San Carlos City Council
January 23, 2023

5. And finally, the city or county must use the fees in areas consistent with the city or county’s local Quimby Act ordinance and General Plan.

AB 1359 also allows a city or county to enter into a joint or shared use agreement with one or more public districts in order to provide additional park and recreational access.

The Quimby Act sets a standard park space to population ratio of up to 3 acres of park space per 1,000 persons. Cities with a ratio of higher than three acres per 1,000 persons can set a standard of up to 5 acres per 1,000 persons for new development. The calculation of a City’s park space to population ratio is based on a comparison of the population count of the last federal census to the amount of City-owned parkland. The City of San Carlos has a Quimby Act ordinance in place and uses the fees for improvements to serve new developments (Municipal Code Chapter 3.34).

Local
Park Land Dedication In-Lieu Fee
Park In-Lieu Fees are assessed pursuant to the Quimby Act under Government Code Section 66447. Under the Quimby Act, local governments may require the dedication of land for parks or the payment of fees in-lieu of land dedication as a condition of subdivision map approval. The Park Land Dedication In-Lieu Fee is collected and expended to purchase land, buy equipment, or construct improvements in neighborhood parks and recreation facilities serving such subdivisions.

Park Facility Development Fee
Park Facility Development Fees are assessed pursuant to Law of the City of San Carlos (Ord. 1007 § 1 (part), 1988) per Municipal Code section 3.34. The fee is used for the acquisition, development, renovation, and replacement of parks and recreational areas and their development, including equipment for recreational purposes.

Master Plan for Parks, Open Space, Buildings and other Recreational Facilities Local regulations for parks and recreational facilities are contained within the Master Plan for Parks, Open Space, Buildings and other Recreational Facilities, which was adopted in August

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2008. The purpose of the Plan is to provide the City with a long-term vision for its park system.

The Plan addresses the City’s park service standards, including park acres per capita, walking distance to park facilities, ideas for new parks, and improvements to existing parks. The Master Plan assumed a population of 34,264 in 2030, which is approximately 1,960 more people than the Draft 2030 General Plan assumed would reside in San Carlos in 2030. Using this rate of population growth, in addition to other factors, the Plan identified the following needs by 2025:
• Expand hiking trails system
• New community swimming pool/aquatic center
• New performing Arts Center
• Additional athletic fields
• New community center/community gathering space
• Indoor gymnasium space for all ages
• New dog park
• New outdoor skate park
• Playground upgrades
• Improvements and upgrades to existing parks
Since 2009, the City has expanded the trail system in Eaton and Big Canyon parks, added night lighting to existing athletic fields to increase availability, opened a new dog park in an existing park and made upgrades to existing playgrounds and improvements to the following parks: Burton, Chilton, Crestview, Highlands, Laureola parks.

The implementation strategy prioritizes and schedules park system improvements, and discusses funding for capital improvements, ongoing operation costs and maintenance. The following service standards are discussed in the Plan:
• Parks Provision Standard. Provide 2.5 acres of developed/active parks for every 1,000 residents in San Carlos. This service standard is stated as P1.1 of the Parks and Recreation Element of the General Plan.
• Trails Provision Standard. Provide 1-mile of hiking trail per 1,000 residents. • Walkability Policy. Locate a park or recreational facility within ½-mile of every resident.

Policy PR-1.2 of the Parks and Recreation Element reaffirms this goal.

City of San Carlos General Plan
The 2009 General Plan includes the following applicable policies:

School Services
Policy CSS-7.1: Provide efficient and timely processing of development review and building permit applications, while maintaining quality standards in accordance with City Ordinances.

Look for solutions to problems, be responsive to community concerns, promote positive

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communications at all levels of review and provide analysis and advice to decisionmakers to help them make informed decisions. Encourage early public input.

Policy CSS-7.2: Establish and regularly monitor levels of service of San Carlos’ public facilities and services.

Policy CSS-7.4: Work with all special districts, including the school districts, to ensure that development within the city is coordinated with provision of services.

Policy CSS-7.5: Maintain neighborhood schools wherever possible. Evaluate City potential to acquire any surplus school sites. If redeveloped, sites shall be used for purposes which are compatible with the surrounding neighborhood and consistent with the General Plan Land Use Map and shall strive to retain school recreation facilities for neighborhood use.

Policy CSS-7.8: Approve rezoning and development permits only when adequate services are available, or when a program to provide services has been approved by the applicable district and the City.

Policy CSS-7.9: Ensure that adequate public services and facilities are planned and constructed to accommodate the population of the city.

Policy CSS-8.1: Support schools and educational institutions as a key component of San Carlos’ identity.

Policy CSS-8.2: Support the availability of all types of educational opportunities, both formal and informal, for residents of all ages and abilities.

Policy CSS-8.4: Evaluate through the California Environmental Quality Act (CEQA) process how new development impacts schools, as the quality of San Carlos schools is a primary asset of the city.

Policy CSS-8.5: Participate in the long-range planning activities with San Carlos Unified School District and Sequoia Union High School District.

Library Services
Policy CSS-7.2: Establish and regularly monitor levels of service of San Carlos’ public facilities and services.

Policy CSS-7.6: Maintain existing library facilities as an important activity center within the community.

Policy CSS-8.3: Ensure that all residents have access to library services including access to computers and other technology.

Parks and Recreation Facilities

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Policy LU-1.9: To the extent possible, retain the channels, floodplains, riparian corridors (including suitable setbacks from top of bank) and closely associated upland areas of Cordilleras, Brittan and Pulgas Creeks and their tributaries as significant open space areas.

These areas should be maintained in their natural state to function as appropriate open space areas, greenbelt and to support a riparian habitat.

Policy LU-1.11: Preserve existing open space by supporting urban infill.

Policy LU-1.12: Promote the development of publicly accessible urban trails throughout the city to provide access to the natural environment and facilitate non-motorized transportation options.

Policy LU-2.15: Provide for and encourage the development of parks and public gathering places in and near Downtown.

Policy LU-5.11: Continue to require developers to pay their fair share of the capital cost of public facilities through appropriate development impact and utility connection fees.

Policy LU-8.7: Require new residential development to provide outdoor areas and landscaping or native vegetation, or tree canopy to enhance the surroundings.

Policy LU-9.7: Encourage the development of community gardens to provide opportunity for interactions and increase residents’ access to healthy foods.

Policy LU-9.8: Encourage developers of new or expanded multi-family residential projects to include gardening spaces for residents of the development as part of the landscaping requirement.

Policy LU-9.16: Require a contribution of parkland and/or fees in-lieu of land dedication as a condition of approval of all new residential subdivisions.

Policy LU-9.18: Continue the City’s program of joint use of school recreation facilities as a means of providing adequate recreation space for San Carlos citizens.

Policy LU-9.19: As lands are subdivided, encourage dedication of trail and path easements where appropriate to expand the City and County’s trail and path system.

Policy CSH-7.7: Public trails should be located and designed so that they serve the needs of the public while minimizing private property impacts.

Policy CSH-7.8: The local public path and trail system should be linked with existing private and regional systems and the road system.

Policy EM-2.7: Retain Pulgas, Brittan, Cordilleras and Belmont Creek channels and their 100- year floodplains wherever possible as natural open space areas. These areas are to function as storm drainage facilities and as open space greenbelts to support natural habitat.

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Policy EM-4.1: Retain existing public open space as open space.

Policy EM-4.2: Support an open space system that is diverse in uses and opportunities and includes natural function/wildlife habitat as well as passive and appropriate active recreation.

Policy EM-4.3: Focus open space acquisition efforts on the most environmentally sensitive areas.

Policy EM-4.4: Coordinate with Midpeninsula Regional Open Space District and other agencies on planning and managing public open space, including management of the Pulgas Ridge Open Space Preserve for public open space use.

Policy EM-4.5: Support the efforts of non-profit organizations to expand and manage protected open space.

Policy EM-4.6: Establish public access to public open space lands appropriate to the character and conservation value of the open space.

Policy EM-4.7: Prohibit the sale of City-owned open space properties.

Policy PR-1.1: Actively pursue land acquisitions to provide additional recreational opportunities, especially in underserved areas, which will help the City achieve the goal of increased park land.

Policy PR-1.2: Maintain a balance of athletic fields, active parks and passive open space that supports a variety of recreational uses.

Policy PR-2.3: Continue to support implementation of trail connections as identified in the City’s Master Plan for Parks, Open Space, Buildings and other Recreation Facilities.

Policy PR-2.4: Continue to maintain City-owned open space trails and connections to regional trails.

Policy PR-2.5: Promote the development of publicly accessible urban trails throughout the city to provide access to the natural environment and facilitate non-motorized transportation options.

Policy PR-2.6: Complete the Bay Trail alignment in San Carlos.

Policy PR-2.7: Encourage new development to provide trails and trail connection easements or dedications where feasible and appropriate.

Policy PR-2.10: Improve the availability and quality of athletic fields in San Carlos.

Policy PR-3.5: Ensure that parks facilities and usage will only be expanded with a commensurate expansion in maintenance resources, including future staff and equipment.

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Policy PR-3.6: Partner with adjacent agencies including San Mateo County, Belmont Parks and Recreation, San Francisco Public Utilities Commission and the Midpeninsula Regional Open Space District to provide expanded parks and open space amenities for San Carlos residents.

4.13.3 Thresholds of Significance
The project would have a significant impact with regard to parks and recreation if it would:

A. Results in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the following public services:

1. Fire protection;

2. Police protection;

3. Schools;

4. Libraries; or

5. Parks and Recreation Facilities.

B. Result in increased use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

C. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

4.13.4 Impacts and Mitigation Measures
This section describes potential impacts related to public services and recreational facilities that would result from implementation of the project. The section begins with the thresholds of significance, followed by the impact analysis and identification of mitigation measures, if required.

Impact PS-1: The project would not result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the following public services. (Less Than Significant Impact)

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Fire Protection Services
Implementation of the Focused GPU is estimated to result in an increase of approximately 3,576 dwelling units within the project area. This increase in development is likely to result in an increase in demand for fire protection services.

The proposed Environmental Safety and Community Services Element Update includes the following policies and actions related to fire protection services:

Policy ESPS 3.1: Promote and improve, as necessary, interjurisdictional consultation and communication regarding disaster or emergency plans of San Carlos with adjacent agencies including but not limited to San Mateo County, Redwood City, Belmont, and CAL FIRE.

Action ESPS 3.1 - Maintain participation in the Joint Powers Authority Agreement with all fire departments in San Mateo County to ensure required response times for initial emergency deployment personnel and equipment.

Action ESPS 3.2 - Preserve the local government agreement with California Department of Forestry and Fire Protection (CAL FIRE) for responses in the Mutual Threat Zone (MTZ) within the Wildland Urban Interface (WUI) areas of the city. Continue to provide equipment and personnel under the mutual aid agreement, with the State of California Office of Emergency Service (OES) Region II. This continued “reverse support” enables the City of San Carlos to receive “no cost” statewide mutual aid in the event of a declared large-scale emergency.

Action ESPS 3.3 - Collaborate with the regional fire agencies on strategies available to maintain defensible space, diverse plant composition (e.g., less combustible native plants), undertake appropriate thinning of vegetation, and maintain fuel breaks without permanently damaging native habitat.

Policy ESPS-3.2 - Conduct annual training for fire, emergency medical, and police staff including cross training with adjacent automatic or mutual aid emergency response departments. Regularly maintain, test, and update training and equipment to meet current standards.

Policy ESPS-3.3 - Ensure adequate Fire Department resources (fire stations, personnel, and equipment) to meet response time standards, keep pace with growth, and provide a high level of service to the community.

Action ESPS-3.4 - Continue to work with the Redwood City Fire Department to ensure that fire services are maintained at adequate levels. With subsequent Safety Element updates, assess and project future emergency service needs. Continue to monitor service area to ensure that all San Carlos areas have fire service. Monitor the City of San Carlos’ fire protection rating and work with the Redwood City and San Mateo County Fire Departments to correct deficiencies and to ensure ongoing training, including cross training is conducted.

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Action ESPS-3.5 - Train and educate public volunteers in basic fire safety response.

Policy ESPS-7.9: Evaluate safety service limitations on an annual basis to provide for adequate levels of service.

Policy ESPS-7.10: Identify potential emergency routes and suggest methods for operational needs for first responders.

Policy ESPS-7.11: Establish the capability to re-locate critical emergency response facilities such as fire, police, and essential services facilities, if needed, in areas that minimize their exposure to flooding, seismic effects, fire, or explosion.

Policy ESPS-8.5: Support emergency service providers and critical facilities' operations and adequate response times should hazard events increase in frequency and severity.

Policy ESPS-13.2: Establish and regularly monitor levels of service of San Carlos’ public facilities and services.

Policy ESPS-13.4: Work with all special districts, including the school districts, to ensure that development within the city is coordinated with provision of services.

Policy ESPS-13.8: Approve rezoning and development permits only when adequate services are available, or when a program to provide services has been approved by the applicable district and the City.

Policy ESPS-13.9: Ensure that adequate public services and facilities are planned and constructed to accommodate the population of the city.

Individual development projects are subject to standard pre-development review by several City departments, including the Fire Departments. This review process ensures that the necessary and appropriate ingress/egress points, fire protection systems such as alarms and automatic sprinklers, and minimum fire flow requirements are incorporated into all project plans.

Furthermore, the Environmental Safety and Community Services Element Update includes policies related to fire protection and emergency services. Several of these policies specifically address ensuring that there is adequate fire department resources to serve existing and proposed development, including evaluating safety service limits annually (Policy ESPS-7.9), monitoring levels of service for public facilities and services (Policy ESPS-13.2), and approving rezoning and development permits only if adequate services are available to serve the City (Policy ESPS-13.8 and ESPS-13.9)
Future development projects associated with implementation of the Housing Element Update would result in the incremental increase in need for fire protection services as the City’s population grows and the number of residential units increases. While the Fire Department does not have an adopted service standard, it is currently preparing a Standards of Cover Study. It is anticipated that

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the Fire Department would need an additional ladder truck and additional personnel staffing located at San Carlos Station 13 to address the increase in demand.2 If a new or expanded fire department facilities were to be required as a result of population growth, this new facility would need to comply with existing environmental regulations, which would include a development review process and environmental review pursuant to CEQA.

In compliance with Policy ESPS-7.9 (evaluate safety service limitations on an annual basis to provide for adequate levels of service), the City Council would annually consider the need for increases in fire equipment, facilities, or personnel. As part of this review, the City Council would receive for consideration the evaluation and recommendation of the Fire Department for providing additional equipment, facilities, or personnel, including the timing for providing such equipment, facilities, or personnel. Criteria for determining need would include, but not be limited to, existing and projected increases of fire station response times for new development within the City, emergency calls, ratio of fire department staff to population, or the capacity of existing fire stations to house additional staff and equipment needed to serve existing and projected population. If the City Council finds that additional equipment, facilities or personnel are needed, the City would coordinate with the fire department to provide for such facilities, equipment, or personnel in a manner timely to ensure existing service levels, including response times, are not impacted.

All projects that are subject to CEQA review would be evaluated to determine whether they can be provided adequate fire prevention and emergency medical services, including adequate response times. In the event that it is determined that adequate services cannot be provided, project specific mitigation may be provided to offset identified service deficiencies.

Compliance with the policies described above would ensure that adequate Fire Department equipment and staffing would be available to serve future development associated with implementation of the Housing Element Update and would ensure this potential impact would be less than significant.

Police Services
Implementation of the Focused GPU is estimated to result in an increase of approximately 3,595 dwelling units within the project area. This increase in development is likely to result in an increase in demand for policing services.

The Environmental Safety and Community Services Element Update includes the following goals and policies relate to police protection services:
2 Redwood City and San Carlos Fire Departments, 2022. Email communication from Gareth Harris, Fire Marshal, August 16.

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Policy ESPS 3.1: Promote and improve, as necessary, interjurisdictional consultation and communication regarding disaster or emergency plans of San Carlos with adjacent agencies including but not limited to San Mateo County, Redwood City, Belmont, and CAL FIRE.

Policy ESPS-7.9: Evaluate safety service limitations on an annual basis to provide for adequate levels of service.

Policy ESPS-7.10: Identify potential emergency routes and suggest methods for operational needs for first responders.

Policy ESPS-7.11: Establish the capability to re-locate critical emergency response facilities such as fire, police, and essential services facilities, if needed, in areas that minimize their exposure to flooding, seismic effects, fire, or explosion.

Policy ESPS-8.5: Support emergency service providers and critical facilities' operations and adequate response times should hazard events increase in frequency and severity.

Policy ESPS-13.2: Establish and regularly monitor levels of service of San Carlos’ public facilities and services.

Policy ESPS-13.4: Work with all special districts, including the school districts, to ensure that development within the city is coordinated with provision of services.

Policy ESPS-13.8: Approve rezoning and development permits only when adequate services are available, or when a program to provide services has been approved by the applicable district and the City.

Policy ESPS-13.9: Ensure that adequate public services and facilities are planned and constructed to accommodate the population of the city.

Several of these policies specifically address ensuring that there is adequate law enforcement resources to serve existing and proposed development, including evaluating safety service limits annually (Policy ESPS-7.9), monitoring levels of service for public facilities and services (Policy ESPS-13.2), and approving rezoning and development permits only if adequate services are available to serve the city (Policy ESPS-13.8 and ESPS-13.9).

Future development projects associated with implementation of the Housing Element Update would result in the incremental increase in need for law enforcement services as the City’s population grows and the number of residential units increases. The Department is anticipating upgrading headquarter office space within the next few years. The Department is currently meeting service standards, but additional development could result in an incremental increase in police service demand and increased response time. It is also possible that increased development would

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result in an increase in traffic; additional police cars would potentially be needed to effectively enforce traffic laws.3
Compliance by the City with the proposed Policies ESPS-13.8 and ESPS-13.9, which require the availability of adequate public services before approval of new development, would ensure that new or expanded police facilities would be constructed to meet the needs of the new population growth. In addition, if a new or expanded facility were to be required as a result of population growth, this new facility would need to comply with existing environmental regulations, which would include a development review process and environmental review pursuant to CEQA. As such, the Focused GPU would not result in substantial adverse physical impacts associated with the provision of new or physically altered facilities; this impact would be less than significant.

School Services
New housing constructed as part of implementation of the Focused GPU would likely result in an increase of students within the project area. Using an elementary/middle (K-8) and high student generation rate of 0.2 students per unit4
, construction of 3,595 residential units would result in 719 elementary/middle school students and 719 high school students. It should be noted that several smaller unit types, including Accessory Dwelling Units (ADUs) and studio or one-bedroom apartments, are unlikely to generate any students given their anticipated small size. However, in order to be conservative, it is estimated that every type of unit, regardless of size, would generate

0.2 elementary/middle school students and 0.2 high school students. The following discussion describes services within each school district.

Belmont-Redwood Shores School District. It is anticipated implementation of the Housing Element Update would result in approximately 79 new students within the Belmont-Redwood Shore School District. As shown in Table 4.13-2, over the last five years (2017-2022), there has been a decline in enrollment of 357 students. In 2021-2022, the District had 3,967 students and a District-wide facility capacity of 4,450 students. In communication with the District, the Superintendent noted that the additional students associated with implementation of the Housing Element Update could likely be accommodated within existing facilities; however, there are several housing development proposals within Belmont that would likely affect enrollment. Additionally, the District is expected 3 San Mateo County Sheriff Department. 2022. Email communication from Kristina Bell, Police Chief for the City of San Carlos. Sept 19.
4 A 0.2 student generation rate was included in the Developer Fee Studies for both the San Carlos School District and the Sequoia Union High School District. While the San Carlos School District provided a different rate (0.28) for single-family homes, as the majority of units would be anticipated to be multi-family units, a student generation rate of 0.2 was used for all elementary/middle school student generation within the project area.

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to expand Transitional Kindergarten (TK) facilities in the future. The District is undertaking a demographic study that will be completed by the end of 2022. 5 San Carlos School District. It is anticipated implementation of the Housing Element Update would result in approximately 632 new students within the San Carlos School District. As shown in Table

4.13-2, over the last five years (2017-2022), there has been a decline in District enrollment of 546 students. There is currently a District-wide facility capacity of 3,162 students.

Student enrollment projection information6 provided by the District indicates a projected decline in enrollment through 2031, with projections identifying a 2022 student population of 2,526 students and a 2031 population of 2,066 (a decline in enrollment of 460 students between 2022 and 2031). However, communication with the District’s Director of Enterprise & Community Relations noted that the current enrollment is 214 students above the projected amount for this year. Additionally, the District will be implementing a Transitional Kindergarten (TK) program in the coming years. The District noted that it would not be able to accommodate an additional 632 new students associated with the project without building additional classroom facilities.7

Redwood City School District. It is anticipated implementation of the Housing Element Update would result in approximately ten new students located within the Redwood City School District.

As shown in Table 4.13-2, over the last five years (2017-2022), there has been a 1,134 student decline in District enrollment. As the anticipated number of new students is limited, and implementation of the Housing Element Update would occur over eight years, it was assumed that the District would be able to accommodate the additional ten students.

Sequoia Union High School District. It is anticipated implementation of the Housing Element Update would result in approximately 719 high school students within the Sequoia Union High School District. Unfortunately, the District did not provide a response to the City’s consultant’s request for information regarding student enrollment, capacity, or projections. Given the number of anticipated students, it is assumed that the District would require additional facilities to accommodate new high school students associated with the Project.

Summary. While Table 4.13-2 shows that elementary school districts within the project area have experienced declining enrollment over the last five years, and that the high school district enrollment has remained stable, it is likely that residential growth associated with implementation of the Focused GPU could exceed the capacity of existing school facilities resulting in the need for additional school facilities.
5 Belmont-Redwood Shores School District, 2022. Email communication from Dan Deguara, Superintendent, August

15. 6 Decision Institute, 2022. Projections, San Carlos School District, 2022. 7 San Carlos School District, 2022. Email communication from Amber Farinha, MA, MSW Director of Enterprise & Community Relations, October 7, 2022.

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It should be noted that while the City has identified the overall level of housing development associated with implementation of the Housing Element Update (3,576 residential units), there is less certainty about the type of units that may be constructed. Many unit types (such as Accessory Dwelling Units [ADUs], studio units, 1-bedroom apartment units, or units marketed to seniors) are unlikely to generate new students given the size or type of unit. Additionally, the Housing Element Update is an eight year plan and the City cannot identify the exact timing that development may occur as the majority of development would be undertaken by private entities. Finally, as many school districts in California have experienced a general decline in enrollment over the last five years, a trend that is anticipated to continue, available capacity within a school district may change year-to-year.

Payment of school impact fees, as allowed by Government Code 65996, are meant to offset increased student enrollment and has been deemed by the State legislature (per Government Code Section 65995(h)) to constitute full and complete mitigation of impacts of a development project on the provision of adequate school facilities. Table 4.13-4 shows current developer fees by school district. Any specific school facility developments would be subject to environmental review on a project-by-project basis.

Table 4.13-4: Developer Fee by School District
Elementary School District
San Carlos School
District
Belmont-Redwood
Shores School
District
Redwood City
School District
Residential Development Fee $4.79 per square foot $3.79 per square foot $3.79 per square foot Percent of fee total allocated to
Sequoia Union High School District 40 percent of fee 40 percent of fee 40 percent of fee Sources: Jack Schreder & Associates, Inc., 2022. Level I Development Fee Study for San Carlos Elementary School District, April 19; Belmont-Redwood Shores School District, 2022. Email communication from Dan Deguara, Superintendent, August 15; Redwood City School District, 2021. Developer Fee Report, Fiscal Year Ending June 30, 2021.

The Environmental Safety and Community Services Element Update includes several policies related to public school services. Policy ESPS-13.4 notes working with the school districts to ensure that development within the City is coordinated with the provision of services. Policy ESPS-14.4 assures that new development does not adversely impact the quality of San Carlos schools by requiring that new development be evaluated through the California Environmental Quality Act. Finally, Policy ESPS-14.5 calls for the participation of the City in the long-range planning activities with the San Carlos Unified School District and the Sequoia Union High School District.

Through the payment of associated development fees, compliance with applicable State and local regulations, adherence to policies included in the Environmental Safety and Community Services Element Update, implementation of the Focused GPU would have a less-than-significant impact on school facilities.

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Library Services
Implementation of the Focused GPU could result in an increase in population within the City, which could result in increased demand for library services. Any remodeled or new library facility would be subject to environmental review under CEQA. Environmental review would identify site-specific conditions and physical changes resulting from library expansion or construction.

New residential development within the project area would result in an increase in the tax base of the city and could be used to offset the incremental demand for library services. Implementation of the Focused GPU would result in a less than significant impact related to library services.

Parks and Recreational Facilities
New development anticipated under the Housing Element update has the potential to add 9,240 new residents which would increase the demand for park and recreational facilities in the project area. To meet the City’s parkland ratio of 2.5 acres per every 1,000 residents during the planning period of the proposed Housing Element (2023-2031), the City would need to add 21.6 acres of new parkland in addition to the existing total of developed parkland in the City.

Existing goals, policies and actions in the 2030 General Plan help the City meet the parkland ratio goal and would make sure that existing facilities are not negatively impacted by future growth.

Goal PR-1 of the Parks and Recreation Element calls for an increase in the amount of City-owned park and open space land. Policy PR-1.1 of that element requires the provision of a minimum of

2.5 acres of traditional parkland for every 1,000 residents. Policy PR-1.2 requires that a park facility be required within ¼- to ½-mile of every resident. Policies PR-1.3 and PR-1.4 call for the maintenance of athletic fields and active parks and passive open space, as well as the acquisition of land to provide additional recreational opportunities. Actions PR-1.1 through PR-1.9 offer strategies to acquire sites for the development of new parks through a variety of funding methods.

For example, Action PR-1.9 considers a policy requiring the maximum allowable park land dedication fee.

The specific environmental impact of constructing new individual park or recreation facilities would be evaluated at the time that new development projects potentially resulting in the demand for such facilities are proposed. As future new development proposals are evaluated, specific park and recreation facility requirements will be identified through the environmental review process and appropriate mitigation measures will be implemented that could include the dedication of parkland, construction of new facilities or rehabilitation of existing facilities, and/or the payment of in-lieu fees. Therefore, implementation of the proposed project would result in a less-thansignificant impact on parks and recreational facilities.

4.13.5 References
Belmont-Redwood Shores School District. 2022. Email communication from Dan Deguara, Superintendent, August 15.

California Department of Education. DataQuest Home, Enrollment Report, 2020-2021.

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San Carlos Focused General Plan Update Draft EIR 4.13-29 October 2022
California Department of Fish and Wildlife. 2022. Bair Island Ecological Reserve. Accessed on August 8, 2022 at https://wildlife.ca.gov/Lands/Places-to-Visit/Bair-Island-ER City of San Carlos. 2020. Development Impact Fees and In-Lieu Fees – Annual Report Fiscal Year Ended June 30, 2020. Accessed August 8, 2022, at
https://www.cityofsancarlos.org/Home/ShowDocument?id=6391 City of San Carlos. 2021. Existing Conditions Atlas, San Carlos 2040. January 6.

County of San Mateo. 2022. Edgewood Park & Natural Preserve, County of San Mateo, CA.

Accessed on August 8, 2022 at https://www.smcgov.org/parks/edgewood-park-naturalpreserve Decision Institute, 2022. Projections, San Carlos School District, 2022.

Design, Community & Environment. 2009. San Carlos 2030 General Plan EIR. June 25.

Harris Design Landscape Architecture. 2008. City of San Carlos, Parks, Open Space, Buildings and Other Recreational Facilities, Master Plan 2009 – 2029, August 11.

Jack Schreder & Associates, Inc. 2018. Level I Developer Fee Study for Sequoia Union High School District, March 1.

Jack Schreder & Associates, Inc. 2022. Level I Development Fee Study for San Carlos Elementary School District, April 19.

Midpeninsula Regional Open Space District. 2022. Midpeninsula Regional Open Space, from 50 to Forever. Accessed on August 8, 2022, at https://www.openspace.org/ Redwood City Fire Department. 2022. Redwood City Fire Department Website:
https://www.redwoodcity.org/departments/fire-department (accessed August 16, 2022).

Redwood City and San Carlos Fire Departments. 2022. Email communication from Gareth Harris, Fire Marshal, August 16.

Redwood City School District. 2021. Developer Fee Report, Fiscal Year Ending June 30, 2021.

San Carlos School District, 2022. Email communication from Amber Farinha, MA, MSW Director of Enterprise & Community Relations, October 7, 2022.

San Mateo County Sheriff. 2022. San Mateo County Sheriff Website:
https://www.smcsheriff.com/ (accessed August 16, 2022).

San Mateo County Sheriff Department. 2022. Email communication from Kristina Bell, Police Chief for the City of San Carlos.

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San Mateo County Libraries, Open for Exploration, Annual Report 2020-2021.

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San Carlos Focused General Plan Update Draft EIR 4.14-1 October 2022

4.14 TRANSPORTATION
This section describes the characteristics of the transportation network in the project area and potential transportation impacts of the Housing Element, including multimodal circulation and vehicle miles traveled (VMT). Measures to mitigate are recommended as necessary to avoid or minimize potentially significant transportation impacts. The analysis focuses on the impacts of the Housing Element Update and addresses other project components when applicable.

4.14.1 Environmental Setting
Project Location
The City of San Carlos is located in San Mateo County, roughly midway between the cities of San Francisco and San Jose. Most of the City is located west of US 101 and east of Interstate 280 (I280). In addition to US 101, major north-south travel routes within San Carlos include El Camino Real, Old County Road, Industrial Road, and Alameda de las Pulgas. San Carlos Avenue and Brittan Avenue serve as major east-west routes connecting to El Camino Real, with access to US 101 provided by Holly Street and Brittan Avenue. The street network is shown in Figure 4.14-1.

Travel Characteristics
Residents of San Carlos rely primarily on personal motor vehicles for commuting. As reported in the 2019 American Community Survey (which reflects commuting prior to the COVID-19 pandemic), 79.7 percent of working San Carlos residents commuted by car, truck, or van, with

74.8 percent driving alone. Public transportation was used as the primary commute mode by 7.7 percent of workers living in San Carlos, including 4.5 percent traveling by commuter rail.

Approximately 3.7 percent of workers reported walking or biking to work, while 8.1 percent worked from home.

This commute pattern is similar to San Mateo County as a whole, although the countywide use of public transportation is higher. Countywide, 75.9 percent of County residents commute by car, truck, or van; 12 percent public transportation; 3.8 percent walking and biking; 6.1 percent work from home. The higher countywide public transportation rate appears to be due to the availability of BART service in the northern part of the county, as 5.2 percent of workers reported commuting by subway or elevated rail.

In terms of commute distance, 87.2 percent of employed San Carlos residents travel less than 25 miles to work, with 46.2 percent having commutes of less than 10 miles and 41.0 percent traveling 10 to 24 miles (U.S. Census Bureau 2019).

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Focused General Plan Update
Figure 4.14-1 Street Network
D Citylimit
11111 Sphere of Influence Areas
-■■■ U.S. Highway
• • I nte rstate
State Highway
Arterial
Collector
Local Streets
0th er Street
Belmont
Bair Island
~ NOIIITH Q 0.25 0.5 Miles

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Existing Circulation Network
Study Area Roadways
The San Carlos General Plan designates four classifications for the City’s roadway network. These classifications are hierarchical, based on the volume and type of traffic associated with each street, as follows.

A. Freeways and State Highways: largely serve through traffic and link the City to the regional transportation network.

B. Arterial Streets: the primary streets within the City, connecting major destinations to one another.

C. Collector Streets: provide connectivity between arterial streets and act as feeders for traffic from less densely developed areas.

D. Local Streets: low-volume, low-speed streets that primarily provide direct access to the abutting properties and typically offer limited connectivity to discourage through trips. They may connect to one or more collector streets.

Freeways and State Highways
US Route 101
US 101 is a north-south highway that runs between southern California and the state of Washington. Locally it is configured as an eight-lane, grade-separated freeway and is a major corridor serving communities on the San Francisco Peninsula. In San Carlos, a full interchange along US 101 exists at Holly Street, and a partial interchange with southbound US 101 is provided at Brittan Avenue. There is also a full interchange at Ralston Avenue in Belmont, while Harbor Boulevard and Whipple Avenue provide access to and from southbound US 101 in Belmont and Redwood City, respectively.

Interstate 280
A major north-south route along the Peninsula, Interstate 280 (I-280) is a freeway connecting San Jose with San Francisco. In the study area it is located just west of the San Carlos city limits.

Ralston Avenue in Belmont provides access to I-280 via State Route (SR) 92, as the SR 92/I-280 interchange is located approximately one-half of a mile west of the SR 92/Ralston Avenue interchange. Along the segment near San Carlos, I-280 includes eight travel lanes.

El Camino Real
El Camino Real, also designated as SR 82, is a regional route that extends between I-880 in San Jose and I-280 in San Francisco. El Camino Real functions as a state highway and commercial corridor through communities along the San Francisco Peninsula. Within San Carlos, the roadway

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has two through lanes in each direction and a posted speed limit of 35 miles per hour (mph). The San Carlos Caltrain station is located on El Camino Real.

Arterials
Alameda de las Pulgas
Alameda de las Pulgas runs north-south through the central part of San Carlos, connecting with Redwood City to the south and Belmont to the north via San Carlos Avenue. Within the City limits there is one travel lane in each direction, the speed limit is 30 mph, and land uses are primarily residential.

Brittan Avenue
Brittan Avenue runs east-west through San Carlos and is considered a primary entry point to the City. East of El Camino Real, land uses are primarily commercial and there are two travel lanes in each direction with a speed limit of 30 mph. West of El Camino Real there is one travel lane in each direction and land uses are primarily residential.

Crestview Drive
Crestview Drive runs along the major north-south ridge in the western portion of San Carlos. The route extends from the Belmont city limit to Edgewood Road at a lower elevation. The speed limit is 30 mph, and there are one to two travel lanes in each direction. Land uses are primarily residential along this roadway and it provides access to several parks and open space areas within and outside the City limits.

Holly Street
Holly Street runs east-west through the downtown area and provides access to US 101 and the Redwood Shores community to the east. East of El Camino Real there are two travel lanes in each direction with a speed limit of 25 mph. West of El Camino Real there is one travel lane in each direction. Land uses are a mix of commercial and residential along this roadway.

Howard Avenue
Howard Avenue between Laurel Street and Industrial Road functions as an arterial with two lanes in each direction and a speed limit of 30 mph. Land uses are primarily commercial in this area.

Industrial Road
Industrial Road runs north-south through the eastern portion of City. There are two travel lanes in each direction with a speed limit of 35 mph. Offices and commercial and industrial land uses exist along this roadway.

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Laurel Street
Laurel Street is a north-south arterial street serving downtown San Carlos with one travel lane in each direction and a speed limit of 25 mph.

Old County Road
Old County Road runs north-south along the east side of the Caltrain tracks and parallel to El Camino Real. With one travel lane in each direction and speed limit of 30 mph, the roadway primarily serves industrial and commercial uses.

