constructed as compared to the proposed project and as such the resulting population would be the same.
Impacts related to substantial population growth would therefore be the same as compared to the proposed project. Impacts resulting from displacement of housing units or people would be less than significant, as with proposed project, as there are no existing housing units onsite.
Public Services
Under this alternative the same number of housing units would be constructed as compared to the proposed project, and as such demand for police, fire, school, library, and other public services would be the same. Unlike the proposed project, this alternative would remove the recreational field at the southern portion of the site and as such there would be fewer recreational opportunities available to project residents and the surrounding neighborhood as compared to the proposed project. However, this alternative would be subject to applicable development impact fees intended to offset incremental increase in use of park facilities. 54 single-family units would not necessitate the expansion or construction of new parks that could result in substantial adverse physical impacts to the environment and therefore impacts of this alternative to public services would be less than significant, as with the proposed project.
Transportation and Traffic
Under the proposed project, VMT impacts were determined to be significant and unavoidable. Under the Park Pacifica Highland Subdivision: 54 Single Family Residences
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Alternative, VMT impacts would be significant as the single-family residences would generate a VMT per capita equivalent to the average for the project site, which is above the existing city wide average VMT per capita and therefore exceeds the threshold of 15% below the existing citywide average. There are no feasible mitigation measures that could reduce VMT impacts of this alternative to levels below significance, and therefore impacts under this alternative would be the same as the proposed project. This alternative would result in construction of additional residential uses to a site surrounded by other residential uses.
Development of the site under this alternative would be subject to all applicable policies and regulations related to parking, bicycle and pedestrian facilities, site design, and emergency access. As with the proposed project, compliance with applicable regulations would result in less than significant impacts to transportation and traffic including as a result of a conflict with applicable policies, plans, or programs, design hazards, or as a result of inadequate emergency access.
Utilities and Service Systems
Under this alternative, the same number of residential units would be constructed as compared to the proposed project, however, impacts would be greater than the proposed project as individual single-family residences would generate increased demand on public utilities as compared to the multi-family units proposed by the project. Though this alternative would generate more demand as compared to the proposed project, residential development at the site has been envisioned in the city’s General Plan and as such impacts to utilities including impacts to water, wastewater, stormwater, natural gas and other utilities, and solid waste, would remain at less than significant levels, as with the proposed project.
Wildfire
Under this alternative, as with the proposed project, impacts due to a conflict with an adopted emergency response or evacuation plan would continue to be less than significant as the increase in trips on surrounding roadways would be nominal and capacity would be sufficient for access to or from the site in the event of an emergency. As with the proposed project, this alternative would be required to comply with Chapter 7A of the California Building Code which sets forth requirements for development of sites located within the WUI. Compliance with applicable regulations intended to increase fire resistance of buildings as well as implementation of a vegetation management plan will ensure impacts associated with exacerbating wildfire risks would be less than significant, as with the proposed project.
The Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would
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construct four new dead-end public rights-of-way to access individual single-family residences, however, these roadways would not exacerbate wildfire risk and impacts of this alternative would be the same as the proposed project. This alternative would also maintain the eastern hillside of the site for defensible space, and as noted above would implement a vegetation management plan. As such, impacts to wildfire under this alternative would be the same as the proposed project.
Other Resource Topics
Similar to the proposed project, the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would not affect agricultural resources as the site is not designated nor currently used as agricultural land, would not result in impacts related to wasteful, inefficient, or unnecessary consumption of energy resources or conflicts with plans for renewable and energy efficiency, and would not result in loss of availability of known mineral resources as none are located on or adjacent to the site.
Under this alternative the existing recreational field located at the southern portion of the site would be removed, and as such impacts to recreational facilities would be greater as compared to the proposed project. Based on the size of this alternative, existing recreational facilities in the vicinity of the project site, and the requirement to pay in-lieu fees to offset incremental increase in use of park facilities, impacts resulting from use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration would occur would be less than significant. Similarly, this alternative would not necessitate construction or expansion of recreational facilities that could result in adverse physical impacts on the environment and impacts would be less than significant. As such, though this alternative would result in greater impacts to recreation as compared to the proposed project, impacts would be less than significant, and no mitigation would be required.
Conclusion
The following summarizes impacts of the Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative as compared to the proposed project and the alternative’s ability to meet the stated project objectives.
Avoid or Substantially Lessen Project Impacts
The Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would result in new or increased impacts to biological resources, hydrology and water quality, recreation, utilities and service systems. Impacts to aesthetics, air quality, archaeological resources,
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human remains, geology and soils, greenhouse gas emissions, land use and planning, noise, public services, transportation, and wildfire would be similar or the same as the proposed project.
