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Attach 1_Exhibit A_EIR Addendum.pdf

Richmond City Council
January 24, 2023

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Attach 1_Exhibit A_EIR Addendum.pdf
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January 24, 2023
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CITY OF RICHMOND
General Plan Updates:

Housing Element,
Environmental Justice
Element, and
Amendments to the
Public Safety & Noise
Element

Addendum to the
Richmond General Plan Update
Final Environmental Impact Report
(SCH# 2008022018)

December 12, 2022
Planning Commission Hearing Draft
Prepared by

Table of Contents
1 INTRODUCTION ................................................................................................................... 1

1.1 Purpose of Addendum and Legal Standards ................................................................................ 2

1.2 Project Background; General Plan EIR ........................................................................................ 4

1.3 Documents Incorporated by Reference ........................................................................................ 5 2 PROJECT DESCRIPTION ....................................................................................................... 6

2.1 Regional and Project Location ........................................................................................................ 6

2.2 The General Plan Updates .............................................................................................................. 6 3 ENVIRONMENTAL ANALYSIS ............................................................................................. 24

3.1 Land Use Consistency and Compatibility ................................................................................... 25

3.2 Air Quality ........................................................................................................................................ 26

3.3 Biological Resources ....................................................................................................................... 30

3.4 Cultural Resources .......................................................................................................................... 31

3.5 Climate Change/Greenhouse Gas Emissions ............................................................................ 34

3.6 Geology, Soils, and Minerals ......................................................................................................... 38

3.7 Hazards and Hazardous Materials ................................................................................................ 40

3.8 Hydrology and Water Quality ....................................................................................................... 42

3.9 Noise ................................................................................................................................................. 44

3.10 Parks and Recreation ...................................................................................................................... 45

3.11 Public Services ................................................................................................................................. 46

3.12 Public Utilities.................................................................................................................................. 48

3.13 Transportation and Circulation .................................................................................................... 50

3.14 Visual Resources ............................................................................................................................. 52

3.15 Population and Housing ................................................................................................................ 54 4 CONCLUSION ..................................................................................................................... 56 REFERENCES ........................................................................................................................... 58

General Plan Updates: Housing Element, Environmental Justice Element, and Amendments to Public Safety & Noise Element
Addendum to the Final EIR
ii
List of Tables
Table 1: RHNA Allocation and Percentage of Income Distribution for Richmond ...................... 9 Table 2: Richmond Housing Element Goals and Policies ................................................................10 Table 3: Summary of Implementation Actions ...................................................................................17 List of Acronyms and Abbreviations
AB Assembly Bill
ABAG Association of Bay Area Governments
AMI Area Median Income
CalEPA California Environmental Protection Agency
CEQA California Environmental Quality Act
City City of Richmond
County Contra Costa County
DEIR Draft Environmental Impact Report
DOF California Department of Finance
EIR Environmental Impact Report
FEIR Final Environmental Impact Report
GHG Greenhouse gas
HCD California Housing and Community Development Department NPDES National Pollutant Discharge Elimination System
Project General Plan Updates, including Housing Element, Environmental Justice Element, and Amendments to the Public Safety and Noise Element
RHNA Regional Housing Needs Allocation
RMC Richmond Municipal Code
SB Senate Bill
VMT vehicle miles traveled

1 Introduction
This Addendum Report is intended to serve as the environmental documentation for the City of Richmond‘s proposed General Plan Updates, which include a Housing Element, a new Environmental Justice Element, and Amendments to the Public Safety and Noise Element. It is an addendum to the City of Richmond General Plan 2030 Final Environmental Impact Report ( EIR) SCH# 2008022018 to demonstrate that the analysis contained in that EIR adequately addresses the potential physical impacts associated with implementation of the City’s proposed General Plan updates, as required by the Califor nia Environmental Quality Act (CEQA) and that none of the conditions described in CEQA Guidelines Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.

The “proposed project” analyzed i n this addendum is the proposed 6th Cycle (2023 -2031) Housing Element, October 2022 Environmental Justice Element , and Amendments to the Public Safety and Noise Element to include evacuation route analysis and associat ed policies and actions, as required by State law. State law requires that housing elements be updated every eight years (California Government Code Sections 65580 to 65589.8). The Housing Element Update identifies residential sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups, defined under State law (California Government Code Section 65583). It analyzes governmental constraints to housing maintenance, improvement, and development; address es conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The City of Richmond Housing Element is being updated as part of the State’s 6th cycle Regional Housing Needs Allocation (RHNA).

The proposed General Plan Update is also intended to meet the community’s and City Council’s vision for environmental justice, hazard mitigation, evacuation route planning , and emergency preparedness ensuring that the City maintains the character established in the 2030 General Plan and the policies and implementing actions for economic development, growth management, land use and transportation, community health and wellnes s, environmental stewardships, and community facilities and services. This section explains the background and purpose of the addendum, establishes its context and scope, and provides references to relevant previous environmental review documents and reports. The City of Richmond is the Lead Agency for the proposed project for purposes of e nvironmental review under CEQA.

The term “l ead agency” is defined by S ection 21067 of CEQA as “the p ublic agency which has the p rincipal responsibility for carrying out or approving a p roject which may have a significant effect upon the environment.”
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2 1.1 Purpose of Addendum and Legal Standards
As required by CEQA G uidelines, the City of Richmond has reviewed the i nformation regarding the proposed project and determined that it is appropriate to prepare an addendum to the certified Final EIR on the General Plan Updates. The p rimary purpose of this addendum is to satisfy CEQA requirements by fully documenting why impacts that may occur as a result of adopting the proposed amendment are consistent with impacts studied in the General Plan Final EIR. The addendum describes why the proposed project would not result in a s ubstantial increase in the severity of p reviously identified significant effects, or n ew information of substantial importance when compared to the analysis in the certified General Plan Final EIR. The proposed General Plan Updates are described in Section 2 of the addendum.

These General Plan Update s do not change the designation of f uture land uses , so new development will be subject to the same standards and review procedures current ly in place.

Additionally, all development will continue to be subject to review on a project -by-project basis to determine compliance with CEQA. If necessary, project-level CEQA review will be required to determine project-specific impacts.

CEQA Guidelines Section 15162 specifies the type of documentation required when changes are proposed to a project. CEQA Guidelines Section 15162 states:
“(a) When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new significa nt environmental effects or a substantial increase in the severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence a t the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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3 (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mit igation measure or alternative.
(b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subdivision (a). Otherwise the lead agency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation.
(c) Once a project has been approved, the lead agency's role in project approval is completed, unless further discretionary ap proval on that project is required.

Information appearing after an approval does not require reopening of that approval.

If after the project is approved, any of the conditions described in subdivision (a) occurs, a subsequent EIR or negative declaration shall only be prepared by the public agency which grants the next discretionary approval for the project, if any. In this situation no other responsible agency shall grant an approval for the project until the subsequent EIR has been certified or subsequent negative declaration adopted. (d) A subsequent EIR or subsequent negative declaration shall be given the same notice and public review as required under Section 15087 or Section 15072. A subsequent EIR or negative declaration shall state where the previou s document is available and can be reviewed.”
Section 15164 of the CEQA Guidelines includes situations when a subsequent or supplemental EIR is not required. CEQA Guidelines Section 15164 states:
“(a) The lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. (b) An addendum to an adopted negative declaration may be pre pared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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4 (c) An addendum need not be circulated for public r eview but can be included in or attached to the final EIR or adopted negative declaration. (d) The decision making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project. (e) A brief ex planation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency's findings on the project, or elsewhere in the record. The explanation must be supported by substantial evidence.”
The proposed project would fulfill none of the conditions outlined in the CEQA Guidelines above; it would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects requiring major revisions to the General Plan EIR. In fact, the General Plan Updates would reduce environmental impacts from the land uses contemplated in the 2030 General Plan. Therefore, consideration and approval of this addendum will satisfy the requirements of CEQA, and no further analysis is required. This is because th e proposed General Plan Updates (the Environmental Justice Element , the amendments to the Public Safety and Noise Element and the Housing Element Update) would not permit more development or land uses of greater height or greater intensity than permitted under the adopted General Plan and would not allow new development in areas where such development is prohibited under the General Plan.

1.2 Project Background; General Plan EIR
On April 25, 2012, the Richmond City Council certified the Richmond General Plan Update Environmental Impa ct Report (SCH# 2008022018) and approved the Richmond General Plan 2030. The City's General Plan 2030 contains elements addressing land use, economic development, transportation, climate change, public safety, arts and culture, and open space conservation strategies to establish the framework for population and job growth and for provision of public services and facilities. General Plan 2030 is intended to guide development in the city through the year 2050. The analysis in the General Plan EIR addressed the short- and long-term impacts of the city -wide General Plan. The General Plan EIR also included analysis of alternatives and cumulative impacts associated with buildout of the General Plan. The EIR evaluated the potential for environmental impacts in the followin g issue areas:

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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5 • Land Use Consistency and
Compatibility
• Demographics
• Air Quality
• Biological Resources
• Climate Change
• Cultural Resources
• Geology, Soils, and Minerals
• Hazards, Public Safety, and Flooding
• Hydrology and Water Quality
• Noise
• Parks and Recreation
• Public Services
• Public Utilities
• Transportation and Circulation
• Visual Resources

1.3 Documents Incorporated by Reference
The General Plan Update Draft EIR (DEIR) and Final EIR (FEIR) evaluated impacts associated with the City’s General Plan, including cumulative impacts associated with future development occurring under the General Plan. These documents, in their entirety, as well as the General Plan EIR Addendum for Change Area 12 , the Addendum for the zoning and subdivision regulations update, the Addendum for the 100 38th Street Project, and the technical reports and appendices p repared in conjunction with the previous General Plan D EIR and FEIR, are incorporated by reference into this addendum. Technical documents supporting the General Plan DEIR and FEIR, the addenda noted above, and this addendum are available for review at the City of Richmond Community Development Department. The General Plan DEIR and FEIR are also a vailable online at: www.ci.richmond.ca.us/2608/General-Plan- 2030.

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6 2 Project Description
The project analyzed in this Addendum is the proposed Environmental Justice Element, the amendments to the Public Safety and Noise Element , and the Housing Element Update , which together constitute the General Plan Updates. The proposed General Plan Updates are intended to implement State law, which calls for an Environmental Justice Element in General Plans, evacuation route planning in Safety Elements, and periodic updates to the General Plan Housing Element and reflect the community’s and City Council’s vision on these subjects .

This project description provides background information regarding the scope of the Environmental Justice Element, the amendments to the Public Safety and Noise Element, and the Housing Element Update , as well as the goals and policies of the proposed updates.

Additional details are provided in the proposed Hearing Drafts for General Plan Update, which are included as attachments to the City Staff Report for this action and can be reviewed on the City’s website (www.ci.richmond.ca.us/151/Council-Agenda-Documents or www.ci.richmond.ca.us/2864/Planning-Commission).

2.1 Regional and Project Location
The City of Richmond is located i n western Contra Costa County, California, on the San Francisco Bay. It is east of San Francisco and north of Berkeley and Oakland. The city boundaries of Richmond include the Point Pinole Regional Shoreline in the north, Sobrante Ridge Regional Preserve in the northeast, Wildcat Canyon Regional Park in the east, and the more urbanized areas of downtown Richmond and the Richmond Harbor in the southeast and central Richmond. Between these different areas of Richmond are the City of San Pablo and the unincorporated area known as North Richmond. San Pablo is entirely surrounded by Richmond, and North Richmond is surrounded by Richmond and a small area of coastline on the San Pablo Bay.

This project applies to all land within the City’s planning area, as establi shed for the 2030 General Plan.

2.2 The General Plan Updates

BACKGROUND
The City of Richmond’s General Plan governs the land use and physical development within the City. The General Plan sets the long -range policy for the City and provides a unified and coherent framework and vision for the future of the community. The General Plan is the primary means for guiding future land use changes in Richmond.

State law requires that housing elements be updated every eight years (California Government Code Section 65588). The Housing Element must identify residential sites adequate to accommodate a variety of housing types for all income levels and to meet the needs of special General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
7 population groups as defined under State law (California Government Code Section 65583).

The Housing Element analyzes market and governmental constraints to housing maintenance, improvement, and dev elopment; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The City of Richmond Housing Element is now being updated as part of the 6th cycle RHNA allocation, which is for planning period 2023 through 2031.

The following items represent substantive changes to State housing law since the City’s last Housing Element was adopted and certified in 2013. The Housing Element update has incorporated and addressed all pertinent housing law changes. • Affordable Housing Streamlined Approval Process: Senate Bill 35 (2017) • Additional Housing Element Sites Analysis Requirements: Assembly Bill 879 (2017) and Assembly Bill 1397 (2017)
• Affirmatively Furthering Fair Housing: Assembly Bill 686 (2017) • No-Net-Loss Zoning: Senate Bill 166 (2017)
• Safety Element to Address Adaptation and Resiliency: Senate Bill 1035 (2018) • By Right Transitional and Permanent Supportive Housing: Assembly Bill 2162 (2018) and Assembly Bill 101 (2019)
• Accessory Dwelling Units: Assembly Bill 2299 (2016), Senate Bill 1069 (2016), Assembly Bill 494 (2017), Senate Bill 229 (2017), Assembly Bill 68 (2019), Assembly Bill 881 (2019), Assembly 587 (2019), Senate Bill 13 (2019), and Assembly Bill 671 (2019) • Density Bonus: Assembly Bill 1763 (2019)
• Housing Crisis Act of 2019: Senate Bill 330
• Surplus Land Act Amendments: Assembly Bill 1486 and AB 1255 (2019) • Housing Impact Fee Data: Assembly Bill 1483 (2019)
• Emergency and Transitional Housing Act of 2019: Assembly Bill 139 (2019) • Standardization of Sites Inventory Analysis and Reporting: Senate Bill 6 (2019) • Evacuation Routes: Senate Bill 99 and AB 747 (2019)
Further, since the adoption of General Plan 2030, new information on shoreline planning has been released. Specifically, the Federal Emergency Management Agency (FEMA) has prepared and issued new Flood Insurance Rate Maps (FIRM) for many of Richmond’s shoreline areas.

Also, the Bay Conservation and Development Commission (BCDC) released its Adapting to Rising Tides Contra Costa County Sea Level Rise Vulnerability Assessment report in February 2016, which includes a broad assessment of the county’s shoreline exposure to flooding or inundation from sea level rise and extreme tide events. Finally, the City participated with General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
8 Contra Costa County in preparation of a local hazard mitigation plan1; Volume 2 of the Contra Costa County Hazard Mitigation Plan includes the Richm ond Annex, which is proposed to be adopted by the City as part of the amendments to the Public Safety and Noise Element.

In addition, the City adopted the Richmond Bay Specific Plan (RBSP) in 2016 , which is intended to accommodate growth along Richmond’s s outhern shoreline, including approximately 11.4 million square feet of new research and development, business, and service space, as well as housing near transit within the South Richmond Priority Development Area (PDA). With adoption of the RBSP, the City reassessed whether anticipated job growth in certain sectors should be directed to the Richmond Bay Specific Plan area and whether the supply of vacant and underutilized industrial land elsewhere in the City is more than sufficient to meet future needs for industrial space. The results of this assessment were reflected in a General Plan amendment for Change Area 12.