San Carlos Avenue
San Carlos Avenue traverses east to northwest and connects to El Camino Real and Alameda de las Pulgas. East of Prospect Street there are two travel lanes in each direction and land uses are a mix of commercial, residential, and institutional. West of Prospect Street there is one travel lane in each direction, and land uses are residential. The speed limit is 30 mph along most of the roadway. San Carlos Avenue provides pedestrian access to the Caltrain station.

Shoreway Road
Shoreway Road runs north-south adjacent to US 101 and mostly serves large commercial and office land uses with one travel lane in each direction and a speed limit of 35 mph.

Existing Pedestrian and Bicycle Facilities
This section describes the existing pedestrian and bicycle facilities in the City of San Carlos.

Pedestrian Facilities
The City of San Carlos has pedestrian facilities that include sidewalks, pathways, curb ramps, crosswalks, curb extensions, and amenities such as pedestrian scale lighting, benches, transit shelters, and street trees. While the sidewalk network is generally complete in the eastern and southern areas of the city, in the hilly residential areas there are numerous locations where sidewalks are substandard, not present, or have gaps.

Bicycle Facilities
Bicycle facilities in San Carlos include Class I pathways, Class II bike lanes, and Class III bike routes. There are continuous bike lanes along Alameda de las Pulgas and Industrial Road, as well as some segments of San Carlos Avenue, Old County Road, and Brittan Avenue. Bicycle routes are also designated along segments of San Carlos Avenue, Old County Road, Brittan Avenue, Cedar Street, and Arroyo Avenue.

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Existing Transit Service
The primary public transit providers in San Carlos are SamTrans and Caltrain. In addition to services they directly provide, they offer connections to regional transit services and local services in other nearby jurisdictions.

SamTrans
SamTrans provides fixed-route bus service throughout San Mateo County, also providing connections to San Francisco and Palo Alto. The following routes, shown in Figure 4.14-2, serve the City of San Carlos:
• Route ECR provides service along El Camino Real from the Palo Alto Transit Center to the Daly City BART Station. On weekdays, the bus runs every 20 minutes from approximately 4:00 a.m. until 2:00 a.m. On weekends, it runs every 30 minutes from 4:45 a.m. until 2:00 a.m.
• Route 397 runs between Downtown San Francisco and the Palo Alto Transit Center. It operates daily from approximately 1:00 a.m. until 6:30 a.m. with one-hour headways, with no mid-day or evening service. This route serves the San Francisco International Airport, the Millbrae Transit Center, and the Redwood City Transit Center. • Route 398 runs between the San Bruno BART Station and the Redwood City Transit Center, also serving the San Francisco International Airport. It runs hourly from 5:00 a.m. until 11:30 p.m. on weekdays and 6:00 a.m. to 11:30 p.m. on weekends. • Route 260 is a weekday route that connects the San Carlos Caltrain Station to the College of San Mateo. It operates every 60 minutes from 6:00 a.m. until 6:30 p.m. This route serves the College of San Mateo, Crystal Springs Shopping Center, and the County Youth Center. • Route 295 is a weekday route that runs between the San Mateo Caltrain Station and the Redwood City Caltrain Station, also serving the station in San Carlos. It operates every two hours from 6:30 a.m. until 7:00 p.m.

Caltrain
Caltrain is the commuter rail line serving the San Francisco Peninsula, connecting San Carlos with San Francisco to the north and San Jose and Gilroy to the south. On weekdays, there are 31 trains servicing the San Carlos Station in the northbound and southbound directions. On weekends, there are 16 trains that stop at the station in each direction. The San Carlos Caltrain Station is located on El Camino Real near the intersection with San Carlos Avenue. The station includes paid vehicle parking as well as racks and lockers for bicycle parking; lockers must be reserved.

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Focused General Plan Update
Figure 4.14-2 SamTrans Bus Routes
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Bay Area Rapid Transit (BART)
BART provides regional heavy-rail rapid transit service, with stations in Alameda, Contra Costa, San Francisco, San Mateo, and Santa Clara Counties. Although BART does not provide service to San Carlos, connections to and from San Carlos are available to the Millbrae and San Francisco International Airport stations via Caltrain and SamTrans bus service.

San Francisco Bay Ferry
The Water Emergency Transportation Authority (WETA) operates the regional San Francisco Bay Ferry service. The only ferry terminal on the Peninsula is in the City of South San Francisco, from where weekday ferry service is available to the Cities of Alameda and Oakland. The South San Francisco ferry terminal includes parking; it is not directly served by transit.

Paratransit
Paratransit is an on-demand curb-to-curb service for persons with disabilities who cannot independently use regular fixed-route transit services. The San Mateo Transit District’s RediWheels service provides paratransit in San Carlos and other San Mateo County communities. RediWheels operates daily service between the hours of 5:30 a.m. and midnight. Riders must have their eligibility certified by SamTrans and reservations can be made in advance.

Private Commuter Shuttles
Numerous employers provide commuter shuttle service for their employees, with such services implemented by individual employers or through partnerships between multiple businesses. Such services typically provide transportation between employment sites and pick-up points in residential areas or at major transit stations; one such example in San Carlos is the shuttle provided by Electronic Arts to connect the Caltrain station to its Redwood City campus, although the shuttle service was suspended as of September 2022.

On-Demand Transportation Services
On-demand private taxi services are available in San Carlos 24 hours a day. Taxis can be used for trips within San Carlos or for trips between San Carlos and locations in other jurisdictions.

Transportation network companies (TNCs) offer similar services in San Carlos and throughout the Bay Area. TNCs provide prearranged transportation services for compensation using an onlineenabled application or platform (such as smart phone apps) to connect drivers using their personal vehicles with passengers.

Existing Truck Routes
The City of San Carlos Municipal Code Section 10.48 designates truck routes for vehicles exceeding a maximum gross weight, including load, of three tons. Segments of Howard Avenue

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and Brittan Avenue between El Camino Real and Industrial Road are designated as truck routes, along with US 101, El Camino Real, and Industrial Road.

Major Planned Transportation Projects
Plan Bay Area 2050 includes several projects that would impact transportation to and from San Carlos. The emphasis of these investments is more efficient use of the regional highway and transit infrastructure through capital and operational enhancements. Projects that would most directly affect San Carlos include the following:
• Enhancements at the US 101/Holly Street interchange.
• Bus rapid transit (BRT) improvements to existing bus service along El Camino Real connecting Daly City BART with the Palo Alto Caltrain Station, including increased frequency, dedicated lanes along portions of the route, and addition of transit signal priority infrastructure.
• Increased Caltrain frequency between San Francisco and San Jose. • New express bus service along US 101 and I-280 (on express lanes where available) between downtown and western San Francisco, including addition of park-and-ride facilities, ramp improvements and bus stop improvements. • New express bus service along US 101, SR 85 and I-280 (on express lanes where available) between San Francisco (Salesforce Transit Center) and San Jose (Diridon Station).

Improvements include high-frequency service and station area amenities such as upgraded local bus stops, taxi/TNC loading zones, and improved bicycle/pedestrian infrastructure.

4.14.2 Regulatory Setting
Local, regional, State, and Federal policies regulate many aspects of the City’s transportation system, including planning and programming; design; operations; and funding. While the City of San Carlos has primary responsibility for the maintenance and operation of local transportation facilities, there is ongoing coordination between San Carlos staff and regional, state, and federal agencies to plan, manage, and enhance the City’s transportation assets; these entities include San Mateo County, San Mateo County Transportation Authority (SMCTA), City/County Association of Governments of San Mateo County (C/CAG), Metropolitan Transportation Commission (MTC), California Department of Transportation (Caltrans), regional transit providers and Federal Highway Administration.

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State
California Department of Transportation (Caltrans)
Caltrans is the owner and operator of the state highway system, which includes US 101 and El Camino Real within San Carlos. In its Vehicle Miles Traveled-Focused Transportation Impact Study Guide (TISG), 2020, Caltrans developed an approach for evaluating the transportation impacts of land use projects and plans on state highway facilities; this document does not address the impacts of transportation projects. In accordance with current CEQA requirements, the TISG does not consider vehicle delay in its evaluation of transportation impacts, instead focusing on VMT. The purposes of the TISG include providing guidance to lead agencies regarding when they should analyze potential impacts to the state highway system; to aid Caltrans staff in reviewing projects; and to ensure consistency in the assessment of impacts and identification of non-capacity increasing mitigation measures.

California Senate Bill 743 (SB 743)
On September 27, 2013, SB 743 was signed into law, supporting previous climate-focused and transportation legislation, including the Sustainable Communities and Climate Protection Act of 2008 (SB 375), the California Global Warming Solutions Act of 2006 (AB 32), as well as the Complete Streets Act (AB 1358), which requires local governments to plan for a balanced, multimodal transportation network that meets the needs of all users.

In December 2018, the Governor’s Office of Planning and Research (OPR) issued a final advisory to guide lead agencies in implementing SB 743, Technical Advisory on Evaluating Transportation Impacts in CEQA. Key guidance includes:
• VMT is the most appropriate metric to evaluate a project’s transportation impact under CEQA.
• VMT for residential and office projects should generally be assessed using efficiency metrics, i.e., on a “per rate” basis.
• The OPR-recommended threshold of significance for residential projects is VMT per capita of fifteen percent below the city or regional average. Applying this threshold, a residential project expected to generate VMT per capita that is more than 85 percent of the regional VMT per capita could result in a significant impact. This threshold was developed to support statewide GHG emission reduction targets.
• Lead agencies have the discretion to set or apply their own significance thresholds in lieu of those recommended in the advisory, provided they are based on substantial evidence. • Cities and counties still have the ability to use metrics such as LOS for other plans, studies, or network monitoring. However, LOS and similar metrics cannot constitute the sole basis for determining CEQA impacts.

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Regional
Plan Bay Area 2050
Plan Bay Area 2050 is the nine-county San Francisco Bay Area’s long-range plan that addresses regional transportation, housing, economic development, and environmental resilience. The plan identifies funding priorities for a $1.4 trillion vision over a 30-year period, directed toward addressing the plan’s 35 strategies. Plan Bay Area 2050 was adopted by the Metropolitan Transportation Commission and Association of Bay Area Governments in 2021.

Plan Bay Area 2050 includes the following transportation strategies:
• T1. Restore, operate and maintain the existing system. Commit to operate and maintain the Bay Area’s roads and transit infrastructure while reversing pandemic-related cuts to total transit service hours.
• T2. Support community-led transportation enhancements in Equity Priority Communities.

Provide direct funding to historically marginalized communities for locally identified transportation needs.
• T3. Enable a seamless mobility experience. Eliminate barriers to multi-operator transit trips by transfer hubs.
• T4. Reform regional transit fare policy. Streamline fare payment and replace existing operator-specific discounted fare programs with an integrated fare structure across all transit operators.
• T5. Implement per-mile tolling on congested freeways with transit alternatives. Apply a per-mile charge on auto travel on select congested freeway corridors where transit alternatives exist, with discounts for carpoolers, low-income residents, and off-peak travel; and reinvest excess revenues into transit alternatives in the corridor. • T6. Improve interchanges and address highway bottlenecks. Rebuild interchanges and widen key highway bottlenecks to achieve short- to medium-term congestion relief. • T7. Advance other regional programs and local priorities. Fund regional programs like motorist aid and 511 while supporting local transportation investments on arterials and local streets.
• T8. Build a Complete Streets network. Enhance streets to promote walking, biking and other micro-mobility through sidewalk improvements, car-free slow streets, and 10,000 miles of bike lanes or multi-use paths.
• T9. Advance regional Vision Zero policy through street design and reduced speeds. Reduce speed limits to between 20 and 35 miles per hour on local streets and 55 miles per hour on

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freeways, relying on design elements on local streets and automated speed enforcement on freeways.
• T10. Enhance local transit frequency, capacity and reliability. Improve the quality and availability of local bus and light rail service, with new bus rapid transit lines, South Bay light rail extensions, and frequency increases focused in lower-income communities. • T11. Expand and modernize the regional rail network. Better connect communities while increasing frequencies by advancing the Link21 new transbay rail crossing, BART to Silicon Valley Phase 2, Valley Link, Caltrain Downtown Rail Extension and Caltrain/High-Speed Rail grade separations, among other projects. • T12. Build an integrated regional express lanes and express bus network. Complete the buildout of the regional express lanes network to provide uncongested freeway lanes for new and improved express bus services, carpools and toll-paying solo drivers.

County
San Mateo County Congestion Management Program 2019
The City/County Association of Governments of San Mateo County (C/CAG) is the designated Congestion Management Agency (CMA) for San Mateo County. In accordance with California Government Code Section 65088, each CMA is required to prepare and adopt a Congestion Management Program (CMP) on a biennial basis. The CMP includes monitoring and evaluation of Level of Service (LOS) along the designated CMP network, which includes US 101 and the El Camino Real/Holly Street intersection in San Carlos. With the updating of CEQA per the requirements of SB 743, maintenance of LOS standards is no longer part of the environmental review process.

C/CAG Transportation Demand Management (TDM) Policy
The C/CAG TDM Policy provides guidelines regarding analysis of the transportation impacts of development projects in municipalities in San Mateo County. Unless exempted from the policy, local jurisdictions are required to notify C/CAG of incoming development that is estimated to generate an average of 100 trips per day. For affected projects, applicants are required to complete a TDM checklist and implement measures to reduce the estimated number of trips and their adverse effects on traffic operations. The type and magnitude of TDM measures are based on the land use type and project size.

Local
San Carlos 2030 General Plan
The Circulation and Scenic Highways Element of the San Carlos 2030 General Plan includes several objectives, policies and programs addressing traffic, roadways, transit, and bicycle and

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pedestrian facilities. The Circulation and Scenic Highways Element emphasizes the efficient use of the City’s existing roadway capacity through development of a multimodal transportation system and coordination of transportation with land use planning and the development of housing.

As stated in the Plan, transportation improvements should “help reduce dependence on the automobile as a method of reducing traffic congestion, improving safety, reducing pollution, promoting energy conservation, promoting health and increasing accessibility for all residents.” Following are select policies and actions identified in the Circulation and Scenic Highways Element that apply to the proposed Housing Element Update component of the project.

Policy CSH-2.3: - Access to public transportation facilities should be convenient and designed to encourage use of public transit.

Policy CSH-3.3: - Support Smart Growth and Sustainability principles to reduce travel time from housing to jobs, provide affordable transportation to all members of the community, allow compact mixed-used development and decrease dependency on automobiles.

Policy CSH-3.13: - The City may consider traffic-calming devices to reduce speeds and to discourage thru traffic in residential neighborhoods. Impacts of diverting traffic to adjacent neighborhoods, bicycle and pedestrian access and safety, noise, emergency response time, aesthetics and maintenance should be reviewed prior to allowing traffic calming devices.

Action CSH-3.3: - The City shall support local school district efforts to reduce traffic through programs such as safe routes to school, school pools and school bus/shuttle programs.

Action CSH-3.7: - The City shall strive to reduce vehicular trip generation from new development by 20 percent and to reduce vehicle miles traveled by 15 percent, using a combination of both public and private funds and efforts. The 20 percent and 15 percent reductions shall be obtained through implementation of Transportation Demand Measures (TDMs). For private development projects, no less than a 10 percent reduction in vehicular trip generation should be attained through the implementation of TDMs that are privately funded and implemented. TDMs may include, but are not limited to, incorporation of the following measures into new development projects:
• Mixed-use areas
• Neighborhood centers
• Pedestrian-oriented public and private development improvements • Increased/enhanced pedestrian linkages
• Bicycle-friendly improvements
• Access to transit corridor

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• Participation in local public shuttle programs
• Parking management
• Links between commercial, residential and industrial areas of the community • Access to a variety of transportation modes
• C/CAG Congestion Management Plan Trip Reduction Measures Action CSH-3.10 - The City shall support an intra-city (east/west) local shuttle to feed into other forms of local and regional transportation.

Action CSH-3.1 - New development projects shall be required to mitigate traffic, circulation and/or parking impacts. The City may impose a mitigation fee on new developments for the proportional share of costs to mitigate the traffic, circulation and/or parking impact of a project.

Policy CSH-4.2 - Reduce potential conflicts, safety hazards and physical obstacles between bicyclists, automobiles and pedestrians and ensure compliance with the Americans with Disabilities Act.

Policy CSH-5.1 - Connect neighborhoods, school sites, activity centers, transportation centers, recreational sites and other important community amenities with sidewalks, pedestrian paths, trails and bikeways.

Policy CSH-5.3 - Support an interconnected system of pedestrian ways, paths, trails, bikeways and transit routes within the city and between adjacent communities.

Policy CSH-6.1 - Bicycling and walking facilities should be incorporated into all new development projects to the maximum extent feasible.

Policy CSH-6.2 - Support transit-oriented development with mixed, dense land use that reduces the need to travel and that is linked to good transit. The City shall work with local, regional and State representatives to encourage the support and funding of transit-oriented development projects.

East Side Innovation District Vision Plan
The East Side Innovation District Vision Plan (adopted October 25, 2021) presents planning strategies, goals, principles, and action items to achieve the desired characteristics for the future East Side Innovation District area, which is a 150-acre commercially zoned area located on the east side of San Carlos, for which the Vision Plan is intended to guide the transformation of the District from its existing industrial character to a neighborhood containing a mix of new uses such as biotechnology, life science, and high-tech office, as well as walkable amenities, sustainable and resilient infrastructure, and publicly accessible open spaces and trails. This plan was intended to

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be used in the early stages of project development to determine how a project can be conceptualized and programmed so that a portion of the plan can be fulfilled with each act of new construction or public involvement.

San Carlos Bicycle and Pedestrian Master Plan
The Bicycle and Pedestrian Master Plan (BPMP) was adopted in June 2020. The BPMP establishes a long-term vision for improving walking and bicycling in San Carlos and presents a strategy to develop a comprehensive bicycling and walking network that provides access to transit, schools and downtown. This plan provides guidance to City staff and the development community in building a balanced transportation system where active modes are supported and accessible.

The goal of the plan is to promote walking and bicycling through the creation of safe, comfortable, and connected networks, and to encourage alternatives to single-occupancy motor vehicle trips.

Existing and planned bicycle facilities are shown in Figure 4.14-3.

San Carlos Vehicle Miles Traveled (VMT) Policy
As provided for in SB 743, in 2020 the City adopted a VMT policy that was based on assessment of local needs and development characteristics, to be used in evaluating the potential VMT impacts of land development and transportation projects. The City’s policy is generally consistent with the OPR technical advisory, establishing a significance threshold of 15 percent below the countywide average VMT per service population. Housing projects are exempt from VMT analysis if they are located within one-half-mile of the San Carlos Caltrain station or El Camino Real and are consistent with the General Plan Land Use Designations and Zoning Code or if they generate fewer than 100 trips per day, corresponding with thresholds established by C/CAG for the CMP.

San Carlos Complete Streets Policy
The City adopted a Complete Streets Policy in 2021 to support the development of a multimodal transportation network that serves all categories of users. Provisions of the policy include applying a context-sensitive approach to local conditions so that appropriate facilities will be designed to best serve the needs of residential as well as commercial areas, with consideration for the urban, suburban, or rural nature of the location.

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Figure 4.14-3 Bicycle and Pedestrian Facilities
Proposed Bikeways
Class I Shared-Use Path
Class II Bicycle Lane
Class IIB Buffered Bike Lane
Class Ill Bicycle Route
Class IIIB Bicycle Boulevard
Class IV Separated Bikeway
Parking Removal
Lane Reduction
- Peninsula Bikeway
Improvement Areas
Downtown
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-- Class I Shared-Use Path
Class II Bicycle Lane
Class IIIB Bicycle Boulevard
-- Class Ill Bicycle Rout e
Destinations +
Boundaries
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0 Shopping
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~ Library
0 School
0 Caltrain Station
- Bay Trai l
Park
> Uphill Bi keway
~ MILES Q 0.25 0.5
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Chapter 4.15 Transportation
San Carlos Focused General Plan Update Draft EIR 4.14-17 October 2022
Transportation Demand Management Program
The City of San Carlos has adopted a Transportation Demand Management (TDM) program with requirements that apply to all new residential developments, except for single-family dwellings, accessory units, and multi-family projects of fewer than ten units. Chapter 18.25.030 of the San Carlos Municipal Code requires each qualifying project to incorporate TDM measures to reduce the estimated project-generated trips to 20 percent lower than the most recent trip generation rates from the Institute for Transportation Engineers (ITE) Trip Generation Manual. To demonstrate compliance with the TDM program, applicants must meet monitoring requirements. For projects not in compliance with program requirements, the City may require project owners/operators to modify their previously approved TDM measures.

Transportation Impact Fees
The City of San Carlos Municipal Code Section 8.50 establishes transportation impact fees to require new development to fund a proportional share of infrastructure improvements to offset potential transportation impacts, which would affect the quality of service, safety, and other factors. For residential development, the fees are assessed on a per unit basis.

4.14.3 Thresholds of Significance
Per the CEQA guidelines, the proposed project would have a significant impact related to transportation if it would:
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities; b) Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b); c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or d) Result in inadequate emergency access.

Regarding VMT, the City’s adopted VMT policy specifies a metric of VMT per service population, which is calculated by dividing the project’s total VMT by the sum of population and employment. While VMT per capita includes only home-based trips (trips that either begin or end at a place of residence) and VMT per employee includes only employee commute trips, total VMT includes other trips not included in the VMT per capita or per employee calculations, such as customer trips to and from retail sites, visitor trips, and deliveries. Per the City’s policy, the significance threshold used for this analysis was 15 percent below the countywide VMT per service population based on existing development.

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Chapter 4.15 Transportation

4.14-18 San Carlos Focused General Plan Update Draft EIR October 2022

4.14.4 Impacts and Mitigation Measures
This section describes potential impacts related to transportation that would result from implementation of the project.

Methodology
The potential housing unit locations have been identified for inclusion in the proposed Housing Element Update and analyzed for their transportation impacts. However, since specific projects have not been proposed for these sites, this analysis was undertaken at the program level, as project-level impacts such as site access and adequacy of multimodal circulation cannot be analyzed as part of this review. This more detailed assessment will take place as part of the development review process for proposed projects.

The analysis of the Housing Element’s potential transportation impacts was based on an assessment of applicable policies and a quantitative evaluation of vehicle miles traveled (VMT).

The project VMT was assessed using the most recent version of the City/County Association of Governments of San Mateo County-Santa Clara County Valley Transportation Authority (C/CAGVTA) Countywide Model. The model is based on the transportation network assumptions from Plan Bay Area 2040 (the Bay Area’s Regional Transportation Plan/ Sustainable Communities Strategy) and the corresponding population, housing and employment forecasts developed by the Association of Bay Area Governments (ABAG). The housing opportunity sites and proposed number of units were assigned to the traffic analysis zones (TAZs) associated with the model.

The following scenarios were analyzed:
• Existing Conditions (2019): Reflects current conditions without the project. • Existing plus Project (2019): Adds buildout of the San Carlos Housing Element to existing conditions.
• Cumulative (2040): Reflects future conditions including regional growth and buildout of the current General Plan.
• Cumulative plus Project (2040): Adds buildout of the San Carlos Housing Element to the Cumulative scenario.

Impact TRANS-1: The project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. (Less Than Significant Impact)
The proposed Housing Element Update would result in an increased number of residential units and therefore increased use of the transportation system. Based on the proximity of the project sites to commercial areas and high-quality transit, the project would support a land development pattern that would result in shorter trip lengths and would encourage use of non-vehicle modes of

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Chapter 4.15 Transportation
San Carlos Focused General Plan Update Draft EIR 4.14-19 October 2022
transportation. It is therefore expected that the project would generate additional walking, bicycling, and transit trips.

The Housing Element Update includes modification and additions to the policies as part of the project. The following proposed policy relates to the City’s circulation system:

Policy HOU-2.2 Complete Streets - Promote development that supports the City’s Complete Streets Policy, Bicycle and Pedestrian Master Plan, and a pedestrian- and bicycle-friendly environment.

The policies included in the adopted Circulation Element of the General Plan indicate the City’s intent to support the development of higher intensity land uses near transit and commercial areas to reduce the need to travel, to provide convenient access to transit, and to support the reduction in vehicle trips. The concentration of the potential housing sites in the vicinity of the Caltrain station and El Camino Real support these policies. The proposed pedestrian, bicycle, and transit facilities to be added in support of the project would need to be designed in accordance with appropriate design guidelines and standards. The adequacy of the existing and planned infrastructure needed to support additional pedestrian, bicycle, and transit travel would be assessed as part of the project level development review.

The City of San Carlos’ TDM requirements would apply to incoming multi-unit residential projects of 10 units or more. Such projects must incorporate measures to achieve trip generation rates that are at least 20 percent below the Institute of Transportation Engineers (ITE) standard rates; the City code references the C/CAG TDM Policy regarding the amount of trip reduction associated with each measure. Such TDM measures would support the City’s Circulation Element policies, as the concentration of the potential housing sites near the San Carlos Caltrain station and El Camino Real supports the successful implementation of trip reduction measures focused on transit or active transportation.

Since the project is expected to further encourage the use of transit and active transportation, it supports existing City policies and proposed Housing Element policies. Therefore, with respect to potential conflicts with circulation system policies, the impact of the proposed Housing Element Update would be less than significant.

Impact TRANS-2: The project would not conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b). (Less Than Significant Impact) The VMT associated with the project was estimated using the C/CAG-VTA travel demand model.

The VMT estimates for each analysis scenario are presented in Table 4.14-1 and Table 4.14-2, including a comparison between City of San Carlos, San Mateo County, and Bay Area estimates of VMT per service population; additional details of the VMT analysis are presented in Appendix E.

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Chapter 4.15 Transportation

4.14-20 San Carlos Focused General Plan Update Draft EIR October 2022
Table 4.14-1: 2019 Daily VMT Summary – VMT per Service Population Scenario Households Population Jobs
ADT
Trips
VMT
Households VMT Jobs
VMT/
Service
Population*
Existing (2019)
City of
San
Carlos
13,046 33,896 20,416 167,429 566,823 386,523 17.55
San
Mateo
County
271,610 782,585 383,066 3,592,118 12,478,042 7,385,584 17.04 Bay
Area
2,766,914 7,740,411 3,848,081 31,021,369 124,970,549 66,795,404 16.55 Existing Plus Project (2019)
Housing
Element
5,057 12,927 779 29,487 174,365 4,727 13.07
City of
San
Carlos
18,103 46,823 21,195 196,910 741,262 391,113 16.65
San
Mateo
County
276,667 795,512 383,845 3,622,554 12,734,825 7,345,660 17.03 Bay
Area
2,771,971 7,753,338 3,848,860 31,059,674 125,045,004 66,831,525 16.54 15% Below San Mateo County Average VMT: 14.48 per Service Population Source: C/CAG Model, Kittelson & Associates, Inc., 2022 * Service population is the sum of population and jobs
Table 4.14-2: 2040 Daily VMT Summary – VMT per Service Population Scenario Households Population Jobs ADT Trips
VMT
Households VMT Jobs
VMT/
Service
Population
2040 No Project
City of
San
Carlos
13,046 33,896 26,452 184,791 562,267 494,834 17.52
San
Mateo
County
322,670 930,289 485,854 4,194,713 14,026,367 9,881,890 16.88 Bay
Area
3,423,406 9,663,450 4,725,006 36,319,573 156,510,412 83,719,586 16.70 2040 Plus Project
Housing
Element
5,057 12,927 779 28,957 167,217 12,091 13.08
City of
San
Carlos
18,103 46,823 27,231 213,691 729,625 506,250 16.69
San
Mateo
County
327,727 943,216 486,633 4,224,846 14,239,276 9,860,833 16.86

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Chapter 4.15 Transportation
San Carlos Focused General Plan Update Draft EIR 4.14-21 October 2022
Table 4.14-2: 2040 Daily VMT Summary – VMT per Service Population Scenario Households Population Jobs ADT Trips
VMT
Households VMT Jobs
VMT/
Service
Population
Bay
Area
3,428,463 9,676,377 4,725,785 36,360,865 156,881,584 83,922,042 16.72 15% Below San Mateo County Average VMT: 14.48 per Service Population Source: C/CAG Model, Kittelson & Associates, Inc., 2022 * Service population is the sum of population and jobs
The San Mateo countywide VMT per service population under existing conditions is 17.04 miles, resulting in a threshold of 14.48 miles. With a VMT per service population of 13.07 miles, the proposed Housing Element Update is below this threshold. With consideration for planned and regional growth, the proposed Housing Element Update is estimated to have a VMT per service population of 13.08, which is also below the countywide threshold. Therefore, the impact of the proposed Housing Element Update with respect to VMT is less than significant.

As noted in the Regulatory Setting discussion, San Carlos has adopted a citywide TDM requirement, which is not accounted for in the travel demand model. The policy requires all multiunit residential projects of 10 units or more to reduce their estimated number of trips by 20 percent compared to standard rates from the most recent edition of the Institute of Transportation Engineers (ITE) Trip Generation Manual. The Code specifies a list of acceptable trip reduction measures, to be selected on a project-by-project basis, and references the guidance provided by the C/CAG TDM Policy regarding the number of trips reduced per trip reduction measure.

Projects subject to the City’s TDM requirement must include a TDM plan with the project application. Annual TDM program monitoring is required for such projects, as well as a five-year review of the overall effectiveness of TDM activities. Based on the results of this review, the City may suggest new or modified activities to ensure that the project meets the trip reduction target.

Based on the Housing Element’s VMT as estimated in the C/CAG-VTA model, the VMT per service population would be below the threshold of significance. As most of the proposed housing units would be subject to the City’s TDM requirements, and would be required to implement TDM measures, the VMT would be expected to be further reduced below this level. Therefore, the impact of the project with respect to the CEQA Guidelines § 15064.3, subdivision (b) would be less than significant.

Impact TRANS-3: The project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). (Less Than Significant Impact)
Modifications to the transportation network near the housing sites identified in the project would be implemented over time, as would facilities elsewhere in San Carlos and the surrounding communities. New or upgraded facilities would be designed and constructed to be consistent with local, regional, and federal standards and guidelines; as a result, they would not be expected to introduce hazardous design features.

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Chapter 4.15 Transportation

4.14-22 San Carlos Focused General Plan Update Draft EIR October 2022
Housing development projects that include infrastructure improvements such as new streets, driveways, or pedestrian and bicycle facilities would undergo project-level review, and potential hazards would be identified as part of the review process. Potential safety concerns to be evaluated include the adequacy of sight lines at project access points and visibility issues that result from project-related vehicle queues.

Based on the design requirements for new projects and the analysis included in project-level review, the impact of the project with respect to the introduction of hazardous design features would be less than significant.

Impact TRANS-4: The project would not result in inadequate emergency access. (Less Than Significant Impact)
Housing Element Update
The implementation of the housing units proposed as part of the proposed Housing Element Update would not be expected to result in inadequate emergency access. At the project level, each project would be required to meet City and County standards and requirements and would be reviewed by public safety officials as part of the approval process. Safety, Fire, and Building Codes would be adhered to for all proposed development included in the updated Housing Element.

Emergency vehicle response times would continue to be reduced due to the ability of emergency vehicles to use vehicle preemption technology (where possible) and sirens; this capability would remain regardless of any roadway capacity modification. For any roadways that would be modified as part of the implementation of the proposed housing units, any reduction in vehicular roadway capacity would require an analysis of traffic operations to identify potential impacts to emergency vehicle access; in the event that any such impacts are identified, mitigation measures would be developed to reduce potentially significant impacts to less than significant levels.

Environmental Safety and Public Services Element Update, Land Use Element Update, Circulation and Scenic Highways Element Update, and Environmental Management Element Update
The proposed Environmental Safety and Public Services Element, Land Use Element, Circulation and Scenic Highways Element, and Environmental Management Element contain the following policies related to emergency access:

Action ESPS-3.8: When a fire has occurred in the VHFSZ, evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency. If the City has an unwritten policy, adopt a written re-development policy.

Action ESPS-3.14: Condition all new development and redevelopment to have adequate fire protection, incorporate and maintain fire safe design, including fuel modification zones, defensible space, two ingress/egress points, emergency vehicle access, and visible home addressing and street signage.

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San Carlos Focused General Plan Update Draft EIR 4.14-23 October 2022
Action ESPS-3.23: Evaluate the City’s roadways regarding access, alignments, etc. to facilitate fire, police, and ambulance access and resident egress in case of an emergency.

Policy ESPS-3.14: Provide adequate evacuation routes and access for fire and emergency service vehicles to all San Carlos areas.

Policy ESPS-3.15: Identify and implement measures to mitigate the single access roads and non-conforming roadways, as feasible.

Action ESPS-3.24: Identify streets and key intersections that, due to pavement width, hairpin turns, and tight curves, if not cleared of vehicles, may interfere with emergency vehicle access and/or resident evacuation during a fire.

Action ESPS-3.25: Identify the potential for street widening and improvement during regular Capital Improvement project maintenance, e.g., emergency access, utility undergrounding, resurfacing, and American with Disabilities (ADA) compliance.

Action ESPS-3.26: Prohibit parking on one or both sides of a street identified as having the potential to interfere with emergency vehicle access and/or resident evacuation during a fire, when Red Flag alerts have been issued.

Action ESPS-3.27: In conjunction with the use of the Zonehaven system, supplement the evacuation plan as shown in Figure 8-12, with special emphasis placed on the areas that do not have sufficient access and egress identified on Figure 8-13. Recommend improvements to ensure adequate evacuation capabilities.

Action ESPS-3.28: Conduct a study to review evacuation routes, their capacity, safety, and viability under a range of emergency scenarios as set forth in AB 747. Determine remedial actions, as appropriate. Update evacuation plans with each update of the Safety Element to address changes in at-risk areas and populations.

Policy LU-10.6: Require all new development and significantly modified development in the High and Very High Fire Susceptibility Zones to install and maintain fire prevention design and materials in accordance with Building Codes at the time of the construction/reconstruction.

Policy CSH-1.1: Widths of streets and highways should be sufficient to address existing and projected traffic volumes, emergency access requirements, while providing positive pedestrian and bicycle experiences.

Policy CSH-3.5: Street and right-of-way widths should be designed and constructed in accordance with the street standards established in this plan, the City Subdivision Ordinance and Standard Details. However, flexibility for street widths should be permitted with sensitivity to slope, neighborhood character, traffic volume, emergency access requirements, and pedestrian/bicycle needs.

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4.14-24 San Carlos Focused General Plan Update Draft EIR October 2022
Action EM-11.3: Design streets to accommodate all modes of transportation, including emergency vehicles, and provide for a safe and attractive pedestrian experience.

These policies and actions ensure that proper emergency access is considered and planned for in wildfire hazard areas and other areas of the City. These policies ensure that no significant impacts would result from inadequate emergency access and the impact is considered less than significant.