Attain Project Objectives
The Park Pacifica Highland Subdivision: 54 Single Family Residences Alternative would fail to meet some of the stated project objectives as it would not provide workforce housing for current and future staff members of the Pacifica School District, would not provide rental rates and lease terms that enable and improve the District’s ability to retain and attract qualified faculty and staff, and would not maintain and expand recreational opportunities on site for use by the surrounding neighborhood, future residents, and organized recreational groups.
6.4.3 Alternative 3: Variation of Site Layout and Unit Types Description
The Variation of Site Layout and Unit Types Alternative assumes that Lot 1, at the southern portion of the project site, would be retained as a recreational field for use by the public, and Lots 2 and 3, totaling 7.47 acres would be developed in a varied layout and with a different unit mix as compared to the proposed project. Under this alternative, Building A, located at the eastern portion of Lot 2 would be relocated to the area of Buildings B1 and B2 and would include an additional floor with 14 units. The height of Building A would increase from 30- feet to approximately 40-feet. Under this alternative, the site would be rezoned from R-1 to Planned Development (P-D), which provides for flexibility in building height if the findings in Section 9-4.2211(a) of the PMC can be made. In addition to modification of the location of Building A, under this alternative, Building B3would be modified to eliminate two units for a total of four units. Under this alternative, the unit count and mix would be as follows:
• Building A (41 units)
32 one-bedroom
9 two-bedroom
• Building B3
2 two-bedroom
2 three-bedroom
• Buildings C1 and C2 (no change)
2 two-bedroom
2 three-bedroom
• Building D (no change)
11 one-bedroom
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6 two-bedroom
Analysis
The following includes a discussion of the impacts of the Variation of Site Layout and Unit Types Alternative as compared to the proposed Pacifica School District Workforce Housing project.
Aesthetics
As with the proposed project, Variation of Site Layout and Unit Types Alternative would result in a potentially significant impact associated with degradation of the existing visual character and quality of public views of the site and surrounding area however, as this alternative would result in construction of one building with three stories as opposed to two, impacts to scenic vistas including views of the San Pedro and Montara Ranges would be greater as compared to the proposed project. Though impacts would be greater as compared to the proposed project, the three-story residential building would be generally consistent with surrounding residential uses and would be located in the central portion of the site, providing a buffer between existing single-family residences to the north. As with the proposed project, implementation of Mitigation Measure AES-1 would be required for this alternative, which would ensure impacts related to degradation of the existing character as it relates to the removal of mature trees are reduced to a less than significant. All other impacts to aesthetics including impacts to a scenic vista, scenic resources within a state scenic highway, and light and glare would be the same as compared to the proposed project.
Air Quality
Similar to the proposed project, with implementation of Mitigation Measures AQ-1 and AQ2, the Variation of Site Layout and Unit Types Alternative would not result in a cumulatively considerable increase in criteria pollutants during construction or at operation or result in significant impacts to sensitive receptors. As with the proposed project, impacts due to a conflict with an applicable air quality plan, and other emissions such as odors will remain at less than significant.
Biological Resources
The Variation of Site Layout and Unit Types Alternative would relocate Building A, providing for a greater distance from special-status species located onsite and would consequently result in decreased impacts to biological resources as compared to the proposed project.
Though impacts to biological resources would be less under this alternative, as with the proposed project, implementation of Mitigation Measures BIO-1 through BIO-9 and AES-1
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would be required to reduce impacts to the San Francisco dusky-footed woodrat, obscure bumblebee, California red-legged frog, bats, birds, protected waters, and protected trees to less than significant. Impacts to wildlife movement under this alternative would be the same as the proposed project, and as there is no adopted Habitat Conservation plans within the project area, like the proposed project, there would be no impacts under this alternative.
Cultural and Tribal Cultural Resources
Under the Variation of Site Layout and Unit Types Alternative, impacts to cultural and tribal cultural resources would be the same as the proposed project. Potentially significant impacts to archaeological resources, human remains, and tribal cultural resources could result if such resources were encountered during construction. As with the proposed project, under this alternative, implementation of Mitigation Measures C/TCUL-1 and C/TCUL-2 would be required.