As a result of the General Plan Housing Element update required by State law, the City is required to update the Public Safety and Noise Element of the General Plan to include additional information on emergency preparedness, fire risks and evaluation routes, including route mapping and capacity analysis under alternative emergency preparedness. In addition, because two General Plan elements would be updated, the City is obligated, under the provisions of Senate Bill 1000, passed in 2016, to address environmental justice in the General Plan as well because the City has CalEPA identified disadvantaged communities within its boundaries. This could be done in a freestanding Environmental Justice Element pr through amendments to the other General Plan elements to integrate environmental justice goals, policies and objectives into them. The City has decided to prepare a separate Environmental Justice Element along with the required amendments to the Public Safety and Noise Element.

The amendments to the Public Safety and Noise Element include specific information required by State law (Assembly Bill (AB) 747 and Senate Bill (SB) 99:
• Map(s) of hazard zones;
• Identification and mapping of evacuation routes under a range of emergency scenarios and an analysis of their capacity (AB 747); and
• Identification of residential development with one point of egress (SB 99).

1 https://www.contracosta.ca.gov/6842/Local-Hazard-Mitigation-Plan

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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9 THE HOUSING ELEMENT
Regional Housing Needs Allocation
The RHNA reflects the California Department of Housing and Community Development’s determination of the projected housing needs in a region by household income level as a percent of the Area Median Income (AMI). The Association of Bay Area Governments (ABAG) was tasked with allocating this regional housing need among the jurisdictions in the ABAG region, which includes Richmond. Error! Reference source not found. shows the breakdown of the RHNA for Richmond during the 2023-2031 planning period. As shown in the Table, the City’s total RHNA is 3,614 units. The City had 40,831 households as of January 2022 (California Department of Finance [DOF] 2022).

Table 1: RHNA Allocation and Percentage of Income Distribution for Richmond Income Level Percent of Area Median Income (AMI) Units Percent Extremely Low and Very Low <50% 840 23%
Low 50-80% 485 13%
Moderate 80-120% 638 18%
Above Moderate >120% 1,651 46%
Total – 3,614 100%
Source: Association of Bay Area Governments Methodology and numbers were approved by ABAG’s Executive board on January 21, 2021 (Resolution No. 02-2021).

Housing Element Update Components
The 2022 Housing Element Update has the following major components:
• Introduction: An introduction to review the requirements of the Housing Element, public participation process, and data sources (Section I)
• Projected Housing Need: A profile and analysis of the cit y’s demographics, housing characteristics, and existing and future housing needs (Section II) • Housing Resources: A review of resources available to facilitate and encourage the production and maintenance of housing, including land available for new constru ction, financial and administrative resources available for housing, and opportunities for energy conservation (Section III)
• Housing Plan: A statement of the Housing Plan to address the city’s identified housing needs, including an assessment of past accom plishments, and a formulation of housing goals, policies, and programs (Section IV)
A series of appendices provide additional documentation. Appendix A provides information on the housing needs assessment, Appendix B is the sites inventory and methodology , Appendix C is the Housing Constraints, Appendix D is the Existing Programs Review, Appendix E is a summary of Public Participation, Appendix F includes information on Furthering Fair Housing, and Appendix G includes Housing Resources.

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10 Meeting the RHNA
State law requires that the goals and policies of the housing element shall encourage and facilitate the production of a range in types of housing affordable to households of varied income levels. The City supports this goal by identifying adequate sites for residential development (vacant sites and underutilized sites) that are appropriately zoned for the type and density that can accommodate housing for certain income levels. The Housing Element also identifies programs the City will take to support and incentivize housing development and address the City’s housing needs.

The vacant and underutilized sites identified for new housing can adequately accommodate the City’s RHNA as determined by the state Housing and Community Development Department (HCD) for t he 2023-2031 planning period. The City has identified an adequate number of sites so as to not require rezoning as part of the Housing Element Update ; therefore, no rezones are proposed. HCD reviews the Housing Element for adequacy.

Goals, Policies, and Programs
The primary objective of the Housing Element is to encourage the production of new housing units to meet the RHNA and housing for special needs populations. This is done by adopting a series of goal and policies that support housing programs related to housing production, special needs housing, neighborhood quality and fair housing. Table 2, below, includes a full list of Housing Element Update goals and associated policies.

Table 2: Richmond Housing Element Goals and Policies
Goals Supportive Policies
Goal 1: Promote new housing
construction to create more
equitable and affordable options
that meet Richmond’s Regional
Housing Needs Allocation
(RHNA).

Policy 1.1 Housing Element Implementation. Coordinate and monitor the implementation of the City’ s Housing Element
Policy 1.2 Adequate Supply of Housing Sites. Ensure an adequate supply of housing sites to achieve the City’s Regional Housing Needs Allocation numbers for the 2023-2031 planning period
Goal 2: Facilitate different
housing types to accommodate
housing needs of moderate- and
lower-income households and
create inclusive neighborhoods
for all income levels.

Policy 2.1 Supply of Affordable Housing. Promote the development of homes that are affordable to extremely low, very low, low, and moderate- income households in all new residential developments as well as in existing single-family neighborhoods.

Policy 2.2 Variety of Housing Choices and Access. Promote a variety of housing types that meet the different lifestyle and life cycle needs of residents including young adults, young couples and single professionals, small and large families, empty-nesters, and older couples.

Policy 2.3 Funding for Affordable Housing Development. Identify and secure funding sources to assist with affordable housing development Policy 2.4 Balanced Neighborhoods. Encourage a mix of affordable and market rate housing within neighborhoods.

Policy 2.5 Rent Subsidies for Affordable Housing. Identify and secure funding to provide rent subsidies that assist extremely low and very low- income families, seniors, and persons.

Goal 3: Remove constraints to
the development of housing.

Policy 3.1 Reduction of Housing Production Constraints. Implement measures to remove or reduce constraints to housing production in Richmond.

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11 Goals Supportive Policies
Policy 3.2 Collaboratively Address Constraints. Consult with stakeholders (e.g., housing organizations, for- and non-profit developers) to identify and seek solutions to address constraints to housing production.

Goal 4: Create housing
opportunities for people with
special needs, including seniors,
persons with disabilities, single-
parent households, first-time
homebuyers, large families,
unhoused individuals and
families.

Policy 4.1 Senior Housing Development. Actively seek to expand the development of affordable housing for extremely low, very low, low and moderate-income seniors.

Policy 4.2 Accessible Housing Opportunities. Actively seek to expand housing opportunities for persons with disabilities in new and existing single- family and multifamily developments.

Policy 4.3 Child Daycare. Actively seek to expand child daycare opportunities to assist single-parent and dual-income households, especially those who are extremely low, very low, low, and moderate income.

Policy 4.4 First-Time Homebuyer Opportunities. Actively seek to expand housing opportunities for extremely low, very low, low, and moderate income first-time homebuyers
Policy 4.5 Large-Family Housing. Actively seek to expand housing opportunities for large families that are extremely low, very low, low, and moderate income
Goal 5: Conserve and improve
the existing housing stock to
enhance quality of life and
provide greater housing stability
and community resiliency.

Policy 5.1 Preservation and Modernization of Public Housing.

Preserve and systematically modernize Richmond’s public housing developments.

Policy 5.2 Conservation of At-Risk Affordable Housing Units. Facilitate the conservation of subsidized housing developments that are at risk of converting to market rate housing.

Policy 5.3 Abatement of Foreclosures, Substandard Housing, and Blight. Improve the physical, social, and economic health of neighborhoods by addressing foreclosures, substandard housing conditions, and neighborhood blight through a balanced program of education, code enforcement, inspections, acquisition, and financial assistance.

Goal 6: Promote fair housing
access and opportunities for all
persons.

Policy 6.1 Tenant Protections. Explore reasonable and enforceable regulations that protect tenants from evictions and exorbitant rent increases and refer residents with issues such as foreclosures, landlord-tenant disputes, and unlawful evictions, and housing discrimination to counseling services.

Policy 6.2 Discrimination Prevention. Identify, monitor, and prevent discriminatory housing practices.

Policy 6.3 Displacement Avoidance. Create housing stability for current residents by supporting limited equity and community ownership models and facilitating the preservation and production of affordable housing units.

Policy 6.4 Resources Alignment. Prioritize programming and align funding and resources, including City staff, with highest needs.

Policy 6.5 Lower Income Family Needs. Assess unit size production of publicly subsidized units and align target units sizes of publicly funded and private development projects with the needs of lower income families with children as feasible
Goal 7: Encourage energy and
resource conservation and
sustainability measures.

Policy 7.1 Green Building Measures and Practices. Promote the incorporation of green building measures and practices in new residential development projects and existing residential structures.

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12 THE ENVIRONMENTAL JUSTICE ELEMENT
The Environmental Justice Element provides a specific lens through which to advance equity and protect human health. The scope of environmental justice has broadened beyond its original focus on environmental contamination and degradation to include policy topics such as food access and physical activity. State legislation has adopted several laws and programs that promote and incorporate environmental justice into decision-making.

In 2016, State lawmakers passed Senate Bill (SB) 1000 (Government Code Section 65302(h)), requiring that cities that have “disadvantaged communities ” within their borders include environmental justice goals, policies, and objectives in their general plans to improve health outcomes in such areas. Specifically, the environmental justice goals, policies, and actions must do all of the following:
• Identify objectives and policies to reduce the unique or compounded health risks in disadvantaged communities by means that include, but are not limited to, the reduction of pollution exposure, including the improvement of air quality, and the promotion of public facilities, food access, safe and sanitary homes, and physical activity. • Identify objectives and policies to promote civic engagement in the public decision-making process.
• Identify objectives and policies that prioritize improvements and programs that address the needs of disadvantaged communities.

As defined in SB 1000, a “disadvantaged community” refers to “an area identified by the California Environmental Protec tion Agency [CalEPA] pursuant to Section 39711 of the Health and Safety Code or an area that is a low-income area that is disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation.” As of 2022, there are approximately 10 census tracts within or intersecting the City of Richmond that are designated as “disadvantaged communities” by CalEPA pursuant to SB 535. Moreover, SB 1000 stipulates that jurisdictions subject to this subdivision shall adopt or review the environmental justice element or related goals, policies, and objectives upon the adoption or next revision of two or more elements concurrently on or after January 1, 2018. In addition to the Public Safety and Noise Element included in the General Plan Update, the City of Richmond is also updating its Housing Element for the sixth housing cycle (2023 to 2031), as previously noted . Given these conditions, t he proposed Environmental Justice Element fulfills the C ity of Richmond’s obligation to meet these legal requirements.

Key Findings
The following list summarizes the key findings based on assessment of existing conditions related to environmental justice:
• There is a moderate degree of neighborhood segregation b y race, with a clear delineation between areas in which white residents represent the majority or highest concentration versus those that are communities of color. In addition, there has been a substantial General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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13 increase in the number and overall proportion of H ispanic or Latinx populations, while the Black or African American racial group is the only one that declined in Richmond over the last 10 years.
• There is a clear health equity gap that most affects communities living in western Central Richmond, while neighborhoods in the hills are least impacted. This geographic pattern is consistent across issues such as pollution exposure, income, and race – all of which are correlated with lack of health insurance or access to healthcare, other health risks, and negative health outcomes.
• Provision and access to healthy food can be better aligned with populations that lack affordable sources of nutritious food. For example, there is a relatively higher concentration of households receiving assistance from the Supplement al Nutrition Assistance Program (SNAP, or “food stamps”) in the Metro, Pullman, and Park Plaza neighborhoods.
• Residents that live nearest to industrial land uses, freeways, major roads, and railways continue to be most impacted by air pollution, water quality threats, and risk of exposure to hazardous substances.
• The effects of climate change will exacerbate environmental and natural hazards for certain geographic areas and impact certain vulnerable populations in Richmond. Extreme heat, for example, will affect livability most in places that lack shade from tree canopy and incur greater energy costs for air conditioning. Sea level rise and extreme storm events will also increase likelihood of flooding, especially for neighborhoods along the coast. • Housing quality concerns such as incomplete plumbing or kitchen facilities, overcrowding, exposure to lead or asbestos , lack of proper ventilation, and poor maintenance of older structures disproportionately affect communities of color, l ow-income households, and renters. In addition to having less access to affordable housing opportunities, which are not well -distributed throughout the City, these populations are more likely to face tradeoffs in housing quality and affordability at the cost of their health and their children’s health.
• Community facilities and services are generally well-distributed throughout the City, and although there are fewer City parks in the Hilltop and hills neighborhoods, local park access in these areas is supplemented by access to regi onal parks and open space.

Walkability and connectivity to these destinations can be enhanced by prioritizing the needs of Environmental Justice Communities and other areas with poor access. • Meaningful c ivic involvement and community engagement of Environm ental Justice Communities can be strengthened by creating a new City staff position charged with advancing diversity, equity, and inclusion in all City programs as well as responding to residents’ concerns and facilitating interdepartmental coordination. Other Citywide efforts can include staff education about cultural competency that will enable more effective outreach and services.

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14 Goals, Policies, and Implementing Actions
The following goals, policies and implementing actions were developed for the Environmental Justice Element in response to the key findings summarized above with the objective of improving health outcomes and advancing equity in Richmond.

Proposed Goals for the Environmental Justice Element
Goal EJ-1. Reduced Exposure to Pollution and Toxics . Develop a comprehensive approach to coordinating efforts to improve air quality and reduce exposure to toxics, considering the specific needs of Environmental Justice Communities and low -income residents.

Goal EJ-2. Community Health. Strive to improve community health citywide and reduce health inequities in Environmental Justice Communities.

Goal EJ -3. Equitable Access to Healthy Food . Address the needs for healthy food in Environmental Justice Communities and among residents with limited transportation options.

Goal EJ-4. Reduced Risks from Climate Change and Urban Heat . Address future risks and burdens on neighborhoods and vulnerable populations.

Goal EJ -5. Protection from Natural Hazards . Focus on affected neighborhoods and mitigation/protection strategies.

Goal EJ -6. Safe and Sanitary Housing . Focus on physical conditions and disparities, housing insecurities, and residents’ ability to stay in homes; address distribution of affordable housing especially in areas with higher access to resources and opportunities.

Goal EJ-7. Equitable Access to C ommunity Facilities and Physical Activity . Facilitate multi-modal access to parks and recreation facilities, libraries, senior services, and community centers, and improve walkability in neighborhoods.

Goal EJ-8. Community Engagement and Investment Prioritization. Support community participation in planning and implementation, including budgeting for capital improvements and funding for services relative to needs, particularly in Environmental Justice Communities.

Proposed Policies for the Environmental Justice Element Policy EJ1.1. Air Pollution Reduction. Continue to reduce air pollution and the incidence of respiratory illness through land use and transportation planning and transportation demand management.

Policy EJ1.2. Mobile Source Emissions. Continue to reduce the mobile source emissions by supporting transit use, a multi-modal transportation system, and transportation demand management (TDM) programs that working together reduce solo driving and offers opportunities for biking and walking.