4.14.5 References
City of San Carlos Transportation Significance Criteria, Resolution 2020-066, http://sancarlosca.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=3108&Inline=True San Carlos General Plan, 2009, https://www.cityofsancarlos.org/Home/ShowDocument?id=1105 San Carlos Bicycle and Pedestrian Master Plan, 2020,
https://www.cityofsancarlos.org/home/showpublisheddocument/6058/637302506699000000 San Carlos Complete Streets Policy, Resolution 2012-066, https://www.cityofsancarlos.org/home/showpublisheddocument/730/636568158369870000 Plan Bay Area 2050, Metropolitan Transportation Commission and Association of Bay Area Governments, 2021, https://planbayarea.org
San Mateo Countywide Transportation Plan 2040, City/County Association of Governments, 2017, https://ccag.ca.gov/programs/countywide-transportation-plan/ Vehicle Miles Travel-Focused Transportation Impact Study Guide, Caltrans, 2020, https://dot.ca.gov/-/media/dot-media/programs/transportation-planning/documents/sb743/2020-05-20-approved-vmt-focused-tisg-a11y.pdf Handbook for Analyzing GHG Emission Reductions, Assessing Climate Vulnerabilities, And Advancing Health and Equity, California Air Pollution Control Officers Association (CAPCOA), 2021, https://www.caleemod.com/handbook/index.html.

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Chapter 4.15 Utilities and Service Systems
San Carlos Focused General Plan Update Draft EIR 4.15-1 October 2022

4.15 UTILITIES AND SERVICE SYSTEMS
This EIR section addresses the project’s potential impacts on utilities and service systems and suggests mitigation measures, if required.

4.15.1 Environmental Setting
Water Supply
San Carlos receives its water from two local domestic water providers: the California Water Service Company (Cal Water) and the Mid-Peninsula Water District. The Cal Water San Carlos system has 112 miles of mains, 18 storage tanks, and 24 booster pumps1. The Mid-Peninsula Water District only serves a small portion of San Carlos2. All of the inventory sites identified within the Housing Element Update are within the Cal Water and Mid-Peninsula District service area. These two local domestic water providers purchase water from the San Francisco Public Utilities Commission (SFPUC).

San Francisco Public Utilities Commission (SFPUC)
As described in the Cal Water Mid-Peninsula District 2020 Urban Water Management Plan, the sole source of water supply to the Cal Water Mid-Peninsula District is treated water purchased from the City and County of San Francisco’s Regional Water System (RWS), which is operated by the San Francisco Public Utilities Commission (SFPUC). Approximately 85 percent of the water supply to the SFPUC RWS originates in the Hetch Hetchy watershed, located in Yosemite National Park, and flows down the Tuolumne River into the Hetch Hetchy Reservoir. Water from the Hetch Hetchy watershed is managed through the Hetch Hetchy Water and Power Project. The remaining 15 percent of the water supply to the SFPUC RWS originates locally in the Alameda and Peninsula watersheds and is stored in six different reservoirs in Alameda and San Mateo Counties.

California Water Service Company
The majority of water service in San Carlos is managed by Cal Water’s Bayshore District. The Bayshore District is divided into two areas; the Mid-Peninsula District, which includes San Carlos and San Mateo, and the South San Francisco District. It is estimated that the Mid-Peninsula District’s service area population was 137,486 in 2020. The 2045 projected population (150,974) is based on population, housing, and employment projections developed by the Association of Bay Area Governments (Association of Bay Area Governments [ABAG] Projections 2040). Water use in the Mid-Peninsula District in 2020 was 14,563 acre-feet (AF), with residential customers 1 California Water Service, 2022. San Carlos 2021 Water Quality Report, Website:
https://www.calwater.com/ccrs/bay-sc-2021/ (accessed August 19, 2022). 2 Mid-Peninsula Water District, 2022 Urban Water Master Plan System Map, Website:

UWMP_MPWD_SystemMap2_Large.png (1899×1229) (storage.googleapis.com)(accessed August 29, 2022).

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4.15-2 San Carlos Focused General Plan Update Draft EIR October 2022
accounting for most of the District’s service connections and 72 percent of its water use. The San Carlos public water system accounted for 3,658 AF of the Mid-Peninsula District’s 14,465 AF total. Non-residential water uses accounted for 22 percent of total demand, while distribution system losses accounted for six percent. Projected water use in 2045 is anticipated to be 15,279 AF.
3 Table 4.15-1 shows projected water use.

Cal Water’s Individual Supply Guarantee (ISG) from the SFPUC is 35.68 MGD (39,993 acre-feet per year; AFY), which is shared among its Bear Gulch, Mid-Peninsula, and South San Francisco Districts (also referred to as the “Peninsula Districts”). The 2020 UWMP estimates the Peninsula Districts’ demand will increase over time to 36,396 AF in 2045. Therefore, the Peninsula Districts are expected to have adequate water supplies during normal years to meet its projected demands through 2045. However, the District is expected to experience significant shortfalls during single dry and multiple dry year conditions as a result of Bay-Delta Plan Amendment implementation.

At this time numerous uncertainties remain in the implementation of the Bay-Delta Plan Amendment and the resultant allocation of the available supply to the District and the other SFPUC wholesale customers. Cal Water has developed a Water Shortage Contingency Plan to address potential water shortage conditions. 4 The Water Shortage Contingency Plan (WSCP) addresses water shortage conditions resulting from any cause (e.g., droughts, impacted distribution system infrastructure, regulatory-imposed shortage restrictions, etc.). The WSCP identifies a variety of actions that Cal Water would implement to reduce demands and further ensure supply reliability at various levels of water shortage. The WSCP is based on the six water shortage levels (also referred to as “stages”); these shortage stages are intended to address shortage caused by any condition, including the catastrophic interruption of water supplies.

Table 4.15-1: Cal Water Mid-Peninsula District Projected Potable and Non-Potable Water Use
Use Type
Additional
Description
(as needed)
Projected Water Use (volume in acre-feet)
2025 2030 2035 2040 2045
Single Family 8,146 8,094 8,108 7,997 7,948
Multi-Family 2,204 2,370 2,499 2,720 2,971
Commercial 2,345 2,301 2,368 2,409 2,464
Institutional/Gov’t 718 722 755 787 824
Industrial 31 31 31 31 31
Other Potable 121 121 121 121 121
Landscape (a) 0 0 0 0 0
3 Ibid.
4 Ibid.

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Chapter 4.15 Utilities and Service Systems
San Carlos Focused General Plan Update Draft EIR 4.15-3 October 2022
Table 4.15-1: Cal Water Mid-Peninsula District Projected Potable and Non-Potable Water Use
Use Type
Additional
Description
(as needed)
Projected Water Use (volume in acre-feet)
2025 2030 2035 2040 2045
Losses (b) 853 891 904 912 920
Total 14,418 14,530 14,786 14,977 15,279
Notes
Source: Cal Water 2020 UMWP for the Mid-Peninsula District. June 2021. (a) District’s billing system does not track this use type separate from other use types. (b) Real and apparent losses.

Sanitary Sewer Service
The San Carlos Public Works Department provides wastewater collection service for San Carlos.

The City owns and operates a sanitary sewer collection system consisting of approximately 104 miles of sewer pipelines and six sewer lift stations. The average flow from the City to the treatment plant is about two million gallons per day. The majority of the gravity system (almost 70 percent) consists of 6-inch pipe, and over 85 percent is pipes less than 10 inches in diameter. The oldest portions of the system date to the 1920s, with a large portion of the system constructed in the 1940s and 1950s, with newer areas in the hills developed later. The primary sewer pipe material in the collection system is vitrified clay pipe, with plastic materials used for newer sewer construction and rehabilitation. The collection system also includes approximately 11,000 private sewer laterals.5
Wastewater generated within the City is treated at a wastewater treatment plant (WWTP) operated by a joint powers authority called Silicon Valley Clean Water (SVCW), which serves the communities of Belmont, Redwood City, San Carlos, and the West Bay Sanitary District. The WWTP is a regional wastewater treatment plant jointly owned by San Carlos, Belmont, Redwood City, and the West Bay Sanitary District, for treatment and subsequent discharge into the San Francisco Bay. A small percentage of SVCW’s wastewater is treated to higher levels and used as recycled water by Redwood City.

SVCW owns and operates the WWTP, including support facilities necessary for the operation and maintenance of the treatment plant, wastewater conveyance system force mains, five wastewater conveyance pump stations, and an effluent outfall into the San Francisco Bay. Approximately eight miles of force main pipe is owned, operated, and maintained by SVCW. The pipe varies in diameter from 33-inch to 63-inch. Four pump stations pump raw wastewater to the SVCW force main and one booster station pumps peak wet weather flows from West Bay Sanitary District and 5 City of San Carlos Public Works Department, 2022. San Carlos Sewer System General Information. Website:
https://www.cityofsancarlos.org/home/showpublisheddocument/848/636571580313500000 (accessed August 19, 2022).

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Chapter 4.15 Utilities and Service Systems

4.15-4 San Carlos Focused General Plan Update Draft EIR October 2022
City of Redwood City when necessary. SVCW owns, operates, and maintains the pump stations and is reimbursed by the individual member agencies for costs expended on the operation and maintenance related to the member agency’s service areas.6 The wastewater at the SVCW WWTP undergoes primary, secondary (activated sludge), dual media filtration, disinfection, and dechlorination treatment before being discharged to a deep-water outfall in the San Francisco Bay. The SVCW WWTP has a capacity to treat 29.5 MGD, but currently receives approximately 20.0 MGD from customers in the SVCW service area. SVCW is currently providing recycled water to sites located in and owned by the Cities of Redwood City and Menlo Park.7
Stormwater Management
The City owns and operates a storm drain system comprised of catch basins, manholes, pipes, conveyance channels, creeks, ditches, pump stations, and covers four main watersheds. In general, stormwater in the City drains from the residential areas in the hills at the west side of the City, then flows east towards the commercial areas at the east side of the City to the San Francisco Bay via four outfalls. Stormwater is conveyed to the Bay via open ditches and pipelines into the City’s four primary creeks: Belmont, Brittan, Cordilleras, and Pulgas. The City has three pump stations:

Pulgas Pump Station, Holly Street Pump Station, and Howard/Brittan Pump Station. 8 The City has experienced periodic flooding over the years and these flooding events are generally due to a combination of issues, including storm drain inlet blockages from leaves and debris; stormwater volumes that are greater than the capacity of the City storm drain pipelines; and backwater and overtopping from creeks. In addition, the eastern portion of the City is mostly flat and at low ground elevation relative to the Bay and is subject to tidal influences and sedimentation.

The City is responsible for maintenance of the storm drain system and the creeks, but the City does not have easements to access and maintain portions of the creeks, especially the upstream reaches west of El Camino Real.9 Property owners along most of Belmont and Cordilleras Creeks are responsible for creek maintenance.10
A technical study has been prepared to determine feasible flood control alternatives for Belmont Creek that would reduce flooding at the Novartis Pharmaceuticals Corporation (Novartis) facility located at 150 Industrial Road in the City of San Carlos. The Belmont Creek Watershed Study, Creek Assessment, and Recommendations for Sustainable Improvements Project studied flood control measures to mitigate the flooding that has historically occurred at the Novartis facility.11 6 Silicon Valley Clean Water, 2020. Capital Improvement Program, 2020 Update, FY20-21 to FY29-30. 7 California Water Service, 2022. 2020 Urban Water Management Plan, Mid-Peninsula District, June. 8 City of San Carlos, 2017. Citywide Storm Drain System Master Plan, April. 9 Ibid.
10 Personal Communication with Grace Le, San Carlos Public Works Department. October 5, 2022. 11 Wreco, 2014. Belmont Creek Watershed Study, Creek Assessment, and Recommendations for Sustainable Improvements San Mateo County, California, September.

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Chapter 4.15 Utilities and Service Systems
San Carlos Focused General Plan Update Draft EIR 4.15-5 October 2022
Electricity, Natural Gas, and Telecommunications
Electricity and natural gas would be provided to the project site by Peninsula Clean Energy (PCE) and Pacific Gas and Electric (PG&E), respectively. PCE is San Mateo County’s Community Choice Aggregate (CCA), a community-controlled, not-for-profit joint powers agency. PCE procures renewable sources of electricity throughout San Mateo County, while PG&E manages and maintains the electrical infrastructure used to supply consumers with electricity.

Solid Waste
Solid waste and recyclables are collected within the city by a provider contracted through the South Bayside Waste Management Authority (SBWMA). SBWMA, also known as RethinkWaste, is a joint powers authority formed by eleven local government jurisdictions in San Mateo County (City of Belmont, City of Burlingame, City of East Palo Alto, City of Foster City, Town of Hillsborough, City of Menlo Park, City of Redwood City, City of San Carlos, City of San Mateo, County of San Mateo and West Bay Sanitary District). RethinkWaste owns and manages the Shoreway Environmental Center in San Carlos, which receives all the recyclables, green waste and garbage collected from the member agencies. Unrecyclable waste is then disposed of at Ox Mountain Landfill in Half Moon Bay.

4.15.2 Regulatory Setting
Water Supply
Federal
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA), administered by EPA in coordination with the California Department of Public Health (CDPH), is the main federal law that ensures the quality of drinking water. Under SDWA, EPA sets standards for drinking water quality and oversees the states, localities, and water suppliers who implement those standards.

State
California Safe Drinking Water Act
The California Department of Public Health (CDPH) coordinates with the federal EPA to ensure the quality of local drinking water. The CDPH oversees state implementation of the SDWA based on the standards for drinking water quality established by the EPA.

State of California Recycled Water Policy
On January 22, 2013, the SWRCB adopted the State of California Recycled Water Policy, a revision of a 2009 statewide recycled water policy, with the ultimate goal of increasing the use of recycled water from municipal wastewater sources. Included in this policy is the mandate to

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increase the use of recycled water in California to 1.5 million acre-feet per year (AFY) by 2020, and an additional 2.5 million AFY by 2030. The plan also states that the SWRCB expects to increase the use of stormwater from 2007 levels to at least 500,000 AFY by 2020 and one million AFY by 2030.

Government Code §65589.7
Section (a) of Government Code §65589.7 states that the housing element adopted by the legislative body and any amendments made to that element shall be immediately delivered to all public agencies or private entities that provide water or sewer services for municipal and industrial uses, including residential, within the territory of the legislative body and that priority for the provision of these services shall be provided to proposed developments that include housing units affordable to lower income households.

California Code of Regulations, Title 22, Division 4
The SWRCB – Division of Drinking Water is authorized to set the criteria for recycled water production and use. Title 22, Division 4 of the California Code of Regulations (CCR) defines these criteria, which pertain to treatment processes, water quality, and reliability. It establishes minimum water quality criteria requirements for various use categories, including irrigation, wetlands, and industrial uses. For unrestricted reuse, including use at parks and playgrounds, schoolyards, and other unrestricted access facilities, and specifies disinfected tertiary treatment. Title 22 also specifies that for disinfected tertiary-treated water, there must be a separation of 50 feet between areas irrigated with recycled water and domestic groundwater wells.

California Code of Regulations, Title 17
Title 17, Section 7584 of the CCR requires the water supplier to protect the public water supply from contamination by implementing a cross-connection control program. This program must include, but not be limited to, surveys to identify water use premises where cross-connections are likely to occur, and provisions of backflow protection by the water user downstream (after) the user’s connection to the public water system.

In accordance with Title 17, Section 7604 of the CCR, the type of protection required to prevent backflow into the public water supply is determined by the degree of hazard that exists on the consumer’s property. Required backflow devices must include, but not be limited to, a double check valve assembly reduced-pressure principal device, and air-gap separation. The required backflow protection device is determined by the individual city and/or the appropriate state agency.

Senate Bill 610 and Senate Bill 221
Senate Bill 610 (SB 610) and Senate Bill 221 (SB 221) amended state law to ensure better coordination between local water supply and land use decisions, and ensure adequate water supply for new development. SB 610 requires the preparation of a water supply assessment for projects

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within cities and counties that propose certain projects. The Water Code requires that a water supply assessment be prepared for any “project” that would consist of one or more of the following:
• A proposed residential development of more than 500 dwelling units • A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space
• A proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space
• A proposed commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space
• A proposed hotel or motel, or both, having more than 500 rooms • A proposed industrial, manufacturing, or processing plant, or industrial park planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area
• A mixed use project that includes one or more of the projects specified above • A project that would demand an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling-unit project
SB 221 amended state law, effective January 1, 2002, to improve the link between information on water supply availability and land use at the tentative map preparation phase of a project. SB 610 and SB 221 are companion measures that seek to:
• Promote more collaborative planning between local water suppliers and cities and counties • Require detailed information regarding water availability be provided to city and county decisionmakers prior to approval of specific large development projects • Require that this detailed information be included in the administrative record that serves as the evidentiary basis for an approval action by the city or county on such projects • Recognize local control and decision making regarding the availability of water for projects and the approval of projects
Both statutes require that detailed information regarding water availability be provided to city/town and county decision-makers prior to approval of large development projects.

Statewide Water Conservation Act of 2009 (Senate Bill X7-7) In November 2009, the California State legislature passed, and the Governor approved, a comprehensive package of water legislation, including Senate Bill (SB) X7-7 addressing water conservation. In general SB X7-7 requires a 20 percent reduction in per capita urban water use by 2020, with an interim 10 percent target in 2015. The legislation requires urban water users to develop consistent water use targets and to use those targets in their Urban Water Management Plans (UWMPs). SB X7-7 also requires certain agricultural water supplies to implement a variety of water conservation and management practices and to submit Agricultural Water Management Plans.

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Urban Water Management Planning Act
Through the Urban Water Management Act of 1983, the California Water Code requires all urban water suppliers within California to prepare and adopt an Urban Water Management Plan (UWMP) and update it every five years. This requirement applies to all suppliers providing water to more than 3,000 customers or supplying more than 3,000 acre-feet of water annually. The Act is intended to support conservation and efficient use of urban watersupplies at the local level. The Act requires that total projected water use be compared to water supply sources over the next 20 years in five year increments, that planning occur for single and multiple dry water years and that plans include a water recycling analysis that incorporates a description of the wastewater collection and treatment system within the agency’s service area along with current and potential recycled water uses.

Groundwater Management Act
The Groundwater Management Act of the California Water Code (AB 3030) provides guidance for applicable local agencies to develop a voluntary Groundwater Management Plan (GMP) in State-designated groundwater basins. GMPs can allow agencies to raise revenue to pay for measures influencing the management of the basin, including extraction, recharge, conveyance, facilities maintenance and water quality.

Local/Regional
Cal Water 2020 Urban Water Management Plan for the Mid-Peninsula District Cal Water’s Mid-Peninsula District provides water service to the cities of San Carlos and San Mateo. The Cal Water 2020 Urban Water Management Plan (UWMP) is the long-range planning document used by Cal Water for water supply and system planning. The UWMP summarizes the Mid-Peninsula District’s historical and projected water demands, water supplies, supply reliability and potential vulnerabilities, water shortage contingency planning, and demand management programs for the years 2020 through 2045.

San Carlos General Plan
The 2009 General Plan provides the fundamental basis for the City’s land use and development policy, and represents the basic community values, ideals and aspirations to govern a shared environment over the life of the General Plan. The General Plan includes the following elements:

Land Use; Housing; Circulation and Scenic Highways; Environmental Management; Parks and Recreation; Community Safety and Services; and Noise.

Goals, policies, and actions contained in the Environmental Management Element of the General Plan focus on the protection, preservation and enhancement of natural resources in San Carlos, including the protection of water. Under State law, the City’s General Plan is the primary planning document, and all other City plans and policies must be consistent with the adopted General Plan.

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The General Plan Environmental Management Element includes the following applicable policies:

Policy EM-5.3: Promote the conservation and efficient use of water in new and existing residences and by commercial and industrial consumers.

Policy EM-5.4: Encourage the use of drought-tolerant plants and efficient watering techniques for all City landscaping.

Policy EM-5.5: Recycled water distribution system (purple pipe) should be used for landscaping and other non-potable water uses for residential, commercial and industrial customers, where technically and financially feasible.

Policy EM-5.8: Work with water service providers to provide high quality domestic water.

Policy EM-5.10: Require the evaluation of potential groundwater depletion that could occur from new development through dewatering.

San Carlos Municipal Code, Title 18 Zoning, Chapter 18.18 Landscaping, Section 18.18.080 and

18.18.090
Chapter 18.18, Section 18.18.080 (Water efficient landscaping and irrigation) of the San Carlos Municipal Code establishes standards to minimize water use associated with landscaping. Section

18.18.080 requires proposed site landscaping to not exceed a maximum applied water allowance threshold based on the site’s proposed landscaped area. Section 18.18.090 (Irrigation specifications) prescribes specifications for landscaping irrigation systems. Irrigation systems must consist of low-volume sprinkler heads, dry emitters, and bubbler emitters with automatic controllers.

Wastewater
State
State Water Resources Control Board
The SWRCB, in coordination with nine RWQCBs, performs functions related to water quality, including issuance and oversight of wastewater discharge permits (e.g., NPDES), other programs regulating stormwater runoff, and underground and above-ground storage tanks. The RWQCB requires all wastewater collection and disposal providers to prepare a Sewer System Management Plan according to the Statewide General Order Waste Discharge Requirements for Sanitary Sewer Systems.
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Local
San Carlos General Plan
The 2009 General Plan provides the fundamental basis for the City’s land use and development policy, and represents the basic community values, ideals and aspirations to govern a shared environment over the life of the General Plan. The General Plan includes the following elements:

Land Use; Housing; Circulation and Scenic Highways; Environmental Management; Parks and Recreation; Community Safety and Services; and Noise.

Goals, policies, and actions contained in the Land Use and Environmental Management Elements of the General Plan include those pertaining to the City’s sanitary sewer system. Under State law, the City’s General Plan is the primary planning document, and all other City plans and policies must be consistent with the adopted General Plan.

The General Plan Land Use Element and Environmental Management Element include the following applicable policies:

Policy LU-4.5: Annexation of developed parcels shall be in substantial compliance with the following criteria:
a. The parcels are contiguous to parcels located in the City of San Carlos and contiguous to city streets.
b. The parcels are connected to the city's sanitary sewer system or can be connected to the city's sewer to the satisfaction of the City Engineer.
c. The structures on the parcels shall comply with the Building Codes in effect at the time the structures were constructed. A Code Compliance evaluation prepared by a licensed Civil Engineering or Architect shall be submitted to the San Carlos Building Department for review and approval prior to annexation.

Policy LU-4.7: Prior to annexation of parcels, public services and facilities meeting City standards shall be installed or provisions for their installation shall have been made to the satisfaction of the City Engineer. Public services and utilities include:
a. Construction and acceptance of improvements shall be completed prior to issuance of Building Permits or sewer connections.
b. Construction of streets meeting City subdivision street standards from the terminus of city streets currently meeting City standards to and throughout the subdivision. Where possible and appropriate and subject to environmental, health and safety considerations, rural road standards shall apply. Assessment districts may be used by the developer for installation of portions of the street which is the responsibility of the owner of abutting unimproved lands at the time their development.
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Policy EM-5.1: Reduce the discharge of toxic materials into the city’s sanitary sewer and stormwater collection system by promoting the use of Best Management Practices (BMPs).

Policy EM-5.9: Sewer service may be extended outside the city limit only as required to protect public health due to failing septic systems in accordance with the following policies:
• Extension of sewer service would be denied if there is insufficient capacity in the wastewater collection system.
• No change to the land use would occur.
• The extension of sewer service could not be used to enable further subdivision. • The property owner would be required to annex as such time as a complete consolidation of properties could be annexed.
• The property owner would be required to complete all improvements necessary to meet City building and engineering standards.
• Applicant to assure payment of all sewer connection, plan checking and inspection fees.

Sewer Collection System Master Plan
The City prepared a Sewer Collection System Master Plan in 2013. The report presents a comprehensive assessment of the City’s sewer collection system in order to identify system capital improvement needs. The Master Plan was also prepared to meet the requirements of the Statewide General Waste Discharge Requirements for Sanitary Sewer Systems, which require every collection system agency in California prepare a Sewer System Management Plan. The plan includes a system evaluation and capacity assurance plan and a plan for rehabilitation and replacement of sewers based on their condition.

Sanitary Sewer Management Plan
The San Carlos Sanitary Sewer Management Plan (SSMP) was originally prepared in July 2014 and last updated April 30, 2021. The SSMP includes eleven elements; including but not limited to goals; operation and maintenance program; design and performance provisions; overflow emergency response plan; fats, oils and grease control program; system evaluation and capacity assurance plan; and monitoring measurement and program modifications among others.

Stormwater
Federal
Clean Water Act
The Clean Water Act (CWA) is the primary federal legislation governing water quality and forms the basis for several state and local laws throughout the nation. The objective of the CWA is “to

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restore and maintain the chemical, physical, and biological integrity of the Nation’s waters.” Important and applicable sections of the Act are:
• Section 404 authorizes the United States (U.S.) Army Corps of Engineers (USACE) to regulate the discharge of dredged or fill material to waters of the U.S., including wetlands.

The USACE issues individual site-specific or general (Nationwide) permits for such discharges.
• Sections 303 and 304 provide for water quality standards, criteria, and guidelines. The State implements Section 303 through the State Water Resources Control Board and Regional Water Quality Control Board (RWQCB), as discussed below. Section 304 requires the U.S.

Environmental Protection Agency to publish water quality criteria that accurately reflects the latest scientific knowledge on the kind of effects and extent of effects that pollutants in water may have on health and welfare. Section 304 also provides guidance to the State in adopting water quality standards.
• Section 401 requires an applicant for any Federal permit that proposes an activity that may result in a discharge to “waters of the U.S.” to obtain certification from the State that the discharge will comply with other provisions of the CWA. In California, a Water Quality Certification is provided by the State Water Resources Control Board and/or RWQCB. • Section 402 establishes the National Pollutant Discharge Elimination System (NPDES), which is a permitting system for the discharge of any pollutant (except for dredge or fill material) into waters of the U.S. In California, this permit program is administered by the RWQCBs, and is discussed in detail below.

National Pollutant Discharge Elimination System
The CWA has nationally regulated the discharge of pollutants to waters of the U.S. (e.g., streams, lakes, bays, etc.) from any point source since 1972. In 1987, amendments to the CWA added Section 402(p), which established a framework for regulating nonpoint source stormwater discharges under the National Pollutant Discharge Elimination System (NPDES) permit program.

These regulations are implemented at the regional level by the Regional Water Quality Control Boards (RWQCBs). The City of San Carlos is within the jurisdiction of the San Francisco Bay RWQCB.

State
State Water Resources Control Board
Created by the California State Legislature in 1967, the State Water Resources Control Board (SWRCB) holds authority over water resources allocation and water quality protection within the State. The five-member SWRCB allocates water rights, adjudicates water right disputes, develops statewide water protection plans, establishes water quality standards, and guides the nine RWQCBs. The mission of the SWRCB is to, “preserve, enhance, and restore the quality of California’s water resources, and ensure their proper allocation and efficient use for the benefit of ---

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present and future generations.” The proposed project is under the jurisdiction of the San Francisco Bay RWQCB.

Porter-Cologne Water Quality Control Act
The state’s Porter-Cologne Water Quality Control Act, as revised in December 2007 (California Water Code Sections 13000-14290), provides for protection of the quality of all waters of the State of California for use and enjoyment by the people of California. It further provides that all activities that may affect the quality of waters of the state shall be regulated to obtain the highest water quality that is reasonable, considering all demands being made and to be made on those waters.

The Act also establishes provisions for a statewide program for the control of water quality, recognizing that waters of the state are increasingly influenced by interbasin water development projects and other statewide considerations, and that factors such as precipitation, topography, population, recreation, agriculture, industry, and economic development vary regionally within the State. The statewide program for water quality control is, therefore, administered most effectively on a local level with statewide oversight. Within this framework, the Act authorizes the SWRCB and RWQCBs to oversee the coordination and control of water quality within California.

Statewide Construction General Permit
The SWRCB has implemented an NPDES General Construction Permit for the State of California (Construction General Permit). For projects disturbing one acre or more of soil, a Notice of Intent (NOI) and Storm Water Pollution Prevention Plan (SWPPP) must be prepared by a qualified professional prior to commencement of construction. The Construction General Permit includes requirements for training, inspections, record keeping, and, for projects of certain risk levels, monitoring. The general purpose of the requirements is to minimize the discharge of pollutants and to protect beneficial uses and receiving waters from the adverse effects of construction-related storm water discharges.

Local
San Francisco Bay Basin Plan
The San Francisco Bay RWQCB regulates water quality in accordance with the Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan). The Basin Plan lists the beneficial uses that the San Francisco Bay RWQCB has identified for local aquifers, streams, marshes, rivers, and the San Francisco Bay, as well as the water quality objectives and criteria that must be met to protect these uses. The San Francisco Bay RWQCB implements the Basin Plan by issuing and enforcing waste discharge requirements, including permits for nonpoint sources such as the urban ----

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runoff discharged by a City’s stormwater drainage system. The Basin Plan also describes watershed management programs and water quality attainment strategies.

Municipal Regional Permit Provision C.3.

The San Francisco Bay RWQCB most recently re-issued the Municipal Regional Stormwater NPDES Permit (MRP) in May 2022 to regulate stormwater discharges from municipalities and local agencies (co- permittees) in Alameda, Contra Costa, San Mateo, and Santa Clara Counties, and the cities of Fairfield, Suisun City, and Vallejo. Under Provision C.3 of the MRP, new and redevelopment projects that create or replace 10,000 square feet or more of impervious surface area are required to implement site design, source control, and Low Impact Development (LID)- based stormwater treatment controls to treat post-construction stormwater runoff. LID-based treatment controls are intended to maintain or restore the site’s natural hydrologic functions, maximizing opportunities for infiltration and evapotranspiration, and using stormwater as a resource (e.g., rainwater harvesting for non-potable uses). The MRP also requires that stormwater treatment measures be properly installed, operated, and maintained.

In addition to water quality controls, the MRP requires new development and redevelopment projects that create or replace one acre or more of impervious surface to manage developmentrelated increases in peak runoff flow, volume, and duration, where such hydromodification is likely to cause increased erosion, silt pollutant generation, or other impacts to local rivers, streams, and creeks.

Projects may be deemed exempt from these requirements if they do not meet the minimum size threshold, drain into tidally influenced areas or directly into the Bay, or drain into hardened channels, or if they are infill projects in subwatersheds or catchment areas that are greater than or equal to 65 percent impervious.

San Mateo Countywide Water Pollution Prevention Program The San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) is the local agency responsible for the oversight of implementation of the applicable provisions, including Provision C.3, of the MRP by local jurisdictions within San Mateo County.

San Carlos General Plan
The 2009 General Plan provides the fundamental basis for the City’s land use and development policy, and represents the basic community values, ideals and aspirations to govern a shared environment over the life of the General Plan. The General Plan includes the following elements:

Land Use; Housing; Circulation and Scenic Highways; Environmental Management; Parks and Recreation; Community Safety and Services; and Noise.

Goals, policies, and actions contained in the Environmental Management, Parks and Recreation, and Community Safety and Services Elements of the General Plan include those pertaining to the City’s stormwater system and runoff management. Under State law, the City’s General Plan is the

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primary planning document, and all other City plans and policies must be consistent with the adopted General Plan.

The General Plan Environmental Management, Parks and Recreation, and Community Safety and Services Elements include the following applicable policies:

Policy EM-5.1: Reduce the discharge of toxic materials into the city’s sanitary sewer and stormwater collection system by promoting the use of Best Management Practices (BMPs).

Policy EM-5.2: Promote the use of less toxic household and commercial cleaning materials.

Policy EM-5.6: Continue public education programs on water issues working with water service providers, local non-profits and other environmental organizations, including conservation measures and BMPs for residents, businesses, contractors and City employees.

Policy EM-5.7: Encourage site designs that manage the quantity and quality of storm water run-off.

Policy PR-4.10: Integrate stormwater management onsite to the greatest extent possible for all parks facilities.

Policy CSS-2.1: Improve and maintain City storm drainage infrastructure in a manner that reduces flood hazards.

Policy CSS-2.2: Maintain a healthy riparian corridor in City-maintained flood control channels to reduce the risk of flooding due to erosion, siltation, blockage and heavy undergrowth.

Policy CSS-2.3: Maintain a strong and enforceable Stream Development and Maintenance Ordinance for all city creeks and their tributaries.

Policy CSS-2.4: Minimize impervious surfaces to reduce stormwater runoff and increase flood protection.

Policy CSS-2.8: Coordinate with neighboring jurisdictions on approaches to flooding and creek maintenance.

Policy CSS-2.12: Incorporate stormwater drainage systems in development projects to effectively control the rate and amount of runoff, so as to prevent increases in downstream flooding potential.

San Carlos Municipal Code, Title 13 Public Services, Chapters13.14 and 13.16 Chapter 13.14, Article II of the San Carlos Municipal Code implements the provisions of the federal Clean Water Act regarding discharge regulations and requirements for the City. It prohibits non-stormwater discharges to the City storm sewer system, and requires any person engaged in activities which will or may result in pollutants entering the City storm sewer system to undertake

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all practicable measures to reduce such pollutants. Examples of these activities cited in the ordinance include ownership and use of facilities which may be a source of pollutants such as parking lots, gasoline stations, industrial facilities, commercial facilities, stores fronting City streets, etc. Chapter 13.14, Article II further requires owners of property through which a watercourse passes, or such owner’s lessee or tenant, to keep and maintain that part of the watercourse within the property reasonably free of trash, debris, excessive vegetation and other obstacles which would pollute, contaminate or significantly retard the flow of water through the watercourse, and to maintain existing privately owned structures within a watercourse so that they will not become a hazard to the use, function or physical integrity of the watercourse. It also prohibits the property owner, tenant or lessee from removing healthy bank vegetation beyond what is necessary for maintenance, and from removing vegetation in such a manner as to increase the vulnerability of the watercourse to erosion. Article III establishes the City’s power of inspection enforcement of these regulations.

Chapter 13.16 describes the provisions allowing the City to collect storm drainage fees pursuant to Health and Safety Code Section 5471 et seq., on the tax roll. The fees are to be used only for the acquisition, construction, reconstruction, maintenance and operation of storm drainage facilities or programs, or to repay principal and interest on bonds issued for the construction or reconstruction of said storm drainage facilities, or to repay federal or state loans or advances made to the City for the construction or reconstruction of storm drainage facilities. (Ord. 1184 § 2 (part), 1995: Ord. 1153 § 2 (part), 1994).