Geology and Soils
Under the Variation of Site Layout and Unit Types Alternative all elements of the proposed project would remain, except Building A would be relocated, and the number of units in Building B3 would be reduced by 2. Given that this alternative would be subject to the same geologic conditions and setting as the proposed project and would construct all other buildings and improvements the same as the proposed project, impacts to geology and soils under this alternative would be the same as the proposed project. Given that this alternative would install a three-story versus two-story building, specific geotechnical recommendations would need to be established. However, as with the proposed project, this alternative would be subject to Mitigation Measure GEO-1 which requires implementation of design-specific geotechnical recommendations as well as measures GEO-2 and GEO-3. The Variation of Site Layout and Unit Types Alternative would connect to the existing sewer system and therefore would not result in impacts related to septic tanks.
Greenhouse Gas Emissions
The Variation of Site Layout and Unit Types Alternative would result in construction of the same number of dwelling units and substantially the same disturbed area as compared to the proposed project. As such, GHG impacts are presumed to be the same as compared to the proposed project. During construction, this alternative would be subject to Mitigation Measure GHG-1, which is aimed at reducing construction-related GHG emissions. At operation, GHG impacts would be the same as compared to the proposed project as there would be the same number of dwelling units, and consequently the same GHG emissions
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would be generated. This alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases and as such would result in the same impacts as the proposed project.
Hazards and Hazardous Materials
Under the Variation of Site Layout and Unit Types y Alternative, impacts resulting from the routine transport, use, or disposal of hazardous materials, use of hazardous materials within one-quarter mile of a school, exposure of people residing on the site to airport noise, interference with an emergency response or evacuation plan, and risk of loss, injury or death involving wildland fires would be the same as the proposed project. As with the proposed project, under this alternative the existing buildings onsite would be demolished to accommodate construction of the residential development which could result in the release of hazardous materials into the environment. As such, this alternative would be subject to Mitigation Measure HAZ-1 to ensure the proper demolition and disposal of asbestos containing material and lead-based paint. The project site is not identified as a hazardous materials site and as such, impacts resulting from being located on such a site would be the same as the proposed project. With implementation of mitigation measures impacts resulting from hazards and hazardous materials under this alternative would be the same as the proposed project and no additional mitigation measures would be required.
Hydrology and Water Quality
The Variation of Site Layout and Unit Types Alternative would result in a marginal difference in impervious areas as compared to the proposed project. As such, impacts related to water quality, groundwater recharge, soil erosion, runoff, and flooding would be substantially the same as compared to the proposed project. As with the proposed project, this alternative would be subject to regulations intended to protect water quality and reduce soil erosion and runoff such as implementation of BMPs during construction, and preparation of a stormwater control plan and stormwater pollution prevention plan. Through compliance with standard regulations, impacts to water quality, groundwater recharge, soil erosion, runoff, and flooding would be reduced to less than significant, and as stated above would be substantially the same as compared to the proposed project.
Land Use and Planning
Under Variation of Site Layout and Unit Types Alternative, land use and planning impacts would be the same as the proposed project. No physical division of an established community or conflict with land use regulations would occur as this alternative would result
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in redevelopment of an underutilized site within and established residential area on a site zoned for residential use. Therefore, as with the proposed project, land use and planning related impacts under this alternative would be less than significant.
Noise
Similar to the proposed project, the Variation of Site Layout and Unit Types Alternative would result in temporary noise and vibration during construction. Though this alternative would result in construction of fewer buildings than the proposed project, compliance with Mitigation Measure NOI-1 would be required to reduce noise impacts during construction to less than significant. At operation, the Variation of Site Layout and Unit Types Alternative would generate the same noise levels as compared to the proposed project as it would introduce the same number of residential units. As with the proposed project noise at operation would be typical of residential land uses and impacts would continue to be less than significant. Under this alternative, the site would be subject to the same impacts as the proposed project as it relates to exposing people residing in the project area to excessive noise levels as a result of being locating in an airport land use plan.
Population and Housing
Under this alternative, the same number of residential units would be constructed as compared to the proposed project and as such the resulting population would be the same.
Impacts related to substantial population growth would therefore be the same as the proposed project. Impacts resulting from displacement of housing units or people would be the same as the proposed project as there are no existing housing units onsite.
Public Services
Under the Variation of Site Layout and Unit Types Alternative the same number of residential units would be constructed as compared to the proposed project, and as such demand for police, fire, school, library, recreational, and other public services would be the same as the proposed project.
Transportation and Traffic
Under the proposed project, VMT impacts were determined to be significant and unavoidable. Under the Variation of Site Layout and Unit Types Alternative, the same number of units at the same affordability rates would be constructed and would therefore exceed the threshold of 15% below the existing citywide average and impacts would be significant.