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15 Policy EJ1.3. Regional Coordination. Proactively coordinate City’s air quality improvement activities and pollution controls with the Bay Area Air Quality Management District (BAAQMD) and other regional programs, as well as with neighboring communities.

Policy EJ2.1. Reduce Health Disparities and Inequities. Seek to improve citywide health out-comes and reduce disparities between census tracts by focusing on prevention and interventions, and by addressing the root causes of health disparities and inequities in Richmond.

Policy EJ2.2. Expansion of Medical Facilities and Services. Support expansion of and access to medical facilities and services that serve Richmond residents, particularly in Environmental Justice Communities.

Policy EJ2.3. Protection from Toxics and Hazardous Materials. Protect community health from pollution by toxics and hazardous materials, especially in areas with vulnerable or sensitive populations and in Environmental Justice Communities.

Policy EJ2.4. Regional Coordination. Coordinate with the East Bay Municipal Utility District (EBMUD) to ensure all residents have access to high quality drinking water.

Policy EJ3.1. Expanding Supply of Healthy Food Sources. Support development of venues, including farmers’ markets, community gardens, food cooperatives, and local grocery stores, with healthy food options, such as fresh produce and plant-based food. Seek to provide for healthy, affordable food in areas that are currently underserved.

Policy EJ3.2. Education. Promote nutrition education and expand access to healthy foods in schools.

Policy EJ4.1. Protection from Sea Level Rise. Proactively protect vulnerable shoreline land and low-lying residential neighborhoods from the effects of sea level rise.

Policy EJ4.2. Green Streets and Urban Forestry. Expand programs for green streets and urban forestry to all areas of the City, consistent with the City’s Urban Greening Master Plan, and prioritize areas that currently lack tree canopy.

Policy EJ4.3. New Green Spaces. Actively pursue the creation of new green spaces in areas with the highest heat-related vulnerability and/or highest ambient temperatures.

Policy EJ4.4. Green Design. Promote green design, as provided for in the California Green Building Code, to mitigate the effects of urban heat and enhance livability of the built environment throughout the City.

Policy EJ5.1. Flood Hazards. Continue to protect vulnerable areas from flood hazards with a comprehensive flood management program.

Policy EJ5.2. Wildfires and Emergency Evacuation. Minimize the risks of wildfire damage in developed areas with wildfire management programs and emergency evacuation procedures.

Policy EJ5.3. Geologic and Seismic Hazards. Continue to protect development from geologic and seismic hazards through the land use planning process and building standards.

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16 Policy EJ6.1. Safe, Healthy and Affordable Housing. Continue to foster healthy, diverse neighborhoods with a robust supply of safe, healthy, affordable, and stable housing available to residents of all backgrounds, identities, and abilities.

Policy EJ7.1. Opportunities for Recreation and Physical Activity. Provide convenient and safe opportunities for public recreation and physical activities in the City’s parks that meet the needs of residents of all ages, backgrounds, identities, abilities, and in-come levels.

Policy EJ7.2. Improving Access. Improve bicycle, pedestrian, and transit connectivity to community facilities and services, including parks and schools, especially in under-served areas.

Policy EJ8.1. Community Capacity. Strengthen community capacity to actively participate in civic life and in development and implementation of solutions for neighborhood priorities, particularly historically underrepresented groups.

Policy EJ8.2. Refining Outreach. Utilize diverse methods of outreach that promote public participation and ensure City events are communicated to all communities, especially to linguistically isolated households, households without internet access, seniors, low-income residents, and residents with limited computer literacy.

Policy EJ8.3. Focusing on Highest Needs. Focus planning and intervention in and with communities with the highest need by ensuring that policies, services, and programs are responsive to community members, especially in historically marginalized communities, who are most impacted by pollution and most vulnerable to the potential impacts of natural hazards, particularly wildfires and flooding, and future risks from climate change.

Proposed Implementing Actions for the Environmental Justice Element Table 3 summarizes the proposed implementing actio ns for the Environmental Justice Element; in the element itself departmental responsibilities are assigned and the policies that would be addressed by each action are listed.

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17 Table 3: Summary of Implementation Actions
Number Action Number Action
EJ1.A Air Pollution Monitoring. EJ4.E Community Education EJ1.B Ban on Coal and Petroleum Coke Storage and Handling. EJ5.A Implementing Contra Costa County LHMP.

EJ1.C Zoning Enforcement. EJ5.B Establishing Resilience Hubs.

EJ1.D Transportation Demand Management. EJ5.C Updating Hazard Maps.

EJ1.E Regional Collaboration EJ5.D Seismic Upgrades of Critical Facilities in Environmental Justice Communities.

EJ1.F Development Review Procedures. EJ5.E Addressing Dam Failure Risks.

EJ2.A Update Data Base to Track Changes in Community
Health.

EJ5.F Community Input for Wildland Protection Program.

EJ2.B Attract a Replacement Hospital. EJ5.G Community Education in High Fire Hazard Areas.

EJ2.C Funding for Adaptive Reuse. EJ6.A Monitor Implementation of Housing Programs.

EJ2.D Partnerships and Leveraging Resources. EJ6.B Work with Housing Authority of Contra Costa County and Nonprofit Housing Providers.

EJ2.E Community Education. EJ6.C Support Removal of Lead-based Paint and Protection from Asbestos-Containing Materials in Older Housing.

EJ2.F Timely Notification. EJ7.A Assessing Walkability to Parks and Recreation Facilities.

EJ2.G Reporting Illegal Dumping. EJ7.B Addressing Needs of Environmental Justice Communities.

EJ2.H 311 Reporting System. EJ7.C Bicycle and Pedestrian Action Plan.

EJ3.A Leveraging Resources to Attract Grocery Stores. EJ7.D Programming Transportation Improvements.

EJ3.B Protecting Supermarkets. EJ7.E Funding Improvements to Correct Deficiencies.

EJ3.C Healthy Food Displays at Checkout. EJ7.F Co-Location to Facilitate Access.

EJ3.D Sites for Farmers’ Markets and Urban Agriculture. EJ8.A Continue to participate in Government Alliance on Race and Equity (GARE).

EJ3.E Cottage Food Operations. EJ8.B Staff Position for Diversity, Equity and Inclusion.

EJ3.F Expanding Urban Agriculture. EJ8.C Support for Community Organizations and Partners.

EJ3.G Lists of Resources on Healthy Food. EJ8.D Consultation on CIP.

EJ3.H School Food Programs. EJ8.E Community Benefits Program to Support Environmental Justice.

EJ3.I Healthy Employee Food Programs EJ8.F Adding Culturally Competent Policies and Practices.

EJ4.A Heat Reduction Strategies. EJ8.G Expanding Methods of Outreach and Communications to Non-English Speakers.

EJ4.B Community Outreach. EJ8.H Identifying and Removing Barriers.

EJ4.C Implementation of Urban Greening Master Plan. EJ8.I Indigenous Land Acknowledgement.

EJ4.D Targeting Heat Mitigation Strategies. EJ8.J Action Plan Supporting Indigenous People and Communities.

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18 AMENDMENTS TO THE PUBLIC SAFETY AND NOISE ELEMENT
The proposed Amendments to the Public Safety and Noise Element include the information required by the California Government Code due to State legislation (SB99 and related bills) in the form of draft text inserts for the “Richmond Today” and “Key Findings and Recommendations” sections and additional policies and implementing actions on evacuation route planning to be added to the “Policies and Implementing Actions” section.

Hazard Mapping
The maps in the amendments to the Public Safety and Noise Element illustrate the geographic extent of the hazards identified in Richmond, using current (2022) geographic information available to the City from regional, State, and federal sources. These include maps of geologic and seismic hazards, liquefaction susceptibility, flood and tsunami hazards, and fire threats.

Hazard Mitigation
The amendments to the Public Safety and Noise Element incorporate as an appendix Volume 2 - Planning Partner Annexes of the 2018 Contra Costa Hazard Mitigation Plan (2018 HMP) which assesses risks posed by natural hazards and presents a mitigation strategy for reducing these risks. The Annex contains information specific to the City of Richmond and therefore constitutes Richmond’s local hazard mitigation plan (LHMP). The LHMP lays o ut a process to prepare for and lessen the impacts of specified natural hazards that are most likely to impact Richmond, such as earthquakes, wildfires, floods, debris flows, wind damage, and tsunamis.

Evacuation Route Planning
As required by State law (Senate Bill 99 and Assembly Bill 747 – 2021 Statutes), the City has reviewed emergency evacuation preparedness as foundational information for the General Plan Public Safety and Noise Element. This analysis provided an assessment of roadway capacity under fire, tsunami and earthquake scenarios that are consistent with the Contra Costa County Hazard Mitigation Plan. The assessment provides the City with broad “planning level” information on the capacity of the transportation system during an evacuation scenario for use in formulating policies and implementation actions to be incorporated into the General Plan.

Hazard zones used for this analysis include:
• Fire Hazard Severity Zones
• Tsunami Evacuation Zones
• Flood Hazard Zones
• Landslide Hazard (Rainfall Induced)
• Probabilistic Earthquake Shaking Hazard Zones
• Earthquake Liquefaction Susceptibility Zones
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19 The emergency evacuation scenarios selected for specific analysis included a localized wildfire event, a tsunami event causing flooding in low -lying areas, and a localized earthquake event causing seismic damage to buildings. An event associated with the refinery was not considered as it had been addressed previously in environmental documents 2 and would large ly be confined to land owned by the refinery and it would be less likely to require an evacuation (as opposed to sheltering in place). In addition, adjacent urban uses are well served by transportation facilities, with multiple routes available in a grid system, and so do not pose the same challenges for evacuation route planning as in the other areas selected for the analysis.

Evacuation routes (including roadways, BART, and ferry routes ) were identified in consultation with the City of Richmond’s Fire and Police Departments. Emergency access out of the City is limited to a few major routes:
• I-580 and ferry routes to the west over the San Francisco Bay; • I-80 and San Pablo Avenue to the north;
• Hilltop Drive, Pinole Valley Road/Alhambra Valley Road, Castro R anch Road, and San Pablo Dam Road to the west; and
• I-580, I-80, San Pablo Avenue, and BART to the south
Places that could serve as emergency evacuation centers also were identified; some of these are privately-owned and the City will need to negotiate acce ss during an emergency, which could be done ahead of time. In the event that an area of the City needed to be evacuated, these emergency evacuation centers would serve as the designated gathering points and shelters, and also staging areas for buses that could evacuate those without access to vehicles.

Residential streets in very high fire hazard areas that provide one emergency access route are considered “evacuation-constrained,” consistent with the requirements of Senate Bill 99. A total of 1,713 residential single access parcels, which aggregate to 213 acres, were identified.

Key Findings
The City’s evacuation routes can accommodate evacuation needs with support from AC Transit, BART, and the Water Emergency Transportation Authority (WETA) for those without access to automobiles. Evacuation times can be reduced with operational strategies and parking restrictions to increase the traffic -carrying capacity of evacuation routes. The capacity of the transportation system during evacuation events was evaluate d for the three evacuation scenarios.

2 https://www.ci.richmond.ca.us/DocumentCenter/View/45966/Fina-EIR?bidId=

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20 • Scenario 1 – Localized Evacuation due to Fire: This scenario evaluated evacuation of the hills in the northeast section of the City within a very high fire hazard severity zone. It assumed San Pablo Dam Road, Pinole Valley Road and Alhambra Valley Road would be blocked due to a wildfire. The emergency evacuation center closest to the evacuation would be the Hilltop Mall.
• Scenario 2 – Localized Evacuation due to Tsunami : This scenario evaluated evacuation of the southern coastal portion of the City within a tsunami hazard area. It assumed that I-580 would not be available for use during the evacuation. The emergency evacuation center closest to the evacuation would be the Richmond Senior Center on Macdonald Avenue.
• Scenario 3 – Localized Evacuation due to Earthquake : This scenario evaluated evacuation of the southwestern coastal portion of the City near the landslide and liquefaction zones. It assumed that the El Cerrito BART station would not be available for evacuation purposes due to the hazard. The emergency evacu ation center closest to the evacuation would be the Richmond Recreation Complex near Nicholl Park.

For each scenario, the analysis determined how many residents would need to be evacuated and the anticipated vehicle ownership per household; it also estimat ed the number of employees in the area that would need to evacuate. The evacuation of vehicles in each scenario is controlled by bottlenecks in the evacuation routes. In Scenario 1, all of the roads flow into three main evacuation routes that limit the eva cuation capacity down the hill. In Scenario 2, the capacity is limited to the roadways that access I -580 or cross under or over I -580, and in Scenario 3, the three main evacuation routes can be taken north or south out of the evacuation zone. This assessment assumes that traffic signals throughout the evacuation routes distribute approximately half of the green time in the direction of evacuation such that only half of the available through capacity is available on the evacuation routes.

For persons without access to a vehicle, the analysis determined how long it would take a fleet of buses to mobilize, stage, load/unload, and drive people to the nearest emergency evacuation center. The average AC Transit bus has capacity for 37 people, and it would take approximately 30 minutes following an emergency alert to identify and route the appropriate buses to the evacuation staging areas. The round-trip time from the staging areas to the closest evacuation center was determined to be, on average, 45 minutes, includ ing loading and unloading. With eight buses, approximately 395 people per hour could be evacuated under ideal conditions.

If BART were still in operation following a declared emergency, typical BART trains have five cars with capacity for up to 70 people, or 350 people per train.

Evacuation times could be significantly improved if fewer people drove and more used transit.

Time to reach an evacuation point by foot also may vary significantly from that assumed for vehicles or transit. Finally, traffic signa l synchronization between City intersections and/or Caltrans ramps, or power issues that would trigger traffic signals to operate in “red flags” would have an effect on evacuation capacity.

The specific findings of the evacuation route assessment are as follows:

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21 • Scenario 1 – Localized Wildfire Hazard. Just under 12,000 vehicles could be evacuated in approximately three hours and 15 minutes in this scenario. If the evacuation route of Castro Ranch Road to Pinole Valley Road was not accessible due to fire or other hazards, the evacuation would take approximately four hours and 15 minutes. The evacuation of the remaining 513 people without access to vehicles would take approximately two hours utilizing eight buses.
• Scenario 2 – Localized Tsunami Hazard. In this scenario, around 7,400 vehicles could be evacuated in approximately 40 minutes. If half of the roads flooded due to the tsunami or were inaccessible due to some other hazard, the evacuation could be completed within an hour and a half. The evacuation of the remaining 314 people without access to vehicles would take approximately an hour and 20 minutes utilizing eight buses. • Scenario 3 – Localized Earthquake Damage. About 9,600 vehicles could be evacuated in approximately an hour and 15 minutes. If half of the roads were blocked by landslide or were inaccessible due to some other hazard, evacuation could be completed within two and a half hours. The evacuation of the remaining 1,235 people without access to vehicles would take approximately and three hours and 15 minutes utilizing eight buses. The same 1,235 people could be evacuated on BART using four trains in as little as 20 minutes utilizing empty trains in both directions, not counting walk time to BART stations.

Proposed Policies and Implementing Actions
The following policies and implementing actions are proposed to supplement the existing policies and implementing actions in the Public Safety and Noise Element on emergency and disaster preparedness.