Electricity and Natural Gas
State
Senate Bill 100
Officially titled, “The 100 Percent Clean Energy Act of 2018,” Senate Bill 100:
• Sets a 2045 goal of powering all retail electricity sold in California and state agency electricity needs with renewable and zero-carbon resources — those such as solar and wind energy that do not emit climate-altering greenhouse gases. • Updates the state’s Renewables Portfolio Standard to ensure that by 2030 at least 60 percent of California’s electricity is renewable.
• Requires the Energy Commission, Public Utilities Commission and Air Resources Board to use programs under existing laws to achieve 100 percent clean electricity and issue a joint policy report on SB 100 by 2021 and every four years thereafter. ---

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Local
San Carlos Municipal Code Section 15.04.080
San Carlos has adopted a reach code creating local energy standards to electrify new construction and achieve greenhouse gas reduction goals. The local amendments to the California Energy Code and Green Building Code require:
• New construction of all building types to be all-electric, with exceptions • Rooftop solar in non-residential and high-rise residential buildings • Electric vehicle charging readiness for all building types Solid Waste
State
Integrated Waste Management Act of 1989
The California Integrated Waste Management Act of 1989, also known as AB 939, requires that each city or county prepare a new integrated waste management plan. The act also required each city to prepare a Source Reduction and Recycling Element by July 1, 1991. Each Source Reduction and Recycling Element includes a plan for achieving a solid waste goal of 25 percent by January 1, 1995, and 50 percent by January 1, 2000. In 2011, AB 341 was passed, which directs the California Department of Resources Recycling and Recovery to require local agencies to include strategies to enable the diversion of 75 percent of all solid waste by 2020.

California Department of Resources, Recycling, and Recovery (CalRecycle) CalRecycle oversees, manages, and monitors waste generated in California. It provides limited grants and loans to help California cities, counties, businesses, and organizations meet the State waste reduction, reuse, and recycling goals. It also provides funds to clean up solid waste disposal sites and co-disposal sites, including facilities that accept hazardous waste substances and nonhazardous waste. CalRecycle develops, manages, and enforces waste disposal and recycling regulations, including AB 939 and SB 1016 (see below).

Assembly Bill 939
The California Integrated Waste Management Act of 1989, or AB 939, established the Integrated Waste Management Board, required the implementation of integrated waste management plans, and mandated that local jurisdictions divert from the landfill at least 50 percent of solid waste generated beginning January 1, 2000, and divert at least 75 percent by 2010. Projects that would have an adverse effect on waste diversion goals are required to include waste diversion mitigation measures.

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Senate Bill (SB) 1016
This requires that the 50 percent solid waste diversion requirement established by AB 939 be expressed in pounds per person per day. SB 1016 changed the CalRecycle review process for each municipality’s IWMP. The CalRecycle Board reviews a jurisdiction’s diversion rate compliance in accordance with a specified schedule. Beginning January 1, 2018, the Board will be required to review a jurisdiction’s source reduction and recycling element and hazardous waste element every two years.

Assembly Bill 341
AB 341 (2011) sets forth the requirements of the statewide mandatory commercial recycling program for businesses that generate four or more cubic yards of commercial solid waste per week and multi-family dwellings with five or more units in California. AB 341 sets a statewide goal for 75 percent disposal reduction by the year 2020.

Assembly Bill 1826
AB 1826 (2014) sets forth the requirements of the statewide mandatory commercial organics recycling program for businesses and multi-family dwellings with five or more units that generate two or more cubic yards of commercial solid waste per week. AB 1826 sets a statewide goal for 50 percent reduction in organic waste disposal by the year 2020.

Senate Bill 1383
SB 1383 (2016) establishes targets to achieve a 50 percent reduction in the level of the statewide disposal of organic waste from the 2014 level by 2020 and a 75 percent reduction by 2025. The bill grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that at least 20 percent of currently disposed edible food is recovered for human consumption by 2025. On January 1, 2022, CalRecycle’s regulations to meet the organic waste reduction targets for 2025 took effect and became enforceable.

California Green Building Standards Code Compliance for Construction, Waste Reduction, Disposal and Recycling.

In January 2010, the State of California adopted the California Green Building Standards Code (“CALGreen”), establishing mandatory green building standards for all buildings in California.

The code covers five categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resources efficiency, and indoor environmental quality.

These standards include the following mandatory set of measures, as well as more rigorous voluntary guidelines, for new construction projects to achieve specific green building performance levels:
• Reducing indoor water use by 20 percent;

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• Reducing wastewater by 20 percent;
• Recycling and/or salvaging 65 percent of nonhazardous construction and demolition (“C&D”) debris, or meeting the local construction and demolition waste management ordinance, whichever is more stringent (see San Carlos-specific CALGreen building code requirements below); and
• Providing readily accessible areas for recycling by occupants.

Local
San Carlos General Plan
The 2009 General Plan provides the fundamental basis for the City’s land use and development policy, and represents the basic community values, ideals and aspirations to govern a shared environment over the life of the General Plan. The General Plan includes the following elements:

Land Use; Housing; Circulation and Scenic Highways; Environmental Management; Parks and Recreation; Community Safety and Services; and Noise.

Goals, policies, and actions contained in the Environmental Management Element of the General Plan include those pertaining to solid waste disposal and management. Under State law, the City’s General Plan is the primary planning document, and all other City plans and policies must be consistent with the adopted General Plan.

The General Plan Environmental Management Element includes the following applicable policies:

Policy EM-12.1: Work with the local waste management authority to increase community diversion of solid waste that meets or exceeds the targeted rate in the Climate Action Plan.

Policy EM-12.2: Minimize City government waste by expanding reduction, recycling and composting programs and practicing reuse.

Policy EM-12.3: Encourage the public and private sectors to utilize reusable, returnable, recyclable, environmentally-friendly products and repairable goods through incentives, educational displays and activities, as well as City purchasing policies and practices.

San Carlos Climate Mitigation and Adaptation Plan
The San Carlos CMAP includes a goal to transform San Carlos into a zero-waste community. The CMAP includes waste reduction strategies geared toward City operations and public events, waste haulers, and construction contractors, and actions that encourage community material reuse and repairs programs, compostable food service ware, increased composting, improved recycling, and sustainable food consumption. CMAP strategies aimed at reducing construction and demolition waste include:
• Incentivize the recycling of construction debris by working with regional partners. ----

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• Research and consider providing financial incentives to encourage the recycling of construction debris.
• Determine how certain construction materials may be donated and reused to help those in need by working with local community based organizations and construction companies.

San Carlos Recycling and Diversion of Construction and Demolition Debris Ordinance Chapter 8.05 of the San Carlos Municipal Code requires projects that qualify for coverage under CALGreen that generate waste comprised of mixed debris, including both structural debris (e.g., wood, metal, wallboard) and inert materials (dirt, asphalt, brick, and/or cinderblock), to divert at least 60 percent of all generated tonnage. All project applicants are required to submit a properly completed “waste management plan” (WMP) to the City Department of Planning and Building’s WMP Compliance Official, as a portion of the building or demolition permit process. The completed WMP must indicate, at minimum, all of the following:
• The estimated volume or weight of project construction and demolition debris, by materials type, to be generated;
• The maximum volume or weight of such materials that can feasibly be diverted via reuse or recycling;
• The vendor or facility that the applicant proposes to use to collect or receive that material; and
• The estimated volume or weight of construction and demolition debris that will be land filled.

Project contractors are required to keep records in tonnage or in other measurements approved by the WMP Compliance Official. Project applicants must also pay and administrative fee and submit a deposit for each estimated ton of construction and/or demolition debris that equals no less than one thousand dollars (the deposit). The deposit is returned to the project applicant upon proof to the satisfaction of the WMP Compliance Official that no less than the required percentages of the waste tonnage of construction and demolition debris generated by the project have been diverted from landfills and have been recycled or reused or stored for later reuse or recycling.

San Carlos Mandatory Organic Waste Disposal Reduction Ordinance Chapter 8.60 of the San Carlos Municipal Code implements the provisions of AB 1826, which requires businesses and multi-family complexes (with five or more units) that generate specified amounts of organic waste (compost) to arrange for organics collection services. The ordinance contains requirements for single-family organic waste generators, multifamily residential dwellings, and Tier One and Tier Two commercial businesses. Under the ordinance, a Tier One commercial edible food generator is defined as a commercial edible food generator that is either a supermarket, a grocery store with a total facility size equal to or greater than 10,000 square feet, a food service provider, a food distributor, or a wholesale food vendor. A Tier Two commercial edible food generator is defined as either a restaurant with 250 or more seats (or a total facility size

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equal to or greater than 5,000 square feet, a hotel with an on-site food facility 200 or more rooms, a health facility with an on-site food facility and 100 or more beds, a large venue, a large event, a State agency with a cafeteria with 250 or more seats or total cafeteria facility size equal to or greater than 5,000 square feet, or a local education agency facility with an on-site food facility.

4.15.3 Thresholds of Significance
Per the CEQA Guidelines, implementation of the project would have a significant impact related to utilities and service systems if it would:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects;
b) Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years; c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the projected demand in addition to the provider’s existing commitments;
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or e) Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

4.15.4 Impacts and Mitigation Measures
This section describes utility impacts which could result from the implementation of the project and recommends mitigation measures, as needed, to reduce significant impacts.

Impact UTS-1 – The project would not require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects. (Less Than Significant Impact)
Analysis of Impacts
Development associated with implementation of the project would result in increased demand for utility services. This growth could require the expansion of existing utility infrastructure to accommodate new development. The proposed project does not include any specific proposals for new utility facilities, and all future infrastructure projects subject to CEQA would be required to undergo project specific environmental review t to evaluate impacts at the time of their proposal.

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4.15-22 San Carlos Focused General Plan Update Draft EIR October 2022
Water
As described above, the project area is served by two local domestic water providers: the California Water Service Company (Cal Water) and the Mid-Peninsula Water District. All the housing inventory sites identified within the Housing Element Update are within the Cal Water MidPeninsula District service area.

The proposed Housing Element and Environmental Safety and Public Services Element contain the following goals, policies, and actions relevant to this analysis:

Action HOU-1.2 - Residential Rehabilitation Programs. As CDBG funds are available through San Mateo County Consortium, provide grants or loans to Low and moderate-income households for the rehabilitation of residences. Examples of eligible repairs and improvements include but are not limited to energy efficiency and water conservation improvements, removal of impediments and material barriers that obstruct accessibility, roofing, plumbing repairs, electrical repairs, exterior painting, window replacement, seismic and flooding safety repairs/adaptations, and climate resiliency adaptations.

Goal ESPS-13 - Ensure adequate public services and high-quality design of public facilities to make San Carlos as safe, enjoyable, and quality community in which to live, work and shop.

Policy ESPS-13.2: Establish and regularly monitor levels of service of San Carlos’ public facilities and services.

Policy ESPS-13.4: Work with all special districts, including the school districts, to ensure that development within the city is coordinated with provision of services.

Policy ESPS-13: Approve rezoning and development permits only when adequate services are available, or when a program to provide services has been approved by the applicable district and the City.

Policy ESPS-13.9: Ensure that adequate public services and facilities are planned and constructed to accommodate the population of the city.

Action ESPS-13.1: Define acceptable service levels for San Carlos’ public facilities and services.

Action ESPS-13.2: Annually update the City’s long-range Capital Improvements Program.

The Program shall continue to address all City facilities that are included in the development impact fee program, facilities needed to solve existing deficiencies and to accommodate projected growth and shall include a funding and phasing program for provision of facilities in not less than five-year increments through the end of the updated planning period. Encourage all special districts serving San Carlos to do the same. ----

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San Carlos Focused General Plan Update Draft EIR 4.15-23 October 2022
Cal Water, as the water supplier, is required to prepare a UWMP, which provides a framework for long term water supply and evaluates existing water conservation efforts. The UWMP is required to be updated every five years. As described in the UWMP, Cal Water Mid-Peninsula District is expected to have adequate water supplies during normal years to meet its projected demands through 2045, but is expected to experience shortfalls during single dry and multiple dry year conditions as a result of Bay-Delta Plan Amendment implementation. Currently there are uncertainties regarding the implementation of the Bay-Delta Plan Amendment and the resultant allocation of the available supply to the District. Cal Water has developed a Water Shortage Contingency Plan to address potential water shortage conditions.

Given the projections associated with the RHNA, which would result in more development than was projected in the UWMP, it is possible that new or expanded facilities may be needed to meet water demand. Any future expansion of existing facilities or construction of new facilities would be required to undergo environmental review pursuant to CEQA. Water-related impacts would be identified, along with measures to mitigate any significant impacts, as part of the CEQA compliance process for future project-specific proposals. This potential impact would be considered less than significant.

Wastewater
The SVCW WWTP has a capacity to treat 29.5 MGD, but currently receives approximately 20.0 MGD from customers in the SVCW service area. As described in the General Plan EIR, of the total capacity, the City of San Carlos is allocated a total treatment capacity of 4.47 MGD. The San Carlos flow wastewater projection for residential and existing non-residential uses by the year 2035 is 3.16 MGD, which would result in 1.31 MGD of capacity remaining within San Carlos allocation.

While there would likely be existing wastewater facility capacity to treat the additional demand associated with the proposed project, this facility serves other jurisdictions as well and it is possible that new or expanded facilities may be needed to meet wastewater demand. Any future expansion of existing facilities, or construction of new facilities, would be required to undergo environmental review pursuant to CEQA. This potential impact would be considered less than significant.

Stormwater Drainage
As the majority of development associated with implementation of the proposed project would occur within already developed urban areas, there would not be a substantial increase in impervious surfaces associated with implementation of the project. Any new development would need to adhere to applicable permit requirements, including the new development provisions of the MRP that limit impervious surface area and require the implementation of on-site runoff treatment measures. This potential impact would be considered less than significant.

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Electricity, Natural Gas, and Telecommunications
The potential increase in population associated with implementation of the project could create the potential need for new or upgraded electric power, natural gas, and telecommunication facilities.

These projects, if proposed, would need to comply with adopted, mandatory environmental regulations, including CEQA. This potential impact would be less than significant.

Impact UTS-2 – The proposed project would not have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry year. (Less Than Significant Impact)
The most recent UWMP for the project area was prepared in June 2021. The Cal Water MidPeninsula District’s water service area does not include all areas of the City, but does include the inventory sites identified within the Housing Element Update. The projected population used within the existing UWMP is based on 2040 population, housing, and employment projections developed by ABAG; these projections identified an increase of 335 housing units over the next 20 years.

Since preparation of the UWMP, ABAG projections have been updated for 2050 (Plan Bay Area 2050) and the RHNA has been identified for each jurisdiction. The City of San Carlos’s RHNA, including additional buffer units, is 3,595 units, which is more units than were evaluated within the current UWMP. As such, it is likely that implementation of the project would result in more demand for water than what was considered in the current UWMPs. The project is expected to require an additional 826,500 gallons per day or 825.8 acre-feet per year. Future updates to the Cal Water Mid-Peninsula District UWMP would need to reflect the updated projections associated with the project. As noted above in the regulatory section, Government Code §65589.7 requires new Housing Elements be provided to water and sewer services providers immediately upon adoption so they may be accounted for in the next UWMP.

The General Plan does include several water supply policies including:

Policy EM-5.3: Promote the conservation and efficient use of water in new and existing residences and by commercial and industrial consumers.

Policy EM-5.4: Encourage the use of drought-tolerant plants and efficient watering techniques for all City landscaping.

Policy EM-5.5: Recycled water distribution system (purple pipe) should be used for landscaping and other non-potable water uses for residential, commercial and industrial customers, where technically and financially feasible.

Policy EM-5.8: Work with water service providers to provide high quality domestic water.

Policy EM-5.10: Require the evaluation of potential groundwater depletion that could occur from new development through dewatering.

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In addition, the Environmental Safety and Public Services Element Update includes Policies ESPS-13.4, ESPS-13.8, and ESPS-13.9, as listed above in the response under Impact UTS-1, including approving developments only when adequate services are available, or when a program to provide services has been approved by the applicable district and the City and coordination with service providers for adequate service.

Furthermore, as specific projects are proposed within the project area, potential water-related impacts would be evaluated and identified, along with measures to mitigate any significant impacts, as part of the CEQA compliance process for future project-specific proposals. In adherence with SB 610, any new development project subject to CEQA that meets specific development specifications, such as residential development with over 500 dwelling units, would need to complete a Water Supply Assessment (WSA).

These policies and planning procedures ensure future projects do not result in significant impacts to water supply.

Impact UTS-3 – The project would not result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the projected demand in addition to the provider’s existing commitments. (Less Than Significant Impact)
The SVCW WWTP has a capacity to treat 29.5 MGD, but currently receives approximately 20.0 MGD from customers in the SVCW service area. As described in the General Plan EIR, of the total capacity, the City of San Carlos is allocated a total treatment capacity of 4.47 MGD. The San Carlos flow wastewater projection for year 2035 is 3.16 MGD, which would result in 1.31 MGD of capacity remaining within San Carlos allocation. If it is assumed that each residential unit associated with implementation of the Housing Element Update had a wastewater generation rate of 160 GPD (gallons per day), this would result in generation of approximately 575,200 GPD of wastewater. This would fall within the 1.31 MGD capacity remaining within the San Carlos allocation.

Furthermore, as specific projects within the project area are proposed, potential wastewater system-related impacts would be evaluated and identified, along with measures to mitigate any significant impacts, as part of the CEQA compliance process for future development proposals.

All new development and redevelopment would be required to pay applicable sewer connection and capacity charges. As described in Section 13.04.025 of the Municipal Code, the purpose of the sewer capacity charge is to recover costs for the City’s sewer system infrastructure and assets that provide benefit to (1) new connections to the sanitary sewer system, and (2) existing sanitary sewer connections that increase wastewater discharge, such as due to redevelopment or changes in property use. These charges are used to pay for improvements and expansion of sewer facilities, including the wastewater collection system, and any other purpose allowed by State and Federal law.

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4.15-26 San Carlos Focused General Plan Update Draft EIR October 2022
It should be noted that this wastewater facility serves other jurisdictions as well, and it is possible that incremental increases in demand, as anticipated under the project, and in conjunction with increased demand for other communities, could result in the need for future new or expanded wastewater treatment facilities. These projects, if proposed, would need to comply with adopted, mandatory environmental regulations, including CEQA. This potential impact would be considered less than significant.

Impact UTS-4 – The proposed project would not generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. (Less Than Significant Impact) The City would continue to implement a variety of solid waste reduction, recycling, and reuse measures to meet its obligation under AB 939.

Implementation of the project would result in an increase in residential units within the city, and an associated increase in solid waste generation. In order to estimate solid waste generation associated with implementation of the project, a per-capita waste generation rate of four pounds per day per resident was used. Implementation of the proposed project is estimated to result in a population increase of approximately 9,240 residents, and the net new waste generated associated with the increase in residents would be 36,960 pounds per day or 6,745 tons per year.

The Corinda Los Trancos Landfill (Ox Mountain) currently has a throughput limit of 3,598 tons per day and is expected to remain operational through 2034. 12 The increase in solid waste
associated with implementation of the project would be less than one percent of the landfill’s daily capacity. As this facility does provide service to other jurisdictions, there is a possibility of exceeding the landfill’s capacity. Any proposed new or expanded solid waste facility would need to comply with adopted, mandatory environmental regulations, including CEQA. This potential impact would be less than significant.

Impact UTS-5 – The proposed project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste. (Less Than Significant Impact) Any individual future project completed under the proposed Focused General Plan Update would be required to comply with all applicable federal, state, and local statues and regulations related to solid waste management and reduction. This impact would be less than significant.

4.15.5 References
Association of Bay Area Governments. Projections 2040 by Jurisdiction. Accessed on August 19, 2022 at http://projections.planbayarea.org/
12 CalRecycle, 2022. SWIS Facility/Site Activity Details Corinda Los Trancos Landfill (Ox Mtn), website:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223 (accessed August 26, 2022).

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San Carlos Focused General Plan Update Draft EIR 4.15-27 October 2022
California Department of Finance. 2022. E-1: City/County/State Population Estimates with Annual Percentage Change. January 1, 2021 and 2022. Accessed on August 29, 2022 at:
https://dof.ca.gov/wp-content/uploads/Forecasting/Demographics/Documents/E1_2022PressRelease.pdf California Department of Finance 2022b. E-5 Population and Housing Estimates for Cities, Counties and the State 2020-2022. Accessed on August 29, 2022 at: E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020-2022 | Department of Finance (ca.gov) and
https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fdof.ca.gov%2Fwpcontent%2Fuploads%2FForecasting%2FDemographics%2FDocuments%2FE5_2022_InternetVersion.xlsx&wdOrigin=BROWSELINK California Water Service. 2022. San Carlos 2021 Water Quality Report. Accessed on August 19, 2022 at: https://www.calwater.com/ccrs/bay-sc-2021/
California Water Service. 2022. 2020 Urban Water Management Plan, Mid-Peninsula District.

June.

CalRecycle. 2022. SWIS Facility/Site Activity Details Corinda Los Trancos Landfill (Ox Mountain). Accessed on August 26, 2022 at:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223 City of San Carlos Public Works Department. 2022. San Carlos Sewer System General Information. Accessed on August 19, 2022 at:
https://www.cityofsancarlos.org/home/showpublisheddocument/848/636571580313500000 City of San Carlos. 2017. Citywide Storm Drain System Master Plan, April.

Design, Community & Environment. 2009. San Carlos 2030 General Plan EIR, June 25.

RethinkWaste. 2022. Accessed on August 25, 2022 at:
https://rethinkwaste.org/about/rethinkwaste/about/
Silicon Valley Clean Water. 2020. Capital Improvement Program, 2020 Update, FY20-21 to FY29-30.

Wreco. 2014. Belmont Creek Watershed Study, Creek Assessment, and Recommendations for Sustainable Improvements San Mateo County, California, September 2014.

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Chapter 4.16 Wildfire
San Carlos Focused General Plan Update Draft EIR 4.16-1 October 2022

4.16 WILDFIRE

4.16.1 Environmental Setting
San Carlos’ foothill neighborhoods west of Alameda de las Pulgas are designated Very High Fire Hazard Severity Zones (VHFSZ) by the California Department of Forestry and Fire Protection (CAL FIRE). Fire protection in California is the responsibility of either the federal, state, or local government. In State Responsibility Areas (SRA), which are defined according to land ownership, population density, and land use, CAL FIRE has a legal responsibility to provide fire protection.

Local Responsibility Areas (LRA) include incorporated cities and cultivated agriculture lands. In LRA, fire protection is provided by city fire departments, fire protection districts, or counties, or by CAL FIRE under contract to local government. All VHFHZ areas in San Carlos are in LRA.

The Heather Elementary School and many homes in the western hills are located within the VHFSZ. Other nearby schools include Carlmont High School, Tierra Linda Middle School, Mariposa Upper Elementary School, and San Carlos Charter Learning Center. Additionally, the Bayview Villa, an assisted living community, is within the unincorporated Devonshire Area.

Several California Water Services (Bay Area Region) water tanks are located in the western hills, including at the intersection of Los Vientos Way and Crestview Drive, off of Crestview Drive near Crestview Park, on Melendy Drive near Crestview, on Melendy Drive near Heather School, and off of Heather Drive near Melendy Drive.

San Carlos fire service is provided under contract by the City of Redwood City Fire Department.

It provides fire protection, hazardous materials response, disaster preparedness, and emergency medical response. CAL FIRE has a legal responsibility to provide fire protection to all within the State Responsibility Area. A portion of the San Carlos Sphere of Influence is under the SRA.

Portions of unincorporated San Mateo County (Devonshire and Palomar Park) are within the City’s SOI, see Figure 4.16-1. While these unincorporated pockets are within the City’s SOI, they are subject to the planning goals, policies, and actions, land use and zoning of the San Mateo County General Plan. Wildfire and other safety hazards associated with development within unincorporated County lands would be addressed in the San Mateo County Safety Element.

Emergency and Disaster Preparedness
As required by State law, the City of San Carlos has established emergency preparedness procedures to respond to a variety of natural and built environment disasters that could affect the community. In the event of an emergency, the City will respond according to the Standardized Emergency Management System (SEMS) developed by the State. The SEMS system establishes a hierarchy of response, with local government as the first responders. If San Carlos does not have sufficient resources to respond to a disaster, the County of San Mateo would lend resources.

Mutual Aid agreements between various agencies would be enacted all the way to the State level.

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Focused General Plan Update
Figure 4.16-1 Wildfire Hazards
Fire Hazard Severity Zones
Moderate
High
Very High
I:::::::::::: :I l ocal Responsibility Area (LRA)
State Responsibility Area (SRA)
0 Fire Station
All fire hazard severity zones within San Carlos city limits are within the San Carlos Local Responsibility Area for fire emergency response. All other fire haza rd seve ri ty zones illustrated in this map arc within the State
Responsibility Area or other Local Responsibility Areas.

Base M ap Features
- - - · City of San Ca rlos Boundary
Sphere of Influence
--- Major Streets
Streets
---t:Jt-- Caltrain Ra ilroad and Stations
Surrounding Jurisdictions
Pa rks and Open Space
Waterbodies
San Carlos Airport
August2020
Sources: llnitt'dStaleiCemusBu,eau,2019.StateofCaliforniaDepartment ofForestryandFheProte<tion,OtyofSanCarlos,CoumyofSanMateo, llrbanfootprint,2020.

B EL MON T
, .... ,,,,' ""'¼: I r-,... ) <t. ,, : . \
.

I
: Pu/ga s R,dg I I . . ,
. . .
• , ....
.--\
'
an Mateo Count Fire Station •;
I
I ••• ~-
., .,. ·::: .
. · 1
Palomar Park
-------------------

SAN MA T EO COUNTY
/ '
~'
,,q...~
'°" X ~'n [, >< re'<','?
!f:n 16 ~ / " ,-- .Y
< />
Bair
Island
Smith Slough
0 ____ l"'" ___________ Mile
0 ¼ ½ 1

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Chapter 4.16 Wildfire
San Carlos Focused General Plan Update Draft EIR 4.16-3 October 2022
San Carlos established an Emergency Operations Center (EOC) program in 1987. The Emergency Response Plan establishes evacuation routes, identifies agencies responsible for emergency response and summarizes and assesses potential threats and hazards. Additionally, as required by California Government Code 3100, all City employees will report to City Hall, after ensuring the welfare of their families, to assist in emergency response in the event of a disaster.

The San Mateo County Department of Emergency Management (DEM) coordinates countywide preparedness, response, and protection services and activities for large-scale incidents and disasters. The DEM is responsible for alerting and notifying appropriate agencies within the county's 20 cities when disaster strikes; coordinating all agencies that respond; ensuring resources are available and mobilized in times of disaster; developing plans and procedures in response to and recovery from disasters; and developing and providing preparedness materials for the residents. DEM also maintains the County's Regional Operations Center and provides a duty officer on a 24-hour basis to address county, local, and State officials on matters of potential or escalating emergency conditions. The Emergency Services Council, which consists of a representative from each of the 20 incorporated cities and a member of the County Board of Supervisors, governs the DEM.

SMC Alert
SMC Alert is a software application used to send emergency alerts, notifications, and updates to cell phones, mobile devices, home phones, work, and/or e-mail accounts. In the event of an emergency, public safety agencies such as the City of San Carlos are able to provide emergency information directly to the community. These messages provide the community with instructions, orders, and updates.

The SMC Alert system is managed by the DEM. The service is free to all and is available to all cities, towns, and special districts within San Mateo County. Alerts may also be sent by local fire, police, and emergency operations managers from other cities within San Mateo County. Alert types may include life safety, fire, weather, accidents involving utilities, or roadway or disaster notifications.

Zonehaven
San Carlos implements the San Mateo County’s Zonehaven evacuation system. Zonehaven determines the most efficient and effective evacuation routes based on the emergency type and location. Evacuation routes will vary; however, Figure 4.16-2 identifies the roadways most frequently used for evacuations.

Landslide
When a wildfire burns the vegetation that helps to stabilize slopes, hillsides may be more likely to slide. Rainstorms that occur following wildfires can potentially destabilize slopes further, leading to post-fire debris flows.

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Focused General Plan Update
Figure 4.16-2 Evacuation Routes
Evacuation Routes
Base Map Features
---· CityofSanCarlosBoundary
-------- Sphereof lnfluence
---- Major Streets
Streets
-+-fl--+- Caltrain Railroad and Stations
Surrounding Jurisdictions
Parks and Open Space
Waterbodies
San Carlos Airport
January2022
Sources:UnrtedStatesCensusBureau,2019.
(ityofSan(arlos,CountyofSanMateo,UrbanFootprint2020

BELMONT
/•,.
-~~\ Devonshire
\ . " r--l·· ,.....,, ·--..: , ·, ·, Crystal
Springs ,,<' ,,,' ,,
! ;""""
\ \ ,, ' 1-----.
,, \. ~ . / Pu/gas Ridge '• ,
,: \. I \
I ' L
,..... '
•,,-- ", , Pulgas Ridge Open Spacc ,..,
' ' ' ' ' ' ' ' ' '-•--; I
I
~----- Edgewood Park and
Natural Preserve
Palomar Park

SAN MATEO COUNTY
Bair
Island
Smith Slough

DWOOD C Y
0 ____ ,. ___________ Mile
0 ¼ ½ 1

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Chapter 4.16 Wildfire
San Carlos Focused General Plan Update Draft EIR 4.16-5 October 2022
Chapter 4.6 Geology presents Figure 8-5 of the proposed Environmental Safety and Public Services Element, which shows the landslide hazards areas in San Carlos. The best predictor of where slides might occur is the location of past movements. Landslides occur on some of the upper hilly slopes, more commonly in the northwestern area of the City.

4.16.2 Regulatory Setting
Federal Regulations
Federal Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 authorizes the Federal Emergency Management Agency (FEMA) to set mitigation planning requirements for state, local, and Indian Tribal governments as a condition of mitigation grant and disaster assistance, and requires close coordination of mitigation planning and implementation efforts between FEMA and jurisdictions.

Healthy Forest Restoration Act of 2003
This Act calls for preparation of Community Wildfire Protection Plans (CWPP) as planning and funding prioritization tools to create incentives for communities to engage in comprehensive fire hazard planning and to help define and prioritize local needs.

State Regulations
California Department of Forestry and Fire Protection (CAL FIRE) CAL FIRE protects life and property through fire prevention engineering programs, law and code enforcement and education. CAL FIRE identifies areas within LRAs and recommends fire hazard severity zones; CAL FIRE also designates fire hazard severity zones for areas within SRAs. Cal FIRE will review and approved the City’s wildfire section of the Environmental Safety and Public Services Element.

California Climate Adaptation Strategy (2021)
The California Climate Adaptation Strategy is formulated to strengthen protections for climate vulnerable communities. Part of this Strategy relates to wildfire risk and prevention, such as improving and refining quantitative wildfire risk assessments across California to identify the most wildfire vulnerable communities and populations; supporting wildfire prone communities by expanding the Regional Forest and Fire Capacity Program and increasing local and regional government capacity to build and maintain projects to improve forest health and prevent wildfire; and reducing health impacts of wildfire smoke (including improving wildfire smoke guidance for schools, children, and other vulnerable populations). The Strategy also identifies the need to reduce risk from energy infrastructure-related ignitions that can lead to wildfire. In addition, the Strategy promotes “climate smart” forest management – such as reintroducing prescribed fire onto landscapes – as a means to reduce the threat of wildfire; supports increase in the pace and scale of wildfire resilience and forest health projects; and calls for reducing wildfire risks through increased

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Chapter 4.16 Wildfire

4.16-6 San Carlos Focused General Plan Update Draft EIR October 2022
use of fuel breaks and fuels reduction and expediting the permitting of wildfire resilience projects using exemptions or the California Vegetation Treatment program.

General Plan Safety Element Review: Government Code 65302.5 The Board of Forestry and Fire Protection must provide recommendations to a local jurisdiction’s general plan safety element at the time that the general plan is being amended. Board recommendations include goals and policies that provide for contemporary fire-prevention standards for the jurisdiction. This is not a direct and binding fire prevention requirement for individuals.

Sprinkler Systems: California Residential Code, Chapter 3, Section R313 All new dwellings, dwelling units, and one- and two-family townhomes must be equipped with an automatic fire-sprinkler system that can protect the entirety of the dwelling. Dwellings and homes constructed prior to January 1, 2011 that do not have a sprinkler system may be retrofitted, but it is not required.

Fire Safety Standards: California Public Resources Code 4290 and 14 California Code of Regulations (CCR) 1270
These regulations govern roads, driveway width, clearance, turnarounds, signing, and water related to fire safety throughout California. Public Resources Code 4290 is typically enacted through regulation at the county level, as described below.

Wildland-Urban Interface Building Standards: California Government Code 51189 The Office of the State Fire Marshal is required to create building standards for wildfire resistance.

Construction of buildings in the wildland-urban interface must use fire-resistant materials to save life and property. As of 2011, the standards relevant to fire-safe construction for all new structures in the SRA are the California Building Code, Chapter 7A (for commercial construction) and the California Residential Code, Chapter 3, Section R327 (for residential construction).

Government Code §51175-51189 Fire Safe Regulations: Minimum fire safety standards gives the State Board of Forestry the authority to adopt regulations for minimum fire safety standards applicable to SRA lands under the authority of the department, and to VHFHSZs starting on July 1, 2021. The Fire Safe regulations are codified in CCR, Title 14 (Natural Resources), Division 1.5 (Department of Forestry), Chapter 7 (Fire Protection) under Subchapter 2 (SRA Fire Safe Regulations). These regulations generally address the following:
• Standards for signs identifying streets, roads, and buildings. • Minimum private water supply reserves for emergency fire use. • Fuel modification standards for fuel breaks and greenbelts. • Road and driveway standards for emergency fire equipment access and public evacuation.

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State Responsibility Area: Public Resources Code 4102, 4125-4229 and 14 CCR 1220 These statutes and regulations establish the locations where CAL FIRE has the financial responsibility for preventing and suppressing fires. These designations define financial arrangements for fire protection services and establish the locations where fire safe and defensible space laws or regulations apply.

Defensible Vegetation Clearing Around Structures: Public Resources Code 4291/14 CCR 1299 Public Resources Code 4291 regulates fuel management around a property. It states that a person who owns or controls a building or structure in or adjoining to forest, brush, or grass covered lands shall follow certain guidelines outlined in the code. At least 100 feet of defensible space is required.

The owner of the property is liable for making these changes to protect habitable structures. The 100 feet is separated into two zones, with the closer zone, 30 feet out from the structure, being managed more intensively.

AB 38 (2019) California Wildfire Mitigation Financial Assistance Program (Government Code §8654.7 and §8654.10; Public Resources Code §8389.5)
Established a comprehensive wildfire mitigation financial assistance program to encourage costeffective structure hardening and retrofitting to create fire-resistant homes, businesses, and public buildings. The bill required the State Fire Marshal, in consultation with specified State officials, to identify building retrofits and structure hardening measures, and CAL FIRE to identify defensible space, vegetation management, and fuel modification activities, that are eligible for financial assistance under the program. The bill specifies the types of designated wildfire hazard areas eligible for funding under the program.

AB 1823 (Committee on Natural Resources, 2019) Fire Risk Reduction Communities (Public Resources Code §4290.1)
This bill amended PRC Section 4290.1 to require that, on or before July 1, 2022, the State Board develop criteria for and maintain a list of local agencies considered to be a “Fire Risk Reduction Community” located in the SRA or VHFHSZ, identified pursuant to GC§51178, that meet best practices for local fire planning. Criteria that must be used to develop the Fire Risk Reduction Community list include recently developed or updated CWPPs, adoption of the board’s recommendations to improve the Safety Element, participation in Fire Adapted Communities and Firewise USA programs, and compliance with the Board’s minimum fire safety standards. For example, any new road in the SRA will need to comply with State regulations governing access.