For the reasons discussed in Section 4.13, Transportation and Traffic, there are no feasible mitigation measures that could reduce VMT impacts of this alternative to levels below
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significance, and therefore impacts under this alternative would be the same as the proposed project. Though impacts under this alternative would be significant and unavoidable, implementation of Mitigation Measure TRA-1 and TRA-2 would still be required.
All other transportation and traffic impacts under the Variation of Site Layout and Unit Types Alternative would be the same as the proposed project. With implementation of Mitigation Measures TRA-3 and TRA-4, impacts would be reduced to less than significant as with the proposed project.
Utilities and Service Systems
Under this alternative, the same number of residential units would be constructed as compared to the proposed project, and as such demand on public utilities as compared to the proposed project would be the same. Impacts to utilities including impacts to water, wastewater, stormwater, natural gas and other utilities, and solid waste, would remain at less than significant levels, as with the proposed project.
Wildfire
Under the Variation of Site Layout and Unit Types Alternative, a greater degree of defensible space would be provided as Building A, which is located nearest to the undeveloped hillside, would be relocated. As such, impacts related to wildfire would be less than the proposed project. As with the proposed project, this alternative would be required to comply with Chapter 7A of the California Building Code related to WUI requirements and would also be required to implement a vegetation management plan. Through compliance with applicable regulations impacts associated with exacerbating wildfire risks as a result of the Variation of Site Layout and Unit Types Alternative would be less than significant, as with the proposed project.
Other Resource Topics
Similar to the proposed project, the Variation of Site Layout and Unit Types Alternative would not affect agricultural resources as the site is not designated nor currently used as agricultural land, would not result in impacts related to wasteful, inefficient, or unnecessary consumption of energy resources or conflicts with plans for renewable and energy efficiency, would not result in loss of availability of known mineral resources as none are located on or adjacent to the site, and would not result in impacts to recreational facilities as the use of existing recreational facilities onsite would remain unchanged. As such, impacts to other resource topics would be the same as the proposed project.
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Conclusion
The following summarizes impacts of the Variation of Site Layout and Unit Types Alternative as compared to the proposed project and the alternative’s ability to meet the stated project objectives.
Avoid or Substantially Lessen Project Impacts
The Variation of Site Layout and Unit Types Alternative would result in decreased or substantially similar impacts as the proposed project to all resource areas including aesthetics, air quality, biological resources, archaeological resources, human remains, geology and soils, greenhouse gas emissions, hazards, hydrology, land use and planning, noise, population and housing, public services, transportation, utilities, and wildfire. All mitigation measures identified for the proposed project would be applicable to the Variation of Site Layout and Unit Types Alternative and no additional mitigation measures would be needed.
Attain Project Objectives
The Variation of Site Layout and Unit Types Alternative would meet all of the project objectives.
Env ironmentally Superior Alterna tiv e
An EIR is required to identify the environmentally superior alternative from among the range of reasonable alternatives that are evaluated. Section 15126.6 (e)(2) of the State CEQA Guidelines require that an environmentally superior alternative be designated and states that if the environmentally superior alternative is the No Project alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives.
Under the No Project/No Development Alternative, no physical changes would occur on the project site, and no new environmental impacts beyond what currently exists would occur.
As such, the No Project/No Development alternative is considered the environmentally superior alternative as it would reduce or eliminate short-term, long-term, and cumulative impacts in all categories when compared to the proposed project.
The context of an environmentally superior alternative is based on the consideration of several factors including the reduction of environmental impacts to a less than significant level, the project objectives, and an alternative’s ability to fulfill the objectives with minimal impacts to the existing site and surrounding environment. As stated above and as shown in Table 6-1, the No Project/No Development alternative would be the environmentally
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superior alternative because it would eliminate all of the potentially significant impacts of the proposed project. However, while the No Project/No Development alternative is the environmentally superior alternative, it is not capable of meeting any of the project objectives.
After the No Project alternative, the environmentally superior alternative is that which would result in the fewest or least significant environmental impacts. Based on the analysis contained herein and as shown in Table 6-1, Alternative 3: Variation of Site Layout and Unit Types Alternative is the environmentally superior. Though this alternative would not avoid the proposed project’s significant and unavoidable transportation impacts, it is an environmentally superior project alternative because it would construct the same amount of units in fewer buildings as compared to the proposed project which would reduce all other potentially significant impacts as compared to the proposed project. This alternative is considered environmentally superior, and would achieve the stated project objectives.
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TABLE 6-1: COMPARISON OF PROJECT ALTERNATIVES
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
AES-1
Implementation of the proposed project
would not have a substantial adverse effect
on a scenic vista.