Policies
Policy SN3.1. Evacuation Route Planning . Ensure redundancy of critical transportation routes to allow for continued access and movement in the event of an emergency.

Policy SN 3.2 Access to Emergency Routes. Increase connectivity within areas with evacuation constraints through the use of easements, and emergency access roadways, if the addition of new roadways or roadway extensions are deemed infeasible by the City.

Policy SN3.3. Increase Evacuation Capacity. Include evacuation capacity in f uture roadway design, especially in areas that have less accessibility and on key evacua tion routes.

Incorporate design treatments such as painted medians (instead of raised medians) that could assist in creating reversible lanes and facilitate additional capacity in an evacuation event scenario. Coordinate with AC Transit and BART to develop procedures and protocols for use of their transit facilities during emergencies.

Policy SN 3.4. Evacuation Centers for Emergencies . Identify and r egularly evaluate the availability and anticipated demand for community facilities to serve as evacuation centers or designated cooling or smoke relief center during emergencies. Designate such facilities and General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
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22 maintain them to comply with industry standards. Establish solar photovoltaic systems and battery storage for evacuation centers and other critical facilities in the event of power outages.

Policy SN 3.5. Emergency Assistance for Vulnerable Populations. Evaluate the evacuation needs of vulnerable populations, such as senior housing facilities , homeless shelters, transitional housing, residential care facilities, and schools, and others without access to a personal vehicle in City emergency preparedness and evacuation plans. Develop and implement outreach programs to explain emergency preparedness and offer technical assistance on preparing emergency evacuation plans.

Policy SN3.6. Emergency Communicati ons Systems . Continue to develop and test emergency communications systems to inform residents to evacuate in a timely manner in order to reduce last-minute evacuations and concentrated demand on the roadway network.

Coordinate with the school district to build awareness regarding school evacuation protocols which include sheltering-in-place or evacuating off-site using school buses.

Implementing Actions
Action SN3. F. Emergency Access in New Development Citywide. Require new development in subdivisions to provide adequate access (ingress, egress) and a minimum of two roadways with widths and lengths. This requirement would not apply to infill sites.

Action SN3.G. Evacuation Alternatives for Access -Constrained Residential Neighborhoods. Work with homeowners’ associations and local residents in access - constrained neighborhoods to identify evacuation alternatives and/or alternative emergency access routes.

Action SN3.H. Evacuation Route Signage. Create a signage system to permanently identify evacuation routes, particularly in areas of the City subject to high wildfire hazards or other risks.

Action SN3.I. Safety Zones. Designate safety zones or shelter-in-place locations as potential places of refuge when evacuation routes are blocked and communicate where these are to those living in hazard areas.

Action SN3.J. Traffic Operations Strategies. Implement transportation operations strategies for evacuation events to be managed by the Emergency Operations Center, with contingency plans for loss of power and communications grids. Incorporate Caltrans operations into the City’s emergency operations protocols and jointly agree on emergency evacuation signal timing. Restrict parking on red flag days along critical evacuation routes if necessary to ensure critical capacity is maintained.

Action SN3.K. Emergency Wayfinding Signage. During declared emergencies, d eploy clear wayfinding, signs, and barriers to direct traffic, and allow for prioritizing traffic signals in vulnerable areas during declared emergencies.

Action SN3. L. Evacuation Management for Areas with Access Constraints. Ensure targeted evacuation management to areas of the community that do not have redundancy in critical transportation routes, such as those that rely on one roadway for evacuations and the movement of goods and services, as well as areas that have multiple evacuation routes but are not as prepared for an evacuation event.

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23 Action SN3.M. Emergency Communications Systems. Establish and periodically upgrade emergency communications infrastructure to warn residents of potential evacuation events.

Ensure that this system is designed to provide for uninterrupted emergency operations and communications with backup power sources.

Action SN3.N. Bi-Lingual Information Materials. Create bi -lingual materials for emergency preparedness for households where English is not the primary language.

Action SN3.O. Emergency Access Mitigation Fee. Evaluate developing an Emergency Access Mitigation Fee for new developments to assist in funding improvements to alleviate evacuation constraints.

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24 3 Environmental Analysis
This addendum focuses on potential impacts associated with the General Plan Update compared to impacts identified in the General Plan DEIR and FEIR. The analysis corresponds to the environmental issue areas presented in Chapter 3 of the General Plan DEIR.

Agricultural resources and land use are not addressed; no agricultural lands are designated for conversion, and no changes in land use would occur as a result of the proposed General Plan Updates.

As stated in the Project Description, the vacant and underutilized sites identified for new housing would be able to adequately accommodate the City’s RHNA for the 2023 -2031 planning period. As shown in Error! Reference source not found. , the City’s total RHNA is 3,614 units. The City had 40,831 households as of January 2022 (DOF 2022). The City has identified an adequa te number of sites so as to not require rezoning as part of the Housing Element Update. Because no rezoning or General Plan land use designation changes would occur, for any given parcel within the City, the proposed General Plan Updates would not allow increased building area, density, or height compared to what is currently allowed under the General Plan for that parcel. The General Plan EIR identified anticipated growth of 30,147 residents, 15,548 residential units, and 22,488 jobs between 2012 and 2030. Approximately 750 units have been built since 2011. Given growth that has occurred, and assuming all 3,614 units to meet the RHNA are built, total buildout under the Housing Element Update would be within the buildout anticipated under the General Plan an d analyzed in the General Plan EIR of 15,548 residential units.

Under California law, zoning and subdivision regulations must be consistent wit h a General Plan; adopting the zoning amendments required for General Plan consistency is part of the project. Individual development projects that require discretionary action from City decision makers will be subject to separate site-specific environmental review . These General Plan Updates have no substantive impact on land use and development consistent with the 2030 General Plan, as previously amended. In fact, the policies and implementing actions in the General Plan Updates could limit development in hazard areas.

This section of the addendum provides analysis and cites substantial evidence that supports the City’s determination that the proposed General Plan Updates (the proposed project) are activities within the scope of the General Plan Program E IR, and no further CEQA environmental review is required. The analysis in this chapter focuses on the criteria under Section 15162. The analysis in each issue area section first summarizes the impacts identified in the General Plan EIR for that issue and t hen addresses impacts of the proposed General Plan Amendment for Change Area 12 and compares them to impacts in the General Plan EIR.

In all cases, the addendum finds that no new significant environmental effect or a substantial increase in the severity of previously identified significant land use impacts would occur beyond what was addressed in the General Plan Final EIR.

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25 3.1 Land Use Consistency and Compatibility

PREVIOUSLY IDENTIFIED IMPACTS IN THE RICHMOND GENERAL PLAN

FINAL EIR
The General Plan Update DEIR determined that implementation of the General Plan land uses and policies would not physically divide an existing community. The DEIR also concluded that implementation of the General Plan development strategy to integrate uses within the City’s core areas would not result in substantial land use incompatibilities. Land use consistency and compatibility issues were addressed in detail in DEIR pages 3.1-1 through -9.

PROPOSED GENERAL PLAN UPDATES
Since the proposed General Plan Updates do not change policies and land use designations for future development and resource conservation in the City, they would not have an impact on future development. Land uses in the vast majority of the city, such as established residential neighborh oods, shopping areas, commercial corridors, and industrial districts , would not be affected by this update. Richmond’s “change areas” were deemed most suitable for a shift in intended use as compared to existing conditions and have experienced changes in land use and development character as envisioned by the 2030 General Plan . They largely represent areas that are underutilized, have incompatible land uses, high potential for redevelopment, or are inconsistent with current community priorities. Each of these areas has characteristics that demand a more focused approach to land use regulation, infrastructure investment, services and redevelopment. The General Plan Update s would not change the City’s vision of development in these change areas and the land us e policies and zoning regulations that would implement that vision. Therefore, the impacts associated with the General Plan Update would not be greater than those analyzed in the General Plan EIR.

The Housing Element Update identifies sites located throughout the city designated for residential development; potential development on these sites was evaluated in the General Plan EIR as part of the overall impact assessment of General Plan buildout . The Housing Element Update would not involve circulation changes and individual development projects would occur within private property in already developed areas. Moreover, consistent with the General Plan, development under the Housing Element Update would be subject to existing zoning and development regulations in the Richmond Municipal Code (RMC) and policies in the General Plan. Compliance with these regulations and policies and required development and planning review would ensure individual projects would not conflict with applicable land use policies, plans, and regulations. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in additional impacts beyond those identified for the General Plan as analyze d in the General Plan EIR.

Regarding potential division of a community, the General Plan Updates do not include any policies or actions that would physically divide an existing established community.

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26 In sum, no new significant environmental effect or a substantial increase in the severity of previously identified significant land use impacts would occur beyond what was addressed in the General Plan Final EIR.

3.2 Air Quality

PREVIOUSLY IDENTIFIED AIR QUALITY IMPACTS IN THE RICHMOND

GENERAL PLAN FINAL EIR
Impact 3.3-1 Implementation of the proposed
General Plan could provide new
sources of regional air emissions
that would conflict with or
obstruct implementation of the
Clean Air Plan. Though all
feasible mitigation measures
would be implemented to reduce
this impact, there is insufficient
evidence to quantify the effect of
those measures. Because it
cannot be stated with certainty
the mitigation would reduce the
impact to a less-than-significant
level, this impact would be
considered significant and
unavoidable.

Mitigation Measure 3.3-1:
a. Encourage the inclusion of the ferry terminal within the shuttle service feasibility study and within the
current transportation system to promote the use of
public transportation and provide for convenience
of use.
b. Promote reduced transit fares for daily commutes
within the City, and encourage the cooperation
between all modes of transportation to provide for
ease of use, such as the institution of a monthly
commuter pass that would provide access to the
ferry, as well as bus, train, and/or BART system.
c. Continue to expand the Bay Trail and other routes
for bicycle and pedestrian travel.
d. Provide bicycle and pedestrian amenities, such as
benches and bike storage, along routes leading to
the Richmond and El Cerrito Del Norte BART
stations to promote non-motorized travel to and
from public transit.
e. Provide development incentives, such as reduced
parking requirements, for businesses that provide
transit incentives to employees.

Impact 3.3-2 Implementation of the proposed
General Plan would result in
construction and operational
emissions that could contribute
substantially to an existing or
projected air quality violation.

Though all feasible mitigation
measures would be
implemented, the impact of
operational emissions remains
uncertain and, therefore, would
be considered significant and
unavoidable.

Mitigation Measure 3.3-2a:
a. All construction projects shall incorporate the most recent Best Management Practices as required by
the BAAQMD.
b. Future development under the proposed General
Plan shall be subject to review to determine
construction air quality impacts in accordance with
CEQA.

Mitigation Measure 3.3-2b:
a. The City of Richmond shall continue to require
individual developers to implement applicable new
stationary source control measures as proposed in
the most recent CAP, while conforming with
existing BAAQMD stationary source regulations
and requirements and complying with BAAQMD
rules and regulations regarding indirect sources.
b. The City of Richmond shall consult with project
proponents during the pre-application review
process to ensure that uses with a high level of
operational emissions are appropriately designed
and sited to avoid impacts on neighboring uses and
regional air quality.

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27 Impact 3.3-3 Operational activities under the
proposed General Plan would
not expose sensitive receptors to
substantial pollutant
concentrations in excess of the
established thresholds. This
impact would be considered less-
than-significant.

Mitigation Measure 3.3-3:
a. The City of Richmond shall implement special
overlay zones around all planned sources of TACs
to minimize the potential impacts to sensitive
receptors. Land Use diagrams within the adopted
General Plan will indicate the Special Overlay
Zones which shall include an overlay zone of at
least 500 feet on either side of all freeways and
high volume roadways (100,000 vehicles per day or
more).
b. The City of Richmond shall require all new
industrial and commercial development projects
that have the potential to emit TACs to be located
an adequate distance from existing and proposed
development used by sensitive receptors—
including residential, schools, day care facilities,
congregate care facilities, hospitals, or other places
of long-term residency. The determination of
development projects that have the potential for
TAC emissions and adequate distances from
sensitive receptors as identified in CARB’s Air
Quality and Land Use Handbook—A Community
Health Perspective (April 2005; CARB Guidance)
are as follows:
• Proposed dry cleaners and film processing
services that use Perchloroethylene shall be
sited at least 500 feet from sensitive land uses.
• Proposed auto body repair services shall be sited
at least 500 feet from sensitive land uses.
• Proposed gasoline dispensing stations with an
annual throughput of less than 3.6 million gallons
shall be sited at least 50 feet from sensitive land
uses. Proposed gasoline dispensing stations with
an annual throughput at or above 3.6 million
gallons shall be sited at least 300 feet from
sensitive land uses.
• Other proposed sources of TACs including
furniture manufacturing and repair services that
use Methylene Chloride or other solvents
identified as a TAC shall be sited at least 300 feet
from sensitive land uses.
• Proposed distribution centers with more than 100
trucks per day; more than 40 trucks with operating
transport refrigeration units per day; or where
transport refrigeration unit operations cumulatively
exceed 300 hours per week should not be sited
within 1,000 feet of sensitive land uses.
• Proposed rail yards for major service and
maintenance operations should not be sited within
1,000 feet of sensitive land uses.
• Proposed chrome platers should not be sited
within 1,000 feet of new sensitive land uses.
• Proposed port developments should not site the
heavily impacted areas immediately upwind of
sensitive land uses. Siting of port developments
should be done in consultation with the BAAQMD.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
28 • Proposed petroleum refineries should not site the
heavily impacted areas immediately upwind of
sensitive land uses. Siting of refineries should be
done in consultation with the BAAQMD.
c. Proposed sensitive land uses including schools,
daycare facilities, congregate care facilities,
hospitals, or other places of long term residency for
people shall be sited:
• At least 500 feet from dry cleaners and film
processing services that use Perchloroethylene.
• A least 500 feet from auto body repair services.
• At least 50 feet from existing gasoline dispensing
stations with an annual throughput of less than 3.6
million gallons and 300 feet from existing gasoline
dispensing stations with an annual throughput at
or above 3.6 million gallons.
• At least 300 feet from existing land uses that use
Methylene Chloride or other solvents identified as
a TAC, including furniture manufacturing and
repair services.
• At least 1,000 feet from distribution centers with
more than 100 trucks per day; more than 40 trucks
with operating transport refrigeration units per day;
or where transport refrigeration unit operations
cumulatively exceed 300 hours per week. In
addition sensitive land uses should not be sited
near facility entry and exit points.
• At least 1,000 feet from major service and
maintenance rail yards.
• At least 1,000 feet from chrome plating facilities.
• Avoid siting sensitive land uses immediately
downwind from the most heavily impacted areas
of existing port facilities.
• Avoid siting sensitive land uses immediately
downwind from petroleum refineries.
d. The City of Richmond shall consult with the
BAAQMD to identify TAC sources and determine
the need for and requirements of a health risk
assessment for proposed developments.

Impact 3.3-4 Implementation of the proposed
General Plan would not create
objectionable odors that would
affect a substantial number of
people. This is a less-than-
significant impact.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.3 -17 through -31 with minor modifications made in the FEIR.