Standards extend to road steepness, curvature, and width.

California Fire Code (California Code of Regulations, Title 24, Part 9) The City of San Carlos has adopted the 2019 California Fire Code, with amendments to address specific local conditions and needs. These provisions include construction standards and fire

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hydrant requirements, road widths and configurations designed to accommodate the passage of fire trucks and engines, and requirements for the handling and storage of hazardous materials.

California Code of Regulations, Title 19
Title 19, chapters one through six of the California Code of Regulations (CCR), establishes regulations related to emergency response and preparedness under CAL Emergency Management Agency.

California Health and Safety Code (Sections 13000 et seq.) This statute establishes State fire regulations, including regulations for building standards (also set forth in the California Building Code), fire protection and notification systems, fire protection devices such as extinguishers and smoke alarms, high-rise building and childcare facility standards, and fire suppression training.

Recent State Legislative Initiatives
The following are recent State of California legislative initiatives that show the direction the State is taking in proactively addressing increased wildfire risks. They serve as a guide for planning for communities throughout California.
• SB 85: Wildfire Package (Chaptered on April 13, 2021): Includes $536 million to fund projects to restore the ecological health of forests and watersheds, fuel breaks around vulnerable communities, statewide fire prevention grants targeting projects to advance community hardening, and improvements to defensible space to mitigate wildfire damage. • AB 9: Creates Entity Dedicated to Wildfire Prevention Work and Regional Forest and Fire Capacity (Chaptered on September 23, 2021): Creates new branch in Office of the State Fire Marshal to focus exclusively on community fire prevention, preparedness, and mitigation efforts of CAL FIRE. Supports regional leadership to build local and regional capacity and develop, prioritize, and implement strategies and projects that create fire adapted communities and landscapes by improving ecosystem health, community wildfire preparedness, and fire resilience.
• AB 642: Enhance Fire Prevention Efforts (Chaptered on September 28, 2021): Directs the Director of the Department of Forestry and Fire Prevention to designate moderate and high fire hazard severity zones. Makes changes to State law to enhance wildland fire prevention efforts, including, incorporating, and facilitating cultural burning practices. Also requires the Director of the Department of Forestry and Fire Protection to designate a cultural burning liaison.
• SB 63: Fire Prevention; Vegetation Management (Chaptered on September 28, 2021):

Provides for fuel modification beyond the property line if necessary to maintain 100 feet of defensible space, as applicable; would also require State Fire Marshal and Department of Housing and Community Development to consider, if appropriate, expanding

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application of fire protection building standards (as specified for building in fire hazard severity zones) to expand application of these building standards to moderate fire hazard severity zones.
• AB 38 (Chaptered on October 2, 2019): California Wildfire Mitigation Financial Assistance Program: Established a comprehensive wildfire mitigation financial assistance program to encourage cost-effective structure hardening and retrofitting to create fireresistant homes, businesses, and public buildings. The bill required the State Fire Marshal, in consultation with specified State officials, to identify building retrofits and structure hardening measures, and CAL FIRE to identify defensible space, vegetation management, and fuel modification activities, which are eligible for financial assistance under the program. The bill specifies the types of designated wildfire hazard areas eligible for funding under the program. AB 38 also required on or after January 1, 2021, the seller of any real property located in a high or very high fire hazard severity zone to provide a prescribed disclosure notice to the buyer, if the home was constructed before January 1, 2020, of information relating to fire hardening improvements on the property and a list of specified features that may make the home vulnerable to wildfire and flying embers and which features, if any, that exist on the home of which the seller is aware. By July 1, 2025, requires the disclosure notice to also include the State Fire Marshal’s list of low-cost retrofits, and a specified final inspection report or information on where a copy may be obtained. Also requires on or after July 1, 2021, specified documentation to the buyer that the real property is in compliance with the wildfire protection measures or a local vegetation management ordinance, or enter into an agreement with the buyer pursuant to which the buyer will obtain documentation of compliance, as provided. • AB 2911 (Introduced in Assembly, Not Chaptered): Fire Safety included various changes to fire safety planning efforts including:
o Requires a local agency to transmit a copy of its adopted ordinance designating very high fire hazard severity (VHFHS) zones to the Board of Forestry and Fire Protection (Board);
o Removes exemptions from requirement that a local agency designate, by ordinance, very high fire hazard severity zones in its jurisdiction within 120 days of receiving recommendations from the director of CAL FIRE;
o Requires, before July 1, 2020, the Office of Planning and Research to update the guidance document entitled "Fire Hazard Planning General Plan Technical Advice Series" and update not less than once every eight years; o Authorizes the Board of Forestry, within 15 days of receipt of notification that its fire prevention recommendations will not be accepted by the local government, to request a consultation, prior to approval of the draft element or amendment, conducted in person, electronically, or by phone; and
o Requires on or before July 1, 2021, and every five years thereafter, the Board, in consultation with the State Fire Marshal (SFM), to survey local governments to identify

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existing subdivisions (more than 30 dwelling units) in State Responsibility Areas (SRA) or Very High Fire Hazard Severity (VHFHS) zones without a secondary egress route that are at significant fire risk.
• SB 99: General Plans: Safety Element (Chaptered on August 30, 2019): Emergency Evacuation Routes requires the safety element of the general plan, upon the next revision of the housing element on or after January 1, 2020, to identify any residential developments in any hazard area that does not have at least two emergency evacuation routes. • SB 1241: Land Use: General Plan Safety Element: Fire Hazard Impacts (Chaptered on September 13, 2012): Required cities and counties to address fire risk in the State Responsibility Areas (SRA) and Very High Fire Hazard Severity Zone (VHFHSZ) in the Safety Element of their general plans upon the next revision of the housing element and requires cities and counties to make certain findings regarding available fire protection and suppression services before approving a tentative map or parcel map. Requires review of Draft Safety Element by the Board of Forestry and CAL FIRE Land Use Planning Program staff, as well as to every local fire agency having jurisdiction. • SB 1260: Fire Prevention and Protection (Chaptered on September 21, 2018): Promoted long-term forest health and wildfire resiliency. It made various changes related to local fire planning, prescribed fire requirements, and broader fire prevention efforts, including the following:
o Requires a local agency to transmit a copy of its adopted ordinance designating VHFHS zones to the Board of Forestry and Fire Protection within 30 days of adoption; o Removed exemptions from the requirement that a local agency designate, by ordinance, VHFHS in its jurisdiction within 120 days of receiving recommendations from the director of CAL FIRE;
o Authorizes the Board to recommend changes to a planning agency's safety element for methods and strategies accepted as best practices in the most recent guidance document entitled "Fire Hazard Planning, General Plan Technical Advice Series"; o Requires a city or county that contains either SRA or VHFHS zones to notify the Board if it adopts or amends the safety element of its general plan; and o Requires, upon approving a tentative map or a parcel map for an area located in either the SRA or VHFHS zone, the local agency to transmit a copy of the minimum fire safety standards findings required and accompanying maps to the Board.

Regional Regulations
San Mateo County Multi-Jurisdictional Local Hazard Mitigation Plan (2021) The San Mateo County Department of Emergency Management is responsible for alerting and notifying appropriate agencies within the county's 20 cities (including San Carlos) when disaster strikes; coordinating all agencies that respond, ensuring resources are available and mobilized in

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times of disaster, developing plans and procedures in response to and recovery from disasters, and developing and providing preparedness materials for residents. In 2021, the San Mateo County Department of Emergency Management published a Multi-Jurisdictional Local Hazard Mitigation Plan, a large regional and cross-jurisdictional effort to plan for the reduction of risk from natural and other disasters.

The Local Hazard Mitigation Plan (LHMP) assesses hazard vulnerabilities and identifies mitigation actions that jurisdictions will pursue in order to reduce the level of injury, property damage, and community disruption that might otherwise result from such events. The LHMP addresses natural and human-caused hazards, including flooding, drought, wildfire, landslides, severe weather, terrorism, cyber threats, pandemic, and the impact of climate change on hazards, as well as other hazards.

Adoption of the Plan ensures the County and partner agencies remain eligible for various types of pre- and post-disaster community assistance, such as grants, from FEMA and the State government.

The City of San Carlos is a planning partner with San Mateo County and has assumed responsibility for adopting the recommendations of the plan and committing resources toward implementation of the action plan specific to San Carlos.

San Mateo County Fire Protection Regulations
Chapter 3.84 of the San Mateo County Code, Fire Protection Regulations, adopts the California Fire Code by reference and sets forth fire protection regulation pertinent to local conditions.

Section 3.84.100 requires fuel breaks around buildings of at least 30 feet, while considering the retention of existing landscaping and sensitive natural habitats. Section 3.84.120 requires compliance with the California Fire Code when constructing, relocating or altering a building.

Other sections of the Chapter include revisions to the California Fire Code regarding emergency vehicle access; fire alarms, hydrants and sprinklers; construction and other issues.

Santa Cruz and San Mateo County Community Wildfire Protection Plan (2018) The joint, Santa Cruz and San Mateo County Community Wildfire Protection Plan was updated in 2018. It is a tool for communities to identify landscape scale hazards and take strategic action to reduce wildfire risk for healthier ecosystems and more resilient communities. The plan assesses hazards and priorities within the two counties, identifies at-risk communities, and provides fuel reduction recommendations for high priority areas. The intent of the plan is to foster collaboration between communities for local action and to assist in planning, providing general guidelines to develop site-appropriate projects. The Community Wildfire Protection Plan can also aid communities to apply for state and federal funding for fire prevention projects and programs.

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Local
San Carlos Climate Mitigation and Adaptation Plan (2021) The 2021 Climate Mitigation and Adaptation Plan (CMAP) aims to reduce City-wide emissions 40% by 2030 and 80% by 2050 relative to 1990 levels and identifies strategies to achieve those targets. In addition, the CMAP recognizes the potential climate change impacts and vulnerabilities in the community and identifies strategies that support climate adaptation and resilience.

Sections of the Safety Element are supplemented by the CMAP, which is incorporated by reference, as allowed by California Government Code Section 65302(g).

San Carlos Safety Element Vulnerability Assessment
As required by California Senate Bill (SB) 379, adopted in 2015, a jurisdiction’s General Plan Safety Element must contain relevant climate adaptation and resiliency strategies. The Safety Element update must include the preparation of a Vulnerability Assessment that identifies the specific risks that climate change poses to the local jurisdiction. The 2021 San Carlos Safety Element Update Vulnerability Assessment includes an assessment of: (1) the community’s exposure to past, current, and projected climate hazards, and (2) responsible agencies and their ability to respond and address climate change impacts.

San Carlos Emergency Operations Plan (DRAFT, unpublished) The Emergency Operations Plan provides the framework, concepts, and policies of San Carlos’s emergency procedures and operations to ensure effective management and coordination of the City’s response to emergencies and disasters. It identifies roles and responsibilities for various individuals and departments related to preparedness, response, recovery, and mitigation activities.

The plan serves as a foundational document for other City plans, as well as a reference document for other government and non-government organizations and entities. It is intended to be used in concert with other related plans, such as mitigation, recovery, and continuity of operations to facilitate emergency response and short-term recovery functions for emergencies and disasters which are outside of the scope of normal City operations. This plan is regularly reviewed and updated by staff and approved by the City Council.

San Carlos General Plan
The following are the currently adopted General Plan policies related to wildfire and emergency response in the Community Safety and Services Element.

Goal CSS-3: Protect lives and property from risks associated with fire-related emergencies.

Policy CSS-3.1: Evaluate fire response needs of the Fire Department as new development and redevelopment continues within city limit.

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Policy CSS-3.2: Participate in fire prevention and life safety programs with neighboring jurisdictions and other governmental agencies as needed.

Policy CSS-3.4: Maintain participation with the Joint Powers Authority Agreement with all fire departments in San Mateo County to ensure required response times for initial emergency deployment personnel and equipment.

Policy CSS-3.5: Preserve the local government agreement with California Department of Forestry and Fire Protection (CAL FIRE) for responses in the Mutual Threat Zone (MTZ) within the Wildland Urban Interface Areas of the city. Continue to provide BSCFD equipment and personnel under the mutual aid agreement, with the State of California Office of Emergency Service (OES) Region II. This continued “reverse support” enables the City of San Carlos to receive “no cost” statewide mutual aid in the event of a declared large-scale emergency.

Policy CSS-3.6: Continue to enforce building code regulations that minimize fire hazards in areas subject to a very high fire severity zone (VHFSZ) risk west of Alameda de las Pulgas and prohibit any structural development in areas where wildland urban fire hazards cannot be mitigated under an agreement addressing alternate means of protection and materials agreement.

Policy CSS-3.7: Maintain City-owned open space lands in a manner that minimizes and reduces fire hazard threats to fixed public and private properties, by reducing hazardous vegetation fuels.

Policy CSS-3.8: Provide adequate access for fire and emergency service vehicles to new development in hillside areas, as per the International Fire Code and the Urban Wildland Interface Code.

Policy CSS-3.9: Support “early review” of proposed development by the Belmont-San Carlos Fire Department and institute impact fees to ensure adequate all-risk fire equipment for the community.

Policy CSS-3.10: Continue to require all new development to provide all necessary water service, fire hydrants and road improvements consistent with City standards and the California Fire Code.

Policy CSS-3.11: Ensure that in existing developed areas within the city there is an acceptable level of fire safety and emergency medical/paramedic services.

Policy CSS-3.12: Incorporate drought-resistant and fire resistant plants in capital improvement projects in areas that are subject to wildland fires.

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Policy CSS-3.13: Ensure that property owners maintain property in a manner that minimizes fire hazards through the removal of vegetation, hazardous structures and materials and debris as governed under the City Municipal Code for enforcement.

Action CSS-3.1: Update the City’s Community Wildfire Protection Plan as appropriate.

Action CSS-3.2: Enforce the established residential fire sprinkler ordinance.

Goal CSS-6: Continue effective emergency response procedures to ensure public safety in the event of natural or man-made disasters.

Policy CSS-6.1: Display leadership in the preparation for natural and man-made disasters by taking a proactive rather than a reactive approach.

Policy CSS-6.2: Preserve a Basic Emergency Operation Plan consistent with the National Incident Management System (NIMS).

Policy CSS-6.3: Maintain City Hall as the Emergency Operations Center (EOC) in San Carlos and provide for fully-functional back up EOC for City staff.

Policy CSS-6.4: Coordinate the preparation for natural and man-made disasters with the San Mateo County Office of Emergency Services, neighboring jurisdictions and other governmental agencies.

Policy CSS-6.5: Inform the public about disaster preparedness by providing information on supplies, training, evacuation routes, communication systems and shelter locations.

Policy CSS-6.6: Make available to the community, programs and resources relating to disaster preparedness.

Policy CSS-6.7: Support the efforts of neighborhood and civic organizations to prepare for disasters if City resources are not available.

Policy CSS-6.8: Identify and develop communication systems, evacuation methods, shelter locations and other services for special needs populations.

Policy CSS-6.9: Evaluate safety service limitations on an annual basis to provide for adequate levels of service.

Policy CSS-6.10: Identify potential emergency routes and suggest methods for operational needs for first responders.

Policy CSS-6.11: Establish the capability to re-locate critical emergency response facilities such as fire, police and essential services facilities, if needed, in areas that minimize their exposure to flooding, seismic effects, fire, or explosion.

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Policy CSS-6.12: Develop a procedure to quantify community emergency preparedness levels.

Action CSS-6.1: Evaluate the Emergency Operation Plan on an annual basis and revise as needed to promote disaster preparedness.

Action CSS-6.2: Coordinate emergency response procedures with acute care medical facilities in San Mateo County to ensure adequate preparedness for hospital patients and staff.

Action CSS-6.3: Participate in regional disaster event simulations semi-annually by using the primary EOC and methods for implementing a back-up EOC.

Action CSS-6.4: Create a back-up EOC for City staff. Enter into a shared EOC agreement with a neighboring jurisdiction or County in the event City Hall is rendered inoperable as an EOC.

Action CSS-6.5: Participate in San Mateo County OES preparedness exercises and disaster simulations.

Action CSS-6.6: Encourage City employees through a volunteer program to obtain training in disaster preparedness and basic first aid skills.

Action CSS-6.7: Maintain and enhance the community disaster preparedness programs.

Action CSS-6.8: Identify the need for community awareness and education programs for residents. Develop programs to respond to identified needs.

Action CSS-6.9: Disseminate semi-annually, disaster preparedness information to residents through the City web site, newsletters, e-notify, newspaper articles, or other methods.

Action CSS-6.10: Make available multi-language disaster preparedness information.

Action CSS-6.11: Identify and program for emergency supplies through the EOC program in public parks.

The project includes updating the 2030 General Plan, including the 2009 Community Safety and Services Element. The new Safety Element is now renamed the Environmental Safety and Public Services Element, and has been updated as necessary to address climate adaptation and resiliency strategies and ensure consistency with the 2021 Multi-Jurisdictional Local Hazard Mitigation Plan.

The new wildfire policies will be reviewed and approved by CAL FIRE's Board of Forestry.

The proposed Housing and Environmental Safety and Public Services Elements are contained in Appendix B.

Municipal Code
Municipal Code Title 15.04.110 is the Fire Code which adopts by reference Title 24 Part 9 of the California Code, 2019 Edition, with amendments and modifications, also known as the San Carlos Fire Ordinance. Chapter 49 – Requirements to Wildland-Urban Interface (WUI) Fire Areas,

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Section 4901.1 adopts and designates the most recent Very High Fire Hazard Severity Zones map as recommended by the Director of the California Department of Forestry and Fire Protection and retained on file, or via the internet, and made available at the offices of the Fire Chief and Building Official of the City of San Carlos. Buildings and structures shall comply with the provisions as stipulated by the City of San Carlos Building Official, the California Building Code Chapter 7A, or the California Residential Code Section R337.

Municipal Code 15.24.050 – Unlawful Materials, Conditions and Activities states it is unlawful for any landowner or person leasing, occupying, or having charge or possession of any real property in the City to keep, maintain, deposit or perform on such property any of the following:

D. Overgrown vegetation; dead, decayed, diseased or hazardous trees; weeds and other vegetation likely to harbor rats, vermin or nuisances or that constitute a fire hazard.

The City’s Zoning Ordinance is Title 18 within the Municipal Code. Regulations related to wildfire safety within the zoning code are as follows:

Title 18.12.060 Hillside (H) Overlay District. Building design standards. o Section D: Underfloors. Areas between the lowest floor and finished grade shall not exceed six feet in height and shall be completely enclosed with fire-retardant materials to prevent exposure to wildfire hazard.
o Section F.3: In areas of potential high fire hazard, exterior building materials shall be fireretardant.

Title 18.12.070 Landscaping.
o Section B. Fire Hazards. Fire-resistant, drought-tolerant species shall be used where appropriate to reduce fire hazards.

4.16.3 Thresholds of Significance
Based on Appendix G of the State CEQA Guidelines, implementation of the project would have a significant impact related to wildfire if it would:

For projects located in or near state responsibility areas or lands classified as very high fire hazard severity zones, the Focused GPU would have an impact related to wildfire if it would:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan; b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire;

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c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment; or d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

4.16.4 Impacts and Mitigation Measures
Impact WLDFR-1: The project would not substantially impair an adopted emergency response plan or emergency evacuation plan. (Less Than Significant Impact) The project consists of amending the General Plan to address housing and environmental safety needs of the community. The updated Environmental Safety and Public Services Element contains the same emergency and disaster preparedness goals, policies, and actions from the previous Community Safety and Public Services Element (Goal 6, Policies CSS 6.1 through CSS 6.12 and Actions CSS 6.1 through CSS 11, but are now renumbered to Goal 7, Policies ESPS 7.1 through ESPS 7.12 and Actions ESPS 7.1 through ESPS 7.11.

The project, including the addition of housing through the updated Housing Element, does not require changes to the Emergency Operations Plan. The majority of new housing is concentrated along El Camino Real and in the downtown area of the city, in already developed urban corridors near identified evacuation routes and away from areas in the western hills where significant wildfire threat exists and where single access roads are concentrated. Per ESPS Goal 3, Land Use Planning Action 4, any future housing in the VHFHSZ would require two points of ingress /egress in addition to meeting all fire safe design requirements as required in the Zoning Ordinance.

Action ESPS-7.1 requires evaluation of the emergency operations plan on an annual basis making revisions as needed to promote disaster preparedness. In addition, as discussed in the Environmental Setting discussion above, the City utilizes SMC Alert to send emergency alerts, notifications, and updates to cell phones, mobile devices, home phones, work, and/or e-mail accounts to quickly and effectively disseminate information to the public. Alert types may include life safety, fire, weather, accidents involving utilities, or roadway or disaster notifications.

Additionally, the City implements Zonehaven, the County’s evacuation system. The program determines the most efficient and effective evacuation routes based on the emergency type and location. Other relevant policies from the updated Environmental Safety and Public Services Element include:

Goal ESPS-3 - Agency Coordination: A resilient San Carlos is well prepared to minimize risks associated with wildfire.

Policy ESPS-3.1: Promote and improve, as necessary, inter-jurisdictional consultation and communication regarding disaster or emergency plans of San Carlos with adjacent agencies including but not limited to San Mateo County, Redwood City, Belmont, and CAL FIRE.

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Action ESPS-3.1: Maintain participation in the Joint Powers Authority Agreement with all fire departments in San Mateo County to ensure required response times for initial emergency deployment personnel and equipment.

Action ESPS-3.2: Preserve the local government agreement with California Department of Forestry and Fire Protection (CAL FIRE) for responses in the Mutual Threat Zone (MTZ) within the Wildland Urban Interface (WUI) areas of the city. Continue to provide equipment and personnel under the mutual aid agreement, with the State of California Office of Emergency Service (OES) Region II. This continued “reverse support” enables the City of San Carlos to receive “no cost” statewide mutual aid in the event of a declared large-scale emergency.

Action ESPS-3.3: Collaborate with the regional fire agencies on strategies available to maintain defensible space, diverse plant composition (e.g., less combustible native plants), undertake appropriate thinning of vegetation, and maintain fuel breaks without permanently damaging native habitat.

Facilities and Training
Policy ESPS-3.2: Conduct annual training for fire, emergency medical, and police staff including cross training with adjacent automatic or mutual aid emergency response departments. Regularly maintain, test, and update training and equipment to meet current standards.

Policy ESPS-3.3: Ensure adequate Fire Department resources (fire stations, personnel, and equipment) to meet response time standards, keep pace with growth, and provide a high level of service to the community.

Action ESPS-3.4: Continue to work with the Redwood City Fire Department to ensure that fire services are maintained at adequate levels. With subsequent Safety Element updates, assess and project future emergency service needs. Continue to monitor service area to ensure that all San Carlos areas have fire service. Monitor the City of San Carlos’ fire protection rating and work with the Redwood City and San Mateo County Fire Departments to correct deficiencies and to ensure ongoing training, including cross training is conducted.

Action ESPS-3.5: Train and educate public volunteers in basic fire safety response.

Access and Evacuation
Policy ESPS-3.14: Provide adequate evacuation routes and access for fire and emergency service vehicles to all San Carlos areas.

Policy ESPS-3.15: Identify and implement measures to mitigate the single access roads, as feasible.

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Action ESPS-3.24: Identify streets and key intersections that, due to pavement width, hairpin turns, and tight curves, if not cleared of vehicles, may interfere with emergency vehicle access and/or resident evacuation during a fire.

Action ESPS-3.25: Identify the potential for street widening and improvement during regular Capital Improvement project maintenance, e.g., utility undergrounding, resurfacing, and American with Disabilities (ADA) compliance.

Action ESPS-3.26: Prohibit parking on one or both sides of a street identified as having the potential to interfere with emergency vehicle access and/or resident evacuation during a fire, when Red Flag alerts have been issued.

Action ESPS-3.27: Conduct a study to review evacuation routes, their capacity, safety, and viability under a range of emergency scenarios as set forth in AB 747. Determine remedial actions, as appropriate. Update evacuation plans with each update of the Safety Element to address changes in at-risk areas and populations.

Action ESPS-3.28: Conduct a study to review evacuation routes, their capacity, safety, and viability under a range of emergency scenarios as set forth in AB 747. Determine remedial actions, as appropriate. Update evacuation plans with each update of the Safety Element to address changes in at-risk areas and populations.

Goal ESPS-4: Develop a community that proactively prevents wildfires and protects life, property, and infrastructure from urban and wildfire impacts.

Policy ESPS-4.1: Provide public education to promote community awareness and preparedness for self-action in the event of a major disaster or emergency.

Action ESPS-4.1: Partner with Redwood City Fire Department, San Mateo Sheriff Department, neighboring cities, regional agencies, local school districts, local businesses, and community organizations to conduct emergency and disaster preparedness exercises that test operational and emergency response plans (including evacuation routes); and prepare and conduct public outreach regarding evacuation procedures and routes and defensible space.

Action ESPS-4.2: Identify at-risk populations that would be vulnerable during wildfire evacuations and provide information to the at-risk residents regarding defensible space and evacuation routes.

Action ESPS-4.3: Prepare and make available to the public a current map of areas subject to wildland fires as provided by the California Department of Forestry and Fire Protect (CAL FIRE).

Action ESPS-4.4: Implement a fire hazards education program to minimize risk for residential, commercial, and institutional uses.

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• Provide training opportunities for residents for fuel modification methods, practices, and materials.
• Prepare and distribute two vegetation lists – one identifies recommended vegetation in the VHFSZ and the other identifies prohibited vegetation in the VHFSZ.

Action ESPS-4.5: Create and promote enrollment in a San Carlos emergency reverse dial program. Work with vulnerable populations to ensure enrollment.

Action ESPS-4.6: Consider establishing an outdoor warning system in the VHFSZ designed to alert residents about possible fire danger.

Construction of the development associated with the updated Housing Element may temporarily impact traffic circulation conditions during construction periods. However, construction impacts on circulation would be temporary and would still allow for evacuation in the event of an emergency, and emergency access would be maintained to development sites during construction.

Development included under the updated Housing Element would increase the population of the City, which in turn may exacerbate traffic congestion during an evacuation by increasing the number of vehicles utilizing evacuation routes. However, the updated Environmental Safety and Public Services Element implementing programs listed above would reduce potential impacts because the goals, policies, and actions would improve evacuation and emergency response compared to existing conditions. Further, the development projects included under the Housing Element Update have been sited such that most new housing would not be located in areas that would interfere with wildfire emergency response or evacuation procedures and planning. One parcel on Crestview Drive and another just west of Devonshire Canyon SOI are in the VHFHSZ has been identified for increased density. Crestview Drive would function as a primary evacuation route for the western edge of the city and would provide an adequate evacuation route for the new residents. New policies are in place to ensure adequate access for new developments.

The project includes implementation of the above listed Goals, Policies, and Actions of the updated Environmental Safety and Public Services Element, annual requirement to update the City’s Emergency Operations Plan, and implementation of SMC Alert and Zonehaven evacuation systems. These ensure the proposed project would not result in substantial impairment of an adopted emergency response plan or emergency evacuation plans. The impact is considered less than significant.

IMPACT WLDFR-2: The project would not, due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. (Less Than Significant Impact) The risks associated with wildfires are most pronounced for land west of Alameda de las Pulgas where homes and other structures are often located within areas of dense vegetation and on steep slopes. These areas are designated as HFHSZ or VHFHSZ. As noted above under Impact WLDFR1, the majority of new housing proposed by the updated Housing Element is concentrated in

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already developed urban areas with flat topography in the eastern portion of the City closer to San Francisco Bay and outside of the HFHSZ and VHFHSZ. One parcel on Crestview Drive in the VHFHSZ has been identified for increased density and another parcel just west of the incorporated Devonshire Canyon area (within the City of San Carlos) has been identified in the Housing Element for additional housing. The City has adopted the 2019 California Fire Code and 2018 International Fire Code as described above in 4.17.2 Regulatory Setting. Chapter 5 Fire Service Features includes:
• Section 503 which specifies provisions pertaining to road standards for fire equipment access,
• Section 505 which presents standards for signs identifying streets, roads, and buildings, and
• Section 507 establishes minimum private water supply reserves for emergency fire use Chapter 33 of the 2019 Fire Code addresses fire safety during construction and demolition, mandating fire safety procedures for the construction and demolition of structures (Section 3301- 3317) and Chapter 49 of the same addresses requirements for construction within wildland-urban interface fire areas and establishes minimum standards related to defensible space, requiring that property owners in a VHFHSZ manage vegetation within a 100-foot radius of a building.

Specific policies contained within the updated Environmental Safety and Public Services Element directly address wildfire safety in new development including:

Land Use Planning
Policy ESPS-3.4: Locate essential public facilities out of high-risk, wildfire-prone areas including the VHFHSZ unless mitigation measures, above the minimum fire protection standards, are installed.

Policy ESPS-3.5: Prioritize infill development opportunities to prevent increased development in the WUI and Very High Fire Severity Zones (VHFSZ).

Policy ESPS-3.6: Minimize new development within the VHFSZ.

Policy ESPS-3.7: Consider the preservation of undeveloped ridgelines to reduce fire risk and improve fire protection.

Policy ESPS-3.8: Regularly review and confirm the City’s re-development policy for all structures in VHFSZs after large fires. If the City has an unwritten policy, adopt a written redevelopment policy.

Policy ESPS-3.9: Incorporate or require the incorporation of fire safety features in new development and re-development.

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Policy ESPS-3.10: Require new residential developments to have adequate fire protection; and be more wildfire resistant by establishing greenbelt zones for fire resistant landscaping.

Policy ESPS-3.11: Require new residential development to be designed in such a manner that reduces wildfire hazard and improves defensibility (e.g. clustering lots, managed greenbelts, water storage, fuel modification zones, and vegetation setbacks.) Action ESPS-3.6: Discourage critical facilities being in the VHFSZ.

Action ESPS-3.7: Periodically re-evaluate the City’s policy allowing rebuilding in the VHFSZ.

If the policy is unwritten, adopt a formal written policy.

Action ESPS-3.8: When a fire has occurred in the VHFSZ, evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency.

Action ESPS-3.9: If development is permitted within the VHFSZ, require:
• a Fire Protection Plan addressing: risk analysis, fire response capabilities, fire safety requirements (defensible space, infrastructure, and building ignition resistance), mitigation measures and design considerations for non-conforming fuel modification, and wildfire education maintenance and limitations;
• landscape/fuel modification installation, incorporating open areas to complement defensible spaces, identifying possible refuge areas, and mapping and providing multiple ingress and egress routes;
• resident evacuation plans and ways to effectively communicate those plans, including identifying the location and direction of evacuation routes and at least two points of ingress and egress; and a roadside fuel reduction plan to prevent fires along public roads caused by vehicles.

Action ESPS-3.10 - Enforce fire standards and regulations while reviewing building plans and conducting building inspections.

Water Supply
Policy ESPS-3.12: Ensure adequate water supply is available.

Action ESPS-3.12: Require new development projects have adequate water supplies to meet the fire-suppression needs of the project without compromising existing fire suppression services to existing uses.

Action ESPS-3.13: Work with water suppliers (Cal Water) to:
• maintain and ensure the long-term integrity of future water supply for fire suppression needs;

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• ensure that water supply infrastructure adequately supports existing and future development and redevelopment;
• provide adequate water flow to combat structural and wildland fires, including during peak domestic demand periods. Water systems shall equal or exceed the standards of the latest edition of National Fire Protection Association (NFPA) 1142, “Standard on Water Supplies for Suburban and Rural Fire-Fighting.”;
• ensure water infrastructure can provide for peak fire flow; and • identify where water infrastructure does not allow for peak fire flow and develop a plan to mitigate the deficiencies.

Construction and Property Maintenance
Policy ESPS-3.13: Ensure new and existing public and privately owned properties are constructed and maintained in a manner that minimizes and reduces fire hazard threats and has adequate fire protection.

Action ESPS-3.14: Condition all new development and redevelopment to have adequate fire protection, incorporate and maintain fire safe design, including fuel modification zones, defensible space, two ingress/egress points, emergency vehicle access, and visible home addressing and street signage.

Action ESPS-3.15: Require the use of fire-retardant roofing material for all new construction and major remodels involving roof additions. Encourage property owners with shake shingle roofs to upgrade to fire-retardant materials.

Action ESPS-3.16: Continue to enforce the brush clearance/weed abatement program for both private and public roads as well as City-owned open spaces.

Action ESPS-3.17: Continue code enforcement programs requiring private and public property owners to maintain buildings and properties to prevent blighted conditions, remove excessive or overgrown vegetation (e.g., trees, shrubs, weeds), and remove litter, rubbish, and illegally dumped items from properties.

Action ESPS-3.18: Seek grants and other funding sources to assist low-income residents with home hardening efforts.

Action ESPS-3.19: Adopt an ordinance or update existing ordinances to require development standards that meet or exceed title 14, CCR, division 1.5, chapter 7, subchapter 2, articles 1-5 (commencing with section 1270) (SRA Fire Safe Regulations) and title 14, CCR, division 1.5, chapter 7, subchapter 3, article 3 (commencing with section 1299.01) (Fire Hazard Reduction Around Buildings and Structures Regulations) for SRAs and/or VHFHSZs.

Action ESPS-3.20: Within the VHFSZ, the City’s building and planning departments will work with local fire departments, community organizations, and other responsible organizations to require and ensure:

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• the installation of fire protection water system for all new construction projects including fire hydrant instillation, fire sprinkler, or suppression systems, and providing adequate fire flow;
• the long-term maintenance of defensible space clearances around structures, subdivisions, and fuel breaks; and
• all structures rebuilt/re-developed after a large fire to comply with building and fire codes in effect at the time of the re-development.

Action ESPS-3.21: Conduct a survey of existing residential structures within the VHFSZ identifying buildings that do not comply with fire safety standards. Consult with property owners to bring those properties into compliance with the most current building and fire safety standards.

Action ESPS-3.22: Consider developing or improving structure hardening standards for community refuges (such as schools, hospitals, evacuation centers).

Current regulations, along with the proposed updated Environmental Safety and Community Services Element goals, policies, and actions, will continue to influence future housing development. These provisions will continue to regulate, for example, building design, access, firefighting water supply, and vegetation management, all to lessen the possible risk of ignition and spread of wildfires.

One parcel on Crestview Drive and another parcel just west of the incorporated Devonshire Canyon area (within the City of San Carlos) have been identified for increased density as multifamily housing and are located in the VHFHSZ. New housing in VHFSHZs and SRAs would not be likely to exacerbate wildfire risks because of the requirement for fire safe building materials, defensible space, and water for firefighting requirements. Human-caused fires have been negatively correlated with population density, meaning more developed areas are less likely to be affected by wildfires throughout the state and suggesting that additional development would not necessarily lead to more wildfire risk, especially where high-density housing is developed.