LTS/LTS NI = +
AES-2
Implementation of the proposed project
would not substantially damage scenic
resources, including, trees, rock
outcroppings, and historic buildings within a
state scenic highway.
LTS/LTS NI = =
AES-3
Development of the project site would
substantially degrade the visual character
and quality of public views of the site and its
surroundings.
PS/LTS NI + =
AES-4
The project would not create a new source
of substantial light or glare which would
adversely affect day or nighttime
LTS/LTS NI = =
AQ-1
Implementation of the proposed Pacifica
School District Workforce Housing project
would not conflict with or obstruct
implementation of an applicable air quality
plan.
LTS/LTS NI = =
6.0 ALTERNATIVES
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PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
AQ-2
Construction and operation of the proposed
project would generate emissions that
would result in a cumulatively considerable
net increase of any critical pollutant for
which the project region is non-attainment
under an applicable federal or state
ambient air quality standard.
PS/LTS NI = =
AQ-3
Implementation of the proposed project
would potentially expose sensitive
receptors to substantial pollutant
concentrations.
PS/LTS NI = =
AQ-4
Implementation of the proposed project
would not result in other emissions (such as
those leading to odors) adversely affecting a
substantial number of people.
LTS/LTS NI = =
BIO-1
The project could result in a substantial
adverse effect, either directly or through
habitat modifications, on species identified
as 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.
PS/LTS NI + -
6.0 ALTERNATIVES
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PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
BIO-2
The project would not result in 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 Game or US Fish and Wildlife
Service.
NI/NI NI + =
BIO-3
The project could 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.
LTS/LTS NI + =
BIO-4
The project would not interfere
substantially with the movement of any
native resident or migratory fish or wildlife
species or with established native resident
or migratory wildlife corridors or impede
the use of native wildlife nursery sites.
LTS/LTS NI = =
BIO-5
The project could conflict with local policies
or ordinances protecting biological
resources, such as a tree preservation policy
or ordinance.
PS/LTS NI + =
6.0 ALTERNATIVES
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PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
BIO-6
The project would not conflict with the
provisions of an adopted Habitat
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan.
NI/NI NI = =
C/TCUL-1
Implementation of the proposed project
would not cause a substantial adverse
change in the significance of a historical
resource pursuant to Section15064.5.
LTS/LTS NI = =
C/TCUL-2
Implementation of the project could
potentially cause a substantial adverse
change in the significance of an
archaeological resource pursuant to Section
15064.5
PS/LTS NI = =
C/TCUL-3
Implementation of the project could
potentially cause a significant impact due to
disturbance of human remains, including
those interred outside of formal cemeteries.
PS/LTS NI = =
C/TCUL-4
Implementation of the project could cause a
substantial adverse change in the
significance of a tribal cultural resource.
PS/LTS NI = =
6.0 ALTERNATIVES
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PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
GEO-1
The proposed project could potentially
directly or indirectly result in substantial
adverse effects, including the risk of loss,
injury, or death involving fault rupture,
strong seismic ground shaking, or seismicrelated ground failure including liquefaction and landslides.
PS/LTS NI = =
GEO-2
The proposed project could result in
substantial soil erosion or loss of topsoil. PS/LTS NI = = GEO-3
The proposed project would 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 offsite landslide, lateral spreading, subsidence, liquefaction or collapse.
PS/LTS NI = =
GEO-4
The proposed project would 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.
PS/LTS NI = =
6.0 ALTERNATIVES
6-37
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
GEO-5
The proposed project will not be located on
soils incapable of adequately supporting the
use of septic tanks or alternative
wastewater disposal systems where sewers
are not available for the disposal of waste
water.
NI/NI NI = =
GEO-6
The proposed project could directly or
indirectly destroy a unique paleontological
resource or site or unique geologic feature.
PS/LTS NI = =
GHG-1
Implementation of the proposed Pacifica
School District Workforce Housing project
would not generate greenhouse gas
emissions, either directly or indirectly, that
would result in a significant impact on the
environment.
PS/LTS NI + =
GHG-2
Implementation of the proposed project
would not conflict with an applicable plan,
policy or regulation adopted for the
purpose of reducing the emissions of
greenhouse gases.
LTS/LTS NI = =
HAZ-1
The proposed project would not create a
significant hazard to the public or the
environment through the routine transport,
use, or disposal of hazardous materials.
LTS/LTS NI = =
6.0 ALTERNATIVES
6-38
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
HAZ-2
The proposed project could 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.