PROPOSED GENERAL PLAN UPDATES
The proposed General Plan Updates would not change any land use designations. A prior General Plan amendment did change industrial land use designations in Change Area 12, reducing development potential from that envisioned under the 2030 General Plan. The General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
29 proposed project would not result in further change in the severity of air quality impacts beyond those analyzed in the General Plan FEIR. The Housing Element update includes sites located throughout the city designated for residential development, potential development was evaluated previously for potential environmental impacts in the General Plan EIR. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in additional impacts beyond those identified for the General Plan as analyzed in the General Plan EIR. Potential air quality - related impacts cannot be assessed in a meaningful way until a specific project site and development design is known, including the number of units and potential vehicle miles traveled (VMT) that would be generated . Short -term air quality impacts resulting from construction of the sites, such as dust generated by clearing and grading activities, exhaust emissions from gas - and diesel -powered construction equipment, and vehicular emissions associated with the commuting of construction workers will be subject to Bay Area Air Quality Management District rules and protocols. Similarly, operational impacts would be addressed by provisions in the General Plan a nd other regulations and standards that govern air quality in Richmond. Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project. Future development in Richmond would be subj ect to mitigation measures 3.3 -1 and 3.3 -2 from the General Plan EIR, which would reduce emissions to the extent feasible. In addition, future development would be subject to Chapter 9.64 of the RMC, which prohibits the use of natural gas in most new buildings, which would reduce natural gas and associated air pollution emissions in future development. The addition of new residential units under the Housing Element update would not result in long-term objectionable odors. Temporary odors may occur during construction activities and cease upon completion. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse air quality impacts to a greater extent tha n buildout under the General Plan and analyzed in the General Plan EIR.

In addition, the Environmental Justice Element includes an implementing action intended to avoid creation of new sources of air pollution ( Action EJ1.F). Also, t he proposed Environmental Justice Element would serve to reduce future air quality impacts and support the Climate Action Plan (CAP) greenhouse gas reduction strategies by promoting active modes of transportation such as biking and walking in addition to p ublic transit in place of solo driving throughout more communities in Richmond (Policy EJ1.2 and Actions EJ3.I and EJ7.B through EJ7.E). Policies that seek to expand local access to services and amenities such as parks, health care, grocery stores, and mor e would also reduce vehicle miles traveled (Policies EJ3.1 and EJ7.2). Therefore, no new significant environmental effect or a substantial increase in the severity of pre viously identified significant air quality impacts would occur beyond what was addressed in the General Plan Final EIR.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
30 3.3 Biological Resources

PREVIOUSLY IDENTIFIED IMPACTS ON BIOLOGICAL RESOURCES IN THE

RICHMOND GENERAL PLAN FINAL EIR
Impact 3.4-1 The proposed General Plan would not have a substantial adverse effect, either directly or through
habitat modification, on any species identified as a
candidate, sensitive, or special status species in
local or regional plans, policies, or regulations, or
by the California Department of Fish and Game or
U.S. Fish and Wildlife Service. This is considered a
less-than-significant impact.

No Mitigation Measures Required.

Impact 3.4-2 The proposed General Plan would not interfere substantially with the movement of 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. This is considered a less-than-
significant impact.

No Mitigation Measures Required.

Impact 3.4-3 The proposed General Plan would not have a substantial adverse effect on any riparian habitat or
other sensitive natural community identified in local
or regional plans, policies, regulations or by the
California Department of Fish and Game or U.S.

Fish and Wildlife Service. This is considered a less-
than significant impact.

No Mitigation Measures Required.

Impact 3.4-4 The proposed General Plan would not have a substantial adverse effect on federally protected
wetlands as defined by section 404 of the Clean
Water Act (including, but not limited to, marsh,
vernal pool, coastal, etc.) through direct removal,
filling, hydrological interruption, or other means.

This is considered a less-than-significant impact.

No Mitigation Measures Required.

Impact 3.4-5 The proposed General Plan would not conflict with any local policies or ordinances protecting
biological resources, such as a tree preservation
policy or ordinance. This is considered a less-than-
significant impact.

No Mitigation Measures Required.

Impact 3.4-6 The proposed General Plan 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 since none exist. As a result, the
proposed project would have no impacts on
adopted conservation plans.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.4-28 through -37 with minor refinements made in the FEIR.

PROPOSED GENERAL PLAN UPDATES
The General Plan DEIR determined that all impacts related to biological resources were less than significant because of the General Plan provisions that ensure protection of sensitive General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
31 species and habitats . The proposed General Plan Updates would not change any land use designations, so there would be no change in habitat conservation from what was envisioned under the adopted General Plan . The Housing Element Update identifies sites located throughout the city designated for residential development; potential development on these sites was evaluated in the General Plan EIR as part of the overall impact assessment of General Plan buildout. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan . Potential impacts to biological resources cannot be assessed in a meaningful way until a specific project site and development design is known potential biological resources on site, and construction activities. Individual projects would also be subject to policies under the General Plan such as Policy CN1.1: Habitat and Biological Resources Protection and Restoration, CN1.2: Local Native Plant Species, and CN1.3: Urban Creek Restoration, as well as state and fede ral regulations. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to biological resources to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR. The General Plan Update would have no impact, either directly or indirectly on natural areas identified in the General Plan, such as the eight County- designated Significant Ecological Areas or the one are a of the City that ma y support the Alameda whipsnake.

No portion of the General Plan Update s would change any General Plan policies or action items related to biological resources.

With these findings in mind, no new significant environmental effect or a substantial increase in the severity of previously identified significant biological impacts would occur beyond what was addressed in the General Plan Final EIR. All future development projects would be subject to applicable City requirements pertaining to biological resources, as well as further CEQA analysis of project specific impacts.

3.4 Cultural Resources

PREVIOUSLY IDENTIFIED IMPACTS ON CULTURAL RESOURCES IN THE

RICHMOND GENERAL PLAN FINAL EIR
Impact 3.5-1 Development activities associated with the proposed Richmond General Plan Update
could cause a substantial adverse change
in the significance of a historical resource
as defined in section 15064.5 of the CEQA
Guidelines. Because mitigation is not
certain to reduce impacts to a less-than-
significant level, this would be considered a
significant and unavoidable impact.

Mitigation Measure 3.5-1: Future projects
shall implement the City’s Historic
Structures Code to minimize impacts on
historical resources by requiring thorough
scrutiny before any resource may be
demolished and ensuring that alteration
conforms to the Secretary of the Interior’s
Standards for the Treatment of Historic
Properties.

Impact 3.5-2 Development activities associated with the proposed Richmond General Plan Update
Mitigation Measure 3.5-2a: The City shall
require that impacts on unique
General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
32 could cause a substantial adverse change
in the significance of an archaeological
resource as defined in section 15064.5 of
the CEQA Guidelines or disturb human
remains, including those interred outside of
formal cemeteries. With the implementation
of mitigation measures, this is considered a
less-than-significant impact.
archaeological resources be mitigated to a
less than significant level through methods
identified in Public Resources section
21083.2, including planning construction
to avoid archaeological sites, deeding
archaeological sites into permanent
conservation easements, capping or
covering archaeological sites with a layer
of soil before building on the sites, or
planning parks, greenspace, or other open
space to incorporate archaeological sites.

Mitigation Measure 3.5-2b: The City shall
require new development within the City to
evaluate the potential for
impacts on human remains. The City shall
require that the treatment of human
remains and of associated or
unassociated funerary objects discovered
during any soils disturbing activity shall
comply with applicable state and federal
laws, including
notification of the County Coroner and, in
the event of the Coroner’s determination
that the human remains are Native
American remains, notification of the
California State Native American Heritage
Commission (NAHC).

Impact 3.5-3 Development activities associated with the proposed Richmond General Plan Update
could directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature. With the implementation
of mitigation measures, this is considered a
less-than-significant impact.

Mitigation Measure 3.5-3: The City shall
require new development within areas of
high sensitivity paleontological resources
to evaluate the potential for impacts on
significant paleontological resources. The
City shall require that impacts on
significant paleontological resources be
mitigated to a less than significant level
through data recovery or other methods
determined adequate by a professional
paleontologist.

These impacts were addressed in detail in DEIR pages 3.5-18 through -27.

PROPOSED GENERAL PLAN UPDATES
Development activities directly or indirectly resulting from the General Plan Updates would not have the potential to cause a substantial adverse change in the significance of an historical resource through demolition or alteration of a historical resource’s physical characteristics that convey its historical significance beyond those identified in the General Plan EIR for buildout under the General Plan. The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed f or development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan. Potential impacts to cultural resources cannot be assessed in a meaningful way General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
33 until a specific project site is known, including the potential for cultural resources on site.

Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project. Future development in Richmond would be subject to mitigation measures 3.5-1 through 3.5-3 from the General Plan EIR, which would reduce impacts to historic, archaeological, and paleontological resources to the extent feasible.

Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to cultural resources to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

All development projects are required to comply with CEQA Guidelines Section 15064.5 and California Public Resources Code Section 5097.98, which require specific procedures if buried remains are inadvertently discovered. No additional adverse effects on human remains are likely that were not previously disclosed in the General Plan DEIR. Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant cultural or paleontological impacts would occur beyond what was addressed in the General Plan Final EIR. All future development projects would be subject to applicable City requirements pertaining to cultural and paleontological resources, as well as further CEQA analysis of project-specific impacts.

Tribal Cultural Resources was added to the 2016 CEQA Guidelines as a separate environmental issue area. Thus, the 2012 EIR does not include a chapter or section dedicated to analysis of impacts to tribal c ultural resources. However, it does analyze general impacts to cultural resources (including archeological resources that may originate from Native American tribes) in Section 3.5, Cultural Resources and concludes that impacts would be less than significan t.

The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. However, development, including ground disturbance would occ ur in the same areas as analyzed in the General Plan; there would be no changes to the land use or zoning maps and no change to the General Plan boundaries. The General Plan and General Plan EIR do not discuss compliance with Assembly Bill 52 (AB 52), whic h was approved in 2014 and requires lead agencies to complete consultation with California Native American Tribes regarding proposed projects, because it was approved after adoption of the General Plan. However, individual future projects would likely be s ubject to project -level CEQA review and would thus be required to meet the requirements of AB 52; the City of Richmond would be required to notify tribes of pending projects and complete consultation when requested. Further, as part of its tribal cultural resources identification process under AB 52 and SB 18 for the Housing Element Update, the City of Richmond sent letters via certified mail on July 18, 2022 to ten Native American tribes that had previously requested to be informed through formal notification of proposed projects in the geographic area that is traditionally and culturally affiliated with the Tribes. The Tribal Chair of the Confederated Villages of Lisjan Tribe reached out to request more information on the project site and the Sacred Lands File (SLF) results and the information request was responded to. However, to date, the City has not received any responses requesting consultation under AB 52 or SB 18.

Lastly, future development would be required to implement Mitigation Measures 3.5-2a and General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
34 3.5-2b which prohibit actions that would cause a substantial change to cultural resources.

Therefore, impacts to tribal cultural resources would be less than significant.

3.5 Climate Change/Greenhouse Gas Emissions

PREVIOUSLY IDENTIFIED GREENHOUSE GAS IMPACTS IN THE RICHMOND

GENERAL PLAN FINAL EIR
Impact 3.6-1 Implementation of the proposed
General Plan would result in the
generation of GHGs that may have a
significant impact on the environment.

Implementation of BAAQMD BMPs
would ensure that construction
emissions of GHGs would be less than
significant. However, even with the
implementation of all feasible mitigation
measures, the impacts of operational
emissions would remain uncertain and,
therefore, be considered significant and
unavoidable.

Mitigation Measure 3.6-1a: All construction
projects shall incorporate the most recent Best
Management Practices for Greenhouse Gas
Emissions as indicated by the BAAQMD.

Mitigation Measure 3.6-1b: All new
development and all retrofits of single-family
developments, multi-family developments of
over 10 units, and all commercial/industrial
remodels of over 10,000 square feet shall be
required to exceed Title 24 standards by 20
percent by 2020 and 30 percent by 2030. This
mitigation measure enhances General Plan
Action EC3.C. Measures to reduce emissions
can include, but are not limited to:
• Install energy efficient appliances,
including air conditioning and heating
units, dishwashers, water heaters, etc.;
• Install solar water heaters;
• Install top quality windows and insulation;
• Install energy efficient lighting;
• Optimize conditions for natural heating,
cooling and lighting by building siting and
orientation;
• Use features that incorporate natural
ventilation;
• Install light-colored "cool" pavements, and
strategically located shade trees along all
bicycle and pedestrian routes; and
• Incorporate skylights, reflective surfaces,
and natural shading in buildings design
and layouts;
• Replace inefficient air conditioning and
heating units with new energy efficient
models;
• Replace older, inefficient appliances with
new energy efficient models;
• Replace old windows and insulation with
top-quality windows and insulation;
• Replace inefficient and incandescent
lighting with energy efficient lighting; and
• Weatherize existing buildings to increase
energy efficiency.

Mitigation Measure 3.6-1c: Require all new
City-owned and operated facilities and 50
General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
35 percent of all new development to generate at
least 10 percent of their energy use from
renewable sources. Enhances General Plan
Action EC3.B.

Mitigation Measure 3.6-1d: All new
commercial and multi-family developments
installing boilers shall be required to install
energy efficient boilers such that they achieve
a minimum 4.5 percent reduction in energy
usage. The same reductions shall be required
of all remodeled multi-family developments of
over 10 units and all commercial/industrial
remodels of over 10,000 square feet.

Mitigation Measure 3.6-1e: Develop improved
waste reduction and expanded recycling
programs such that a 75 percent diversion rate
is achieved by 2020 and an 85 percent
diversion rate is achieved by 2030 for all non-
construction waste streams. Potential
measures could include: providing recycling
containers in parks and public spaces;
establishing computer reuse and recycling
programs; enhancing recycling and green
waste services for all residents; and providing
locations for household hazardous wastes to
be recycled. Enhances General Plan Actions
EC3.D.

Mitigation Measure 3.6-1f: Develop a
program that requires all construction and
demolition activities to evaluate energy use
and waste and to reduce or mitigate
construction-related impacts by 75 percent.

Enhances General Plan Actions EC3.E.

Mitigation Measure 3.6-1g: Implement an
Anti-Idling Policy for heavy-duty diesel trucks,
including local delivery trucks and long-haul
truck transport within the City. This policy
would prohibit idling of on- and off-road heavy
duty diesel vehicles for more than 5 minutes.

Enhances General Plan Policy EC5.3.

Mitigation Measure 3.6-1h: Provide tax and
development incentives for employers with
more than 100 employees within the City to
establish a trip reduction plan that would
incorporate annual employee commute
surveys, marketing of commute alternatives,
ride matching assistance, and transit
information at a minimum, and implement
secure bicycle parking, showers and lockers
for employees who bike to work. This measure
could encourage smaller businesses to
cooperate in establishing joint trip reduction
plans. Enhances General Plan Actions EC2.F
and EC2.I.

Mitigation Measure 3.6-1i: Implement
Citywide car and bicycle sharing programs.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
36 Collaborate with service providers to identify
potential sites for locating carshares.