The proposed updated Environmental Safety and Public Service Element goals, policies, and actions require collaboration with local fire departments to provide adequate fire protection for existing and new development. Further, the updated Housing Element inventory of sites has been selected to avoid hazardous areas, including areas subject to wildfire hazards. Compliance with proposed updated Environmental Safety and Public Services Element goals, policies, and actions, State regulatory requirements described above and in Section 4.17.2, and the applicable fire department development review process for new development, will help minimize the potential for impacts related to wildfires and subsequent downhill or downstream impacts, including exposure to air pollutants. In addition, the project includes a new policy in the Land Use Element:
• Policy LU-10.6: Require all new development and significantly modified development in the High and Very High Fire Susceptibility Zones to install and maintain fire prevention

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design and materials in accordance with Building Codes at the time of the construction/reconstruction.

Therefore, the project would not result in substantial adverse impacts due to slope, prevailing winds, and other factors, exacerbating wildfire risks, and thereby exposing project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire. This impact is considered less than significant.

Impact WLDFR-3: The project would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. (Less Than Significant impact)
The project does not involve the placement of new development within previously undeveloped areas requiring the installation of or maintenance of infrastructure such as roads, fuel breaks, emergency water sources, powerlines, or other utilities. As stated previously, the changes proposed by the updated Housing Element allows a greater density of housing in areas where housing is already allowed.

Future development in San Carlos would be subject to the adopted 2019 California Fire Code and the updated Environmental Safety and Public Services Element which contains the Goal, Policies, and Actions noted above in IMPACT WLDFR-1 and IMPACT WLDFR-2 that address potential impacts related to wildland fires citywide.

Implementation of the above-listed Agency Coordination, Facilities and Training, Land Use Planning, Water Supply, Construction and Property Maintenance, and Access and Evacuation goals, policies and actions contained in the updated Environmental Safety and Public Services Element would ensure fire risks are not exacerbated or result in temporary or ongoing impacts to the environment. This would be a less than significant impact.

Impact WLDFR-4: The project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post fire slope instability or drainage changes. (Less Than Significant Impact) Landslides and erosion are often associated with areas that have been burned by wildfires.

Landslide susceptibility is shown in Figure 8-5 of the proposed Environmental Safety and Public Services Element. Wildfires can result in slopes and soils that are susceptible to soil movement and loss. Exposure to rain and increased runoff could exacerbate the possible impact. Soil movement may clog road drains. In addition, wildfires kill vegetation and their roots, which hold soil in place. Decaying roots of trees pose a substantial decrease in the strength of soil to resist sliding.

As noted previously, new housing proposed by the updated Housing Element concentrates housing in already developed urban corridors on flat topography near identified evacuation routes and away from areas in the western hills where significant wildfire threat exists and where single access

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roads are concentrated. Proposed goals, policies, and actions included in the project are designed to minimize exposure of people and structures to post-fire risks. The programs range from maintaining an adequate level of preparedness to protecting development from geologic hazards, restricting development in VHFHSZ. Chapter 4.6 (Geology and Soils) of this EIR provides further detail on landslide and slope stability hazards. The applicable updated Environmental Safety and Public Services Element policies that would avoid or reduce significant impacts are listed below.

Goal ESPS-3 - Agency Coordination: A resilient San Carlos is well prepared to minimize risks associated with wildfire.

Land Use Planning
Policy ESPS-3.4: Locate essential public facilities out of high-risk, wildfire-prone areas including the VHFHSZ unless mitigation measures, above the minimum fire protection standards, are installed.

Policy ESPS-3.5: Prioritize infill development opportunities to prevent increased development in the WUI and Very High Fire Severity Zones (VHFSZ).

Policy ESPS-3.6: Minimize new development within the VHFSZ.

Policy ESPS-3.7: Consider the preservation of undeveloped ridgelines to reduce fire risk and improve fire protection.

Policy ESPS-3.8: Regularly review and confirm the City’s re-development policy for all structures in VHFSZs after large fires. If the City has an unwritten policy, adopt a written redevelopment policy.

Policy ESPS-3.9: Incorporate or require the incorporation of fire safety features in new development and re-development.

Policy ESPS-3.10: Require new residential developments to have adequate fire protection; and be more wildfire resistant by establishing greenbelt zones for fire resistant landscaping.

Policy ESPS-3.11: Require new residential development to be designed in such a manner that reduces wildfire hazard and improves defensibility (e.g., clustering lots, managed greenbelts, water storage, fuel modification zones, and vegetation setbacks.) Action ESPS-3.6: Discourage critical facilities being in the VHFSZ.

Action ESPS-3.7: Periodically re-evaluate the City’s policy allowing rebuilding in the VHFSZ.

If the policy is unwritten, adopt a formal written policy.

Action ESPS-3.8: When a fire has occurred in the VHFSZ, evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency.

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Action ESPS-3.9: If development is permitted within the VHFSZ, require:
• a Fire Protection Plan addressing: risk analysis, fire response capabilities, fire safety requirements (defensible space, infrastructure, and building ignition resistance), mitigation measures and design considerations for non-conforming fuel modification, and wildfire education maintenance and limitations;
• landscape/fuel modification installation, incorporating open areas to complement defensible spaces, identifying possible refuge areas, and mapping and providing multiple ingress and egress routes;
• resident evacuation plans and ways to effectively communicate those plans, including identifying the location and direction of evacuation routes and at least two points of ingress and egress; and a roadside fuel reduction plan to prevent fires along public roads caused by vehicles.

Action ESPS-3.10 - Enforce fire standards and regulations while reviewing building plans and conducting building inspections.

The proposed Environmental Safety and Public Services Safety Element goals, policies, and actions listed above and discussed in Chapter 4.6 (Geology and Soils) and Chapter 4.9 (Hydrology and Water Quality) of this EIR require existing and new development to be adequately protected from potential flooding, slope stability, or landslide hazards and to not cause such hazards through careful site planning and construction. Further, the updated Environmental Safety and Public Services Element includes proposed policies and actions that would reduce the risk of the ignition and spread of wildfire in the City, thereby reducing the potential for post-fire impacts. Proposed policies and an actions included in the Environmental Safety and Public Services Element are designed to minimize exposure of people and structures to post-fire risks. The policies and actions range from maintaining an adequate level of preparedness to protecting development from geologic hazards, by implementing stability report requirements. Chapter 4.6 (Geology and Soils) of this EIR provides further detail. The proposed Environmental Safety and Public Services Element combined with geotechnical requirements for development contained in the Municipal Code address the geologic safety of development in areas prone to landslide. Implementation of the proposed Environmental Safety and Public Services Element goals, policies, and actions would ensure people or structures would not be exposed to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. This impact is considered less than significant.

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4.16.5 References
Design, Community & Environment. 2009. San Carlos 2030 General Plan EIR, June 25.

Draft Safety Element Update.

City of San Carlos. 2022. Municipal Code. Accessed on August 22, 2022 at:
https://www.codepublishing.com/CA/SanCarlos/#!/html/SanCarlos15/SanCarlos1504.ht ml
Tetra Tech. 2021 Multijurisdictional Local Hazard Mitigation Plan – Volume 1. October. Accessed August 19, 2022 at https://www.smcgov.org/ceo/2021-multijurisdictional-lhmp Tetra Tech. 2022. San Carlos Emergency Operations Plan Draft 3. June.

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5.0 ALTERNATIVES TO THE PROPOSED FOCUSED GENERAL

PLAN UPDATE AND ZONING AMENDMENTS
Section 15126.6 of the CEQA Guidelines requires an EIR to "describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project, but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” The section also states that “the discussion of alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if those alternatives would impede to some degree the attainment of the project objectives, or would be more costly.” Under Section 15126.6(a) of the CEQA Guidelines, an EIR does not need to consider alternatives that are not feasible, nor need it address every conceivable alternative to the project. The range of alternatives “is governed by the ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice” (CEQA Guidelines § 15126.6(f).)
Pursuant to Section 15126.6, this chapter describes two alternatives to the Focused GPU and Zoning Amendments (Project), including (1) the CEQA-mandated No Project Alternative, and (2) RHNA Only Alternative and compares the impacts of each alternative to the project. The ability of each alternative to meet the basic project objectives is also described, and the “environmentally superior” alternative among the two (2) alternatives is identified, as required by the CEQA Guidelines.

5.1 IMPACTS OF THE PROPOSED PROJECT
CEQA requires the alternatives discussion to describe alternatives to the project that would avoid or substantially lessen any of the significant effects of the project, This EIR has identified the following significant unavoidable impacts that could result from the Housing and Safety Element Update Project (also see Table 2-1 in the Summary chapter).

5.1.1 Significant Unavoidable Project Impacts
Impact AIR-1: The project would conflict with or obstruct implementation of the applicable air quality plan. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMD-recommended threshold of significance. However, it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures.

Impact AIR-2: The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under an applicable federal or state ambient air quality standard. Implementation of Mitigation Measure AIR-2 would reduce

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construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMD-recommended threshold of significance. However, it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures.

Impact AIR-3: The project could expose sensitive receptors to substantial pollutant concentrations. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMDrecommended threshold of significance. However, with regard to localized criteria air pollutant and TAC emissions generated during future construction activities it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant and TAC emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures.

Impact AIR-5: The project could cause substantial adverse cumulative impacts with respect to Air Quality. Because future construction activities could result in ozone precursor and PM emissions that exceed BAAQMD thresholds, the project could increase the frequency and/or severity of air quality violations in the Bay Area Basin or otherwise impede attainment of air quality standards.

5.1.2 Less Than Significant with Mitigation Project Impacts:

Impact BIO-1: New housing development on sites that are on or adjacent to natural vegetation or aquatic habitat, and/or vegetation thinning and fuel breaks in natural habitat areas, could impact sensitive habitat or special-status species supported by such habitat. Mitigation Measures BIO-1, Project-Specific Biological Resources Evaluation would reduce impacts to less than significant.

Impact BIO 2: Construction of housing and/or vegetation thinning and the creation of fuel breaks during the nesting bird season could have direct and indirect impacts on nesting birds protected by the federal Migratory Bird Treaty Act, and California Fish and Game Code. Mitigation Measure BIO-2 Nesting Birds and BIO-3a and 3b Mitigation Measure BIO-3a. Bat Habitat Assessment and Dusk Surveys would reduce impacts to less than significant.

Impact BIO-3: The construction of housing adjacent to creeks could adversely impact state or federally protected wetlands through filling, hydrological interruption, loss or riparian vegetation, or other means. Mitigation Measure BIO-1 would reduce this impact to less than significant.

Impact BIO-4: Mitigation Measure BIO-1 requires a project specific biological resources evaluation for sites that are on or adjacent to natural vegetation or aquatic habitat. The biological resources evaluation would address wildlife movement and nursery sites if applicable and include site-specific mitigation as needed.

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Impact BIO-5: Implementation of Mitigation Measures BIO-1, BIO-2, and BIO-3 would ensure future housing projects don’t conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Impact TRIB-1: To prevent otherwise non-significant resources which are significant to a local tribe from being destroyed or damaged, the implementation of Mitigation Measure TRIB-1 would reduce impacts to TCRs to less than significant.

5.2 Rationale for Alternative Selection
In accordance with CEQA Guidelines Section 15126.6(a), an EIR does not need to evaluate every conceivable alternative. Section 15126.6(c) of the CEQA Guidelines states, “Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to avoid significant environmental effects.” CEQA Guidelines Section 15126(f)(2) indicates that alternatives that are remote or speculative, or the effects of which cannot be reasonably predicted, need not be considered.

CEQA Guidelines Section 15126.6(f) indicates that the Lead Agency should consider site suitability, economic viability, availability of infrastructure, general plan consistency, other regulatory limitation, jurisdictional boundaries, and the proponent’s control over alternative sites in determining the range of alternatives to be evaluated in an EIR.

The Housing Element site selection process involved extensive research into viable housing sites, and multiple public workshops and presentations to the City Planning Commission and City Council. The Housing Element ultimately identifies housing sites with demonstrated viability for future housing development and which minimizes environmental impacts by clustering the housing sites in areas already zoned for residential or multi-use, which are close to downtown and transit options, and which minimize exposure to environmental hazards such as wildfire or sea level rise. This effort to locating the housing sites in areas where environmental impacts would be minimized is reflected in the number and type of significant and unavoidable impacts identified above in Section 5.1. Most of the significant and unavoidable impacts are related to short-term air emissions associated with housing construction.

Because the housing sites identified in the Housing Element are primarily located in the downtown area of the city and along El Camino Real, and thus close to transit, the EIR impact analysis determined the project would not have significant VMT impacts, air emissions from vehicle traffic, GHG emissions, or cause land use impacts based on the identified Thresholds of Significance presented in the EIR. Section 15126.6 of the CEQA Guidelines requires an EIR to describe a range of reasonable alternatives to the project that would avoid or substantially lessen any of the significant effects of the project. For these reasons the EIR does not present alternatives that propose different housing sites, or propose to place housing in different locations within the city, or alternatives to the density increases proposed under the project.

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With respect to alternative locations, CEQA Guidelines Section 15126.6(f) indicates that alternative locations need not be evaluated in every case. For this project, examining an alternative location for the project is not a feasible alternative since the project is to update the City’s General Plan Housing and Safety Elements. Therefore, this chapter does not discuss an alternative project location.

The EIR is required to describe a range of reasonable alternatives to the project which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project. The project objectives included in Chapter 3, Project Description, are:

Project Objectives:

1. Promote the preservation and improvement of the quality of existing housing and neighborhoods.

2. Encourage housing development located close to transit, Downtown, and along El Camino Real and San Carlos Avenue with high quality, higher density, multi-family housing.

3. Assist in the development of new housing that is affordable at all income levels.

4. Remove and/or mitigate potential governmental constraints to the provision of adequate, affordable housing.

5. Provide adequate housing for special needs populations.

6. Eliminate discrimination in the provision of housing.

7. Reduce the potential loss of life, injury, and property damage due to seismic and geologic hazards.

8. Reduce hazards associated with flooding or inundation from inland flooding and Sea Level Rise.

9. Protect lives and property from risks associated with wildfire-related emergencies.

10. Protect the community from the harmful effects of hazardous materials.

11. Combat housing discrimination, lessen racial bias, lessen historic patterns of segregation, and lift barriers that restrict access to foster inclusive communities and achieve racial equity.

12. Continue effective emergency response procedures to ensure public safety in the event of natural or man-made disasters.

13. Identify communities most vulnerable to climate change impacts and establish new goals, policies, and programs for equitable public safety, emergency preparedness, response, and recovery.

While selecting alternatives to be considered for analysis, the City focused on alternatives which could potentially reduce the significant effects of the project and would also achieve project objectives. One overarching objective of the project is to accommodate, within the framework of the Housing Element, the State-mandated RHNA goal for the City for the 6th Housing Cycle, which is a total of 2,735 dwelling units. Therefore, the extent to which the RHNA would be achieved (referred to as the “RHNA Objective”) was analyzed for each alternative.

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The EIR impact analysis did not identify any potentially significant impacts requiring mitigation or significant and unavoidable impacts associated with adoption and implementation of the Safety Element Update. The Land Use Element, Environmental Management Element, Circulation and Scenic Highways Element, Noise Element, and Title 18 Zoning Amendment updates are only required to maintain consistency with the updated Housing and Environmental Safety and Public Services Elements. Therefore, the EIR does not need to present alternatives for these portions of the project.

5.3 Alternatives Selected
The following alternatives have been evaluated in comparison to the proposed Focused GPU project:
• Alternative 1: No Project
• Alternative 2: RHNA Only
Per CEQA Guidelines Section 15126.6(d), the discussion of impacts associated with the alternatives is less detailed than the evaluation included in Chapters 4.1 through 4.16. Table 5-1 summarizes the development assumptions of each alternative. Table 5-2 summarizes the potential impacts of the alternatives compared to the impacts associated with implementation of the project.

The alternatives’ potential impacts are evaluated in the following Sections 5.3 through 5.5.

In accordance with State CEQA Guidelines Section 15126.6, (1) an “environmentally superior alternative” has been identified, and (2) the discussion of the impacts of the alternatives is less detailed than the discussions in the environmental topic chapters.

5.3.1 Alternative 1: No Project/Existing Housing Element/2009 General Plan State CEQA Guidelines Section 15126.6(e) requires an EIR to analyze the specific alternative of “No Project”. The purpose of describing and analyzing the No Project Alternative is to allow decision makers to compare the impacts of approving a proposed project with the impact of not approving the proposed project. The No Project Alternative must discuss the existing conditions at the time the EIR notice of preparation is published, as well as what would be reasonably expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services.

Additionally, State CEQA Guidelines Section 15126.6(e)(3)(a) states that when the project is the revision of an existing land use or regulatory plan, the “No Project” alternative will be the continuation of the existing plan. Typically, this is a situation where new projects would be proposed under the existing plan. Thus, the impacts of the proposed project would be compared to the impacts that would occur under the existing plan.

Although the No Project Alternative does not meet any of the Focused General Plan Update project objectives and is not considered a viable project alternative, it is presented below as required by CEQA.

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Principal Characteristics
Housing Element: Under the No Project Alternative, the City would not update the existing 2015 to 2023 Housing Element. The existing Housing Element would continue to direct the City’s decisions related to housing development and the RHNA assignment of 596 new housing units to be planned for. Although between 2015 and 2021, 622 units of the current 596-unit RHNA assignment were constructed and total construction exceeded the full RHNA allocation, this was largely due to the development of above-moderate income units. Only 11 percent of very lowincome units, 13 percent of low-income units, and 13 percent of moderate-income units were built during this period (see Section 3.1.2 of the Project Description).

The No Project Alternative assumes that development would occur within the City as anticipated under the 2009 General Plan and the 2015-2023 Housing Element (RHNA assignment of 596 which has already been exceeded in 2021), as well as the future Downtown Specific Plan and the Northeast Area Specific Plan which are planning projects currently underway in the City. Demand for new housing in the City would continue to be market driven and the City would continue to receive development applications for housing projects.

As described in detail in the Project Description (section 3.3.8) the proposed project includes amendments to the City’s Zoning Ordinance (Title 18 of the San Carlos Municipal Code) to allow for fulfilment of the City’s RHNA by increasing the residential density within certain zoning designations, as well as by creating new zoning designations. Under the No Project Alternative amendments would not be made to the Zoning Ordinance and existing residential densities would remain.

The Development assumptions for this alternative are shown in Table 5-1. As compared to the proposed new Housing Element (RHNA assignment of 2,735), there would be a significant reduction in residential development. Additionally, no new Housing Elements goals, policies, or actions facilitating housing construction would be adopted.

It should be noted that the City would face significant, adverse repercussions for not adopting a new Housing Element reflecting the 6th cycle RHNA assignment. State housing law identifies penalties that can be levied against jurisdictions that do not adopt new housing elements, including:
• Eligibility for grants: A city without a compliant housing element is not eligible for a variety of state grants and loans. Several federal funding programs consider compliance with housing element law as an eligibility or ranking criterion. • Court approval of housing developments: If a city fails to adopt a compliant housing element, the Housing Accountability Act requires that city to approve any proposed housing development project that has 20% of units set aside for low-income residents or 100% of units set aside for middle-income residents irrespective of its compliance with the applicable zoning or general plan (Cal. Gov. Code § 65589.5(d)). • Fines and fees: If a court finds a city to be out of compliance, the court can order the city to pay fines to the California state housing trust fund, attorney’s fees to the plaintiff, or both. Cal. Gov. Code § 65585(l)(1) defines an escalating structure of fines with a minimum amount of $10,000 per month and a maximum of $100,000 per month. Continued failure to achieve a certified Housing Element allows the court to multiply the fines by a factor of three per month and later a factor of six per month.

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• Legal suits and attorney fees: Local governments with noncompliant housing elements are vulnerable to litigation from housing rights’ organizations, developers, and HCD. If a jurisdiction faces a court action stemming from its lack of compliance and either loses or settles the case, it often must pay substantial attorney fees to the plaintiff’s attorneys in addition to the fees paid to its own attorneys. Potential consequences of lawsuits include:
mandatory compliance within 120 days, suspension of local control on building matters, and court approval of housing developments.
• Loss of permitting authority: Courts have authority to take local government residential and nonresidential permit authority to bring the jurisdiction’s General Plan and housing element into substantial compliance with State law. The court may suspend the locality’s authority to issue building permits or grant zoning changes, variances, or subdivision map approvals (Cal. Gov. Code § 65755(a)).

Community Safety and Services Element: Under the No Project Alternative, the existing Community Safety and Services Element would continue to function as the City’s Safety Element.

The existing Community Safety and Services Element discusses the hazards posed by geologic and seismic, flooding, and wildfire hazards. It does not cover the new spectrum of environmental hazards required by Gov. Code §65304(g), including climate change and resiliency planning (drought, extreme weather events, extreme heat events), sea level rise, or a more robust discussion and analysis of wildfire hazards.

Analysis of No Project Alternative
The impacts of the No Project Alternative are examined qualitatively to allow comparison with the project. The City does not contain agricultural, forestry, or mineral resources, therefore these topics are not discussed below.

Housing Element: The RHNA assignment for the current 2015-2023 Housing Element is 596 units whereas the RHNA assignment for the proposed Housing Element update (2023-2031) is 2,735 units. With the required planning buffer this EIR analyzes the impacts of 3,576 units (2,735 RHNA + 841 buffer units). Because of the substantially greater number of housing units planned for in the proposed Housing Element Update and the resulting increase in population, the proposed project has overall greater environmental impacts than the No Project Alternative. The proposed project would have greater air quality, GHG, and energy emissions because of the greater number of units and increase in population, it would generate greater VMT, greater demand on public services and utilities, generate more noise from housing construction and increased number of vehicles on local roadways than the No Project Alternative.

The Draft EIR analysis found the impacts of the proposed Focused GPU on air quality to be significant and unavoidable under Impacts AIR-1, AIR-2, AIR-3, and AIR-5. Mitigation Measure AIR-2 would be required but the impact would remain significant and unavoidable even with mitigation. The No Project Alternative would have a reduced amount of air quality emissions, but the impact is assumed to remain significant and unavoidable as described in 2009 General Plan EIR.

The proposed project would alter the visual character of the downtown area and a stretch of El Camino with buildings that would be taller than currently allowed under the General Plan or Zoning Ordinance.

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Chapter 5 Alternatives
While the project does not cause land use impacts as measured against the CEQA Thresholds of Significance, it would increase housing density, propose more housing in mixed-use areas, and facilitate the construction of multi-family units adjacent to single-family housing.

Community Safety and Services Element: The proposed project includes the Environmental Safety and Public Services Update and would help the City prepare for the adverse effects of climate change. The No Project Alternative would not have the beneficial effect of creating new planning policy for climate change and resiliency planning, including wildfire hazard and sea level rise.

Attainment of Project Objectives
The No Project Alternative would not meet any of the project objectives and would not allow the city to comply with state housing laws or SB 379 requiring the inclusion on climate change resilience planning in Safety Elements. As described above, the City would have substantial, adverse consequences for not adopting a new Housing Element reflecting the 6th cycle RHNA assignment.

5.3.2 Alternative 2: RHNA Only Alternative
The City of San Carlos has been assigned a RHNA of 2,735 new housing units for the 2023-2031 planning period. This is broken down into 739 extremely low/very low-income units, 425 lowincome units, 438 moderate income units, and 1,133 above moderate income units. Government Code section 65863, including amendments pursuant to Chapter 367, Statutes of 2017 (Senate Bill 166) requires jurisdictions to maintain adequate sites to accommodate their remaining unmet RHNA by each income category at all times throughout the entire planning period. If, at any time during the planning period, the jurisdiction finds that there is a shortfall of sites to accommodate its remaining RHNA, the jurisdiction must take immediate action to correct the shortfall by amending its Housing Element sites inventory to either include sites previously unidentified with capacity to accommodate the shortfall, or sites that have been rezoned to correct for the shortfall.

Failure to do so constitutes a violation of the No Net Loss law. HCD guidance states: To ensure that sufficient capacity exists in the Housing Element to accommodate the RHNA throughout the planning period, create a buffer in the Housing Element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower-income RHNA.

Jurisdictions can also create a buffer by projecting capacity less than what is allowed from the maximum density to allow for some reductions in density or rezoning additional sites above what is needed to accommodate the RHNA.

Because the Housing Element must plan for or have policies in place to accommodate the RHNA assignment in any given planning period, the City is planning for and evaluating a total of 3,576 units (2,735 RHNA + 841 buffer units).

As the project’s primary impacts are significant and unavoidable short-term air quality impacts from emissions during housing construction, an alternative that analyzes the effects of fewer housing units is appropriate.

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October 2022
Principal Characteristics
The RHNA Only Alternative reflects a reduced number of residential units from 3,576 units to 2,735 (841 units), and the same amount of non-residential development included in the project.

Since the significant impacts of the project (air quality) are largely due to the substantial number of new residential units proposed, this alternative reduces the potential number of future dwelling units, therefore reducing the amount of air emissions and short-term construction noise that would be generated from housing construction. Development assumptions for this alternative are shown in Table 5-1, below. This alternative assumes that goals, policies, or development standards associated with the project would apply to this alternative.

Analysis of the RHNA Only Alternative
The potential impacts associated with the RHNA-Only Alternative are described below.

A. Aesthetics. The EIR analysis found the aesthetic impacts of the proposed Focused GPU to be less than significant. Neither the project nor the RHNA Only Alternative would impact a scenic vista, damage scenic resources within a state designated highway, conflict with applicable zoning or other City regulations governing scenic quality, or create a new source of light and glare. The project and the RHNA Only Alternative would increase allowable density in the downtown mixed-use zones and would decrease setbacks and increase allowable residential building heights. The RHNA Only Alternative may reduce the degree of impacts to the aesthetic design and character of the downtown area and El Camino Real corridor due this alternative’s reduced development potential. As such, this alternative would reduce aesthetic impacts and would have a similar less-than-significant impact compared to the project.

B. Air Quality. The project would result in significant unavoidable air quality impacts. The EIR analysis found the impacts of the proposed Focused GPU on air quality to be significant and unavoidable under Impacts AIR-1, AIR-2, AIR-3, and AIR-5. Mitigation Measure AIR-2 would be required to reduce the project’s significant and unavoidable impacts; however, even after implementation of this mitigation measure, the project’s significant and unavoidable impacts would remain significant and unavoidable. The RHNA Only Alterative would decrease the amount of development potential compared to the project by 23.9 percent through removal of the project’s proposed buffer sites. It is likely that air quality impacts under this alternative would be similar to those of the project, and mitigation measures needed for the project would also be required for this alternative.

As such, the RHNA Only Alternative would have a similar significant and unavoidable air quality impact compared to the project.

C. Biological Resources. The EIR analysis found the impacts of the proposed Focused GPU on biological resources to be potentially significant under Impacts BIO-1, BIO-2, BIO-3, BIO-4, and BIO-5. Mitigation Measures BIO-1, BIO-2, BIO-3a, and BIO-3b would be required to reduce the project’s potentially significant impacts to less than significant. The RHNA Only Alternative would reduce potential residential development by 23.9 percent compared to the proposed project by excluding the project’s proposed buffer sites. As with the project, development under the RHNA Only Alternative could potentially significantly impact special-status plant and wildlife species and their habitat. While the RHNA Only

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Alternative would reduce the amount of potential development in the project area, this alternative would likely have similar impacts due to the potential to adversely impact habitat for special-status species. As such, this alternative would have similar impacts as the proposed project.

D. Cultural Resources and Tribal Cultural Resources. The EIR analysis concluded the project would have a potentially significant impact related to tribal cultural resources under Impact TRIB-1. Mitigation Measure TRIB-1 would be required to reduce the project’s tribal cultural impacts to less than significant. As with the project, development under the RHNA Only Alternative could uncover previously unknown cultural resources or destroy/change structures that could be considered historic. While the RHNA Only Alternative would reduce the amount of potential housing development in the city, this alternative would likely have similar impacts due to the potential to uncover previously unknown cultural resources and would require similar mitigation to reduce impacts to a less than significant level. The RHNA Only Alternative would have similar less than significant impact with mitigation as the proposed project.

E. Energy. Given the reduced amount of development associated with the RHNA Only Alternative, this alternative would likely result in less consumption of electricity, natural gas, and vehicle fuel resources. Similar to the proposed project, new development and land use turnover under this alternative would be required to comply with statewide mandatory energy requirements outlined in Title 24, Part 6, of the California Code of Regulations (the CALGreen Code), which would decrease estimated natural gas consumption in new and/or retrofitted structures. The RHNA Only Alternative would have a somewhat less energy usage compared to the project.

F. Geology and Soils. Development under both the RHNA Only Alternative and the project would be exposed to the same existing geologic and seismic hazards within the project area and existing building requirements would be applicable to all housing projects, whether they are constructed under the proposed project or under this alternative. For these reasons, the RHNA Only Alternative would have similar impacts to those of the proposed project.

G. Greenhouse Gas Emissions. Overall, GHG emissions associated with the RHNA Only Alternative would be reduced compared to the project due to the exclusion of the 841 buffer units included in the proposed project (reduce potential residential development by 23.9 percent compared to the project). As with the project, development under the RHNA Only Alternative would be subject to all applicable local, State, and federal regulations and programs related to GHG emissions reductions. For these reasons, the GHG emissions associated with this alternative would be reduced in total amount compared to the project which already has a less-than-significant impact.

H. Hazards and Hazardous Materials. All development under this alternative, similar to development under the project, would be subject to all applicable federal, State, local laws and regulations including San Carlos General Plan policies regarding the development of contaminated sites, unanticipated discovery of contamination, hazardous material handling, and hazardous material disposal. The RHNA Only Alternative would further reduce the severity of the less-than-significant impact because this alternative would result in less housing development potential, thereby decreasing the number of construction sites

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where hazardous materials would be used. The RHNA Only Alternative would have a reduced less-than-significant hazards and hazardous materials impact due to less proposed housing development.

I. Hydrology and Water Quality. Though the project area is largely built out, both the project and the RHNA Only Alternative could result in new housing development that would increase the amount of surface runoff generated in the project area and could put future development at risk of flooding and sea level rise. Development under both the project and this alternative would be subject to all existing hydrology water quality regulations and programs, including regulations and programs intended to reduce potential impacts related to runoff, soil erosion, and flooding. Development under the project and this alternative would benefit from the additional sea level rise-related policies and actions included in the proposed Safety Element update, which would reduce the severity of existing and future flooding in the City from creeks and drainages, as well as from sea level rise. Therefore, the RHNA Only Alternative would have a somewhat reduced, but similar less-thansignificant hydrology and water quality impact compared to the project.

J. Land Use and Planning. As with the project, the RHNA Only Alternative would not physically divide an established community and would not conflict with regulations adopted to avoid environmental effects. This alternative’s exclusion of the buffer units would not result in a reduction of the less-than-significant impacts identified under the project. The RHNA Only Alternative would have similar, less than significant land use impacts as the proposed project.

K. Noise. The RHNA Only Alternative would have somewhat reduced noise impacts compared to the proposed project because it would result in less noise from housing construction projects and less traffic noise on local roadways.

L. Population and Housing. This alternative would result in fewer housing units being constructed and less of a population increase than the proposed project. less development compared to the project due to the exclusion of the project’s proposed buffer units.

M. Public Services and Recreation. This alternative would result in less housing development compared to the project due to the exclusion of the project’s proposed buffer units. Due to the RHNA Only Alternative’s reduced development potential, this alternative would result in a decrease in demand for public services and recreational facilities compared to the project. The RHNA Only Alternative would result in a reduced less-than-significant public services and recreation impact compared to the project.

N. Transportation. The EIR analysis found the impacts of the proposed Focused GPU on transportation to be less than significant. The RHNA Only Alternative would result in 2841 fewer units potentially being developed would occur with implementation of the project.

Given the reduction in development associated with this alternative, it is possible that vehicle miles traveled impacts under this alternative might decrease compared to the project. Therefore, the RHNA Only Alternative is assumed to have reduced VMT impacts when compared to the proposed project.

O. Utilities and Service Systems. This alternative would result in a reduced amount of housing development compared to the project. While this alternative assumes a housing increase

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that could increase demand for utilities services and potentially require service systems improvements and/or installations in the project area, this alternative would still result in a decrease in utilities services demands compared to the project due to this alternative’s reduced development potential. For this reason, the RHNA Only Alternative would result in a reduced, less-than-significant utilities and service system impact compared to the project.

P. Wildfire. High fire severity zones are present in the western portions of the project area, but no new housing is proposed in these areas. As with the proposed project, the RHNA Only Alternative would result in the implementation of the proposed Housing Element and Safety Element policies and actions, including the proposed Safety Element policies and actions that would reduce wildfire hazards pursuant to recent State law. Neither the project nor the RHNA Only Alternative would locate new housing in the VHFHSZ. As such, the RHNA Only Alternative would have similar less-than-significant wildfire impacts compared to the project.

Attainment of Project Objectives
The RHNA Only Alternative would meet all but one of the project objectives. Guidance from HCD on housing element preparation requires the inclusion of buffer sites to ensure enough sites have been identified to construct not only the total RHNA assignment (2,735), but also all the various income level categories as described in Project Description. Not including buffer units in the Housing Element puts the element at risk of not being approved by HCD, leaving the City at risk.

Ultimately, not including buffer units in the proposed Housing Element does not meet the City’s objectives of preparing a Housing Element that will get approved by HCD within the mandated timeframe (adoption of the new Element by January 31, 2023). Not including buffer units would also jeopardize the obtainment of the EIR Project Objective of: Assist in the development of new housing that is affordable at all income levels.

5.4 SUMMARY OF ATTAINMENT OF PROJECT OBJECTIVES
As described above under the discussion of the alternative, the No Project Alternative does not meet any of the project’s objectives and would mean the City would not be in compliance with State laws regarding General Plan Housing and Safety Elements. The City would be subject to the significant penalties for not adopting a Housing Element reflecting the 6th cycle RHNA assignment.

The RHNA Only Alternative would meet many of the City’s stated project objectives; however, HCD guidance states: To ensure that sufficient capacity exists in the Housing Element to accommodate the RHNA throughout the planning period, create a buffer in the Housing Element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower-income RHNA. Jurisdictions can also create a buffer by projecting capacity less than what is allowed from the maximum density to allow for some reductions in density, or rezoning additional sites above what is needed to accommodate the RHNA. If the City prepares a Housing Element Update that does not include buffer sites (RHNA only) HCD will not accept the proposed Housing Element Update and would direct the City to include buffer sites.

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Thus, the RHNA Only Alternative does not meet the important objective of having HCD approve the Housing Element Update and adopt the new element within the mandated timeframe (by January 31, 2023)

5.5 ENVIRONMENTALLY SUPERIOR ALTERNATIVE
If an alternative is considered clearly superior to the proposed project relative to identified impacts, Section 15126.6 of the CEQA Guidelines requires that alternative to be identified as the environmentally superior alternative. By statute, if the environmentally superior alternative is the No Project Alternative, an EIR must also identify an environmentally superior alternative among the other alternatives. The identification of the environmentally superior alternative does not consider the ability of the alternative to meet the stated project objectives; it focuses on environmental impacts only.