PS/LTS NI = =
HAZ-3
The proposed project would not emit
hazardous emissions or involve handling
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school.
LTS/LTS NI = =
HAZ-4
The proposed project would not be located
on a site included on a list of hazardous
materials sites compiled pursuant to
Government Code Section 65962.5.
NI/NI NI = =
HAZ-5
The proposed project would be located
within an airport land use plan, but would
not result in a safety hazard or excessive
noise for people residing or working in the
project area.
LTS/LTS NI = =
HAZ-6
The proposed project would not impair
implementation of or physically interfere
with an adopted emergency response plan
or emergency evacuation plan.
LTS/LTS NI = =
6.0 ALTERNATIVES
6-39
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
HAZ-7
The proposed project could expose people
or structures, either directly or indirectly, to
a significant risk of loss, injury or death
involving wildland fires.
LTS/LTS NI = =
HYDRO-1
Implementation of the proposed project
would not violate any water quality
standards or waste discharge requirements
or otherwise substantially degrade surface
or groundwater quality.
LTS/LTS NI + =
HYDRO-2
Implementation of the project would not
substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the project
would impede sustainable groundwater
management of the basin.
LTS/LTS NI + =
6.0 ALTERNATIVES
6-40
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
HYDRO-3
Implementation of the proposed would not
substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would i) result
in substantial erosion or siltation on- or offsite; ii) substantially increase the rate or amount of surface runoff in a manner which
would result in flooding on- or offsite; iii)
create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or iv) impede or redirect
flood flows.
LTS/LTS NI + =
HYDRO-4
Implementation of the proposed project
would not result in the risk of release of
pollutants due to project inundation as a
result of being located in a flood hazard,
tsunami, or seiche zone.
LTS/LTS NI + =
HYDRO-5
Implementation of the proposed project
would not conflict with or obstruct
implementation of a water quality control
plan or sustainable groundwater
management plan.
LTS/LTS NI + =
6.0 ALTERNATIVES
6-41
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
LUP-1
The project would not physically divide an
established community.
LTS/LTS NI = =
LUP-2
The project would not conflict with any land
use plan, policy, or regulation adopted for
the purpose of avoiding or mitigating an
environmental impact.
LTS/LTS NI = =
NOI-1
The proposed project could involve
generation of 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.
PS/LTS NI = =
NOI-2
The proposed project would not result in
generation of excessive groundborne
vibration or groundborne noise levels.
LTS/LTS NI = =
NOI-3
The proposed project, would not expose
people residing or working in the project
area to excessive noise levels as a result of
being located in an airport land use plan.
NI/NI NI = =
6.0 ALTERNATIVES
6-42
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
POP-1
The project would not induce direct
substantial population growth in the area as
a result of construction of the proposed
units, nor would the project result in indirect
population growth in the area as a result of
expansion of public facilities, such as roads
or other infrastructure.
LTS/LTS NI = =
POP-2
The project would not displace substantial
numbers of existing people or housing,
necessitating the construction of
replacement housing elsewhere.
LTS/LTS NI = =
PS-1
The project would not require expansion or
construction of new governmental facilities
which could result in substantial adverse
physical impacts as a result of increased
demand for fire protection, police
protection, schools, parks, or other public
facilities.
LTS/LTS NI = =
TRA-1
The project will not conflict with a program,
plan, ordinance, or policy addressing the
circulation system including transit,
roadway, bicycle, and pedestrian facilities.
LTS/LTS NI = =
TRA-2
The project will conflict or be inconsistent
with CEQA Guidelines section 15064.3,
subdivision (B).
S/SU NI = =
6.0 ALTERNATIVES
6-43
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
TRA-3
The project will not substantially increase
hazards due to a geometric design or
incompatible uses.
PS/LTS NI = =
TRA-4
Implementation of the project will not result
in inadequate emergency access.
LTS/LTS NI = =
UTIL-1
Implementation of the proposed project
would not require or result in the relocation
or construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects.
LTS/LTS NI + =
UTIL-2
Implementation of project would have
sufficient water supplies available to serve
the project and reasonably foreseeable
future development during normal, dry and
multiple dry years.
LTS/LTS NI + =
UTIL-3
Implementation of the project would not
result in a determination by the wastewater
treatment provider which serves or may
serve the project that it does not have
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments.
LTS/LTS NI + =
6.0 ALTERNATIVES
6-44
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
UTIL-4
Implementation of the project would not
generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals.
LTS/LTS NI + =
UTIL-5
Implementation of the project would
comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste.