Mitigation Measure 3.6-1j: Require new local-
serving mixed-use in residential areas to
provide needed services and amenities close
to where people live and work. Require new
development and redevelopment projects to
provide community amenities and uses that
serve priority community needs. Enhances
General Plan Policy EC4.1 and General Plan
Actions EC4.A, EC4.B, and EC4.D.

Mitigation Measure 3.6-1k: Require mixed-
use development along transit-oriented
corridors that attracts people and facilitates
activity throughout the day. Prohibit isolated or
gated communities in order to improve physical
connectivity throughout the City, and remove
barriers in existing gated areas. Maintain
streets to ensure that neighborhoods and
streets are safe and well used. Enhances
General Plan Policy EC4.2 and Actions EC2.C,
EC2.E, EC2.G, EC4.A, EC4.B, EC4.C and
EC4.E.

Mitigation Measure 3.6-1l: Collaborate with
AC transit, BART, West Contra Costa Transit
Agency, Amtrak, and major employers in
Richmond that provide shuttle service to
expand transit in the evenings and late nights,
and for people with special needs. Enhance
Richmond’s paratransit service. Collaborate
with major employers to provide employer-
based “open-door” shuttles to BART, the
planned ferry terminal and other transit hubs.

Collaborate with regional and Contra Costa
County transportation agencies to maintain
and enhance service within the City and
region. Explore strategies to address
affordability, access, and safety. Expand
outreach and information programs to promote
transit use. Measure results in a 10 percent
expansion of transit system, and an increase in
service frequency and speed for 2020; and a
15 percent expansion by 2030. Expand
outreach and information programs to promote
transit use. Enhances General Plan Policy
EC2.C.

Mitigation Measure 3.6-1m: All new street
lighting and all re-modeled or replaced street
lighting shall consist of high-efficiency lamps
that reduce energy consumption by a minimum
of 16 percent.

Mitigation Measure 3.6-1n: All new traffic
lights and all replaced traffic lights shall consist
of LED lights. This high efficiency lighting
would reduce emissions from traffic lights by
90 percent.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
37 Mitigation Measure 3.6-1o: Require new
development to incorporate water-saving
measures demonstrating a minimum reduction
of 20 percent in water use over a similar
project completed within the previous five
years. This measure enhances General Plan
Action EC3.F. This measure would be
enhanced by General Plan Action EC3.G.

Impact 3.6-2 Construction and operation of the
proposed project could conflict with an
applicable plan, policy, or regulation
adopted for the purpose of reducing the
emissions of greenhouse gases.

Through the implementation of
Mitigation Measures 3.3-1, 3.3-2, and

3.6-1 and General Plan Policies, it is
anticipated that emissions would be
reduced to a less-than- significant level
and, therefore, would not be considered
cumulatively considerable.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.6-13 through -32 with minor refinements made in the Final EIR.

PROPOSED GENERAL PLAN UPDATES
The General Plan Updates would not result in a change in anticipated growth and the vehicle miles travelled (VMT) associated with that growth, so the greenhouse gas impacts identified for the adopted General Plan would not change as the future buildout is expected to be the same as identified in the Change Area 12 Addendum to the General Plan DEIR. Therefore, there would be no new greenhouse gas impacts that have not been previously disclosed, examined, or adequately addressed in the General Plan DEIR and associated addenda . No new greenhouse gas emissions would also mean that there would be no additional contribution to sea level rise beyond what was already considered in the General Plan FEIR . With greater commitments to open space and urban forestry, walkability, and support for alternative modes of travel in the Environmental Justice Element than in the adopted General Plan,), the General Plan Update would help reduce Richmond’s carbon footprint and support the CAP’s greenhouse gas reduction strategies. Development within the City of Richmond is required to comply with AB 32 and with the Richmond CAP. The CAP provides a clear roadmap to meet air pollution reduction target mandated by State law and includes measures that will enable the City to accomplish much deeper reductions by 2030.

The Housing Element update identifies sites located throughout the city designated for residential development, potential development on these sites was evaluated in the General Plan EIR as part of the overall assessmen t of the General Plan buildout. The units accommodated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Potential impacts to climate change/greenhouse gas emissions cannot be assessed in a meaningful way until a specific project site and development design is known, including the number of units, the number of residents, and VMT associated with the project. Impacts identified for an individual General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
38 project would be addressed through the project approval process specific to concerns for that project. Future development in Richmond would be subject to mitigation measures 3.6 -1a through 3.6-1o from the General Plan EIR, which would reduce climate/ greenhouse gas impacts to the extent feasible. In addition, future development would be subject to Chapter

9.64 of the RMC, which prohibits the use of natural gas in most new buildings, which would reduce natural gas and associated GHG emissions in future development. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to climate/ greenhouse gas to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant climate change impacts would occu r beyond what was addressed in the General Plan Final EIR.

3.6 Geology, Soils, and Minerals

PREVIOUSLY IDENTIFIED IMPACTS ON GEOLOGY, SOILS, AND MINERALS IN

THE RICHMOND GENERAL PLAN FINAL EIR
Impact 3.7-1 Buildout of the proposed General Plan would not expose people or structures to fault rupture, strong
seismic groundshaking, or seismic-related ground
failure beyond an acceptable level of risk which is
minimized through adherence to the California
Building Code. This is considered a less-than-
significant impact.

No Mitigation Measures Required.

Impact 3.7-2 Adherence to the California Building Code would ensure that development under the proposed
General Plan would not be subject to risk from
settlement and/or subsidence of land, lateral
spreading, or expansive soils, which could create
risks to life and property. This is considered a
less-than-significant impact.

No Mitigation Measures Required.

Impact 3.7-3 Project-specific review and conformity with the City’s Hillside Preservation Ordinance would
ensure that development under the proposed
General Plan would not result in soil erosion that
would result in long-term safety concerns or slope
instability beyond an acceptable level of risk. This
is considered a less-than-significant impact.

No Mitigation Measures Required.

Impact 3.7-4 Development under the proposed General Plan would not result in landslide hazards beyond an
acceptable level of risk. This is considered a less-
than-significant impact.

No Mitigation Measures Required.

Impact 3.7-5 Development under the proposed General Plan would not affect mineral resource availability. This
is considered a less-than-significant impact.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.7-20 through -31.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
39 PROPOSED GENERAL PLAN UPDATES
No portion of the General Plan Updates would change any General Plan policies and action items related to geology and soils. Furthermore, all structures are subject to stringent building codes established in State and local regulations regarding seismic safety, landslides, settlement, and expansive soils. In addition to Building Code regulations, existing General Plan policies and implementing actions regulate land use, development standards, an d construction practices to reduce the risk to humans and property in the event of an earthquake or other seismic activity. The amendments to the Public Safety and Noise Element include details on hazard mapping related to geologic and seismic hazards and hazard mitigation, evacuation route planning, and emergency preparedness and provide for the City’s adoption of a Local Hazard Mitigation Plan by reference to the Contra Costa County Hazard Mitigation Plan, Volume 2 – Planning Partner Annexes.

Also, there are existing State and local regulations established to minimize erosion. E rosion control standards are set by the Regional Water Quality Control Board ( RWQCB) through administration of the National Pollution Discharge Elimination System (NPDES) permit process for storm drainage discharge. At the local level, the existing General Plan includes numerous measures to minimize soil erosion. Since the General Plan Updates would not lead to inconsistencies with General Plan geology, soils, or minerals policies and would further the objectives of State law related to hazard mitigation and emergency planning, no new or substantially more severe impacts would occur than was identified in the General Plan FEIR.

The Housing Eleme nt update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan. Potential impacts to geology, soils, and minerals cannot be assessed in a meaningful way until a specific project site is known, including the specific location of residential development, the potential for paleontological resources on site, and the typ e of soil and natural hazards such as fault zones near the site. Future development would be required to comply with local and state codes and requirements related to geologic hazards, including the California Building Code and applicable General Plan poli cies. Compliance with these requirements would ensure impacts would remain less than significant. In addition, future development would connect to the existing sewer system and not include septic tanks or other alternative wastewater disposal systems. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to geology, soils, and minerals to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant geological, soil, or mineral impacts would occur beyond what was addressed in the General Plan Final EIR.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
40 3.7 Hazards and Hazardous Materials

PREVIOUSLY IDENTIFIED IMPACTS ON HAZARDOUS MATERIALS IN THE

RICHMOND GENERAL PLAN FINAL EIR
Impact 3.8-1 Implementation of the proposed General Plan would involve the routine use, storage,
transportation, and disposal of hazardous materials
in existing and proposed land uses. However, it
would not create a significant hazard to the public
or the environment. As a result, the proposed
General Plan would have a less-than-significant
impact with respect to use, storage, handling and
disposal of hazardous materials.

No Mitigation Measures Required.

Impact 3.8-2 Development under the proposed General Plan would include demolition or renovation of existing
structures that could contain asbestos-containing
materials, lead-based paint, PCBs, or other building
materials containing hazardous substances that
could expose people or the environment to risks
associated with those materials. However, project-
specific review and implementation of best
management practices and project-specific
mitigation measures would ensure that these
activities would not result in 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. As a result, this is considered a less-
than-significant impact.

No Mitigation Measures Required.

Impact 3.8-3 There are locations within the City that are included on the list of hazardous materials sites (Cortese
List) compiled pursuant to Government Code
section 65962.5, as well as other locations where
hazardous materials related environmental
contamination may be present, but the site is not
yet listed. However, the existing regulatory
framework and City requirements to address
contaminated sites would reduce exposure hazards
to the public or the environment to less than
significant.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.8-14 through -24.

PROPOSED GENERAL PLAN UPDATES
The General Plan Update s augment the General Plan policies and action items related to hazards and human health and includes mapping of hazards; they do not alter the physical setting related to hazardous materials from that analyzed in the General Plan EIR.

The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
41 scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan.

Additionally, there is no rezoning or changes in land use associated with the housing element update. Therefore, the housing element update would not result in in greater impacts to hazards and hazardou s materials than what was analyzed in the 2030 General Plan EIR.

Potential impacts to hazards and hazardous materials cannot be assessed in a meaningful way until a specific project site is known, including the specific location of residential development, and the potential for the presence of hazardous materials on site. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to hazards and h azardous materials to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Additionally, all future development projects would be subject to all applicable local, State, and federal regulations regarding the transportation, use, and disposal of hazardous materials as well as regulations regarding sites with contaminated soil or groundwater. Compliance with these existing regulations would reduce impacts related to hazardous materials. Because the proposed amendment would not affect existing review procedures and performance standards for the use, handling, storage and transportation of hazardous wastes, no new or increased severity of significant hazard impacts would occur beyond what was addressed in the General Plan FEIR.

The Environmental Justice Element continues and builds on the General Plan to reinforce this finding. For example, Action EJ5.A would support implementation of the Contra Costa County LHMP, including updating hazard risk maps to assess and address natural hazards in Richmond, and Action EJ6.D would facilitate abatement of lead and asbestos hazards from lead-based paints and asbestos -containing materials. Both of these would help to reduce exposure to hazards and hazardous materials.

In addition, the amendments to the Public Safety and Noise Element add mapped information on geologic and seismic hazards, flooding and tsunami hazards, and fire threats and incorporate a LMHP into the General Plan by reference to the Contra Costa Hazard Mitigation Plan, Volume 2 – Planning Partner Annexes . Policies added to the General Plan through the amendments to the Public Safety and Noise Element will increase evacuation capabilities during emergencies and provide for evacuation alter natives in access -constrained neighborhoods. They also will provide for improved communications systems during emergencies and bi-lingual information materials for emergency preparedness. An emergency access mitigation fee also is proposed to help fund imp rovements that would alleviate evacuation constraints.

Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant hazard and hazardous materials impacts would occur beyond what was addressed in the General Plan Final EIR.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
42 3.8 Hydrology and Water Quality

PREVIOUSLY IDENTIFIED IMPACTS ON HYDROGOLOGY AND WATER

QUALITY IN THE RICHMOND GENERAL PLAN FINAL EIR
Impact 3.9-1 Development under the proposed General Plan would not result in violation of waste discharge
requirements (WDRs), because of existing
measures to ensure compliance with the WDRs and
the proposed policies and implementing actions
included as part of the General Plan. This is a less-
than-significant impact.

No Mitigation Measures Required.

Impact 3.9-2 New development under the proposed General Plan would not be expected to substantially reduce
groundwater recharge or increase groundwater use
within the City. This is a less-than-significant impact.

No Mitigation Measures Required.

Impact 3.9-3 Construction and operation of development under the proposed General Plan could substantially alter
drainage patterns that could result in substantial
erosion or siltation. Implementation of General Plan
Policies and Implementing Actions would render this
impact less than significant.

No Mitigation Measures Required.

Impact 3.9-4 Implementation of the proposed General Plan could alter drainage patterns and cause or contribute to
increased runoff and flooding. This impact is less
than significant.

No Mitigation Measures Required.

Impact 3.9-5 Buildout of the proposed General Plan could increase the amount of runoff and pollution in runoff.

This impact is less than significant.

No Mitigation Measures Required.

Impact 3.9-6 Construction and operation of development under the proposed General Plan could contribute to
groundwater quality degradation. This impact is less
than significant.

No Mitigation Measures Required.

Impact 3.9-7 Construction and operation of development under the proposed General Plan could expose people and
structures to 100-year flood hazards. However,
existing and proposed flood hazard regulations,
policies, and implementing actions of the proposed
General Plan would reduce risks to acceptable
levels. The impact would be less than significant.

No Mitigation Measures Required.

Impact 3.9-8 Development within the City could be subject to dam failure inundation and sea level rise flood hazards.

Implementation of General Plan Policies and
Implementing Actions would render this a less than
significant impact.

No Mitigation Measures Required.

Impact 3.9-9 The proposed General Plan would require
infrastructure improvements to accommodate
increased stormwater runoff and drainage needs,
the construction of which could result in physical
impacts. However, standard construction measures
and Best Management Practices would reduce
impacts to less than significant. This is a less-than-
significant impact.

No Mitigation Measures Required.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
43 These impacts were addressed in d etail in DEIR pages 3. 9-17 through -38 with minor refinements made in the FEIR.

PROPOSED GENERAL PLAN UPDATES
As noted above, citywide buildout and development under t he General Plan Update s are anticipated to be the same as that identified in the General Plan EIR , as modified by the Change Area 12 Addendum . Th erefore, there would be no new causes for substantial depletion or interference with groundwater recharge , water quality degradation, increased runoff or flooding, increased sources of polluta nt discharge, seiche, tsunami, or mudflow, or exacerbation of sea level rise effects that have not been previously examined or adequately addressed in the General Plan EIR. Additionally, with the Environmental Justice Element the General Plan Update s support more open space and recreational uses, semi -permanent buildings (e.g. greenhouses and similar temporary structures ), improved access to parks and recreational facilities, urban agriculture, and urban forestry and in the amendments to the Public Safety and Noise Element better hazard mitigation and emergency preparedness. These policies and implementing actions would lead to greater protection from future hazards particularly in areas that are vulnerable to flooding and sea level rise, tsunamis, seismic hazards, and wildfires.

The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing E lement update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Pl an EIR for buildout under the General Plan.