Per CEQA Guidelines Section 15126.6(d), the discussion of impacts associated with the alternatives is less detailed than the evaluation included in Chapters 4.1 through 4.16. Table 5-1 summarizes the development assumptions of each alternative. Table 5-2 summarizes the potential impacts of the alternatives compared to the impacts associated with implementation of the project.

The alternatives’ potential impacts are evaluated in Section 5.3.

Table 5-1: Land Use Alternatives’ Development Assumptions Land Use
Existing
Conditions
Net Change
Proposed
Focused GPU
Alternatives

1. No Project/Existing
Housing Element/2009
General Plan

2. RHNA Only Alternative
Residential
(units) 12,3851 +3,5762 +1,4363 +2,735
1 Source: Table 4.1-5 in the Needs Assessment. MIG 2021. 2 RHNA Units 2,735 + 841 buffer units = 3,576
3 Source: Table 3-2, 2009 General Plan EIR

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Table 5-2: Alternatives Impacts Compared to Project Impacts Impact/Resource Proposed Project Alternative 1:

No Project
Alternative 2:

RHNA Only Alternative
Aesthetics LTS Reduced LTS Similar LTS
Air Quality SU with Mitigation Reduced SU with Mit. Similar SU with Mitigation Biological Resources LTS with
Mitigation Reduced LTS Similar LTS with Mitigation
Cultural Resources and Tribal
Cultural Resources
LTS with
Mitigation Reduced LTS Similar LTS with Mitigation
Energy LTS Reduced LTS Reduced LTS
Geology and Soils LTS Similar LTS Similar LTS
Greenhouse Gas Emissions LTS Reduced LTS Reduced LTS
Hazards and Hazardous Materials LTS Similar LTS Reduced LTS Hydrology and Water Quality LTS Similar LTS Similar LTS Land Use LTS Reduced LTS Similar LTS
Noise LTS Reduced LTS Reduced LTS
Population and Housing LTS Reduced LTS Reduced LTS
Public Services and Recreation LTS Reduced LTS Reduced LTS Transportation LTS Reduced LTS Reduced LTS
Utilities and Service Systems LTS Reduced LTS Reduced LTS Wildfire LTS Greater LTS Similar LTS
Source: MIG, 2021
LTS= Less than Significant Impacts
SU= Significant and Unavoidable Impacts
While the No Project Alternative would result in similar or reduced impacts compared to the project due to the absence of the development proposed under the project, the No Project Alternative would not meet State laws regarding both the Housing and Safety Elements.

The RHNA Only Alternative eliminate 841 units from the proposed project and is only marginally superior to the proposed project because it would not substantially reduce the environmental impacts associated with the proposed project. Any reduction in impacts would not be significant because the number of housing units in the proposed project is not that much greater than the RHNA Only Alternative.

The RHNA Only Alternative would comply with State law, and it would satisfy most of the City’s objectives. The RHNA Only Alternative would also provide the benefit of updating the Environmental Safety and Public Services Element with the new wildfire, sea level rise, and climate change resiliency policies and actions included in the proposed Safety Element update.

Therefore, the RHNA Only Alternative is considered the environmentally preferrable alternative.

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San Carlos Focused General Plan Update Draft EIR 6-1
October 2022
CHAPTER 6 CEQA MANDATED SECTIONS

6.1 Impacts Found Less than Significant

6.1.1 Agriculture and Forestry Resources
Environmental Setting
The project area covers the City of San Carlos, which contains developed commercial, mixed use, industrial, open space, and residential land uses. The California Department of Conservation’s (CDOC) Farmland Mapping and Monitoring Program identifies the site as Urban and Built-up Land (CDOC 2019).

Thresholds of Significance
The project would have a significant impact on agriculture and forestry resources if it would:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use, b) Conflict with existing zoning for agricultural use or conflict with a Williamson Act contract,
c) Result in the loss of forest land or conversion of forest land to non-forest use, or d) Involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use.

Impacts
Impact AGFOR-1: The project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to nonagricultural use. (No Impact) The CDOC Farmland Mapping and Monitoring Program designates the majority of the City as Urban and Built-Up Land (CDOC 2022). Several areas of the project area are designated as Other Land or Grazing Land and consist of vacant, non-agricultural land and open space (CDOC 2022).

Areas within the City designated as Other Land occur in the western foothills of the City west of Alameda de las Pulgas near the City’s western boundary. The project does not propose any new development in areas designated as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. As such, the project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, and no impact would occur.

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Impact AGFOR-2: The project would not conflict with existing zoning for agricultural use or conflict with a Williamson Act contract. (No Impact)
There is no land within the City or its Sphere of Influence designated for agricultural use. The City does not contain Williamson Act contract parcels. As such, the project would have no impact related to agricultural zoning or Williamson Act contract lands, and no conflicts with existing zoning for agricultural uses would occur.

Impact AGFOR-3: The project would not conflict with existing zoning for, or cause rezoning of forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)). (No Impact)
The City does not contain lands zoned as forest land. As such, the project does not identify Opportunity Sites zoned for forest land. In addition, there are no lands zoned as timberland, or timberland zoned Timberland Production areas (as defined in Public Resources Code [PRC] 12220(g) and PRC 4526 or Government Code 51104(g)) within the City. The Project would not affect forest land or timberland or conflict with existing zoning for forest land.

Impact AGFOR-3: The project would not result in the loss of forest land or conversion of forest land to non-forest use. (No Impact)
As described above, the project does not identify Opportunity Sites zoned for forest land. As such, no impacts related to the loss of forest land or conversion of forest land to non-forest use would occur.

Impact AGFOR-4: The project would not involve other changes in the existing environment that, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use. (No Impact) As described above, the sites selected for future intensification of residential density as described in the Project Description do not include farmland or forest land. These sites are within a developed urban area and are concentrated in existing developed neighborhoods and commercial thoroughfares. None of the identified sites are located on agricultural land. The project would not result in the conversion of Farmland to non-agricultural use or conversion of forest land to nonforest use. As such, no impacts related to the conversion of agricultural or forest land to other land uses would occur.

6.1.2 Mineral Resources
Environmental Setting
The City of San Carlos is a developed city located in an urban area. There are no mines or known mineral resources in the City of San Carlos (San Carlos 2009).

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Regulatory Setting
State
Surface Mining and Reclamation Act
The Surface Mining and Reclamation Act (SMARA) was enacted by the California legislature in 1975 to address the need for a continuing supply of mineral resources, and to prevent or minimize the negative impacts of surface mining to public health, property, and the environment. As mandated under SMARA, the State Geologist has designated mineral land classifications to help identify and protect mineral resources in areas within the state subject to urban expansion or other irreversible land uses which would preclude mineral extraction. SMARA also allowed the State Mining and Geology Board (SMGB), after receiving classification information from the State Geologist, to designate lands containing mineral deposits of regional or statewide significance.

Thresholds of Significance
The project would have a significant impact to mineral resources if it would:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

Impacts
Impact MIN-1: The project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state. (No Impact) As described in Section 4.10 Land Use and Planning, what is now the City of San Carlos was occupied by ranchos established through the disbursement of land grants from the Spanish government in the early 1800s. The construction of the first railroad from San Francisco to San Jose and the expansion of infrastructure spurred the successful development of the City’s first residential neighborhoods, followed by commercial development in the form of gas stations, grocery stores, a pharmacy, and industrial facilities (San Carlos 2009). San Carlos does not have a history of quarrying or mineral extraction.

The State Mining and Geology Board establishes Mineral Resource Zones (MRZs) to designate lands that contain mineral deposits (State Mining and Geology Board 2000). The classifications used by the state to define MRZs are as follows:
• MRZ-1: Areas where the available geologic information indicates no significant likelihood of significant mineral deposits
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• MRZ-2a: Areas where the available geologic information indicates that there are significant mineral deposits
• MRZ-2b: Areas where the available geologic information indicates that there is a likelihood of significant mineral deposits
• MRZ-3a: Areas where the available geologic information indicates that mineral deposits exist; however, the significance of the deposit is undetermined • MRZ-3b: Areas where the available geologic information indicates that mineral deposits are likely to exist; however, the significance of the deposit is undetermined • MRZ-4: Areas where there is not enough information available to determine the presence or absence of mineral deposits
The City does not have mineral resource areas as noted in the Environmental Management Element of the 2030 General Plan. The City does not have land designated by the California Department of Conservation as having the potential for being a significant source of composite materials or industrial minerals. As such, none of the project’s proposed Opportunity Sites is located in an area with known mineral deposits. There would be no impact related to the loss of availability of a known mineral resource that would be of value to the region and the residents of the state as a result of the Project.

Impact MIN-2: The project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan. (No Impact)
The City does not contain mineral resource recovery sites; as such, implementation of the project would not result in the loss of availability of a locally important mineral resource recovery site delineated in the 2030 General Plan, a Specific Plan, or any other land use plan. There would be no impact.

6.1.3 References
California Department of Conservation. 2018. California Important Farmland Finder. Accessed on July 18, 2022 at https://maps.conservation.ca.gov/DLRP/CIFF/.

City of San Carlos. San Carlos 2030 General Plan. October 12, 2009.

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6.2 CUMULATIVE IMPACTS
Section 15130(a) of the CEQA Guidelines requires that the EIR "discuss cumulative impacts of a project when the project's incremental effect is cumulatively considerable...." The CEQA Guidelines (Section 15355) define "cumulative impacts" as "...two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts."
The analyses of quantitative cumulative impacts in this EIR are based on the “summary of projections” method, as authorized by section 15130(b)(1)(B) of the CEQA Guidelines.

The proposed San Carlos Focused GPU is itself a cumulative project because it would be implemented across the entire project area incrementally and cumulatively over the approximately eight year time horizon of the proposed 6
th cycle Housing Element and the Environmental Safety
and Public Services Element. This Program EIR evaluates the Focused GPA as one “project” in accordance with CEQA. All potentially significant cumulative impacts are addressed in this chapter with the following exceptions:

A. The project would have no impacts in the following two environmental topics: Agriculture and Forest Resources; and Mineral Resources. See Chapter 6.1 (Impacts found Less than Significant), above. Therefore, these topics are not further evaluated in the DEIR and cumulative impacts for these resources are considered less than significant.

B. The BAAQMD identifies all regional air pollutant emission impacts and climate change impacts as inherently cumulative impacts because they contribute to regional and global conditions, and are not confined to physical boundaries. Accordingly, the analyses of these impacts in Chapters 4.2 (Air Quality), 4.6 (Energy) and 4.7 (Greenhouse Gas Emissions and Global Climate Change) are analyses of cumulative impacts.

C. Cumulative noise impacts are analyzed in detail in Chapter 4.11 (Noise).

D. Cumulative transportation impacts are analyzed in detail in Chapter 4.14 (Transportation).

All other potential cumulative impacts are addressed in the sections that follow below.

6.2.1 Aesthetics
Scenic Vistas
A cumulative impact to scenic vistas would occur if cumulative housing projects within the project area, combined with other cumulative projects in the surrounding area, resulted in the substantial degradation of quality or obstruction of particularly scenic views available from a recognized scenic vista. Project specific impacts with respect to scenic vistas were determined to be less than significant. Buildout of the Focused GPU addresses the City’s RHNA assignment plus buffer units for the next 8-year cycle and would occur primarily in the downtown area and along El Camino

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Real and are far from scenic vistas. Since the project area is almost entirely urbanized, incremental changes that would occur from implementation of the proposed Focused GPU would not result in cumulative impacts with respect to scenic vistas. Potential cumulative impacts would be less than significant.

Scenic Highways
Since the proposed housing sites are primarily clustered in the downtown and El Camino Real areas, new housing would not be visible from Hwy 280 which is a designated state scenic highway.

The only housing development that would be visible from Hwy 280 would be ADUs and lot splits done under SB9. Housing development proposed by the project would not result in impacts to scenic resources within a state scenic highway. Therefore, the proposed Focused GPU would not contribute to a potential cumulative significant impact to a scenic highway. Potential cumulative impacts would be less than significant.

Degrade Visual Character
Construction and habitation of future housing development within the project area was determined to result in less than significant impacts to the existing visual character and quality of the project area and to the surrounding area. Future housing projects, as well as other development allowed under the 2009 General Plan considered in the cumulative scenario would generally be subject to the City’s underlying zoning standards that include regulations pertaining to permitted uses, minimum lot dimensions, and maximum building height. The proposed Focused GPU includes Zoning Ordinance revisions related to setbacks, FAR, parking, landscaping, and public open space, among other things.

Future projects within the project area would be located where similar existing uses occur, and as such, would not entail a significant visual change such that the existing visual character or quality of project sites and their surroundings would be substantially degraded. Design Review per Municipal Code Chapter 18.29.060 is required for all projects that require a permit for new construction, reconstruction, rehabilitation, alteration, or other improvements to the exterior of a structure. The purpose of the Design Review is to ensure that new development supports the General Plan’s goal of creating a vibrant pedestrian- and transit-oriented core with distinctive neighborhoods and districts with a diversity of building types that provide continuity in scale and character with the appropriate transitions. Specific design review criteria are provided in Municipal Code Chapter 18.29.060.

Currently, specific design review criteria are provided in the Zoning Code (Municipal Code Chapter 18.29.060). However, the project will revise Land Use Element Actions LU-8.5 and LU9.2 of the General Plan to specifically include objective design standards and transitional design standards for multi-family residential buildings and commercial uses adjacent to single-family homes among the proposed Zoning Ordinance Amendments. See Chapter 4.1.4, Impact AES-3 for a discussion of the new land use policies directing the preparation of objective design standards.

The City has already initiated a planning effort to develop these objective design standards. The

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benefit of the City adopting objective design standards is that they would apply to all projects, even “by right” projects and ministerial projects, and can be used as standard conditions of project approval.

In addition, the project includes two revised polices in the Land Use Element pertaining to views and building height for new development (see Chapter 4.1.4, Impact AES-3 discussion).

Conformance with the new Land Use Element policies would ensure that new development under the proposed Focused GPU would not adversely affect views, and would not contribute to cumulative impacts that would degrade the existing visual character or quality of the area and its surroundings. Potential cumulative impacts would be less than significant.

Light and Glare
Project related impacts with respect to light and glare were determined to be less than significant.

Lighting and building materials associated with cumulative housing development would be subject to Municipal Code 18.29.060(J) which requires lighting and lighting fixtures be designed to complement buildings, be of appropriate scale, provide adequate lighting over walkways and parking areas to create a sense of pedestrian safety, and avoid creating glare. If detailed information regarding proposed lighting and building materials are not known during preparation of necessary environmental documentation for cumulative projects, then the adoption of applicant-proposed measures or mitigation measures would likely be required by the City of San Carlos to ensure that lighting and glare impacts are less than significant. Therefore, cumulative impacts would be less than significant.

6.2.2 Biological Resources
Housing development associated with the implementation of the Focused GPU would not significantly contribute to the ongoing loss of natural lands in San Mateo County, or San Carlos.

Proposed housing development under the Focused GPU would be predominantly within urbanized areas and established neighborhoods. Much of the remaining biodiversity within the project area is concentrated in park and open space areas and within Devonshire Canyon, or along the two creeks within the city. Existing General Plan policies would continue to protect biological resources within the City and proposed mitigation measures as part of the Focused GPU would further protect biological resources from future development. Mitigation measures BIO-1, BIO-2, and BIO-3 ensure that future housing development implemented as part of the Focused GPU would not result in significant impacts to sensitive species, nesting birds, and roosting bats. Therefore, the cumulative impact is considered less than significant.

6.2.3 Cultural and Tribal Cultural Resources
Investigations for Native American tribal cultural and archaeological resources and sites and historical resources in the built environment are not comprehensive for the project area and in the case of buried resources, are unknown as they have yet to be identified since they are typically

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only uncovered during earth moving activities. Therefore, cumulative impacts to cultural, historic, or tribal cultural resource sites or resources are difficult to quantify and assess.

Cumulative impacts would occur when a series of actions leads to the loss of a substantial type of site, building, or resource. For example, while the loss of a single historic building may not be significant to the character of a neighborhood or streetscape, continued loss of such resources on a project-by-project basis could constitute a significant cumulative effect. This is most obvious in historic districts, where destruction or alteration of a percentage of the contributing elements may lead to a loss of integrity for the district overall. Changes to the setting or atmosphere of an area, for example, by adding modern structures on all sides of a historically significant building, thus altering the aesthetics of the streetscape, would create a significant impact. Destruction or relocation of historic buildings would also significantly impact the setting.

As discussed in Chapter 4.4 Cultural and Tribal Cultural Resources, however, development in areas both within and outside the project area would be subject to federal and state laws protecting cultural and tribal cultural resources. The goals and polices of the Land Use Element protecting historic architectural resources, archaeological resources, human remains, and historic architectural resources – in combination with the actions put forth in that Element as well as Mitigation Measure TRIB-1 and mitigation in subsequent analyses to address site specific conditions and records for known resources – would result in less-than-significant cumulative impacts to cultural and tribal cultural resources.

6.2.4 Geology and Soils
The City of San Carlos is located in a seismically active region of the state and within relative proximity to several major faults. Geologic and soils hazards are largely site specific. The magnitude of this risk would be dependent on the site-specific conditions present at each location.

Regardless of the potential risk, any future projects within the project area would be required to implement design and construction practices intended to reduce and or avoid site-specific geologic and soils risks (either through compliance with general plan policies and local building code, or through the implementation of site-specific mitigation measures developed as a result of required site investigations). The proposed project does not allow any specific future development to occur.

Mitigation in subsequent analyses to address site-specific geological conditions and site soils would render the site-specific risks posed by local and regional hazards such as ground shaking, liquefaction, and other soils and geologic-related conditions less than significant for each project and would prevent significant cumulative impacts from occurring. The cumulative impacts of the project would be less than significant.

6.2.5 Hazards and Hazardous Materials
Implementation of the project would result in additional housing development within the City which could increase the potential for exposure to hazards and hazardous materials. Other types of development within the City and surrounding cities throughout the region could induce similar exposure to hazardous materials and other hazards. However, the housing development proposed

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by the Focused GPU would have localized effects on the exposure of residents to these hazards through the housing construction process and the types of hazardous materials used during construction. This type of exposure would not be compounded by additional exposure in other parts of the region. Additionally, future development implemented because of the project would be subject to existing and proposed General Plan policies, Zoning Code requirements, to ensure that all hazards and hazardous materials are managed appropriately and according to California and local regulations to ensure public safety. Subsequently, the implementation of the project would have a less-than-significant cumulative impact on hazards and hazardous materials. The updated Environmental Safety and Public Services Element would not increase the public’s risk from hazards and hazardous materials and would not contribute to cumulative impacts.

6.2.6 Hydrology and Water Quality
The watershed is used as the geographic unit for the cumulative hydrology and water quality analysis based on the concept that many water quality problems, like the accumulation of pollutants or nonpoint source pollution, are best addressed at the watershed level. In addition, California’s regulatory framework for protection of water quality focusses on the watershed.

The proposed project could, in conjunction with other projects within the watershed, contribute urban runoff pollutants to downstream receiving waters, resulting in degradation of water quality delivered to the San Francisco Bay. Future projects within the watershed would incorporate BMPs, LID, retention, and treatment measures per NPDES requirements, to control and/or treat stormwater runoff during construction and operation to prevent significant erosion, siltation, flooding, and other sources of pollution. As such the cumulative impact of the project related to surface water quality is less than significant. Similarly, Chapter 15.56 of the Municipal Code (Floodplain Management). establishes construction requirements for development that would minimize flood hazard risks, including anchoring, elevation, and flood-proofing, and standards for utilities, subdivisions, residential, and non-residential construction. General Plan Policies CSS-2.4 and CSS-2.12 increase flood protection through reductions in impervious surface area and by requiring new development projects to incorporate storm drain systems that control runoff rates and volumes. Therefore, cumulative impacts because of impeding or redirecting flood flows is also less than significant.

San Carlos does not utilize groundwater for potable water supplies, therefore future development associated with the project would have no effect on groundwater supplies. New or redevelopment projects would be required to implement LID-based runoff treatment controls in conformance with the MRP, including the use of permeable paving materials that could potentially allow for greater groundwater recharge through infiltration compared to existing conditions. Groundwater depletion could result from dewatering activities during subterranean construction, however, the implementation of existing General Plan Policy EM-5.10 and related Actions (Actions 5.1, 5.2,

5.4 & 5.10, described in 4.9 Hydrology) would result in less than significant cumulative impacts for groundwater depletion. Therefore, the project would result in a less than significant cumulative impact groundwater supply, recharge, and quality.

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6.2.7 Land Use
As described in Chapter 4.10 Land Use, implementation of the proposed project would not result in a significant land use impact by potentially physically dividing an established community; therefore, it would not make a cumulatively considerable contribution to an environmental impact related to physically dividing an established community.

The proposed project would be consistent with applicable land use plans and policies adopted for the purpose of avoiding or reducing an adverse environmental effect. The City would continue to review future development proposals to ensure compliance with the City’s environmental policies and utilize its discretion to disapprove projects and/or general plan amendments that would cause significant cumulative impacts to the environment. However, no such conflicts, including those with Plan Bay Area 2050, have been identified for the proposed project. Implementation of the proposed project would not make a cumulatively considerable contribution to conflicts with land use plans and policies adopted for the purpose of avoiding or reducing an adverse environmental effect. This potential impact would be less than significant.

6.2.8 Population and Housing
As described above, the proposed updated Housing Element and proposed Environmental Safety and Public Services Element would not result in substantial unplanned population growth or the displacement of substantial numbers of housing units, requiring the construction of replacement housing. The potential growth in housing, and related population, identified in the Housing Element Update would be consistent with the City’s RHNA and Plan Bay Area 2050. Other planning jurisdictions in the Bay Area are currently updating their housing elements to identify available sites to accommodate their designated RHNA share, as jurisdictions must accommodate more than 441,000 new housing units to meet the RHNA for the region during the 2023-2031 planning period. Other housing elements must also prepare for the population growth projected for the region and the associated need for new housing to accommodate that growth. As with the San Carlos Housing Element Update, the growth accommodated by the housing elements of other jurisdictions would be planned growth, not unplanned growth; implementation of the project would not result in a significant cumulative impact.

Implementation of the updated San Carlos Housing Element would result in a net increase in housing. Thus, the project would not make a cumulatively considerable contribution to a regional impact related to a substantial displacement of housing or people. This cumulative impact would be considered a less than significant impact.

6.2.9 Public Services and Recreation
Housing development that is facilitated by the Focused General Plan Update, in combination with other cumulative development in the project area, would increase the demand for all public services. Public services can be potentially impacted by increased population, especially when new infrastructure is not built to meet population increases or when existing facilities are not adequately

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maintained. Alternatively, impacts may also occur when new facilities are built, resulting in physical impacts to the environment resources. The proposed Environmental Safety and Public Services Element provides policies addressing levels of services, and new development would be required to pay school impact fees to address the need for new or expanded facilities. New developments would result in increased property taxes which would assist in paying for the incremental increases in demand for public services. Further, should new public services facilities be required, environmental review would identify site-specific conditions and physical changes resulting from facility expansion.

Future regional growth would result in increased demand for park and recreational facilities throughout the region. As a result, City of San Carlos and other jurisdictions would need to expand and construct additional parks and other recreational facilities to meet the increased demand. State law allows jurisdictions to require additional development to fund park improvements, which would ensure the provision of adequate parklands. However, the location and size of additional facilities would be determined as part of future development activity. As specific parkland expansion or improvement projects are identified, additional project-specific, environmental analysis would be completed. As a result, a significant cumulative impact associated with public services and recreations would not occur.

6.2.10 Utilities and Service Systems
Cumulative development within the Cal Water service area will continue to increase demands on water supplies. As discussed in Chapter 4.15 Utilities and Service Systems, it is possible that new or expanded facilities may be needed to meet future water demand within Cal Water’s service area.

Cal Water has developed a Water Shortage Contingency Plan to address potential water shortage conditions. In addition, any future expansion of existing facilities or construction of new facilities would be required to undergo environmental review pursuant to CEQA. Because water-related impacts would be identified, along with measures to mitigate any significant impacts, as part of the CEQA compliance process for future project-specific proposals, the project would not have a cumulatively considerable contribution to a significant cumulative impact regarding water supply services. This would be considered a less than significant impact.

The SVCW WWTP (wastewater facility) serves other jurisdictions in addition to the City of San Carlos, and it is possible that incremental increases in demand, as anticipated under the project, and in conjunction with increased demand for other communities, could result in the need for future new or expanded wastewater treatment facilities. The need for new or expanded wastewater infrastructure would be addressed on a case-by-case basis for each cumulative project, and would be subject to CEQA review and any resulting mitigation measures. Therefore, cumulative impacts related to wastewater facilities would be less than significant.

The geographic scope for cumulative electricity and natural gas impacts is the PG&E service area, which includes the Focused GPU project area. PG&E is subject to the requirements set forth and/or enforced by the CPUC. The need for electric and natural gas infrastructure would be addressed on a case-by-case basis for each cumulative project, and would be subject to CPUC requirements,

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similar to those applicable to the project. Therefore, cumulative impacts related to electric power and natural gas transmission facilities would be less than significant.

All development projects in San Carlos are required to be consistent with adopted solid waste and recycling regulations and programs, including those described in Chapter 4.15 Utilities and Service Systems. The solid waste disposal and recycling facilities used by the City of San Carlos have ample capacity, and the applicable regulations and programs have been deliberately designed and adopted to avoid or reduce cumulative solid waste/recycling impacts to less-than-significant levels.

The overall cumulative solid waste/recycling impact of cumulative development would be less than significant.

6.2.11 Wildfire
The project includes updated policies within the Environmental Safety and Public Services Element and the Land Use Element which are specifically designed to address wildfire hazards in the community. Implementation of Policies ESPS-3.4 – 3.11 and Actions ESPS-3.6 – 3.9 and 4.2, and LU-10.6 would ensure that wildfire hazards associated with future development within the City is minimized. The majority of land use density changes proposed by the housing element is concentrated in urbanized areas outside of the VHFHZ. The cumulative impact is considered less than significant.

6.2.12 References
City of San Carlos. San Carlos 2030 General Plan. October 12, 2009.

City of San Carlos Municipal Code. August 22, 2022.

6.3 GROWTH INDUCEMENT
CEQA Guidelines Section 15126.2(d) requires that the EIR discuss "...the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment." The proposed project would result in an allowable increase of up to 2,735 additional dwelling units. An estimated population increase of approximately 11.7 percent (approximately 5,105 residents) is projected for the 2040 horizon year (from 2020). However, no substantial, detrimental, growth-inducing effect is expected.

State law requires the City to promote the production of housing to meet its fair share of the regional housing needs distribution made by ABAG. The housing and employment growth in San Carlos would generally have beneficial effects by allowing the City to address its regional fairshare housing obligations. In addition, the type of growth envisioned by the proposed Focused GPU would be concentrated in specific, designated areas and new development would be pedestrian-friendly, use land efficiently, and promote transportation alternatives.

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Housing along and near the El Camino Real transit corridor and Caltrain station would be encouraged, as would mixed-use development. The growth envisioned under the 2030 General Plan would result in regional benefits by promoting growth that encourages less automobile dependence and supports regional transit systems, which could reduce air quality and noise impacts associated with population growth and non-residential development. Encouraging infill growth in the Downtown area and other designated areas and maintaining the City’s open space designations would help to preserve open space at the urban fringe and reduce development pressures on lands outside the city limit. For these reasons, the growth-inducing effects of implementation of the Focused GPU would be beneficial to the city and surrounding areas.

The goals, polices and implementing actions, contained in the proposed Focused GPU address the potentially negative aspects of growth, have been designed to facilitate development efficiently and effectively in an area where roads and infrastructure already exist. The more compact urban form envisioned by the Focused GPU is expected to improve the livability of San Carlos by enhancing open space and recreation, improving walking and bicycling opportunities, increasing economic vitality and job opportunities, and reducing vehicle-miles-travelled (VMT). The potential growth-related impacts associated with the Focused GPU have also been evaluated in the topical chapters of this EIR (Aesthetics, Biological Resources, etc.) and, as appropriate, mitigation measures have been applied to address such impacts. In addition, implementation of the proposed Focused GPU would not involve the extension of roads, major sewer or water lines, or the construction of other major infrastructure facilities that would induce growth in areas adjoining San Carlos.

6.3.1 Indirect Impacts
The 2030 General Plan encourages new growth in the urbanized areas of San Carlos. Development in these areas would consist of infill development on the remaining vacant sites or redevelopment of underutilized sites. Since the infrastructure is largely in place, and since commercial growth would be required to comply with the City’s standards for public services and utilities, secondary growth-inducing effects do not represent a significant environmental impact.

6.3.2 References
City of San Carlos. San Carlos 2030 General Plan. October 12, 2009.

6.4 SIGNIFICANT UNAVOIDABLE IMPACTS
CEQA Guidelines Section 15126.2(b) requires that the EIR discuss "significant environmental effects which cannot be avoided if the proposed project is implemented." As described in the environmental analyses contained in Section 4.1 through 4.16 of this EIR, most of the potentially significant impacts would be reduced to a less than significant level with mitigation. However, there are Air Quality impacts, listed below, that are considered significant and unavoidable impacts as the proposed mitigation is not able to reduce the impacts to less than significant levels. These significant and unavoidable impacts are:

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Impact AIR-1 – The project would conflict with or obstruct implementation of the applicable air quality plan. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMDrecommended threshold of significance. However, it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact) Impact AIR-2 – The project would result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment under an applicable federal or state ambient air quality standard. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMD-recommended threshold of significance. However, it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact)
Impact AIR-3 – The project could expose sensitive receptors to substantial pollutant concentrations. Implementation of Mitigation Measure AIR-2 would reduce construction criteria air pollutant and toxic air contaminant emissions to a level that is below the BAAQMDrecommended threshold of significance. However, with regard to localized criteria air pollutant and TAC emissions generated during future construction activities it cannot be definitively known or stated at this time that all future development projects occurring under implementation of the proposed project would be able to reduce potential criteria air pollutant and TAC emissions to levels that are below BAAQMD thresholds. This impact would be considered significant and unavoidable even with the incorporation of feasible mitigation measures. (Significant and Unavoidable Impact)
Impact AIR-5 –The project could cause substantial adverse cumulative impacts with respect to Air Quality. Because future construction activities could result in ozone precursor and PM emissions that exceed BAAQMD thresholds, the project could increase the frequency and/or severity of air quality violations in the Bay Area Basin or otherwise impede attainment of air quality standards. (Significant and Unavoidable Impact)

6.5 SIGNIFICANT IRREVERSIBLE CHANGES
Section 15126.2(c) of the CEQA Guidelines requires a discussion of "significant irreversible environmental changes which would be caused by the proposed project should it be implemented." An example of such an irreversible commitment is the construction of highway improvements that would provide public access to previously inaccessible areas. A project would generally result in a significant irreversible impact if:

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• Primary and secondary impacts would commit future generations to similar uses. • The project would involve a large commitment of nonrenewable resources. • The project would involve uses in which irreversible damage could result from any potential environmental accidents associated with the project.

6.5.1 Commitment of Future Generations to Similar Uses
Housing development under the Focused GPU would result in the intensification of residential and mixed-use zoned areas to meet the City’s RHNA. This development would constitute a long-term commitment to intensification of residential and other urban uses.

6.5.2 Commitment of Non-Renewable Resources
CEQA Guidelines Section 15126.2(c) requires that the EIR discuss "significant irreversible environmental changes which would be caused by the proposed Project should it be implemented." Since nearly all of San Carlos is developed and the project would not significantly change the circulation pattern or make other major changes to backbone infrastructure facilities, there would not be any significant irreversible physical changes caused by the Focused GPU. Housing development allowed under the Focused GPU would irretrievably commit nonrenewable resources to the construction and maintenance of buildings, infrastructure, and roadways. These nonrenewable resources include mining resources such as sand, gravel, steel, lead, copper, and other metals. Buildout of the Focused GPU also represents a long-term commitment to the consumption of fossil fuels, natural gas, and gasoline. Increased energy demands would be used for construction, lighting, heating, and cooling of residences, and transportation of people within, to, and from the planning area. Because development facilitated by the proposed Focused GPU would be required by law to comply with California Code of Regulations Title 24 (including updates over time) and adopted City energy conservation ordinances and regulations, implementation of the project would not be expected to use energy in a wasteful, inefficient, or unnecessary manner.

The consumption or destruction of other non-renewable or slowly renewable resources would also result during construction, occupancy, and use of individual development sites under the proposed Focused GPU. These resources would include, but would not be limited to, lumber, concrete, sand, gravel, asphalt, masonry, metals, and water. Project implementation would also irreversibly use water and solid waste landfill resources. However, development under the proposed Focused GPU would not involve a large commitment of those resources relative to supply, nor would it consume any of those resources wastefully, inefficiently, or unnecessarily, especially considering ongoing City conservation and recycling programs.

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CHAPTER 7.0: LIST OF PREPARERS

LEAD AGENCY
City of San Carlos: www.cityofsancarlos.org Planning Division City of San Carlos 600 Elm Street, First Floor San Carlos, CA 94070
Lisa Porras, Planning Manager
Grace Le, City Engineer
Amy Newby, Parks and Recreation Director
Aaron Aknin, AICP, Consultant to the City with Good City Company Chris Nicholas, Consultant to the City with Good City Company

CONSULTANTS
MIG Inc.: www.migcom.com 800 Hearst Avenue, Berkeley, CA 94710 Mike Campbell, AICP, Director of Environmental Analysis Chris Dugan, Director of Air Quality, Greenhouse Gas, and Noise Services Barbara Beard, Senior Project Manager
Christina Lau, Senior Environmental Analyst/Project Manager Alex Broskoff, Biologist II
Megan Kalyankar, Senior Biologist
Miranda Miller, Project Associate
Amy Paulsen, Senior Environmental Planner
Robert Westbrook, Environmental Planning Project Associate W-Trans: www.w-trans.com 414 13th Street, 5th Floor, Oakland, CA 94612 Mark Spencer, W-Trans Senior Principal, California Traffic Engineering Consultants Barry Bergman, AICP, Senior Planner

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MD Acoustics, LLC: www.mdacoustics.com 1197 Los Angeles Ave, Suite C-256, Simi Valley, CA 93065, P. 805.426.4477
Tyler Klassen, Air Quality Specialist
Claire Pincock, Noise Specialist

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City of San Carlos Focused General Plan Update
Draft Environmental Impact Report
SCH# 2021120442

APPENDICES
Lead Agency:

City of San Carlos
Community Development Department
Planning Division
600 Elm Street
San Carlos, CA 94070
www.cityofsancarlos.org
October 2022
Prepared with the assistance of MIG, Inc.