LTS/LTS NI + =
FIRE-1
The project would not substantially impair
an adopted emergency response plan or
emergency evacuation plan.
LTS/LTS NI = =
FIRE-2
The project would not exacerbate wildfire
risks due to slope, prevailing winds, and
other factors, and thereby would not
expose project occupants to pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire.
LTS/LTS NI = =
6.0 ALTERNATIVES
6-45
PROJECT IMPACT
PACIFICA SCHOOL
DISTRICT WORKFORCE
HOUSING PROJECT:
PROPOSED
PROJECT (BEFORE AND
AFTER MITIGATION)
ALT 1: NO PROJECT/NO
DEVELOPMENT
ALT 2: PARK PACIFICA
HIGHLAND SUBDIVISION:
54 SINGLE FAMILY
RESIDENCES
ALT 3: VARIATION OF
SITE LAYOUT AND UNIT
TYPES
FIRE-3
The project would not require installation or
maintenance of infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities) that
may exacerbate fire risk or that may result
in temporary or ongoing impacts to the
environment.
LTS/LTS NI = =
FIRE-4
The project would not expose people or
structures to significant risks, including
downslope or downstream flooding or
landslides, as a result of runoff, post-fire
slope instability, or drainage changes.
LTS/LTS NI = =
Key:
S Significant
SU Significant and unavoidable
PS Potentially significant
LTS Less than significant
NI No impact
= Impact similar to proposed project
- Impact less than proposed project
+ Impact greater than proposed project
7-1
7.0 References
Sources
The following sources were used in the preparation of this Draft Environmental Impact Report (DEIR). Each chapter/section lists the sources referenced at the end of the chapter/section.
1. 2019 California Fire Code, Chapter 1, Division 1, Section 1.1.3
2. 2020 Urban Water Management Plan for North Coast County Water District, https://www.nccwd.com/images/North_Coast_County_Water_District_2020_UWMP.pdf
3. 2021 Multijurisdictional Local Hazard Mitigation Plan Volume 2 Planning Partner Annexes, October 2021
4. 2021 Multijurisdictional Local Hazard Mitigation Plan Volume 2 Planning Partner Annexes, October 2021
5. C.3 Regulated Project Guide, San Mateo Countywide Water Pollution Prevention Program, Version 1.0, January 2020
6. California Air Resources Board, Sensitive Receptor Assessment https://ww2.arb.ca.gov/capp-resource-center/community-assessment/sensitivereceptor-assessment, accessed December 2021.
7. California Coastal Commission, Overview, https://www.coastal.ca.gov/whoweare.html, accessed February 25, 2022
8. California Code of Regulations, Title 5: Education Code
9. California Code, Government Code, Section 53311 et seq.: The Mello-Roos Community Facilities Act of 1982
10. California Code, Government Code, Section 65995 et seq.: Payment of Fees, Charges, Dedications, or Other Requirements Against a Development Project
11. California Code, Government Code, Section 66000 et seq.: Fees for Development Projects
12. California Code, Health and Safety Code, Sections 13000 et seq.: Fires and Fire Protection
13. California Department of Conservation, Alquist-Priolo Fault Zones
7.0 REFERENCES
7-2
14. California Department of Conservation, Division of Land Resource Protection, Farmland Mapping and Monitoring Program, 2018.
15. California Department of Conservation, San Mateo County Tsunami Hazard Areas, https://www.conservation.ca.gov/cgs/tsunami/maps/san-mateo
16. California Department of Education Data Quest, Enrollment Multi-Year Summary by Grade, Academic Year 2020-21, https://dq.cde.ca.gov/dataquest/, accessed March 11, 2022
17. California Department of Forestry and Fire Protection Fire Hazard Severity Zones Maps
18. California Department of Toxic Substances Control Envirostor, February 28, 2022.
19. California Environmental Quality Act Air Quality Guidelines, Bay Area Air Quality Management District, May 2017.
20. California Fish and Game Code
21. California Government Code, Title 7. Planning And Land Use [65000 - 66499.58], Division
2. Subdivisions [66410 - 66499.38], Chapter 4. Requirements [66473 - 66498], Article 1.
General [66473 - 66474.10], Section 6647.2(b)(2)