Additionally, there is no proposed rezoning or changes in land use proposed as part of the housing element update. Therefore , the housing element would not impact hydrology and water quality to a greater extent t han what was analyzed in the 2030 General Plan EIR.

Potential impacts to hydrology and water quality cannot be assessed in a meaningful way until a specific project site is known, including the specific location of residential development , water sources near the site, groundwater location below the site, and construction activities .

As with buildout under the General Plan, all future development would be subject to State and local regulations regarding stormwater discharge, sedimentation, drainage alteration, construction practices, and water quality. Therefore, future development wou ld not violate water quality standards or NPDES requirements and would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge. Because future development under the proposed project would be within the buildout a ssumed under the General Plan, the proposed project would not result in adverse impacts to hydrology and water quality to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Future development would be subject to Sta te and local regulations regarding stormwater discharge, sedimentation, drainage alteration, construction practices, and water quality.

Therefore, no new significant environmental effect or a substantial increase in the severity of General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
44 previously identified significant hydrology or water quality impacts would occur beyond what was addressed in the General Plan Final EIR.

3.9 Noise

PREVIOUSLY IDENTIFIED NOISE IMPACTS IN THE RICHMOND GENERAL

PLAN FINAL EIR
Impact 3.10-1 Construction activities associated with the future land use changes under the proposed General
Plan could generate noise levels that temporarily
exceed acceptable noise levels. Implementation
of noise limits in the City of Richmond Municipal
Code would limit the exposure of sensitive
receptors to temporary or periodic increases in
noise levels. However, because noise from
construction activities could exceed allowable
noise levels, this is considered a significant and
unavoidable impact.

Mitigation Measure 3.10-1: Future
projects shall incorporate project-
specific mitigation measures to
reduce the impact of construction
noise.

Impact 3.10-2 Construction of future new land uses under the proposed General Plan could generate or expose
persons or structures to temporary groundborne
vibration. Though it is unlikely that vibration
would exceed levels of mere annoyance for short
periods, the potential for impacts on sensitive
uses renders this impact significant and
unavoidable.

Mitigation Measure 3.10-2: Future
projects shall incorporate project-
specific mitigation measures to
reduce the impact of construction-
related groundborne vibration.

Impact 3.10-3 Implementation of the proposed General Plan could expose sensitive receptors to noise levels
in excess of the existing noise standards
established by the City. There are no known
feasible measures to reduce train noise below a
level of significance; this impact would be
significant and unavoidable.

Mitigation Measure 3.10-3: Future
projects shall incorporate project-
specific mitigation measures and
maintain Quiet Zones to reduce the
impact of train noise.

Impact 3.10-4 Operation of new land uses under the proposed General Plan would not generate and expose
sensitive receptors on- or off-site to excessive
groundborne vibration or groundborne noise
levels. This is considered a less-than-significant
impact.

No mitigation measures required.

Impact 3.10-5 Operation of new land uses under the proposed General Plan would generate increased local
traffic volumes that would cause a substantial
permanent increase in ambient noise levels in
the project vicinity. While implementation of
General Plan policies would reduce impacts on
sensitive receptors, the impact would remain
significant and unavoidable.

Mitigation Measure 3.10-5: Future
projects shall incorporate project-
specific mitigation measures to
promote nonmotorized transportation
to reduce the impact of traffic noise.

These impacts were addressed in detail in Draft EIR pages 3. 10-19 through -35 with minor refinements made in the FEIR.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
45 PROPOSED GENERAL PLAN UPDATES
The General Plan Updates would not change any of the General Plan policies related to noise or noise exposure . In addition, because the Environmental Justice Element promotes walkability and greater use of alternative modes and calls for preparation of a Bicycle and Pedestrian Action Plan , there would be less automobile traffic, which would reduce the potential noise related to automobiles from the level analyzed in the General Plan EIR. Also, the Environmental Justice Element calls for the correction of existing deficiencies in the transportation system which reduce congestion and vehicle backups and more street tree planting, which may have an impact on the exposure of residents to noise associated with cars, motorcycles, and trucks. The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be wit hin those studied in the General Plan EIR for buildout under the General Plan. Potential impacts to noise cannot be assessed in a meaningful way until a specific project site is known, including the specific location of residential development, potential sensitive receptors near the project site, construction hours, and construction activities.

Impacts identified for an individual project would be addressed through the project approval process specific to that project. Future development in Richmond would b e subject to mitigation measures 3.10-1 through 3.10-5 from the General Plan EIR, which would reduce noise impacts to the extent feasible. Because future development under the proposed project would be within the buildout assumed under the General Plan, th e proposed project would not result in adverse impacts related to noise to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR. Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant noise impacts would occur beyond what was addressed in the General Plan Final EIR.

3.10 Parks and Recreation

PREVIOUSLY IDENTIFIED IMPACTS ON PARKS AND RECREATION IN THE

RICHMOND GENERAL PLAN FINAL EIR
Impact 3.11-1 Implementation of the proposed General Plan would increase the use of existing
neighborhood and regional parks or other
recreational facilities but would not
substantially accelerate or result in substantial
physical deterioration of the facilities. This is
considered a less-than-significant impact.

No Mitigation Measures Required.

Impact 3.11-2 Implementation of the proposed General Plan would not create a demand for the construction
or expansion of park facilities beyond that
anticipated in the General Plan. This is
considered a less-than-significant impact.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.11-7 through -13.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
46 PROPOSED GENERAL PLAN UPDATES
Buildout under the General Plan Updates is anticipated to include the same amount of housing identified in the General Plan DEIR and, therefore, overall use of existing parks and the demand for new parks would be the same as the estimated effects in the Ge neral Plan FEIR.

The parkland dedication standard applied through the Subdivision Regulations to new residential development within the City ensure s that parkland is created in conjunction with population growth and that existing park resources are not ove rused. The City also would continue to impose development impact fees to fund parks and recreation. Existing General Plan policies would further reduce the potential for impacts on parks and recreation facilities.

Additionally, the General Plan Updates propose new policies that improving access to parks and recreational facilities, particularly for those in Environmental Justice neighborhoods.

Policy EJ7.1 seeks to provide citywide opportunities for recreation and physical activity for all residents, and Policy EJ7.2 would approve transportation connectivity to improve park access.

Further, Action EJ7.F would leverage existing facilities to help meet park and recreation demand, thereby reducing the need for construction of new facilities.

The Housing Elemen t update identifies sites located throughout the city designated for residential development, potential development on these sites was evaluated in the General Plan EIR as part of the overall assessment of the General Plan buildout. The units accommodated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Therefore, the proposed project would not generate population growth beyond what could occur under the General Plan. As a result, the proposed project would not increase the use of parks and recreational facilities beyond the increase analyzed in the General Pl an EIR and would therefore not result in substantial physical deterioration of facilities. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to parks and recreation to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant parks and recreation impacts would occur beyond what was addressed in the General Plan Final EIR.

3.11 Public Services

PREVIOUSLY IDENTIFIED IMPACTS ON PUBLIC SERVICES IN THE RICHMOND

GENERAL PLAN FINAL EIR
Impact 3.12-1 Implementation of the General Plan Update would increase the demand for fire protection and
emergency services and/or create a demand for
additional fire stations, department personnel, and/or
equipment, but would not reduce the level of
protection. This is considered a less-than-significant
impact.

No Mitigation Measures
Required.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
47 Impact 3.12-2 Implementation of the General Plan Update would increase the demand for police protection services
and create a demand for additional police stations,
department personnel, and/or equipment, but would
not reduce the level of protection. This is considered
a less-than-significant impact.

No Mitigation Measures
Required.

Impact 3.12-3 Implementation of the proposed General Plan could generate additional students, but the demand for
new school facilities would be fully mitigated with
required payment of school fees. As a result, this is
considered a less-than-significant impact.

No Mitigation Measures
Required.

Impact 3.12-4 Implementation of the proposed General Plan would create an additional demand for library services but
would not result in a substantial adverse
environmental impact associated with the provision
of new or physically altered libraries or the need for
new or physically altered libraries. This is considered a less-than-significant impact.

No Mitigation Measures
Required.

These impacts were addressed in detail in DEIR pages 3.12-9 through -20.

PROPOSED GENERAL PLAN UPDATES
The General Plan Updates would not create more residential land uses than established in the General Plan, nor would buildout estimates under the General Plan Update s change from those established for the current General Plan . The Housing Element update identifies sites located throughout the city designated for residential development, potential development on these sites was evaluated in the General Plan EIR as part of the overall assessment of the General Plan buildout. The units accommodated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR . Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to public services to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR. Therefore, the proposed project would not create additional demand for public services beyond the demand evaluated in the General Plan DEIR. As a consequence, no new significant environmental effect is expected, nor would a substantial increase in the severity of previously identified significant public service impacts occur beyond what was addressed in the General Plan Final EIR.

Recent changes to the CEQA Guidelines have added additional checklist questions related to wildfire hazards to Appendix G of the CEQA Guidelines. Since Wildfire was added to the CEQA Guidelines as a separate environmental issue area after certification of the General plan EIR, it does not inc lude a chapter or section dedicated to analysis of impacts to wildfire.

However, impacts associated with wildland fire were discussed in Section 3.12, Public Services, of the General Plan EIR. As discussed in that section, implementation of the General Pla n would involve construction and operation of land uses in areas that are surrounded by urban land uses that are not mixed with or adjacent to wildlands and would not be exposed to an increased risk of wildfires. The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
48 environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan. Wildfires are of particular concern in areas designated as a Very High Fire Hazard Severity Zone. The areas identified for housing development under the Housing Element are not located within or adjacent to land classified as a Very High Fire Hazard Severity Zone (California Department of Forestry & Fire Protection 2009 and 2020). Therefore, with compliance with applicable State requirements, the project would not exacerbate wildfire risk and impacts would be less than significant.

3.12 Public Utilities

PREVIOUSLY IDENTIFIED IMPACTS ON PUBLIC UTILITIES IN THE RICHMOND

GENERAL PLAN FINAL EIR
Impact 3.13-1 Implementation of the proposed General Plan would not require or result in the construction and/or
expansion of water supply facilities, the construction
of which could cause significant environmental
impacts, or require water supplies in excess of
existing entitlements. This is considered a less-than-
significant impact.

No Mitigation Measures
Required.

Impact 3.13-2 Implementation of the proposed General Plan would not exceed wastewater treatment requirements of
the Regional Water Quality Control Board. This is
considered a less-than-significant impact.

No Mitigation Measures
Required.

Impact 3.13-3 Implementation of the General Plan Update could require the construction or expansion of wastewater
treatment facilities or collection systems that could
cause significant environmental impacts, absent
project-specific mitigation measures. Because it is
not certain that project-specific mitigation would
reduce all impacts to a less-than- significant level,
this is considered a significant impact.

Mitigation Measure 3.13-3:

Future projects shall incorporate
project-specific mitigation
measures to reduce impacts
from the construction of new
wastewater collection and
treatment facilities.

Impact 3.13-4 Implementation of the proposed General Plan would not result in a determination by the wastewater
treatment provider that it does not have adequate
capacity to serve the project’s demand in addition to
the provider’s existing commitments. This is
considered a less-than-significant impact.

No Mitigation Measures
Required.

Impact 3.13-5 Implementation of the proposed General Plan could result in the generation of additional solid waste, but there is sufficient landfill capacity to accommodate
the increased demand for solid waste service. This
is considered a less-than-significant impact.

No Mitigation Measures
Required.

Impact 3.13-6 Implementation of the proposed General Plan would comply with all applicable federal, state, and local
statutes and regulations related to solid waste. This
is considered a less-than-significant impact.

No Mitigation Measures
Required.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
49 Impact 3.13-7 Implementation of the General Plan would increase the demand for electricity and natural gas but would
not require or result in the construction of new
energy production or transmission facilities, the
construction of which could cause a significant
environmental impact. This is considered a less-
than-significant impact.

No Mitigation Measures
Required.

Impact 3.13-8 Implementation of the proposed General Plan would not result in the wasteful or inefficient use of energy.

This is considered a less-than- significant impact.

No Mitigation Measures
Required.

These impacts were addressed in detail in DEIR pages 3.13-8 through -28.

PROPOSED GENERAL PLAN UPDATES
The proposed General Plan Updates would not cre ate more residential land uses or commercial and industrial development opportunities than established in the current General Plan. Therefore, these General Plan Updates would not create additional demand for public utilities beyond the demand evaluated in the General Plan DEIR.

The Housing Element update identifies sites located throughout the city designated for residential development, potential development on these sites was evaluated in the General Plan EIR as part of the overall assessment of the General Plan buildout. The units accommodated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. The units accommodated by the Housing Eleme nt update would also be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General P lan EIR for buildout under the General Plan. Potential impacts to public utilities cannot be assessed in a meaningful way until a specific project site and development design is known, including the number of units, current utilities provided on site, the number of residents, and construction activities. Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project.

Consistent with buildout under the General Plan, development assoc iated with the Housing Element would not increase water demand more than what was previously analyzed. Under EMBUD’s Water Supply Management Program 2040, consumer consumption is projected to be reduced by 35 percent through conservation measures to ensure adequate water supply for EBMUD’s service area (EBMUD 2012). Like development under the General Plan, development under the Housing Element would also result in less than significant impacts to wastewater treatment requirements as wastewater districts ser ving the City of Richmond would be required to comply with NPDES permit requirements to ensure discharges would not exceed the Regional Water Quality Control Board wastewater treatment requirements.

Although development under the General Plan and proposed project could require the construction or expansion of wastewater treatment facilities or collection systems that could cause significant and unavoidable environmental impacts, Mitigation Measure 3.14 -3 would reduce impacts to the extent feasible. Future development in Richmond would be subject to mitigation measure 3.13-1 from the General Plan EIR, which would reduce impacts to public utilities to the extent feasible. Because future development under the proposed project would General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
50 be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to public utilities to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

It may affect the geographic distribution of service avail ability to meet the goals and policies of the Environmental Justice Element related to equity and services provided to Environmental Justice Element neighborhoods and the priorities for capital investments may be influenced by additional outreach and community input. For example, Policy EJ8.3 would focus planning and intervention in and with communities with the highest needs by ensuring that policies, services, and programs are prioritized to benefit Environmental Justice Communities. This would also apply to the Capital Improvement Plan (CIP) and use of the General Fund (Actions EJ7.E and EJ8.D). Further, Policy EJ4.4 would promote green design, as provided for in the California Green Building Code, to help reduce energy use and demand in Environmental Jus tice Communities, as would other co -benefits of heat mitigation strategies achieved by Policy EJ4.2. However, because citywide land use is not changed , no new significant environmental effect or a substantial increase in the severity of previously identified significant public utility impacts would occur beyond what was addressed in the General Plan Final EIR.

Since Energy was added to the 2019 CEQA guidelines as a separate environmental issue area, the General Plan EIR does not include a chapter or section dedicated to analysis of energy impacts. However, it does analyze such impacts in Chapter 3, Section 3.13, Public Utilities, of the 2012 EIR. The General Plan EIR concludes that no mitigation measures are required as energy impacts would be less than significant. The proposed General Plan Updates would not allow increased building area or height than is currently allowed under the General Plan.