CITY1s 1
·
6000
LIVING

SAN CARLOS

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San Carlos Focused General Plan Update Project
Appendix A: NOP, Responses, and
Distribution List

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NOTICE OF PREPARATION OF AN

ENVIRONMENTAL IMPACT REPORT
PROJECT TITLE: Environmental Impact Report for the City of San Carlos Focused General Plan Update: Housing, Land Use and Safety Elements and Accompanying Zoning Ordinance Amendments
PURPOSE OF THIS NOTICE: The City of San Carlos (City) will be the Lead Agency and will prepare an Environmental Impact Report (EIR) for the proposed San Carlos Housing, Land Use and Safety Element Updates and accompanying Zoning Ordinance Amendments Project (“Project” or “proposed Project”). The City is requesting input from you or your agency with respect to the scope and content of the environmental information relevant to your agency’s or organization’s statutory responsibilities or interests in connection with the proposed Project.

The City is preparing the City of San Carlos General Plan Housing, Land Use and Safety Element Updates that were last updated in 2009, with the exception of the Housing Element, which was last updated in 2015. While the Housing and Safety elements are the original focus of the Focused General Plan Update, the Land Use Element will also need to be revised to ensure General Plan consistency, as required by State law. In addition, Zoning Amendments will also be made to implement new policies and land use intensities envisioned in the Housing Element Update to accommodate the provision of additional housing needs as part of San Carlos’ Regional Housing Needs Allocation (“RHNA”). The subject EIR will provide an environmental assessment of the updated Housing, Land Use and Safety Elements, and Zoning Ordinance and related Municipal Code updates. The overall purpose of the Housing, Land Use and Safety Element Updates are to create a policy framework that will:
 Facilitate new housing growth within San Carlos in response to the region’s need for more affordable and market rate housing, as well as develop housing solutions to meet the City’s RHNA, or new housing unit allocation; and
 Provide updated information about natural and man-made hazard risks to the community; provide new information related to wildfire hazard, sea level rise and resiliency planning to the Safety Element; and present policies designed to protect life and property from these hazards
PUBLIC COMMENT INVITED: You are invited to submit written comments and recommendations regarding the scope and content of the EIR that is being prepared.

Comments should focus on discussing possible impacts on the physical environment, ways in which potential adverse effects might be minimized, and alternatives to the project in light of the purpose of the environmental review to provide useful and accurate information about such factors. Note that if you challenge this project proposal in court, for topics addressed in the EIR, you may be limited to raising only those issues you or someone else raised in written correspondence during the review period of the EIR or at the public meeting described in this notice.

COMMENT PERIOD: A 45-day public review period for the Notice of Preparation (NOP) shall begin on December 17, 2021, and end on January 31, 2022, at 5:00 p.m. All comments regarding the EIR must be made in writing and received by this ending date/time.

Written comments and recommendations may be directed to Lisa Porras, Planning Division, City of San Carlos, 600 Elm Street, San Carlos, CA 94070, or sent via email to:

[email protected]. Specify “Housing and Safety Element Update EIR” in the subject line.

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Notice of Preparation: San Carlos General Plan Housing and Safety Element Update EIR December 17, 2021 2
PUBLIC SCOPING MEETING: The Planning Commission will hold the public scoping meeting to provide a forum for submittal of comments on the analysis to be included in the EIR. The meeting will be held on January 12, 2022, starting at 6:00 p.m. Meeting details will be available on the City’s website http://sancarlosca.iqm2.com/citizens/default.aspx after 5:00p.m. on Thursday, January 6, 2022.

You are invited to a Zoom webinar.

Topic: Special PC Meeting: Environmental Review Scoping Meeting Please click the link below to join the webinar:
https://us02web.zoom.us/j/88523285187
Or One tap mobile:

US: +16699006833,88523285187# or +13462487799,,88523285187# Or Telephone:

Dial (for higher quality, dial a number based on your current location):

US: +1 669 900 6833 or +1 346 248 7799 or +1 253 215 8782 or +1 301 715 8592 or +1 312 626 6799 or +1 929 436 2866
Webinar ID: 885 2328 5187
International numbers available: https://us02web.zoom.us/u/kcQosnyGOj FOR FURTHER INFORMATION: call Lisa Porras at (650) 802-4264or e-mail:

[email protected]

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Housing and Environmental Safety Element Update EIR
Project Description
PROJECT LOCATION: The City of San Carlos is located in the central-east portion of San Mateo County on the San Francisco Peninsula, approximately halfway between San Francisco and San Jose. San Carlos’ city limit extends to the City of Belmont to the northwest, the San Francisco Bay to the northeast, the City of Redwood City to the southeast, and unincorporated San Mateo County to the southwest (Figure 1 - Regional Location).

Freeways and highways offer regional access to San Carlos, including the Bayshore Freeway (US 101) on the east and Junipero Serra Freeway (I 280) to the west. A regional artery, El Camino Real (SR 82) traverses San Carlos in a northwest-southeast direction. A subregional arterial through San Carlos is Alameda de la Pulgas.

PLANNING AREA: The City of San Carlos encompasses approximately eight square miles, nearly all of which are developed with urban land uses. San Carlos’ sphere of influence (Planning Area) includes three areas of unincorporated San Mateo County – the Devonshire Area (including two non-adjacent areas: Devonshire Canyon and a nearby 17-acre area adjacent to Club Drive, Cranfield Avenue, and the City of Belmont), Palomar Park, and Pulgas Ridge (formally known as the Hassler Area). The City’s Planning Area consists of 10,348 parcels encompassing 3,570 gross acres (Figure 2 - Planning Area).

Gross residential land uses represent the predominant existing land use in San Carlos (1,970 gross acres), which account for more than half (55 percent) of the total land area. Single-family residential uses - generally consisting of one house per lot - make up over 50 percent of the residential category. Multi-family residential uses make up less than five percent of residential uses. Mixed – Use land uses total 8 acres (less than one percent).

Commercial and light industrial land uses total 488 acres (14 percent). Public Facilities and Institutions makes up 311 gross acres (9 percent). Park and open space uses encompass 668 gross acres (19 percent). Parking uses total 20 acres or less than one percent, while vacant land makes up 106 acres and three percent of the Planning Area.

Land Use Category Description:

The following description of land uses is defined in the City’s General Plan. Figure 3 shows the existing land uses within the City and Figure 4 presents the existing General Plan Land Use Map. Figure 5 presents the City’s existing Zoning Map (see Attachments).

Residential Uses1
Residential uses comprise the largest land use category, 55 percent of the Planning Area.

Residential uses are comprised of single-family, multi-family, and mixed use. Single- family use is generally considered to be one house per lot. Single-family residential use makes up over 50 percent of the entire planning area and is located throughout San Carlos including east of 1 The San Carlos Zoning Ordinance Chapter 18.04 sets forth four (4) residential zoning districts with the following densities:
 Single Family Low Density development ranges from three units per net acre  Single Family Residential Density allows for residential densities up to six units per net acre  Multi Family Low Density Residential allows for residential densities up to twenty units per net acre  Multi Family Medium Density Residential allows for residential development at up to fifty nine units per net acre

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El Camino Real. Multi-family use is generally considered to be more than three housing units on a lot and can include stacked flats and townhomes. Like single-family use, multi-family uses are found throughout the Planning Area.

Residential Densities
Single Family Residential RS-3 and RS-6 Zoning Districts allow up to 3 units to the acre and 6 units to the acre respectively. Of the single-family residential zoning districts, the most predominant is the RS-6 Single Family Zoning District located throughout San Carlos and west of US 101, as well as a neighborhood of single-family homes to the east of El Camino Real and Old County Road.

Low residential density (defined as up to twenty units per net acre, in accordance with the San Carlos Zoning Ordinance) and occur in various specific locations in the San Carlos hills. Low residential density can occur in the following housing types or building forms --stand-alone or one housing unit on a lot, duplexes, triplexes, stacked flats, townhouses, and rowhouses.

Medium density residential RM-20 and RM-59 Zoning Districts allow for 20 units to the acre and 59 units to the acre, respectively. These zones accommodate stacked flats, townhomes, and rowhouses developed at a scale and form appropriate to neighborhood context and adjacent single-family residential uses. The medium density residential is generally located in the east and central portions of San Carlos—Downtown, Laurel Street, El Camino Real, San Carlos Avenue, and Cherry Street. Smaller areas of medium density residential is found along the Devonshire area’s southern edge and along San Carlos’ western boundary.

Accessory dwelling units (ADUs) are another residential form found in San Carlos. San Carlos allows ADUs to be established on any lot in any zoning district where a primary single-unit dwelling has been previously established or is proposed to be established in conjunction with construction of a second unit. Junior Accessory Dwelling Units (JADUs) are a subset of ADUs.

JADUs are contained entirely within an existing or proposed single-family residence. Recent State law (2019) allows ADUs to be built in multi-family districts under specified conditions. As of November 2021, San Carlos has permitted 211 ADUs.

Mixed-Use Districts
Other zoning districts in San Carlos that allow residential uses are the seven (7) Mixed-Use zoning districts, which allows residential uses either vertically or horizontally with a nonresidential, ground floor use, typically a commercial use. Mixed-use zoning districts primarily occur along El Camino Real and the downtown and surrounding environs.

Mixed-use development combines two or more types of land use into a building or set of buildings that are physically and functionally integrated and mutually supporting. This can be a combination of residential, commercial, office, institutional, or other land uses. Mixed-use development accommodating 50 or more units per acre occurs along the eastern portion of El Camino Real corridor east of San Carlos Avenue, with the highest allowed density occurring in the Mixed Use – San Carlos Avenue zoning district at 59 units to the acre (Figure 3). Mixed-use districts account for less than one percent of the total land use in San Carlos.

Other Land Uses
Other land uses include light and heavy industrial, general commercial, landmark commercial, neighborhood retail, airport, planned development, parks, and open space.

Commercial development covers six percent, or 226 gross acres of all land uses in the Planning Area. Office commercial uses containing business, professional, and medical services make up 117 gross acres or three percent. Industrial uses comprise 262 gross acres or seven percent of total land area. Industrial uses include large manufacturing businesses, biotechnical and

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Notice of Preparation: San Carlos General Plan Housing and Safety Element Update EIR December 17, 2021 5
biomedical firms, and light and heavy industrial uses. Industrial uses are predominately located east of US 101 and between US 101 and El Camino Real. The San Carlos Airport is located at the City’s eastern edge on land owned by San Mateo County.

Vacant Land Uses
Little vacant land exists within San Carlos; as of 2020, only approximately 30 gross acres (see Table 1) or three percent of the Planning Area is vacant. Vacant land is defined as having no building structures constructed on the land. Vacant land does not include parks nor open space, which is “vacant” or open by design. Vacant land can occur in each of the General Plan and Zoning designated areas.

PROJECT DESCRIPTION:

Housing Element Update
All cities and counties in California are required to meet their fair share of the State’s housing needs. The planning process for accomplishing this is typically implemented every eight years through an update of the Housing Element of each jurisdiction’s General Plan. Housing Elements are long-range policy documents mandated by the State and further required to be reviewed and certified by the State of California’s Housing and Community Development Department (HCD). The City of San Carlos’ existing Housing Element Update covers the period of 2015-2023 (5th housing cycle) and included a Regional Housing Needs Allocation assignment of 596 new housing units at different income levels to be constructed during the 2015 through 2023 planning period. As of the end of 2020, the City has constructed approximately 526 units of the current 596-unit RHNA assignment.

All San Mateo County jurisdictions are now undertaking planning for the 6th housing cycle and the RHNA assignments assigned to their jurisdiction for the 2023-2031 planning period. The Housing Element updates must be approved by HCD and adopted by January 31, 2023.

The main components of the Housing Element update are dictated by State law and typically must include:
• A detailed analysis of the City’s demographic, economic, and housing characteristics • A comprehensive analysis of the barriers to producing and preserving housing • A review of the City’s progress in implementing its adopted housing policies and programs
• An identification of goals, objectives, and policies, in addition to a full list of programs that will help the City carry out the plan’s vision
• A list of sites that could accommodate new housing, demonstrating the City’s ability to meet its target number of new homes established in the RHNA In addition, Housing Elements will have to address recent changes in state housing law enacted by SB 9 and SB 10 which take effect January 1, 2022.

SB 9 allows property owners to split a single-family lot into two lots, add a second home to their lot or split their lot into two and place duplexes on each. The last option would create four housing units on a property currently limited to a single-family house.

SB 10 would, notwithstanding any local restrictions on adopting zoning ordinances, authorize a local government to adopt an ordinance to zone any parcel for up to 10 units of residential density per parcel, at a height specified in the ordinance, if the parcel is located in a transit-rich area or an urban infill site, as those terms are defined.

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State Regional Housing Needs Allocation
California State law (Government Code Section 65584) recognizes that local governments play a vital role in developing affordable housing. In 1969, the state mandated that all California cities, towns, and counties must plan for the housing needs of residents, regardless of income. This state mandate is called the Housing Element and Regional Housing Needs Allocation, or RHNA. As part of RHNA, the State Department of Housing and Community Development (“HCD”) determines the total number of new homes the Bay Area needs to plan for, and their affordability levels in order to meet the housing needs of people at all income levels.

The Association of Bay Area Governments (ABAG), working with the Housing Methodology Committee (HMC), then distributes a share of the region's housing need to each city, town, and county in the region. Each local government must then update the Housing Element of its general plan to show the locations where housing can be built and the policies and strategies necessary to meet the community's housing needs.

ABAG conducts the RHNA process every eight years as required by state law and local jurisdictions must update their housing elements to reflect the current RHNA assignment on this eight-year cycle. The last completed cycle is from 2015 to 2023 (5th housing cycle). ABAG is undertaking the RHNA process for 2023 to 2031 (6th housing cycle).

The RHNA methodology is required to meet the five statutory objectives summarized below:

1. Increase housing supply and mix of housing types, with the goal of improving housing affordability and equity in all cities and counties within the region.

2. Promote infill development and socioeconomic equity; protect environmental and agricultural resources; encourage efficient development patterns; and achieve greenhouse gas reduction targets.

3. Improve intra-regional jobs-to-housing relationship, including the balance between lowwage jobs and affordable housing units for low-wage workers in each jurisdiction.

4. Balance disproportionate household income distributions (more high-income allocation to lower-income areas, and vice-versa)

5. Affirmatively further fair housing
RHNA must also be consistent with the growth pattern from the region's long-range plan for transportation, housing, the economy, and the environment, known as Plan Bay Area 2050.

San Carlos RHNA Assignment
The City of San Carlos has been assigned a RHNA goal of 2,735 new housing units for the 2023-2031 planning period. This is broken down into 739 very low-income units, 425 lowincome units, 438 moderate income units, and 1,133 above moderate income units. The RHNA assignment represents an increase of 22 percent over the number of existing housing units within the city limits. Because the Housing Element has to plan for or have policies in place to accommodate the RHNA assignment in any given planning period, jurisdictions typically plan for a slightly higher number of housing units than the actual RHNA assignment. This allows for some market variations between what the City is planning and what is developed. The City of San Carlos has determined it will include a buffer equaling 30 percent of the number of affordable housing units or an additional 481 units. Thus, for the purposes of the CEQA document the City is planning for a total of 3,216 units (2,735 RHNA + 481 buffer units).

The updated Housing Element must identify possible sites where future housing can be built, called opportunity sites, and identify the potential number of homes that can be built on these sites. San Carlos anticipates accommodating the new housing by increasing the allowed housing density (units/gross acre) in certain zoning designations and certain areas within the --------------

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Notice of Preparation: San Carlos General Plan Housing and Safety Element Update EIR December 17, 2021 7
designations. The areas which may have increased density are shown on Figure 6 – Potential Zoning Code Changes (note: the term ‘Zoning Code’ is synonymous with ‘Zoning Ordinance’).

The areas are located near transit and are primarily located along and west of El Camino Real, and along San Carlos Avenue near the downtown area. Figure 7 – San Carlos Tentative 6th Cycle Housing Sites, show parcels under consideration for increased residential density to meet the 6th cycle RHNA assignment.

Safety Element Update
The City will update the 2009 Community Safety and Services Element to meet current state requirements per Government Code Section 65302(g). The existing General Plan includes Public Services with the Community Safety Element to form a single Community Safety and Services Element. The City is proposing to rename the element the Environmental Safety and Public Services Element to reflect the focus on environmental hazards the element must address.

The updated Safety Element will provide goals, objectives, policies, and feasible implementation plans for protecting the community from any unreasonable risks associated with the impacts of geologic hazards, flooding and sea level rise, wildland fires, climate change hazards (extreme weather events, drought, extreme heat events), hazardous materials, airport operations, and general emergency and disaster preparedness.

General Plan (i.e., Land Use Element) and Zoning Code Amendments Areas of the City are anticipated to be rezoned to allow for fulfilment of the City’s RHNA by increasing the density in certain zoning designations. The possible Zoning Ordinance amendments are anticipated to include single-family residential (e.g., in response to SB-9), multifamily residential and mixed-use categories, which would provide for development of some lower-level commercial/retail, office, and potentially live/work uses. The Land Use Element (including the Land Use Map) is anticipated to be updated to ensure consistency between the General Plan and Zoning Ordinance as required by State law.

The possible zoning density increases include some areas within the following zones:

Mixed Use Neighborhood (MU-N), Mixed Use-North Boulevard (MU-NB), Mixed Use-South Boulevard (MU-SB), Mixed-Use San Carlos Avenue (MU-SC), Mixed-Use Downtown Core, MixedUse Downtown (MU-D) and Multifamily Medium Density (RM-59). Densities will range from 40 dwelling units per gross acre to 120 dwelling units per gross acre. Note, building heights are anticipated to be limited to four-stories for the MU-N and six-stories in all other zones. New residential buildings are anticipated to be lower than 6-stories as they approach single family residential designated areas due to the City’s ‘transitional standards’ currently in place.

In addition to the proposed density increases, the City may also revise required Development Standards for residential and mixed use zoning districts such as setbacks, FAR, parking, landscaping, public open space, and other development related requirements.

PROJECT OBJECTIVES:

The Focused General Plan Update: Housing, Land Use and Safety Element and accompanying Zoning Ordinance Amendments Project establishes the objectives listed below for the long-term growth and enhancement of the community.

1. Promote the preservation and improvement of the quality of existing housing and neighborhoods.

2. Encourage housing development located close to transit, Downtown and along El Camino Real with high quality, higher density, multi-family housing.

3. Assist in the development of new housing that is affordable at all income levels.

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Notice of Preparation: San Carlos General Plan Housing and Safety Element Update EIR December 17, 2021 8

4. Remove and/or mitigate potential governmental constraints to the provision of adequate, affordable housing.

5. Provide adequate housing for special needs populations.

6. Eliminate discrimination in the provision of housing.

7. Limit priority sites for new housing units to residentially-zoned properties along and to the west of the El Camino Real corridor in the Downtown area.

8. Reduce the potential loss of life, injury, and property damage due to seismic and geologic hazards.

9. Reduce hazards associated with flooding or inundation from inland flooding and Sea Level Rise

10. Protect lives and property from risks associated with fire-related emergencies. (wildfire)

11. Protect the community from the harmful effects of hazardous materials.

12. Plan for and protect the community from the effects of climate change such as severe weather including extreme heat events.

13. Minimize risks associated with operations at the San Carlos Airport.

14. Continue effective emergency response procedures to ensure public safety in the event of natural or man-made disasters.

PROGRAMMATIC EIR:

The City of San Carlos has determined that the proposed Project will require preparation of a Program EIR pursuant to the California Environmental Quality Act (CEQA). The Program EIR will evaluate the environmental impacts resulting from implementation of the project and will recommend mitigation measures to avoid or reduce significant impacts, where applicable. The Program EIR also is intended to help the City review future project proposals pursuant to section 15168 (Program EIR) of the CEQA Guidelines. The following environmental topics will be evaluated in the EIR:
 Aesthetics  Mineral Resources
 Agriculture and Forestry  Noise
 Air Quality  Population and Housing
 Biological Resources  Public Services
 Cultural Resources  Tribal Cultural Resources
 Energy  Transportation and Circulation
 Geology and Soils  Utilities and Service Systems
 Greenhouse Gas Emissions  Wildfire
 Hazards and Hazardous Materials  Cumulative Impacts
 Hydrology and Water Quality  Alternatives
 Land Use and Planning
OTHER PUBLIC AGENCIES WHOSE REVIEW OR APPROVAL IS REQUIRED:

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Notice of Preparation: San Carlos General Plan Housing and Safety Element Update EIR December 17, 2021 9
 California Department of Housing and Community Development (HCD) will approve the Housing Element update prior to its adoption.
 California Geological Survey of the Department of Conservation will review the Environmental Safety and Public Services Element Update prior to its adoption.  State Board of Forestry and Fire Protection will review the Environmental Safety and Public Services Element Update prior to its adoption.  AB 52/SB 18 Tribal Consultation
Attachments:

Figure 1: Regional Location
Figure 2: San Carlos Planning Area Map
Figure 3: Existing Land Uses
Figure 4: General Plan Land Use Map
Figure 5: Zoning Map
Figure 6: Potential Zoning Code Changes
Figure 7: San Carlos Tentative 6th Cycle Housing Sites

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City of San Carlos Boundary
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Figure 1
San Carlos
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Regional Location
Legend
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B E L M O N T

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Eaton Park
Big Canyon Park
Highlands Park
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San Carlos
Airport
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Pulgas Creek
Belmont Creek
Cordilleras Creek
Smith Slough
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ton Ave
Edgewood Rd
Brittan Ave
Club Dr
Holly St
Brewster Ave
Industrial Rd
Crestview Dr
Hallmark Dr
San Carlos Ave
Whipple Ave
Topaz St
Twin Dolphin Dr
Harbor Blvd
Beverly Dr
Alemeda de Las Pulgas
Alameda de Las Pulgas
Brittan Ave
Alameda de Las Pulgas
Ralston Ave
Industrial Rd
El Camino Real
San Carlos Ave
Elm St
Cedar St
Laurel St
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January 23, 2023 Packet Pg. 641
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Multi-Fami ly Residential Mixed-Use
Retail
Office/Commercial
Industrial
Warehousing
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Schools/Education Facilities
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Existing General Plan Designations
Single-Family, Low Density (3 DUs/Ac)
Single-Family (6 DUs/Ac)
Multi-Family, Low Density (10-20 DUs/Ac)
Multi-Family, Medium Density (21-59 DUs/Ac)
Mixed Use, Low Density (10-20 DUs/Ac)
Mixed Use, Medium Density (21-50 DUs/Ac)
Mixed Use, Medium High Density (21-59 DUs/Ac)
Neighborhood Retail/Mixed Use (21-50 DUs/Ac)
Neighborhood Retail
Planned Industrial
General Commercial - Industrial
Public
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Open Space
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Topaz St
Twin Dolphin Dr
Harbor Blvd
Beverly Dr
Alemeda de Las Pulgas
Alameda de Las Pulgas
Brittan Ave
Alameda de Las Pulgas
Ralston Ave
Industrial Rd
El Camino Real
San Carlos Ave
Elm St
Cedar St
Laurel St
Melendy Dr
Jeter St
Cordilleras Ave
Arroyo Ave
6th Ave
Hastings Dr
Hull Dr
Hewitt Dr
Cherry St
Bayport Ave
Taylor Way
Pulgas Creek
Belmont Creek
Cordilleras Creek
Smith Slough
Steinberger Slough
0 ¼ ½ 1 ° Mile
August 2020
Sources: United States Census Bureau, 2019. City of San Carlos, County of San Mateo, Urban Footprint, 2020.

RS-3: Single-Family, Low Density
RS-6: Single-Family
RM-20: Multi-Family, Low Density
RM-59: Multi-Family, Medium Density
MU-NB: Mixed Use North Boulevard
MU-SB: Mixed Use South Boulevard
MU-D: Mixed Use Downtown
MU-DC: Mixed Use Downtown Core
MU-N: Neighborhood Mixed Use
MU-SA: Mixed Use Station Area
MU-SC: Mixed Use San Carlos Ave
IL: Light Industrial
IH: Heavy Industrial
IA: Industrial Arts
IP: Industrial Professional
GCI: General Commercial/Industrial
LC: Landmark Commercial
NR: Neighborhood Retail
PD: Planned Development
A: Airport
P: Public
PK: Park
OS: Open Space
Neighborhood Hub Overlay
G Gateway Overlay District
Figure 5
San Carlos
General Plan
Zoning
Existing Zoning Designations

SAN CARLOS

HOUSING
2040
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January 23, 2023 Packet Pg. 644
Figure 6
Potential Zoning Code Changes
Zoning
MU-NB
- MU-N-40
111111
MU-N-50
111111
MU-N-120
- MU-SB-120
MU-DC
- MU-D-100
- MU-D-120
MU-SC
MU-SB-100
RM-59
- RM-100
December 2021
Sources: United States Census Bureau, 2019. City ofSanCa~os, County of San Mateo, Urban footprint. 2020.

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8.b
January 23, 2023&nbsp;Packet Pg.&nbsp;645&nbsp;
Service Layer Credits: Sources: Esri, USGS,
NOAA
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82 ST
82 ST
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P a l o m a r P a r k

S A N M A T E O C O U N T Y
D e v o n s h i r e
B a i r
I s l a n d
P u l g a s R i d g e

B E L M O N T

R E D W O O D C I T Y
San Carlos
Airport Ralston Ave
Edgewood Rd
Brittan Ave
Club Dr
Holly St
Brewster Ave
Industrial Rd
Crestview Dr
Hallmark Dr
San Carlos Ave
Whipple Ave
Topaz St
Twin Dolphin Dr
Harbor Blvd
Beverly Dr
Alemeda de Las Pulgas
Alameda de Las Pulgas
Brittan Ave
Alameda de Las Pulgas
Ralston Ave
Industrial Rd
El Camino Real
San Carlos Ave
Elm St
Cedar St
Laurel St
Melendy Dr
Jeter St
Cordilleras Ave
Arroyo Ave
6th Ave
Hastings Dr
Hull Dr
Hewitt Dr
Cherry St
Bayport Ave
Taylor Way
Pulgas Creek
Belmont Creek
Cordilleras Creek
Smith Slough
Steinberger Slough
0 ¼ ½ 1 ° Mile
December 2021
Sources: United States Census Bureau, 2019. City of San Carlos, County of San Mateo, Urban Footprint, 2020.

Figure 7
San Carlos Tentative
6th Cycle Housing Sites
Tentative 6th Cycle Housing Sites
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8.b
January 23, 2023 Packet Pg. 646
San Carlos’ Focused General Plan Update Project: Land Use, Housing, Safety Element Updates and Accompanying Zoning Ordinance Amendments
Summary of Comments on the Notice of Preparation

PUBLIC OUTREACH
Public outreach for the project included public noticing, issuance of a Notice of Preparation (NOP) for an Environmental Impact Report (EIR), and a public scoping meeting for the EIR, as summarized below. Comments received on the NOP and during the scoping meeting will be considered during the preparation of the draft EIR.

Notice of Preparation
A Notice of Preparation (NOP) is a document stating that an Environmental Impact Report (EIR) will be prepared for a particular project. The NOP is the first step in the EIR process and needs to be prepared immediately after deciding that an EIR is required for a project. The purpose of a NOP is to solicit comments on the scope and content of an EIR.

As required by CEQA Guidelines Section 15082, the City prepared a NOP and circulated it to agencies and made it available to the public on December 17, 2021 (SCH# 2021120442). The NOP contained a summary of the project description, a map depicting the project location, and salient environmental issues; and identified the purpose of the NOP process (to solicit input on the content of the EIR), how the NOP could be reviewed, and how to submit comments. Circulation of the NOP consisted of its filing with the San Mateo County Clerk’s office, submittal to the State Clearinghouse for State Agency Distribution, and emailing the NOP to surrounding agencies, special districts serving the City of San Carlos, and all persons who had signed up to follow and/or attended previous community workshops regarding the project. In addition, an announcement of the availability of the NOP was published in the local newspaper (Examiner–Enquirer-Bulletin) on December 22, 2021.

The NOP was provided to the Governor’s Office of Planning and Research State Clearinghouse for distribution to various State agencies for review. Copies of the NOP were made available electronically via a web link on the City’s website. The City provided a concurrent 45-day public review period for the NOP from December 17, 2021 to January 31, 2022.

Written comments in response to the NOP were received from two (2) agencies, including the California Department of Transportation (Caltrans) and Native American Heritage Commission (NAHC), and seven (7) individuals during the NOP comment period.

On January 12, 2022, the City held a NOP scoping meeting via Zoom in front of the Planning Commission that gave the public a chance to provide input on potential environmental effects that should be evaluated as part of the EIR. No formal decision by the Planning Commission was made at the meeting.

The following agencies and individuals submitted comments on the NOP within the designated public comment period.

Agencies
 Native American Heritage Commission (NAHC), Katy Sanchez, Associate Environmental Planner
 California Department of Transportation (Caltrans), Mark Leong, District Branch Chief

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January 23, 2023 Packet Pg. 647
Individuals
 Dimitri Vandellos
 David Crabbe
 Sandra Wallace
 Gina Vandellos
 Gladwyn d’Souza
 Ralph Althouse
 Sean Gibson
Summary of Comments Received
The following bullet points summarize topics raised by the commenters. Comments that do not pertain to the scope (i.e., what should be evaluated or addressed within the EIR) of the EIR are not included.

Several comment letters raised questions about the location of housing proposed in the Housing Element. Since these comments are focused on the proposed project and not the content of the EIR, they have not been included in this summary.

General Topics
 Description of relationship between General Plan elements in the Draft EIR;  Traffic and traffic patterns, water supply availability, and school district impacts as part of the EIR scope and study;
 Specific proposal the Draft EIR will evaluate;
 [Building] height and setbacks on East San Carlos Avenue considered in the Draft EIR;  Alternative designs considering duck-outs and bus only lanes on El Camino Real considered in the Draft EIR; and
 Housing considered in the Draft EIR that could be approved without future site-specific EIR (i.e., “by right”).

Cultural Resources/Tribal Cultural Resources
 Requirements for compliance with AB 52 and SB 18, and mitigation of cultural resources and tribal cultural resources; and
 Recommendations for conducting cultural resources assessments.

Land Use
 Analyze the project in light of the East Side Innovation District Vision Plan; and  Analyze proposed zoning changes and impacts to single-family housing.

Hydrology/Hazards
 Analyze impacts of Sea Level Rise; and
 Analyze effects of rising groundwater from SLR and transport of hazardous chemicals in the groundwater.

Transportation/Traffic
 VMT analysis requirement if project does not meet City’s adopted VMT screening criteria;

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January 23, 2023 Packet Pg. 648
 Requirement for VMT mitigation, if any, to support use of transit and active transportation modes;
 Requirement for Draft EIR to include transportation impact analyses with applicable mitigation for any additional or re-zoning of improvements adjacent to Caltrans’ Right-of-Way (ROW);  Requirement for a robust Transportation Demand Management (TDM) Program to reduce VMT and greenhouse gas emissions from future development in this area;  Requirement for draft EIR to identify in text and graphics existing and proposed improvements for the pedestrian, bicycle, and transit networks;
 City is responsible for all project mitigation, including any needed improvements to the State Transportation Network (STN);
 Ability of Caltrain to accommodate increase in ridership; and  Analyze walkability and bicycle safety in the City.

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January 23, 2023 Packet Pg. 649

CHAIRPERSON
Laura Miranda
Luiser'io

VICE C HAIRPERSON
Reginald Pagaling
Chumash

PARLIAMENTARIAN
Russell Attebery
Karuk

COMMISSIONER
Wllllam Mungary
Poiute/White Mountain
Apache

COMMISSIONER
Isaac. Bojorquez
O hlone-C ostonoon

COMMISSIONER
Sara Dutschke
Miwok

COMMISSIONER
Buffy McQuillen
Yokoyo Pomo, Yuki,
Nomloki

COMMISSIONER
Wayne Nelson
Luiseno

COMMISSIONER
Stanley Rodriguez
Kumeyooy

EXECUTIVE SECRETARY
ChrisHna Snider
Pomo

NAHC HEADQUARTERS
1550 Harb0< Boulevard
Suite 100 ·
West Socramento,
California 95691
(916) 373-3710
[email protected]
NAHC.co.gov
STATE OF CALIFORNIA Ggyjn Newsom Governor

NATIVE AMERICAN HERITAGE COMMISSION
December 20, 2021
Lisa Porras
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Re: 2021120442, Environmental Impact Report for the Focused General Plan Update: Housing, Land Use, & Safety Elements and Accompanying Zoning Ordinance Amendments Project, San Mateo County
Dear Ms. Porras:

The Native American ,Heritage Commission (NAHC) has received the Notice of Preparation (NOP), Draft Environme:nta l Impact Report (DEIR) or Early Consultation for the project referenc~d above. The California Environmental Quality Act (CEQA) (Pub. Resources Code §21000 et.seq.), specifically Pyblic Resources Code §21084.1, sta tes that a project that may cause a substantial adver~e change in the significance of a historical resource, is a project that may hove a significant effect orifhe environment. (Pub. Resources Code§ 21084.1; Cal. Code Regs., tit.1 4, § 15064.5 (bl (CEQA Guidelines§ 15064.5 (b)). If there is substantial evidence, in light of the whole. record before a lead agency, that a project may have a significant effect on the. environmer,t, an Environmental Impact Report (EIR) shall be prepared. (Pub. Resources Code §21080 (d); Cal. Code Regs., tit. 14, § 5064 subd.(a)(l) (CEQA Guidelines§ 15064 (a)(l )).

In order to determine whether a project will cause a substantial adverse change in the significance of a historical resource, a lead agency will need to determine whether there are historical resources within the area of potential effect (APE).

CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes o f 2014) (AB 52) amended CEQA to create a separate category of cultural resources, "tribal cultural resou.rces" (Pub. Resources Code § 2107 4) and provides that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have ci significant effect on the environment. (Pub. Resources Code § 21084.2) . Public agencies shall, when feasible, avoid damaging effects' to any tribal cultural resource. (Pub. Resources Code § 21084.3 (a)). AB 52 applies to any project for which a notice of preparation, a notice of negative declaration, or a mitigated negative declaration Is filed on or after July 1, 2015. If your project involves the adoption of or amendment to a general plan or a specific plan, or the designation or proposed designation of open space, on or after March 1, 2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18).

Both SB 18 and AB 52 have tribal consultation requirements. If your project is also subject to the federal National Environmental Policy Act (42 U.S.C. § 4321 et seq.) (NEPA), the tribal consultation requirements of Section l 06 of the National Historic Preservation Act of 1966 ( 154 U.S.C. 300101, 36 C.F.R. §800 et seq.) may also apply.

The NAHC recommends consultation with California Native American tribes that are traditionally and culturally affiliated with the geographic area of your proposed project as early as possible in order to avoid inadvertent discoveries of Native American human remains and best protect tribal cultural resources. Below is a brief summary of portions of AB 52 and SB 18 as well as the NAHC's recommendations for conducting cultural resources assessments.

Consult your legal counsel about c ompliance with AB 52 and SB 18 as well as compliance with any other aP,plicable laws.