22. California State Water Resources Control Board, February 28, 2022.
23. CalRecycle Jurisdiction Per Capita Disposal Trends, Pacifica, 2020
24. CalRecycle SWIS Facility/Site Activity Details: Corinda Los Trancos Landfill (Ox Mtn) (41- AA-0002)
25. City of Pacifica 1980 General Plan
26. City of Pacifica 2015 - 2023 Housing Element
27. City of Pacifica 2040 General Plan EIR
28. City of Pacifica Climate Action Plan Implementation Report, October 2017
29. City of Pacifica Design Guidelines
30. City of Pacifica Municipal Code
31. City of Pacifica Wet Weather Equalization Basin Project Information Sheet
32. City of Pacifica, City Council Ordinance 884-C.S.
7.0 REFERENCES
7-3
33. City of Pacifica, Climate Action Plan Implementation Report, October 2017
34. City of Pacifica, Wastewater Treatment, Wastewater Collection, Sanitary Sewer System, https://www.cityofpacifica.org/departments/public-works/wastewatertreatment/wastewater-collection/sanitary-sewer-system
35. City/County Association of Governments, San Mateo County Congestion Management Program, Final Report, December 2019.
36. Comprehensive Airport Land Use Compatibility Plan for the Environs of San Francisco International Airport
37. County of San Mateo, 2014 Five-Year Countywide Integrated Waste Management Plan Review Report, October 2014
38. Designated Scenic Route Map for San Mateo County, California Department of Transportation (Caltrans), California Scenic Highway Mapping System;
39. Income, Location Efficiency, and VMT: Affordable Housing as a Climate Strategy by Gregory L. Newmark Ph.D and Peter M. Haas Ph.D, Center for Neighborhood Technology, December 16, 2015.
40. Jack Schreder & Associates, Inc., Level I Developer Fee Study for Jefferson Union High School District, July 28, 2020
41. Jack Schreder & Associates, Inc., Level I Developer Fee Study for Pacifica School District, June 14, 2018
42. Local Coastal Land Use Plan, Plan Pacifica, https://www.planpacifica.org/local-coastalprogram, accessed February 25, 2022
43. Maps numbered 06081CO128E, 06081CO129E,
https://msc.fema.gov/portal/search?AddressQuery=930%20Oddstad%20Blvd%2C%20P acifica%2C%20CA#searchresultsanchor
44. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, U.S. Department of the Interior, National Park Service, 1990
45. North Coast County Water District, 2020 Urban Water Management Plan, June 2021
46. North County Fire Authority, 2020 Annual Report
47. Pacifica Police Department, Annual Report 2016
7.0 REFERENCES
7-4
48. Plan Bay Area 2050 Final Plan, Implementation Plan, and Environmental Impact Report https://www.planbayarea.org/
49. San Francisco Regional Water Quality Control Board, Revised Tentative Order, Amendment of Cease and Desist Order for City of Pacifica Calera Creek Water Recycling Plant and Wastewater Collection System in Pacifica, San Mateo County,
50. San Mateo County Datasets, Williamson Act Parcels, 2016.
51. San Mateo County Integrated Waste Management Plan, Final Draft, January 8, 1999
52. San Mateo County Land Conservation (Williamson) Act, San Mateo County Planning and Building Department, 2013.
53. San Mateo County Libraries, Open for Exploration, Annual Report, 2020-2021
54. San Mateo County Recorder, Park Pacifica Highlands No. 1, Volume 63, Pages 13-15
55. State of California Tribal Consultation Guidelines, Supplement to General Plan Guidelines, prepared by the Governor’s Office of Planning and Research, November 14, 2005
56. Superior Court of California, County of San Mateo, Planning for the County’s Waste Management Challenges, 2018-2019 San Mateo County Civil Grand Jury, 2019
57. The Harry Tracy Water Treatment Plant Fact Sheet, February 2017
58. U.S. EPA, Understanding the Safe Drinking Water Act, June 2004
59. United States Army Corps of Engineers, Nationwide Permit 41 – Reshaping Existing Drainage and Irrigation Ditches, Effective February 25, 2022, NWP Final Notice, 86 FR 73522
60. United States Code
61. United States Environmental Protection Agency (EPA), Overview of Greenhouse Gases, https://www.epa.gov/ghgemissions/overview-greenhouse-gases
62. United States Geological Survey, The Modified Mercalli Intensity Scale Persons Consulted
Patrick Kobernus, Principal Wildlife Biologist, Coast Ridge Ecology Gary Black, President, Hexagon Transportation Consultants, Inc.
7.0 REFERENCES
7-5
Report Prepa rers
M-Group:
Olivia Ervin, Principal
Krystle Rizzi, Project Manager and Senior Planner
Ranu Aggarwal, AICP, Principal Planner
Justin Shiu, Senior Planner
Eric Roberts, Associate Planner
Alaina Lipp, Associate Planner