Consistent with buildout under the General Plan, future development would increase demand for electricity but wou ld not require the construction of new energy production or transmission facilities. Future development would be subject to Chapter 9.64 of the RMC, which prohibits the use of natural gas in most new buildings, which would reduce natural gas use. The proposed General Plan Updates would also not result in the wasteful or inefficient use of e nergy. Finally, consistent with the analysis in the General Plan EIR, future development would be required to comply with General Plan policies and Implementing Actions that serve to reduce impacts on energy and electricity supply to a less than significant level.

3.13 Transportation and Circulation

PREVIOUSLY IDENTIFIED IMPACTS ON TRANSPORTATION AND

CIRCULATION IN THE RICHMOND GENERAL PLAN FINAL EIR
Impact 3.14-1 The proposed General Plan may result in traffic congestion that exceeds the previous City of
Richmond traffic LOS standard of LOS D, as well
as CCTA and WCCTAC LOS and MTOS
standards. Because it is not certain that project-
specific mitigation measures would reduce
Mitigation Measure 3.14-1: Future
projects shall incorporate project-
specific mitigation measures to
reduce traffic impacts.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
51 impacts to a less-than-significant level, this is a
significant and unavoidable impact.

Impact 3.14-2 The proposed General Plan’s Planned Roadway Improvements would improve mobility and safety
for all modes, fulfilling the proposed General
Plan’s goals and policies regarding safety and
provision of a multi-modal circulation system.

This is a less-than-significant impact.

No Mitigation Measures Required.

Impact 3.14-3 Implementation of the proposed General Plan would produce higher demand for transit service,
potentially exceeding the capacity of transit
service providers. This is a significant and
unavoidable impact.

No Mitigation Measures Required.

Impact 3.14-4 Implementation of the proposed General Plan would provide enhanced facilities to serve
pedestrians and bicyclists, increasing
connectivity and safety for these modes.

Therefore, the project would result in no impact.

No Mitigation Measures Required.

Impact 3.14-5 The proposed General Plan would reduce the potential for conflicts at rail/roadway crossings,
improving safety for all modes. Therefore, the
result would be no impact.

No Mitigation Measures Required.

Impact 3.14-6 The proposed General Plan would increase
congestion and reduce travel speeds on various
roadways throughout the City, including some
that are on primary emergency response routes
(i.e. freeways and arterials). This is a significant
and unavoidable impact.

No Mitigation Measures Required.

These impacts were addressed in detail in DEIR pages 3.14-27 through -52 with minor refinements made in the FEIR.

PROPOSED GENERAL PLAN UPDATES
Pursuant to CEQA Guidelines section 5064.3, subdivision(b), a project’s transportation impact is now based on vehicle miles traveled (VMT) instead of an LOS analysis as conducted under the General Plan EIR. Under the updated state requirements, VMT estimat es are derived based on location and the amount and distance of vehicle travel attributable to a project, including induced automobile travel. Significance criteria used to determine VMT impact include questions as to whether the project would cause substa ntial additional VMT, or substantially induce additional automobile travel by increasing physical roadway capacity in congested areas (e.g., by adding new mixed flow travel lanes) or by adding new roadways to the network.

Buildout under the General Plan Updates is not anticipated to be different from that identified in the General Plan DEIR as modified by the Change Area 12 Addendum, so the impacts on traffic and transit would be the same as those identified in the General Plan EIR as modified by the Change Area 12 Addendum. Emergency response capabilities would be improved as a result of the amendments to the Public Safety and Noise Element as they focused on emergency preparedness related to identified evacuation scenarios and add polices and implementation actions for emergency preparedness . For example, Policy SN3.4 would General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
52 increase evacuation capacity, Policy SN3.7 w ould enhance emergency communications systems, and Action SN3.J would implement traffic operations strategies during emergencies, to be managed by the City’s Emergency Operations Center, and signal timing would be coordinated with Caltrans.

The Housing Element update identifies sites located throughout the city designated for residential development, potential development on these sites was ev aluated in the General Plan EIR as part of the overall assessment of the General Plan buildout. The units accommodated by the Housing Element update would not exceed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Potential impacts to transportation cannot be assessed in a meaningful way until a specific project site and development design is known, including the number of units , the number of residents, and the potential VMT associate with the project . Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project.

Future development in Richmond would be subject to mitigation measure 3.14 -1 from the General Plan EIR, which would reduce transportation impacts to the extent feasible. Further, the City has a Transportation Demand Management (TDM) Ordinance (RMC Section

15.04.612) which requires multi -unit residential developments of ten or more units and nonresidential developments of 10,000 or more square feet to develop and implement a TDM plan to the extent feasible reduce the development’s vehicle trip generation to 15 percent below the standard rates as published in the latest edition of the Institute of Transportation Engineers’ Trip Gen eration Manual and/or to ensure that the VMT per resident or worker for the development is below the citywide average. Most of the future residential development under the Housing Element Update would be subject to the requirements of the City’s TDM ordinance. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to transportation to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Furthermore, the General Plan Update would serve to reduce future transportation impacts and support the Climate Action Plan ’s greenhouse gas reduction strategies , with greater emphasis on walkability and support for alternative modes, than in the adopted General Plan.

In fact, one of the implementation actions in the Environmental Justice Element is to prepare a Bicycle and Pedestrian Action Plan. As a result, no new significant environmental effect or a substantial increase in the severity of previously identified significant transportation impacts would occur beyond what was addressed in the General Plan Final EIR.

3.14 Visual Resources

PREVIOUSLY IDENTIFIED IMPACTS ON VISUAL RESOURCES IN THE

RICHMOND GENERAL PLAN FINAL EIR
Impact 3.15-1 Development activities associated with the proposed General Plan could have a
substantial adverse effect on a scenic vista
or substantially degrade the existing visual
No Mitigation Measures Required.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
53 These impacts were addressed in detail in DEIR pages 3.15-7 through -20.

PROPOSED GENERAL PLAN UPDATES
As noted above, buildout under the General Plan Updates is anticipated to be the same as that identified in the General Plan DEIR as modified by the Change Area 12 Addendum . The current General Plan decreased the maximum building heights for d evelopment in Change Area 12 to 20 - 25 feet under the Industrial Agriculture and Shoreline Conservation land use designations rather than the 55 feet allowed with a conditional use permit in the ILL (Limited Light Industrial ) Zoning District used to implement the Low Intensity Business/Light Industrial designation established in the original 2030 General Plan.

The Housing Element update identifies sites located throughout the city designated for residential development evaluated previously for potential environmental impacts in the General Plan EIR. The units accommodated by the Housing Element update would be built in locations that were assumed for development under the General Plan, including building scale and extent of site disturbance, and therefore the physical effects of such projects would be within those studied in the General Plan EIR for buildout under the General Plan. Potential impacts to visual resources cannot be assessed in a meaningful way until a specific project site and development design is known, including the specific location of residential development, potential scenic resources near the project, and the design components of the project. Impacts identified for an individual project would be addressed through the project approval process specific to concerns for that project. F uture development in Richmond would be subject to mitigation measure 3.15-2 from the General Plan EIR, which would reduce impacts to visual resources to the extent feasible. Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would character or quality of the site and its
surroundings. Though project-specific
mitigation measures would be
implemented, this remains a significant and
unavoidable impact.

Impact 3.15-2 The development of the proposed General
Plan could create a new source of
substantial of light or glare that would
adversely affect day or nighttime views in
the area. Though all available mitigation
would be implemented, this remains a
significant and unavoidable impact.

Mitigation Measure 3.15-2:
a. All street lighting shall be directed
downward and shielded to prevent
light spill onto surrounding
properties, sky glow, and glare.
b. The City shall restrict the use of high
level outdoor lighting for new homes,
particularly along the hillside ridges.
c. Landscaping shall be incorporated
along internal roads and near off-site
homes to reduce spill light emanating
from vehicles and buildings.
d. The City shall require design review
of any project containing reflective
glass or metal building materials that
exceed 50 percent of any building
surface or the first three floors.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
54 not result in adverse impacts to visual resources to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR.

Future land uses and new development would be requi red to conform to all applicable regulations, property development and performance standards, including limitations on light trespass and glare, and design standards that address the preservation of public scenic vistas set forth in the adopted General Plan. The General Plan Updates would not result in new or more severe impacts related to light and glare. Therefore, no new significant environmental effect or a substantial increase in the severity of previously identified significant visual resource impacts would occur beyond what was addressed in the General Plan Final EIR.

3.15 Population and Housing

PREVIOUSLY IDENTIFIED IMPACTS IN THE RICHMOND GENERAL PLAN

FINAL EIR
(No Impact
Number)
Buildout under the General Plan would induce
population growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example, through
extension of roads or other infrastructure).

No Mitigation Measures Required.

Impacts on population and housing were addressed in DEIR pages 3. 2-1 through 3.2 -8; growth-inducing impacts were addressed on pages 4-6 through 4-9.

PROPOSED GENERAL PLAN UPDATES
As noted above, buildout under the General Plan Updates is anticipated to be the same as that identified in the General Plan DEIR as modified by the Change Area 12 Addendum .

Therefore, implementation of the General Plan Updates would not result in higher levels of growth or more concentrated growth than identified for the General Plan. Future development that occurs pursuant to the proposed General Plan Updates would be required to conform to all applicable regulations, performance standards , and design standards that would minimize or avoid the adverse physical impacts of growth. In fact, the General Plan includes a Growth Management Element th at specifically addresses the impacts of growth, and no changes to that element, to its policies, performance standards, and implementing actions, are proposed in these General Plan Updates.

The General Plan Updates do not include any changes to future residential land uses, so the General Plan Update would not remove or replace housing. Similarly, the Updates would not cause people to be displaced by future development.

The Housing Element update identifies sites located throughou t the city designated for residential development, potential development on these sites was evaluated in the General Plan EIR as part of the overall assessment of the General Plan buildout. The units accommodated by the Housing Element update would not exc eed the buildout capacity estimated under the General Plan and analyzed in the General Plan EIR. Therefore, the General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
55 proposed project would not induce development that would be denser or otherwise generate more population growth than development under the Gener al Plan. Impacts related to population growth would therefore be consistent with impacts anticipated under the General Plan. Moreover, consistent with development under the General Plan, buildout under the Housing Element would largely be in relatively hig h-density mixed -use and in -fill developments and would not result in substantial unplanned population growth in Richmond or surrounding communities. While some housing could be removed with individual future projects, it is not anticipated that there would be substantial removal of housing, and replacement housing would be constructed, similar to the General Plan analysis.

Because future development under the proposed project would be within the buildout assumed under the General Plan, the proposed project would not result in adverse impacts to population and housing to a greater extent than buildout under the General Plan and analyzed in the General Plan EIR. Therefore, no new significant environmental effect or a substantial increase in the severity of pr eviously identified significant population and housing impacts would occur beyond what was addressed in the General Plan Final EIR.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
56 4 Conclusion
The City of Richmond, acting as the lead agency, determined that an addendum is the appropriate environmental doc ument under CEQA, because the proposed General Plan Updates would not require revisions to the adopted General Plan’s Final EIR, as modified by the Change Area 12 Addendum, due to the involvement of new significant environmental effects or substantial increases in the severity of significant effects previously identified in the General Plan Update Final EIR.

There are no changed circumstances or new information that meets the standards for requiring further environmental review under CEQA Guidelines Section 15162. Thus, these circumstances and information would not result in new or more severe impacts beyond what were addressed in the General Plan Final EIR and would not meet any other standards under CEQA Guidelines Section 15162(a)(3). No additional analysis i s required based on the following findings.

First, as addressed in the analysis, the proposed project —the General Plan Update s— implements and is consistent with the land uses in the General Plan that were analyzed in the General Plan Final EIR and with subsequent amendments to the General Plan Land Use Element for Change Area 12. In Change Area 12, the approved amendments to the Land Use Element of the General Plan meant less development than examined in the General Plan EIR and policies incorporated into the General Plan as a result of the Change Area 12 amendment that provided environmental benefits by supporting renewable energy production, protecting wetlands and aquatic habitats, establishing local hiring targets, and maintaining t he San Francisco Bay Trail. The General Plan Update would not result in new or more severe impacts beyond what was addressed in the General Plan Final EIR.

Second, the City is not aware of any substantial changes in the circumstances that would cause a new significant impact or substantially increase the severity of a previously identified significant impact requiring major revisions to the General Plan Final EIR (State CEQA Guidelines Section 15162[a][2]). There have been no changes in the environmental conditions in the City of Richmond not contemplated and analyzed in the General Plan Final EIR that would result in new or substantially more severe environmental impacts.

Third, as documented in Section 3, there is no new information of substantial importan ce (which was not known or could not have been known at the time of the General Plan adoption in October 2003) that identifies: a new significant impact (condition “A” under State CEQA Guidelines Section 15162[a][3]); a substantial increase in the severity of a previously identified significant impact (condition “B” State CEQA Guidelines Section 15162[a][3]); mitigation measures or alternatives previously found infeasible that would now be feasible and would substantially reduce one or more significant effects of the General Plan; or mitigation measures or alternatives that are considerably different from those analyzed in the General Plan Final EIR which would substantially reduce one or more significant effects on the environment (conditions “C” and “D” St ate CEQA Guidelines Section 15162[a][3]). In sum, n one of the General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
57 “new information” conditions listed in the State CEQA Guidelines Section 15162[a][3] are present here to trigger the need for a subsequent or supplemental EIR.

State CEQA Guidelines Section 151 64 states that “The lead agency or a responsible agency shall prepare an addendum to a previously certifie d EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” An addendum is therefore appropriate because, as explained above, none of the conditions calling for preparation of a subsequent EIR have occurred.

General Plan Update: Housing Element, Environmental Justice Element, and Public Safety and Noise Element Amendments
Addendum to the Final EIR
58 References
California Department of Finance. 2022. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022.
https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing- estimates-for-cities-counties-and-the-state-2020-2022/
California Department of Forestry & Fire Protection. 2009. Very High Fire Hazard Severity Zones in LRA As Recommended by CAL FIRE.
https://osfm.fire.ca.gov/media/5784/richmond.pdf (accessed July 2021). ______. 2020. California Fire Hazard Severity Zone Viewer. https://gis.data.ca.gov/datasets/789d5286736248f69c4515c04f58f414 (accessed July 2021).

City of Richmond. 2016. City of Richmond Climate Action Plan.

City of Richmond. 2012. City of Richmond General Plan.

City of Richmond. 2011. City of Richmond General Plan Draft Environmental Impact Report.

City of Richmond. 2011. City of Richmond General Plan Final Environmental Impact Report.

City of Richmond. 2018. City of Richmond Addendum to General Plan Final Environmental Impact Report for Change Area 12
Contra Costa County. 2016. Hazard Mitigation Plan (two volumes) East Bay Municipal Utility District. 2012. Water Supply Management Program 2040. Available:
https://www.ebmud.com/water/about-your-water/water-supply/water-supply- management-program-2040/

Mapped Information
Sources for mapped information included in the Environmental Justice Element and the amendments to the Public Safety and Noise Element are shown on each map. These include the U.S. Geologic Survey, City of Richmond Geologic Information System (GIS) data, MTC/ABAG GIS Data, FEMA, and Contra Costa County GIS data.

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